Motion,Ex Parte: SANDRA HOPE VS. RUSSELL GONZALEZ AND KAYLA GONZALEZ

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                 1    SANDRA E. HOPE-EL
                      6008 Walton Drive
                 2.   Bakerseld, California 93304                                       S” em l:lLnEfDC If
                            _                                                                    r   ou   o   a‘       '
                 3    661 834 85 54                                                        gounty of Los Angeizlgrsma

                 4    Sandra E. Hope—EL, IN PRO PER                                            JUL 1 1 :20 H /
                                                                                     Shem‘ R. C rter, E   cutive Officer/Clerk
                 5                                                                       By               uw
                                                                                              Kimb ly ohnson
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                                          SUPERIOR COURT OF THE STATE OF CALIFORNIA
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                                                   FOR THE COUNTY OF LOS ANGELES
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                      SANDRA HOPE, AS AN EXECUTRIX                   '   No. TC028557
                12                                                       PLAINTIFF’S OBJECTION TO PURPOSED
                      OF THE ESTATE OF CHRISTINE                         ORDER DATED JULY 2, 2019 AND ASK
                13                                                       FOR LEAVE FOR MOTION FOR
                      SHANKLIN WILLIAMS,                                 PLAINTIFF TO AMEND TO PLEAD
                14                    _ ,                                SPECIAL DAMAGES AGAINST MERCURY
                                   Plalntlffa VS-                        INSURANCE COMPANY/TRAVELERS
                15                                                       AND TO ADD MERCURY INSURANCE
                      RUSSELL GONZALEZ; KAYLA                            COMPANY/TRAVELERS AS (:0-
                16                                                       DEFENDANTS PURSUANT TO                        177.70-
                      GONZALEZ DOES 1 TO 20                              177.72 Governing Statues                  §
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                      INCLUSIVE,                                         Judge: TANAKA
                18                       D f d     t                     Department: A
                                           e en an .
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                      Plaintiff respectfully submits an Objection to the purposed Ruling of July 2, 2019 which is over
                20    turning a Motion Summary Judgment already granted to the Plaintiff. Plaintiff is now pleading
                21    “Special Damages” and the right to sue that the Motion Summary Judgment already granted to
                22    the Plaintiff in this court. Plaintiff now submits a request for Leave for Plaintiff for Motion to
                23    Amend Complaint to include Mercury Insurance Company/Travelers as co— defendants as a
                24    matter of Law (primary right, judgment reversed to allow plaintiff to amend to plead special
                25    damages)]. Plaintiff is asking this court to uphold the Motion Summary Judgment. THIS IS A
                      CAUSE IN EFFECT PROPERTY DAMAGE CASE, WITH A CLAIM HANDLING THIRD
                26    PARTY CLAIM AGAINST MERCURY INSURANCE COMPANY/TRAVELERS.
:i§_§ »?.       27
                          (Code Civ. Proc. §§ 473(a), 576). A complaint is a pleading (Code Civ. Proc. § 422.10).
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                      PLAINTIFF'S OBJECTION TO PURPOSED ORDER DATEDIIULY 2, 2019 AND MOTION FOR
                      LEAVE FOR PLA NTIFF TO AMEND TO PLEAD SPECIAL AMAGES AGAINST MERCURY
                      INSURANCE COMPANYS/TRAVELERS AND TO ADD MERCURY INSURANCE
                      COMPANY/TRAVELER AS CO-DEFENDANTS PURSUANT TO§ 177.70-177.72           Page 1