On December 08, 2016 a
Party Discovery
was filed
involving a dispute between
Dollar Tree Stores, Inc.,
Spice Delight, Inc,
Eason, Deborah Antionette,
and
Blm Victorville,
Dollar Tree Stores Inc,
Spice Delight Inc,
for Personal Injury Non-Motor Vehicle Unlimited
in the District Court of San Bernardino County.
Preview
:2: E 5. E 1D
rvs_;:.>Eqarw COURT OFU KL I
{J:N' A
x)
George G. Mgdesyan, Esq.
‘
(State Bar No. 225476) 5.
E
waif:
Araksya Boyadzhyan, Esq. (State Bar No. 299917)
MGDESYAN LAW FIRM DEC2 1 2029
4529 Sherman Oaks Avenue
¢
Sherman Oaks, Caufomia 91 403 gfafqfl [$33.
,
Telephone: 818-386—6777 AFWELS'E 3333‘- J
Faicsimile: 813-754—6778
cooxloxmawm—
Email: arakéva@ngdesy'anlaw.com
Attorneys for Plaintiff, DEBORAH ANTIONETTE EASON
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR TIE COUNTY 0F SAN BERNARDINO
DEBORAH ANTIONETTE EASON an ) Case No.: CIVDSI621424
individual, )
) PLAINTIFF’S NOTICE OF MOTION
Plaintiff, AND MOTION TO COMPEL
g
DEFENDANT BLM VICTORVILLE’S
RESPONSES T0 REQUEST FOR
PRODUCTION OF DOCUMENTS,
VS. SET ONE, AND REQUEST FOR
)
MONETARY SANCTIONS IN THE
)
SUM OF $1,060.00 AGAINST
DEFENDANT AND HIS ATTORNEY
NNNNNNNNN—r—Iua—nr—I—fl—u—A—A
0F RECORD; MEMORANDUM 0F
POINTS AND AUTHORITIES;
g
W‘JO‘sLflhWNHOOOCNQM-PWNfi—‘O
DOLLAR TREE STORES, INC., SPICE DECLARATION 0F ARAKSYA
DELIGHT, INC, and DOES 1 to 100, inclusive, BOYADZHYAN IN SUPPORT
i THEREOF
Dcfendanfs.
[Concurrentlyfiled with [Proposed]
) 0rde r]
)
) Trial Readiness: 07/22/2021 at 8:30 am.
) Trial: 07/26/2021 at 10:00 am.
Action Filed: 12/06/2016
i
Date: January 26, 2021
Time: 9:00 a.m.
i
Location: 247 Wat Third St.
San Bernardino, CA 92415
) Dept: 827
)
u
I
PLAINTIFF’ S NOTICEOF MOTION AND MOTION TO COMPEL DEFENDANT 99 CENTS ONLY S'l ORES LLC S
RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SE’I ONE, AND REQUEST FOR MONETARY
SANCTIONS 1N THE SUM OF $1 7060.- 00 AGAINST DEFENDANT AND HIS ATFQRNEYBF
MEMORANDUM OP POINTS AND AU’I IIORITIE§s Eggéjggé’l‘lQN @F‘ ARAK§YA QQVABZIWARN EN §Uf’PQR’f
T0 ALL PARTIES AND ATTORNEYS 0F RECORD:
PLEASE TAKE NOTICE that on January 26, 2021 at 9:00AM, or as soon thereafier as the
matter can be heard in Department “S27” of the above-entitled
Court located at 247 West Third
\DWQQM#WN—u
Street, San Bernardino, CA 92415. Plaintiff, DEBORAH ANTIONE'I'I'E EASON, by and
through his attorney ofrecord will, and hereby does move the Court for an order compelling
Defendant, BLM VICTORVILLE’S to respond to Plaintifl‘ Deborah Antionette Eason’s Request
for Production of Documents, Set One and for an order imposing fnonetary sanctions against
p—
Defendant BLM VICTORVILLE and its counsel of record in the amount of $1,060.00
This motion will be made pursuant to California Code of Civil Procedure Section
Hhr—a
WNHO
2031.300(a), (b), and (c) and applicable case law on the grounds that Defendant BLM
VICTORVILLE is willfully frustrating Plaintifl‘ DEBORAH ANTIONETI‘E EASON’S
boa
p—A
fundamental right to discovery by refusing to provide any response to Plaintiff’s First Set of
I— QMQ
Requests for Production of Documents.
p—I
r—t
fl
This motion will be based on this notice, the attached memorandum ofpoints and
p—s
authorities, the declaration of Araksya Boyadzhyan, the attached exhibits, and upon the complete
p—4
HOOOO
court records and files in this action and upon such further oral and documentary evidence as
N
may be presented at the hearing of this motion by counsel for moving
parties.
N
M
[\J
LAN
DATED: November 17, 2020 MGDESYAN LAW FIRM
[\J
[\J
N OO'xIO‘UI-D
GEGRGE G. MGDESYAN, ESQ.
ARAKSYA BOYADZHYAN, ESQ.
