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WRIGHT, FINLAY & ZAK, LLP
Dana Jonathon Nitz, Esq.
Edgar C. Smith, Esq.
Nevada Bar No. 5506
Yanxiong Li, Esq.
(702) 475-7964; Fax: (702) 946-1345
yli@wrightlegal.net
Attorneys for Plaintiffs/Counter-Defendants, Fred Sadri, both in his individual capacity and as Trustee for The Star Living Trust, dated April 14, 1997; Ray Koroghli and Sathsowi T. Koroghli, in their individual capacities as well as Managing Trustees for Koroghli Management Trust
UNITED STATES BANKRUPTCY COURT
DISTRICT OF NEVADA
Case No.: N-16-50644-btb
CHAPTER 15
Adv. No. 17-05016-btb
PLAINTIFFS’ RESPONSES TO DEFENDANT JED MARGOLIN’S FIRST SET OF INTERROGATORIES
In re: JAZI GHOLAMREZA ZANDIAN,
Debtor.
FRED SADRI, AS TRUSTEE FOR THE STAR LIVING TRUST, DATED APRIL 14, 1997; RAY KOROGHLI AND SATHSOWI T. KOROGHLI, ASMANAGING TRUSTEES FOR KOROGHLI MANAGEMENT TRUST,
Plaintiffs,
vs.
JED MARGOLIN; JAZI GHOLAMREZA ZANDIAN; and all other parties claiming an interest in real properties described in this action,
Defendants.
PATRICK CANET,
Counterclaimant,
vs.
FRED SADRI INDIVIDUALLY AND IN HIS
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CAPACITY AS TRUSTEE OF THE STAR LIVING TRUSTAND RAY KOROGHLI INDIVIDUALLY, AND RAY KOROGHLI AND SATHSOWI T. KOROGHLI AS
MANAGING TRUSTEES OF THE KOROGHLI MANAGEMENT TRUST,
Counter-Defendants.
PATRICK CANET,
Cross-Claimant,
v.
JED MARGOLIN,
Cross-Defendant.
COME NOW, Plaintiffs/Counter-Defendants, Fred Sadri, as Trustee for The Star Living Trust, dated April 14, 1997 (“SLT”) and Ray Koroghli and Sathsowi T. Koroghli, as Managing Trustees for Koroghli Management Trust (“KMT”) (collectively with SLT, hereinafter as “Plaintiffs”), by and through their counsel, Dana Jonathon Nitz, Esq., and Yanxiong Li, Esq., of the law firm of Wright, Finlay & Zak, LLP, and hereby submit their responses to Defendant Jed Margolin’s (“Margolin”) First Set of Interrogatories.
PRELIMINARY STATEMENT AND GENERAL OBJECTIONS
Plaintiffs’ responses herein to Margolin’s First Set of Interrogatories (the “Responses”) are subject to the following general objections (the “General Objections”). The General Objections may be specifically referred to in the Responses for the purpose of clarity. The failure to specifically incorporate a General Objection, however, should not be construed as a waiver of the General Objections.
1. Nothing herein shall be construed as an admission or waiver by Plaintiffs of: (a) their rights respecting admissibility, competency, relevance, privilege, materiality, and authenticity of any information provided in the Responses, any documents identified therein, or the subject matter thereof; (b) their objection due to vagueness, ambiguity, or undue burden; and (c) their rights to object to the use of any information provided in the Responses, any document
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identified therein, or the subject matter contained in the Responses during a subsequent proceeding, including the trial of this or any other action.
2. The Responses are made solely for the purposes of, and in relation to, this litigation.
3. Plaintiffs object to the Interrogatories to the extent they seek documents and information protected by the attorney-client privilege and/or seeks the work product of counsel.
