Preview
: Superior
Michelle Sampson o2 Court of ,,C‘n:'“'Om'a
2692 Adriatic T
Long Beach, CA 90810 FEB 07 2023
562-235-4590 michelles220@yahoo
DavidW, Siayton, Exacutive OffcerCieck
o Gout
Michelle Sampson, In Pro Per By: J. Baflesteros, Deputy
SUPERIOR COURT OF CALIFORNIA
COUNTY OF Los Angeles
Michelle Sampson, ) Case No.: 22.LBCV00299
Plaintiff, )
VS. ) NOTICE OF MOTION AND MOTION;
ALBERTO CARVALHO, LAUSD, ) MEMORANDUM OF POINTS AND
Defendant ) AUTHORITIES; and DECLARATION OF
10 ) plaintiff IN SUPPORT OF MOTION TO
) COMPEL RESPONSES TO REQUESTS
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) FOR PRODUCTION OF DOCUMENTS,
) SET2
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)
13 ) Date:
) Dept. O (,
14 ) Time:
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To defendant and to his/her/its attorney of record:
17 NOTICE IS HEREBY GIVEN that on or as soon thereafter as the matter may
18 be heard, in Department ____this court, located in Long Beach, the plaintiff will, and
19 hereby does, move for an order compelling defendant, to serve on him/her/it a response to
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the plaintiff's Requests for Production of Documents and written statement, set 2, which
he/she/it served on defendant on ' C115 /o . The motion will be made on the grounds
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that defendant has failed to serve a timely response to the above-described Requests for
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Production of Documents and written request.
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The motion will be based on this notice of motion, on the declaration of plaintiff and the
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memorandum set forth below, on the records and file herein, and on such evidence as may
25 be presented at the hearing of the motion.
26 Dated: | 13 /&3 |
27 By: %W/{Z/g«
Michelle Sampson, In Pro Per
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Sampson v LAUSD page } ot‘%
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT FOR ORDER
COMPELLING RESPONSES TO REQUEST FOR PRODUCTION
Defendant HAS FAILED TO SERVE A TIMELY RESPONSE TO Plaintif’S DEMAND FOR
PRODUCTION OF DOCUMENTS, SET 2, AND THUS THE COURT SHOULD MAKE AN
ORDER COMPELLING A RESPONS.
A. Party May Move for Order Compelling Response. When a party makes an inspection
demand under Section 2031.010 of the Code of Civil Procedure and the party to whom the
demand is directed fails to respond, the demanding party may move for an order compelling
response under Section 2023.030 of the Code of Civil Procedure ( Code Civ. Proc. §
2031.300).
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B. Waiver of Objection to Demand. When the party to whom an inspection demand has
11 been directed fails to serve a timely response to it, that party waives any objection to the
demand, including one based on privilege or on the protection for work product under
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Section 2018.010 et seq. of the Code of Civil Procedure ( Code Civ. Proc. § 2031.300(a)).
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Dated:( [S 2>
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16 By: ‘/22 g[L/‘/lg % A
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Michelle Sampséh,1n Pro Per
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Sampson v LAUSD page&otz
DECLARATION OF Michelle Sampson IN SUPPORT FOR ORDER COMPELLING
RESPONSES TO DISCOVERY REQUESTS
I, Michelle Sampson, declare:
1. I am the Plaintiff in the above entitled action.
2.0n o) 15 )& A served my Requests for Production of Documents, Set 2, on
the defendant ALBERTO CARVALHO, LAUSD. A true copy with proof of service is attached
to this declaration as Exhibit A and made a part hereof.
3. I have not received any response to my Requests for Production of Documents,
Set 2, from the defendant.
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4.0n Q [ Qfl Z I , | had served the “meet and confer” letter attached with a
11 proof of service, as Exhibit B, but have still not received any responses. O fegurst v
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13 NOTICE OF TENTATIVE RULING SYSTEM
14 Pursuant to Local Rule 1.06 (A) the court will make a tentative ruling on the merits of this
15 matter by 2:00 p.m., the court day before the hearing. The complete text of the tentative
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rulings for the department may be downloaded off the court’s website. If the party does not
have online access, they may call the dedicated phone number for the department as
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referenced in the local telephone directory between the hours of 2:00 p.m. and 4:00 p.m. on
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the court day before the hearing and receive the tentative ruling. If you do not call the court
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and the opposing party by 4:00 p.m. the court day before the hearing, no hearing will be
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held.
