On March 21, 2019 a
Hearing
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 ROSERT S INST IN 140412
ESQ
Robert S einstein Assoc
2 12401 ilshire Slvd 3te 240
Los Angel es CA 90025 1 n
S JpERIORCaURTO FCALIFORNiA
3 310 277 7762
OUNTY UF SA B RNARL lc
SF N iE NA L 4N0 4aluTRIGT
4 1039 8
Palm Canyon Dr
Palm Springs ca 92264 OCT 0 2019
5 760 797 5502
Y
6 Attorney8 for Plaintiffs
qEL HEHNAPdDEZ DFPU Y
BRIAN MAHAFFI3Y
7 ASHLEY MAHAFFEY
8
SIIPERIOR COIIRT OF THE STATE OF CALIFORNTA
9
FOR TIiB COT NTX OF SAN BERNARDINO i
10
SRIAN MAHAFFBY CASE NO CIVD31908657
11
ASHLEY MAHAFFEY
12
P3 ain iffg OPPOSITION T DEFENDANT3
M TIONS TO CO1 LL
13
DISCOVERY DECLARATION
v
0 ROBERT S 1EINSTEIN
R2CHARD WILSON et al PLAINTIFFS REQUE3T FOR SANCTIONS
AQAINST DEFENDANr3 AND THEIR COUNSEL
POINT3 AND AUTHORITIBS IN
SVPPORT THEREOF
16
DATE October 15 2019
17
TIME 8s30 a m
DEPT 330
g
19
TO ALL INTERESTSD PARTIES AND TO THEIR ATTORNEY3 OF RECORD
2Q
PLEA3E TAKE NOTICE THAT cn October 15 2019 at 8s30 a m or
21
a soon thereafter as couasel rnay be heard in Departmeat 830 of the
22
San Bernardino Superivr Court located at 24 Weat Third Street
23
California 92415 Plainti ff iatends to appvse
Saa Bernardino
24
Motiona to Compel baBed the
defendanta moot and frivoloue
25
following grounds
26
1 Defendant was timely served with verified responses
27
28
QPPOSITTON TO DEFENDANTS MOTIONS TO COD PLL
d TLL6S9 ETL T 6i 6TOZ ZO 0
Z
1 despite Defendant s contention
that they were aot
2 d
serv
or in receipt of any responses
3 2
Defendant was made aware that the diacovery was beiag
4 mailed aad a request for an adclition 2 week were
5 requeated aad granted in he event Plaintif went aver or
6 cutting it close to their deadline Sxhibit A1
3 In accordance with Defendan ts exteusion Plaiutiff
8 timely served verified responses without ob ection an
9 July 8 2019 despi e
being g ven until August 2 2019
10 Exhibit B
11 4 5oon thexeafter Defendant iZed and served Motions ta
12 aompel Plaintiffs cownsel repeatedly left telephone
13 messages for har dling Defease couasel M Croain
14 5 Fi zally on September 20 2019 8lafatiff pake with
15 Mr
Cronir and iaformed him that Plaintiffs were sending
1fi
aut another copy of the Discovery respox aes ae soon as
17 Plainti f s counsel returned to the office ae
18 Plaixzti f e counsel was away eent out 2 business days
4 later Since September 20th was a Friday Couneel
20
returned on Tuesday and eexit another set via priority
21 mail
22 6 Mr Croain agreed to remove ita Motions upan reaeipt of
23 same Nonetheless its defense motiox s remained on
24 calendar as of this date
25 7 Plafntiff forwarded meet and confer carrespondence to
26 Defense couasel on September 20 2419 and
27 Octaber 1 201 9 hibit C
28
2
E d TGL6S9 ETG T BT 6TOZ ZO 0
Document Filed Date
October 02, 2019
Case Filing Date
March 21, 2019
Category
Personal Injury Motor Vehicle Unlimited
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1 ROSERT S INST IN 140412 ESQ Robert S einstein Assoc 2 12401 ilshire Slvd 3te 240 Los Angel es CA 90025 1 n S JpERIORCaURTO FCALIFORNiA 3 310 277 7762 OUNTY UF SA B RNARL lc SF N iE NA L 4N0 4aluTRIGT 4 1039 8 Palm Canyon Dr Palm Springs ca 92264 OCT 0 2019 5 760 797 5502 Y 6 Attorney8 for Plaintiffs qEL HEHNAPdDEZ DFPU Y BRIAN MAHAFFI3Y 7 ASHLEY MAHAFFEY 8 SIIPERIOR COIIRT OF THE STATE OF CALIFORNTA 9 FOR TIiB COT NTX OF SAN BERNARDINO i 10 SRIAN MAHAFFBY CASE NO CIVD31908657 11 ASHLEY MAHAFFEY 12 P3 ain iffg OPPOSITION T DEFENDANT3 M TIONS TO CO1 LL 13 DISCOVERY DECLARATION v 0 ROBERT S 1EINSTEIN R2CHARD WILSON et al PLAINTIFFS REQUE3T FOR SANCTIONS AQAINST DEFENDANr3 AND THEIR COUNSEL POINT3 AND AUTHORITIBS IN SVPPORT THEREOF 16 DATE October 15 2019 17 TIME 8s30 a m DEPT 330 g 19 TO ALL INTERESTSD PARTIES AND TO THEIR ATTORNEY3 OF RECORD 2Q PLEA3E TAKE NOTICE THAT cn October 15 2019 at 8s30 a m or 21 a soon thereafter as couasel rnay be heard in Departmeat 830 of the 22 San Bernardino Superivr Court located at 24 Weat Third Street 23 California 92415 Plainti ff iatends to appvse Saa Bernardino 24 Motiona to Compel baBed the defendanta moot and frivoloue 25 following grounds 26 1 Defendant was timely served with verified responses 27 28 QPPOSITTON TO DEFENDANTS MOTIONS TO COD PLL d TLL6S9 ETL T 6i 6TOZ ZO 0 Z 1 despite Defendant s contention that they were aot 2 d serv or in receipt of any responses 3 2 Defendant was made aware that the diacovery was beiag 4 mailed aad a request for an adclition 2 week were 5 requeated aad granted in he event Plaintif went aver or 6 cutting it close to their deadline Sxhibit A1 3 In accordance with Defendan ts exteusion Plaiutiff 8 timely served verified responses without ob ection an 9 July 8 2019 despi e being g ven until August 2 2019 10 Exhibit B 11 4 5oon thexeafter Defendant iZed and served Motions ta 12 aompel Plaintiffs cownsel repeatedly left telephone 13 messages for har dling Defease couasel M Croain 14 5 Fi zally on September 20 2019 8lafatiff pake with 15 Mr Cronir and iaformed him that Plaintiffs were sending 1fi aut another copy of the Discovery respox aes ae soon as 17 Plainti f s counsel returned to the office ae 18 Plaixzti f e counsel was away eent out 2 business days 4 later Since September 20th was a Friday Couneel 20 returned on Tuesday and eexit another set via priority 21 mail 22 6 Mr Croain agreed to remove ita Motions upan reaeipt of 23 same Nonetheless its defense motiox s remained on 24 calendar as of this date 25 7 Plafntiff forwarded meet and confer carrespondence to 26 Defense couasel on September 20 2419 and 27 Octaber 1 201 9 hibit C 28 2 E d TGL6S9 ETG T BT 6TOZ ZO 0