On February 21, 2018 a
Motion-Secondary
was filed
involving a dispute between
Los Angeles County Of By And Through,
and
Association For Los Angeles Deputy,
Los Angeles County Employee Relations,
Ramirez Esmeralda Assistant Director Los Angeles County Sheriff'S Department Personnel Administration Bureau,
for civil
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 02/16/2022 06:18 PM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Soto,Deputy Clerk
1 JACOB A. KALINSKI, SBN 233709
GIDIAN R. MELLK, SBN 214404
2 BRIAN P. ROSS, SBN 273991
RAINS LUCIA STERN ST. PHALLE & SILVER, PC
3
1428 2nd Street, Suite 200
4 Santa Monica, Ca 90401
Tel: (310) 393-1486
5 Fax: (310) 395-5801
E-Mail: jkalinski@rlslawyers.Com
6
7 Attorneys For Cross-Petitioner/Cross-Plaintiff
Association For Los Angeles Deputy Sheriffs
8
SUPERIOR COURT OF THE STATE OF CALIFORNIA
9
IN AND FOR THE COUNTY OF LOS ANGELES
10
11 COUNTY OF LOS ANGELES, BY AND CASE NO. BC 712068
THROUGH ITS SHERIFF’S DEPARTMENT,
12 [Assigned for All Purposes to the Hon. Mary
Plaintiffs/Petitioners H. Strobel, Dept. 82]
13 vs.
14 EVIDENTIARY OBJECTIONS TO
ASSOCIATION FOR LOS ANGELES EVIDENCE SUBMITTED BY COUNTY
15 DEPUTY SHERIFFS, et al., OF LOS ANGELES IN OPPOSITION
TO CROSS-PETITIONER/CROSS-
16 Defendants/Respondents. PLAINTIFF ASSOCIATION FOR LOS
_______________________________________ ANGELES DEPUTY SHERIFFS’
17
ASSOCIATION FOR LOS ANGELES SECOND MOTION TO ENFORCE
18 DEPUTY SHERIFFS, WRIT OF MANDATE
19 Cross-Petitioners/Cross-Plaintiffs [Filed concurrently with ALADS’ Reply to
Opposition to Motion to Enforce;
20 vs. Supplemental Declaration of Dan Nathan;
Supplemental Declaration of Ervin Francios;
21
COUNTY OF LOS ANGELES, a political Declaration of Derek Hsieh; Proposed
22 subdivision of the State of California; LOS Order]
ANGELES COUNTY SHERIFF’S
23 DEPARTMENT; a political subdivision of the [CCP § 1097; Gov. Code § 800]
County of Los Angeles; and ROES 1 through 40,
24 inclusive,
Cross-Petition filed: August 17, 2019
25
Cross-Respondents/Cross-
26 Defendants. Date: February 24, 2022
Time: 1:30 p.m.
27 Dept.: 82
28
1
RAINS LUCIA STERN
EVIDENTIARY OBJECTIONS IN SUPPORT OF SECOND MOTION TO ENFORCE
ST. PHALLE & SILVER. PC
Document Filed Date
February 16, 2022
Case Filing Date
February 21, 2018
Status
Court Finding - After Court Trial 07/14/2020
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 02/16/2022 06:18 PM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Soto,Deputy Clerk 1 JACOB A. KALINSKI, SBN 233709 GIDIAN R. MELLK, SBN 214404 2 BRIAN P. ROSS, SBN 273991 RAINS LUCIA STERN ST. PHALLE & SILVER, PC 3 1428 2nd Street, Suite 200 4 Santa Monica, Ca 90401 Tel: (310) 393-1486 5 Fax: (310) 395-5801 E-Mail: jkalinski@rlslawyers.Com 6 7 Attorneys For Cross-Petitioner/Cross-Plaintiff Association For Los Angeles Deputy Sheriffs 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE COUNTY OF LOS ANGELES 10 11 COUNTY OF LOS ANGELES, BY AND CASE NO. BC 712068 THROUGH ITS SHERIFF’S DEPARTMENT, 12 [Assigned for All Purposes to the Hon. Mary Plaintiffs/Petitioners H. Strobel, Dept. 82] 13 vs. 14 EVIDENTIARY OBJECTIONS TO ASSOCIATION FOR LOS ANGELES EVIDENCE SUBMITTED BY COUNTY 15 DEPUTY SHERIFFS, et al., OF LOS ANGELES IN OPPOSITION TO CROSS-PETITIONER/CROSS- 16 Defendants/Respondents. PLAINTIFF ASSOCIATION FOR LOS _______________________________________ ANGELES DEPUTY SHERIFFS’ 17 ASSOCIATION FOR LOS ANGELES SECOND MOTION TO ENFORCE 18 DEPUTY SHERIFFS, WRIT OF MANDATE 19 Cross-Petitioners/Cross-Plaintiffs [Filed concurrently with ALADS’ Reply to Opposition to Motion to Enforce; 20 vs. Supplemental Declaration of Dan Nathan; Supplemental Declaration of Ervin Francios; 21 COUNTY OF LOS ANGELES, a political Declaration of Derek Hsieh; Proposed 22 subdivision of the State of California; LOS Order] ANGELES COUNTY SHERIFF’S 23 DEPARTMENT; a political subdivision of the [CCP § 1097; Gov. Code § 800] County of Los Angeles; and ROES 1 through 40, 24 inclusive, Cross-Petition filed: August 17, 2019 25 Cross-Respondents/Cross- 26 Defendants. Date: February 24, 2022 Time: 1:30 p.m. 27 Dept.: 82 28 1 RAINS LUCIA STERN EVIDENTIARY OBJECTIONS IN SUPPORT OF SECOND MOTION TO ENFORCE ST. PHALLE & SILVER. PC