N
Attorneys for Plaintiff,
N DEBORAH ANTIONETTE EASON
2
PLAINTIFF’S NOTICE OF MOTION AND MOTION T0 COMPEL DEFENDANT 99 CENTS ONLY STORES, LLC'S
RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, AND REQUEST FOR MONETARY
SANCTIONS IN THE SUM 0F S 1,060.00 AGAINST DEFENDANT AND HIS ATTORNEY 0F RECORD;
MEMORANDUM 0F POINTS AND AUTHORITIES; DECLARATION 0F ARAKSYA BOYADZHYAN IN
SUPPORT
THEREOF
Document Filed Date
December 21, 2020
Case Filing Date
December 08, 2016
Category
Personal Injury Non-Motor Vehicle Unlimited
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Preview
:2: E 5. E 1D rvs_;:.>Eqarw COURT OFU KL I {J:N' A x) George G. Mgdesyan, Esq. ‘ (State Bar No. 225476) 5. E waif: Araksya Boyadzhyan, Esq. (State Bar No. 299917) MGDESYAN LAW FIRM DEC2 1 2029 4529 Sherman Oaks Avenue ¢ Sherman Oaks, Caufomia 91 403 gfafqfl [$33. , Telephone: 818-386—6777 AFWELS'E 3333‘- J Faicsimile: 813-754—6778 cooxloxmawm— Email: arakéva@ngdesy'anlaw.com Attorneys for Plaintiff, DEBORAH ANTIONETTE EASON SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR TIE COUNTY 0F SAN BERNARDINO DEBORAH ANTIONETTE EASON an ) Case No.: CIVDSI621424 individual, ) ) PLAINTIFF’S NOTICE OF MOTION Plaintiff, AND MOTION TO COMPEL g DEFENDANT BLM VICTORVILLE’S RESPONSES T0 REQUEST FOR PRODUCTION OF DOCUMENTS, VS. SET ONE, AND REQUEST FOR ) MONETARY SANCTIONS IN THE ) SUM OF $1,060.00 AGAINST DEFENDANT AND HIS ATTORNEY NNNNNNNNN—r—Iua—nr—I—fl—u—A—A 0F RECORD; MEMORANDUM 0F POINTS AND AUTHORITIES; g W‘JO‘sLflhWNHOOOCNQM-PWNfi—‘O DOLLAR TREE STORES, INC., SPICE DECLARATION 0F ARAKSYA DELIGHT, INC, and DOES 1 to 100, inclusive, BOYADZHYAN IN SUPPORT i THEREOF Dcfendanfs. [Concurrentlyfiled with [Proposed] ) 0rde r] ) ) Trial Readiness: 07/22/2021 at 8:30 am. ) Trial: 07/26/2021 at 10:00 am. Action Filed: 12/06/2016 i Date: January 26, 2021 Time: 9:00 a.m. i Location: 247 Wat Third St. San Bernardino, CA 92415 ) Dept: 827 ) u I PLAINTIFF’ S NOTICEOF MOTION AND MOTION TO COMPEL DEFENDANT 99 CENTS ONLY S'l ORES LLC S RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SE’I ONE, AND REQUEST FOR MONETARY SANCTIONS 1N THE SUM OF $1 7060.- 00 AGAINST DEFENDANT AND HIS ATFQRNEYBF MEMORANDUM OP POINTS AND AU’I IIORITIE§s Eggéjggé’l‘lQN @F‘ ARAK§YA QQVABZIWARN EN §Uf’PQR’f T0 ALL PARTIES AND ATTORNEYS 0F RECORD: PLEASE TAKE NOTICE that on January 26, 2021 at 9:00AM, or as soon thereafier as the matter can be heard in Department “S27” of the above-entitled Court located at 247 West Third \DWQQM#WN—u Street, San Bernardino, CA 92415. Plaintiff, DEBORAH ANTIONE'I'I'E EASON, by and through his attorney ofrecord will, and hereby does move the Court for an order compelling Defendant, BLM VICTORVILLE’S to respond to Plaintifl‘ Deborah Antionette Eason’s Request for Production of Documents, Set One and for an order imposing fnonetary sanctions against p— Defendant BLM VICTORVILLE and its counsel of record in the amount of $1,060.00 This motion will be made pursuant to California Code of Civil Procedure Section Hhr—a WNHO 2031.300(a), (b), and (c) and applicable case law on the grounds that Defendant BLM VICTORVILLE is willfully frustrating Plaintifl‘ DEBORAH ANTIONETI‘E EASON’S boa p—A fundamental right to discovery by refusing to provide any response to Plaintiff’s First Set of I— QMQ Requests for Production of Documents. p—I r—t fl This motion will be based on this notice, the attached memorandum ofpoints and p—s authorities, the declaration of Araksya Boyadzhyan, the attached exhibits, and upon the complete p—4 HOOOO court records and files in this action and upon such further oral and documentary evidence as N may be presented at the hearing of this motion by counsel for moving parties. N M [\J LAN DATED: November 17, 2020 MGDESYAN LAW FIRM [\J [\J N OO'xIO‘UI-D GEGRGE G. MGDESYAN, ESQ. ARAKSYA BOYADZHYAN, ESQ. N Attorneys for Plaintiff, N DEBORAH ANTIONETTE EASON 2 PLAINTIFF’S NOTICE OF MOTION AND MOTION T0 COMPEL DEFENDANT 99 CENTS ONLY STORES, LLC'S RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, AND REQUEST FOR MONETARY SANCTIONS IN THE SUM 0F S 1,060.00 AGAINST DEFENDANT AND HIS ATTORNEY 0F RECORD; MEMORANDUM 0F POINTS AND AUTHORITIES; DECLARATION 0F ARAKSYA BOYADZHYAN IN SUPPORT THEREOF