Motion-Secondary: JOSHUA CHOWAIKI VS REBEKAH ROUNDS

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 04/28/2021 11:22 AM Sherri R. Carter, Executive Officer/Clerk of Court, by L. Coreas,Deputy Clerk




           1     Michael Yadegari (SBN 286514)
                 Law Office of Yadegari & Associates
           2     287 South Robertson Blvd #221
                 Beverly Hills, CA 90211
           3     Telephone: (310) 779-9327
           4     Attorney for: PLAINTIFF
                 JOSHUA CHOWAIKI
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                                    IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
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                                                        FOR THE COUNTY OF LOS ANGELES
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                 JOSHUA CHOWAIKI, an individual                                          )   Case No.: 20STCV47185
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                 Plaintiff,                                                              )
           9                                                                             )
                                                                                         )   PLAINTIFF’S OPPOSITION TO
         10                 vs.                                                          )   DEFENDANT’S MOTION TO STRIKE
                                                                                         )   PLAINTIFF’S CLAIM
         11                                                                              )   FOR PUNITIVE DAMAGES
                  REBEKAH ROUNDSAND DOES 1-20                                            )
         12       inclusive;                                                             )
                                                                                         )
         13                                                                              )
                 Defendant.                                                              )
         14                                                                              )
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                            Plaintiff, hereby opposes Defendant’s motion to strike all or portions of Plaintiff’s claim
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                 for punitive damages.
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         19                 This opposition is based upon Defendant has failed to demonstrate how the pleading, or
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                 any of the alleged matters therein, are irrelevant, false, improper or not drawn in conformity with
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                 the laws of this State or in conformity with a court rule or order as mandated by Code of Civil
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         23      Procedure sections 435 and 436; Defendant improperly relies upon extrinsic evidence to support

         24      alleged grounds for striking the pleading; the motion is untimely pursuant to Code of Civil
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                 Procedure section 435(b)(1) and California Rules of Court, rule 3.1322(b); Defendant failed to
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                 cite the specific matter sought to be stricken as mandated by California Rules of Court, Rule
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                 3.1322(s), etc.




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