On January 22, 2019 a
Motion-Secondary
was filed
involving a dispute between
Dehey Marjorie,
Overacker Paul,
Quality Control Restoration Inc.,
The Point At Beverly Hills Inc.,
and
Barber Victor Michael,
Lb Property Management Inc,
Quality Control Restoration Inc.,
The Point At Beverly Hills Inc.,
for Other Personal Injury/Property Damage/Wrongful Death (General Jurisdiction)
in the District Court of Los Angeles County.
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Electronically FILED by Superior Court of California, County of Los Angeles on 07/15/2019 03:55 PM Sherri R. Carter, Executive Officer/Clerk of Court, by A. Williams,Deputy Clerk
CIV-141
ATTORNEY OR PARTY WITH()UT ATTO RNEY: STATE BAR NO: 221922 FOR COURT USE ONLY
NAME: Gregory J. Carpenter, Esq.
FIRM NAME: Har:tsuyker, Stratman & Williams-Abrego :
STREET ADDRESS: •700 S. Flower St. 28th Floor
CITY: Los Angeles STATE: CA ZIP CODE: 90017
TELEPHONE NO.: (2 13)615-2548 FAX NO.: (213)615-2698
E-MAILAODRESS: gregory.carpenter@farmersinsurance.com
ATTORNEY FOR (Name): The Point at Beverly Hills, Inc. and LB Property Management, Inc.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Los Angeles
STREET ADDRESS: 312 North Spring Street, Los Angeles, CA 900.12
MAILING AODRESS: 312 North Spring Street, Los Angeles, CA 90012
.
CITY AND ZIP CODE: Los Angeles, CA 90012
BRANCH NAME: Spring Street Courthouse
PLAINTIFF/PETITIONER: MARJORIE DEHEY, et al.
DEFENDANT/RESPONDENT: THE POINT AT BEVERLY HILLS INC., et al.
CASE NUMBER:
DECLARATION OF DEMURRING OR MOVING PARTY 19STCV02006
IN SUPPORT OF AUTOMATIC EXTENSION
'
1. (Name of party): THE POINT AT BEVERLY HILLS, INC. was served with
D a complaint [TI an amended complaint D a cross-complaint
D an answer D other (specify):
in the above-titled action.
2. For a demurrer or motion to strike, a responsive pleading is due on (dai~): July 15, 2019
DECLARATION
I intend to file a demurrer, motion to strike, or motion for judgment on the pleadings in this action. Before I can do so, I am required to
meet and confer with the party who filed the pleading that I am responding to at least five days before the date when the responsive
pleading is due (if I am filing a demurrer or motion to strike) and at least five days before the last day a motion for judgment on the
pleadirigs may be filed (if I am filing a motion for judgment on the pleadings). We have not been able to meet and confer. I have not
previously requested an automatic extension of time. Therefore, on timely filing and serving a declaration that meets the requirements
of Code of Civil Procedure sections 430.41 , 435.5, or 439, I am entitled to an automatic 30-day extension of time within which to file a
responsive pleading or motion for judgment on the pleadings.
I made a good faith attempt to meet and confer with the party who filed the pleading at least five days before the date the responsive
pleading was due (if I am filing a demurrer or motion to strike) and at least five days before the last day a motion for judgment on the
pleadings may be filed (if I am filing a motion for judgment on the pleadings). I was unable to meet with that party because
(the reasons why the parties could not meet and confer are stated):
0 below c::J on form MC-031, Attached Declaration
On July 10, 2019, I e-mailed Plaintiffs' counsel requesting that we set up a time to meet and confer with regard to a potential
Demurrer and Motion to Strike on the First Amended Complaint. To date, I have not received a response, but will endeavor to
continue to follow up. Therefore, I have been unable to meet and confer on this matter due to Plaintiffs' counsel's unav ailability to
meet and confer.
I declare under penalty of perjury under the laws of the State of California that the information above is true and correct.
