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1 G. Andrew Slater #238126
DOWLING AARON INCORPORATED
2 8080 North Palm Avenue, Third Floor
P.O. Box 28902
3 Fresno, California 93729-8902
Tel: (559) 432-4500
4 Fax: (559) 432-4590
aslater@dowlingaaron.com
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Attorneys for Defendant
6 CITY NATIONAL BANK RECEIVED VIA E-FILE
2/20/2018 3:08 PM
7 FRESNO COUNTY SUPERIOR COURT
By: S. Lopez, Deputy
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF FRESNO
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11 SURJIT BAGGA, Case No. 16CECG03336
12 Plaintiff, [PROPOSED] ORDER COMPELLING
RESPONSE TO REQUESTS FOR
13 v. ADMISSION, AND FOR MONETARY
SANCTION
14 CITY NATIONAL BANK, FRESNO
MANAGEMENT COMPANY, a California Date: April 17, 2018
15 Corporation; Ray Hutchins, an individual,; Time: 3:30 p.m.
James Krause, an individual; and DOES 1- Dept: 402
16 100, inclusive, Judge: Hon. Jeffrey Hamilton
17 Defendants.
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The motion of Defendant City National Bank for an order compelling Plaintiff,
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Surjit Bagga to serve on it responses to its first set of Requests for Admission that it served on
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Plaintiff on November 7, 2017, came on regularly for hearing on April 17, 2018. Plaintiff
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appeared by counsel Margarita Salazar; defendant appeared by counsel G. Andrew Slater.
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On proof made to the satisfaction of the court that the motion ought to be
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granted,
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IT IS ORDERED that the motion be, and hereby is, granted and that Plaintiff
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Surjit Bagga serve response to defendant City National Bank’s Request for Admissions, Set
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One, on or before ____________________ 2018.
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IT IS FURTHER ORDERED that Plaintiff, Surjit Bagga and her attorney
[PROPOSED] ORDER COMPELLING RESPONSE TO REQUESTS FOR ADMISSION, AND FOR
MONETARY SANCTION
1 Margarita Salazar pay forthwith to Defendant City National Bank the sum of
2 $___________________ as reasonable expenses and attorney’s fees.
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Dated:
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By:
6 JUDGE OF THE SUPERIOR COURT
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28 014939-000004-02366383.docx-1
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[PROPOSED] ORDER COMPELLING RESPONSE TO REQUESTS FOR ADMISSION, AND FOR
MONETARY SANCTION
1 PROOF OF SERVICE
2 STATE OF CALIFORNIA )
) SS
J COUNTY OF'F'RESNO )
4 I am a citizen of the United States and a resident of the County aforesaid; I am over the
age of eighteen (18) years and not aparty to the within-entitled action. My business address is
5 Dowling Aaron Incorporated, 8080 N. Palm Avenue, Third Floor, Fresno, California, 93711. On
February 20,2018,I served the within document(s):
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IPROPOSEDI ORDER COMPELLING RESPONSE TO REQUESTS FOR
7 ADMISSION, AND FOR MONETARY SANCTION
I n BY FAX: By transmitting via facsimile transmission the document(s) listed above to the
fax number(s) set forth below on this date before 5:00 p.m.
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I BY HAND: By personally delivering the document(s) listed above to the person(s) at the
10 address(es) set forth below.
11 X BY MAIL: By placing the document(s) listed above in a sealed envelope with postage
thereon fully prepaid, in the United States mail at Fresno, California, addressed as set
t2 forth below.
13 Margarita Salazar, Esq.
Law Offices Of MargaritaSalazar, APLC
T4 333 H Street, Suite 5000
Chula Vista, California 91910
15 Telephone: (619)551-7023-9578
Facsimile: (877)264-4695
t6 Email: margarita@msalazarlaw.com
l7 Attorney for Plaintiff
SURJIT BAGGA
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I am readily familiar with the firm's practices of collection and processing of
I9 correspondence for mailing. Under that practice, it would be deposited with the United States
Postaf Service on that same day with postage thereon fully prepaid in the ordinary course of
20 business. I am aware that on motion of the party served, service is presumed invalid if postal
cancellation date or postage meter date is moie than one day after date of deposit for mailing in
2T affrdavit.
22 I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
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Executed on February 20,2018, Fresno,
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N acques
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27 1205.DOCX.
