On December 10, 2020 a
Party Discovery
was filed
involving a dispute between
Chowaiki Joshua,
and
Rounds Rebekah,
for Personal Injury/Property Damage/Wrongful Death - Uninsured Motorist (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 09/15/2021 03:38 AM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Guzman,Deputy Clerk
Michael Yadegari (SBN 286514)
Law Office of Yadegari & Associates
287 South Robertson Blvd #221
Beverly Hills, CA 90211
Telephone: (310) 779-9327
Attorney for: PLAINTIFF
JOSHUA CHOWAIKI
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
vvvvvvvvvvvvvvvvvvvvvvv
JOSHUA CHOWAIKI , an individual Case No.: ZOSTCV47185
Plaintiff, PLAINTIFF’S OPPOSITION TO
10 DEFENDANT'S MOTION TO COMPEL
VS.
RESPONSES TO FORM
11 INTERROGATORIES, SET ONE,
REBEKAH ROUNDS AND DOES 1-20 REQUESTS FOR ADMISSIONS, SET
12 ONE, PRODUCTION OF DOCUMENTS
inclusive; , SET ONE, AND SPECIAL
13
INTERROGATORIES, SET ONE AND
Defendant. FOR MONETARY SANCTIONS;
14
PLAINTIFF'S REQUESTS FOR
15 MONETARY SANCTIONS AGAINST
DEFENDANT'S COUNSEL IN THE
16 AMOUNT OF $1,440; MEMORANDUM
OF POINTS AND AUTHORITIES;
17 DECLARATION OF MICHAEL
YADEGARI IN SUPPORT THEREOF;
18
Hearing Date: September 29 and 30, 2021
19
Time: 1:30 PM
20 Location: Dept. 27
21
TO THE HONORABLE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF
22
RECORD:
23
PLEASE TAKE NOTICE that Plaintiff JOSHUA CHOWAIKI submits the following
24
Opposition to Defendant’s Motion to Compel Responses to Request for FORM
25 INTERROGATORIES, SET ONE, REQUESTS FOR ADMISSIONS, SET ONE,
26 PRODUCTION OF DOCUMENTS , SET ONE, AND SPECIAL INTERROGATORIES, SET
27 ONE , and Requests for Monetary Sanctions.
28
PLEASE TAKE FURTHER NOTICE that Plaintiff seeks an Order imposing Monetary
Sanctions in the amount of $1,440 against Defendant’s counsel for the violation of Code of
Page 1
Document Filed Date
September 15, 2021
Case Filing Date
December 10, 2020
Category
Personal Injury/Property Damage/Wrongful Death - Uninsured Motorist (General Jurisdiction)
Status
Request for Dismissal - Before Trial not following ADR or more than 60 days since ADR 05/25/2022
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Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 09/15/2021 03:38 AM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Guzman,Deputy Clerk Michael Yadegari (SBN 286514) Law Office of Yadegari & Associates 287 South Robertson Blvd #221 Beverly Hills, CA 90211 Telephone: (310) 779-9327 Attorney for: PLAINTIFF JOSHUA CHOWAIKI IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES vvvvvvvvvvvvvvvvvvvvvvv JOSHUA CHOWAIKI , an individual Case No.: ZOSTCV47185 Plaintiff, PLAINTIFF’S OPPOSITION TO 10 DEFENDANT'S MOTION TO COMPEL VS. RESPONSES TO FORM 11 INTERROGATORIES, SET ONE, REBEKAH ROUNDS AND DOES 1-20 REQUESTS FOR ADMISSIONS, SET 12 ONE, PRODUCTION OF DOCUMENTS inclusive; , SET ONE, AND SPECIAL 13 INTERROGATORIES, SET ONE AND Defendant. FOR MONETARY SANCTIONS; 14 PLAINTIFF'S REQUESTS FOR 15 MONETARY SANCTIONS AGAINST DEFENDANT'S COUNSEL IN THE 16 AMOUNT OF $1,440; MEMORANDUM OF POINTS AND AUTHORITIES; 17 DECLARATION OF MICHAEL YADEGARI IN SUPPORT THEREOF; 18 Hearing Date: September 29 and 30, 2021 19 Time: 1:30 PM 20 Location: Dept. 27 21 TO THE HONORABLE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF 22 RECORD: 23 PLEASE TAKE NOTICE that Plaintiff JOSHUA CHOWAIKI submits the following 24 Opposition to Defendant’s Motion to Compel Responses to Request for FORM 25 INTERROGATORIES, SET ONE, REQUESTS FOR ADMISSIONS, SET ONE, 26 PRODUCTION OF DOCUMENTS , SET ONE, AND SPECIAL INTERROGATORIES, SET 27 ONE , and Requests for Monetary Sanctions. 28 PLEASE TAKE FURTHER NOTICE that Plaintiff seeks an Order imposing Monetary Sanctions in the amount of $1,440 against Defendant’s counsel for the violation of Code of Page 1