On March 21, 2019 a
Motion-Secondary
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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1 Kimberly S Oberrecht C S B No 190794
Jeremy R Cronin C S B No 270284
2 Cheyenne J Page C S B No 323354 I r
p
HORTON OB RR CHT KIRICPATRICIC MARTHA
3 101 W Broadway Suite 600
San Diego Califoi nia 92101 Y
4 619 232 1183 619 b96 5719 facsimile
5
Attomeys for Defendants RICHARD WILSON JOSE MEDINA and COLORAMA
6 WHOLESAL NURSERY dba COLORAMA
7
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 CAS NO CIVDS 1908657
12 Plaintiffs DECLARATION OF J RrMY R
CRONIN IN SUPPORT OF
13 vs DEFENDANT RICfIARD WILSON S
MOTION TO COMP L
14 RICHARD WILSON JOSE MEDINA PLAINTIFFS BRIAN MAHAFF Y
COLORAMA WHOL SALE NURSERY dba TO RESPOND TO I ORM
l5 COLORAMA and DOES 1 through 100 TNTERROGATORIES SET ONE
Inclusive AND REQU ST FOR MONETARY
I6 SANCTIONS
Defendants
17
Date October 15 2419
18 Time 8 3Q a m
Dept S30
19
Action Filect March 21 2019
20 Trial Date None Set
21
22
23 I Jeremy R Cronin declare
24 1 I am an attorney at law duly licensed to practice before all of the Courts of the State
25 of California and am an associate with Horton Oberrecht Kirkpatrick Martha attorneys of
26 record for Defendant 12ICHARD WILSON The following facts are based on my own personal
27 knowledge and if called upon to do so I could and wotild testify competentiy thereto
28
D6CLARATION Of iLREMY R CR01 N IN SUPPORT OF MOTfON TO CONIPEL RESPONSES f0 FORM INTERROGATOI21E5 SLT
ON6
G ICLIGNTS 8451P1eadingslMotions to Compel Brian lahaffey bec MTC DRIAN FROGS 1 SROGS 1 wpd
1 2 Oi May 3 2019 my office caused Plaintiffto be served via U S mail with Parm
2 Inteil ogatories Set One propounded by RICHARD WILSON A true and correct copy of Form
3 Interrogatories Set One is attached hereto as Exhibit A
4 3 Given the secvice of Form Ii terrogatories Set One Plaintiff s responses were due
5 on June 6 2019
6 4 On July 3 20I9 having received no responses from Plaintiff our office issued
7 correspondence to Plaintiff s counsel Robert Weinstein in an attempt to meet and confer regarding
8 Plaintif s delinquent discovery A tri e and correct copy of this correspondence is attached hereto
9 as Exhibit B
10 5 Following further discussions regarding the status of these responses Plaintiff s
11 counsel agreed to provide responses by August 2 2019 However responses were never provided
12 and Plaintiffls counsei has not further acknowledged Plaintiffs failure to respond
13 6 Defendant RTCHARD WILSON l as and will incur reasonable eapenses and
14 attorneys fees in connection with briilgiiig this Motion Particularly Defendant has spent 2 3 hours
15 preparing this Motion including legal research and expects to spend another 1 5 hours reviewing
16 Plaintiffs 4pposition and preparing a Reply and 5 5 hours reviewing the Tentative Ruling and
17 preparing for travelling to and attending the Izearing on the Motion In addition our office has also
18 incurred a 60 00 fee for filiilg the instant motion My modest hourly rate is I55 As such
19 Defendant has incurred 1 501 50 in unnecessary costs and fees resulting from Plaintiffs failureto
20 respond to discoveiy requests This amount is requested as a monetary sanction against Plaintiff
21 BRIAN MAHAFFEY and her counsel of record Robert Weinstein
22 I declared under penalty of petjury under the laws of the State of Califoinia that the
2 foregoing is tnie and correct and that this Declaration is executed on August 26 2019 at San
24 Diego California
25
26
Jereiny R Cronin
27
28
D6CLARATfOT OP JGREMY R CRONIT I N SUPI ORT Of N10TION TO COMPEL RESPONSGS TO FORM INTERROGATORIL S SC f
ONE
G 1CL ENT3 5845 PfeadingslMotions to CompellE3rian Mahaffey Dec 1viTC BRIAN PROGS SROGS l wpd
Document Filed Date
