On June 01, 2016 a
Party Discovery
was filed
involving a dispute between
Dbp Investments,
King Plaza Center, Llc,
and
Does 1 - 10, Inclusive,
King Plaza Center,Llc,
Lai, Thanh,
Lien, Sovan,
Quach, Bua,
Voung, Dong,
for (26) Unlimited Other Real Property
in the District Court of San Mateo County.
Preview
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1
STEVEN B. PISER, SBN 62414
LAW OFFICES OF STEVEN B. PISER
A Professional Corporation
1300 Clay Street, Suite 1050
Oakland, California 94612
Telephone: (510) 835-5582
Facsimile: (510) 832-1717 FTLED
MATEO COUNTY
JOHN L. FITZGERALD, SBN 126613 SAN
LAW OFFICES OF JOHN L. FITZGERALD
101 California Street, Suite
2300
San Francisco, California
94111
Telephone: (415) 689-1209
Attorneys for
DBP INVESTMENTS,
a California General
Partnership
IN THE SUPERIOR COURT OF THE
STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF
SAN MATEO
DBP INVESTMENTS, a California
Partnership,
General ) CASE NO. CIV538897
24E
)
Plaintifi )
) NOTICE OF MOTION AND MOTION
I
) COMPEL FURTHER RESPONSES
To
V To REQUEST
) FOR PRODUCTION OF
DOCUMENTS AND FOR
KING PLAZA CENTER, LLC, a J PRODUCTION OF DOCUMENTS,
Delaware J SET ONE AND
Limited Liability Company, SANCTIONS
an individual, SOVAN
BUA-QUACH, )
LIENfan individual, )
DONG VUONG, an individual, DATE
FEBRUARY 16, 2017
THANH ) TIME
LAI, and DOES 1 through 10 9:00 A. M.
) DEPT. LAW & MOTION
Defimdcmls.
) TRIAL NOT YET SET
)
KING PLAZA CENTER, LLC, a )
Delaware )
Limited L:iability Company,
)
Cross-Complainant,
) BY FAX,
V. J
)
DBP INVESTMENTS, a California ‘
Partnership and ROES 1 through
General 3 { iii/53589;
MOTC
10, ) ,
.'
Motion
) ,3
337033
Cross-Defiandam‘s.
) .r'
Law Oflices of
Steven B. Piser
\ _' ' - - . .
,
l 0 REQUEST FOR Pnouucnon
OF Documms AND Fox
DOCUMENTS, SET ONE AND PRODUCTION OF
SANCTIONS
C- ~
0
1 PLEASE TAKE NOTICE that on February 16, 2017 at 9:00 am. in Law & Motion
2 Department of the above-entitled court, located at 400 County Center, Redwood City, California,
3 plaintiff DBP Investments will seek an order compelling responses, without objection, to
4 inspection demand, set one, from Bua Quach and production of documents. DBP will also seek
5 an order for sanctions against Bua Quach and his attorney James Barrett for failing to respond to
6 DBP’s first inspection demand.
7 This motion will be based on the grounds that defendants have failed to respond to
8 request for production of documents pursuant to GOP. §2031.210, et. seq. and produce
9 documents responsive to the requests. This motion is made based upon California Code of Civil
10 Procedure §§ 2031.310, 2031.320, 2023.010, and 2023.030.
11 This motion is based upon this notice, declaration of Steven B. Piser, memorandum of
12 points and authorities, separate statement and such other and further evidence that may be
13 presented at the hearing.
14 LAW OFFICES OF STEVEN B. PISER
A Professional Corporation
15
x"
16 //
17 DATED: Januaryig2017 By: / a/
STEVEN B. PISER
18 Attorney for
DBP INVESTMENTS, a California
19 .
General Partnershlp
2O
21
22
23
24
25
26
27
28
Law Offices of 2
SEW" 3- Pisa" NOTICE OF MOTION AND MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION Ol’ DOCUMENTS AND FOR PRODUCTION OF
DOCUMENTS, SET ONE AND SANCTIONS
Preview
=3 1 STEVEN B. PISER, SBN 62414 LAW OFFICES OF STEVEN B. PISER A Professional Corporation 1300 Clay Street, Suite 1050 Oakland, California 94612 Telephone: (510) 835-5582 Facsimile: (510) 832-1717 FTLED MATEO COUNTY JOHN L. FITZGERALD, SBN 126613 SAN LAW OFFICES OF JOHN L. FITZGERALD 101 California Street, Suite 2300 San Francisco, California 94111 Telephone: (415) 689-1209 Attorneys for DBP INVESTMENTS, a California General Partnership IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN MATEO DBP INVESTMENTS, a California Partnership, General ) CASE NO. CIV538897 24E ) Plaintifi ) ) NOTICE OF MOTION AND MOTION I ) COMPEL FURTHER RESPONSES To V To REQUEST ) FOR PRODUCTION OF DOCUMENTS AND FOR KING PLAZA CENTER, LLC, a J PRODUCTION OF DOCUMENTS, Delaware J SET ONE AND Limited Liability Company, SANCTIONS an individual, SOVAN BUA-QUACH, ) LIENfan individual, ) DONG VUONG, an individual, DATE FEBRUARY 16, 2017 THANH ) TIME LAI, and DOES 1 through 10 9:00 A. M. ) DEPT. LAW & MOTION Defimdcmls. ) TRIAL NOT YET SET ) KING PLAZA CENTER, LLC, a ) Delaware ) Limited L:iability Company, ) Cross-Complainant, ) BY FAX, V. J ) DBP INVESTMENTS, a California ‘ Partnership and ROES 1 through General 3 { iii/53589; MOTC 10, ) , .' Motion ) ,3 337033 Cross-Defiandam‘s. ) .r' Law Oflices of Steven B. Piser \ _' ' - - . . , l 0 REQUEST FOR Pnouucnon OF Documms AND Fox DOCUMENTS, SET ONE AND PRODUCTION OF SANCTIONS C- ~ 0 1 PLEASE TAKE NOTICE that on February 16, 2017 at 9:00 am. in Law & Motion 2 Department of the above-entitled court, located at 400 County Center, Redwood City, California, 3 plaintiff DBP Investments will seek an order compelling responses, without objection, to 4 inspection demand, set one, from Bua Quach and production of documents. DBP will also seek 5 an order for sanctions against Bua Quach and his attorney James Barrett for failing to respond to 6 DBP’s first inspection demand. 7 This motion will be based on the grounds that defendants have failed to respond to 8 request for production of documents pursuant to GOP. §2031.210, et. seq. and produce 9 documents responsive to the requests. This motion is made based upon California Code of Civil 10 Procedure §§ 2031.310, 2031.320, 2023.010, and 2023.030. 11 This motion is based upon this notice, declaration of Steven B. Piser, memorandum of 12 points and authorities, separate statement and such other and further evidence that may be 13 presented at the hearing. 14 LAW OFFICES OF STEVEN B. PISER A Professional Corporation 15 x" 16 // 17 DATED: Januaryig2017 By: / a/ STEVEN B. PISER 18 Attorney for DBP INVESTMENTS, a California 19 . General Partnershlp 2O 21 22 23 24 25 26 27 28 Law Offices of 2 SEW" 3- Pisa" NOTICE OF MOTION AND MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION Ol’ DOCUMENTS AND FOR PRODUCTION OF DOCUMENTS, SET ONE AND SANCTIONS