On April 05, 2021 a
Party Discovery
was filed
involving a dispute between
and
for Guardianship of Person Only
in the District Court of San Bernardino County.
Preview
..
MAR/lB/ZUZZ/WED 08:46 AM Center for Children FAX No. 7145164785 P. 007
SUPERIOR COURT E
F L 5 D
COUNTY 0F SAN 0F CALIF
BERNARDOISg'A
SAN BERNARDmn
msmrcr
Loni Klein, Esq. SBN 222695 MAR 0 2 2027
A CENTER FOR CHLDREN &. FAMILY LAW ~
1111 W. Chapman Ave. ,,
‘
Orange, CA 92868 q
L \
.. _ _
,_‘ -
NW
b
.:_
V
(714) 937-1234 9%“3 Rizfifié‘fififi
Attorney for Petitionem
SUPERIOR COURT OF TIE STATE 0F CALIFORNIA
FOR THE COUNTY 0F SAN BERNARDINO
1N RE GUARDLANSHIP OF: CASE No. GARP52100134
10
OLIVER. ORION HUY'NH Mono»: To COMPEL
11 MOTHER To RESPOND To
A minor. DEMAND FOR PRODUCTION OF
12
DOCUMENTS FOR INSPECTION AND
13 VVVVVVVVVVVVV
PHOTOCOPYING [cop 2031 ET SEQ],
SET ONE, AND SPECLALLY PREPARED
14 INTERROGATORIES
15
DATE: L4 (28 IZZ
15 TIME: l
1"0 O
DEPT:
17 S 3v
18 TO TIE ABOVE-ENTITLED COURT, AND ALL OTIER WTERESTED PARTIES
19
AND TIEIR RESPECTIVE COUNSEL:
20
21
Through their attorney, LON! KLEIN, Petitioners WE AND KIM RHYWR seek
22
an order mquesting tho following to compel:
23 1. Mother Genniva Le Braga to respond to the Demand ofProduction ofDocuments
24
for Inspection and Photocopying and Specially Prepared Interrogatories served
25
on her within 10 days ofthis Court’s order,
26
2. Mother Genniva Le Braga’s responses to be complete without objection, and
27
28 3. Mother Gemiva Le Braga to pay attorney fees. costs and sanctions in the amount
MOTION TO COMPEL MOTl-ER T0 RESPOND TO DISCOVERY - Page 1 of 4
. MAR/15/2022/WED 08:46 AM Center for Children FAX N0. 714*515'9785 P. 008
of $2,500.00 forthwith for Petitioners for having to bring this Motion.
1. Petitioners filed their Petition for Guardianship of the minor Oliver Orion Huynh
on April 5, 2021. On August 23, 2021 Mother Genniva Le Braga filed an objection to the
guardianship and her address in the caption of the objection pleading is 15351 Purdy Street,
Westminster, CA 92863. Mother was in pro per when filing her objection and remains so at this
time.
2. On November 3, 2021 Pctitioners’ counsel served a Demand for Production oi
10
Documents and Spccially Prepared Interrogatories on Mother via mail to 15351 Purdy Street,
ll
Westminster, CA 92863. Please Demand attached as Exhibit "A” to the concurrently filed
12
Memorandum of Points and Authorities. Please see Specially Prepared Interrogatories attached aa
14 Exhibit “B to the concurrently filed Memorandum of Points and Authorities. Please see Proof oi
15 “C”
Service attached as Exhibit to the concurrently filed Memorandum of Points and Authorities
16
The Demand and Specially Prepared Inten‘ogatories propounded on Mother ware sent both to
21.7
18
Mother and to Father’s counsel as required by CCP Sections 2030.080 and 2031.040. Please see
19 Exhibit “C.” It is Petitioners’ understanding that Mothcr and Father are in a relationship and live
20 together.
