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GREGORY E. STONE, ESQ., S.B. #144057 gstone@srclaw.com GREG S. MILLER, ESQ., S.B. #181288 gmiller@srclaw.com

STONE | ROSENBLATT | CHA

A Professional Law Corporation 21550 Oxnard Street, Main Plaza Suite 200 Woodland Hills, California 91367 Tel: (818) 999-2232 Fax: (818) 999-2269 Attorneys for Defendant, RALPHS GROCERY COMPANY SUPERIOR COURT OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT

SANDRA RODRIGUEZ, Plaintiff(s), v. FOOD 4 LESS OF SOUTHERN CALIFORNIA, a Delaware Corporation; AND, DOES 1-20, INCLUSIVE, Defendants.

Case No.: 11K05820

[Complaint filed: March 30, 2011] [Assigned for all Purposes to the Honorable Hon. Steven J. Kleifeld, Dept. 77]

Stone | Rosenblatt | Cha

A Professional Law Corporation 21550 Oxnard Street, Main Plaza Suite 200 Woodland Hills, California 91367

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DEFENDANTS NOTICE OF CONTINUANCE OF DEPOSITION OF SANDRA RODRIGUEZ AND REQUEST FOR PRODUCTION OF DOCUMENTS THEREAT Date: October 27, 2011 Time: 10:00 a.m. Location: Stone | Rosenblatt | Cha

TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that Defendant, RALPHS GROCERY COMPANY, will take the deposition of Plaintiff, SANDRA RODRIGUEZ, per the agreement of the parties on October 27, 2011 at 10:00 a.m. at Stone | Rosenblatt | Cha, 21550 Oxnard Street, Main Plaza - Suite 200, Woodland Hills, California 91367. This is a date and time requested by and agreed to by plaintiffs counsel, after he took the deposition originally set for September 15, 2011, off calendar. Said deposition will be taken before a certified shorthand reporter in and for the County of Los Angeles, State of California, and will continue from day to day, Sundays and holidays excepted, until completed.
1 DEFENDANTS NOTICE OF CONTINUANCE OF DEPOSITION OF SANDRA RODRIGUEZ AND REQUEST FOR PRODUCTION OF DOCUMENTS THEREAT

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Defendant intends to have the deposition testimony recorded by audio and visual technology, including potentially by stenographic method through the instant display of testimony. If there should be a need for an interpreter to be present at this deposition, counsel for plaintiff shall be responsible to notify Stone | Rosenblatt | Cha at least five (5) working days prior to said scheduled deposition regarding the need for said interpreter, and the language of preference. In the event that this deposition cannot go forward for any reason, the Noticing Party requires 48 hours notice of cancellation; otherwise the Deposition Officer and interpreter may charge a late cancellation fee. PLEASE TAKE FURTHER NOTICE that pursuant to Code of Civil Procedure. 2025.220(4), the deponent is required to produce the following documents at the time of her deposition: REQUEST FOR PRODUCTION 1. The shoes that YOU were wearing on the date and time of the INCIDENT.

Stone | Rosenblatt | Cha

A Professional Law Corporation 21550 Oxnard Street, Main Plaza Suite 200 Woodland Hills, California 91367

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The production of the shoes shall be made at the aforementioned date and time of production for a reasonable time to allow inspection of the same. Upon request, the shoes will be returned to plaintiff's attorney to maintain custody and control of same. 2. All DOCUMENTS and billing statements reflecting Medi-Care and/or Medi-

Cal adjustments for care received for injuries alleged in YOUR Complaint. 3. A copy of YOUR drivers license or identification card.

Dated: September __, 2011

STONE | ROSENBLATT | CHA

A Professional Law Corporation By: Gregory E. Stone Greg S. Miller Attorneys for Defendant, RALPHS GROCERY COMPANY
2 DEFENDANTS NOTICE OF CONTINUANCE OF DEPOSITION OF SANDRA RODRIGUEZ AND REQUEST FOR PRODUCTION OF DOCUMENTS THEREAT

1 2 3 4 5 6 7 8 9 10 11 STATE OF CALIFORNIA COUNTY OF LOS ANGELES PROOF OF SERVICE ) ) )

I am employed in the county of Los Angeles, State of California. I am over the age of 18 and not a party to the within action; my business address is: 21550 Oxnard Street, Main Plaza, Suite 200, Woodland Hills, California. On September 16, 2011, I served the foregoing document described as: DEFENDANTS NOTICE OF CONTINUANCE OF DEPOSITION OF SANDRA RODRIGUEZ AND REQUEST FOR PRODUCTION OF DOCUMENTS THEREAT, on all interested parties in this action by placing a true copy thereof enclosed in a sealed envelope with postage thereon fully prepaid in the United States mail at: Woodland Hills, California addressed as follows: SEE ATTACHED SERVICE LIST [X] (BY MAIL) I am familiar with the ordinary business practice of the law firm of Stone, Rosenblatt & Cha for collection and processing of correspondence for mailing with the United States Postal Service at the aforementioned place of business and that the above-entitled document was placed in a sealed envelope and deposited for collection and mailing on the date stated above, following such ordinary practices, and in such manner as to cause it to be deposited with the United States Postal Service that same day, with postage thereon fully prepaid, in the ordinary course of business, addressed as indicated above. [] (BY FACSIMILE) I caused such document to be faxed to the addressee. [] (BY E-MAIL) I caused such document to be e-mailed to the addressee. [] (BY PERSONAL SERVICE) I caused such envelope to be delivered by hand to the offices of the addressee. [] (BY EXPRESS MAIL, CCP 1013(c,d) I caused such envelope to be placed in the box regularly maintained by the express service carrier, Federal Express, at 21550 Oxnard Street, Suite 200, Woodland Hills, California. [X] (STATE) I declare under penalty of perjury under the laws of the State of California that the above is true and correct. [] (FEDERAL) I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made. [X] Executed on September 16, 2011, at Woodland Hills, California.

Stone | Rosenblatt | Cha

A Professional Law Corporation 21550 Oxnard Street, Main Plaza Suite 200 Woodland Hills, California 91367

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3 DEFENDANTS NOTICE OF CONTINUANCE OF DEPOSITION OF SANDRA RODRIGUEZ AND REQUEST FOR PRODUCTION OF DOCUMENTS THEREAT

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_____________________________________ Zara Ter-Matevosyan

Stone | Rosenblatt | Cha

A Professional Law Corporation 21550 Oxnard Street, Main Plaza Suite 200 Woodland Hills, California 91367

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4 DEFENDANTS NOTICE OF CONTINUANCE OF DEPOSITION OF SANDRA RODRIGUEZ AND REQUEST FOR PRODUCTION OF DOCUMENTS THEREAT

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SERVICE LIST Vince V. Shulman, Esq. Law Offices of Vince V. Shulman 1801 Century Park East, Suite 1430 Los Angeles, CA 90067 (310) 551-1550 Fax: (310) 551-1553 E-Mail: [Representing Plaintiff, SANDRA RODRIGUEZ]

Stone | Rosenblatt | Cha

A Professional Law Corporation 21550 Oxnard Street, Main Plaza Suite 200 Woodland Hills, California 91367

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5 DEFENDANTS NOTICE OF CONTINUANCE OF DEPOSITION OF SANDRA RODRIGUEZ AND REQUEST FOR PRODUCTION OF DOCUMENTS THEREAT