On June 22, 2017 a
Party Discovery
was filed
involving a dispute between
Hernandez Julio,
and
Bmw Of North America Llc,
Nick Alexander Imports Dba Nick Alexander Bmw,
for Contract/Warranty Breach - Seller Plaintiff (no fraud/negligence) (General Jurisdiction)
in the District Court of Los Angeles County.
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© a m8
ORIGINAL
BOWMAN AND BROOKE LLP
Brian Takahashi (SBN: 146505
Richard L. Stuhlbarg (SBN: 180631
Theodore Dorenkamp III (SBN: 277004)
970° West 190th Street, Suite 700 FILED
Torrance, California 90502 Su rior Court of California
ounty of Los Angeles
Tel No: 310/ 768-3068
Fax No: 310/ 719-1019
MAR 21 2018
Attorneys for Defendants Shi Clerk
BMW OF NORTH AMERICA, LLC and By
NICK ALEXANDER IMPORTS d/b/a NICK ALEXANDER BM’ Deputy
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES -STANLEY MOSK
10
11 JULIO HERNANDEZ, CASE NO.: BC666145
12 Plaintiff, Assigned to: Hon. Joseph R. Kalin
Department: 74
13 vs.
BMW OF NORTH AMERICA, LLC'S
14 BMW OF NORTH AMERICA, LLC, a ) OPPOSITION TO PLAINTIFF'S MOTION
Delaware Limited Liability Company, TO COMPEL FURTHER RESPONSES TO.
15 NICK ALEXANDER IMPORTS, a REQUESTS FOR PRODUCTION FROM
16
California Corporation, d/b/a NICK
ALEXANDER BMW, and DOES 1
through 10, inclusive,
DEFENDANT BMW OF NORTH AMERICA,
LLC; REQUEST FOR MONETARY
SANCTIONS; MEMORANDUM OF POINTS
{ny}
17 AND AUTHORITIES; DECLARATION OF
<
Defendants. ARCENIO "ACE" CAMPOS; DECLARATION
18 OF THEODORE DORENKAMP III
19 Date: April 4, 2018
Time: 8:30
"74"
a.m.
20 Dept.:
21 Reservation ID: 171012258555
22 [Filed concurrently with BMW of North
America, LLC's Opposition to Plaintiffs
23 Separate Statement in Support of Motion to
Compel Further Responses to Requests for
228 Production from Defendant BMW of North
America, LLC]
0028
Action Filed: June 22, 2017
1526 Trial: July 30, 2018
“997
28
19233367v3 1
BMW OF NORTH AMERICA, LLC'S OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL FURTHER
RESPONSES TO REQUESTS FOR PRODUCTION FROM DEFENDANT BMW OF NORTH AMERICA,
LLC; REQUEST FOR MONETARY SANCTIONS; MEMORANDUM OF POINTS AND AUTHORITIES;
DECLARATION OF ARCENIO "ACE" CAMPOS; DECLARATION OF THEODORE DORENKAMP III
Document Filed Date
March 21, 2018
Case Filing Date
June 22, 2017
Category
Contract/Warranty Breach - Seller Plaintiff (no fraud/negligence) (General Jurisdiction)
Status
Jury Verdict 08/09/2019
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~——— © a m8 ORIGINAL BOWMAN AND BROOKE LLP Brian Takahashi (SBN: 146505 Richard L. Stuhlbarg (SBN: 180631 Theodore Dorenkamp III (SBN: 277004) 970° West 190th Street, Suite 700 FILED Torrance, California 90502 Su rior Court of California ounty of Los Angeles Tel No: 310/ 768-3068 Fax No: 310/ 719-1019 MAR 21 2018 Attorneys for Defendants Shi Clerk BMW OF NORTH AMERICA, LLC and By NICK ALEXANDER IMPORTS d/b/a NICK ALEXANDER BM’ Deputy SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES -STANLEY MOSK 10 11 JULIO HERNANDEZ, CASE NO.: BC666145 12 Plaintiff, Assigned to: Hon. Joseph R. Kalin Department: 74 13 vs. BMW OF NORTH AMERICA, LLC'S 14 BMW OF NORTH AMERICA, LLC, a ) OPPOSITION TO PLAINTIFF'S MOTION Delaware Limited Liability Company, TO COMPEL FURTHER RESPONSES TO. 15 NICK ALEXANDER IMPORTS, a REQUESTS FOR PRODUCTION FROM 16 California Corporation, d/b/a NICK ALEXANDER BMW, and DOES 1 through 10, inclusive, DEFENDANT BMW OF NORTH AMERICA, LLC; REQUEST FOR MONETARY SANCTIONS; MEMORANDUM OF POINTS {ny} 17 AND AUTHORITIES; DECLARATION OF < Defendants. ARCENIO "ACE" CAMPOS; DECLARATION 18 OF THEODORE DORENKAMP III 19 Date: April 4, 2018 Time: 8:30 "74" a.m. 20 Dept.: 21 Reservation ID: 171012258555 22 [Filed concurrently with BMW of North America, LLC's Opposition to Plaintiffs 23 Separate Statement in Support of Motion to Compel Further Responses to Requests for 228 Production from Defendant BMW of North America, LLC] 0028 Action Filed: June 22, 2017 1526 Trial: July 30, 2018 “997 28 19233367v3 1 BMW OF NORTH AMERICA, LLC'S OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL FURTHER RESPONSES TO REQUESTS FOR PRODUCTION FROM DEFENDANT BMW OF NORTH AMERICA, LLC; REQUEST FOR MONETARY SANCTIONS; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF ARCENIO "ACE" CAMPOS; DECLARATION OF THEODORE DORENKAMP III