On September 13, 2018 a
Party Discovery
was filed
involving a dispute between
Matusenko Emil,
Matusenko Katherine,
Matusenko Zoya,
and
Cooley John,
Dalco Forensic Consultants Inc. A Califor,
Farmers Insurance Exchange A California Entity,
Fire Insurance Exchange A California Entity,
Matrix Roofing & Waterproofing Inc.,
Mossakowski Anjey,
Ross Morgan & Company Inc.,
Tarzana Gardens Condominium Association,
for civil
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 02/25/2020 02:14 PM Sherri R. Carter, Executive Officer/Clerk of Court, by L. Marquez,Deputy Clerk
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1 GREGORY J. CARPENTER, ESQ. - State Bar No. 221922
HARTSUYKER, STRATMAN & WILLIAMS-ABREGO
2 P.O. Box 258829
Oklahoma City, OK 73125-8829
3 Physical Address:
700 South Flower Street, Suite 2800
4 Los Angeles, CA 90017
Phone: (213) 615-2500
5 Fax: (213) 615-2698
6 Attorney for Defendant,
TARZANA GARDENS CONDOMINIUM ASSOCIATION, A CALIFORNIA ASSOCIATION; ROSS
t 7 MORGAN & COMPANY, INC., A CALIFORNIA CORPORATION
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10 SUPERIOR COURT OF THE STATE OF CALIFORNIA
11 FOR THE COUNTY OF LOS ANGELES
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13 EMIL MATUSENKO, AN INDIVIDUAL; AND Case No.: BC722213
ZOYA MATUSENKO, AN INDIVIDUAL, UNLIMITED JURISDICTION
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Plaintiffs, ASSIGNED TO FOR ALL PURPOSES:
15 HON . MICHALE J . CONVEY
vs. DEPT: U
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DALCO FORENSIC CONSULTANTS INC. A DEFENDANTS’ OMNIBUS OPPOSITION TO
17 CALIFORNIA CORPORATION; JOHN MOTIONS TO COMPEL AND MOTION TO
COOLEY, AN INDIVIDUAL; TARZANA DEEM REQUEST FOR ADMISSIONS
18 GARDENS CONDOMINIUM ASSOCIATION, A ADMITTED; DECLARATION OF
CALIFORNIA ASSOCIATION AND DOES 1 TO GREGORY J. CARPENTER
19 50 INCLUSIVE,
DATE: March 9, 2020
20 Defendants. TIME: 8:30 a.m.
DEPT: U
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Defendants, Tarzana Gardens Condominium Association, A California Association and Ross
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Morgan & Company, Inc ., hereby oppose Plaintiffs motion to deem matters admitted and motions to
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compel discovery .
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This Opposition is based upon the response has already been made and the delay in responding
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was due to mistake, inadvertence, or excusable neglect.
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DEFENDANTS’ OMNIBUS OPPOSITION TO MOTIONS TO COMPEL AND MOTION TO DEEM REQUEST FOR ADMISSIONS
ADMITTED; DECLARATION OF GREGORY J. CARPENTER I -
Document Filed Date
February 25, 2020
Case Filing Date
September 13, 2018
Status
Request for Dismissal - Before Trial not following ADR or more than 60 days since ADR 08/26/2020
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