EXHIBIT A

EXHIBIT B

In the Matter of:

PPJ Enterprise, Inc. vs. Narinder S. Grewal

Reporter's Transcript of Proceedings

10/03/2014

Job #: 42888

(818)988-1900

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT

DEPARTMENT 48

PPJ ENTERPRISE, INC., A

NEVADA CORPORATION

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HON.

ELIZABETH ALLEN WHITE, JUDGE

)
)
)
PLAINTIFF,
)
)
VS.
)
NARINDER S. GREWAL, AN
)
INDIVIDUAL; NARINDER S.
)
GREWAL, M.D., A MEDICAL
) CASE NO. BC 427192
CORPORATION, DOING BUSINESS )
AS SANTA CLARITA SURGERY
)
CENTER FOR ADVANCED PAIN
)
MANAGEMENT, AND DOES 1
)
THROUGH 25, INCLUSIVE
)
)
DEFENDANTS.
)
_____________________________)
)
AND CROSS-DEFENDANTS.
)
_____________________________)

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REPORTER'S TRANSCRIPT OF PROCEEDINGS

FRIDAY, OCTOBER 3, 2014

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APPEARANCES:

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FOR THE PLAINTIFF:

L/O OF MICHAEL J. HEMMING

BY: MICHAEL J. HEMMING, ESQ.
333 W. MISSION BOULEVARD
POMONA, CALIFORNIA 91766
909.469.6087

FOR THE DEFENDANTS

CROSS-COMPLAINANTS:

L/O OF JEREMY O. ARNAIZ

BY: JEREMY O. ARNAIZ, ESQ.
BY: FRANK EDWARD HARRIGAN III, ESQ
6690 ALESSANDRO BOULEVARD
SUITE A
RIVERSIDE, CALIFORNIA 92517
951.789.6291

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REPORTED BY:

MEEMO TOMASSIAN, CSR, RPR, NO. 10435

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MASTER INDEX
(NONE)

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breach of contract claim, that's what it said in the

verdict form, that that sum has to be stricken, because
there is no corollary award on breach of contract.
So I would agree with plaintiff that the
proposed form of the jury verdict should be as it is
indicated on the attached proposed verdict form, which
plaintiff attached to its brief.
The Court would strike the amount that is
indicated on the affirmative defense of mitigation.
And the Court would award the sum of $374,926.86
subtracting out the setoff of 140,000, for a total
verdict of $234,926.86.
As to the cross-complaint, the total award
after striking the damages which the jury improperly
awarded on the affirmative defense of mitigation, would
be $86,900.55.
I know that on the plaintiff's side, they're
expecting an additur on the trade secret. The Court
would not consider any additur. I think the jury could
have equally said, "No trade secret, zero."
I think they were assessing the value of the
purported trade secret when they said it was worth a
dollar. It was almost -- I hesitate to say -- well I
think it was almost flippant: "It was your trade
secret. You may claim a trade secret, but in our mind
it's not worth anything."
I think that's how I would interpret that. So
I'm not going to consider an additur.

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On the defense side, I know you feel that the

million which was awarded on the mitigation should be
mitigation that the Court should apply toward the tort.
I disagree, because your verdict form said, "breach of
contract slash mitigation."
So, that's what the Court has concluded.
Go ahead.
MR. HEMMING: May I be heard, your Honor?
THE COURT: Yes.
MR. HEMMING: On the issue of setoff and
recoupment, also, as I recall, the jury verdict form
indicated it had to do with contract damages. It did
not say contract and tort. It said contract. It's the
same situation with respect to the mitigation issue.
THE COURT: All right. So let me go to the
affirmative defense of -MR. ARNAIZ: That's Page 11, your Honor.
THE COURT: -- setoff.
Well, I'm looking at the new proposed verdict
form. Here we go the setoff. It says, "Defendant
seeks affirmative defense setoff recoupment. Have you
found that defendants and cross-complainants breached
the contract?" "Yes."
You're correct, it is as to the contract.
MR. HEMMING: So it shouldn't be applied.
THE COURT: You're correct.
MR. HEMMING: The other issue, your Honor, is
with respect to Ms. Basu, the cross-defendant, Basu.

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CASE NUMBER:
BC 427192
CASE NAME:
PPJ -V- GREWAL
LOS ANGELES, CALIFORNIA FRIDAY, OCTOBER 3, 2014
DEPARTMENT 48
HON. ELIZABETH ALLEN WHITE
REPORTER:
MEEMO TOMASSIAN, CSR 10435
TIME:
8:30 A.M.
APPEARANCES: FOR THE PLAINTIFF, MICHAEL J. HEMMING,
ESQ; FOR THE DEFENDANTS, JEREMY O. ARNAIZ, ESQ., AND
FRANK EDWARD HARRIGAN III, ESQ.
--o0o-THE COURT: PPJ.
MR. HEMMING: Good morning, your Honor.
Michael Hemming on behalf of PPJ and
cross-defendant Chandana Basu.
MR. ARNAIZ: Good morning, your Honor.
Jeremy Arnaiz for defendants and
cross-complainants.
MR. HARRIGAN: Good morning, your Honor.
Frank Harrigan for the plaintiff and
cross-complainants.
THE COURT: All right. Good morning.
Thank you for the briefing that the Court
requested with regard to the interpretation of the
verdict. I've reviewed the briefs. I've reviewed the
proposed forms of judgment.
I agree with plaintiff that the fact that the
jury awarded damages on the affirmative defense of
mitigation, which was specific to mitigation on the

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THE COURT: There was no finding of alter ego.

MR. HEMMING: That's right.
THE COURT: There was nothing in the verdict
form indicating a finding of alter -MR. HEMMING: Exactly.
THE COURT: -- so that the jury could find
alter ego. I agree with you.
MR. HEMMING: There should be no verdict.
MR. ARNAIZ: Your Honor -THE COURT: This is going to end up with
post-trial motions.
MR. ARNAIZ: I understand.
THE COURT: I need a final judgment so that we
can move on.
MR. ARNAIZ: Your Honor, actually, in
conversion and -- both conversion and breach of
fiduciary duty, they did find against Ms. Basu. It
wasn't based on alter ego. It was based on her own
personal action.
THE COURT: Let's look at conversion.
MR. ARNAIZ: That would be -- oh, actually,
and misrepresentation also, your Honor. I'm sorry,
misrepresentation was only to PPJ.
So conversion is Page 4 of defendant's special
verdicts.
THE COURT: All right. Hang on. I'll have to
coordinate it with the proposed verdict.
Here it is. The conversion is on the

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cross-complaint; correct?
MR. ARNAIZ: Yes, your Honor. I don't know if
they included it in plaintiff's papers.
THE COURT: Well, it should be, because they
should have had a complete recitation of the verdicts.
MR. ARNAIZ: It is, your Honor. It's actually
Page 31, your Honor, of plaintiff's papers.
THE COURT: Okay. Thank you.
All right. Conversion: "Grewal,
cross-complainants against cross-defendants PPJ and
Chandana Basu, herein after known as PPJ."
So they were lumped together, which is
problematic.
MR. ARNAIZ: Your Honor, we'd always -- they
were -- Ms. Basu was specifically named as a defendant
in the cross-complaint, your Honor, and so we pursued
her as -THE COURT: But it should have been separated
out. You should have -- you lumped them together. It
should have been: "Did cross-complainant Grewal have
an ownership right to the money in the possession of
cross-defendant PPJ at any time?" So it should have
been "PPJ," then it should have been "Basu." Then, the
second question should have been: "Did PPJ wrongfully
interfere?" And then, "Did Chandana Basu?"
They should have been set out separately. And
I can't infer -- here's the problem: I can't infer
what the jury would have done. So it's not fair.

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MR. ARNAIZ: Your Honor -THE COURT: We're going to have post-trial
motion, Mr. Arnaiz.
MR. ARNAIZ: It is there, your Honor.
THE COURT: Well, it's not. You lumped them
together. How could I determine whether the jury would
have found conversion as against PPJ versus conversion
as against Basu? They're not separated out. You just
said "PPJ." You lumped them together.
MR. ARNAIZ: But, your Honor, we did that
throughout all the special verdicts. I mean -THE COURT: That's a problem.
MR. ARNAIZ: -- Grewal was lumped together
also.
THE COURT: That's a problem.
MR. ARNAIZ: And the jury, when they found
conflicting positions, they came back with questions
asking if they can separate. They did that with the
trade secret. They did it with other issues.
THE COURT: And I'm supposed to infer that
because you lumped them together I should separate them
and find it separately when they didn't come to the
Court with any questions. I can't make those
inferences, Mr. Arnaiz.
MR. ARNAIZ: Well, your Honor, you don't need
to make those inferences. You just need to read the
special verdict itself as to both -THE COURT: I just did.

