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1 Krsto Mijanovic (Bar No. 205060)
kmijanovic@hbblaw. com
2 Steven A. Scordalakis (Bar No. 293212) 12/09/2020
sscordalakis@hbblaw. com
3 HAIGHT BROWN & BONESTEEL LLP
500 Capitol Mall, Suite 2150
4 Sacramento, California 95814
Telephone: 916.702.3200
5 Facsimile: 916.570.1947
6 Attorneys for Defendant/Cross-Defendant/Cross-
Complainant CASSANDRA SOARS
7
8 SUPERIOR COURT OF TH:E STATE OF CALIFORNIA
9 COUNTY OF BUTTE
10 KOBY BUSTILLOS, Case No. 20CV00874
11 Plaintiff, DEFENDANT/CROSS-
DEFENDANT/CROSS-COMPLAINANT
12 v. CASSANDRA SOARS' NOTICE NON-
OPPOSITION TO MOTION DEEMING
13 CASSANDRA SOARS, JACOB MATTERS ADMITTED IN REQUESTS
DEADMORE; and DOES 1 through 10, FOR ADMISSION TO PLAINTIFF KOBY
~ 14 inclusive, BUSTILLOS, SET ONE; AND REQUEST
FOR MONETARY SANCTIONS
15 Defendants.
[Filed Concurrently Declaration of Steven
16 Scordalakis]
17 Date: December 16, 2020
Time: 9:00 a.m.
18 Department: 1
19
Action Filed: April 14, 2020
20 Trial Date: July 26, 2021
AND RELATED CROSS-ACTIONS
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PS27-0000035
13597329.1 NOTICE NON-OPPOSITION TO MOTION DEEMING MATTERS ADMITTED
1 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD,
2 PLEASE TAKE NOTICE that no opposition has been received by defendant/cross-
3 defendant/cross-complainant CASANDRA SOARS ("Defendant") to her motion for an order
4 deeming all matters admitted specified in Defendant's Requests for Admissions, Set One,
5 propounded to plaintiff KOBY BUSTILLOS ("Plaintiff'); and for monetary sanctions.
6 On November 17, 2020, Defendant filed and served by electronic service her subject
7 Motion. Based on the December 16, 2020 hearing date, and pursuant to Code of Civil Procedure
8 section 1005(b), Plaintiff's opposition was due December 3, 2020. As of the date of this Notice,
9 however, no such opposition has been filed (according to this Court's online docket); and
10 Defendant has not received any opposition. (Declaration of Steven A. Scordalakis ("Scordalakis
11 Non-Opp. Decl.") ¶2.).
12 Therefore, based on the legal arguments contained in her moving papers, Defendant
13 respectfully requests that this Court grant her motion and issue an order that those matters set forth
~ 14 and specified in Defendant's Requests for Admission, Set One, be deemed admitted; and Order
~ 15 that Plaintiff pay monetary sanctions to Defendant within ten (10) days of the hearing on this
16 Motion.
17 ~ Dated: December 9, 2020 HAIGHT BROWN & BONESTEEL LLP
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20 Krsto Mijanovic
Steven A. Scordalakis
21 Attorneys for Defendant/Cross-Defendant/Cross-
Complainant CASSANDRA SOARS
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PS27-0000035 1
13597329.1 NOTICE NON-OPPOSITION TO MOTION DEEMING MATTERS ADMITTED
1 DECLARATION OF STEVEN A. SCORDALAKIS
2 I, Steven A Scordalakis, declare as follows:
3 1. I am an attorney at the law firm of Haight Brown & Bonesteel LLP, counsel of
!~ record for defendant/cross-defendant/cross-complainant CASSANDRA SOARS ("Defendant") in
5 the above-captioned matter. I am a member in good standing of the State Bar of California. I
6 have personal knowledge of the facts set forth in this Declaration and, if called as a witness, could
7 and would testify competently to such facts under oath.
8 2. On November 17, 2020, my firm filed and served by electronic service Defendant's
9 Motion for an order deeming all matters admitted specified in Defendant's Requests for
10 Admissions, Set One, propounded to plaintiff KOBY BUSTILLOS ("Plaintiff'); and for monetary
11 sanctions. As of the date of this Notice ofNon-Opposition, my office has not received any
12 opposition to Defendant's Motion; and my review of the court's online docket indicates that no
13 opposition has been filed
~ 14 6. My firm bills $225 per hour for service. I previously billed approximately .9 hours
~ 15 for preparing Defendant's motion and supporting papers. I billed approximately .3 hours related
16 to drafting this Notice ofNon-Opposition. Thus, Defendant has incurred a total of $330 in
17 attorney's fees and costs ($60.00 filing fee) in connection with this motion.
18 I declare under penalty of perjury under the laws of the State of California that the
19 foregoing is true and correct. Executed on December 9, 2020, at Sacramento, California.