4. Plaintiffs have not completed: (a) their investigation of facts, witnesses, or documents relating to this case, (b) discovery in this action, (c) their analysis of available data, and (d) their preparations for trial. Thus, although a good faith effort has been made to supply pertinent information where the same has been requested, it is not possible in some instances for unqualified Responses to be made to the Discovery Requests. Further, the Responses are necessarily made without prejudice to Plaintiffs’ right to produce evidence of subsequently discovered fact, witnesses, or documents, as well as any new theories or contentions that Plaintiffs may adopt. The Responses are further given without prejudice to Plaintiffs’ right to provide information concerning facts, witnesses, or documents omitted by the Responses as a
result of oversight, inadvertence, good faith error, or mistake. Plaintiffs have responded to the Interrogatories based on information that is presently available to them and to the best of their knowledge to date. The Responses may include hearsay and other forms of evidence that may be neither reliable nor admissible.
Without waiving their General Objections, Plaintiffs respond to the Interrogatories as follows:
INTERROGATORIES
INTERROGATORY NO. 1:
Identify and Describe in Detail all facts and non-privileged Documents, Writings, and Communications between the PLAINTIFFS, or any of them, Relating To MARGOLIN, any court judgment MARGOLIN has against ZANDIAN, any patent owned by MARGOLIN, and any lawsuit between MARGOLIN and ZANDIAN, from December 2007 to present.
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RESPONSE TO INTERROGATORY NO. 1:
In addition to the General Objections, Plaintiffs further object to this Interrogatory on the grounds that it is compound with discrete subparts (4), overly broad and vague as to scope, and seeks information that is neither relevant nor proportional to the needs of this case. This Interrogatory is also unduly burdensome as it seeks information outside of possession and control of Plaintiffs and that is more than a decade prior to Plaintiffs’ filing of this Adversary Proceeding.
INTERROGATORY NO. 2:
Identify and Describe in Detail all facts and non-privileged Documents, Writings, and Communications between SADRI and RAY KOROGHLI Relating To MARGOLIN, any court judgment MARGOLIN has against ZANDIAN, any patent owned by MARGOLIN, and any lawsuit between MARGOLIN and ZANDIAN, from December 2007 to present.
RESPONSE TO INTERROGATORY NO. 2:
In addition to the General Objections, Plaintiffs further object to this Interrogatory on the grounds that it is compound with discrete subparts (4), overly broad and vague as to scope, and seeks information that is neither relevant nor proportional to the needs of this case. This Interrogatory is also unduly burdensome as it seeks information outside of possession and control of Plaintiffs and that is more than a decade prior to Plaintiffs’ filing of this Adversary Proceeding. Furthermore, Plaintiffs object to the extent this Interrogatory seeks confidential and private information regarding individuals who are not named Respondents.
INTERROGATORY NO. 3:
Identify and Describe in Detail all facts and non-privileged Documents, Writings, and Communications between SADRI and SATHSOWI T. KOROGHLI Relating To MARGOLIN, any court judgment MARGOLIN has against ZANDIAN, any patent owned by MARGOLIN, and any lawsuit between MARGOLIN and ZANDIAN, from December 2007 to present.
RESPONSE TO INTERROGATORY NO. 3:
In addition to the General Objections, Plaintiffs further object to this Interrogatory on the grounds that it is compound with discrete subparts (4), overly broad and vague as to scope, and
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seeks information that is neither relevant nor proportional to the needs of this case. This Interrogatory is also unduly burdensome as it seeks information outside of possession and control of Plaintiffs and that is more than a decade prior to Plaintiffs’ filing of this Adversary Proceeding. Furthermore, Plaintiffs object to the extent this Interrogatory seeks confidential and private information regarding individuals who is not a named Respondents or who is not a party to this action, the disclosure of which would violate those individuals’ or entities’ constitutionally protected right to privacy.
INTERROGATORY NO. 4:
Identify and Describe in Detail all facts and non-privileged Documents, Writings, and Communications between SADRI and KMT Relating To MARGOLIN, any court judgment MARGOLIN has against ZANDIAN, any patent owned by MARGOLIN, and any lawsuit between MARGOLIN and ZANDIAN, from December 2007 to present.
