Preview
FILED/ENDORS
1 LEWIS BRISBOIS BISGAARD & SMITH LLP SEP 1 0 2020
SHANE SINGH, SB# 202733
2 E-Mail: Shane.Singh@lewisbrisbois.com
GEORGE J. THEOFANIS, SB# 324037 By:. p. Vue
3 E-Mail: George.Theofanis@lewisbrisbois.com Deputy Clerk
NOLAN W. KESSLER, SB# 327178
4 E-Mail: Nolan.Kessler@lewisbrisbois.com
2020 West El Camino Avenue, Suite 700
5 Sacramento, Califomia 95833
Telephone: 916.564.5400
6 Facsimile: 916.564.5444
7 Attomeys for Defendant, ASOMEO
ENVIRONMENTAL RESTORATION
8 INDUSTRY, LLC
9
10 SUPERIOR COURT OF THE STATE OF CALIFORNIA
11 COUNTY OF SACRAMENTO
12
13 JAY ROBINSON and HUGO PINEDA, CASE NO. 34-2019-00262942-CU-OE-GDS
individually and on behalf of all others
14 similarly situated, DECLARATION OF SHANE SINGH IN
SUPPORT OF OPPOSITION TO
15 Plaintiffs, PLAINTIFFS' MOTION TO COMPEL
FURTHER RESPONSES TO
16 vs. PLAINTIFFS' REQUEST FOR
ADMISSIONS, SET ONE; AND MOTION
17 ASOMEO ENVIRONMENTAL FOR SANCTIONS
RESTORATION INDUSTRY, LLC, a
18 Califomia Corporation and PHILLIPS & Date: September 23, 2020
JORDAN ENVIRONMENTAL SERVICES Time: 9:00 a.m.
19 LLC, a Delaware Corporation and DOES 1-10, Dept.: 54
20 Defendants. Action Filed: August 16, 2019
Trial Date: None Set
21
22 DECLARATION OF SHANE SINGH
23 I , Shane Singh, declare as follows:
24 1. I am an attomey duly admitted to practice in all of the courts of the State of
25 Califomia. and I am a partner with Lewis Brisbois Bisgaard & Smith LLP, attomeys of record for
26 Defendant Asomeo Environmental Restoration Industry, LLC ("Defendant"). The facts set forth
27 herein are of my own personal knowledge, and if swom I could and would competently testify
28 thereto.
LEWIS 4832-8026-9770.1 1 Case No. 34-2019-00262942-CU-OE-GDS
BRISBOIS
BISGAARD DECLARATION OF SHANE SINGH IN SUPPORT OF OPPOSITION TO PLAINTIFFS' MOTION TO COMPEL
&SM1HLi? FURTHER RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS, SET ONE
AnORNEYS AT LAW
1 2. Plaintiffs noticed the hearing on their Motion to Compel Further Responses to
2 Plaintiffs' Request for Admissions, Set One; and Motion for Sanctions (the "Motion") for
3 September 23, 2020. Consequently, Plaintiffs were required to serve their Motion no later than
4 Monday, August 31, 2020, which is sixteen court days prior to the hearing noticed for September
5 23, 2020.
6 3. On Tuesday, September 3, 2020 at 1:14 p.m., Plaintiffs served their Mofion via e-
7 mail to me and my associates, George J. Theofanis and Nolan W. Kessler. Plaintiffs noficed the
8 hearing for the Motion for September 23, 2020. A true and correct copy of the September 3, 2020
9 email from Patricia Savage's office containing the Motion is attached hereto as "Exhibit A."
10 4. A more complete opposition was not able to be filed because the defective notice of
11 motion did not give counsel adequate time to prepare a response.
12 1 declare under the laws of the State of Califomia that the foregoing is true and correct and
13 that this declaration was executed on September 10, 2020, at Sacramento, Califomia.
14
15
16
Shane Singh
17
18
19
20
21
22
23
24
25
26
27
28
LEWIS 4832-8026-9770.1 Case No. 34-2019-00262942-CU-OE-GDS
BRISBOIS
BISGAARD DECLARATION OF SHANE SINGH IN SUPPORT OF OPPOSITION TO PLAINTIFFS' MOTION TO COMPEL
&SM1HL1P FURTHER RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS, SET ONE
AHORNEYSATLAW
EXHIBIT A
Attachments:
Revised Notice - Ints.pdf ;Revised Notice - RF A.pdf ;Revised Notice - RPD.pdf;
Original mail: [EXTERNAL] Re_ Robinson, et al. v. AERl, et al. - Motion to Compel - Electronic Service.msg:
External Email
Attached please find revised notices for the motion to compel hearing. The date was changed to 9:00 a.m. September 23 in
department 54.
