Motion,Ex Parte: LISA R JOHNSON VS ALBRIGHT YEE & SCHMIT ET AL

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 04/24/2019 04:32 PM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Hung,Deputy Clerk




                    1     rad N. Baker (SBN: 065106)
                          lbro L. Lundy, III (SBN: 123133)
                   2      van R. Koch (SBN: 275144)
                          AKER, BURTON & LUNDY,
                   3       Professional Corporation
                          15 Pier Avenue
                   4      ermosa Beach, CA 90254
                          elephone: (310) 376-9893
                   5      acsimile: (310) 376-7483

                   6      ttomeys for Petitioner
                          ISA R. JOHNSON
                   7

                    8
                                                      SUPERIOR COURT OF THE STATE OF CALIFORNIA
                   9
                                                                 FOR THE COUNTY OF LOS ANGELES
                  10

                  11
                      ISA R. JOHNSON, an individual, as a        )                              CASE NO: BC673173
                  12 eneficiary and as Successor Trustee of      )
                     he Bobby J. Johnson Trust dated March       )                              PLAINTIFF LISA R. JOHNSON'S MOTION
                  13 14,2000.                                    )                              TO DEEM ADMITTED HER REQUESTS
                                                                 )                              FOR ADMISSION, SET ONE;
                  14                   Plaintiff,                )                              MEMORANDUM OF POINTS AND
                                                                 )                              AUTHORITIES; DECLARATION OF EVAN
                  15                                             )                              R. KOCH
                                                                 )
                  16      LBRIGHT, YEE & SCHMIT, a               )
                          alifomia Professional Law Corporation; )
                  17      OBBY Q. JOHNSON, an individual, as )
                          ormer Trustee of the Bobby 1. Johnson )                               Date: July 17, 2019
                  18      rust dated March 14,2000; CLIFTON      )                              Time: 8:30 a.m.
                           . ALBRIGHT; and DOES 1 through 50, )                                 Dept: 56
                  19     nclusive,                               )
                                                                 )
                 20                    Defendants.               )                              RESERVATION ID: 083604146125
                                                                 )
                 21
                 22                PLEASE TAKE NOTICE that on July 17,2019 at 8:30 a.m., or as soon thereafter as this

                 23        atter may be heard, in Department 56 of the above-entitled Court, located at 111 N Hill St, Los

                  24        geles, CA 90012, California, Plaintiff Lisa R. Johnson ("Plaintiff') will move this Court for

                  25     n order deeming admitted Plaintiffs Requests for Admissions (Set One), as to Defendant Bobby

                  26       . Johnson ("Defendant"). Good cause exists to grant this motion because Plaintiff properly

                 27      erved Defendant with her Requests for Admissions, Set One, on December 27,2017, but

                  28       efendant has failed to provide any responses to said discovely.

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                                                   Plaintiff Lisa R. Johnson's Motion to Deem RF A's Admitted