Party Statement: ALAN LABOSSIERE, ET AL. VS BRAILE INSTITUTE OF AMERICA, INC., A CORPORATION

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 04/27/2020 02:56 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Lopez,Deputy Clerk




                      1             Marc A. Trachtman, Esq. [SBN 167820]
                                    Timothy M. Smith, Esq. [SBN 125534]
                      2             TRACHTMAN & TRACHTMAN, LLP
                                      19732 MacArthur Blvd., Suite 100
                      3                       Irvine, CA 92612
                                         Telephone: (949) 282-0100
                      4                   Facsimile: (949) 282-0111

                      5      Attorneys for Defendant BRAILLE INSTITUTE
                             OF AMERICA, INC. (erroneously sued as BRAILE
                      6      INSTITUTE OF AMERICA, INC.)
                      7
                      8                                 SUPERIOR COURT OF THE STATE OF CALIFORNIA

                      9                                                       COUNTY OF LOS ANGELES

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                    11       ALAN LABOSSIERE, individual and as                                      CASE NO.: 19STCV40743
                             a successor in interest to Thelma
                    12       Labossiere; ANNETTE LEITZKE,                                            [Assigned for All Purposes to
                    13       individually and as a successor in                                      Hon. Kristin S. Escalante, Department 2]
                             interest to Thelma Labossiere;
                    14       ESTATE OF LABOSSIERE, by and                                            SEPARATE STATEMENT OF
                             through its successors in interest, Alan                                REQUESTS FOR ADMISSION AND
                    15       Labossiere and Annette Leitzke;                                         OBJECTIONS BY PLAINTIFFS THAT
                    16                                                                               ARE IN DISPUTE
                                                    Plaintiffs,
                    17                                                                               DATE:                  June 10, 2020
                                        vs.                                                          TIME:                  10:00 a.m.
                    18                                                                               DEPT.:                 29
                    19       BRAILE INSTITUTE OF AMERICA,
                             INC., a corporation; DOES 1 to 50,                                      RESERVATION NO. 000867022368
                    20       Inclusive,
                                                                                                     COMPLAINT FILED:                              11/12/19
                    21                              Defendants.                                      TRIAL DATE:                                   05/11/21
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                    25                  Defendant BRAILLE INSTITUTE OF AMERICA, INC. submits the following

                    26       Separate Statement in Support of its Motion for an order compelling Plaintiffs ALAN

                    27       LABOSSIERE and ANNETTE LEITZKE (“Plaintiffs”) to produce responsive information

                    28       in response to Requests for Admission, Set One.
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                                                      SEPARATE STATEMENT OF REQUESTS FOR ADMISSION AND
                                                          OBJECTIONS BY PLAINTIFFS THAT ARE IN DISPUTE