Party Discovery: HDM FURNITURE INDUSTRIES INC VS. VICTORIA L CARD ET AL

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                                SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO

Document Scanning Lead Sheet
Sep-09-2015 9:05 am

Case Number: CGC-15-544243
Filing Date: Sep-08-2015 9:03
Filed by: EDNALEEN JAVIER

Juke Box: 001 Image: 05066816
GENERIC CIVIL FILING (NO FEE)

HDM FURNITURE INDUSTRIES INC VS. VICTORIA L CARD ET AL

001C05066816

Instructions:
Please place this sheet on top of the document to be scanned.: . Ss E:
Name: Victoria L. Card / couny, , ERIOR Soup T
Address: P.O. Box 502 20) “NER ANGISG
Petaluma, CA 94953 SSEP~@ ay
In Pro Per 3: 05

Tel: 415-710-9296

SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO

PLAINTIFF, i .

Case No.: CGC - 15 — 544243
HDM FURNITURE INDUSTRIES INC, i
HERITAGE HOME GROUP LLC. i RESPONSE TO:

NOTICE OF DEFENDANT’S MOTION FOR

ORDER COMPELLING RESPONSE TO

vs INTERROGATORIES AND FOR SANCTIONS »
‘THEREON.
DEFENDANT, ‘Date: October 7, 2015
‘Time: 9.30 am
VICTORIA CARD ‘Dept: 302

TO ALL PARTIES AND THEIR COUNSEL OF RECORD:

FACTS
1. Plaintiff's Counsel assertions submitted are false. The Plaintiff in question filed
bankruptcy back in September 2013 therefore, the company dissolved. The Counsel’s
attempt is baseless and unfounded and I don’t owe plaintiff a Cent.

2. Plaintiffs counsel continuously is diverting the truth, resorting to misleading legal
ways to extort monetary relief. In fact, the entire lawsuit is bogus and plaintiff has to date
failed to provide a shred of evidence to show proof to justify the lawsuit.

3. Plaintiff has failed to prove ownership of this debt. Therefore, applying CCP
2033.280 and pressing for documents or admission and asking the court for sanctions isbaseless and unwarranted.
CONCLUSION

I pray the court dismiss plaintiff's entire complaint.
I pray for cost of suit incurred herein; and
For such other further relief as the court may find just and proper.

I am 60 year old single women self-employed in the Bay Area for over 35 years. I
have to represent myself without a lawyer because I can't afford and justify the
expense. I fully rely on the honorable judge in court to apply the correct law and

reach the right conclusions.

Respectfully Submit,
Victoria L. Card

Yetrue L QuePROOF OF SERVICE
The undersigned declares as follows:
I am a citizen of the United States, over 18 years of age, reside in the County of
Marin State of California, and am not a party to the within cause of action. My address is
1977B Union Street Francisco, CA 94123 On 09/03/2015 I served a copy of the
document (s) described as: MOTION RESPONSE
On all interested parties in this action as addressed below in the indicated manner:

-HDM FUNITURE
PO BOX 2169
OAKLAND CA 94621

_X (BY MAIL & FAX) I placed said document(s) in a sealed envelope, with postage
thereon fully prepaid for first class mail, and placed such envelope in the United States
mail at San Francisco, California..

I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct and that this declaration was executed on this Monday day
of 09/03/2015 San Francisco, CA California.

Michael Mott: Signature: \