On May 26, 2022 a
Motion-Secondary
was filed
involving a dispute between
Av Automotive, Inc.,
Vartanian, Arsen H,
Portillo, Edgar,
and
Does 1-60,
Does 1 Through 35,
Vartanian, Vahak,
for Fraud Unlimited
in the District Court of San Bernardino County.
Preview
DAVID L. PRINCE, ESQ, #1 13599
MILES L. PRINCE, ESQ, #298823
EVAN A. CLARK, ESQ, #309697 +31
-.
191 2 EastVernon Avenue, Suite 100 .
'
“
Los Angeles, California 90058
“
Tel. 323/234—2989 Fax. 323/234—2619 w; é}
PH -4;
VAHAK VARTANIAN
\oooqomnwm...
Attorney for Defendant,
SUPERIOR COURT OF THE STATE 0F CALIFORNIA
COUNTY OF SAN BERNARDINO
.—n
O
»-—-
r—
ARSEN H. VARTANIAN, ct (11., ) CASE NO.: CIVSB221 0697 3y Fax
)
_:
N Plaintiff, )
DEFENDANT’S OPPOSITION TO MOTION
) TO COMPEL FURTHER RESPONSES AND
b—A
W vs. ) REQUEST FOR SANCTIONS OF $1,41 7.50; '
) DECLARATION OF MILES L. PRINCE
'—- 4: VAHAK VARTANIAN, )
) DATE: May 19 2023
n—t UI
Defendants. ) TIME: 8:30 A. .
) DEPT S33
p—J ON
>—‘
N Defendant, Vahak Vartanian, (“Defendant”) hereby opposes the motion to compel
~—4 00
further responses (the “Motion”) by Plaintiff, Arsen H. Vananian (“Plaintiff”).
~— \O I.
NC SUMMARY
[\J
H Plaintiff filed the Motion solely to compel further responses over Defendant’s single
NN objection that the case was not at issue yet, so discovery was premature. No other basis for
[\J b3
further responses were provided. Verified responses have since been provided. Parties are
N .5 currently engaged in good faith efforts to meet and confer over those responses. At this
N U] point, it is premature to compel any further responses, and the present Motion fails the
N O\ statutory burdens to obtain such an order.
NQ 1
Defendant’s Opposition to Motion to Compel Further Responses and Request for Sanctions of $1 ,417.50;
IQ 00
Declaration of Miles L. Prince
6’
0
4’9???»
A0
Q 4/— ??’?1'
7% ‘6‘
«3‘5
6‘
9¢ 9é ,2
429%
W
0/99
O<0 1'
’9
o ‘5‘?
\J \r
Document Filed Date
May 08, 2023
Case Filing Date
May 26, 2022
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
DAVID L. PRINCE, ESQ, #1 13599 MILES L. PRINCE, ESQ, #298823 EVAN A. CLARK, ESQ, #309697 +31 -. 191 2 EastVernon Avenue, Suite 100 . ' “ Los Angeles, California 90058 “ Tel. 323/234—2989 Fax. 323/234—2619 w; é} PH -4; VAHAK VARTANIAN \oooqomnwm... Attorney for Defendant, SUPERIOR COURT OF THE STATE 0F CALIFORNIA COUNTY OF SAN BERNARDINO .—n O »-—- r— ARSEN H. VARTANIAN, ct (11., ) CASE NO.: CIVSB221 0697 3y Fax ) _: N Plaintiff, ) DEFENDANT’S OPPOSITION TO MOTION ) TO COMPEL FURTHER RESPONSES AND b—A W vs. ) REQUEST FOR SANCTIONS OF $1,41 7.50; ' ) DECLARATION OF MILES L. PRINCE '—- 4: VAHAK VARTANIAN, ) ) DATE: May 19 2023 n—t UI Defendants. ) TIME: 8:30 A. . ) DEPT S33 p—J ON >—‘ N Defendant, Vahak Vartanian, (“Defendant”) hereby opposes the motion to compel ~—4 00 further responses (the “Motion”) by Plaintiff, Arsen H. Vananian (“Plaintiff”). ~— \O I. NC SUMMARY [\J H Plaintiff filed the Motion solely to compel further responses over Defendant’s single NN objection that the case was not at issue yet, so discovery was premature. No other basis for [\J b3 further responses were provided. Verified responses have since been provided. Parties are N .5 currently engaged in good faith efforts to meet and confer over those responses. At this N U] point, it is premature to compel any further responses, and the present Motion fails the N O\ statutory burdens to obtain such an order. NQ 1 Defendant’s Opposition to Motion to Compel Further Responses and Request for Sanctions of $1 ,417.50; IQ 00 Declaration of Miles L. Prince 6’ 0 4’9???» A0 Q 4/— ??’?1' 7% ‘6‘ «3‘5 6‘ 9¢ 9é ,2 429% W 0/99 O<0 1' ’9 o ‘5‘? \J \r