SUPERIOR COURT OF THE STATE OF CALIFORNIA

SEAN RASHTI

5150 YARMOUTH AVE APT. 210

ENCINO, CA 91315

CELL TELEPHONE: 818-448-6500

FAX: 818-705-2724

 

PLAINTIFF IN PROPER

 

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR COUNTY OF LOS ANGELES – CENTRAL DISTRICT

 

SEAN RASHTI,

Plaintiff

vs.

KOOROSH SHAHROKH

Late Attorney

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 Case No.: No. 19STCV42312

 

Judge:  Honorable Audra Mori

Department: 31

 

 

RE: DEMAND TO REMOVE LIEN

 

 

Complaint filed: Nov. 26. 2019

Trial Date: May 20.2022

 

Dear Mr. Koorosh Shahrokh,

 

I, Sean A. Rashti, am writing this demand letter as my LAST NOTICE requesting you remove lien on the case CASE # 19STCV42312.

As the Attorney, you were responsible for the Sanction’s discredit, Inaccurate Answers and their correction, Motion in limine, Motion to pursue additional insurance, Motion to Compel for Further Discovery Responses, Accurately answering the Insured Discovery Responses, Representation and protection of your client, the Plaintiff, and Showing a fight in court.  You utterly failed in the above and thus were negligent in your duty as an attorney.

The following actions by you further prove that you neglected your duty of care:

  1. Voluntarily case abandonment.
  2. Acquiring a Sanction on the case.
  3. Failure to file a Motion to Compel Further Discovery Responses intime, within 45 days of objections and non-admissions.
  4. Weakening the case by providing false responses to Defendant’s interrogatories, dated 10/26/2020, which discredited the plaintiff during the Depositions.
  5. Allowing for your client to be deposed, when you knew client was suffering from severe depression, pain, and was untreated for several months during COVID crises
  6. Most importantly, you voluntarily withdrew from the case before the trial.
  7. Falsely claiming 40% when agreement states 33% when you tried to settle pre-trial.
  8. State firm’s Independent Doctor’s opinion had many Errors which was neutralized directly by the client. Mr. Koorosh Shahrokh had no part in the 10x offer of 40,000.

 

You must terminate the lien formally WITH PREJUDICE, giving notice to ALL STAKE HOLDERS, and negotiate with Plaintiff for a cash settlement after trial ends.

If there is no response to this demand letter within 30 days, all legal rights shall be explored, including, but not limited to, legal proceedings necessary in accordance with State and Federal laws, formal complaint to California Bar Associations, San Fernando Bar Association, followed by a grievance campaign in social media using professional writers for Yelp, Angies list, AVVO, LawDepot, JustAnswer to name a few.

 

This notice of demand serves as official notice to you and may be tendered in any tribunal or court as evidence of your failure to cooperate. If legal action is to occur to resolve this matter, it may involve having you pay attorney’s fees.

 

We hope to resolve this matter as soon as possible.

 

Respectfully Submitted

Sean Rashti

Dated: July 7, 2022

 

 

 

 

CERTIFICATE OF SERVICE

I hereby certify that on July 7, 2022 a copy of the foregoing document has been sent to the Mr. Koorosh Shahrokh in the following address:

____via U.S. MAIL

____via OVERNIGHT DELIVERY SERVICE

____via FACSIMILE

____via E-MAIL

 

Koorosh Shahrokh

6345 Balboa Blvd.

Building III, suite 273

Encino, CA 91316

Phone: 818-996-7301

Fax: 818-996-7302

Dated: July 7, 2022