Document for THE HARTFORD STEAM BOILER INSPECTION VS. CITY OF BURBANK

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                                FILING FEE EXEMPT
                                                   '                             PURSUANT TO GOV. CODE § 6103




           1   AMELIA ANN ALBANO, CITY ATTORNEY                                       ._            "‘*¢
               State Bar No. 103640                                              Su
           2   CAROLYN A. BARNES, SR. ASST. CITY ATTY.                            8f)i11ntyofl;c>aAngele:~                E
               State Bar No. 113313                                                                                       I
           3   275 E. Olive Avenue                                                          17 2018               g       I
           4   Burbank, CA 91502                                            Sherri ‘~ r ' mu ‘ ‘I vmwr ‘Ierk
               (818) 238-5707                                                av     -
                                                                              0 SCOTT
           5   (818) 238-5724
           6   Attorney for Defendant CITY OF BURBANK


           7

           8                        SUPERIOR COURT OF THE STATE OF CALIFORNIA

           9                                     COUNTY OF LOS ANGELES
          10

          II    THE HARTFORD STEAM BOILER                       ) Case No.: EC06938O
          12    INSPECTION AND INSURANCE,                       )
                                                                )   DEFENDANT CITY OF BURBANK’S
          13                    Plaintiff,             ) SEPARATE STATEMENT OF
                                                         DISCOVERY IN DISPUTE REGARDING
                       V                               ) PLAINTIFF’S RESPONSES TO
          14             '                             ) DEFENDANT’S FORM AND SPECIAL
                                        ,    _         ) INTERROGATORIES, SET ONE,
          15    CITY OF BURBANK, a public entity, DOES )
                1 through 50 Inclusive,                ) [Filed Concurrently MOTION TO COMPEL
          16                                                        FURTHER RESPONSES]
                                Defendants.                     )
          17                                                    ) DATE: January 11,2018
                                                                ) TIME: 8:30 A.M
          18                                                    ) DEPT: A Burbank
          19                                                    )   RESERVATION #: 441253133879


          20
               TO PLAINTIFF AND ITS COUNSEL OF RECORD:

          21          PLEASE TAKE NOTICE THAT pursuant to California Rules of Court, Rule 3.1345,

          22   Defendant City of Burbank, les this separate statement of dispute in reference to Plaintiff

          23   Angelique Avery’s responses to Defendant City of Burbank’s Forrn Interrogatories, Set One, and

          24   its responses to Defendant City of Burbank’s that are at issue in this dispute. Plaintiff’ s

          25   responses to the Form Interrogatories, Set One, as well as and the factual and legal reasons for       I

          26   compelling Plaintiffs further response to both are as follows:
I_‘1,?*
          27

          28

                 DEFENDANT CITY OF BURBANK’S NOTICE OF MOTION AND MOTION TO COMPEL FURTHER
                RESPONSES TO, SPECIAL INTERROGATORIES AND TO FORM INTERROGATORIES, SET ONE;