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NAME AND ADDRESS OF ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NUMBER Reserved for Clei’s File Stamp
Rona Eli (SBN 326093)
Angelica A. Zabanal (SBN 303329)
‘Duane Morris LLP
Electronically FILED b
885 S. Figueroa Street, Suite 3100 Superior Court of Cali fornia,
Los Angeles, CA 90017 County of Los Angeles
FAX NO.: 213-689-7401 4/05/2023 11:32 AM
TELEPHONE NO.: 213-689-7443 David W. Sla
E-MAIL ADDRESS: Executive O' icer/Clerk of Court,
reli@duanemorris.com By A. Trinh, Deputy Clerk
ATTORNEY FOR (Name): CIT GROUP, INC., CIT BANK, N.A., ONE WEST BANK
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
COURTHOUSE ADDRESS:
Spring Street Courthouse, 312 N. Spring Street, Los Angeles, CA 90012
PLAINTIFF:
HOVANNES KIRAMITTCHIAN
DEFENDANT:
CITY OF LOS ANGELES, et al.
INFORMAL DISCOVERY CONFERENCE FORM FOR CASE NUMBER:
PERSONAL INJURY COURTS CRS: 126662506593
(Department 27, 28, 29, 30, 31, 32) 20STCV03111
AN INFORMAL DISCOVERY CONFERENCE (‘IDC’) HAS BEEN RESERVED IN DEPARTMENT:
027, m2s, (129, L130, 131, 32 on 04/27/2023 at 14:30 v AM/ PM.
Type of case: ([] Auto [s] Slip/Trip & Fall [] Med Mal [] Product Liability [1] Assault & Battery
Other (please describe):
You must file and serve this Informal Discovery Conference Form no later than 15 court days prior
to the IDC. The opposing party may file and serve a responsive IDC Form, briefly setting forth that
party’s response, at least 10 court days prior to the IDC.
Briefly describe the discovery dispute (information requested and/or the basis for objection) in the
space provided below (do not add extra pages):
On 9/27/22, Defendant CIT GROUP INC., CIT BANK, N.A., and ONEWEST BANK, all of which are n/k/a First-Citizens
Bank & Trust Company ("Defendant"), served on Plaintiff the following discovery: Form Interrogatories, Set One;
Special Interrogatories, Set One; and Requests for Production of Documents, Set One. Plaintiff did not provide any
responses, which were due on November 1, 2022. The 12 Special Interrogatories requested the following: 1) IDENTIFY
the name of each PERSON answering these interrogatories, supplying information, or in any way assisting with the
preparation of these answers; 2) If YOU contend that a dangerous condition existed on the SUBJECT PROPERTY,
please state all facts that support YOUR contention; 3) If YOU contend that a dangerous condition on the SUBJECT
PROPERTY caused the INCIDENT, please state all facts that support YOUR contention; 4) If YOU contend that a
dangerous condition on the SUBJECT PROPERTY caused the INCIDENT, please IDENTIFY all PERSONS who have
knowledge of any facts that support YOUR contention; 5) For each PERSON identified in YOUR response to SPECIAL
INTERROGATORY NO. 4, state all facts known to that PERSON that support YOUR contention; 6) If YOU contend
that DEFENDANT are liable for dangerous conditions on the SUBJECT PROPERTY, please state all facts that support
YOUR contention; 7) If YOU contend that DEFENDANT owe YOU a legal duty, please state all facts that support
YOUR contention; 8) State all facts that support the cause of action for negligence against DEFENDANT as alleged in
the FAC; 9) State all facts that support the cause of action for premises liability against DEFENDANT as alleged in the
FAC; 10) State the dollar amount for YOUR claim for damages, including, but not limited to, medical and related
expenses, lost wages, loss of earning capacity, property damage, loss of use of property as alleged against
DEFENDANT in the FAC; 11) IDENTIFY all DOCUMENT that support YOUR damages, including, but not limited to,
medical and related expenses, lost wages, loss of earning capacity, property damage, loss of use of property as
alleged against DEFENDANT in the FAC; 12) State all facts supporting YOUR claim that DEFENDANT owned,
operated, maintained, managed, entrusted, and/or controlled the SUBJECT PROPERTY. The 19 Requests for
INFORMAL DISCOVERY CONFERENCE
LASC CIV 239 Rev. 10/24 FORM FOR PERSONAL INJURY COURTS Page 1 of 2
For Optional Use
(Department 27, 28, 29, 30, 31, 32)
