OPPOSITION TO PLAINTIFF?S MOTION IN LIMINE NUMBER FIVE RE: INADMISSIBILITY OF ALLEGED LACK OF PRIOR INCIDENTS AND/OR ACCIDENTS - TANAZ ZAMANI VS CITY OF REDONDO BEACH ET AL

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On October 19, 2016 a premises liability (e.g.slip & fall) (general jurisdiction) case was filed by Zamani Tanaz, represented by Law Offices Of Paul R. Markley, against Arakelian Enterprises Inc. Dba Athens, City Of Redondo Beach, Cota Gilbert et al. represented by Maguire Michael Patrick, Moore Kenton E, Perry Ariella E. Esq., Rice Robert J. Esq., and Santa Romana Mark V. Esq., in the jurisdiction of Los Angeles County. Judge Mark A. Borenstein presiding.

                        
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     Ariella E, Perry, State Bar No. 239801
     MARK R. WEINER & ASSOCIATES
     Employees of the Law Department                                             FILED
     State Farm Mutual Automobile Insurance Company                       Superior Court of California
     655 North Central Avenue, 12" Floor                                    ~ Countv of Tne Angeles
     Glendale, California 91203-1434
     Telephone: (818) 543-4000 / FAX: (855) 396-3606                           SEP 202018
     E-Mail Address: Cali.Law-Perry@StateFarm.com                   Sherr n. Vater, eaccuuve uilicer/Clerk

     Attomeys for defendants and cross-defendants Gilbert Cota       By     othr     Forte
                                                                                      LOTR , Deputy
                                                                             eather Clarec
     and Rosa Cota



                           SUPERIOR COURT OF THE S…