On July 31, 2020 a
Motion-Secondary
was filed
involving a dispute between
Flores, Sergio Lee Andrew,
and
Jasper Auto Group, Inc.,
Kessenger, Ashley,
for Personal Injury Motor Vehicle Unlimited
in the District Court of San Bernardino County.
Preview
~~.
FAXED ~
Daniel P. Schrader (SBN 145670)
chr: Jaw.com
r@m;
Dane W. Schrader (SBN 317004) ny
IN REN A INARDING
IOP
dwschrader mgmlaw.com
MANNING GROSS + MASSENBURG LLP MAR 2 6 2093
201 Spear Street, 18" Floor
San Francisco, CA 94105
Tel:
Fax:
415.512.4381
415.512.6791
m Ace dade
Deputy
Attorneys for Defendants
ASHLEY KESSENGER and JASPER AUTO GROUP, INC.
dba VICTORVILLE HYUNDAI MAZDA
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 IN AND FOR THE COUNTY OF SAN BERNARDINO
11 SERGIO LEE ANDREW FLORES, Case No. CIVDS2015515
[Assigned to Hon. Donald Alvarez, Dept. S23]
12 Plaintiff,
DEFENDANTS ASHLEY KESSENGER
13 V. AND JASPER AUTO GROUP REPLY IN
SUPPORT OF MOTION TO COMPEL
14 ASHLEY KESSENGER; JASPER AUTO RESPONSES BY PLAINTIFF SERGIO
GROUP, INC.; and DOES 1 to 100, inclusive, LEE ANDREW FLORES TO SPECIAL
15 INTERROGATORIES, SET ONE AND
Defendants. REQUEST FOR MONETARY
16 SANCTIONS IN THE AMOUNT OF
$2,750.00
17
Date: April 5, 2021
18 Time: 9:00 a.m.
Dept.: $23
19
20 Date Filed: July 31, 2020
Trial Date: October 17, 2022
21
22
23 Defendants Ashley Kessenger and Jasper Auto Group, Inc. (collectively “Jasper”) respectfully
24 submit this Reply in support of its Motion to Compel Responses by Plaintiff Sergio Lee Andrew Flores
25 (‘Plaintiff’) to Special Interrogatories, Set One, and Request for Monetary Sanctions in the amount of
26 $2,750.00 against Plaintiff and his counsel of record, Jonathan Kashani, jointly and severally.
27 it
28 it
1
DEFENDANTS ASHLEY KESSENGER AND JASPER AUTO GROUP, INC. REPLY ISO MOTION TO COMPEL
RESPONSES BY PLAINTIFF SERGIO LEE ANDREW FLORES TO SPECIAL INTERROGATORIES, SET ONE
toby
Document Filed Date
March 26, 2021
Case Filing Date
July 31, 2020
Category
Personal Injury Motor Vehicle Unlimited
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~~. FAXED ~ Daniel P. Schrader (SBN 145670) chr: Jaw.com r@m; Dane W. Schrader (SBN 317004) ny IN REN A INARDING IOP dwschrader mgmlaw.com MANNING GROSS + MASSENBURG LLP MAR 2 6 2093 201 Spear Street, 18" Floor San Francisco, CA 94105 Tel: Fax: 415.512.4381 415.512.6791 m Ace dade Deputy Attorneys for Defendants ASHLEY KESSENGER and JASPER AUTO GROUP, INC. dba VICTORVILLE HYUNDAI MAZDA SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 IN AND FOR THE COUNTY OF SAN BERNARDINO 11 SERGIO LEE ANDREW FLORES, Case No. CIVDS2015515 [Assigned to Hon. Donald Alvarez, Dept. S23] 12 Plaintiff, DEFENDANTS ASHLEY KESSENGER 13 V. AND JASPER AUTO GROUP REPLY IN SUPPORT OF MOTION TO COMPEL 14 ASHLEY KESSENGER; JASPER AUTO RESPONSES BY PLAINTIFF SERGIO GROUP, INC.; and DOES 1 to 100, inclusive, LEE ANDREW FLORES TO SPECIAL 15 INTERROGATORIES, SET ONE AND Defendants. REQUEST FOR MONETARY 16 SANCTIONS IN THE AMOUNT OF $2,750.00 17 Date: April 5, 2021 18 Time: 9:00 a.m. Dept.: $23 19 20 Date Filed: July 31, 2020 Trial Date: October 17, 2022 21 22 23 Defendants Ashley Kessenger and Jasper Auto Group, Inc. (collectively “Jasper”) respectfully 24 submit this Reply in support of its Motion to Compel Responses by Plaintiff Sergio Lee Andrew Flores 25 (‘Plaintiff’) to Special Interrogatories, Set One, and Request for Monetary Sanctions in the amount of 26 $2,750.00 against Plaintiff and his counsel of record, Jonathan Kashani, jointly and severally. 27 it 28 it 1 DEFENDANTS ASHLEY KESSENGER AND JASPER AUTO GROUP, INC. REPLY ISO MOTION TO COMPEL RESPONSES BY PLAINTIFF SERGIO LEE ANDREW FLORES TO SPECIAL INTERROGATORIES, SET ONE toby