Document for JANE DOE, A MINOR vs JAYANTIBHAI PATEL, et al

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                                1   Elizabeth J. Carpenter (SBN 315674)
     COZEN O'CONNOR
 2   601 S. Figueroa Street, Suite 3700
     Los Angeles, CA 90017
 3   Telephone: 213.892.7900
     Facsimile: 213.892.7999
 4   ecarpenter@cozen.com
 5   Attorneys for Defendant
     I.V. PATEL LIVING TRUST
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 8                        SUPERIOR COURT OF THE STATE OF CALIFORNIA
 9                                       COUNTY OF SANTA CRUZ
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11   JANE DOE, a minor, by and through her                   Case No.: 22CV01796
     Guardian Ad Litem, BIANCA COTO,
12                                                           [PROPOSED] ORDER RE
                     Plaintiff,                              DEFENDANT’S EX PARTE
13                                                           APPLICATION FOR AN ORDER
            vs.                                              GRANTING LEAVE TO SUBMIT
14                                                           TARDY EXPERT WITNESS
     EL VIEW LODGE MOTEL, unknown entity;                    INFORMATION AND EXTEND
15   JAYANTIBHAI PATEL, an individual; PATEL                 DISCOVERY TO PERMIT DEFENSE
     I V, unknown entity; and DOES 1-50 inclusive,           MEDICAL EXAMINATION
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                     Defendants.                             DATE:              November 7, 2023
17                                                           TIME:              1:00 p.m.
                                                             DEPT:              10
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                                                             Complaint Filed:   08/19/2022
19                                                           Trial Date:        12/04/2023
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21          This matter having come before the Court on November 7, 2023, at 1:00 p.m. and the Court

22   having reviewed Defendant I.V. Patel Living Trust’s Ex Parte Application for An Order Granting

23   Leave to Submit Tardy Expert Witness Information and Extend Discovery to Permit Defense Medical

24   Examination, and having heard the arguments of counsel for the parties, and GOOD CAUSE

25   HAVING BEEN SHOWN,

26          IT IS HEREBY ORDERED that Defendant I.V. Patel Living Trust’s Ex Parte Application is

27   GRANTED as follows:

28                1. Defendant I.V. Patel Living Trust’s designation of rebuttal experts is allowed;


                                                         1
                          [PROPOSED] ORDER RE DEFENDANT’S EX PARTE APPLICATION
                                                  LEGAL\67000003\1
 1           2. The defense mental health examination will proceed as noticed on November 20, 2023;
 2           3. Defendant I.V. Patel Living Trust’s experts will be produced for deposition between
 3              November 20, 2023 and November 22, 2023, or on a date mutually agreed to by the
 4              parties; and
 5           4. In advance of the defense mental health examination, Defendant’s counsel is provide a
 6              list of areas of intended inquiry and tests that the expert intends to conduct.
 7        IT IS SO ORDERED.
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     DATED: ________, 2023                     _____________________________
 9                                             Hon. Timothy Schmal
                                               Judge of the Superior Court
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                                                     2
                     [PROPOSED] ORDER RE DEFENDANT’S EX PARTE APPLICATION
                                              LEGAL\67000003\1
 1                        CALIFORNIA STATE COURT PROOF OF SERVICE
 2                                 Jane Doe, a minor v. El View Lodge Motel, et al.
                                   Santa Cruz Superior Court Case No. 22CV01796
 3

 4   STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
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            At the time of service, I was over 18 years of age and not a party to the action. My business
 6   address is 601 S. Figueroa Street, Suite 3700, Los Angeles, CA 90017.

 7       On November 28, 2023, I served the following document(s): [PROPOSED] ORDER RE
     DEFENDANT’S EX PARTE APPLICATION FOR AN ORDER GRANTING LEAVE TO
 8   SUBMIT TARDY EXPERT WITNESS INFORMATION AND EXTEND DISCOVERY TO
     PERMIT DEFENSE MEDICAL EXAMINATION
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10         I served the documents on the following persons at the following addresses (including fax
     numbers and e-mail addresses, if applicable):
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12     Edward Morgan, Esq.                                    Attorneys for Plaintiff
       DOWNTOWN L.A. LAW GROUP                                JANE DOE, a minor, by and through her
13     910 S. Broadway                                        Guardian Ad Litem BIANCA COTO
       Los Angeles, CA 90015
14                                                            Tel: (213) 389-3765
                                                              Fax: (877) 389-2775
15                                                            Edward@downtownlalaw.com
                                                              Channel@downtownlalaw.com
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17          The documents were served by the following means:
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           (BY ELECTRONIC MAIL SERVICE) Based upon CRC Rule 2.251 or an agreement of the
19          parties to accept electronic service, I caused such document(s) to be Electronically Mailed
            through Cozen O’Connor electronic mail system for the above entitled case. Should your
20          office require a hard copy of said document, please contact our office.
21            I declare under penalty of perjury under the laws of the State of California that the foregoing
22   is true and correct.

23          Executed on November 28, 2023, at Los Angeles, California.

24                                                   /s/ Nancy L. Alfaro
                                                    Nancy L. Alfaro
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                         [PROPOSED] ORDER RE DEFENDANT’S EX PARTE APPLICATION
                                                   LEGAL\67000003\1