objections to petitioner's request for judicial notice in support of petition for writ of mandate

8/2/2019 Objections to Petitioner's Request for Judicial Notice in Support of Petition for Writ of Mandate

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Attorneys for Real Party in Interest,CARMEN TRUT ANICH

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Stephen J. Kaufinan, Esq. (SBN131605)Joseph A. Guardarrama, Esq. (SBN204530)KAUFMAN LEGAL GROUP, APC777 S. Figueroa Street, Suite4050Los Angeles, CA 90017Tel: (213) 452-6565Fax: (213) 452-6575Email: [email protected]

[email protected]

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SUPERIOR COURT OF THE STATE OF CALIFORNIAFOR THE COUNTY OF LOS ANGELES

CENTRAL DISTRICT

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)j- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -. .r-! 21l)I : - < Real Parties in Interest.

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1213 ALAN JAY JACKSON, an individualtIl

0 r-tIl tIl0 '" 14'< j< I Petitioner,"I,r--!1) vs..w0 15

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OBJECTION TO PETITIONER'S REQUEST FOR JUDICIAL NOTICE TO PETITION FOR WRIT OFMANDATE - Case No. BS136537

2Exhibit "0," the LA Weekly article, contains the biased opinions of its author and

does not contain any recognizable facts. To the extent the article purports to contain any factsat all, they are highly disputed. Consequently, the article is not the proper subject of a requestfor judicial notice in this matter. Thus, Real Party in Interest respectfully requests that thisCourt decline to take judicial notice of Exhibit "D," and strike it in its entirety fromPetitioner's papers.

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4567 Trutanich further objects to the admissibility of Exhibit "D" on the ground that the

the article contains inadmissible opinion testimony that lacks any foundation. Moreover,Real Party in Interest objects to the admissibility of statements by District Attorney SteveCooley quoted in the article, on the ground that they constitute inadmissible hearsaypursuant to Section 1200 of the California Evidence Code, and should not be consideredby the Court to prove the truth of the matters stated. Consequently, the statements reliedupon by Petitioner are inadmissible.

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15 Dated: April 2, 2012 KAUFMAN LEGAL GROUP APC1617 By:~~~~~~~~ ___St /; aufmJoseph A. Guard ama

Attorneys for Real Parties in InterestCARMEN TRUTANICH

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PROOF OF SERVICESTATE OF CALIFORNIA, COUNTY OF LOS ANGELES

3 I am employed in the County of Los Angeles, State of California. I am over the age of 184 years and not a party to the within entitled action. My business address is Kaufman Legal

Group, 777 South Figueroa Street, Suite 4050, Los Angeles, California, 90017.5

6 On April 2, 2012, I served the following document(s):7 OBJECTIONS TO PETITIONER'S REQUEST FOR JUDICIAL NOTICE INSUPPORT OF PETITION FOR WRIT OF MANDATE8

9 on all interested parties in this action, as stated on the attached Service List:[ ] (BY HAND DELIVERY) I caused to be delivered the foregoing envelope by hand to theindividuals on the attached Service List via Ace Messenger and Attorney Service, 811Wilshire Boulevard, Suite 900, Los Angeles, CA 90017.[X] (BY ELECTRONIC DELIVERY): By transmitting/delivering a true and correct copy

of the aforementioned document(s) to said parties at the electronic mail addressees)listed on the attached Service List.[X] (STATE) I declare under penalty of perjury under the laws of the State ofCalifornia that the above is true and correct.[ ] (FEDERAL) I declare that I am employed in the office of a member of thebar of this Court at whose direction the service was made.

Executed on April 2, 2012, at Los Angeles, California.

Joseph~

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3 REED & DAVIDSON, LLPDana W. ReedStuart L.Leviton3699 Wilshire Boulevard, Suite 1290Los Angeles, CA 90010

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7Attorneys for Petitioner,ALAN JAY JACKSON

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SERVICE LIST

JOHN F. KRATTLIBRANDI MILES MOOREOffice of the County Counsel648 Kenneth Hahn Hall of Administration500 West Temple StreetLos Angeles, CA 90012-2713Attorneys for Respondent,DEAN LOGAN,Registrar-Recorder/County Clerk of theCounty of Los Angeles


objections to petitioner's request for judicial notice in support of petition for writ of mandate

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