Response - RESPONSE PLAINTIFFS REQUEST PURSUANT TO C.C.P. 437C H FOR THE COURT TO DENY DEFENDANTS MOTIONS FOR SUMMARY JUDGMENT OR CONTINUE THE HEARING ON THEM PENDING COMPLETION OF DISCOVERY; MEMORAND

On February 26, 2018 a toxic tort/environmental (general jurisdiction) case was filed by Benitez Carla, Benitez Margarita, and Marguarita Benitez As Successor-In Interest To Decedent Raul Guadalupe Benitez, represented by Metzger Raphael, against Axiall Corporation, Does 1 To 250, Ecolab Inc. et al. represented by Botros Samantha A., Drapalski H Joseph Iii, Gilhuly R. Morgan et al. in the jurisdiction of Los Angeles County. Judge Richard J. Burdge Jr. presiding.

                        
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Electronically FILED by Superior Court of California, County of Los Angeles on 12/08/2021 09:17 AM Sherri R. Carter, Executive Officer/Clerk of Court, by R. Sanchez,Deputy Clerk F:\WP\Cases\1500\SUM-JUDG\CCP 437c(h) Request.wpd 1 METZGER LAW GROUP telecopier (562) 436-1561 telephone (562) 437-4499 toll-free (877) tox-tort www.toxictorts.com A PROFESSIONAL LAW CORPORATION 2 RAPHAEL METZGER, ESQ., SBN 116020 SCOTT P. BRUST, ESQ. SBN 215951 3 555 E. OCEAN BLVD., SU…

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