Due to a technical error regarding the types of exhibit tabs we used for the documents sent to the court, they were retumed. The
documents will be resent today and should be on file next week.
Thank you.
On Thu, Aug 13, 2020 at 4:09 PM Robert Towne wrote:
Attached please find electronic service for the documents to be filed with the Court today regarding Plaintilf s Motion to
Compelfiirtherresponsesfordiscovery in the above captioned matter.
Please confirm receipt.
Thank you,
B Separate Statement of Items in Dispute - RPD.si...
M Declaration in Support of IMotion and Exhibits.R...
Robbie Towne
CLS, Paralegal
Preferred pronouns: He/Him
Law OflBces of Patricia A. Savage
1550 Humboldt Rd. Suite 4
Chico, CA 95928
Phone:530-809-1851
Fax:530-592-3865
CONFIDENTIAL
This transmission may be: (1) subject to Attomey-Client Privilege, (2) an attomey work product, or (3) confidential. If you
received this in error, please notify the sender and delete the message. Unauthorized interception of this e-mail is a violation of
federal law.
This does not reflect an intentbn by the sender, the sender's client or principal to make any agreement by electronic means.
Nothing contained herein shall satisfy the requirements for a writing, contract or electronic signature under the Electronic
Signatures in Global and National Commerce Act, any version ofthe Uniform Electronic Transactions Act or any other
statute.
IRS Circular 230: You are advised that any tax advice herein was not intended to be used for avoiding penalties under the
U.S. Intemal Revenue Code
Robbie Towne
CLS, Paralegal
Preferred pronouns: He/Him
Law Offices of Patricia A. Savage
1550 Humboldt Rd. Suite 4
Chico, CA 95928
Phone:530-809-1851
Fax:530-592-3865
CONFIDENTIAL
This transmission may be: (1) subject to Attomey-Client Privilege, (2) an attomey work product, or (3) confidential. If you
received this in error, please notify the sender and delete the message. Unauthorized interception of this e-mail is a violation of
federal law.
This does not reflect an intention by the sender, the sender's client or principal to make any agreement by electronic means.
Nothing contained herein shall satisfy the requirements for a writing, contract or electronic signature under the Electronic
Signatures in Global and National Commerce Act, any version of the Uniform Electronic Transactions Act or any other statute.
IRS Circular 230: You are advised that any tax advice herein was not intended to be used for avoiding penalties under the U.S.
Intemal Revenue Code
PATRICIA A. SAVAGE (SBN 236235)
SAVAGE & LAMB, P.C.
1550 Humboldt Road, Suite 4
Chico, CA 95928
Telephone: (530) 809-1851
Facsimile: (530) 592-3865
Email: psavesq@gmail.com
5 Attorney for Plaintiffs,
JAY ROBINSON and
6 HUGO PINEDA, individually and on
behalf of all others similariy situated
7
8 SUPERIOR COURT OF CALIFORNIA
9 COUNTY OF SACRAMENTO
10
JAY ROBINSON and
HUGO PINEDA, individually and on behalf of CaseNo. 34-2019-00262942
11
all others similariy situated,
12 NOTICE OF MOTION AND MOTION TO
COMPEL FURTHER RESPONSES TO
13 PLAINTIFFS' SPECIAL
Plaintiffs,
14
INTERROGATORIES, SET ONE, FORM
INTERROGATORIES - EMPLOYMENT,
15 SET ONE; AND MOTION FOR
ASOMEO ENVIRONMENTAL SANCTIONS
16
RESTORATION INDUSTRY, LLC, a
17 California Corporation and PHILLIPS & Filed concurrently herewith: Separate Statement
JORDAN, INC., a North Carolina Corporation, of Items in Dispute; and Declaration of Patricia
18 and DOES 1-10, A. Savage
19 Hearing Date: 9/23/2020
20 Defendants. Time: 9:00 a.m.
Dept.: 54
21
22 ActionFiled: 08/16/2019
23
24
TO DEFENDANT AND THEIR ATTORNEY OF RECORD:
25
PLEASE TAKE NOTICE that on September 23, 2020, at 9:00 a.m. or as soon as the
26
matter may be heard in Department 54 of the Sacramento County Superior Court, located at 720
27
9"' Street, Sacramento, California 95814, Plaintiffs will move the Court for an Order granting its
28
Molion lo Compel Further Responses to Defendanl's Special Inlcrrogalorics, Sel One, Fonn Inlcrrogalorics -
Employinenl, Set One and Request for Sanclions
1 Motion to Compel Further Responses to Plaintiffs' Special Interrogatories, Set One, Plaintiffs'
2 Form Interrogatories - General, Set One, and Plaintiffs' Form Interrogatories - Employment, Set
3 One propounded to ASOMEO Environmental Restoration Industry, LLC and request for monetary
4 sanctions.
