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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
						
                                

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