Preview
1 PETER SCHWARTZ (SBN: 109859)
pschwartz@grsm.com
2 DAVID L. JONES (SBN: 112307)
djones@grsm.com
3 CHRISTOPHER R. WAGNER (SBN: 162092)
cwagner@grsm.com
4 STEVEN R. INOUYE (SBN: 245024)
sinouye@grsm.com
5 GORDON REES SCULLY MANSUKHANI, LLP
633 West Fifth Street, 52nd Floor
6 Los Angeles, CA 90071
Telephone: (213) 576-5019
7 Facsimile: (213) 680-4470
8 Attorneys for Defendant,
FIRE INSURANCE EXCHANGE
9
10 SUPERIOR COURT OF CALIFORNIA
11 COUNTY OF SONOMA – HALL OF JUSTICE
Gordon Rees Scully Mansukhani, LLP
633 West Fifth Street, 52nd Floor
12 GARY KOOP, ) CASE NO. SCV-266944
[Assigned for All Purposes to Hon. Oscar A.
Los Angeles, CA 90071
)
13 Plaintiff, ) Pardo, Dept. 19]
)
14 vs. ) DEFENDANT FIRE INSURANCE
) EXCHANGE’S OBJECTIONS TO
15 FIRE INSURANCE EXCHANGE, dba EVIDENCE SUBMITTED IN
)
FARMERS INSURANCE GROUP; OPPOSITION TO PLAINTIFF’S
16 BRIAN HUNSAKER, ) MOTION FOR SUMMARY
) JUDGMENT AND/OR SUMMARY
17 Defendants. ) ADJUDICATION; AND [PROPOSED]
) ORDER
18 )
) Hearing Date: June 28, 2023
19 ) Time: 3:00 p.m.
) Dept: 19
20 )
) Complaint filed: August 24, 2020
21 Trial Date: November 8, 2023
22
23 Pursuant to California Rules of Court, rules 3.1352 and 3.1354, Defendant Fire Insurance
24 Exchange (“Fire”) hereby submit its objections to the evidence submitted by Plaintiff Gary Koop
25 (“Plaintiff”) in support of his motion for summary judgment or, alternatively, summary
26 adjudication:
27
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DEFENDANT FIRE INSURANCE EXCHANGE’S OBJECTIONS TO EVIDENCE
SUBMITTED IN OPPOSITION TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT
1 I. DECLARATION OF STACY TUCKER, ESQ.
2 A. STATEMENT:
3 “Farmers’ policies and procedures stated that the agent should not accept the assumptive
4 information input, but should check each item with the insured. It noted that if an estimate seemed
5 too low, it was likely due to the wrong quality grade being selected, and that the more expensive a
6 home, the more detail should be input to correctly insure it ”
7 (Tucker Dec. at ¶ 10.)
8 OBJECTIONS: This statement is objectionable because:
9 (a) It lacks foundation, and misstates evidence. (Evd. Code § 403.)
10 (b) The assertion constitutes inadmissible hearsay. (Cal. Evid. Code §
11 1200.)
Gordon Rees Scully Mansukhani, LLP
633 West Fifth Street, 52nd Floor
12
Los Angeles, CA 90071
13 COURT’S RULING: Sustained: ______________________________
14 Overruled: ______________________________
15
16 B. STATEMENT:
17 “On April 1, 2013, Farmers announced that the conversion for all policies to 360Value
18 would occur as of June 16, 2013. The notice explained that Dwelling Quality Grade would be
19 determined based on the Kitchen Quality Grade in RCT.”
20 (Tucker Dec. at ¶ 11.)
21 OBJECTIONS: This statement is objectionable because:
22 (a) It lacks foundation, and misstates evidence. (Evd. Code § 403.)
23 (b) The assertion constitutes inadmissible hearsay. (Cal. Evid. Code §
24 1200.)
25 (c) It is irrelevant because the quality grade of Plaintiff’s kitchen has
26 no bearing on the actual quality grade of his home. (Evd. Code
27 § 350.)
