On September 07, 2021 a
Motion-Secondary
was filed
involving a dispute between
Novalk, Llc,
and
Cirit, Denis Baran,
Cirit, Fatma Handan,
Cirit, Semih,
C-Tech, Inc,
Does 1-100,
Kim, Yun Kyung,
Kyung, Yun,
Nc Queen, Inc.,
Sargent, Sarina Berna,
for Other Real Property Unlimited
in the District Court of San Bernardino County.
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9-fiug-ZBZZ —
16 45
: 14212789418 p Z .
”\sa \
F I L E D
StwaRIOR coma 0F CALIFORNIA
COUNTY 0F SAN emNARDmo
Michelangelo Tatone (SBN: 29043 l)
SAN BERNARDQNO DISTRICT
TATONE LAW, APC AU G 0 9 2022
4333 Admiralty Way, Ste. 100
Marina del Rey, CA 90292
Phone: (424) 289-9707
Email: mtatone@tatonelegal.com
BY Mu.“
v {ufifl
~
d7
WCTOR'A SANChEZ' D PUTY
Attorney for Plaintiff
NOVALK, LLC
SUPERIOR COURT OF THE STATE 0F CALIFORNIA
COUNTY 0F SAN BERNARDINO
10 NOVALK, LLC, Case No.: CWSBZI 22277
ll Plaintiff,
PLAINTIFFS' REPLY TO DEFENDANTS’
12 vs. OPPOSITION T0 PLAIN'I‘IFF’S MOTIONS
TO COMPEL DEFENDANTS T0 FURTHER
13 SEMIH CI'RIT; FATMA HANDAN DEN’ES C'I‘RIT; RESPOND T0 PLAINTIFFS’ REQUESTS
BARAN CIRIT; SARINA BBRNA SARGENT; C— FOR PRODUCTION, SET ONE, AND
TECH, INC; NC QUEEN, INC; Y'UN KYUNG REQUEST FOR MONETARY SANCTIONS
and DOES 1—100, inclusive,
15 [Concurrently filed with Supplemental
Defendants. Declaration 0f Michelangelo Tatone]
16
l7
18 MEMQRANDUM 0F POINTS AND AUTHORITIES
19 'l'.
INTRODUCTION
20 Plaintiff NOVALK, LLC (“Plaintiff’ or “Novalk”) submits the herein Reply in response to the
21 Opposition to the Six Motions to Compel Further Rasponses to Requwts for Production of Documents
22 (“Opposition”). Contrary to Dcfendants’ baseless and unfounded contention that Plaintiff has over litigated
23 the case, this is simply not true, and has no basis for whether the Motions to Compel should be granted or
24 not. Pursuant to the Discovery Act, Defendants were obligated to provide timely responses; however,
25 because they failed to do so, objections were waived. (Cal. Code Civ. Proc. § 203 1 .3 10(c).)
26
Moreover, the Motions to Compel are not untimely. The Motions were served and filed in the time
period in which the parties agreed that motions to compel would be filed; specifically, on or before July 7,
2022. (See Supplemental Declaration of Michelangelo Tatone (“Supp Tatone Deci.” 113.) However,
PLAINTIFFS’ REPLY TO DEFENDANT’S OPPOSITION T0 PLAINTIFFS’ MOTION T0 COMPEL
DEFENDAN'PS TO FURTHER RESPOND T0 PLAINTIFFS’ REQUESTS FOR PRODUCTION, SET ONE, AND
REQUEST FOR MONETARY SANCTIONS
l
Document Filed Date
August 09, 2022
Case Filing Date
September 07, 2021
Category
Other Real Property Unlimited
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9-fiug-ZBZZ — 16 45 : 14212789418 p Z . ”\sa \ F I L E D StwaRIOR coma 0F CALIFORNIA COUNTY 0F SAN emNARDmo Michelangelo Tatone (SBN: 29043 l) SAN BERNARDQNO DISTRICT TATONE LAW, APC AU G 0 9 2022 4333 Admiralty Way, Ste. 100 Marina del Rey, CA 90292 Phone: (424) 289-9707 Email: mtatone@tatonelegal.com BY Mu.“ v {ufifl ~ d7 WCTOR'A SANChEZ' D PUTY Attorney for Plaintiff NOVALK, LLC SUPERIOR COURT OF THE STATE 0F CALIFORNIA COUNTY 0F SAN BERNARDINO 10 NOVALK, LLC, Case No.: CWSBZI 22277 ll Plaintiff, PLAINTIFFS' REPLY TO DEFENDANTS’ 12 vs. OPPOSITION T0 PLAIN'I‘IFF’S MOTIONS TO COMPEL DEFENDANTS T0 FURTHER 13 SEMIH CI'RIT; FATMA HANDAN DEN’ES C'I‘RIT; RESPOND T0 PLAINTIFFS’ REQUESTS BARAN CIRIT; SARINA BBRNA SARGENT; C— FOR PRODUCTION, SET ONE, AND TECH, INC; NC QUEEN, INC; Y'UN KYUNG REQUEST FOR MONETARY SANCTIONS and DOES 1—100, inclusive, 15 [Concurrently filed with Supplemental Defendants. Declaration 0f Michelangelo Tatone] 16 l7 18 MEMQRANDUM 0F POINTS AND AUTHORITIES 19 'l'. INTRODUCTION 20 Plaintiff NOVALK, LLC (“Plaintiff’ or “Novalk”) submits the herein Reply in response to the 21 Opposition to the Six Motions to Compel Further Rasponses to Requwts for Production of Documents 22 (“Opposition”). Contrary to Dcfendants’ baseless and unfounded contention that Plaintiff has over litigated 23 the case, this is simply not true, and has no basis for whether the Motions to Compel should be granted or 24 not. Pursuant to the Discovery Act, Defendants were obligated to provide timely responses; however, 25 because they failed to do so, objections were waived. (Cal. Code Civ. Proc. § 203 1 .3 10(c).) 26 Moreover, the Motions to Compel are not untimely. The Motions were served and filed in the time period in which the parties agreed that motions to compel would be filed; specifically, on or before July 7, 2022. (See Supplemental Declaration of Michelangelo Tatone (“Supp Tatone Deci.” 113.) However, PLAINTIFFS’ REPLY TO DEFENDANT’S OPPOSITION T0 PLAINTIFFS’ MOTION T0 COMPEL DEFENDAN'PS TO FURTHER RESPOND T0 PLAINTIFFS’ REQUESTS FOR PRODUCTION, SET ONE, AND REQUEST FOR MONETARY SANCTIONS l