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  • Abel vs McCutchan, JR Civil document preview
  • Abel vs McCutchan, JR Civil document preview
  • Abel vs McCutchan, JR Civil document preview
  • Abel vs McCutchan, JR Civil document preview
  • Abel vs McCutchan, JR Civil document preview
  • Abel vs McCutchan, JR Civil document preview
  • Abel vs McCutchan, JR Civil document preview
  • Abel vs McCutchan, JR Civil document preview
						
                                

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Edward McCutchan (SBN 119376) SUNDERLAND | McCUTCHAN, LLP 1083 Vine Street, Suite 907 Healdsburg, California 95448 Telephone: (707) 433-0377 Facsimile: (707) 433-0379 Attorneys for Defendants DALE DAVIS SUED AS DOE 4 and JACINDA DUVAL SUED AS DOE 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SONOMA RICHARD ABEL, an individual, } CASE NO. SCV-263456 Plaintiff, } DALE DAVIS’ AND JACINDA DUVAL’S NOTICE OF MOTION TO COMPEL 3 FURTHER ADMISSION RESPONSES VS. AND FOR MONETARY SANCTIONS ) AGAINST PLAINTIFF RICHARD ABEL B. EDWARD McCUTCHAN, JR. an 3 individual; SUNDERLAND | McCUTCHAN, Hearing Mate: LLP, a general partnership; and DOES 1 J Courtroom? through 100, inclusive, J ° ) Assigned For All Purposes to the Defendants. ) Honorable Arthur Wick ; Dept. 17 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that on , 2022 at am. in Department 17 of the Sonoma County Superior Court located at 3055 Cleveland Avenue, Santa Rosa, California 95403, Defendant, DALE DAVIS sued herein as DOE 4 and Jacinda Duval sued herein as DOE 9, will have their motion to compel further admission responses to their separate first request for admissions on him where he either admits or denies the requests where his March 30, 2022 responses are evasive and incomplete and that he answer the perceived deficient admission requests with a “admit” or “deny” response. DALE DAVIS’ AND JACINDA DUVAL’S NOTICE OF MOTION TO COMPEL FURTHER ADMISSION RESPONSES AND FOR MONETARY SANCTIONS AGAINST PLAINTIFF RICHARD ABEL 1Moving parties will also be requesting monetary sanctions against Richard Abel in the amount of $2,847.50 for his improper discovery responses pertaining to the insolvency of debtor Robert Zuckerman in the Liebling v. Goodrich matter and his claimed assignment from former plaintiffs that appear back dated and are not signed by whose names are on the claimed assignments. Richard Abel has refused to attend his noticed deposition in the matter and where there is a June 29, 2022 motion to compel his deposition. This motion is based upon this notice of motion, the accompanying memorandum of points and authorities in support thereof, the accompanying request for judicial notice, the accompanying separate statement, the accompanying declaration of Edward McCutchan, the court’s file, and oral argument. Date: May 0 » 2022 Ana & DALE DAVIS’ AND JACINDA DUVAL’S NOTICE OF MOTION TO COMPEL FURTHER ADMISSION RESPONSES AND FOR MONETARY SANCTIONS AGAINST PLAINTIFF RICHARD ABEL 2PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF SONOMA Tam employed in the County of Sonoma, State of California. I am over the age of 18 and| not a party to the within action; my present address is: 1083 Vine Street, Suite 907, Healdsburg, California 95448. On May 0. 2022, I served the foregoing documents described as DALE DAVIS’ AND JACINDA DUVAL’S NOTICE OF MOTION TO COMPEL FURTHER ADMISSION RESPONSES AND FOR MONETARY SANCTIONS AGAINST PLAINTIFF RICHARD ABEL on the parties by placing a true copy thereof enclosed in a sealed envelope addressed as follows: SEE ATTACHED SERVICE LIST As Regular U.S. Mail. The documents were placed for collection and mailing following ordinary business practice for deposit in the United States Postal Service in a sealed envelope with postage thereon fully prepaid, addressed as stated above. By personal service. I caused each such envelope to be delivered by hand to thd addressee(s) as stated above. By facsimile transmitted from (707) 433-0379. The document transmission was reported ag complete and without error. / By email or electronic transmission. I caused the document to be sent to the persons at the email addresses listed below. I did not receive within a reasonable time after the transmission an} electronic message or other indication that the transmission was unsuccessful. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that this declaration was executed on May (] , 2022, at Healdsburg. —Cheaeca Kobe, Edward fr) California. te DALE DAVIS’ AND JACINDA DUVAL’S NOTICE OF MOTION TO COMPEL FURTHER ADMISSION RESPONSES AND FOR MONETARY SANCTIONS AGAINST PLAINTIFF RICHARD ABEL 3Abel v. McCutchan, et al. Sonoma County Superior Court Case No. SCV-263456 Plaintiff in Pro Per: Richard Abel Richard Abel USPS FIRST CLASS MAIL - ONLY 707 Hahman Drive, #9301 Santa Rosa, CA 95405-9301 Tel: (707) 340-3894 E-Mail: pererel@gmail.com Attorneys for Defendants: Sunderland | McCutchan, Inc.; Sunderland | McCutchan, LLP; B. Edward McCutchan, Jr. Joseph S. Picchi, Esq. ELECTRONIC SERVICE - ONLY Aaron T. Schultz, Esq. Galloway, Lucchese, Everson & Picchi A Professional Corporation 2300 Contra Costa Blvd., Suite 350 Pleasant Hill, CA 94523-2398 Tel. No. (925) 930-9090 Fax No. (925) 930-9035 E-Mail: aschultz@glattys.com DALE DAVIS’ AND JACINDA DUVAL’S NOTICE OF MOTION TO COMPEL FURTHER ADMISSION RESPONSES AND FOR MONETARY SANCTIONS AGAINST PLAINTIFF RICHARD ABEL 4