Motion,Ex Parte: Juanita Olson vs Lidia Ryan

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                                1    JOHN P. HANNON II
                          Law Offices of John P. Hannon II
                     2    SB No:     111692
                          716 Capitola Avenue, Ste. F
                     3    Capitola, CA     95010
                          PH:   (831)476-8005
                     4    FAX:    (831)476-8984
                          E-Mail:    jph3002@yahoo.com
                     5
                          Attorney for Plaintiff:
                     6    JUANITA OLSON

                     7

                     8                      IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
                     9                                            COUNTY OF SANTA CRUZ
                    10
                   11     JUANITA OLSON,                                        )        CASE NO.: 21CV00921
                                                                                )
                   12                       Plaintiffs,                         )        NOTICE OF MOTION TO COMPEL
                                                                                )        ANSWERS TO FORM AND SPECIAL
                   13     V.                                                    )        INTERROGATORIES, TO COMPEL
                                                                                )        RESPONSE TO REQUEST FOR
                   14     LIDIA RYAN, et al.,                                   )        PRODUCTION OF DOCUMENTS AND
                                                                                )        TO DEEM MATTERS ADMITTED
                   15                       Defendants.                         )
                   16                                                           )
                          AND RELATED CROSS-ACTION,                             )        Hearing Date:              9/8//22
                   17                                                                    Time:                      8:30 a.m.
                                                                                         Dept.:                     5
                   18

                   19     TO:      Defendant, Lydia Ryan and all other parties and counsel in this matter:
                   20              Please take note that on September 8, 2022, at the hour of 8:30 a.m. in department 5, or
                   21     such other department as may be assigned, of the above-entitled court located at 701 Ocean Street,
                   22     Santa Cruz, California, Plaintiffs will move this court for an order compelling Defendant, Lydia

                   23     Ryan, to do the following and/or for the court to enter the following orders:
                   24              1.  That Defendant be ordered to answer, without objection, the form interrogatories
                   25     attached as Exhibit A to the declaration of John P. Hannon II which is filed concurrently herewith,
                   26     within 30 days of the hearing on this motion.
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                     1             2.  That Defendant be ordered to answer, without objection, the specially drafted

                     2    interrogatories attached as Exhibit B to the declaration of John P. Hannon II which is filed
                     3    concurrently herewith, within 30 days of the hearing on this motion.
                     4             3.  That Defendant be ordered to respond, without objection, and to produce each of the

                     5    items contained in the request for production which is attached as Exhibit C to the declaration of

                     6    John P.   Hannon II which is filed concurrently herewith, within 30 days of the hearing on this
                     7    motion.
                     8             4.  That the court order that all matters set forth in the request for admissions which is
                     9    attached as Exhibit D to the declaration of John P. Hannon II filed concurrently herewith, be
                   10     deemed admitted.
                   11              5.  That the court order Defendant to pay attorney fees in the sum of $800.00 and court
                   12     costs in the sum of $63.75, or such other amount as the court may deem appropriate, to Plaintiff to
                   13     defray the cost of bringing the present motion.
                   14              This motion will be made upon the grounds that Defendant has failed to respond to said
                   15     discovery in a timely manner.        No request for extension ohime has been requested or granted.
                   16              The matters subject to discovery are necessary to protect the rights of Plaintiff and seek

                    17    information that is relevant or likely to lead to relevant evidence.
                   18              This motion will be based upon this notice, the attached memorandum of points and
                   19     authorities, the declaration of John P. Hannon II, the records, files and documents submitted to this

                   20     court and upon such other and further evidence and argument as the court may consider.
                   21     Dated     1(c.(z_z__                                           By JO __ P_
                                                                                                fill   �         ON II -
                   22                                                                        Attorney for Plaintiff:
                                                                                             JUANITA OLSON
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                                                      PROOF OF SERVICE BY MAIL AND E-MAIL


                                     The undersigned hereby declares that he/she is over the age of 18 years and not a party
                            to the action.   The undersigned's business address is          130 A Rogers Avenue,        Watsonville, CA
                            95076.

                                     On the date last written, the undersigned delivered the following document(s):

                            Notice of Motion to Compel Answers to Form and Special Interrogatories;                         to Compel
                            Response to Request for Production of Documents and to Deem Matters Admitted.


                            by personally mailing, by first class mail, postage prepaid, and by e-mailing the above listed
                            document(s) on the same date of signature hereto to the address(es) and e-mail(s) set forth:

                            Lidia Ryan
                            3970 Harney Street
                            San Diego, CA       92110

                                     E-mail:    rriver.ryan@gmail.com

                                     I declare under penalty of perjury under the laws of the State of California that the
                            foregoing is true and correct.

                            Dated:     1{&(,?2-                                                    � II
                                                                                                            