On January 13, 2022 a
Party Discovery
was filed
involving a dispute between
Carrasco, Linda A,
and
for Trust
in the District Court of San Bernardino County.
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1 LAW OFFICES 0F DAVID D. MORIEL ELECTRONICALLY FILED
A Professional Law Corporation ggfififieglgggfig EgNa’AF‘QI-Igffigmp‘
444 West Ocean Boulevard, Suite 800
3 Long Beach, CA 90802-4529 4/17/2023 3:16 PM
4 Landline: (562) 277—0848 By: Michelle Munguia, DEPUTY
Mobile: (562) 208-0439
5 Facsimile: (562) 490-8339
e-mail: dm@davidmoriel.com
6
Attorneys for Petitioner LINDA A.
7 CARRASCO
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9
IN AND FOR THE COUNTY OF SAN BERNARDINO
In Re The Matter: Case No.1 TRUSB2200003
1 O
d g 11 ALICE SANCHEZ LIVING TRUST, Hearing
no:
8o: °9 Dated December 2001, and as Date: 10.16.2023
E
.5
.._,
wNO 6,
D. gg €13 3F
12
amended.
.
Tlme: 9:00 AM
Q (ggfi Hon. Douglas K. Mann
g“ g $3 13
—8
2 Date of death: 08/10/2021 Dept. s35
a m0
cu<\E
u. :I
14
g g
§g" g NOTICE OF MOTION AND MOTION
15
lg '9,
5g
,0; TO COMPEL FURTHER RESPONSES
E g E 9% 16
TO SPECIAL INTERROGATORIES
O PROPOUNDED BY LINDA A.
iE 8
_°:
E E
17 CARRASCO DIRECTED T0 TYRONE
J. SANCHEZ, SET #1, MONETARY
18
SANCTIONS IN THE SUM 0F
19 $6,585.00, MEMORANDUM OF POINTS
AND AUTHORITIES, AND
20 (PROPOSED) ORDER
21
[Separately Filed (1) Declaration Of
22 Attorney David D. Moriel With Attached
Exhibits, and (2) Separate Statement]
23
LINDA CARRASCO
24
25 Petitioner,
26 VS.
27
TYRONE J. SANCHEZ, an individual,
28 TYRONE J. SANCHEZ, as the successor
Recyctd Paper NOTICE 0F MOTION To COMPEL FURTHER RESPONSES To SPECIAL INTERROGATORIES PROPOUNDED BY LINDA A.
CARRAsco DIRECTED To TYRONE J. SANCHEZ, SET #1, ETc..doc
1 of 3
trustee 0f the ALICE SANCHEZ LIVING
TRUST, Dated December 6, 2001,
MARIA T. SANCHEZ, and DOES 1 TO
50, INCLUSIVE.
Respondent(s)
TO ALL PARTIES AND THEIR RESPECTIVE ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that 0n the above time, date, and department, 0r as soon
thereafter as this matter may be heard before the Honorable Douglas K. Mann, Judge sitting in
Department S35 of the above-entitled Court, located at 247 West Third Street San Bernardino,
CA 92415-0212, Petitioner Linda A. Carrasco seeks an order compelling further and
10 supplemental responses to Special Interrogatories Propounded By Linda A. Carrasco Directed
11 To Tyrone J. Sanchez, Set #1, and monetary sanctions in the sum 0f $6,585.00 against Tyrone J.
MORIEL
800
562-490-8339
12 Sanchez and/or his counsel.
Corporation
D. Suite 90802-4529
13
This Motion is based on grounds the following grounds: The fist is the fact that
DAVID
Blvd., Fax
Respondent Tyrone J. Sanchez has asserted frivolous boilerplate objections in Violation 0f the
Law
CA / 14
OF
Ocean
holding of also Korea Data Systems Co. Ltd. V. Superior Court (1997) 51 Ca1.App.4th 1513.
Beach,
15
M,
Professional
OFFICES
W.
562-277-0848
And he refuses to provide complete and straightforward responses per Code 0f Civil
16
Long
444
Procedure section 2030.220(a).
A
LAW
Tel. 17
The requested orders are justified because the interrogatories directly relate to
18
Petitioner's claim that the Respondent, while acting as the Decedent's attorney—in—fact and co-
19
trustee, misappropriated $988,000.00 from Decadent by taking out loans against her real
20 property for his own benefit.
21 ///
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23
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24
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25
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26
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27
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28
D
Recycled Paper NOTICE OF MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES PROPOUNDED BY LINDA A.
