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ELECTRONICALLY FILED
Terri L. Masserman, Esq. (SBN 147815)
Mitchell F. Ducey, Esq. (SBN 154071)
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Jessica A. Hoch, Esq. (SBN 341 131)
SAN BERNARD'NO D'STR'CT
MASSERMAN & DUCEY 12/7/2023 7:14 PM
A Limited Liability Partnership
15260 Ventura Boulevard, Suite 1740 By: Leslie Zepeda, DEPUTY
Sherman Oaks, California 91403
Telephone: (8 1 8) 646-5000
E-Mail: Litigation®md—llp.com
Attorneys for Defendant, MARIA A. TORRES
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO
lO ALEXANDRA COELLO, Case N0.: CIVD82017322
[Complaint Filed August 5, 2020]
ll Plaintiff, Assigned t0 the Honorable Khymberli S. Apaloo
Dept. S25
12 -V...
DEFENDANT’S NOTICE OF MOTION
l3 MARIA A. TORRES; and DOES 1 through AND MOTION TO COMPEL
LLP
50, inclusive, PLAINTIFF’S RESPONSES TO DEMAND
l4 FOR PRODUCTION OF DOCUMENTS,
Ducey, Defendants. SET ONE; MEMORANDUM OF POINTS
15 AND AUTHORITIES; REQUEST FOR
& MONETARY SANCTIONS IN THE
16 vvvvvvvvvvvvvvvvvvvvvvvvv
AMOUNT OF $849.15 AGAINST
PLAINTIFF AND HER COUNSEL OF
17 RECORD; DECLARATION OF JESSICA
HOCH
Masserman
A.
18
Lodged Concurrently With:
l9 [PROPOSED] ORDER
20 DATE: March 14, 2024
TIME: 8:30 a.m.
21 DEPT: 825
22
23 TO THIS HONORABLE COURT AND PLAINTIFF, AND TO HER COUNSEL OF
24 RECORD:
25 PLEASE TAKE NOTICE that 0n March 14, 2024, at 8:30 a.m., or as soon thereafter as
26 the matter may be heard in Department S25 of the above-mentioned court, located at 247 West
27 Third Street, San Bernardino, California 92415, defendant, MARIA A. TORRES (“defendant”)
28 Will and hereby does move this Court for the following orders:
DEFENDANT’S NOTICE OF MOTION AND MOTION TO COMPEL PLAINTIFF’S
RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE
_l_
500.0528
(1) For an order compelling plaintiff, ALEXANDRA COELLO (“plaintiffl”) t0
provide verified responses, Without objections, Within ten (10) days to Request for Production 0f
Documents, Set One, propounded by moving defendant on August 10, 2023; and
(2) For monetary sanctions against plaintiff and plaintiff’ s counsel 0f record, S. Sean
Bral, Esq., Sarkis Tulumdzhyan, Esq., and Bral & Associates, jointly and severally, for the
reasonable attorney’s fees and costs incurred by moving defendant in bringing the instant
motion, in the amount 0f $849.15, pursuant t0 Code 0f Civil Procedure sections 2031.300(a)-(c),
2023.010(d) and (h), and 2023.030(a).
This motion is brought pursuant to California Code of Civil Procedure, Section
lO 2031.300(a)-(c), and 2023.010(d), 0n the grounds that the outstanding discovery is relevant to
ll the subject matter 0f this action, is not privileged, and plaintiff has failed to provide a verified
12 response to defendant’s Request for Production of Documents, Set One. Defendant is entitled t0
l3 responses to the subject basic discovery requests as a matter of law.
LLP
l4 This motion is further based upon this Notice of Motion, the attached Memorandum of
Ducey,
l5 Points and Authorities, the Declaration of Jessica A. Hoch, the exhibits attached hereto, the
& 16 [Proposed] Order lodged concurrently herewith, the pleadings and papers in the Court's file, and
Masserman
17 on all such other oral and documentary evidence as may be presented at the hearing on this
18 Motion.
19 Dated: December 6, 2023 MASSERMAN & DUCEY, LLP
20
21
TERRI L. MASSERMAN, ESQ.
22 MITCHELL F. DUCEY, ESQ.
JESSICA A. HOCH, ESQ.
