Motion-Secondary: JETCRUZER -V- SANDY ACOSTA Print

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                                From Law Office        1.310.822.8529 Mon Jun   7 18:50:41 2071     PDT Page 2 of 6
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     David M. Shaby II, Esq. (97871)                                            SUPERIOR COUR
       dshaby@shabyandassociates.com                                                          T OF CG, -ALI
                                                                                                             FORNIA
     R. Christopher Harshman, Esq. (248214)                                       SAN BERNARD \NING S| RNARDINO
                                                                                                       DISTRICT
      charshman@shabyandassociates.com
     Davip M. Suasy II & AssociaTEs, APC                                                 JUN      8 2091
     11949 Jefferson Boulevard, Suite 104
     Culver City, California 90230                                                         =
     Telephone:       310)   827-7171                                         ee
                                                                              S AMANTHA NEUBAUER
     Facsimile:       310) 822-8529                                                              ,             DEPUTY
     Attorneys for Defendant and Cross-Complainant Sandy Acosta                                            :




                                        SUPERIOR CourRT OF CALIFORNIA
                                           CouNTY OF SAN BERNARDINO
10   Jetcruzer International, LLC,                              Case no, CIVDS1930132
 n                                      Plaintiff,              Assigned to the Hon. Tom Garza, Dept. $27
12                                                              RESPONSE TO PLAINTIFF’S
                                                                                     JUNE 7, 2021
                              vs,
                                                                OBJECTION TO THE MAY 25, 2021
13   Sandy Acosta, et al,                                       SUPPLEMENTAL DECLARATION OF R.
                                                                CHRISTOPHER HARSHMAN FILED IN SUPPORT
14                                      Defendants.             OF DEFENDANT’S MOTION TO COMPEL
                                                                FURTHER RESPONSES
15   And Related Cross-Complaint
                                                                Date:              June 9, 2021
16                                                              Time:              9:00 a.m.
V7
                                                                Department:        $27

18

19          Defendant and cross-complainant Sandy Acosta (“ Acosta” or Defendant”) hereby responds
20   to the Objection to the Supplemental Declaration of R. Christopher Harshman Filed in Support of

21   Defendant’s Motion to Compel Further Responses (the “Objection”). The Objection was received by
22   Ms. Acosta’s counsel moments after it was sent via email at 5:29 p.m. on June 7, 2021. The
23   Supplemental Declaration in question was submitted, along with a Request to Submit Supplemental

24   Declaration, Under Seal, in Support of Motion to Compel Further Responses (the “Request”),

25   electronically to both the Court and counsel for plaintiff and cross-defendant JetCruzer International,
26   LLC (“JetCruzer” or “Plaintiff”), on May 25, 2021. JetCruzer makes this objection after the close of
27   business on June 7, 2021, leaving a single court day before the hearing on the instant Motion to Compel

28   Further Responses, despite JetCruzer’s counsel having not only been served with the Request and
                                                            1
                                    RESPONSE TO OPPOSITION TO SUPPLEMENTAL DECLARATION
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