On March 21, 2019 a
Party Discovery
was filed
involving a dispute between
Mahaffey, Ashley,
Mahaffey, Brian,
and
Colorama Wholesale Nursery,
Medina, Jose,
Wilson, Richard,
for Personal Injury Motor Vehicle Unlimited
in the District Court of San Bernardino County.
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i RNIA
r
l f Rl 7FtC J u t C5v
f 1 i
CO lt lTY 3 33
r
SC h F3E
A a
1 Kimberly S Oberrecht C S B No 190794
Jeremy R Cronin C S B No 270284 1
2 Cheyenne J Page C S B No 323354 s
TM
HORTON OBERRECHT KIRKPATRICK MART c ot ol
3 101 W Broadway Suite 600
San Diego California 92101
4 619 232 1183 619 696 5719 facsimile
5
Attorneys for Defendants RICHARD WILSON JOSE MEDINA and COLORAMA
6 WHOLESALE NURSERY dba COLORAMA
8
SUPERIOR COURT OF THE STATE OF CALIFORNIA
9
IN AND FOR THE COUNTY OF SAN BERNARDINO
10 CENTRAL JUDICIAL DISTRICT
11 BRIAN MAHAFFEY ASHLEY MAHAFFEY CASE NO CIVDS1908657
12 Plaintiffs MEMORANDUM OF POINTS AND
AUTHORITIES IN SUPPORT OF
13 vs DEFENDANT RICHARD WILSON S
MOTION TO COMPEL
14 RICHARD WILSON JOSE MEDINA PLAINTIFFS ASHLEY MAHAFFEY
COLORAMA WHOLESALE NURSERY dba TO RESPOND TO REQUEST FOR
15 COLORAMA and DOES 1 through 100 PRODUCTION OF DOCUMENTS
Inclusive SET ONE AND REQUEST FOR
16 MONETARY SANCTIONS
Defendants
17 Date October 15 2019
Time 8 30 a m
18 Dept S30
v 19 Action Filed March 21 2019
Trial Date None Set
20
m
21
22
23
24 Defendant RICHARD WILSON respectfully submits the following Memorandum ofPoints
25 and Authorities in Support of his Motion to Compel Plaintiff ASHLEY MAHAFFEY to respond
26 to Request for Production of Documents Set One and Request for Monetary Sanctions
27
28
MEMORANDUM OF POINTS AND AU77IORITIES IN SUPPORT OF MOTION TO COMPEL RESPONSES TO REQUEST FOR
PRODUCTION OF DOCUMENTS SET ONE
G CLIENTS 5845 Plcadings Motions to Compel
Ashlcy Mahaffey P s c A s MTC ASHLEY RFP 1 wpd
1 MEMORANDUM OF POINTS AND AUTHORITIES
2 I
3 INTRODUCTION
4 In an effort to obtain the necessary information to prepare a Motion for Summary Judgment
5 and otherwise prepare for Trial Defendant RICHARD WILSON served Plaintiff ASHLEY
6 MAHAFFEY with ReGuest for Production of Documents Set One on May 3 2019 Thereafter
7 Plaintiff have failed to provided responses to the interrogatories Consequently Defendant
8 respectfully asks this Court to 1 compel Plaintiff to provide full and complete verified responses
9 without objections to Request for Production ofDocuments Set One propounded by Defendant
10 as well as the corresponding document production within ten days of the date of this Motion s
11 hearing and 2 Order Plaintiff and or her counsel ofrecord Robert Weinstein to pay monetary
12 sanctions in the amount of 928 as reasonable costs and expenses necessarily incurred in bringing
13 this Motion
14 II
15 PROCEDURAL BACKGROUND
16 On May 3 2019 Defendant RICHARD WILSON propounded via U S Mail Request far
17 Production of Documents Set One on PlaintiffASHLEY MAHAFFEY Declaration of Jeremy
18 R Cronin hereinafter Cronin Decl 2 Exhibits A and B Given the service of Request for
19 Production of Documents Set One Plaintiffls responses were due on June 6 2019 Cronin Decl
20 3 Having received no responses from Plaintiff on July 3 2019 counsel for Defendant issued
21 correspondence to Plaintiff s counsel in an attempt to meet and confer regarding Plaintiff s
22 delinquent discovery Cronin Decl 4 Exhibit C Following further discussions regarding the
23 status ofthese responses Plaintiff s counsel agreed to provide responses by August 2 2019 Cronin
24 Decl 5 However responses were never provided and Plaintiff s counsel has not further
25 acknowledged Plaintiffls failure to respond Cronin Decl 5
26
27
28
MEMORANDUM OF POINTS AND AUTHORI7 IES IN SUPPOR7 OF MOTION TO COMPEL RESPONSES TO REQUEST FOR
PRODUCTiON OF DOCLTMENTS SET ONE
