Motion,Ex Parte: AZADUHY KHATCHATURIAN, ET AL. VS CITY OF GLENDALE, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 02/15/2023 02:39 PM David W. Slayton, Executive Officer/Clerk of Court, by J. Hernandez,Deputy Clerk

           1     MICHAEL J. GARCIA, CITY ATTORNEY
                 ANN M. MAURER, CHIEF ASSISTANT CITY ATTORNEY, SBN: 179649
           2     EDWARD B. KANG, PRINCIPAL ASSISTANT CITY ATTORNEY, SBN: 237751
                 CARL B. ARIAS, PRINCIPAL ASSISTANT CITY ATTORNEY, SBN: 205068
           3     613 E. Broadway, Suite 220
                 Glendale, CA 91206
           4     Telephone: (818) 548-2080
                 Facsimile: (818) 547-3402
           5     Email: ekang@glendaleca.gov
           6     Attorneys for Defendant                                                                                           Exempt from Filing Fee
                 CITY OF GLENDALE                                                                                                  Government Code § 6103
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           8
                                                  SUPERIOR COURT OF THE STATE OF CALIFORNIA
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                                                               FOR THE COUNTY OF LOS ANGELES
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                 AZADUHY KHATCHATURIAN; and          )                                          Case No.: 22GDCV01106
         12                                          )
                 VAHAG KACHATURIAN,
                                                     )                                          (Assigned to Hon. David A. Rosen, Dept. E)
         13                               Plaintiff, )
                                                     )                                          DEFENDANT CITY OF GLENDALE’S
         14                       vs.                )                                          NOTICE OF MOTION AND MOTION TO
                 CITY OF GLENDALE; COLUMBUS          )                                          STRIKE PORTIONS OF COMPLAINT;
         15                                          )                                          MEMORANDUM OF POINTS AND
                 APARTMENTS, LLC; MOSHE SILBER; and )                                           AUTHORITIES IN SUPPORT THEREOF
         16      DOES 1-30 INCLUSIVE,                )
                                                     )                                          DATE: March 17, 2023
         17                                          )                                          TIME: 10:00 A.M.
                                        Defendants. )                                           DEPT.: Dept. E
         18                                          )
                                                     )                                          RESERVATION ID: 136669762243
         19                                          )
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         21      TO PLAINTIFFS AND TO THEIR ATTORNEYS OF RECORD:
         22                 PLEASE TAKE NOTICE that on March 17, 2023, at 10:00 a.m. or as soon thereafter as the
         23      matter can be heard in Department E of the above-entitled court located at 600 E. Broadway, Glendale,
         24      California, Defendant City of Glendale will move the Court for an order striking the first and second
         25      counts of Plaintiff’s second cause of action, for Negligence and Willful Failure to Warn, respectively.
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                   DEFENDANT’S NOTICE OF MOTION AND MOTION TO STRIKE PORTIONS OF COMPLAINT