On May 27, 2020 a
Party Discovery
was filed
involving a dispute between
Romero, Dennis L,
and
1 Venture Realty, Inc. A California Corporation,
Buchanan, Laurie L,
Coldwell Banker Kivett-Teeters Associates,
Diamond Real Estate Group, Inc,
Gallucci, Katie Estrella,
Kivett Realtors, Inc.,
Menifee Valley Escrow, Inc.,
Orchard Holdings Group Inc. A Nevada Corporation,
Reynolds, Buddy G,
Rios, Antonio L,
Romero, Roman Aldian,
Teeters, Garey Donald,
Turner, Robin Elaine,
for Unlimited Civil Complaint - Real Property
in the District Court of San Bernardino County.
Preview
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L t ‘
MANSOUR LAW GROUP, APLC SUPERIOR COURT OF CALIFORNI/I
COUNTY OF SAN BERNARDINC
John Mansour (SBN 204835)
F. RAN RERNARDINO UES‘TRW“
Tyler Vance (SBN: 3 1 88 1 0)
8280 Utica Avenue, Suite 150 DEC 0? 207.0
Rancho Cucamonga, California 91730
Phone: (909) 941-1611
Fax: (909) 941 -1 811 M3R'A hfi ‘N’IQTU' n DEPUTW
\OOOQONUI-PWNH
iohn@mansourlaw2roup.com
Attorney for Diamond Real Estate Group, Inc., Antonio Rios, and
Robin Elaine Turner, Defendants
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO
DENNIS L. ROMERO, Case No.: CIVD82008532
Plaintiff,
vs. NOTICE OF MOTION AND MOTION TO
COMPEL RESPONSES TO REQUEST
ROMAN ALDIAN ROMERO; ROBIN FOR PRODUCTION OF DOCUMENTS —
ELAINE TURNER; KATIE ESTRELLA SET ONE; MEMORANDUM OF POINTS
GALLUCCI; ANTONIO L. RIOS; AND AUTHORITIES; DECLARATION
DIAMOND REAL ESTATE GROUP OF TYLER M. VANCE; [PROPOSED]
NNNNNNNNqu—tr—t—Ap—Ar—Ar—Ir—Ar—tu—A
INC.; BUDDY G. REYNOLDS; GAREY SANCTIONS
DONALD TEEERS; COLDWELL
BANKER KIVETT-TEETERS REQUEST FOR DISCOVERY
OOQONUl-RLDNHOKOOONQUI-hWN—‘O
ASSOCIATES; KIVETT REALTORS SANCTIONS
INC;LAURIE L. BUCHANAN;
MENIFEE VALLEY ESCROW, INC; Date: February 16, 2021
AND ANY AND ALL PERSON(S) Time: 09:00 a.m.
UNKNOWN CLAIMING: (A) ANY Judge: Hon. Tom Garza
LEGAL OR EQUITABLE RIGHT(S), Dept: $27
TITLE, ESTATE, LIEN(S), OR
INTEREST(S) IN THE PROPERTY
DESCRIBED IN THIS COMPLAINT Complaint Filed: May 27, 2020
ADVERSE TO THE PLAINTIFF’S Trial Date: TBD
TITLE OR (B) ANY CLOUD ON
PLAINITFF’S TITLE TO THE
PROPERT; and DOES 1 TO 100,
inclusive.
Defendants.
1
NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO REQUEST FOR PRODUCTION
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
NOTICE IS HEREBY GIVEN that on February 16, 2021 at 09:00 a.m. in Department $27
of the above-entitled court, located at 247 West Third Street San Bemardino, CA 92415-0210,
Defendants, DIAMOND REAL ESTATE GROUP, INC., ANTONIO RIOS, and ROBIN ELAINE
TURNER will move and hereby does move this Court for AN ORDER compelling Plaintiff
\OOOQONUlhbJNH
DENNIS L. ROMERO (“Plaintiff”) to provide responses to Request For Production of Documents
— Set One propounded by Diamond Real Estate Group, Inc. pursuant to the Civil Discovery Act of
1986, Code ofCivil Procedure § 2030, et seq. Without objection.
The grounds for this Motion to Compel Responses are that all Plaintiff has not served any
responses as of filing this motion.
NOTICE IS FURTHER GIVEN that DIAMOND REAL ESTATE GROUP, INC.,
ANTONIO RIOS, and ROBIN ELAINE TURNER further move this Court for AN ORDER that
DENNIS L. ROMERO pay monetary SANCTIONS to DRE Defendants in the amount of $815.00,
which includes the filing fee, for failing to respond to the discovery properly.
This Motion is based upon this Notice, the attached Memorandum of Points and Authorities,
Statement of Disputed Responses and Declaration of Tyler M. Vance, all other papers and pleadings
on file in this case, and other such matters as may be raised at the hearing on the Motion.
