Party Discovery: Charles Somers vs. Dr. James Longoria

• 
• 
• 
• 

						
                                
Preview
                                1   DOWNEY BRAND LLP
          WILLL^M R. WARNE (Bar No. 141280)
     2    ANNIE S. AMARAL (Bar No. 238189)
          621 Capitol Mall, 18th Flooi-
     3    Sacramento, CA 95814-:4731
          Telephone:    916.444.1000
     4    Facsimile:    916.444.2100
          bwame@downeybrarid.cbm
     5    aamaral@downeybrand.com
     6    Attomeys for Plaintiff
          CHARLES SOMERS, individually and as trustee for the
     7    CHARLES SOMERS. LIVING TRUST
     8                                    SUPERIOR COURT OF CALIFORNIA
     9                                        COUNTY OF SACRAMENTO
     10
     11   CHARLES SOMERS, individually and as               CASENO. 34-2018-00229212
          tmstee for the CHARLES SOMERS
     12   LIVINGTRUST,                                      PLAINTIFF CHARLES SOMERS?S
PH                                                          NOTICE OF ^ibTION AND MOTION TO
hJ
hJ
     13                      Plaintiff,                     COMPEL DEFENDANT DR; J A M E S .
Q                                                           LONGORIA'S FURTHER DISCOVERY
Z    14                                                     RESPONSES TO FORM
<                                                           INTERROGATORIES; SET ONE, AND
oi   15
pa        DR. JAMES LONGORIA, an individual,                RiEQUEST FOR MONETARY
          and DOES 1-10,                                    SANCTIONS
w    16
Z
                             Defendant.
o    17                                                     Date:      November 14, 2018 •
Q                                                           Time:      9:00 a.m.
     18                                                     Dept;':    54
     19                                                     Complaint Filed: March 16, 2018
                                                            Trial Date:      TBD
     20
     21               TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

     22               PLEASE TAKE NOTICE that, on Wednesday, November 14, 2018, at 9:00 a.m., or as

     23   soon thereafter as the matter may be heard, in Department 54 of the above-entitled Court, located

     24   at 813 6tii Sti-eet, Second Floor, Sacramento, Califomia, 95814, Plaintiff CHARLES SOMERS

     25   ("Plaintiff") will, and hereby does, move this Court for an order compelling Defendant DR.

     26   JAMES LONGORIA ("Defendant") to provide further responses to Form Interrogatories, Set

     27   One, and for him or his counsel to pay monetary sanctions to Plairitiff pursuant to Code of Civil

     28   Procedure § 2030.300(d) and 2023.020 and Local Rule 2.36.
          1533210.1                                         1
                      NOTICE OF MOTION TO COMPEL FURTHER DISCOVERY RESPONSES - FORM INTERROGATORIES
       1          This motion is made pursuant to Code of Civil Procedure sections 2023.020 and

       2   2030.300, and is brought because Defendant's responses do not comply with the requirements

       3   imposed by the Discovery Act, and because Defendant failed to meet-and-confer as required by

       4   the Code.

       5          This Motion will be based on this Notice of Motion and Motion; the accompanying
       6   Memorandum of Points and Authorities; the accompanying Declaration of Annie S. Amaral and
       7   all exhibits thereto; the accompanying Separate Statement; all of the documents and materials set
       8   forth in the Court's file in this matter; and on such other argument and oral and documentary
       9   evidence as the Court will allow at the time of the hearing on this Motion.
      10          Pursuant to Local Rule 1.06 (A), the Court will make a tentative mling on the merits of
      11   this matter by 2:00 p.m., the court day before the hearing. The complete text of the tentative
      12   mlings for the department may be downloaded from the Court's public access site. I f you do not
PH
HJ.   13   have online access, you may call the dedicated phone number for the department as referenced in
Q
Z     14   the local telephone directory, between the hours of 2:00 p.m. and 4:00 p.rii. on the court day ,
<
oi
      15   before the hearing and listen to the tentative mling. If you do not call the court and the opposing
PQ

W
      16   party by 4:00 p.m. the court day before the hearing, no hearing will be held.
Z     17   DATED: October 12, 2018                    DOWNEY BRAND LLP
o     18
Q
      19
      20                                                              'WILLIAM R. WARNE
                                                                        ANNIE S. AMARAL
      21                                                               Attomeys for Plaintiff
                                                           CHARLES SOMERS, individually and as tiiistee
                                                            for the CHARLES SOMERS LIVING TRUST
      22
      23
      24
      25
      26
      27
      28


                 NOTICE OF MOTION TO COMPEL FURTHER DISCOVERY RESPONSES - FORM INTERROGATORIES