On February 10, 2023 a
Party Discovery
was filed
involving a dispute between
Saenz Cortez Jr., Luis,
and
Does 1 Through 100, Inclusive,
Mendez, Arturo,
for Auto PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
F l L E
SUPERIOR COURT OF CALIFORNIA
D
MELISSA M- THOM (SBN 189300) COUNTY op SAN BERNARDINO
SAN BERNARDWO Dusmucw
MASTAGNI HOLSTEDT, APC
19IZIStreet
MAY 262023
Sacramento, California 95811
Telephone: (916) 446-4692
Facsimile: (916) 447-4614
W I t
YST L K‘ D'AM'CQ DEPUTY
Email: Mthom@mastagni.com
Attorneys for Plaintiff,
\OOONONUI-b
LUIS SAENZ CORTEZ, JR.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO
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11
LUIS SAENZ CORTEZ, JR., Case No.2 CIVSB2300604
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Plaintiff,
PLAINTIFF’S NOTICE OF MOTION AND
13
VS.
MOTION TO COMPEL DEFENDANT TO
PROVIDE RESPONSES TO FORM
14 INTERROGATORIES, SET ONE;
ARTURO MENDEZ; and DOES 1 through
15
100, inclusive, MEMORANDUM 0F POINTS AND
AUTHORITIES IN SUPPORT THEREOF;
Defendants- AND SUPPORTING DECLARATION 0F
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MELISSA M. THOM; AND FOR
17 SANCTIONS AGAINST DEFENDANT
18
$190 6W MU)
DATE: August 16, 2023
19 TIME: 8:30 am.
DEPT.: 824
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21
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TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
23
PLEASE TAKE NOTICE that on August 16, 2023, at 8:30 a.m., or as soon thereafter as
24 the matter may be heard in Department No. $24 of the San Bernardino County Superior Court
25 located at 247 West 3rd Street, San Bernardino, CA 92415, Plaintiff LUIS SAENZ CORTEZ,
26 JR., will and hereby does move this Court for an order compelling Defendant ARTURO
27 MENDEZ to serve responses to Plaintiff’s Form Interrogatories, Set One, served on Defendant
28
Page 1 of 2
NOTICE OF MOTION TO COMPEL RESPONSE TO FORM INTERROGATORIES
\r \r
on March 13, 2023. Additionally, Plaintiff intends to seek monetary sanctions in the amount of
$2,160 against Defendant ARTURO MENDEZ.
This motion to compel answers is brought pursuant to Code of Civil Procedure California
Code of Civil Procedure §§ 2030.210, 2030.290(b), on the gounds that the responding party has
failed, without justification, to Serve any response to these discovery requests.
NOTICE IS FURTHER GIVEN that Plaintiff LUIS SAENZ CORTEZ, JR. will request
that the Court award monetaIy sanctions against Defendant ARTURO MENDEZ and in favor of
Plaintiff in the amount of $2,160 pursuant to Code of Civil Procedure §§ 2023.010(d), 2023.030,
2030.290(c), and California Rules of Court, Rule 3.1348.
10 This motion is further based upon this Notice of Motion; the attached Memorandum of
11 Points and Authorities; the Declaration of Melissa M. Thom; and the Proposed Order; a1]
12 concurrently filed herewith, the papers, records, and files of this action; and any evidence
13 presented at the hearing of the motion. No separate statement has been filed pursuant to
14 California Rules of Court, Rule 3.1345(b)(1).
15
DATED: May 25, 2023 MASTAGNI HOLSTEDT, A.P.C.
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WWW
MELISSA M. THOM
Attorney for Plaintiff LUIS SAENZ
CORTEZ, JR.
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Page 2 of 2
NOTICE OF MOTION TO COMPEL RESPONSE TO FORM INTERROGATORIES
Document Filed Date
May 26, 2023
Case Filing Date
February 10, 2023
Category
Auto PI/PD/WD Unlimited
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F l L E SUPERIOR COURT OF CALIFORNIA D MELISSA M- THOM (SBN 189300) COUNTY op SAN BERNARDINO SAN BERNARDWO Dusmucw MASTAGNI HOLSTEDT, APC 19IZIStreet MAY 262023 Sacramento, California 95811 Telephone: (916) 446-4692 Facsimile: (916) 447-4614 W I t YST L K‘ D'AM'CQ DEPUTY Email: Mthom@mastagni.com Attorneys for Plaintiff, \OOONONUI-b LUIS SAENZ CORTEZ, JR. SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO 10 11 LUIS SAENZ CORTEZ, JR., Case No.2 CIVSB2300604 12 Plaintiff, PLAINTIFF’S NOTICE OF MOTION AND 13 VS. MOTION TO COMPEL DEFENDANT TO PROVIDE RESPONSES TO FORM 14 INTERROGATORIES, SET ONE; ARTURO MENDEZ; and DOES 1 through 15 100, inclusive, MEMORANDUM 0F POINTS AND AUTHORITIES IN SUPPORT THEREOF; Defendants- AND SUPPORTING DECLARATION 0F 16 MELISSA M. THOM; AND FOR 17 SANCTIONS AGAINST DEFENDANT 18 $190 6W MU) DATE: August 16, 2023 19 TIME: 8:30 am. DEPT.: 824 20 21 22 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 23 PLEASE TAKE NOTICE that on August 16, 2023, at 8:30 a.m., or as soon thereafter as 24 the matter may be heard in Department No. $24 of the San Bernardino County Superior Court 25 located at 247 West 3rd Street, San Bernardino, CA 92415, Plaintiff LUIS SAENZ CORTEZ, 26 JR., will and hereby does move this Court for an order compelling Defendant ARTURO 27 MENDEZ to serve responses to Plaintiff’s Form Interrogatories, Set One, served on Defendant 28 Page 1 of 2 NOTICE OF MOTION TO COMPEL RESPONSE TO FORM INTERROGATORIES \r \r on March 13, 2023. Additionally, Plaintiff intends to seek monetary sanctions in the amount of $2,160 against Defendant ARTURO MENDEZ. This motion to compel answers is brought pursuant to Code of Civil Procedure California Code of Civil Procedure §§ 2030.210, 2030.290(b), on the gounds that the responding party has failed, without justification, to Serve any response to these discovery requests. NOTICE IS FURTHER GIVEN that Plaintiff LUIS SAENZ CORTEZ, JR. will request that the Court award monetaIy sanctions against Defendant ARTURO MENDEZ and in favor of Plaintiff in the amount of $2,160 pursuant to Code of Civil Procedure §§ 2023.010(d), 2023.030, 2030.290(c), and California Rules of Court, Rule 3.1348. 10 This motion is further based upon this Notice of Motion; the attached Memorandum of 11 Points and Authorities; the Declaration of Melissa M. Thom; and the Proposed Order; a1] 12 concurrently filed herewith, the papers, records, and files of this action; and any evidence 13 presented at the hearing of the motion. No separate statement has been filed pursuant to 14 California Rules of Court, Rule 3.1345(b)(1). 15 DATED: May 25, 2023 MASTAGNI HOLSTEDT, A.P.C. 16 17 18 19 WWW MELISSA M. THOM Attorney for Plaintiff LUIS SAENZ CORTEZ, JR. 20 21 22 23 24 25 26 27 28 Page 2 of 2 NOTICE OF MOTION TO COMPEL RESPONSE TO FORM INTERROGATORIES