Document for OLUFEMI OGUNTOLU VS NINA C MONTOYA

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 10/17/2019 05:39 PM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Hung,Deputy Clerk




                      .SUSAN L. CALDWELL (SBN: 190421)
                    1 CALDWELL LAW GROUP
                      9701 Wilshire Blvd., 10th Floor
                    2 Beverly Hills, CA 90212
                      Telephone: (310) 858-7000
                    3 Facsimile: (310) 858-7008
                      E-Mail: scaldwell@caldwelllaw.com
                    4

                    5 Attorneys for Plaintiff OLUFEMI OGUNTOLU

                    6

                    7
                                                       SUPERIOR COURT OF THE STATE OF CALIFORNIA
                    8
                                               FOR THE COUNTY OF LOS ANGELES – CENTRAL DISTRICT
                    9

                  10
                                                                                                     Case No.: BC722093 [Assigned for all
                  11 OLUFEMI OGUNTOLU,                                                               purposes to the Honorable Gregory Alarcon]
                  12                                                   Plaintiff,                    PLAINTIFF’S SEPARATE STATEMENT
                                     vs.                                                             IN SUPPORT OF PLAINTIFF’S
                  13                                                                                 MOTION FOR ORDER OF
                                                                                                     EVIDENTIARY AND/OR ISSUE
                  14 NINA MONTOYA, An Individual, and                                                SANCTIONS BARRING
                                                                                                     INTRODUCTION OF EVIDENCE AND
                  15 Does 1 – 10, Inclusive,                                                         ISSUES AT TRIAL; DECLARATION OF
                                                                                                     SUSAN L. CALDWELL IN SUPPORT
                  16                                                    Defendants.
                                                                                                     [Filed concurrently with Plaintiff Oguntolu’s
                  17                                                                                 Motion for Evidence and Issue Sanctions per
                                                                                                     CCP§ 2023, et seq.]
                  18
                                                                                                     Reservation No. 284510261972
                  19
                                                                                                     DATE: November 8, 2019
                  20                                                                                 TIME: 8:30 am
                                                                                                     DEPT: 36
                  21
                                                                                                     FAC Filed: October 19, 2018
                  22                                                                                 Trial: December 11, 20193
                  23

                  24 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:

                  25                 Pursuant to California Rule of Court 3.1345, Plaintiff submits this Separate Statement in
                         support of her Motion for an Order of Evidentiary and/or Issue Sanctions against Defendant Nina C.
                  26
                         Montoya (“Defendant”), and her counsel, barring introduction of evidence and issues at trial.
                  27

                  28
                                                                                            -1-
                                                                                    SEPARATE STATEMENT