Mark Johnson (142984) FF __Superior Court of California =
Attorney at Law | County of Butte |
2531 Forest Avenue Suite 100
Chico California 95928 L L
(530) 345-6801 E E
[email protected] D D
Kings Fy Mgt, Clerk
Attomey for Johnson Brothers, a partnership By ee Ne Ot
CALIFORNIA STATE COURT
JOHNSON BROTHERS, a partnership
CASE NO. 20CV00844
Johnson Brothers’ Reply Memorandum
Supporting Their Motion for
Reconsideration of Order Granting
Demurrer to Complaint
FENIX FARMS, a corporation, FENIX FARMS,
a partnership, JAMES BIANCHI, individually and Date: November 18, 2020
as a partner of FENIX FARMS, and DOES 1-20, Time: 9:00 a.m.
inclusive, Dept: 10
The Johnson Brothers submits this reply supporting its motion for reconsideration of the
order sustaining defendants’ demurrer and refuting defendants’ opposition to the granting of
plaintiffs’ motion for reconsideration.
1. The Defendants have Failed to Show any Grounds on which to Deny the
Plaintiffs’ Motion for Reconsideration.
The defendants’ demurrer was sustained on the assumption that plaintiff's repossession of
the defendant’s equipment terminated the contract in September 2012 and started the running of
the four year statute of limitations. “Based upon Plaintiff’s repossession and subsequent sale of
Johnson Brothers’ Reply Memorandum Supporting Motion for ReconsiderationCO ND HW YW NY &
NR MN NY De ee ee ei ea ei
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