28
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DEFENDANT FIRE INSURANCE EXCHANGE’S OBJECTIONS TO EVIDENCE
SUBMITTED IN OPPOSITION TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT
1 COURT’S RULING: Sustained: ______________________________
2 Overruled: ______________________________
3
4 C. STATEMENT:
5 “If a home was custom-built, it should be considered “premium.” ”
6 (Tucker Dec. at ¶ 15.)
7 OBJECTIONS: This statement is objectionable because:
8 (a) It lacks foundation, and misstates evidence. (Evd. Code § 403.)
9 (b) The assertion constitutes inadmissible hearsay. (Cal. Evid. Code §
10 1200.)
11
Gordon Rees Scully Mansukhani, LLP
633 West Fifth Street, 52nd Floor
12 COURT’S RULING: Sustained: ______________________________
Los Angeles, CA 90071
13 Overruled: ______________________________
14
15 D. STATEMENT:
16 “Farmers has confirmed in verified interrogatory responses that it takes no steps at all to
17 verify that the sources and methods used by 360Value are kept current.”
18 (Tucker Dec. at ¶ 21.)
19 OBJECTIONS: This statement is objectionable because:
20 (a) It lacks foundation, and misstates evidence. (Evd. Code § 403.)
21 (b) The assertion constitutes inadmissible hearsay. (Cal. Evid. Code §
22 1200.)
23
24 COURT’S RULING: Sustained: ______________________________
25 Overruled: ______________________________
26
27
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DEFENDANT FIRE INSURANCE EXCHANGE’S OBJECTIONS TO EVIDENCE
SUBMITTED IN OPPOSITION TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT
1 E. STATEMENT:
2 “Hunsaker has confirmed in interrogatory responses that he does not make any changes
3 or edits to the 360Value estimate provided after he inputs the data from the insured, and he does
4 not believe it is job to create the estimate, only to input the insured’s information.”
5 (Tucker Dec. at ¶ 22.)
6 OBJECTIONS: This statement is objectionable because:
7 (a) It lacks foundation, and misstates evidence. (Evd. Code § 403.)
8 (b) The assertion constitutes inadmissible hearsay. (Cal. Evid. Code §
9 1200.)
10
11 COURT’S RULING: Sustained: ______________________________
Gordon Rees Scully Mansukhani, LLP
633 West Fifth Street, 52nd Floor
12 Overruled: ______________________________
Los Angeles, CA 90071
13
14 F. STATEMENT:
15 “In its original inspection of the home after the fire in October 2017, the claim adjuster
16 confirmed that the house was ‘custom built.’ ”
17 (Tucker Dec. at ¶ 24.)
18 OBJECTIONS: This statement is objectionable because:
19 (a) It lacks foundation as to Tucker and the claims adjuster, and
20 misstates evidence. (Evd. Code § 403.)
21 (b) The assertion constitutes inadmissible hearsay. (Cal. Evid. Code §
22 1200.)
23
24 COURT’S RULING: Sustained: ______________________________
25 Overruled: ______________________________
26
27
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DEFENDANT FIRE INSURANCE EXCHANGE’S OBJECTIONS TO EVIDENCE
SUBMITTED IN OPPOSITION TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT
1 II. DECLARATION OF GARY KOOP
2 A. STATEMENT:
3 “Each home was custom built” in his neighborhood.
4 (Koop Dec. at ¶ 4.)
5 OBJECTIONS: This statement is objectionable because:
6 (a) It lacks foundation, and misstates evidence. (Evd. Code § 403.)
7 (b) The assertion constitutes improper opinion from a non-expert.
8 (Cal. Evid. Code § 720.)
9
10 COURT’S RULING: Sustained: ______________________________
11 Overruled: ______________________________
Gordon Rees Scully Mansukhani, LLP
633 West Fifth Street, 52nd Floor
12
Los Angeles, CA 90071
13 B. STATEMENT:
14 “Both 3000 and 3500 Amber Lane were built as custom homes in 1975.”
15 (Koop Dec. at ¶ 4.)
16 OBJECTIONS: This statement is objectionable because:
17 (a) It lacks foundation, and misstates evidence. (Evd. Code § 403.)
18 (b) The assertion constitutes improper opinion from a non-expert.
19 (Cal. Evid. Code § 720.)
