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  • JOSE ZEPEDA VS STARBUCKS CORPORATION ET AL Wrongful Termination (General Jurisdiction) document preview
  • JOSE ZEPEDA VS STARBUCKS CORPORATION ET AL Wrongful Termination (General Jurisdiction) document preview
						
                                

Preview

LAW OFFICES OF MARYANN P. GALLAGHER MARYANN P. GALLAGHER, SBN 146078 Superig, Lr 205 South Broadway, Suite 920 Ounty of L, Calitorn ig ‘OS4 Los Angeles, California 90012 Phone: (213) 626-1810 Sherp, TRC Fax: (213) 626-0961 R 20 201g E-mail: mail@mpg-law.com Clerk of Attomeys for Plaintiff Sanch ee JOSE ZEPEDA Duty SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES 10 JOSE ZEPEDA, Case No.: BC620585 Assigned to Hon. Gregory Alarcon, Dept. 36 11 Plaintiff, Vv. PLAINTIFF’S REPLY IN SUPPORT OF 12 PLAINTIFF’S MOTION TO TAX COSTS; STARBUCKS CORPORATION; PAM MEMORANDUM OF POINTS AND 13 MICHNO; and JOELEAN PERRAS; and AUTHORITIES; DECLARATION OF DOES 1 through 100, Inclusive, MARYANN P. GALLAGHER 14 Defendants. 1S Date: March 27, 2018 Time: 8:30am 16 Dept.: 36 17 Reservation ID: 171108265575 \ 18 19 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 20 Plaintiff hereby provided this reply to Defendants’ opposition to Plaintiff's Motion to 21 Strike and Tax Costs. Since the Motion for Attorney’s Fees will be heard at the same time as the 22 motion to tax costs, Plaintiff incorporates by reference all of the arguments in support of his 23 Opposition to the Motion For Attorney’s Fees as well. ee 6a 24 Defendants are not entitled to costs in this case as a matter of right. In Williams v. Chino he a 25 Valley Independent Fire District 61 Cal. 4" 97 (2015) the California Supreme Court held that ano California Government Code 12965(b), part of the Fair Employment and Housing Act (FEHA)— — 26 Ce 27 is “an express exception to [California] Code of Civil Procedure 1032(b)” and Government Code 28 129659(b) not CCP 1032(b), therefore governs cost awards in FEHA cases. Williams, 61 Cal. 4th 1 PLAINTIFF'S REPLY IN SUPPORT OF PLAINTIFF'S MOTION TO TAX COSTS