On October 08, 2020 a
Party Discovery
was filed
involving a dispute between
Jacocks Stanley,
Mcdonald Krystol Renee,
Mcdonald Kyira Renee,
and
Fieldturf Usa Inc.,
Wells Robert Aaron,
for Motor Vehicle - Personal Injury/Property Damage/Wrongful Death (General Jurisdiction)
in the District Court of Los Angeles County.
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Electronically FILED by Superior Court of California, County of Los Angeles on 08/24/2021 04:31 PM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Briggs,Deputy Clerk
DANIELS, FINE, ISRAEL,
1 SCHONBUCH & LEBOVITS, LLP
1801 CENTURY PARK EAST, NINTH FLOOR
LOS ANGELES, CALIFORNIA 90067
2 TELEPHONE (310) 556-7900
FACSIMILE (310) 556-2807
3 Michael Schonbuch, State Bar No. 150884
Mary R. Fersch, State Bar No. 305855
4
Attorneys For Defendant
5 FIELDTURF USA, INC.
6
7
8
SUPERIOR COURT OF THE STATE OF CALIFORNIA
9
FOR THE COUNTY OF LOS ANGELES - NORTH DISTRICT
10
11
BRIANNA MAREESE JACOCKS, a minor by Case No. 20AVCV00726
12 and through her Guardian ad Litem STANLEY [Complaint Filed: October 8, 2020]
JACOCKS, KATIE FRANCIS JACOCKS, a [Hon. Wendy Chang, Dept. A15]
13 minor by and through her Guardian ad Litem
STANLEY JACOCKS, GENE DAVEYON SEPARATE STATEMENT IN SUPPORT
14 BERNIE JACOCKS, a minor by and through his OF DEFENDANT’S NOTICE OF MOTION
Guardian ad Litem STANLEY JACOCKS, AND MOTION TO COMPEL ANSWERS
15 KRYSTOL RENEE MCDONALD, and KYIRA TO DEPOSITION QUESTIONS
RENEE MCDONALD,
16 [Filed concurrently with Notice of Motion to
Plaintiffs, Compel; Memorandum of Points and
17 Authorities; Declaration of Mary R. Fersch
v. and [Proposed] Order]
18
ROBERT AARON WELLS, FIELDTURF USA, Hearing Date: September 30, 2021
19 INC., and DOES 1 through 30, inclusive, Time: 8:30 a.m.
Dept: A15
20 Defendants.
RESERVATION NO. 591886713038
21
22
Defendant FIELDTURF USA, INC. submits this Separate Statement in support of
23
its MOTION TO COMPEL ANSWERS TO DEPOSITION QUESTIONS pursuant to California
24
Rules of Court, Rule 3.1345.
25
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26
///
27
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28
1
______________________________________________________________________________________
DECLARATION OF MARY R. FERSCH IN SUPPORT OF MOTION TO COMPEL PLAINTIFFS' GUARDIAN
AD LITEM STANLEY JACOCKS' ANSWERS TO DEPOSITION QUESTIONS
Document Filed Date
August 24, 2021
Case Filing Date
October 08, 2020
Category
Motor Vehicle - Personal Injury/Property Damage/Wrongful Death (General Jurisdiction)
Status
Request for Dismissal - Before Trial not following ADR or more than 60 days since ADR 11/03/2022
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Electronically FILED by Superior Court of California, County of Los Angeles on 08/24/2021 04:31 PM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Briggs,Deputy Clerk DANIELS, FINE, ISRAEL, 1 SCHONBUCH & LEBOVITS, LLP 1801 CENTURY PARK EAST, NINTH FLOOR LOS ANGELES, CALIFORNIA 90067 2 TELEPHONE (310) 556-7900 FACSIMILE (310) 556-2807 3 Michael Schonbuch, State Bar No. 150884 Mary R. Fersch, State Bar No. 305855 4 Attorneys For Defendant 5 FIELDTURF USA, INC. 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF LOS ANGELES - NORTH DISTRICT 10 11 BRIANNA MAREESE JACOCKS, a minor by Case No. 20AVCV00726 12 and through her Guardian ad Litem STANLEY [Complaint Filed: October 8, 2020] JACOCKS, KATIE FRANCIS JACOCKS, a [Hon. Wendy Chang, Dept. A15] 13 minor by and through her Guardian ad Litem STANLEY JACOCKS, GENE DAVEYON SEPARATE STATEMENT IN SUPPORT 14 BERNIE JACOCKS, a minor by and through his OF DEFENDANT’S NOTICE OF MOTION Guardian ad Litem STANLEY JACOCKS, AND MOTION TO COMPEL ANSWERS 15 KRYSTOL RENEE MCDONALD, and KYIRA TO DEPOSITION QUESTIONS RENEE MCDONALD, 16 [Filed concurrently with Notice of Motion to Plaintiffs, Compel; Memorandum of Points and 17 Authorities; Declaration of Mary R. Fersch v. and [Proposed] Order] 18 ROBERT AARON WELLS, FIELDTURF USA, Hearing Date: September 30, 2021 19 INC., and DOES 1 through 30, inclusive, Time: 8:30 a.m. Dept: A15 20 Defendants. RESERVATION NO. 591886713038 21 22 Defendant FIELDTURF USA, INC. submits this Separate Statement in support of 23 its MOTION TO COMPEL ANSWERS TO DEPOSITION QUESTIONS pursuant to California 24 Rules of Court, Rule 3.1345. 25 /// 26 /// 27 /// 28 1 ______________________________________________________________________________________ DECLARATION OF MARY R. FERSCH IN SUPPORT OF MOTION TO COMPEL PLAINTIFFS' GUARDIAN AD LITEM STANLEY JACOCKS' ANSWERS TO DEPOSITION QUESTIONS