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ATTORNEY OR PARTY WITHOUT ATTORNEY (Nome, store bar number, and address): FOR COURT USE ONLY
Alaino N. Yborrc, SBN 269130
Low Office of Alcino N. Yborrc
4478 W. Spaotz Avenue, Fresno, CA 93722
TELEPHONE NO: (559) 437-9200 FAX NO: (559) 437—3927
AWORNEY FOR (Nome): Defendants. MARIA TERESA NAVARRO, em}.
E-FILED
SUPERIOR COURT OF CALIFORNIA - COUNTY OF FRESNO 12/21/2021 4:23 PM
Civil Division Superior Court of California
I 130 O Street County of Fresno
Fresno, California 93721—2220 By: I. Herrera, Deputy
PLAINTlFF/PETrTIONER: JANET HERNANDEZ, etol.
DEFENDANT/RESPONDENTZMARIA TERESA NAVARRO, etol.
CASE NUMBER:
OPPOSITION TO REQUEST FOR PRETRIAL DISCOVERY CONFERENCE
21CEC602514
D request
Ploinfiffls)
o
Defendonfis)
Prefrio!
D Cross—comploinonfis)
Discovery Conference filed by
D
PLAINTIFFS
Cross-defendon‘r(s)
on
D Other(s)
12/15/2021
Opposition f0
This opposition relates to:
A dispute regarding o request for production of documents, setOne propounded onO9/29/2021
A dispute regarding form or special interrogatories, seTOne propounded on 09/29/2021 .
D A dispute regarding a deposition subpoena directed of for deposition scheduled for
[j A dispute regarding <3deposition notice, producfion of documents OT a deposition or deposifion questions
relo’red to The deposition of scheduled for .
D A dispute regarding monetary, issue, evidence or Terminating sanctions related To
D with
Privilege
Local
isthe
Rule
basis for
2.]
The refusal To produce documents 0nd c1privilege log is attached which complies
.17(B).
The parties hove engaged in the following meaningful meef and confer efforts prior To fifing this opposition:
(Describe in detail all meeT and confer efforts including any narrowing of The issues or resolutions reached via
these efforTs.)
On November 22, 2021, Plaintiff's counsel sent a meet and confer Iefier outlining what she believed were
inodequofe responses to discovery propounded on Defendant MARIA TERESA NAVARRO, as on individual.
Pursuom‘ To the lefier O deadline of December l, 2021 was set. On December I, 2021 Attorney Alaino N. Yborro
conTOCTed Plaintiff‘s counsel 0nd requested additional fime until December 10, 2021 to provide amended
discovery responses. The exTension wos confirmed by cm eAmoil.
On December 10, 2021, Attorney Alamo N. Yborra sent on e—mail To Pioinfiff's counsel requesting on additional
extension due to Attorney Yborra's client not being able to able to provide The information 0nd documen’rs
needed f0 complete The amended responses. Piainfiff'scounsel did not respond 1‘0 the e—moil, but rather filed
The Request for Pretrial Discovery Conference Request.
PCV‘7‘ R05" 9 OPPOSITION To REQUEST FOR PRETMAL DISCOVERY CONFERENCE Fresno Counigsckgfiflg 9‘13“]?
Mandatory
'A
brief summary of why the requested discovery should be denied, including The facts 0nd legal arguments in
support isGs follows:
(Excepfing o privilege log ifchecked above, no pleadings, exhibits, declarations, or ofiochmenfs shall be
afiochedJ
On DecembergL, 2021, counsel was served with the following:
Plaintiff's 1) amended responses to form
interrogatories, set one; 2) amended responses To speciot interrogatories, set one: 3) amended responses fo
reques’r for producfion of documents, set one; 0nd 4) documents bate stomped numbers I
-
23.
Defendant contends her amended responses addressed The discovery issues raised by counsel
Plaintiff's meet
0nd confer le’rfer dated November 22, 2021. Therefore, The discovery issues ore now moot and request
P!<:xinfiff's
should be denied.
H is understood Th0? ’me filingof The Request foro Pretrial Discovery Conference Tolls ’rheTime for filing a
mofion compel discovery on the disputed issues for fhe number of days between fhe
’ro of The request
filing
0nd issuance by the Court of o subsequent order pertaining to the discovery dispute.
Porfy received The REQUEST FOR PRETRIAL DISCOVERY CONFERENCE on: 12/] 5/2]
Date
Pursuant To Local Rule 2.1 .17(A)(1), This opposi’rion is being filed within five (5) cour’r days of service of the request
for o Pretrial Discovery Conference, extended five (5) days for service by mail, 0nd hos been served on ’rhe
opposing party.
