Party Discovery: EASON -v- BLM VICTORVILLE et al Print

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     George G. Mgdesyan, Esq.           (State Bar    No. 225476)
     Araksya Boyadzhyan. Esq. (State Bar No. 299917)
     MGDESYAN LAW FIRM                                                                   sLégelJam'EégnhEFHE-figfigm
     4529 Sherman Oaks Avenue                                                              SAN BERNARDINO D.STRET

     Sherman Oaks. California 91403
                                                                                                MAY 05   2021
     Telephone: 818—386-6777
     Facsimile: 818—754—6778
                                                                                    BY
     Email: araksvac’iizmgdesvanlawcom
                       -



                                                                                         EUSA     H MART:       pm
     Attorneys for   Plaintiff.   DEBORAH ANTIONETTE EASON

                           SUPERIOR COURT OF THE STATE OF CALIFORNIA
                                    FOR THE COUNTY OF SAN BERNARDINO
     DEBORAH ANTIONETTE EASON                        an                 Case No.3 ClVDSl621424
     individual.
10                                                                      PLAINTIFF          DEBORAH EASON’S
                                  Plaintiff.
                                                                        SEPARATE STATEMENT IN
11                                                                      SUPPORT OF NOTICE OF MOTION
                                                                        AND MOTION TO COMPEL
12
                                                                        DEFENDANT BLM VICTORVILLE’S
13          VS.
                                                                        FURTHER RESPONSES T0
                                                                        INTERROGATORIES, SET ONE
14

                                                                         Trial Readiness: 07/22/2021 at 8:30 a.m.
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                                                                         Trial:   07/26/2021 at 10:00 a.m.

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     DOLLAR TREE STORES.                INC. SPICE
     DELIGHT. INC, and DOES                1   t0 100. inclusivc‘        Date:        July 1, 2021
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                                                                         Time:        9:00 a.m.
                                  Defendants.                            Location: 247 West Third St.
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                                                                         San Bernardino. CA 92415
                                                                         Dept:     $27
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                                                                         Action Filed: 12/06/201 6
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     TO THE HONORABLE COURT ALL PARTIES AND ATTORNEYS OF RECORD:
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               Pursuant t0 California Rules of Court 3.1345. Plaintiff DEBORAH                       EASON hereby
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     submits her Separate Statement of Items              in   Dispute in support of his Motion to Compel Further
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        PLAINTIFF     DEBORAH EASON‘S SEPARATE STATEMENT IN SUPPORT OF NOTICE OF MOTION AND
                   MOTION TO COMPEL DEFENDANT BLM VICTORVILLE’S FURTHER RESPONSES TO
                                                INTERROGATORIES, SET ONE: PAGE             1
                                       V                                                   V
     Responses to Request for Form Interrogatories and Special Interrogatories. Set One from


     Defendants      BLM VICTORVILLE as follows:


     PLAINTIFF’S REQUEST FOR FORM INTERROGATORIES NOAJ:
          At the time of the INCIDENT, was there in effect any policy of insurance through

     which you were or might be insured                in   any manner    (for   example, primary, pro-rata. 0r excess

     liability   coverage or medical expense coverage) for the damages, claims, or actions that have

     arisen out of the      INCIDENT?         If so, for    each policy   state:

             (a)      the kind 0f coverage;

             (b)      the   name and ADDRESS            of the insurance      com pany;
             (c)      the name,     ADDRESS, and telephone number of each named                         insured;

1O           (d)      the policy    num ber;
11           (e)      the limits of coverage for each type of coverage con-tained in the policy;

             (f)      whether any reservation of rights 0r controversy or coverage dispute                         exists
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     between you and the insurance company; and
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             (g)      the name,     ADDRESS, and            telephone   number 0f the      custodian of the policy.
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     DEFENDANT’S RESPONSE TO FORM INTERROGATORY NO.                                              4.1:
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             Yes. There      is   sufficient insurance t0 cover this claim.
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18   LEGAL AND FACTUAL REASONS FOR COMPELLING FURTHER RESPONSES:

19           Code ofCivil Procedure               2030.210 requires     that “(a)   The   party to   whom   interrogatories
                                              §

20   have been propounded                  respond   in writing   under oath separately
                                   shall                                                    t0   each interrogatory by any

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     ofthe following:

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23           (l)    An answer containing          the information sought t0 be discovered.


24           (.2)   An   exercise of the party's option to produce writings.


25           (3)    An   objection to the particular interrogatory.



        PLAINTIFF      DEBORAH EASON'S SEPARATE STATEMENT IN SUPPORT OF NOTICE ()F MOTION AND
                    MOTION TO COMPEL DEFENDANT BLM VlCTORVlLLE'S FURTHER RESPONSES TO
                                     INTERROGATORIES. SET ONE: PAGE 2