On April 29, 2021 a
Party Discovery
was filed
involving a dispute between
Lara, Daniel,
and
Does 1-50,
Martin, Bradley Carl,
Priksnr, Llc,
for Other PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
18778772811 p.123
28-Dec-2822 12:31 SpanDSP F?‘ Header
V \I
'
l LE DALlFC RNIA
. ‘ .
1 Benjamln Arsenlan (SBN: 235877) SlgaoES'th gggfllgFEgNAfibeO
DlsTm 3T
Law Offices of Benj amm Arsenxan, PC SAN BERNARD‘NQ
2 2677 Noah Main Street, Suite 900
Santa Ana, CA 92705 DEC 2 8 2022
3 Phone: (657) 212-6900
Fax: (877) 877-2811
4 Email: attorney@arsenian.com C? ’
5 DANIEL LARA BY: m” '
°“"S°" De p uty
,
Attorneys for Plaintiff,
6
7 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
8 IN AND FOR THE COUNTY OF SAN BERNARDINO
9
DANIEL LARA, an individual, CASE NO: CIVSB21 12428
10
11 Plaintiff, NOTICE 0F MOTION AND MOTION
T0 COMPEL FURTHER
12 vs. INTERROGATORY RESPONSES;
MEMORANDUM OF POINTS AND
13 AUTHORITIES; DECLARATION OF
PRIKSNR, LLC dba BUDGET LODGE, a BENJAMIN ARSENIAN
14
limited liability company; BRADLEY CARL A ____m_ n__ ____‘_
F“ d c t,
15 MARTIN, an individual; and DOES 1-50, [Stafemgflcg’f‘ ife‘ngg‘fiisg‘gg‘e‘f g‘ljd
3
. .
mcluswe, [Proposed] Order]
1 6
Com p laint Filed: A pril 29, 2021
17 Defendants.
18 Hearing
19 Date: March 30, 2023
20
Time: 8:30 AM
Dept: $27
Judge: Hon. Thomas Garza
21
22
23
TO THE COURT, ALL PARTIES and THEIR ATTORNEYS OF RECORD:
24 PLEASE TAKE NOTICE that on March 30, 2023 at 8:30 AM in Department $27, ofthe
25 above entitled court, located at 247 West Third Street, San Bernardino, CA 92415, Plaintiff
26 DANIEL LARA will and. hereby doesymoyfi_thjs._Cnutt fonan order. companing. -Defhwiam -__ _ ”mm.
27 PRIKSNR, LLC dba BUDGET LODGE to fuflher produce responses to Plaintiff’s Fonn and
28 Special Interrogatories (Set One) and monetary sanctions.
PLAINTIFF” S MOTION TO COIVIPEL FURTHER RESPONSES TO INTERROGATORIES (SET ONE)
1
F' 18778772811 p.124
23-Dec-2322 12 32
: SpanDSP Header
\y \y
1 This motion is brought pursuant t0 California Code of Civil Procedure sections 2030.300
Defendant
2 and is brought on the grounds that after the Bench ordered t0 provide answers,
3 PRIKSNR, LLC dba BUDGET LODGE has failed t0 provide full and complete responses t0 form
4 and special interrogatories propoundcd by Plaintiff A declaration in conformance with Civil C_od§
5 0f Procedure section 2016.040 is provided herewith
6 PLEASE TAKE FURTHER NOTICE, that pursuant t0 California Code OfCivil Procedure,
seeks additional
7 Sections 203 1 .300, 2023.030, Plaintiff, through his attorney Benjamin Arsenian,
8 monetary sanctions to be paid to Plaintiff s counsel by Defendant PRIKSNR, LLC dba BUDGET
9 LODGE and/or its attorney Ofrccord in the amount ofw for having t0 bring this motion.
10 This motion is based upon this notice, the attached memorandum of points and authorities,
the supporting declaration of Bcnj amin Arsenian, the separate statement
0f items in dispute
11
12 concurrently served and filed with this motion, upon all papers and pleadings currently on file with
the CouIT, and upon such oral and documentary evidence as may be presented t0 the Court at the
13
14 time 0f the hearing.