Date: July 15, 2019
Gregory J. Carpenter
(NAME OF PARTY OR ATTORNEY FOR PARTY) â–º (SIGNATUR~ OF PARTY OR ATTORNEY FOR PARTY)
Page 1 of1
Form Approved for Oplional Use
Judicial Council of California
DECLARATION OF DEMURRING OR MOVING PARTY Cod.for Civil Procedure,
§§ 430.41, 435.5, 439
CIV- 141 [Rev. January 1, 20191 www.courls.ca.gov
IN SUPPORT OF AUTOMATIC EXTENSION
Document Filed Date
July 15, 2019
Case Filing Date
January 22, 2019
Category
Other Personal Injury/Property Damage/Wrongful Death (General Jurisdiction)
Status
Request for Dismissal - Before Trial Within 60 days of Settlement Conference 10/13/2022
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Electronically FILED by Superior Court of California, County of Los Angeles on 07/15/2019 03:55 PM Sherri R. Carter, Executive Officer/Clerk of Court, by A. Williams,Deputy Clerk CIV-141 ATTORNEY OR PARTY WITH()UT ATTO RNEY: STATE BAR NO: 221922 FOR COURT USE ONLY NAME: Gregory J. Carpenter, Esq. FIRM NAME: Har:tsuyker, Stratman & Williams-Abrego : STREET ADDRESS: •700 S. Flower St. 28th Floor CITY: Los Angeles STATE: CA ZIP CODE: 90017 TELEPHONE NO.: (2 13)615-2548 FAX NO.: (213)615-2698 E-MAILAODRESS: gregory.carpenter@farmersinsurance.com ATTORNEY FOR (Name): The Point at Beverly Hills, Inc. and LB Property Management, Inc. SUPERIOR COURT OF CALIFORNIA, COUNTY OF Los Angeles STREET ADDRESS: 312 North Spring Street, Los Angeles, CA 900.12 MAILING AODRESS: 312 North Spring Street, Los Angeles, CA 90012 . CITY AND ZIP CODE: Los Angeles, CA 90012 BRANCH NAME: Spring Street Courthouse PLAINTIFF/PETITIONER: MARJORIE DEHEY, et al. DEFENDANT/RESPONDENT: THE POINT AT BEVERLY HILLS INC., et al. CASE NUMBER: DECLARATION OF DEMURRING OR MOVING PARTY 19STCV02006 IN SUPPORT OF AUTOMATIC EXTENSION ' 1. (Name of party): THE POINT AT BEVERLY HILLS, INC. was served with D a complaint [TI an amended complaint D a cross-complaint D an answer D other (specify): in the above-titled action. 2. For a demurrer or motion to strike, a responsive pleading is due on (dai~): July 15, 2019 DECLARATION I intend to file a demurrer, motion to strike, or motion for judgment on the pleadings in this action. Before I can do so, I am required to meet and confer with the party who filed the pleading that I am responding to at least five days before the date when the responsive pleading is due (if I am filing a demurrer or motion to strike) and at least five days before the last day a motion for judgment on the pleadirigs may be filed (if I am filing a motion for judgment on the pleadings). We have not been able to meet and confer. I have not previously requested an automatic extension of time. Therefore, on timely filing and serving a declaration that meets the requirements of Code of Civil Procedure sections 430.41 , 435.5, or 439, I am entitled to an automatic 30-day extension of time within which to file a responsive pleading or motion for judgment on the pleadings. I made a good faith attempt to meet and confer with the party who filed the pleading at least five days before the date the responsive pleading was due (if I am filing a demurrer or motion to strike) and at least five days before the last day a motion for judgment on the pleadings may be filed (if I am filing a motion for judgment on the pleadings). I was unable to meet with that party because (the reasons why the parties could not meet and confer are stated): 0 below c::J on form MC-031, Attached Declaration On July 10, 2019, I e-mailed Plaintiffs' counsel requesting that we set up a time to meet and confer with regard to a potential Demurrer and Motion to Strike on the First Amended Complaint. To date, I have not received a response, but will endeavor to continue to follow up. Therefore, I have been unable to meet and confer on this matter due to Plaintiffs' counsel's unav ailability to meet and confer. I declare under penalty of perjury under the laws of the State of California that the information above is true and correct. Date: July 15, 2019 Gregory J. Carpenter (NAME OF PARTY OR ATTORNEY FOR PARTY) ► (SIGNATUR~ OF PARTY OR ATTORNEY FOR PARTY) Page 1 of1 Form Approved for Oplional Use Judicial Council of California DECLARATION OF DEMURRING OR MOVING PARTY Cod.for Civil Procedure, §§ 430.41, 435.5, 439 CIV- 141 [Rev. January 1, 20191 www.courls.ca.gov IN SUPPORT OF AUTOMATIC EXTENSION