Motion,Ex Parte: JONI FRASER VS EVIE CROCKER ET AL

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 07/22/2022 10:31 AM Sherri R. Carter, Executive Officer/Clerk of Court, by V. Sino-Cruz,Deputy Clerk




               1            Stephen Hsu, State Bar No. 277765
                            MARK R. WEINER & ASSOCIATES
               2            Employees of the Law Department
                            State Farm Mutual Automobile Insurance Company
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                            655 North Central Avenue, 12th Floor
               4            Glendale, California 91203-1434
                            Telephone: (818) 543-4000 / FAX: (855) 396-3606
               5            E-Mail Address: Cali.Law-Glendale@StateFarm.com
                            Attorneys for defendants Ali Farvid and Lilyana Amezcua
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               8                                          SUPERIOR COURT OF THE STATE OF CALIFORNIA

               9                            FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT, MOSK

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               11            Joni Fraser,                                                                )     NO. BC724217
                                                                                                         )     Complaint Filed:           October 3, 2018
               12                       Plaintiff,                                                       )     Judge:                     Hon. Gregory Alarcon
                                                                                                         )     Department:                96
               13                                               v.                                       )     Judgment Date:             July 8, 2022
                                                                                                         )
               14            Evie Crocker, Ali Farvid, Lilyana Amezcua,                                  )     Date:                      August 26, 2022
                             and Does 1 through 50, inclusive,                                           )     Time:                      8:30 AM
               15                                                                                        )
                                        Defendants.                                                      )     NOTICE OF MOTION AND MOTION
               16                                                                                        )     FOR JUDGMENT NOTWITHSTANDING
                                                                                                               THE VERDICT; MEMORANDUM OF
               17                                                                                              POINTS AND AUTHORITIES;
                                                                                                               DECLARATION OF STEPHEN HSU
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               19           TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:

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               21                      PLEASE TAKE NOTICE that on August 26, 2022, at 8:30 AM, or as soon thereafter as

               22           counsel may be heard in Department 96 of the above-entitled court, located at 111 North Hill Street

               23           in Los Angeles, California, 90012, defendants Ali Farvid and Lilyana Amezcua will move this

               24           court for an order granting judgment notwithstanding the verdict in favor of moving defendants

               25           Ali Farvid and Lilyana Amezcua and against plaintiff Joni Fraser.

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               27                      This motion is made pursuant to Code of Civil Procedure section 629 on the ground that

               28           even assuming the truth of all of the evidence presented in the light most favorable to plaintiff,

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                                                NOTICE OF MOTION FOR JUDGMENT NOTWITHSTANDING THE VERDICT