CARRASCO DIRECTED TO TYRONE J. SANCHEZ, SET #1, ETC..doc
20f3
Document Filed Date
April 17, 2023
Case Filing Date
January 13, 2022
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1 LAW OFFICES 0F DAVID D. MORIEL ELECTRONICALLY FILED A Professional Law Corporation ggfififieglgggfig EgNa’AF‘QI-Igffigmp‘ 444 West Ocean Boulevard, Suite 800 3 Long Beach, CA 90802-4529 4/17/2023 3:16 PM 4 Landline: (562) 277—0848 By: Michelle Munguia, DEPUTY Mobile: (562) 208-0439 5 Facsimile: (562) 490-8339 e-mail: dm@davidmoriel.com 6 Attorneys for Petitioner LINDA A. 7 CARRASCO 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE COUNTY OF SAN BERNARDINO In Re The Matter: Case No.1 TRUSB2200003 1 O d g 11 ALICE SANCHEZ LIVING TRUST, Hearing no: 8o: °9 Dated December 2001, and as Date: 10.16.2023 E .5 .._, wNO 6, D. gg €13 3F 12 amended. . Tlme: 9:00 AM Q (ggfi Hon. Douglas K. Mann g“ g $3 13 —8 2 Date of death: 08/10/2021 Dept. s35 a m0 cu<\E u. :I 14 g g §g" g NOTICE OF MOTION AND MOTION 15 lg '9, 5g ,0; TO COMPEL FURTHER RESPONSES E g E 9% 16 TO SPECIAL INTERROGATORIES O PROPOUNDED BY LINDA A. iE 8 _°: E E 17 CARRASCO DIRECTED T0 TYRONE J. SANCHEZ, SET #1, MONETARY 18 SANCTIONS IN THE SUM 0F 19 $6,585.00, MEMORANDUM OF POINTS AND AUTHORITIES, AND 20 (PROPOSED) ORDER 21 [Separately Filed (1) Declaration Of 22 Attorney David D. Moriel With Attached Exhibits, and (2) Separate Statement] 23 LINDA CARRASCO 24 25 Petitioner, 26 VS. 27 TYRONE J. SANCHEZ, an individual, 28 TYRONE J. SANCHEZ, as the successor Recyctd Paper NOTICE 0F MOTION To COMPEL FURTHER RESPONSES To SPECIAL INTERROGATORIES PROPOUNDED BY LINDA A. CARRAsco DIRECTED To TYRONE J. SANCHEZ, SET #1, ETc..doc 1 of 3 trustee 0f the ALICE SANCHEZ LIVING TRUST, Dated December 6, 2001, MARIA T. SANCHEZ, and DOES 1 TO 50, INCLUSIVE. Respondent(s) TO ALL PARTIES AND THEIR RESPECTIVE ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that 0n the above time, date, and department, 0r as soon thereafter as this matter may be heard before the Honorable Douglas K. Mann, Judge sitting in Department S35 of the above-entitled Court, located at 247 West Third Street San Bernardino, CA 92415-0212, Petitioner Linda A. Carrasco seeks an order compelling further and 10 supplemental responses to Special Interrogatories Propounded By Linda A. Carrasco Directed 11 To Tyrone J. Sanchez, Set #1, and monetary sanctions in the sum 0f $6,585.00 against Tyrone J. MORIEL 800 562-490-8339 12 Sanchez and/or his counsel. Corporation D. Suite 90802-4529 13 This Motion is based on grounds the following grounds: The fist is the fact that DAVID Blvd., Fax Respondent Tyrone J. Sanchez has asserted frivolous boilerplate objections in Violation 0f the Law CA / 14 OF Ocean holding of also Korea Data Systems Co. Ltd. V. Superior Court (1997) 51 Ca1.App.4th 1513. Beach, 15 M, Professional OFFICES W. 562-277-0848 And he refuses to provide complete and straightforward responses per Code 0f Civil 16 Long 444 Procedure section 2030.220(a). A LAW Tel. 17 The requested orders are justified because the interrogatories directly relate to 18 Petitioner's claim that the Respondent, while acting as the Decedent's attorney—in—fact and co- 19 trustee, misappropriated $988,000.00 from Decadent by taking out loans against her real 20 property for his own benefit. 21 /// 22 /// /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 D Recycled Paper NOTICE OF MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES PROPOUNDED BY LINDA A. CARRASCO DIRECTED TO TYRONE J. SANCHEZ, SET #1, ETC..doc 20f3