Legal Document: 524 UNION STREET, A CALIFORNIA GENERAL PARTNERSHIP, et al vs. JAMES S. KNOPF, et al

On February 01, 2018 a MTC&PO_MPA_DNA_EXE was filed involving a dispute between 524 Union Street, A California General Partnership, Smucha, Beverly A., Knopf, James S., and Does 1 Through 10, Does 3 Through 10, Knopf, James S., for (25) Unlimited Professional Negligence in the District Court of San Mateo County.

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1 AKAY LAW
DOUGLAS N. AKAY, SBN 131011
2 Email: dnakay@akaylaw.com
ELSA BERRY, SBN 262363
3 Email: eberry@akaylaw.com
90 New Montgomery Street, Ninth Floor
4 San Francisco, California 94105
Telephone: (415) 362-2580
5 Facsimile: (415) 434-0882

6 Attorneys for Plaintiffs 524 UNION STREET
and BEVERLY A. SMUCHA
7
SUPERIOR COURT OF CALIFORNIA
8
IN AND FOR THE COUNTY OF SAN MATEO
9

10 524 UNION STREET, a California General Case No.: 18-CIV-00533
Partnership, and BEVERLY A. SMUCHA, an
11 individual, PLAINTIFFS 524 UNION STREET’S AND
BEVERLY A. SMUCHA’S
12 Plaintiffs, MEMORANDUM OF POINTS AND
AUTHORITY IN SUPPORT OF
13 v. PLAINTIFFS’ MOTION TO COMPEL
COMPLIANCE WITH THE MARCH 28,
14 JAMES S. KNOPF, individually and dba Law 2022 AGREEMENT TO PRODUCE
Offices of JAMES S. KNOPF, and DOES 1 NATIVE FORMAT AND THE
15 through 10, inclusive, JANURARY 11, 2022 AGREEMENT TO
PRODUCE DOCUMENTS AND FOR
16 Defendants. PROTECTIVE ORDER

17 DATE: June 22, 20022
AND RELATED CROSS-ACTION. TIME: 2:00 P. M.
18 DEPT: Law & Motions
JUDGE: Hon. Marie S. Weiner
19
Accompanying Pleadings:
20 1. Notice of Motion and Motion to Compel
Compliance and for Protective Order
21 2. Elsa Berry’s Declaration ISO Motion to
Compel Compliance and for Protective
22 Order
23
I. INTRODUCTION
24
On January 11, 2022, Defendant Knopf served a response to Plaintiffs’ discovery requests (the “January
25
11, 2022 Agreement to Produce”). At the same time, Defendant produced 48,936 documents in a heavily
26
disorganized manner, which were, for the most part, unresponsive and irrelevant. 17,205 documents, labeled
27
bates numbers JSK031731 through JSK048936, were corrupted and illegible.
28 1
CASE NO.: 18-CIV-00533
PLAINTIFFS’S MOTION TO COMPEL COMPLIANCE WITH AGREEMENT AND FOR PROTECTIVE ORDER
1 Through email exchanges from March 22, 2022, to March 28, 2022, the Parties entered into an

2 agreement (the March 28, 2022 Agreement”) whereby Defendant agreed to reproduce the documents in a

3 native format, and that after Defendants served the documents in their native format, Plaintiffs would then have

4 15 days to respond to Defendants’ discovery. The purpose of the 15 day period was to allow Plaintiff sufficient

