Electronically Filed
`Apr 25 2025 11:57 AM
`Elizabeth A. Brown
`Clerk of Supreme Court
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`Docket 90533 Document 2025-18547
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`District Court Case No: A-21-828776-C
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`IN THE EIGHTH JUDICIAL DISTRICT COURT OF THE
`STATE OF NEVADA IN AND FOR
`THE COUNTY OF CLARK
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`Plaintiff(s),
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`vs.
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`RAUL SUAREZ,
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`JASON FRANCE; STEPHANIE FRANCE;
`ALEXANDER R. KHALAF, individually
`and as trustee of the ALEXANDER R.
`KHALAF AND FAHIMA KHALAF
`REVOCABLE LIVING TRUST; FAHIMA
`KHALAF, individually and as trustee of the
`ALEXANDER R. KHALAF AND
`FAHIMA KHALAF REVOCABLE
`LIVING TRUST; ANTHEM REALTY
`GROUP, LLC,
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`Defendant(s).
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`NOTICE OF APPEAL PACKET
`COVER SHEET
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`NOAS
`JONATHAN J. HANSEN, ESQ.
`Nevada Bar No. 7002
`HANSEN & HANSEN, LLC
`9030 W. Cheyenne Ave. #210
`Las Vegas, NV 89129
`(702) 906-1300: office
`(702) 620-5732: facsimile
`jjhansen@hansenlawyers.com
`Attorneys for Defendant
` Anthem Realty Group, LLC
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`DISTRICT COURT
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`CLARK COUNTY, NEVADA
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`RAUL SUAREZ,
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` Plaintiff,
`v.
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`JASON FRANCE, individually; STEPHANIE
`FRANCE, individually; ALEXANDER R.
`KHALAF AND FAHIMA KHALAF REVOCABLE
`LIVING TRUST; FAHIMA KHALAF, individually
`and as trustee of the ALEXANDER R. KHALAF
`AND FAHIMA KHALAF REVOCABLE LIVING
`TRUST; ANTHEM REALTY GROUP, LLC;
`DOES I through X, inclusive; and ROE
`CORPORATIONS I through X, inclusive,
`
` Defendants
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` CASE NO. A-21-828776-C
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` DEPT. NO. 13
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`DEFENDANT ANTHEM REALTY
`GROUP’S NOTICE OF APPEAL
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`NOTICE is hereby given that Defendants ANTHEM REALTY GROUP, LLC., hereby
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`appeals to the Supreme Court of Nevada from the “Judgment Upon Jury Verdict” filed in this action
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`on the 18th day of March, 2024. On March 31, 2025, the Judgment on Jury Verdict was certified
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`under NRCP 54(b) as final and finding that there is no just reason for delay.
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`DATED this 23rd day of April, 2025.
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`HANSEN & HANSEN, LLC
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`BY:
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`/s/ Jonathan J. Hansen____________
`JONATHAN J. HANSEN, ESQ.
`Nevada Bar No. 7002
`9030 W. Cheyenne Ave. #210
`Las Vegas, NV 89129
`Attorney for Defendant
` Anthem Realty Group, LLC
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`Case Number: A-21-828776-C
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`Electronically Filed
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`4/23/2025 12:33 PM
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`Steven D. Grierson
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`CLERK OF THE COURT
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`

