Motion-Secondary: HEATHER C STOTTS VS ARTT LEDESMA ET AL

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 09/25/2020 03:21 PM Sherri R. Carter, Executive Officer/Clerk of Court, by L. Coreas,Deputy Clerk



                      1 CRUSER, MITCHELL, NOVITZ,
                        SANCHEZ, GASTON & ZIMET LLP
                      2 Marc J. Zimet (SBN 183111)

                      3 Martin S. Gattas (SBN 316898)
                        800 Wilshire Boulevard, 15th Floor
                      4 Los Angeles, CA 90017
                        213-689-8500 (phone)
                      5 213-689-8501 (fax)

                      6 Attorneys for Defendant

                      7 WALTER NALLY, JR.

                      8                                SUPERIOR COURT OF THE STATE OF CALIFORNIA
                      9                                              FOR THE COUNTY OF LOS ANGELES
                    10
                           HEATHER C. STOTTS, an individual,                                       Case No.: BC721898
                    11                                                                             Judge: Hon. Edward B. Moreton
                                                  Plaintiff,                                       Dept.: 27 – Spring Street
                    12                 v.
                    13                                                                             DEFENDANT WALTER NALLY, JR.’S
                       ARTT LEDESMA; RENEE LEDESMA;                                                EVIDENTIARY OBJECTIONS TO
                    14 COLDWELL BANKER OLYMPIC;                                                    DECLARATION OF JARED GROSS FILED IN
                       WALTER NALLY, JR. (sued as DOE 11);                                         SUPPORT OF OPPOSITION TO
                    15 and DOES 1 to 25,                                                           DEFENDANTS’ MOTION TO DISMISS FOR
                    16                                                                             DELAY IN PROSECUTION
                                                  Defendants.
                    17                                                                             Date: September 28, 2020
                                                                                                   Time: 1:30 p.m.
                    18                                                                             Dept.: 27
                    19

                    20                                                                             Complaint Filed: September 14, 2018
                                                                                                   Final Status Conference: August 28, 2020
                    21                                                                             Trial Date: January 26, 2021

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                           TO THE COURT, ALL PARTIES AND THEIR COUNSEL OF RECORD:
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                                       PLEASE TAKE NOTICE THAT Defendant WALTER NALLY, JR. (“Nally”) hereby
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                           submits these objections to Plaintiff Heather Stotts’ (“Plaintiff”) evidence in support of its
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                           Opposition Motion to Dismiss Plaintiff’s Complaint for Delay in Prosecution and related Joinder
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                           of Motion to Dismiss (the “Motion”), which is scheduled to be heard on September 28, 2020 at
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                           1:30 p.m. in Department 27 of the above entitled Court located at Spring Street Courthouse, 312
                    28
                                                                     -1-
                    29     DEFENDANT WALTER NALLY, JR.’S EVIDENTIARY OBJECTIONS TO DECLARATION OF JARED GROSS
                               FILED IN SUPPORT OF OPPOSITION TO DEFENDANTS’ MOTION TO DISMISS FOR DELAY IN
                    30                                          PROSECUTION