Preview
V ORIGINAL V
Angelica Acosta Samaniego, SBN 235423
ea.» 3.3.x cow; 3.4 Ch.
3750 University Avenue, Suite 610
Riverside, California 92501
Telephone: (951) 274—7777
Facsimile: (95 1) 274-7770
Wm” COUNTY OF SAN
SAN BERNAaam m;
BER’
g
'
and Cross—Defendant 4’ ”‘4- “y(f"
Attorneys for Plaintiff, L ..
1
"
JETCRUZER INTERNATIONAL, LLC. AND
FARRAR AEROSPACE, LLC
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
0:113
11
JETCRUZER INTERNATIONAL, LLC. Case No.2 ClVDSl9301 32
12 Assigned for all purposes t0:
Plaintiffs, Hon. Thomas S. Garza
Dept. $27
13
A8
v.
14
SANDY ACOSTA, an individual and PLAINTIFF’S SEPARATE STATEMENT RE:
15 DBA CHINO AIRCRAFT INTERIORS & FORM INTERROGATORIES IN xva
PAINT and CHINO AIRCRAFT OPPOSITION TO DEFENDANT’S MOTION
16 INTERIORS / CA1, and DOES 1 through TO COMPEL FURTHER RESPONSES
50, inclusive,
17
Complaint Filed: October 2019
8,
18 AND RELATED CROSS-ACTIONS Cross-Complaint Filed: December 2019 13,
Trial: February 7, 2022
19
20 COMES NOW Plaintiff, JETCRUZER INTERNATIONAL, LLC (“JetCruzer”), and
21 hereby provides its Separate Statement in Opposition to Defendant’s Motion to Compel Further
22 Responses to Form Interrogatories, Set One:
ADDRESS, telephone number, and
23 FORMINTERROGA TORY 1.1: State the name,
24 relationship t0 you ofeach PERSON who prepared 0r assisted in the preparation 0fthe responses
25 t0 th ese interrogatories.
26 ///
27 ///
28 ///
1
PLAINTIFF’S SEPARATE STATEMENT RE: FORM INTERROGATORIES, SET ONE
RESPONSE T0 FORM INTERROGATORYIJ:
Jonathan Garza and Victor Tao, JetCruzer (addresses omitted as these individuals may
be contacted exclusively through defense counsel); Angelica A. Samaniego, Varner & Brandt
LLP, 3750 University Avenue, Suite 610, Riverside, California, 92501, (951) 274-7777.
WHY FURTHER RESPONSE SHOULD NOT BE COMPELLED:
“the
Pursuant t0 Code of Civil Procedure § 2017.010 parties are entitled t0 discovery 0f
.” (Emphasis
identity and location of persons having knowledge of any discoverable matter . . .
added.) The statute does not provide an absolute right t0 discovery of a witness’ specific address
disclosed. In other words, the means 0f locating and
as long as “the location” of the witness is
10 contacting the witness. In this particular instance, Plaintiff identified two witnesses who
Plaintiff, and
11 participated in the preparation of the interrogatory responses, as well as counsel for
12 identified them both as party-affiliated witnesses who may be contacted through counsel. One 0f
a member 0f the Plaintiff limited liability company, and the other, Jonathan
13 them, Victor Tao, is
14 Garza, is a key supervisory employee of Plaintiff. This is a proper designation and disclosure of
15 witnesses pursuant t0 CCP § 2017.0 0 as
l it provides Defendant and her counsel with the means t0
16 locate and contact said witnesses (i.e., through counsel).
17 CCP § 1987(b) provides that parties may use the less formal Notice to Appear at Trial
18 (rather than the more formal process of issuing and service 0f subpoenas) for requiring the presence
19 ofparty-affiliated witnesses to appear and testify at trial. Likewise, CCP § 2025.230 is 0fthe same
20 effect for requiring a party—affiliated witness t0 testify at a deposition. Both 0f these processes
provide for service of the Notice upon counsel for the pertinent party, rather than requiring
arduous
21
22 personal service of a subpoena upon the particular witness.
