Motion,Ex Parte: FELIX REYES VS ANTONY DIAZ

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 03/29/2019 06:13 PM Sherri R. Carter, Executive Officer/Clerk of Court, by C. Coleman,Deputy Clerk




                 1 Justin Toobi, Esq. (SBN:296174)
                   600 Wilshire Blvd., #500
                 2 Los Angeles, CA 90017
                   Telephone: (310) 435-9407
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                   Attorney for Plaintiff,
                 4 FELIX REYES
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                                                                       SUPERIOR COURT OF CALIFORNIA
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                                                          COUNTY OF LOS ANGELES - CENTRAL DISTRICT
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                       FELIX REYES, an individual,                                                    Case No. BC668338
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                 9     Plaintiff,                                                                     Assigned for all purposes to Department 32, Honorable
                                                                                                      Daniel Murphy presiding
               10                vs.
                                                                                                      AMENDED NOTICE OF MOTION AND MOTION
               11      ANTONY DIAZ, an individual, and DOES 1-                                        FOR NEW TRIAL; MEMORANDUM OF POINTS
                       10, inclusive,                                                                 AND AUTHORITIES IN SUPPORT THEREOF;
               12                                                                                     DECLARATION OF JUSTIN TOOBI, ESQ.
               13      Defendants.
                                                                                                      HEARING
               14                                                                                     Date:   May 20, 2019
                                                                                                      Time:   8:30 a.m.
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                                                                                                      [RESERVATION ID: 284443889036]
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                      TO THE HONORABLE COURT AND DEFENDANTS’ ATTORNEY OF RECORD:
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                                 PLEASE TAKE NOTICE that on May 20, 2019 or as soon as the matter may be heard in
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                      Department 32, Plaintiff will move and hereby does move this Court for a new trial on all issues. Plaintiff
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                      submits this amended motion with a hearing date, reservation number and receipt. No other changes have
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                      been made from the motion previously served and submitted to the Court but rejected by the Court clerk.
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                                 This motion will be made pursuant to Code of Civil Procedure section 657, subsections (1), (5) and
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                      (6) on the grounds that:
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                                             1. Defendant’s motion and the Court’s minutes do not address Plaintiff’s cause of action
               25                                 for wrongful termination and as such at least that claim remains.
               26                            2. Plaintiff’s claims state sufficient facts to constitute causes of action and are not precluded
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               28           PLAINTIFF’S AMENDED NOTICE OF MOTION AND MOTION FOR NEW TRIAL; MEMORANDUM OF
                              POINTS AND AUTHORITIES IN SUPPORT THEREOF; DECLARATION OF JUSTIN TOOBI, ESQ.