5 Plaintiff brings this motion pursuant to Code of Civil Procedure section 2030.300, on the
6 grounds that Defendant's responses to Plaintiffs propounded discovery are incomplete, evasive,
7 and Defendant's objections are made without merit.
This Motion will be based on Plaintiffs Notice of Motion and Motion, Plaintiffs
9 Memorandum of Points and Authorities in support of its Motion, Plaintiffs Separate Statement of
10 Items in Dispute, the Declaration of Patricia A. Savage, as well as the pleadings and records on
11 file in this action.
12 Pursuant to Local Rule 1.06 (A), the court will make a tentative ruling on the merits of this
13 matter by 2:00 p.m., the court day before the hearing. The complete text of the tentative rulings for
14 the department may be downloaded off the court's website. If the party does not have online
15 access, they may call the dedicated phone number for the department as referenced in the local
16 telephone directory between the hours of 2:00 p.m. and 4:00 p.m. on the court day before the
17 hearing and receive the tentative ruling. If you do not call the court and the opposing party by 4:00
18 p.m. the court day before the hearing, no hearing will be held.
19
20 Date: August [ 3 , 2020 RespeCffWIy Submitted,
21
22
23
Patricia A. Savage
24 Attorney for Plaintiffs
25
26
27
28
Molion lo Compel Further Responses to Defendant's Special Interrogatories, Sel One, Fonn Interrogatories
Employment, Sel One and Request for Sanclions
PATRICIA A. SAVAGE (SBN 236235)
SAVAGE & LAMB, P.C.
1550 Humboldt Road, Suite 4
Chico, CA 95928
Telephone: (530) 809-1851
Facsimile: (530) 592-3865
Email: psavesq@gmail.com
Attorney for Plaintiffs,
JAY ROBINSON and
HUGO PINEDA, individually and on
Behalf of all others similarly situated
SUPERIOR COURT OF CALIFORNIA
9 COUNTY OF SACRAMENTO
10
JAY ROBINSON and
HUGO PINEDA, individually and on behalf of Case No. 34-2019-00262942
11
all others similariy situated.
12 NOTICE OF MOTION AND MOTION TO
COMPEL FURTHER RESPONSES TO
13
Plaintiffs, PLAINTIFFS' REQUEST FOR
ADMISSIONS, SET ONE; AND MOTION
14
FOR SANCTIONS
15
ASOMEO ENVIRONMENTAL Filed concurrently herewith: Separate Statement
16
RESTORATION INDUSTRY, LLC, a of Items in Dispute; and Declaration of Patricia
California Corporation and PHILLIPS & A. Savage
17
JORDAN, INC., a North Carolina Corporation,
18 and DOES 1-10, Hearing Date: 9/23/2020
Time: 9:00 a.m.
19 Dept.: 54
20 Defendants.
21 ActionFiled: 08/16/2019
22
23 TO DEFENDANT AND THEIR ATTORNEY OF RECORD:
24 PLEASE TAKE NOTICE that on September 23, 2020, at 9:00 a.m., or as soon as the
25 matter may be heard in Department 54 of the Sacramento County Superior Court, located at 720
26 9*'' Street, Sacramento, California 95814, Plaintiffs will move the Court for an Order granting its
27 Motion to Compel Further Responses to Plaintiffs' Request for Admissions propounded to
28 ASOMEO Environmental Restoration Industry, LLC and request for monetary sanctions.
1
Molion to ComiJcl Further Responses lo Plaintiff's Request for Admissions and Molion for Sanclions
1 Plaintiff brings this motion pursuant to Code of Civil Procedure section 2033.290, on the
2 grounds that Defendant's responses to Plaintiffs propounded discovery are incomplete, evasive,
3 and Defendant's objections are made without merit.
