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Electronically FILED by Superior Court of California, County of Los Angeles on 02/07/2020 02:07 PM Sherri R. Carter, Executive Officer/Clerk of Court, by A. Boyadzhyan,Deputy Clerk
Jon O. Blanda, Esq. (State Bar No. 217222)
COLLECTION AT LAW, INC.
A PROFESSIONAL LAW CORPORATION
3835 East Thousand Oaks Blvd., Suite R- 349
Westlake Village, California 91362
Phone Number (818) 716-7630
Facsimile (818) 716-7775
Attorney for Plaintiff
ALAN M. GOLDBERG, Attorney At Law,
ALAN M. GOLDBERG, Attorney At Law, ) Case No. LC106987
10 )
Plaintiff, NOTICE OF MOTION ANB MOTION
) TQ COMPEL INITIAL RKSPONSKS
vs. } TO PLAINTIFF'S BISCQVKRY'KT
12 ) TWO - FARM INTERROGATORIES,;
EUGENE SAAL, an individual; ARYEH ) BKCLARATION OF W)N 0. BLANBA
13 PATHI, an individual; PASCAL )
BRENNINKMEIJER, an individual; JUDY ) DATE: May 7, 2020
14 WEISS, an individual; and DOES 1 through ) TIME: 8:30AM
100, inclusive, DEPT: U
15 )
)
Defendant(s). }
Reservation ID: 451109505028
)
)
)
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TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
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PLEASE TAKE NOTICE, that on May 7, 2020 at 8:30 A;M. in Dept. U of the above
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captioned Court, located at 6230 Sylmar Ave., Van Nuys, CA 91401, ALAN M. GOLDBERG,
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Attorney At Law, will move the Court to compel responses to the Form Interrogatories
propounded on Defendant, EUGENE SAAL, an individual, pursuant to $$ 2030.230, 2030.260,
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2030.290, 2031.260, 2031.300, 2033.010, 2033.020, 2033.250, 2033.280, and 2033.420 of the
Code of Civil Procedure.
This Motion will be based upon this Notice, the attached Declaration of JON O.
26
BLANDA, the Memorandum of Points and Authorities, the pleadings, records and files in this
27
action and such other oral and/or documentary evidence as may be presented at the time of the
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 02/07/2020 02:07 PM Sherri R. Carter, Executive Officer/Clerk of Court, by A. Boyadzhyan,Deputy Clerk Jon O. Blanda, Esq. (State Bar No. 217222) COLLECTION AT LAW, INC. A PROFESSIONAL LAW CORPORATION 3835 East Thousand Oaks Blvd., Suite R- 349 Westlake Village, California 91362 Phone Number (818) 716-7630 Facsimile (818) 716-7775 Attorney for Plaintiff ALAN M. GOLDBERG, Attorney At Law, ALAN M. GOLDBERG, Attorney At Law, ) Case No. LC106987 10 ) Plaintiff, NOTICE OF MOTION ANB MOTION ) TQ COMPEL INITIAL RKSPONSKS vs. } TO PLAINTIFF'S BISCQVKRY'KT 12 ) TWO - FARM INTERROGATORIES,; EUGENE SAAL, an individual; ARYEH ) BKCLARATION OF W)N 0. BLANBA 13 PATHI, an individual; PASCAL ) BRENNINKMEIJER, an individual; JUDY ) DATE: May 7, 2020 14 WEISS, an individual; and DOES 1 through ) TIME: 8:30AM 100, inclusive, DEPT: U 15 ) ) Defendant(s). } Reservation ID: 451109505028 ) ) ) 18 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 19 PLEASE TAKE NOTICE, that on May 7, 2020 at 8:30 A;M. in Dept. U of the above 20 captioned Court, located at 6230 Sylmar Ave., Van Nuys, CA 91401, ALAN M. GOLDBERG, 21 Attorney At Law, will move the Court to compel responses to the Form Interrogatories propounded on Defendant, EUGENE SAAL, an individual, pursuant to $$ 2030.230, 2030.260, 23 2030.290, 2031.260, 2031.300, 2033.010, 2033.020, 2033.250, 2033.280, and 2033.420 of the Code of Civil Procedure. This Motion will be based upon this Notice, the attached Declaration of JON O. 26 BLANDA, the Memorandum of Points and Authorities, the pleadings, records and files in this 27 action and such other oral and/or documentary evidence as may be presented at the time of the