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`CERTIFICATE OF SERVICE
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`Pursuant to NRCP 5 (b), I hereby certify that on 23rd day of April, 2025, I served a copy of
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`the foregoing DEFENDANT ANTEHM REALTY GROUP’S NOTICE OF APPEAL as follows:
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`X
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`□
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`□
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`Electronic Service - via the Court’s electronic service system; and/or
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`U.S. Mail – By depositing a true copy thereof in the U.S. mail, first class postage
`prepaid and addressed as listed below; and/or
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`Facsimile – By facsimile transmission pursuant to EDCR 7.26 to the facsimile
`number(s) shown below and in the confirmation sheet filed herewith. Consent
`to service under NRCP 5(b)(2)(D) shall be assumed unless an objection to
`service by facsimile transmission is made in writing and sent to the sender via
`facsimile within 24 hours of receipt of this Certificate of Service; and/or
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`□
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`Hand Delivery – By hand - delivery to the address listed below.
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` /s/ Lisa M. Sabin______________________
`An Employee of HANSEN & HANSEN, LLC
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`Michael C. Kane, Esq.
`Bradley J. Myers, Esq.
`Brandon A. Born, Esq.
`THE702FIRM INJURY ATTORNEYS
`400 South 7th Street #400
`Las Vegas NV 89101
`AND
`Adam S. Kutner, Esq.
`ADAM S. KUTNER & ASSOCIATES
`1137 S. Rancho Dr. Ste. 150A
`Las Vegas NV 89102
`Attorneys for Plaintiff
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`ASTA
`JONATHAN J. HANSEN, ESQ.
`Nevada Bar No. 7002
`HANSEN & HANSEN, LLC
`9030 W. Cheyenne Ave. #210
`Las Vegas, NV 89129
`(702) 906-1300: office
`(702) 620-5732: facsimile
`jjhansen@hansenlawyers.com
`Attorneys for Defendant
`Anthem Realty Group, LLC
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`DISTRICT COURT
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`CLARK COUNTY, NEVADA
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`RAUL SUAREZ,
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` Plaintiff,
`v.
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`JASON FRANCE, individually; STEPHANIE
`FRANCE, individually; ALEXANDER R.
`KHALAF AND FAHIMA KHALAF REVOCABLE
`LIVING TRUST; FAHIMA KHALAF, individually
`and as trustee of the ALEXANDER R. KHALAF
`AND FAHIMA KHALAF REVOCABLE LIVING
`TRUST; ANTHEM REALTY GROUP, LLC;
`DOES I through X, inclusive; and ROE
`CORPORATIONS I through X, inclusive,
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` Defendants.
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` CASE NO. A-21-828776-C
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` DEPT. NO. 13
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`CASE APPEAL STATEMENT
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` Name of appellants filing this case appeal statement:
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`ANTHEM REALTY GROUP, LLC
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`Identify the judge issuing the decision, judgment, or order appealed from:
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`Honorable Judge Mark Denton
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`1.
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`2.
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`3.
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`Identify each appellant and the name and address of counsel for each appellant:
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`ANTHEM REALTY GROUP, LLC
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`Case Number: A-21-828776-C
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`Electronically Filed
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`4/23/2025 12:33 PM
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`Steven D. Grierson
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`CLERK OF THE COURT
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`c/o Jonathan Hansen, Esq.
`9030 West Cheyenne Ave. Suite 210
`Las Vegas, NV 89129
`702-906-1300
`JJHansen@hansenlawyers.com
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`4.
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`Identify each respondent and the name and address of appellate counsel, if known, for each
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`respondent (if the name of a respondent’s appellate counsel is unknown, indicate as much and
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`provide the name and address of that respondent’s trial counsel):
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`Raul Suarez
`c/o Joel S. Henstler, Esq.
`THE702FIRM INJURY ATTORNEYS
`8335 West Flamingo Road
`Las Vegas, Nevada 89147
`Telephone: (702) 776-3333
`brandon@the702firm.com
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`5.
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`Indicate whether any attorney identified above in response to question 3 or 4 is not licensed
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`to practice law in Nevada and, if so, whether the district court granted that attorney permission to
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`appear under SCR 42 (attach a copy of any district court order granting such permission):
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`All attorneys listed are licensed to practice in Nevada.
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`6.
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`Indicate whether appellant was represented by appointed or retained counsel in the district
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`court:
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`Appellants were represented by retained counsel Jonathan Hansen, Esq., in district court.
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`7.
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`Indicate whether appellant is represented by appointed or retained counsel on appeal:
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`Appellants are represented by retained counsel Jonathan Hansen, Esq., on appeal.
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`8.
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`Indicate whether appellant was granted leave to proceed in forma pauperis, and the date of
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`entry of the district court order granting such leave:
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`Appellants did not apply for and was not granted leave.
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`. . .
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`Indicate the date the proceedings commenced in the district court (e.g., date complaint,
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`indictment, information, or petition was filed):
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`Raul Suarez’ Complaint was filed in District Court on February 2, 2021.
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`10.
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` Provide a brief description of the nature of the action and result in the district court, including
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`the type of judgment or order being appealed and the relief granted by the district court:
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`Plaintiff brought an action for injuries from a dog bite incident that occurred on
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`property owned by the Khalaf Trust and managed by Anthem Realty, with tenants
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`named France. The Frances owned the dogs. The tenants were defaulted so Plaintiff
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`continued against Khalaf and Anthem Realty. Despite Defendants’ assertion that they
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`did not own the dog or control the tenants, the court didn’t dismiss the claims and let
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`the jury decide all claims. The jury found that the property management company were
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`liable for the Plaintiff’s injuries and awarded over $72,000 in damages. The jury did
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`not render a verdict against the property owners and they were subsequently dismissed.
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`Defendant management company is appealing the judgment by the jury and the denial
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`of the requests for dismissal by the court. A prior appeal was dismissed as the Judgment
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`by Jury Verdict had not been certified under NRCP 54(b). A Notice of Entry of Order
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`Granting Motion for Rule 54(b) Certification of Judgment was entered on March 25,
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`2025.
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`11.
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` Indicate whether the case has previously been the subject of an appeal to or original writ
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`proceeding in the Supreme Court and, if so, the caption and Supreme Court docket number of the
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`prior proceeding:
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`An appeal of the Judgment was previously filed in the Nevada Supreme Court and assigned
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`docketing number 88492.
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`. . .
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`12.
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` Indicate whether this appeal involves child custody or visitation:
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`This appeal does not involve child custody or visitation.
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`13.
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` If this is a civil case, indicate whether this appeal involves the possibility of settlement:
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`It is possible.
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`DATED this 23rd day of April, 2025.
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`HANSEN & HANSEN, LLC
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`BY:
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`/s/ Jonathan J. Hansen____________
`JONATHAN J. HANSEN, ESQ.
`Nevada Bar No. 7002
`9030 W. Cheyenne Ave. #210
`Las Vegas, NV 89129
`Attorney for Defendant
` Anthem Realty Group, LLC
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`CERTIFICATE OF SERVICE
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`Pursuant to NRCP 5 (b), I hereby certify that on 23rd day of April, 2025, I served a copy of
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`the foregoing CASE APPEAL STATEMENT as follows:
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`X
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`□
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`□
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`Electronic Service - via the Court’s electronic service system; and/or
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`U.S. Mail – By depositing a true copy thereof in the U.S. mail, first class postage
`prepaid and addressed as listed below; and/or
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`Facsimile – By facsimile transmission pursuant to EDCR 7.26 to the facsimile
`number(s) shown below and in the confirmation sheet filed herewith. Consent
`to service under NRCP 5(b)(2)(D) shall be assumed unless an objection to
`service by facsimile transmission is made in writing and sent to the sender via
`facsimile within 24 hours of receipt of this Certificate of Service; and/or
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`□
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`Hand Delivery – By hand - delivery to the address listed below.
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`Michael C. Kane, Esq.
`Bradley J. Myers, Esq.
`Brandon A. Born, Esq.
`THE702FIRM INJURY ATTORNEYS
`400 South 7th Street #400
`Las Vegas NV 89101
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`AND
`Adam S. Kutner, Esq.
`ADAM S. KUTNER & ASSOCIATES
`1137 S. Rancho Dr. Ste. 150A
`Las Vegas NV 89102
`Attorneys for Plaintiff
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` /s/ Lisa M. Sabin______________________
`An Employee of HANSEN & HANSEN, LLC
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`5
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`