0 14939-000004\0207
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Preview
1 G. Andrew Slater #238126 DOWLING AARON INCORPORATED 2 8080 North Palm Avenue, Third Floor P.O. Box 28902 3 Fresno, California 93729-8902 Tel: (559) 432-4500 4 Fax: (559) 432-4590 aslater@dowlingaaron.com 5 Attorneys for Defendant 6 CITY NATIONAL BANK RECEIVED VIA E-FILE 2/20/2018 3:08 PM 7 FRESNO COUNTY SUPERIOR COURT By: S. Lopez, Deputy 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF FRESNO 10 11 SURJIT BAGGA, Case No. 16CECG03336 12 Plaintiff, [PROPOSED] ORDER COMPELLING RESPONSE TO REQUESTS FOR 13 v. ADMISSION, AND FOR MONETARY SANCTION 14 CITY NATIONAL BANK, FRESNO MANAGEMENT COMPANY, a California Date: April 17, 2018 15 Corporation; Ray Hutchins, an individual,; Time: 3:30 p.m. James Krause, an individual; and DOES 1- Dept: 402 16 100, inclusive, Judge: Hon. Jeffrey Hamilton 17 Defendants. 18 19 The motion of Defendant City National Bank for an order compelling Plaintiff, 20 Surjit Bagga to serve on it responses to its first set of Requests for Admission that it served on 21 Plaintiff on November 7, 2017, came on regularly for hearing on April 17, 2018. Plaintiff 22 appeared by counsel Margarita Salazar; defendant appeared by counsel G. Andrew Slater. 23 On proof made to the satisfaction of the court that the motion ought to be 24 granted, 25 IT IS ORDERED that the motion be, and hereby is, granted and that Plaintiff 26 Surjit Bagga serve response to defendant City National Bank’s Request for Admissions, Set 27 One, on or before ____________________ 2018. 28 IT IS FURTHER ORDERED that Plaintiff, Surjit Bagga and her attorney [PROPOSED] ORDER COMPELLING RESPONSE TO REQUESTS FOR ADMISSION, AND FOR MONETARY SANCTION 1 Margarita Salazar pay forthwith to Defendant City National Bank the sum of 2 $___________________ as reasonable expenses and attorney’s fees. 3 Dated: 4 5 By: 6 JUDGE OF THE SUPERIOR COURT 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 014939-000004-02366383.docx-1 2 [PROPOSED] ORDER COMPELLING RESPONSE TO REQUESTS FOR ADMISSION, AND FOR MONETARY SANCTION 1 PROOF OF SERVICE 2 STATE OF CALIFORNIA ) ) SS J COUNTY OF'F'RESNO ) 4 I am a citizen of the United States and a resident of the County aforesaid; I am over the age of eighteen (18) years and not aparty to the within-entitled action. My business address is 5 Dowling Aaron Incorporated, 8080 N. Palm Avenue, Third Floor, Fresno, California, 93711. On February 20,2018,I served the within document(s): 6 IPROPOSEDI ORDER COMPELLING RESPONSE TO REQUESTS FOR 7 ADMISSION, AND FOR MONETARY SANCTION I n BY FAX: By transmitting via facsimile transmission the document(s) listed above to the fax number(s) set forth below on this date before 5:00 p.m. 9 I BY HAND: By personally delivering the document(s) listed above to the person(s) at the 10 address(es) set forth below. 11 X BY MAIL: By placing the document(s) listed above in a sealed envelope with postage thereon fully prepaid, in the United States mail at Fresno, California, addressed as set t2 forth below. 13 Margarita Salazar, Esq. Law Offices Of MargaritaSalazar, APLC T4 333 H Street, Suite 5000 Chula Vista, California 91910 15 Telephone: (619)551-7023-9578 Facsimile: (877)264-4695 t6 Email: margarita@msalazarlaw.com l7 Attorney for Plaintiff SURJIT BAGGA 18 I am readily familiar with the firm's practices of collection and processing of I9 correspondence for mailing. Under that practice, it would be deposited with the United States Postaf Service on that same day with postage thereon fully prepaid in the ordinary course of 20 business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is moie than one day after date of deposit for mailing in 2T affrdavit. 22 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 23 Executed on February 20,2018, Fresno, 24 25 N acques 26 27 1205.DOCX. 0 14939-000004\0207 28