Motion-Secondary: RICHARD CORVERA VS PRESTON COLE, LLC, ET AL.

• 
• 

						
                                
Preview
                                Electronically FILED by Superior Court of California, County of Los Angeles on 11/24/2021 05:02 PM Sherri R. Carter, Executive Officer/Clerk of Court, by L. Coreas,Deputy Clerk




           1     FRED B. SMITH, ESQ. – State Bar No. 272178
                 STRATMAN, SCHWARTZ & WILLIAMS-ABREGO
           2     P.O. Box 258829
                 Oklahoma City, OK 73125-8829
           3     Phone: (818) 216-6171
                 Email: fred.smith@farmersinsurance.com
           4
                 Attorney for Defendants/Cross-Complainant,
           5     PRESTON COLE, LLC and WESTRIDGE COMMERCIAL, INC
           6

           7

           8                                      SUPERIOR COURT OF THE STATE OF CALIFORNIA
           9                               FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT
          10

          11     RICHARD CORVERA,                                                                   Case No.: 19STCV24372
                                                                                                    UNLIMITED JURISDICTION
          12                            Plaintiff,
                                                                                                    ASSIGNED TO FOR ALL PURPOSES:
          13                 vs.                                                                    HON. WILLIAM A. CROWFOOT
                                                                                                    DEPT: 27
          14     PRESTON COLE, LLC; SOCAL BIOFUEL, INC.;
                 and DOES 1 to 100, inclusive,           OPPOSITION TO MOTION FOR
          15                                             SUMMARY JUDGMENT BY DEFENDANT
                              Defendants.                SOCAL BIOFUELS, INC.; MEMORANDUM
          16                                             OF POINTS AND AUTHORITIES;
                 ______________________________________  DECLARATION OF FRED B. SMITH IN
          17                                             SUPPORT THEREOF
                 AND RELATED CROSS-ACTIONS.
          18                                             [Filed concurrently with Separate Statement of
                                                         Disputed and Undisputed Facts and Objections by
          19                                             Defendants Preston Cole, LLC. and Westridge
                                                         Commercial, Inc.; Declaration of Mohammed
          20                                             Baghdadi]
          21                                                                                        DATE:                December 8, 2021
                                                                                                    TIME:                1:30 p.m.
          22                                                                                        DEPT:                27
          23

          24
                             COME NOW the Defendants, PRESTON COLE, LLC. and WESTRIDGE COMMERCIAL,
          25
                 INC. (hereinafter “PRESTON/WESTRIDGE”) and offer the following opposition to Defendant SOCAL
          26
                 BIOFUEL, INC.’s (hereinafter “SOCAL”) motion for summary judgment and summary adjudication
          27
                 including upon the following bases:
          28

                        OPPOSITION TO MOTION FOR SUMMARY JUDGMENT BY DEFENDANT SOCAL
                                                BIOFUELS, INC. - 1