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`DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-21-828776-C
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`Location: Department 13
`Judicial Officer: Denton, Mark R.
`Filed on: 02/02/2021
`A828776
`Cross-Reference Case
`Number:
`Supreme Court No.: 88492
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`§§§§§§
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`CASE INFORMATION
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`Case Type: Negligence - Premises Liability
`Case Flags: Appealed to Supreme Court
`Jury Demand Filed
`Arbitration Exemption Granted
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`Raul Suarez, Plaintiff(s)
`vs.
`Jason France, Defendant(s)
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`Statistical Closures
`03/18/2024 Verdict Reached
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`DATE
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`CASE ASSIGNMENT
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`Current Case Assignment
`Case Number
`Court
`Date Assigned
`Judicial Officer
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`A-21-828776-C
`Department 13
`02/02/2021
`Denton, Mark R.
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`Plaintiff
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`Suarez, Raul
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`PARTY INFORMATION
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`Defendant
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`Alexander R Khalaf and Fahima Khalaf Revocable Living Trust
`Removed: 03/24/2025
`Dismissed
`Anthem Realty Group LLC
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`France, Jason
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`France, Stephanie
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`Khalaf, Alexander R.
`Removed: 03/24/2025
`Dismissed
`Khalaf, Fahima
`Removed: 03/24/2025
`Dismissed
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`Lead Attorneys
`Born, Brandon A.
`Retained
`702-776-3333(W)
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`Dion, Nicholas Joseph
`Retained
`702-605-3113(W)
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`Dion, Nicholas Joseph
`Retained
`702-605-3113(W)
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`DATE
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`02/02/2021
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`02/02/2021
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`EVENTS & ORDERS OF THE COURT
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`INDEX
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`Complaint With Jury Demand
`Filed By: Plaintiff Suarez, Raul
`[1] Complaint and Demand for Jury Trial
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`Initial Appearance Fee Disclosure
`Filed By: Plaintiff Suarez, Raul
`[2] Initial Appearance Fee Disclosure
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`PAGE 1 OF 17
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`Printed on 04/24/2025 at 3:14 PM
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`

