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To: 19097088586 From: 18186962307 Date: 12/22/21 Time: 1:29 PM Page: 58/85
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HAIG B. KAZANDJIAN LAWYERS, APC SUEELJ5HECOQHT
Haig B. Kazandjian, Esq. Bar No.1 278622 BERNARD!INO
CSOAUrIquEgrSASAN
Cathy Gonzalez, Esq. Bar No.: 310625 RD'NO D'STWCT
Melissa R. Robinson, Esq. Bar No.2 336951
DEC 2 2 2021
801 North Brand Boulevard, Suite 970
Glendale, California 91203
Telephone: 1-818-696-2306 BY
L)!
Facsjmne; 1-818-696-2307 Kahska Monaco.DEPUTY
.Attorrzeysfbr PLAIN’TIFFS
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
\OOONO
KENYA BRINSON, an individual; KENYA
j
44'
Case N0. CIVD52017097
BRINSON, 0n behalf 0f LENNOX M,, a {4ssz’gnedf0r all purpoflses t0 the Honorable Johr
minor individual M Tomberlz'n Dept S3 3]
10
Plaintiffs, PLAINTIFF KENYA BRINSON’S
11 SEPARATE STATEMENT IN SUPPORT
v. 0F PLAINTIFF'S MOTION TO COMPEL
12 FURTHER RESPONSES TO SPECIAL
INTERROGATORIES (SET ONE) T0
13 SOCAL PACIFIC MF MANAGEMENT DEFENDANT SOCAL PACIFIC MF
CORP, a California corporation, dba Nova MANAGEMENT CORP AND REQUEST
14 Points Apartments; and DOES l through 50, FOR MONETARY SANCTIONS AGAINST
Inclusive, DEFENDANT SOCAL PACIFIC MF
115 MA NAGEMENT CORP AND ITS
DEFENDANTS. COUNSEL, GORDON REES SCULLY
16 MANSUKHANI, LLP, IN THE AMOUNT
OF $5,685.00
17 FILED CONCURRENTLY WITHPLAINTIFF KENYA
BRINSON ’SMOTION T0 COM’PEL FUR THER
18 RESPONSES TO SPECIAL [NTERROGATORIES SET
ONE. TO DEFENDANT SOCAL PACIFIC MF
19 MANAGEMENT CORP AND REQUEST FOR MONETARY
SAN(‘.'.'TIONS A GAINST DEFENDAJW' AND ITS (:70 UNSEL
20 GORDONREES SC ULLYMAMSUKHANI, LLP,‘
DECIARATION 0F HAIG B. E4Z4NDJIAN, ESQ. &
21 [PR OPOSED] ORDER]
22 Complaint Filed: August 24, 2020
Trial Date: October 25, 2021
23
Hearing Date: March 8, 2022
24 Time: 9:00 am.
Dept: S33
25
Pursuant to California Rules of Court Rule 3Ql345(a), Plaintiff KENYA BRINSON
26
hereby submits her separate statement in support ofher Motion to Comps! Defendant SOCAL
27
PACIFIC MF MANAGEMENT CORP’s further responses t0 Plaintiff‘s Special Interrogatories,
28
Set One, Request Nos. 1—22, and 24.
PLAINTIFF KENYABRINSON’S SEPARATE STATEMENT IN SUPPORT OF PLAINTIFF'S MOTION TO COIVIPEL
FURTHER RESPONSES TO SPECIAL INTERROGATORIES (SET ONE) TO DEFENDANT
T0: 19097088586 From: 18186962307 Date: 12/22/21 Time: 1:29 PM Page: 59/85
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SPECIAL INTERROGA'I‘ORY NO. 1:
State with specificity, exactly what YOU did t0 address ANY 0f PLAINTIFF’S requests
for WORK at the SUBJECT PROPERTY at ANY time during their tenancy.
