On July 20, 2022 a
Party Discovery
was filed
involving a dispute between
City Of Chino Hills,
and
Dimaranan, Adelaida A.,
Dimaranan, Flaviano E.,
Does 1-30,
Gao, Xiangyan,
Kazi, Ashfaq,
Kazi, Farhana,
Li, Ligang,
Moon, Geonju,
Moon, James,
Patamakanthin, Pissamai,
Patamakanthin, Sommai,
Qiu, Yiming,
Wang, Chuan,
for Other PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
ELECTRONICALLY FILED
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
SAN BERNARDINO DISTRICT
MARK D. HENSLEY (SBN 142653)
City Attorney, City 0f Chino Hills 12/14/2023 9:38 PM
ELIZABETH M. CALCIANO (SBN 161080) By: Abrianna Rodriguez, DEPUTY
CRAIG S. GUNTHER (SBN 167174)
HENSLEY LAW GROUP
2600 W. Olive Avenue, Suite 500 Exempt From Filing Fees Pursuant
Burbank, CA 91505 t0 Government Code § 6103
KOOOQQUI-PUJNb—t
Tel: (818) 333-5120; Fax: (818) 333-5121
ecalciano@hensleylawgroup.com
cgunther@hensleylawgr0up.com
Attorneys for Plaintiff CITY OF CHINO HILLS
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
CITY OF CHINO HILLS, a general law municipal Case No.2 CIVSB 2215548
corporation,
[Assignedfor allpurposes t0 the
Hon. JanetM. Frangie, Dept. R1]
Plaintiff,
NOTICE OF MOTION AND MOTION OF
V. PLAINTIFF CITY OF CHINO HILLS TO
COMPEL FURTHER RESPONSES,
FLAVIANO E. DIMARANAN, an individual; WITHOUT OBJECTIONS, TO FORM
ADELAIDA A. DIMARANAN, an individual; INTERROGATORIES (SET NO. 1) FROM
NNNNNNNNNr—tr—tr—tr—tr—tr—tr—tr—tr—tr—t
LIGANG LI, an individual; CHUAN WANG, an DEFENDANT JAMES MOON AND
REQUEST FOR AN ORDER AWARDING
individual; PISSAMAI PATAMAKANTHIN, an
MONETARY SANCTIONS AGAINST
individual; ASHFAQ KAZI, an individual; DEFENDANT AND DEFENSE COUNSEL
FARHANA KAZI, an individual; JAMES MOON IN THE SUM OF $1050 MEMORANDUM ;
an individual; GEONJU MOON, an individual; OF POINTS AND AUTHORITES
OONQLII-PUJNHOKDOOQQUI-PWNHO
XIANGYAN GAO, an individual; YIMING QIU,
Filed Concurrently with Separate Statement;
an individual; and DOES 1 through 30, inclusive,
Declaration 0f Craig S. Gunther, Esq. and
Exhibits; [Proposed] Order
Defendants.
[California Code osz'vil Procedure (“CCP”) §
2030.300]
Date: February 6, 2024
Time: 8:30 a.m.
Dept: R1
-1-
MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES
TO THE COURT, ALL PARTIES AND THEIR RESPECTIVE ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that on February 6, 2024, at 8:30 a.m., 0r as soon thereafter as the
matter may be heard in Department R1 of the above-entitled court, located at 8303 Haven Avenue,
Rancho Cucamonga, California, Plaintiff City 0f Chino Hills (“Plaintiff’ or “City”), Will move the
MOON (“Defendant”), to produce further verified
KOOOQQUI-PUJNb—t
court for an order compelling Defendant, JAMES
responses, Without obj actions, t0 Plaintiff’ s Form Interrogatories (Set No. 1), Interrogatory No. 15.1
served on Defendant 0n July 19, 2023.
Notice is further given that Plaintiff will request that the Court award monetary sanctions
against Defendant and Defense Counsel, and in favor of Plaintiff in the sum of $1050.00 pursuant t0
Code 0f Civil Procedure (“CCP”) § 2023.010 et seq., and CCP § 2030.300, et seq.
This motion is made pursuant t0 CCP §§ 2030.300 and 2030.220 and is brought on the
grounds that the Defendant has provided evasive, incomplete and non-responsive statements in
response t0 certain from interrogatories propounded by Plaintiff. A declaration in conformance with
CCP §2015.040 is provided herewith.
This motion is further based upon this notice; the attached Memorandum of Points and
Authorities; Separate Statement; Declaration 0f Craig S. Gunther and Exhibits, filed herewith; upon
NNNNNNNNNr—tr—tr—tr—tr—tr—tr—tr—tr—tr—t
the records and files in this action; and upon such further evidence and argument as may be
presented prior to or at the time of hearing on the motion.
