Motion-Secondary: 632 N PALM DRIVE, LLC VS ADAN PENA, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 06/29/2020 06:17 PM Sherri R. Carter, Executive Officer/Clerk of Court, by B. McClendon,Deputy Clerk

                                  1   SEAN P. REYNOLDS, ESQ., State Bar No. 249649
                                      US CONSTRUCTION LAW, A Law Corporation
                                  2   3433 Corte Altura
                                      Carlsbad CA, 92009
                                  3   T: (760) 452-5752
                                      sreynolds@usclawcorp.com
                                  4
                                      Attorneys for Defendants GOLD PACIFIC
                                  5   CONSTRUCTION, INC., ADAN PENA and
                                      SURETEC INDEMNITY COMPANY
                                  6

                                  7

                                  8                         SUPERIOR COURT OF THE STATE OF CALIFORNIA

                                  9                                     FOR THE COUNTY OF LOS ANGELES

                                 10   632 N PALM DRIVE, LLC.                                            CASE NO.: 19SMCV00434
                                                                                                        (Complaint filed: March 5, 2019)
                                 11                    Plaintiff,
          US CONSTRUCTION LAW




                                                                                                        Related Matter as of August 23, 2019 with:
                                 12          v.                                                         CASE NO.: 19SMCV00962
             A LAW CORPORATION




                                                                                                        (Complaint filed: March 23, 2019)
                                 13   GOLD PACIFIC CONSTRUCTION, INC.,
                                      a California corporation, ADAN PENA, an                           OPPOSITION OF GOLD PACIFIC
                                 14   individual; SURETEC INDEMNITY                                     CONSTRUCTION, INC. TO PLAINTIFF’S
                                      COMPANY, a California corporation, and                            DEMURRER TO FIRST AMENDED
                                 15   DOES 1-20                                                         CROSS-COMPLAINT AND REQUEST
                                                     Defendants.                                        FOR MONETARY SANCTIONS IN THE
                                 16                                                                     AMOUNT OF $3,007.65 AGAINST
                                                                                                        PLAINTIFF AND COUNSEL PURSUANT
                                 17   AND RELATED CROSS-ACTIONS                                         TO CCP §§128.5, 128.7; DECLARATION
                                                                                                        OF SEAN P. REYNOLDS
                                 18
                                                                                                        Dept.:     M
                                 19                                                                     Judge:     Hon. Mark A. Young
                                                                                                        Date:      July 10, 2020
                                 20                                                                     Time:      9:00 a.m.

                                 21   TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD:
                                 22   Defendant/Cross-Complainant Gold Pacific Construction, Inc. (“GOLD”) hereby submits the
                                 23   following Opposition to the Demurrer to GOLD’s First Amended Cross-Complaint, (“FAXC”)
                                 24   of plaintiff 632 N PALM DRIVE, LLC,’s (“632.”)
                                 25

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                                                                                   OPPOSITION TO DEMURRER