15
16
17 Dated: December 28, 2022 Respectfully Submitted,
18
19
20
507W flW
By: Benjamin Arsepian SBN: 235877
21 Law Offices of Ben] amin Arsenlan PC
22 Attorney for Plaintiff, DANIEL LARA
23
24
25
26
27
28
PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES TO INTERROGATORIES (SET ONE)
2
Document Filed Date
December 28, 2022
Case Filing Date
April 29, 2021
Category
Other PI/PD/WD Unlimited
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Preview
18778772811 p.123 28-Dec-2822 12:31 SpanDSP F?‘ Header V \I ' l LE DALlFC RNIA . ‘ . 1 Benjamln Arsenlan (SBN: 235877) SlgaoES'th gggfllgFEgNAfibeO DlsTm 3T Law Offices of Benj amm Arsenxan, PC SAN BERNARD‘NQ 2 2677 Noah Main Street, Suite 900 Santa Ana, CA 92705 DEC 2 8 2022 3 Phone: (657) 212-6900 Fax: (877) 877-2811 4 Email: attorney@arsenian.com C? ’ 5 DANIEL LARA BY: m” ' °“"S°" De p uty , Attorneys for Plaintiff, 6 7 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 IN AND FOR THE COUNTY OF SAN BERNARDINO 9 DANIEL LARA, an individual, CASE NO: CIVSB21 12428 10 11 Plaintiff, NOTICE 0F MOTION AND MOTION T0 COMPEL FURTHER 12 vs. INTERROGATORY RESPONSES; MEMORANDUM OF POINTS AND 13 AUTHORITIES; DECLARATION OF PRIKSNR, LLC dba BUDGET LODGE, a BENJAMIN ARSENIAN 14 limited liability company; BRADLEY CARL A ____m_ n__ ____‘_ F“ d c t, 15 MARTIN, an individual; and DOES 1-50, [Stafemgflcg’f‘ ife‘ngg‘fiisg‘gg‘e‘f g‘ljd 3 . . mcluswe, [Proposed] Order] 1 6 Com p laint Filed: A pril 29, 2021 17 Defendants. 18 Hearing 19 Date: March 30, 2023 20 Time: 8:30 AM Dept: $27 Judge: Hon. Thomas Garza 21 22 23 TO THE COURT, ALL PARTIES and THEIR ATTORNEYS OF RECORD: 24 PLEASE TAKE NOTICE that on March 30, 2023 at 8:30 AM in Department $27, ofthe 25 above entitled court, located at 247 West Third Street, San Bernardino, CA 92415, Plaintiff 26 DANIEL LARA will and. hereby doesymoyfi_thjs._Cnutt fonan order. companing. -Defhwiam -__ _ ”mm. 27 PRIKSNR, LLC dba BUDGET LODGE to fuflher produce responses to Plaintiff’s Fonn and 28 Special Interrogatories (Set One) and monetary sanctions. PLAINTIFF” S MOTION TO COIVIPEL FURTHER RESPONSES TO INTERROGATORIES (SET ONE) 1 F' 18778772811 p.124 23-Dec-2322 12 32 : SpanDSP Header \y \y 1 This motion is brought pursuant t0 California Code of Civil Procedure sections 2030.300 Defendant 2 and is brought on the grounds that after the Bench ordered t0 provide answers, 3 PRIKSNR, LLC dba BUDGET LODGE has failed t0 provide full and complete responses t0 form 4 and special interrogatories propoundcd by Plaintiff A declaration in conformance with Civil C_od§ 5 0f Procedure section 2016.040 is provided herewith 6 PLEASE TAKE FURTHER NOTICE, that pursuant t0 California Code OfCivil Procedure, seeks additional 7 Sections 203 1 .300, 2023.030, Plaintiff, through his attorney Benjamin Arsenian, 8 monetary sanctions to be paid to Plaintiff s counsel by Defendant PRIKSNR, LLC dba BUDGET 9 LODGE and/or its attorney Ofrccord in the amount ofw for having t0 bring this motion. 10 This motion is based upon this notice, the attached memorandum of points and authorities, the supporting declaration of Bcnj amin Arsenian, the separate statement 0f items in dispute 11 12 concurrently served and filed with this motion, upon all papers and pleadings currently on file with the CouIT, and upon such oral and documentary evidence as may be presented t0 the Court at the 13 14 time 0f the hearing. 15 16 17 Dated: December 28, 2022 Respectfully Submitted, 18 19 20 507W flW By: Benjamin Arsepian SBN: 235877 21 Law Offices of Ben] amin Arsenlan PC 22 Attorney for Plaintiff, DANIEL LARA 23 24 25 26 27 28 PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES TO INTERROGATORIES (SET ONE) 2