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MR. ARNAIZ: -- PPJ, covered by both Ms. Basu

and PPJ.
THE COURT: The jury could have found that
Chandana Basu converted and PPJ did not. You lumped
them together. I can't separate them out. And there's
no alter ego determination. There's nothing in this
verdict form that says Ms. Basu is individually liable
because there was no adherence to corporate
formalities. The factors of alter ego are not present.
Mr. Arnaiz, I agree that this may not be what
the jury thought or meant, but I can't make inferences.
I need to get a judgment, and then we're going to move
on because there will be post-trial motions.
MR. ARNAIZ: Well, last point, your Honor, is
I don't think -- I would say you don't need to make an
inference. You just need to read the verdict itself.
The jury said both of them -THE COURT: All the questions said "PPJ." I
don't know that they looked up and said that you had
lumped them together. Even assume that you had lumped
them together, how can I separate them? Even assuming
the jury saw that they were lumped together, how can I
separate them?
MR. ARNAIZ: Well, your Honor, I guess we can
make the same arguments throughout all the special
verdict.
THE COURT: I think the special verdict is a
problem in itself.

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MR. ARNAIZ: Okay.

THE COURT: All I'm trial trying to do is
reduce it to a judgment, then we're going to have
post-trial motions.
MR. ARNAIZ: Okay. The only other thing I
would raise, your Honor, on the mitigation damages and
also the setoff, again, the Court is required to try to
uphold the jury special verdict as much as possible.
And only where it's hopelessly ambiguous, fairly
inconsistent, should the Court not follow the special
verdict.
In this situation, you can give -- you don't
need to strike the mitigation of damages or the setoff.
Even though it says breach of contract in the first
paragraph, the rest of the information, or the rest of
the questions are regarding harm and damages. And the
instructions also gave that, your Honor.
THE COURT: Well, it appears to the Court that
you're being inconsistent here. You're saying I should
have the million-two, but on the other hand, I should
be able to separate out Basu and PPJ even though I
lumped them together.
Mr. Arnaiz. It's a mess.
MR. ARNAIZ: I understand, your Honor.
THE COURT: It's a mess. I need a judgment so
that we can start the clock ticking on post-trial
motions.
MR. ARNAIZ: Your Honor --

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THE COURT: I'm encouraging the parties, and I

know you haven't listened to me in the past, but I'm
encouraging the parties to try to settle this case,
because unless you start afresh and you condense this
down to bare bones, which is basically a conversion and
a breach of contract -- you could have a very clean
simple trial on this case.
You opted, all of you, to turn this into a
huge case, breach of fiduciary duty, conversion, breach
of contract. You made it so complicated, and you
pushed it after 15 continuances to the point where the
Court had absolutely no ability to control you, because
we were right up against the five years.
Now, if I had to do it over again, I would
have made you stay in the jury room until we had
instructions and verdict forms before I even called in
the jury. But you assured me that you had them and
would get them to me the next day. And that continued
throughout five weeks.
So, I put part of the blame on myself here,
but you made this, both of you, into, both sides, into
something much more than it should have been.
MR. ARNAIZ: Your Honor, if I can mention a
few more words? And I understand, there was a lot of
patience shown by the Court, and also by the jury. And
that's why we feel we should really look at what the
jury did. They worked hard on this.
THE COURT: I know they did.

