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Electronically FILED by Superior Court of California, County of Los Angeles on 03/30/2020 09:17 AM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Mariscal,Deputy Clerk
1 SEAN P. REYNOLDS, ESQ., State Bar No. 249649
US CONSTRUCTION LAW, A Law Corporation
2 3433 Corte Altura
Carlsbad CA, 92009
3 T: (760) 452-5752
sreynolds@usclawcorp.com
4
Attorneys for Defendants GOLD PACIFIC
5 CONSTRUCTION, INC., ADAN PENA and
SURETEC INDEMNITY COMPANY
6
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF LOS ANGELES
10 632 N PALM DRIVE, LLC. CASE NO.: 19SMCV00434
(Complaint filed: March 5, 2019)
11 Plaintiff,
US CONSTRUCTION LAW
DEFENDANT’S MOTION TO DEEM
12 v. REQUESTS FOR ADMISSIONS, SET ONE
A LAW CORPORATION
ON PLAINTFF ADMITTED AND
13 GOLD PACIFIC CONSTRUCTION, INC., REQUEST FOR SANCTIONS ON
a California corporation, ADAN PENA, an PLAINTIFF AND COUNSEL OF $4,987.90
14 individual; SURETEC INDEMNITY PURSUANT TO CCP §§2023.010, 2033.280,
COMPANY, a California corporation, and RULES OF COURT RULE 2.30;
15 DOES 1-20 DECLARATION OF SEAN P. REYNOLDS;
Defendants. [PROPOSED] ORDER.
16
Dept.: M
17 AND RELATED CROSS-ACTIONS Judge: Hon. Mark A. Young
Date: April 23, 2020
18 Time: 8:30 a.m.
Res. ID: 831963844972
19
20 TO PLAINTIFF AND THEIR ATTORNEYS OF RECORD:
21 NOTICE IS HEREBY GIVEN that on April 23, 2020, at 8:30 a.m., or as soon
22 thereafter as the matter may be heard in Department M of the above-entitled Court, located at
23 1725 Main Street Santa Monica, California, Defendant/Cross-Complainant Gold Pacific
24 Construction, Inc. (“GOLD”) will move this Court for an order deeming GOLD’s First Set of
25 Request for Admissions on 632 N PALM DRIVE, LLC, (“632”) admitted, and Order
26 sanctions on 632 and their attorneys, Nilou Zakariaie jointly and severally in an amount not
27 less than $4,987.90 pursuant to Cal. Cod. Proc. §§2023.010, 2023.030, 2033.010, 2033.050,
28 2033.210, 2033.220, 2033.230, 2033.240, 2033.280, and Cal. Rul. Court Rules 2.30,
1
MOTION TO DEEM REQUEST FOR ADMISSIONS ADMITTED
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Electronically FILED by Superior Court of California, County of Los Angeles on 03/30/2020 09:17 AM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Mariscal,Deputy Clerk 1 SEAN P. REYNOLDS, ESQ., State Bar No. 249649 US CONSTRUCTION LAW, A Law Corporation 2 3433 Corte Altura Carlsbad CA, 92009 3 T: (760) 452-5752 sreynolds@usclawcorp.com 4 Attorneys for Defendants GOLD PACIFIC 5 CONSTRUCTION, INC., ADAN PENA and SURETEC INDEMNITY COMPANY 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF LOS ANGELES 10 632 N PALM DRIVE, LLC. CASE NO.: 19SMCV00434 (Complaint filed: March 5, 2019) 11 Plaintiff, US CONSTRUCTION LAW DEFENDANT’S MOTION TO DEEM 12 v. REQUESTS FOR ADMISSIONS, SET ONE A LAW CORPORATION ON PLAINTFF ADMITTED AND 13 GOLD PACIFIC CONSTRUCTION, INC., REQUEST FOR SANCTIONS ON a California corporation, ADAN PENA, an PLAINTIFF AND COUNSEL OF $4,987.90 14 individual; SURETEC INDEMNITY PURSUANT TO CCP §§2023.010, 2033.280, COMPANY, a California corporation, and RULES OF COURT RULE 2.30; 15 DOES 1-20 DECLARATION OF SEAN P. REYNOLDS; Defendants. [PROPOSED] ORDER. 16 Dept.: M 17 AND RELATED CROSS-ACTIONS Judge: Hon. Mark A. Young Date: April 23, 2020 18 Time: 8:30 a.m. Res. ID: 831963844972 19 20 TO PLAINTIFF AND THEIR ATTORNEYS OF RECORD: 21 NOTICE IS HEREBY GIVEN that on April 23, 2020, at 8:30 a.m., or as soon 22 thereafter as the matter may be heard in Department M of the above-entitled Court, located at 23 1725 Main Street Santa Monica, California, Defendant/Cross-Complainant Gold Pacific 24 Construction, Inc. (“GOLD”) will move this Court for an order deeming GOLD’s First Set of 25 Request for Admissions on 632 N PALM DRIVE, LLC, (“632”) admitted, and Order 26 sanctions on 632 and their attorneys, Nilou Zakariaie jointly and severally in an amount not 27 less than $4,987.90 pursuant to Cal. Cod. Proc. §§2023.010, 2023.030, 2033.010, 2033.050, 28 2033.210, 2033.220, 2033.230, 2033.240, 2033.280, and Cal. Rul. Court Rules 2.30, 1 MOTION TO DEEM REQUEST FOR ADMISSIONS ADMITTED