Opposing Pfirfy was served with a copy of the OPPOSITION TO REQUEST FOR PRETRIAL DISCOVERY CONFERENCE
on: l? 2/ 2o
Ge
|declare under penalty of perjury under The lows of ’rhe Sfo’re of California That The foregoing isTrue 0nd correct.
ALAINA N. YBARRA
lg/g/ /¢pg/
I IDote Type or Nome
Pnn’r
PCV-71 R054 9 OPPOSITION To REQUEST FOR PRETRlAL DISCOVERY CONFERENCE Fresno County Superlor Coufi
Mandatory Locol Rule 2.1.17
PROOF OF SERVICE
Iam employed in the County of Fresno, I am over the age 0f 18 years and not a party t0
the within action. My business address is 4478 W. Spaatz Avenue, Fresno, California 93722.
On, December fl, 2021, I served the foregoing document described as: DEFENDANT
MARIA TERESA NAVARRO OPPOSITION TO REQUEST FOR DISCOVERY
CONFERENCE t0 the parties in this action as follows:
_X_ (By Mail) I am readily familiar with the business practice at my place 0f business for
collection and processing of correspondence for mailing with the United States postal Service.
Correspondence so collected and processed is deposited with the United States Postal Service
that same day in the ordinary course 0f business. Icaused each document to be sent as addressed
10 below:
11 Amy R. Lovegren—Tipton
Law Office of Amy R. Lovegren-Tipton, APLC
5703 N. West Avenue, Ste. 103
13
Fresno, CA 9371 1
14
_ (By Fax) Icaused each document to be sent by facsimile to the following number(s):
15
_X_(By Email Transmission) Pursuant to Code of Civil Procedure §1013b the documents listed
16 above are being served by electronic transmission. I caused each document t0 be sent addressed
17 to the person(s) set forth below:
18 Amy R. Lovegren-Tipton — ATipton@Tipt0nLegal.com
I declare under the penalty 0f perjury under the laws of the State 0f California that the
l9
i
foregoing istrue and correct. This declaration isexecuted on DecemberQ§ ,2021, at Fresno,
20
California. 1’;
21
22
dig; ”gaggfiv gm
gyélanda Gonzalezififiré
Mfigpoxzfiv
23
24
25
26
27
28
DEFENDANT MARIA TERESA NAVARRO’S RESPONSES TO PLAINTFF JANET HERNANDEZ’S REQUEST FOR
ADMISSIONS, SET ONE
1
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ATTORNEY OR PARTY WITHOUT ATTORNEY (Nome, store bar number, and address): FOR COURT USE ONLY Alaino N. Yborrc, SBN 269130 Low Office of Alcino N. Yborrc 4478 W. Spaotz Avenue, Fresno, CA 93722 TELEPHONE NO: (559) 437-9200 FAX NO: (559) 437—3927 AWORNEY FOR (Nome): Defendants. MARIA TERESA NAVARRO, em}. E-FILED SUPERIOR COURT OF CALIFORNIA - COUNTY OF FRESNO 12/21/2021 4:23 PM Civil Division Superior Court of California I 130 O Street County of Fresno Fresno, California 93721—2220 By: I. Herrera, Deputy PLAINTlFF/PETrTIONER: JANET HERNANDEZ, etol. DEFENDANT/RESPONDENTZMARIA TERESA NAVARRO, etol. CASE NUMBER: OPPOSITION TO REQUEST FOR PRETRIAL DISCOVERY CONFERENCE 21CEC602514 D request Ploinfiffls) o Defendonfis) Prefrio! D Cross—comploinonfis) Discovery Conference filed by D PLAINTIFFS Cross-defendon‘r(s) on D Other(s) 12/15/2021 Opposition f0 This opposition relates to: A dispute regarding o request for production of documents, setOne propounded onO9/29/2021 A dispute regarding form or special interrogatories, seTOne propounded on 09/29/2021 . D A dispute regarding a deposition subpoena directed of for deposition scheduled for [j A dispute regarding <3deposition notice, producfion of documents OT a deposition or deposifion questions relo’red to The deposition of scheduled for . D A dispute regarding monetary, issue, evidence or Terminating sanctions related To D with Privilege Local isthe Rule basis for 2.] The refusal To produce documents 0nd c1privilege log is attached which complies .17(B). The parties hove engaged in the following meaningful meef and confer efforts prior To fifing this opposition: (Describe in detail all meeT and confer efforts including any narrowing of The issues or resolutions reached via these efforTs.) On November 22, 2021, Plaintiff's counsel sent a meet and confer Iefier outlining what she believed were inodequofe responses to discovery propounded on Defendant MARIA TERESA NAVARRO, as on individual. Pursuom‘ To the lefier O deadline of December l, 2021 was set. On December I, 2021 