On June 26, 2018 a
Motion,Ex Parte
was filed
involving a dispute between
Las Vegas Land & Development Co. Inc. A Nevada Corporation,
Las Vegas Land & Development Inc A Nevada Corporation,
Ontario Shopping Center Llc A California Llc,
and
Ep2 Ontario Llc A Limited Liability Company,
Peninsula Retail Partners Llc A Limited Liability Company,
Penninsula Retail Partners Iii, Llc A Limited Liabilty Company,
Prp Commercial Real Estate Services Inc A California Corporation,
Prp-Cre Ontario Llca Limited Liability Company,
Prp Development Company Llc A Limited Liability Company,
Prp Investors Iii, Llc A Limited Liability Company,
Pr Property Services Llc A Limited Liability Company,
Sbs Lien Services, An Unknown Business Formation,
Sbs Trust Deed Network,
The Marketplace At Ontario Center,
The Ontario Center Owners Association, A Non-Profit Corporation,
Valle, Brett Del,
Willet, Mitch,
for Unlimited Civil Complaint - Real Property
in the District Court of San Bernardino County.
Preview
v ORrGINAL
Benson K. Lau, State Bar No.: 287429
Bensongcl/SatnickLau.com
Adam M. Satnick, State Bar No.: 302326
Adamgci‘SamiCkLauxom
SATNICK. “5U LLP
D
sUPERngR COURT 0F CALIFORNM
.
11755 sthlre Blvd, Sultc 1250 CQUN Iv OF SAN BERNARDINO
"
53518;??? m mm
NA pm 1N (3,5; :1!-
Los Angeles, CA 90025
Facsimile: (310)436—4969
Attorneys for Plaintiffs/Cross—Defendants Ontario
Shopping Center, LLC 8c Las Vegas Land & MEDSSA Penez. DEPUTY
Development Company, Inc.
FAX
BY SUPERIOR COURT OF THE STATE OF CALIFORNIA
10
FOR THE COUNTY OF SAN BERNARDINO
11
12
ONTARIO SHOPPING CENTER, LLC, a Case No.2 CIVD51815756
1250 13 California limited liability company, and LAS
VEGAS LAND 8c DEVELOPMENT CO. INC, DECLARATION OF ADAM SATNICK IN
LLP
Suite
90025 356-8472
14 a Nevada corporation, SUPPORT IN SUPPORT OF MOTION TO
CA
COMPEL FURTHER RESPONSES
LAU
B1vd.,
(310)
15 Plaintiffs,
Angeles,
vs. Hearing: May 1, 2023
16
SATNICK
Wilshire
Judge: Hon. Corey Lee (Dept. 815)
Los
Telephone:
17
THE MARKETPLACE AT ONTARIO Action Filed: June 26, 201 8
CENTER aka THE ONTARIO CENTER XCmplt Filed: December 14, 2021
11755
18 OWNERS ASSOCIATION, a non-profit Trial Date: August 7, 2023
corporation, ct al.,
19
Defendants.
20
PRP COMMERCIAL REAL ESTATE
21 SERVICES, INC, a California corporation
22
Cross—Complainant,
vs.
23
24 ONTARIO SHOPPING CENTER, LLC, a
California limited liability company, and LAS
25 VEGAS LAND 8c DEVELOPMENT CO. INC,
a Nevada corporation,
26
Cross-Defendants.
27
28
1
DECLARATION OF ADAM SATNICK
\v \a
I, Adam M. Satnick, Esq., declare as follows:
1. I am an attorney duly licensed to practice law before all courts of the State of
California. My law firm, SATNICK LAU LLP, is counsel for Plaintiffs Las Vegas Land & Development
Company, Inc., and Ontario Shopping Center, LLC (“Plaintiffs”), in this action. This declaration is
submitted in support of Plaintiff/Cross—Defendant Ontario
Shopping Center, LLC’s (“fl”) Notice
of Motion and Motion to Compel Further Responses to its First Set of Special Interrogatories to
Dcfcndant/Cross-Complainant PRP Commercial Real Estate Services, Inc. (“£112”). The following
facts are Within my personal knowledge and, if called as a Witness herein, I can and will competently
testify thereto.
10 2. On December 16, 2021, OSC electronically served its Special Interrogatories, Set One,
11 on PRP. Based on that date of electronic service, answers were due no later than January 19, 2022.
12 Attached as Exhibit “A” hereto is a true and correct copy of OSC’s Special Interrogatories, Set One,
1250 13 t0 PRP.
LLP
Suite 90025 356-8472
14 3. OSC granted PRP seven extensions of time to answer the interrogatories. The final
CA
LAU
Blvd.,
15 deadline to respond was agreed to bejune 30, 2022. The
(310) extensions amounted to 162 additional
Angeles,
16 days to respond or about five-and-a-half times longer than the standard deadline. After
SATNICK
Wilshire
not
Telephone:
Los 17 receiving responses by the deadline, on August 15, 2022, OSC filed a motion to compel. The hearing
11755
18 0n that motion was set for November 8, 2022. Attached as Exhibit “B” hereto is a true and correct
19 copy of communications with PRP’s counsel evidencing the discovery extensions.
