On April 05, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
and
for Guardianship of Person Only
in the District Court of San Bernardino County.
Preview
V V
id
SUPERvon CéURT 0F CALIFORNIA
SBN 222695
Loni Klein, Esq. coum 0F SAN BERNARDmo
A CENTER FOR CHILDREN & FAMILY LAW SAN Rr‘mmuwo DISTRICT
1 1 1 1 W. Chapman Ave.
MAR 2 5 n 7
CA 92868 2u2-
4m
Orange,
(714) 937-1234
I, 4
'
BY
Attorney for Petitioners AMY’GAMEfi-REYEE’DEPUTY
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
IN RE GUARDIANSHIP 0F: ) CASE No. GARPszl 00134
10 ) EX PARTE APPLICATION
) REGARDING
ll OLIVER ORION HUYNH ) MOTION To COMPEL
) MOTHER To RESPOND T0
12 A minor. ) DEMAND FOR PRODUCTION 0F
13 ) DOCUMENTS FOR INSPECTION AND
) PHOTOCOPYING [CCP 2031 ET SEQ],
l4 ) AND SPECIALLY PREPARED
SET ONE,
‘71}
E“
‘ ) INTERROGATORIES
c“.
1-.)
l5
m
v
x_l
l6 g DATE: APR 0 5 2022
o O "4"
Rifvev" §
) TIME: i
l I
L”
figs“,
l7 ) DEPT: 53% 53; g;
)
18
l9
TO THE ABOVE-ENTITLED COURT, AND ALL OTHER INTERESTED PARTIES
20
AND THEIR RESPECTIVE COUNSEL:
21
22
Through their attorney, LONI KLEIN, Petitioners MIKE AND KIM RHYMER seek an
23 EX PARTE APPLICATION for the following orders:
24
1. The Motion to Compel filed on March 2, 2022 be granted via an ex part6 request
25
and for Mother t0 produce her documents, without objection within 10 days’ of
26
the court’s order.
27
28 2. The discovery cut off date be extended to the day of trial, June 1, 2022 to allow
EX PARTE APPLICATION REGARDING MOTION TO COMPEL MOTHER TO RESPOND
TO DISCOVERY — Page 1 of 4
V \d
Petitioners’ counsel to obtain discovery documents including subpoenaed
documents.
Or in the alternative, an order shortening time for the Motion t0 Compel t0 be
heard as soon as possible before the currently set date 0f April
28, 2022.
BASIS FOR ORDER
On March 2, 2022 Petitioners submitted a Motion to Compel to the court for filing
The Motion was processed 0n or about March 18, 2022 and the documents were
received by Petitioner’s counsel on March 21, 2022. On March 21 2022 , the Motion
10
t0 Compel was served via email and mail to Father’s counsel and to Mother. The
ll
hearing on the Motion to Compel is set for April 28, 2022. Even if the court
12 grants
l3 the order 0n April 28, 2022, the deadline for production will be by May 2022.
8,
14 Due to the discovery cut off in California Code 0f Civil Procedure Section
15
2024.020, Petitioners will be precluded from issuing any subpoenas to
any entities
l6
that are discovered though the parents’ response to the discovery request.
l7
Therefore, Petitioners are requesting the Motion t0 Compel be heard
18 via Ex Parte
l9 to ensure a sooner production date and to allow for subpoenas to be issued as
soon
20 as possible. The court on January 11, 2022 indicated if there are any issues
21
regarding discovery an ex parte may be sought.
22
. Furthermore, Petitioners are requesting the discovery cut offin this matter
pursuant
23
24
to California Code of Civil Procedure Section 2024.020, be extended to June 1,
25 2022 to allow for Petitioners t0 obtain documents Via subpoena. There is also a tn'a]
26
readiness conference set for May 17, 2022. The current discovery cut off date is
27
May 2, 2022.
