On June 19, 2015 a
Opposition - To Motion to Compel
was filed
involving a dispute between
Garcia Marcia,
Garcia Maria,
and
Davidson Darlene,
Ralph'S Grocery Company,
Ralphs Grocery Company,
Ralphs,
for civil
in the District Court of Los Angeles County.
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4/8/g//2/7
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I BOB B. KHAKSHOOY, p FILED
SBN 224044
SANDEEP G. AGARWAL, Sugefm Court of California
ESQ., SBN 210598
2 LAW OFFICES OF BOB °””’V °’ ‘-05 A"9e'95
3
KHAKSHOOY
9454 Wilshire BlVd., JUL 2 5 2018
Suite 601
212
Sherri R. Caner. E
4 Fax: (310) 278-0866 live icer/Clerk
Bv evurv
5 Attarneyfor Plaintiff MARIA
GARCIA
6
7
8 SUPERIOR COURT OF THE
STATE OF CALIFORNIA
9
FOR THE COUNTY OF
LOS ANGELES
10
WEST DISTRICT
BY FAX
11
12 MARIA GARCIA, an
individual,
CASE NQ_; BC5g5516
is 5L‘%¥ll$’&‘%8‘3n%%§S‘%£§
PP I 4 A
14
'.}3i>“5§‘£¥1“.§1‘3‘f}t?’;3L‘A‘?N%‘¥i%i»‘?sEL
15 RALPHS GROCERY COMPANY; EXPERTS AND REQUEST FOR
16
an individual; and SANCTIONS AGAINST DEFENDANTS
ANB
' v (;rogFp;ggg£0g)g0REoCRD [N
C V a
17 TH A N , . ;
Defendants.
DECLARATION OF SANDEEP G.
AGARWAL, ESQ,
18
19 Date: August 7, 2018
Time: 8:3 am
Dept: WE-‘K’
20
Trial Date: January 22, 2019
21
22
TO THE COURT, ALL
PARTIES AND TO THEIR
23 COUNSEL OF RECORD HEREIN:
24 PLEASE BE ADVISED
that plaintiff hereby
brings this opposition to
defense counsel’
25 motion to compel the deposition
of plaintiffs experts, which
the defense seeks to in a motion
slate
26 to be heard more than
5 MONTHS BEFORE
TRML. What possible reason could
27 there be to see
28 to compel the depositions
of the plaintiffs experts
so early before trial?
There is no reason to d
V l
-1-
129
OPPOSITION TO MOTION
COMPEL DEPOSITION OF
PLAINTIFF’S EXPERTS
Document Filed Date
July 25, 2018
Case Filing Date
June 19, 2015
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, \ I 6\ 4/8/g//2/7 ,G%/ I BOB B. KHAKSHOOY, p FILED SBN 224044 SANDEEP G. AGARWAL, Sugefm Court of California ESQ., SBN 210598 2 LAW OFFICES OF BOB °””’V °’ ‘-05 A"9e'95 3 KHAKSHOOY 9454 Wilshire BlVd., JUL 2 5 2018 Suite 601 212 Sherri R. Caner. E 4 Fax: (310) 278-0866 live icer/Clerk Bv evurv 5 Attarneyfor Plaintiff MARIA GARCIA 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF LOS ANGELES 10 WEST DISTRICT BY FAX 11 12 MARIA GARCIA, an individual, CASE NQ_; BC5g5516 is 5L‘%¥ll$’&‘%8‘3n%%§S‘%£§ PP I 4 A 14 '.}3i>“5§‘£¥1“.§1‘3‘f}t?’;3L‘A‘?N%‘¥i%i»‘?sEL 15 RALPHS GROCERY COMPANY; EXPERTS AND REQUEST FOR 16 an individual; and SANCTIONS AGAINST DEFENDANTS ANB ' v (;rogFp;ggg£0g)g0REoCRD [N C V a 17 TH A N , . ; Defendants. DECLARATION OF SANDEEP G. AGARWAL, ESQ, 18 19 Date: August 7, 2018 Time: 8:3 am Dept: WE-‘K’ 20 Trial Date: January 22, 2019 21 22 TO THE COURT, ALL PARTIES AND TO THEIR 23 COUNSEL OF RECORD HEREIN: 24 PLEASE BE ADVISED that plaintiff hereby brings this opposition to defense counsel’ 25 motion to compel the deposition of plaintiffs experts, which the defense seeks to in a motion slate 26 to be heard more than 5 MONTHS BEFORE TRML. What possible reason could 27 there be to see 28 to compel the depositions of the plaintiffs experts so early before trial? There is no reason to d V l -1- 129 OPPOSITION TO MOTION COMPEL DEPOSITION OF PLAINTIFF’S EXPERTS