Jonathan Lopez Vs Ventura Transfer Company, A California Corporation, Et Al.

Proof of Service (not Summons and Complaint); Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant); As to: Jonathan Lopez (Plaintiff)

Answer DEFENDANT VENTURA TRANSFER COMPANY?S FIRST AMENDED ANSWER TO PLAINTIFF?S UNVERIFIED COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant); As to: Jonathan Lopez (Plaintiff)

Separate Statement; Filed by: Norman Taumoefolau (Defendant)

Response DEFENDANTS’ JOINT RESPONSE TO PLAINTIFF’S SEPARATE STATEMENT OF ADDITIONAL UNDISPUTED MATERIAL FACTS IN SUPPORT OF OPPOSITION TO DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, FOR SUMMARY ADJUDICATION; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Motion in Limine No. 4 To Exclude Evidence of Plaintiff's Performance as a Loader; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Declaration DECLARATION OF NAYRI JILIZIAN IN SUPPORT OF PLAINTIFF?S OPPOSITION TO DEFENDANT VENTURA TRANSFER COMPANY?S MOTION FOR LEAVE TO FILE AMENDED ANSWER; Filed by: Jonathan Lopez (Plaintiff)

Separate Statement; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Answer DEFENDANT NORMAN TAUMOEFOLAU?S FIRST AMENDED ANSWER TO PLAINTIFF?S UNVERIFIED COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant); As to: Jonathan Lopez (Plaintiff)

Separate Statement; Filed by: Jonathan Lopez (Plaintiff)

Reply DEFENDANT VENTURA TRANSFER COMPANY’S REPLY IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Case Management Order; Filed by: Clerk

Notice of Case Reassignment and Order for Plaintiff to Give Notice; Filed by: Clerk

Motion in Limine No. 6 To Exclude Improper Argument in Plaintiff's Opening Statement; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Motion for Leave to Amend TO FILE AMENDED ANSWER; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Reply DEFENDANT VENTURA TRANSFER COMPANY?S to Opposition to Motion for Leave to File Amended Answer; Filed by: Ventura Transfer Company (Defendant)

Order Appointing Court Approved Reporter as Official Reporter Pro Tempore; Filed by: Jonathan Lopez (Plaintiff)

Case Management Statement; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Reply In Support of Motion to Bifurcate Trial; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Reply DEFENDANT NORMAN TAUMOEFOLAU’S REPLY IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Exhibit List; Filed by: Jonathan Lopez (Plaintiff)

Opposition PLAINTIFF?S OPPOSITION TO DEFENDANT VENTURA TRANSFER COMPANY?S MOTION FOR LEAVE TO FILE AMENDED ANSWER; Filed by: Jonathan Lopez (Plaintiff)

Notice of Posting of Jury Fees; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Certificate of Mailing for (Ruling on Submitted Matter) of ; Filed by: Clerk

Opposition to Defendant Ventura Transfer Company's Separate Statement of Undisputed Material Facts in support of MSJ/MSA; Filed by: Jonathan Lopez (Plaintiff); As to: Ventura Transfer Company (Defendant)

Objection TO PURPORTED EVIDENCE SUBMITTED BY DEFENDANTS IN SUPPORT OF ITS MOTION FOR SUMMARY JUDGMENT; Filed by: Jonathan Lopez (Plaintiff)

Proof of Service by Mail; Filed by: Jonathan Lopez (Plaintiff); As to: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant); After Substituted Service of Summons and Complaint ?: No

Opposition PLAINTIFF?S OPPOSITION TO DEFENDANT NORMAN TAUMOEFOLAU?S MOTION FOR LEAVE TO FILE AMENDED ANSWER; Filed by: Jonathan Lopez (Plaintiff)

Reply DEFENDANT NORMAN TAUMOEFOLAU?S to Opposition to Motion for Leave to File Amended Answer; Filed by: Norman Taumoefolau (Defendant)

Notice of Change of Address or Other Contact Information; Filed by: Kaveh Sam Elihu (Attorney)

Opposition TO DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE SUMMARY ADJUDICATION OF ISSUE; MEMORANDUM OF POINTS AND AUTHORITIES; Filed by: Jonathan Lopez (Plaintiff)

Notice of Ruling Re: Hearings On Defendants' Motions For Leave To Amend Answers; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Order Appointing Court Approved Reporter as Official Reporter Pro Tempore Robin Casillas CSR #14042 (via LACourtConnect); Filed by: Jonathan Lopez (Plaintiff)

Notice of Posting of Jury Fees; Filed by: Jonathan Lopez (Plaintiff)

Separate Statement; Filed by: Ventura Transfer Company (Defendant)

Affidavit Defendants Index Of Evidence In Support Of Motions For Summary Judgment Or In The Alternative Summary Adjudication Against Plaintiff Jonathan Lopez; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Motion to Bifurcate; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Reply Defendants' Reply in Support of Their Motion to Compel Depo of Plaintiff's Expert; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Motion in Limine No. 2 to Prevent Plaintiff's Expert Witnesses from Publishing, etc. Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Motion in Limine No. 8 To Preclude Guadalupe Perez from Testifying; Filed by: Ventura Transfer Company (Defendant)

Motion to Compel Deposition of Expert Joseph Dadourian; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant); As to: Jonathan Lopez (Plaintiff)

Stipulation and Order Joint Stipulation to Continue Expert Discovery Cut Off to New Trial Date; Signed and Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant); As to: Jonathan Lopez (Plaintiff)