21
3. The due date for the Demand and Specially Prepared Interrogatories was
December 8, 2021. No response was received or any communication received from Mother. 0n
23
December 16, 2021 Petitioners’ counsel sent the first meet and confer letter to Mother to produce
24
25 her responses to the discovery requests. Please see letter attached as Exhibit “D” to thJ
26
concurrently filed Memorandum of Points and Authorities. No response was received. On January
2'7
10, 2022 Petitioners' counsel followed up again and requested Mother respond to the discovery
28
requests in a second meet and confer letter. Please see letter attached as Exhibit “E” to the
MOTION TO COMPEL MOTI-ER T0 RESPOND T0 DISCOVERY — Page 2 of 4
Document Filed Date
March 02, 2022
Case Filing Date
April 05, 2021
Category
Guardianship of Person Only
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.. MAR/lB/ZUZZ/WED 08:46 AM Center for Children FAX No. 7145164785 P. 007 SUPERIOR COURT E F L 5 D COUNTY 0F SAN 0F CALIF BERNARDOISg'A SAN BERNARDmn msmrcr Loni Klein, Esq. SBN 222695 MAR 0 2 2027 A CENTER FOR CHLDREN &. FAMILY LAW ~ 1111 W. Chapman Ave. ,, ‘ Orange, CA 92868 q L \ .. _ _ ,_‘ - NW b .:_ V (714) 937-1234 9%“3 Rizfifié‘fififi Attorney for Petitionem SUPERIOR COURT OF TIE STATE 0F CALIFORNIA FOR THE COUNTY 0F SAN BERNARDINO 1N RE GUARDLANSHIP OF: CASE No. GARP52100134 10 OLIVER. ORION HUY'NH Mono»: To COMPEL 11 MOTHER To RESPOND To A minor. DEMAND FOR PRODUCTION OF 12 DOCUMENTS FOR INSPECTION AND 13 VVVVVVVVVVVVV PHOTOCOPYING [cop 2031 ET SEQ], SET ONE, AND SPECLALLY PREPARED 14 INTERROGATORIES 15 DATE: L4 (28 IZZ 15 TIME: l 1"0 O DEPT: 17 S 3v 18 TO TIE ABOVE-ENTITLED COURT, AND ALL OTIER WTERESTED PARTIES 19 AND TIEIR RESPECTIVE COUNSEL: 20 21 Through their attorney, LON! KLEIN, Petitioners WE AND KIM RHYWR seek 22 an order mquesting tho following to compel: 23 1. Mother Genniva Le Braga to respond to the Demand ofProduction ofDocuments 24 for Inspection and Photocopying and Specially Prepared Interrogatories served 25 on her within 10 days ofthis Court’s order, 26 2. Mother Genniva Le Braga’s responses to be complete without objection, and 27 28 3. Mother Gemiva Le Braga to pay attorney fees. costs and sanctions in the amount MOTION TO COMPEL MOTl-ER T0 RESPOND TO DISCOVERY - Page 1 of 4 . MAR/15/2022/WED 08:46 AM Center for Children FAX N0. 714*515'9785 P. 008 of $2,500.00 forthwith for Petitioners for having to bring this Motion. 1. Petitioners filed their Petition for Guardianship of the minor Oliver Orion Huynh on April 5, 2021. On August 23, 2021 Mother Genniva Le Braga filed an objection to the guardianship and her address in the caption of the objection pleading is 15351 Purdy Street, Westminster, CA 92863. Mother was in pro per when filing her objection and remains so at this time. 2. On November 3, 2021 Pctitioners’ counsel served a Demand for Production oi 10 Documents and Spccially Prepared Interrogatories on Mother via mail to 15351 Purdy Street, ll Westminster, CA 92863. Please Demand attached as Exhibit "A” to the concurrently filed 12 Memorandum of Points and Authorities. Please see Specially Prepared Interrogatories attached aa 14 Exhibit “B to the concurrently filed Memorandum of Points and Authorities. Please see Proof oi 15 “C” Service attached as Exhibit to the concurrently filed Memorandum of Points and Authorities 16 The Demand and Specially Prepared Inten‘ogatories propounded on Mother ware sent both to 21.7 18 Mother and to Father’s counsel as required by CCP Sections 2030.080 and 2031.040. Please see 19 Exhibit “C.” It is Petitioners’ understanding that Mothcr and Father are in a relationship and live 20 together. 21 3. The due date for the Demand and Specially Prepared Interrogatories was December 8, 2021. No response was received or any communication received from Mother. 0n 23 December 16, 2021 Petitioners’ counsel sent the first meet and confer letter to Mother to produce 24 25 her responses to the discovery requests. Please see letter attached as Exhibit “D” to thJ 26 concurrently filed Memorandum of Points and Authorities. No response was received. On January 2'7 10, 2022 Petitioners' counsel followed up again and requested Mother respond to the discovery 28 requests in a second meet and confer letter. Please see letter attached as Exhibit “E” to the MOTION TO COMPEL MOTI-ER T0 RESPOND T0 DISCOVERY — Page 2 of 4