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  • ANN TURKEL VS JIM FALK MOTORS OF BEVERLY HILLS, INC., ET AL. Fraud (no contract) (General Jurisdiction) document preview
  • ANN TURKEL VS JIM FALK MOTORS OF BEVERLY HILLS, INC., ET AL. Fraud (no contract) (General Jurisdiction) document preview
						
                                

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1 Monica L. Hartsock, SBN 270114 Colin Welch, SBN 314103 2 LAW OFFICE OF MONICA L. HARTSOCK 3 4562 Hastings Ct. Chino, CA 91710 4 Telephone: 909-536-1773 Monica@HartsockLawFirm.com 5 Attorneys for Plaintiff, 6 Ann Turkel 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 FOR THE COUNTY OF LOS ANGELES 9 10 ANN TURKEL, an individual Case No. 20STCV43369 11 Plaintiff, Assigned for all purposes to Department 50 Judge 12 Beaudet v. 13 NOTICE OF MOTION AND SECOND JIM FALK MOTORS OF BEVERLY MOTION FOR SANCTIONS INCLUDING 14 HILLS, INC., a California Corporation; TERMINATING SANCTIONS, AND TOYOTA MOTOR CREDIT EVIDENCE SANCTIONS, INCLUDING A 15 CORPORATION, dba LEXUS JURY INSTRUCTIONS UPON WILLFUL FINANCIAL SERVICES; and DOES 1 16 SUPPRESSION OF EVIDENCE FOR through 10, inclusive, FAILURE TO OBEY COURT ORDERS; 17 MEMORANDUM IN SUPPORT; AND Defendants. DECLARATION OF MONICA HARTSOCK 18 (Separate Statement filed concurrently) 19 Reservation ID: 097358299376 20 Hearing Date: November 1, 2023 Time: 10:00 a.m. 21 Complaint Filed: November 11, 2020 22 Trial: April 12, 2023 23 TO EACH PARTY AND TO THE COUNSEL OF RECORD FOR EACH PARTY: 24 YOU ARE HEREBY NOTIFIED THAT on November 1, 2023 at 10:00 a.m. in 25 Department 50 of this Court located at 111 North Hill Street, Los Angeles, 90012, Plaintiff Ann 26 Turkel moves the Court for an order imposing evidence sanctions, and ordering that a willful 27 suppression of evidence jury instruction be read to the jury. 28 This Court ordered Defendant Jim Falk Motors of Beverly Hills, Inc. to produce the NOTICE OF MOTION AND MOTION FOR ISSUE SANCTIONS, EVIDENCE SANCTIONS AND JURY INSTRUCTION