Document for ROSEMARY NELSON ET AL VS FCA US LLC ET AL

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 02/25/2020 04:24 PM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Soto,Deputy Clerk




                     1      Barry R. Schirm (SBN 94553)
                            Ryan K. Marden (SBN 217709)
                     2      Mari Kiridjian (SBN 303277)
                            HAWKINS PARNELL & YOUNG LLP
                     3      445 South Figueroa Street, Suite 3200
                            Los Angeles, California 90071
                     4      Telephone: (213) 486-8000
                            Facsimile: (213) 486-8080
                     5      Email:      rmarden@hpylaw.com
                                        mkiridjian@hpylaw.com
                     6
                            Attorneys for Defendants
                     7      FCA US LLC and TUTTLE-CLICK, INC.
                     8                                    SUPERIOR COURT OF THE STATE OF CALIFORNIA
                     9                                                 FOR THE COUNTY OF LOS ANGELES
                   10

                   11       ROSEMARY NELSON and RICHARD          )                                    Case No.: BC692728
                            NELSON,                              )
                   12                                            )                                    Assigned for All Purposes to Hon. Rupert A.
                                                                 )                                    Byrdsong; Dept. 28
                   13                            Plaintiffs,
                                                                 )
                                                                 )                                    DEFENDANT FCA US LLC’S MOTION FOR NEW
                   14       vs.                                  )                                    TRIAL; DECLARATION OF RYAN K. MARDEN IN
                                                                 )                                    SUPPORT THEREOF
                   15       FCA US, LLC; TUTTLE-CLICK, INC.; and )
                            DOES 1 through 10, inclusive,        )
                   16                                            )                                    HEARING DATE: TBD
                                                 Defendants.     )                                    HEARING TIME: TBD
                   17                                            )
                                                                 )
                   18                                            )                                    Compliant Filed:                   February 2, 2018
                                                                 )                                    Trial Date:                        January 13, 2020
                   19

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                   21                  TO THE COURT, PLAINTIFF AND THEIR ATTORNEYS OF RECORD:

                   22                  PLEASE TAKE NOTICE THAT FCA US LLC hereby moves pursuant to California Code

                   23       659 of its intention to move this Court for an Order setting aside judgment entered in favor of

                   24       Plaintiff Rosemary Nelson and granting a new trial. The motion is made on the following grounds:

                   25                  (1) Irregularity in the proceedings of the court, jury or adverse party, or order of the Court by

                   26                        which FCA was prevented from having a fair trial (C.C.P 657(1));

                   27                  (2) Error in law, occurring at the trial and excepted by the party making the application

                   28                        (C.C.P 657(7)).
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                                            DEFENDANT FCA US LLC’S MOTION FOR NEW TRIAL; DECLARATION OF RYAN K. MARDEN
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