On October 30, 2017 a
Party Discovery
was filed
involving a dispute between
Palmgren Aj,
and
Sagoo Paul Dba Knollwood Auto Sales,
for civil
in the District Court of Los Angeles County.
Preview
A. ' ‘~
FLED
1 PAUL SAGOO Sugeriotr Cgulrt ofACalif'c;rnia
11920 Indian Hills rd. °“" V ° °s "99 S
2 Chatsworth, Ca 91311 MAR 26 mg
3 Tel: 818-232-1155 '
Defendant In Propia Persona Shem 3- Cr. Executive Officer/Clerk
By
4 Isabel Jaime Deputy
5
6
7 .
i SUPERIOR COURT, COUNTY OF LOS ANGELES
8
CENTRAL BRANCH - STANLEY MOSK COURT
‘ 9
10 A.J. PALMGREN, an Individual ) Case No: 17STLC03918
)
11 Plaintiff, ) DEFENDANT’S OPPOSITION TO MOTION TO
vs. ) COMPEL RESPONSES TOREQEUST FOR
12 ) PRODUCTION — SET TWO .
PAUL SAGOO, an Individual, )
13 and Does 1 to 20 Inclusive ) DATE: April 4, 2019
Defendant. ) TIME: 8:30 a.m.
’ 14 ) DEPT. 94
15
Defendant PAUL SAGOO, herein files his Opposition to Plaintiff's Motion to Compel
16 Responses to Request for Production of Documents - Set Two as follows:
17 Plaintiff previously propounded a full set of discovery to which I responded on or about
18 Aec 7% 2013)’
Now Plaintiff claims that he propounded a second set of Request for Production of
19 Documents - Set Two which were presumably mailed to me on September 13, 2018 from Texas -
20 as per the verified proof of service. This cannot be correct as the documents were not signed by
21 attorney Kevin Faulk until December 13, 2018. How can a document be mailed in September
22 when it was not even signed until a month later. This set of discovery is void.
This SET TWO consists of only one request for Production. Even though the defective proof
23 of service renders this Request for Production void, I have already responded to this SET TWO on
24 March 5, 2019. I have asked that the moving attorney take his motion off calendar as being
25 defective as to its proof of service, and moot as I have already provi : responses. He has refused
as he wants sanctions against me.
26
27 Dated: March 26, 2019 {fr
/1
28 /.6"
Paul '.-5. o — Defendant in Pro per
OPPOSITION TO MOTION TO COMPEL RESPONSES TO REQEUST FOR PRODUCTION — SET TWO
-1-
Document Filed Date
March 26, 2019
Case Filing Date
October 30, 2017
Status
Court Finding - After Court Trial
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Preview
A. ' ‘~ FLED 1 PAUL SAGOO Sugeriotr Cgulrt ofACalif'c;rnia 11920 Indian Hills rd. °“" V ° °s "99 S 2 Chatsworth, Ca 91311 MAR 26 mg 3 Tel: 818-232-1155 ' Defendant In Propia Persona Shem 3- Cr. Executive Officer/Clerk By 4 Isabel Jaime Deputy 5 6 7 . i SUPERIOR COURT, COUNTY OF LOS ANGELES 8 CENTRAL BRANCH - STANLEY MOSK COURT ‘ 9 10 A.J. PALMGREN, an Individual ) Case No: 17STLC03918 ) 11 Plaintiff, ) DEFENDANT’S OPPOSITION TO MOTION TO vs. ) COMPEL RESPONSES TOREQEUST FOR 12 ) PRODUCTION — SET TWO . PAUL SAGOO, an Individual, ) 13 and Does 1 to 20 Inclusive ) DATE: April 4, 2019 Defendant. ) TIME: 8:30 a.m. ’ 14 ) DEPT. 94 15 Defendant PAUL SAGOO, herein files his Opposition to Plaintiff's Motion to Compel 16 Responses to Request for Production of Documents - Set Two as follows: 17 Plaintiff previously propounded a full set of discovery to which I responded on or about 18 Aec 7% 2013)’ Now Plaintiff claims that he propounded a second set of Request for Production of 19 Documents - Set Two which were presumably mailed to me on September 13, 2018 from Texas - 20 as per the verified proof of service. This cannot be correct as the documents were not signed by 21 attorney Kevin Faulk until December 13, 2018. How can a document be mailed in September 22 when it was not even signed until a month later. This set of discovery is void. This SET TWO consists of only one request for Production. Even though the defective proof 23 of service renders this Request for Production void, I have already responded to this SET TWO on 24 March 5, 2019. I have asked that the moving attorney take his motion off calendar as being 25 defective as to its proof of service, and moot as I have already provi : responses. He has refused as he wants sanctions against me. 26 27 Dated: March 26, 2019 {fr /1 28 /.6" Paul '.-5. o — Defendant in Pro per OPPOSITION TO MOTION TO COMPEL RESPONSES TO REQEUST FOR PRODUCTION — SET TWO -1-