On October 03, 2018 a
Motion,Ex Parte
was filed
involving a dispute between
Ramos, Andrea L.,
and
Does 1 To 50, Inclusive,
Wigton, Tessa Evangeline,
for (22) Unlimited Auto
in the District Court of San Mateo County.
Preview
1/7/2020
41585-50-25
PATRICIA M. GREEN ROE (SBN 116405)
SAMUELSON, WILSON dt ROE
210 North Foui'treet, Suite 201
San Jose, CA 95112
Telephone: (408) 790-5320
Facsimile: (408) 295-5799
Attorneys for TESSA EVANGELINF, WIGTON
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN MATEO
ANDREA L. RAMOS, CASE NO. 18CIV05369
10
Plaintiff, NOTICE OF MOTION AND MOTION TO
11 COMPEL PLAINTIFF RESPONSES 'I'0
V. DEFENDANT DISCOVERY REQUESTS;
12 REQUFST FOR MONETARY
TESSA EVANGELINE WIGTON, and Does SANCTIONS
13 I to 50, Inclusive,
Date: March 5, 2020
14 Defendants. Tillie: 9:00 a.m.
Dept; Law and Motion Department
15
Action Filed: October 3, 2017
16 Judge: John "Jack" L. Grandsaert
Dept: ll
17
18 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD HFRFIN:
19 PLEASE TAKF. NOTICE that on MARCH 5, 2020 and 9:00 a.m., or as soon as counsel
20 may be heard in Department 11 of the above-entitled court location at 400 County Ccntcr Road,
21 Redwood City, California 94063, Defendant TESSA EVANGELINE WIGTON will move this
22 Court for an order compelling plaintiff ANDREA I,.RAMOS to provide verified, objection-free
23 responses to Defendant's Second Special Interrogatories, First Supplemental Interrogatories and
24 First Supplemental Request for Production of Documents and produce all the requested
25 documents pursuant to CCP Il'2030.290 and 2031.300.
26 PLEASE TAKE FURTHER NOTICE that Defendant will request monetary sanctions
27 pursuant to CCP tj2023.010, 2023.030 (a), 2023.290(c) and 2031.300(c) in the amount of $ 510.00
28 against plaintiff for failure to comply with Defendant's overdue discovery and failure to respond
-I-
NOTICE OF MOTION AND MOTION TO COMPEL PLAINTIFF RESPONSFS TO DEPENDANT DISCOVERY REQUESTS; Rl-'IQUEST
FOR MOVtETARY SANCTIONS
I to defendant counsel's attempts to resolve this matter informally.
2 This Motion is made on thc grounds that Plaintiff has failed to provide code compliant
3 responses to defendant's properly served discovery requests despite defendant counsel's meet-
4 and-confer eflorts.
5 This Motion is further based on this Notice, the attached Memorandum of Points and
6 Authorities, thc Declaration of Patricia M. Green Roc, the complete pleadings, records and files in
7 this action and upon such oral or documentary evidence as may be presented at the hearing of this
Motion.
10 Dated: January 7, 2020 SAMVELON, WILSON & ROE
12
J'4 6
13 PATRICIA M. GREEN ROE
Attorney for Defendant,
14 TESSA EVANGEI,INE WIGTON
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NOTICE OF MOTION AND MOTION TO COMPL'L PLAINTIFF RESPONSES TO DEFENDANT DISCOVERY REQUESTS; REQI JEST
FOR MONETARY SANCTIONS
Document Filed Date
January 07, 2020
Case Filing Date
October 03, 2018
Category
(22) Unlimited Auto
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1/7/2020 41585-50-25 PATRICIA M. GREEN ROE (SBN 116405) SAMUELSON, WILSON dt ROE 210 North Foui'treet, Suite 201 San Jose, CA 95112 Telephone: (408) 790-5320 Facsimile: (408) 295-5799 Attorneys for TESSA EVANGELINF, WIGTON IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN MATEO ANDREA L. RAMOS, CASE NO. 18CIV05369 10 Plaintiff, NOTICE OF MOTION AND MOTION TO 11 COMPEL PLAINTIFF RESPONSES 'I'0 V. DEFENDANT DISCOVERY REQUESTS; 12 REQUFST FOR MONETARY TESSA EVANGELINE WIGTON, and Does SANCTIONS 13 I to 50, Inclusive, Date: March 5, 2020 14 Defendants. Tillie: 9:00 a.m. Dept; Law and Motion Department 15 Action Filed: October 3, 2017 16 Judge: John "Jack" L. Grandsaert Dept: ll 17 18 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD HFRFIN: 19 PLEASE TAKF. NOTICE that on MARCH 5, 2020 and 9:00 a.m., or as soon as counsel 20 may be heard in Department 11 of the above-entitled court location at 400 County Ccntcr Road, 21 Redwood City, California 94063, Defendant TESSA EVANGELINE WIGTON will move this 22 Court for an order compelling plaintiff ANDREA I,.RAMOS to provide verified, objection-free 23 responses to Defendant's Second Special Interrogatories, First Supplemental Interrogatories and 24 First Supplemental Request for Production of Documents and produce all the requested 25 documents pursuant to CCP Il'2030.290 and 2031.300. 26 PLEASE TAKE FURTHER NOTICE that Defendant will request monetary sanctions 27 pursuant to CCP tj2023.010, 2023.030 (a), 2023.290(c) and 2031.300(c) in the amount of $ 510.00 28 against plaintiff for failure to comply with Defendant's overdue discovery and failure to respond -I- NOTICE OF MOTION AND MOTION TO COMPEL PLAINTIFF RESPONSFS TO DEPENDANT DISCOVERY REQUESTS; Rl-'IQUEST FOR MOVtETARY SANCTIONS I to defendant counsel's attempts to resolve this matter informally. 2 This Motion is made on thc grounds that Plaintiff has failed to provide code compliant 3 responses to defendant's properly served discovery requests despite defendant counsel's meet- 4 and-confer eflorts. 5 This Motion is further based on this Notice, the attached Memorandum of Points and 6 Authorities, thc Declaration of Patricia M. Green Roc, the complete pleadings, records and files in 7 this action and upon such oral or documentary evidence as may be presented at the hearing of this Motion. 10 Dated: January 7, 2020 SAMVELON, WILSON & ROE 12 J'4 6 13 PATRICIA M. GREEN ROE Attorney for Defendant, 14 TESSA EVANGEI,INE WIGTON 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NOTICE OF MOTION AND MOTION TO COMPL'L PLAINTIFF RESPONSES TO DEFENDANT DISCOVERY REQUESTS; REQI JEST FOR MONETARY SANCTIONS