Document for SERGIO FLORES ET AL VS STATE FARM GENERAL INSURANCE CO ET AL

• 
• 

						
                                
Preview
                                @                                            @
          WLA LEGAL SERVICES, INC.                                                        FILED
          Steven Zelig (State Bar No. 94654)                                      Superior Court of California
          1543 7th Street, Suite 300                                                  County af tne Anceles
          Santa Monica, CA 90401
          Tel.: 310/393-6702                                                            AUG 17 2018
          Fax: 310/393-6703                                              Sherri K. Cases, carcuuve wuc
                                                                                                       er/Clerk
          Attorneys for Plaintiffs                                          By.                       hd, Deputy
                                                                                      Goathar Cavan




                                  SUPERIOR COURT OF THE STATE OF CALIFORNIA

                                          FOR THE COUNTY OF LOS ANGELES

          VERONICA FLORES, SERGIO FLORES,                           CASE NO. BC 677076
     10   and RAMON SANCHEZ,                                        (Assigned to the Honorable
                                                                    John P. Doyle, Dept. 58)
     11
                   Plaintiffs,                                      PLAINTIFFS' NOTICE OF
     12                                                             SUBMISSION OF VERIFIED
             vs.                                                    RESPONSES TO REQUESTS FOR
     13                                                             ADMISSIONS SUPPLEMENTING
          STATE FARM GENERAL INSURANCE                              PLAINTIFFS' EARLIER-FILED
     14   COMPANY, ET AL.                                           OPPOSITION TO DEFENDANT
                                                                    STATE FARM'S MOTION TO
     15            Defendants.                                      ESTABLISH REQUESTS FOR
                                                                    ADMISSIONS AS ADMITTED;
     16                                                             DECLARATION OF STEVEN ZELIG
     17                                                             DATE:     08-27-18
                                                                    TIME:     8:30 A.M.
     18                                                             DEPT:     58
                                                                    TRIAL:    02-25-19
     19                                                             COMPLAINT FILED: 02-25-19
     20               Plaintiffs SERGIO FLORES, VERONICA FLORES, and RAMON SANCHEZ
     21   (collectively "Plaintiffs") hereby supplement their earlier-filed opposition to Defendant State Farm's

     22   Motion for an Order to Establish Requests for Admissions Admitted, so as to reflect service of
     23   verified responses in full compliance with C.C.P. Section 2033.100, et seq.

     24               Pursuant to C.C.P. Section 2033.280( c), the court shall not enter the Order deeming the

     25   subject requests for admissions admitted, where responses in full compliance with C.C.P. Section
     26   2033.100 et seq. have been served prior to the hearing -- as is the case here. As can be seen, each
     27   response is an unequivocal denial, clearly verified by Plaintiffs under penalty of perjury, and as such
2
he   28


                        Combined Opposition to Discovery Motions filed by the State Farm Defendants
                                          -
                                                               1