On June 18, 2018 a
Motion,Ex Parte
was filed
involving a dispute between
Sha, Solomon,
Sweet Production, Inc., A California Corporation,
and
Does 1 To 10, Inclusive,
Sha, Solomon,
for (07) Unlimited Business Tort/Unfair Business Practice
in the District Court of San Mateo County.
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DAVID J. MICLEAN (SBN 115098)
dmiclean@micleangleason.com
DANIELLE M. MIHALKANIN (SBN 271442)
dmihalkanin@micleangleason.com
MICLEAN GLEASON LLP
411 Bore] Avenue, Suite 3 1 0
San Mateo, CA 94402
Telephone: (650) 684-1 181
Facsimile: (650) 684-1 182
Attorneys for Defendant and Cross-Complainant
Solomon Sha
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN MATEO
SWEET PRODUCTION, INC., a California Case No. 18—CIV—O3 1 10
Corporation,
Plaintiff, DEFENDANT SOLOMON SHA’S AMENDED
NOTICE OF MOTION FOR LEAVE OF
v.
COURT TO FILE AND HAVE HEARD
SI-IA’S MOTION FOR TERMINATING
SANCTIONS OR ALTERNATIVELY TO
SOLOMON SHA, an individual; andtDOES 1to REOPEN AND COMPEL DISCOVERY
10, inclusive, (C.C.P. §§ 2023.010, 2023.030, 2024.050)
Defendants.
Date: August 28, 20 1 9
Time: 9:00 a.m.
Department: Law & Motion
SOLOMON SHA,
Cross-Complainant,
f
18—cIV—0311u
AMOTNF
l
AmendedNotice of Motion and Motion to
V.
SWEET PRODUCTION, INC, a California ”zil’iiumnmmmmN
corporation; SWEET EXPRESS; MWG CHIN; \___
DOREEN CHIN; and ROES 1 through 10,
inclusive,
Cross—Defendants.
SHA MOUON FOR LEAVE (CCP 2023 .010, 2023 .030, 2024.050) CASE NO. 18-CIV-O3 1 10
TO ALL PARTIES AND THEIR COUNSEL OF RECORD:
Please take notice that on August 28. 2019, in the Law & Motion Department of the above-
entitled court, located at 400 County Center, Redwood City, California 94063, Defendant and Cross-
Complainant SOLOMON SHA (“Sha”) will, and hereby does, move this Court for leave t0 have the
Court hear Sha’s motion for terminating sanctions against Plaintiff Sweet Production, Inc. (“SP1”) for
discovery misuse pursuant to California Code 0f Civil Procedure section 2023.030, or alternatively to
reopen and compel discovery from SP1 to allow Sha to prepare for trial pursfiant to California Code of
WOOQG
Civil Procedure section 2024.050.
This motion isbased upon this notice of motion, and the motion, memorandum of points and
10 authorities, and the declarations 0f David J. Miclean and Solomon Sha filed and served on July 5, 2019;
Y
11 the pleadings and records on file herein; and other such evidence and argument as may be presented at
12 or before the hearing on this Motion.
13
14 Dated: July 8, 2019 ReSpectfully Submitted:
fix
15 MICLEAN GLEASON LLP
16
17
TDavid J.Miclean
18
Danielle M. Mihalkanin
Attorneys for Defendant and Cross-Complainant
19
SOLOMON SHA
20
21
22
23
24
25
26
27
28
1
SHA MOTION FOR LEAVE (CCP 2023.010, 2023.030, 2024.050) CASE No. 18-CIV-03 1 10
Document Filed Date
July 08, 2019
Case Filing Date
June 18, 2018
Category
(07) Unlimited Business Tort/Unfair Business Practice
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