On April 07, 2022 a
Hearing
was filed
involving a dispute between
Espinosa, Celia,
Espinosa, Eduardo,
and
American Honda Motor Co., Inc.,
Does 1 Through 10,
for Breach of Contract/Warranty Unlimited
in the District Court of San Bernardino County.
Preview
" ORTGINAL
KNIGHT LAW GROUP, LLP
Roger Kimos (SBN 283 163) .2 i-
9
E a
CALIFORNIA
0's»?
T0gerk@knightlaW-Com SUPERtOF:
'
93.05.}???
COUNT\/_Q.L T-ggr‘agxmgwj
Timothy Lupinek (SBN 334876) SAM
‘
89.>2r»..¢,a~e>n~ae I s_n..;.,TR.L..
Timothyl@knightlaw.com
10250 Constellation Blvd., Suite 2500 MAR 1 5 2027)
Los Angeles, CA 90067
Telephone: (3 1 0) 552—2250
Fax:(310)552-7973 W flfgggfla‘é Zggg
LAURA BRUCK, DEPUTY
E
Attorneys for Plaintiff,
EDUARDO ESPINOSA
and CELIA ESPINOSA
SUPERIOR COURT OF CALIFORNIA
\OOOQQ
COUNTY OF SAN BERNARDINO
Case No.: CIVSBZZO7097
EDUARDO ESPINOSA
10 and CELIA ESPINOSA, . .
Unhmlted Jur1sd1ct10n
. . .
11 Plaintiffs,
DECLARATION OF TIMOTHY
12 VS- LUPINEK re COURT ORDERED
FURTHER MEET AND CONFER
13 EFFORTS IN ADVANCE OF
AMERICAN HONDA MOTOR CO., INC., HEARING 0N PLAINTIFFS’
14 a California Corporation, and DOES 1 MOTION TO COMPEL FURTHER
through 10, inclusive, RESPONSES TO REQUESTS FOR
15 PRODUCTION, SET ONE FROM
DEFENDANT AMERICAN HONDA
16 Defendants. MOTOR CO., INC AND REQUEST
FOR SANCTIONS
17
18
Date: February 24, 2023
Time: 8:30 am.
19
Dept; S33
20
Action filed: April 7, 2022
21
Trial: None
22
23
24
25
26
27
28
DECLARATION OF TIMOTHY LUPINEK IN SUPPORT OF PLAINTIFFS’
MOTION TO COMPEL FURTHER
RESPONSES TO REQUE STS FOR PRODUCTION
DECLARATION OF TIMOTHY LUPINEK
I, Timothy Lupinek, declare as follows:
Courts 0f the State of California, at Knight
1. I am an attorney licensed to practice before all
.h
Law Group, LLP, attorneys of record for EDUARDO ESPINOSA and CELIA ESPINOSA
(“Plaintiffs”) in the above—captioned matter.
2. I have personal knowledge of the facts set forth herein, and, if called t0 testify regarding
\OOOQONLI]
stated on
those matters, I could and would competently testify thereto except as to matters
information and belief, and as to those matters, I believe them to be true based upon my review
of my firm’s files and records in this matter.
10 3. I submit this declaration in support of Plaintiffs’ Motion to Compel Further Responses to
and Request for
Requests for Production, Set One, from American Honda Motor Co.,
11 Inc.,
12 Sanctions.
13 4. The accompanying separate statement includes all of the prior arguments made in
Plaintiffs’ Separate Statement in Support of Plaintiffs’ Motion to Compel Further
14 initial
Defendant’s Further
15 Responses to Request for Production and Request for Sanctions because
Responses are subject to the objections made in its initial responses. That said, Ihave bolded the
16
Defendant’s Further Responses for the
17 arguments that specifically address the deficiencies in
18 Court’s convenience.
5. Regarding the parties’ meet and confer efforts in advance of the February 24, 2023
19
hearing on this matter, on March 13, 2023 I called and telephonically met and conferred with
20
Ariel Redfern, counsel for American Honda Motor Co., Inc. and discussed the deficiencies in
21
Defendant’s Further Responses. A true and correct copy of an email sent memorializing that meet
22
and confer telephone call is attached hereto as Exhibit 1.
23
24
declare under penalty of perjury under the laws of the State
0f California that the
I
25
that this declaration was executed on March 14, 2023 in Los
foregoing is true and correct and
26
Angeles, California.
