Party Discovery: JOSHUA CHOWAIKI VS REBEKAH ROUNDS

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 07/26/2021 03:59 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Lopez,Deputy Clerk




                          1 LAUREN L. ROSE, ESQ. (SBN 305501)
                               MACDONALD & CODY, LLP
                          2 28 Executive Park, Third Floor
                               Irvine, California 92614
                          3 (714) 831-1713; Fax: (714) 823-3229
                               lrose@macdonaldcody.com
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                               Attorneys for Defendant
                          5 REBEKAH ROUNDS
                          6                                SUPERIOR COURT OF THE STATE OF CALIFORNIA

                          7                                                       COUNTY OF LOS ANGELES

                          8 JOSHUA CHOWAIKI                                                                 Case No.: 20STCV47185
                                                                                                            [Unlimited Civil Jurisdiction - Demand exceeds $25,000]
                          9                            Plaintiff,
                               vs.                                                                          NOTICE OF MOTION AND MOTION TO
                        10                                                                                  COMPEL FURTHER RESPONSES TO
                                                                                                            DEFENDANT’S REQUESTS FOR
                        11 REBEKAH ROUNDS and                                                               ADMISSIONS, SET ONE;
                               DOES 1 – 20 Inclusive                                                        MEMORANDUM OF POINTS AND
                        12                                                                                  AUTHORITIES; DECLARATION OF
                                                        Defendants.                                         LAUREN ROSE
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                                                                                                            Date: September 30, 2021
                        14                                                                                  Time: 1:30 p.m.
                                                                                                            Dept: 27
                        15                                                                                  Reservation No.: 084169221068

                        16                                                                                  Assigned for All Purposes to:
                                                                                                            Hon. Edward B. Moreton, Dept. 27
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                                                                                                            Complaint Filed: 12/10/2020
                        18                                                                                  Trial Date:      06/09/2022

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                                           TO PLAINTIFF AND PLAINTIFF’S ATTORNEYS OF RECORD HEREIN:
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                                           PLEASE TAKE NOTICE that on September 30, 2021 at 1:30 p.m. or soon thereafter as
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                               the matter may be heard, in Department 27 of the above-entitled Court, located at 312 N Spring St,
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                               Los Angeles, CA 90012, defendant REBEKAH ROUNDS (hereinafter “Defendant”) will move this
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                               court for an order compelling plaintiff JOSHUA CHOWAIKI (hereinafter “Plaintiff”) to provide
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                               further responses to Requests for Admissions, Set One.
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                                           This motion is made on the grounds that good cause exists for this Motion to Compel as
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                               Plaintiff has failed to provide adequate and proper responses to Defendant’s Requests for
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                                     NOTICE OF MOTION AND MOTION TO COMPEL FURTHER RESPONSES TO DEFENDANT’S
                                     REQUESTS FOR ADMISSIONS, SET ONE; MEMORANDUM OF POINTS AND AUTHORITIES;
                                                           DECLARATION OF LAUREN ROSE