-1- NOTICE OF MOTION AND MOTION IN SUPPORT OF DEFENDANT LOS ANGELES MAGAZINE LLC’S SPECIAL MOTION TO STRIKE PURSUANT TO CCP SEC. 425.16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Gordon Rees Scully Mansukhani, LLP 101 W. Broadway, Suite 2000 San Diego, CA 92101 SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES PLEASE TAKE NOTICE that, on January 24, 2023, at 10:00 a.m., or as soon thereafter as this matter can be heard in Department 61 of the above-entitled Court located at 111 North Hill Street, Los Angeles, California, defendant Los Angeles Magazine LLC will, and does hereby, move the Court for an order, pursuant to Code of Civil Procedure sec. 425.16: MILES D. SCULLY (SB N: 135853) mscully@grsm.com TIMOTHY K. BRANSON (SBN: 187242) tbranson@grsm.com GABRIEL G. HEDRICK (SBN: 220649) ghedrick@grsm.com GORDON REES SCULLY MANSUKHANI, LLP 101 W. Broadway, Suite 2000 San Diego, CA 92101 Telephone: (619) 230-7422 Facsimile: (619) 696-7124 Attorneys for Defendant LOS ANGELES MAGAZINE , LLC YASHAR ALI , an individual, Plaintiff, vs. LOS ANGELES MAGAZINE, LLC, a California limited liability company; and DOES 1-20, inclusive, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CASE NO. 22STCV18984 DEFENDANT LOS ANGELES MAGAZINE LLC’S NOTICE OF MOTION AND MOTION TO STRIKE PLAINTIFF’S CLAIMS PURSUANT TO CCP SEC. 425.16 Filed and Served Concurrently with: 1. Memorandum of Points and Authorities; 2. Declaration of Steven Christianson; 3. Declaration of Peter Kiefer; 4. Declaration of Maer Roshan; 5. [Proposed] Order Date: January 24, 2023 Time: 10:00 a.m. Dept.: 61 Judge: Hon. Gregory Keosian Reservation ID: 984082585326 Complaint Filed: June 9, 2022 Trial Date: Not Set Electronically FILED by Superior Court of California, County of Los Angeles on 12/23/2022 01:54 PM Sherri R. Carter, Executive Officer/Clerk of Court, by V. Sino-Cruz,Deputy Clerk -2- NOTICE OF MOTION AND MOTION IN SUPPORT OF DEFENDANT LOS ANGELES MAGAZINE LLC’S SPECIAL MOTION TO STRIKE PURSUANT TO CCP SEC. 425.16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Gordon Rees Scully Mansukhani, LLP 101 W. Broadway, Suite 2000 San Diego, CA 92101 (1) striking and/or dismissing all of the claims asserted in the First Amended Complaint’s first cause of action for defamation, including all claims based on any of the allegedly false and defamatory statements referred to in that cause of action; (2) striking and/or dismissing all of the claims asserted in the First Amended Complaint’s second cause of action for promissory fraud; (3) striking and/or dismissing all of the claims asserted in the First Amended Complaint’s third cause of action for breach of contract; and (4) awarding defendant its attorneys’ fees and costs pursuant to C.C.P. sec. 425.16(c); This motion is made pursuant to California Code of Civil Procedure section 425.16 on the ground that the claims asserted in the First Amended Complaint arise out of the defendant’s conduct in furtherance of its right of free speech in connection with a public issue, and the plaintiff cannot demonstrate that he is likely to prevail on his claims. This motion is based on this Notice, the Memorandum of Points and Authorities filed herewith, the Declarations and exhibits filed herewith, the Complaints filed in this action, the papers filed in this action, and such other evidence that may be presented at or before the hearing on this motion. Dated: December 22, 2022 GORDON REES SCULLY MANSUKHANI By___________________________ Miles Scully Timothy Branson Attorneys for Defendant Los Angeles Magazine LLC Journal Technologies Court Portal Make a Reservation YASHAR ALI vs LOS ANGELES MAGAZINE, LLC, A CALIFORNIA LIMITED LIABILITY COMPANY Case Number: 22STCV18984 Case Type: Civil Unlimited Category: Defamation (slander/libel) Date Filed: 2022-06-09 Location: Stanley Mosk Courthouse - Department 61 Reservation Fees Description Fee Qty Amount Special Motion to Strike under CCP Section 425.16 (Anti-SLAPP motion) 60.00 1 60.00 Credit Card Percentage Fee (2.75%) 1.65 1 1.65 Payment Print Receipt Reserve Another Hearing Case Name: YASHAR ALI vs LOS ANGELES MAGAZINE, LLC, A CALIFORNIA LIMITED LIABILITY COMPANY Case Number: 22STCV18984 Type: Special Motion to Strike under CCP Section 425.16 (Anti-SLAPP motion) Status: RESERVED Filing Party: Los Angeles Magazine, LLC, a California limited liability company (Defendant) Location: Stanley Mosk Courthouse - Department 61 Date/Time: 01/24/2023 10:00 AM Number of Motions: 1 Reservation ID: 984082585326 Con rmation Code: CR-2X9GM8GC8YPP5GJDW TOTAL $61.65 Amount: $61.65 Type: Visa Account Number: XXXX5771 Authorization: 06469D Payment Date: 1969-12-31 + Chat