On October 08, 2019 a
Motion-Secondary
was filed
involving a dispute between
Acosta, Sandy,
Jetcruzer International, Llc.,
and
Acosta, Sandy,
Does 3 Through 50,
Guzman, Marvin J.,
Zepeda, Ulises A.,
for Fraud
in the District Court of San Bernardino County.
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ORIGINAL“
An elica Acosta Samanie o SBN 235423 ) sun- F. "
VAgRNER & BRANDT Eng c'b'iJR’OR cgu%r& U
-"~
3750 University Avenue, Suite 61 0
Riverside, California 92501
Telephone: (951) 274—7777
Facsimile: (95 1) 274—7770
JUN 9‘
8 om
‘
\OOOVQUl-bww—
Attorneys for Plaintiff and Cross—
JETCRUZER INTERNATIONAL, LLC. AND
FARRAR AEROSPACE, LLC
e end§1t, CESAR .
m
SUPERIOR COURT OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
JETCRUZER INTERNATIONAL, LLC; CASE NO, CIVDSl930132
Assigned for all purposes to the Honorable
Plaintiff,
Thomas S. Garza, Department S27
610
V. OBJECTION TO THE SUPPLEMENTAL
DECLARATION OF R. CHRISTOPHER GE‘IH
LLP
Suite 92501
SANDY ACOSTA, an individual and DBA HARSHMAN FILED IN SUPPORT OF
CHINO AIRCRAFT INTERIORS & PAINT DEFENDANT’S MOTION TO COMPEL
Avenue,
andCHINO AIRCRAFT INTERIORS/CAI, FURTHER RESPONSES
Brandt
California
274-7777 andDOES through 50, inclusive,
1
A8
VVVVVVVVVVVVVVVVVV
Date: June 9, 2021
&
(951) Time: 9:00 a.m.
University Defendant
Varner
Riverside,
Department: S27
XV:|
3750
AND RELATED CROSS-ACTIONS Complaint Filed: October 8, 201 9
NNNNNNNNNp—a—A—d—ap—twr—y—a—ap—
Cross—Complaint Filed: December 13, 2019
Trial: February 7, 2022
OONONKflgk’JNflOKOOONONM-PWNHO
TO DEFENDANT AND HER ATTORNEYS OF RECORD:
Plaintiff JETCRUZER INTERNATIONAL, LLC (hereinafter referred t0 as “JetCruzer”
or “Plaintiff’) and Cross—Defendant FARRAR AEROSPACE, LLC (hereinafter referred t0 as
“Farrar Aerospace”) hereby object t0 the Supplemental Declaration 0f R. Christopher Harshman
filed in support of Defendant’s Motion to Compel Further Responses (hereinafter referred t0 as
the “Supplemental Declaration") as follows:
///
///
1
OBJECTION TO THE SUPPLEMENTAL DECLARATION OF R. CHRISTOPHER HARSHMAN FILED
IN SUPPORT OF DEFENDANT’S MOTION TO COMPEL FURTHER RESPONSES
OBJECTIONS
I. Plaintiff objects to the Supplemental Declaration on the grounds that it was filed 0n May
25, 2021, after Defendant SANDY ACOSTA (hereinafter referred to as “‘Defendant”) had
already filed her Motion t0 Compel Further Responses 0n April 5, 2021 (hereinafter referred t0
as “Motion to Compel”). It appears to Plaintiff that Defendant is seeking t0 improperly
\OOONONU‘I-BLNNfl
introduce new evidence t0 be considered by this Court, even afier already filing her Motion t0
Compel.
2. Additionally, Plaintiff also objects t0 this Supplemental Declaration 0n the grounds that
Defendant identifies an individual, private party’s name into public record while both Plaintiff
and Defendant are in the middle of working 0n a Protective Order t0 protect precisely this kind
0f information from open public disclosure. Defendant was fully aware of the
610
Protective Order,
however, still filed the Supplemental Declaration identifying a private party’s name even though
Suite 92501
LLP
both parties were working in good faith to stipulate to said Protective Order. It borders on
Brandt Avenue,
California
274-7777
misconduct for Defendant t0 knowingly reveal any portion of this material in a public document
85
during the time that her counsel is “supposedly” reviewing the stipulation
(951) in preparation of
University
Vamer
Riverside, signing it. Defense counsel was even given sage advice t0 “hold off” 0n making
any such public
disclosure to any of the information until the matter could be further investigated
3750 and jointly
NNNNNNNNN’fit—‘t—‘t—‘H—flfi—t—
discussed. As is the pattern in this matter, however, Defendant chose to disregard this
advice in
an attempt to gain an unfair advantage.
OOQOM-waflowcoflakhwa—‘O
3. Plaintiff objects t0 this Supplemental Declaration on the grounds that the investor named
in Defendant’s Motion was never a “Lost Investor” as described
by Plaintiff in its Complaint.
