Party Discovery: BROOKE KIM VS ANTHONY KYLE, ET AL.

• 
• 

						
                                
Preview
                                Electronically FILED by Superior Court of California, County of Los Angeles on 09/11/2020 01:06 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Lopez,Deputy Clerk




                1 EMILY COREA, ESQ. (State Bar No.: 273758)
                  RAFFALOW, BRETOI, LUTZ & STELE
                2 Attorneys at Law
                  2280 Wardlow Circle
                3 Suite 200
                  Corona, CA 92878
                4 (877) 529-9329
                  E-Service Address: coronalegal@mercuryinsurance.com
                5
                  Attorney for: Defendant, ANTHONY KYLE
                6 Our File No.: 20-111234-127

                7

                8                                        SUPERIOR COURT OF THE STATE OF CALIFORNIA

                9                                                     FOR THE COUNTY OF LOS ANGELES

              10

              11 BROOKE KIM,                                                                                       CASE NO: 20STCV03943

              12                                                  Plaintiff,                                       JUDGE: Hon. Daniel M. Crowley
                                                                                                                   DEPT: 28
              13                                vs.
                                                                                                                   NOTICE OF MOTION FOR ORDER
              14 ANTHONY KYLE; CYNTHIA GUINEA; DOES                                                                COMPELLING PLAINTIFF, BROOKE
                 1 TO 10,                                                                                          KIM, TO (1) ANSWER SPECIAL
              15                                                                                                   INTERROGATORIES, SET NO. ONE;
                                    Defendants.                                                                    AND (2) PAY COSTS AND
              16                                                                                                   SANCTIONS IN THE AMOUNT OF
                                                                                                                   $1,090.00; MEMORANDUM OF
              17                                                                                                   POINTS AND AUTHORITIES IN
                                                                                                                   SUPPORT THEREOF;
              18                                                                                                   DECLARATION OF EMILY COREA,
                                                                                                                   ESQ.; [PROPOSED] ORDER
              19
                                                                                                                   DATE:                  February 16, 2021
              20                                                                                                   TIME:                  8:30 a.m.
                                                                                                                   DEPT:                  28
              21
                                                                                                                   RESERVATION ID#: 912947974203
              22

              23                 TO:         ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:
              24                 PLEASE TAKE NOTICE that on February 16, 2021 at 8:30 a.m., or as soon thereafter as the
              25 matter may be heard in Department 28 of the above-entitled court, located at 312 North Spring Street,

              26 Los Angeles, CA, 90012, Defendant, ANTHONY KYLE, will, and hereby does, move the court for an
              27 order compelling, Plaintiff, BROOKE KIM, to respond within fifteen (15) days, without objections, to

              28 the Special Interrogatories, Set No. One, propounded to Plaintiff, BROOKE KIM, and also for an

                                                                                   1
                                                               MOTION TO COMPEL SPECIAL INTERROGATORIES