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  • ANNIE GOMBEAUD VS PETCO ANIMAL SUPPLIES STORES, INC. Premise Liability (e.g., dangerous conditions of property, slip/trip and fall, dog attack, etc.) (General Jurisdiction) document preview
  • ANNIE GOMBEAUD VS PETCO ANIMAL SUPPLIES STORES, INC. Premise Liability (e.g., dangerous conditions of property, slip/trip and fall, dog attack, etc.) (General Jurisdiction) document preview
						
                                

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Electronically FILED by Superior Court of California, County of Los Angeles on 09/09/2022 04:06 PM Sherri R. Carter, Executive Officer/Clerk of Court, by L. Coreas,Deputy Clerk JACOB D. FLESHER- SBN 210565 NICOLE M. LOW — SBN 321429 FLESHER SCHAFF & SCHROEDER, INC. 2205 Plaza Drive, Suite 225 Rocklin, CA 95765 Telephone: (916) 672-6558 Facsimile: &9161 672-6602 Attorneys for defendant, PETCO ANIMAL SUPPLIES STORES, INC. IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF LOS ANGELES 10 ANNIE GOMBEAUD, CASE NO. 21STCV39937 Complaint, filed: 10/o9/ol 12 Plaintiff, Trial Date: not set 13 vs. 14 PETCO ANIMAL SUPPLIES STORES, NOTICE OF MOTION AND MOTION INC.; and DOES 1-50, inclusive, TO COMPEL INITIAL RESPONSES 15 TO SPECIAL INTERROGATORIES, Defendants. SET ONE; MEMORANDUM OF 16 POINTS AND AUTHORITIES 17 Date: January 4, 2023 Time: 1:30 p.m. 18 Dept.: 27 Reservation No.: 308133453189 19 20 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 21 PLEASE TAKE NOTICE that on January 4, 2023, at 1:30 p.m. in Department 22 27, located at 312 N spring Street, Los Angeles, California, defendant, Petco Animal 23 Supplies Stores, Inc., moves this Court for an order compelling Plaintiff, Annie 24 Gombeaud responses to Defendant's special interrogatories, set one and requiring that 25 Annie Gombeaud and Plaintiffs counsel, Hesam Yazdanpanah, jointly and severally, pay 26 sanctions in the sum of $ 540.00. 27 This motion is made pursuant to Code of Civil Procedure section 2030.010, el. seq., 28 on the grounds that Defendant served Annie Gombeaud with special interrogatories, set I NOTICE OF MOTION AND MOTION TO COMPEL INTERROGATORIES, MEMORANDUM OF POINTS AND AUTHORITIES