Motion,Ex Parte: JACKELINE SANCHEZ VS CRISTINA ROMAN BAHENA

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 03/15/2023 08:34 AM David W. Slayton, Executive Officer/Clerk of Court, by H. Aldana,Deputy Clerk


              1     RODOLFO GONZALEZ, ESQ., SBN 285121
                    LAW OFFICES OF THOMAS D. POKLADOWSKI & ASSOCIATES
              2     13340 183rd Street, Suite 110
                    Cerritos, CA 90703
              3     Telephone: (562) 419-4169
                    Email: tdp-cerritos@kempercorporation.onmicrosoft.com
              4
              5     Attorneys for Defendant,
                    CRISTINA ROMAN BAHENA
              6
              7
              8                                SUPERIOR COURT OF THE STATE OF CALIFORNIA
              9                                            COUNTY OF LOS ANGELES, CENTRAL
            10                SPRING STREET COURTHOUSE - LIMITED (EXCEEDS $10,000)
            11                                          CASE NO.: 21STLC00745
                    JACKELINE SANCHEZ,                  Assigned for all purposes to:
            12                                          25
                          Plaintiff,
            13                                         NOTICE OF MOTION AND MOTION
                    vs.                                FOR TERMINATING AND MONETARY
            14                                         SANCTIONS IN THE AMOUNT OF
                                                       $660.00 AGAINST PLAINTIFF;
            15      CRISTINA ROMAN BAHENA, AND DOES 1 MEMORANDUM OF POINTS AND
                    THROUGH 100, INCLUSIVE,            AUTHORITIES; DECLARATION OF
            16
                                                       RODOLFO GONZALEZ; [PROPOSED]
            17                                         ORDER
                          Defendants.
            18                                         Date:        June 7, 2023
                                                       Time:        10:00 AM
            19                                         Dept.:       25

            20                                                                                    RES ID: 976692484679
            21                                                                                    Complaint Filed: 1/27/2021
            22      TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:
            23                  PLEASE TAKE NOTICE that on June 7, 2023, in Department 25 of the above-entitled
            24      Court, Defendant CRISTINA ROMAN BAHENA (“Defendant”), will move this Court for an
            25      Order terminating this lawsuit brought by Plaintiff JACKELINE SANCHEZ (“Plaintiff”) and
            26      entering judgement of dismissal in favor of Defendant for Plaintiff’s failure to comply with this
            27      Court’s Order compelling discovery responses.
            28
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                        NOTICE OF MOTION AND MOTION FOR TERMINATING AND MONETARY SANCTIONS IN THE
                         AMOUNT OF $660.00 AGAINST PLAINTIFF; MEMORANDUM OF POINTS AND AUTHORITIES;
                                  DECLARATION OF RODOLFO GONZALEZ; AND [PROPOSED] ORDER