Rama Sou, et al. vs Michael Bash, et al.

Filing 89

ORDER Granting 88 Motion for Telephonic Appearance. The call in telephone number is [phone], access code: 3912597. The call must be made 5 minutes prior to the hearing time. The court will join the call and convene the proceedings. The call must be made on a land line. The use of a cell phone or speaker phone during the proceedings is prohibited. Signed by Magistrate Judge Cam Ferenbach on 9/15/16. (Copies have been distributed pursuant to the NEF - ADR)

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RICHARD H. LEE
CA Bar No. 223553
Admitted Pro Hac Vice
SALISIAN | LEE LLP
550 South Hope Street, Suite 750
Los Angeles, California 90071-2627
Telephone:
[phone]
Facsimile:
[phone]
Email: [e-mail]
MICHAEL B. LEE
NV Bar No. 10122
MICHAEL B. LEE, P.C.
2000 S. Eastern Avenue
Las Vegas, NV 89104
Telephone: [phone]
Email: [e-mail]
Attorneys for Defendants
Michael Bash, Jeremy Bash, Berkley Enterprises, Inc.,
Pepperdine Enterprises, Inc., Ninety-Five Fort Apache
Complex, LLC, and Royal View, LLC

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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RAMA SOU; TAI BUI; and SCOTT
ZIMMERMAN,

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Plaintiffs,
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vs.
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MICHAEL BASH; JEREMY BASH;
BERKLEY ENTERPRISES, INC.;
PEPPERDINE ENTERPRISES, INC.;
NINETY-FIVE FORT APACHE COMPLEX,
LLC; ROYAL VIEW, LLC; and DOES 1
through 20, inclusive,

Case No.: 2:15-cv-00698-APG-VCF
MOTION FOR TELEPHONIC
APPEARANCE OF SALISIAN | LEE LLP
ON BEHALF OF DEFENDANTS AT
HEARING ON PLAINTIFFS’ MOTION TO
COMPEL ON SEPTEMBER 16, 2016

Defendants.

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MOTION FOR TELEPHONIC APPEARANCE OF SALISIAN | LEE LLP ON BEHALF OF
DEFENDANTS

TO THE HONORABLE COURT, ALL PARTIES, AND THEIR COUNSEL OF

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RECORD:
COMES NOW defendants Michael Bash, Jeremy Bash, Berkley Enterprises, Inc.,

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Pepperdine Enterprises, Inc., Ninety-Five Fort Apache Complex, LLC, and Royal View, LLC

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(collectively, “Defendants”), by and through their counsel of record, Salisian Lee LLP, and local

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counsel of record, Michael B. Lee, P.C., and hereby submits the following Motion for Telephonic

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Appearance of Salisian Lee LLP on September 16, 2016, at the hearing on Plaintiffs’ motion to

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compel.
Salisian Lee LLP’s sole office is located in Los Angeles, California, and the lead counsel

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on this matter, Richard Lee of Salisian Lee LLP, is located in Los Angeles, California.

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Defendants’ local counsel, Michael Lee of Michael B. Lee, P.C., will be available to be present in

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person at the September 16 hearing. Richard Lee can be reached at [phone] and

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respectfully requests to be allowed to appear telephonically on behalf of Defendants at the subject

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September 16 hearing.

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Dated:

September 14, 2016

SALISIAN | LEE LLP

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By: ___/s/ Richard H. Lee_____________
Richard H. Lee
CA Bar No. 223553
Admitted Pro Hac Vice

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9-15-2016
The call in telephone number is
[phone], access code: 3912597. The
call must be made 5 minutes prior to the
hearing time. The court will join the call
and convene the proceedings. The call must
be made on a land line. The use of a cell
phone or speaker phone during the
proceedings is prohibited.

Michael B. Lee
NV Bar No. 10122
MICHAEL B. LEE, P.C.
Attorneys for Defendants
Michael Bash, Jeremy Bash, Berkley Enterprises,
Inc., Pepperdine Enterprises, Inc., Ninety-Five Fort
Apache Complex, LLC, and Royal View, LLC

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MOTION FOR TELEPHONIC APPEARANCE OF SALISIAN | LEE LLP ON BEHALF OF
DEFENDANTS

PROOF OF SERVICE
Case No. 2:15-cv-00698-APG-VCF

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STATE OF CALIFORNIA

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COUNTY OF LOS ANGELES

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I am employed in the County of Los Angeles, State of California. I am over the age of 18
and not a party to the within action. My business address is 550 South Hope Street, Suite 750,
Los Angeles, California 90071.

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ss.

On September 15, 2016, I caused the foregoing document(s) described as SALISIAN |
LEE LLP’S MOTION FOR TELEPHONIC APPEARANCE ON BEHALF OF
DEFENDANTS AT HEARING ON PLAINTIFFS’ MOTION TO COMPEL ON
SEPTEMBER 16, 2016 to be served on the interested parties in this action as follows:

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)
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)

See Attached Service List
X

VIA CM/ECF SYSTEM
Pursuant to L.R. 5-3 and 5-4, following ordinary business practices, I electronically filed
the foregoing document(s) with the Clerk of the Court by using the Court’s automated CM/ECF
system. I checked the CM/ECF docket for this case and determined that the person(s) indicated
above are registered as CM/ECF Users who have consented to electronic service through the
Notice of Electronic Filing transmission sent to the e-mail address(es) listed above.
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VIA U.S. MAIL
Following ordinary business practices, I placed the document for collection and mailing at
my business address listed above, in a sealed envelope, postage fully prepaid, addressed to the
person(s) at the address I am informed and believe is the current address for such person(s). I am
readily familiar with the business’s practice for collection and processing of correspondence for
mailing with the United States Postal Service. In the ordinary course of business, such
correspondence is deposited with the United States Postal Service on the day on which it is placed
for collection and mailing at the business.

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X

FEDERAL
I declare under penalty of perjury under the laws of the United States of America that the
above is true and correct. Executed on September 15, 2016, at Los Angeles, California.

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___/s/ Christina Cordero_______
Christina Cordero

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PROOF OF SERVICE

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SERVICE LIST
Case No. 2:15-cv-00698-APG-VCF
Edward Suh, Esq.
Law Offices of Michael K. Suh & Associates
3810 Wilshire Blvd., Suite 1212
Los Angeles, California 90010
Telephone:
[phone]
Facsimile:
[phone]
Email: [e-mail]

Attorneys for Plaintiffs
Rama Sou; Tai Bui; and Scott Zimmerman

Matthew Knepper
Knepper & Clark, LLC
10040 W. Cheyenne Ave., Suite #170-109
Las Vegas, NV 89052
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

Attorneys for Plaintiffs
Rama Sou; Tai Bui; and Scott Zimmerman

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PROOF OF SERVICE