On June 05, 2019 a
Party Discovery
was filed
involving a dispute between
Auffret, Olivier,
Leclair, Virginie,
Lendormy, Jeanyves,
Lendormy, Jean-Yves,
Luscutoff, Lendormy & Associates,
and
Auffret, Olivier,
Leclair, Virginie,
Lendormy, Jean-Yves,
Luscutoff, Lendormy & Associates,
for COMMON COUNTS/OPEN BOOK ACCOUNT/COLLECTIONS
in the District Court of San Francisco County.
Preview
1 Jean-Yves Lendormy (101695)
LUSCUTOFF, LENDORMY & ASSOCIATES
2 5 Third Street, Suite 1216
ELECTRONICALLY
San Francisco, California 94103-3213
3 Tel: (415) 989-7500 F I L E D
Superior Court of California,
4 Email: jeanyves.lendormy@lla-law.com County of San Francisco
02/01/2021
5 Attorneys for plaintiffs Clerk of the Court
BY: EDNALEEN ALEGRE
Deputy Clerk
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8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF SAN FRANCISCO
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11 Luscutoff, Lendormy & Associates, Case No. CGC-19-576483
Jean-Yves Lendormy
12 DISCOVERY
Plaintiffs,
13 REPLY MEMORANDUM OF POINTS AND
vs. AUTHORITIES IN SUPPORT OF PLAINTIFFS’
14 MOTION TO COMPEL PROPER RESPONSES
Olivier Auffret, Virginie Leclair AND DOCUMENTS TO REQUEST FOR
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PRODUCTION OF DOCUMENTS, SET THREE
16 Defendants. AND FOR SANCTIONS
17 Date: February 8, 2021
Time: 9:00 A.M.
18 Dept: 302
19 Date Filed: June 6, 2019
Trial Date: June 7, 2021
20 And Related Cross-Action.
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22 The defendants’ brazen response is shocking. The meaning of word “evidencing” is very well
23 understood and, in addition, is one that they use in each and every one of their discovery requests. There is
24 no ambiguity.
25 The defendants defying the Court’s January 12, 2021 order that they “are required to amend their
26 responses to state that all responsive, non-privileged documents have [been] produced and identified by
27 defendants pursuant to the Court order of September 17, 2020, and/or to produce any responsive, non-
28 privileged documents not previously produced”.
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REPLY MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO COMPEL
DISCOVERY AND REQUESTS FOR SANCTIONS CASE NO. CGC-19-576483
1 The defendants have also utterly failed to respond to plaintiffs’ Supplemental Interrogatories, Set
2 One served on December 23, 2020.
3 The court must order full and complete answers and the production of documents as requested and
4 also impose serious financial sanctions.
5 DATED: February 1, 2021 LUSCUTOFF, LENDORMY & ASSOCIATES
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7 By:
JEAN-YVES LENDORMY
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Attorneys for Plaintiffs
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REPLY MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO COMPEL
DISCOVERY AND REQUESTS FOR SANCTIONS CASE NO. CGC-19-576483
Document Filed Date
February 01, 2021
Case Filing Date
June 05, 2019
Category
COMMON COUNTS/OPEN BOOK ACCOUNT/COLLECTIONS
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