23 Attorneys for Defendant,
MARIA A. TORRES
24
25
26
27
28
DEFENDANT’S NOTICE OF MOTION AND MOTION TO COMPEL PLAINTIFF’S
RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE
_2_
500.0528
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ELECTRONICALLY FILED Terri L. Masserman, Esq. (SBN 147815) Mitchell F. Ducey, Esq. (SBN 154071) ggififileglgggfigggNangfigNIA Jessica A. Hoch, Esq. (SBN 341 131) SAN BERNARD'NO D'STR'CT MASSERMAN & DUCEY 12/7/2023 7:14 PM A Limited Liability Partnership 15260 Ventura Boulevard, Suite 1740 By: Leslie Zepeda, DEPUTY Sherman Oaks, California 91403 Telephone: (8 1 8) 646-5000 E-Mail: Litigation®md—llp.com Attorneys for Defendant, MARIA A. TORRES SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO lO ALEXANDRA COELLO, Case N0.: CIVD82017322 [Complaint Filed August 5, 2020] ll Plaintiff, Assigned t0 the Honorable Khymberli S. Apaloo Dept. S25 12 -V... DEFENDANT’S NOTICE OF MOTION l3 MARIA A. TORRES; and DOES 1 through AND MOTION TO COMPEL LLP 50, inclusive, PLAINTIFF’S RESPONSES TO DEMAND l4 FOR PRODUCTION OF DOCUMENTS, Ducey, Defendants. SET ONE; MEMORANDUM OF POINTS 15 AND AUTHORITIES; REQUEST FOR & MONETARY SANCTIONS IN THE 16 vvvvvvvvvvvvvvvvvvvvvvvvv AMOUNT OF $849.15 AGAINST PLAINTIFF AND HER COUNSEL OF 17 RECORD; DECLARATION OF JESSICA HOCH Masserman A. 18 Lodged Concurrently With: l9 [PROPOSED] ORDER 20 DATE: March 14, 2024 TIME: 8:30 a.m. 21 DEPT: 825 22 23 TO THIS HONORABLE COURT AND PLAINTIFF, AND TO HER COUNSEL OF 24 RECORD: 25 PLEASE TAKE NOTICE that 0n March 14, 2024, at 8:30 a.m., or as soon thereafter as 26 the matter may be heard in Department S25 of the above-mentioned court, located at 247 West 27 Third Street, San Bernardino, California 92415, defendant, MARIA A. TORRES (“defendant”) 28 Will and hereby does move this Court for the following orders: DEFENDANT’S NOTICE OF MOTION AND MOTION TO COMPEL PLAINTIFF’S RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE _l_ 500.0528 (1) For an order compelling plaintiff, ALEXANDRA COELLO (“plaintiffl”) t0 provide verified responses, Without objections, Within ten (10) days to Request for Production 0f Documents, Set One, propounded by moving defendant on August 10, 2023; and (2) For monetary sanctions against plaintiff and plaintiff’ s counsel 0f record, S. Sean Bral, Esq., Sarkis Tulumdzhyan, Esq., and Bral & Associates, jointly and severally, for the reasonable attorney’s fees and costs incurred by moving defendant in bringing the instant motion, in the amount 0f $849.15, pursuant t0 Code 0f Civil Procedure sections 2031.300(a)-(c), 2023.010(d) and (h), and 2023.030(a). This motion is brought pursuant to California Code of Civil Procedure, Section lO 2031.300(a)-(c), and 2023.010(d), 0n the grounds that the outstanding discovery is relevant to ll the subject matter 0f this action, is not privileged, and plaintiff has failed to provide a verified 12 response to defendant’s Request for Production of Documents, Set One. Defendant is entitled t0 l3 responses to the subject basic discovery requests as a matter of law. LLP l4 This motion is further based upon this Notice of Motion, the attached Memorandum of Ducey, l5 Points and Authorities, the Declaration of Jessica A. Hoch, the exhibits attached hereto, the & 16 [Proposed] Order lodged concurrently herewith, the pleadings and papers in the Court's file, and Masserman 17 on all such other oral and documentary evidence as may be presented at the hearing on this 18 Motion. 19 Dated: December 6, 2023 MASSERMAN & DUCEY, LLP 20 21 TERRI L. MASSERMAN, ESQ. 22 MITCHELL F. DUCEY, ESQ. JESSICA A. HOCH, ESQ. 23 Attorneys for Defendant, MARIA A. TORRES 24 25 26 27 28 DEFENDANT’S NOTICE OF MOTION AND MOTION TO COMPEL PLAINTIFF’S RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE _2_ 500.0528