Free Declaration in Support - District Court of California - California

Case 5:07-cv-04808-JF

Document 46

Filed 07/03/2008

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KURT OSENBAUGH (State Bar No. 106132) DEBORAH YOON JONES (State Bar No. 178127)
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SA Y AKA KARIT ANI (State Bar No. 240122)

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WESTON, BENSHOOF, ROCHEFORT, RUBALCA VA & MacCUISH LLP 333 South Hope Street, Sixteenth Floor Los Angeles, California 90071
Telephone: (213) 576-1000

Facsimile: (213) 576-1100
kosenbaughêwbcounsel.com djonesêwbcounsel.com

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skari taniêwbcounsel. com

Attorneys for Plaintiff and Counter-Defendant
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BP WEST COAST PRODUCTS LLC

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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA
BP WEST COAST PRODUCTS LLC, a Delaware Limited Liability Company,
Plaintiff,
v.

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Case No.: C07 04808 JF

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DECLARATION OF DEBORAH YOON JONES IN SUPPORT OF BP WEST COAST PRODUCTS LLC'S:
(1) MOTION FOR SUMMARY JUDGMENT, OR IN THE AL TERNA TIVE, PARTIAL SUMMARY JUDGMENT AS TO THE SECOND AMENDED COMPLAINT; AND
(2) MOTION FOR SUMMARY
JUDGMENT, OR IN THE AL TERN

STTN ENTERPRISES, INC., a California
Corporation; NAZIM F AQUIR Y AN, an individual; SA YED FAQUIRY AN, an individual; and MAGHUL FAQUIRY AN, an individual; and A V A

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GLOBAL ENTERPRISE, LLC, a California limite liability company,
Defendants.

A TIVE,

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PARTIAL SUMMARY JUDGMENT AS TO THE COUNTERCLAIM
(Filed concurrently with Notices and Motions; Memoranda of Points and Authorities; Declaration of Thomas Reeder, Brad Christensen, and Cecile McDonnell; Appendix of Non-Federal Authorities; and (Proposed)
Orders. )

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Date: August 8, 2008 (reserved) Time: 9:00 a.m.
Crtrm: 3

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Honorable Jeremy Fogel

Filing Date:

September 17,2007

AND RELATED CROSS-ACTION.
DECLARATION OF DEBORAH YOON JONES IN SUPPORT OF BP WEST COAST PRODUCTS LLC'S

MOTIONS FOR SUMARY JUDGMENT. OR IN TIE ALTERNATIVE, PARTIAL

1213068.1

SUMAR Y JUDGMENT AS TO THE COUNERCLAIM

Case 5:07-cv-04808-JF

Document 46

Filed 07/03/2008

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DECLARATION OF DEBORAH YO

ON JONES

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I, DEBORAH YOON JONES, declare and state as follows:
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I am an attorney duly licensed to practice law before all courts of the State of

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California and am a partner with the law firm of Weston, Benshoof, Rochefort, Rubalcava &

MacCuish LLP, attorneys of record herein for plaintiffs BP West Coast Products LLC ("BPWCP").

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I make this declaration in support of BPWCP's: (1) Motion for Summary Judgment, Or In the
Alternative, Partial Summary Judgment as to the Second Amended Complaint; and (2) Motion for

Summary Judgment, Or In the Alternative, Partial Summary Judgment as to the Counterclaim. 1
have personal knowledge of the facts set forth in this declaration and if called as a witness, could and
would testify competently to them.
2.

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Attached as Exhibit 1 are the true and correct copies of relevant excerpts and

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exhibits from the deposition transcript of Sayed Faquiryan, taken on April 23, 2008, and that are
cited in BPWCP's Motion. The relevant portions have been underlined for the Court's convenience.
3.

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Attached as Exhibit 2 are the true and correct copies of excerpts and exhibits

from the deposition transcript of Nazim Faquiryan, taken on April 24, 2008, and that are cited in
BPWCP's Motion. The relevant portions have been underlined for the Court's convenience.
4.

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Attached as Exhibit 3 is the true and correct copy of BPWCP's Requests for

Admissions, Set One, propounded to Maghul Faquiryan.
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Attached as Exhibit 4 is the true and correct copy of Maghul Faquiryan's

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Responses to BPWCP's Requests for Admissions, Set One.
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Attached as Exhibit 5 is the true and correct copy of Sayed Faquiryan's

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Responses to BPWCP's Interrogatories, Set One.
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Attached as Exhibit 6 is the true and correct copy of Nazim Faquiryan's

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Responses to BPWCP's Interrogatories, Set One.
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Attached as Exhibit 7 is the true and correct copy of STTN Enterprises, Inc.' s

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Responses to BPWCP's Interrogatories, Set One.

DECLARATION OF DEBORAH YOON JONES IN SUPPORT OF BP WEST COAST PRODUCTS LLC'S

MOTIONS FOR SUMARY JUDGMENT, OR IN TH ALTERNATIVE,

1213068.1

PARTIAL SUMARY JUGMENT AS TO TH SECOND AMNDED COMPLAI

Case 5:07-cv-04808-JF

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Filed 07/03/2008

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I declare under penalty of perjury under the laws of the State of California and the
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United States that the foregoing is true and correct.
Executed on July 3,2008, at Los Angeles, California.

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DECLARATION OF DEBORAH YOON JONES IN SUPPORT OF BP WEST COAST PRODUCTS LLC'S

MOTIONS FOR SUMARY JUDGMENT, OR IN THE ALTERNATIVE,

1213068.1

PARTIAL SUMARY JUGMENT AS TO TH SECOND AMNDED COMPLAIT