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Joseph Lavi, Esq.
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(SBN 209776)
V
jlavigcblglawfirm.com f
F s
SUPERIOR COURT OF CALIFORNIA
L E D
Vincent C. Granberry, Esq. (SBN 276483) COUNTY 0F SAN BERNARDINO
vgranberrya-Dlelawfirmcom SAN BERNARDINO DISTRICT
Anwar D. Burton, Esq. (SBN 253504)
aburton(aDlealawfirm.com MAY 1 9 2021
Pooja V. Patel, Esq. (SBN 317891)
-"
ppatelgcblelawfirmpom i
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LAVI & EBRAHIMIAN, LLP BY ‘ MMM'; 41’. fi
8889 W. Olympic Blvd, Suite 200 u ORIA M ?BOHTILLO. DEPUTY
Beverly Hills, California 90211
Telephone: (310) 432-0000
Facsimile: (3 10) 432-0001
Attorneys for PLAINTIFF JEFFREY MADDIES,
0n behalf of himself and others similarly situated.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10
FOR THE COUNTY OF SAN BERNARDINO
11
12
JEFFREY MADDIES, on behalf of himself and Case No.2 CIVDS1919776
others similarly situated,
13
CLASS ACTION
PLAINTIFF,
14
[Assignedfor all purposes t0 the Hon. David
VS'
15 Cohn; Dept. 5—26]
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GOLIATH FINANCIAL, INC; and DOES 1 to PLAINTIFF JEFFREY MADDIES’S
100, inclusive, NOTICE OF MOTION AND MOTION
17
TO COMPEL DEFENDANT GOLIATH
DEFENDANTS .
FINANCIAL, INC.’S FURTHER
18
RESPONSES TO PLAINTIFF’S
19 REQUEST FOR FORM
INTERROGATORIES, GENERAL, SET
ONE AND REQUEST FOR SANCTIONS
IN THE AMOUNT OF $6,202.49
[Filed concurrently with the Declaration 0f
Pooja V. Patel in support thereof; Separate
Statement in support thereof and [Proposed]
Order]
HEARING INFORMATION:
Date: July 6, 2021
Time: 10:00 am.
Dept: 826
PLAINTIFF JEFFREY MADDIES’S NOTICE OF MOTION AND MOTION TO COMPEL DEFENDANT
GOLIATH FINANCIAL, INC.’S FURTHER RESPONSES TO PLAINTIFF’S REQUEST FOR FORM
INTERROGATORIES, GENERAL, SET ONE AND REQUEST FOR SANCTIONS IN THE AMOUNT OF $6,202.49
1
V v
TO THE HONORABLE COURT, TO ALL PARTIES AND THEIR ATTORNEY(S)
OF RECORD:
NOTICE IS HEREBY GIVEN that on July 6, 2021, at 10:00 am. in Department S-26 of
the Superior Court for the County of San Bernardino, San Bemardino Justice Center, located at 247
West Third Street, San Bemardino, California 92415, Plaintiff JEFFREY MADDIES ("Plaintiff”)
will, and hereby does, move for an order compelling Defendant GOLIATH FINANCIAL, INC.
("Defendant") to provide further responses to Plaintiffs Request for Form Interrogatories, General,
Set One numbers 1 through 76.
On October 25, 2021, Plaintiff propounded Request for Form Interrogatories, General, Set
10 One. (See Declaration of Pooja V. Patel (“Patel Decl.”) 114.) Despite multiple extensions, several
11 meet and confer efforts, and two informal discovery conferences, as of the date of the filing of this
12 motion, Plaintiff has not received supplemental substantive responses to its Request for Form
13 Interrogatories, General, Set One. (Patel Dec1., 1116.) After obtaining an extension, Defendant
14 served all boilerplate objects to Plaintiff‘s Request for Form Interrogatories, General, Set One.
15 (Patel Decl., 116.) Specifically, each and every response was an identical string objection and there
16 was clearly no attempt made to narrow or tailor the response to the specific Request. (Patel Decl.,
17 'H7.)
18 On April 7, 2021, at the Parties second informal discovery conference, this Court gave
19 Plaintiff permission to proceed with a Motion to Compel responses t0 Plaintiffs Request for Form
20 Interrogatories, General, Set One and seek sanctions against Defendant, with a deadline for May 21,
21 2021. (Patel Decl., 1114.) On April 27, 2021, at the Case Management Conference, this Court
22 scheduled Plaintiff’s Motion to Compel hearing and a further Case Management Conference for
23 July 6, 2021. (Patel Decl., 1115.) Therefore, Plaintiff now brings the instant motion to compel.
24 PLEASE TAKE FURTHER NOTICE Plaintiff will also seek sanctions in the amount 0f
25 $6,202.49 from Defendant or its attorneys of record Brendan T. Sapien of Lewis Brisbois for the
26 attorneys' fees and costs associated in preparing and filing this motion. (Patel Decl., 1117.)