4 This Motion will be based on Plaintiffs Notice of Motion and Motion, Plaintiffs
5 Memorandum of Points and Authorities in support of its Motion, Plaintiff s Separate Statement of
6 Items in Dispute, the Declaration of Patricia A. Savage, as well as the pleadings and records on
7 file in this action.
8 Pursuant to Local Rule 1.06 (A), the court will make a tentative ruling on the merits of this
9 matter by 2:00 p.m., the court day before the hearing. The complete text of the tentative rulings for
10 the department may be downloaded off the court's website. If the party does not have online
11 access, they may call the dedicated phone number for the department as referenced in the local
12 telephone directory between the hours of 2:00 p.m. and 4:00 p.m. on the court day before the
13 hearing and receive the tentative ruling. If you do not call the court and the opposing party by 4:00
14 p.m. the court day before the hearing, no hearing will be held.
15
16 Date: August 2020 Ily Submitted,
17
18
19
''atricHa-A'. Savage
20 Attorney for Plaintiff
Jay Robinson
21
22
23
24
25
26
27
28
Motion lo Compel Further Responses to Plaintiffs Request for Admissions and Molion for Sanctions
PATRICIA A. SAVAGE (SBN 236235)
SAVAGE & LAMB, P.C.
1550 Humboldt Road, Suite 4
Chico, CA 95928
Telephone: (530) 809-1851
Facsimile: (530) 592-3865
Email: psavesq@gmail.com
Attorney for Plaintiffs,
JAY ROBINSON and
HUGO PINEDA, individually and on
Behalf of all others similariy situated
SUPERIOR COURT OF CALIFORNIA
9 COUNTY OF SACRAMENTO
10
JAY ROBINSON and
Case No. 34-2019-00262942
11 HUGO PINEDA, individually and on behalf of
all others similariy situated.
12 NOTICE OF MOTION AND MOTION TO
COMPEL FURTHER RESPONSES TO
13
Plaintiffs, PLAINTIFFS' REQUEST FOR
PRODUCTION, SET ONE; AND MOTION
14
FOR SANCTIONS
v.
15
ASOMEO ENVIRONMENTAL Filed concurrently herewith: Separate Statement
16
RESTORATION INDUSTRY, LLC, a of Items in Dispute; and Declaration of Patricia
California Corporation and PHILLIPS & A. Savage
17
JORDAN, INC., a North Carolina Corporation,
18 and DOES 1-10, Hearing Date: 9/23/2020
Time: 9:00 a.m.
19 Dept.: 54
20
Defendants.
21 ActionFiled: 08/16/2019
22
23 TO DEFENDANT AND THEIR ATTORNEY OF RECORD:
24 PLEASE TAKE NOTICE that on September 23, 2020,- at 9:00 a.m., or as soon as the
25 matter may be heard in Department 54 of the Sacramento County Superior Court, located at 720
26 9"' Street, Sacramento, California 95814, Plaintiffs will move the Court for an Order granting its
27 Motion to Compel Further Responses to Plaintiffs' Request for Production, Set One propounded
28 to ASOMEO Environmental Restoration Industry, LLC and request for monetaiy sanctions.
1
Molion Io Compel Further Responses lo Plainliff's Request for Produclion and Molion for Sanclions
1 Plaintiff brings this motion pursuant to Code of Civil Procedure section 203 1.300, on the
2 grounds that Defendant's responses to Plaintiff s propounded discovery are incomplete, evasive,
3 and Defendant's objections are made without merit.
4 This Motion will be based on Plaintiffs Notice of Motion and Motion, Plaintiffs
5 Memorandum of Points and Authorities in support of its Motion, Plaintiffs Separate Statement of
6 Items in Dispute, the Declaration of Patricia A. Savage, as well as the pleadings and records on
7 file in this action.
8 Pursuant to Local Rule 1.06 (A), the court will make a tentative ruling on the merits of this
9 matter by 2:00 p.m., the court day before the hearing. The complete text of the tentative rulings for
10 the department may be downloaded off the court's website. If the party does not have online
11 access, they may call the dedicated phone number for the department as referenced in the local
12 telephone directory between the hours of 2:00 p.m. and 4:00 p.m. on the court day before the
13 hearing and receive the tentative ruling. If you do not call the court and the opposing party by 4:00
14 p.m. the court day before the hearing, no hearing will be held.