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MR. ARNAIZ: And I don't think we're ever

going to get as good a jury as we had in this matter.
THE COURT: You probably won't.
MR. ARNAIZ: The one thing I would say for
mitigation of damages, it wasn't an award of damages.
It was a statement of the avoidable damages, that
basically these are the damages that Ms. Basu could
have avoided.
THE COURT: And they put them under breach of
contract. That's what your -- that's what your verdict
form says on the affirmative defense, breach of
contract, failure to mitigate. They found no breach of
contract.
I cannot offset by way of the affirmative
defense, because you can't award damages on affirmative
defense. You know, I thought this through, Mr. Arnaiz,
I would love to, you know, say it's a complete wash.
Nobody won. That's where it should go. Nobody won
here and I think that's true.
You probably spent an inordinate amount of
time, attorneys' fees, and nobody won. And there's no
attorney's fees provision. Nobody won. The case
should settle.
MR. HEMMING: I had a dream about that, your
Honor, that that happened.
MR. HARRIGAN: Your Honor?
THE COURT: Yes.
MR. HARRIGAN: May I be heard?

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THE COURT: Yes.

MR. HARRIGAN: For the record, not in direct
argument with your decision, for the record, the Court
is charged with a duty to interpret and attempt to
reconcile the verdict by resort to all of the evidence,
all of the pleadings, all of the instructions, all of
the verdict forms, the total context of the case.
Even failing that, which I think that is
enough to say, this jury knew very well what it was
doing when it awarded the avoidable damages amount. It
knew it had awarded damages on fiduciary duty. It knew
it awarded damages on fraud. It knew it had not
ordered damages on contract.
But if you look at the question that they
answered, not the first question about breach of
contract, which is irrelevant, but the actual question
and answer was specifically about harm and damages.
And the Doctrine of Mitigation of Damages of
avoidable consequence is a strong public policy to
avoid multiplicity of actions, to recognize the
inherent power of the Court to do justice. And there's
-- in our mind, there's obviously no reason not to
honor the jury's intelligent, conscientious decision to
say damages are subject -If I may continue.
THE COURT: I appreciate that, Mr. Harrigan, I
have another trial that's here at 9:00. Actually, I
have a meeting at 9:30.

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MR. HARRIGAN: One-and-a-half more minutes,

please.
MR. HEMMING: Both of them are arguing.
THE COURT: I know, and I heard already from
Mr. Arnaiz. I'm giving Mr. Harrigan the opportunity
because he seems to want to.
MR. HARRIGAN: Thank you, your Honor.
MR. HEMMING: All right.
MR. HARRIGAN: The further step that the Court
is required to do under Taylor is even when a verdict
is defective to subject it to harmless error analysis.
Which, bottom line the harmless error analysis, given
everything the jury had done, is it reasonable to
assume, if you gave them the correct question, they
would answer it any differently?
Final step for me: I do, for the record, move
orally to amend our pleadings for mitigation of damages
and setoff recoupment on tort as well as contract
theories.
THE COURT: Okay. That would be a violation
of due process. I'm not going to amend after the jury
has made its verdict. Let me finish. Let me finish,
please.
Mr. Harrigan, your entire argument is premised
on: "This was an intelligent jury, we know that that's
what they meant."
That's an inference that I can't make. I was
not in that jury room. I don't know what they were

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thinking.
All I have is your form says, "affirmative
defense, mitigation of damages, slash, breach of
contract." It does not say "fiduciary duty." It does
not say "fraud." It says, "breach of contract."
I can't sit as a 13th juror and say, "That's
what they meant." I wasn't there. So, listen -listen to what I'm saying, all I want is a judgment
submitted so that I can sign the judgment so that it
can be entered so the clock starts ticking. I can't
sua sponte grant you a new trial. I can't.
MR. HEMMING: Your Honor, so you want us to
prepare the verdict?
THE COURT: Plaintiff is to prepare the
verdict form and the judgment, submit it. And, again,
I'm encouraging you to try to settle the case. If you
want to go to someone other than Judge Sinanian and
start, fresh, I can possibly get some time with Judge
Bendix.
I don't know what your financial arrangements
are. I don't know whether the clients are paying by
the hour or what the story is. But you have gone
beyond the point of no return on this, way beyond that.
MR. HEMMING: Your Honor, with respect to the
judgment, did you want the interrogatories put in like
we did on -THE COURT: That's exactly the way you're
supposed to do it under California Rules of Court. You

