Motion,Ex Parte: CLAUDIO R. AGUIRRE VS JOSE A. OSORIO, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 02/22/2021 03:51 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Reyna,Deputy Clerk




                1     Robin E. Paley, Esq. SBN: 118138
                      LAW OFFICES OF ROBIN E. PALEY
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                      16430 Ventura Boulevard, Suite 301
                3     Encino, California 91436
                      Tel: (818) 386 - 2995
                4     Fax: (818) 386 - 0684
                5     Attorney for Plaintiff: Claudio R. Aguirre
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                                                 SUPERIOR COURT OF THE STATE OF CALIFORNIA
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                                             COUNTY OF LOS ANGELES, NORTH VALLEY DISTRICT
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                                                                    )                              Case No.: 20CHCV00185
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                      CLAUDIO R. AGUIRRE,                           )
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                                                                    )                              NOTICE OF MOTION AND MOTION
                                     Plaintiff,                     )                              FOR ORDER THAT FACTS ARE
              11             vs.                                    )                              DEEMED ADMITTED AND FOR
                                                                    )                              MONETARY SANCTIONS OF $900.00
              12      JOSE A. OSORIO, an individual, MARIA          )                              AGAINST JOSE A. OSORIO AND THEIR
                      ALMA BUENROSTRO OSORIO, an                    )                              ATTORNEY; DECLARATION OF ROBIN
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                      individual; and DOES 1 through 10, inclusive, )                              E. PALEY, ESQ. IN SUPPORT THEREOF
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                                                                    )
                                      Defendants.                   )                              Date: March 23, 2021
              15                                                    )                              Time: 8:30 AM
                                                                    )                              Dept: F49
              16                                                    )                              Reservation ID: 449497337413521794520870
                                                                    )
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                                                                    )
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                                                                    )
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                                 TO JOSE A. OSORIO AND TO THEIR COUNSEL OF RECORD:
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                                 PLEASE TAKE NOTICE and notice is herein given that on March 23, 2021 at 8:30 AM
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                      in Department F49 of the above entitled court located at 9425 Penfield Ave, Chatsworth, CA
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                      91311, Plaintiff will, and hereby does, move this Court for an order that the truth of each matter
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                      specified in the Requests for Admissions served on JOSE A. OSORIO by E-mail on November
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                      25, 2020, be deemed admitted and conclusively established for all purposes in this action. (A
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                      true and correct copy of the Request for Admissions is attached hereto as Exhibit “1”).
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                             NOTICE OF MOTION AND MOTION FOR ORDER THAT FACTS ARE DEEMED ADMITTED