On November 04, 2015 a
Motion-Secondary
was filed
involving a dispute between
Jenkins William Iv,
and
Arguelles Jennifer Monet,
for civil
in the District Court of Los Angeles County.
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LAW OFFICES OF TIMOTHY J. O'SHEA FILED O
By: Sophia Kuo Tiong-- Bar No. 290200
Attorneys At Law
Bonn oun of On!
vat tos Anneke es
505 N. Brand Blvd., Ste. 210
Glendale, CA 91203 OCT 19 2017
Attorneys & Support Staff are Employees of Sherri Carie: xe@cuuve Ulticer/Cletk
GEICO Staff Counsel Department Depu
By.
Rau! Sanchez
Telephone: (818) 956-9100
Fax: (818) 956-9191
Attorneys for Defendant, JENNIFER ARGUELLES
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
10
UNLIMITED CIVIL
11 CASE NO. BC600190
WILLIAM JENKINS, IV, AN INDIVIDUAL,
12 DEFENDANT’S OPPOSITION TO
PLAINTIFF, PLAINTIFF'S MOTION TO
13 RECOVER COST OF PROOF
14 VS. SANCTIONS PURSUANT TO C.CP.
SECTION 2033.420; DECLARATION
15 JENNIFER MONET ARGUELLES, AN OF SOPHIA KUO TIONG
INDIVIDUAL, AND DOES 1 TO 20,
16 INCLUSIVE., Date: November 2, 2017
Time: 8:30AM
17 DEFENDANTS. Department: 41
Assigned to Honorable Stephen Moloney|
18
19 DEFENDANT JENNIFER MONET ARGUELLES (“Defendant”) submits the following
20 Memorandum of Points and Authorities in Opposition to Plaintiff, William Jenkins, IV’s Motion
21 to Recover Cost of Proof Sanctions Pursuant to California Code of Civil Procedure § 2033.420.
22 MEMORANDUM OF POINTS AND AUTHORITIES
23 1. Introduction
24 Plaintiff William Jenkins, IV (“Plaintiff”) is not entitled to cost of proof sanctions as
25 California Code of Civil Procedure § 2033.420(a) provides Defendant’s denials must be excused)
26 if the Court finds any of the following:
27 (1) An objection to the request was sustained or a response to it was waived under
Section 2033.290;
28 (2) The Admission sought was of no substantial importance;
Page |
DEFENDANT’S OPPOSITION TO PLAINTIFF'S MOTION TO RECOVER COST OF PROOF SANCTIONS
PURSUANT TO C.C.P. SECTION 2033.420
Document Filed Date
October 19, 2017
Case Filing Date
November 04, 2015
Status
Legacy Judgment 09/12/2017
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@ @ LAW OFFICES OF TIMOTHY J. O'SHEA FILED O By: Sophia Kuo Tiong-- Bar No. 290200 Attorneys At Law Bonn oun of On! vat tos Anneke es 505 N. Brand Blvd., Ste. 210 Glendale, CA 91203 OCT 19 2017 Attorneys & Support Staff are Employees of Sherri Carie: xe@cuuve Ulticer/Cletk GEICO Staff Counsel Department Depu By. Rau! Sanchez Telephone: (818) 956-9100 Fax: (818) 956-9191 Attorneys for Defendant, JENNIFER ARGUELLES SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES 10 UNLIMITED CIVIL 11 CASE NO. BC600190 WILLIAM JENKINS, IV, AN INDIVIDUAL, 12 DEFENDANT’S OPPOSITION TO PLAINTIFF, PLAINTIFF'S MOTION TO 13 RECOVER COST OF PROOF 14 VS. SANCTIONS PURSUANT TO C.CP. SECTION 2033.420; DECLARATION 15 JENNIFER MONET ARGUELLES, AN OF SOPHIA KUO TIONG INDIVIDUAL, AND DOES 1 TO 20, 16 INCLUSIVE., Date: November 2, 2017 Time: 8:30AM 17 DEFENDANTS. Department: 41 Assigned to Honorable Stephen Moloney| 18 19 DEFENDANT JENNIFER MONET ARGUELLES (“Defendant”) submits the following 20 Memorandum of Points and Authorities in Opposition to Plaintiff, William Jenkins, IV’s Motion 21 to Recover Cost of Proof Sanctions Pursuant to California Code of Civil Procedure § 2033.420. 22 MEMORANDUM OF POINTS AND AUTHORITIES 23 1. Introduction 24 Plaintiff William Jenkins, IV (“Plaintiff”) is not entitled to cost of proof sanctions as 25 California Code of Civil Procedure § 2033.420(a) provides Defendant’s denials must be excused) 26 if the Court finds any of the following: 27 (1) An objection to the request was sustained or a response to it was waived under Section 2033.290; 28 (2) The Admission sought was of no substantial importance; Page | DEFENDANT’S OPPOSITION TO PLAINTIFF'S MOTION TO RECOVER COST OF PROOF SANCTIONS PURSUANT TO C.C.P. SECTION 2033.420