Motion,Ex Parte: HEATHER C STOTTS VS ARTT LEDESMA ET AL

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 07/13/2020 03:14 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Lopez,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
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                               HEATHER C. STOTTS, an individual,                                       Case No.: BC721898
                        11                                                                             Judge: Hon. Laura A. Seigle
                        12                            Plaintiff,                                       Dept.: 27 – Spring Street
                                           v.
                        13                                                                             DEFENDANT WALTER NALLY JR.’S
                           ARTT LEDESMA; RENEE LEDESMA;                                                NOTICE OF MOTION AND MOTION TO
                        14 COLDWELL BANKER OLYMPIC;                                                    DEEM REQUESTS FOR ADMISSION, SET
                           WALTER NALLY, JR. (sued as DOE 11);                                         ONE, SERVED ON PLAINTIFF HEATHER
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                           and DOES 1 to 25,                                                           STOTTS, ADMITTED; REQUEST FOR
                        16                                                                             SANCTIONS; MEMORANDUM OF POINTS
                                        Defendants.                                                    AND AUTHORITIES
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                                                                                                       Date: December 16, 2020
                        18                                                                             Time: 8:30 a.m.
                        19                                                                             Dept.: 27
                                                                                                       Reservation ID: 359955255032
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                                                                                                       Complaint Filed: September 14, 2018
                        21                                                                             Final Status Conference: August 28, 2020
                        22                                                                             Trial Date: September 18, 2020

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                               TO THE COURT, ALL PARTIES AND THEIR COUNSEL OF RECORD:
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                                           PLEASE TAKE NOTICE that on December 16, 2020 at 8:30 a.m. or as soon thereafter as
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                               the matter may be heard in Department 27 of the above entitled Court located at Spring Street
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                               Courthouse, 312 North Spring Street, Los Angeles, CA 90012, Defendant WALTER NALLY, JR.
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                               (“Defendant”) will and hereby does move this court for an Order deeming admitted the truth of
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                                                                          -1-
                        29         DEFENDANT WALTER NALLY JR.’S NOTICE OF MOTION AND MOTION TO DEEM REQUESTS FOR
                                    ADMISSION, SET ONE, SERVED ON PLAINTIFF HEATHER STOTTS, ADMITTED; REQUEST FOR
                        30                        SANCTIONS; MEMORANDUM OF POINTS AND AUTHORITIES