Motion,Ex Parte: CHOOSAK NISPORN VS VORAVUTH ITTIWAMEETHAM

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         Stephen A. Ebner, Esq. (SBN 108348)
         LAW OFFICES OF STEPHEN A. EBNER
         4766 Park Granada, Suite 206
                                                                                FILED
                                                                         Los Angeles Superior Court
         Calabasas, CA 91302
         Telephone:      (818) 591-7990
         Facsimile:      (818) 591-7781                                        WL 14 2016
         Email:          sae@ebnerlaw.net

         Attorney for Plaintiff,
         SANDRA MURRAY
                                                                         ore aba
                                                                               Dawn Alexander
                                                                                                   my
                           SUPERIOR COURT FOR THE STATE OF CALIFORNIA

                       COUNTY OF LOS ANGELES - CENTRAL JUDICIAL DISTRICT


    10   SANDRA MURRAY,                                          CASE NO.: BC586402
                                                                 [Assigned for All Purposes to the Hon. Debre
    11                             Plaintiff,                    K. Weintraub - Dept. 47]

    12           Vv.                                             PLAINTIFF’S POINTS AND
                                                                 AUTHORITIES IN OPPOSITION TO
    13   BUDDHA JONES, LLC; and                                  DEFENDANT’S MOTION TO CONTINUE:
         DOES 1 through 100, Inclusive,                          (1) TRIAL DATE; (2) FINAL STATUS
    14                                                           CONFERENCE DATE; AND (3) RELATED
                                   Defendants.                   LITIGATION DATES
    1S                                                           [Filed concurrently with Declaration of
                                                                 Stephen Love in Support Hereof]
    16
                                                                 DATE:          July 22, 2016
    17                                                           TIME:           8:30 a.m.
                                                                 DEPT:          47
    18
    19                                          POINTS AND AUTHORITIES

    20   1       Disfavored Motion: “To ensure the prompt dispoition of civil cases, the dates assigned

    21   for trial are firm. All parties and their courisel must regard the date set for trial as certain.” [CRC

    22   3.1332(a); see also CRC 3.1332(c) - “continuances of trial are disfavored.”]

    23            Similarly, the Delay Reduction Act directs judges to commence trial on the scheduled

    24   date and to adopt a “firm, consistent policy against continuances, to the maximum extent

    25   possible and reasonable.” [Gov. C. §68607(f), (g) (emphasis added)]

    26   2        “Good Cause” Showing: An affirmative showing of “good cause” according to Judicial

    27   Council standards is required ona motion for continuance before or during trial. [CRC 3.1332(b)]

    28            Defendant has failed to show good cause as to why Trial and related motion dates in this


                                                             1
             PLAINTIFF’S POINTS AND AUTHORITIES IN OPPOSITION TO DEFENDANT’S MOTION TO CONTINUE:(1) TRIAL
                                   DATE; (2) FINAL STATUS CONFERENCE DATE; AND (3) RELATED LITIGATION DATES