No Value: Gina CavuotoTM vs Moise Nahouraii

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                                Todd A. Angstadt (SBN 166404)
                  Micah A. H. Yospe (SBN 281350)
             2    PHILLIPS, SPALLAS          & ANGSTADT LLP
                  560 Mission Street, Suite 1010
             3    San Francisco, CA 94105
                  Telephone (415) 278-9400
             4    Facsimile (415) 278-9411

             5    Attorneys for Defendant
                  MOISE NAHOURAII
             6
                                                 SUPERIOR COURT OF THE STATE OF CALIFORNIA
             7
                                         CITY AND COUNTY OF SANTA CRUZ, UNLIMITED JURISDICTION
             8

             9                                                                    Case No.: 21CV0l 326
                  GINA MARIE CAVUOTOrM in persona,
           10
                                  Plaintiff,
                                                                                  DEFENDANT'S OBJECTION TO PLAINTIFF'S
           11                                                                     UNAUTHORIZED REPLY BRIEF IN SUPPORT
                       v.                                                         OPPOSITION TO DEMURRER AND REPLY
           12                                                                     BRIEF IN SUPPORT OF OPPOSITION TO
                  MOISE NAHOURAII of Referral Realty c/o           Kimora         MOTION TO STRIKE
           13     Family Trust,
                                                                                  Date:   February 15, 2022
           14                                                                     Time:   8:30 a.m.
                                 Defendant.                                       Dept:   5
           15
                                                                                  Complaint Filed: May 25, 2021
           16                                                                     Trial Date: Not Set

           17

           18              Defendant MOISE NAHOURAII hereby objections and respectfully requests that the Court disregard in

           19     entirety "Plaintiff's Reply Brief in Support of Opposition to Second Demurrer'' and "Plaintiff's Reply Brief in

           20     Support of Opposition to Motion to Strike" which plaintiff filed and served on February 4, 2022.               Plaintiff filed

           21     these "reply briefs" after she already filed her opposition briefs to Defendant's demurrer and motion to strike,

           22     respectively, and after Defendant filed his responsive reply briefs earlier in the day on February 4, 2022.

           23              Neither the California Rules of Court nor the Local Rules provide for the filing of a "reply brief" by the

           24     opposing party after the opposition and reply have been filed.          The California Rules of Court and the

           25     California Code of Civil Procedure contemplate that only moving papers (by the moving party), opposition

           26     papers (by the opposing party), and reply papers (by the moving party) are allowed.              (Cal. Rules of Court Rule

           27     3.l 113(d); CCP § 1005.)       A subsequent "reply" brief by the opposing party is not contemplated by these rules

           28     and is not permitted.    Plaintiff has not provided any authority for the filing of these subsequent "reply" briefs


                     DEFENDANT'S OBJECTION TO PLAINTIFF'S UNAUTHORIZED REPLY BRIEF IN SUPPORT OPPOSITION TO DEMURRER AND
                                                REPLY BRIEF IN SUPPORT OF OPPOSITION TO MOTION TO STRIKE
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