20
21
22 COURT’S RULING: Sustained: ______________________________
23 Overruled: ______________________________
24
25
26
27
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DEFENDANT FIRE INSURANCE EXCHANGE’S OBJECTIONS TO EVIDENCE
SUBMITTED IN OPPOSITION TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT
1 III. DECLARATION OF KEN BUNGER
2 A. STATEMENT:
3 “All of the homes on Amber Lane were custom built.”
4 (Bunger Dec. at ¶ 22.)
5 OBJECTIONS: This statement is objectionable because:
6 (a) It lacks foundation, and misstates evidence. (Evd. Code § 403.)
7 (b) The assertion constitutes improper opinion from a non-expert.
8 (Cal. Evid. Code § 720.)
9
10 COURT’S RULING: Sustained: ______________________________
11 Overruled: ______________________________
Gordon Rees Scully Mansukhani, LLP
633 West Fifth Street, 52nd Floor
12
Los Angeles, CA 90071
13
Dated: June 9, 2023 GORDON REES SCULLY MANSUKHANI, LLP
14
15 By:
Peter Schwartz
16 Christopher R. Wagner
Steven R. Inouye
17 Attorneys for Defendant
FIRE INSURANCE EXCHANGE
18
19
20
21
22
23
24
25
26
27
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DEFENDANT FIRE INSURANCE EXCHANGE’S OBJECTIONS TO EVIDENCE
SUBMITTED IN OPPOSITION TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT
1 PROOF OF SERVICE
2 I am a resident of the State of California, over the age of eighteen years, and not a party
to the within action. My business address is: Gordon Rees Scully Mansukhani, LLP 633 West
3 Fifth Street, 52nd floor, Los Angeles, CA 90071. On June 9, 2023, I served the within
documents:
4
DEFENDANT FIRE INSURANCE EXCHANGE’S OBJECTIONS TO EVIDENCE
5 SUBMITTED IN OPPOSITION TO PLAINTIFF’S MOTION FOR SUMMARY
JUDGMENT AND/OR SUMMARY ADJUDICATION; AND [PROPOSED] ORDER
6
7 by placing the document(s) listed above in a sealed envelope with postage thereon
fully prepaid, in United States mail in the State of California at Los Angeles,
addressed as set forth below.
8
by transmitting via E-Mail the document(s) listed above to the E-Mail address(s) set
forth below on this date before 5:00 p.m.
9
10 Glenn R. Kantor Albert M. T. Finch, III
KANTOR & KANTOR, LLP ERICKSSEN ARBUTHNOT
11
Gordon Rees Scully Mansukhani, LLP
19839 Nordhoff Street 210 North Fourth Street, Suite 350
633 West Fifth Street, 52nd Floor
Northridge, CA 91324 San Jose, CA 95112
12 (818) 886-2525 / Fax: (818) 350-6272 (408) 286/0880 / Fax: (408) 286-0337
Los Angeles, CA 90071
gkantor@kantorlaw.net afinch@ericksenarbuthnot.com
13 cmormann@kantorlaw.net kokasaki@ericksenarbuthnot.com
Attorneys for Plaintiff, GARY KOOP Attorneys for Defendant, BRIAN
14 HUNSAKER
Stacy Monahan Tucker
15 Monahan Tucker Law
4241 Woodinville-Duvall Road, Suite 382
16 Woodinville, WA 98072
(206) 486-3553 / Fax: 206- 339-7155
17 smtucker@mtlawpc.com
cspencer@mtlawpc.com
18 Attorneys for Plaintiff, GARY KOOP
19
20 I am readily familiar with the firm’s practice of collection and processing correspondence
for mailing. Under that practice it would be deposited with the U.S. Postal Service on that same
day with postage thereon fully prepaid in the ordinary course of business. I am aware that on
21 motion of the party served, service is presumed invalid if postal cancellation date or postage
meter date is more than one day after the date of deposit for mailing in affidavit.
22
I declare under penalty of perjury under the laws of the State of California that the above
23 is true and correct.