27
28 -2-
FURTHER
DECLARATION OF TIMOTHY LUPINEK IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL
RESPONSES TO REQUESTS FOR PRODUCTION
Document Filed Date
March 15, 2023
Case Filing Date
April 07, 2022
Category
Breach of Contract/Warranty Unlimited
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Preview
" ORTGINAL KNIGHT LAW GROUP, LLP Roger Kimos (SBN 283 163) .2 i- 9 E a CALIFORNIA 0's»? T0gerk@knightlaW-Com SUPERtOF: ' 93.05.}??? COUNT\/_Q.L T-ggr‘agxmgwj Timothy Lupinek (SBN 334876) SAM ‘ 89.>2r»..¢,a~e>n~ae I s_n..;.,TR.L.. Timothyl@knightlaw.com 10250 Constellation Blvd., Suite 2500 MAR 1 5 2027) Los Angeles, CA 90067 Telephone: (3 1 0) 552—2250 Fax:(310)552-7973 W flfgggfla‘é Zggg LAURA BRUCK, DEPUTY E Attorneys for Plaintiff, EDUARDO ESPINOSA and CELIA ESPINOSA SUPERIOR COURT OF CALIFORNIA \OOOQQ COUNTY OF SAN BERNARDINO Case No.: CIVSBZZO7097 EDUARDO ESPINOSA 10 and CELIA ESPINOSA, . . Unhmlted Jur1sd1ct10n . . . 11 Plaintiffs, DECLARATION OF TIMOTHY 12 VS- LUPINEK re COURT ORDERED FURTHER MEET AND CONFER 13 EFFORTS IN ADVANCE OF AMERICAN HONDA MOTOR CO., INC., HEARING 0N PLAINTIFFS’ 14 a California Corporation, and DOES 1 MOTION TO COMPEL FURTHER through 10, inclusive, RESPONSES TO REQUESTS FOR 15 PRODUCTION, SET ONE FROM DEFENDANT AMERICAN HONDA 16 Defendants. MOTOR CO., INC AND REQUEST FOR SANCTIONS 17 18 Date: February 24, 2023 Time: 8:30 am. 19 Dept; S33 20 Action filed: April 7, 2022 21 Trial: None 22 23 24 25 26 27 28 DECLARATION OF TIMOTHY LUPINEK IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES TO REQUE STS FOR PRODUCTION DECLARATION OF TIMOTHY LUPINEK I, Timothy Lupinek, declare as follows: Courts 0f the State of California, at Knight 1. I am an attorney licensed to practice before all .h Law Group, LLP, attorneys of record for EDUARDO ESPINOSA and CELIA ESPINOSA (“Plaintiffs”) in the above—captioned matter. 2. I have personal knowledge of the facts set forth herein, and, if called t0 testify regarding \OOOQONLI] stated on those matters, I could and would competently testify thereto except as to matters information and belief, and as to those matters, I believe them to be true based upon my review of my firm’s files and records in this matter. 10 3. I submit this declaration in support of Plaintiffs’ Motion to Compel Further Responses to and Request for Requests for Production, Set One, from American Honda Motor Co., 11 Inc., 12 Sanctions. 13 4. The accompanying separate statement includes all of the prior arguments made in Plaintiffs’ Separate Statement in Support of Plaintiffs’ Motion to Compel Further 14 initial Defendant’s Further 15 Responses to Request for Production and Request for Sanctions because Responses are subject to the objections made in its initial responses. That said, Ihave bolded the 16 Defendant’s Further Responses for the 17 arguments that specifically address the deficiencies in 18 Court’s convenience. 5. Regarding the parties’ meet and confer efforts in advance of the February 24, 2023 19 hearing on this matter, on March 13, 2023 I called and telephonically met and conferred with 20 Ariel Redfern, counsel for American Honda Motor Co., Inc. and discussed the deficiencies in 21 Defendant’s Further Responses. A true and correct copy of an email sent memorializing that meet 22 and confer telephone call is attached hereto as Exhibit 1. 23 24 declare under penalty of perjury under the laws of the State 0f California that the I 25 that this declaration was executed on March 14, 2023 in Los foregoing is true and correct and 26 Angeles, California. 27 28 -2- FURTHER DECLARATION OF TIMOTHY LUPINEK IN SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL RESPONSES TO REQUESTS FOR PRODUCTION