NNNNNNNNNHHHHHHHHr—Ar—a
mflom-hWNHoomflthWNF—‘O
Dated: December 7, 2020 MANSOUR LAW GROUP, APLC
Tyl . ance
ey for Diamond Real Estate Group, Inc.,
Antonio Rios, and Robin Elaine Turner
Defendants
2
NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO REQUEST FOR PRODUCTION
Document Filed Date
December 07, 2020
Case Filing Date
May 27, 2020
Category
Unlimited Civil Complaint - Real Property
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,.~ u L t ‘ MANSOUR LAW GROUP, APLC SUPERIOR COURT OF CALIFORNI/I COUNTY OF SAN BERNARDINC John Mansour (SBN 204835) F. RAN RERNARDINO UES‘TRW“ Tyler Vance (SBN: 3 1 88 1 0) 8280 Utica Avenue, Suite 150 DEC 0? 207.0 Rancho Cucamonga, California 91730 Phone: (909) 941-1611 Fax: (909) 941 -1 811 M3R'A hfi ‘N’IQTU' n DEPUTW \OOOQONUI-PWNH iohn@mansourlaw2roup.com Attorney for Diamond Real Estate Group, Inc., Antonio Rios, and Robin Elaine Turner, Defendants SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO DENNIS L. ROMERO, Case No.: CIVD82008532 Plaintiff, vs. NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO REQUEST ROMAN ALDIAN ROMERO; ROBIN FOR PRODUCTION OF DOCUMENTS — ELAINE TURNER; KATIE ESTRELLA SET ONE; MEMORANDUM OF POINTS GALLUCCI; ANTONIO L. RIOS; AND AUTHORITIES; DECLARATION DIAMOND REAL ESTATE GROUP OF TYLER M. VANCE; [PROPOSED] NNNNNNNNqu—tr—t—Ap—Ar—Ar—Ir—Ar—tu—A INC.; BUDDY G. REYNOLDS; GAREY SANCTIONS DONALD TEEERS; COLDWELL BANKER KIVETT-TEETERS REQUEST FOR DISCOVERY OOQONUl-RLDNHOKOOONQUI-hWN—‘O ASSOCIATES; KIVETT REALTORS SANCTIONS INC;LAURIE L. BUCHANAN; MENIFEE VALLEY ESCROW, INC; Date: February 16, 2021 AND ANY AND ALL PERSON(S) Time: 09:00 a.m. UNKNOWN CLAIMING: (A) ANY Judge: Hon. Tom Garza LEGAL OR EQUITABLE RIGHT(S), Dept: $27 TITLE, ESTATE, LIEN(S), OR INTEREST(S) IN THE PROPERTY DESCRIBED IN THIS COMPLAINT Complaint Filed: May 27, 2020 ADVERSE TO THE PLAINTIFF’S Trial Date: TBD TITLE OR (B) ANY CLOUD ON PLAINITFF’S TITLE TO THE PROPERT; and DOES 1 TO 100, inclusive. Defendants. 1 NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO REQUEST FOR PRODUCTION TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: NOTICE IS HEREBY GIVEN that on February 16, 2021 at 09:00 a.m. in Department $27 of the above-entitled court, located at 247 West Third Street San Bemardino, CA 92415-0210, Defendants, DIAMOND REAL ESTATE GROUP, INC., ANTONIO RIOS, and ROBIN ELAINE TURNER will move and hereby does move this Court for AN ORDER compelling Plaintiff \OOOQONUlhbJNH DENNIS L. ROMERO (“Plaintiff”) to provide responses to Request For Production of Documents — Set One propounded by Diamond Real Estate Group, Inc. pursuant to the Civil Discovery Act of 1986, Code ofCivil Procedure § 2030, et seq. Without objection. The grounds for this Motion to Compel Responses are that all Plaintiff has not served any responses as of filing this motion. NOTICE IS FURTHER GIVEN that DIAMOND REAL ESTATE GROUP, INC., ANTONIO RIOS, and ROBIN ELAINE TURNER further move this Court for AN ORDER that DENNIS L. ROMERO pay monetary SANCTIONS to DRE Defendants in the amount of $815.00, which includes the filing fee, for failing to respond to the discovery properly. This Motion is based upon this Notice, the attached Memorandum of Points and Authorities, Statement of Disputed Responses and Declaration of Tyler M. Vance, all other papers and pleadings on file in this case, and other such matters as may be raised at the hearing on the Motion. NNNNNNNNNHHHHHHHHr—Ar—a mflom-hWNHoomflthWNF—‘O Dated: December 7, 2020 MANSOUR LAW GROUP, APLC Tyl . ance ey for Diamond Real Estate Group, Inc., Antonio Rios, and Robin Elaine Turner Defendants 2 NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO REQUEST FOR PRODUCTION