RESPONSE TO INTERROGATORY NO. 4:
In addition to the General Objections, Plaintiffs further object to this Interrogatory on the grounds that it is compound with discrete subparts (4), overly broad and vague as to scope, and seeks information that is neither relevant nor proportional to the needs of this case. This Interrogatory is also unduly burdensome as it seeks information outside of possession and control of Plaintiffs and that is more than a decade prior to Plaintiffs’ filing of this Adversary Proceeding. Furthermore, Plaintiffs object to the extent this Interrogatory seeks confidential and private information regarding individuals who is not a named Respondent.
INTERROGATORY NO. 5:
Identify and Describe in Detail all facts and non-privileged Documents, Writings, and Communications between RAY KOROGHLI and SATHSOWI T. KOROGHLI Relating To MARGOLIN, and court judgment MARGOLIN has against ZANDIAN, any patent owned by MARGOLIN, and any lawsuit between MARGOLIN and ZANDIAN, from December 2007 to present.
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RESPONSE TO INTERROGATORY NO. 5:
In addition to the General Objections, Plaintiffs further object to this Interrogatory on the grounds that it is compound with discrete subparts (4), overly broad and vague as to scope, and seeks information that is neither relevant nor proportional to the needs of this case. This Interrogatory is also unduly burdensome as it seeks information outside of possession and control of Plaintiffs and that is more than a decade prior to Plaintiffs’ filing of this Adversary Proceeding. Furthermore, Plaintiffs object to the extent this Interrogatory seeks confidential and private information regarding individuals who is not a named Respondents or who is not a party to this action, the disclosure of which would violate those individuals’ or entities’ constitutionally protected right to privacy.
INTERROGATORY NO. 6:
Identify and Describe in Detail all facts and non-privileged Documents, Writings, and Communications between RAY KOROGHLI and KMT Relating ToMARGOLIN, any court judgment MARGOLIN has against ZANDIAN, any patent owned by MARGOLIN, and any lawsuit between MARGOLIN and ZANDIAN, from December 2007 to present.
RESPONSE TO INTERROGATORY NO. 6:
In addition to the General Objections, Plaintiffs further object to this Interrogatory on the grounds that it is compound with discrete subparts (4), overly broad and vague as to scope, and seeks information that is neither relevant nor proportional to the needs of this case. This Interrogatory is also unduly burdensome as it seeks information outside of possession and control of Plaintiffs and that is more than a decade prior to Plaintiffs’ filing of this Adversary Proceeding. Furthermore, Plaintiffs object to the extent this Interrogatory seeks confidential and private information regarding individuals who is not a named Respondent.
INTERROGATORY NO. 7:
Identify and Describe in Detail all facts and non-privileged Documents, Writings, and Communications between SATHSOWI T. KOROGHLI and KMT Relating To MARGOLIN, any court judgment MARGOLIN has against ZANDIAN, any patent owned by MARGOLIN, and any lawsuit between MARGOLIN and ZANDIAN, from December 2007 to present.
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RESPONSE TO INTERROGATORY NO. 7:
In addition to the General Objections, Plaintiffs further object to this Interrogatory on the grounds that it is compound with discrete subparts (4) and exceeds the limit under Fed. R. Civ. P. 33(a)(1) for number of Interrogatories that may be propounded without leave by three (3) Interrogatories. This Interrogatory is also overly broad and vague as to scope, and seeks information that is neither relevant nor proportional to the needs of this case. This Interrogatory is also unduly burdensome as it seeks information outside of possession and control of Plaintiffs and that is more than a decade prior to Plaintiffs’ filing of this Adversary Proceeding. Furthermore, Plaintiffs object to the extent this Interrogatory seeks confidential and private information regarding individuals or entities who are not a party to this action, the disclosure of which would violate those individuals’ or entities’ constitutionally protected right to privacy.
