DEFENDANT THE ADULT SKILLS CENTER'S REPLY TO PLAINTIFF'S RESPONSE TO SEPARATE STATEMENT OF UNDISPUTED MATERIAL FACTS IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT, OR IN THE ALTERNATIVE, FOR SUMMARY ADJUD - CAROLYN THOMAS VS THE ADULT SKILLS CENTER ET AL

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On June 20, 2017 an elder/dependent adult abuse case (general jurisdiction) case was filed by Thomas Carolyn, represented by Agello Frank P., Roy Legal Group, and Roy Raj D., against Contreras Grecia, Does 1 To 100, and The Adult Skills Center, represented by Beach * Cowdrey * Jenkins Llp, Beach Thomas, Pappas Louis W. Esq., and Renick Steven J., in the jurisdiction of Los Angeles County. Judge Richard Fruin presiding.

                        
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                    Louis W. Pappas (State Bar No. 118140)
                       lwp@manningllp.com                                                           FILED
                    Michael H. Cooper (State Bar No. 272124)                              Superloy Court of California
                                                                                              Cannes     of    Fae Anoeles
                       mhc@manningllp.com
                    Mae G. Alberto (State Bar No. 228067)
                       mga@manningllp.com                                                         MAY 18 2018
                    MANNING & KASS
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                                                                                    Sherri R. Ua tex, wrecutive Utttcer/Clerk of Court
                    ELLROD, RAM…