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| declare under penalty of perjury under the laws of the State of California that the
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foregoing is true and correct.
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24 Dated: \h}(éb
b
25 By: /7) Z// Ly >
Michelle Samp* In Pro Per
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28
Sampson v LAUSD page\‘gof 2
N
Michelle Sampson
2692 Adriatic Ave
Long Beach, CA 90810
562-235-4590
michelles220@yahoo
SUPERIOR COURT OF CALIFORNIA
COUNTY OF LOS ANGELES
MICHELLE SAMPSON, Case No. . L ])
Plaintiff,
2ALDCV (g
U &\q 7
vs., [short title] ,LAUSD Short title: -
Defendant
SAMPSON V LAUSD
Al beito Lrilhe
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MOTION TO COMPEL
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Plaintiff moves for an Order compelling the Defendant to produce a copy of plaintiff’s
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personnel file.
This was requested by the Plaintiff requested, again, by way of an email addressed to
charlie.hill@lausd.net 10/15/22.
20 WHEREFORE, the Plaintiff moves for an Order compelling the Defendants to produce
21 complete and executed Answers to deposition questions and the required documents within the next 15
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days.
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Respectfully submitted,
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Michelle Sampson
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Dated this 15st day of October, 2022
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27 OV
Michelle Sampson
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SAMPSON V LAUSD - MOTION TO COMPEL
Michelle
To:
Fw: Reservation: 22LBCV00299 -
Reservation: 22LBCV00299 - 250775541094
The following reservation has been made by the REQUESTOR.
Event: Motion for Order (Plantiff motion to compel/response of plaintiff to
defendant papers)
Reservation ID: 250775541094
PIN: WXTZWSZTH72U
Status: RESERVED
Case Number: 22L.BCV00299
Case Title: MICHELLE SAMPSON vs ALBERTO CARVALHO, et al.
Courthouse: Governor George Deukmejian Courthouse
Dept: Department S26 '
Date: 03-21-2023
Time: 08:30:00 AM i
Parties: Michelle Sampson (Plaintiff) ¢
Motion Count: will not be accepted without the
receipt page and the Reservation ID. Lo ’ -
Preview
: Superior Michelle Sampson o2 Court of ,,C‘n:'“'Om'a 2692 Adriatic T Long Beach, CA 90810 FEB 07 2023 562-235-4590 michelles220@yahoo DavidW, Siayton, Exacutive OffcerCieck o Gout Michelle Sampson, In Pro Per By: J. Baflesteros, Deputy SUPERIOR COURT OF CALIFORNIA COUNTY OF Los Angeles Michelle Sampson, ) Case No.: 22.LBCV00299 Plaintiff, ) VS. ) NOTICE OF MOTION AND MOTION; ALBERTO CARVALHO, LAUSD, ) MEMORANDUM OF POINTS AND Defendant ) AUTHORITIES; and DECLARATION OF 10 ) plaintiff IN SUPPORT OF MOTION TO ) COMPEL RESPONSES TO REQUESTS 11 ) FOR PRODUCTION OF DOCUMENTS, ) SET2 12 ) 13 ) Date: ) Dept. O (, 14 ) Time: 15 16 To defendant and to his/her/its attorney of record: 17 NOTICE IS HEREBY GIVEN that on or as soon thereafter as the matter may 18 be heard, in Department ____this court, located in Long Beach, the plaintiff will, and 19 hereby does, move for an order compelling defendant, to serve on him/her/it a response to 20 the plaintiff's Requests for Production of Documents and written statement, set 2, which he/she/it served on defendant on ' C115 /o . The motion will be made on the grounds 21 that defendant has failed to serve a timely response to the above-described Requests for 22 Production of Documents and written request. 23 The motion will be based on this notice of motion, on the declaration of plaintiff and the 24 memorandum set forth below, on the records and file herein, and on such evidence as may 25 be presented at the hearing of the motion. 