15
16
Date: August I3. , 2020 RespectMlr^ubmitted,
17
18
19
'atricia A. Savage
20 Attorney for Plaintiff
Jay Robinson
21
22
23
24
25
26
27
28
Molion to Compel Further Responses to Plaintiffs Request for Production and Molion for Sanctions
Preview
FILED/ENDORS 1 LEWIS BRISBOIS BISGAARD & SMITH LLP SEP 1 0 2020 SHANE SINGH, SB# 202733 2 E-Mail: Shane.Singh@lewisbrisbois.com GEORGE J. THEOFANIS, SB# 324037 By:. p. Vue 3 E-Mail: George.Theofanis@lewisbrisbois.com Deputy Clerk NOLAN W. KESSLER, SB# 327178 4 E-Mail: Nolan.Kessler@lewisbrisbois.com 2020 West El Camino Avenue, Suite 700 5 Sacramento, Califomia 95833 Telephone: 916.564.5400 6 Facsimile: 916.564.5444 7 Attomeys for Defendant, ASOMEO ENVIRONMENTAL RESTORATION 8 INDUSTRY, LLC 9 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 COUNTY OF SACRAMENTO 12 13 JAY ROBINSON and HUGO PINEDA, CASE NO. 34-2019-00262942-CU-OE-GDS individually and on behalf of all others 14 similarly situated, DECLARATION OF SHANE SINGH IN SUPPORT OF OPPOSITION TO 15 Plaintiffs, PLAINTIFFS' MOTION TO COMPEL FURTHER RESPONSES TO 16 vs. PLAINTIFFS' REQUEST FOR ADMISSIONS, SET ONE; AND MOTION 17 ASOMEO ENVIRONMENTAL FOR SANCTIONS RESTORATION INDUSTRY, LLC, a 18 Califomia Corporation and PHILLIPS & Date: September 23, 2020 JORDAN ENVIRONMENTAL SERVICES Time: 9:00 a.m. 19 LLC, a Delaware Corporation and DOES 1-10, Dept.: 54 20 Defendants. Action Filed: August 16, 2019 Trial Date: None Set 21 22 DECLARATION OF SHANE SINGH 23 I , Shane Singh, declare as follows: 24 1. I am an attomey duly admitted to practice in all of the courts of the State of 25 Califomia. and I am a partner with Lewis Brisbois Bisgaard & Smith LLP, attomeys of record for 26 Defendant Asomeo Environmental Restoration Industry, LLC ("Defendant"). The facts set forth 27 herein are of my own personal knowledge, and if swom I could and would competently testify 28 thereto. LEWIS 4832-8026-9770.1 1 Case No. 34-2019-00262942-CU-OE-GDS BRISBOIS BISGAARD DECLARATION OF SHANE SINGH IN SUPPORT OF OPPOSITION TO PLAINTIFFS' MOTION TO COMPEL &SM1HLi? FURTHER RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS, SET ONE AnORNEYS AT LAW 1 2. Plaintiffs noticed the hearing on their Motion to Compel Further Responses to 2 Plaintiffs' Request for Admissions, Set One; and Motion for Sanctions (the "Motion") for 3 September 23, 2020. Consequently, Plaintiffs were required to serve their Motion no later than 4 Monday, August 31, 2020, which is sixteen court days prior to the hearing noticed for September 5 23, 2020. 6 3. On Tuesday, September 3, 2020 at 1:14 p.m., Plaintiffs served their Mofion via e- 7 mail to me and my associates, George J. Theofanis and Nolan W. Kessler. Plaintiffs noficed the 8 hearing for the Motion for September 23, 2020. A true and correct copy of the September 3, 2020 9 email from Patricia Savage's office containing the Motion is attached hereto as "Exhibit A." 10 4. A more complete opposition was not able to be filed because the defective notice of 11 motion did not give counsel adequate time to prepare a response. 12 1 declare under the laws of the State of Califomia that the foregoing is true and correct and 13 that this declaration was executed on September 10, 2020, at Sacramento, Califomia. 14 15 16 Shane Singh 17 18 19 20 21 22 23 24 25 26 27 28 LEWIS 4832-8026-9770.1 Case No. 34-2019-00262942-CU-OE-GDS BRISBOIS BISGAARD DECLARATION OF SHANE SINGH IN SUPPORT OF OPPOSITION TO PLAINTIFFS' MOTION TO COMPEL &SM1HL1P FURTHER RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS, SET ONE AHORNEYSATLAW EXHIBIT A Attachments: Revised Notice - Ints.pdf ;Revised Notice - RF A.pdf ;Revised Notice - RPD.pdf; Original mail: [EXTERNAL] Re_ Robinson, et al. v. AERl, et al. - Motion to Compel - Electronic Service.msg: External Email Attached please find revised notices for the motion to compel hearing. The date was changed to 9:00 a.m. September 23 in department 54. Due to a technical