On January 01, 1900 a
Party Discovery
was filed
involving a dispute between
Bagga, Surjit,
and
City National Bank,
Fresno Management Company, A California Corporation,
Hutchins, Ray,
Kruse, James,
for 26 Unlimited - Other Real Property
in the District Court of Fresno County.
Preview
1 G. Andrew Slater, #238126
DOWLING AARON INCORPORATED E-FILED
2 8080 North Palm Avenue 8/31/2020 2:34 PM
Third Floor Superior Court of California
3 Fresno, California 93711 County of Fresno
Tel: 559.432.4500 / Fax: 559.432.4590
4 aslater@dowlingaaron.com By: L. Vang, Deputy
5 Attorneys for Defendants_
CITY NATIONAL BANK
6
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF FRESNO
10
11 SURJIT BAGGA, Case No. 16CECG03336
12 Plaintiff, DECLARATION OF G. ANDREW
SLATER IN SUPPORT OF
13 V. DEFENDANT'S MOTION FOR:(l) AN
ORDER DEEMING THE REQUESTS
14 CITY NATIONAL BANK, FRESNO FOR ADMISSIONS (SET ONE) TO BE
MANAGEMENT COMPANY, a California DEEMED ADMITTED, (2)
15 Corporation; Ray Hutchins, an individual; TERMINATING SANCTIONS, (3)
James Krause, an individual; and DOES 1-100, ALTERNATIVELY, EVIDENTIARY
16 inclusive, SANCTIONS, AND (4) MONETARY
SANCTIONS
17 Defendants.
Date: November 18, 2020
18 Time: 3:30 p.m.
Dept: 403
19 Judge: Hon. Kristi Culver Kapetan
20 I, G. Andrew Slater, declare:
21 1. I am an attorney duly licensed to practice before the courts of the state of
22 California. I am an attorney with Dowling Aaron Incorporated, attorneys of record for Defendant
23 City National Bank ("C�B"). The following is of my own personal knowledge and if called to
24 testify, I could and would testify as follows.
25 I. THE ORIGINAL FAILURE TO RESPOND TO THE REQUESTS FOR
ADMISSION BY MS. BAGGA.
26
27 2. On November 7, 2017, CNB propounded Requests for Admission, Set One
28 on plaintiff, Surjit Bagga. A true and correct copy of the Requests for Admission, Set One are
DOWLING I AARON DECLARATION OF G. ANDREW SLATER ISO ( I) ORDER DEEMING THE RFA ( ET ONE) ADMITTJ:m, (2)
I N C O M I' Q II 4 l II. 0
Al!O•W1•••"1CO"'ll
Document Filed Date
August 31, 2020
Case Filing Date
January 01, 1900
Category
26 Unlimited - Other Real Property
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1 G. Andrew Slater, #238126 DOWLING AARON INCORPORATED E-FILED 2 8080 North Palm Avenue 8/31/2020 2:34 PM Third Floor Superior Court of California 3 Fresno, California 93711 County of Fresno Tel: 559.432.4500 / Fax: 559.432.4590 4 aslater@dowlingaaron.com By: L. Vang, Deputy 5 Attorneys for Defendants_ CITY NATIONAL BANK 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF FRESNO 10 11 SURJIT BAGGA, Case No. 16CECG03336 12 Plaintiff, DECLARATION OF G. ANDREW SLATER IN SUPPORT OF 13 V. DEFENDANT'S MOTION FOR:(l) AN ORDER DEEMING THE REQUESTS 14 CITY NATIONAL BANK, FRESNO FOR ADMISSIONS (SET ONE) TO BE MANAGEMENT COMPANY, a California DEEMED ADMITTED, (2) 15 Corporation; Ray Hutchins, an individual; TERMINATING SANCTIONS, (3) James Krause, an individual; and DOES 1-100, ALTERNATIVELY, EVIDENTIARY 16 inclusive, SANCTIONS, AND (4) MONETARY SANCTIONS 17 Defendants. Date: November 18, 2020 18 Time: 3:30 p.m. Dept: 403 19 Judge: Hon. Kristi Culver Kapetan 20 I, G. Andrew Slater, declare: 21 1. I am an attorney duly licensed to practice before the courts of the state of 22 California. I am an attorney with Dowling Aaron Incorporated, attorneys of record for Defendant 23 City National Bank ("C�B"). The following is of my own personal knowledge and if called to 24 testify, I could and would testify as follows. 25 I. THE ORIGINAL FAILURE TO RESPOND TO THE REQUESTS FOR ADMISSION BY MS. BAGGA. 26 27 2. On November 7, 2017, CNB propounded Requests for Admission, Set One 28 on plaintiff, Surjit Bagga. A true and correct copy of the Requests for Admission, Set One are DOWLING I AARON DECLARATION OF G. ANDREW SLATER ISO ( I) ORDER DEEMING THE RFA ( ET ONE) ADMITTJ:m, (2) I N C O M I' Q II 4 l II. 0 Al!O•W1•••"1CO"'ll