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`DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-21-828776-C
`Summons Electronically Issued - Service Pending
`Party: Plaintiff Suarez, Raul
`[3] Summons for Defendant Stephanie France
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`Summons Electronically Issued - Service Pending
`Party: Plaintiff Suarez, Raul
`[4] Summons for Defendant Jason France
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`Summons Electronically Issued - Service Pending
`Party: Plaintiff Suarez, Raul
`[5] Summons for Defendant Alexander R. Khalaf, individually and as trustee of the Alexander
`R. Khalaf and Fahima Khalaf Revocable Living Trust
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`Summons Electronically Issued - Service Pending
`Party: Plaintiff Suarez, Raul
`[6] Summons for Defendant Fahima Khalaf, individually and as trustee of the Alexander R.
`Khalaf and Fahima Khalaf Revocable Living Trust
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`Summons Electronically Issued - Service Pending
`Party: Plaintiff Suarez, Raul
`[7] Summons for Defendant Anthem Realty Group LLC
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`Affidavit of Service
`Filed By: Plaintiff Suarez, Raul
`Party Served: Defendant France, Jason
`[8] Affidavit of Service on Defendant Jason France
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`Affidavit of Service
`Filed By: Plaintiff Suarez, Raul
`Party Served: Defendant France, Stephanie
`[9] Affidavit of Service on Defendant Stephanie France
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`Affidavit of Service
`Filed By: Plaintiff Suarez, Raul
`Party Served: Defendant Khalaf, Alexander R.
`[10] Affidavit of Service on Defendant Alexander Khalaf, individually and as trustee
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`Affidavit of Service
`Filed By: Plaintiff Suarez, Raul
`Party Served: Defendant Khalaf, Fahima
`[11] Affidavit of Service on Defendant Fahima Khalaf, individually and as trustee
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`Affidavit of Service
`Filed By: Plaintiff Suarez, Raul
`Party Served: Defendant Anthem Realty Group LLC
`[12] Affidavit of Service on Defendant Anthem Realty Group
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`Answer
`Filed By: Defendant Khalaf, Alexander R.; Defendant Khalaf, Fahima; Defendant Anthem
`Realty Group LLC
`[13] Answer
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`Initial Appearance Fee Disclosure
`Filed By: Defendant Khalaf, Alexander R.; Defendant Khalaf, Fahima; Defendant Anthem
`Realty Group LLC; Defendant Alexander R Khalaf and Fahima Khalaf Revocable Living
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`02/02/2021
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`02/02/2021
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`02/02/2021
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`02/02/2021
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`02/02/2021
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`04/20/2021
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`04/20/2021
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`04/20/2021
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`04/20/2021
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`04/20/2021
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`04/21/2021
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`04/21/2021
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`PAGE 2 OF 17
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`Printed on 04/24/2025 at 3:14 PM
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`

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`04/21/2021
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`05/10/2021
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`05/11/2021
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`05/12/2021
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`05/25/2021
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`05/27/2021
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`06/21/2021
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`06/29/2021
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`06/30/2021
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`06/30/2021
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`01/21/2022
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`03/15/2022
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`DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-21-828776-C
`
`Trust
`[14] Initial Appearance Fee Disclosure
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`Demand for Jury Trial
`Filed By: Defendant Khalaf, Alexander R.; Defendant Khalaf, Fahima; Defendant Anthem
`Realty Group LLC
`[15] Demand for Jury Trial
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`Request for Exemption From Arbitration
`Filed by: Plaintiff Suarez, Raul
`[16] Plaintiff's Request for Exemption from Arbitration
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`Opposition to Request for Exemption
`Filed by: Defendant Khalaf, Alexander R.; Defendant Khalaf, Fahima; Defendant Anthem
`Realty Group LLC; Defendant Alexander R Khalaf and Fahima Khalaf Revocable Living
`Trust
`[17] Opposition to Plaintiffs' Request for Exemption from Arbitration
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`Reply to Opposition to Request for Exemption
`Filed by: Plaintiff Suarez, Raul
`[18] Reply to Defendant's Opposition to Plaintiff's Request for Exemption
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`Commissioners Decision on Request for Exemption - Granted
`[19] Commissioner's Decision on Request for Exemption - Granted
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`Notice of Early Case Conference
`Filed By: Plaintiff Suarez, Raul
`[20] Notice of Telephonic Early Case Conference set for 5-28-2021
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`Joint Case Conference Report
`Filed By: Plaintiff Suarez, Raul
`[21] Joint Case Conference Report
`
`Scheduling and Trial Order
`[22] Order Setting Civil Jury Trial, Pre-Trial, Calendar Call, and Deadlines for Motions;
`Discovery Scheduling Order
`
`Default
`Filed By: Plaintiff Suarez, Raul
`[23] Default Against Defendant Jason France
`
`Default
`Filed By: Plaintiff Suarez, Raul
`[24] Default Against Defendant Stephanie France
`
`Designation of Expert Witness
`Filed By: Plaintiff Suarez, Raul
`[25] Plaintiff's Initial Designation of Expert Witnesses
`
`Motion for Summary Judgment
`Filed By: Defendant Khalaf, Alexander R.; Defendant Khalaf, Fahima; Defendant Anthem
`Realty Group LLC; Defendant Alexander R Khalaf and Fahima Khalaf Revocable Living
`Trust
`[26] Defendants Alexander Khalaf, Fahima Khalaf Revocable Living Trust, Fahima Khalaf,
`and Anthem Realty Group, LLC's Motion for Summary Judgment
`
`PAGE 3 OF 17
`
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`
`