error regarding the types of exhibit tabs we used for the documents sent to the court, they were retumed. The documents will be resent today and should be on file next week. Thank you. On Thu, Aug 13, 2020 at 4:09 PM Robert Towne wrote: Attached please find electronic service for the documents to be filed with the Court today regarding Plaintilf s Motion to Compelfiirtherresponsesfordiscovery in the above captioned matter. Please confirm receipt. Thank you, B Separate Statement of Items in Dispute - RPD.si... M Declaration in Support of IMotion and Exhibits.R... Robbie Towne CLS, Paralegal Preferred pronouns: He/Him Law OflBces of Patricia A. Savage 1550 Humboldt Rd. Suite 4 Chico, CA 95928 Phone:530-809-1851 Fax:530-592-3865 CONFIDENTIAL This transmission may be: (1) subject to Attomey-Client Privilege, (2) an attomey work product, or (3) confidential. If you received this in error, please notify the sender and delete the message. Unauthorized interception of this e-mail is a violation of federal law. This does not reflect an intentbn by the sender, the sender's client or principal to make any agreement by electronic means. Nothing contained herein shall satisfy the requirements for a writing, contract or electronic signature under the Electronic Signatures in Global and National Commerce Act, any version ofthe Uniform Electronic Transactions Act or any other statute. IRS Circular 230: You are advised that any tax advice herein was not intended to be used for avoiding penalties under the U.S. Intemal Revenue Code Robbie Towne CLS, Paralegal Preferred pronouns: He/Him Law Offices of Patricia A. Savage 1550 Humboldt Rd. Suite 4 Chico, CA 95928 Phone:530-809-1851 Fax:530-592-3865 CONFIDENTIAL This transmission may be: (1) subject to Attomey-Client Privilege, (2) an attomey work product, or (3) confidential. If you received this in error, please notify the sender and delete the message. Unauthorized interception of this e-mail is a violation of federal law. This does not reflect an intention by the sender, the sender's client or principal to make any agreement by electronic means. Nothing contained herein shall satisfy the requirements for a writing, contract or electronic signature under the Electronic Signatures in Global and National Commerce Act, any version of the Uniform Electronic Transactions Act or any other statute. IRS Circular 230: You are advised that any tax advice herein was not intended to be used for avoiding penalties under the U.S. Intemal Revenue Code PATRICIA A. SAVAGE (SBN 236235) SAVAGE & LAMB, P.C. 1550 Humboldt Road, Suite 4 Chico, CA 95928 Telephone: (530) 809-1851 Facsimile: (530) 592-3865 Email: psavesq@gmail.com 5 Attorney for Plaintiffs, JAY ROBINSON and 6 HUGO PINEDA, individually and on behalf of all others similariy situated 7 8 SUPERIOR COURT OF CALIFORNIA 9 COUNTY OF SACRAMENTO 10 JAY ROBINSON and HUGO PINEDA, individually and on behalf of CaseNo. 34-2019-00262942 11 all others similariy situated, 12 NOTICE OF MOTION AND MOTION TO COMPEL FURTHER RESPONSES TO 13 PLAINTIFFS' SPECIAL Plaintiffs, 14 INTERROGATORIES, SET ONE, FORM INTERROGATORIES - EMPLOYMENT, 15 SET ONE; AND MOTION FOR ASOMEO ENVIRONMENTAL SANCTIONS 16 RESTORATION INDUSTRY, LLC, a 17 California Corporation and PHILLIPS & Filed concurrently herewith: Separate Statement JORDAN, INC., a North Carolina Corporation, of Items in Dispute; and Declaration of Patricia 18 and DOES 1-10, A. Savage 19 Hearing Date: 9/23/2020 20 Defendants. Time: 9:00 a.m. Dept.: 54 21 22 ActionFiled: 08/16/2019 23 24 TO DEFENDANT AND THEIR ATTORNEY OF RECORD: 25 PLEASE TAKE NOTICE that on September 23, 2020, at 9:00 a.m. or as soon as the 26 matter may be heard in Department 54 of the Sacramento County Superior Court, located at 720 27 9"' Street, Sacramento, California 95814, Plaintiffs will move the Court for an Order granting its 28 Molion lo Compel Further Responses to Defendanl's Special Inlcrrogalorics, Sel One, Fonn Inlcrrogalorics - Employinenl, Set One and Request for Sanclions 1 Motion to Compel Further Responses to Plaintiffs' Special Interrogatories, Set One, Plaintiffs' 2 Form Interrogatories - General, Set One, and Plaintiffs' Form Interrogatories - Employment, Set 3 One propounded to ASOMEO Environmental Restoration Industry, LLC and request for monetary 4 sanctions. 