Opposition TO DEFENDANTS’ EX PARTE APPLICATION TO COMPEL THE DEPOSITION OF PLAINTIFF’S EXPERT JOSEPH DADOURIAN; DECLARATION OF JOSE J. VALDEZ; Filed by: Jonathan Lopez (Plaintiff)

Notice of Ruling; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Notice of Ruling RE: DEFENDANTS’ EX PARTE APPLICATION TO COMPEL THE DEPOSITION OF PLAINTIFF’S EXPERT JOSEPH DADOURIAN AND DEFENDANTS’ MOTION TO BIFURCATE TRIAL; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Ex Parte Application TO COMPEL THE DEPOSITION OF PLAINTIFF’S EXPERT JOSEPH DADOURIAN; DECLARATION OF JASON SHON; [PROPOSED] ORDER; Filed by: Jonathan Lopez (Plaintiff); As to: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Opposition TO DEFENDANTS’ EX PARTE APPLICATION TO SHORTEN TIME FOR NOTICE AND HEARING ON DEFENDANTS MOTION TO COMPEL THE DEPOSITION OF PLAINTIFF’S EXPERT JOSEPH DADOURIAN OR, IN THE ALTERNATIVE CONTINUE TRIAL; DECLARATION OF JOSE J. VALDEZ; Filed by: Jonathan Lopez (Plaintiff)

Notice of Ruling; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Updated -- Stipulation and Order Joint Stipulation to Continue Expert Discovery Cut Off to New Trial Date: Filed By: Norman Taumoefolau (Defendant),Ventura Transfer Company (Defendant); Result: Granted ; Result Date:

Opposition TO DEFENDANTS’ MOTION TO COMPEL THE DEPOSITION OF PLAINTIFF’S EXPERT JOSEPH DADOURIAN; DECLARATION OF JOSE J. VALDEZ; Filed by: Jonathan Lopez (Plaintiff)

Further Declaration of Jason Shon in Support of Motion to Compel Deposition of Plaintiff's Expert; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Ex Parte Application to Shorten Time for Notice and Hearing on Defendants' Motion to Compel the Deposition of Joseph Dadourian; Filed by: Ventura Transfer Company (Defendant); As to: Jonathan Lopez (Plaintiff)

Updated -- Ex Parte Application TO COMPEL THE DEPOSITION OF PLAINTIFF’S EXPERT JOSEPH DADOURIAN; DECLARATION OF JASON SHON; [PROPOSED] ORDER: Filed By: Jonathan Lopez (Plaintiff); Result: Denied ; Result Date:

Updated -- Ex Parte Application to Shorten Time for Notice and Hearing on Defendants' Motion to Compel the Deposition of Joseph Dadourian: Filed By: Ventura Transfer Company (Defendant); Result: Denied ; Result Date:

Motion in Limine No. 3 To Exclude Bal Grewals' Expert Testimony; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Updated -- Motion to Bifurcate the trial of liability and compensatory damages from the trial of punitive damages pursuant to Code of Civil Procedure § 598; reservation no.: 673930659289: Filed By: Norman Taumoefolau (Defendant),Ventura Transfer Company (Defendant); Result: Granted in Part ; Result Date:

Declaration in Support of Motion to Compel Deposition of Expert; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Motion in Limine No. 7 To Prohibit Witnesses Proffered by Plaintiff from Consulting with Plaintiff and His Counsel After Direct and Cross Examination; Filed by: Ventura Transfer Company (Defendant)

Motion in Limine No. 9 To Preclude Plaintiff from Claiming or Presenting Evidence of Income Damages After April 12, 2021; Filed by: Ventura Transfer Company (Defendant)

Motion in Limine No. 1 to Exclude Publishing, etc. Filed by: Ventura Transfer Company (Defendant)

Motion in Limine #6 TO PRECLUDE DEFENDANTS FROM PRESENTING HEARSAY STATEMENTS AS A BASIS FOR ANY EMPLOYEE WRITE UP; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF JOSE L. VALDEZ; Filed by: Jonathan Lopez (Plaintiff)

Motion in Limine #3 TO PRECLUDE DEFENDANTS FROM PRESENTING EVIDENCE OF COLLATERAL SOURCE PAYMENTS; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF JOSE L. VALDEZ;; Filed by: Jonathan Lopez (Plaintiff)

Motion in Limine No. 4 To Exclude Evidence of Plaintiff's Performance as a Loader; Filed by: Ventura Transfer Company (Defendant)

Motion in Limine #5 TO PRECLUDE DEFENDANTS FROM PRESENTING EVIDENCE OF PLAINTIFF’S WORK PERFORMANCE OR DISCIPLINE RELATED TO HIS POSITION AS A LOADER; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF JOSE L. VALDEZ;; Filed by: Jonathan Lopez (Plaintiff)

Motion in Limine #4 TO PRECLUDE DEFENDANTS FROM PRESENTING EVIDENCE OF PLAINTIFF’S APRIL 2014 LAST CHANCE AGREEMENT; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF JOSE L. VALDEZ;; Filed by: Jonathan Lopez (Plaintiff)

Motion in Limine Amended No. 3 To Exclude Bal Grewal's Expert Testimony; Filed by: Ventura Transfer Company (Defendant)

Motion in Limine No. 5 To Exclude Evidence of Plaintiff's Alleged Disability and Discrimination; Filed by: Ventura Transfer Company (Defendant)

