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.
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H George G. Mgdesyan. Esq. (State Bar No. 225476)
Araksya Boyadzhyan, Esq. (State Bar No. 29991 7) F L I
N
MGDESYAN LAW FIRM s%%%“~’?v"8c°°s§§§‘es?“m§8“~“
SAN BERNARD'NO DISTRC’P
DJ
4529 Sherman Oaks Avenue
Sherman Oaks, California 91403 MAY 05
b 2021
Telephone: 818—386-6777
Kl)
Facsimile: 818—754—6778
,. BY
.. n,
0 Email. draksw afim1gdchanlawcom ELISAB H MART, PUTY
fl
Attomeys for Plaintiff. DEBORAH ANTIONETTE EASON
0°
SUPERIOR COURT OF THE STATE 0F CALIFORNIA
FOR THE COUNTY OF SAN BERNADRINO
'C
u...
O
DEBORAH ANTIONET'I‘E EASON an ) Case No.: Clvns1621424
)
individual,
) NOTICE 0F MOTION AND MOTION
plaintiff;
2 T0 COMPEL DEFENDANT BLM
§
VICTORVILLE’S FURTHER
)
RESPONSES T0
) INTERROGATORIES, AND REQUEsfl
VS,
) FOR SANCTIONS IN THE SUM 0F
$1,090.00 AGAINST DEFENDANT
AND ITS ATTORNEY 0F RECORD;
g
)
)
MEMORANDUM 0F POINTS AND
) AUTHORITIES; DECLARATION 0F
)
ARAKSYA BOYADZHVAN IN
INC. SPICE
)
SUPPORT THEREOF
DOLLAR TREE STORES,
DELIGHT, INC, and DOES 1 t0 100, inclusive.
Trial Readiness: 07/22/2021 at 8:30 a.m.
DefendantS- -
T rial: 07/26/2021 at 10:00 am.
A ction Filed: 12/06/2016
Date: July l, 2021
‘
JVVVVVVVVVVVVVVVV'VV
Time: 9:00 a.m.
Location: 247 West Third St.
L.)
A San Bernardino, CA 92415
Dept: $27
NOTICE MOTION AND MOTION TO COMPEL DEFENDANI' BLM VICTOR
()F
INTERROGA'IT)RIES. AND REQUEST FOR SANCTIONS 1N THE
ATTORNEY OF RECORD: MEMOR ANDUM
BOYADZHYAN 1N SUPPORT THEREOF
()F POINTS AND
SUM
AUTHOR
()F
l
ITIES;
VILLE‘S FURTHER RESPONSES TO
51.090.0 0 AGAINST DEFENDAN'I‘ AND ITS
DECLAR ATION 0F ARAKSYA
WW
T0 ALL PARTIES AND ATTORNEYS OF RECORD:
9:00AM. or as soon thereafter as the
PLEASE TAKE NOTICE that 0n July 1. 2021 at
b)
“S27" 0f the above—emitled Court located at 247 West Third
matter can be heard in Department
Street, San Bemardino, CA 92415. Plaintiff. DEBORAH ANTIONETTE EASON by and
move the Court for an order compelling
through his attorney of record will. and hereby does
\OWVQUI-b
Defendant, BLM VICTORVILLE‘S further responses to Plaintiff DEBORAH ANTIONETTE
EASON‘S Form Interrogatories. Set One and Special Interrogatories. Set One.
300 Plaintiff hereby moves for an
Pursuant to Code ofCivil Procedure. sections 2030.
to Interrogatories.
order compelling further discovery response
and hereby does move this Court
PLEASE TAKE FURTHER NOTICE that Plaintiffwill
Code 0f Civil Procedure 2030.300 for an order that imposes monetary sanctions on
pursuant to
in the amount of $1 .090.00 for
Defendant BLM VICTORVILLE and/or its attorneys ofrecord,
'I'he motion further made on the grounds that Plaintiff
the reasonable attorney‘s fees and costs.
is
reasonable and good-faith attempt at informal resolution of the issues addressed in this
made a
motion but Defendant has still refused to provide further responses.
The motion will be based on this Notice 0f Motion and Motion the accompanying
Boyadzhyan, papers and
Authorities, the Declaration of Araksya
all
Memorandum of Points and
ce and oral arguments as may be presented at
documents on file herein and on such further eviden
the hearing of the motion.
MGDESY FIRM
DATED: May 4, 2021 ‘
GEO GDESYAN, ESQ. .
ARAKSYA BOYADZHYAN, ESQ.
Attorneys for Plaintiff.
