Party Discovery: DAISY VASQUEZ VS SANTA BARBARA FOODS, INC., A CALIFORNIA CORPORATION, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 01/26/2021 06:30 PM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Lara,Deputy Clerk




                       1     Omero Banuelos, SBN 228267
                       2     415 W. Foothill Blvd., Suite 202
                             Claremont CA 91711
                       3     Phone: 213-457-7171
                             Attorneys for Defendants Santa Barbara Foods, Inc. and Jose Medeiros
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                                                        SUPERIOR COURT OF THE STATE OF CALIFORNIA
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                                                                     FOR THE COUNTY OF LOS ANGELES
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                             DAISY VASQUEZ, an individual              )                                  Case No: 19STCV44009
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                                                Plaintiff,             )                                  PLAINTIFFS’ OPPOSITION TO
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                                                                       )                                  DEFENDANTS’ MOTIONS TO COMPEL
                             v.                                        )                                  RESPONSE TO FORM
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                                                                       )                                  INTERROGATORIES, (EMPLOYMENT)
                     12                                                )                                  SET ONE; MEMORANDUM OF POINTS
                             SANTA BARBARA, INC., a California                                            AND AUTHORITIES AND
                     13      Corporation, JOE MEDEIROS, an individual, )                                  DECLARATION OF OMERO
                             and DOES 1 through 100, inclusive,        )                                  BANUELOS
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                                                 Defendants.           )
                     15                                                )                                  Date: February 8, 2021
                                                                       )                                  Time: 8:30
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                                                                       )                                  Dept: 31
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                             TO EACH PARTY AND TO THE COUNSEL OF RECORD FOR EACH PARTY:
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                     23                  Defendants, SANTA BARBARA, INC. and JOSE C. MEDEIROS (“Defendants”)
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                             hereby opposes the motion to compel responses to Form Interrogatories. This Opposition is
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                             based upon the fact that Defendants have timely served Responses to the Form Interrogatories
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                             and/or are entitled to relief for mistake, inadvertence or excusable neglect. Further, Plaintiff has
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                             not met and conferred in good faith.
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                                  OPPOSITION TO MOTION TO COMPEL RESPONSES TO FORM INTERROGATORIES (EMP)
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