DEFENDANT'S REPLY MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION FOR AN ORDER DEEMING ADMITTED THE TRUTH OF MATTERS SPECIFIED IN DEFENDANT'S REQUESTS FOR ADMISSION OR, ALTERNATIVELY, FOR AN

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On August 29, 2016 a quiet title (general jurisdiction) case was filed by Smith Rhonda, represented by Meredith L. Caliman Attorney At Law, against All Persons Claiming By Through Or Under, Any All Other Persons Unknown Claiming, Dynasty Dynamics Inc., and Malcolm Barrington, represented by Greenberg Whitcombe Et Al. Llp, and Mark E. Madison Law Offices Of, in the jurisdiction of Los Angeles County. Judge Patricia D. Nieto presiding.

                        
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John D. Whitcombe (#138542)
                 Michael E. Adler (#236115
                 Shenne J. Hahn (#173881)                                                                 FILED
                 Greenberg, Whitcombe, Takeuchi,                                                  Supe       un of Californi
                 Gibson & Grayver, LLP                                                                      net ayeA
                 21515 Hawthorne Boulevard, Suite 450
                 Torrance, California 90503-6531                                                         MAR © 7 2018
                 (310) 540-2000
                                                                                            Shortt Py varier &    ise Vitteer/Clerk
                 Attorneys for Defendant Dynasty Dynamics, Inc.; and                        By,                             Bepuly
                 Defendant and Cross-Complainant Barrington Malcolm


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