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..~"
22 Steven A. Scordalakis
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PS27-0000035 2
13597329.1 NOTICE NON-OPPOSITION TO MOTION DEEMING MATTERS ADMITTED
PROOF OF SERVICE
2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
Koby Bustillos v. Cassandra Soars, et al.
Case No. 20CV00874
D At the time of service, I was over 18 years of age and not a party to this action. I
am employed in the County of Los Angeles, State of California. My business address is
555 South Flower Street, Forty-Fifth Floor, Los Angeles, CA 90071.
6 On December 9, 2020, I served true copies of the following documents) described
as DEFENDANT/CROSS-DEFENDANT/CROSS-COMPLAINANT CASSANDRA
7 SOARS' on the interested parties in this action as follows:
8 Max G. Arnold Shani M. Roark
Barrick Arnold Carbone, Smith & Koyama
9 Brian Michael Pratt, 1610 Arden Way, Suite 190
The Law Offices of Max G. Arnold, Inc. Sacramento, CA 95815
10 1410 Neotomas Avenue, Suite 100
Santa Rosa, CA 95405 Tel: 916.480.1068
11 Fax: 916.481.0990
Tel: 707.535.1920 Email: Shani.Roark@csaa.com
12 Fax: 707.535.1930 E-Serve Secretary:
Email: Brian@maxgarnold.com Terry.Bersig@csaa.com
13 E-serve documents to:
litdocs@maxgarnold.com Attorneys for Defendant and Cross-
14 Complainant, Jacob Deadmore
15
Koby Bustillos In Pro Per
16 1142 Del Sol Place, Apt B
Redding, CA 96002 [VIA FEDERAL EXPRESS]
17
18 BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the
documents) to be sent from e-mail address ssmith@hbblaw.com to the persons at the e-
19 mail addresses listed in the Service List. I did not receive, within a reasonable time after
the transmission, any electronic message or other indication that the transmission was
20 unsuccessful.
21 BY FEDEX: I enclosed said documents) in an envelope or package provided by
FedEx and addressed to the persons at the addresses listed in the Service List. I placed the
22 envelope or package for collection and overnight delivery at an office or a regularly
utilized drop box of FedEx or delivered such documents) to a courier or driver authorized
23 by FedEx to receive documents.
24 I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
25
Executed on December 9, 2020, at Los Ange,~es, California.
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28 Smith
PS27-0000035 3
13597329.1 NOTICE NON-OPPOSITION TO MOT10N DEEMING MATTERS ADMITTED
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1 Krsto Mijanovic (Bar No. 205060) kmijanovic@hbblaw. com 2 Steven A. Scordalakis (Bar No. 293212) 12/09/2020 sscordalakis@hbblaw. com 3 HAIGHT BROWN & BONESTEEL LLP 500 Capitol Mall, Suite 2150 4 Sacramento, California 95814 Telephone: 916.702.3200 5 Facsimile: 916.570.1947 6 Attorneys for Defendant/Cross-Defendant/Cross- Complainant CASSANDRA SOARS 7 8 SUPERIOR COURT OF TH:E STATE OF CALIFORNIA 9 COUNTY OF BUTTE 10 KOBY BUSTILLOS, Case No. 20CV00874 11 Plaintiff, DEFENDANT/CROSS- DEFENDANT/CROSS-COMPLAINANT 12 v. CASSANDRA SOARS' NOTICE NON- OPPOSITION TO MOTION DEEMING 13 CASSANDRA SOARS, JACOB MATTERS ADMITTED IN REQUESTS DEADMORE; and DOES 1 through 10, FOR ADMISSION TO PLAINTIFF KOBY ~ 14 inclusive, BUSTILLOS, SET ONE; AND REQUEST FOR MONETARY SANCTIONS 15 Defendants. [Filed Concurrently Declaration of Steven 16 Scordalakis] 17 Date: December 16, 2020 Time: 9:00 a.m. 18 Department: 1 19 Action Filed: April 14, 2020 20 Trial Date: July 26, 2021 AND RELATED CROSS-ACTIONS 21 22 23 24 25 26 27 28 PS27-0000035 13597329.1 NOTICE NON-OPPOSITION TO MOTION DEEMING MATTERS ADMITTED 1 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD, 2 PLEASE TAKE NOTICE that no opposition has been received by defendant/cross- 3 defendant/cross-complainant CASANDRA SOARS ("Defendant") to her motion for an order 4 deeming all matters admitted specified in Defendant's Requests for Admissions, Set One, 5 propounded to plaintiff KOBY BUSTILLOS ("Plaintiff'); and for monetary sanctions. 6 On November 17, 2020, Defendant filed and served by electronic service her subject 7 Motion. Based on the December 16, 2020 hearing date, and pursuant to Code of Civil Procedure 8 section 1005(b), Plaintiff's opposition was due December 3, 2020. As of the date of this Notice, 9 however, no such opposition has been filed (according to this Court's online docket); and 10 Defendant has not received any opposition. (Declaration of Steven A. Scordalakis ("Scordalakis 11 Non-Opp. Decl.") ¶2.). 