Motion,Ex Parte: FADI ELLAHIB VS ERIK JAMES WANLAND ET AL

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 11/09/2022 12:22 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Lopez,Deputy Clerk




               1        PATRICIA R. VALENZUELA (SBN 132904)
                        pvalenzuela@guideone.law
               2        PO Box 14503
                        Des Moines, IA 50306-3503
               3        Telephone: (515) 267-5252
                        Fax: (515) 267-5431
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                        Attorney for Defendant, Islamic Center of Claremont
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                                              IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
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                                                                         COUNTY OF LOS ANGELES
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                        FADI ELLAHIB, a minor by and through his                                  CASE NO.: BC709831
               9        Guardian Ad Litem HATOUM ELLAHIB,
                                                                                                   DEFENDANT ISLAMIC CENTER OF
             10                                                                                    CLAREMONT’S NOTICE OF MOTION
                                                          Plaintiff,                               TO BIFURCATE TRIAL,
             11                                                                                    MEMORANDUM OF POINTS AND
                                   v.                                                              AUTHORITIES IN SUPPORT
             12                                                                                    THEREOF, DECLARATION OF
                        ERIK JAMES WANLAND, STATE OF                                               PATRICIA R VALENZUELA
             13                                                                                   Dept.: 31
                        CALIFORNIA, ISLAMIC CENTER OF
                                                                                                  Judge: Hon. Yolanda Orozco
             14         CLAREMONT, and DOES 1 to 30,                                              Complaint Filed: 6/11/18
                                                                                                  Trial Date: 1/10/23
             15                                              Defendants.
                                                                                                  Hearing Date: December 01, 2022
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                                                                                                  Hearing Time: 1:30 p.m.
             17                                                                                   Department: 31
                                                                                                  Reservation ID.: 555665297619
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             19         TO ALL PARTIES AND THEIR RESPECTIVE ATTORNEYS OF RECORD:
             20                    PLEASE TAKE NOTICE that on December 1, 2022, at 1:30 pm, or as soon thereafter
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                        as the matter may be heard in Department of the above-entitled court, Defendant, The Islamic
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                        Center, will move the court for an order granting a prior separate trial on liability before trial on
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             24         damages issues this action.

             25                    This motion will be made on the grounds that a prior separate trial on liability issues will
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                        promote the ends of justice, promote judicial economy and convenience of witnesses and will
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