August 26, 2019
Case Filing Date
March 21, 2019
Category
Personal Injury Motor Vehicle Unlimited
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1 Kimberly S Oberrecht C S B No 190794 Jeremy R Cronin C S B No 270284 2 Cheyenne J Page C S B No 323354 I r p HORTON OB RR CHT KIRICPATRICIC MARTHA 3 101 W Broadway Suite 600 San Diego Califoi nia 92101 Y 4 619 232 1183 619 b96 5719 facsimile 5 Attomeys for Defendants RICHARD WILSON JOSE MEDINA and COLORAMA 6 WHOLESAL NURSERY dba COLORAMA 7 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 CAS NO CIVDS 1908657 12 Plaintiffs DECLARATION OF J RrMY R CRONIN IN SUPPORT OF 13 vs DEFENDANT RICfIARD WILSON S MOTION TO COMP L 14 RICHARD WILSON JOSE MEDINA PLAINTIFFS BRIAN MAHAFF Y COLORAMA WHOL SALE NURSERY dba TO RESPOND TO I ORM l5 COLORAMA and DOES 1 through 100 TNTERROGATORIES SET ONE Inclusive AND REQU ST FOR MONETARY I6 SANCTIONS Defendants 17 Date October 15 2419 18 Time 8 3Q a m Dept S30 19 Action Filect March 21 2019 20 Trial Date None Set 21 22 23 I Jeremy R Cronin declare 24 1 I am an attorney at law duly licensed to practice before all of the Courts of the State 25 of California and am an associate with Horton Oberrecht Kirkpatrick Martha attorneys of 26 record for Defendant 12ICHARD WILSON The following facts are based on my own personal 27 knowledge and if called upon to do so I could and wotild testify competentiy thereto 28 D6CLARATION Of iLREMY R CR01 N IN SUPPORT OF MOTfON TO CONIPEL RESPONSES f0 FORM INTERROGATOI21E5 SLT ON6 G ICLIGNTS 8451P1eadingslMotions to Compel Brian lahaffey bec MTC DRIAN FROGS 1 SROGS 1 wpd 1 2 Oi May 3 2019 my office caused Plaintiffto be served via U S mail with Parm 2 Inteil ogatories Set One propounded by RICHARD WILSON A true and correct copy of Form 3 Interrogatories Set One is attached hereto as Exhibit A 4 3 Given the secvice of Form Ii terrogatories Set One Plaintiff s responses were due 5 on June 6 2019 6 4 On July 3 20I9 having received no responses from Plaintiff our office issued 7 correspondence to Plaintiff s counsel Robert Weinstein in an attempt to meet and confer regarding 8 Plaintif s delinquent discovery A tri e and correct copy of this correspondence is attached hereto 9 as Exhibit B 10 5 Following further discussions regarding the status of these responses Plaintiff s 11 counsel agreed to provide responses by August 2 2019 However responses were never provided 12 and Plaintiffls counsei has not further acknowledged Plaintiffs failure to respond 13 6 Defendant RTCHARD WILSON l as and will incur reasonable eapenses and 14 attorneys fees in connection with briilgiiig this Motion Particularly Defendant has spent 2 3 hours 15 preparing this Motion including legal research and expects to spend another 1 5 hours reviewing 16 Plaintiffs 4pposition and preparing a Reply and 5 5 hours reviewing the Tentative Ruling and 17 preparing for travelling to and attending the Izearing on the Motion In addition our office has also 18 incurred a 60 00 fee for filiilg the instant motion My modest hourly rate is I55 As such 19 Defendant has incurred 1 501 50 in unnecessary costs and fees resulting from Plaintiffs failureto 20 respond to discoveiy requests This amount is requested as a monetary sanction against Plaintiff 21 BRIAN MAHAFFEY and her counsel of record Robert Weinstein 22 I declared under penalty of petjury under the laws of the State of Califoinia that the 2 foregoing is tnie and correct and that this Declaration is executed on August 26 2019 at San 24 Diego California 25 26 Jereiny R Cronin 27 28 D6CLARATfOT OP JGREMY R CRONIT I N SUPI ORT Of N10TION TO COMPEL RESPONSGS TO FORM INTERROGATORIL S SC f ONE G 1CL ENT3 5845 PfeadingslMotions to CompellE3rian Mahaffey Dec 1viTC BRIAN PROGS SROGS l wpd