On May 24, 2019 a
Party Discovery
was filed
involving a dispute between
Bautista Sergio,
and
City Of Los Angeles,
Los Angeles World Airports,
for Premise Liability (e.g., dangerous conditions of property, slip/trip and fall, dog attack, etc.) (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 06/21/2022 12:05 AM Sherri R. Carter, Executive Officer/Clerk of Court, by L. Coreas,Deputy Clerk
1 Ann M. Asiano, Esq. (SBN 094891)
David H. You, Esq. (SBN 282106)
2 Victoria A. Koenitzer (SBN 322131) [No filing fee required
CLARK HILL LLP pursuant to Government
3 555 South Flower Street, 24th Floor Code]
Los Angeles, California 90071
4 Telephone: (213) 891-9100
Facsimile: (213) 488-1178
5 AAsiano@clarkhill.com
DYou@clarkhill.com
6 VKoenitzer@clarkhill.com
7 Attorneys for Defendants
CITY OF LOS ANGELES,
8 LOS ANGELES WORLD AIRPORTS, A Public Entity
9
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10
COUNTY OF LOS ANGELES
11
SERGIO BAUTISTA, an individual, Case No.: 19STCV18168
12
Plaintiff, DEFENDANTS CITY OF LOS ANGELES
13 AND LOS ANGELES WORLD AIRPORTS’
v. OPPOSITION TO PLAINTIFF’S MOTION
14 TO COMPEL FURTHER RESPONSES RE:
CITY OF LOS ANGELES; LOS ANGELES SPECIAL INTERROGATORIES
15 WORLD AIRPORT and DOES 1 to 10, inclusive,
16 Defendants. Date: July 1, 2022
Time: 1:30 p.m.
17 Dept.: 29
18 Reservation # 726884149666
19 TO PLAINTIFF AND HIS ATTORNEY OF RECORD:
20 Defendants Los Angeles World Airports and City of Los Angeles (“Defendants” or “LAWA”),
21 by and through their attorneys of record, hereby file the following Opposition to Plaintiff’s Motion to
22 Compel Further Responses to Special Interrogatories. Defendants further request that sanctions be
23 awarded in their favor in the amount of $5,520 against Plaintiff and his attorney.
24 The Opposition is based on the following: Plaintiff’s requests were objectionable and
25 Defendants’ objections were meritorious and well-taken. Further, sanctions should be awarded against
26 Plaintiff for bringing the subject motion because Plaintiff’s claims are unmeritorious; Defendants’
27 objections and responses were justified and Plaintiff’s motion is unjustified.
28
1
DEFENDANTS OPPOSITION TO PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES RE:
SPECIAL INTERROGATORIES, SET ONE
267594250
Document Filed Date
June 21, 2022
Case Filing Date
May 24, 2019
Category
Premise Liability (e.g., dangerous conditions of property, slip/trip and fall, dog attack, etc.) (General Jurisdiction)
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Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 06/21/2022 12:05 AM Sherri R. Carter, Executive Officer/Clerk of Court, by L. Coreas,Deputy Clerk 1 Ann M. Asiano, Esq. (SBN 094891) David H. You, Esq. (SBN 282106) 2 Victoria A. Koenitzer (SBN 322131) [No filing fee required CLARK HILL LLP pursuant to Government 3 555 South Flower Street, 24th Floor Code] Los Angeles, California 90071 4 Telephone: (213) 891-9100 Facsimile: (213) 488-1178 5 AAsiano@clarkhill.com DYou@clarkhill.com 6 VKoenitzer@clarkhill.com 7 Attorneys for Defendants CITY OF LOS ANGELES, 8 LOS ANGELES WORLD AIRPORTS, A Public Entity 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF LOS ANGELES 11 SERGIO BAUTISTA, an individual, Case No.: 19STCV18168 12 Plaintiff, DEFENDANTS CITY OF LOS ANGELES 13 AND LOS ANGELES WORLD AIRPORTS’ v. OPPOSITION TO PLAINTIFF’S MOTION 14 TO COMPEL FURTHER RESPONSES RE: CITY OF LOS ANGELES; LOS ANGELES SPECIAL INTERROGATORIES 15 WORLD AIRPORT and DOES 1 to 10, inclusive, 16 Defendants. Date: July 1, 2022 Time: 1:30 p.m. 17 Dept.: 29 18 Reservation # 726884149666 19 TO PLAINTIFF AND HIS ATTORNEY OF RECORD: 20 Defendants Los Angeles World Airports and City of Los Angeles (“Defendants” or “LAWA”), 21 by and through their attorneys of record, hereby file the following Opposition to Plaintiff’s Motion to 22 Compel Further Responses to Special Interrogatories. Defendants further request that sanctions be 23 awarded in their favor in the amount of $5,520 against Plaintiff and his attorney. 24 The Opposition is based on the following: Plaintiff’s requests were objectionable and 25 Defendants’ objections were meritorious and well-taken. Further, sanctions should be awarded against 26 Plaintiff for bringing the subject motion because Plaintiff’s claims are unmeritorious; Defendants’ 27 objections and responses were justified and Plaintiff’s motion is unjustified. 28 1 DEFENDANTS OPPOSITION TO PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES RE: SPECIAL INTERROGATORIES, SET ONE 267594250