On December 08, 2021 a
Trial Materials
was filed
involving a dispute between
Macias, Monique,
San Bernardino City Unified School District,
and
Ccs Contractors, Inc.,
Couts Heating And Cooling, Inc.,
Couts Heating & Cooling, Inc.,
Doe 1,
Doe 2,
Doe 3,
Doe 4,
Doe 5,
Doe 6,
Doe 7,
Doe 8,
Doe 9,
Does 11 To 100,
for Other PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
DAVID M. FRISHMAN, STATE BAR #129992 ELECTRONICALLY FILED (Auto)
CHRISTIAN M. FOSTER, STATE BAR #3 19148 SUPERIOR COURT OF C; ALIFORNIA
TYSON & MENDES, LLP COUNTY OF SAN BERNA RDINO
445 South Figueroa Street, Suite 3 100 11/1 6/2023 7:00 PM
Los Angeles, CA 90071
Telephone: 213.745.8600
A Facsimile: 213.745.8604
dfrishman@TvsonMendes.com
Email(s):
cfoster@TvsonMendes.com
Attorneys for Defendant and Cross—Defendant COUTS HEATING & COOLING, INC.
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
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MONIQUE MACIAS, Case No.2 CIVSB2133542
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Plaintiff, Assigned t0 Hon. Michael A. Sachs, Dept. 828
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VS. COUTS HEATING AND COOLING,
14 NOTICE OF LODGING AND
INC.’S
INDEX OF EXHIBITS IN SUPPORT OF
15 COUTS HEATING AND COOLING, INC., a OPPOSITION TO DEFENDANT CCS
corporation; DOE DOE 2, DOE 3, DOE 4
I, CONTRACTORS’ MOTION FOR
16 and DOE 5, individually, and d/b/a COUTS SUMMARY ADJUDICATION
HEATING AND COOLING; CCS
17 CONTRACTORS, INC., a corporation; DOE [Filed concurrently with Memorandum 0f
6, DOE 7, DOE 8, DOE 9, DOE IO, Points and Authorities; Separate Statement 0f
18 individually, and d/b/a CCS Disputed and Undisputed Material Facts;
CONTRACTORS; and DOES 11 through I 00, Declaration ofChristian M Foster]
19 inclusive,
Case Filed: December 8, 2021
20 Defendants. Trial: April 15, 2024
Trial Readiness: April 11, 2024
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22 CCS CONTRACTORS, INC.,
23 Cross-Complainant,
24 VS.
25 COUTS HEATING & COOLING, INC., and
FOES 1 through 50, Inclsuive.
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Cross—Defendant.
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AND ALL RELATED CROSS-ACTIONS.
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INDEX OF EXHIBITS IN OPPOSITION TO MOTION FOR SUMMARY ADJUDICATION
Defendant/Cross-Defendant, COUTS HEATING & COOLING, INC., (“Couts”) hereby
submits the following Index 0f Exhibits in opposition to the Motion for Summary Adjudication of
defendant CCS CONTRACTORS, INC., (“CCS”):
A
INDEX OF EXHIBITS
1. Exhibit 1: True and correct copies of pertinent excerpted portions of the transcript 0f
Plaintiff Monique Macias’ deposition 0n May 16, 2023.
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. Exhibit 2: True and correct copies 0f pertinent excerpted portions 0f the transcript 0f
James Carter’s deposition on August 24, 2023.
. Exhibit 3: True and correct copies of pertinent excerpted portions 0f the transcript 0f
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Adam Couron’s deposition on August 24, 2023.
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. Exhibit 4: True and correct copies 0f pertinent excerpted portions of Defendant’s
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Further Supplemental Responses to Plaintiff s Special Interrogatories, Set One.
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. Exhibit 5: True and correct copies 0f pertinent excerpted portions 0f Plaintiffs
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Complaint.
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. Exhibit 6: True and correct copy of the Agreement between CCS and Couts Heating
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and Cooling.
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. Exhibit 7: True and correct copy 0f the photograph 0f boilers and dumpsters taken by
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Adam Couron.
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Dated: November 15, 2023
By
41¢;ng— fl
TYSON & MENDES, LLP
David M. Frishman, ESQ.
Christian M. Foster,
Attorneys for Defendant,
ESQ.
COUTS HEATING
24 AND COOLING, INC.
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INDEX OF EXHIBITS IN OPPOSITION TO MOTION FOR SUMMARY ADJUDICATION