12 Therefore, based on the legal arguments contained in her moving papers, Defendant 13 respectfully requests that this Court grant her motion and issue an order that those matters set forth ~ 14 and specified in Defendant's Requests for Admission, Set One, be deemed admitted; and Order ~ 15 that Plaintiff pay monetary sanctions to Defendant within ten (10) days of the hearing on this 16 Motion. 17 ~ Dated: December 9, 2020 HAIGHT BROWN & BONESTEEL LLP 18 19 20 Krsto Mijanovic Steven A. Scordalakis 21 Attorneys for Defendant/Cross-Defendant/Cross- Complainant CASSANDRA SOARS 22 23 24 25 26 27 28 PS27-0000035 1 13597329.1 NOTICE NON-OPPOSITION TO MOTION DEEMING MATTERS ADMITTED 1 DECLARATION OF STEVEN A. SCORDALAKIS 2 I, Steven A Scordalakis, declare as follows: 3 1. I am an attorney at the law firm of Haight Brown & Bonesteel LLP, counsel of !~ record for defendant/cross-defendant/cross-complainant CASSANDRA SOARS ("Defendant") in 5 the above-captioned matter. I am a member in good standing of the State Bar of California. I 6 have personal knowledge of the facts set forth in this Declaration and, if called as a witness, could 7 and would testify competently to such facts under oath. 8 2. On November 17, 2020, my firm filed and served by electronic service Defendant's 9 Motion for an order deeming all matters admitted specified in Defendant's Requests for 10 Admissions, Set One, propounded to plaintiff KOBY BUSTILLOS ("Plaintiff'); and for monetary 11 sanctions. As of the date of this Notice ofNon-Opposition, my office has not received any 12 opposition to Defendant's Motion; and my review of the court's online docket indicates that no 13 opposition has been filed ~ 14 6. My firm bills $225 per hour for service. I previously billed approximately .9 hours ~ 15 for preparing Defendant's motion and supporting papers. I billed approximately .3 hours related 16 to drafting this Notice ofNon-Opposition. Thus, Defendant has incurred a total of $330 in 17 attorney's fees and costs ($60.00 filing fee) in connection with this motion. 18 I declare under penalty of perjury under the laws of the State of California that the 19 foregoing is true and correct. Executed on December 9, 2020, at Sacramento, California. 20 21 ..~" 22 Steven A. Scordalakis 23 24 25 26 27 28. PS27-0000035 2 13597329.1 NOTICE NON-OPPOSITION TO MOTION DEEMING MATTERS ADMITTED PROOF OF SERVICE 2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES Koby Bustillos v. Cassandra Soars, et al. Case No. 20CV00874 D At the time of service, I was over 18 years of age and not a party to this action. I am employed in the County of Los Angeles, State of California. My business address is 555 South Flower Street, Forty-Fifth Floor, Los Angeles, CA 90071. 6 On December 9, 2020, I served true copies of the following documents) described as DEFENDANT/CROSS-DEFENDANT/CROSS-COMPLAINANT CASSANDRA 7 SOARS' on the interested parties in this action as follows: 8 Max G. Arnold Shani M. Roark Barrick Arnold Carbone, Smith & Koyama 9 Brian Michael Pratt, 1610 Arden Way, Suite 190 The Law Offices of Max G. Arnold, Inc. Sacramento, CA 95815 10 1410 Neotomas Avenue, Suite 100 Santa Rosa, CA 95405 Tel: 916.480.1068 11 Fax: 916.481.0990 Tel: 707.535.1920 Email: Shani.Roark@csaa.com 12 Fax: 707.535.1930 E-Serve Secretary: Email: Brian@maxgarnold.com Terry.Bersig@csaa.com 13 E-serve documents to: litdocs@maxgarnold.com Attorneys for Defendant and Cross- 14 Complainant, Jacob Deadmore 15 Koby Bustillos In Pro Per 16 1142 Del Sol Place, Apt B Redding, CA 96002 [VIA FEDERAL EXPRESS] 17 18 BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the documents) to be sent from e-mail address ssmith@hbblaw.com to the persons at the e- 19 mail addresses listed in the Service List. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was 20 unsuccessful. 21 BY FEDEX: I enclosed said documents) in an envelope or package provided by FedEx and addressed to the persons at the addresses listed in the Service List. I placed the 22 envelope or package for collection and overnight delivery at an office or a regularly utilized drop box of FedEx or delivered such documents) to a courier or driver authorized 23 by FedEx to receive documents. 24 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 25 Executed on December 9, 2020, at Los Ange,~es, California. 26 27 28 Smith PS27-0000035 3 13597329.1 NOTICE NON-OPPOSITION TO MOT10N DEEMING MATTERS ADMITTED