`

`DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-21-828776-C
`
`03/16/2022
`
`03/18/2022
`
`03/18/2022
`
`04/12/2022
`
`04/27/2022
`
`05/06/2022
`
`05/16/2022
`
`06/10/2022
`
`06/14/2022
`
`06/15/2022
`
`Clerk's Notice of Hearing
`[27] Notice of Hearing
`
`Stipulation and Order
`[28] Stipulation and Order to Extend Briefing Schedule and Continue Hearing on Defendants'
`Motion for Summary Judgment
`
`Notice of Entry of Stipulation and Order
`Filed By: Plaintiff Suarez, Raul
`[29] Notice of Entry of Stipulation and Order to Extend Briefing Schedule and Continue
`Hearing Date on Defendant's Motion for SJ
`
`Opposition to Motion For Summary Judgment
`Filed By: Plaintiff Suarez, Raul
`[30] Plaintiff's Opposition to Defendants' Motion for Summary Judgment and Plaintiff's
`Request for 56(d) Relief
`
`Reply to Opposition
`Filed by: Defendant Khalaf, Alexander R.; Defendant Khalaf, Fahima; Defendant Anthem
`Realty Group LLC; Defendant Alexander R Khalaf and Fahima Khalaf Revocable Living
`Trust
`[31] Defendants Alexander R. Khalaf, FahimaKhalaf Revocable Living Trust; Fahima Khalaf,
`and Anthem Realty Group, LLC's Reply to Plaintiff's Opposition to Motion for Summary
`Judgment
`
`Minute Order (1:15 PM) (Judicial Officer: Denton, Mark R.)
`Appearance / BlueJeans
`Minute Order - No Hearing Held; Appearance / BlueJeans
`Minute Order - No Hearing Held
`
`Motion for Summary Judgment (9:00 AM) (Judicial Officer: Denton, Mark R.)
`05/16/2022, 06/16/2022
`Defendants Alexander Khalaf, Fahima Khalaf Revocable Living Trust, Fahima Khalaf, and
`Anthem Realty Group, LLC's Motion for Summary Judgment
`Matter Continued;
`Denied;
`Matter Continued;
`Denied;
`Matter Continued
`
`Supplemental
`Filed by: Plaintiff Suarez, Raul
`[32] Plaintiff's Supplemental Opposition to Defendants' Motion for Summary Judgment
`
`Minute Order (11:00 AM) (Judicial Officer: Denton, Mark R.)
`Appearance / BlueJeans
`Minute Order - No Hearing Held; Appearance / BlueJeans
`Minute Order - No Hearing Held
`
`Reply to Opposition
`Filed by: Defendant Khalaf, Alexander R.; Defendant Khalaf, Fahima; Defendant Anthem
`Realty Group LLC; Defendant Alexander R Khalaf and Fahima Khalaf Revocable Living
`Trust
`[33] Defendants' Reply to Plaintiff's Supplemental Opposition to Defendants' Motion for
`Summary Judgment
`
`PAGE 4 OF 17
`
`Printed on 04/24/2025 at 3:14 PM
`
`

`

`07/01/2022
`
`07/11/2022
`
`08/30/2022
`
`09/09/2022
`
`09/09/2022
`
`09/09/2022
`
`09/09/2022
`
`09/09/2022
`
`09/13/2022
`
`09/22/2022
`
`DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-21-828776-C
`
`Order Denying Motion
`[34] Order Denying Defendants' Motion for Summary Judgment
`
`Notice of Entry of Order
`Filed By: Plaintiff Suarez, Raul
`[35] Notice of Entry of Order Denying Defendants Motion for Summary Judgment
`
`Notice
`Filed By: Plaintiff Suarez, Raul
`[36] Notice of EDCR 2.47 Meeting
`
`Motion in Limine
`Filed By: Plaintiff Suarez, Raul
`[37] Plaintiff's Motion In Limine No. 1: To Exclude Argument that this Case is Attorney
`Driven or a Medical Buildup Case And to Exclude References to Attorney Referals Or , In The
`Alternative, Allow Evidence of Defendant's Liability Insurance
`
`Motion in Limine
`Filed By: Plaintiff Suarez, Raul
`[38] Plaintiff's Motion In Limine No. 2: To Exclude Argument or Suggestion that Defendants
`will Have to Personally Pay the Judgement Amount
`
`Motion in Limine
`Filed By: Plaintiff Suarez, Raul
`[39] Plaintiff's Motion In Limine No. 3: To Preclude References or Opinions Regarding
`Symptom Magnification or Secondary Gain Behavior
`
`Motion in Limine
`Filed By: Plaintiff Suarez, Raul
`[40] Plaintiff's Motion In Limine No. 4: To Permit Voir Dire Questions Regarding
`Relationship with or Interest In Insurance Companies
`
`Motion in Limine
`Filed By: Plaintiff Suarez, Raul
`[41] Plaintiff's Motion In Limine No. 5: for a Jury Instructions Regarding Spoliation of
`Evidence of Rental File of Jason France and Stephanie France and to Allow Examination
`Regarding the Same
`
`Clerk's Notice of Hearing
`Party: Plaintiff Suarez, Raul
`[42] Notice of Hearing
`
`Opposition to Motion in Limine
`Filed By: Defendant Khalaf, Alexander R.; Defendant Khalaf, Fahima; Defendant Anthem
`Realty Group LLC; Defendant Alexander R Khalaf and Fahima Khalaf Revocable Living
`Trust
`[43] Defendants Alexander R. Kahalf, Fahima Kahlaf Revocable Living Trust; Fahima Kahlaf
`and Anthem Realty Group, LLCs Opposition to Plaintiffs Motion in Limine No. 1: to Exclude
`Argument that this Case is Attorney Driven or a Medical Buildup Case and To Exclude
`References to Attorney Referrals or, in the Alternative, Allow Evidence of Defendants Liability
`Insurance
`
`09/22/2022
`
`Opposition to Motion in Limine
`Filed By: Defendant Khalaf, Alexander R.; Defendant Khalaf, Fahima; Defendant Anthem
`Realty Group LLC; Defendant Alexander R Khalaf and Fahima Khalaf Revocable Living
`Trust
`
`PAGE 5 OF 17
`
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`
`

