On July 25, 2019 a
Party Discovery
was filed
involving a dispute between
Catalan Morales Josefina,
Pineda Rojas Froylan Aka Froylan Pineda,
and
Nissan North America Inc. A California Corporation,
for civil
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 12/10/2020 10:52 AM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Soto,Deputy Clerk
1 KNIGHT LAW GROUP LLP
Steve Mikhov (SBN 224676)
2
stevem@kngihtlaw.com
3 Amy Morse (SBN 290502)
amym@knightlaw.com
4 10250 Constellation Blvd. Suite 2500
Los Angeles, CA 90067
5
Telephone: (310) 552-2250
6 Fax: (310) 552-7973
7
8 Attorneys for Plaintiffs,
FROYLAN PINEDA ROJAS
9 aka FROYLAN PINEDA
and JOSEFINA CATALAN MORALES
10
11 SUPERIOR COURT OF CALIFORNIA
12 COUNTY OF LOS ANGELES
13 FROYLAN PINEDA ROJAS Case No.: 19STCV26034
aka FROYLAN PINEDA Unlimited Jurisdiction
14 and JOSEFINA CATALAN MORALES,
15 Plaintiffs, PLAINTIFFS’ MEMORANDUM IN
SUPPORT OF MOTION TO COMPEL
16 FURTHER RESPONSES TO REQUESTS
vs. FOR PRODUCTION FROM DEFENDANT
17 NISSAN NORTH AMERICA, AND
NISSAN NORTH AMERICA, INC., a REQUEST FOR SANCTIONS
18 California Corporation, and DOES 1
19 through 10, inclusive, [Submitted concurrently with Notice of Motion
and Motion to Compel Further Responses,
20 Statement of Items in Dispute, Declaration of
Defendants. Amy Morse in Support of Motion, and
21 [Proposed] Order.]
22 Hearing Date: April 12, 2021
23 Hearing Time: 8:30 a.m.
Department: 40
24 Reservation ID: 139750783685
25
Complaint Filed: July 25, 2019
26
27
28
PLAINTIFFS’ MEMORANDUM IN SUPPORT OF MOTION TO COMPEL FURTHER DISCOVERY
RESPONSES FROM DEFENDANT
Document Filed Date
December 10, 2020
Case Filing Date
July 25, 2019
Status
Request for Dismissal - Before Trial not following ADR or more than 60 days since ADR 01/07/2022
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Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 12/10/2020 10:52 AM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Soto,Deputy Clerk 1 KNIGHT LAW GROUP LLP Steve Mikhov (SBN 224676) 2 stevem@kngihtlaw.com 3 Amy Morse (SBN 290502) amym@knightlaw.com 4 10250 Constellation Blvd. Suite 2500 Los Angeles, CA 90067 5 Telephone: (310) 552-2250 6 Fax: (310) 552-7973 7 8 Attorneys for Plaintiffs, FROYLAN PINEDA ROJAS 9 aka FROYLAN PINEDA and JOSEFINA CATALAN MORALES 10 11 SUPERIOR COURT OF CALIFORNIA 12 COUNTY OF LOS ANGELES 13 FROYLAN PINEDA ROJAS Case No.: 19STCV26034 aka FROYLAN PINEDA Unlimited Jurisdiction 14 and JOSEFINA CATALAN MORALES, 15 Plaintiffs, PLAINTIFFS’ MEMORANDUM IN SUPPORT OF MOTION TO COMPEL 16 FURTHER RESPONSES TO REQUESTS vs. FOR PRODUCTION FROM DEFENDANT 17 NISSAN NORTH AMERICA, AND NISSAN NORTH AMERICA, INC., a REQUEST FOR SANCTIONS 18 California Corporation, and DOES 1 19 through 10, inclusive, [Submitted concurrently with Notice of Motion and Motion to Compel Further Responses, 20 Statement of Items in Dispute, Declaration of Defendants. Amy Morse in Support of Motion, and 21 [Proposed] Order.] 22 Hearing Date: April 12, 2021 23 Hearing Time: 8:30 a.m. Department: 40 24 Reservation ID: 139750783685 25 Complaint Filed: July 25, 2019 26 27 28 PLAINTIFFS’ MEMORANDUM IN SUPPORT OF MOTION TO COMPEL FURTHER DISCOVERY RESPONSES FROM DEFENDANT