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ELECTRONICALLY FILED
1 SPERTUS, LANDES & UMHOFER, LLP Superior Court of California
Matthew Donald Umhofer (SBN 206607) County of Santa Barbara
2 Diane H. Bang (SBN 271939) Darrel E. Parker, Executive Officer
1990 South Bundy Dr., Suite 705 5/13/2022 4:48 PM
3 Los Angeles, California 90025 By: Johnny Aviles, Deputy
Telephone: (310) 826-4700
4 Facsimile: (310) 826-4711
matthew@spertuslaw.com
5 diane@spertuslaw.com
6 Attorneys for Mark Schaub and TLG Ltd.
7
SUPERIOR COURT OF THE STATE OF CALIFORNIA
8
FOR THE COUNTY OF SANTA BARBARA
9
10 MARK SCHAUB, an individual;
TELEPHONE 310-826-4700; FACSIMILE 310-826-4711
Case No.: 20CV02113
Spertus, Landes & Umhofer, LLP
TLG LTD., a Hong Kong limited
11 liability company,
1990 SOUTH BUNDY DR., SUITE 705
Hon. Donna D. Geck
LOS ANGELES, CA 90025
12 Plaintiffs,
13 PLAINTIFF MARK SCHAUB’S
v. NOTICE OF MOTION AND
14 MOTION TO COMPEL FURTHER
ANDREW WYLES WATERS, an RESPONSES TO REQUESTS FOR
individual; FCP CORPORATE (HK) PRODUCTION BY DEFENDANT
15 LTD., a Hong Kong limited liability ANDREW WATERS AND REQUEST
company; FCP PRIVATE, LLC, a FOR SANCTIONS
16 California limited liability
corporation; and DOES 1 through 10
17 inclusive, [Notice of Motion to Compel Further
Responses to Interrogatories; Notice of
18 Defendants. Motion to Compel Further Responses to
Requests for Admissions; Memorandum
19 of Points & Authorities; Declaration of
Diane Bang and Exhibits; Separate
20 Statement; and Request for Judicial
Notice filed concurrently]
21
Hearing Date: August 12, 2022
22 Hearing Time: 10:00 a.m.
Dept.: 4
23
SAC filed: June 14, 2021
24 Trial: Not set
25
26
27
28
SCHAUB’S NOTICE OF MOTION TO COMPEL FURTHER RESPONSES TO
REQUESTS FOR PRODUCTION – WATERS
1 TO ALL PARTIES AND THEIR COUNSEL OF RECORD:
2 PLEASE TAKE NOTICE that on August 12, 2022 at 10:00 a.m., in
3 Department 4 of the above-entitled Court, located at 1100 Anacapa Street, Santa
4 Barbara, California 93101, Plaintiff Mark Schaub (“Mr. Schaub”) will, and hereby
5 does, move this Court for an order compelling further responses to his First Set of
6 Requests for Production, Nos. 1-47 (“RFPs”) against Defendant Andrew Waters,
7 and for an order of sanctions in the amount of $8,500.00 against him.
8 The motion to compel further responses to Plaintiff’s RFPs and the
9 accompanying request for sanctions are based on California Code of Civil
10 Procedure § 2031.310. The motion to compel further responses and request for
TELEPHONE 310-826-4700; FACSIMILE 310-826-4711
Spertus, Landes & Umhofer, LLP
11 sanctions are also based on this Notice of Motion and Motion, the Memorandum of
1990 SOUTH BUNDY DR., SUITE 705
LOS ANGELES, CA 90025
12 Points and Authorities, the Declaration of Diane H. Bang, the concurrently filed
13 Separate Statement and Request for Judicial Notice, the pleadings and papers on
14 file herein, and such other oral and documentary evidence and argument as may be
15 presented to the Court at or prior to the hearing of this matter. To the extent the
16 Court intends to deny any portion of Plaintiffs’ motion to compel, Plaintiffs request
17 oral argument.
18 Dated: May 13, 2022 SPERTUS, LANDES & UMHOFER, LLP
19
20 By:
Matthew Donald Umhofer
21 Diane H. Bang
22 Attorneys for Plaintiffs
23
24
25
26
27
28
1.