`

`DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-21-828776-C
`[44] Defendants Alexander R. Kahalf, Fahima Kahlaf Revocable Living Trust; Fahima Kahlaf
`and Anthem Realty Group, LLCs Opposition to Plaintiffs Motion in Limine No. 2: to Exclude
`Argument or Suggestion That Defendants Will Have to Personally Pay the Judgment Amount
`
`Opposition to Motion in Limine
`Filed By: Defendant Khalaf, Alexander R.; Defendant Khalaf, Fahima; Defendant Anthem
`Realty Group LLC; Defendant Alexander R Khalaf and Fahima Khalaf Revocable Living
`Trust
`[45] Defendants Alexander R. Kahalf, Fahima Kahlaf Revocable Living Trust; Fahima Kahlaf
`and Anthem Realty Group, LLCs Opposition to Plaintiffs Motion in Limine No. 3: To Preclude
`References or Opinions Regarding Symptom Magnification or Secondary or Secondary Gain
`Behavior
`
`Non Opposition
`Filed By: Defendant Khalaf, Alexander R.; Defendant Khalaf, Fahima; Defendant Anthem
`Realty Group LLC; Defendant Alexander R Khalaf and Fahima Khalaf Revocable Living
`Trust
`[46] Defendants Alexander R. Kahalf, Fahima Kahlaf Revocable Living Trust; Fahima Kahlaf
`and Anthem Realty Group, LLCs Notice of Non-Opposition to Plaintiffs Motion in Limine No.
`4: to Permit Voir Dire Questions Regarding Relationship With or Interest in Insurance
`Companies
`
`Opposition to Motion in Limine
`Filed By: Defendant Khalaf, Alexander R.; Defendant Khalaf, Fahima; Defendant Anthem
`Realty Group LLC; Defendant Alexander R Khalaf and Fahima Khalaf Revocable Living
`Trust
`[47] Defendants Alexander R. Kahalf, Fahima Kahlaf Revocable Living Trust; Fahima Kahlaf
`and Anthem Realty Group, LLCs Opposition to Plaintiffs Motion in Limine No. 5: For a Jury
`Instruction Regarding Spoliation of Evidence of Rental File of Jason France and Stephanie
`France and to Allow Examination Regarding the Same
`
`Pre Trial Conference (3:25 PM) (Judicial Officer: Denton, Mark R.)
`Matter Heard;
`Matter Heard
`
`CANCELED Motion in Limine (9:00 AM) (Judicial Officer: Denton, Mark R.)
`Vacated
`Plaintiff's Motion In Limine No. 1: To Exclude Argument that this Case is Attorney Driven or a
`Medical Buildup Case And to Exclude References to Attorney Referals Or , In The Alternative,
`Allow Evidence of Defendant's Liability Insurance
`
`CANCELED Motion in Limine (9:00 AM) (Judicial Officer: Denton, Mark R.)
`Vacated
`Plaintiff's Motion In Limine No. 2: To Exclude Argument or Suggestion that Defendants will
`Have to Personally Pay the Judgement Amount
`
`CANCELED Motion in Limine (9:00 AM) (Judicial Officer: Denton, Mark R.)
`Vacated
`Plaintiff's Motion In Limine No. 3: To Preclude References or Opinions Regarding Symptom
`Magnification or Secondary Gain Behavior
`
`CANCELED Motion in Limine (9:00 AM) (Judicial Officer: Denton, Mark R.)
`Vacated
`Plaintiff s Motion In Limine No. 4: To Permit Voir Dire Questions Regarding Relationship
`with or Interest In Insurance Companies
`
`CANCELED Motion in Limine (9:00 AM) (Judicial Officer: Denton, Mark R.)
`Vacated
`Plaintiff s Motion In Limine No. 5: for a Jury Instructions Regarding Spoliation of Evidence of
`Rental File of Jason France and Stephanie France and to Allow Examination Regarding the
`Same
`
`09/22/2022
`
`09/22/2022
`
`09/22/2022
`
`10/03/2022
`
`10/17/2022
`
`10/17/2022
`
`10/17/2022
`
`10/17/2022
`
`10/17/2022
`
`PAGE 6 OF 17
`
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`
`