Motion in Limine No. 2 to Prevent Plaintiff, Plaintiff's Attorneys and Expert Witnesses from Publishing, etc. Filed by: Ventura Transfer Company (Defendant)

Motion in Limine No. 6 To Exclude Improper Argument in Plaintiff's Opening Statement and Closing Argument; Filed by: Ventura Transfer Company (Defendant)

Motion in Limine #2 FOR ORDER PRECLUDING INTRODUCTION OR REFERENCE TO EVIDENCE RELATED TO AFFIRMATIVE DEFENSES OR CONTENTIONS NOT PREVIOUSLY DISCLOSED; DECLARATION OF JOSE L. VALDEZ IN SUPPORT; Filed by: Jonathan Lopez (Plaintiff)

Opposition TO DEFENDANTS’ MOTION IN LIMINE NO. 8 TO PRECLUDE GUADALUPE PEREZ FROM TESTIFYING; Filed by: Jonathan Lopez (Plaintiff)

Opposition TO RESPONDENT’S MOTION IN LIMINE NO. 3 TO EXCLUDE BAL GREWAL’S EXPERT TESTIMONY; Filed by: Jonathan Lopez (Plaintiff)

Notice of Withdrawal of Motion in Limine No. 4; Filed by: Ventura Transfer Company (Defendant); As to: Jonathan Lopez (Plaintiff)

Opposition TO DEFENDANT’S MOTION IN LIMINE NO. 2 TO PREVENT PLAINTIFF, PLAINTIFF’S ATTORNEYS AND EXPERT WITNESSES FROM PUBLISHING, REFERENCING OR ADMITTING CERTAIN MEDICAL RECORDS AND DEPOSITION TESTIMONY INTO EVIDENCE WITHOUT THE PROPER FOUNDATION; DECLARATION OF J; Filed by: Jonathan Lopez (Plaintiff)

Opposition TO DEFENDANTS’ MOTION IN LIMINE NO. 1 TO EXCLUDE PUBLISHING, REFERENCING OR ADMITTING CERTAIN OUT-OF-COURT STATEMENTS FROM THIRD-PARTIES INTO EVIDENCE WITHOUT THE PROPER FOUNDATION;; Filed by: Jonathan Lopez (Plaintiff)

Opposition TO MOTION IN LIMINE #7 TO PROHIBIT WITNESSES PROFFERED BY PLAINTIFF FROM CONSULTING WITH PLAINTIFF AND HIS COUNSEL AFTER DIRECT AND CROSS EXAMINATION; Filed by: Jonathan Lopez (Plaintiff)

Opposition TO DEFENDANTS’ MOTION IN LIMINE NO. 9 TO PRECLUDE EVIDENCE OF INCOME DAMAGES AFTER APRIL 12, 2021; Filed by: Jonathan Lopez (Plaintiff)

Opposition to Plaintiffs Motion In Limine No. 5; Filed by: Ventura Transfer Company (Defendant)

Notice of Non-Opposition to Plaintiffs Motion In Limine No. 3; Filed by: Ventura Transfer Company (Defendant); As to: Jonathan Lopez (Plaintiff)

Reply In Support of Defendants Motion In Limine No. 3; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Notice OF RULING; Filed by: Jonathan Lopez (Plaintiff)

Opposition to Plaintiffs Motion In Limine No. 4; Filed by: Ventura Transfer Company (Defendant)

Trial Brief DEFENDANTS’; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Reply to Plaintiffs Opposition to Defendants Motion In Limine No. 1; Filed by: Ventura Transfer Company (Defendant)

Reply to Plaintiffs Opposition to Motion In Limine No. 9; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Opposition to Plaintiffs Motion In Limine No. 2; Filed by: Ventura Transfer Company (Defendant)

Proof of Service (not Summons and Complaint); Filed by: Ventura Transfer Company (Defendant); As to: Jonathan Lopez (Plaintiff)

Notice of Plaintiffs Non-Opposition to Defendants Motion In Limine No. 6; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant); As to: Jonathan Lopez (Plaintiff)

Reply In Support of Defendants Motion In Limine No. 8; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Notice of Continuance; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Reply In Support of Defendants Motion In Limine No. 2; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Statement of the Case; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Notice of Plaintiffs Non-Opposition to Defendants Motion In Limine No. 5; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant); As to: Jonathan Lopez (Plaintiff)

Witness List JOINT; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Reply to Plaintiffs Opposition to Defendants Motion In Limine No. 7; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Jury Instructions JOINT LIST OF PROPOSED JURY INSTRUCTIONS (JOINT AND CONTESTED); Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Opposition TO PLAINTIFF’S MOTION IN LIMINE NO. 6 TO PRECLUDE DEFENDANTS FROM PRESENTING HEARSAY STATEMENTS AS A BASIS FOR ANY EMPLOYEE WRITE UP; DECLARATION OF JASON SHON; Filed by: Ventura Transfer Company (Defendant)

Proof of Service (not Summons and Complaint); Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant); As to: Jonathan Lopez (Plaintiff)

Exhibit List; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Updated -- Motion to Be Admitted Pro Hac Vice Application for Heidi L. Eckert; reservation no.: 188440273289: Filed By: Norman Taumoefolau (Defendant),Ventura Transfer Company (Defendant); Result: Granted ; Result Date:

Notice of Non-Opposition to Plaintiffs Motion In Limine No. 1; Filed by: Ventura Transfer Company (Defendant); As to: Jonathan Lopez (Plaintiff)

