On November 22, 2016 a
Motion,Ex Parte
was filed
involving a dispute between
Lee, Hyeong Geon,
and
Does 1-50,
Henshaw, David S.,
Henshaw & Henry Pc,
for (25) Unlimited Professional Negligence
in the District Court of San Mateo County.
Preview
F 11 1L E 113.3
SAN MMED seesaw
David s. Henshaw SBN 271226 JUL 1 8 2017
1871 The Alameda
Suite 333
San Jose, CA 95126
(408) 533-1075
(408) 583-4016 Fax
Attorney for Defendants
koooqoxuihwm.‘
DAVID S. HENSHAW and
HENSHAW & HENRY, PC
SUPERIOR COURT OF CALIFORNIA
16—cw—02520
COUNTY OF SAN MATEO
mm
‘.
MOTC
Motion
[WED 1
607 65
\ll||llllllIlllllllllllllllllllllIll
HYEONG GEON LEE, ) Case No. 16CIV02520
)
Plaintiff, ) MOTION FOR TERMINATING
) SANCTIONS
V. )
NNNNNNNNNHH—ar—IHv—ai—Ai—Ap—Iy—a
) Date: August 14, 2017
DAVID S. HENSHAW, HENSHAW & HENRY) Time: 9:00 am. 31V FAX
P.C., ) Place: 400 County Center,
) Dept. 16, Ctrm 7A
Defendants. ) Redwood City, CA 94063
ooqoxUI-bwwv—aoxoooqoxm-AWNHO
)
Defendants DAVID S. HENSHAW and HENSHAW & HENRY, PC (“Defendants”)
hereby file this Motion for Terminating Sanctions pursuant to Code of Civil Procedure, section
2030.03 0(d)(3). Defendants seek such sanctions against Plaintiff HYEONG GEON LEE
(“Plaintiff”) as Plaintiff has continually failed to provide repsonses to discovery requests, even
after being ordered by the Court after motions to compel, that comply with the Code of Civil
NIOTION FOR TERMINATING SANCTIONS
l
Procedure. Plaintiff has notprovided documents responsive to the requests. Further, Plaintiff
continues to be evasive with his responses. Defendants seek dismissal of Plaintiff’s Complaint
based on Plaintis continued bad faith discovery responses.
This Motion isbased on the Memorandum of Points and Authorities in Support of the
Motion, the Declaration of David
\OOOQONUI-RUJNH
S. Henshaw in Support of the Motion, and on such evidence as
may be presented at the hearing of the Motion.
Dated: July 18, 2017
David S. Henshaw, Attorney for
Defendants DAVID S. HENSHAW
and HENSHAW & HENRY, PC
NNNNNNNNNi—Jh—ifi—IHHh—lh—ih—IHH
WflOm-bWNHOKOOOQONUl-DWNP-‘O
MOTION FOR TERMINATING SANCTIONS
2
Document Filed Date
July 18, 2017
Case Filing Date
November 22, 2016
Category
(25) Unlimited Professional Negligence
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
F 11 1L E 113.3 SAN MMED seesaw David s. Henshaw SBN 271226 JUL 1 8 2017 1871 The Alameda Suite 333 San Jose, CA 95126 (408) 533-1075 (408) 583-4016 Fax Attorney for Defendants koooqoxuihwm.‘ DAVID S. HENSHAW and HENSHAW & HENRY, PC SUPERIOR COURT OF CALIFORNIA 16—cw—02520 COUNTY OF SAN MATEO mm ‘. MOTC Motion [WED 1 607 65 \ll||llllllIlllllllllllllllllllllIll HYEONG GEON LEE, ) Case No. 16CIV02520 ) Plaintiff, ) MOTION FOR TERMINATING ) SANCTIONS V. ) NNNNNNNNNHH—ar—IHv—ai—Ai—Ap—Iy—a ) Date: August 14, 2017 DAVID S. HENSHAW, HENSHAW & HENRY) Time: 9:00 am. 31V FAX P.C., ) Place: 400 County Center, ) Dept. 16, Ctrm 7A Defendants. ) Redwood City, CA 94063 ooqoxUI-bwwv—aoxoooqoxm-AWNHO ) Defendants DAVID S. HENSHAW and HENSHAW & HENRY, PC (“Defendants”) hereby file this Motion for Terminating Sanctions pursuant to Code of Civil Procedure, section 2030.03 0(d)(3). Defendants seek such sanctions against Plaintiff HYEONG GEON LEE (“Plaintiff”) as Plaintiff has continually failed to provide repsonses to discovery requests, even after being ordered by the Court after motions to compel, that comply with the Code of Civil NIOTION FOR TERMINATING SANCTIONS l Procedure. Plaintiff has notprovided documents responsive to the requests. Further, Plaintiff continues to be evasive with his responses. Defendants seek dismissal of Plaintiff’s Complaint based on Plaintis continued bad faith discovery responses. This Motion isbased on the Memorandum of Points and Authorities in Support of the Motion, the Declaration of David \OOOQONUI-RUJNH S. Henshaw in Support of the Motion, and on such evidence as may be presented at the hearing of the Motion. Dated: July 18, 2017 David S. Henshaw, Attorney for Defendants DAVID S. HENSHAW and HENSHAW & HENRY, PC NNNNNNNNNi—Jh—ifi—IHHh—lh—ih—IHH WflOm-bWNHOKOOOQONUl-DWNP-‘O MOTION FOR TERMINATING SANCTIONS 2