Motion,Ex Parte: BELLA ROSSAL BY AND THROUGH HER GUARDIAN AD LITEM JACQUELINE GARCIA VS CITY OF BURBANK, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 12/30/2020 02:48 PM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Ismael,Deputy Clerk




              1     John W. Evans, (SBN 100654)                                                                                      (SPACE BELOW FOR FILING STAMP ONLY)
                    LIEBMAN, QUIGLEY & SHEPPARD                                                                      [Exempt from filing fee under Government Code Section 6103]
              2     A PROFESSIONAL LAW CORPORATION
                       3255 WILSHIRE BOULEVARD
              3               SUITE 1200
                    LOS ANGELES, CALIFORNIA 90010-1404
              4               (213) 387-0777
                    Facsimile: (213) 383-6754
              5
                    Attorneys for Defendant
              6     BURBANK UNIFIED SCHOOL DISTRICT (A Public Entity)

              7
                                                    SUPERIOR COURT OF THE STATE OF CALIFORNIA
              8
                                                                 FOR THE COUNTY OF LOS ANGELES
              9
            10
                    BELLA ROSSAL, by and through her                                               CASE NO.               20STCV12022
            11      guardian ad litem JACQUELINE GARCIA,
                                                                                                   [Assigned for All Purposes to the Honorable
            12                             Plaintiff,                                              Thomas D. Long; Dept. "31"]

            13      v.                                                                             NOTICE OF MOTION AND MOTION TO HAVE
                                                                                                   REQUESTS FOR ADMISSION (SET NO. 1)
            14      CITY OF BURBANK; BURBANK UNIFIED)                                              DEEMED ADMITTED;
                    SCHOOL DISTRICT; and DOES 1 to 100,
            15      Inclusive,                                                                     REQUEST FOR MONETARY SANCTIONS
                                                                                                   AGAINST PLAINTIFF IN THE AMOUNT OF
            16                                                                                     $675.00;
                                           Defendants.                                      )
                                                                                                   DECLARATION OF JOHN W. EVANS;
                    -----------------------~
            17

            18                                                                                     MEMORANDUM OF POINTS AND AUTHORITIES
                                                                                                   IS SUPPORT THEREOF;
            19
                                                                                                   ORDER [PROPOSED]
            20
                                                                                                   DATE:                              March 22, 2021
            21                                                                                     TIME:                              8:30a.m.
                                                                                                   DEPT.:                             "31"
            22
                                                                                                   ID RESERVATION: 419602890365
            23
            24      TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:
            25                  PLEASE TAKE NOTICE that on March 22, 2021,                                                          at 8:30 a.m. or as soon
            26      thereafter as counsel may be heard in Department "31" of the above-entitled court located at
            27      312 North Spring Street, Los Angeles, California, Defendant BURBANK UNIFIED SCHOOL

            28      DISTRICT, A Public Entity ("BUSD") will move the Court for an order deeming admitted the

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                                     NOTICE OF MOTION AND MOTION TO HAVE REQUESTS FOR ADMISSION (SET N0.1)
                                                       DEEMED ADMITTED AGAINST PLAINTIFF