Notice of Case Assignment - Unlimited Civil Case

Civil Case Cover Sheet

Complaint

Summons - SUMMONS ON COMPLAINT

Notice of Case Management Conference

Proof of Personal Service

Answer

Case Management Statement

Notice of Posting of Jury Fees

Notice of Posting of Jury Fees

Case Management Order

Minute Order - MINUTE ORDER (CASE MANAGEMENT CONFERENCE)

Notice of Case Reassignment and Order for Plaintiff to Give Notice

Motion for Leave - MOTION FOR LEAVE DEFENDANT NORMAN TAUMOEFOLAUS NOTICE OF MOTION AND MOTION FOR LEAVE TO FILE AMENDED ANSWER; MEMORANDUM OF POINTS AND AUTHORITIES

Declaration - DECLARATION OF JASON SHON IN SUPPORT OF NORMAN TAUMOEFOLAUS MOTION FOR LEAVE TO FILE AMENDED ANSWER

Motion for Leave to Amend - MOTION FOR LEAVE TO AMEND TO FILE AMENDED ANSWER

Declaration - DECLARATION OF JASON SHON IN SUPPORT OF VENTURA TRANSFER COMPANYS MOTION FOR LEAVE TO FILE AMENDED ANSWER

Declaration - DECLARATION DECLARATION OF NAYRI JILIZIAN IN SUPPORT OF PLAINTIFF’S OPPOSITION TO DEFENDANT VENTURA TRANSFER COMPANY’S MOTION FOR LEAVE TO FILE AMENDED ANSWER

Declaration - DECLARATION DECLARATION OF NAYRI JILIZIAN IN SUPPORT OF PLAINTIFF’S OPPOSITION TO DEFENDANT NORMAN TAUMOEFOLAU’S MOTION FOR LEAVE TO FILE AMENDED ANSWER

Opposition - OPPOSITION PLAINTIFF’S OPPOSITION TO DEFENDANT VENTURA TRANSFER COMPANY’S MOTION FOR LEAVE TO FILE AMENDED ANSWER

Opposition - OPPOSITION PLAINTIFF’S OPPOSITION TO DEFENDANT NORMAN TAUMOEFOLAU’S MOTION FOR LEAVE TO FILE AMENDED ANSWER

Notice of Change of Address or Other Contact Information

Reply - REPLY DEFENDANT VENTURA TRANSFER COMPANY’S TO OPPOSITION TO MOTION FOR LEAVE TO FILE AMENDED ANSWER

Reply - REPLY DEFENDANT NORMAN TAUMOEFOLAU’S TO OPPOSITION TO MOTION FOR LEAVE TO FILE AMENDED ANSWER

Notice of Ruling - NOTICE OF RULING RE: HEARINGS ON DEFENDANTS' MOTIONS FOR LEAVE TO AMEND ANSWERS

Minute Order - MINUTE ORDER (HEARING ON MOTION FOR LEAVE TO AMEND ANSWER OF VENTURA TRANSF...)

Answer - ANSWER DEFENDANT VENTURA TRANSFER COMPANY’S FIRST AMENDED ANSWER TO PLAINTIFF’S UNVERIFIED COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

Answer - ANSWER DEFENDANT NORMAN TAUMOEFOLAU’S FIRST AMENDED ANSWER TO PLAINTIFF’S UNVERIFIED COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

Separate Statement

Motion for Summary Judgment

Affidavit - AFFIDAVIT DEFENDANTS INDEX OF EVIDENCE IN SUPPORT OF MOTIONS FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE SUMMARY ADJUDICATION AGAINST PLAINTIFF JONATHAN LOPEZ

Separate Statement

Motion for Summary Judgment

Affidavit - AFFIDAVIT DEFENDANTS AMENDED INDEX OF EVIDENCE IN SUPPORT OF MOTIONS FOR SUMMARY JUDGMENT, OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION AGAINST PLAINTIFF JONATHAN LOPEZ

Opposition - OPPOSITION TO DEFENDANT NORMAN TAUMOEFOLAU’S MOTION FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE SUMMARY ADJUDICATION OF ISSUE; MEMORANDUM OF POINTS AND AUTHORITIES

Opposition - OPPOSITION TO DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE SUMMARY ADJUDICATION OF ISSUE; MEMORANDUM OF POINTS AND AUTHORITIES

Opposition - OPPOSITION TO DEFENDANT NORMAN TAUMOEFOLAU’S SEPARATE STATEMENT OF UNDISPUTED MATERIAL FACTS IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT, OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION (FILED

Objection - OBJECTION TO DEFENDANT VENTURA TRANSFER COMPANY’S SEPARATE STATEMENT OF UNDISPUTED MATERIAL FACTS IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT, OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION (FI

Objection - OBJECTION TO PURPORTED EVIDENCE SUBMITTED BY DEFENDANTS IN SUPPORT OF ITS MOTION FOR SUMMARY JUDGMENT

Proof of Service by Mail

Declaration - DECLARATION OF JOSE L. VALDEZ IN SUPPORT OF PLAINTIFF’S OPPOSITION TO DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE SUMMARY ADJUDICATION

Separate Statement

Exhibit List

Reply - REPLY DEFENDANT VENTURA TRANSFER COMPANY’S REPLY IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION

Supplemental Declaration - SUPPLEMENTAL DECLARATION SUPPLEMENTAL DECLARATION OF JASON SHON IN SUPPORT OF DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT, OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION

Response - RESPONSE DEFENDANTS’ JOINT RESPONSE TO PLAINTIFF’S SEPARATE STATEMENT OF ADDITIONAL UNDISPUTED MATERIAL FACTS IN SUPPORT OF OPPOSITION TO DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT OR, IN THE

Reply - REPLY DEFENDANT NORMAN TAUMOEFOLAU’S REPLY IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION

Order Appointing Court Approved Reporter as Official Reporter Pro Tempore

Minute Order - MINUTE ORDER (HEARING ON MOTION FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE,...)

