Preview
1 ROBERT H. ZIMMERMAN, BAR NO. 84345
SCHUERING ZIMMERMAN & DOYLE, LLP 11/17/2020
2 400 University Avenue
Sacramento, California 95825-6502
3 (916) 567-0400
FAX: 568-0400
4
5 Attorneys for Defendant ENLOE MEDICAL CENTER
6
7
8 SUPERIOR COURT OF CALIFORNIA, COUNTY OF BUTTE
9
10 PATSY NEWTON, individually; HAROLD ) NO. 20CV01091
NEWTON, individually; SUZANNE )
11 BOLDEN, individually, ) Assigned to the Honorable Judge
) Tamara L. Mosbarger for All
12 Plaintiffs, ) Purposes
)
13 vs. ) NOTICE OF MOTION AND MOTION TO
) COMPEL PLAINTIFF’S RESPONSES TO
14 ENLOE MEDICAL CENTER; and DOES 1 - ) REQUEST FOR ADMISSIONS, SET ONE
50, et al., )
15 ) Date: November 25, 2020
Defendants. ) Time: 9:00 a.m.
16 ______________________________________ ) Dept: 1
17 Action Filed: May 29, 2020
Trial Date: December 14, 2020
18
19 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
20 PLEASE TAKE NOTICE THAT on November 25, 2020 at 9:00 a.m., in Department1
21 of this Court located at 1775 Concord Avenue, Chico California, Defendant ENLOE
22 MEDICAL CENTER will move this Court for an Order granting its Motion to Compel
23 Plaintiff's Further Responses to Request for Admissions, Set One. This motion will be
24 made on the grounds that plaintiff has failed to provide responses to defendant’s Request
25 for Admissions, Set One. Defendant sent meet and confer correspondence to plaintiff
26 requesting responses, however, plaintiff has yet to provide the requested responses.
27 This motion will be based on this Notice of Motion and Motion, the attached
28 Memorandum of Points and Authorities, the supporting declarations, and any oral and
01298677.WPD 1
NOTICE OF MOTION AND MOTION TO COMPEL RESPONSE TO REQUEST FOR ADMISSIONS
1 documentary evidence that may be presented at the time the motion is heard.
2 NOTICE IS FURTHER GIVEN of this Court’s tentative ruling procedures:
3 2.9 TENTATIVE RULINGS: The Court follows the tentative
ruling procedure set forth in CRC § 3.1308(a)(1): tentative
4 rulings on law and motion matters will be available on the
Court’s website at www.buttecourt.ca.gov and by telephone
5 at (530) 532-7022 by 3:00 p.m. on the court day preceding the
hearing. (Effective 7-1-89, as amended 7-1-03, as amended
6 7-1-04, as amended 7-1-05, as amended 1-1-07)
7 Dated: November 17, 2020
8 SCHUERING ZIMMERMAN & DOYLE, LLP
9
10 By
ALAINA T. DICKENS
11 Attorneys for Defendant ENLOE
MEDICAL CENTER
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
01298677.WPD 2
NOTICE OF MOTION AND MOTION TO COMPEL RESPONSE TO REQUEST FOR ADMISSIONS
1 Proof of Service by Electronic Transmission - Civil
2 [Code of Civ. Proc. §§ 1010.6, 1011, 1013, 1013a, 2015.5; Cal. Rules of Court, rules
3 10.503, 2.100-2.119, 2.251; EMERGENCY RULE 12]
4 I, Lucia Ruiz, declare:
5 At the time of service, I was over 18 years of age and not a party to this action. My
6 business address is: 400 University Avenue, Sacramento, California 95825.
7 On November 17, 2020, I served the following documents:
8 NOTICE OF MOTION AND MOTION TO COMPEL PLAINTIFF’S RESPONSES
TO REQUEST FOR ADMISSIONS, SET ONE; MEMORANDUM OF POINTS AND
9 AUTHORITIES; SEPARATE STATEMENT; DECLARATION OF ALAINA T.
DICKENS IN SUPPORT THEREOF
10
11 by electronic service pursuant to Emergency Rule 12 of the California Rules of Court. I
12 served the documents by email to the addresses listed below. I did not receive, within
13 a reasonable time after the transmission, any electronic message or other indication that
14 the transmission was unsuccessful.
15 Attorney Representing Phone/Fax/E-Mail
16 Sean R. Laird Plaintiffs PHONE: 916-441-1636
The Law Firm of Sean R. FAX: 916-760-9002
17 Laird EMAIL:
805 16th Street seanlairdlaw@gmail.com
18 Sacramento, CA 95814
19
20 I declare under penalty of perjury, under the laws of the State of California, that the
21 foregoing is true and correct, and that this declaration was executed on November 17,
22 2020, at Sacramento, California.
23
24
Lucia Ruiz
1579-12195
25
26
27
28