24 Executed on June 9, 2023 at Los Angeles, California.
25
26
Jennifer Odell
27
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DEFENDANT FIRE INSURANCE EXCHANGE’S OBJECTIONS TO EVIDENCE
SUBMITTED IN OPPOSITION TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT
Preview
1 PETER SCHWARTZ (SBN: 109859) pschwartz@grsm.com 2 DAVID L. JONES (SBN: 112307) djones@grsm.com 3 CHRISTOPHER R. WAGNER (SBN: 162092) cwagner@grsm.com 4 STEVEN R. INOUYE (SBN: 245024) sinouye@grsm.com 5 GORDON REES SCULLY MANSUKHANI, LLP 633 West Fifth Street, 52nd Floor 6 Los Angeles, CA 90071 Telephone: (213) 576-5019 7 Facsimile: (213) 680-4470 8 Attorneys for Defendant, FIRE INSURANCE EXCHANGE 9 10 SUPERIOR COURT OF CALIFORNIA 11 COUNTY OF SONOMA – HALL OF JUSTICE Gordon Rees Scully Mansukhani, LLP 633 West Fifth Street, 52nd Floor 12 GARY KOOP, ) CASE NO. SCV-266944 [Assigned for All Purposes to Hon. Oscar A. Los Angeles, CA 90071 ) 13 Plaintiff, ) Pardo, Dept. 19] ) 14 vs. ) DEFENDANT FIRE INSURANCE ) EXCHANGE’S OBJECTIONS TO 15 FIRE INSURANCE EXCHANGE, dba EVIDENCE SUBMITTED IN ) FARMERS INSURANCE GROUP; OPPOSITION TO PLAINTIFF’S 16 BRIAN HUNSAKER, ) MOTION FOR SUMMARY ) JUDGMENT AND/OR SUMMARY 17 Defendants. ) ADJUDICATION; AND [PROPOSED] ) ORDER 18 ) ) Hearing Date: June 28, 2023 19 ) Time: 3:00 p.m. ) Dept: 19 20 ) ) Complaint filed: August 24, 2020 21 Trial Date: November 8, 2023 22 23 Pursuant to California Rules of Court, rules 3.1352 and 3.1354, Defendant Fire Insurance 24 Exchange (“Fire”) hereby submit its objections to the evidence submitted by Plaintiff Gary Koop 25 (“Plaintiff”) in support of his motion for summary judgment or, alternatively, summary 26 adjudication: 27 28 -1- DEFENDANT FIRE INSURANCE EXCHANGE’S OBJECTIONS TO EVIDENCE SUBMITTED IN OPPOSITION TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT 1 I. DECLARATION OF STACY TUCKER, ESQ. 2 A. STATEMENT: 3 “Farmers’ policies and procedures stated that the agent should not accept the assumptive 4 information input, but should check each item with the insured. It noted that if an estimate seemed 5 too low, it was likely due to the wrong quality grade being selected, and that the more expensive a 6 home, the more detail should be input to correctly insure it ” 7 (Tucker Dec. at ¶ 10.) 8 OBJECTIONS: This statement is objectionable because: 9 (a) It lacks foundation, and misstates evidence. (Evd. Code § 403.) 10 (b) The assertion constitutes inadmissible hearsay. (Cal. Evid. Code § 11 1200.) Gordon Rees Scully Mansukhani, LLP 633 West Fifth Street, 52nd Floor 12 Los Angeles, CA 90071 13 COURT’S RULING: Sustained: ______________________________ 14 Overruled: ______________________________ 15 16 B. STATEMENT: 17 “On April 1, 2013, Farmers announced that the conversion for all policies to 360Value 18 would occur as of June 16, 2013. The notice explained that Dwelling Quality Grade would be 19 determined based on the Kitchen Quality Grade in RCT.” 20 (Tucker Dec. at ¶ 11.) 21 OBJECTIONS: This statement is objectionable because: 22 (a) It lacks foundation, and misstates evidence. (Evd. Code § 403.) 23 (b) The assertion constitutes inadmissible hearsay. (Cal. Evid. Code § 24 1200.) 25 (c) It is irrelevant because the quality grade of Plaintiff’s kitchen has 26 no bearing on the actual quality grade of his home. (Evd. Code 27 § 350.) 28 -2- DEFENDANT FIRE INSURANCE EXCHANGE’S OBJECTIONS TO EVIDENCE SUBMITTED IN OPPOSITION TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT 1 COURT’S RULING: Sustained: ______________________________ 2 Overruled: ______________________________ 3 4 C. STATEMENT: 5 “If a home was custom-built, it should be considered “premium.” ” 6 (Tucker Dec. at ¶ 15.) 