Motion-Secondary: MARIE UNDERHILL VS ESTATE OF TESTA

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                                Hetal J. Kommes, State Bar No. 255838
     MARK R. WEINER & ASSOCIATES
                                                                                               FILED
                                                                                       Superior Court of California
     Employees of the Law Department                                                      Countv of Los Angeles
     State Farm Mutual Automobile Insurance Company
     655 North Central Avenue, 12" Floor                                                     APR 05 2018
     Glendale, California 91203-1434

                                                                                           X
     Telephone: (818) 543-4000/ FAX: (855) 396-3606                          Sherri R. Cai er, Executive Ufficer/Clerk of Cour}
     E-Mail Address: Cali.Law-Kommes@StateFarm.com                           By.                                    + Deputy
                                                                                           Raul Sanche
     Attorneys for defendant Estate of Lynne S. Testa, Deceased,
     erroneously sued and served as Estate of Testa (Deceased)



                            SUPERIOR COURT OF THE STATE OF CALIFORNIA

                                      FOR THE COUNTY OF LOS ANGELES

10

il   Marie Underhill,                                      ) NO. BC638507
                                                           ) Complaint Filed: October 26, 2016
12           Plaintiff,                                    ) Judge:           Hon. Dennis Landin
                                                           ) Department:           9
13                             Vv.                         ) Trial Date:           May 15, 2018

14   Estate of Testa (Deceased) and Does 1 to 100,         ) Hearing Date:         April 12, 2018
                                                           ) Time:                 1:30 p.m.
15           Defendants.                                   ) Department:           9
                                                           ) RES. ID:              180103 278484
16
                                                             REPLY MEMORANDUM OF POINTS AND}
17                                                           AUTHORITIES IN SUPPORT OF MOTION
                                                             FOR SUMMARY JUDGMENT; REPLY
18                                                           DECLARATION OF TOM PARCO
19                                                           [OBJECTIONS TO EVIDENCE]
20                                                    I

21                        GROSSMAN’S DECLARATION LACKS FOUNDATION ON

22                        . THE ISSUE OF APPLICABILITY OF THE CALIFORNIA

23                         BUILDING CODE TO RESIDENTIAL PROPERTY AND

a4                   THEREFORE DOES NOT RAISE A TRIABLE ISSUE OF FACT

25                                             AS TO FACTS 7-9
a
26

27          Plaintiff opposes defendants’ first moving argument — that the California Building Code

28   applies to commercial and not residential property, with the declaration of Richard Grossman.

                                                     -1-
                                     REPLY ISO MOTION FOR SUMMARY JUDGMENT