5 Plaintiff brings this motion pursuant to Code of Civil Procedure section 2030.300, on the 6 grounds that Defendant's responses to Plaintiffs propounded discovery are incomplete, evasive, 7 and Defendant's objections are made without merit. This Motion will be based on Plaintiffs Notice of Motion and Motion, Plaintiffs 9 Memorandum of Points and Authorities in support of its Motion, Plaintiffs Separate Statement of 10 Items in Dispute, the Declaration of Patricia A. Savage, as well as the pleadings and records on 11 file in this action. 12 Pursuant to Local Rule 1.06 (A), the court will make a tentative ruling on the merits of this 13 matter by 2:00 p.m., the court day before the hearing. The complete text of the tentative rulings for 14 the department may be downloaded off the court's website. If the party does not have online 15 access, they may call the dedicated phone number for the department as referenced in the local 16 telephone directory between the hours of 2:00 p.m. and 4:00 p.m. on the court day before the 17 hearing and receive the tentative ruling. If you do not call the court and the opposing party by 4:00 18 p.m. the court day before the hearing, no hearing will be held. 19 20 Date: August [ 3 , 2020 RespeCffWIy Submitted, 21 22 23 Patricia A. Savage 24 Attorney for Plaintiffs 25 26 27 28 Molion lo Compel Further Responses to Defendant's Special Interrogatories, Sel One, Fonn Interrogatories Employment, Sel One and Request for Sanclions PATRICIA A. SAVAGE (SBN 236235) SAVAGE & LAMB, P.C. 1550 Humboldt Road, Suite 4 Chico, CA 95928 Telephone: (530) 809-1851 Facsimile: (530) 592-3865 Email: psavesq@gmail.com Attorney for Plaintiffs, JAY ROBINSON and HUGO PINEDA, individually and on Behalf of all others similarly situated SUPERIOR COURT OF CALIFORNIA 9 COUNTY OF SACRAMENTO 10 JAY ROBINSON and HUGO PINEDA, individually and on behalf of Case No. 34-2019-00262942 11 all others similariy situated. 12 NOTICE OF MOTION AND MOTION TO COMPEL FURTHER RESPONSES TO 13 Plaintiffs, PLAINTIFFS' REQUEST FOR ADMISSIONS, SET ONE; AND MOTION 14 FOR SANCTIONS 15 ASOMEO ENVIRONMENTAL Filed concurrently herewith: Separate Statement 16 RESTORATION INDUSTRY, LLC, a of Items in Dispute; and Declaration of Patricia California Corporation and PHILLIPS & A. Savage 17 JORDAN, INC., a North Carolina Corporation, 18 and DOES 1-10, Hearing Date: 9/23/2020 Time: 9:00 a.m. 19 Dept.: 54 20 Defendants. 21 ActionFiled: 08/16/2019 22 23 TO DEFENDANT AND THEIR ATTORNEY OF RECORD: 24 PLEASE TAKE NOTICE that on September 23, 2020, at 9:00 a.m., or as soon as the 25 matter may be heard in Department 54 of the Sacramento County Superior Court, located at 720 26 9*'' Street, Sacramento, California 95814, Plaintiffs will move the Court for an Order granting its 27 Motion to Compel Further Responses to Plaintiffs' Request for Admissions propounded to 28 ASOMEO Environmental Restoration Industry, LLC and request for monetary sanctions. 1 Molion to ComiJcl Further Responses lo Plaintiff's Request for Admissions and Molion for Sanclions 1 Plaintiff brings this motion pursuant to Code of Civil Procedure section 2033.290, on the 2 grounds that Defendant's responses to Plaintiffs propounded discovery are incomplete, evasive, 3 and Defendant's objections are made without merit. 4 This Motion will be based on Plaintiffs Notice of Motion and Motion, Plaintiffs 5 Memorandum of Points and Authorities in support of its Motion, Plaintiff s Separate Statement of 6 Items in Dispute, the Declaration of Patricia A. Savage, as well as the pleadings and records on 7 file in this action. 