This action might not be possible to undo. Are you sure you want to continue?
Dr. Orly Taitz, ESQ 29839 S. Margarit4 ste 100 RSM CA 92688 Ph 949-683 -54tr F 949-766-0378
ORANGE COUNTY SUPERIOR COURT CENTRAL JUSTICE CENTER
Medical Dental Development LLC,
Case no. : 30-2010-00367 447
Hon Frederick P. Horn Dept C-31
Statement of Compliance
Pearson, Johnson, Iskander
Orange county Superior Court Rule 3.17
Trial Date March
This is to confirm that Dr. Orly Tutz, counsel for the Plaintiff and Mr. Ettinger, recently hired
counsel for Defendant David Johnson conducted a phone pretrial conference on 03.10.2011, pursuant to local rule 3.17. During the conference Mr. Ettinger did not disclose to Dr. Taitzthat there will be any witnesses aside from defendant David Johnson. Only a few days before trial
plaintiffs received a list of witnesses for trial, which was compiled by Mr. Ettinger a day earlier,
on 03.09.2011, which included a name of witness Mark Jerue, whom Mr. Ettinger did not disclose to Orly Taitz on 03.10.2011, a day later.
Plaintiffs oppose proposed witness Mark Jerue. Defense proposed witness intends to
testify regarding the current value of the property and efforts to re-let the property.
Plaintiffs object to this testimony on following grounds. A. Current rental value of the
property is not relevant to the case, as the lease agreement was signed 7 years ago and
the lease agreement does not provide for modification of the lease based on current lease
value. B. Mr. Mark Jerue was never a lease agent on this property and does not have any
direct knowledge of the efforts to re-let the property. His testimony regarding efforts to re-let
be hearsay and inadmissible.
as he is a party
Plaintiffs do not oppose the testimony of the defendant David Johnson,
th-e case and he
is a lessee. who breached the lease agreement. however the Plaintiffs
oppose the testimony of Mr. Johnson regarding efforts to re-let the property after he left.
Defendant does not have any direct knowledge in regards to efforts to re-let and his
testimony will be a pure speculation and insinuation that the Plaintiff somehow did noi
make sufficient efforts to re-let the premises. Due to highly speculative nature
proposed line of testimony of Defendant Johnson, Plaintiff objects to this part of the testimony, however Plaintiff does not object to Johnson's testimony regarding the lease
19 20 2L