28
4. In the alternative, Petitioners request the Motion to Compel be heard as soon as
EX PARTE APPLICATION REGARDING MOTION TO COMPEL MOTHER TO RESPOND
TO DISCOVERY -
Page 2 of 4
Document Filed Date
March 25, 2022
Case Filing Date
April 05, 2021
Category
Guardianship of Person Only
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V V id SUPERvon CéURT 0F CALIFORNIA SBN 222695 Loni Klein, Esq. coum 0F SAN BERNARDmo A CENTER FOR CHILDREN & FAMILY LAW SAN Rr‘mmuwo DISTRICT 1 1 1 1 W. Chapman Ave. MAR 2 5 n 7 CA 92868 2u2- 4m Orange, (714) 937-1234 I, 4 ' BY Attorney for Petitioners AMY’GAMEfi-REYEE’DEPUTY SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO IN RE GUARDIANSHIP 0F: ) CASE No. GARPszl 00134 10 ) EX PARTE APPLICATION ) REGARDING ll OLIVER ORION HUYNH ) MOTION To COMPEL ) MOTHER To RESPOND T0 12 A minor. ) DEMAND FOR PRODUCTION 0F 13 ) DOCUMENTS FOR INSPECTION AND ) PHOTOCOPYING [CCP 2031 ET SEQ], l4 ) AND SPECIALLY PREPARED SET ONE, ‘71} E“ ‘ ) INTERROGATORIES c“. 1-.) l5 m v x_l l6 g DATE: APR 0 5 2022 o O "4" Rifvev" § ) TIME: i l I L” figs“, l7 ) DEPT: 53% 53; g; ) 18 l9 TO THE ABOVE-ENTITLED COURT, AND ALL OTHER INTERESTED PARTIES 20 AND THEIR RESPECTIVE COUNSEL: 21 22 Through their attorney, LONI KLEIN, Petitioners MIKE AND KIM RHYMER seek an 23 EX PARTE APPLICATION for the following orders: 24 1. The Motion to Compel filed on March 2, 2022 be granted via an ex part6 request 25 and for Mother t0 produce her documents, without objection within 10 days’ of 26 the court’s order. 27 28 2. The discovery cut off date be extended to the day of trial, June 1, 2022 to allow EX PARTE APPLICATION REGARDING MOTION TO COMPEL MOTHER TO RESPOND TO DISCOVERY — Page 1 of 4 V \d Petitioners’ counsel to obtain discovery documents including subpoenaed documents. Or in the alternative, an order shortening time for the Motion t0 Compel t0 be heard as soon as possible before the currently set date 0f April 28, 2022. BASIS FOR ORDER On March 2, 2022 Petitioners submitted a Motion to Compel to the court for filing The Motion was processed 0n or about March 18, 2022 and the documents were received by Petitioner’s counsel on March 21, 2022. On March 21 2022 , the Motion 10 t0 Compel was served via email and mail to Father’s counsel and to Mother. The ll hearing on the Motion to Compel is set for April 28, 2022. Even if the court 12 grants l3 the order 0n April 28, 2022, the deadline for production will be by May 2022. 8, 14 Due to the discovery cut off in California Code 0f Civil Procedure Section 15 2024.020, Petitioners will be precluded from issuing any subpoenas to any entities l6 that are discovered though the parents’ response to the discovery request. l7 Therefore, Petitioners are requesting the Motion t0 Compel be heard 18 via Ex Parte l9 to ensure a sooner production date and to allow for subpoenas to be issued as soon 20 as possible. The court on January 11, 2022 indicated if there are any issues 21 regarding discovery an ex parte may be sought. 22 . Furthermore, Petitioners are requesting the discovery cut offin this matter pursuant 23 24 to California Code of Civil Procedure Section 2024.020, be extended to June 1, 25 2022 to allow for Petitioners t0 obtain documents Via subpoena. There is also a tn'a] 26 readiness conference set for May 17, 2022. The current discovery cut off date is 27 May 2, 2022. 28 4. In the alternative, Petitioners request the Motion to Compel be heard as soon as EX PARTE APPLICATION REGARDING MOTION TO COMPEL MOTHER TO RESPOND TO DISCOVERY - Page 2 of 4