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recite exactly what the verdict form says, and then

it's reduced to a judgment in terms of number.
MR. ARNAIZ: Your Honor, the only
clarification I would like in terms of judgment,
looking at what they had written, there was nothing
there in regards to G-3 Healthcare.
THE COURT: It should -- it should conform -it should be -- the three verdict forms exactly as they
are. The only thing that the Court has done is to try
to reconcile so that we get to a bottom line number.
MR. ARNAIZ: I understand, your Honor. Thank
you.
THE COURT: And, please, once you do it -MR. HEMMING: We'll send it to them.
THE COURT: -- send it to them, so that
they're in agreement that that's what the jury said.
And then you have the Court's determination as to what
the amount should be.
MR. ARNAIZ: Your Honor, is there a timeframe
when the Court will enter the judgment? And I only ask
because I actually will be out of the state from
October 10th to the 20th.
THE COURT: Okay. Well, if you send it,
you've got five days to review it; right? And then it
comes to me after that. I am actually at a conference
the 14th to the 17th. So the first I would even look
at it would be the week of the 20th.
MR. ARNAIZ: Okay.

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MR. HARRIGAN: Your Honor, we would ask at the

time of entry of judgment for a stay as to any
enforcement of Dr. Grewal. Not that -- I don't think
there's any question that he can pay a judgment, but it
would be very disruptive -THE COURT: You're going to need to come in
ex-parte. I can't do that now.
MR. HARRIGAN: Okay.
THE CLERK: What about the exhibits?
THE COURT: Oh. Have we reached agreement on
the return of the exhibits?
MR. ARNAIZ: Your Honor, Annie had made a
proposal, and it's my fault that I had not followed
through with it. She had asked us to list the exhibits
that are actually in question. That should actually
amount to maybe a couple of boxes, and the Court would
hold on to those boxes. I was supposed to bring the
list today. I apologize, I did not. I can have it
prepared by this afternoon. I can share it with
opposing counsel and get it to the court by Monday.
MR. HEMMING: I'm gone all day today, your
Honor, I've got -- I won't be back in the office.
THE COURT: Well, this is just like the trial.
"The jury instructions will be to you in the morning,
your Honor." "The special verdict will be to you in
the morning, your Honor." This went on and on. You
remember?
MR. ARNAIZ: I understand, your Honor. This

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is my fault. I'm not making an excuse, or a story, but

I can get it -- I can speak with Ms. Shome, who
actually has done most of the exhibit work. And I
think she probably has an understanding of what's
contested and what's not. If that's agreeable?
THE COURT: All right. I will require that
you have a stipulation signed to Annie by Tuesday.
MR. HEMMING: Fine.
THE COURT: Tuesday.
MR. HEMMING: Have a nice weekend.
MR. ARNAIZ: Thank you, your Honor.
THE COURT: Notice waived?
MR. ARNAIZ: Notice waived, your Honor.
THE COURT: Okay. Thank you.
(Whereupon the foregoing proceedings were concluded)
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EXHIBIT A

EXHIBIT B

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SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT

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)
)
)
Plaintiff,
)
)
v.
)
)
NARINDER S. GREWAL, an Individual; )
NARINDER S. GREWAL, M.D., a Medical )
Corporation doing business as SANTA
)
CLARITA SURGERY CENTER FOR
)
ADVANCED PAIN MANAGEMENT; and )
Does 1 through 25, inclusive,
)
)
Defendants.
)
___________________________________ )
)
AND RELATED CROSS-ACTIONS
)
)
)

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TO ALL PARTIES AND THEIR ATTORNEY OF RECORD:

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PPJ ENTERPRISE, INC., a Nevada

Corporation

CASE NO. BC427192

[PROPOSED] ORDER

Hearing Date: December 19, 2014

Trial: August 12, 2014
Judge: Hon. Elizabeth White
Dept. 48
Action Filed: December 3, 2009
Cross-Complaint Filed: June 7, 2011

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PLEASE TAKE NOTICE that on December 19, 2014 at 8:30 a.m., in Department 48 of

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the Los Angeles Superior Court, located at 111 North Hill Street, Los Angeles, California 90012,

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Cross-Defendant Chandana Basu brings this Ex Parte Application To Correct Clerical Error In

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Judgment And/Or For An Order Shortening Time For Motion To Correct Clerical Error In

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Judgment, came for hearing before the Honorable Judge Elizabeth White.