5 time review the documents prior to responding to Defendants’ discovery requests and interrogatories.
On April 7, 2022, Defendant breached the terms of the March 28, 2022 Agreement, by demanding
6
Plaintiff to convert Defendants’ production and bear the costs to do so, while imposing a April 22, 2022
7
deadline for the Plaintiffs to respond to discovery.
8
Plaintiffs, 524 Union Street and Beverly A. Smucha, respectfully request this Court to issue an Order
9
compelling Defendant to comply with (1) the March 28, 2022 Agreement; (2) the January 11, 2022 Agreement
10
to Produce, and; (3) for a Protective Order requiring each party to bear their own costs of production of
11
electronically stored information in both native and PDF format, on the following grounds:
12
(1) Pursuant to Code of Civil Procedure section 2031.320, which provides that if the Responding Party
13
fails to comply as agreed, the Demanding Party’s remedy is to file a motion compelling compliance.
14
Here, Responding Party Defendant violated the March 28, 2022 Agreement by: (i) failing to
15 produce the native format of Documents Bates numbers JSK031731 through JSK048936, as agreed;
16 and (ii) by insisting that Plaintiffs’ 15 day period to respond to Defendants’ discovery requests and
17 interrogatories commence despite Defendant’s failure to serve the aforementioned documents in
18 native format. The March 28, 2022 Agreement does not require Plaintiffs to convert Defendant’s
19 documents to have access to their native format and to bear the cost thereof and the Parties agreed
20 that the 15-day notice will only commence on the date Respondent will serve accessible and

21 readable documents bates numbered Documents Bates numbers JSK031731 through JSK048936.

22 Defendant has not produced the native format of those documents as of the filing date of this

23 Motion.
(2) Pursuant to Code of Civil Procedure section 2031.320, Defendant shall be compelled to comply to
24
produce Documents Bates numbers JSK031731 through JSK048936, as agreed in his Responses to
25
Plaintiffs’ Requests for Production serve upon Plaintiffs, on or about January 11, 2022. Inconsistent
26
with the January 11, 2022 Agreement to Produce, Defendant produced corrupted and illegible PDF
27

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2
CASE NO. 18-CIV-00533
PLAINTIFFS’ MOTION TO COMPEL COMPLIANCE AND FOR PROTECTIVE ORDER
1 emails labeled Bates numbers JSK031731 through JSK048936. Responding Party did not produce

2 as agreed and shall be compelled to comply with the January 11, 2022 Agreement to Produce

3 documents numbered JSK031731 through JSK048936 in an uncorrupted and legible PDF format,

4 as agreed.

5 (3) Pursuant to Code of Civil Procedure section 2031.060(b)(4), which provides that the Demanding
Party may seek a protective order if asked to pay for translations of ESI it does not deem
6
“necessary” or if it disputes the “reasonableness of the expenses. Each Party shall bear the cost of
7
producing its electronically stored information in native and PDF format. Defendant’s demands that
8
Plaintiffs convert Defendants’ electronically stored information produced by Defendant, and bear
9
the cost associated therewith and/or invest in an Apple computer to access Defendant’s native
10
format production, are both unnecessary and unreasonable.
11
II. STATEMENT OF FACTS
12
A. This Malpractice Case Does Not Require Massive Production of Documents on Either Side
13 Because Defendants’ Time and Work In the Underlying Case Were Very Limited.

14 This case is a malpractice case by Plaintiffs 524 Union Street and Beverly A. Smucha against attorney
15 Defendant James S. Knopf, for his legal representation of 524 Union Street and Beverly Smucha in the matter
16 of the matter of ENA North Beach v. 524 Union Street, et. al., Case No. CGC-15-547922 (the “Underlying

17 Case”). Defendant’s length of legal representation in this matter was very limited, covering only 13 months.

18 As evidenced by the Register of Actions, the Defendant’s work performed on his clients’ behalf of his client

19 in the Underlying Case was also limited, many of which were Knopf’s Motion to be Relieved as counsel.

