On February 19, 2019 a
Motion,Ex Parte
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 08/21/2020 02:57 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Lopez,Deputy Clerk
1 Angela M. Powell (State Bar No. 191876)
amp@manningllp.com
2 Andrea K. Kornblau (State Bar No. 291613)
akk@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, PRISCILLA ZAMORA
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF LOS ANGELES, SPRING STREET COURTHOUSE
10
11 RICHARD YCAZA, Case No. 19STCV05779
12 Plaintiff, DEFENDANT TARGET
CORPORATION’S NOTICE OF MOTION
13 v. AND MOTION FOR PROTECTIVE
ORDER AS TO PLAINTIFF’S SECOND
14 TARGET CORPORATION; PRISCILLA SET OF WRITTEN DISCOVERY;
ZAMORA, an individual; and DOES 1 to 50, MEMORANDUM OF POINTS AND
15 inclusive, AUTHORITIES
16 Defendants. Filed Concurrently with Separate Statement in
Support of Motion; Declaration of Andrea
17 Kornblau; [Proposed] Order
18 Date: November 24, 2020
Time: 1:30 p.m.
19 Dept.: 28
20 RESERVATION ID: 345450430608
21 Action Filed: 2/19/2019
TSC: 8/18/2020
22
23 TO ALL PARTIES AND THEIR COUNSEL OF RECORD:
24 PLEASE TAKE NOTICE that on November 24, 2020, at 1:30 p.m., or as soon thereafter
25 as counsel may be heard in Department 28 of the above-entitled court, located at 312 North Spring
26 Street, Los Angeles, California 90012, Defendants Target Corporation ("Target"), will and hereby
27 does, move the Court for a protective order striking:
28 ///
MOTION FOR PROTECTIVE ORDER
Document Filed Date
August 21, 2020
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 08/21/2020 02:57 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Lopez,Deputy Clerk 1 Angela M. Powell (State Bar No. 191876) amp@manningllp.com 2 Andrea K. Kornblau (State Bar No. 291613) akk@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, PRISCILLA ZAMORA 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF LOS ANGELES, SPRING STREET COURTHOUSE 10 11 RICHARD YCAZA, Case No. 19STCV05779 12 Plaintiff, DEFENDANT TARGET CORPORATION’S NOTICE OF MOTION 13 v. AND MOTION FOR PROTECTIVE ORDER AS TO PLAINTIFF’S SECOND 14 TARGET CORPORATION; PRISCILLA SET OF WRITTEN DISCOVERY; ZAMORA, an individual; and DOES 1 to 50, MEMORANDUM OF POINTS AND 15 inclusive, AUTHORITIES 16 Defendants. Filed Concurrently with Separate Statement in Support of Motion; Declaration of Andrea 17 Kornblau; [Proposed] Order 18 Date: November 24, 2020 Time: 1:30 p.m. 19 Dept.: 28 20 RESERVATION ID: 345450430608 21 Action Filed: 2/19/2019 TSC: 8/18/2020 22 23 TO ALL PARTIES AND THEIR COUNSEL OF RECORD: 24 PLEASE TAKE NOTICE that on November 24, 2020, at 1:30 p.m., or as soon thereafter 25 as counsel may be heard in Department 28 of the above-entitled court, located at 312 North Spring 26 Street, Los Angeles, California 90012, Defendants Target Corporation ("Target"), will and hereby 27 does, move the Court for a protective order striking: 28 /// MOTION FOR PROTECTIVE ORDER