On March 18, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
M.D.L.F.,
and
Arrowood, Cindy,
Does 1 Through 10, Inclusive,
Fisher, Diana,
Morongo Unified School District, A Government Entity,
for Personal Injury Non-Motor Vehicle Unlimited
in the District Court of San Bernardino County.
Preview
yT G ALIFt RNIA
If3R
C asa 1 Al t3 Ft lARDlNO
0 ClISTRICT
5
1 MARTIN MARTIN LLP a T O o
Janet A Ariza Esq SBN 144629
2 j riza c martin jnartin c c m
L aura M Fields Esq SBN 132427
i
3 1 TY
telc sr cilmarti2 mart n corn
p 1 1 T G
3530 Wilshire Boulevard Suite 670 FILING FEE EXL RSUANT
4 Los Angeles California 90Q10 TO GOVERNMENT CQDE 6103
Telephone 213 388 4747
5 Facsimile 213 388 6655
Attorney for Defendants
MORONGO UNIFIED SCHOQL DISTRICT
7 CINDY ARROW JOD and LIIANA FISHER
g SUPERIOR C URT OF THE STATE C F CALIF4RNIA
C4UNTY OF SAN BERNARDINC
10
MD LF a rninor 6y and thraugh his CASE NU CIVDS 1908236
1
Guardian ad Litem MELINDA FIELDS Hon Lynn Poncin Dept S28
I2
Plaintiff DEFENDANTS NUTICE AND
DEMURRER TO THE THIRD
vs
AMENDED C4MPLAINT OF M D L F
1
MEMORANDUM OF POINTS AND
MORONGO UNIFIED SCHOtJL DISTRICT
S a government
AUTHORITIES IN SUPPORT
entity
THEREUF
l C INDY ARROW40D an individual
DIANA FISHER an individual
DATE December 10 2020
1 7 and DOES 1 thraugh 20 inclusive
TIME 9 00 A M
18 Defendants DEPT S28
l Complaint Filed March 8 2019
2Q Trial Date None Set
21 Filed concurrently with Defendants Motion to
Strike and Declaration af Laura M Fieids
22
23 TO PLAINTIFF AND HIS ATTURNEY OF REC4RD
24 PLEASE TAKE NOTICE that an December 10 2020 at 10 00 a m in Department
25 S28 of the above entitled Court located at 247 West 3rd Street San Bernard tno CA 92415
26 0210 Defendants MORONGO UNIFIED SCHOOL DISTRICT CINDY ARROWOOD and
27 DIANA FISI IER by and through their attorney af recard LAURA M FIELDS of Martin
28 Martin LLP respectfully will and hereby do demur specially and generally pursuant to Code of
Page 1 af 4
DEMURRER TO THE TAC
i
1 Civil Procedure Section 430 10 to the Third Amended Complaint TAC of Plaintiff M D L F
2 a minor by and through his Guardian ad Litem MELINDA FIELDS The Plaintiff s TAC is
3 fatally defective because it continues to fail to state multiple causes of action against the
4 Defendants in accordance with California Code ofCivil Procedure Section 430 10 e
5
The foregoing grounds are more particularly set forth in the Demurrer and the
6 Memorandum of Points and Authorities served and iled herewith The Demurrer will be based
7 on this notice the Demurrer the Memorandum of Points and Authorities the Declaration of
8 Laura M Fields all papers records and pleadings herein and all matters that may be judicially
9
noticed and upon such further and other oral and documentary evidence as may be presented at
10 the time of hearing
11
12 DATED October 23 2020 MARTIN MARTIN LLP
13
14
L 2 u
15
Janet A Ariza
16 Laura M Fields Esq
Attorneys for Defendants
17 MORONGO UNIFIED SCHOOL DISTRICT
CINDY ARROWOOD and DIANA FISHER
1g
19
20
21
22
23
24
25
26
27
28
Page 2 of 4
DEMURRER TO THE TAC
Document Filed Date
October 28, 2020
Case Filing Date
March 18, 2019
Category
Personal Injury Non-Motor Vehicle Unlimited
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
yT G ALIFt RNIA If3R C asa 1 Al t3 Ft lARDlNO 0 ClISTRICT 5 1 MARTIN MARTIN LLP a T O o Janet A Ariza Esq SBN 144629 2 j riza c martin jnartin c c m L aura M Fields Esq SBN 132427 i 3 1 TY telc sr cilmarti2 mart n corn p 1 1 T G 3530 Wilshire Boulevard Suite 670 FILING FEE EXL RSUANT 4 Los Angeles California 90Q10 TO GOVERNMENT CQDE 6103 Telephone 213 388 4747 5 Facsimile 213 388 6655 Attorney for Defendants MORONGO UNIFIED SCHOQL DISTRICT 7 CINDY ARROW JOD and LIIANA FISHER g SUPERIOR C URT OF THE STATE C F CALIF4RNIA C4UNTY OF SAN BERNARDINC 10 MD LF a rninor 6y and thraugh his CASE NU CIVDS 1908236 1 Guardian ad Litem MELINDA FIELDS Hon Lynn Poncin Dept S28 I2 Plaintiff DEFENDANTS NUTICE AND DEMURRER TO THE THIRD vs AMENDED C4MPLAINT OF M D L F 1 MEMORANDUM OF POINTS AND MORONGO UNIFIED SCHOtJL DISTRICT S a government AUTHORITIES IN SUPPORT entity THEREUF l C INDY ARROW40D an individual DIANA FISHER an individual DATE December 10 2020 1 7 and DOES 1 thraugh 20 inclusive TIME 9 00 A M 18 Defendants DEPT S28 l Complaint Filed March 8 2019 2Q Trial Date None Set 21 Filed concurrently with Defendants Motion to Strike and Declaration af Laura M Fieids 22 23 TO PLAINTIFF AND HIS ATTURNEY OF REC4RD 24 PLEASE TAKE NOTICE that an December 10 2020 at 10 00 a m in Department 25 S28 of the above entitled Court located at 247 West 3rd Street San Bernard tno CA 92415 26 0210 Defendants MORONGO UNIFIED SCHOOL DISTRICT CINDY ARROWOOD and 27 DIANA FISI IER by and through their attorney af recard LAURA M FIELDS of Martin 28 Martin LLP respectfully will and hereby do demur specially and generally pursuant to Code of Page 1 af 4 DEMURRER TO THE TAC i 1 Civil Procedure Section 430 10 to the Third Amended Complaint TAC of Plaintiff M D L F 2 a minor by and through his Guardian ad Litem MELINDA FIELDS The Plaintiff s TAC is 3 fatally defective because it continues to fail to state multiple causes of action against the 4 Defendants in accordance with California Code ofCivil Procedure Section 430 10 e 5 The foregoing grounds are more particularly set forth in the Demurrer and the 6 Memorandum of Points and Authorities served and iled herewith The Demurrer will be based 7 on this notice the Demurrer the Memorandum of Points and Authorities the Declaration of 8 Laura M Fields all papers records and pleadings herein and all matters that may be judicially 9 noticed and upon such further and other oral and documentary evidence as may be presented at 10 the time of hearing 11 12 DATED October 23 2020 MARTIN MARTIN LLP 13 14 L 2 u 15 Janet A Ariza 16 Laura M Fields Esq Attorneys for Defendants 17 MORONGO UNIFIED SCHOOL DISTRICT CINDY ARROWOOD and DIANA FISHER 1g 19 20 21 22 23 24 25 26 27 28 Page 2 of 4 DEMURRER TO THE TAC