On April 10, 2014 a
Hearing
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: (510) 227-4406
Email: knowyourightsinsf@ gmail.com
Attorneys for Plaintiff Phillip Garcia
ELECTRONICALLY
FILED
Supertor Court of Caiffornia,
County of San Francisco
10/23/2015
Clerk of the Court
BY:ROMY RISK
Deputy Clerk
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
UNLIMITED JURISDICTION
PHILLIP 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 PHILLIP GARCIA’S
) NOTICE OF MOTION AND MOTION
) TO COMPEL RESPONSES TO
) DISCOVERY AND REQUESTS FOR
MONETARY SANCTIONS
Date: November 17, 2015
Time: 9:30 a.m.
Dept: 501
-.1-
PLAINTIFF PHILLIP GARCIA’S NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO
DISCOVERY AND REQUESTS FOR MONETARY SANCTIONSTO THE DEFENDANTS AND THEIR COUNSEL OF RECORD:
PLEASE TAKE NOTICE THAT on November 17, 2015 at 9:30 a.m. or as soon thereafter as|
the matter may be heard, in Dept. 501 of the above-entitled located at 400 McAllister Street, San
Francisco, California, Plaintiffs Phillip Garcia will and hereby does move the Court for an Order
compelling Defendant THE WILSON FAMILY TRUST to respond to Form Interrogatories, Set
Two, and Special Interrogatories, Set Two, pursuant to CCP § 2030.260, 2033.250, 2031.260,
2023.010, and 2030.290.
Pursuant to CCP §§ 2030.290; 2030.300, 2023.030, 2023.010, Plaintiffs hereby give notice
that monetary sanctions in the amount of $2,437.50 is sought jointly against Defendants’ counsel
Murchison & Cummings, and Defendant THE WILSON FAMILY TRUST.
This Motion will be based upon this Notice, the Declaration of Plaintiff's Counsel Benny
Martin in Support, and the Memorandum of Points and Authorities all served and filed herein, the
papers and records on file in the above-entitled action, and such oral and documentary evidence as
may be presented at the time of the hearing of this motion.
Dated: October 22, 2015 LAW OFFICE OF BENNY MARTIN
Benny Martin, Esq.
Counsel for Plaintiff
Plaintiff Garcia
~-2-
PLAINTIFF PHILLIP GARCIA’S NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO
DISCOVERY AND REQUESTS FOR MONETARY SANCTIONS
Document Filed Date
October 23, 2015
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: (510) 227-4406 Email: knowyourightsinsf@ gmail.com Attorneys for Plaintiff Phillip Garcia ELECTRONICALLY FILED Supertor Court of Caiffornia, County of San Francisco 10/23/2015 Clerk of the Court BY:ROMY RISK Deputy Clerk SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO UNLIMITED JURISDICTION PHILLIP 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 PHILLIP GARCIA’S ) NOTICE OF MOTION AND MOTION ) TO COMPEL RESPONSES TO ) DISCOVERY AND REQUESTS FOR MONETARY SANCTIONS Date: November 17, 2015 Time: 9:30 a.m. Dept: 501 -.1- PLAINTIFF PHILLIP GARCIA’S NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO DISCOVERY AND REQUESTS FOR MONETARY SANCTIONSTO THE DEFENDANTS AND THEIR COUNSEL OF RECORD: PLEASE TAKE NOTICE THAT on November 17, 2015 at 9:30 a.m. or as soon thereafter as| the matter may be heard, in Dept. 501 of the above-entitled located at 400 McAllister Street, San Francisco, California, Plaintiffs Phillip Garcia will and hereby does move the Court for an Order compelling Defendant THE WILSON FAMILY TRUST to respond to Form Interrogatories, Set Two, and Special Interrogatories, Set Two, pursuant to CCP § 2030.260, 2033.250, 2031.260, 2023.010, and 2030.290. Pursuant to CCP §§ 2030.290; 2030.300, 2023.030, 2023.010, Plaintiffs hereby give notice that monetary sanctions in the amount of $2,437.50 is sought jointly against Defendants’ counsel Murchison & Cummings, and Defendant THE WILSON FAMILY TRUST. This Motion will be based upon this Notice, the Declaration of Plaintiff's Counsel Benny Martin in Support, and the Memorandum of Points and Authorities all served and filed herein, the papers and records on file in the above-entitled action, and such oral and documentary evidence as may be presented at the time of the hearing of this motion. Dated: October 22, 2015 LAW OFFICE OF BENNY MARTIN Benny Martin, Esq. Counsel for Plaintiff Plaintiff Garcia ~-2- PLAINTIFF PHILLIP GARCIA’S NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO DISCOVERY AND REQUESTS FOR MONETARY SANCTIONS