20 B. Defendant Knopf Produced 48,936 Documents Mostly Unresponsive, 17,205 of Which Were
Corrupted and Illegible.
21
Yet Defendant overwhelmed Plaintiffs with a mammoth disorganized production of no less that 48,936
22
documents, for the most part, unresponsive, and otherwise corrupted and illegible. A third of Defendant’s
23
production of documents, bearing bates numbers JSK031731 through JSK048936 (17,205 documents) were
24
corrupted because imbedded with characters that made them illegible. As an illustration, document bates
25
number JSK031958, randomly pulled out from Defendant’s corrupted files, reads:
26 <= font class="Apple-style-span" face="'bookman old style', 'new york', ti=
mes, serif" size="2">Realtor SFR Certified.
27

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3
CASE NO. 18-CIV-00533
PLAINTIFFS’ MOTION TO COMPEL COMPLIANCE AND FOR PROTECTIVE ORDER
1 Similar illegible embedded characters are found throughout the 17,205 documents, bates numbers JSK031731

2 through JSK048936. Elsa Berry’s Declaration (“Berry Decl.”) ¶ 3, Exhibit A.

3 C. Pursuant to an Agreement Entered Into On March 28, 2022, Defendant Agreed to Produced the
Native Format of Documents Bates Numbered JSK031731 through JSK048936.
4
On March 22, 2022, Plaintiffs’ counsel, Elsa Berry, emailed Defendant’ counsel, Adrian Sacharski,
5
and requested that Defendant reproduced bates numbers JSK031731 through JSK048936, in a native format.
6
Berry Decl. ¶ 4, Exhibit B. Defendants’ counsel did not respond. On March 25, 2022, Elsa Berry sent another
7
email, inquiring whether Defendant’s counsel would be agreeable to produce the native format of such
8
documents by March 30, 2022. Berry Decl. ¶ 5, Exhibit C (page 3, at the bottom). Plaintiffs’ counsel needed
9
to review those documents prior to responding to Defendants’ Requests and Interrogatories, which were due
10
on April 14, 2022. Berry Decl. ¶ 6. Defendant’s counsel, Adrian Sacharski, replied on March 28, 2022, stating
11
in relevant part:
12 I will review our production and attempt to remedy the issue. However, I
13 will not be able to do so by March 30, 2022, as I will be in depositions until
this Thursday. I will review our production and underlying client file and
14 let you know if there is anything that can be done about the production set
by next week, April 8, 2022.
15 Please let me know if this is acceptable to you.
16 Berry Decl. ¶ 7, Exhibit C (page 3, at the top).
17 The same day, March 28, 2022, Plaintiffs’ counsel replied, in the following terms:
18 If you cannot provide the native format of bates No. JSK031731-
JSK048936 by March 30, 2022, then we request that your extent our
19
deadline to respond to discovery until 15 days after the date
20 you will re-produce those documents in native format . . ..
Please confirm that you are agreeable to such an extension, so our clients
21 are not affected by your client’s defective production.

22 Berry Decl. ¶ 8, Exhibit C (page 1 and 2).
23 On March 28, 2022, Defendant’s counsel materialized the terms of their agreement, stating:
24 We agree to the below terms. I completely understand your needing to
review documents in advance of responding to discovery.
25 To that end, we agree that your client will have 15 days to respond to our
26 discovery starting on the date which you receive the subject document
production, presuming that our deadline to file a motion to compel is equally
27 extended.

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4
CASE NO. 18-CIV-00533
PLAINTIFFS’ MOTION TO COMPEL COMPLIANCE AND FOR PROTECTIVE ORDER
1 I will get to this as soon as I am done with depositions this Thursday and
will hopefully have the documents sent to you by this Friday or early next
2 week . . ..
3
Berry Decl. ¶ 9, Exhibit C (page 1).
4 D. Defendant’s Breach of the March 28, 2022 Agreement.
5 On April 7, 2022, Defendant’s counsel appeared to have a change of mind, and wrote:
6 [W]e have no obligation to produce native versions of the previously
produced documents identified in your email . . .
7

8 You will need a conversion software or outside vendor to convert them for
you. The software that we used to convert them into the format which they
9 were previously produced is called “Aid 4 Mail.” However, you should try
to find an alternative software as a conversion by Aid 4 Mail would result
10 in the same errors . . .
11
If you disagree, please send me a formal meet and confer letter discussing
12 the legal basis for your position.

