On July 15, 2019 a
Motion-Secondary
was filed
involving a dispute between
Schneider Michele Marie,
and
Fierro Irene Gutierrez,
Fierro Rudy,
for Intentional Bodily Injury/Property Damage/Wrongful Death (e.g., assault, battery, vandalism, etc.) (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 03/01/2021 12:11 PM Sherri R. Carter, Executive Officer/Clerk of Court, by L. Coreas,Deputy Clerk
1 Wilfredo Trivino Perez (SBN 219345)
TRIVINO PEREZ & ASSOCIATES
2 10940 Wilshire Blvd., 16th Fl.
Los Angeles, CA 90024
3 Telephone: 310-443-4251
Facsimile: 310-443-4252
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Attorneys for Defendant, RUDY FIERRO
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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COUNTY OF LOS ANGELES– SPRING STREET COURTHOUSE
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MICHELLE MARIE SCHNEIDER, Case No. 19STCV24550
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12 Plaintiff,
DEFENDANTS OPPOSITION TO
v. PLAINTIFF MICHELLE MARIE
13 SCHNEIDER’S MOTION COMPELLING
DEFENDANT RUDY FIERRO TO APPEAR
14 RUDY FIERRO, ET AL, FOR DEPOSITION; AND FOR MONETARY
SANCTIONS; DECLARATION OF
15 WILFREDO TRIVINO-PEREZ (IN SUPPORT
Defendants. THEREOF)
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18 OPPOSITION
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20 I. INTRODUCTION
21 The Court should deny Michelle Marie Schneider’s motion to compel deposition and request for
22 monetary sanctions for the following reasons:
23 Pursuant to rule 3-700(D), and complying with applicable laws and rules, mandatory withdrawal
24 from further representation existed, which prevented Defendant Rudy Fierro’s counsel from further
25 representation, which includes attendance and defense in depositions. Plaintiff counsel was notified of
26 this on November 24, 2020. Yet, he failed to call off the deposition, and proceeded with it, in order to
27 create grounds for the instant motion.
28 ///
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DEFENDANT RUDY FIERRO’S OPPOSITION TO PLAINTIFF’S MOTION TO COMPEL AND DISCOVERY SANCTIONS
Document Filed Date
March 01, 2021
Case Filing Date
July 15, 2019
Category
Intentional Bodily Injury/Property Damage/Wrongful Death (e.g., assault, battery, vandalism, etc.) (General Jurisdiction)
Status
Default Judgment By Court - Before Trial 01/05/2022
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