Party Discovery: BRIANNA MAREESE JACOCKS, ET AL. VS ROBERT AARON WELLS, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 08/24/2021 04:31 PM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Briggs,Deputy Clerk



                           DANIELS, FINE, ISRAEL,
                   1       SCHONBUCH & LEBOVITS,                                LLP
                           1801 CENTURY PARK EAST, NINTH FLOOR
                           LOS ANGELES, CALIFORNIA 90067
                   2       TELEPHONE (310) 556-7900
                           FACSIMILE (310) 556-2807

                   3       Michael Schonbuch, State Bar No. 150884
                           Mary R. Fersch, State Bar No. 305855
                   4
                           Attorneys For Defendant
                   5       FIELDTURF USA, INC.

                   6
                                                          SUPERIOR COURT OF THE STATE OF CALIFORNIA
                   7
                                                     FOR THE COUNTY OF LOS ANGELES - NORTH DISTRICT
                   8

                   9
                           BRIANNA MAREESE JACOCKS, a minor by                                                Case No. 20AVCV00726
                 10        and through her Guardian ad Litem STANLEY                                          [Complaint Filed: October 8, 2020]
                           JACOCKS, KATIE FRANCIS JACOCKS, a                                                  [Hon. Wendy Chang, Dept. A15]
                 11        minor by and through her Guardian ad Litem
                           STANLEY JACOCKS, GENE DAVEYON                                                      DEFENDANT FIELDTURF USA, INC.'S
                 12        BERNIE JACOCKS, a minor by and through his                                         NOTICE OF MOTION AND MOTION TO
                           Guardian ad Litem STANLEY JACOCKS,                                                 COMPEL PLAINTIFFS' GUARDIAN AD
                 13        KRYSTOL RENEE MCDONALD, and KYIRA                                                  LITEM STANLEY JACOCKS' ANSWERS
                           RENEE MCDONALD,                                                                    TO DEPOSITION QUESTIONS;
                 14                                                                                           MEMORANDUM OF POINTS AND
                                                              Plaintiffs,                                     AUTHORITIES IN SUPPORT
                 15
                           v.                                                                                 [Filed concurrently with Declaration of Mary
                 16                                                                                           R. Fersch; Separate Statement and [Proposed]
                           ROBERT AARON WELLS, FIELDTURF USA,                                                 Order]
                 17        INC., and DOES 1 through 30, inclusive,
                                                                                                              Hearing Date: September 30, 2021
                 18                                           Defendants.                                     Time:         8:30 a.m.
                                                                                                              Dept:         A15
                 19                                                                                           RESERVATION NO. 591886713038
                 20

                 21                               TO ALL PARTIES, THEIR ATTORNEYS OF RECORD HEREIN AND TO THIS
                 22        HONORABLE COURT:
                 23                               PLEASE TAKE NOTICE that on September 30, 2021 at 8:30 a.m., or as soon
                 24        thereafter as the matter may be heard in Department A15 of the Los Angeles Superior Court located
                 25        at the Michael D. Antonovich Antelope Valley Courthouse, 42011 4th Street West, Lancaster, CA
                 26        93534, Defendant FIELDTURF USA, INC. (“Defendant”) will move the Court for an order
                 27

                 28                                                       1
                               ______________________________________________________________________________________
                             DEFENDANT FIELDTURF USA, INC.'S NOTICE OF MOTION AND MOTION TO COMPEL PLAINTIFFS'
                            GUARDIAN AD LITEM STANLEY JACOCKS' ANSWERS TO DEPOSITION QUESTIONS; MEMORANDUM
                                                      OF POINTS AND AUTHORITIES IN SUPPORT