Motion-Secondary: 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 07/21/2021 05:36 PM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Briggs,Deputy Clerk




                  1       DANIELS, FINE, ISRAEL,
                          SCHONBUCH & LEBOVITS,                                LLP
                          1801 CENTURY PARK EAST, NINTH FLOOR
                  2       LOS ANGELES, CALIFORNIA 90067
                          TELEPHONE (310) 556-7900
                          FACSIMILE (310) 556-2807
                  3       Michael Schonbuch, State Bar No. 150884
                          Mary R. Fersch, State Bar No. 305855
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                          Attorneys For Defendant
                  5       FIELD TURF USA, INC.
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                                                          SUPERIOR COURT OF THE STATE OF CALIFORNIA
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                                                     FOR THE COUNTY OF LOS ANGELES - NORTH DISTRICT
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                          BRIANNA MAREESE JACOCKS, a minor by                                                 Case No. 20AVCV00726
                11        and through her Guardian ad Litem STANLEY                                           [Complaint Filed: October 8, 2020]
                12        JACOCKS, KATIE FRANCIS JACOCKS, a                                                   [Hon. Wendy Chang, Dept. A15]
                          minor by and through her Guardian ad Litem
                13        STANLEY JACOCKS, GENE DAVEYON                                                       OPPOSITION TO PLAINTIFFS’ EX
                          BERNIE JACOCKS, a minor by and through his                                          PARTE APPLICATION TO CONTINUE
                14        Guardian ad Litem STANLEY JACOCKS,                                                  TRIAL AND FACT DISCOVERY AS TO
                          KRYSTOL RENEE MCDONALD, and KYIRA                                                   DEFENDANTS; DECLARATION OF
                15        RENEE MCDONALD,                                                                     MARY R. FERSCH
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                                                             Plaintiffs,
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                          v.
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                          ROBERT AARON WELLS, FIELDTURF USA,
                19        INC., and DOES 1 through 30, inclusive,
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                                                             Defendants.
                21

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                                                  COMES NOW Defendant FIELDTURF USA, INC. (“Defendant”), and hereby
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                          respectfully submits the following Memorandum of Points and Authorities in Opposition to
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                          Plaintiffs’ Ex Parte Application to Continue Trial and Fact Discovery as to Defendants. Defendant
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                          does not oppose Plaintiffs’ request asking for an order to continue trial by the statutory maximum
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                          of fourteen (14) days. However, Defendant takes issue with and opposes Plaintiffs’ apparent request
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                          for an outright one-sided waiver of the discovery cutoff as to Defendant only and all other requests
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                            OPPOSITION TO PLAINTIFFS’ EX PARTE APPLICATION TO CONTINUE TRIAL AND FACT DISCOVERY
                                               AS TO DEFENDANTS; DECLARATION OF MARY R. FERSCH