On December 27, 2017 a
Motion-Secondary
was filed
involving a dispute between
Sierra Annette,
and
The City Of Los Angeles,
for Other Employment Complaint Case (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 10/07/2021 12:41 AM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Lara,Deputy Clerk
(SPACE BELOW FOR FILING STAMP ONLY)
1 LINDA MILLER SAVITT, SBN 94164
lsavitt@brgslaw.com
2 PHILIP L. REZNIK, SBN 204590
preznik@brgslaw.com
3 BALLARD ROSENBERG GOLPER & SAVITT, LLP
15760 Ventura Boulevard, 18th Floor
4 Encino, CA 91436
Telephone: (818) 508-3700
5 Facsimile: (818) 506-4827
6 Attorneys for Defendant
CITY OF LOS ANGELES
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF LOS ANGELES
10 ANNETTE SIERRA, an individual, CASE NO. BC 688510
BALLARD ROSENBERG GOLPER & SAVITT, LLP
11 Plaintiff, [Assigned to Hon. Robert B. Broadbelt]
Dept. 53]
15760 VENTURA BOULEVARD, EIGHTEENTH FLOOR
12 vs.
DEFENDANT CITY'S REPLY IN
ENCINO, CALIFORNIA 91436
13 THE CITY OF LOS ANGELES, a public SUPPORT OF ITS MOTION TO
entity; and DOES 1 through 40, inclusive, COMPEL FURTHER RESPONSES TO
14 DISCOVERY
Defendants.
15
Date: October 14, 2021
16 Time: 8:30 AM
Dept.: 53
17
Reservation No.: 691316191173
18
Action Filed: December 27, 2017
19 TRIAL: February , 2022
FSC: February 4, 2022
20
21 Plaintiff argues in her Opposition that the City is not entitled to discovery regarding her ability
22 to perform the essential functions of a Deputy City Attorney, nor is it entitled to discovery as to
23 whether she cooperated in good faith in the City's efforts to accommodate her because: "as currently
24 pled, this case has not placed the quality of Plaintiff's job performance at issue – only the City's ability
25 to accommodate the restrictions provided by her physicians." (Opp. at 4:21-23.) This is nonsense.
26 The courts have long recognized that, in order to prove that an employer failed to provide reasonable
27
28
1624134.1 1
DEFENDANT CITY'S REPLY RE: MOTION TO COMPEL FURTHER RESPONSES
Document Filed Date
October 07, 2021
Case Filing Date
December 27, 2017
Category
Other Employment Complaint Case (General Jurisdiction)
Status
Request for Dismissal - Before Trial not following ADR or more than 60 days since ADR 11/13/2023
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Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 10/07/2021 12:41 AM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Lara,Deputy Clerk (SPACE BELOW FOR FILING STAMP ONLY) 1 LINDA MILLER SAVITT, SBN 94164 lsavitt@brgslaw.com 2 PHILIP L. REZNIK, SBN 204590 preznik@brgslaw.com 3 BALLARD ROSENBERG GOLPER & SAVITT, LLP 15760 Ventura Boulevard, 18th Floor 4 Encino, CA 91436 Telephone: (818) 508-3700 5 Facsimile: (818) 506-4827 6 Attorneys for Defendant CITY OF LOS ANGELES 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF LOS ANGELES 10 ANNETTE SIERRA, an individual, CASE NO. BC 688510 BALLARD ROSENBERG GOLPER & SAVITT, LLP 11 Plaintiff, [Assigned to Hon. Robert B. Broadbelt] Dept. 53] 15760 VENTURA BOULEVARD, EIGHTEENTH FLOOR 12 vs. DEFENDANT CITY'S REPLY IN ENCINO, CALIFORNIA 91436 13 THE CITY OF LOS ANGELES, a public SUPPORT OF ITS MOTION TO entity; and DOES 1 through 40, inclusive, COMPEL FURTHER RESPONSES TO 14 DISCOVERY Defendants. 15 Date: October 14, 2021 16 Time: 8:30 AM Dept.: 53 17 Reservation No.: 691316191173 18 Action Filed: December 27, 2017 19 TRIAL: February , 2022 FSC: February 4, 2022 20 21 Plaintiff argues in her Opposition that the City is not entitled to discovery regarding her ability 22 to perform the essential functions of a Deputy City Attorney, nor is it entitled to discovery as to 23 whether she cooperated in good faith in the City's efforts to accommodate her because: "as currently 24 pled, this case has not placed the quality of Plaintiff's job performance at issue – only the City's ability 25 to accommodate the restrictions provided by her physicians." (Opp. at 4:21-23.) This is nonsense. 26 The courts have long recognized that, in order to prove that an employer failed to provide reasonable 27 28 1624134.1 1 DEFENDANT CITY'S REPLY RE: MOTION TO COMPEL FURTHER RESPONSES