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1 JAMES R. PICKER, ESQ. (SBN 237851)
PHILIP M. ANDERSEN & ASSOCIATES
2 Employees of the Law Department
State Farm Mutual Automobile Insurance Company ELECTRONICALLY
3 4450 Rosewood Drive, Suite 450 F I L E D
Pleasanton, California 94588 Superior Court of California,
4 Telephone: (925) 225-6838
County of San Francisco
Facsimile: (855) 732-9437 10/23/2020
5 Email: james.picker@statefarm.com Clerk of the Court
BY: JUDITH NUNEZ
Deputy Clerk
6 Attorneys for Defendant
Weilin Li
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IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
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COUNTY OF SAN FRANCISCO / UNLIMTED JURISDICTION
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HELEN SUN, NO. CGC-20-582737
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AMENDED NOTICE OF MOTION AND
14 Plaintiff, MOTION TO COMPEL PLAINTIFF'S
FURTHER RESPONSES AND
15 VERIFICATIONS TO DEFENDANT'S
v. DISCOVERY REQUESTS; REQUEST
16 FOR MONETARY SANCTIONS
WEILIN LI AND
17 DOES 1 TO 100,, DATE: NOVEMBER 23, 2020
18 TIME: 9:00 AM
Defendants. DEPT: 301
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DISCOVERY MOTION
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TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD HEREIN:
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PLEASE TAKE NOTICE that on, November 23, 2020, at 9:00 am, or as soon as
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counsel may be heard in Department 301 of the above-entitled court located at 400
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McAllister St. San Francisco, California, defendant Weilin Li will move this Court for an
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order compelling plaintiff Helen Sun to provide verified responses to defendant's Form
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Interrogatories, Special Interrogatories, and Request for Production of Documents, and
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further responses to Form Interrogatory Requests 6.1-6.7, 7.1 - 7.3, 8.1 - 8.8, 9.1 - 9.2,
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_______________________________________________________________
Notice of Motion & Motion to Compel Responses to Discovery Requests
1 10.1 - 10.3, and 11.1 - 11.2 documents pursuant to CCP §§2030.290 and 2031.300.
2 PLEASE TAKE FURTHER NOTICE that defendant will request monetary
3 sanctions pursuant to CCP §§2023.010, 2023.030(a), 2030.290(c) and 2031.300(c) in
4 the amount of $916.20 against plaintiff for failure to provide complete code-compliant
5 verified responses and failed to respond to defense counsel’s attempts to resolve this
6 matter informally.
7 This Motion is made on the grounds that defendant propounded Form
8 Interrogatories, Special Interrogatories, and a Request for Production of Documents to
9 plaintiff on May 19, 2020. However, to date, plaintiff failed to respond to Meet and Confer
10 efforts regarding Plaintiff’s failure to respond completely to Form Interrogatories or to
11 provide any verifications for any responses.
12 This Motion is further based on this Notice, the attached Memorandum of Points
13 and Authorities, the Declaration of James R. Picker, the complete pleadings, records and
14 files in this action and upon such oral or documentary evidence as may be presented at
15 the hearing of this Motion.
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Dated: October 19, 2020 PHILIP M. ANDERSEN & ASSOCIATES
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James R. Picker
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Attorneys for Defendant
21 WEILIN LI
Electronic signature pursuant to Civil Code §1633.7(d).
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_______________________________________________________________
Notice of Motion & Motion to Compel Responses to Discovery Requests
1 PROOF OF SERVICE
2 Sun v. Li
San Francisco County Superior Court. CGC-20-582737
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I, the undersigned, declare that I am a resident of the United States; employed in
4 the City of Pleasanton and County of Alameda, State of California; over the age of 18
years; not a party to the within entitled cause; and my business address is 4450
5 Rosewood Drive, Suite 450, Pleasanton, CA 94588.
6 On October 23, 2020, I served the within document(s),
7 NOTICE OF MOTION AND MOTION TO COMPEL PLAINTIFF'S RESPONSES TO
DEFENDANT'S DISCOVERY REQUESTS; REQUEST FOR MONETARY
8 SANCTIONS
9 MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO
COMPEL PLAINTIFF'S RESPONSES TO DEFENDANT'S DISCOVERY REQUESTS;
10 REQUEST FOR MONETARY SANCTIONS
11 DECLARATION OF JAMES R. PICKER IN SUPPORT OF MOTION TO COMPEL
PLAINTIFF'S RESPONSES TO DEFENDANT'S DISCOVERY REQUESTS;
12 REQUEST FOR MONETARY SANCTIONS
13 SEPARATE STATEMENT OF ISSUES REGARDING MOTION TO COMPEL
14 FURTHER RESPONSES ; REQUEST FOR MONETARY SANCTIONS
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[PROPOSED] ORDER GRANTING MOTION TO COMPEL PLAINTIFF'S
16 RESPONSES TO DEFENDANT'S DISCOVERY REQUESTS; ORDER GRANTING
MONETARY SANCTIONS
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on the interested parties in this action as follows:
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Helen Sun
19 1254 43rd Avenue
San Francisco, CA 94122 - 1213
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[ x ] ONLY BY ELECTRONIC TRANSMISSION. Only by e-mailing the document(s)
21 to the persons at the e-mail address(es) listed based on notice provided
that, during the Coronavirus (COVID-19) pandemic, this office will be
22 working remotely, not able to send physical mail as usual, and is therefore
using only electronic mail.
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24 I declare under penalty of perjury under the laws of the State of California that the
above is true and correct, and that this declaration was executed on October 23, 2020,
25 at Pleasanton, California.
