Chaganti

I. BACKGROUND

In 2015, Chaganti filed a civil action against real parties for breach of contract, fraud, and negligence. The action concerned a commercial lease on property in Missouri. The named lessee on the lease was “AT&T Wireless PCS, Inc.,” and the rent was paid by checks from “AT&T.” Chaganti’s complaint alleged that New Cingular was “formerly known as AT&T Wireless PCS, Inc.” Real parties were represented in the trial court (and are represented in this writ proceeding) by Raymond Bolaños, who is “an Assistant Vice President and Senior Legal Counsel employed in the AT&T Legal Dept.” The case was assigned to

1 All statutory references are to the Code of Civil Procedure unless otherwise indicated.

2 Judge Theodore Zayner. In April 2018, real parties moved for summary adjudication. Bolaños submitted a declaration in support of the motion in which he stated that he was submitting “this declaration in support of AT&T’s Motion for Summary Adjudication.” This motion was heard by Judge Zayner in July 2018. Judge Zayner’s tentative ruling on the motion was not challenged, and an order granting the motion in part was filed in August 2018. Judge Zayner summarily adjudicated two…