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NAME AND ADDRESS OF ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NUMBER Reserved for Clerk’s File Stamp
Ann M. Asiano, Esq.; Victoria A. Koenitzer, Esq. 322131
600 West Broadway, Suite 500
San Diego, CA 92101
TELEPHONE NO.: 619-819-2412 FAX NO.: 619-557-0460
E-MAIL ADDRESS: vkoenitzer@clarkhill.com
ATTORNEY FOR (Name): Defendants City of LA; LAWA
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
COURTHOUSE ADDRESS:
Spring Street Courthouse, 312 N. Spring Street, Los Angeles, CA 90012
PLAINTIFF:
Sergio Bautista
DEFENDANT:
City of Los Angeles; Los Angeles World Airports
CASE NUMBER:
INFORMAL DISCOVERY CONFERENCE FORM FOR
PERSONAL INJURY COURTS
(Department 27, 28, 29, 30, 31, 32) 19STCV18168
AN INFORMAL DISCOVERY CONFERENCE (“IDC”) HAS BEEN RESERVED IN DEPARTMENT.
□ 27, □ 28, [!] 29, □ 30, □ 31, 32 on ____________
06/30/2022 at 11
_______ AM/ PM.
1. Type of case:
□ Auto Slip/Trip & Fall
□ Med Mal □ Product Liability □ Assault & Battery
Electronically Received 06/09/2022 05:01 PM
Other (please describe):___________________________________________________________.
2. 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.
3. Briefly describe the discovery dispute (information requested and/or the basis for objection) in the
space provided below (do not add extra pages):
Plaintiff filed a Motion to Compel Further Responses to Request for Production of Documents, Set One, requesting that
the Court compel responses to request nos. 1-85, including Defendants' substantive responses.
Plaintiff filed a Motion to Compel Further Responses to Request for Admissions, Set One and Form Interrogatory 17.1,
Set One, requesting that the Court compel responses to Request for Admissions Nos. 2, 3, 7-9, 11-26, 30, 32, and 35,
as well as Form Interrogatories No. 17.1.
Plaintiff filed a Motion to Compel Further Responses to Special Interrogatories, Set One, requesting that the Court
compel responses to Special Interrogatories Nos. 2, 20-24, 26-33, and 38-48.
Plaintiff's requests are improper and unintelligible. Plaintiff does not address the issues in his Informal Discovery
Conference Statement; it does not discuss a single request or interrogatory. Instead, it details the discovery timeline
and meet and confer process, which are not the subject of the Informal Discovery Conference, nor productive in
resolving the discovery disputes.
Plaintiff's discovery requests are improper and impossible to respond to. For example, Plaintiff's Request for
Admissions No. 14 requests that Defendants "[a]dmit that regarding the BATHROOM, always displayed a yellow plastic
caution sign in the BATHROOM because the BATHROOM had a high volume of traffic and the floor often gets wet, is
NOT sufficient to make the wet BATHROOM floor safe for use by the public." This request is compound, assumes
facts not in evidence, lacks foundation, incomplete hypothetical, overbroad, and not reasonably calculated to lead to
the discovery of admissible evidence, among others. This is iunintelligible, including with grammar.
INFORMAL DISCOVERY CONFERENCE
LASC CIV 239 Rev. 10/21
For Optional Use FORM FOR PERSONAL INJURY COURTS Page 1 of 2
(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 Clerk’s File Stamp Ann M. Asiano, Esq.; Victoria A. Koenitzer, Esq. 322131 600 West Broadway, Suite 500 San Diego, CA 92101 TELEPHONE NO.: 619-819-2412 FAX NO.: 619-557-0460 E-MAIL ADDRESS: vkoenitzer@clarkhill.com ATTORNEY FOR (Name): Defendants City of LA; LAWA SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES COURTHOUSE ADDRESS: Spring Street Courthouse, 312 N. Spring Street, Los Angeles, CA 90012 PLAINTIFF: Sergio Bautista DEFENDANT: City of Los Angeles; Los Angeles World Airports CASE NUMBER: INFORMAL DISCOVERY CONFERENCE FORM FOR PERSONAL INJURY COURTS (Department 27, 28, 29, 30, 31, 32) 19STCV18168 AN INFORMAL DISCOVERY CONFERENCE (“IDC”) HAS BEEN RESERVED IN DEPARTMENT. □ 27, □ 28, [!] 29, □ 30, □ 31, 32 on ____________ 06/30/2022 at 11 _______ AM/ PM. 1. Type of case: □ Auto Slip/Trip & Fall □ Med Mal □ Product Liability □ Assault & Battery Electronically Received 06/09/2022 05:01 PM Other (please describe):___________________________________________________________. 2. 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. 3. Briefly describe the discovery dispute (information requested and/or the basis for objection) in the space provided below (do not add extra pages): Plaintiff filed a Motion to Compel Further Responses to Request for Production of Documents, Set One, requesting that the Court compel responses to request nos. 1-85, including Defendants' substantive responses. Plaintiff filed a Motion to Compel Further Responses to Request for Admissions, Set One and Form Interrogatory 17.1, Set One, requesting that the Court compel responses to Request for Admissions Nos. 2, 3, 7-9, 11-26, 30, 32, and 35, as well as Form Interrogatories No. 17.1. Plaintiff filed a Motion to Compel Further Responses to Special Interrogatories, Set One, requesting that the Court compel responses to Special Interrogatories Nos. 2, 20-24, 26-33, and 38-48. Plaintiff's requests are improper and unintelligible. Plaintiff does not address the issues in his Informal Discovery Conference Statement; it does not discuss a single request or interrogatory. Instead, it details the discovery timeline and meet and confer process, which are not the subject of the Informal Discovery Conference, nor productive in resolving the discovery disputes. Plaintiff's discovery requests are improper and impossible to respond to. For example, Plaintiff's Request for Admissions No. 14 requests that Defendants "[a]dmit that regarding the BATHROOM, always displayed a yellow plastic caution sign in the BATHROOM because the BATHROOM had a high volume of traffic and the floor often gets wet, is NOT sufficient to make the wet BATHROOM floor safe for use by the public." This request is compound, assumes facts not in evidence, lacks foundation, incomplete hypothetical, overbroad, and not reasonably calculated to lead to the discovery of admissible evidence, among others. This is iunintelligible, including with grammar. INFORMAL DISCOVERY CONFERENCE LASC CIV 239 Rev. 10/21 For Optional Use FORM FOR PERSONAL INJURY COURTS Page 1 of 2 (Department 27, 28, 29, 30, 31, 32)