Party Discovery: Goetz VS Glaxo Smith Kline, LLC

• 
• 
• 
• 

						
                                
Preview
                                1       R. Brent Wisner, Esq. (SBN: 276023)
         rbwisner@wisnerbaum.com
 2       WISNER BAUM, LLP
         100 Drakes Landing Rd., Suite 160
 3       Greenbrae, CA 94904
         Telephone: (310) 207-3233
 4       Facsimile: (310) 820-7444
 5       Jennifer A. Moore (SBN: 206779)
         jennifer@moorelawgroup.com
 6       Andie B. Camden (admitted PHV)
         andie@moorelawgroup.com
 7       Ashton R. Smith (admitted PHV)
         ashton@moorelawgroup.com
 8       MOORE LAW GROUP, PLLC
         1473 South 4th Street
 9       Louisville, KY 40208
         Telephone: (502) 717-4080
10       Facsimile: (502) 717-4086
11
         Counsel for Plaintiffs
12                           SUPERIOR COURT OF THE STATE OF CALIFORNIA
13                                      COUNTY OF ALAMEDA

14       COORDINATION PROCEEDING SPECIAL                          JCCP NO. 5150
         TITLE (Rule 3.550)
15                                                                Hon. Evelio M. Grillo
         RANITIDINE PRODUCTS CASES                                Department 21
16
                                                                  PLAINTIFF'S ADDITIONAL SEPARATE
17       THIS DOCUMENT RELATES TO:                                STATEMENT OF UNCONTROVERTED
                                                                  FACTS IN SUPPORT OF PLAINTIFFS’
18       Goetz v. GlaxoSmithKline, LLC, et al.,                   OMNIBUS OPPOSITION TO GSK’S
         Case No. RG20061705                                      MOTIONS FOR SUMMARY ADJUDICATION
19
                                                                  [REDACTED PUBLIC VERSION]
20
                                                                  [Plaintiff’s Opposition to GSK’s Motions for
21                                                                Summary Judgment; Plaintiff’s Statement of
                                                                  Genuine Disputes of Material Facts; Declaration of
22                                                                James Goetz and Declaration of R. Brent Wisner
                                                                  filed concurrently]
23
                                                                  Hearing Date:        February 23, 2023
24                                                                Hearing Time:        10:00 a.m.
                                                                  Department:          21
25                                                                Reservation ID:      169002324509, 451650344613,
                                                                                       1115319579191
26
     1
27     Pursuant to the January 26, 2023 First Amended Order regarding schedule for various pretrial deadlines for Goetz trial,
     these Motions will be heard on February 23, 2023. The above reservation ID’s are the original numbers for Defendants’
28   Motions at the time of filing.

         PLAINTIFF’S ADDITIONAL SEPARATE STATEMENT OF UNCONTROVERTED FACTS IN
         SUPPORT OF PLAINTIFFS’ OMNIBUS OPPOSITION TO GSK’S MOTIONS FOR SUMMARY
                                      ADJUDICATION
                                            1
                                             PROOF OF SERVICE
 1

 2   STATE OF CALIFORNIA, COUNTY OF ALAMEDA

 3           I am a resident and employed in the County of Los Angeles, State of California, over the age of
     18 and not a party to the within action or proceedings; my business address is 11111 Santa Monica
 4   Blvd., Suite 1750, Los Angeles, California 90025.
 5          On February 1, 2023, I served the following document(s):
 6
     PLAINTIFF'S ADDITIONAL SEPARATE STATEMENT OF UNCONTROVERTED FACTS
 7   IN SUPPORT OF PLAINTIFFS’ OMNIBUS OPPOSITION TO GSK DEFENDANTS’
     MOTIONS FOR SUMMARY ADJUDICATION [REDACTED PUBLIC VERSION]
 8
             on the interested parties and/or through their attorneys of record in this action by depositing
 9   the original or true copy thereof as designated below, at Los Angeles, California, addressed to the
     following:
10
     [X]    BY ELECTRONIC TRANSMISSION: I served each document via electronic transfer of
11
            the document file to Case Anywhere for service on all registered case users. Each document
12          electronically served pursuant to and in accordance with the Court’s Order (PTO No. 8)
            governing Case No. JCCP005150 Order authorizing all documents to be served via Electronic
13          Service upon interested parties via Case Anywhere and its litigation system.

14           I declare under penalty of perjury under the laws of the State of California that the above is
     true and correct.
15

16          Executed on February 1, 2023 at Los Angeles, California.

17

18                                                            Valeriya Adlivankina
19
20

21

22

23

24

25

26
27

28
      PLAINTIFF’S ADDITIONAL SEPARATE STATEMENT OF UNCONTROVERTED FACTS IN
      SUPPORT OF PLAINTIFFS’ OMNIBUS OPPOSITION TO GSK’S MOTIONS FOR SUMMARY
                                   ADJUDICATION
                                         2