INTERROGATORY NO. 8:
Identify and Describe in Detail all facts and non-privileged Documents, Writings, and Communications between any of the PLAINTIFFS Relating To any purchase or potential purchase of any court judgment MARGOLIN has against ZANDIAN
RESPONSE TO INTERROGATORY NO. 8:
In addition to the General Objections, Plaintiffs further object to this Interrogatory on the grounds that it exceeds the limit under Fed. R. Civ. P. 33(a)(1) for number of Interrogatories that may be propounded without leave. This Interrogatory is also vague and ambiguous as to time and scope, overly broad and unduly burdensome. Plaintiffs further object to this Interrogatory to the extent it seeks information that is neither relevant nor proportional to the needs of this case.
INTERROGATORY NO. 9:
Identify and Describe in Detail all facts and non-privileged Documents, Writings, and Communications that Relate to ZANDIAN receiving any payment of any money or other consideration from “Pico Holdings.”
RESPONSE TO INTERROGATORY NO. 9:
In addition to the General Objections, Plaintiffs further object to this Interrogatory on the grounds that it exceeds the limit under Fed. R. Civ. P. 33(a)(1) for number of Interrogatories that
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may be propounded without leave. This Interrogatory is also vague and ambiguous as to time and scope, overly broad and unduly burdensome. Plaintiffs further object to this Interrogatory to the extent it seeks information that is neither relevant nor proportional to the needs of this case.
INTERROGATORY NO. 10:
Identify and Describe in Detail all facts and non-privileged Documents, Writings, and Communications that Relate to any payment of any money or other consideration from any PLAINTIFF to ZANDIAN.
RESPONSE TO INTERROGATORY NO. 10:
In addition to the General Objections, Plaintiffs further object to this Interrogatory on the grounds that it exceeds the limit under Fed. R. Civ. P. 33(a)(1) for number of Interrogatories that may be propounded without leave. This Interrogatory is also vague and ambiguous as to time and scope, overly broad and unduly burdensome. Plaintiffs further object to this Interrogatory to the extent it seeks information that is neither relevant nor proportional to the needs of this case.
INTERROGATORY NO. 11:
Identify and Describe in Detail all facts and non-privileged Documents, Writings, and Communications that support Your FIRST CAUSE OF ACTION contained in Your COMPLAINT.
RESPONSE TO INTERROGATORY NO. 11:
In addition to the General Objections, Plaintiffs further object to this Interrogatory on the grounds that it exceeds the limit under Fed. R. Civ. P. 33(a)(1) for number of Interrogatories that may be propounded without leave.
Without waiving any objections, Plaintiffs respond: Margolin acquired no more than what Zandian held at the time of the execution sales, which was one-third (1/3) undivided interest in the parcels of raw land that the subject of this Adversary Proceeding, and therefore Margolin may claim, at most, a tenancy-in-common interest with the Plaintiffs as to the parcels he executed upon and sold to himself. Plaintiffs is not now, nor ever has been, a party to the underlying action by which Margolin obtained his Default Judgment against Zandian, which provides the authority underlying his execution sales against Zandian’s interest. Plaintiffs has
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never transferred any interest in the subject parcels to Zandian. Plaintiffs are not joint tenants with the Zandian.
In addition, Margolin failed to record an affidavit required for a proper judgment abstract under NRS 17.150(4) and failed to otherwise include information required under that statute as part of his Default Judgment. Thus, Margolin never had a valid judgment lien against any of the affected parcels before the execution sales.
The proof of these facts is a matter of public record and not subject to reasonable dispute. See also documents bates-stamped WFZ1 to WFZ2598 served with Plaintiffs’ Initial Disclosures and supplements thereto. Investigation is continuing and this Response will be supplemented if and when appropriate.
INTERROGATORY NO. 12:
Identify and Describe in Detail all facts and non-privileged Documents, Writings, and Communications that support Your SECOND CAUSE OF ACTION contained in Your COMPLAINT.
