Motion-Secondary: MIRACLE FAITH DAVIS VS ALEX FERRAR MIGLIORINI, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 09/09/2021 12:31 PM Sherri R. Carter, Executive Officer/Clerk of Court, by C. Aquino,Deputy Clerk


                    1     LAW OFFICES OF JOHN A. HAUSER
                          By: OLIVER J. VASQUEZ (210174)
                    2     One Pointe Drive, 6th Floor
                    3     Brea, CA 92821
                          Phone: (714) 571-0407 / Fax: (877) 369-5799
                    4     Direct Line: (714) 371-2725
                          E-Mail: Oliver.Vasquez@thehartford.com
                    5     Mailing Address: P.O. Box 2282, Brea, CA 92822-2282
                    6
                          Attorneys for Defendant
                    7     MILK STUDIOS LOS ANGELES, LLC
                    8
                                                        SUPERIOR COURT OF THE STATE OF CALIFORNIA
                    9
                  10                                FOR THE COUNTY OF LOS ANGELES - SPRING STREET

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                            MIRACLE FAITH DAVIS, an individual,                                     CASE NO. 20STCV13119
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                                                   Plaintiff,                                       OPPOSITION TO PLAINTIFF’S EX
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                                                                                                    PARTE APPLICATION TO CONTINUE
                  14        vs.                                                                     TRIAL; MEMORANDUM OF POINTS
                                                                                                    AND AUTHORITIES; DECLARATION
                  15        ALEX FERRAR MIGLIORINI, an                                              OF OLIVER J. VASQUEZ
                            individual, MILK STUDIOS LOS
                  16
                            ANGELES, LLC, a business entity, and                                    DATE: September 10, 2021
                  17        DOES 1 to 20, inclusive,                                                TIME: 8:30 a.m.
                                                                                                    DEPT: 32
                  18                               Defendants.
                  19                                                                                Date Action Filed: 4/2/2020
                                                                                                    Trial Date: 09/30/2021
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                  21      TO: ALL PARTIES HEREIN AND TO THEIR ATTORNEYS OF RECORD:
                  22                  Defendant MILK STUDIOS LOS ANGELES, LLC hereby submits its opposition to
                  23      plaintiff’s Ex Parte Application to Continue Trial. The opposition is predicated on the fact that
                  24      plaintiff has failed to articulate justifiable grounds for a trial continuance and has done very little
                  25      towards the prosecution of the case.
                  26                  The opposition will be based upon this notice, upon the memorandum of points and
                  27      authorities and declaration of Oliver J. Vasquez served and filed herewith, upon all of the
                  28      pleadings and records contained in the court file herein, and upon such oral and documentary

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                                            OPPOSITION TO PLAINTIFF’S EX PARTE TO CONTINUE TRIAL