26 Dated: | 13 /&3 | 27 By: %W/{Z/g« Michelle Sampson, In Pro Per 28 Sampson v LAUSD page } ot‘% MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT FOR ORDER COMPELLING RESPONSES TO REQUEST FOR PRODUCTION Defendant HAS FAILED TO SERVE A TIMELY RESPONSE TO Plaintif’S DEMAND FOR PRODUCTION OF DOCUMENTS, SET 2, AND THUS THE COURT SHOULD MAKE AN ORDER COMPELLING A RESPONS. A. Party May Move for Order Compelling Response. When a party makes an inspection demand under Section 2031.010 of the Code of Civil Procedure and the party to whom the demand is directed fails to respond, the demanding party may move for an order compelling response under Section 2023.030 of the Code of Civil Procedure ( Code Civ. Proc. § 2031.300). 10 B. Waiver of Objection to Demand. When the party to whom an inspection demand has 11 been directed fails to serve a timely response to it, that party waives any objection to the demand, including one based on privilege or on the protection for work product under 12 Section 2018.010 et seq. of the Code of Civil Procedure ( Code Civ. Proc. § 2031.300(a)). 13 Dated:( [S 2> 14 15 16 By: ‘/22 g[L/‘/lg % A 17 Michelle Sampséh,1n Pro Per 18 19 20 21 22 23 24 25 26 27 28 Sampson v LAUSD page&otz DECLARATION OF Michelle Sampson IN SUPPORT FOR ORDER COMPELLING RESPONSES TO DISCOVERY REQUESTS I, Michelle Sampson, declare: 1. I am the Plaintiff in the above entitled action. 2.0n o) 15 )& A served my Requests for Production of Documents, Set 2, on the defendant ALBERTO CARVALHO, LAUSD. A true copy with proof of service is attached to this declaration as Exhibit A and made a part hereof. 3. I have not received any response to my Requests for Production of Documents, Set 2, from the defendant. 10 4.0n Q [ Qfl Z I , | had served the “meet and confer” letter attached with a 11 proof of service, as Exhibit B, but have still not received any responses. O fegurst v 12 13 NOTICE OF TENTATIVE RULING SYSTEM 14 Pursuant to Local Rule 1.06 (A) the court will make a tentative ruling on the merits of this 15 matter by 2:00 p.m., the court day before the hearing. The complete text of the tentative 16 rulings for the department may be downloaded off the court’s website. If the party does not have online access, they may call the dedicated phone number for the department as 17 referenced in the local telephone directory between the hours of 2:00 p.m. and 4:00 p.m. on 18 the court day before the hearing and receive the tentative ruling. If you do not call the court 19 and the opposing party by 4:00 p.m. the court day before the hearing, no hearing will be 20 held. 21 | declare under penalty of perjury under the laws of the State of California that the 22 foregoing is true and correct. 23 24 Dated: \h}(éb b 25 By: /7) Z// Ly > Michelle Samp* In Pro Per 26 27 28 Sampson v LAUSD page\‘gof 2 N Michelle Sampson 2692 Adriatic Ave Long Beach, CA 90810 562-235-4590 michelles220@yahoo SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES MICHELLE SAMPSON, Case No. . L ]) Plaintiff, 2ALDCV (g U &\q 7 vs., [short title] ,LAUSD Short title: - Defendant SAMPSON V LAUSD Al beito Lrilhe 14 MOTION TO COMPEL 15 Plaintiff moves for an Order compelling the Defendant to produce a copy of plaintiff’s 16 personnel file. This was requested by the Plaintiff requested, again, by way of an email addressed to charlie.hill@lausd.net 10/15/22. 20 WHEREFORE, the Plaintiff moves for an Order compelling the Defendants to produce 21 complete and executed Answers to deposition questions and the required documents within the next 15 22 days. 23 Respectfully submitted, 24 Michelle Sampson 25 Dated this 15st day of October, 2022 26 27 OV Michelle Sampson 28 SAMPSON V LAUSD - MOTION TO COMPEL Michelle To: Fw: Reservation: 22LBCV00299 - Reservation: 22LBCV00299 - 250775541094 The following reservation has been made by the REQUESTOR. Event: Motion for Order (Plantiff motion to compel/response of plaintiff to defendant papers) Reservation ID: 250775541094 PIN: WXTZWSZTH72U Status: RESERVED Case Number: 22L.BCV00299 Case Title: MICHELLE SAMPSON vs ALBERTO CARVALHO, et al. Courthouse: Governor George Deukmejian Courthouse Dept: Department S26 ' Date: 03-21-2023 Time: 08:30:00 AM i Parties: Michelle Sampson (Plaintiff) ¢ Motion Count: will not be accepted without the receipt page and the Reservation ID. Lo ’ -