On April 10, 2014 a
Motion,Ex Parte
was filed
involving a dispute between
Garcia, Phillip,
and
Carrie Wilson, In Her Capacitcy As Trustee Of The,
Does 1 To 20,
Markham, Erika,
Markham, Shaun,
Markham, Shawn,
Wilson, Angelo,
Wilson, Carrie,
for civil
in the District Court of San Francisco County.
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LAW OFFICES OF BENNY MARTIN
Benjamin Martin (SBN 257452)
195 41st Street
P.O. Box 11120
Oakland, CA 94611
Phone: (415) 558-1760.
Email: knowyourightsinsf@ gmail.com
Attorneys for Plaintiff Phil Garcia
ELECTRONICALLY
FILED
Superior Court of California,
County of San Francisco
DEC 12 2014
Clerk of the Court
BY: MAURA RAMIREZ
Deputy Clerk
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
UNLIMITED JURISDICTION
PHIL GARCIA, an individual,
Plaintiff,
vs.
CARRIE WILSON, in her capacity as trustee of
THE WILSON FAMILY TRUST, SHAUN
MARKHAM, an individual, ERIKA
MARKHAM, an individual, and ANGELO
WILSON, an individual, and DOES 1-20.
Defendants.
} Case No. CGC-14-538560
} PLAINTIFF PHIL GARCIA‘S
) NOTICE OF MOTION AND MOTION
) TO COMPEL RESPONSES
) DEPOSITION DOCUMENT
) REQUESTS AND DEPOSITION
} QUESTIONS
)
) Date: January 7, 2014
) Time: 9:30 am.
} Dept: 501
TO DEFENDANTS AND THEIR COUNSEL: YOU ARE HEREBY NOTIFIED THAT on
January 7, 2014 at 9:30 a.m, or as soon as this matter may be heard, in Department 501 of this
Court located at 400 McAllister Street, San Francisco, California, Plaintiff Phil Garcia will and
hereby does move the Court for an order compelling objection free production of documents
requested in the notice of deposition of Defendant Angelo Wilson, and to compel responses to
deposition questions, and for sanctions in the amount of $5,293.75 pursuant to CCP §§ 2025 410,
2025 450, 2025 480.
it
PLAINTIFF PHIL GARCIA‘S NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES
DEPOSITION DOCUMENT REQUESTS AND DEPOSITION QUESTIONS
~1-The motion will be based upon this notice, the memorandum in support of filed and served
herewith, the declaration of Plaintiff's counsel Benny Martin filed and served herewith, and upon
further evidence and arguments as may be presented prior to or at the time of hearing.
A certified copy of the relevant pages of the August 7, 2014 deposition transcript of
Defendant Angelo Wilson are attached as Exhibit H to the Declaration of Benny Martin filed and
served in support herewith pursuant to CCP § 2025.480(h).
Respectfully submitted.
Dated: December 9, 2014 LAW OFFICES OF BENNY MARTIN
By:
Benny Martin
Attorney for Plaintiff Garcia
DEPOSITION DOCUMENT REQUESTS AND DEPOSITION QUESTIONS
~2-
Document Filed Date
December 12, 2014
Case Filing Date
April 10, 2014
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LAW OFFICES OF BENNY MARTIN Benjamin Martin (SBN 257452) 195 41st Street P.O. Box 11120 Oakland, CA 94611 Phone: (415) 558-1760. Email: knowyourightsinsf@ gmail.com Attorneys for Plaintiff Phil Garcia ELECTRONICALLY FILED Superior Court of California, County of San Francisco DEC 12 2014 Clerk of the Court BY: MAURA RAMIREZ Deputy Clerk SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO UNLIMITED JURISDICTION PHIL GARCIA, an individual, Plaintiff, vs. CARRIE WILSON, in her capacity as trustee of THE WILSON FAMILY TRUST, SHAUN MARKHAM, an individual, ERIKA MARKHAM, an individual, and ANGELO WILSON, an individual, and DOES 1-20. Defendants. } Case No. CGC-14-538560 } PLAINTIFF PHIL GARCIA‘S ) NOTICE OF MOTION AND MOTION ) TO COMPEL RESPONSES ) DEPOSITION DOCUMENT ) REQUESTS AND DEPOSITION } QUESTIONS ) ) Date: January 7, 2014 ) Time: 9:30 am. } Dept: 501 TO DEFENDANTS AND THEIR COUNSEL: YOU ARE HEREBY NOTIFIED THAT on January 7, 2014 at 9:30 a.m, or as soon as this matter may be heard, in Department 501 of this Court located at 400 McAllister Street, San Francisco, California, Plaintiff Phil Garcia will and hereby does move the Court for an order compelling objection free production of documents requested in the notice of deposition of Defendant Angelo Wilson, and to compel responses to deposition questions, and for sanctions in the amount of $5,293.75 pursuant to CCP §§ 2025 410, 2025 450, 2025 480. it PLAINTIFF PHIL GARCIA‘S NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES DEPOSITION DOCUMENT REQUESTS AND DEPOSITION QUESTIONS ~1-The motion will be based upon this notice, the memorandum in support of filed and served herewith, the declaration of Plaintiff's counsel Benny Martin filed and served herewith, and upon further evidence and arguments as may be presented prior to or at the time of hearing. A certified copy of the relevant pages of the August 7, 2014 deposition transcript of Defendant Angelo Wilson are attached as Exhibit H to the Declaration of Benny Martin filed and served in support herewith pursuant to CCP § 2025.480(h). Respectfully submitted. Dated: December 9, 2014 LAW OFFICES OF BENNY MARTIN By: Benny Martin Attorney for Plaintiff Garcia DEPOSITION DOCUMENT REQUESTS AND DEPOSITION QUESTIONS ~2-