RESPONSE TO INTERROGATORY NO. 12:
In addition to the General Objections, Plaintiffs further object to this Interrogatory on the grounds that it exceeds the limit under Fed. R. Civ. P. 33(a)(1) for number of Interrogatories that may be propounded without leave.
Without waiving any objections, Plaintiffs respond: see Response to Interrogatory No. 11 above. Investigation is continuing and this Response will be supplemented if and when appropriate.
INTERROGATORY NO. 13:
Identify and Describe in Detail all facts and non-privileged Documents, Writings, and Communications that support Your THIRD CAUSE OF ACTION contained in Your COMPLAINT.
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RESPONSE TO INTERROGATORY NO. 13:
In addition to the General Objections, Plaintiffs further object to this Interrogatory on the grounds that it exceeds the limit under Fed. R. Civ. P. 33(a)(1) for number of Interrogatories that may be propounded without leave.
INTERROGATORY NO. 14:
Identify and Describe in Detail all facts and non-privileged Documents, Writings, and Communications that support the PRAYER for relief contained in Your COMPLAINT.
RESPONSE TO INTERROGATORY NO. 14:
In addition to the General Objections, Plaintiffs further object to this Interrogatory on the grounds that it exceeds the limit under Fed. R. Civ. P. 33(a)(1) for number of Interrogatories that may be propounded without leave.
Without waiving any objections, Plaintiffs respond: see Responses to Interrogatories 1113 above. Investigation is continuing and this Response will be supplemented if and when appropriate.
INTERROGATORY NO. 15:
Identify and Describe in Detail all facts and non-privileged Documents, Writings, and Communications that support paragraph 23 of Your COMPLAINT.
RESPONSE TO INTERROGATORY NO. 15:
In addition to the General Objections, Plaintiffs further object to this Interrogatory on the grounds that it exceeds the limit under Fed. R. Civ. P. 33(a)(1) for number of Interrogatories that may be propounded without leave.
Without waiving any objections, Plaintiffs respond: see Response to Interrogatory No. 11 above. Investigation is continuing and this Response will be supplemented if and when appropriate.
INTERROGATORY NO. 16:
Identify and Describe in Detail all facts and non-privileged Documents, Writings, and Communications that support paragraph 24 of Your COMPLAINT.
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RESPONSE TO INTERROGATORY NO. 16:
In addition to the General Objections, Plaintiffs further object to this Interrogatory on the grounds that it exceeds the limit under Fed. R. Civ. P. 33(a)(1) for number of Interrogatories that may be propounded without leave.
Without waiving any objections, Plaintiffs respond: NRS 21.130(c) requires inter alia Notice of Sale to be served, posted and published as follows (1) personal service or service by registered mail of the Notice of Sale upon each judgment debtor; (2) posting of a similar notice describing the property for 20 days successively in 3 public places of the township or city where property is situated/sold; (3) publication of the Notice of Sale three times, once each week, for 3
successive weeks in a newspaper in the county; and (4) recording a copy of the Notice of Sale in the office of the county recorder. In response to Plaintiffs’ Requests for Production Nos. 5 and 6, Margolin failed to provide any evidence to show that the Notice of Sale was served, posted, published and recorded in accordance with requirements under subsection (c). Investigation is continuing and this Response will be supplemented if and when appropriate.
INTERROGATORY NO. 17:
Identify and Describe in Detail all facts and non-privileged Documents, Writings, and Communications that support paragraph 34 of Your COMPLAINT.
RESPONSE TO INTERROGATORY NO. 17:
In addition to the General Objections, Plaintiffs further object to this Interrogatory on the grounds that it exceeds the limit under Fed. R. Civ. P. 33(a)(1) for number of Interrogatories that may be propounded without leave.
Without waiving any objections, Plaintiffs respond: see Response to Interrogatories 11 and 16 above. Investigation is continuing and this Response will be supplemented if and when appropriate.