13 Berry Decl. ¶ 10, Exhibit D.
14
Defendant’s counsel’s new requirements that Plaintiffs’ counsel convert Defendants’ Production to
15
access Defendant’s document were inconsistent with the terms of the March 28, 2022 Agreement. Berry Decl.
16
¶ 11. Exhibit C (page 1).
17
In a good faith attempt to resolve this matter without this Court’s intervention, Plaintiff’s counsel sent
18
a meet and confer letter to Defendant’s counsel on April 14, 2022, stating the legal grounds for Plaintiffs’
19
Requests to abide by the terms of the March 28, 2022 Agreement and identifying Defendant’s Production of
20
Documents and Responses to Requests for Production of Documents’ statutory violations. Berry Decl., ¶ 12,
21 Exhibit E.
22 Although Plaintiffs’ counsel could not access the documents upon clicking on the link provided by
23 Defendant’s counsel, the latter insisted that the 15-day time period for the Plaintiffs to respond commence
24 upon receipt his April 7, 2022 email, and demanded, on April 15, 2022 that Plaintiffs’ respond to Defendant’s
25 discovery request and interrogatories by April 22, 2022, regardless of the fact that Plaintiffs still did not have

26 access to legible and uncorrupted Defendant’s documents bates numbered JSK031731 through JSK048936.

27 Berry Decl., ¶ 13, Exhibits F (pages 2-3). Again, on April 18, 2022, Plaintiffs’ counsel reiterated her efforts

28
5
CASE NO. 18-CIV-00533
PLAINTIFFS’ MOTION TO COMPEL COMPLIANCE AND FOR PROTECTIVE ORDER
1 to resolve the matter amicably, reminding Defendant’s counsel’ unjustified underlying threat of motion to

2 compel were improper in the context of a good faith meet and confer, especially because such threats were not

3 warranted considering that there are no case management discovery deadlines and the trial date has not been

4 set yet. Berry Decl., ¶ 14, Exhibits G (pages 1-2)

5 In his meet and confer reply of March 21, 2022, Defendant’s counsel advised Plaintiffs’ counsel to
acquire an Apple computer to upload, Defendants’ documents. If furthers claims that his original production
6
of documents bates numbered JSK031731 through JSK048936 was not corrupted, stating in relevant part:
7
Plaintiffs were subsequently informed that the MBOX files may easily be
8 accessed by uploading them to an Apple computer. To that end, the
9 documents produced were not “corrupted” so as to warrant their being
reproduced in a different format.
10

11 Berry Decl., ¶ 15, Exhibit H.

12 Plaintiffs’ counsel is only equipped with a PC computer system. Berry Decl., ¶ 16. Plaintiffs’ counsel

13 or Plaintiffs are not required to acquire an Apple computer to access the native format of Defendant’s
electronically stored information.
14
E. Defendant Did Not Reproduce Uncorrupted and Legible PDF Format of Documents Bates
15 Numbered JSK031731 through JSK048936.
16
Defendant continues to claim that he is not obligated to produce Documents bates numbered
17
JSK031731 through JSK048936 in any other format that a PDF format. Yet, Defendant still has not reproduced
18
the foregoing documents in an uncorrupted and legible PDF format, to allow Plaintiffs to at least read the
19 contents of such documents pending production of their native format, and to permit Plaintiffs to fully respond
20 to Defendant’s discovery. Berry Decl. ¶ 17.
21 III. LEGAL ARGUMENT
22 A. This Court Should Grant Plaintiffs’ Motion to Compel Compliance with the March 28, 2022 and
the January 11, 2022 Agreement to Produce Under CCP § 2031.320 Because Defendant Breached
23 Both Agreements.
24
If the responding party fails to permit inspection in accordance with its agreement to comply with an
25
inspection demand, the demanding party's remedy is to file a motion compelling compliance. CCP § 2031.320
26

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6
CASE NO. 18-CIV-00533
PLAINTIFFS’ MOTION TO COMPEL COMPLIANCE AND FOR PROTECTIVE ORDER
1 There is no fixed time limit on this motion. And, no “attempt to resolve informally” need be shown.