DEBORAH ANTIONETTE EASON
______._.__________:_______._____.J
NOTICE OF MOTION AND MOTION TO COMPEL DEFENDANT
BLM VK‘TORV’ILLE‘S FURTHER RESPONSES TO
THIS SUM OF $l.()90.()0 AGAINST DEFENDANT AND
ITS
INTERROGA'I‘ORIES. AND REQUEST FOR SANCTIONS IN A'I'IO N OF ARAKSYA
AND AUTHOR ITIES: DECLAR
ATTORNEY ()F RECORD; MEMORANDUM 0F POINTS
BOYADZHYAN [N SUPPORT THEREOF
Document Filed Date
May 05, 2021
Case Filing Date
December 08, 2016
Category
Personal Injury Non-Motor Vehicle Unlimited
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H George G. Mgdesyan. Esq. (State Bar No. 225476) Araksya Boyadzhyan, Esq. (State Bar No. 29991 7) F L I N MGDESYAN LAW FIRM s%%%“~’?v"8c°°s§§§‘es?“m§8“~“ SAN BERNARD'NO DISTRC’P DJ 4529 Sherman Oaks Avenue Sherman Oaks, California 91403 MAY 05 b 2021 Telephone: 818—386-6777 Kl) Facsimile: 818—754—6778 ,. BY .. n, 0 Email. draksw afim1gdchanlawcom ELISAB H MART, PUTY fl Attomeys for Plaintiff. DEBORAH ANTIONETTE EASON 0° SUPERIOR COURT OF THE STATE 0F CALIFORNIA FOR THE COUNTY OF SAN BERNADRINO 'C u... O DEBORAH ANTIONET'I‘E EASON an ) Case No.: Clvns1621424 ) individual, ) NOTICE 0F MOTION AND MOTION plaintiff; 2 T0 COMPEL DEFENDANT BLM § VICTORVILLE’S FURTHER ) RESPONSES T0 ) INTERROGATORIES, AND REQUEsfl VS, ) FOR SANCTIONS IN THE SUM 0F $1,090.00 AGAINST DEFENDANT AND ITS ATTORNEY 0F RECORD; g ) ) MEMORANDUM 0F POINTS AND ) AUTHORITIES; DECLARATION 0F ) ARAKSYA BOYADZHVAN IN INC. SPICE ) SUPPORT THEREOF DOLLAR TREE STORES, DELIGHT, INC, and DOES 1 t0 100, inclusive. Trial Readiness: 07/22/2021 at 8:30 a.m. DefendantS- - T rial: 07/26/2021 at 10:00 am. A ction Filed: 12/06/2016 Date: July l, 2021 ‘ JVVVVVVVVVVVVVVVV'VV Time: 9:00 a.m. Location: 247 West Third St. L.) A San Bernardino, CA 92415 Dept: $27 NOTICE MOTION AND MOTION TO COMPEL DEFENDANI' BLM VICTOR ()F INTERROGA'IT)RIES. AND REQUEST FOR SANCTIONS 1N THE ATTORNEY OF RECORD: MEMOR ANDUM BOYADZHYAN 1N SUPPORT THEREOF ()F POINTS AND SUM AUTHOR ()F l ITIES; VILLE‘S FURTHER RESPONSES TO 51.090.0 0 AGAINST DEFENDAN'I‘ AND ITS DECLAR ATION 0F ARAKSYA WW T0 ALL PARTIES AND ATTORNEYS OF RECORD: 9:00AM. or as soon thereafter as the PLEASE TAKE NOTICE that 0n July 1. 2021 at b) “S27" 0f the above—emitled Court located at 247 West Third matter can be heard in Department Street, San Bemardino, CA 92415. Plaintiff. DEBORAH ANTIONETTE EASON by and move the Court for an order compelling through his attorney of record will. and hereby does \OWVQUI-b Defendant, BLM VICTORVILLE‘S further responses to Plaintiff DEBORAH ANTIONETTE EASON‘S Form Interrogatories. Set One and Special Interrogatories. Set One. 300 Plaintiff hereby moves for an Pursuant to Code ofCivil Procedure. sections 2030. to Interrogatories. order compelling further discovery response and hereby does move this Court PLEASE TAKE FURTHER NOTICE that Plaintiffwill Code 0f Civil Procedure 2030.300 for an order that imposes monetary sanctions on pursuant to in the amount of $1 .090.00 for Defendant BLM VICTORVILLE and/or its attorneys ofrecord, 'I'he motion further made on the grounds that Plaintiff the reasonable attorney‘s fees and costs. is reasonable and good-faith attempt at informal resolution of the issues addressed in this made a motion but Defendant has still refused to provide further responses. The motion will be based on this Notice 0f Motion and Motion the accompanying Boyadzhyan, papers and Authorities, the Declaration of Araksya all Memorandum of Points and ce and oral arguments as may be presented at documents on file herein and on such further eviden the hearing of the motion. MGDESY FIRM DATED: May 4, 2021 ‘ GEO GDESYAN, ESQ. . ARAKSYA BOYADZHYAN, ESQ. Attorneys for Plaintiff. DEBORAH ANTIONETTE EASON ______._.__________:_______._____.J NOTICE OF MOTION AND MOTION TO COMPEL DEFENDANT BLM VK‘TORV’ILLE‘S FURTHER RESPONSES TO THIS SUM OF $l.()90.()0 AGAINST DEFENDANT AND ITS INTERROGA'I‘ORIES. AND REQUEST FOR SANCTIONS IN A'I'IO N OF ARAKSYA AND AUTHOR ITIES: DECLAR ATTORNEY ()F RECORD; MEMORANDUM 0F POINTS BOYADZHYAN [N SUPPORT THEREOF