Preview
BRYAN CAVE LL
THREE EMBARCADERO CENT
8
8
SAN FRANCISCO, CA 94111-4070
BRYAN CAVE LLP
Daniel T. Rockey, California Bar No. 178604
Goli Mahdavi, California Bar No. 245705
Three Embarcadero Center, 7th Floor
San Francisco, CA 94105-2994
Telephone: (415) 675-3400
Facsimile: (415) 675-3434
E-Mail: daniel.rockey@bryancave.com
goli.mahdavi@bryancave.com
Attorneys for Defendant
JPMORGAN CHASE BANK, N.A.
ELECTRONICALLY
FILED
Superior Court of California,
County of San Francisco
01/04/2017
Clerk of the Court
BY-MADONNA CARANTO
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN FRANCISCO
MARTIN ENG,
Plaintiff,
Vv.
JPMORGAN CHASE BANK, N.A.;
QUALITY LOAN SERVICES; LENDER
PROCESSING SERVICES, INC., DOES 1-
1000 inclusive,
Defendants.
SFO1DOCS\294737.1
Case No. CGC-15-546377
NOTICE OF MOTION AND MOTION
TO HAVE REQUESTS FOR
ADMISSIONS DEEMED ADMITTED, TO
COMPEL DISCOVERY RESPONSES
AND THE PRODUCTION OF
DOCUMENTS AND TO IMPOSE
SANCTIONS
[Filed concurrently with Declaration of Goli
Mahdavi, and [Proposed] Order]
Date: — February 3, 2017
Time: 9:00 a.m.
Dept.: 302 - DISCOVERY
Complaint Filed: June 16, 2015
Trial Date: August 21, 2017
DEFENDANT’S MOTION TO HAVE MATTERS DEEMED ADMITTED, COMPEL RESPONSES &
PRODUCTIONBRYAN CAVE LLP,
THREE EMBARCADERO CENTER, 7" FLOOR
SAN FRANCISCO, CA 94111-4077;
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD, AND THE CLERK
OF THE ABOVE-ENTITLED COURT:
PLEASE TAKE NOTICE that on February 3, 2017 at 9:00 a.m., or as soon thereafter as
the matter may be heard, in Department 302 in the Superior Court of San Francisco County,
located at 400 McAllister Street, San Francisco, California 94102, Defendant, JPMorgan Chase
Bank, N.A. (“Chase”), will, and hereby does, move this Court for an Order deeming admitted each
of Defendant’s Requests For Admission To Plaintiff, Set One, and for an Order compelling
Plaintiff to respond to Defendant’s Form Interrogatories, Set One, Special Interrogatories, Set
One, and Request for Production, Set One, all served on November 3, 2016. In addition,
Defendant respectfully moves for an award of sanctions against Plaintiff in the amount of $2,150
for Plaintiff’s failure to provide responses to Defendant’s discovery and for requiring that
Defendant file this motion, and said amount be increased for any time spent preparing a reply brief
or appearing at a hearing on this motion.
This Motion is brought pursuant to, inter alia, California Code of Civil Procedure §§
2023.010, 2030.290, 2031.300, and 2033.280.
This Motion is based on this Notice of Motion and Motion, the attached Memorandum of
Points and Authorities, the concurrently filed Declaration of Goli Mahdavi, the pleadings and
papers already on file in this action, and upon such other oral and documentary evidence as may
be presented to or at the hearing on this Motion.
Dated: January 4, 2017 BRYAN CAVE LLP
f
{
By:
Goli Mahdavi
Attorneys/for Defendant
JPMORGAN CHASE BANK, N.A.
SFOIDOCS\294737.1 1
DEFENDANT'S MOTION TO HAVE MATTERS DEEMED ADMITTED & COMPEL RESPONSES &
PRODUCTION
Preview
BRYAN CAVE LL THREE EMBARCADERO CENT 8 8 SAN FRANCISCO, CA 94111-4070 BRYAN CAVE LLP Daniel T. Rockey, California Bar No. 178604 Goli Mahdavi, California Bar No. 245705 Three Embarcadero Center, 7th Floor San Francisco, CA 94105-2994 Telephone: (415) 675-3400 Facsimile: (415) 675-3434 E-Mail: daniel.rockey@bryancave.com goli.mahdavi@bryancave.com Attorneys for Defendant JPMORGAN CHASE BANK, N.A. ELECTRONICALLY FILED Superior Court of California, County of San Francisco 01/04/2017 Clerk of the Court BY-MADONNA CARANTO SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO MARTIN ENG, Plaintiff, Vv. JPMORGAN CHASE BANK, N.A.; QUALITY LOAN SERVICES; LENDER PROCESSING SERVICES, INC., DOES 1- 1000 inclusive, Defendants. SFO1DOCS\294737.1 Case No. CGC-15-546377 NOTICE OF MOTION AND MOTION TO HAVE REQUESTS FOR ADMISSIONS DEEMED ADMITTED, TO COMPEL DISCOVERY RESPONSES AND THE PRODUCTION OF DOCUMENTS AND TO IMPOSE SANCTIONS [Filed concurrently with Declaration of Goli Mahdavi, and [Proposed] Order] Date: — February 3, 2017 Time: 9:00 a.m. Dept.: 302 - DISCOVERY Complaint Filed: June 16, 2015 Trial Date: August 21, 2017 DEFENDANT’S MOTION TO HAVE MATTERS DEEMED ADMITTED, COMPEL RESPONSES & PRODUCTIONBRYAN CAVE LLP, THREE EMBARCADERO CENTER, 7" FLOOR SAN FRANCISCO, CA 94111-4077; TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD, AND THE CLERK OF THE ABOVE-ENTITLED COURT: PLEASE TAKE NOTICE that on February 3, 2017 at 9:00 a.m., or as soon thereafter as the matter may be heard, in Department 302 in the Superior Court of San Francisco County, located at 400 McAllister Street, San Francisco, California 94102, Defendant, JPMorgan Chase Bank, N.A. (“Chase”), will, and hereby does, move this Court for an Order deeming admitted each of Defendant’s Requests For Admission To Plaintiff, Set One, and for an Order compelling Plaintiff to respond to Defendant’s Form Interrogatories, Set One, Special Interrogatories, Set One, and Request for Production, Set One, all served on November 3, 2016. In addition, Defendant respectfully moves for an award of sanctions against Plaintiff in the amount of $2,150 for Plaintiff’s failure to provide responses to Defendant’s discovery and for requiring that Defendant file this motion, and said amount be increased for any time spent preparing a reply brief or appearing at a hearing on this motion. This Motion is brought pursuant to, inter alia, California Code of Civil Procedure §§ 2023.010, 2030.290, 2031.300, and 2033.280. This Motion is based on this Notice of Motion and Motion, the attached Memorandum of Points and Authorities, the concurrently filed Declaration of Goli Mahdavi, the pleadings and papers already on file in this action, and upon such other oral and documentary evidence as may be presented to or at the hearing on this Motion. Dated: January 4, 2017 BRYAN CAVE LLP f { By: Goli Mahdavi Attorneys/for Defendant JPMORGAN CHASE BANK, N.A. SFOIDOCS\294737.1 1 DEFENDANT'S MOTION TO HAVE MATTERS DEEMED ADMITTED & COMPEL RESPONSES & PRODUCTION