On September 20, 2017 a
Motion-Secondary
was filed
involving a dispute between
California Top Construction Inc.,
Fabian Pereyra Individually And Dba,
and
Business Alliance Insurance Company A,
Fabian Pereyra Individually And Dba,
for civil
in the District Court of Los Angeles County.
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‘ . .SuperiorFILED
Court of California
'
County of Los Angeles
NUII 16 ZIII8
1 PETER M. MARQUEZ, ESQ. SBN: 219823 Sherri R. w, 'ec I" r/Clerk of Court
LAW OFFICES OF PETER MARQUEZ By Deputy
2 2400 E. Katella Ave., Suite 800 on _Iv-iwiki
3 e ep one:CA %21§10§15 - 7529
Tnlahehim’
Fax: I714I919-0007 a I
4 County of Los Angeles I
5 Attorney for Defendants NOV 1 6 2018 I
6 Sherri B. Carter, Executive Iifticer/Clerk I
7 Bv:-_.______._____, Deputy
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 IN AND FOR THE COUNTY OF LOS ANGELES
10 '
CALIFORNIA TOP CONSTRUCTION I
11 W0 I CASE NO. VC 066578 BY FAX II
l2 P|aintiff(s), ) OPPOSITION TO PLAINTIFF’S MOTION I
13 I FOR LEAVE TO AMEND COMPLAINT; ;
vs. MEMORANDUM OF POINTS AND :
14 I AUTHORITIES.
15 FABIAN PEREYRA, individually and ) DECLARATION OF PETER MARQUEZ.
doing business as HOME REMEDIES I I
16 GENERAL CONTRACTOR, BUSINESS DATE: November 29. 2018 I
ALLIANCE INSURANCE COMPLAINT, TIME: 1:30 a.m. :
17 a corporation ; and DOES 1 through 100 PLACE: F I
inclusive.
18 Trial Date: O4/‘I 5/2019 I
Defendants I
19 ) I
20 I
21
22 TO ALL THE PARTIES AND THEIR ATTORNEYS OF RECORD: 5
I
23
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: I
24 I
25 Defendant FABIAN PEREYRA, individually and doing business as HOME I
REMEDIES GENERAL CONTRACTOR (hereafter Defendant) hereby submit his
26 I
O Opposition to PLAINTIFF’S Motion for Leave to Amend Complaint set for November 29,
27 I
2018, for reasons set forth below, P|aintiff’s Motion should be denied.
if 28 I
CA Top Construction V. Pereyra el: al. UV OPPOSITION TO MOTION TO AMEND Cf)iv1[“L7‘.I‘I’'‘ -
I1, CASE I-!0.: vc 066578
Document Filed Date
November 16, 2018
Case Filing Date
September 20, 2017
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‘ . .SuperiorFILED Court of California ' County of Los Angeles NUII 16 ZIII8 1 PETER M. MARQUEZ, ESQ. SBN: 219823 Sherri R. w, 'ec I" r/Clerk of Court LAW OFFICES OF PETER MARQUEZ By Deputy 2 2400 E. Katella Ave., Suite 800 on _Iv-iwiki 3 e ep one:CA %21§10§15 - 7529 Tnlahehim’ Fax: I714I919-0007 a I 4 County of Los Angeles I 5 Attorney for Defendants NOV 1 6 2018 I 6 Sherri B. Carter, Executive Iifticer/Clerk I 7 Bv:-_.______._____, Deputy 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE COUNTY OF LOS ANGELES 10 ' CALIFORNIA TOP CONSTRUCTION I 11 W0 I CASE NO. VC 066578 BY FAX II l2 P|aintiff(s), ) OPPOSITION TO PLAINTIFF’S MOTION I 13 I FOR LEAVE TO AMEND COMPLAINT; ; vs. MEMORANDUM OF POINTS AND : 14 I AUTHORITIES. 15 FABIAN PEREYRA, individually and ) DECLARATION OF PETER MARQUEZ. doing business as HOME REMEDIES I I 16 GENERAL CONTRACTOR, BUSINESS DATE: November 29. 2018 I ALLIANCE INSURANCE COMPLAINT, TIME: 1:30 a.m. : 17 a corporation ; and DOES 1 through 100 PLACE: F I inclusive. 18 Trial Date: O4/‘I 5/2019 I Defendants I 19 ) I 20 I 21 22 TO ALL THE PARTIES AND THEIR ATTORNEYS OF RECORD: 5 I 23 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: I 24 I 25 Defendant FABIAN PEREYRA, individually and doing business as HOME I REMEDIES GENERAL CONTRACTOR (hereafter Defendant) hereby submit his 26 I O Opposition to PLAINTIFF’S Motion for Leave to Amend Complaint set for November 29, 27 I 2018, for reasons set forth below, P|aintiff’s Motion should be denied. if 28 I CA Top Construction V. Pereyra el: al. UV OPPOSITION TO MOTION TO AMEND Cf)iv1[“L7‘.I‘I’'‘ - I1, CASE I-!0.: vc 066578