On June 20, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
Thomas Carolyn,
and
Contreras Grecia,
Does 1 To 100,
The Adult Skills Center,
for Elder/Dependent Adult Abuse Case (General Jurisdiction)
in the District Court of Los Angeles County.
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co @
BEACH + COWDREY + JENKINS. LLp
500 E. ESPLANADE DRIVE, SUITE 1400
ARD, ALIFORI 036
PH (805) 00
FA IMI ) 388-3414 FILED
Superior Court of California
Thomas E. Beach - State Bar No. 096321 County of Los Angeles
Darryl C. Hottinger — State Bar No. 201870
Varouj Arabian - State Bar No. 242919 NOV 08 2017
mail@beachcowdrey.com
At Ade.
Sherri
R. Carter, Executi Officer/Clerk
Attorneys for Defendant,
GRECIA CONTRERAS By. . . Deputy
Moses Soto
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT
10
11 CAROLYN THOMAS, Case No. BC665771
Complaint Filed 06/20/2017
12 Plaintiff,
Assigned to Hon. Richard Fruin, Dept. 15
Z, gs 13 y.
Ra
DEFENDANT GRECIA CONTRERAS’
14 THE ADULT SKILLS CENTER, A California NOTICE OF MOTION AND MOTION TO
Non-Profit Corporation, GRECIA STRIKE PORTIONS OF PLAINTIFF’S
15 CONTRERAS, an Individual, and DOES 1 50 COMPLAINT; MEMORANDUM OF
100, Inclusive, POINTS AND AUTHORITIES
16
Defendants. Date: December 21, 2017
17 Time: 9:30 a.m.
18
Dept.: 15
By Fax
Trial Date: None
19
RES ID: 171108265447
20
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
21
PLEASE TAKE NOTICE THAT on December 21, 2017, at 8:30 a.m., or as soon
22
thereafter as the matter may be heard, in Department 15 of the above-entitled court, located at 111
23
N. Hill Street, Los Angeles, California 90012, defendant, GRECIA CONTRERAS, for herself and
24
herself alone, will and hereby does move the Court to strike portions of the plaintiff's Complaint
25
as follows:
26
i] I “ “Statuto: Damages”:
27 —piatutory Damages”:
i=l “6. For statutory damages.” (Complaint, p. 10:10.)
28.
1 1
| DEFENDANT GRECIA CONTRERAS’ NOTICE OF MOTION AND MOTION TO STRIKE PORTIONS OF
PLAINTIFF’S COMPLAINT
Document Filed Date
November 08, 2017
Case Filing Date
June 20, 2017
Category
Elder/Dependent Adult Abuse Case (General Jurisdiction)
Status
Jury Verdict 11/26/2018
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co @ BEACH + COWDREY + JENKINS. LLp 500 E. ESPLANADE DRIVE, SUITE 1400 ARD, ALIFORI 036 PH (805) 00 FA IMI ) 388-3414 FILED Superior Court of California Thomas E. Beach - State Bar No. 096321 County of Los Angeles Darryl C. Hottinger — State Bar No. 201870 Varouj Arabian - State Bar No. 242919 NOV 08 2017 mail@beachcowdrey.com At Ade. Sherri R. Carter, Executi Officer/Clerk Attorneys for Defendant, GRECIA CONTRERAS By. . . Deputy Moses Soto SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT 10 11 CAROLYN THOMAS, Case No. BC665771 Complaint Filed 06/20/2017 12 Plaintiff, Assigned to Hon. Richard Fruin, Dept. 15 Z, gs 13 y. Ra DEFENDANT GRECIA CONTRERAS’ 14 THE ADULT SKILLS CENTER, A California NOTICE OF MOTION AND MOTION TO Non-Profit Corporation, GRECIA STRIKE PORTIONS OF PLAINTIFF’S 15 CONTRERAS, an Individual, and DOES 1 50 COMPLAINT; MEMORANDUM OF 100, Inclusive, POINTS AND AUTHORITIES 16 Defendants. Date: December 21, 2017 17 Time: 9:30 a.m. 18 Dept.: 15 By Fax Trial Date: None 19 RES ID: 171108265447 20 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 21 PLEASE TAKE NOTICE THAT on December 21, 2017, at 8:30 a.m., or as soon 22 thereafter as the matter may be heard, in Department 15 of the above-entitled court, located at 111 23 N. Hill Street, Los Angeles, California 90012, defendant, GRECIA CONTRERAS, for herself and 24 herself alone, will and hereby does move the Court to strike portions of the plaintiff's Complaint 25 as follows: 26 i] I “ “Statuto: Damages”: 27 —piatutory Damages”: i=l “6. For statutory damages.” (Complaint, p. 10:10.) 28. 1 1 | DEFENDANT GRECIA CONTRERAS’ NOTICE OF MOTION AND MOTION TO STRIKE PORTIONS OF PLAINTIFF’S COMPLAINT