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  • Bonilla, Daniel Gregory vs. Toor, Harjoban Kaur et al Auto Tort (22) document preview
  • Bonilla, Daniel Gregory vs. Toor, Harjoban Kaur et al Auto Tort (22) document preview
  • Bonilla, Daniel Gregory vs. Toor, Harjoban Kaur et al Auto Tort (22) document preview
  • Bonilla, Daniel Gregory vs. Toor, Harjoban Kaur et al Auto Tort (22) document preview
  • Bonilla, Daniel Gregory vs. Toor, Harjoban Kaur et al Auto Tort (22) document preview
  • Bonilla, Daniel Gregory vs. Toor, Harjoban Kaur et al Auto Tort (22) document preview
						
                                

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ELECTRONICALLY FILED Superior Court of California, PETERJ. HIRSIG (State Bar No. 197993) Count of Placer peter.hirsig@ mcnamaralaw.com 03/05/2024 at 10:01:17 AM DANIEL R. MAYER (State Bar No. 300077) By: Marina C Olivarez Fuentes daniel. mayer@ mcnamaralaw.com Deputy Clerk McNAMARA, AMBACHER, WHEELER, HIRSIG & GRAY LLP 639 Kentucky Street, Fairfield, CA 94533 Telephone: (707) 427-3998 Facsimile: (707) 427-0268 Attorneys for Defendants HARJOBAN KAUR TOOR and BALJIT SINGH TOOR SUPERIOR COURT OF CALIFORNIA, COUNTY OF PLACER CIVIL - UNLIMITED JURISDICTION 10 11 DANIEL GREGORY BONILLA, an Case No. S-CV-0048973 12 individual, NOTICE OF NON-OPPOSITIONTO 13 Plaintiff, DEFENDANTS’ MOTION FOR LEAVE TO PERFORM A FURTHER 14 vs. INDEPENDENT MEDICAL PHYSICAL EXAMINATION OF PLAINTIFF 15 HARJOBAN KAUR TOOR, an individual; BALJIT SINGH TOOR, an individual; Date: March 12, 2024 16 DOES 1 through 50, inclusive, Time: 8:30 am. Dept: 42 17 Defendants. Trial Date: 4/2/2024 Action Filed: 8/19/2022 18 19 20 TO THE COURT, ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 21 PLEASE TAKE NOTICE that Plaintiff DANIEL BONILLA (“Plaintiff”) has not filed or 22 served a brief in Opposition to the Motion of Defendants HARJOBAN KAUR TOOR and BALJIT 23 SINGH TOOR (“Defendants”) for Leave to Perform a Further Independent Medical Examination 24 of Plaintiff. 25 Pursuant to the briefing schedule ordered by the Court in granting Defendants’ ex parte 26 application for an order shortening time to hear this and other Motions, on February 22, 2024, 27 Plaintiff's last day to file and serve Oppositions to Defendants’ Motions was March 1, 2024. On 28 that date, Plaintiff did serve Oppositions to Defendants’ two other Motions (for Protective Order NOTICE OF NON-OPPOSITION TO MOTION FOR LEAVE TO PERFORM FURTHER PHY SICAL EXAMINATION OF PLAINTIFF and for Leave to Take a Second Volume of Plaintiff's Deposition), but no Opposition to the instant Motion was received. Defendant therefore respectfully requests that the Court grant Defendants’ Motion, in full, on its unopposed merits. Dated: March 5, 2024 MCNAMARA, AMBACHER, WHEELER, HirsiG & GRAY LLP By: Danie R. M ayer Peter J. Hirsig Daniel R. Mayer Attorneys for Defendant HARJOBAN KAUR TOOR and BALJIT SINGH 10 TOOR 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 NOTICE OF NON-OPPOSITION TO MOTION FOR LEAVE TO PERFORM FURTHER PHY SICAL EXAMINATION OF PLAINTIFF CERTIFICATE OF SERVICE VIA E-MAIL I hereby declare that I am a citizen of the United States, am over the age of eighteen years, and not a party to the within action. My electronic notification address is: liesl.swartwood@ mcnamaralaw.com. On this date, I electronically served the foregoing NOTICE OF NON-OPPOSITION TO DEFENDANTS’ MOTION FOR LEAVE TO PERFORM A FURTHER INDEPENDENT MEDICAL PHYSICAL EXAMINATION OF PLAINTIFF based on a court order or an agreement of the parties to accept service by e-mail or electronic transmission, I caused the documents to be sent to the persons at the e-mail addresses listed below. I did not receive, within a 10 reasonable time after the transmission, any electronic message or other indication that the 11 transmission was unsuccessful. 12 13 Attomeys For Plaintiff: 14 Colin Jones, Esq. Todd Drakeford, Esq. 15 Wilshire Law Firm 3055 Wilshire Blvd., 12th Floor 16 Los Angeles , CA 90010-1176 17 Phone: 213-381-9988 Fax: 213-381-9989 18 E-Mail: Colin@ wilshirelawfirm.com; tdrakeford@ wilshirelawfirm.com; 19 evaughn@ wilshirelawfirm.com; 20 21 I declare under penalty of perjury under the laws of the State of California that the foregoing 22 is true and correct and that this declaration was executed on March 5, 2024 at Fairfield, California. eae) 23 24 Cc —— a ees Cx bias LIESL C. SWARTWOOD 25 26 27 28 3 NOTICE OF NON-OPPOSITION TO MOTION FOR LEAVE TO PERFORM FURTHER PHY SICAL EXAMINATION OF PLAINTIFF