Party Discovery: MARLENE GARCIA ET AL VS ROBERT J OWIECKI ET AL

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 01/15/2019 12:19 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Lopez,Deputy Clerk




                         1      Teresa Li (Bar No. 278779)
                                teresa@lawofficesofteresali.com
                         2      LAW OFFICES OF TERESA LI, PC
                                5674 Stoneridge Dr. Suite 107
                         3      Pleasanton, California 94588
                                Telephone:     415.423.3377
                         4      Facsimile:     888.646.5493
                         5      Attorneys for Plaintiffs
                                MARLENE GARCIA and J.J.
                         6
                         7
                         8                                     SUPERIOR COURT OF THE STATE OF CALIFORNIA

                         9                                COUNTY OF LOS ANGELES - UNLIMITED JURISDICTION

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                       11       MARLENE GARCIA, and J.J., a minor, by                                      Case No. BC679114
                                and through his guardian ad litem,
                       12       MARLENE GARCIA,
                                                                                                           PLAINTIFFS’ NOTICE OF MOTION TO
                       13                                    Plaintiffs,                                   COMPEL SCHOOL DISTRICT’S
                                                                                                           EMPLOYEES FOR DEPOSITION
                       14                   v.
                                                                                                           Hearing Date:    2/20/2019
                       15       ROBERT J. OWIECKI, WHITTIER CITY                                           Hearing Time:    1:30 p.m.
                                SCHOOL DISTRICT, and DOES 1-20                                             Department:       3
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                                                             Defendants.                                   Courthouse:       Spring Street Courthouse
                       17                                                                                  Reservation No.: 464581238389

                       18                                                                                  JURY TRIAL DEMANDED

                       19                   TO EACH PARTY AND TO THE COUNSEL OF RECORD FOR EACH PARTY:

                       20                    YOU ARE HEREBY NOTIFIED THAT on February 20, 2019 at 1:30 pm in Department

                       21       3 of this Court Spring Street Courthouse, Plaintiffs MARLENE GARCIA, and J.J., a minor, by

                       22       and through his guardian ad litem, MARLENE GARCIA will move the Court for an order

                       23       compelling Defendant WHITTIER CITY SCHOOL DISTRICT produce its employees for

                       24       deposition and produce the documents requested in the subpoenas and deposition notices, all as

                       25       shown in the declaration of Teresa Li with this motion.

                       26                    Plaintiffs will also move the Court for an order that Defendant WHITTIER CITY

                       27       SCHOOL DISTRICT pay to the moving party the sum of $5,126 as the reasonable costs and

                       28       attorney fees incurred by Plaintiffs for these proceedings.

                                  PLAINTIFFS’ NOTICE OF MOTION TO COMPEL SCHOOL DISTRICT’S EMPLOYEES FOR DEPOSITION