On May 15, 2019 a
Party Discovery
was filed
involving a dispute between
American Recovery Service Incorporated, A California Corporation As Assignee Of Sta,
and
R.A.V. Construction,
for Collections
in the District Court of San Bernardino County.
Preview
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1 GEORGE APOSHIAN ESQ Bar 303238
LtiURA M D ANNA ESQ Bar 266113
2 PATENAUDE FELIX A P C r
6800 Owensmouth Avenue Suite 290 sur FR ota Tr r t j iFo Nia
Cc 7Y a s r cFz ako o
3 Canoga Park CA 913 03 4216
SA 1 E ERNA Rt YCl t1 eST i CT
4 Tel 866 784 8084
AN 2 2 2D
5 Attorneys for Plaintiff
N T
BY r
6
P iC i1L Afi VvFii i i ii tS7 Y
7
8
IN THE SUPERIOR COURT OF CALIFORNIA
9
COUNTY OF SAN BERNARDINO
10
11
AMERICAN RECOVERY SERVICE CASE NO CIVDS1915212
12 INCORPORATED A CALIFORNIA
CORPORATION AS ASSIGNEE OF STATE NOTICE OF MOTION AND MOTION FOR
13 COMPENSATION INSURANCE FUND A ORDER DEEMING REQUEST FOR
PUBLIC ENTERPRISE FUND AND ADMISSIONS TO DEFENDANT
14 INDEPENDENT AGENCY OF THE STATE ADMITTED DECLARATION OF LAURA
OF CALIFORNIA M D ANNA AND MEMORANDUM OF
15 POINTS AND AUTHORITIES IN
Plaintiff SUPPORT THEREOF PROPOSED ORDER
16
DATE 3 5 20
17 vs TIME 8 30 a m
DEPT S23
18
R A V CONSTRUCTION DBA R A V COMPLAINT FILED 5 15 19
19 CJNSTRUCTION INC TRIAL DATE SET 8 10 20
and DOES 1 through 5 Inclusive
20 SUBMITTED WITHOUT APPEAR ANCE
Defendants PURSUANT TO CRC 3 1304 c
21
Z C G
4
22
23
24 TO DEFENDANT R A V CONSTRUCTION DBA R A V CONSTRUCTION INC
25 AND ITS ATTORNEY OF RECORD
26
1
27
MOTION FOR ORDER DEEMING REQUEST FOR ADMISSIONS TO DEFENDANT ADMITTED
2 8 FILE NO 18 16381 0 6000 10
t
1 PLEASE TAKE NOTICE THAT at 8 30 a m on 3 5 20 or as soon
2
thereafter as the matter may be called for hearing in Department S23
3 of the above entitled court located at 247 W Third St San
4 Bernardino CA 92415 0210 pursuant to California Code of Civil
5 Procedure Sections 2023 010 et seq and 2031 010 et seq Plaintiff
6 AMERICAN RECOVERY SERVICE INCORPORATED A CALIFORNIA CORPORATION AS
7 ASSIGNEE OF STATE COMPENSATION INSURANCE FUND A PUBLIC ENTERPRISE
8 FUND AND INDEPENDENT AGENCY OF THE STATE OF CALIFORNIA will move the
9 court for an Order establishing the admissions by Defendant R A V
10 CONSTRUCTION DBA R A V CONSTRUCTION INC of all matters set forth in
11 Plaintiff s Requests for Admissions and Genuineness of Documents Set
12 One on the grounds that the Requests are relevant to the subject
13 matter of this litigation and are reasonably calculated to lead to the
14 discovery of admissible evidence in this case
15 This motion is based on this Notice of Motion the Declaration of
16 Laura M D Anna and Exhibits attached thereto the Memorandum of
17 Points and Authorities attached hereto and such further evidence as
18 may be admitted at the hearing of this motion
19
20 PATENA E FELIX A P C
21
22 DATED January 2020 By
IAN LAURA M D ANNA
23 Attorneys for Plaintiff
24
25
26
2
27
