On May 14, 2015 a
Motion-Secondary
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.
Preview
e @
Brian J. Virag (State Bar No. 205197) FILED
Superior Court of California
MYBEDBUGLAWYER, INC. ounty of Los Angeles
16400 Ventura Blvd., Suite 301
Encino, California 91436 SEP 23 2016
Telephone: (818) 907-5333
Facsimile: (818) 990-0216 Carter, Executive Officar/Clerk
Shi err
info@mybedbuglawyer.com,
By.eal Nene Deputy
Attorneys for Plaintiffs Raul Sanchez
SUPERIOR COURT FOR THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES
SUNNE JUNTHANUN ET. AL. Case No.: BCS81954
Plaintiffs, LAINTIFF'S’ OPPOSITION TO
vs. /EFENDANTS’ MOTION TO
10
(COMPEL & REQUEST FOR MONETARY
il PLB MANAGEMENT LLC ET. AL. SANCTIONS
12 Defendants Hearing Date: 10/06/16
Time: 08:30 AM
13
Pept 53 Srey
14
15 TO DEFENDANTS AND THEIR ATTORNEY OF RECORD:
16
Plaintiffs hereby submit this Opposition to the Motion to Compel filed by Defendants
17
which seek discovery responses of Plaintiffs and seek monetary sanctions. Plaintiff's counsel has
18
been engaged in trial preparation for the last several weeks and is currently engaged in trial in
19
20 Oakland, California. Further, the only other associate working for the office has left on early
21 maternity leave. These occurrences left the office extremely short-staffed.
22
There is no need to burden this court with this motion as both plaintiff and defense
23
counsel have had a cooperative working relationship on numerous cases in the past, and this
24
could all have been avoided with meet and confer amongst counsel. In the numerous cases that
28
26 defense and my firm have been involved with over the last several years, I have always made
“27 myself available to defense to resolve simple discovery issues. Sanctions are certainly not
=r
bom 28
7 appropriate.
PLAINTIFFS’ OPPOSITION TO DEFENDANTS’ MOTION TO COMPEL & REQUEST FOR MONETARY SANCTIONS
Document Filed Date
September 23, 2016
Case Filing Date
May 14, 2015
Status
Court-Ordered Dismissal - Other (Other) 12/20/2016
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e @ Brian J. Virag (State Bar No. 205197) FILED Superior Court of California MYBEDBUGLAWYER, INC. ounty of Los Angeles 16400 Ventura Blvd., Suite 301 Encino, California 91436 SEP 23 2016 Telephone: (818) 907-5333 Facsimile: (818) 990-0216 Carter, Executive Officar/Clerk Shi err info@mybedbuglawyer.com, By.eal Nene Deputy Attorneys for Plaintiffs Raul Sanchez SUPERIOR COURT FOR THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES SUNNE JUNTHANUN ET. AL. Case No.: BCS81954 Plaintiffs, LAINTIFF'S’ OPPOSITION TO vs. /EFENDANTS’ MOTION TO 10 (COMPEL & REQUEST FOR MONETARY il PLB MANAGEMENT LLC ET. AL. SANCTIONS 12 Defendants Hearing Date: 10/06/16 Time: 08:30 AM 13 Pept 53 Srey 14 15 TO DEFENDANTS AND THEIR ATTORNEY OF RECORD: 16 Plaintiffs hereby submit this Opposition to the Motion to Compel filed by Defendants 17 which seek discovery responses of Plaintiffs and seek monetary sanctions. Plaintiff's counsel has 18 been engaged in trial preparation for the last several weeks and is currently engaged in trial in 19 20 Oakland, California. Further, the only other associate working for the office has left on early 21 maternity leave. These occurrences left the office extremely short-staffed. 22 There is no need to burden this court with this motion as both plaintiff and defense 23 counsel have had a cooperative working relationship on numerous cases in the past, and this 24 could all have been avoided with meet and confer amongst counsel. In the numerous cases that 28 26 defense and my firm have been involved with over the last several years, I have always made “27 myself available to defense to resolve simple discovery issues. Sanctions are certainly not =r bom 28 7 appropriate. PLAINTIFFS’ OPPOSITION TO DEFENDANTS’ MOTION TO COMPEL & REQUEST FOR MONETARY SANCTIONS