2 All that has to be shown is that the responding party's failed to comply as agreed. CCP § 2031.320(a);

3 see Standon Co., Inc. v. Sup.Ct. (Kim) (1990) 225 Cal.App.3d 898, 903.

4 Here, on January 11, 2022, Defendant agreed to produce emails in the Underlying Case, in PDF format.

5 Berry Decl., ¶ 18. Defendant’s PDF production of documents Bates numbered JSK031731 through JSK048936
was corrupted and illegible. Berry Decl., ¶ 3, Exhibits A. Defendants’ counsel reviewed the corrupted
6
production and insisted it was not corrupted, in his letter of April 21, 2022, despite illegible lines of characters
7
embedded with the text of those documents. Berry Decl., ¶ 15, Exhibit H. The embedded illegible lines of
8
characters throughout documents Bates numbered JSK031731 through JSK04893, refute Defendant’s assertion
9
that documents Bates numbered JSK031731 through JSK04893 are not corrupted. Berry Decl., ¶ 3, Exhibits
10
A.
11
On March 28, 2022, Defendant’s counsel agreed to produce documents Bates Numbered Bates
12
numbered JSK031731 through JSK04893, in their native format, without further conditions. Berry Decl., ¶ 9,
13
Exhibit C (page 1). Inconsistently, on April 7, 2022, Defendant’s counsel changed his mind and wrote: “we
14
have no obligation to produce native versions of the previously produced documents identified in your email.”
15 Berry Decl., ¶ 10, Exhibit D. In the same email, Defendant’s counsel demanded that Plaintiff’s convert
16 Defendant’s document production at Plaintiffs’ cost and provided an MBOX link, which did not provide access
17 to the documents when clicking on it. Defendant’s counsel incorrectly argues that his email of April 7, 2022
18 constitutes production of Documents Bates Numbered Bates numbered JSK031731 through JSK04893, thus
19 commencing the 15-day deadline for Plaintiffs’ to read the 17, 205 documents and respond to Defendants’
20 discovery requests and interrogatories. Defendant’s counsel’s position is inconsistent with both the January

21 11, 2021 Agreement to Produce the documents in a legible PDF format and the March 28, 2022 Agreement to

22 produce the documents in an accessible native format. See Berry Decl. ¶¶ , 9 and 18, Exhibit C.

23 Consequently, Plaintiffs respectfully requests this Court to compel compliance with the January 11,
2022 Agreement to Produce and the March 28, 2022 Agreement by ordering that:
24
(1) Defendant produces an uncorrupted PDF version of documents bates numbered JSK031731
25
through JSK04893, in compliance with the January 11, 2022 Agreement to Produce;
26

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CASE NO. 18-CIV-00533
PLAINTIFFS’ MOTION TO COMPEL COMPLIANCE AND FOR PROTECTIVE ORDER
1 (2) Defendant produces the native format of documents bates numbered JSK031731 through

2 JSK04893, in compliance with the March 28, 2022, which does not requires Plaintiffs to convert

3 and/or translate Defendant’s Production and/to incur cost for such conversion;

4 (3) The 15-day extension for Plaintiffs to respond to Defendant’s requests and interrogatories will

5 commence when Defendant will provide access to the native format of documents bates numbered
JSK031731 through JSK04893, with no prerequisite that Plaintiffs convert such documents or incur
6
conversion costs.
7
B. This Court Should Grant Plaintiffs’ Motion For Protective Order, Under CCP § 2031.060(b)(4)
8 and CCP § 2031.280(a).
9
1. This Court Should Issue a Protective Order Ordering That Each Party Bears the Cost of
10 Producing ESI Information In Native Format Without The Demanding Party Be Required to
Convert and/or Translate Responding Party’s Document Production for Access.
11

12 Under persuasive federal precedent production of ESI in PDF format “may not be sufficient if the
13 requesting party can show that the format is not ‘reasonably usable’ and that the native format, with

14 accompanying metadata, meet the criteria of reasonably usable” while the PDF format does not. Ellis v.