INTERROGATORY NO. 18:
Identify and Describe in Detail all facts and non-privileged Documents, Writings, and Communications that support paragraph 38 of Your COMPLAINT.
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RESPONSE TO INTERROGATORY NO. 18:
In addition to the General Objections, Plaintiffs further object to this Interrogatory on the grounds that it exceeds the limit under Fed. R. Civ. P. 33(a)(1) for number of Interrogatories that may be propounded without leave.
Without waiving any objections, Plaintiffs respond: see Response to Interrogatories 11 and 16 above. Further, Plaintiffs never received a copy of the Notice of Sale related to the purported Sheriff’s auction of the three parcels of land that is subject to this Adversary Proceeding. Investigation is continuing and this Response will be supplemented if and when appropriate.
INTERROGATORY NO. 19:
Identify and Describe in Detail all facts and non-privileged Documents, Writings, and Communications that support paragraph 39 of Your COMPLAINT.
RESPONSE TO INTERROGATORY NO. 19:
In addition to the General Objections, Plaintiffs further object to this Interrogatory on the grounds that it exceeds the limit under Fed. R. Civ. P. 33(a)(1) for number of Interrogatories that may be propounded without leave.
Without waiving any objections, Plaintiffs respond: see Response to Interrogatories 11 and 16 above. Investigation is continuing and this Response will be supplemented if and when appropriate.
INTERROGATORY NO. 20:
Identify and Describe in Detail all facts and non-privileged Documents, Writings, and Communications that support paragraph 40 of Your COMPLAINT.
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RESPONSE TO INTERROGATORY NO. 20:
In addition to the General Objections, Plaintiffs further object to this Interrogatory on the grounds that it exceeds the limit under Fed. R. Civ. P. 33(a)(1) for number of Interrogatories that may be propounded without leave.
Without waiving any objections, Plaintiffs respond: see Response to Interrogatory 11 above. Investigation is continuing and this Response will be supplemented if and when appropriate.
INTERROGATORY NO. 21:
Identify and Describe in Detail all facts and non-privileged Documents, Writings, and Communications that support paragraph 43 of Your COMPLAINT.
RESPONSE TO INTERROGATORY NO. 21:
In addition to the General Objections, Plaintiffs further object to this Interrogatory on the grounds that it exceeds the limit under Fed. R. Civ. P. 33(a)(1) for number of Interrogatories that may be propounded without leave.
Without waiving any objections, Plaintiffs respond: see Response to Interrogatories 11 and 16 above. Investigation is continuing and this Response will be supplemented if and when appropriate.
INTERROGATORY NO. 22:
Identify and Describe in Detail all facts and non-privileged Documents, Writings, and Communications that support paragraph 44 of Your COMPLAINT.
RESPONSE TO INTERROGATORY NO. 22:
In addition to the General Objections, Plaintiffs further object to this Interrogatory on the grounds that it exceeds the limit under Fed. R. Civ. P. 33(a)(1) for number of Interrogatories that may be propounded without leave.
Without waiving any objections, Plaintiffs respond: see Response to Interrogatories 11 and 16 above. Investigation is continuing and this Response will be supplemented if and when appropriate.
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INTERROGATORY NO. 23:
Identify and Describe in Detail all facts and non-privileged Documents, Writings, and Communications that support paragraph 45 of Your COMPLAINT.
RESPONSE TO INTERROGATORY NO. 23:
In addition to the General Objections, Plaintiffs further object to this Interrogatory on the grounds that it exceeds the limit under Fed. R. Civ. P. 33(a)(1) for number of Interrogatories that may be propounded without leave.
Without waiving any objections, Plaintiffs respond: see Response to Interrogatories 11 and 16 above. Investigation is continuing and this Response will be supplemented if and when appropriate.
INTERROGATORY NO. 24:
Identify and Describe in Detail all facts and non-privileged Documents, Writings, and Communications that support paragraph 46 of Your COMPLAINT.
