JOHN F. PRENTICE, ESQ. SBN 87606
LARRY R. SHOCKEY, ESQ. SBN 167783
PRENTICE & SCOTT
433 Turk Street
San Francisco, CA 94102
Telephone: (415) 292-1660
Facsimile: (415) 776-4237

DAVID J. DUCHROW, ESQ. SBN
2828 Donald Douglas Loop North, 2nd Fl.
Santa Monica, CA 90404-2959
Telephone: (310) 581-3506
Facsimile: (310) 581-3508

Attorneys for Plaintiff

SUPERIOR COURT FOR THE STATE OF CALIFORNIA

IN AND FOR THE COUNTY OF LOS ANGELES, WEST DISTRICT


TERRI NICOLE HESS,

Plaintiff,

vs.

PENINSULA BEVERLY HILLS, INC., a Delaware Corporation, PENINSULA BEVERLY HILLS MANAGEMENT, INC. a Delaware Corporation, LUIS ALVERADO, individually and in his capacity as Director of Security, JOSEPH VELEZ, DON KIREMIT, DONALD TURK and DOES 1 - 50,

Defendants.


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No. SC049485

PLAINTIFF'S NOTICE OF MOTION AND MOTION FOR RECONSIDERATION AND REVOCATION OF ORDER GRANTING DEFENDANTS' DEMURRER AS TO HER SEVENTH AND EIGHTH CAUSES OF ACTION WITHOUT LEAVE TO AMEND

DATE: April 16, 1998

TIME:1:30 P.M.

DEPT: B


TO ALL DEFENDANTS AND THEIR ATTORNEYS OF RECORD TIMOTHY R. GRAVES and RAIMO H. KAASIK:

PLEASE TAKE NOTICE that on the above referenced date and time, or as soon thereafter as the matter may be heard the above-entitled Court, plaintiff Terri Nicole Hess will move this court to reconsider and revoke its Order sustaining defendants' demurrer pursuant to Code of Civil Procedure §1008(a), on the basis that, on March 24, 1998, plaintiff discovered legal authority for plaintiff's position which was previously not readily available at the time of her response to the demurrer, despite diligent attempts to research and to discover all such legal precedent.

This motion is based on this notice, the Memorandum of Points and Authorities filed concurrently herewith, the declaration of Larry R. Shockey, Request for Judicial Notice, and the complete files and records of this action.

Dated: March 24, 1998 PRENTICE & SCOTT

_______________________________________

LARRY R. SHOCKEY
Attorneys for Plaintiff