Motion,Ex Parte: DR JERROLD S DREYER MD ET AL VS JM CAPITAL INVESTMENTS LLC E

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 01/22/2019 05:13 PM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Hung,Deputy Clerk



                 1     DIANE GOLDMAN, SBN 89681
                       LAW OFFICE OF DIANE GOLDMAN
                 2     21860 Burbank Boulevard, Suite 360
                       Woodland Hills, CA 91367
                 3     (818) 883-3344
                       FAX (818) 883-3355
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                       Attorneys for Defendant,
                 5     KATHY MACIAS
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                 8                                SUPERIOR COURT OF THE STATE OF CALIFORNIA
                 9                                                      COUNTY OF LOS ANGELES
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               11        DR. JERROLD S. DREYER, M.D. et al.,                                       Case No.: BC714688
                                                                                                   (Judge Patricia Nieto-Dept. 24)
               12                                           Plaintiffs,
                                                                                                   DEFENDANT, KATHY MACIAS’ MOTION
               13                    v.                                                            TO STRIKE PORTIONS OF THE FIRST
                                                                                                   AMENDED COMPLAINT; DECLARATION
               14        JM CAPITAL INVESTMENTS LLC, et al.,                                       OF DIANE GOLDMAN; MEMORANDUM
                                                                                                   OF POINTS AND AUTHORITIES
               15                                           Defendants.                            Date: March 28, 2019 Time: 8:30 a.m.
                                                                                                   Dept: 24 Reserv. ID#: 283133547379
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                       TO: ALL PARTIES AND THEIR COUNSEL OF RECORD HEREIN:
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                                   PLEASE TAKE NOTICE that on March 28, 2019 at 8:30 a.m. in Department 24 of
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                       the above-entitled court, Defendant, KATHY MACIAS, will and does hereby move the court
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                       for an order striking the following portions of the First Amended Complaint herein:
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                                   1)         Exhibit “A” in its entirety;
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                                   2)         Exhibit “H” in its entirety; and
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                                   3)         Exhibit “I” in its entirety.
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                                   This motion is based upon the ground that the aforesaid portions of the First Amended
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                       Complaint are irrelevant, improper attempts to introduce evidence before the court at the
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                       pleading stage, and/or the pleading is “not drawn in accordance with law.”
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                                   This motion is further based upon this notice, the Declaration of Diane Goldman and
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                                                   DEFENDANT, KATHY MACIAS’ MOTION TO STRIKE PORTIONS
                                                  OF THE FIRST AMENDED COMPLAINT; DECLARATION OF DIANE
                                                    GOLDMAN; MEMORANDUM OF POINTS AND AUTHORITIES