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 03/16/2021 06:48 PM Sherri R. Carter, Executive Officer/Clerk of Court, by J. So,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.
RESPONSE TO OBJECTION TO
ENCINO, CALIFORNIA 91436
13 THE CITY OF LOS ANGELES, a public PLAINTIFF'S REPLY SEPARATE
entity; and DOES 1 through 40, inclusive, STATEMENT
14
Defendants. Reservation ID: 402466525886
15
Date: March 19, 2021
16
Time: 10:00 a.m.
17 Dept: 53
18 Action Filed: December 27, 2017
TRIAL: June 9, 2021
19 FSC: May 28, 2021
20 Plaintiff objects to the City's Reply Separate Statement on grounds that there is no specific
21 provision in the Code of Civil Procedure ("CCP") or California Rules of Court ("CRC") authorizing a
22 reply separate statement. There is also nothing in the CCP nor the CRC that prohibits a reply separate
23 statement. In fact, the only exception that subdivision (c) of CCP §437c places on the requirement for
24 the Court to consider "all the papers submitted" is consideration of evidence to which objections
25 have been sustained. The Court has inherent power to exercise its discretion and control over all
26 proceedings before it, including consideration of a reply separate statement. Neither Nazir v. United
27 Airlines, Inc. nor San Diego Watercrafts. v. Wells Fargo is suggests otherwise, as those cases
28 prohibited new evidence submitted with a reply. The City's reply separate statement of facts does not
1498076.1 1
RESPONSE TO OBJECTION TO PLAINTIFF'S REPLY SEPARATE STATEMENT
Document Filed Date
March 16, 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 03/16/2021 06:48 PM Sherri R. Carter, Executive Officer/Clerk of Court, by J. So,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. RESPONSE TO OBJECTION TO ENCINO, CALIFORNIA 91436 13 THE CITY OF LOS ANGELES, a public PLAINTIFF'S REPLY SEPARATE entity; and DOES 1 through 40, inclusive, STATEMENT 14 Defendants. Reservation ID: 402466525886 15 Date: March 19, 2021 16 Time: 10:00 a.m. 17 Dept: 53 18 Action Filed: December 27, 2017 TRIAL: June 9, 2021 19 FSC: May 28, 2021 20 Plaintiff objects to the City's Reply Separate Statement on grounds that there is no specific 21 provision in the Code of Civil Procedure ("CCP") or California Rules of Court ("CRC") authorizing a 22 reply separate statement. There is also nothing in the CCP nor the CRC that prohibits a reply separate 23 statement. In fact, the only exception that subdivision (c) of CCP §437c places on the requirement for 24 the Court to consider "all the papers submitted" is consideration of evidence to which objections 25 have been sustained. The Court has inherent power to exercise its discretion and control over all 26 proceedings before it, including consideration of a reply separate statement. Neither Nazir v. United 27 Airlines, Inc. nor San Diego Watercrafts. v. Wells Fargo is suggests otherwise, as those cases 28 prohibited new evidence submitted with a reply. The City's reply separate statement of facts does not 1498076.1 1 RESPONSE TO OBJECTION TO PLAINTIFF'S REPLY SEPARATE STATEMENT