Party Discovery: ZALA DIST ET AL-V-A DAWAR ET AL Print

• 
• 
• 
• 

						
                                
Preview
                                OMAR A. SIDDIQUI, ESQ. (SBN 213581)
     NICOLE A. SOMA, ESQ. (SBN 322184)
     SIDDIQUI LAW, A Prof. Corp.                                                                L E     D
     Park Tower, Suite 700
                                                                                       F    I

                                                                          SUPERIOR COURT 0F CAUFO‘SgIA
     695 Town Center Drive                                                  COUNTY 0F SAN BERNARQCT
                                                                             SAN BERNARDINO DtSTR
     Costa Mesa, California 92626
     Telephone: (714) 384-6650                                                         FEB 15 2022
     Facsimile: (714) 384-6651
     osiddigungsidlaWpccom
     nsomangidlawpccom                                                    BY                       DEPUTY
                                                                               PAULETTE RODRIGUEZ.
     Attorneys for Plaintiffs,
     ZALA DISTRIBUTION, INC. dba
     THE PIPE KING and ZEID ALABED
                            SUPERIOR COURT OF THE STATE OF CALIFORNIA
                                     FOR THE COUNTY OF SAN BERNARDINO
10

11   ZALA DISTRIBUTION, INC., a California              Case No. CIVD82014299
     corporation doing business as THE PIPE
12   KING; and ZEID ALABED, an            individual,   [UNLIMITED CIVIL]

13
                       Plaintiffs,                      Assigned for all Purposes to:
                                                        Judge: Hon. John Tomberlin
14
     VS.                                                Dept: 33
15
     ARJIT DAWAR, an individual;                        PLAINTIFF ZALA DISTRIBUTION, INC.’S
16   SAI NANAK INVESTMENTS CORR,                  a     NOTICE OF MOTION AND      N T0
     California corporation;                            COMPEL FURTHER RESPONSES TO (1)
17
     SAI NANAK        RESTAURANT C0,,         a
                                                        FORM INTERROGATORIES — GENERAL
                                                        (           E);   AN      )        ___..AL_,1


18
     California corporation; and                        INTERROGATORIES (SET ONE) FROM
     DOES    1   through 50, inclusive,                 DEFENDANT ARJIT DAWAR;
19                                                      MEMORANDUM OF POINTS AND
                      Defendants.                       AUTHORITIES IN SUPPORT THEREOF
20
                                                        [Filed concurrently with Separate Statement,
                                                        Declaration osz'cole A. Soma, and [Proposed]
21
                                                        Order]
22
                                                        HEARING:
23                                                      Date:      magma”             April 20, 2022
                                                        Time: 8:30 a.m.
24                                                      Dept: s-33

25                                                      Complaint filed: June 26, 2020
                                                                           2022
                                                        Trial Date: July 25,
26

27

28

                                                            _1'_


            NOTICE OF MOTION AND MOTION TO COMPEL FURTHER RESPONSES TO (1) FORM
           INTERROGATORIES; AND (2) SPECIAL INTERROGATORIES FROM DEFENDANT DAWAR
          TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
                   PLEASE TAKE NOTICE THAT                  on SgfiEégkggéi             at   8:30 a.m., 0r as soon thereafter as

          may be    heard in Department S-33 of the above-entitled Court, located               at   247 West Third   Street,   San

          Bemardino, California 92415, Plaintiff         ZALA DISTRIBUTION,                 INC. (“ZALA”) will and hereby

          does   move   for an   Order compelling Defendant ARJIT              DAWAR         (“DAWAR”)         to provide further


          responses t0    Form    Interrogatories   -   General (Set One) and Special Interrogatories (Set One),

          propounded by     Plaintiff   ZALA   on September 20, 2021. Defendant “served” responses                  to the   above
 \OOOVO


          stated discovery requests      0n or about November           15,   2021 and November          16,   2021, which were

          unverified and did not contain proofs 0f service. Despite several extensions                          to serve   adequate

10        supplemental responses and extensive meet and confer                   efforts,     Defendant’s responses remain

11        deficient and not in conformity with California law.

12                 This Motion    is   made under   California   Code 0f       Civil   Procedure section 2030.300 0n the

13        grounds that Defendant       DAWAR failed t0 provide full and complete responses to Plaintiff ZALA’s
14        Form    Interrogatories and Special Interrogatories (Set       One) pursuant       t0 the California    Discovery Act.

15        Defendants have made numerous good-faith attempts to further meet and confer with Defendant

16        DAWAR pursuant t0 Code 0f Civil Procedure sections 2016.040 and 2030.300. However, the patties
17        were unable   to resolve their issues informally, necessitating the instant Motion.


18


19        ///



20

21        ///



22

23        ///



24

25        ///



26

27        ///



28


                                                                 -11-

                 NOTICE 0F MOTION AND MOTION TO COMPEL FURTHER RESPONSES TO (1) FORM
                INTERROGATORIES; AND (2) SPECIAL INTERROGATORIES FROM DEFENDANT DAWAR