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Opposition to Motion to Quash in CA Case

This document is a declaration from Todd Bernstein in support of the Los Angeles County Sheriff's Department's opposition to the County of Los Angeles' motion to quash deposition notices and motion for a protective order. It was electronically filed by the Superior Court of California, County of Los Angeles. The declaration is in regards to case number 19STCP00630, which involves a dispute between the County of Los Angeles and the Los Angeles County Sheriff's Department over subpoenas issued as part of the case.

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0% found this document useful (0 votes)
519 views2 pages

Opposition to Motion to Quash in CA Case

This document is a declaration from Todd Bernstein in support of the Los Angeles County Sheriff's Department's opposition to the County of Los Angeles' motion to quash deposition notices and motion for a protective order. It was electronically filed by the Superior Court of California, County of Los Angeles. The declaration is in regards to case number 19STCP00630, which involves a dispute between the County of Los Angeles and the Los Angeles County Sheriff's Department over subpoenas issued as part of the case.

Uploaded by

lisa
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd
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Electronically FILED by Superior Court of California, County of Los Angeles on 07/25/2019 04:59 PM Sherri R.

Carter, Executive Officer/Clerk of Court, by L. Perez,Deputy Clerk

Exempt from Filing Fee


Government Code § 6103
1 Steven G. Madison (Bar No. 101006)
[email protected]
2 T. Scott Mills (Bar No. 313554)
[email protected]
3 QUINN EMANUEL URQUHART & SULLIVAN, LLP
865 South Figueroa Street, 10th Floor
4 Los Angeles, California 90017-2543
Telephone: (213) 443-3000
5 Facsimile: (213) 443-3100

6 Attorneys for Sheriff Alex Villanueva and


Los Angeles County Sheriff’s Department
7

8 SUPERIOR COURT OF THE STATE OF CALIFORNIA

9 COUNTY OF LOS ANGELES

10 CENTRAL DISTRICT

11 COUNTY OF LOS ANGELES, CASE NO. 19STCP00630

12 Petitioner/Plaintiff, DECLARATION OF TODD BERNSTEIN


IN SUPPORT OF
13 vs. RESPONDENTS/DEFENDANTS
SHERIFF ALEX VILLANUEVA AND
14 ALEX VILLANUEVA, Sheriff of Los LOS ANGELES COUNTY SHERIFF’S
Angeles County Sheriff’s Department; DEPARTMENT’S OPPOSITION TO
15 CAREN CARL MANDOYAN, an individual; PETITIONER/PLAINTIFF COUNTY OF
LOS ANGELES COUNTY SHERIFF’S LOS ANGELES’ NOTICE OF MOTION
16 DEPARTMENT; and DOES 1 through 10, AND MOTION TO QUASH DEPOSITION
inclusive, NOTICES; MOTION FOR PROTECTIVE
17 ORDER
Respondents/Defendants.
18 [Filed concurrently with Opposition to Motion
to Quash, Declaration of Timothy K.
19 Murakami, Declaration of Eliezer Vera,
Declaration of Lawrence Del Mese,
20
LOS ANGELES COUNTY SHERIFF’S Declaration of T. Scott Mills, and Response to
21 DEPARTMENT, Separate Statement]

22 Cross-Petitioner/Cross- Date: August 7, 2019


Plaintiff, Time: 9:30 a.m.
23 Dept.: 86
vs.
24 Assigned for All Purposes to the
BOARD OF SUPERVISORS OF THE Hon. Mitchell L. Beckloff
25 COUNTY OF LOS ANGELES,
Action Filed: March 4, 2019
26 Cross-Respondent/Cross-Defendant. Trial Date: None set

27

28
Case No. 19STCP00630
DECLARATION OF TODD BERNSTEIN ISO OPPOSITION
TO COUNTY’S MOTION TO QUASH AND MOTION FOR PROTECTIVE ORDER

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