On October 19, 2016 a
Party Discovery
was filed
involving a dispute between
Zamani Tanaz,
and
Arakelian Enterprises Inc. Dba Athens,
City Of Redondo Beach,
Cota Gilbert,
Cota Rosa,
Emmerson John,
Ghavami Ashkan,
Schaye Gordon,
Soma Medical Group Inc.,
Wu David,
for civil
in the District Court of Los Angeles County.
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KENTON E. MOORE, STATE BAR #143645 Sangre hue AF Balifnenia
Tie
JULIAN S. SMITH, STATE BAR #309241 ‘ounty af Lat Angeles
McCUNE & HARBER, LLP
AUG 07 2018
zy
515 South Figueroa Street, Suite 1100
Los Angeles, California 90071
Sherri R. Cartel, lerk of Court
Telephone: (213) 689-2500
Facsimile: (213) 689-2501 By. » Deputy
kmoore@mccuneharber.com and jsmith@mecunehazber.com arlos Hidalgo
Attorneys for Defendant and Cross-Complainant, CITY OF REDONDO BEACH [FEE EXEMPT PUBLIC
ENTITY, GOVERNMENT CODE § 6103]
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT
10
vs 11 TANAZ ZAMANI, an individual, Case No: BC637727
a Qo
Saree
a8z
[Assigned to Honorable Yolanda Orozco - Dept.7|
Ross 312 Plaintiff, (Complaint filed on October 19, 2016)
28.
So 988 13
R826
V. DATE: August 20, 2018
S¢E 14 TIME: 10:00 a.m.
CITY OF REDONDO BEACH; GILBERT DEPT: 7
COTA; ROSA COTA and DOES 1-20,
15 Inclusive, SEPARATE STATEMENT BY DEFENDANT
CITY OF REDONDO BEACH SUPPORTING
16 Defendants. OPPOSITION TO MOTION BY PLAINTIFF
TO COMPEL FURTHER DEPOSITION
17 ANSWERS BY MICHAEL KLEIN
AND ALL RELATED CROSS ACTIONS.
18 Trial Date: October 18, 2018
FSC Date: October 03, 2018
19
20
21 TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD:
22 Defendant CITY OF REDONDO BEACH (“City”) hereby submits the following separate
23 statement, pursuant to Rule 3.1345 of the California Rules of Court, in support of the opposition to the
24 motion by plaintiff to compel further deposition answers at the deposition of Michael Klein.
225
26
me 27
-1-
JAWPDOCs\Zamani, T v. City of Redondo Beach\Pld\MTC Michael Klein DepoiCity of Redondo Beach's Response to Separate Stmt to P's MTC Depo of
Michael Klein.docx 14200032
RESPONSE TO PLAINTIFF’S SEPARATE STATEMENT
Document Filed Date
August 07, 2018
Case Filing Date
October 19, 2016
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