Minute Order - MINUTE ORDER (NUNC PRO TUNC ORDER)

Minute Order - MINUTE ORDER (HEARING ON MOTION FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE,...)

Certificate of Mailing for - CERTIFICATE OF MAILING FOR (RULING ON SUBMITTED MATTER) OF 07/11/2022

Order Appointing Court Approved Reporter as Official Reporter Pro Tempore - ORDER APPOINTING COURT APPROVED REPORTER AS OFFICIAL REPORTER PRO TEMPORE ROBIN CASILLAS CSR #14042 (VIA LACOURTCONNECT)

Minute Order - MINUTE ORDER (RULING ON SUBMITTED MATTER)

Minute Order - MINUTE ORDER (STATUS CONFERENCE RE SETTLEMENT)

Motion to Bifurcate

Opposition - OPPOSITION TO DEFENDANT’S MOTION TO BIFURCATE [TRIFURCATE] THE TRIAL OF LIABILITY AND COMPENSATORY DAMAGES FROM THE TRIAL OF PUNITIVE DAMAGES

Reply - REPLY IN SUPPORT OF MOTION TO BIFURCATE TRIAL

Proof of Service (not Summons and Complaint)

Motion in Limine - MOTION IN LIMINE NO. 2 TO PREVENT PLAINTIFF'S EXPERT WITNESSES FROM PUBLISHING, ETC.

Motion in Limine - MOTION IN LIMINE NO. 7 TO PROHIBIT WITNESSES PROFFERED BY PLAINTIFF FROM CONSULTING WITH PLAINTIFF

Motion in Limine - MOTION IN LIMINE NO. 3 TO EXCLUDE BAL GREWALS' EXPERT TESTIMONY

Motion in Limine - MOTION IN LIMINE NO. 1 TO EXCLUDE PUBLISHING, ETC.

Motion in Limine - MOTION IN LIMINE NO. 5 TO EXCLUDE EVIDENCE OF PLAINTIFF'S ALLEGED DISABILITY AND DISCRIMINATION

Motion in Limine - MOTION IN LIMINE NO. 4 TO EXCLUDE EVIDENCE OF PLAINTIFF'S PERFORMANCE AS A LOADER

Opposition - OPPOSITION TO DEFENDANTS’ EX PARTE APPLICATION TO COMPEL THE DEPOSITION OF PLAINTIFF’S EXPERT JOSEPH DADOURIAN; DECLARATION OF JOSE J. VALDEZ

Motion in Limine - MOTION IN LIMINE NO. 6 TO EXCLUDE IMPROPER ARGUMENT IN PLAINTIFF'S OPENING STATEMENT

Ex Parte Application - EX PARTE APPLICATION TO COMPEL THE DEPOSITION OF PLAINTIFF’S EXPERT JOSEPH DADOURIAN; DECLARATION OF JASON SHON; [PROPOSED] ORDER

Minute Order - MINUTE ORDER (HEARING ON MOTION TO BIFURCATE THE TRIAL OF LIABILITY AND COM...)

Notice of Ruling - NOTICE OF RULING RE: DEFENDANTS’ EX PARTE APPLICATION TO COMPEL THE DEPOSITION OF PLAINTIFF’S EXPERT JOSEPH DADOURIAN AND DEFENDANTS’ MOTION TO BIFURCATE TRIAL

Opposition - OPPOSITION TO DEFENDANTS’ EX PARTE APPLICATION TO SHORTEN TIME FOR NOTICE AND HEARING ON DEFENDANTS MOTION TO COMPEL THE DEPOSITION OF PLAINTIFF’S EXPERT JOSEPH DADOURIAN OR, IN THE ALTER

Motion to Compel - MOTION TO COMPEL DEPOSITION OF EXPERT JOSEPH DADOURIAN

Ex Parte Application - EX PARTE APPLICATION TO SHORTEN TIME FOR NOTICE AND HEARING ON DEFENDANTS' MOTION TO COMPEL THE DEPOSITION OF JOSEPH DADOURIAN

Declaration - DECLARATION IN SUPPORT OF MOTION TO COMPEL DEPOSITION OF EXPERT

Notice of Ruling

Minute Order - MINUTE ORDER (HEARING ON EX PARTE APPLICATION TO SHORTEN TIME FOR NOTICE AN...)

Opposition - OPPOSITION TO DEFENDANTS’ MOTION TO COMPEL THE DEPOSITION OF PLAINTIFF’S EXPERT JOSEPH DADOURIAN; DECLARATION OF JOSE J. VALDEZ

Declaration - FURTHER DECLARATION OF JASON SHON IN SUPPORT OF MOTION TO COMPEL DEPOSITION OF PLAINTIFF'S EXPERT

Reply - REPLY DEFENDANTS' REPLY IN SUPPORT OF THEIR MOTION TO COMPEL DEPO OF PLAINTIFF'S EXPERT

Stipulation and Order - STIPULATION AND ORDER JOINT STIPULATION TO CONTINUE EXPERT DISCOVERY CUT OFF TO NEW TRIAL DATE

Minute Order - MINUTE ORDER (HEARING ON MOTION TO COMPEL DEPOSITION OF PLAINTIFF'S EXPERT ...)

