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Electronically FILED by Superior Court of California, County of Los Angeles on 12/18/2019 09:51 AM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Mariscal,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
EX PARTE APPLICATION OF GOLD
12 v. PACIFIC CONSTRUCTION, INC. TO
A LAW CORPORATION
STRIKE PLAINTIFF’S MOTION TO
13 GOLD PACIFIC CONSTRUCTION, INC., COMPEL SPECIAL INTERROGATIRES
a California corporation, ADAN PENA, an OR, IN THE ALTERNATIVE AN ORDER
14 individual; SURETEC INDEMNITY TO SHORTEN TIME FOR A MOTION TO
COMPANY, a California corporation, and STRIKE, AND REQUEST FOR
15 DOES 1-20 SANCTIONS OF $5,789.95 ON PLAINTIFF
Defendants. AND COUNSEL PURSUANT TO CCP
16 §§177.5, 128, 128.5, 128.7; DECLARATION
OF SEAN P. REYNOLDS; [PROPOSED]
17 GOLD PACIFIC CONSTRUCTION, INC., ORDER.
a California corporation,
18 Dept.: M
Cross-Complainant, Judge: Hon. Mark A. Young
19 Date: December 19, 2019
v. Time: 8:30 a.m.
20
632 N PALM DRIVE, LLC, a California
21 limited liability corporation; MICHAEL
COHEN, an individual; RUSSELL ALLEN
22 LINCH, an individual; RAL DESIGN
AND MANAGEMENT, INC., a California
23 corporation, and ROES 1-10,
24 Cross-Defendants.
25
26 TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD:
27 PLEASE TAKE NOTICE THAT on December 19, 2019, at 8:30 a.m. in Department
28 M of the above-entitled Court located at 1725 Main Street Santa Monica CA, 90401,
1
EX PARTE APPLICATION
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Electronically FILED by Superior Court of California, County of Los Angeles on 12/18/2019 09:51 AM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Mariscal,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 EX PARTE APPLICATION OF GOLD 12 v. PACIFIC CONSTRUCTION, INC. TO A LAW CORPORATION STRIKE PLAINTIFF’S MOTION TO 13 GOLD PACIFIC CONSTRUCTION, INC., COMPEL SPECIAL INTERROGATIRES a California corporation, ADAN PENA, an OR, IN THE ALTERNATIVE AN ORDER 14 individual; SURETEC INDEMNITY TO SHORTEN TIME FOR A MOTION TO COMPANY, a California corporation, and STRIKE, AND REQUEST FOR 15 DOES 1-20 SANCTIONS OF $5,789.95 ON PLAINTIFF Defendants. AND COUNSEL PURSUANT TO CCP 16 §§177.5, 128, 128.5, 128.7; DECLARATION OF SEAN P. REYNOLDS; [PROPOSED] 17 GOLD PACIFIC CONSTRUCTION, INC., ORDER. a California corporation, 18 Dept.: M Cross-Complainant, Judge: Hon. Mark A. Young 19 Date: December 19, 2019 v. Time: 8:30 a.m. 20 632 N PALM DRIVE, LLC, a California 21 limited liability corporation; MICHAEL COHEN, an individual; RUSSELL ALLEN 22 LINCH, an individual; RAL DESIGN AND MANAGEMENT, INC., a California 23 corporation, and ROES 1-10, 24 Cross-Defendants. 25 26 TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD: 27 PLEASE TAKE NOTICE THAT on December 19, 2019, at 8:30 a.m. in Department 28 M of the above-entitled Court located at 1725 Main Street Santa Monica CA, 90401, 1 EX PARTE APPLICATION