On May 14, 2015 a
Party Discovery
was filed
involving a dispute between
Bautista Nathankan Rueasrichan,
Junthanun Sunnee,
and
Plb Mangement Llc,
for civil
in the District Court of Los Angeles County.
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SEDGWICK LLP
STEVEN D. DI SAIA, State Bar No. 158119
ORICIEAL
steven. disaiat edgwicklaw.com
NICHOLAS A, WEISS, State Bar No. 260606
nicholas. weiss@sedgwicklaw.com
FILED
Superior Court of California
801 South Figueroa Street, 19th Floor ounty of Los Angeles
Los Angeles, CA 90017-5556
Telephone: 213.426.6900 SEP 29 2016
Facsimile: 877.547.6580
Sh eri Carter, Executive Officer/Clerk
Attorneys for Defendant, PLB MANAGEMENT, LLC od
By. Qenz Deputy
Raul Sanchez
SUPERIOR COURT OF CALIFORNIA
COUNTY OF LOS ANGELES, CENTRAL DISTRICT
10
11 SUNNEE JUNTHANUN and NATHANKAN Case No. BC 581954
RUEASRICHAN BAUTISTA,
12 Reassigned for All Purposes to:
Plaintiffs, Hon. Howard L. Halm, Dept. 53
13
Vv. REPLY IN SUPPORT OF MOTION TO
14 COMPEL RESPONSES BY PLAINTIFFS
PLB MANGEMENT LLC, a California TO DEFENDANT PLB MANAGEMENT'S
15 limited liability company; and DOES.-1 to 20, FIRST SET-OF WRITTEN DISCOVERY;
inclusive, DECLARATION OF NICHOLAS A.
16 WEISS IN SUPPOR THEREOF
Defendants.
17 Reservation No.: 160912157812
Date: October 6, 2016
18 Time: 8:30 a.m.
Dept.: 53
19
Action Filed: May 14, 2015
20 Trial Date: July 19.2017
2)
22 THE MOTION SHOULD BE GRANTED BECAUSE PLAINTIFFS' OPPOSITION
23 CONCEDES THAT PLAINTIFFS' FAILED TO SERVE ANY RESPONSES TO
824 PLB'S TIMELY SERVED WRITTEN DISCOVERY
@25 The Opposition is correct about one thing —~ this Court should not be burdened with such
26 discovery motions. In most cases, discovery disputes can and should be resolved informally
be
"97 between the parties without court intervention. While it is also true that counsel for PLB has made
28 every effort to foster a cooperative working relationship with plaintiffs’ counsel in other cases,
83841184v1 -l-
REPLY IN SUPPORT OF MOTION TO COMPEL RESPONSES BY PLAINTIFFS TO DEFENDANT PLB
MANAGEMENT'S FIRST SET OF WRITTEN DISCOVERY
Document Filed Date
September 29, 2016
Case Filing Date
May 14, 2015
Status
Court-Ordered Dismissal - Other (Other) 12/20/2016
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| @ @ SEDGWICK LLP STEVEN D. DI SAIA, State Bar No. 158119 ORICIEAL steven. disaiat edgwicklaw.com NICHOLAS A, WEISS, State Bar No. 260606 nicholas. weiss@sedgwicklaw.com FILED Superior Court of California 801 South Figueroa Street, 19th Floor ounty of Los Angeles Los Angeles, CA 90017-5556 Telephone: 213.426.6900 SEP 29 2016 Facsimile: 877.547.6580 Sh eri Carter, Executive Officer/Clerk Attorneys for Defendant, PLB MANAGEMENT, LLC od By. Qenz Deputy Raul Sanchez SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES, CENTRAL DISTRICT 10 11 SUNNEE JUNTHANUN and NATHANKAN Case No. BC 581954 RUEASRICHAN BAUTISTA, 12 Reassigned for All Purposes to: Plaintiffs, Hon. Howard L. Halm, Dept. 53 13 Vv. REPLY IN SUPPORT OF MOTION TO 14 COMPEL RESPONSES BY PLAINTIFFS PLB MANGEMENT LLC, a California TO DEFENDANT PLB MANAGEMENT'S 15 limited liability company; and DOES.-1 to 20, FIRST SET-OF WRITTEN DISCOVERY; inclusive, DECLARATION OF NICHOLAS A. 16 WEISS IN SUPPOR THEREOF Defendants. 17 Reservation No.: 160912157812 Date: October 6, 2016 18 Time: 8:30 a.m. Dept.: 53 19 Action Filed: May 14, 2015 20 Trial Date: July 19.2017 2) 22 THE MOTION SHOULD BE GRANTED BECAUSE PLAINTIFFS' OPPOSITION 23 CONCEDES THAT PLAINTIFFS' FAILED TO SERVE ANY RESPONSES TO 824 PLB'S TIMELY SERVED WRITTEN DISCOVERY @25 The Opposition is correct about one thing —~ this Court should not be burdened with such 26 discovery motions. In most cases, discovery disputes can and should be resolved informally be "97 between the parties without court intervention. While it is also true that counsel for PLB has made 28 every effort to foster a cooperative working relationship with plaintiffs’ counsel in other cases, 83841184v1 -l- REPLY IN SUPPORT OF MOTION TO COMPEL RESPONSES BY PLAINTIFFS TO DEFENDANT PLB MANAGEMENT'S FIRST SET OF WRITTEN DISCOVERY