More specifically, Plaintiff never alleged to have lost the individual named in Defendant’s
Motion, so Plaintiff did not need to reveal the private party’s identification t0 Defendant
for this
very reason. However, Defendant went ahead and released the private party’s identification
without Plaintiff’s consent. Moreover, in meeting and conferring over the motion, Defense
counsel has taken great pains t0 point out that it is imperative to the defense t0 inquire about all
potential fl investors because Plaintiff has alleged causes of action for lost economic
opportunity. Since lost investors (used in a very broad sense) is the focus of Defendant’s
2
OBJECTION TO THE SUPPLEMENTAL DECLARATION OF R. CHRISTOPHER HARSHMAN FILED
IN SUPPORT OF DEFENDANT’S MOTION TO COMPEL FURTHER RESPONSES
Document Filed Date
June 08, 2021
Case Filing Date
October 08, 2019
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ORIGINAL“ An elica Acosta Samanie o SBN 235423 ) sun- F. " VAgRNER & BRANDT Eng c'b'iJR’OR cgu%r& U -"~ 3750 University Avenue, Suite 61 0 Riverside, California 92501 Telephone: (951) 274—7777 Facsimile: (95 1) 274—7770 JUN 9‘ 8 om ‘ \OOOVQUl-bww— Attorneys for Plaintiff and Cross— JETCRUZER INTERNATIONAL, LLC. AND FARRAR AEROSPACE, LLC e end§1t, CESAR . m SUPERIOR COURT OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO JETCRUZER INTERNATIONAL, LLC; CASE NO, CIVDSl930132 Assigned for all purposes to the Honorable Plaintiff, Thomas S. Garza, Department S27 610 V. OBJECTION TO THE SUPPLEMENTAL DECLARATION OF R. CHRISTOPHER GE‘IH LLP Suite 92501 SANDY ACOSTA, an individual and DBA HARSHMAN FILED IN SUPPORT OF CHINO AIRCRAFT INTERIORS & PAINT DEFENDANT’S MOTION TO COMPEL Avenue, andCHINO AIRCRAFT INTERIORS/CAI, FURTHER RESPONSES Brandt California 274-7777 andDOES through 50, inclusive, 1 A8 VVVVVVVVVVVVVVVVVV Date: June 9, 2021 & (951) Time: 9:00 a.m. University Defendant Varner Riverside, Department: S27 XV:| 3750 AND RELATED CROSS-ACTIONS Complaint Filed: October 8, 201 9 NNNNNNNNNp—a—A—d—ap—twr—y—a—ap— Cross—Complaint Filed: December 13, 2019 Trial: February 7, 2022 OONONKflgk’JNflOKOOONONM-PWNHO TO DEFENDANT AND HER ATTORNEYS OF RECORD: Plaintiff JETCRUZER INTERNATIONAL, LLC (hereinafter referred t0 as “JetCruzer” or “Plaintiff’) and Cross—Defendant FARRAR AEROSPACE, LLC (hereinafter referred t0 as “Farrar Aerospace”) hereby object t0 the Supplemental Declaration 0f R. Christopher Harshman filed in support of Defendant’s Motion to Compel Further Responses (hereinafter referred t0 as the “Supplemental Declaration") as follows: /// /// 1 OBJECTION TO THE SUPPLEMENTAL DECLARATION OF R. CHRISTOPHER HARSHMAN FILED IN SUPPORT OF DEFENDANT’S MOTION TO COMPEL FURTHER RESPONSES OBJECTIONS I. Plaintiff objects to the Supplemental Declaration on the grounds that it was filed 0n May 25, 2021, after Defendant SANDY ACOSTA (hereinafter referred to as “‘Defendant”) had already filed her Motion t0 Compel Further Responses 0n April 5, 2021 (hereinafter referred t0 as “Motion to Compel”). It appears to Plaintiff that Defendant is seeking t0 improperly \OOONONU‘I-BLNNfl introduce new evidence t0 be considered by this Court, even afier already filing her Motion t0 Compel. 2. Additionally, Plaintiff also objects t0 this Supplemental Declaration 0n the grounds that Defendant identifies an individual, private party’s name into public record while both Plaintiff and Defendant are in the middle of working 0n a Protective Order t0 protect precisely this kind 0f information from open public disclosure. Defendant was fully aware of the 610 Protective Order, however, still filed the Supplemental Declaration identifying a private party’s name even though Suite 92501 LLP both parties were working in good faith to stipulate to said Protective Order. It borders on Brandt Avenue, California 274-7777 misconduct for Defendant t0 knowingly reveal any portion of this material in a public document 85 during the time that her counsel is “supposedly” reviewing the stipulation (951) in preparation of University Vamer Riverside, signing it. Defense counsel was even given sage advice t0 “hold off” 0n making any such public disclosure to any of the information until the matter could be further investigated 3750 and jointly NNNNNNNNN’fit—‘t—‘t—‘H—flfi—t— discussed. As is the pattern in this matter, however, Defendant chose to disregard this advice in an attempt to gain an unfair advantage. OOQOM-waflowcoflakhwa—‘O 3. Plaintiff objects t0 this Supplemental Declaration on the grounds that the investor named in Defendant’s Motion was never a “Lost Investor” as described by Plaintiff in its Complaint. More specifically, Plaintiff never alleged to have lost the individual named in Defendant’s Motion, so Plaintiff did not need to reveal the private party’s identification t0 Defendant for this very reason. However, Defendant went ahead and released the private party’s identification without Plaintiff’s consent. Moreover, in meeting and conferring over the motion, Defense counsel has taken great pains t0 point out that it is imperative to the defense t0 inquire about all potential fl investors because Plaintiff has alleged causes of action for lost economic opportunity. Since lost investors (used in a very broad sense) is the focus of Defendant’s 2 OBJECTION TO THE SUPPLEMENTAL DECLARATION OF R. CHRISTOPHER HARSHMAN FILED IN SUPPORT OF DEFENDANT’S MOTION TO COMPEL FURTHER RESPONSES