OPPOSITION BY DEFENDANT CITY OF REDONDO BEACH TO PLAINTIFF'S MOTION FOR RELIEF UNDER CCP 473; MEMORANDUM OF POINTS AND AUTHORITIES; REQUEST FOR SANCTIONS AGAINST PLAINTIFF AND THEIR COUNSEL IN THE AMO

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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® KENTON E. MOORE, STATE BAR #143645 JULIAN S. SMITH, STATE BAR #309241 McCUNE & HARBER, LLP i 515 South Figueroa Street, Suite 1100 Los Angeles, California 90071 Sup atigr Coun of Galifarnia ounty of Los Angeles Telephone: (213) 689-2500 Facsimile: (213) 689-2501 SEP - 5 2018 @n kmoore@mccuneharber.com and jsmith@mccuneharber.com om ri R. Carter, Exeputive Officer/Clerk <—M Attorneys for Defendant And Cr…

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