Motion,Ex Parte: WILD CHANG ET AL VS FARMERS INSURANCE COMPANY INC ET AL

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 03/18/2022 09:31 AM Sherri R. Carter, Executive Officer/Clerk of Court, by R. Perez,Deputy Clerk




                      1     GREGORY B. SCHER - State Bar No. 137228
                            gscher@wpdslaw.com
                      2     CAITLIN R. ZAPF - State Bar No. 255450
                            czapf@wpdslaw.com
                      3     WOOLLS PEER DOLLINGER & SCHER
                            A Professional Corporation
                      4     One Wilshire Building
                            624 South Grand Avenue, 22nd Floor
                      5     Los Angeles, California 90017
                            Telephone:    (213) 629-1600
                      6     Facsimile:    (213) 629-1660
                      7     Attorneys for Defendants
                            FIRE INSURANCE EXCHANGE, STACY
                      8     CHERN
                      9                                   SUPERIOR COURT OF THE STATE OF CALIFORNIA
                    10                             FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT
                    11

                    12      WILD CHANG, KENNETH LO,                                                            Case No.: BC650876 Related to
                                                                                                               Case No. 21STCV03453
                    13                             Plaintiffs,                                                 (Hon. Judge Teresa A. Beaudet, Dept. 50)
                               v.
                    14
                            FARMERS INSURANCE COMPANY, INC., a                                                 NOTICE OF MOTION AND MOTION
                    15      corporation; FIRE INSURANCE EXCHANGE, a                                            FOR TERMINATING SANCTIONS OR, IN
                            corporation; STACY CHERN INSURANCE                                                 THE ALTERNATIVE, EVIDENTIARY
                    16      AGENCY; STACY CHERN, an individual; and                                            SANCTIONS AND MONETARY
                            DOES 1 through 100, Inclusive                                                      SANCTIONS AND REDUCTION OF ALL
                    17                                                                                         MONETARY SANCTIONS INTO A
                                                   Defendants.                                                 JUDGMENT; MEMORANDUM OF
                    18                                                                                         POINTS AND AUTHORITIES AND
                                                                                                               DECLARATION OF CAITLIN R. ZAPF IN
                    19                                                                                         SUPPORT THEREOF
                    20                                                                                         Date:                              10/6/22
                                                                                                               Time:                              10:00 a.m.
                    21                                                                                         Dept:                              50
                    22                                                                                         Complaint Filed:                   February 16, 2017
                    23                                                                                         Trial Date:                        6/14/22
                                                                                                               Discovery Cut-Off:                 5/16/22
                    24                                                                                         Motion Cut-Off:                    5/13/22
                    25

                    26      TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD HEREIN:

                    27                 PLEASE TAKE NOTICE that on October 6, 2022, at 10:00 a.m., or as soon thereafter as the

                    28      matter may be heard, in Department 50 of the above-entitled Court, located at 111 N. Hill Street, Los

                            PRINTED ON RECYCLED PAPER                                                1
                                                                                                                      MOTION FOR TERMINATING SANCTIONS
     910890.1