SCHAUB’S NOTICE OF MOTION TO COMPEL FURTHER RESPONSES TO
REQUESTS FOR PRODUCTION – WATERS
Preview
ELECTRONICALLY FILED 1 SPERTUS, LANDES & UMHOFER, LLP Superior Court of California Matthew Donald Umhofer (SBN 206607) County of Santa Barbara 2 Diane H. Bang (SBN 271939) Darrel E. Parker, Executive Officer 1990 South Bundy Dr., Suite 705 5/13/2022 4:48 PM 3 Los Angeles, California 90025 By: Johnny Aviles, Deputy Telephone: (310) 826-4700 4 Facsimile: (310) 826-4711 matthew@spertuslaw.com 5 diane@spertuslaw.com 6 Attorneys for Mark Schaub and TLG Ltd. 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 FOR THE COUNTY OF SANTA BARBARA 9 10 MARK SCHAUB, an individual; TELEPHONE 310-826-4700; FACSIMILE 310-826-4711 Case No.: 20CV02113 Spertus, Landes & Umhofer, LLP TLG LTD., a Hong Kong limited 11 liability company, 1990 SOUTH BUNDY DR., SUITE 705 Hon. Donna D. Geck LOS ANGELES, CA 90025 12 Plaintiffs, 13 PLAINTIFF MARK SCHAUB’S v. NOTICE OF MOTION AND 14 MOTION TO COMPEL FURTHER ANDREW WYLES WATERS, an RESPONSES TO REQUESTS FOR individual; FCP CORPORATE (HK) PRODUCTION BY DEFENDANT 15 LTD., a Hong Kong limited liability ANDREW WATERS AND REQUEST company; FCP PRIVATE, LLC, a FOR SANCTIONS 16 California limited liability corporation; and DOES 1 through 10 17 inclusive, [Notice of Motion to Compel Further Responses to Interrogatories; Notice of 18 Defendants. Motion to Compel Further Responses to Requests for Admissions; Memorandum 19 of Points & Authorities; Declaration of Diane Bang and Exhibits; Separate 20 Statement; and Request for Judicial Notice filed concurrently] 21 Hearing Date: August 12, 2022 22 Hearing Time: 10:00 a.m. Dept.: 4 23 SAC filed: June 14, 2021 24 Trial: Not set 25 26 27 28 SCHAUB’S NOTICE OF MOTION TO COMPEL FURTHER RESPONSES TO REQUESTS FOR PRODUCTION – WATERS 1 TO ALL PARTIES AND THEIR COUNSEL OF RECORD: 2 PLEASE TAKE NOTICE that on August 12, 2022 at 10:00 a.m., in 3 Department 4 of the above-entitled Court, located at 1100 Anacapa Street, Santa 4 Barbara, California 93101, Plaintiff Mark Schaub (“Mr. Schaub”) will, and hereby 5 does, move this Court for an order compelling further responses to his First Set of 6 Requests for Production, Nos. 1-47 (“RFPs”) against Defendant Andrew Waters, 7 and for an order of sanctions in the amount of $8,500.00 against him. 8 The motion to compel further responses to Plaintiff’s RFPs and the 9 accompanying request for sanctions are based on California Code of Civil 10 Procedure § 2031.310. The motion to compel further responses and request for TELEPHONE 310-826-4700; FACSIMILE 310-826-4711 Spertus, Landes & Umhofer, LLP 11 sanctions are also based on this Notice of Motion and Motion, the Memorandum of 1990 SOUTH BUNDY DR., SUITE 705 LOS ANGELES, CA 90025 12 Points and Authorities, the Declaration of Diane H. Bang, the concurrently filed 13 Separate Statement and Request for Judicial Notice, the pleadings and papers on 14 file herein, and such other oral and documentary evidence and argument as may be 15 presented to the Court at or prior to the hearing of this matter. To the extent the 16 Court intends to deny any portion of Plaintiffs’ motion to compel, Plaintiffs request 17 oral argument. 18 Dated: May 13, 2022 SPERTUS, LANDES & UMHOFER, LLP 19 20 By: Matthew Donald Umhofer 21 Diane H. Bang 22 Attorneys for Plaintiffs 23 24 25 26 27 28 1. SCHAUB’S NOTICE OF MOTION TO COMPEL FURTHER RESPONSES TO REQUESTS FOR PRODUCTION – WATERS