15 Toshiba America Information Systems, Inc. (2013) 218 Cal.App.4th 853, 862; Victor Stanley, Inc. v. Creative

16 Pipe, Inc. (D MD 2010) 269 FRD 497, 523-524; Fujitsu Ltd. v. Federal Express Corp. (2nd Cir. 2001) 247

17 F3d 423, 436.
Contrary to Defendant’s assertion, CCP 2031.030(a)(2) does not require a propounding party to specify
18
the form in which each type of electronically stored information is to be produced. CCP § 2031.030(a)(2)
19
states:
20
[A] party demanding inspection, copying . . . of electronically stored
21 information may specify the form or forms in which each type of
electronically stored information is to be produced. (Italic emphasis added).
22

23 To the contrary, the Responding Party has a statutory obligation, in its responses, to state the form in

24 which it intends to produce electronically stored information. CCP § 2031.280(c) provides that the responding

25 party “shall state in its response the form in which it intends to produce each type of information.” (emphasis
added) so the demanding party can ensure that the ESI will be “usable” on its computer.
26

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8
CASE NO. 18-CIV-00533
PLAINTIFFS’ MOTION TO COMPEL COMPLIANCE AND FOR PROTECTIVE ORDER
1 Defendant’s Responses to Plaintiffs’ Request for Production of Documents failed to state the form in

2 which Defendant intended to produce electronically stored information, in violation of CCP § 2031.280(c).

3 Plaintiffs were not given the opportunity to object to the format in which Defendant intended to produce its

4 electronically stored information.

5 The demanding party may seek a protective order (CCP § 2031.060(b)(4)) if asked to pay for
translations of ESI it does not deem “necessary” or if it disputes the “reasonableness” of the expenses alleged.
6
[Toshiba America Electronic Components, Inc. v. Sup.Ct. (Lexar Media, Inc.) (2004) 124 CA4th 762, 772, 21
7
CR3d 532, 540—“Reasonableness and necessity are purely factual issues … which … are properly submitted
8
to the discretion of the trial court”]. Defendant’s counsel’s demand that Plaintiffs invest in an Apple computer
9
to convert Defendant’s Production of ESI documents is unnecessary and unreasonable because Defendant
10
already has an Apple computer and he and/or his counsel can easily perform such conversion, so that Plaintiffs
11
can access the documents immediately upon service by Defendant.
12
Defendant’s counsel’s assertion that Defendant and his counsel “are not obligated to translate, convert,
13
or otherwise effect the emails to make them “reasonably useable,” absent your [Plaintiffs] funding such an
14
endeavor out of necessity”, is inaccurate. To the contrary, CCP § 2031.280(d)(1) provides that the responding
15 party shall produce the information in the form or forms in which it is ordinarily maintained or in a form that
16 is reasonably usable. “Reasonably usable form” presumably means the electronically stored information must
17 be produced in a form that a party can access and read. The link provided by Defendant’s counsel in his April
18 7, 2022 email, does not provide access to a reasonably usable form of the documents because it does not provide
19 access to Defendant’s documents bates numbered JSK031731 through JSK04893, and requires that such
20 documents be first converted by Plaintiffs.