7 OBJECTIONS: This statement is objectionable because: 8 (a) It lacks foundation, and misstates evidence. (Evd. Code § 403.) 9 (b) The assertion constitutes inadmissible hearsay. (Cal. Evid. Code § 10 1200.) 11 Gordon Rees Scully Mansukhani, LLP 633 West Fifth Street, 52nd Floor 12 COURT’S RULING: Sustained: ______________________________ Los Angeles, CA 90071 13 Overruled: ______________________________ 14 15 D. STATEMENT: 16 “Farmers has confirmed in verified interrogatory responses that it takes no steps at all to 17 verify that the sources and methods used by 360Value are kept current.” 18 (Tucker Dec. at ¶ 21.) 19 OBJECTIONS: This statement is objectionable because: 20 (a) It lacks foundation, and misstates evidence. (Evd. Code § 403.) 21 (b) The assertion constitutes inadmissible hearsay. (Cal. Evid. Code § 22 1200.) 23 24 COURT’S RULING: Sustained: ______________________________ 25 Overruled: ______________________________ 26 27 28 -3- DEFENDANT FIRE INSURANCE EXCHANGE’S OBJECTIONS TO EVIDENCE SUBMITTED IN OPPOSITION TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT 1 E. STATEMENT: 2 “Hunsaker has confirmed in interrogatory responses that he does not make any changes 3 or edits to the 360Value estimate provided after he inputs the data from the insured, and he does 4 not believe it is job to create the estimate, only to input the insured’s information.” 5 (Tucker Dec. at ¶ 22.) 6 OBJECTIONS: This statement is objectionable because: 7 (a) It lacks foundation, and misstates evidence. (Evd. Code § 403.) 8 (b) The assertion constitutes inadmissible hearsay. (Cal. Evid. Code § 9 1200.) 10 11 COURT’S RULING: Sustained: ______________________________ Gordon Rees Scully Mansukhani, LLP 633 West Fifth Street, 52nd Floor 12 Overruled: ______________________________ Los Angeles, CA 90071 13 14 F. STATEMENT: 15 “In its original inspection of the home after the fire in October 2017, the claim adjuster 16 confirmed that the house was ‘custom built.’ ” 17 (Tucker Dec. at ¶ 24.) 18 OBJECTIONS: This statement is objectionable because: 19 (a) It lacks foundation as to Tucker and the claims adjuster, and 20 misstates evidence. (Evd. Code § 403.) 21 (b) The assertion constitutes inadmissible hearsay. (Cal. Evid. Code § 22 1200.) 23 24 COURT’S RULING: Sustained: ______________________________ 25 Overruled: ______________________________ 26 27 28 -4- DEFENDANT FIRE INSURANCE EXCHANGE’S OBJECTIONS TO EVIDENCE SUBMITTED IN OPPOSITION TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT 1 II. DECLARATION OF GARY KOOP 2 A. STATEMENT: 3 “Each home was custom built” in his neighborhood. 4 (Koop Dec. at ¶ 4.) 5 OBJECTIONS: This statement is objectionable because: 6 (a) It lacks foundation, and misstates evidence. (Evd. Code § 403.) 7 (b) The assertion constitutes improper opinion from a non-expert. 8 (Cal. Evid. Code § 720.) 9 10 COURT’S RULING: Sustained: ______________________________ 11 Overruled: ______________________________ Gordon Rees Scully Mansukhani, LLP 633 West Fifth Street, 52nd Floor 12 Los Angeles, CA 90071 13 B. STATEMENT: 14 “Both 3000 and 3500 Amber Lane were built as custom homes in 1975.” 15 (Koop Dec. at ¶ 4.) 16 OBJECTIONS: This statement is objectionable because: 17 (a) It lacks foundation, and misstates evidence. (Evd. Code § 403.) 18 (b) The assertion constitutes improper opinion from a non-expert. 