On September 20, 2018 a
Conference
was filed
involving a dispute between
Horner Lisa,
Horner Matthew Robert,
Truck Insurance Exchange,
and
Banda Armando Rodriguez,
Blake Leslie W.,
Moon Mountain Farms,
Moon Mountain Farms Llc,
for civil
in the District Court of Los Angeles County.
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NAME AND ADDRESS OF ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NUMBER Reserved for Clerk’s File Stamp
Sherwin Nahavandi, Esq. 322548
Parris Law Firm
43364 10th Street West
Lancaster, CA 93534
TELEPHONE NO.: 661 949 2595 FAX NO.: 661 949 7524
E-MAIL ADDRESS: evera@parris.com
ATTORNEY FOR (Name): Plaitniffs
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
COURTHOUSE ADDRESS:
Spring Street Courthouse, 312 N. Spring Street, Los Angeles, CA 90012
PLAINTIFF:
Matthew Horner
DEFENDANT:
Armando Banda
CASE NUMBER:
INFORMAL DISCOVERY CONFERENCE FORM FOR
PERSONAL INJURY COURTS
(Department 27, 28, 29, 31, 32) BC722801
AN INFORMAL DISCOVERY CONFERENCE (“IDC”) HAS BEEN RESERVED IN DEPARTMENT.
27, 28, 29, 3, 3 on 02/18/2022
____________ at 11:30
_______AM/PM.
✔
1. Type of case: ■ Auto Slip/Trip & Fall Med Mal Product Liability Assault & Battery
Electronically Received 10/28/2021 04:57 PM
Other (please describe):___________________________________________________________.
2. You must file and serve this Informal Discovery Conference Form no later than 15 court days prior
to the IDC. The opposing party may file and serve a responsive IDC Form, briefly setting forth that
party’s response, at least 10 court days prior to the IDC.
3. Briefly describe the discovery dispute (information requested and/or the basis for objection) in the
space provided below (do not add extra pages):
Plaintiffs have met and conferred with Defendants since July 14, 2021 on being provided verifications to discovery
previously responded to by Defendant Armando Rodriguez Banda. Defendants refuse to provide verifications.
Unverified responses are tantamount to no responses at all. (See Appleton v. Superior Court (1988) 206 Cal.App.3d
632, 636, citing Zorro Inv. Co. v. Great Pacific Securities Corp. (1977) 69 Cal.App.3d 907, 914.). Therefore, Plaintiffs
moved ex-parte to compel verifications on September 30, 2021. The Court denied it on the grounds that it must be a
noticed motion. Subsequently, trial was continued to February 1, 2022 and fact discovery was re-opened so Plainiffs
seek an informal discovery conference pursuant to the Local Rules for verified responses prior to filing its motions.
Currently, the following discovery by Armando Rodriguez Banda is unverified:
• Defendant Armando Rodriguez Banda’s Responses to Demands for Production, Set One;
• Defendant Armando Rodriguez Banda’s Amended Responses to Demands for Production, Set Two;
• Defendant Armando Rodriguez Banda’s Responses to Form Interrogatories, Set One;
• Defendant Armando Rodriguez Banda’s Further Responses to Form Interrogatories, Set One;
• Defendant Armando Rodriguez Banda’s Responses to Form Interrogatories, Set Four;
• Defendant Armando Rodriguez Banda’s Responses to Special Interrogatories, Set One;
• Defendant Armando Rodriguez Banda’s Further Responses to Special Interrogatories, Set One;
• Defendant Armando Rodriguez Banda’s Responses to Supplemental Responses to Special Interrogatories, Set Three
INFORMAL DISCOVERY CONFERENCE
LASC CIV 239 Rev.
For Optional Use FORM FOR PERSONAL INJURY COURTS Page 1 of 2
(Department 27, 28, 29, 31, 32) RESERVATION 792671795493
Document Filed Date
October 28, 2021
Case Filing Date
September 20, 2018
Status
Request for Dismissal - After Non-Jury Trial 07/05/2022
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NAME AND ADDRESS OF ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NUMBER Reserved for Clerk’s File Stamp Sherwin Nahavandi, Esq. 322548 Parris Law Firm 43364 10th Street West Lancaster, CA 93534 TELEPHONE NO.: 661 949 2595 FAX NO.: 661 949 7524 E-MAIL ADDRESS: evera@parris.com ATTORNEY FOR (Name): Plaitniffs SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES COURTHOUSE ADDRESS: Spring Street Courthouse, 312 N. Spring Street, Los Angeles, CA 90012 PLAINTIFF: Matthew Horner DEFENDANT: Armando Banda CASE NUMBER: INFORMAL DISCOVERY CONFERENCE FORM FOR PERSONAL INJURY COURTS (Department 27, 28, 29, 31, 32) BC722801 AN INFORMAL DISCOVERY CONFERENCE (“IDC”) HAS BEEN RESERVED IN DEPARTMENT. 27, 28, 29, 3, 3 on 02/18/2022 ____________ at 11:30 _______AM/PM. ✔ 1. Type of case: ■ Auto Slip/Trip & Fall Med Mal Product Liability Assault & Battery Electronically Received 10/28/2021 04:57 PM Other (please describe):___________________________________________________________. 2. You must file and serve this Informal Discovery Conference Form no later than 15 court days prior to the IDC. The opposing party may file and serve a responsive IDC Form, briefly setting forth that party’s response, at least 10 court days prior to the IDC. 3. Briefly describe the discovery dispute (information requested and/or the basis for objection) in the space provided below (do not add extra pages): Plaintiffs have met and conferred with Defendants since July 14, 2021 on being provided verifications to discovery previously responded to by Defendant Armando Rodriguez Banda. Defendants refuse to provide verifications. Unverified responses are tantamount to no responses at all. (See Appleton v. Superior Court (1988) 206 Cal.App.3d 632, 636, citing Zorro Inv. Co. v. Great Pacific Securities Corp. (1977) 69 Cal.App.3d 907, 914.). Therefore, Plaintiffs moved ex-parte to compel verifications on September 30, 2021. The Court denied it on the grounds that it must be a noticed motion. Subsequently, trial was continued to February 1, 2022 and fact discovery was re-opened so Plainiffs seek an informal discovery conference pursuant to the Local Rules for verified responses prior to filing its motions. Currently, the following discovery by Armando Rodriguez Banda is unverified: • Defendant Armando Rodriguez Banda’s Responses to Demands for Production, Set One; • Defendant Armando Rodriguez Banda’s Amended Responses to Demands for Production, Set Two; • Defendant Armando Rodriguez Banda’s Responses to Form Interrogatories, Set One; • Defendant Armando Rodriguez Banda’s Further Responses to Form Interrogatories, Set One; • Defendant Armando Rodriguez Banda’s Responses to Form Interrogatories, Set Four; • Defendant Armando Rodriguez Banda’s Responses to Special Interrogatories, Set One; • Defendant Armando Rodriguez Banda’s Further Responses to Special Interrogatories, Set One; • Defendant Armando Rodriguez Banda’s Responses to Supplemental Responses to Special Interrogatories, Set Three INFORMAL DISCOVERY CONFERENCE LASC CIV 239 Rev. For Optional Use FORM FOR PERSONAL INJURY COURTS Page 1 of 2 (Department 27, 28, 29, 31, 32) RESERVATION 792671795493