RESPONSE TO INTERROGATORY NO. 24:
In addition to the General Objections, Plaintiffs further object to this Interrogatory on the grounds that it exceeds the limit under Fed. R. Civ. P. 33(a)(1) for number of Interrogatories that may be propounded without leave.
Without waiving any objections, Plaintiffs respond: see Response to Interrogatories 11 and 16 above. Investigation is continuing and this Response will be supplemented if and when appropriate.
INTERROGATORY NO. 25:
Identify and Describe in Detail all facts and non-privileged Documents, Writings, and Communications that support paragraph 47 of Your COMPLAINT.
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RESPONSE TO INTERROGATORY NO. 25:
In
addition to the General Objections, Plaintiffs further object to this
Interrogatory on the grounds that it exceeds the limit under Fed. R. Civ. P.
33(a)(1) for number of Interrogatories that may be
propounded without leave. Without waiving any objections, Plaintiffs respond:
see Response to Interrogatories 11 above. Further, between August and October
of 2013, Mr. Adam P. McMillen and Ms. Nancy Lindsley of the firm Watson Rounds, which represented Margolin as counsel, met and communicated with Ray Koroghli, Fred Sadri and Elias Abrishami
regarding Plaintiffs’ ownership interest in the
DATED this 22nd day of February, 2018.
WRIGHT, FINLAY & ZAK, LLP
/s/ Yanxiong Li, Esq.
Dana Jonathon Nitz, Esq.
Edgar C. Smith, Esq.
Nevada Bar No. 5506
Yanxiong Li, Esq.
Tel: (702) 475-7964
Fax: (702) 946-1345
Attorneys for Plaintiffs/Counter-Defendants, Fred Sadri, both in his individual capacity and as Trustee for The Star Living Trust, dated April 14, 1997; Ray
Koroghli and Sathsowi T. Koroghli, in their individual capacities as well as Managing Trustees for Koroghli Management Trust
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VERIFICATION
STATE
OF
)
)
)
ss.
I, Ray Koroghli, solely as Trustee of Koroghli Management Trust, being first duly sworn according to law, deposes and says:
I have read the foregoing PLAINTIFFS’ RESPONSES TO MARGOLIN’S FIRST SET OF INTERROGATORIES and know the contents thereof, and that, based on the available sources of information, the same are true to the best of my knowledge, information and belief.
Ray Koroghli, as Trustee of Koroghli Management Trust
SUBSCRIBED and SWORN to before me
this _____ day of _______________, 2018.
Notary Public in and for said
County and State
*************************************************************************
STATE
OF
) ss.
I, Fred Sadri, solely as Trustee of Star Living Trust dated April 14, 1997, being first duly sworn according to law, deposes and says:
I have read the foregoing PLAINTIFFS’ RESPONSES TO MARGOLIN’S FIRST SET OF INTERROGATORIES and know the contents thereof, and that, based on the available sources of information, the same are true to the best of my knowledge, information and belief.
Fred Sadri, as Trustee of Star Living Trust dated April 14, 1997
SUBSCRIBED and SWORN to before me
this _____ day of _______________, 2018.
Notary Public in and for said
County and State
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I am an employee of WRIGHT, FINLAY & ZAK, LLP, and that service of the foregoing PLAINTIFFS’ RESPONSES TO DEFENDANT JED MARGOLIN’S FIRST SET OF INTERROGATORIES was made on this 22nd day of February, 2018, through the CM/ECF Electronic Filing system, and/or by depositing a true and correct copy in the United States Mail, addressed as follows:
Adam McMillen, Esq..
BROWNSTEIN HYATT FARBER SCHRECK, LLP
Attorney for Jed Margolin
Jeffrey L. Hartman, Esq.
HARTMAN & HARTMAN
Attorney for Patrick Canet, Foreign Representative and Jazi Gholamreza Zandian
/s/ Kelli Wightman
An Employee of WRIGHT, FINLAY & ZAK, LLP
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