RESPONSE T0 INTERROGATORY NO. 1:
Responding Party objects to this interrogatory as vague and ambiguous. Without waiving,
and subject to, said objections, and based 0n its understanding of this interrogatory, Responding
Parry responds as follows:
OO\l
Responding Party was notified 0n June 11, 2019, of water issues in the bathrooms at the
KO
SUBJECT PROPERTY. Responding Party replaced stems, seats, shower heads, and handles in
10 1w0 bathrooms. Responding Party also had Servpro perfomI services related t0 these issues.
11 Responding Party was notified on May 16, 2019, of an issue with the kitchen light at the
12 SUBJECT PROPERTY. Responding Party replaced four light bulbs.
13 Responding Party was notified 0n May 16, 2019, 0f an issue with a bathroom tub at the
14 SUBJECT PROPERTY. Responding Party replaced the water handle.
15 Responding Party was notified 0n May 3, 2019, ofa leaking kitchen sink at the
16 SUBJECT PROPERTY. Responding Party reconnected the pipes to stop the leak.
17 Responding Party had Serve U provide services on September 13, 2019 at the SUBJECT
18 PROPERTY.
19 Responding Pany repaired drywall in bathroom ceiling in July of 2019.
20 Discovery and investigation arc ongoing, and Responding Party reserves the right to
21 amend or supplement this response upon the discovery 0f additional information.
22 REASON FOR FURTHER RESPONSE TO SPECIAL INTERROGATORY N0. 1:
23 Where a party's responses are untimely, that pany waives the right t0 object t0 the subject
24 discovery. This interrogatmy was duly served upon Defendant 0n February 10, 2021, and after
25 more than five (5) months of exTensions, Defendant untimely sent Plaintiff its Discovery
26 responses, on September 17, 2021, although deficient and with objections included, despite
27 numerous prior emails from Plaintiff stating that Defendant had waived its Objections because its
28 responses were untimely. As such, pursuant to C.C.P. Section 2030.290(a), Defendant has
2
PLAINTIFF KENYA BRINSONTS SEPARATE STATEMENT IN SUPPORT OF PLAINTIFF'S MOTION TO COMPEL
FURTHER RESPONSES TO SPECIAL INTERROGATORIES (SET ONE) TO DEFENDANT
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To: 19097088586 From: 18186962307 Date: 12/22/21 Time: 1:29 PM Page: 58/85 \r V HAIG B. KAZANDJIAN LAWYERS, APC SUEELJ5HECOQHT Haig B. Kazandjian, Esq. Bar No.1 278622 BERNARD!INO CSOAUrIquEgrSASAN Cathy Gonzalez, Esq. Bar No.: 310625 RD'NO D'STWCT Melissa R. Robinson, Esq. Bar No.2 336951 DEC 2 2 2021 801 North Brand Boulevard, Suite 970 Glendale, California 91203 Telephone: 1-818-696-2306 BY L)! Facsjmne; 1-818-696-2307 Kahska Monaco.DEPUTY .Attorrzeysfbr PLAIN’TIFFS SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO \OOONO KENYA BRINSON, an individual; KENYA j 44' Case N0. CIVD52017097 BRINSON, 0n behalf 0f LENNOX M,, a {4ssz’gnedf0r all purpoflses t0 the Honorable Johr minor individual M Tomberlz'n Dept S3 3] 10 Plaintiffs, PLAINTIFF KENYA BRINSON’S 11 SEPARATE STATEMENT IN SUPPORT v. 0F PLAINTIFF'S MOTION TO COMPEL 12 FURTHER RESPONSES TO SPECIAL INTERROGATORIES (SET ONE) T0 13 SOCAL PACIFIC MF MANAGEMENT DEFENDANT SOCAL PACIFIC MF CORP, a California corporation, dba Nova MANAGEMENT CORP AND REQUEST 14 Points Apartments; and DOES l through 50, FOR MONETARY SANCTIONS AGAINST Inclusive, DEFENDANT SOCAL PACIFIC MF 115 MA NAGEMENT CORP AND ITS DEFENDANTS. COUNSEL, GORDON REES SCULLY 16 MANSUKHANI, LLP, IN THE AMOUNT OF $5,685.00 17 FILED CONCURRENTLY WITHPLAINTIFF KENYA BRINSON ’SMOTION T0 COM’PEL FUR THER 18 RESPONSES TO SPECIAL [NTERROGATORIES SET ONE. TO DEFENDANT SOCAL PACIFIC MF 19 MANAGEMENT CORP AND REQUEST FOR MONETARY SAN(‘.'