On February 21, 2019 a
Response - RESPONSE SOUTH BAY RESTAURANT GROUP, INC. DBA SAMBA BRAZILIAN STEAKHOUSE’S RESPONSE TO SEPARATE STATEMENT RE: PLAINTIFF’S MOTION TO COMPEL PRODUCTION OF DOCUMENTS FROM DEPOSITION OF DEFENDA
was filed
involving a dispute between
Berglund Mark,
South Bay Restaurant Group Inc.,
Raymundo Ana,
and
Berglund Mark,
South Bay Restaurant Group Inc. Dba Samba Brazilian Steakhouse A California Corporation,
for Premise Liability (e.g., dangerous conditions of property, slip/trip and fall, dog attack, etc.) (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 01/06/2021 02:29 PM Sherri R. Carter, Executive Officer/Clerk of Court, by L. Coreas,Deputy Clerk
1 KEVIN P. KENNEDY, ESQ. (SBN 157019)
kkennedy@kennedysouza.com
2 CHRIS LAMPROU, ESQ. (SBN 86291)
clamprou@kennedysouza.com
3 KENNEDY & SOUZA, APC
7964 Arjons Drive, Suite I
4 San Diego, California 92126
Telephone: (858) 267-4127
5 Facsimile: (858) 267-4128
6 Attorneys for Defendant/Cross-Complainant,
SOUTH BAY RESTAURANT GROUP, INC., dba
7 SAMBA BRAZILIAN STEAKHOUSE
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT
10 ANA RAYMUNDO, an individual, Case No.: 19STCV05930
11 Assigned to: Hon. Jon R. Takasugi
Dept: 31
12 Plaintiff,
SOUTH BAY RESTAURANT GROUP,
13 INC. dba SAMBA BRAZILIAN
SAN DIEGO, CALIFORNIA 92126
vs. STEAKHOUSE’S RESPONSE TO
KENNEDY & SOUZA, APC
7964 ARJONS DRIVE, SUITE I
14 SEPARATE STATEMENT RE:
PLAINTIFF’S MOTION TO COMPEL
15 PRODUCTION OF DOCUMENTS FROM
SOUTH BAY RESTAURANT GROUP, INC., DEPOSITION OF DEFENDANT’S
16 dba SAMBA BRAZILIAN STEAKHOUSE, a PERSON MOST KNOWLEDGEABLE
California corporation; MARK BERGLUND,
17 an individual and DOES 1 through 50, Date: January 20, 2021
inclusive, Time: 1:30 p.m.
18 Dept: 31
Defendant. Reservation No. 334656167321
19
Action Filed: February 21, 2019
20 Trial Date: June 29, 2022
AND RELATED CROSS-ACTION.
21
22
23
24 SEPARATE STATEMENT OF ISSUES IN DISPUTE
25
26 REQUEST NUMBER 7
27 Any report regarding this INCIDENT and prepared by anyone, including Defendant and any
28 law enforcement agency, OSHA, Fire Department, Paramedics, or any similar such governmental
{00775636:1} 1
SOUTH BAY RESTAURANT GROUP’S RESPONSE TO SEPARATE STATEMENT RE: PLAINTIFF’S
MOTION TO COMPEL PRODUCTION OF DOCUMENTS FROM DEPOSITION OF DEFENDANT’S PMK
Document Filed Date
January 06, 2021
Case Filing Date
February 21, 2019
Category
Premise Liability (e.g., dangerous conditions of property, slip/trip and fall, dog attack, etc.) (General Jurisdiction)
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Electronically FILED by Superior Court of California, County of Los Angeles on 01/06/2021 02:29 PM Sherri R. Carter, Executive Officer/Clerk of Court, by L. Coreas,Deputy Clerk 1 KEVIN P. KENNEDY, ESQ. (SBN 157019) kkennedy@kennedysouza.com 2 CHRIS LAMPROU, ESQ. (SBN 86291) clamprou@kennedysouza.com 3 KENNEDY & SOUZA, APC 7964 Arjons Drive, Suite I 4 San Diego, California 92126 Telephone: (858) 267-4127 5 Facsimile: (858) 267-4128 6 Attorneys for Defendant/Cross-Complainant, SOUTH BAY RESTAURANT GROUP, INC., dba 7 SAMBA BRAZILIAN STEAKHOUSE 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT 10 ANA RAYMUNDO, an individual, Case No.: 19STCV05930 11 Assigned to: Hon. Jon R. Takasugi Dept: 31 12 Plaintiff, SOUTH BAY RESTAURANT GROUP, 13 INC. dba SAMBA BRAZILIAN SAN DIEGO, CALIFORNIA 92126 vs. STEAKHOUSE’S RESPONSE TO KENNEDY & SOUZA, APC 7964 ARJONS DRIVE, SUITE I 14 SEPARATE STATEMENT RE: PLAINTIFF’S MOTION TO COMPEL 15 PRODUCTION OF DOCUMENTS FROM SOUTH BAY RESTAURANT GROUP, INC., DEPOSITION OF DEFENDANT’S 16 dba SAMBA BRAZILIAN STEAKHOUSE, a PERSON MOST KNOWLEDGEABLE California corporation; MARK BERGLUND, 17 an individual and DOES 1 through 50, Date: January 20, 2021 inclusive, Time: 1:30 p.m. 18 Dept: 31 Defendant. Reservation No. 334656167321 19 Action Filed: February 21, 2019 20 Trial Date: June 29, 2022 AND RELATED CROSS-ACTION. 21 22 23 24 SEPARATE STATEMENT OF ISSUES IN DISPUTE 25 26 REQUEST NUMBER 7 27 Any report regarding this INCIDENT and prepared by anyone, including Defendant and any 28 law enforcement agency, OSHA, Fire Department, Paramedics, or any similar such governmental {00775636:1} 1 SOUTH BAY RESTAURANT GROUP’S RESPONSE TO SEPARATE STATEMENT RE: PLAINTIFF’S MOTION TO COMPEL PRODUCTION OF DOCUMENTS FROM DEPOSITION OF DEFENDANT’S PMK