On July 09, 2021 a
Motion-Secondary
was filed
involving a dispute between
Sanchez, Alma Garcia,
and
Does 1 To 100, Inclusive,
Ross Dress For Less, Inc.,
Ross Stores, Inc,
for Other PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
2(6/
527 \y V
COLLINSON, DAEHNKE, INLOW & GRECO SUPERIORFCO'UIR'TEFaL
Charles F. Saacke, CASB N0. 84468 0F sAN Beams'a'figm
03mgERNARD'NO
chuckgwcdiglaw.com D'STRlCT
Barbara Kokkinakis, CASB NO. 1 10743
Barbara.kokkinakis@cdiglaw.com
JAN 1 8 2022
21515 Hawthorne Blvd., Suite 800
Torrance, CA 90503
OKUIAMN
Telephone: (424) 212-7777
W /
N'C LE CAR RI
Facsimile: (424) 212-7757 T. DEPUTY
Attorneys for Defendant,
ROSS DRESS FOR LESS, INC.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 FOR THE COUNTY OF SAN BERNARDINO
é
|I-
11
ALMA GARCIA SANCHEZ, E
GRECO
Case No. CIVSBZI20127
12 Judge Assigned: Thomas S. Garza
800
212-7757
Plaintiff, Dept: S27
90503
SUITE
13
INLOW&
(424) vs.
BLVD.,
14 DEFENDANT’S OPPOSITION TO
MOTION T0 QUASH AND
CALIFORNIA
FAX
| ROSS STORES, INC. dba ROSS DRESS FOR PLAINTIFF’S
15 LESS; and DOES t0 1 100, INCLUSIVE, REQUEST FOR MONETARY
DAEHNKE,
HAWTHORNE
212-7777
SANCTIONS IN THE AMOUNT OF $1890
TORRANCE,
16 AGAINST PLAINTIFF AND
(424)
Defendants PLAINTIFF’S COUNSEL OF RECORD;
21515
TEL. 17 MEMORANDUM OF POINTS AND
AUTHORITIES; DECLARATION 0F
COLLINSON,
18 CHARLES F SAACKE; [PROPOSED]
ORDER
19
20
21 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
22 PLEASE TAKE NOTICE that on February 8, 2022 and 9 AM as noticed in Department S
23 27 of the above entitled court, defendant, Ross Dress For Less, Inc. will oppose plaintiff’ s
24 motion t0 quash and allegedly served Subpoena of Defendant Ross Dress For Less, Inc. that was
25 never served 0n Pomona Unified School District.
26 This opposition is based upon the fact that the subpoena sought t0 be quashed had never
27 been served, as defendant had offered modifications. The motion was improperly made and
28 when brought t0 the attention 0f the plaintiff’s attorneys that they refused t0 withdraw the motion
1
OPPOSITION TO PLAINTIFF'S MOTION TO QUASH
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Document Filed Date
January 18, 2022
Case Filing Date
July 09, 2021
Category
Other PI/PD/WD Unlimited
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2(6/ 527 \y V COLLINSON, DAEHNKE, INLOW & GRECO SUPERIORFCO'UIR'TEFaL Charles F. Saacke, CASB N0. 84468 0F sAN Beams'a'figm 03mgERNARD'NO chuckgwcdiglaw.com D'STRlCT Barbara Kokkinakis, CASB NO. 1 10743 Barbara.kokkinakis@cdiglaw.com JAN 1 8 2022 21515 Hawthorne Blvd., Suite 800 Torrance, CA 90503 OKUIAMN Telephone: (424) 212-7777 W / N'C LE CAR RI Facsimile: (424) 212-7757 T. DEPUTY Attorneys for Defendant, ROSS DRESS FOR LESS, INC. SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 FOR THE COUNTY OF SAN BERNARDINO é |I- 11 ALMA GARCIA SANCHEZ, E GRECO Case No. CIVSBZI20127 12 Judge Assigned: Thomas S. Garza 800 212-7757 Plaintiff, Dept: S27 90503 SUITE 13 INLOW& (424) vs. BLVD., 14 DEFENDANT’S OPPOSITION TO MOTION T0 QUASH AND CALIFORNIA FAX | ROSS STORES, INC. dba ROSS DRESS FOR PLAINTIFF’S 15 LESS; and DOES t0 1 100, INCLUSIVE, REQUEST FOR MONETARY DAEHNKE, HAWTHORNE 212-7777 SANCTIONS IN THE AMOUNT OF $1890 TORRANCE, 16 AGAINST PLAINTIFF AND (424) Defendants PLAINTIFF’S COUNSEL OF RECORD; 21515 TEL. 17 MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION 0F COLLINSON, 18 CHARLES F SAACKE; [PROPOSED] ORDER 19 20 21 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 22 PLEASE TAKE NOTICE that on February 8, 2022 and 9 AM as noticed in Department S 23 27 of the above entitled court, defendant, Ross Dress For Less, Inc. will oppose plaintiff’ s 24 motion t0 quash and allegedly served Subpoena of Defendant Ross Dress For Less, Inc. that was 25 never served 0n Pomona Unified School District. 26 This opposition is based upon the fact that the subpoena sought t0 be quashed had never 27 been served, as defendant had offered modifications. The motion was improperly made and 28 when brought t0 the attention 0f the plaintiff’s attorneys that they refused t0 withdraw the motion 1 OPPOSITION TO PLAINTIFF'S MOTION TO QUASH 0“ c/ @r\ ‘30 42¢. '9 19 xd’ "4",72‘ (“fie x g9/ x) x; ‘6) r" 5’ /’*\\ «(\v "‘1" o r“, “CB 422??) <33 fi\J// R.WJ r ., ‘.. (u ‘1 1"L‘ .‘ y i .7” ,M") ' é. "'I' uié}..: . v . f