identifying these witnesses as party-affiliated witnesses, Plaintiff has availed these
less
23 By
24 stringent processes t0 Defendant. Since Plaintiff is required by the cited statutes to produce these
25 witnesses, there is n0 necessity for Defendant to have their individual residence addresses;
26 Defendant has all the means she needs t0 require these witnesses t0 appear and testify. Furthermore,
27 since they are party-affiliated witnesses who are authorized representatives of Plaintiff, defense
28 counsel is prohibited from making direct contact with them, 0r contacting them through a private
2
PLAINTIFF’S SEPARATE STATEMENT RE: FORM INTERROGATORIES, SET ONE
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V ORIGINAL V Angelica Acosta Samaniego, SBN 235423 ea.» 3.3.x cow; 3.4 Ch. 3750 University Avenue, Suite 610 Riverside, California 92501 Telephone: (951) 274—7777 Facsimile: (95 1) 274-7770 Wm” COUNTY OF SAN SAN BERNAaam m; BER’ g ' and Cross—Defendant 4’ ”‘4- “y(f" Attorneys for Plaintiff, L .. 1 " JETCRUZER INTERNATIONAL, LLC. AND FARRAR AEROSPACE, LLC SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO 0:113 11 JETCRUZER INTERNATIONAL, LLC. Case No.2 ClVDSl9301 32 12 Assigned for all purposes t0: Plaintiffs, Hon. Thomas S. Garza Dept. $27 13 A8 v. 14 SANDY ACOSTA, an individual and PLAINTIFF’S SEPARATE STATEMENT RE: 15 DBA CHINO AIRCRAFT INTERIORS & FORM INTERROGATORIES IN xva PAINT and CHINO AIRCRAFT OPPOSITION TO DEFENDANT’S MOTION 16 INTERIORS / CA1, and DOES 1 through TO COMPEL FURTHER RESPONSES 50, inclusive, 17 Complaint Filed: October 2019 8, 18 AND RELATED CROSS-ACTIONS Cross-Complaint Filed: December 2019 13, Trial: February 7, 2022 19 20 COMES NOW Plaintiff, JETCRUZER INTERNATIONAL, LLC (“JetCruzer”), and 21 hereby provides its Separate Statement in Opposition to Defendant’s Motion to Compel Further 22 Responses to Form Interrogatories, Set One: ADDRESS, telephone number, and 23 FORMINTERROGA TORY 1.1: State the name, 24 relationship t0 you ofeach PERSON who prepared 0r assisted in the preparation 0fthe responses 25 t0 th ese interrogatories. 26 /// 27 /// 28 /// 1 PLAINTIFF’S SEPARATE STATEMENT RE: FORM INTERROGATORIES, SET ONE RESPONSE T0 FORM INTERROGATORYIJ: Jonathan Garza and Victor Tao, JetCruzer (addresses omitted as these individuals may be contacted exclusively through defense counsel); Angelica A. Samaniego, Varner & Brandt LLP, 3750 University Avenue, Suite 610, Riverside, California, 92501, (951) 274-7777. WHY FURTHER RESPONSE SHOULD NOT BE COMPELLED: “the Pursuant t0 Code of Civil Procedure § 2017.010 parties are entitled t0 discovery 0f .” (Emphasis identity and location of persons having knowledge of any discoverable matter . . . added.) The statute does not provide an absolute right t0 discovery of a witness’ specific address disclosed. In other words, the means 0f locating and as long as “the location” of the witness is 10 contacting the witness. In this particular instance, Plaintiff identified two witnesses who Plaintiff, and 11 participated in the preparation of the interrogatory responses, as well as counsel for 12 identified them both as party-affiliated witnesses who may be contacted through counsel. One 0f a member 0f the Plaintiff limited liability company, and the other, Jonathan 13 them, Victor Tao, is 14 Garza, is a key supervisory employee of Plaintiff. This is a proper designation and disclosure of 15 witnesses pursuant t0 CCP § 2017.0 0 as l it provides Defendant and her counsel with the means t0 16 locate and contact said witnesses (i.e., through counsel). 17 CCP § 1987(b) provides that parties may use the less formal Notice to Appear at Trial 18 (rather than the more formal process of issuing and service 0f subpoenas) for requiring the presence 19 ofparty-affiliated witnesses to appear and testify at trial. Likewise, CCP § 2025.230 is 0fthe same 20 effect for requiring a party—affiliated witness t0 testify at a deposition. Both 0f these processes provide for service of the Notice upon counsel for the pertinent party, rather than requiring arduous 21 22 personal service of a subpoena upon the particular witness. identifying these witnesses as party-affiliated witnesses, Plaintiff has availed these less 23 By 24 stringent processes t0 Defendant. Since Plaintiff is required by the cited statutes to produce these 25 witnesses, there is n0 necessity for Defendant to have their individual residence addresses; 26 Defendant has all the means she needs t0 require these witnesses t0 appear and testify. Furthermore, 27 since they are party-affiliated witnesses who are authorized representatives of Plaintiff, defense 28 counsel is prohibited from making direct contact with them, 0r contacting them through a private 2 PLAINTIFF’S SEPARATE STATEMENT RE: FORM INTERROGATORIES, SET ONE