Motion-Secondary: LENDLEASE (US) CONSTRUCTION, INC. VS ZURICH AMERICAN INSURANCE COMPANY

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 10/07/2020 11:40 AM Sherri R. Carter, Executive Officer/Clerk of Court, by B. McClendon,Deputy Clerk

             1      Jeremiah M. Welch (State Bar No. 180370)
                    jmw@sdvlaw.com
             2      Cheryl L. Kozdrey (State Bar No. 323308)
             3      clk@sdvlaw.com
                    SAXE DOERNBERGER & VITA
             4      Two Better World Circle, Suite 200
                    Temecula, CA 92590
             5      Ph: (951) 365-3145; Fax: (203) 287-8847
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                    Attorneys for Plaintiff, Lendlease (US) Construction, Inc.
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                                                    SUPERIOR COURT OF THE STATE OF CALIFORNIA
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             9                                                            COUNTY OF LOS ANGELES

           10       LENDLEASE (US) CONSTRUCTION INC.,                                                 Case No.: 20SMCV00857
                              Plaintiff,                                                              Judge: Hon. Mark H. Epstein
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           12       vs.                                                                               LENDLEASE’S NOTICE OF OPPOSITION
                                                                                                      AND OPPOSITION TO ZURICH’S GENERAL
           13       ZURICH AMERICAN INSURANCE                                                         DEMURRER; MEMORANDUM OF POINTS
                    COMPANY,                                                                          AND AUTHORITIES
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                              Defendant.
           15                                                                                         Date: October 21, 2020
                                                                                                      Time: 1:30 p.m.
           16                                                                                         Dept: R
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                                                                                                      Complaint Filed: June 26, 2020
           18                                                                                         Trial Date: Not Set
           19                                                NOTICE OF OPPOSITION TO DEMURRER
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                    TO ALL PARTIES AND THEIR COUNSEL OF RECORD:
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                               PLEASE TAKE NOTICE that on October 21, 2020 at 1:30 p.m. this matter is scheduled for
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                    hearing in Department “R” of the Santa Monica Courthouse located at 1725 Main Street, Santa Monica,
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                    California 90401, in Courtroom 10B of the above-entitled court located at 350 W. First Street, Los
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                    Angeles, California 90012, wherefore Plaintiff, Lendlease (US) Construction Inc. (“Lendlease”), will,
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                    and hereby does, move for an order OVERRULING Defendant Zurich American Insurance Company’s
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                    (“Zurich”) general demurrer to Lendlease’s Complaint for Breach of Contract, Declaratory Relief and
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                    Demand for Jury Trial (the “Complaint”), pursuant to California Code of Civil Procedure §430.10(e).
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                          LENDLEASE’S NOTICE OF OPPOSITION AND OPPOSITION TO ZURICH’S GENERAL DEMURRER;
                                              MEMORANDUM OF POINTS AND AUTHORITIES
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