`

`DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-21-828776-C
`
`10/17/2022
`
`CANCELED Calendar Call (2:00 PM) (Judicial Officer: Denton, Mark R.)
`Vacated
`
`10/17/2022
`
`Order Setting Civil Jury Trial, Pre-Trial, and Calendar Call
`[48] Order Setting Civil Jury Trial, Pre-Trial, and Calendar Call
`
`10/25/2022
`
`CANCELED Jury Trial (9:00 AM) (Judicial Officer: Denton, Mark R.)
`Vacated
`
`10/31/2022
`
`01/06/2023
`
`01/11/2023
`
`01/13/2023
`
`01/17/2023
`
`01/17/2023
`
`01/17/2023
`
`01/17/2023
`
`01/17/2023
`
`Notice of Change of Address
`Filed By: Plaintiff Suarez, Raul
`[49] Notice of Change of Address
`
`Pre-Trial Disclosure
`Party: Plaintiff Suarez, Raul
`[50] Plaintiff's Pre-Trial Disclosures
`
`Clerk's Notice of Hearing
`[51] Notice of Hearing
`
`Minute Order (3:00 AM) (Judicial Officer: Denton, Mark R.)
`Minute Order - No Hearing Held;
`Minute Order - No Hearing Held
`
`Motion in Limine (9:00 AM) (Judicial Officer: Denton, Mark R.)
`Plaintiff's Motion In Limine No. 1: To Exclude Argument that this Case is Attorney Driven or a
`Medical Buildup Case And to Exclude References to Attorney Referals Or , In The Alternative,
`Allow Evidence of Defendant's Liability Insurance
`Denied Without Prejudice;
`Denied Without Prejudice
`
`Motion in Limine (9:00 AM) (Judicial Officer: Denton, Mark R.)
`Plaintiff's Motion In Limine No. 2: To Exclude Argument or Suggestion that Defendants will
`Have to Personally Pay the Judgement Amount
`Denied Without Prejudice;
`Denied Without Prejudice
`
`Motion in Limine (9:00 AM) (Judicial Officer: Denton, Mark R.)
`Plaintiff's Motion In Limine No. 3: To Preclude References or Opinions Regarding Symptom
`Magnification or Secondary Gain Behavior
`Denied Without Prejudice;
`Denied Without Prejudice
`
`Motion in Limine (9:00 AM) (Judicial Officer: Denton, Mark R.)
`Plaintiff's Motion In Limine No. 4: To Permit Voir Dire Questions Regarding Relationship
`with or Interest In Insurance Companies
`Motion Granted;
`Motion Granted
`
`Motion in Limine (9:00 AM) (Judicial Officer: Denton, Mark R.)
`Plaintiff's Motion In Limine No. 5: for a Jury Instructions Regarding Spoliation of Evidence of
`Rental File of Jason France and Stephanie France and to Allow Examination Regarding the
`Same
`Granted in Part;
`Granted in Part
`
`01/17/2023
`
`All Pending Motions (9:00 AM) (Judicial Officer: Denton, Mark R.)
`
`PAGE 7 OF 17
`
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`
`

`

`DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-21-828776-C
`
`Matter Heard;
`Matter Heard
`
`Pre Trial Conference (3:00 PM) (Judicial Officer: Denton, Mark R.)
`Matter Heard;
`Matter Heard
`
`Calendar Call (2:00 PM) (Judicial Officer: Denton, Mark R.)
`Matter Heard;
`Matter Heard
`
`Court Recorders Invoice for Transcript
`[52]
`
`Recorders Transcript of Hearing
`[53] Recorder's Transcript of Hearing Re: All Pending Motions - June 30, 2022
`
`Objection
`Filed By: Plaintiff Suarez, Raul
`[54] Plaintiff's Objection to Defendants Alexander R. Khalaf, Fahima Khalaf Revocable
`Living Trust, Fahima Khalaf, and Anthem Realty Group, LLC's Second Supplement to Early
`Case Conference Exchange of Information
`
`Order
`Filed By: Plaintiff Suarez, Raul
`[55] Order Regarding Plaintiff's Motions in Limine
`
`01/17/2023
`
`01/23/2023
`
`01/26/2023
`
`01/26/2023
`
`02/01/2023
`
`02/06/2023
`
`02/07/2023
`
`CANCELED Jury Trial (9:00 AM) (Judicial Officer: Denton, Mark R.)
`Vacated
`
`02/07/2023
`
`02/07/2023
`
`05/15/2023
`
`05/22/2023
`
`05/25/2023
`
`05/31/2023
`
`Notice of Entry of Order
`Filed By: Plaintiff Suarez, Raul
`[56] Notice of Entry of Order regarding Plaintiff's Motions in Limine
`
`Order Setting Civil Jury Trial, Pre-Trial, and Calendar Call
`[57] Order Setting Civil Jury Trial, Pre-Trial, and Calendar Call
`
`Audiovisual Transmission Equipment Appearance Request
`[58] Notice of Intent to Appear Via Simultaneous Audiovisual Transmission Equipment
`(BlueJeans)
`
`Pre Trial Conference (2:35 PM) (Judicial Officer: Denton, Mark R.)
`Matter Heard;
`Matter Heard
`
`Joint Pre-Trial Memorandum
`Filed By: Plaintiff Suarez, Raul
`[59] Joint Pre-Trial Memorandum
`
`Joint Pre-Trial Memorandum
`Filed By: Defendant France, Jason; Defendant France, Stephanie; Defendant Khalaf,
`Alexander R.; Defendant Anthem Realty Group LLC; Defendant Alexander R Khalaf and
`Fahima Khalaf Revocable Living Trust
`[60] Defendants' Addendum to Joint Pre-Trial Memorandum
`
`PAGE 8 OF 17
`
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`
`

