Santos Casaus
Attorneys’ Business Address
City, ST ZIP Code
Phone | Fax
Email
Defendant in pro per
SUPERIOR COURT OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
CIVIL DIVISION
DAVID TUSHIN ET. AL,
Plaintiff,
vs.
SANTOS CASAUS,
Defendant
Case No.: 20VECC00708
MOTION FOR CLARIFICATION
NOTICE OF MOTION FOR CLARIFICATION
Please take notice that on Date at Time, or as soon thereafter as the matter may be heard in the
above court, Defendant will and hereby does move the Court for an Order granting Clarification
in his favor.
This Motion is based upon this Notice of Motion, the subsequent Motion for Clarification, and
such oral or documentary evidence as may be presented at or before the hearing of the Motion.
Dated this __ day of July, 2022.
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MOTION FOR CLARIFICATION – 2
Respectfully Submitted,
Santos Casaus,
Defendant in pro per
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MOTION FOR CLARIFICATION – 3
Santos Casaus
Attorneys’ Business Address
City, ST ZIP Code
Phone | Fax
Email
Defendant in pro per
SUPERIOR COURT OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
CIVIL DIVISION
DAVID TUSHIN ET. AL.,
Plaintiff,
vs.
SANTOS CASAUS,
Defendant
Case No.: 20VECVOO708
MOTION FOR CLARIFICATION
COMES NOW Santos Casaus, Defendant, who moves for clarification of the Order issued by this
Honorable Court on August 13, 2020, and for cause would show this Court as follows:
- The Order issued on August 13, 2020 instructed Mr. Grant Stephenson to receive
documents from Mr. Tushin on behalf of Mr. Casaus. Exhibit 1. - Mr. Casaus has gone ahead to file a complaint with The State Bar of California stating that
Mr. Stephenson engaged in the unlawful practice of law when he received documents on
behalf of Mr. Casaus. Mr. Stephenson received correspondence from The State Bar of
California stating that his action of receiving documents on behalf of Mr. Casaus amount
to the unlawful practice of law. - Had Mr. Stephenson failed to receive the documents on behalf of Mr. Casaus, he would
have been liable for contempt of court pursuant to Penal Code § 166 punishable by
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MOTION FOR CLARIFICATION – 4
imprisonment in county jail for not more than one year, a fine of not more than $5,000, or
both.
- Mr. Stephenson’s actions were in compliance with the order issued by this Court on August
13, 2020. - It is well presumed that the order issued by this Court on August 13, 2020 was a lawful
order made in consideration of the State of California.
REASONS WHEREFORE, Defendant respectfully requests this Honorable Court to clarify that
Mr. Stephenson engaged in clerical work of receiving documents on behalf of Mr. Casaus, not the
unlawful practice of law.
Dated this __ day of January, 2022.
Respectfully Submitted,
Santos Casaus,
Defendant in pro per
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MOTION FOR CLARIFICATION – 5
VERIFICATION
I, Santos Casaus, being duly sworn depose and say that I am the Defendant in the above-entitled
action, that I have read the foregoing Motion for Clarification and know the contents thereof. That
the same is true of my own knowledge except as to those matters and things stated upon
information and belief, and as to those things, I believe them to be true.
(Sign in the presence of a Notary Public)
Sworn to and subscribed before me this _ day of _________, 2021.
Notary Public
(Printed name of Notary Public)
My Commission Expires: ________
EXHIBIT 1
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
Civil Division
Northwest District, Van Nuys Courthouse East, Department W
20VECV00708 August 13, 2020
DAVID TUSHIN, et al. vs SANTOS CASAUS 8:30 AM
Judge: Honorable Virginia Keeny CSR: None
Judicial Assistant: Ani Dastaryan ERM: None
Courtroom Assistant: Rommel Villagonzalo Deputy Sheriff: None
Minute Order Page 1 of 1
APPEARANCES:
For Plaintiff(s): Jacques Tushinsky-Fox (Telephonic)
For Defendant(s): Santos Casaus
NATURE OF PROCEEDINGS: Hearing on Ex Parte Application for Temporary Restraining
Order
The matter is called for hearing.
The Court having fully considered the arguments of all parties, both written and oral, as well as
the evidence presented, now rules as follows:
The Ex Parte Application Ex Parte Application filed by Santos Casaus on 08/12/2020 is Granted
in Part.
Hearing on Motion for Preliminary Injunction is scheduled for 08/24/2020 at 08:30 AM in
Department W at Van Nuys Courthouse East.
Defendant Santos Casaus is permitted to use $10,000 of the money from the blocked account to
retain a licensed California attorney to represent him in preparation for and at the mediation.
Remainder of the funds to be transferred no later than 8/17/20 to Client Trust Account of J.T.
Fox. Plaintiff David Tushin is entitled in principle to also use $10,000 of company funds towards
mediation, with the court to determine whether such funds have already been accessed by David
Tushin.
Tushin is ordered to provide copies of all financial records for company from date of
incorporation to present (including bank statements//ledgers, financial statements, invoices,
payment received, tax returns, etc.) to Casaus via Grant Stephenson by 8/20/20.
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