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SUPERIOR
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?NIA
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ROSS HOONANIAN, ESQ. (SBN 291479) FEB 2 7 2024
ross@hafilaw.com
HAFTANI LAW GROUP, APLC BY . .. ‘
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4040 Vineland Avenue, Suite 104
KALISKA
Studio City, California 91604 Mgfincue-CASTHO, r: EPUTY
Telephone: (8 1 8) 752-0220
Facsimile: (8 1 8) 752-0221
Attorneys for Plaintiff
SUPERIOR COURT 0F THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO — RANCHO CUCAMONGA
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RICARDO CALVILLO VEGA, etc., Case No.: CIVSB2220649
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Plaintiffs, [Assigned to Hon. Tony Raphael, Dept. R-17]
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vs. NOTICE OF MOTION AND MOTION TO
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HELIDA VEGA, etc., et aL, , FOMVMWS
COMPEL RESPONSES TO FIRST SET OF
- GENERAL
WITHOUT OBJECTION AND FOR
Defendants. MONETARY SANCTIONS AGAINST HELIDA
16 VELA, SHINGO ANDREW AMANO, AND
MARTINEZ, DIETERICH & ZARCONE
l7 LEGAL GROUP, PURSUANT TO C.C.P.,
SECTION 2030.290; DECLARATION OF ROSS
18 HOONANIAN; AND MEMORANDUM OF
POINTS AND AUTHORITIES IN SUPPORT
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THEREOF
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DATE: April 23, 2024
TIME: 8:00 am.
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DEPT: R—17
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TO PLAINTIFF, CARLA LANGLEY AND TO HER ATTORNEYS OF RECORD:
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PLEASE TAKE NOTICE that on April 23, 2024, at the hour of 8:30 a.m., or as soon
26 thereafter as the matter may be heard in Department R—l 7 of the above-entitled court located at
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8303 Haven Avenue, Rancho Cucamonga, California 91730 Plaintiff, RICARDO CALVILLO
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MOTION TO COMPEL RE FIRST SET OF FORM INTERROGATORIES — GENERAL, ETC. l
VEGA, will, and does hereby, move for an order compelling Defendant, HELIDA VEGA, to
provide responses to the First Set of Form Interrogatories -
General without obj ections, and for
monetary sanctions pursuant t0 C.C.P., Section 2030.290 against HELIDA VELA, SHINGO
ANDREW AMANO, and MARTINEZ, DIETERICH & ZARCONE LEGAL GROUP, in such
sum as the Court deems proper. The motion will be, and is, made upon the ground that a First
Set of Form Interrogatories - General was served 0n said Defendant, through Plaintiff’s
attorney, that the time to respond has elapsed, and said Defendant has failed and refused to
provide a response thereto.
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The motion will be, and is, based on this notice, the attached Declaration of Ross
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Hoonanian, the attached memorandum of points and authorities, upon all of the papers and
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records on file in this action, and upon such other and further oral
13 and documentary evidence as
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DATED: February 26, 2024
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HAFTANI LAW GROUP, APLC
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PE ROSS HOONANIAN, ESQ.
Attorney for Plaintifi‘
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MOTION TO COMPEL RE FIRST SET OF FORM INTERROGATORIES GENERAL, ETC. ~—
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\r V F LED CW gssiagznm SUPERIOR l ?NIA T10 ROSS HOONANIAN, ESQ. (SBN 291479) FEB 2 7 2024 ross@hafilaw.com HAFTANI LAW GROUP, APLC BY . .. ‘ . ‘ 4040 Vineland Avenue, Suite 104 KALISKA Studio City, California 91604 Mgfincue-CASTHO, r: EPUTY Telephone: (8 1 8) 752-0220 Facsimile: (8 1 8) 752-0221 Attorneys for Plaintiff SUPERIOR COURT 0F THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO — RANCHO CUCAMONGA 10 11 RICARDO CALVILLO VEGA, etc., Case No.: CIVSB2220649 12 Plaintiffs, [Assigned to Hon. Tony Raphael, Dept. R-17] 13 vs. NOTICE OF MOTION AND MOTION TO l4 15 HELIDA VEGA, etc., et aL, , FOMVMWS COMPEL RESPONSES TO FIRST SET OF - GENERAL WITHOUT OBJECTION AND FOR Defendants. MONETARY SANCTIONS AGAINST HELIDA 16 VELA, SHINGO ANDREW AMANO, AND MARTINEZ, DIETERICH & ZARCONE l7 LEGAL GROUP, PURSUANT TO C.C.P., SECTION 2030.290; DECLARATION OF ROSS 18 HOONANIAN; AND MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT 19 THEREOF 20. DATE: April 23, 2024 TIME: 8:00 am. 21 DEPT: R—17 22 23 TO PLAINTIFF, CARLA LANGLEY AND TO HER ATTORNEYS OF RECORD: 24 25 PLEASE TAKE NOTICE that on April 23, 2024, at the hour of 8:30 a.m., or as soon 26 thereafter as the matter may be heard in Department R—l 7 of the above-entitled court located at 27 8303 Haven Avenue, Rancho Cucamonga, California 91730 Plaintiff, RICARDO CALVILLO 28 MOTION TO COMPEL RE FIRST SET OF FORM INTERROGATORIES — GENERAL, ETC. l VEGA, will, and does hereby, move for an order compelling Defendant, HELIDA VEGA, to provide responses to the First Set of Form Interrogatories - General without obj ections, and for monetary sanctions pursuant t0 C.C.P., Section 2030.290 against HELIDA VELA, SHINGO ANDREW AMANO, and MARTINEZ, DIETERICH & ZARCONE LEGAL GROUP, in such sum as the Court deems proper. The motion will be, and is, made upon the ground that a First Set of Form Interrogatories - General was served 0n said Defendant, through Plaintiff’s attorney, that the time to respond has elapsed, and said Defendant has failed and refused to provide a response thereto. 10 The motion will be, and is, based on this notice, the attached Declaration of Ross ll Hoonanian, the attached memorandum of points and authorities, upon all of the papers and 12 records on file in this action, and upon such other and further oral 13 and documentary evidence as 14 may be presented at the hearing 15 DATED: February 26, 2024 l6 HAFTANI LAW GROUP, APLC 17 18 19 20 PE ROSS HOONANIAN, ESQ. Attorney for Plaintifi‘ 21 22 23 24 25 26 27 28 MOTION TO COMPEL RE FIRST SET OF FORM INTERROGATORIES GENERAL, ETC. ~— 2