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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1 Teresa Li (Bar No. 278779)
teresa@lawofficesofteresali.com
2 Xiong “Jackson” Zhou (Bar No. 278160)
jackson@lawofficesofteresali.com
3 LAW OFFICES OF TERESA LI, PC
5674 Stoneridge Dr. Suite 107
4 Pleasanton, California 94588
Telephone: 415.423.3377
5 Facsimile: 888.646.5493
6 Attorneys for Plaintiffs
MARLENE GARCIA and J.J.
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF LOS ANGELES - UNLIMITED JURISDICTION
10
11 MARLENE GARCIA, and J.J., a minor, by Case No. BC679114
and through his guardian ad litem,
12 MARLENE GARCIA,
EX PARTE APPLICATION TO COMPEL
13 Plaintiffs, DEPOSITION OF DEFENDANT ROBERT
OWIECKI AND SEEK SANCTIONS OR
14 v. ALTERNATIVELY FOR AN ORDER
SHORTENING TIME TO HEAR THE
15 ROBERT J. OWIECKI, WHITTIER CITY MOTION TO COMPEL
SCHOOL DISTRICT, and DOES 1-20
16 Hearing Date: March 4, 2019
Defendants. Hearing Time: 8:30 a.m.
17
Department: 3
18 Courthouse: Spring Street Courthouse
19
Action Filed: October 11, 2017
20 Trial Date: April 11, 2019
21
TO: ALL PARTIES AND THEIR ATTORNEY OF RECORD:
22
NOTICE IS HEREBY GIVEN that on March 4, 2019 at 8:30 a.m., or as soon thereafter as
23
the matter may be heard at the Los Angeles County Superior Court, Spring Street Courthouse,
24
located at 312 North Spring Street, Los Angeles, CA 90012, Plaintiffs MARLENE GARCIA, and
25
J.J., a minor, by and through his guardian ad litem, MARLENE GARCIA (“Garcia”), hereby
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apply an order to compel the deposition of Defendant Robert Owiecki and seek sanctions.
27
Alternatively, the Court should grant an order shortening time to hear the motion for
28
[PROPOSED] ORDER
Document Filed Date
March 04, 2019
Case Filing Date
October 11, 2017
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1 Teresa Li (Bar No. 278779) teresa@lawofficesofteresali.com 2 Xiong “Jackson” Zhou (Bar No. 278160) jackson@lawofficesofteresali.com 3 LAW OFFICES OF TERESA LI, PC 5674 Stoneridge Dr. Suite 107 4 Pleasanton, California 94588 Telephone: 415.423.3377 5 Facsimile: 888.646.5493 6 Attorneys for Plaintiffs MARLENE GARCIA and J.J. 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF LOS ANGELES - UNLIMITED JURISDICTION 10 11 MARLENE GARCIA, and J.J., a minor, by Case No. BC679114 and through his guardian ad litem, 12 MARLENE GARCIA, EX PARTE APPLICATION TO COMPEL 13 Plaintiffs, DEPOSITION OF DEFENDANT ROBERT OWIECKI AND SEEK SANCTIONS OR 14 v. ALTERNATIVELY FOR AN ORDER SHORTENING TIME TO HEAR THE 15 ROBERT J. OWIECKI, WHITTIER CITY MOTION TO COMPEL SCHOOL DISTRICT, and DOES 1-20 16 Hearing Date: March 4, 2019 Defendants. Hearing Time: 8:30 a.m. 17 Department: 3 18 Courthouse: Spring Street Courthouse 19 Action Filed: October 11, 2017 20 Trial Date: April 11, 2019 21 TO: ALL PARTIES AND THEIR ATTORNEY OF RECORD: 22 NOTICE IS HEREBY GIVEN that on March 4, 2019 at 8:30 a.m., or as soon thereafter as 23 the matter may be heard at the Los Angeles County Superior Court, Spring Street Courthouse, 24 located at 312 North Spring Street, Los Angeles, CA 90012, Plaintiffs MARLENE GARCIA, and 25 J.J., a minor, by and through his guardian ad litem, MARLENE GARCIA (“Garcia”), hereby 26 apply an order to compel the deposition of Defendant Robert Owiecki and seek sanctions. 27 Alternatively, the Court should grant an order shortening time to hear the motion for 28 [PROPOSED] ORDER