On October 11, 2017 a
Party Discovery
was filed
involving a dispute between
Garcia Marlene,
and
Owiecki Robert J.,
Whittier City School District,
for civil
in the District Court of Los Angeles County.
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Electronically FILED by Superifir Court of California, County of Los Angeles on 12/03/2020 05:25 PM Sherri R. Carter, Executive Officer/Clerk of Court, by C. Cappadona,Deputy Clerk
LINDA S. BAUERMEISTER (S.B. #113321) EXEMPT FROM
ROBERT KOSTRENICH (S.B. #123370) FEES PURSUANT TO
OMAR SUBAT (S.B. # 307820 GOVERNMENT CODE §6103
LAW OFFICES OF BARBER & BAUERMEISTER
1551 N. Tustin Avenue, Suite 720
Santa Ana, California 92705
(714) 973-1075
(714) 973-1670 (fax)
Attorneys for Defendant,
ROBERT J. OWIECKI
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
10
11
MARLENE GARCIA, and J.J.,a minor, by) CASE NO. BC679114
12 and through his guardian ad litem,
MARLENE GARCIA Assigned for all purposes:
13 Honorable Lori Ann Fornier
Plaintiff, Dept. C
14
vs. SEPARATE STATEMENT IN SUPPORT
15 OF MOTION TO QUASH SUBPOENA
ROBERT J. OWIECKI, WHITTIER CITY (WHITTIER UNION HIGH SCHOOL)
16 SCHOOL DISTRICT, and DOES 1-20,
[Cal. Rules of Court, rule 3.1345]
17
Defendants. (Filed Concurrently with Motion for Order
18 Quashing Deposition Subpoena and for
Order Imposing Monetary Sanctions
19 against Plaintiffs )
20 DATE: March 25, 2021
TIME: 2:30 p.m.
21 DEPT: Cc
22 Reservation No.: 026639338421
23
TO THE CLERK OF THE COURT AND TO ALL ATTORNEYS OF RECORD HEREIN:
24
Moving Party, Defendant ROBERT J. OWIECKI (“Mr. Owiecki”), hereby submits his
25
Separate Statement of Issues as required by California Rules of Court Rule 3.1345.
26
This Separate Statement is required with a Motion to Compel or to Quash the Production of
27
Documents or Tangible Things at a Deposition." Cal. Rules of Court, rule 3.1345(a)(5).
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I\mrh\lopez\MotionToQuashLosNietoSepStmt.wpd 1
SEPARATE STATEMENT IN SUPPORT OF MOTION TO QUASH SUBPOENA
Document Filed Date
December 03, 2020
Case Filing Date
October 11, 2017
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Electronically FILED by Superifir Court of California, County of Los Angeles on 12/03/2020 05:25 PM Sherri R. Carter, Executive Officer/Clerk of Court, by C. Cappadona,Deputy Clerk LINDA S. BAUERMEISTER (S.B. #113321) EXEMPT FROM ROBERT KOSTRENICH (S.B. #123370) FEES PURSUANT TO OMAR SUBAT (S.B. # 307820 GOVERNMENT CODE §6103 LAW OFFICES OF BARBER & BAUERMEISTER 1551 N. Tustin Avenue, Suite 720 Santa Ana, California 92705 (714) 973-1075 (714) 973-1670 (fax) Attorneys for Defendant, ROBERT J. OWIECKI SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES 10 11 MARLENE GARCIA, and J.J.,a minor, by) CASE NO. BC679114 12 and through his guardian ad litem, MARLENE GARCIA Assigned for all purposes: 13 Honorable Lori Ann Fornier Plaintiff, Dept. C 14 vs. SEPARATE STATEMENT IN SUPPORT 15 OF MOTION TO QUASH SUBPOENA ROBERT J. OWIECKI, WHITTIER CITY (WHITTIER UNION HIGH SCHOOL) 16 SCHOOL DISTRICT, and DOES 1-20, [Cal. Rules of Court, rule 3.1345] 17 Defendants. (Filed Concurrently with Motion for Order 18 Quashing Deposition Subpoena and for Order Imposing Monetary Sanctions 19 against Plaintiffs ) 20 DATE: March 25, 2021 TIME: 2:30 p.m. 21 DEPT: Cc 22 Reservation No.: 026639338421 23 TO THE CLERK OF THE COURT AND TO ALL ATTORNEYS OF RECORD HEREIN: 24 Moving Party, Defendant ROBERT J. OWIECKI (“Mr. Owiecki”), hereby submits his 25 Separate Statement of Issues as required by California Rules of Court Rule 3.1345. 26 This Separate Statement is required with a Motion to Compel or to Quash the Production of 27 Documents or Tangible Things at a Deposition." Cal. Rules of Court, rule 3.1345(a)(5). 28 I\mrh\lopez\MotionToQuashLosNietoSepStmt.wpd 1 SEPARATE STATEMENT IN SUPPORT OF MOTION TO QUASH SUBPOENA