G CLIENTS 5845 Pleadings Motions to CompelWshley Mahaffcy P s i As MTC ASHLEY RFP 1 wpd
Document Filed Date
August 26, 2019
Case Filing Date
March 21, 2019
Category
Personal Injury Motor Vehicle Unlimited
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i RNIA r l f Rl 7FtC J u t C5v f 1 i CO lt lTY 3 33 r SC h F3E A a 1 Kimberly S Oberrecht C S B No 190794 Jeremy R Cronin C S B No 270284 1 2 Cheyenne J Page C S B No 323354 s TM HORTON OBERRECHT KIRKPATRICK MART c ot ol 3 101 W Broadway Suite 600 San Diego California 92101 4 619 232 1183 619 696 5719 facsimile 5 Attorneys for Defendants RICHARD WILSON JOSE MEDINA and COLORAMA 6 WHOLESALE NURSERY dba COLORAMA 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE COUNTY OF SAN BERNARDINO 10 CENTRAL JUDICIAL DISTRICT 11 BRIAN MAHAFFEY ASHLEY MAHAFFEY CASE NO CIVDS1908657 12 Plaintiffs MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF 13 vs DEFENDANT RICHARD WILSON S MOTION TO COMPEL 14 RICHARD WILSON JOSE MEDINA PLAINTIFFS ASHLEY MAHAFFEY COLORAMA WHOLESALE NURSERY dba TO RESPOND TO REQUEST FOR 15 COLORAMA and DOES 1 through 100 PRODUCTION OF DOCUMENTS Inclusive SET ONE AND REQUEST FOR 16 MONETARY SANCTIONS Defendants 17 Date October 15 2019 Time 8 30 a m 18 Dept S30 v 19 Action Filed March 21 2019 Trial Date None Set 20 m 21 22 23 24 Defendant RICHARD WILSON respectfully submits the following Memorandum ofPoints 25 and Authorities in Support of his Motion to Compel Plaintiff ASHLEY MAHAFFEY to respond 26 to Request for Production of Documents Set One and Request for Monetary Sanctions 27 28 MEMORANDUM OF POINTS AND AU77IORITIES IN SUPPORT OF MOTION TO COMPEL RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS SET ONE G CLIENTS 5845 Plcadings Motions to Compel Ashlcy Mahaffey P s c A s MTC ASHLEY RFP 1 wpd 1 MEMORANDUM OF POINTS AND AUTHORITIES 2 I 3 INTRODUCTION 4 In an effort to obtain the necessary information to prepare a Motion for Summary Judgment 5 and otherwise prepare for Trial Defendant RICHARD WILSON served Plaintiff ASHLEY 6 MAHAFFEY with ReGuest for Production of Documents Set One on May 3 2019 Thereafter 7 Plaintiff have failed to provided responses to the interrogatories Consequently Defendant 8 respectfully asks this Court to 1 compel Plaintiff to provide full and complete verified responses 9 without objections to Request for Production ofDocuments Set One propounded by Defendant 10 as well as the corresponding document production within ten days of the date of this Motion s 11 hearing and 2 Order Plaintiff and or her counsel ofrecord Robert Weinstein to pay monetary 12 sanctions in the amount of 928 as reasonable costs and expenses necessarily incurred in bringing 13 this Motion 14 II 15 PROCEDURAL BACKGROUND 16 On May 3 2019 Defendant RICHARD WILSON propounded via U S Mail Request far 17 Production of Documents Set One on PlaintiffASHLEY MAHAFFEY Declaration of Jeremy 18 R Cronin hereinafter Cronin Decl 2 Exhibits A and B Given the service of Request for 19 Production of Documents Set One Plaintiffls responses were due on June 6 2019 Cronin Decl 20 3 Having received no responses from Plaintiff on July 3 2019 counsel for Defendant issued 21 correspondence to Plaintiff s counsel in an attempt to meet and confer regarding Plaintiff s 22 delinquent discovery Cronin Decl 4 Exhibit C Following further discussions regarding the 23 status ofthese responses Plaintiff s counsel agreed to provide responses by August 2 2019 Cronin 24 Decl 5 However responses were never provided and Plaintiff s counsel has not further 25 acknowledged Plaintiffls failure to respond Cronin Decl 5 26 27 28 MEMORANDUM OF POINTS AND AUTHORI7 IES IN SUPPOR7 OF MOTION TO COMPEL RESPONSES TO REQUEST FOR PRODUCTiON OF DOCLTMENTS SET ONE G CLIENTS 5845 Pleadings Motions to CompelWshley Mahaffcy P s i As MTC ASHLEY RFP 1 wpd