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
STEVEN B. PISER, SBN 62414
LAW OFFICES OF STEVEN B. PISER
A Professional Corporation
1300 Clay Street,
Oakland,
Suite
California 94612
1050
FILED
Telephone: (510) 835-5582 SAN MATEO COUNTY
Facsimile: (510) 832-1717 2017
MAY 2 6
JOHN L. FITZGERALD,
\OOOQONO'l—POJLQH
SBN 126613 3 rim court
LAW OFFICES OF JOHN L. FITZGERALD
101 California Street, Suite 23 00
San Francisco, California 94111
Telephone: (415) 689—1209
Attorneys for
DBP INVESTMENTS,
a California General Partnership
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNLA
IN AND FOR THE COUNTY OF SAN MATEO
DBP INVESTMENTS, a California General ) CASE NO. CIV538897
Partnership, )
)
Plaintiff
NNMMMNNMNI—IHI—II—II—II—II—II—IHI—I
) NOTICE OF MOTION AND MOTION To
) COMPEL FURTHER ANSWER To SPECIAL
v. ) INTERROGATORY #5 AND FOR SANCTIONs
)
*
FROM KING PLAZA CENTER, LLC
KING PLAZA CENTER, LLC, a Delaware )
Limited Liability Company, BUA-QUACH,
mflOIUT-PCOLQl—‘Okomqmm-POJLOHO
) DATE : JUNEQQ 2017 BY FAX
an individual, SOVAN LIEN, an individual, ) TIME : 9:00 AM.
DONG VUONG, an individual, THANH ) DEPT. : LAW & MOTION
LAI, and DOES 1 through 10 ) TRIAL : NOVEMBER 13, 2017 '
)
\E\W
.
Defendants. )
\/\‘\
_ _
) cwsaeagv
KING PLAZA CENTER, LLC, a Delaware ) MOTC
Limited Liability Company, ) Motion
525028
)
Cross—Complainant, )
v. ) lllllIIlllllllllllllllllllllllllIll
)‘
DBP INVESTMENTS, a California General )
Partnership and ROES 1 through 10, )
)
Cross-Defendants. )
)
Law Offices of 1
Steven B. Piser NOTICE OF MOTION AND MOTION To COMPEL FURTHER ANSWER To SPECIAL INTERROGATORY #5 AND FOR SANCTIONS FROM KING PLAZA
CENTER, LLC
PLEASE TAKE NOTICE that on June 29a 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 5, from defendant King Plaza Center, LLC and for
sanctions
OOOVOM-hwwh‘
against King Plaza Center, LLC.
This motion will be based on the grounds that the information sought by the
interrogatory is properly the subject of discovery that good cause exists for compelling responses
to the interrogatory, that the answer is incomplete and evasive and the failure to provide a proper
answer is without substantial justification. 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 and such other and further evidence that
may be presented at the hearing.
LAW OFFICES OF STEVEN B. PISER
A Professional Corporation
DATED: May 33, 2017 By: k/
wwwwwwwwwl—‘Hl—‘Hl—‘I—li—‘l—‘Hl—l
STEVEN B. PISER
Attorney for
mfimm-DCONHOLOOONOUI-P'OJIOHO
DBP INVESTMENTS, a California
General Partnership
Law Offices of 2
Steven B. Piser NOTICE OF MOTION AND MOTION To COMPEL FURTHER ANSWER To SPECIAL INTERROGATORY #5 AND FOR SANCTIONS FROM KING PLAZA
CENTER, LLC
Document Filed Date
May 26, 2017
Case Filing Date
June 01, 2016
Category
(26) Unlimited Other Real Property
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STEVEN B. PISER, SBN 62414 LAW OFFICES OF STEVEN B. PISER A Professional Corporation 1300 Clay Street, Oakland, Suite California 94612 1050 FILED Telephone: (510) 835-5582 SAN MATEO COUNTY Facsimile: (510) 832-1717 2017 MAY 2 6 JOHN L. FITZGERALD, \OOOQONO'l—POJLQH SBN 126613 3 rim court LAW OFFICES OF JOHN L. FITZGERALD 101 California Street, Suite 23 00 San Francisco, California 94111 Telephone: (415) 689—1209 Attorneys for DBP INVESTMENTS, a California General Partnership IN THE SUPERIOR COURT OF THE STATE OF CALIFORNLA IN AND FOR THE COUNTY OF SAN MATEO DBP INVESTMENTS, a California General ) CASE NO. CIV538897 Partnership, ) ) Plaintiff NNMMMNNMNI—IHI—II—II—II—II—II—IHI—I ) NOTICE OF MOTION AND MOTION To ) COMPEL FURTHER ANSWER To SPECIAL v. ) INTERROGATORY #5 AND FOR SANCTIONs ) * FROM KING PLAZA CENTER, LLC KING PLAZA CENTER, LLC, a Delaware ) Limited Liability Company, BUA-QUACH, mflOIUT-PCOLQl—‘Okomqmm-POJLOHO ) DATE : JUNEQQ 2017 BY FAX an individual, SOVAN LIEN, an individual, ) TIME : 9:00 AM. DONG VUONG, an individual, THANH ) DEPT. : LAW & MOTION LAI, and DOES 1 through 10 ) TRIAL : NOVEMBER 13, 2017 ' ) \E\W . Defendants. ) \/\‘\ _ _ ) cwsaeagv KING PLAZA CENTER, LLC, a Delaware ) MOTC Limited Liability Company, ) Motion 525028 ) Cross—Complainant, ) v. ) lllllIIlllllllllllllllllllllllllIll )‘ DBP INVESTMENTS, a California General ) Partnership and ROES 1 through 10, ) ) Cross-Defendants. ) ) Law Offices of 1 Steven B. Piser NOTICE OF MOTION AND MOTION To COMPEL FURTHER ANSWER To SPECIAL INTERROGATORY #5 AND FOR SANCTIONS FROM KING PLAZA CENTER, LLC PLEASE TAKE NOTICE that on June 29a 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 5, from defendant King Plaza Center, LLC and for sanctions OOOVOM-hwwh‘ against King Plaza Center, LLC. This motion will be based on the grounds that the information sought by the interrogatory is properly the subject of discovery that good cause exists for compelling responses to the interrogatory, that the answer is incomplete and evasive and the failure to provide a proper answer is without substantial justification. 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 and such other and further evidence that may be presented at the hearing. LAW OFFICES OF STEVEN B. PISER A Professional Corporation DATED: May 33, 2017 By: k/ wwwwwwwwwl—‘Hl—‘Hl—‘I—li—‘l—‘Hl—l STEVEN B. PISER Attorney for mfimm-DCONHOLOOONOUI-P'OJIOHO DBP INVESTMENTS, a California General Partnership Law Offices of 2 Steven B. Piser NOTICE OF MOTION AND MOTION To COMPEL FURTHER ANSWER To SPECIAL INTERROGATORY #5 AND FOR SANCTIONS FROM KING PLAZA CENTER, LLC