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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@ ORIGINAL
KNIGHT LAW GROUP, LLP
Steve Mikhov (SBN 224676) FILED
rior Court of Callfomia
Daniel Kalinowski (SBN 305087) ‘Ountv of Fas Annale s
1801 Century Park East, Suite 2300
Los Angeles, CA 90067 OCT 13 2017
Tel.: (310) 552-2250 Sherri R, 7
Fax: (310) 552-7973 By, Wve Officen/Clerk
Depury
Attorneys for Plaintiff,
JULIO HERNANDEZ
SUPERIOR COURT OF CALIFORNIA
COUNTY OF LOS ANGELES
10
JULIO HERNANDEZ, Case No.: BC666145
11 Unlimited Jurisdiction
Action Filed: June 22, 2017
12 Plaintiff,
PLAINTIFF’S SEPARATE
13
VS. STATEMENT IN SUPPORT OF
MOTION TO COMPEL FURTHER
RESPONSES TO REQUESTS FOR
BMW OF NORTH AMERICA, LLC, a PRODUCTION FROM
15 BMW OF NORTH AMERICA, LLC
Delaware Limited Liability Company; NICK
ALEXANDER IMPORTS, a California Submitted concurrently with Notice of
16 Corporation, d/b/a NICK ALEXANDER Motion, Memorandum of Points and
17 BMW, and DOES 1 through 10, inclusive, Authorities in Support of Motion,
Declaration of Daniel Kalinowski in
Defendant. Support of Motion, and Proposed Order
18
19 Hearing Date: April 4, 2018
Hearing Time: 8:30 A.M.
20
Department: 74
21 Reservation: 171012258555
22
23
24 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
25 Plaintiff, JULIO HERNANDEZ, submits the following Separate Statement in support of
26 her Motion to Compel Further Responses from Defendant BMW OF NORTH AMERICA, LLC
ee 27 regarding Plaintiff's First Set of Requests for Production:
=
i 28
od
Ro
2
o.*
ro
wd SEPARATE STATEMENT IN SUPPORT OF PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES-
REQUESTS FOR PRODUCTION
Document Filed Date
October 13, 2017
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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@ ORIGINAL KNIGHT LAW GROUP, LLP Steve Mikhov (SBN 224676) FILED rior Court of Callfomia Daniel Kalinowski (SBN 305087) ‘Ountv of Fas Annale s 1801 Century Park East, Suite 2300 Los Angeles, CA 90067 OCT 13 2017 Tel.: (310) 552-2250 Sherri R, 7 Fax: (310) 552-7973 By, Wve Officen/Clerk Depury Attorneys for Plaintiff, JULIO HERNANDEZ SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES 10 JULIO HERNANDEZ, Case No.: BC666145 11 Unlimited Jurisdiction Action Filed: June 22, 2017 12 Plaintiff, PLAINTIFF’S SEPARATE 13 VS. STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO REQUESTS FOR BMW OF NORTH AMERICA, LLC, a PRODUCTION FROM 15 BMW OF NORTH AMERICA, LLC Delaware Limited Liability Company; NICK ALEXANDER IMPORTS, a California Submitted concurrently with Notice of 16 Corporation, d/b/a NICK ALEXANDER Motion, Memorandum of Points and 17 BMW, and DOES 1 through 10, inclusive, Authorities in Support of Motion, Declaration of Daniel Kalinowski in Defendant. Support of Motion, and Proposed Order 18 19 Hearing Date: April 4, 2018 Hearing Time: 8:30 A.M. 20 Department: 74 21 Reservation: 171012258555 22 23 24 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 25 Plaintiff, JULIO HERNANDEZ, submits the following Separate Statement in support of 26 her Motion to Compel Further Responses from Defendant BMW OF NORTH AMERICA, LLC ee 27 regarding Plaintiff's First Set of Requests for Production: = i 28 od Ro 2 o.* ro wd SEPARATE STATEMENT IN SUPPORT OF PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES- REQUESTS FOR PRODUCTION