On March 03, 2022 a
Motion,Ex Parte
was filed
involving a dispute between
Reynoso, Jasmin,
and
Does 2 To 25,
Maragno, Billy Joe,
Maragno, William,
for Auto PI/PD/WD Unlimited
in the District Court of San Bernardino County.
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ORIGINAL
James M. Bejjani, Esq. [SBNz 310276]
HOMAN, STONE & ROSSI ATTORNEYS F l LE D
1461 Ford Street, Suite 201 SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
Redlands, CA 92373 SAN BERNARDINO DISTRICT
(909) 307-9380
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(909) 793-0210 - Fax Jun .13 2023
Attorneys for Defendant, BILLY JOE MARAGNO (”A-
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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FOR THE COUNTY OF SAN BERNARDINO
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11 JASMIN REYNOSO, Case No.1 CIVSB2204842 FAX
Unlimited Civil Jurisdiction
12 Plaintiff,
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DEFENDANT BILLY JOE MARAGNO’S BY
vs. NOTICE OF MOTION AND MOTION TO
14 COMPEL RESPONSES TO DISCOVERY
BILLY JOE MARAGNO, and DOES 1 through 25, AND FOR SANCTIONS; MEMORANDUM
15 inclusive, OF POINTS & AUTHORITIES; HLED
DECLARATION OF JAMES M. BEJJANI IN
16 Defendants. SUPPORT THEREOF
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Date: July 20, 2023
18 Time: 8:30 a.m.
Dept: $28
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[Assigned to Honorable Michael A. Sachs; Dept.
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S28]
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Trial Date: None Set
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23 TO PLAINTIFF, JASMIN REYNOSO, AND HER ATTORNEYS OF RECORD:
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PLEASE TAKE NOTICE that on July 20, 2023, in Department $28 of the San Bernardino
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Superior Court at 247 West Third Street, San Bernardino, California, 9241 5, Defendant, BILLY JOE
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MARAGNO (herein collectively referred to as “Defendant”), will move the Court for an Order
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DEFENDANT, BILLY JOE MARAGNO’S NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO
DISCOVERY; FOR IMPOSITION OF SANCTIONS; MEMORANDUM OF POINTS & AUTHORITIES;
DECLARATION OF JAMES M. BEJJANI IN SUPPORT THEREOF
compelling Plaintiff, JASMIN REYNOSO (“Plaintiff”) to provide responses to Defendant’s discovery
which includes Form Interrogatories, Request for Production of Documents, and Special Interrogatories,
and for the imposition of monetary sanctions pursuant to California Code of Civil Procedure, Section
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2023.030 (a) in the amount of $700.00 against Plaintiff JASMIN REYNOSO.
This Motion will be made on the ground that Plaintiff JASMIN REYNOSO has not provided any
responses to Defendant BILLY JOE MARAGNO’s discovery which includes Form Interrogatories, Set
One; Requests for Production of Documents, Set One; and Special Interrogatories, Set One served upon
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her, and that this failure to respond is willful pursuant to California Code ofCivil Procedure, Section
10 2023.010.
11 This Motion will be based on this notice, the pleadings, records and files herein, the
12 Memorandum of Points and Authorities, Declaration of James M. Bejj ani, and such oral and
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documentary evidence as may be presented at the hearing 0n this Motion.
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15 DATED: June 12, 2023 HOMAN, STONE & ROSSI ATTORNEYS
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19 James M. Bejjani, Esq.
Attorneys for Defendant, BILLY JOE MARAGNO
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DEFENDANT, BILLY JOE MARAGNO’S NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO
DISCOVERY; FOR IMPOSITION OF SANCTIONS; MEMORANDUM OF POINTS & AUTHORITIES;
DECLARATION OF JAMES M. BEJJANI TN SUPPORT THEREOF
Document Filed Date
June 13, 2023
Case Filing Date
March 03, 2022
Category
Auto PI/PD/WD Unlimited
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