OONQLII-PUJNHOKDOOQQUI-PWNHO
Dated: December 14, 2023 MARK D. HENSLEY
City Attorney, City of Chino Hills
HENSLEY LAW GROUP
-J":
r I "‘-,-~__
CRAIGis".’-1GfiNLTHER
Attorneys for Plaintiff
CITY OF CHINO HILLS
_ 2 _
MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES
Preview
ELECTRONICALLY FILED SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT MARK D. HENSLEY (SBN 142653) City Attorney, City 0f Chino Hills 12/14/2023 9:38 PM ELIZABETH M. CALCIANO (SBN 161080) By: Abrianna Rodriguez, DEPUTY CRAIG S. GUNTHER (SBN 167174) HENSLEY LAW GROUP 2600 W. Olive Avenue, Suite 500 Exempt From Filing Fees Pursuant Burbank, CA 91505 t0 Government Code § 6103 KOOOQQUI-PUJNb—t Tel: (818) 333-5120; Fax: (818) 333-5121 ecalciano@hensleylawgroup.com cgunther@hensleylawgr0up.com Attorneys for Plaintiff CITY OF CHINO HILLS SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO CITY OF CHINO HILLS, a general law municipal Case No.2 CIVSB 2215548 corporation, [Assignedfor allpurposes t0 the Hon. JanetM. Frangie, Dept. R1] Plaintiff, NOTICE OF MOTION AND MOTION OF V. PLAINTIFF CITY OF CHINO HILLS TO COMPEL FURTHER RESPONSES, FLAVIANO E. DIMARANAN, an individual; WITHOUT OBJECTIONS, TO FORM ADELAIDA A. DIMARANAN, an individual; INTERROGATORIES (SET NO. 1) FROM NNNNNNNNNr—tr—tr—tr—tr—tr—tr—tr—tr—tr—t LIGANG LI, an individual; CHUAN WANG, an DEFENDANT JAMES MOON AND REQUEST FOR AN ORDER AWARDING individual; PISSAMAI PATAMAKANTHIN, an MONETARY SANCTIONS AGAINST individual; ASHFAQ KAZI, an individual; DEFENDANT AND DEFENSE COUNSEL FARHANA KAZI, an individual; JAMES MOON IN THE SUM OF $1050 MEMORANDUM ; an individual; GEONJU MOON, an individual; OF POINTS AND AUTHORITES OONQLII-PUJNHOKDOOQQUI-PWNHO XIANGYAN GAO, an individual; YIMING QIU, Filed Concurrently with Separate Statement; an individual; and DOES 1 through 30, inclusive, Declaration 0f Craig S. Gunther, Esq. and Exhibits; [Proposed] Order Defendants. [California Code osz'vil Procedure (“CCP”) § 2030.300] Date: February 6, 2024 Time: 8:30 a.m. Dept: R1 -1- MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES TO THE COURT, ALL PARTIES AND THEIR RESPECTIVE ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that on February 6, 2024, at 8:30 a.m., 0r as soon thereafter as the matter may be heard in Department R1 of the above-entitled court, located at 8303 Haven Avenue, Rancho Cucamonga, California, Plaintiff City 0f Chino Hills (“Plaintiff’ or “City”), Will move the MOON (“Defendant”), to produce further verified KOOOQQUI-PUJNb—t court for an order compelling Defendant, JAMES responses, Without obj actions, t0 Plaintiff’ s Form Interrogatories (Set No. 1), Interrogatory No. 15.1 served on Defendant 0n July 19, 2023. Notice is further given that Plaintiff will request that the Court award monetary sanctions against Defendant and Defense Counsel, and in favor of Plaintiff in the sum of $1050.00 pursuant t0 Code 0f Civil Procedure (“CCP”) § 2023.010 et seq., and CCP § 2030.300, et seq. This motion is made pursuant t0 CCP §§ 2030.300 and 2030.220 and is brought on the grounds that the Defendant has provided evasive, incomplete and non-responsive statements in response t0 certain from interrogatories propounded by Plaintiff. A declaration in conformance with CCP §2015.040 is provided herewith. This motion is further based upon this notice; the attached Memorandum of Points and Authorities; Separate Statement; Declaration 0f Craig S. Gunther and Exhibits, filed herewith; upon NNNNNNNNNr—tr—tr—tr—tr—tr—tr—tr—tr—tr—t the records and files in this action; and upon such further evidence and argument as may be presented prior to or at the time of hearing on the motion. OONQLII-PUJNHOKDOOQQUI-PWNHO Dated: December 14, 2023 MARK D. HENSLEY City Attorney, City of Chino Hills HENSLEY LAW GROUP -J": r I "‘-,-~__ CRAIGis".’-1GfiNLTHER Attorneys for Plaintiff CITY OF CHINO HILLS _ 2 _ MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES