On June 10, 2022 a Party Discovery was filed involving a dispute between Alexander, Alexis, Bryant Jr., Kerry, Castaneda, Alex, Crummie, Joniceya, Gamble, Maxwell, Goodwin, Angelette, Howard, Catherine, Howard, Destiny, Howard, Terrance, Jackson, De'Andre, Little, Anasuya, Little, Azanae, Little, Azanique, Little, Rowmale, Matthews, Starnisha, Mendoza, Raymond, Mendoza, Sally, Moore, Cheri, Moore, Denazia, Price, Rekina, Purvis, Jeremy, Quinney, Trish, Ramos, Valerie, Robinson, Efrem Z., Robinson, L'Rea, Todd, Jermaine, Wilson, Faith, Wilson, Imani, and Does 1-50, Does 2-50, Golden Management Services Inc., Group Ii Azusa Properties Limited, Hightower Management Inc., Pama Management Inc., for Other PI/PD/WD Unlimited in the District Court of San Bernardino County.
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ELECTRONICALLY FILED 1 Chandra Gehri Spencer (SBN 184010) SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO Margaret A. Elder (SBN 177424) SAN BERNARDINO DISTRICT 2 Lanetta D. W. Rinehart (SBN 208969) 3 ELDER & SPENCER, LLP 2/7/2024 12:25 PM 2625 Townsgate Road, Suite 330 By: Abrianna Rodriguez, DEPUTY 4 Westlake Village, CA 91361 Tel: (213) 631-8331 5 Fax: (888) 422-8027 6 Attorneys for Plaintiffs STARNISHA MATTHEWS et al 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 COUNTY OF SAN BERNARDINO 9 10 STARNISHA MATTHEWS, et. al., Case No: CIV SB2210924 Judge: Hon. Khymberli S Apaloo 11 Plaintiffs, Dept.: S25 12 v. PLAINTIFFS’ NOTICE OF MOTION AND MOTION TO COMPEL 13 GROUP II AZUSA PROPERTIES LIMITED, a DEPOSITION OF DEFENSE WITNESS California Limited Partnership; PAMA JESSE CARRILLO; MEMORANDUM OF 14 MANAGEMENT INC., a California POINTS AND AUTHORITIES; Corporation; HIGHTOWER MANAGEMENT DECLARATION OF LANETTA 15 INC., a Nevada Corporation; and DOES 1 RINEHART IN SUPPORT THEREOF through 50, inclusive, 16 REQUEST FOR SANCTIONS Defendants. 17 Date: May 9, 2024 Time: 8:30 a.m. 18 Dept: S25 19 Date Action filed: June 10, 2022 Trial Date: April 8, 2024 20 21 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 22 PLEASE TAKE NOTICE that on May 9, 2024 at 8:30 a.m., or as soon thereafter as the 23 matter may be heard in Department S25 of the above-entitled court, located at 247 W Third Street 24 in San Bernardino, California, Plaintiffs Starnisha Matthews, et al will move, and hereby do move, 25 for an Order compelling the deposition of defense witness, Jesse Carrillo, within fourteen (14) 26 days of the hearing of this motion. 27 This Motion is being brought pursuant to Code of Civil Procedure §§ 2025.450(a) and 28 2030.290(b) on the grounds that Defendants Group II Azusa Properties Limited, PAMA 1 PLAINTIFFS’ NOTICE OF MOTION AND MOTION TO COMPEL DEPOSITION OF DEFENSE WITNESS JESSE CARRILLO 1 Management Inc. and Hightower Management Inc. have failed, without justification, to cooperate 2 in the discovery process and produce this witness for deposition. 3 PLEASE TAKE FURTHER NOTICE that pursuant to Code of Civil Procedure § 4 2025.450(g)(1), Plaintiffs are also seeking an order of monetary sanctions of $5,151.67 against 5 Defendants for the attorneys’ fees and costs related to the filing of this instant motion. 6 This Motion will be based upon this notice, the attached Memorandum of Points and 7 Authorities, Declaration of Lanetta Rinehart and upon all of the papers and records on file in this 8 action, and upon such other and further oral and documentary evidence as may be presented at the 9 hearing. 10 11 DATED: FEBRUARY 6, 2024 ELDER & SPENCER, LLP 12 13 By: Lanetta Rinehart, Of Counsel 14 Attorneys for Plaintiffs 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 PLAINTIFFS’ NOTICE OF MOTION AND MOTION TO COMPEL DEPOSITION OF DEFENSE WITNESS JESSE CARRILLO