Party Discovery: 632 N PALM DRIVE, LLC VS ADAN PENA, ET AL.

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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 COMPEL
                              12          v.                                                          RESPONES TO SPECIAL
          A LAW CORPORATION




                                                                                                      INTERROGATORIES ON PLAINTFF
                              13   GOLD PACIFIC CONSTRUCTION, INC.,                                   AND REQUEST FOR SANCTIONS ON
                                   a California corporation, ADAN PENA, an                            PLAINTIFF AND COUNSEL OF $3,937.90
                              14   individual; SURETEC INDEMNITY                                      PURSUANT TO CCP §§2023.010, 2030.290,
                                   COMPANY, a California corporation, and                             RULES OF COURT RULE 2.30
                              15   DOES 1-20
                                                  Defendants.                                         Dept.:                 M
                              16                                                                      Judge:                 Hon. Mark A. Young
                                                                                                      Date:                  April 23, 2020
                              17   AND RELATED CROSS-ACTIONS                                          Time:                  8:30 a.m.
                                                                                                      Res. ID:               831963844972
                              18

                              19          TO PLAINTIFF AND THEIR ATTORNEYS OF RECORD:
                              20          NOTICE IS HEREBY GIVEN that on April 23, 2020, at 8:30 a.m., or as soon
                              21   thereafter as the matter may be heard in Department M of the above-entitled Court, located at
                              22   1725 Main Street Santa Monica, California, Defendant/Cross-Complainant Gold Pacific
                              23   Construction, Inc. (“GOLD”) will move this Court for an order compelling responses of 632 N
                              24   PALM DRIVE, LLC, (“632”) to GOLD’s First Set of Special Interrogatories and Order
                              25   sanctions on 632 and their attorneys, Nilou Zakariaie jointly and severally in an amount not
                              26   less than $3,937.90 pursuant to Cal. Cod. Proc. §§2023.010, 2023.030, 2030.210, 2030.220,
                              27   2030.240, 2030.250, 2030.260, 2030.290, and Cal. Rul. Court Rules 2.30, 3.1345(c). This
                              28   Motion is jointly filed pursuant to the above authority with GOLD’s Motion to Compel 632
                                                                                 1
                                                    MOTION TO COMPEL RESPONSES TO SPECIAL INTERROGATORIES