PLAINTIFF'S CONSOLIDATED REPLY TO DEFENDANT YOUNAN'S OPPOSITION RE MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES, REQUEST FOR ADMISSONS AND REQUESTS FOR PRODUCTION, AND FOR IMPOSITION OF

On October 30, 2014 an other personal injury/property damage/wrongful death (general jurisdiction) case was filed by Guzman Jorge Jr., represented by Lavine Aaron, and Perez Alexander J., against Alvarez Philma, Avalon Foods Inc. Doe 1, Chavez Hector et al. represented by Anderson Michael D., and Serpik Andrei V., in the jurisdiction of Los Angeles County. Judge Holly J. Fujie presiding.

                        
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. 0 From Alexander 6 1.424.288.4368 Thu Jul 27 17:57:39 7 MDT Page 2 of 12 ot7 Boris naar Esq. (SBN 188893) California rior CoofurtLosof Angeles Si upetinty Alexander J. Perez, Esq. (SBN 163688) Aaperez tslaw.com JUL 28 2017 ABIR COHEN TREYZON SALO, LLP ter, Executive Officer/Clerk …

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