20 4. On October 13, 2022, PRP served tardy responses Without objections. Attached as
21 Exhibit “C” hereto is a true and correct copy of PRP’s tardy responses.
22 5. At the hearing on November 2022, the Court found the motion was
8, moot because
23 PRP served responses; however, the Court also granted sanctions. From November 11 through
December 15, 2022, the parties attempted to meet and confer t0 avoid a motion to compel further
25 responses. Ultimately, the parties agreed to set an informal discovery conference (“M”). The IDC
26 was set for April 7, 2023, but vacated when this matter was reassigned t0 Department $15. Attached
27 as Exhibit “D” are true and correct copies of OSC’s and PRP’s counsels’ correspondence with
28 Department $25 evidencing the reservation of an IDC as well as the parties’ meet and confer
2
DECLARATION OF ADAM SATNICK
Preview
v ORrGINAL Benson K. Lau, State Bar No.: 287429 Bensongcl/SatnickLau.com Adam M. Satnick, State Bar No.: 302326 Adamgci‘SamiCkLauxom SATNICK. “5U LLP D sUPERngR COURT 0F CALIFORNM . 11755 sthlre Blvd, Sultc 1250 CQUN Iv OF SAN BERNARDINO " 53518;??? m mm NA pm 1N (3,5; :1!- Los Angeles, CA 90025 Facsimile: (310)436—4969 Attorneys for Plaintiffs/Cross—Defendants Ontario Shopping Center, LLC 8c Las Vegas Land & MEDSSA Penez. DEPUTY Development Company, Inc. FAX BY SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 FOR THE COUNTY OF SAN BERNARDINO 11 12 ONTARIO SHOPPING CENTER, LLC, a Case No.2 CIVD51815756 1250 13 California limited liability company, and LAS VEGAS LAND 8c DEVELOPMENT CO. INC, DECLARATION OF ADAM SATNICK IN LLP Suite 90025 356-8472 14 a Nevada corporation, SUPPORT IN SUPPORT OF MOTION TO CA COMPEL FURTHER RESPONSES LAU B1vd., (310) 15 Plaintiffs, Angeles, vs. Hearing: May 1, 2023 16 SATNICK Wilshire Judge: Hon. Corey Lee (Dept. 815) Los Telephone: 17 THE MARKETPLACE AT ONTARIO Action Filed: June 26, 201 8 CENTER aka THE ONTARIO CENTER XCmplt Filed: December 14, 2021 11755 18 OWNERS ASSOCIATION, a non-profit Trial Date: August 7, 2023 corporation, ct al., 19 Defendants. 20 PRP COMMERCIAL REAL ESTATE 21 SERVICES, INC, a California corporation 22 Cross—Complainant, vs. 23 24 ONTARIO SHOPPING CENTER, LLC, a California limited liability company, and LAS 25 VEGAS LAND 8c DEVELOPMENT CO. INC, a Nevada corporation, 26 Cross-Defendants. 27 28 1 DECLARATION OF ADAM SATNICK \v \a I, Adam M. Satnick, Esq., declare as follows: 1. I am an attorney duly licensed to practice law before all courts of the State of California. My law firm, SATNICK LAU LLP, is counsel for Plaintiffs Las Vegas Land & Development Company, Inc., and Ontario Shopping Center, LLC (“Plaintiffs”), in this action. This declaration is submitted in support of Plaintiff/Cross—Defendant Ontario Shopping Center, LLC’s (“fl”) Notice of Motion and Motion to Compel Further Responses to its First Set of Special Interrogatories to Dcfcndant/Cross-Complainant PRP Commercial Real Estate Services, Inc. (“£112”). The following facts are Within my personal knowledge and, if called as a Witness herein, I can and will competently testify thereto. 10 2. On December 16, 2021, OSC electronically served its Special Interrogatories, Set One, 11 on PRP. Based on that date of electronic service, answers were due no later than January 19, 2022. 12 Attached as Exhibit “A” hereto is a true and correct copy of OSC’s Special Interrogatories, Set One, 1250 13 t0 PRP. LLP Suite 90025 356-8472 14 3. OSC granted PRP seven extensions of time to answer the interrogatories. The final CA LAU Blvd., 15 deadline to respond was agreed to bejune 30, 2022. The (310) extensions amounted to 162 additional Angeles, 16 days to respond or about five-and-a-half times longer than the standard deadline. After SATNICK Wilshire not Telephone: Los 17 receiving responses by the deadline, on August 15, 2022, OSC filed a motion to compel. The hearing 11755 18 0n that motion was set for November 8, 2022. Attached as Exhibit “B” hereto is a true and correct 19 copy of communications with PRP’s counsel evidencing the discovery extensions. 20 4. On October 13, 2022, PRP served tardy responses Without objections. Attached as 21 Exhibit “C” hereto is a true and correct copy of PRP’s tardy responses. 22 5. At the hearing on November 2022, the Court found the motion was 8, moot because 23 PRP served responses; however, the Court also granted sanctions. From November 11 through December 15, 2022, the parties attempted to meet and confer t0 avoid a motion to compel further 25 responses. Ultimately, the parties agreed to set an informal discovery conference (“M”). The IDC 26 was set for April 7, 2023, but vacated when this matter was reassigned t0 Department $15. Attached 27 as Exhibit “D” are true and correct copies of OSC’s and PRP’s counsels’ correspondence with 28 Department $25 evidencing the reservation of an IDC as well as the parties’ meet and confer 2 DECLARATION OF ADAM SATNICK