NOTICE OF MOTION AND MOTION OF DEFENDANT TO COMPEL RESPONSES AND PRODUCTION TO SUPPLEMENTAL REQUEST FOR PRODUCTION OF DOCUMENTS; ETC. - MARIA GARCIA VS RALPHS GROCERY COMPANY ET AL

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On June 19, 2015 a premise liability (e.g., dangerous conditions of property, slip/trip and fall, dog attack, etc.) (general jurisdiction) case was filed by Garcia Marcia, and Garcia Maria, represented by Bob B. Khakshooy Law Offices Of, and Khakshooy Bob B., against Davidson Darlene, Ralph'S Grocery Company, Ralphs Grocery Company, and Ralphs, represented by Nelson & Griffin, Stone | Dean Llp, and Stone Gregory E., in the jurisdiction of Los Angeles County. Judge Marc D. Gross presiding.

                        
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                  Gregory E. Stone, Esq., S.B. #144057
                         gstone@stonedeanlaw.com
                  Suzanne R. Feffer, Esq., S.B. #121817
                                                                                   seshes
                           sfeffer@stonedeanlaw.com
                  STONE | DEAN LLP                                                   DEC 21 2018
                  21600 Oxnard Street, Upper Lobby — Suite 200              Short
                                                                               R, Caney,
                  Woodland Hills, California       91367                      By
                  Tel:      (818) 999-2232                                             me
                  Fax:      (818) 999-2269
                  Attorneys for Defendant,
                  Ralphs Grocery Company dba Ralphs


                                                SUPERIOR COURT OF CALIF…