Party Discovery: HELEN VIRGINIA MARTIN VS HAMPTON CONDOMINIUM OWNERS ASSOCIATION, INC, , ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 06/30/2021 01:44 PM Sherri R. Carter, Executive Officer/Clerk of Court, by L. Coreas,Deputy Clerk




                          1 LEWIS BRISBOIS BISGAARD & SMITH LLP
                            STEPHEN K. HIURA, SB# 149968
                          2   E-Mail: Stephen.Hiura@lewisbrisbois.com
                            633 West 5th Street, Suite 4000
                          3 Los Angeles, California 90071
                            Telephone: 213.250.1800
                          4 Facsimile: 213.250.7900

                          5 Attorneys for Defendants HAMPTON
                            CONDOMINIUM OWNERS ASSOCIATION,
                          6 INC. and HPK PROPERTY MANAGEMENT,
                            INC.
                          7

                          8
                                                              SUPERIOR COURT OF THE STATE OF CALIFORNIA
                          9
                                                      COUNTY OF LOS ANGELES, SPRING STREET COURTHOUSE
                        10
                               HELEN VIRGINIA MARTIN, an individual,                                         CASE NO. 19STCV42080
                        11               Plaintiff,
                                                                                                             [Assigned for All Purposes to:
                        12                 vs.                                                               Hon. Kristin S. Escalante, Dept. 29]

                        13 TRUE COMMUNITY ASSOCIATION                                                        DEFENDANT HAMPTON
                           MANAGEMENT, INC., a Corporation;                                                  CONDOMINIUM OWNERS
                        14 HAMPTON CONDOMINIUM OWNERS                                                        ASSOCIATION, INC’S OPPOSITION TO
                           ASSOCIATION, INC., a Corporation; and                                             PLAINTIFF’S MOTION FOR AN ORDER
                        15 DOES 1 through 50, Inclusive,                                                     COMPELLING DEFENDANT’S
                                        Defendants.                                                          ANSWERS TO REQUEST FOR
                        16                                                                                   PRODUCTION OF DOCUMENT (SET
                                                                                                             ONE) AND REQUEST FOR SANCTIONS
                        17
                                                                                                             DATE: July 14, 2021
                        18                                                                                   TIME: 8:30 a.m.
                                                                                                             DEPT: 29
                        19
                                                                                                             Action Filed:              November 20, 2019
                        20                                                                                   Trial Date:                June 23, 2022

                        21

                        22                 TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD:
                        23                 PLEASE TAKE NOTICE that Defendant HAMPTON CONDOMINIUM OWNERS
                        24 ASSOCIATION (“Hampton” and “Defendant”) hereby opposes Plaintiff Helen Virginia Martin’s

                        25 Motion to Compel Responses to Requests for Production of Documents, Set One, including a

                        26 request for monetary sanctions (“motion”). Hampton further requests that the court impose

                        27 monetary sanctions against Plaintiff and her counsel for bringing this unmeritorious motion in the

                        28 amount of $1,785. This opposition is based upon the memorandum of points and authorities, the
     LEWIS                     4850-7413-2454.1
     BRISBOIS                   DEFENDANT HAMPTON CONDOMINIUM OWNERS ASSOCIATION, INC’S OPPOSITION TO PLAINTIFF’S
     BISGAARD
     & SMITH LLP                MOTION FOR AN ORDER COMPELLING DEFENDANT’S ANSWERS TO REQUEST FOR PRODUCTION OF
     ATTORNEYS AT LAW                             DOCUMENT (SET ONE) AND REQUEST FOR SANCTIONS