`

`DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-21-828776-C
`Joint Pre-Trial Memorandum
`Filed By: Defendant France, Jason; Defendant France, Stephanie; Defendant Khalaf,
`Fahima; Defendant Anthem Realty Group LLC; Defendant Alexander R Khalaf and Fahima
`Khalaf Revocable Living Trust
`[61] Defendants' Second Addendum to Joint Pre Trial Memorandum
`
`Calendar Call (2:00 PM) (Judicial Officer: Denton, Mark R.)
`Matter Heard;
`Matter Heard
`
`Order Setting Civil Jury Trial, Pre-Trial, and Calendar Call
`[62] Order Setting Civil Jury Trial, Pre-Trial, and Calendar Call
`
`05/31/2023
`
`06/05/2023
`
`06/08/2023
`
`06/13/2023
`
`CANCELED Jury Trial (9:00 AM) (Judicial Officer: Denton, Mark R.)
`Vacated
`
`08/07/2023
`
`08/21/2023
`
`08/23/2023
`
`Pre Trial Conference (2:30 PM) (Judicial Officer: Denton, Mark R.)
`Matter Heard;
`Matter Heard
`
`Calendar Call (2:00 PM) (Judicial Officer: Denton, Mark R.)
`Vacated and Reset;
`Vacated and Reset
`
`Order Setting Civil Jury Trial, Pre-Trial, and Calendar Call
`[63] Order Setting Civil Jury Trial, Pre-Trial, and Calendar Call
`
`08/29/2023
`
`CANCELED Jury Trial (9:00 AM) (Judicial Officer: Denton, Mark R.)
`Vacated
`
`10/02/2023
`
`10/11/2023
`
`Pre Trial Conference (2:35 PM) (Judicial Officer: Denton, Mark R.)
`Matter Heard;
`Matter Heard
`
`Order Setting Civil Jury Trial, Pre-Trial, and Calendar Call
`[64] Order Setting Civil Jury Trial, Pre-Trial, and Calendar Call
`
`10/16/2023
`
`CANCELED Calendar Call (2:00 PM) (Judicial Officer: Denton, Mark R.)
`Vacated
`
`10/24/2023
`
`CANCELED Jury Trial (9:00 AM) (Judicial Officer: Denton, Mark R.)
`Vacated
`
`12/06/2023
`
`01/04/2024
`
`01/05/2024
`
`Notice of Association of Counsel
`Filed By: Plaintiff Suarez, Raul
`[65] Notice of Association of Counsel
`
`Order
`[66] Order Rescheduling Pre-Trial Conference and Calendar Call
`
`Pre-Trial Disclosure
`Party: Plaintiff Suarez, Raul
`[67] Plaintiff's Pre-Trial Disclosures
`
`PAGE 9 OF 17
`
`Printed on 04/24/2025 at 3:14 PM
`
`

`

`DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-21-828776-C
`
`Pre-Trial Disclosure
`Party: Defendant Khalaf, Alexander R.; Defendant Khalaf, Fahima; Defendant Anthem
`Realty Group LLC; Defendant Alexander R Khalaf and Fahima Khalaf Revocable Living
`Trust
`[68] Defendants' First Supplement to Pre-Trial Disclosures
`
`Objection
`Filed By: Defendant Khalaf, Alexander R.; Defendant Khalaf, Fahima; Defendant Anthem
`Realty Group LLC; Defendant Alexander R Khalaf and Fahima Khalaf Revocable Living
`Trust
`[69] Defendants' Objections to Plaintiff's Pre Trial Disclosures
`
`Pre Trial Conference (1:45 PM) (Judicial Officer: Denton, Mark R.)
`Per 1/4/24 Order Rescheduling Pre-Trial Conference and Calendar Call
`Matter Heard;
`Matter Heard
`
`Calendar Call (1:30 PM) (Judicial Officer: Denton, Mark R.)
`Per 1/16 Minutes
`Trial Date Set;
`Trial Date Set
`
`Joint Pre-Trial Memorandum
`Filed By: Plaintiff Suarez, Raul
`[70] JOINT PRE-TRIAL MEMORANDUM
`
`Trial Subpoena
`Filed by: Plaintiff