Motion,Ex Parte: NCP Eagle, LLC, a Delaware limited liability company -v- Delta Tech Industries LLC, a California Limited Liability Company et al Print

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                                BERRY SILBERBERG STOKES PC
     JOSHUA C. STOKES, State Bar No. 220214
     CAROL M. SILBERBERG, State Bar No. 21 7658
     11600 Washington Place, Suite 202C
     Los Angeles, CA 90066
     jstokes@berrysilberberg.com
     csilberberg@berrysilberberg.com


     Attorneys for Plaintiff NCP Eagle,    LLC                BY ’
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                         SUPERIOR COURT OF THE STATE OF CALIFORNIA                                   AXE

                             FOR THE COUNTY OF SAN BERNARDINO                                                  g


                                                        Case N0. CIVSB2126666
10    NCP EAGLE, LLC,          a Delaware limited
      liability   company,                              Assigned for   all   purposes t0 Dept. S30
11
                                                        The Honorable Brian        S.   McCarVille
                             Plaintiff,
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                                                        SEPARATE STATEMENT IN SUPPORT
13    VS.
                                                        0F MOTION To COMPEL
                                                        RESPONSES T0 DISCOVERY
14    DELTA TECH INDUSTRIES LLC, a                      REQUESTS
      California Limited Liability Company,
15    DURIMEX,     INC., a California corporation,      (DURIMEX FORM
      and   BOGDAN DURIAN, an individual,               INTERROGATORIES)
16
                             Defendants.
17                                                    Date:                  July 20, 2023
                                                      Time:                  8:30 a.m.
18                                                    Dept.:                 S30

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                                                      Action Filed:          September 13, 2021
20                                                    Trial Date:            May 6, 2024



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                              SEPARATE STATENIENT IN SUPPORT OF MOTION TO COMPEL
                                       (DURIMEX FORM INTERROGATORIES)
     TO PLAINTIFFS AND TO THEIR ATTORNEYS OF RECORD:
             PLEASE TAKE NOTICE that PlaintiffNCP                   Eagle,   LLC   (“Plaintiff”),   pursuant t0


     California Rule of Court 3.1345(a), hereby submits the following Separate Statement in Support


     of its Motion   t0   Compel. Following are the requests       for production    and the responses received,

     verbatim, and the reasons     why   obj ections should be overruled and further responses should be


     compelled.




     Sec. 4. Definitions


     Words   in   BOLDFACE CAPITALS            in these interrogatories are        defined   as follows:


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11   INCIDENT        means: The contracts referenced    in the     Complaint and attached       to the   Complaint as


12   Exhibits and Defendants” failure to pay the amounts outstanding under those agreements.


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14   YOU OR ANYONE ACTING ON YOUR BEHALF includes you, your agents, your
15   employees, your insurance companies, their agents, their employees, your attorneys, your

16   accountants, your investigators, and anyone else acting on your behalf.


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18   PERSON includes a natural person, firm, association, organization, partnership,                    business, trust,


19   limited liability    company, corporation, 0r public       entity.


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21   DOCUMENT means a writing, as defined in Evidence Code section 250, and includes the
22   original or a   copy of handwriting, typewriting,    printing, photostats, photographs, electronically


     stored information, and every other      means of recording upon any           tangible thing and form of
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24   communicating 0r representation, including        letters,    words, pictures, sounds, or symbols, 0r


25   combinations 0f them.

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27   ADDRESS means the street address,          including the city, state, and zip code.


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                             SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL
                                     (DURIMEX FORM INTERROGATORIES)