Request,Application: Anita Reyes vs. State Center Community College District

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                                ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, state bar number, and address): FOR COURT USE ONLY
The Torkzadeh Law Firm

Tracy R. Horn, SBN: 258170
18650 MacArthur Blvd., Ste. 300, Irvine, CA 92612

E-FILED
TELEPHONE NO: 310.935.1111 FAX NO: 310.935.0100 6/7/2022 6:09PM
ATTORNEY FOR (Name): Plaintiff, Anita Reyes Superior Court of California

 

County of Fresno

SUPERIOR COURT OF CALIFORNIA * COUNTY OF FRESNO By: Estela Alvarado, Deputy

Civil Division
1130 O Street
Fresno, California 93721-2220

 

PLAINTIFF/PETITIONER: Anita Reyes

DEFENDANT/RESPONDENT:State Center Community College District, et al.

 

CASE NUMBER:

REQUEST FOR PRETRIAL DISCOVERY CONFERENCE 19ceCG03826

 

 

 

Plaintiff(s) [] Defendant(s) [1] Cross-complainant(s) [] Cross-defendant(s) [] Other(s) Request a
Pretrial Discovery Conference.

A Pretrial Discovery Conference is being requested for the following reasons:

1 Adispute has arisen regarding a request for production of documents, set propounded on

C1 Adispute has arisen regarding form or special interrogatories, set propounded on :

L] A dispute has arisen regarding a deposition subpoena directed at for deposition
scheduled for :

(1 Adispute has arisen regarding a deposition notice, production of documents at a deposition or deposition

questions related to the deposition of scheduled for or held on
¥]| A dispute has arisen regarding monetary, issue, evidence or terminating sanctions related to a failure to
comply with CCP 2032.610 .
Privilege is the basis for the refusal to produce documents and a privilege log is attached which complies
with Local Rule 2.1.17(B).

OW

The parties have engaged in the following meaningful meet and confer efforts prior to filing this request:
(Describe in detail all meet and confer efforts including any narrowing of the issues or resolutions reached via
these efforts.)

In addition to timely serving her written request for production of the defense medical examiner's report on
01/25/2021, Plaintiff has followed up with no less than six additional written requests between 04/01/2022 and
06/07/2022 by email, three voicemail messages, and two phone conversations with defense counsel wherein a
copy of the report related to the defense medical examination, that took place on March 1, 2021, was
requested each time. Plaintiff has only been told that defense counsel's office will "look into it" and as of the
date of this filing, the report has not been produced nor has any further explaination been offered for
Defendant's failure to do so.

 

PCV-70 ROS-19 REQUEST FOR PRETRIAL DISCOVERY CONFERENCE Page 1 of 2
Mandatory Local Rule 2.1.17A brief summary of the dispute, including the facts and legal arguments at issue is as follows:
(Excepting a privilege log if checked above, no pleadings, exhibits, declarations, or attachments shall be

attached.)

On 01/05/2021, Defendant State Center Community College served a demand for physical examination of
Plaintiff by its expert, Harvey Edmonds, MD. Plaintiff served her response and objections on 01/25/2021, wherein
she included a demand for the production of the medical examination report pursuant to CCP 2032.610(a)
and CCP 2032.610(b). Plaintiff attended the medical examination as demanded on March 1, 2021.

To date, more than a year since the medical examination was completed, Plaintiff has not received a copy of
the medical examiner's report. As described above, numerous email messages, voicemail messages, and
telephone conversations have taken place, wherein Plaintff requests the report and/or an explaination as to
why the report, now more than a year late, has yet to be produced. As of the date of this filing, Plaintiff has only
been told on each occasion that counsel for defendant will "look into it" without resolution. Believing 14 months
to be sufficient time to produce the report, Plaintiff is now seeking this discovery conference as a final attempt
to resolve the matter before filing her Motion with the court.

It is understood that the filing of this request for a Pretrial Discovery Conference tolls the time for filing a motion
to compel discovery on the disputed issues for the number of days between the filing of the request and
issuance by the Court of a subsequent order pertaining to the discovery dispute.

Opposing Party was served with a copy of REQUEST FOR PRETRIAL DISCOVERY CONFERENCE on: 6/7/2022
Date

Pursuant to Local Rule 2.1.17(A)(1), any opposition to this request for a Pretrial Discovery Conference must also
be filed on an approved form and must be filed within five (5) court days of receipt of the request for a Pretrial
Discovery Conference and must be served on the opposing party.

| declare under penalty of perjury under the laws of the State of California that the foregoing is true and

correct. Berns? h—

 

 

6/7/2022 Tracy R. Horn, Esq.
Date Type or Print Name. Sign&tdre of Party or Atforney for Party
PCV-70 ROS-19 REQUEST FOR PRETRIAL DISCOVERY CONFERENCE Page 2 of 2

Mandatory Local Rule 2.1.17