MOTION FOR ORDER DEEMING REQUEST FOR ADMISSIONS TO DEFENDANT ADMITTED
2 8 FILE NO 18 16381 0 6000 10
Document Filed Date
January 24, 2020
Case Filing Date
May 15, 2019
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f 1 GEORGE APOSHIAN ESQ Bar 303238 LtiURA M D ANNA ESQ Bar 266113 2 PATENAUDE FELIX A P C r 6800 Owensmouth Avenue Suite 290 sur FR ota Tr r t j iFo Nia Cc 7Y a s r cFz ako o 3 Canoga Park CA 913 03 4216 SA 1 E ERNA Rt YCl t1 eST i CT 4 Tel 866 784 8084 AN 2 2 2D 5 Attorneys for Plaintiff N T BY r 6 P iC i1L Afi VvFii i i ii tS7 Y 7 8 IN THE SUPERIOR COURT OF CALIFORNIA 9 COUNTY OF SAN BERNARDINO 10 11 AMERICAN RECOVERY SERVICE CASE NO CIVDS1915212 12 INCORPORATED A CALIFORNIA CORPORATION AS ASSIGNEE OF STATE NOTICE OF MOTION AND MOTION FOR 13 COMPENSATION INSURANCE FUND A ORDER DEEMING REQUEST FOR PUBLIC ENTERPRISE FUND AND ADMISSIONS TO DEFENDANT 14 INDEPENDENT AGENCY OF THE STATE ADMITTED DECLARATION OF LAURA OF CALIFORNIA M D ANNA AND MEMORANDUM OF 15 POINTS AND AUTHORITIES IN Plaintiff SUPPORT THEREOF PROPOSED ORDER 16 DATE 3 5 20 17 vs TIME 8 30 a m DEPT S23 18 R A V CONSTRUCTION DBA R A V COMPLAINT FILED 5 15 19 19 CJNSTRUCTION INC TRIAL DATE SET 8 10 20 and DOES 1 through 5 Inclusive 20 SUBMITTED WITHOUT APPEAR ANCE Defendants PURSUANT TO CRC 3 1304 c 21 Z C G 4 22 23 24 TO DEFENDANT R A V CONSTRUCTION DBA R A V CONSTRUCTION INC 25 AND ITS ATTORNEY OF RECORD 26 1 27 MOTION FOR ORDER DEEMING REQUEST FOR ADMISSIONS TO DEFENDANT ADMITTED 2 8 FILE NO 18 16381 0 6000 10 t 1 PLEASE TAKE NOTICE THAT at 8 30 a m on 3 5 20 or as soon 2 thereafter as the matter may be called for hearing in Department S23 3 of the above entitled court located at 247 W Third St San 4 Bernardino CA 92415 0210 pursuant to California Code of Civil 5 Procedure Sections 2023 010 et seq and 2031 010 et seq Plaintiff 6 AMERICAN RECOVERY SERVICE INCORPORATED A CALIFORNIA CORPORATION AS 7 ASSIGNEE OF STATE COMPENSATION INSURANCE FUND A PUBLIC ENTERPRISE 8 FUND AND INDEPENDENT AGENCY OF THE STATE OF CALIFORNIA will move the 9 court for an Order establishing the admissions by Defendant R A V 10 CONSTRUCTION DBA R A V CONSTRUCTION INC of all matters set forth in 11 Plaintiff s Requests for Admissions and Genuineness of Documents Set 12 One on the grounds that the Requests are relevant to the subject 13 matter of this litigation and are reasonably calculated to lead to the 14 discovery of admissible evidence in this case 15 This motion is based on this Notice of Motion the Declaration of 16 Laura M D Anna and Exhibits attached thereto the Memorandum of 17 Points and Authorities attached hereto and such further evidence as 18 may be admitted at the hearing of this motion 19 20 PATENA E FELIX A P C 21 22 DATED January 2020 By IAN LAURA M D ANNA 23 Attorneys for Plaintiff 24 25 26 2 27 MOTION FOR ORDER DEEMING REQUEST FOR ADMISSIONS TO DEFENDANT ADMITTED 2 8 FILE NO 18 16381 0 6000 10