Attorney Alaino N. Yborro conTOCTed Plaintiff‘s counsel 0nd requested additional fime until December 10, 2021 to provide amended discovery responses. The exTension wos confirmed by cm eAmoil. On December 10, 2021, Attorney Alamo N. Yborra sent on e—mail To Pioinfiff's counsel requesting on additional extension due to Attorney Yborra's client not being able to able to provide The information 0nd documen’rs needed f0 complete The amended responses. Piainfiff'scounsel did not respond 1‘0 the e—moil, but rather filed The Request for Pretrial Discovery Conference Request. PCV‘7‘ R05" 9 OPPOSITION To REQUEST FOR PRETMAL DISCOVERY CONFERENCE Fresno Counigsckgfiflg 9‘13“]? Mandatory 'A brief summary of why the requested discovery should be denied, including The facts 0nd legal arguments in support isGs follows: (Excepfing o privilege log ifchecked above, no pleadings, exhibits, declarations, or ofiochmenfs shall be afiochedJ On DecembergL, 2021, counsel was served with the following: Plaintiff's 1) amended responses to form interrogatories, set one; 2) amended responses To speciot interrogatories, set one: 3) amended responses fo reques’r for producfion of documents, set one; 0nd 4) documents bate stomped numbers I - 23. Defendant contends her amended responses addressed The discovery issues raised by counsel Plaintiff's meet 0nd confer le’rfer dated November 22, 2021. Therefore, The discovery issues ore now moot and request P!<:xinfiff's should be denied. H is understood Th0? ’me filingof The Request foro Pretrial Discovery Conference Tolls ’rheTime for filing a mofion compel discovery on the disputed issues for fhe number of days between fhe ’ro of The request filing 0nd issuance by the Court of o subsequent order pertaining to the discovery dispute. Porfy received The REQUEST FOR PRETRIAL DISCOVERY CONFERENCE on: 12/] 5/2] Date Pursuant To Local Rule 2.1 .17(A)(1), This opposi’rion is being filed within five (5) cour’r days of service of the request for o Pretrial Discovery Conference, extended five (5) days for service by mail, 0nd hos been served on ’rhe opposing party. Opposing Pfirfy was served with a copy of the OPPOSITION TO REQUEST FOR PRETRIAL DISCOVERY CONFERENCE on: l? 2/ 2o Ge |declare under penalty of perjury under The lows of ’rhe Sfo’re of California That The foregoing isTrue 0nd correct. ALAINA N. YBARRA lg/g/ /¢pg/ I IDote Type or Nome Pnn’r PCV-71 R054 9 OPPOSITION To REQUEST FOR PRETRlAL DISCOVERY CONFERENCE Fresno County Superlor Coufi Mandatory Locol Rule 2.1.17 PROOF OF SERVICE Iam employed in the County of Fresno, I am over the age 0f 18 years and not a party t0 the within action. My business address is 4478 W. Spaatz Avenue, Fresno, California 93722. On, December fl, 2021, I served the foregoing document described as: DEFENDANT MARIA TERESA NAVARRO OPPOSITION TO REQUEST FOR DISCOVERY CONFERENCE t0 the parties in this action as follows: _X_ (By Mail) I am readily familiar with the business practice at my place 0f business for collection and processing of correspondence for mailing with the United States postal Service. Correspondence so collected and processed is deposited with the United States Postal Service that same day in the ordinary course 0f business. Icaused each document to be sent as addressed 10 below: 11 Amy R. Lovegren—Tipton Law Office of Amy R. Lovegren-Tipton, APLC 5703 N. West Avenue, Ste. 103 13 Fresno, CA 9371 1 14 _ (By Fax) Icaused each document to be sent by facsimile to the following number(s): 15 _X_(By Email Transmission) Pursuant to Code of Civil Procedure §1013b the documents listed 16 above are being served by electronic transmission. I caused each document t0 be sent addressed 17 to the person(s) set forth below: 18 Amy R. Lovegren-Tipton — ATipton@Tipt0nLegal.com I declare under the penalty 0f perjury under the laws of the State 0f California that the l9 i foregoing istrue and correct. This declaration isexecuted on DecemberQ§ ,2021, at Fresno, 20 California. 1’; 21 22 dig; ”gaggfiv gm gyélanda Gonzalezififiré Mfigpoxzfiv 23 24 25 26 27 28 DEFENDANT MARIA TERESA NAVARRO’S RESPONSES TO PLAINTFF JANET HERNANDEZ’S REQUEST FOR ADMISSIONS, SET ONE 1