Notice of Ruling

Motion to Be Admitted Pro Hac Vice

Minute Order - MINUTE ORDER (HEARING ON MOTION TO BE ADMITTED PRO HAC VICE FOR HEIDI L. EC...)

Motion in Limine - MOTION IN LIMINE AMENDED NO. 3 TO EXCLUDE BAL GREWAL'S EXPERT TESTIMONY

Motion in Limine - MOTION IN LIMINE NO. 2 TO PREVENT PLAINTIFF, PLAINTIFF'S ATTORNEYS AND EXPERT WITNESSES FROM PUBLISHING, ETC.

Motion in Limine - MOTION IN LIMINE NO. 8 TO PRECLUDE GUADALUPE PEREZ FROM TESTIFYING

Motion in Limine - MOTION IN LIMINE NO. 7 TO PROHIBIT WITNESSES PROFFERED BY PLAINTIFF FROM CONSULTING WITH PLAINTIFF AND HIS COUNSEL AFTER DIRECT AND CROSS EXAMINATION

Motion in Limine - MOTION IN LIMINE NO. 1 TO EXCLUDE PUBLISHING, ETC.

Motion in Limine - MOTION IN LIMINE NO. 9 TO PRECLUDE PLAINTIFF FROM CLAIMING OR PRESENTING EVIDENCE OF INCOME DAMAGES AFTER APRIL 12, 2021

Proof of Service (not Summons and Complaint)

Motion in Limine - MOTION IN LIMINE NO. 4 TO EXCLUDE EVIDENCE OF PLAINTIFF'S PERFORMANCE AS A LOADER

Motion in Limine - MOTION IN LIMINE NO. 6 TO EXCLUDE IMPROPER ARGUMENT IN PLAINTIFF'S OPENING STATEMENT AND CLOSING ARGUMENT

Motion in Limine - MOTION IN LIMINE NO. 5 TO EXCLUDE EVIDENCE OF PLAINTIFF'S ALLEGED DISABILITY AND DISCRIMINATION

Updated -- Motion for Leave to Amend TO FILE AMENDED ANSWER: Filed By: Norman Taumoefolau (Defendant),Ventura Transfer Company (Defendant); Result: Granted; Result Date:

Notice of Case Assignment - Unlimited Civil Case; Filed by: Clerk

Affidavit Defendants Amended Index Of Evidence In Support Of Motions For Summary Judgment, Or In The Alternative, Summary Adjudication Against Plaintiff Jonathan Lopez; Filed by: Ventura Transfer Company (Defendant)

Civil Case Cover Sheet; Filed by: Jonathan Lopez (Plaintiff); As to: Ventura Transfer Company, a California corporation (Defendant); Norman Taumoefolau (Defendant)

Proof of Personal Service; Filed by: Jonathan Lopez (Plaintiff); As to: Ventura Transfer Company (Defendant); Service Date: ; Service Cost: 50.00; Service Cost Waived: No

Updated -- Motion for Summary Judgment of Norman Taumoefolau reservation no.: 142075335918: Filed By: Norman Taumoefolau (Defendant); Result: Denied; Result Date:

Motion for Leave DEFENDANT NORMAN TAUMOEFOLAUS NOTICE OF MOTION AND MOTION FOR LEAVE TO FILE AMENDED ANSWER; MEMORANDUM OF POINTS AND AUTHORITIES; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Updated -- Motion for Leave DEFENDANT NORMAN TAUMOEFOLAUS NOTICE OF MOTION AND MOTION FOR LEAVE TO FILE AMENDED ANSWER; MEMORANDUM OF POINTS AND AUTHORITIES: Filed By: Ventura Transfer Company (Defendant),Norman Taumoefolau (Defendant); Result: Granted; Result Date:

Opposition TO DEFENDANT’S MOTION TO BIFURCATE [TRIFURCATE] THE TRIAL OF LIABILITY AND COMPENSATORY DAMAGES FROM THE TRIAL OF PUNITIVE DAMAGES; Filed by: Jonathan Lopez (Plaintiff)

Declaration OF JASON SHON IN SUPPORT OF VENTURA TRANSFER COMPANYS MOTION FOR LEAVE TO FILE AMENDED ANSWER; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Opposition TO DEFENDANT NORMAN TAUMOEFOLAU’S SEPARATE STATEMENT OF UNDISPUTED MATERIAL FACTS IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT, OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION (Filed concurrently; Filed by: Jonathan Lopez (Plaintiff)

Case Management Statement; Filed by: Jonathan Lopez (Plaintiff)

Complaint; Filed by: Jonathan Lopez (Plaintiff); As to: Ventura Transfer Company, a California corporation (Defendant); Norman Taumoefolau (Defendant)

Updated -- Motion to Compel Deposition of Plaintiff's Expert Joseph Dadourian; reservation no.: 246624073356: Filed By: Norman Taumoefolau (Defendant),Ventura Transfer Company (Defendant); Result: Granted ; Result Date:

Declaration OF JOSE L. VALDEZ IN SUPPORT OF PLAINTIFF’S OPPOSITION TO DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE SUMMARY ADJUDICATION; Filed by: Jonathan Lopez (Plaintiff)