27 This motion to compel further responses and request for sanctions are based on Code of
28
PLAINTIFF JEFFREY MADDIES’S NOTICE OF MOTION AND MOTION TO COMPEL DEFENDANT
GOLIATH FINANCIAL, INC.’S FURTHER RESPONSES TO PLAINTIFF’S REQUEST FOR FORM
INTERROGATORIES, GENERAL, SET ONE AND REQUEST FOR SANCTIONS IN THE AMOUNT OF $6,202.49
2
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Joseph Lavi, Esq. \" (SBN 209776) V jlavigcblglawfirm.com f F s SUPERIOR COURT OF CALIFORNIA L E D Vincent C. Granberry, Esq. (SBN 276483) COUNTY 0F SAN BERNARDINO vgranberrya-Dlelawfirmcom SAN BERNARDINO DISTRICT Anwar D. Burton, Esq. (SBN 253504) aburton(aDlealawfirm.com MAY 1 9 2021 Pooja V. Patel, Esq. (SBN 317891) -" ppatelgcblelawfirmpom i .o _ x LAVI & EBRAHIMIAN, LLP BY ‘ MMM'; 41’. fi 8889 W. Olympic Blvd, Suite 200 u ORIA M ?BOHTILLO. DEPUTY Beverly Hills, California 90211 Telephone: (310) 432-0000 Facsimile: (3 10) 432-0001 Attorneys for PLAINTIFF JEFFREY MADDIES, 0n behalf of himself and others similarly situated. SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 FOR THE COUNTY OF SAN BERNARDINO 11 12 JEFFREY MADDIES, on behalf of himself and Case No.2 CIVDS1919776 others similarly situated, 13 CLASS ACTION PLAINTIFF, 14 [Assignedfor all purposes t0 the Hon. David VS' 15 Cohn; Dept. 5—26] 16 GOLIATH FINANCIAL, INC; and DOES 1 to PLAINTIFF JEFFREY MADDIES’S 100, inclusive, NOTICE OF MOTION AND MOTION 17 TO COMPEL DEFENDANT GOLIATH DEFENDANTS . FINANCIAL, INC.’S FURTHER 18 RESPONSES TO PLAINTIFF’S 19 REQUEST FOR FORM INTERROGATORIES, GENERAL, SET ONE AND REQUEST FOR SANCTIONS IN THE AMOUNT OF $6,202.49 [Filed concurrently with the Declaration 0f Pooja V. Patel in support thereof; Separate Statement in support thereof and [Proposed] Order] HEARING INFORMATION: Date: July 6, 2021 Time: 10:00 am. Dept: 826 PLAINTIFF JEFFREY MADDIES’S NOTICE OF MOTION AND MOTION TO COMPEL DEFENDANT GOLIATH FINANCIAL, INC.’S FURTHER RESPONSES TO PLAINTIFF’S REQUEST FOR FORM INTERROGATORIES, GENERAL, SET ONE AND REQUEST FOR SANCTIONS IN THE AMOUNT OF $6,202.49 1 V v TO THE HONORABLE COURT, TO ALL PARTIES AND THEIR ATTORNEY(S) OF RECORD: NOTICE IS HEREBY GIVEN that on July 6, 2021, at 10:00 am. in Department S-26 of the Superior Court for the County of San Bernardino, San Bemardino Justice Center, located at 247 West Third Street, San Bemardino, California 92415, Plaintiff JEFFREY MADDIES ("Plaintiff”) will, and hereby does, move for an order compelling Defendant GOLIATH FINANCIAL, INC. ("Defendant") to provide further responses to Plaintiffs Request for Form Interrogatories, General, Set One numbers 1 through 76. On October 25, 2021, Plaintiff propounded Request for Form Interrogatories, General, Set 10 One. (See Declaration of Pooja V. Patel (“Patel Decl.”) 114.) Despite multiple extensions, several 11 meet and confer efforts, and two informal discovery conferences, as of the date of the filing of this 12 motion, Plaintiff has not received supplemental substantive responses to its Request for Form 13 Interrogatories, General, Set One. (Patel Dec1., 1116.) After obtaining an extension, Defendant 14 served all boilerplate objects to Plaintiff‘s Request for Form Interrogatories, General, Set One. 15 (Patel Decl., 116.) Specifically, each and every response was an identical string objection and there 16 was clearly no attempt made to narrow or tailor the response to the specific Request. (Patel Decl., 17 'H7.) 18 On April 7, 2021, at the Parties second informal discovery conference, this Court gave 19 Plaintiff permission to proceed with a Motion to Compel responses t0 Plaintiffs Request for Form 20 Interrogatories, General, Set One and seek sanctions against Defendant, with a deadline for May 21, 21 2021. (Patel Decl., 1114.) On April 27, 2021, at the Case Management Conference, this Court 22 scheduled Plaintiff’s Motion to Compel hearing and a further Case Management Conference for 23 July 6, 2021. (Patel Decl., 1115.) Therefore, Plaintiff now brings the instant motion to compel. 24 PLEASE TAKE FURTHER NOTICE Plaintiff will also seek sanctions in the amount 0f 25 $6,202.49 from Defendant or its attorneys of record Brendan T. Sapien of Lewis Brisbois for the 26 attorneys' fees and costs associated in preparing and filing this motion. (Patel Decl., 1117.) 27 This motion to compel further responses and request for sanctions are based on Code of 28 PLAINTIFF JEFFREY MADDIES’S NOTICE OF MOTION AND MOTION TO COMPEL DEFENDANT GOLIATH FINANCIAL, INC.’S FURTHER RESPONSES TO PLAINTIFF’S REQUEST FOR FORM INTERROGATORIES, GENERAL, SET ONE AND REQUEST FOR SANCTIONS IN THE AMOUNT OF $6,202.49 2