21 2. Plaintiffs Request This Court Issue a Protective Order Ordering That Any Documents or
Category of Documents Produced in Response to a Demand for Inspection, Be Identified with
22 the Specific Request Number to Which the Documents Respond as Required By CCP §
2031.280(a).
23

24 Producing documents as they are kept in the ordinary course of business is no longer an acceptable means
of production. Any documents or category of documents produced in response to a demand for inspection,
25
copying, testing, or sampling shall be identified with the specific request number to which the documents
26
respond. See CCP § 2031.280(a), (emphasis added). Each of and every one of Defendant’s Responses failed
27

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9
CASE NO. 18-CIV-00533
PLAINTIFFS’ MOTION TO COMPEL COMPLIANCE AND FOR PROTECTIVE ORDER
1 to do so. Plaintiffs only request that all parties in this action strictly complies with CCP § 231.280(a), as such

2 Defendant shall be ordered to identify documents or category of documents be produced in response to

3 Plaintiff’s Request for Production of Documents, with a specific number to which the documents respond.

4 IV. CONCLUSION

5 In light of the foregoing, Plaintiffs respectfully request this Court to issue an order:
(1) Compelling Defendant to comply with the January 11, 2022 Agreement to Produce by
6
producing an uncorrupted and PDF format of document bates numbers JSK031731 through
7
JSK048936;
8
(2) Compelling Defendant to comply with the March 28, 2022 Agreement, by producing the native
9
format of documents bates numbers JSK031731 through JSK048936, after conversion, at no
10
cost for Plaintiffs, so that Plaintiffs are not required to convert and/or translate Defendant’s
11
documents and documents are readily accessible and readable upon service;
12
(3) Compelling Defendant to comply with the March 28, 2022 Agreement, which provides that
13
the 15 day extension to respond to Defendants’ Requests for Production and Documents and
14
Interrogatories shall commence upon service of an immediately accessible and legible native
15 format of documents bates numbers JSK031731 through JSK048936;
16 In addition, Plaintiffs respectfully requests this Court to issue a protective order:
17 (1) Ordering all parties to bear the cost of conversion and production of their electronically stored
18 information in a native format;
19 (2) Ordering all parties to strictly complies with CCP § 231.280(a);
20 (3) Ordering Defendant to identify documents or category of documents he produced in responses

21 to Plaintiff’s Request for Production of Documents, with a specific number to which the

22 documents respond, for documents bates number SK000001 through JSK048936.

23 AKAY LAW

24
Dated: March 22, 2022 _____________________
25
Douglas N. Akay
26 Attorneys for Plaintiffs, BEVERLY A. SMUCHA and
524 UNION STREET
27

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CASE NO. 18-CIV-00533
PLAINTIFFS’ MOTION TO COMPEL COMPLIANCE AND FOR PROTECTIVE ORDER

Case Info

Judge

Weiner, Marie S. Track Judge’s New Case

Case No.

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Document Filed Date

April 23, 2022

Case Filing Date

February 01, 2018

County

Parties

524 UNION STREET, A CALIFORNIA GENERAL PARTNERSHIP Cross Defendant
524 UNION STREET, A CALIFORNIA GENERAL PARTNERSHIP Plaintiff
AKAY, DOUGLAS N. Attorneys for Plaintiffs
AKAY, DOUGLAS N. Attorney for the Plaintiff
DOES 1 THROUGH 10 Defendant
DOES 3 THROUGH 10 Defendant
HALLORAN, TIMOTHY J. Attorneys for Defendants
HALLORAN, TIMOTHY J. Attorney for the Defendant
KNOPF, JAMES S. Cross Complainant
KNOPF, JAMES S. Defendant
ROES 1-10 INCLUSIVE Cross Defendant
SMUCHA, BEVERLY A. Cross Defendant
SMUCHA, BEVERLY A. Plaintiff
Tyra Mendez Attorneys for Defendants
Adrian Sacharski Attorneys for Defendants
Ann Draper Attorney
Elsa Beker Berry Attorney
Jessie Burgueno Attorney
Timothy Lupinek Attorneys for Plaintiffs
Colin Galloway Attorneys for Plaintiffs
B Robbins Attorneys for Plaintiffs
Thomas LaLanne Attorney

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Document for 524 UNION STREET, A CALIFORNIA GENERAL PARTNERSHIP, et al vs. JAMES S. KNOPF, et al

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