Document for MYNOR DAVID JIMENEZ VS LOS ANGELES COUNTY METROPOLITAN TRAN

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 11/14/2019 02:27 PM Sherri R. Carter, Executive Officer/Clerk of Court, by L. Coreas,Deputy Clerk




                      Ravmond Ghermezian, Esq. (SBN 198?77)
                     RAYMOND GHERMEZIAN,
                     A PROFESSIONAL LAW CORPORATION
                      3435 Wilshire Boulevard, ¹1800
                      Los Angeles, CA 90010
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                     Telephone: (323) 900-5800
                     Facsimile: (323) 900-5801
                     Attornev for Plaintiffs,
                     MYNOR DAVID JIMENEZ
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                                                 SUPERIOR COURT OF THE STATE OF CALIFORNIA
             10                                               FOR THE COUNTY OF LOS ANGELES

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                       MYNOR DAVID JIMENEZ, an individual,                                         Case No.: BC650741
                                                Plaintiffs,                                       DECLARATION OF RAYMOND
                                                                                                  GHERMEZIAN IN OPPOSITION TO
                                                V.                                                DEFENDANT'S MOTION FOR
                                                                                                  TERMINATING SANCTIONS, FORM
                       LOS ANGELES COUNTY                                                         INTERROGATORIES,(SET TWO),
                       METROPOLITAN TRANSPORTATION                                                REQUEST FOR ADMISSIONS, (SET
                       AUTHORITY; DOE BUS DRIVER; and                                             ONE)
             16        DOES 1 to 100, Inclusive,
                                                                                                  Date: November 18, 2019
                                                                                                  Time: 1:30 p.m.
                                                Defendants.                                       Dept.: 3



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                     TO: ALL PARTIES HEREIN AND TO THEIR RESPECTIVE COUNSEL OF RECORD:
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                           PLEASE TAKE NOTICE that plaintiff hereby files the following opposition to
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                     defendant's motion to compel:
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                                 I,   Raymond Ghermezian, declare as follows:
                                 1.         I   am an attorney licensed to practice law before all of the courts of the
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                                            State of California.              I   am the attorney of record for the plaintiff in the within
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                                            case.
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                                            The following is true of my own personal knowledge and                                           if   called upon to
                                            testify thereto could and would do so competently.
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                                                      DECLARATION OF RAYMOND GHERMEZIAN