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Case No. :09 OC 00279
Dept. No.: 1
THE O'MARA LAW FIRM, P.C.
David C. O'Mara, Esq., (NV Bar 8599)
311 E. Liberty Street
Reno, Nevada 89501
775.323.1321
Counsel for Defendant
IN THE FIRST JUDICIAL
DISTRICT COURT OF THE STATE OF NEVADA
IN AND FOR CARSON CITY
DECLARATION OF DAVID O'MARA, ESQ. IN SUPPORT OF THE MOTION TO QUASH ARREST WARRANT
JED MARGOLION, an individual,
Plaintiff ,
V.
OPTIMA TECHNOLOGY CORPORATION, a California corporation, OPTIMA TECHNOLOGY CORPORATION, a Nevada corporation, REZA ZANDIAN, aka GHOLAM REZA ZANDIAN, aka REZA JAZI, aka J. REZA JAZI aka G. REZA JAZI aka CHONONREZA {sic} ZANDIAN JAZI, an individual, DOES Companies 1-10, DOE Corporations J 1-20, and DOE Individuals 21-30, inclusive,
Defendants
DECLARATION OF DAVID C. O'MARA ESQ.
DAVID C. O'MARA, declares as follows:
1. I am the sole practitioner of The O'Mara Law Firm, P.C. and my firm's office is located in Reno, Nevada.
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2. I am an attorney admitted to practice before all courts in the State of Nevada and have personal knowledge of the facts and circumstances set forth herein.
3. I am seeking on behalf of Defendant an order shortening time to respond to this motion to quash arrest warrant.
4. On April 1, 2025, I was contacted by my client to represent him on the pending warrant for his arrest that was filed in this matter. Client was recently restrained at the Maple River Detention Center in Riverside, California, pursuant to the Court's Arrest Warrant and Amended Arrest Warrant.
5. On April 2, 2025, Declarant traveled to Carson City to review the above-referenced case file and to obtain various documents relevant to this case. Declarant reviewed the documents from the date of the motion to compel a judgment debtor, until the last filed document. Declarant obtained copies of the Motion for Order to Show Cause Regarding Contempt and Ex Parte Motion for Order Shortening Time. Declarant did not see within the file any Affidavit in support of the Motion for Order to Show Cause Regarding Contempt. A true and correct copy of the Motion for Order to Show Cause that was obtained from the Court Clerk is attached as Exhibit 1 of this Declaration.
6. Declarant further obtained a copy of the Court's docket showing all documents filed in this case. There is no entry of an Affidavit in support of the motion for order to show cause regarding contempt filed around the date of the motion, January 14, 2016, entered on the docket.
7. Declarant further requested a copy of the Affidavit from opposing counsel, but because of the timing of the request, counsel would likely not be able to obtain the document, if one exists.
8. A true and correct copy of the Court's Order Holding Defendant in Contempt of Court is attached as Exhibit 1 of this Declaration.
9. A true and correct copy of the Court's Amended Arrest Warrant is attached as Exhibit 3 of this Declaration.
10. Defendant in this matter is currently being held in at the Maple River Correctional Center in Riverside California and the time he spends in the facility may exceed the 25 days allowed for incarceration under Nevada Law. More importantly, Defendant believes that the Arrest Warrant was improper and in violation of his constitutional rights.
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Pursuant to NRS 53.045, I declare under penalty of perjury under the laws of the State of Nevada that the foregoing is true and correct.
Respectfully submitted,
DATED: April 4, 2025
THE O’MARA LAW FIRM, P.C.
DAVID O’MARA, ESQ.
311 B. Liberty Street
Reno, Nevada 89501
Tel.: 775.323.1321
Fax: 775.323.4082
Counsel for Plaintiffs
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CERTIFICATE OF SERVICE
Thereby certify that I am an employee of The O'Mara Law Firm, P.C., 311 B. Liberty Street, Reno, Nevada 89501, and on this date I served a true and correct copy of the foregoing document on all parties to this action by:
[x] Depositing in a sealed envelope placed for collection and mailing in the United States Mail, at Reno, Nevada, following ordinary business practices
[ ] Personal Delivery
[ ] Facsimile
[ ] Federal Express or other overnight delivery Messenger Service
[ ] Certified Mail with Return Receipt Requested Electronically through the Court's ECF system
[x] Email
addressed as follows:
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Frank C. Gilmore, Esq. The Gilmore Law Group, PLLC 3715 Lakeside Drive Reno, NV 89509 frank@gilmoregroupnv. corn
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Law Offices of Amy N. Tierre, APC Amy N. Tine, Esq. 3715 Lakeside Drive Reno, NV 89509 amy@amytirrelaw.com |
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VALERIE WETS
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