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Tanya Shome, Esq. of the Law Office of Tanya Shome, appearing for Cross-Defendant
Chandana Basu;
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[PROPOSED] ORDER

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Sami Haddad, Esq. of the Law Office of Tanya Shome, appearing for Cross-Defendant
Chandana Basu;
Michael J. Hemming, Esq. of the Law Office of Michael J. Hemming, appearing for
Plaintiff PPJ Enterprise, Inc.;

Jeremy Arnaiz, Esq. appearing for Defendants/Cross-Complainants, Narinder S. Grewal

and Narinder S. Grewal, M.D., a Medical Corporation dba Santa Clarita Surgery Center For

Advanced Pain Management and Defendant G3 Healthcare Business Services, Inc.; and

Frank Edward Harrigan, III, Esq. appearing for appearing for Defendants/Cross-

Complainants, Narinder S. Grewal and Narinder S. Grewal, M.D., a Medical Corporation dba

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Santa Clarita Surgery Center For Advanced Pain Management and Defendant G3 Healthcare

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Business Services, Inc.

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The Court, having read and considered the parties moving papers, declarations, exhibits

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and other documents and evidence, both in support of and in opposition to the motion, and good

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cause appearing, hereby finds that good cause exists for:

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1.

The Ex Parte Application to Correct Clerical Error in Judgment is granted;

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2.

Cross-Defendant Chandana Basu will be removed from the Judgment;

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3.

The Judgment will be amended or vacated, so as to remove Cross Defendant

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Chandana Basu in the Judgment; and/or

4.

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An Order Shortening Time to hear Motion to Amend or Vacate or Correct

Judgment.

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IT IS HEREBY ORDERED THAT:

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3.

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4.

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IT IS SO ORDERED.

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Dated: December ____, 2014

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___________________________________
THE HONORABLE ELIZABETH WHITE
JUDGE OF THE SUPERIOR COURT
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[PROPOSED] ORDER

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[PROPOSED] ORDER

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PPJ Enterprises v. Narinder S. Grewal et al.

Los Angeles Superior Court Case No.: BC 427192
PROOF OF SERVICE

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I am resident of State of California, over the age of eighteen years, and not a party to the
above action. My business action is: 888 Prospect Avenue, Suite 200, La Jolla, CA 92037. On
December 19, 2014, I served the above documents:
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Cross-Defendants Chandana Basus Notice of Ex Parte Application to

Correct Clerical Error in Judgment and/or for an Order Shortening Time
for Motion to Correct Clerical Error in Judgment; Memorandum of Points
and Authorities; Declaration of Tanya Shome, Declaration of Michael J.
Hemming; [Proposed Order].
Memorandum of Points and Authorities in Support of Cross-Defendants
Chandana Basus Ex Parte Application to Correct Clerical Error in
Judgment and/or for an Order Shortening Time for Motion to Correct
Clerical Error in Judgment.
Declaration of Tanya Shome in Support of Cross-Defendants Chandana
Basus Ex Parte Application to Correct Clerical Error in Judgment and/or
for an Order Shortening Time for Motion to Correct Clerical Error in
Judgment.
Declaration of Michael J. Hemming in Support of Cross-Defendants
Chandana Basus Ex Parte Application to Correct Clerical Error in
Judgment and/or for an Order Shortening Time for Motion to Correct
Clerical Error in Judgment.
[Proposed] Order

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5.

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BY MAIL. By placing the document(s) listed above in a sealed envelope with postage
thereon fully prepaid, in United States mail in the State of California at state, addressed
to the parties set forth below.
PERSONAL SERVICE BY CAUSE. I caused said documents to be hand-delivered to
the addressee set forth below on December 19, 2014 pursuant to Code of Civil
Procedure 1011.
BY OVERNIGHT MAIL. By placing a true copy thereof enclosed in a sealed
envelope, at a station designated for collection and processing of envelopes and
packages for overnight delivery by an overnight carrier, as part of the ordinary business
practices of the Law Offices of Tanya Shome described below, addressed as follows:
BY FAX. By transmitting, via facsimile, the document(s) listed above to the fax
number(s) set forth below on this date before 5:00 p.m.
BY ELECTRONIC SERVICE {Fed. Rule Civ. Proc. Rule 5(b)] by electronically
mailing a true and correct copy through Tanya Shomes electronic mail system to the email address(s) set forth below, or as stated on the attached service list per agreement in
accordance with Federal Rules of Civil Procedure rule 5(b).

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