Motion-Secondary: PRISCILLA CLARKE VS LEWIS WILKINS

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 01/27/2020 10:50 AM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Gomez,Deputy Clerk


                   Steve Lopez (SBN 224540)
             1     LAW OFFICE OF STEVE LOPEZ
                   8562 Florence Avenue., Ste A. Downey, CA 90240 Suite A
             2     Telephone: (562) 904-1193
                   Facsimile: (562)262-2846
             3     steve@stevelopezlaw.com
             4     Attorney for Plaintiff
                   Priscilla Clarke
             5
             6                  SUPERIOR COURT OF THE STATE OF CALIFORNIA, LOS ANGELES
             7                             CENTRAL DISTRICT – STANLEY MOSK COURTHOUSE
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                                                        )                                      CASE NO.: 18STLC09925
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                   PRISCILLA CLARKE, an individual      )                                      REPLY TO DEFENDANT’S OPPOSITION
           10                                           )                                      TO PLAINTIFF’S SUPPLEMENTAL
                                             PLAINTIFF, )                                      MOTION FOR SUMMARY JUDGMENT
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                   v.                                   )                                      Date : February 3, 2020
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                   LEWIS WILKINS, an individual; and    )                                      Time : 10:30 a.m.
           13      DOES 1-10                            )                                      Dept. : 94
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           14                               DEFENDANTS. )                                      RESERVATION NO. 089705261510
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           20                                                               I. INTRODUCTION
           21                  In opposing the Plaintiff’s Motion for Summary Judgment, defendant makes a series of
           22      arguments that are not supported by the evidence, are irrelevant, and include misstatements
           23      or omissions of facts. Nothing raised by defendant shows that there is a genuine issue of
           24      material fact. Therefore, summary judgment should be granted for the plaintiff in this case.
           25                  The plaintiff has established that the defendant breached the contract and that the
           26      defendant must be estopped from asserting the statute of limitations as a defense to plaintiff's
           27      breach of contract claim. In an attempt to distract from the fact that defendant is estopped from
           28      asserting the statute of limitations as a defense, defendant presents several strawman arguments.

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                    PLAINTIFF’S REPY TO DEFENDANT’S OPPOSITION TO PLAINTIFF’S SUPPLEMENTAL MOTION FOR SUMMARY
                                                             JUDGMENT