On February 14, 2019 a
Motion-Secondary
was filed
involving a dispute between
Polzin Jorge,
and
The Regents Of The University Of California,
for civil
in the District Court of Los Angeles County.
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Electronically FILED by Superior Court of California, County of Los Angeles on 02/03/2021 04:14 PM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Soto,Deputy Clerk
1 ADAM REISNER, ESQ., (State BarNo. 204351)
TESSA KING, ESQ., (State Bar No. 251408)
2 ALYSSA ROMANINI, ESQ. (State Bar No. 325792)
REISNER & KING LLP
3 15303Ventura Blvd., Suite 1260
Sherman Oaks, California 91403
4 Phone: (818) 981-0901
Fax: (818) 981-0902
5
Attorneys for Plaintiff JORGE POLZIN
6
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF LOS ANGELES
10
11 ) Case No: 19STCV04889
JORGE POLZIN,
12
13
v.
Plaintiff,
l [Assigned for all purposes to the Hon.
Michelle Williams Court, Dept. 74]
14 PLAINTIFF'S OBJECTIONS TO
UCLA HEALTH; and DEFENDANT'S REPLY TO
15 DOES 1 THROUGH 100, inclusive, PLAINTIFF'S OPPOSITION TO
16 Defendants. DEFENDANT'S MOTION FOR
MONETARY SANCTIONS PURSUANT
17 TO CCP §128. 7
l
18
Date: Feb.9,2021
19 Time: 8:30a.m.
20 Dept: 74
21 ------------~
22 Plaintiff, Jorge Polzin, by and through his attorneys of record, submits the following
23 objections to Defendant's Reply to Plaintiffs Opposition to Defendant's Motion for Sanctions:
24 1. Defendant, as the moving party, should not be allowed to submit or rely on any
25 additional evidence filed outside of their moving papers, yet Defendant attempts to do
26 so. Defendant did not argue judicial estoppel in its moving papers and cannot bring
27 argue this for the first time in its Reply. New evidence cannot be introduced in a
28
1
PLAINTIFF'S OBJECTIONS TO DEFENDANT'S REPLY TO PLAINTIFF'S OPPOSITION TO
DEFENDANT'S MOTION FOR MONETARY SANCTIONS PURSUANT TO CCP §128.7
Document Filed Date
February 03, 2021
Case Filing Date
February 14, 2019
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Electronically FILED by Superior Court of California, County of Los Angeles on 02/03/2021 04:14 PM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Soto,Deputy Clerk 1 ADAM REISNER, ESQ., (State BarNo. 204351) TESSA KING, ESQ., (State Bar No. 251408) 2 ALYSSA ROMANINI, ESQ. (State Bar No. 325792) REISNER & KING LLP 3 15303Ventura Blvd., Suite 1260 Sherman Oaks, California 91403 4 Phone: (818) 981-0901 Fax: (818) 981-0902 5 Attorneys for Plaintiff JORGE POLZIN 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF LOS ANGELES 10 11 ) Case No: 19STCV04889 JORGE POLZIN, 12 13 v. Plaintiff, l [Assigned for all purposes to the Hon. Michelle Williams Court, Dept. 74] 14 PLAINTIFF'S OBJECTIONS TO UCLA HEALTH; and DEFENDANT'S REPLY TO 15 DOES 1 THROUGH 100, inclusive, PLAINTIFF'S OPPOSITION TO 16 Defendants. DEFENDANT'S MOTION FOR MONETARY SANCTIONS PURSUANT 17 TO CCP §128. 7 l 18 Date: Feb.9,2021 19 Time: 8:30a.m. 20 Dept: 74 21 ------------~ 22 Plaintiff, Jorge Polzin, by and through his attorneys of record, submits the following 23 objections to Defendant's Reply to Plaintiffs Opposition to Defendant's Motion for Sanctions: 24 1. Defendant, as the moving party, should not be allowed to submit or rely on any 25 additional evidence filed outside of their moving papers, yet Defendant attempts to do 26 so. Defendant did not argue judicial estoppel in its moving papers and cannot bring 27 argue this for the first time in its Reply. New evidence cannot be introduced in a 28 1 PLAINTIFF'S OBJECTIONS TO DEFENDANT'S REPLY TO PLAINTIFF'S OPPOSITION TO DEFENDANT'S MOTION FOR MONETARY SANCTIONS PURSUANT TO CCP §128.7