Motions & briefs,
on the record.
Selected motions and briefs the firm has filed in California employment cases, published in full. These are public-record court filings, shared so you can read the firm's actual written work, not a summary of it.
The firm's written work.
Motions and briefs from the firm's cases, newest filing first. Open one to read it in full or download the original PDF.
Opposition to Lionsgate's Writ Petition: Privilege Waived by Late Discovery Responses
Lions Gate Films Inc. v. Superior Court (Rodriguez v. Tyler Perry) · Filed; petition pending. Order temporarily stayed in part by the Court of Appeal on 21 August 2026.
Lionsgate answered our client's document requests five weeks late, after the deadline had passed and every objection had been waived, and it never served a privilege log. The trial court refused to give the objections back. Lionsgate then asked the Court of Appeal to overturn that order. This brief explains why the petition should be denied: the late responses were not in substantial compliance with the Code, and that was Lionsgate's burden to show.
Petition for Peremptory Writ of Mandate: Restoring a Struck Judicial Challenge
Uzuegbu (Brian King Joseph) v. Superior Court of California, County of Los Angeles · Filed; pending before the Court of Appeal
Our client filed his one automatic challenge to the assigned judge the day his refiled case reached that judge. The trial court struck it the same day, on its own motion, before the other side was even served, by treating a separately filed lawsuit as a continuation of a case he had voluntarily dismissed. This petition asks the Court of Appeal to stay the case and restore the challenge, because a stricken peremptory challenge can be reviewed only by writ.
Motion to Compel the Deposition of a Defendant Who Did Not Appear
Rodriguez v. Tyler Perry; Lions Gate Films Inc.
A defendant in this action did not appear for his own properly noticed deposition, and never served a single objection to the notice. The Discovery Act treats that as a straightforward matter: the court may order him to appear, to testify and to produce the documents demanded, and a monetary sanction follows unless the failure to appear was substantially justified.
Motion to Compel Document Responses After a Missed Deadline
Rodriguez v. Tyler Perry; Lions Gate Films Inc. · Granted on 27 July 2026; relief from waiver denied; sanctions denied. Temporarily stayed in part by the Court of Appeal on 21 August 2026; writ petition pending (B356319).
A corporate defendant let the deadline for responding to a document demand pass without serving anything: no responses, no objections, no privilege log, no documents. Under the Discovery Act that failure waives every objection to the requests, including objections based on privilege and work product.
Opposition to Motion for Summary Judgment: Whistleblower Retaliation After a Child Abuse Report
Yousefzadeh v. Temple Akiba of Culver City · Motion for summary judgment denied
A preschool teacher’s assistant of 20 years reported that a colleague was emotionally abusing children. Within weeks the school produced a file of write-ups against her, three carrying signatures a forensic expert found were likely forged, and terminated her. This brief opposed the school’s motion for summary judgment on the untimeliness of the motion, the inapplicability of the religious-organization exemption, the disputed reason for the termination, direct evidence of national origin and age discrimination, and the school’s failure to produce the original electronic files.
These are public-record court filings, published to show the firm's written work. They are not legal advice, describe the facts of specific cases, and do not predict the outcome of yours.
Tell us what happened
See the work. Now tell us yours.
Tell us what happened in a sentence or two. If there’s a case, we’ll tell you what it is and what to do next. If there isn’t, we’ll tell you that too, at no cost.
Prefer to talk? Call (424) 255-8376. A real person answers.