On November 08, 2021 a
Party Discovery
was filed
involving a dispute between
Doe, John,
and
County Of San Bernanrdino County Of Sheriff'S Department,
County Of San Bernardino,
County Of San Bernardino Human Services Department,
Cox, Jeremie,
Does 1 - 100,
Hope Academy, Inc,
Provenance,
Savantco,
for Other PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
1 Christopher Keane (SBN 194848)
J.
THE KEANE LAW FIRM, P.C. v
I
r LE D
8605 Santa Monica Blvd. #23851 summer; comm m: CALIFORNIA
Los Angeles, CA 90069 COUNTY (3F 53AM HERNAHDSNO
SAN BERNARDINO DISTRICT
Telephone: (415) 742-5412
Fax: (415) 520-2282 AUG 22 2%22
.. ~_.."M.....
_
J
2.: A 1314.1
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i,
r
PAD LA N UEV
\OOOQQUIAUJN
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BY: | I
Attorney for Plaintiff
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN BERNARDINO
(UNLIMITED JURISDICTION)
JOHN DOE, Case No.2 CIVSB213 1751
Plaintiff, NOTICE OF MOTION AND
MOTION TO ORDER
V. DEPOSITION OF
INCARCERATED PERSON,
COUNTY OF SAN BERNARDINO and JEREMIE COX; MEMORANDUM
DOES 2—100, inclusive, jointly and
vvvvvvvvvvvvvvvv
0F POINTS AND AUTHORITIES;
severally, DECLARATION OF
CHRISTOPHER J. KEANE
Defendant(s). [PROPOSED] ORDER
NNNNNNNNNHHr—‘L—AHHHHt—AH
Complaint filed: 11/8/2021
WQONU‘IAWNHOKOOONOM-hWNF—‘o
Trial date: N/A
Date 0f hearing: 10/ 10/2022
Time of hearing: 8:30 a.m.
Dept: S31
TO ALL PARTIES AND ATTORNEYS OF RECORD:
Plaintiff, JOHN DOE, will move, and hereby does move, this Court for an order
compelling the attendance of incarcerated person, Jeremie Cox, at deposition in this action, in
compliance with a properly served Notice of Taking Deposition.
NOTICE OF MOTION AND MOTION TO ORDER DEPOSITION OF INCARCERATED PERSON,
JEREMIE COX
. .
|
.
This motion Will be brought for hearing in on October 10, 2022, at 8:30 am. in
Department S31 of the San Bernardino Superior Court, 247 W.
3rd
Street, San Bernardino, CA
9241 5.
This motion is made pursuant to California Code ofCivil Procedure §§1995 and 1996. as
\DOOQQMAWNH
well as California Penal Code §2623. The motion will be made on the grounds that Jeremie Cox
is a material witness in this action and a percipient witness t0 the events and circumstances
surrounding this lawsuit, and on the grounds that he is currently imprisoned under booking
number 2109300582, at San Bernardino County Sheriff Department — High Desert Detention
Center, 9438 Commerce Way, Adelanto, CA 92301, awaiting sentencing in San Bernardino Case
FWV2 1 003520, People V Jeremie Cox.
This motion is further based upon this Notice, the attached Memorandum of Points
and Authorities, the Declaration of Christopher J. Keane, the pleadings, all records and files in
this matter, and such oral and documentary evidence as may be presented at the hearing on this
motion.
NNNNNNNNNHHHHH—tr—Ir—AHH
Dated: 8/22/2022 THE KEANE LAW FIRM, P.C.
OONONM-PWNHOKOWQQMAWNP‘O
By:
Christopher J. Keane
Attorney for Plaintiff, John Doe
2
NOTICE OF MOTION AND MOTION TO ORDER DEPOSITION OF INCARCERATED PERSON,
JEREMIE COX
Document Filed Date
August 22, 2022
Case Filing Date
November 08, 2021
Category
Other PI/PD/WD Unlimited
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Preview
1 Christopher Keane (SBN 194848) J. THE KEANE LAW FIRM, P.C. v I r LE D 8605 Santa Monica Blvd. #23851 summer; comm m: CALIFORNIA Los Angeles, CA 90069 COUNTY (3F 53AM HERNAHDSNO SAN BERNARDINO DISTRICT Telephone: (415) 742-5412 Fax: (415) 520-2282 AUG 22 2%22 .. ~_.."M..... _ J 2.: A 1314.1 ,r i, r PAD LA N UEV \OOOQQUIAUJN I ' BY: | I Attorney for Plaintiff IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN BERNARDINO (UNLIMITED JURISDICTION) JOHN DOE, Case No.2 CIVSB213 1751 Plaintiff, NOTICE OF MOTION AND MOTION TO ORDER V. DEPOSITION OF INCARCERATED PERSON, COUNTY OF SAN BERNARDINO and JEREMIE COX; MEMORANDUM DOES 2—100, inclusive, jointly and vvvvvvvvvvvvvvvv 0F POINTS AND AUTHORITIES; severally, DECLARATION OF CHRISTOPHER J. KEANE Defendant(s). [PROPOSED] ORDER NNNNNNNNNHHr—‘L—AHHHHt—AH Complaint filed: 11/8/2021 WQONU‘IAWNHOKOOONOM-hWNF—‘o Trial date: N/A Date 0f hearing: 10/ 10/2022 Time of hearing: 8:30 a.m. Dept: S31 TO ALL PARTIES AND ATTORNEYS OF RECORD: Plaintiff, JOHN DOE, will move, and hereby does move, this Court for an order compelling the attendance of incarcerated person, Jeremie Cox, at deposition in this action, in compliance with a properly served Notice of Taking Deposition. NOTICE OF MOTION AND MOTION TO ORDER DEPOSITION OF INCARCERATED PERSON, JEREMIE COX . . | . This motion Will be brought for hearing in on October 10, 2022, at 8:30 am. in Department S31 of the San Bernardino Superior Court, 247 W. 3rd Street, San Bernardino, CA 9241 5. This motion is made pursuant to California Code ofCivil Procedure §§1995 and 1996. as \DOOQQMAWNH well as California Penal Code §2623. The motion will be made on the grounds that Jeremie Cox is a material witness in this action and a percipient witness t0 the events and circumstances surrounding this lawsuit, and on the grounds that he is currently imprisoned under booking number 2109300582, at San Bernardino County Sheriff Department — High Desert Detention Center, 9438 Commerce Way, Adelanto, CA 92301, awaiting sentencing in San Bernardino Case FWV2 1 003520, People V Jeremie Cox. This motion is further based upon this Notice, the attached Memorandum of Points and Authorities, the Declaration of Christopher J. Keane, the pleadings, all records and files in this matter, and such oral and documentary evidence as may be presented at the hearing on this motion. NNNNNNNNNHHHHH—tr—Ir—AHH Dated: 8/22/2022 THE KEANE LAW FIRM, P.C. OONONM-PWNHOKOWQQMAWNP‘O By: Christopher J. Keane Attorney for Plaintiff, John Doe 2 NOTICE OF MOTION AND MOTION TO ORDER DEPOSITION OF INCARCERATED PERSON, JEREMIE COX