Request,Application: ANITA DOMINGUEZ VS AMERICAN CANCER SOCIETY ET AL

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 01/31/2019 05:20 PM Sherri R. Carter, Executive Officer/Clerk of Court, by A. Miro,Deputy Clerk




                     BLAIR & RAMIREZ LLP
               1     Oscar Ramirez (State Bar Number: 236768)
                     Matthew P. Blair (State Bar Number: 278411)
               2     David Osorio (State Bar Number: 323414)
                     515 South Flower Street, 19th Floor
               3     Los Angeles, California 90071
                     Telephone: 213.568.4000
               4     Facsimile: 213.568.4100

               5     Attorneys for Plaintiff ANITA DOMINGUEZ
               6

               7

               8
                                                     SUPERIOR COURT OF THE STATE OF CALIFORNIA
               9
                                                       COUNTY OF LOS ANGELES, CENTRAL DISTRICT
             10

             11                                                                                     CASE NO: BC701742
                     ANITA DOMINGUEZ, an individual,                                                (Assigned for aUpurposes to Hon. Dennis J.
             12                                                                                     Landin, Dept. 51)
                                                            Plaintiff,
             13                                                                                     PLAINTIFF'S OPPOSITION TO
                                vs.                                                                 DEFENDANTS' MOTION FOR RELIEF
             14                                                                                     FROM WAIYER OF DISCOVERY
                                                                                                    OBJECTIONS
             15      AMERICAN CANCER SOCIETY, a Georgia
                                                                                  14 2019
                     Corporation; MARLENE YIP, an individual, and Time:
                                                                  Date: February
                                                                         8:30 a.m. ,
             16      DOES 1 through 20, inclusive.                Dept. 51
             17                                             Defendants.                             Res. ID: 181114365666
             18                                                                                     Complaint Filed: April 11, 2018
                                                                                                    Trial: June 25, 2019
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             20                  TO THE HONORABLE COURT, ALL PARTIES AND THEIR ATTORNEYS OF

             21      RECORD:
             22                  PLEASE TAKE NOTICE that on February 14, 2019, at 8:30 a.m., or as soon thereafter as the

             23      matter may be heard in Department 51 of the above entitled court located at 111 N. Hill Street, Los

             24      Angeles, CA 90012, Plaintiff will oppose Defendants frivolous motion for relief under Cal. Civ. Code

             25      § 473(b), C.C.P. §§ 2030.290, and 2031.300, stemming from Defendants' failure to timely serve

             26      responses to Plaintiffs discovery requests. This opposition is based on the following grounds:

             27

             28                                                    1
                          PLAINTIFF'S OPPOSITION TO DEFENDANTS' MOTION FOR RELIEF FROM WAIVER OF DICSOVERY
                                                             OBJECTIONS