Notice of Case Management Conference; Filed by: Clerk

Answer; Filed by: Norman Taumoefolau (Defendant); As to: Jonathan Lopez (Plaintiff)

Supplemental Declaration SUPPLEMENTAL DECLARATION OF JASON SHON IN SUPPORT OF DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT, OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Motion in Limine No. 1 to Exclude Publishing, etc. Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Motion in Limine No. 5 To Exclude Evidence of Plaintiff's Alleged Disability and Discrimination; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Proof of Service (not Summons and Complaint); Filed by: Ventura Transfer Company (Defendant); As to: Jonathan Lopez (Plaintiff)

Motion to Be Admitted Pro Hac Vice; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant); As to: Jonathan Lopez (Plaintiff)

Motion for Summary Judgment; Filed by: Norman Taumoefolau (Defendant); As to: Jonathan Lopez (Plaintiff)

Motion for Summary Judgment; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant); As to: Jonathan Lopez (Plaintiff)

Declaration OF JASON SHON IN SUPPORT OF NORMAN TAUMOEFOLAUS MOTION FOR LEAVE TO FILE AMENDED ANSWER; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Opposition TO DEFENDANT NORMAN TAUMOEFOLAU’S MOTION FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE SUMMARY ADJUDICATION OF ISSUE; MEMORANDUM OF POINTS AND AUTHORITIES; Filed by: Jonathan Lopez (Plaintiff)

Declaration DECLARATION OF NAYRI JILIZIAN IN SUPPORT OF PLAINTIFF?S OPPOSITION TO DEFENDANT NORMAN TAUMOEFOLAU?S MOTION FOR LEAVE TO FILE AMENDED ANSWER; Filed by: Jonathan Lopez (Plaintiff)

Answer; Filed by: Ventura Transfer Company (Defendant); As to: Jonathan Lopez (Plaintiff)

Motion for Summary Judgment; Filed by: Ventura Transfer Company (Defendant); As to: Jonathan Lopez (Plaintiff)

Affidavit Defendants Amended Index Of Evidence In Support Of Motions For Summary Judgment, Or In The Alternative, Summary Adjudication Against Plaintiff Jonathan Lopez; Filed by: Norman Taumoefolau (Defendant)

Summons on Complaint; Issued and Filed by: Jonathan Lopez (Plaintiff); As to: Ventura Transfer Company, a California corporation (Defendant); Norman Taumoefolau (Defendant)

Motion in Limine No. 7 To Prohibit Witnesses Proffered by Plaintiff from Consulting with Plaintiff; Filed by: Ventura Transfer Company (Defendant); Norman Taumoefolau (Defendant)

Updated -- Motion for Summary Judgment of Ventura Transfer Company reservation no.: 738071323552: Filed By: Ventura Transfer Company (Defendant); Result: Granted in Part; Result Date:

Motion for Summary Judgment (of Ventura Transfer Company reservation no.: 738071323552)

Case Management Statement

Notice of Ruling (Re: Hearings On Defendants' Motions For Leave To Amend Answers)

Complaint

Answer

Notice of Posting of Jury Fees

Declaration (OF JASON SHON IN SUPPORT OF VENTURA TRANSFER COMPANYS MOTION FOR LEAVE TO FILE AMENDED ANSWER)

Minute Order ( (Hearing on Motion for Leave to Amend Answer of Ventura Transf...))

Notice of Change of Address or Other Contact Information

Opposition (PLAINTIFF?S OPPOSITION TO DEFENDANT NORMAN TAUMOEFOLAU?S MOTION FOR LEAVE TO FILE AMENDED ANSWER)

Declaration (OF JASON SHON IN SUPPORT OF NORMAN TAUMOEFOLAUS MOTION FOR LEAVE TO FILE AMENDED ANSWER)

Case Management Statement

Answer (DEFENDANT VENTURA TRANSFER COMPANY?S FIRST AMENDED ANSWER TO PLAINTIFF?S UNVERIFIED COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL)

Defendant Ventura Transfer Company's Amended Separate Statement of Undisputed Material Facts in support of MSJ/MSA reservation no.: 738071323552

Notice of Case Assignment - Unlimited Civil Case

Notice of Case Management Conference

Defendant Norman Taumoefolau's Separate Statement of Undisputed Material Facts in support of MSJ/MSA reservation no.: 142075335918

Defendant Norman Taumoefolau's Amended Separate Statement of Undisputed Material Facts in support of MSJ/MSA

Defendants Index Of Evidence In Support of MSJ's/MSA against Plaintiff Jonathan Lopez

Notice of Posting of Jury Fees

Opposition (to Defendant Ventura Transfer Company's Separate Statement of Undisputed Material Facts in support of MSJ/MSA)

Notice of Case Reassignment and Order for Plaintiff to Give Notice

Defendants Amended Index Of Evidence In Support Of Motions For Summary Judgment, Or In The Alternative, Summary Adjudication Against Plaintiff Jonathan Lopez

Declaration (DECLARATION OF NAYRI JILIZIAN IN SUPPORT OF PLAINTIFF?S OPPOSITION TO DEFENDANT NORMAN TAUMOEFOLAU?S MOTION FOR LEAVE TO FILE AMENDED ANSWER)

Minute Order ( (Case Management Conference))

Motion for Leave to Amend (TO FILE AMENDED ANSWER)

