On February 19, 2019 a
Party Discovery
was filed
involving a dispute between
Ycaza Richard,
and
Target Corporation,
Zamora An Individual Priscilla,
for Premise Liability (e.g., dangerous conditions of property, slip/trip and fall, dog attack, etc.) (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 08/17/2021 04:09 PM Sherri R. Carter, Executive Officer/Clerk of Court, by L. Coreas,Deputy Clerk
1 Eugene J. Egan (State Bar No. 130108)
eje@manningllp.com
2 Joshua Babataher (State Bar No. 311367)
jkb@manningllp.com
3 MANNING & KASS
ELLROD, RAMIREZ, TRESTER LLP
4 801 S. Figueroa St, 15th Floor
Los Angeles, California 90017-3012
5 Telephone: (213) 624-6900
Facsimile: (213) 624-6999
6
Attorneys for Defendant TARGET
7 CORPORATION
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF LOS ANGELES, CENTRAL DISTRICT
10
11 RICHARD YCAZA, Case No. 19STCV05779
12 Plaintiff, DEFENDANT TARGET
CORPORATION'S OPPOSITION TO
13 v. PLAINTIFF'S MOTION TO COMPEL
PRODUCTION OF DOCUMENTS IN
14 TARGET CORPORATION; PRISCILLA RESPONSE TO PLAINTIFF'S REQUEST
ZAMORA, an individual; and DOES 1 to 50, FOR PRODUCTION OF DOCUMENTS
15 Inclusive, NO. 48 AGAINST TARGET CORP. AND
FOR MONETARY SANCTIONS
16 Defendant. AGAINST TARGET CORP. AND
DEFENDANT'S COUNSEL FO RECORD;
17 MEMORANDUM OF POINTS AND
AUTHORITIES; DECLARATION OF
18 JOSHUA K. BABATAHER
19 Defendant TARGET CORPORATION ("Defendant") hereby submits this Opposition to
20 Plaintiff's Motion to Compel Production of Documents in Response to Plaintiff's Request for
21 Production of Documents No. 48 Against Target Corporation and for Monetary Sanctions.
22 Plaintiff's motion is unnecessary and should not have been filed. Following the informal discovery
23 conference attended by the parties, Defendant had already served a verified further responses to
24 Plaintiff's Request for Production No. 48 stating that non-privileged responsive documents would
25 be forthcoming.
26 This Opposition is based on the attached Memorandum of Points and Authorities, the
27 Declaration Joshua K. Babataher, Esq., all of the pleadings, files, and records in this proceeding,
28 DEFENDANT TARGET CORPORATION'S OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL
PRODUCTION OF DOCUMENTS IN RESPONSE TO PLAINTIFF'S REQUEST FOR PRODUCTION OF
DOCUMENTS NO. 48 AGAINST TARGET CORP. AND FOR MONETARY SANCTIONS AGAINST
TARGET CORP. AND DEFENDANT'S COUNSEL FO RECORD; MEMORANDUM OF POINTS AND
AUTHORITIES; DECLARATION OF JOSHUA K. BABATAHER
Document Filed Date
August 17, 2021
Case Filing Date
February 19, 2019
Category
Premise Liability (e.g., dangerous conditions of property, slip/trip and fall, dog attack, etc.) (General Jurisdiction)
Status
Request for Dismissal - Before Trial not following ADR or more than 60 days since ADR 10/04/2021
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Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 08/17/2021 04:09 PM Sherri R. Carter, Executive Officer/Clerk of Court, by L. Coreas,Deputy Clerk 1 Eugene J. Egan (State Bar No. 130108) eje@manningllp.com 2 Joshua Babataher (State Bar No. 311367) jkb@manningllp.com 3 MANNING & KASS ELLROD, RAMIREZ, TRESTER LLP 4 801 S. Figueroa St, 15th Floor Los Angeles, California 90017-3012 5 Telephone: (213) 624-6900 Facsimile: (213) 624-6999 6 Attorneys for Defendant TARGET 7 CORPORATION 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF LOS ANGELES, CENTRAL DISTRICT 10 11 RICHARD YCAZA, Case No. 19STCV05779 12 Plaintiff, DEFENDANT TARGET CORPORATION'S OPPOSITION TO 13 v. PLAINTIFF'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS IN 14 TARGET CORPORATION; PRISCILLA RESPONSE TO PLAINTIFF'S REQUEST ZAMORA, an individual; and DOES 1 to 50, FOR PRODUCTION OF DOCUMENTS 15 Inclusive, NO. 48 AGAINST TARGET CORP. AND FOR MONETARY SANCTIONS 16 Defendant. AGAINST TARGET CORP. AND DEFENDANT'S COUNSEL FO RECORD; 17 MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF 18 JOSHUA K. BABATAHER 19 Defendant TARGET CORPORATION ("Defendant") hereby submits this Opposition to 20 Plaintiff's Motion to Compel Production of Documents in Response to Plaintiff's Request for 21 Production of Documents No. 48 Against Target Corporation and for Monetary Sanctions. 22 Plaintiff's motion is unnecessary and should not have been filed. Following the informal discovery 23 conference attended by the parties, Defendant had already served a verified further responses to 24 Plaintiff's Request for Production No. 48 stating that non-privileged responsive documents would 25 be forthcoming. 26 This Opposition is based on the attached Memorandum of Points and Authorities, the 27 Declaration Joshua K. Babataher, Esq., all of the pleadings, files, and records in this proceeding, 28 DEFENDANT TARGET CORPORATION'S OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS IN RESPONSE TO PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS NO. 48 AGAINST TARGET CORP. AND FOR MONETARY SANCTIONS AGAINST TARGET CORP. AND DEFENDANT'S COUNSEL FO RECORD; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF JOSHUA K. BABATAHER