On December 06, 2021 a
Party Discovery
was filed
involving a dispute between
Martinez, Federico E,
Martinez, Mauricio,
and
Does 1 Through 20,
Larsen, Robert,
Valley Transmission And Auto Repair Inc,,
Whittingslow, Edward,
for Business Tort/Unfair Business Practice Unlimited
in the District Court of San Bernardino County.
Preview
V QRHGUNAL L E D
VWDRFCC;URT 0F
COUNTY OF SAN cN-‘FORNIA
SAN BERNARDINBOEBPSTRICT
LEWIS BRISBOIS BISGAARD & SMITH LLP JAN ‘2
2 2024
JOHN S. LOWENTHAL, SB# 120628 s
E-Mail: John.Lowenthal@lewisbrisbois.com
3y ,
CHRISTOPHER A. McINTIRE, SB# 25 1 199
‘
E-Mai]: Christopher.McIntire@lewisbrisbois.com C) DEPu'ry
650 East Hospitality Lane, Suite 600
San Bemardino, California 92408
Telephone: 909.387.1 130
Facsimile: 909.387.] 138
Attorneys for Defendants
VALLEY TRANSMISSION AND AUTO
REPAIR, INC., EDWARD WHITTINGSLOW
\DOONON and ROBERT LARSEN
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 COUNTY OF SAN BERNARDINO, SAN BERNARDINO DISTRICT
11
12 FEDERICO E. MARTINEZ, et al., Case No. CIVSB2133495
13 Plaintiffs, NOTICE OF NO OPPOSITION TO
DEFENDANTS’ MOTION TO COMPEL
14 vs. FURTHER RESPONSES FROM
PLAINTIFF FEDERICO E. MARTINEZ
15 VALLEY TRANSMISSION AND AUTO TO DEFENDANTS’ SPECIAL
REPAIR, INC., et al., INTERROGATORIES, SET ONE
16
Defendants.
17 Date: January 30, 2024
Time: 8:30 a.m.
18 Dept: V11
19 Assigned to:
Hon. Winston Keh, Dept. V11
20
Trial Date: None Set
21
22
23 TO THE COURT, ALL PARTIES, AND THEIR COUNSEL OF RECORD:
24 PLEASE TAKE NOTICE that no opposition has been filed or served to Defendants’
25 Motion t0 Compel Further Responses From Plaintiff FEDERICO E. MARTINEZ to Defendants’
26 Special Interrogatories, Set One.
27 Pursuant to Code of Civil Procedure section 1005, subdivision (b), “[a]11 papers opposing a
28 motion so noticed shall be filed with the court and a copy served 0n each party at least nine court
LEWIS
BRISBOIS 13490401 1‘1 1 Case No. CIVSB2133495
BISGAARD
& sw-I up DEFENDANTS’ NOTICE OF NO OPPOSITION TO ITS MOTION TO COMPEL FURTHER RESPONSES FROM
AWORNEYS AT lAW
PLAINTIFF FEDERICO E. MARTINEZ TO DEFENDANTS’ SPECIAL INTERROGATORIES, SET ONE
1 days . . . before the hearing.” Based 0n the January 30, 2024 hearing date, any opposition to the
2 instant motion was to be filed and served no later than January 17, 2024.
3 As 0f the date of this notice, Defendants have not received any opposition to the instant
4 motion and the Court’s docket does not reflect the filing of any opposition.
5 In light 0f the foregoing, and pursuant to the authority cited in the moving papers,
Defendants respectfully request that the unopposed Motion to Compel be granted without leave to
amend, and that sanctions in the amount of $700.00 be awarded to Defendants for the Plaintiff
\OOOQON
FEDERICO E. MARTINEZ’ failure to provide code-compliant responses to Defendants’ Special
Interrogatories, Set One.