19 (Cal. Evid. Code § 720.) 20 21 22 COURT’S RULING: Sustained: ______________________________ 23 Overruled: ______________________________ 24 25 26 27 28 -5- DEFENDANT FIRE INSURANCE EXCHANGE’S OBJECTIONS TO EVIDENCE SUBMITTED IN OPPOSITION TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT 1 III. DECLARATION OF KEN BUNGER 2 A. STATEMENT: 3 “All of the homes on Amber Lane were custom built.” 4 (Bunger Dec. at ¶ 22.) 5 OBJECTIONS: This statement is objectionable because: 6 (a) It lacks foundation, and misstates evidence. (Evd. Code § 403.) 7 (b) The assertion constitutes improper opinion from a non-expert. 8 (Cal. Evid. Code § 720.) 9 10 COURT’S RULING: Sustained: ______________________________ 11 Overruled: ______________________________ Gordon Rees Scully Mansukhani, LLP 633 West Fifth Street, 52nd Floor 12 Los Angeles, CA 90071 13 Dated: June 9, 2023 GORDON REES SCULLY MANSUKHANI, LLP 14 15 By: Peter Schwartz 16 Christopher R. Wagner Steven R. Inouye 17 Attorneys for Defendant FIRE INSURANCE EXCHANGE 18 19 20 21 22 23 24 25 26 27 28 -6- DEFENDANT FIRE INSURANCE EXCHANGE’S OBJECTIONS TO EVIDENCE SUBMITTED IN OPPOSITION TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT 1 PROOF OF SERVICE 2 I am a resident of the State of California, over the age of eighteen years, and not a party to the within action. My business address is: Gordon Rees Scully Mansukhani, LLP 633 West 3 Fifth Street, 52nd floor, Los Angeles, CA 90071. On June 9, 2023, I served the within documents: 4 DEFENDANT FIRE INSURANCE EXCHANGE’S OBJECTIONS TO EVIDENCE 5 SUBMITTED IN OPPOSITION TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT AND/OR SUMMARY ADJUDICATION; AND [PROPOSED] ORDER 6 7 by placing the document(s) listed above in a sealed envelope with postage thereon fully prepaid, in United States mail in the State of California at Los Angeles, addressed as set forth below. 8 by transmitting via E-Mail the document(s) listed above to the E-Mail address(s) set forth below on this date before 5:00 p.m. 9 10 Glenn R. Kantor Albert M. T. Finch, III KANTOR & KANTOR, LLP ERICKSSEN ARBUTHNOT 11 Gordon Rees Scully Mansukhani, LLP 19839 Nordhoff Street 210 North Fourth Street, Suite 350 633 West Fifth Street, 52nd Floor Northridge, CA 91324 San Jose, CA 95112 12 (818) 886-2525 / Fax: (818) 350-6272 (408) 286/0880 / Fax: (408) 286-0337 Los Angeles, CA 90071 gkantor@kantorlaw.net afinch@ericksenarbuthnot.com 13 cmormann@kantorlaw.net kokasaki@ericksenarbuthnot.com Attorneys for Plaintiff, GARY KOOP Attorneys for Defendant, BRIAN 14 HUNSAKER Stacy Monahan Tucker 15 Monahan Tucker Law 4241 Woodinville-Duvall Road, Suite 382 16 Woodinville, WA 98072 (206) 486-3553 / Fax: 206- 339-7155 17 smtucker@mtlawpc.com cspencer@mtlawpc.com 18 Attorneys for Plaintiff, GARY KOOP 19 20 I am readily familiar with the firm’s practice of collection and processing correspondence for mailing. Under that practice it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid in the ordinary course of business. I am aware that on 21 motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after the date of deposit for mailing in affidavit. 22 I declare under penalty of perjury under the laws of the State of California that the above 23 is true and correct. 24 Executed on June 9, 2023 at Los Angeles, California. 25 26 Jennifer Odell 27 28 -7- DEFENDANT FIRE INSURANCE EXCHANGE’S OBJECTIONS TO EVIDENCE SUBMITTED IN OPPOSITION TO PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT