arrow left
arrow right
  • Newton, Patsy et al  vs. Enloe Medical Center(35) Unlimited Other non-PI/PD/WD Tort document preview
  • Newton, Patsy et al  vs. Enloe Medical Center(35) Unlimited Other non-PI/PD/WD Tort document preview
  • Newton, Patsy et al  vs. Enloe Medical Center(35) Unlimited Other non-PI/PD/WD Tort document preview
  • Newton, Patsy et al  vs. Enloe Medical Center(35) Unlimited Other non-PI/PD/WD Tort document preview
  • Newton, Patsy et al  vs. Enloe Medical Center(35) Unlimited Other non-PI/PD/WD Tort document preview
  • Newton, Patsy et al  vs. Enloe Medical Center(35) Unlimited Other non-PI/PD/WD Tort document preview
						
                                

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