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28 Catherine Easley
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____________________________________________
Proof of Service
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1 JAMES R. PICKER, ESQ. (SBN 237851) PHILIP M. ANDERSEN & ASSOCIATES 2 Employees of the Law Department State Farm Mutual Automobile Insurance Company ELECTRONICALLY 3 4450 Rosewood Drive, Suite 450 F I L E D Pleasanton, California 94588 Superior Court of California, 4 Telephone: (925) 225-6838 County of San Francisco Facsimile: (855) 732-9437 10/23/2020 5 Email: james.picker@statefarm.com Clerk of the Court BY: JUDITH NUNEZ Deputy Clerk 6 Attorneys for Defendant Weilin Li 7 8 9 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF SAN FRANCISCO / UNLIMTED JURISDICTION 11 12 HELEN SUN, NO. CGC-20-582737 13 AMENDED NOTICE OF MOTION AND 14 Plaintiff, MOTION TO COMPEL PLAINTIFF'S FURTHER RESPONSES AND 15 VERIFICATIONS TO DEFENDANT'S v. DISCOVERY REQUESTS; REQUEST 16 FOR MONETARY SANCTIONS WEILIN LI AND 17 DOES 1 TO 100,, DATE: NOVEMBER 23, 2020 18 TIME: 9:00 AM Defendants. DEPT: 301 19 DISCOVERY MOTION 20 21 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD HEREIN: 22 PLEASE TAKE NOTICE that on, November 23, 2020, at 9:00 am, or as soon as 23 counsel may be heard in Department 301 of the above-entitled court located at 400 24 McAllister St. San Francisco, California, defendant Weilin Li will move this Court for an 25 order compelling plaintiff Helen Sun to provide verified responses to defendant's Form 26 Interrogatories, Special Interrogatories, and Request for Production of Documents, and 27 further responses to Form Interrogatory Requests 6.1-6.7, 7.1 - 7.3, 8.1 - 8.8, 9.1 - 9.2, 28 -1- _______________________________________________________________ Notice of Motion & Motion to Compel Responses to Discovery Requests 1 10.1 - 10.3, and 11.1 - 11.2 documents pursuant to CCP §§2030.290 and 2031.300. 2 PLEASE TAKE FURTHER NOTICE that defendant will request monetary 3 sanctions pursuant to CCP §§2023.010, 2023.030(a), 2030.290(c) and 2031.300(c) in 4 the amount of $916.20 against plaintiff for failure to provide complete code-compliant 5 verified responses and failed to respond to defense counsel’s attempts to resolve this 6 matter informally. 7 This Motion is made on the grounds that defendant propounded Form 8 Interrogatories, Special Interrogatories, and a Request for Production of Documents to 9 plaintiff on May 19, 2020. However, to date, plaintiff failed to respond to Meet and Confer 10 efforts regarding Plaintiff’s failure to respond completely to Form Interrogatories or to 11 provide any verifications for any responses. 12 This Motion is further based on this Notice, the attached Memorandum of Points 13 and Authorities, the Declaration of James R. Picker, the complete pleadings, records and 14 files in this action and upon such oral or documentary evidence as may be presented at 15 the hearing of this Motion. 16 17 Dated: October 19, 2020 PHILIP M. ANDERSEN & ASSOCIATES 18 19 James R. Picker 20 Attorneys for Defendant 21 WEILIN LI Electronic signature pursuant to Civil Code §1633.7(d). 22 23 24 25 26 27 28 -2- _______________________________________________________________ Notice of Motion & Motion to Compel Responses to Discovery Requests 1 PROOF OF SERVICE 2 Sun v. Li San Francisco County Superior Court. CGC-20-582737 3 I, the undersigned, declare that I am a resident of the United States; employed in 4 the City of Pleasanton and County of Alameda, State of California; over the age of 18 years; not a party to the within entitled cause; and my business address is 4450 5 Rosewood Drive, Suite 450, Pleasanton, CA 94588. 6 On October 23, 2020, I served the within document(s), 7 NOTICE OF MOTION AND MOTION TO COMPEL PLAINTIFF'S RESPONSES TO DEFENDANT'S DISCOVERY REQUESTS; REQUEST FOR MONETARY 8 SANCTIONS 9 MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO COMPEL PLAINTIFF'S RESPONSES TO DEFENDANT'S DISCOVERY REQUESTS; 10 REQUEST FOR MONETARY SANCTIONS 11 DECLARATION OF JAMES R. PICKER IN SUPPORT OF MOTION TO COMPEL PLAINTIFF'S RESPONSES TO DEFENDANT'S DISCOVERY REQUESTS; 12 REQUEST FOR MONETARY SANCTIONS 13 SEPARATE STATEMENT OF ISSUES REGARDING MOTION TO COMPEL 14 FURTHER RESPONSES ; REQUEST FOR MONETARY SANCTIONS 15 [PROPOSED] ORDER GRANTING MOTION TO COMPEL PLAINTIFF'S 16 RESPONSES TO DEFENDANT'S DISCOVERY REQUESTS; ORDER GRANTING MONETARY SANCTIONS 17 on the interested parties in this action as follows: 18 Helen Sun 19 1254 43rd Avenue San Francisco, CA 94122 - 1213 20 [ x ] ONLY BY ELECTRONIC TRANSMISSION. Only by e-mailing the document(s) 21 to the persons at the e-mail address(es) listed based on notice provided that, during the Coronavirus (COVID-19) pandemic, this office will be 22 working remotely, not able to send physical mail as usual, and is therefore using only electronic mail. 23 24 I declare under penalty of perjury under the laws of the State of California that the above is true and correct, and that this declaration was executed on October 23, 2020, 25 at Pleasanton, California. 26 27 28 Catherine Easley -1- ____________________________________________ Proof of Service