On November 08, 2018 a
Motion,Ex Parte
was filed
involving a dispute between
Sanchez, Jose,
and
Chay, Pether Robert Thao,
Ramirez, Ruben,
Vang, Ba,
for 22 Unlimited - Auto
in the District Court of Fresno County.
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ACCIDENT, INJURY AND MEDICAL MALPRACTICE
ATTORNEYS OF CALIFORNIA, APC
Jeffi‘ey D. Bohn, (SBN: 243870)
2445 Capitol Skeet, Suite 105 E-FILED
Fresno, CA 93721 2/13/2019 3:01 PM
Telephone: (559) 485-1212
Facsimile: (559) 485-1210 FRESNO COUNTY SUPERIOR COURT
By: J. Nelson, Deputy
Attorneys for Plaintiffs
SUPERIOR COURT 0F THE STATE OF CALIFORNIA
FOR THE COUNTY 0F FRESNO
IO
ll JOSE SANCHEZ, et a1., ) Case No.: 18CECG04143
)
12
Plaintiffs, ) NOTICE 0F MOTION AND MOTION
13
vs. ) T0 COMPEL ANSWERS T0
) DISCOVERY AND FOR SANCTIONS
l4 BA VANG, et a1., )
) Date: May 1, 2019
l5
Defendants. ) Time: 3:30 p.m.
16 ) Dept: 403
)
l7
) Hon. Rosemary McGuire
)
18
19 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
20 PLEASE TAKE NOTICE that at 3:30 pm. on May 1, 2019, or as soon thereafier as the
21 matter may be heard, in Department 403 ofthe Fresno County Superior Court, 1 130 “O” Street,
22 Fresno, California, Plaintifi‘ JOSE SANCHEZ will move the Court for an order compelling
23 Defendant ROBERT PETHER to answer, without objection, Plaintiffs Form Interrogatories -
24 General, Set One.
25 This motion is made pursuant to Code of Civil Procedure section 2030.290 on the
26 ground that the intenogatories are relevant to the subject matter of the action, and Defendant’s
27 refusal to answer is without substantial justification.
28
l
Notice of Motion and Motion to Compel Answers to Discovery and for Sanctions
PLEASE TAKE FURTHER NOTICE that Plaintiffs will also move the Court, pursuant
to Code 0f Civil Procedure sections 2030.290 and 2023.01 0, subdivision (d), for an order that
Defendant ROBERT PETHER and/or Defense counsel pay to the moving party the sum of
$1 ,315.60 as the reasonable costs and attorney fees incurred by moving party for these
proceedings on the ground that Defendant was advised of proper service of this action and
subsequent discovery with proof of service, yet Defendant still failed to respond or to submit t0
an authorized method of discovery and such refusal constitutes a misuse ofthe discovery
process.
The motion will be based upon this notice, the attached memorandum in support and
declaration, and the records and files in this action.
Dated: February 13, 2019 ACCIDENT, INJURY AND MEDICAL MALPRACTICE
ATTORNEYS OF CALIFORNIA, APC
wfla
Jeffi’e'y D. Bohn, Esq.
2
Notice of Motion and Motion to Compel Answers to Discovery and for Sanctions
Document Filed Date
February 13, 2019
Case Filing Date
November 08, 2018
Category
22 Unlimited - Auto
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ACCIDENT, INJURY AND MEDICAL MALPRACTICE ATTORNEYS OF CALIFORNIA, APC Jeffi‘ey D. Bohn, (SBN: 243870) 2445 Capitol Skeet, Suite 105 E-FILED Fresno, CA 93721 2/13/2019 3:01 PM Telephone: (559) 485-1212 Facsimile: (559) 485-1210 FRESNO COUNTY SUPERIOR COURT By: J. Nelson, Deputy Attorneys for Plaintiffs SUPERIOR COURT 0F THE STATE OF CALIFORNIA FOR THE COUNTY 0F FRESNO IO ll JOSE SANCHEZ, et a1., ) Case No.: 18CECG04143 ) 12 Plaintiffs, ) NOTICE 0F MOTION AND MOTION 13 vs. ) T0 COMPEL ANSWERS T0 ) DISCOVERY AND FOR SANCTIONS l4 BA VANG, et a1., ) ) Date: May 1, 2019 l5 Defendants. ) Time: 3:30 p.m. 16 ) Dept: 403 ) l7 ) Hon. Rosemary McGuire ) 18 19 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 20 PLEASE TAKE NOTICE that at 3:30 pm. on May 1, 2019, or as soon thereafier as the 21 matter may be heard, in Department 403 ofthe Fresno County Superior Court, 1 130 “O” Street, 22 Fresno, California, Plaintifi‘ JOSE SANCHEZ will move the Court for an order compelling 23 Defendant ROBERT PETHER to answer, without objection, Plaintiffs Form Interrogatories - 24 General, Set One. 25 This motion is made pursuant to Code of Civil Procedure section 2030.290 on the 26 ground that the intenogatories are relevant to the subject matter of the action, and Defendant’s 27 refusal to answer is without substantial justification. 28 l Notice of Motion and Motion to Compel Answers to Discovery and for Sanctions PLEASE TAKE FURTHER NOTICE that Plaintiffs will also move the Court, pursuant to Code 0f Civil Procedure sections 2030.290 and 2023.01 0, subdivision (d), for an order that Defendant ROBERT PETHER and/or Defense counsel pay to the moving party the sum of $1 ,315.60 as the reasonable costs and attorney fees incurred by moving party for these proceedings on the ground that Defendant was advised of proper service of this action and subsequent discovery with proof of service, yet Defendant still failed to respond or to submit t0 an authorized method of discovery and such refusal constitutes a misuse ofthe discovery process. The motion will be based upon this notice, the attached memorandum in support and declaration, and the records and files in this action. Dated: February 13, 2019 ACCIDENT, INJURY AND MEDICAL MALPRACTICE ATTORNEYS OF CALIFORNIA, APC wfla Jeffi’e'y D. Bohn, Esq. 2 Notice of Motion and Motion to Compel Answers to Discovery and for Sanctions