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
(I
STEVEN B. PISER, SBN 62414
\X\1’\ LAW OFFICES OF STEVEN B. PISER
A Professional Corporation
1300 Clay Street, Suite 1050
Oakland, California 94612
Telephone: (510) 835-5582
F E E, E 13].)
SAN MATEO COUNTY
Facsimile: (510) 832-1717
©00\IO‘\(J'l-I>OJL\DI—*
JOHN L. FITZGERALD, SBN 126613
LAW OFFICES OF I OHN L. FITZGERALD
101 California Street, Suite 23 00
San Francisco, California 941 1 1
Telephone: (415) 689-1209
Attorneys for
DBP INVESTMENTS,
a California General Partnership
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN MATEO
DBP INVESTMENTS, a California General ) CASE NO. CIV538897
Partnership, )
)
Plaintifif ) NOTICE OF MOTION AND MOTION To
COMPEL ANSWER To SPECIAL
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)
v. ) IN’I‘ERROGATORY AND FOR SANCTIONS
) FROM KING PLAZA CENTER, LLC
OOflmm-DWLQI-‘OKOOOVGOI-DCDNHO
KING PLAZA CENTER, LLC, a Delaware )
Limited Liability Company, BUA-QUACH, ) DATE : APRIL 28, 2017
an individual, SOVAN LIEN, an individual, ) TIME : 9:00 A.M.
DONG VUONG, an individual, THANI—I ) DEPT. : LAW & MOTION
LAI, and DOES 1 through 10 TRIAL : NOVEMBER 13, 2017
i
Defendants. ) BY FAX
)
KING PLAZA CENTER, LLC, a Delaware )
Limited Liability Company, )
)
Cross- Complainant, )
v. )
)‘
DBP INVESTMENTS, a California General ) {/CIV538897
Partnership and ROES 1 through 10, )
i
MOTCOM
Motion to CompeI
)
1
_
4
Cross—Defendants. )
)
111 1|111111111 ,,
Law Offices 0/
Steven B. Piscr
NOTICE OF MOTION AND MOTION To COMPEL ANSWER To SPECIAL INTERROGATORY AND FOR SANCTIONS FROM KING PLAZA CENTER, LLC
d 06 WW 1102 I
PLEASE TAKE NOTICE that on April 28, 2017 at 9:00 a.m. in Law & Motion
Department of the above-entitled court, located at 400 County Center, Redwood City, California,
or as soon thereafter as the matter can be heard, DBP Investments will seek an order compelling
further responses to special interrogatory 2, set one, from defendant King Plaza Center, LLC and
kOOO\IO\Cfl-l>OJt\)»—-
for sanctions against King Plaza Center, LLC.
This motion will be based on the grounds that the information sought by the
intenogatory is properly the subject of discovery that good cause exists for compelling responses
to the interrogatory, the objections are without merit and that the failure to provide proper
answers is without substantialjustification. This motion is made based upon California Code of
Civil Procedure §§ 2030.300 and 2023.010.
This motion is based upon this notice, the complaint, separate statement, declaration of
Steven B. Piser, memorandum of points and authorities, request for judicial notice and such
other and further evidence that may be presented at the hearing.
LAW OFFICES OF STEVEN B. PISER
A Prof sional Corporation
DATED: March £5: 2017
wwmwwwwHP—‘l—‘l—IHl—lP—‘l—ll—‘l—l
By: ;
,s’TEVEN B. PISER
Attorney for
DBP INVESTMENTS, a California
General Paitnership
OOVOW-bODMHOOOOVONCH-PCDNHO
Law Offices of
Steven B. Piscr 2
NOTICE OE MOTION AND MOTION To COMPEL ANSWER To SPECIAL INTERROGA‘I‘ORY AND FOR SANCTIONs FROM KING PLAZA CENTER, LLC
Preview
(I STEVEN B. PISER, SBN 62414 \X\1’\ LAW OFFICES OF STEVEN B. PISER A Professional Corporation 1300 Clay Street, Suite 1050 Oakland, California 94612 Telephone: (510) 835-5582 F E E, E 13].) SAN MATEO COUNTY Facsimile: (510) 832-1717 ©00\IO‘\(J'l-I>OJL\DI—* JOHN L. FITZGERALD, SBN 126613 LAW OFFICES OF I OHN L. FITZGERALD 101 California Street, Suite 23 00 San Francisco, California 941 1 1 Telephone: (415) 689-1209 Attorneys for DBP INVESTMENTS, a California General Partnership IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN MATEO DBP INVESTMENTS, a California General ) CASE NO. CIV538897 Partnership, ) ) Plaintifif ) NOTICE OF MOTION AND MOTION To COMPEL ANSWER To SPECIAL wwmwwwwwwHHI—‘HHHb—‘I—‘l—‘H ) v. ) IN’I‘ERROGATORY AND FOR SANCTIONS ) FROM KING PLAZA CENTER, LLC OOflmm-DWLQI-‘OKOOOVGOI-DCDNHO KING PLAZA CENTER, LLC, a Delaware ) Limited Liability Company, BUA-QUACH, ) DATE : APRIL 28, 2017 an individual, SOVAN LIEN, an individual, ) TIME : 9:00 A.M. DONG VUONG, an individual, THANI—I ) DEPT. : LAW & MOTION LAI, and DOES 1 through 10 TRIAL : NOVEMBER 13, 2017 i Defendants. ) BY FAX ) KING PLAZA CENTER, LLC, a Delaware ) Limited Liability Company, ) ) Cross- Complainant, ) v. ) )‘ DBP INVESTMENTS, a California General ) {/CIV538897 Partnership and ROES 1 through 10, ) i MOTCOM Motion to CompeI ) 1 _ 4 Cross—Defendants. ) ) 111 1|111111111 ,, Law Offices 0/ Steven B. Piscr NOTICE OF MOTION AND MOTION To COMPEL ANSWER To SPECIAL INTERROGATORY AND FOR SANCTIONS FROM KING PLAZA CENTER, LLC d 06 WW 1102 I PLEASE TAKE NOTICE that on April 28, 2017 at 9:00 a.m. in Law & Motion Department of the above-entitled court, located at 400 County Center, Redwood City, California, or as soon thereafter as the matter can be heard, DBP Investments will seek an order compelling further responses to special interrogatory 2, set one, from defendant King Plaza Center, LLC and kOOO\IO\Cfl-l>OJt\)»—- for sanctions against King Plaza Center, LLC. This motion will be based on the grounds that the information sought by the intenogatory is properly the subject of discovery that good cause exists for compelling responses to the interrogatory, the objections are without merit and that the failure to provide proper answers is without substantialjustification. This motion is made based upon California Code of Civil Procedure §§ 2030.300 and 2023.010. This motion is based upon this notice, the complaint, separate statement, declaration of Steven B. Piser, memorandum of points and authorities, request for judicial notice and such other and further evidence that may be presented at the hearing. LAW OFFICES OF STEVEN B. PISER A Prof sional Corporation DATED: March £5: 2017 wwmwwwwHP—‘l—‘l—IHl—lP—‘l—ll—‘l—l By: ; ,s’TEVEN B. PISER Attorney for DBP INVESTMENTS, a California General Paitnership OOVOW-bODMHOOOOVONCH-PCDNHO Law Offices of Steven B. Piscr 2 NOTICE OE MOTION AND MOTION To COMPEL ANSWER To SPECIAL INTERROGA‘I‘ORY AND FOR SANCTIONs FROM KING PLAZA CENTER, LLC