On June 27, 2019 a
Party Discovery
was filed
involving a dispute between
Binder Ed,
Summers Robert,
Cenveo Worldwide Limited A Delaware Corporation,
Cenveo Worldwilde Limited A Delaware Corporation,
and
Lithographix Inc.,
Minguez Ariel,
Summers Robert,
for Other Breach of Contract/Warranty (not fraud or negligence) (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 02/19/2020 04:41 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Bolden,Deputy Clerk
1 BOREN, OSHER & LUFTMAN LLP
Stephen Z. Boren (SBN 192024)
2 sboren@bollaw.com
Aaron M. Gladstein (SBN 266287)
3
agladstein@bollaw.com
4 222 North Pacific Coast Highway, Ste. 2222
El Segundo, CA 90245
5 Telephone: (310) 322-2021
Facsimile: (310) 322-2228
6
Attorneys for Defendant
7
ROBERT SUMMERS
8
SUPERIOR COURT OF THE STATE OF CALIFORNIA
9
FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT
10
CENVEO WORLDWIDE LIMITED, a Case No.: 19STCV22712
11 Delaware corporation,
Assigned to: Honorable Dennis J. Landin
12 Plaintiff, Department: 51
13 v. DEFENDANT ROBERT SUMMERS’
14 OPPOSITION TO PLAINTIFF’S MOTION
ROBERT SUMMERS, an individual, and DOES
TO COMPEL DOCUMENTS, FURTHER
1-10, inclusive,
15 RESPONSES, OR COMPLIANCE WITH
Defendant. PLAINTIFF’S FIRST SET OF REQUESTS
16 FOR PRODUCTION OF DOCUMENTS
AND REQUEST FOR MONETARY
17
SANCTIONS OF NO LESS THAN $2,500;
18 MEMORANDUM OF POINTS AND
AUTHORITIES; REQUEST FOR
19 SANCTIONS IN THE AMOUNT OF
$8,441.00
20
[Declaration of Aaron M. Gladstein and Response
21 to Plaintiff’s Separate Statement Of Issues filed
concurrently herewith]
22
23 Hearing:
Date: March 3, 2020
24 Time: 9:00 a.m.
Dept. 51
25
26 Reservation ID: 314116667717
27 Complaint Filed: June 27, 2019
28
DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION TO COMPEL DOCUMENTS, FURTHER RESPONSES, OR
COMPLIANCE WITH PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION
Document Filed Date
February 19, 2020
Case Filing Date
June 27, 2019
Category
Other Breach of Contract/Warranty (not fraud or negligence) (General Jurisdiction)
Status
Request for Dismissal - Before Trial not following ADR or more than 60 days since ADR 10/05/2020
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Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 02/19/2020 04:41 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Bolden,Deputy Clerk 1 BOREN, OSHER & LUFTMAN LLP Stephen Z. Boren (SBN 192024) 2 sboren@bollaw.com Aaron M. Gladstein (SBN 266287) 3 agladstein@bollaw.com 4 222 North Pacific Coast Highway, Ste. 2222 El Segundo, CA 90245 5 Telephone: (310) 322-2021 Facsimile: (310) 322-2228 6 Attorneys for Defendant 7 ROBERT SUMMERS 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT 10 CENVEO WORLDWIDE LIMITED, a Case No.: 19STCV22712 11 Delaware corporation, Assigned to: Honorable Dennis J. Landin 12 Plaintiff, Department: 51 13 v. DEFENDANT ROBERT SUMMERS’ 14 OPPOSITION TO PLAINTIFF’S MOTION ROBERT SUMMERS, an individual, and DOES TO COMPEL DOCUMENTS, FURTHER 1-10, inclusive, 15 RESPONSES, OR COMPLIANCE WITH Defendant. PLAINTIFF’S FIRST SET OF REQUESTS 16 FOR PRODUCTION OF DOCUMENTS AND REQUEST FOR MONETARY 17 SANCTIONS OF NO LESS THAN $2,500; 18 MEMORANDUM OF POINTS AND AUTHORITIES; REQUEST FOR 19 SANCTIONS IN THE AMOUNT OF $8,441.00 20 [Declaration of Aaron M. Gladstein and Response 21 to Plaintiff’s Separate Statement Of Issues filed concurrently herewith] 22 23 Hearing: Date: March 3, 2020 24 Time: 9:00 a.m. Dept. 51 25 26 Reservation ID: 314116667717 27 Complaint Filed: June 27, 2019 28 DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION TO COMPEL DOCUMENTS, FURTHER RESPONSES, OR COMPLIANCE WITH PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION