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ELECTRONICALLY FILED
SUPERIOR COURT OF CALIFORNIA
1 McCLAUGHERTY & ASSOCIATES COUNTY OF SAN BERNARDINO
Jay S. McClaugherty, SBN: 99063 SAN BERNARDINO DISTRICT
2 Hayden Traver, SBN: 317428 11/21/2023 9:42 AM
222 E. Huntington Drive, Suite 230
3 Monrovia, CA 91016 By: Sylvia Guajardo, DEPUTY
Telephone: (626) 821-1100
4 Facsimile: (626) 821-2626
5 Attorneys for Defendant,
MARICLARE MALDONADO
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO - CENTRAL DISTRICT
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BARBARA WILLIAMS, CASE NO.: C1VDS2002655
12 (Unlimited Jurisdiction)
Plaintiff,
NOTICE OF REQUEST TO PLAINTIFF TO
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vs. APPEAR AT TRIAL AND FOR
I A TROY WILSON; MARICLARE PRODUCTION OF DOCUMENTS THEREAT
MALDONADO and DOES 1 through
100, Inclusive,
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Trial:
Defendants. Date: December 11,2023.
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Time: 10:00 a.m.
Dept.: S30
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21 TO PLAINTIFF BARBARA WILLIAMSAND ATTORNEY(S) OF RECORD:
PLEASE TAKE NOTICE that pursuant to Code of Civil Procedure section 1987 (b)
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defendant MARICLARE MALDONADO hereby requests that plaintiff BARBARA WILLIAMS
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attend the trial of this matter, which is currently scheduled to begin at 10:00 a.m. on December
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11, 2023, in Department “S30” of above-entitled court, located at 247 West Third Street, San
25 Bernardino, California 92415-0210,
26 PLEASE TAKE FURTHER NOTICE that pursuant to California Code of Civil
27 Procedure section 1987(c), plaintiff BARBARA WILLIAMS is requested to produce the
following documents at the date and time for said trial.
28
1
NOTICE OF REQUEST TO PLAINTIFF TO APPEAR AT TRIAL AND FOR PRODUCTION OF
DOCUMENTS THEREAT
1 DOCUMENTS TO BE PRODUCED
2 1. All documents in the possession, custody or control of
plaintiff BARBARA WILLIAMS, or in the possession, custody or control of any officer, director,
employee, attorney, accountant, partner, or any agent of said Plaintiff, which are or which in any
way relate to, refer to, reference, analyze, tend to substantiate, comment upon, discuss or pertain
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to any and all medical reports and records from any medical facility, physician, or medical
6 practitioners of any type that examined, consulted, and/or treated plaintiff BARBARA
7 WILLIAMS for the injuries allegedly sustained as result of the incident at any time from March
8 13, 2018 to the date of trial, December 11, 2023.
g 2. All documents in the possession, custody or control of plaintiff BARBARA
WILLIAMS, or in the possession, custody or control of any officer, director, employee, attorney,
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accountant, partner, or any agent of said Plaintiff, which are or which in any way relate to, refer
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to, reference, analyze, tend to substantiate, comment upon, discuss or pertain to or purport to any
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and all medical billing from any medical facility, physician, or medical practitioners of any type
13 that examined, consulted, and/or treated plaintiff BARBARA WILLIAMS for the injuries
14 allegedly sustained as a result of the occurrence of the subject accident at any time between from
15 March 13, 2018 to the date of trial, December 11,2023.
3. All documents in the possession, custody or control of plaintiff BARBARA
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WILLIAMS, or in the possession, custody or control of any officer, director, employee, attorney,
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accountant, partner, or any agent of said Plaintiff, which are or which in any way relate to, refer
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to, reference, analyze, tend to substantiate, comment upon, discuss or pertain to or purport to
19 record the income of plaintiff BARBARA WILLIAMS during the five (5) calendar years prior to
20 the occurrence of the subject accident which occurred on March 13, 2018 to the date of trial,
21 December 11, 2023.
4. All documents in the possession, custody, or control of plaintiff BARBARA
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WILLIAMS, or in the possession, custody or control of any officer, director, employee,
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attorney, accountant, partner, or any agent of said Plaintiff, which are or which in any way relate
to, refer to, reference, analyze, tend to substantiate, comment upon, discuss or pertain to or
25 purport to record that plaintiff BARBARA WILLIAMS took time off from work because of the
26 occurrence of the subject accident at any time between March 13, 2018, to the date of trial,
27 December 11, 2023.
28 5. All documents in the possession. custody, or control of plaintiff BARBARA
2
NOTICE OF REQUEST TO PLAINTIFF TO APPEAR AT TRIAL AND FOR PRODUCTION OF
DOCUMENTS THEREAT
Preview
ELECTRONICALLY FILED SUPERIOR COURT OF CALIFORNIA 1 McCLAUGHERTY & ASSOCIATES COUNTY OF SAN BERNARDINO Jay S. McClaugherty, SBN: 99063 SAN BERNARDINO DISTRICT 2 Hayden Traver, SBN: 317428 11/21/2023 9:42 AM 222 E. Huntington Drive, Suite 230 3 Monrovia, CA 91016 By: Sylvia Guajardo, DEPUTY Telephone: (626) 821-1100 4 Facsimile: (626) 821-2626 5 Attorneys for Defendant, MARICLARE MALDONADO 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO - CENTRAL DISTRICT 10 11 BARBARA WILLIAMS, CASE NO.: C1VDS2002655 12 (Unlimited Jurisdiction) Plaintiff, NOTICE OF REQUEST TO PLAINTIFF TO 13 vs. APPEAR AT TRIAL AND FOR I A TROY WILSON; MARICLARE PRODUCTION OF DOCUMENTS THEREAT MALDONADO and DOES 1 through 100, Inclusive, 15 Trial: Defendants. Date: December 11,2023. 16 Time: 10:00 a.m. Dept.: S30 17 18 19 20 21 TO PLAINTIFF BARBARA WILLIAMSAND ATTORNEY(S) OF RECORD: PLEASE TAKE NOTICE that pursuant to Code of Civil Procedure section 1987 (b) 22 defendant MARICLARE MALDONADO hereby requests that plaintiff BARBARA WILLIAMS 23 attend the trial of this matter, which is currently scheduled to begin at 10:00 a.m. on December 24 11, 2023, in Department “S30” of above-entitled court, located at 247 West Third Street, San 25 Bernardino, California 92415-0210, 26 PLEASE TAKE FURTHER NOTICE that pursuant to California Code of Civil 27 Procedure section 1987(c), plaintiff BARBARA WILLIAMS is requested to produce the following documents at the date and time for said trial. 28 1 NOTICE OF REQUEST TO PLAINTIFF TO APPEAR AT TRIAL AND FOR PRODUCTION OF DOCUMENTS THEREAT 1 DOCUMENTS TO BE PRODUCED 2 1. All documents in the possession, custody or control of plaintiff BARBARA WILLIAMS, or in the possession, custody or control of any officer, director, employee, attorney, accountant, partner, or any agent of said Plaintiff, which are or which in any way relate to, refer to, reference, analyze, tend to substantiate, comment upon, discuss or pertain 5 to any and all medical reports and records from any medical facility, physician, or medical 6 practitioners of any type that examined, consulted, and/or treated plaintiff BARBARA 7 WILLIAMS for the injuries allegedly sustained as result of the incident at any time from March 8 13, 2018 to the date of trial, December 11, 2023. g 2. All documents in the possession, custody or control of plaintiff BARBARA WILLIAMS, or in the possession, custody or control of any officer, director, employee, attorney, 10 accountant, partner, or any agent of said Plaintiff, which are or which in any way relate to, refer 11 to, reference, analyze, tend to substantiate, comment upon, discuss or pertain to or purport to any 12 and all medical billing from any medical facility, physician, or medical practitioners of any type 13 that examined, consulted, and/or treated plaintiff BARBARA WILLIAMS for the injuries 14 allegedly sustained as a result of the occurrence of the subject accident at any time between from 15 March 13, 2018 to the date of trial, December 11,2023. 3. All documents in the possession, custody or control of plaintiff BARBARA 16 WILLIAMS, or in the possession, custody or control of any officer, director, employee, attorney, 17 accountant, partner, or any agent of said Plaintiff, which are or which in any way relate to, refer 18 to, reference, analyze, tend to substantiate, comment upon, discuss or pertain to or purport to 19 record the income of plaintiff BARBARA WILLIAMS during the five (5) calendar years prior to 20 the occurrence of the subject accident which occurred on March 13, 2018 to the date of trial, 21 December 11, 2023. 4. All documents in the possession, custody, or control of plaintiff BARBARA 22 WILLIAMS, or in the possession, custody or control of any officer, director, employee, 23 attorney, accountant, partner, or any agent of said Plaintiff, which are or which in any way relate to, refer to, reference, analyze, tend to substantiate, comment upon, discuss or pertain to or 25 purport to record that plaintiff BARBARA WILLIAMS took time off from work because of the 26 occurrence of the subject accident at any time between March 13, 2018, to the date of trial, 27 December 11, 2023. 28 5. All documents in the possession. custody, or control of plaintiff BARBARA 2 NOTICE OF REQUEST TO PLAINTIFF TO APPEAR AT TRIAL AND FOR PRODUCTION OF DOCUMENTS THEREAT