On January 10, 2023 a
Party Discovery
was filed
involving a dispute between
Medina, Charles,
and
Does 1 Through 50, Inclusive,
Guerrero, Jesus,
for Auto PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
Randy A. Johnson, Esq. SBN 165105 ELECTRONICALLY FILED
LAW OFFICES 0F CARLSON & JOHNSON, LLP SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
2107 N. Broadway, #309, Santa Ana, CA 92706 SAN BERNARDINO DISTRICT
Tel: 714.289.9818
Fax: 714.541.7986 12/7/2023 12:08 PM
By: Abrianna Rodriguez, DEPUTY
Attorneys for Plaintiff,
CHARLES MEDINA
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
CHARLES MEDINA, an Individual; Case No.2 CIVSB2301715
Assigned lo: The Hon. Donald Alvarez
Plaintiff, Department S2 3-SBJC
vs. NOTICE OF MOTION AND MOTION TO
12 COMPEL INITIAL RESPONSES T0
JESUS GUERRERO, an Individual; and PLAINTIFF’SREQUESTS FOR
13
DOES 1 through 50, inclusive; PRODUCTION 0F DOCUMENTS, SET
l4
ONE; MEMORANDUM 0F POINTS AND
Defendants. AUTHORITIES; REQUEST FOR MONETARY
15 SANCTIONS; DECLARATION 0F RANDY A.
JOHNSON; [PROPOSED] ORDER
16
Hearing Date: March 1], 2024, 8:30 a. m.
Location: Dept. 8-23
18
19
TO ALL PARTIES AND T0 THEIR ATTORNEY(S) 0F RECORD:
NOTICE IS HEREBY GIVEN that on March 11, 2024, at 8:30 as soon a.111., 01'
20
thereafter as the matter can be heard in Department S-23, of the above entitled Court, located at
21
247 W. 3rd Street, San Bernardino, CA 92415, Plaintiff, CHARLES MEDINA will move this
22
court for an order compelling verified responses t0 Plaintiff’s Requests for Production of
23
Documents, Set One, propounded 011 Defendant JESUS GUERRERO, on, or about Juiy 25 2023.
24
Pursuant to Code of Civii Procedure §§2030.290(c), 2023.030(a), and 2023.010(d), Defendant
25 and
also seeks monetary sanctions against Defendant his counsel 0f record due-to their failure to
26 comply.
27 This motion is made 0n the grounds that despite being granted three extensions, Defendant
28 has failed to respond t0 Plaintiff’s written discovery as required by statute. The sought—after
discovery is highly relevant to Plaintiffs' personal injury allegations.
-1-
NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO REQUESTS FOR PRODUCTION
This motion will b0 based upon this notice, the pleadings, records and files herein, the
attached nlemoraudum 0f points and authorities, served and filed herewith, the declaration 0f
Randy A. Johnson, and upon such other and further oral and/Or documentary evidence as may be
presented at the time 0f the hearing 0f this motion,
LAW OFFICES OF CARLSON & JOHNSON, LLP
w)
/ \kM‘q{7A
Dated; TH?!
Randy A Johnson Esq.
Attomey f01 Plaintiff
CHARLES MEDINA
///
///
///
///
///
///
///
///
22
///
23
24 ///
25
///
26
///
27
///
28
///
-2.
NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO REQUESTS FOR PRODUCTION
Document Filed Date
December 07, 2023
Case Filing Date
January 10, 2023
Category
Auto PI/PD/WD Unlimited
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Randy A. Johnson, Esq. SBN 165105 ELECTRONICALLY FILED LAW OFFICES 0F CARLSON & JOHNSON, LLP SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO 2107 N. Broadway, #309, Santa Ana, CA 92706 SAN BERNARDINO DISTRICT Tel: 714.289.9818 Fax: 714.541.7986 12/7/2023 12:08 PM By: Abrianna Rodriguez, DEPUTY Attorneys for Plaintiff, CHARLES MEDINA SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO CHARLES MEDINA, an Individual; Case No.2 CIVSB2301715 Assigned lo: The Hon. Donald Alvarez Plaintiff, Department S2 3-SBJC vs. NOTICE OF MOTION AND MOTION TO 12 COMPEL INITIAL RESPONSES T0 JESUS GUERRERO, an Individual; and PLAINTIFF’SREQUESTS FOR 13 DOES 1 through 50, inclusive; PRODUCTION 0F DOCUMENTS, SET l4 ONE; MEMORANDUM 0F POINTS AND Defendants. AUTHORITIES; REQUEST FOR MONETARY 15 SANCTIONS; DECLARATION 0F RANDY A. JOHNSON; [PROPOSED] ORDER 16 Hearing Date: March 1], 2024, 8:30 a. m. Location: Dept. 8-23 18 19 TO ALL PARTIES AND T0 THEIR ATTORNEY(S) 0F RECORD: NOTICE IS HEREBY GIVEN that on March 11, 2024, at 8:30 as soon a.111., 01' 20 thereafter as the matter can be heard in Department S-23, of the above entitled Court, located at 21 247 W. 3rd Street, San Bernardino, CA 92415, Plaintiff, CHARLES MEDINA will move this 22 court for an order compelling verified responses t0 Plaintiff’s Requests for Production of 23 Documents, Set One, propounded 011 Defendant JESUS GUERRERO, on, or about Juiy 25 2023. 24 Pursuant to Code of Civii Procedure §§2030.290(c), 2023.030(a), and 2023.010(d), Defendant 25 and also seeks monetary sanctions against Defendant his counsel 0f record due-to their failure to 26 comply. 27 This motion is made 0n the grounds that despite being granted three extensions, Defendant 28 has failed to respond t0 Plaintiff’s written discovery as required by statute. The sought—after discovery is highly relevant to Plaintiffs' personal injury allegations. -1- NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO REQUESTS FOR PRODUCTION This motion will b0 based upon this notice, the pleadings, records and files herein, the attached nlemoraudum 0f points and authorities, served and filed herewith, the declaration 0f Randy A. Johnson, and upon such other and further oral and/Or documentary evidence as may be presented at the time 0f the hearing 0f this motion, LAW OFFICES OF CARLSON & JOHNSON, LLP w) / \kM‘q{7A Dated; TH?! Randy A Johnson Esq. Attomey f01 Plaintiff CHARLES MEDINA /// /// /// /// /// /// /// /// 22 /// 23 24 /// 25 /// 26 /// 27 /// 28 /// -2. NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO REQUESTS FOR PRODUCTION