Objection (to purported evidence submitted by defendants in support of its MSJ)

Motion for Leave (DEFENDANT NORMAN TAUMOEFOLAUS NOTICE OF MOTION AND MOTION FOR LEAVE TO FILE AMENDED ANSWER; MEMORANDUM OF POINTS AND AUTHORITIES)

Defendants' Index of Evidence in support of MSJ's /MSA against Plaintiff Jonathan Lopez

Answer (DEFENDANT NORMAN TAUMOEFOLAU?S FIRST AMENDED ANSWER TO PLAINTIFF?S UNVERIFIED COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL)

Answer

Reply (DEFENDANT NORMAN TAUMOEFOLAU?S to Opposition to Motion for Leave to File Amended Answer)

Affidavit (Defendants Amended Index Of Evidence In Support Of Motions For Summary Judgment, Or In The Alternative, Summary Adjudication Against Plaintiff Jonathan Lopez)

Reply (DEFENDANT VENTURA TRANSFER COMPANY?S to Opposition to Motion for Leave to File Amended Answer)

Motion for Summary Judgment (of Norman Taumoefolau reservation no.: 142075335918)

Opposition (PLAINTIFF?S OPPOSITION TO DEFENDANT VENTURA TRANSFER COMPANY?S MOTION FOR LEAVE TO FILE AMENDED ANSWER)

Motion for Summary Judgment (of Defendant Ventura Transfer Company)

Civil Case Cover Sheet

Defendant Ventura Transfer Company's Separate Statement of Undisputed Material Facts in support of MSJ/MSA

Opposition (to Defendants' MSJ/MSA of issue)

Case Management Order

Declaration (DECLARATION OF NAYRI JILIZIAN IN SUPPORT OF PLAINTIFF?S OPPOSITION TO DEFENDANT VENTURA TRANSFER COMPANY?S MOTION FOR LEAVE TO FILE AMENDED ANSWER)

Plaintiff's Separate Statement of Additional Undisputed Material Facts in Support of Opposition to Defendants' MSJ/MSA

Proof of Personal Service

Summons (on Complaint)

Opposition (to Defendant Norman Taumoefolau's MSJ/MSA of issue)

Proof of Service by Mail

Plaintiff Jonathan Lopez's Compendium of Evidence in Opposition to Defendants' MSJ/MSA of issues

Reply (DEFENDANT NORMAN TAUMOEFOLAU?S REPLY IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION)

Supplemental Declaration (SUPPLEMENTAL DECLARATION OF JASON SHON IN SUPPORT OF DEFENDANTS? MOTION FOR SUMMARY JUDGMENT, OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION)

Order Appointing Court Approved Reporter as Official Reporter Pro Tempore

Opposition (to Defendant Norman Taumoefolau's Separate Statement of Undisputed Material Facts in support of MSJ/MSA reservation no.: 142075335918)

Minute Order ( (Nunc Pro Tunc Order))

Minute Order ( (Hearing on Motion for Summary Judgment or in the alternative,...))

Response (DEFENDANTS? JOINT RESPONSE TO PLAINTIFF?S SEPARATE STATEMENT OF ADDITIONAL UNDISPUTED MATERIAL FACTS IN SUPPORT OF OPPOSITION TO DEFENDANTS? MOTION FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, FOR SUMMARY ADJUDICATION)

Reply (DEFENDANT VENTURA TRANSFER COMPANY?S REPLY IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION)

Declaration (of Jose L. Valdez in support of Plaintiff's Opposition to Defendants' MSJ/MSA)

Summons (on Complaint)

Minute Order ( (Case Management Conference))

Declaration (DECLARATION OF NAYRI JILIZIAN IN SUPPORT OF PLAINTIFF?S OPPOSITION TO DEFENDANT VENTURA TRANSFER COMPANY?S MOTION FOR LEAVE TO FILE AMENDED ANSWER)

Opposition (PLAINTIFF?S OPPOSITION TO DEFENDANT NORMAN TAUMOEFOLAU?S MOTION FOR LEAVE TO FILE AMENDED ANSWER)

Declaration (OF JASON SHON IN SUPPORT OF VENTURA TRANSFER COMPANYS MOTION FOR LEAVE TO FILE AMENDED ANSWER)

Motion for Leave to Amend (TO FILE AMENDED ANSWER)

Motion for Leave (DEFENDANT NORMAN TAUMOEFOLAUS NOTICE OF MOTION AND MOTION FOR LEAVE TO FILE AMENDED ANSWER; MEMORANDUM OF POINTS AND AUTHORITIES)

Declaration (OF JASON SHON IN SUPPORT OF NORMAN TAUMOEFOLAUS MOTION FOR LEAVE TO FILE AMENDED ANSWER)

Reply (DEFENDANT NORMAN TAUMOEFOLAU?S to Opposition to Motion for Leave to File Amended Answer)

Opposition (PLAINTIFF?S OPPOSITION TO DEFENDANT VENTURA TRANSFER COMPANY?S MOTION FOR LEAVE TO FILE AMENDED ANSWER)

Reply (DEFENDANT VENTURA TRANSFER COMPANY?S to Opposition to Motion for Leave to File Amended Answer)

Declaration (DECLARATION OF NAYRI JILIZIAN IN SUPPORT OF PLAINTIFF?S OPPOSITION TO DEFENDANT NORMAN TAUMOEFOLAU?S MOTION FOR LEAVE TO FILE AMENDED ANSWER)