Document for Abel vs McCutchan, JR

• 
• 
• 
• 
• 
• 

						
                                
Preview
                                Richard Abel
             1
                  707 Hahman Drive, No. 9301
             2    Santa Rosa, CA 95405
                  Telephone: (707) 340-3894
             3

             4    Plaintiff,  In pro per

             5

             6

             7

             8
                                         SUPERIOR COURT OF THE STATE OF CALIFORNIA
             9
                                                       FOR THE COUNTY OF SONOMA
            10

            11     RICHARD ABEL, an individual;                                Case Number:       SCV-263456

            12                                                                 NOTICE OF MOTION AND MOTION FOR
                                            Plaintiff;                         ORDER TO DEEM FACTS ADMITTED, TO
            13             v.                                                  COMPEL RESPONSES, AND FOR
                                                                               MONETARY SANCTIONS AGAINST
            14     B. EDWARD McCUTCHAN JR. an                                  DEFENDANT JACINDA DUVAL
                                                                                [CCP §§ 2030.290, 2033.280]
            15     individual; SUNDERLAND/McCUTCHAN,
                   LLP, a general partnership; and DOES 1                      Date:
            16     through 100, inclusive;                                     Time:
            17                                                                 Dept:          13 - Hon. Christopher Honigsberg
                                            Defendants.                        Trial Date:    January 13, 2023
            18

            19
                  TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD:
            20
                           PLEASE TAKE NOTICE that on ________________________, at ________ or as soon
            21
                  thereafter as the matter may be heard in Department 13 of the Sonoma County Superior Court,
            22
                  located at 600 Administration Drive, Santa Rosa, CA 95403, plaintiff Richard Abel ("Plaintiff")
            23
                  will and hereby moves the Court for an order pursuant to Code Civ. Proc. § 2033.280(b) that the
            24
                  Requests for Admission, Set One served to defendant Jacinda Duval (“Responding Party”) be
            25
                  deemed admitted.        Plaintiff also moves the Court for an order pursuant to Code Civ. Proc. §
            26
                  2030.290(b) compelling Responding Party to serve full and complete verified responses, without
            27
                  objections, to the Form Interrogatories, Set One, served to Responding Party on May 5, 2022.
            28



                          NOTICE OF MOTION AND MOTION TO DEEM FACTS ADMITTED, AND TO COMPEL RESPONSE
                                                                           1