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NAME AND ADDRESS OF ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NUMBER Reserved for Clei’s File Stamp Rona Eli (SBN 326093) Angelica A. Zabanal (SBN 303329) ‘Duane Morris LLP Electronically FILED b 885 S. Figueroa Street, Suite 3100 Superior Court of Cali fornia, Los Angeles, CA 90017 County of Los Angeles FAX NO.: 213-689-7401 4/05/2023 11:32 AM TELEPHONE NO.: 213-689-7443 David W. Sla E-MAIL ADDRESS: Executive O' icer/Clerk of Court, reli@duanemorris.com By A. Trinh, Deputy Clerk ATTORNEY FOR (Name): CIT GROUP, INC., CIT BANK, N.A., ONE WEST BANK SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES COURTHOUSE ADDRESS: Spring Street Courthouse, 312 N. Spring Street, Los Angeles, CA 90012 PLAINTIFF: HOVANNES KIRAMITTCHIAN DEFENDANT: CITY OF LOS ANGELES, et al. INFORMAL DISCOVERY CONFERENCE FORM FOR CASE NUMBER: PERSONAL INJURY COURTS CRS: 126662506593 (Department 27, 28, 29, 30, 31, 32) 20STCV03111 AN INFORMAL DISCOVERY CONFERENCE (‘IDC’) HAS BEEN RESERVED IN DEPARTMENT: 027, m2s, (129, L130, 131, 32 on 04/27/2023 at 14:30 v AM/ PM. Type of case: ([] Auto [s] Slip/Trip & Fall [] Med Mal [] Product Liability [1] Assault & Battery Other (please describe): You must file and serve this Informal Discovery Conference Form no later than 15 court days prior to the IDC. The opposing party may file and serve a responsive IDC Form, briefly setting forth that party’s response, at least 10 court days prior to the IDC. Briefly describe the discovery dispute (information requested and/or the basis for objection) in the space provided below (do not add extra pages): On 9/27/22, Defendant CIT GROUP INC., CIT BANK, N.A., and ONEWEST BANK, all of which are n/k/a First-Citizens Bank & Trust Company ("Defendant"), served on Plaintiff the following discovery: Form Interrogatories, Set One; Special Interrogatories, Set One; and Requests for Production of Documents, Set One. Plaintiff did not provide any responses, which were due on November 1, 2022. The 12 Special Interrogatories requested the following: 1) IDENTIFY the name of each PERSON answering these interrogatories, supplying information, or in any way assisting with the preparation of these answers; 2) If YOU contend that a dangerous condition existed on the SUBJECT PROPERTY, please state all facts that support YOUR contention; 3) If YOU contend that a dangerous condition on the SUBJECT PROPERTY caused the INCIDENT, please state all facts that support YOUR contention; 4) If YOU contend that a dangerous condition on the SUBJECT PROPERTY caused the INCIDENT, please IDENTIFY all PERSONS who have knowledge of any facts that support YOUR contention; 5) For each PERSON identified in YOUR response to SPECIAL INTERROGATORY NO. 4, state all facts known to that PERSON that support YOUR contention; 6) If YOU contend that DEFENDANT are liable for dangerous conditions on the SUBJECT PROPERTY, please state all facts that support YOUR contention; 7) If YOU contend that DEFENDANT owe YOU a legal duty, please state all facts that support YOUR contention; 8) State all facts that support the cause of action for negligence against DEFENDANT as alleged in the FAC; 9) State all facts that support the cause of action for premises liability against DEFENDANT as alleged in the FAC; 10) State the dollar amount for YOUR claim for damages, including, but not limited to, medical and related expenses, lost wages, loss of earning capacity, property damage, loss of use of property as alleged against DEFENDANT in the FAC; 11) IDENTIFY all DOCUMENT that support YOUR damages, including, but not limited to, medical and related expenses, lost wages, loss of earning capacity, property damage, loss of use of property as alleged against DEFENDANT in the FAC; 12) State all facts supporting YOUR claim that DEFENDANT owned, operated, maintained, managed, entrusted, and/or controlled the SUBJECT PROPERTY. The 19 Requests for INFORMAL DISCOVERY CONFERENCE LASC CIV 239 Rev. 10/24 FORM FOR PERSONAL INJURY COURTS Page 1 of 2 For Optional Use (Department 27, 28, 29, 30, 31, 32)