On May 24, 2019 a
Party Statement
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 11/29/2021 12:45 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Lopez,Deputy Clerk
1 Steve A. Hoffman, Esq., SBN 136959
4929 Wilshire Boulevard, Suite 410
2 Los Angeles, CA 90010,
Telephone: 323) 997-1188
3 Facsimile 323) 937-1539
E: hoffpiasbcg obal.net
4
Attorneys for Plaintiff SERGIO BAUTISTA
5
6
7 SUPERIOR COURT OF THE STATE OF CALIFORNIA
8 FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT
9
10 SERGIO BAUTISTA, Case No. 19STCV18168
11 Plaintiffs,
Unlimited Jurisdiction
12 VS.
Assigned for All Purposes to
13 CITY OF LOS ANGELES; LOS ANGELES Hon. Serena Murillo, Dept. 29
WORLD AIRPORT and DOES 1 to 10,
14 inclusive PLAINTIFF'S SEPARATE
STATEMENT IN SUPPORT OF
15 Defendants. MOTION TO COMPEL Re: SPECIAL
INTERROGATORIES
16
RESERVATION ID 726884149666
17
Date: 7/1/22
18 Time: 1:30 p.m.
Dept: 29
19
Plaintiff hereby submits the following Separate Statement In Support of Motion To
20
Compel Re: First Set of Special Interrogatories:
21
Defendant's evasive, boilerplate objections to SPECIAL INTERROGATORIES are
22
improper and constitute a blatant, bad faith abuse of discovery, purely for the purpose of delaying
23
and frustrating discovery.
24
SPECIAL INTERROGATORY No. 2 :
25
If, during the past 10 years, anyone was injured or has claimed to have been injured
26
'
anywhere within the BATHROOM, please identify each and every fact which evidences or refers
27
to said accidents, including the dates, persons, claims, lawsuits and circumstances which relate to
28
-1-
PLAINTIFF'S SEPARATE STATEMENT IN SUPPORT OF MOTION TO
COMPEL Re: SPECIAL INTERROGATORIES
Document Filed Date
November 29, 2021
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 11/29/2021 12:45 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Lopez,Deputy Clerk 1 Steve A. Hoffman, Esq., SBN 136959 4929 Wilshire Boulevard, Suite 410 2 Los Angeles, CA 90010, Telephone: 323) 997-1188 3 Facsimile 323) 937-1539 E: hoffpiasbcg obal.net 4 Attorneys for Plaintiff SERGIO BAUTISTA 5 6 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT 9 10 SERGIO BAUTISTA, Case No. 19STCV18168 11 Plaintiffs, Unlimited Jurisdiction 12 VS. Assigned for All Purposes to 13 CITY OF LOS ANGELES; LOS ANGELES Hon. Serena Murillo, Dept. 29 WORLD AIRPORT and DOES 1 to 10, 14 inclusive PLAINTIFF'S SEPARATE STATEMENT IN SUPPORT OF 15 Defendants. MOTION TO COMPEL Re: SPECIAL INTERROGATORIES 16 RESERVATION ID 726884149666 17 Date: 7/1/22 18 Time: 1:30 p.m. Dept: 29 19 Plaintiff hereby submits the following Separate Statement In Support of Motion To 20 Compel Re: First Set of Special Interrogatories: 21 Defendant's evasive, boilerplate objections to SPECIAL INTERROGATORIES are 22 improper and constitute a blatant, bad faith abuse of discovery, purely for the purpose of delaying 23 and frustrating discovery. 24 SPECIAL INTERROGATORY No. 2 : 25 If, during the past 10 years, anyone was injured or has claimed to have been injured 26 ' anywhere within the BATHROOM, please identify each and every fact which evidences or refers 27 to said accidents, including the dates, persons, claims, lawsuits and circumstances which relate to 28 -1- PLAINTIFF'S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL Re: SPECIAL INTERROGATORIES