10 DATED: January 22, 2024 LEWIS BRISBOIS BISGAARD & SMITH LLP
“
12
ziéé—MW
CHRISTOPHER A. McINTIRE
13 Attorneys for Defendants
VALLEY TRANSMISSION AND AUTO
14 REPAIR, INC., EDWARD WHITTINGSLOW
and ROBERT LARSEN
15
16
17
18
19
20
21
22
23
24
25
26
27
28
LEWIS
BRISBOIS 13490401 1'1 2 Case N0. CIVSB2 1 33495
gm”? DEFENDANTS’ NOTICE 0F No OPPOSITION To ITS MOTION To COMPEL FURTHER RESPONSES FROM
MAW
AWORNEYS PLAINTIFF FEDERICO E. MARTINEZ TO DEFENDANTS’ SPECIAL INTERROGATORIES, SET ONE
Document Filed Date
January 22, 2024
Case Filing Date
December 06, 2021
Category
Business Tort/Unfair Business Practice Unlimited
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V QRHGUNAL L E D VWDRFCC;URT 0F COUNTY OF SAN cN-‘FORNIA SAN BERNARDINBOEBPSTRICT LEWIS BRISBOIS BISGAARD & SMITH LLP JAN ‘2 2 2024 JOHN S. LOWENTHAL, SB# 120628 s E-Mail: John.Lowenthal@lewisbrisbois.com 3y , CHRISTOPHER A. McINTIRE, SB# 25 1 199 ‘ E-Mai]: Christopher.McIntire@lewisbrisbois.com C) DEPu'ry 650 East Hospitality Lane, Suite 600 San Bemardino, California 92408 Telephone: 909.387.1 130 Facsimile: 909.387.] 138 Attorneys for Defendants VALLEY TRANSMISSION AND AUTO REPAIR, INC., EDWARD WHITTINGSLOW \DOONON and ROBERT LARSEN SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF SAN BERNARDINO, SAN BERNARDINO DISTRICT 11 12 FEDERICO E. MARTINEZ, et al., Case No. CIVSB2133495 13 Plaintiffs, NOTICE OF NO OPPOSITION TO DEFENDANTS’ MOTION TO COMPEL 14 vs. FURTHER RESPONSES FROM PLAINTIFF FEDERICO E. MARTINEZ 15 VALLEY TRANSMISSION AND AUTO TO DEFENDANTS’ SPECIAL REPAIR, INC., et al., INTERROGATORIES, SET ONE 16 Defendants. 17 Date: January 30, 2024 Time: 8:30 a.m. 18 Dept: V11 19 Assigned to: Hon. Winston Keh, Dept. V11 20 Trial Date: None Set 21 22 23 TO THE COURT, ALL PARTIES, AND THEIR COUNSEL OF RECORD: 24 PLEASE TAKE NOTICE that no opposition has been filed or served to Defendants’ 25 Motion t0 Compel Further Responses From Plaintiff FEDERICO E. MARTINEZ to Defendants’ 26 Special Interrogatories, Set One. 27 Pursuant to Code of Civil Procedure section 1005, subdivision (b), “[a]11 papers opposing a 28 motion so noticed shall be filed with the court and a copy served 0n each party at least nine court LEWIS BRISBOIS 13490401 1‘1 1 Case No. CIVSB2133495 BISGAARD & sw-I up DEFENDANTS’ NOTICE OF NO OPPOSITION TO ITS MOTION TO COMPEL FURTHER RESPONSES FROM AWORNEYS AT lAW PLAINTIFF FEDERICO E. MARTINEZ TO DEFENDANTS’ SPECIAL INTERROGATORIES, SET ONE 1 days . . . before the hearing.” Based 0n the January 30, 2024 hearing date, any opposition to the 2 instant motion was to be filed and served no later than January 17, 2024. 3 As 0f the date of this notice, Defendants have not received any opposition to the instant 4 motion and the Court’s docket does not reflect the filing of any opposition. 5 In light 0f the foregoing, and pursuant to the authority cited in the moving papers, Defendants respectfully request that the unopposed Motion to Compel be granted without leave to amend, and that sanctions in the amount of $700.00 be awarded to Defendants for the Plaintiff \OOOQON FEDERICO E. MARTINEZ’ failure to provide code-compliant responses to Defendants’ Special Interrogatories, Set One. 10 DATED: January 22, 2024 LEWIS BRISBOIS BISGAARD & SMITH LLP “ 12 ziéé—MW CHRISTOPHER A. McINTIRE 13 Attorneys for Defendants VALLEY TRANSMISSION AND AUTO 14 REPAIR, INC., EDWARD WHITTINGSLOW and ROBERT LARSEN 15 16 17 18 19 20 21 22 23 24 25 26 27 28 LEWIS BRISBOIS 13490401 1'1 2 Case N0. CIVSB2 1 33495 gm”? DEFENDANTS’ NOTICE 0F No OPPOSITION To ITS MOTION To COMPEL FURTHER RESPONSES FROM MAW AWORNEYS PLAINTIFF FEDERICO E. MARTINEZ TO DEFENDANTS’ SPECIAL INTERROGATORIES, SET ONE