.'TIONS A GAINST DEFENDAJW' AND ITS (:70 UNSEL 20 GORDONREES SC ULLYMAMSUKHANI, LLP,‘ DECIARATION 0F HAIG B. E4Z4NDJIAN, ESQ. & 21 [PR OPOSED] ORDER] 22 Complaint Filed: August 24, 2020 Trial Date: October 25, 2021 23 Hearing Date: March 8, 2022 24 Time: 9:00 am. Dept: S33 25 Pursuant to California Rules of Court Rule 3Ql345(a), Plaintiff KENYA BRINSON 26 hereby submits her separate statement in support ofher Motion to Comps! Defendant SOCAL 27 PACIFIC MF MANAGEMENT CORP’s further responses t0 Plaintiff‘s Special Interrogatories, 28 Set One, Request Nos. 1—22, and 24. PLAINTIFF KENYABRINSON’S SEPARATE STATEMENT IN SUPPORT OF PLAINTIFF'S MOTION TO COIVIPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES (SET ONE) TO DEFENDANT T0: 19097088586 From: 18186962307 Date: 12/22/21 Time: 1:29 PM Page: 59/85 \y \r SPECIAL INTERROGA'I‘ORY NO. 1: State with specificity, exactly what YOU did t0 address ANY 0f PLAINTIFF’S requests for WORK at the SUBJECT PROPERTY at ANY time during their tenancy. RESPONSE T0 INTERROGATORY NO. 1: Responding Party objects to this interrogatory as vague and ambiguous. Without waiving, and subject to, said objections, and based 0n its understanding of this interrogatory, Responding Parry responds as follows: OO\l Responding Party was notified 0n June 11, 2019, of water issues in the bathrooms at the KO SUBJECT PROPERTY. Responding Party replaced stems, seats, shower heads, and handles in 10 1w0 bathrooms. Responding Party also had Servpro perfomI services related t0 these issues. 11 Responding Party was notified on May 16, 2019, of an issue with the kitchen light at the 12 SUBJECT PROPERTY. Responding Party replaced four light bulbs. 13 Responding Party was notified 0n May 16, 2019, 0f an issue with a bathroom tub at the 14 SUBJECT PROPERTY. Responding Party replaced the water handle. 15 Responding Party was notified 0n May 3, 2019, ofa leaking kitchen sink at the 16 SUBJECT PROPERTY. Responding Party reconnected the pipes to stop the leak. 17 Responding Party had Serve U provide services on September 13, 2019 at the SUBJECT 18 PROPERTY. 19 Responding Pany repaired drywall in bathroom ceiling in July of 2019. 20 Discovery and investigation arc ongoing, and Responding Party reserves the right to 21 amend or supplement this response upon the discovery 0f additional information. 22 REASON FOR FURTHER RESPONSE TO SPECIAL INTERROGATORY N0. 1: 23 Where a party's responses are untimely, that pany waives the right t0 object t0 the subject 24 discovery. This interrogatmy was duly served upon Defendant 0n February 10, 2021, and after 25 more than five (5) months of exTensions, Defendant untimely sent Plaintiff its Discovery 26 responses, on September 17, 2021, although deficient and with objections included, despite 27 numerous prior emails from Plaintiff stating that Defendant had waived its Objections because its 28 responses were untimely. As such, pursuant to C.C.P. Section 2030.290(a), Defendant has 2 PLAINTIFF KENYA BRINSONTS SEPARATE STATEMENT IN SUPPORT OF PLAINTIFF'S MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES (SET ONE) TO DEFENDANT