8 Pursuant to Local Rule 1.06 (A), the court will make a tentative ruling on the merits of this 9 matter by 2:00 p.m., the court day before the hearing. The complete text of the tentative rulings for 10 the department may be downloaded off the court's website. If the party does not have online 11 access, they may call the dedicated phone number for the department as referenced in the local 12 telephone directory between the hours of 2:00 p.m. and 4:00 p.m. on the court day before the 13 hearing and receive the tentative ruling. If you do not call the court and the opposing party by 4:00 14 p.m. the court day before the hearing, no hearing will be held. 15 16 Date: August 2020 Ily Submitted, 17 18 19 ''atricHa-A'. Savage 20 Attorney for Plaintiff Jay Robinson 21 22 23 24 25 26 27 28 Motion lo Compel Further Responses to Plaintiffs Request for Admissions and Molion for Sanctions PATRICIA A. SAVAGE (SBN 236235) SAVAGE & LAMB, P.C. 1550 Humboldt Road, Suite 4 Chico, CA 95928 Telephone: (530) 809-1851 Facsimile: (530) 592-3865 Email: psavesq@gmail.com Attorney for Plaintiffs, JAY ROBINSON and HUGO PINEDA, individually and on Behalf of all others similariy situated SUPERIOR COURT OF CALIFORNIA 9 COUNTY OF SACRAMENTO 10 JAY ROBINSON and Case No. 34-2019-00262942 11 HUGO PINEDA, individually and on behalf of all others similariy situated. 12 NOTICE OF MOTION AND MOTION TO COMPEL FURTHER RESPONSES TO 13 Plaintiffs, PLAINTIFFS' REQUEST FOR PRODUCTION, SET ONE; AND MOTION 14 FOR SANCTIONS v. 15 ASOMEO ENVIRONMENTAL Filed concurrently herewith: Separate Statement 16 RESTORATION INDUSTRY, LLC, a of Items in Dispute; and Declaration of Patricia California Corporation and PHILLIPS & A. Savage 17 JORDAN, INC., a North Carolina Corporation, 18 and DOES 1-10, Hearing Date: 9/23/2020 Time: 9:00 a.m. 19 Dept.: 54 20 Defendants. 21 ActionFiled: 08/16/2019 22 23 TO DEFENDANT AND THEIR ATTORNEY OF RECORD: 24 PLEASE TAKE NOTICE that on September 23, 2020,- at 9:00 a.m., or as soon as the 25 matter may be heard in Department 54 of the Sacramento County Superior Court, located at 720 26 9"' Street, Sacramento, California 95814, Plaintiffs will move the Court for an Order granting its 27 Motion to Compel Further Responses to Plaintiffs' Request for Production, Set One propounded 28 to ASOMEO Environmental Restoration Industry, LLC and request for monetaiy sanctions. 1 Molion Io Compel Further Responses lo Plainliff's Request for Produclion and Molion for Sanclions 1 Plaintiff brings this motion pursuant to Code of Civil Procedure section 203 1.300, on the 2 grounds that Defendant's responses to Plaintiff s propounded discovery are incomplete, evasive, 3 and Defendant's objections are made without merit. 4 This Motion will be based on Plaintiffs Notice of Motion and Motion, Plaintiffs 5 Memorandum of Points and Authorities in support of its Motion, Plaintiffs Separate Statement of 6 Items in Dispute, the Declaration of Patricia A. Savage, as well as the pleadings and records on 7 file in this action. 8 Pursuant to Local Rule 1.06 (A), the court will make a tentative ruling on the merits of this 9 matter by 2:00 p.m., the court day before the hearing. The complete text of the tentative rulings for 10 the department may be downloaded off the court's website. If the party does not have online 11 access, they may call the dedicated phone number for the department as referenced in the local 12 telephone directory between the hours of 2:00 p.m. and 4:00 p.m. on the court day before the 13 hearing and receive the tentative ruling. If you do not call the court and the opposing party by 4:00 14 p.m. the court day before the hearing, no hearing will be held. 15 16 Date: August I3. , 2020 RespectMlr^ubmitted, 17 18 19 'atricia A. Savage 20 Attorney for Plaintiff Jay Robinson 21 22 23 24 25 26 27 28 Molion to Compel Further Responses to Plaintiffs Request for Production and Molion for Sanctions