On June 12, 2018 a
Party Discovery
was filed
involving a dispute between
Thacker Inest,
and
Earle Hyman Defined Benefit Pension Plan,
Halcromb Byron Lamont Aka Byron Halcromb,
Mostafa Charity Laura,
Reyes Michael Blaise,
United Wholesale Mortgate Llc A Michigan Limited Liability Company,
United Wholesale Mortgate Llc A Michigan Limited Liability Company Dba United Wholesale Mortgage,
for civil
in the District Court of Los Angeles County.
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Electronically FILED by Superior Court of California, County of Los Angeles on 09/30/2020 03:24 PM Sherri R. Carter, Executive Officer/Clerk of Court, by D. Rojas,Deputy Clerk
Paul Orloff (SBN 216791)
ORLOFF 86 ASSOCIATES APC
8402 Florence Avenue Suite BI
Downey, California 90240
Telephone (562) 869-3034
Facsimile (562) 869-3539
Attorney for PlaintifF
INEST THACKER
SUPERIOR COURT OF CALIFORNIA
9 FOR THE COUNTY OF LOS ANGELES
10 COMPTON COURTHOUSE
11 INEST THACKER, an individual, ) Case No. TC029189
12 Plaintiff,
) OPPOSITION TO MOTION TO COMPEL
13 vs. ) RESPONSES TO REQUESTS FOR
ADMISSION
14 BYRON LAMONT HALCROMB aka BYRON
HALCROMB, an individual; EARLE HYMAN Original Complaint filed: 6/22i18
15 DEFINED BENEFIT PENSION PLAN; entity Assigned to: Hon. Maurice A. Lei ter
type unknown; MICHAEL BLAISE REYES; Dept: A
16 an individual, CHARITY LAURA MOSTAFA;
an individual; UNITED WHOLESALE
17 MORTGAGE, LLC, a Michigan Limited
Liability Company; and DOES 1-20; and all
18 persons unknown claiming legal or equitable
19
right, title, estate, lien, or interest in the real
property described in the Complaint adverse to
20
Platntift's title and interest, or any cloud upon
PlaintifF s title or interest thereto, named herein as DATE: October I, 2020
DOES 21-50 inclusive; TIME: 8:30 am
21 DEPT: A
22
Defendant.
23
24 COMES NOW, Plaintiff INEST THACKER ("Thacker"), by and through her attorney, and
25 hereby opposes the Motion to Compel Responses to Requests for Admission by Defendants MICHAEL
26 BLAISE REYES ("Reyes") and CHARITY LAURA MOSTAFA ("Mostafa**) as follows:
27 I. INTRODUCTION
28 Thacker is a 93 year old elder who owns the real property at issue in this litigation, a home which
OPPOSITION TO MOTION TO COMPEL RESPONSES TO REQUESTS FOR ADMISSION
Document Filed Date
September 30, 2020
Case Filing Date
June 12, 2018
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Electronically FILED by Superior Court of California, County of Los Angeles on 09/30/2020 03:24 PM Sherri R. Carter, Executive Officer/Clerk of Court, by D. Rojas,Deputy Clerk Paul Orloff (SBN 216791) ORLOFF 86 ASSOCIATES APC 8402 Florence Avenue Suite BI Downey, California 90240 Telephone (562) 869-3034 Facsimile (562) 869-3539 Attorney for PlaintifF INEST THACKER SUPERIOR COURT OF CALIFORNIA 9 FOR THE COUNTY OF LOS ANGELES 10 COMPTON COURTHOUSE 11 INEST THACKER, an individual, ) Case No. TC029189 12 Plaintiff, ) OPPOSITION TO MOTION TO COMPEL 13 vs. ) RESPONSES TO REQUESTS FOR ADMISSION 14 BYRON LAMONT HALCROMB aka BYRON HALCROMB, an individual; EARLE HYMAN Original Complaint filed: 6/22i18 15 DEFINED BENEFIT PENSION PLAN; entity Assigned to: Hon. Maurice A. Lei ter type unknown; MICHAEL BLAISE REYES; Dept: A 16 an individual, CHARITY LAURA MOSTAFA; an individual; UNITED WHOLESALE 17 MORTGAGE, LLC, a Michigan Limited Liability Company; and DOES 1-20; and all 18 persons unknown claiming legal or equitable 19 right, title, estate, lien, or interest in the real property described in the Complaint adverse to 20 Platntift's title and interest, or any cloud upon PlaintifF s title or interest thereto, named herein as DATE: October I, 2020 DOES 21-50 inclusive; TIME: 8:30 am 21 DEPT: A 22 Defendant. 23 24 COMES NOW, Plaintiff INEST THACKER ("Thacker"), by and through her attorney, and 25 hereby opposes the Motion to Compel Responses to Requests for Admission by Defendants MICHAEL 26 BLAISE REYES ("Reyes") and CHARITY LAURA MOSTAFA ("Mostafa**) as follows: 27 I. INTRODUCTION 28 Thacker is a 93 year old elder who owns the real property at issue in this litigation, a home which OPPOSITION TO MOTION TO COMPEL RESPONSES TO REQUESTS FOR ADMISSION