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ATTORNEY OR PARTY WITHOUT ATIORNEY (Name, storebar number. and address): FOR COURT USE ONLY
Jomes S.Rummonds SBN 59954
RUMMONDs LAW FIRM
3n CA
Bonita Drive, Aptos. 95003
TELEPHONE No: 331.655.2911 FAX No: 831.662.3407
ATTORNEY FOR {Name}: Rudolf Leone, Jr.. Humphrey: Leone Equestrian;
Jill Inc. E-FILED
SUPERIOR COURT OF CALIFORNIA - COUNTY OF FRESNO 2/8/2021 4:19 PM
Clvll Dlvlslon Superior Court of California
1 130 O Street County of Fresno
Fresno, California 9372] —2220 By: S. Nunez, Deputy
PLAINTIFF/PEI'WONERI RUDOLF LEONE, JR.. e! al‘
DEFENDANT/RESPONDENT: KAHN. SOARES & CONWAy_ LLP
CASE NUMBER:
OPPOSITION TO REQUEST FOR PRETRIAL DISCOVERY CONFERENCE
9C ECG04570
1
Plainfiffls)
request a
D Defendonfis) D Cross-comploinonfls)
Pretrial Discovery Conference filed
D Cross-defendonffs) D Other{s)
on 2/1/2021
Opposition to
by Defendani
This opposition relates to:
A dispute regarding o request for production of documents, sef 1 propounded on 4/29/2020
A dispute regarding form or special interrogatories, set l propounded on 4/29/2020 .
D A dispute regarding o deposition subpoena directed 0T for deposition scheduled for
D A dispute regarding o deposition notice, production of documents at a depOSIfion or deposi’rion questions
related To the deposifion of scheduled for
D A dispute regarding monetary, issue, evidence or Terminating sanctions reloTed to
D with Local fhe
Privilege is
Rule
basis for the
2.] .I7(B).
refusal ’roproduce documents and c:priviiege log isattached which complies
The pcrfies hove engaged in the following meaningful meet 0nd confer efforts prior f0 filing this opposition:
(Describe in detail oII meet and confer effort including any narrowing of the issues or resolutions reached via
these efforts.)
Defense counsel correctly states that on October 2. 2020. Plaintiff sought and wos granted firne ’ro obtain
documentafion reques’red, On January I9, 2021 ,defense counsel did send Plaintiff's counsel o Meet 0nd
Confer letter which Plaintiff did nof answer within the requested time. Plaintiff's counsel, during the time
imposed by the meet and confer, wos in the midst of depositions, final discovery, private mediofion, and 0
Mandatory Settlement Conference in o case scheduled fo go to trial on March 1, 202]. Plaintiff shou1d hove
responded, especially because defense counsel has been accommodafing in her extension of professional
cour‘fesies.
Plaintiff'scounsel assures the Court and Defendant fhof he is making persistent effofls To obtain the requesfed
discovery. ofiorney is working with his clients,
Plaintiff's the clients' office staff, ond Plaintiff's accountant to
obtain the documents. Plaintiff‘s counsel needs These documents as well to prove ifs case.
PCV‘“ R054 9 opposmon To REQUEST Fox PREIRIAL DISCOVERY CONFERENCE Fresno
Counmflgfiflg 5?}1'}
Mandatory
A brief summary of why the requested discovery should be denied, including The focts ond legal arguments in
support iscs follows:
(Excepfing o privilege log ifchecked above, no pleadings. exhibits, declorofions, or attachments shall be
aflochedJ
Plaintiff agrees That there is no real substantive dispute regarding Defendant's discovery requests. Plaintiff
understands the urgency of the need to present these documents 0nd appreciates Defendant's pofience f0
date.
understood
It is ’rhof The filing of ’rhe Request for c1 Pretrial Discovery Conference tolls the time for filing o
motion to compel discovery on the disputed issues for the number of days between the filing of the request
and issuance by the Court of c1 subsequent order pertaining to the discovery dispute.
PorTy received the REQUEST FOR PRETRIAL DISCOVERY CONFERENCE 0n: 2{4!202]
Dale
Pursuant To Locol Rule 2.] .1 7(A}(] ), this opposition is being filed within five (5) coufl days of service of The request
for a Pre1riol Discovery Conference, exfended five (5)days for service by mail, and hos been served on The
opposing party.
Opposing Party was served with o copy of the OPPOSITION TO REQUEST FOR PRETRIAL DISCOVERY CONFERENCE
on: 2/8/2021
O e
A
'
| declare under penalty of perjury under The laws of the State of C oing is e Emd\correcf.
February 8, 2021 James S. Rummonds ——~
i.
Name
Date Type or Print
f fifg’nomré‘ef‘Por‘ry ormaipiréwm
PCV-71
Mandatory
R0519
V/
OPPOSITION To REQUEST Eon PnEmIAL DQCOVERY c/oNf’ERENCE Fresno COUWSUperIor Coufl
Local Rule 2.].17
PROOF 0F SERVICE
I am employed in the County of Santa Cruz, California. I am over the age of 1 8 years
and not a pany to the within entitled action. My business address is 311 Bonita Drive, Aptos,
mgww
California 95003.
On the date hereinbelow, I served the foregoing document(s) described as:
OPPOSITION TO REQUEST FOR PRETRIAL DISCOVERY CONFERENCE
on all other panics and/or their attomey(s) of record to this action by placing a true copy thereof
in a sealed envelope as follows:
Marshall C. Whitney
\OWNQ
Kristi D. Marshal]
Whitney, Thompson & Jeffcoach
8050 N. Palm Avenue, Suite ll0
10 Fresno, California 937] 1
Email: mwhitney@wtjlaw.com
11 Email: kmarshall@wtjlaw.com
12
[X ] (By U.S. Mail) I am a resident of, or employed in, the county where the mailing occurs.
13
I am over the age of l8 yeaxs and not a party to the cause. l am readily familiar with this
business’ practice for collecting and processing correspondence for mailing with the
14
United States Postal Services at Aptos, California. On the same day that correspondence
15 is placed for collection and mailing, it isdeposited in the ordinary course of business with
the United States Postal Services, in a sealed envelope with postage fully prepaid.
16
[X ] (By Email) On this date, by electronic transmission (email) to the parties and/or to their
17
attomey(s) 0f record stated above and/or attached list, to their known email address(es).
18 The document(s) was/were transmitted by electronic transmission. The transmission
was reported as complete and without error. A copy ofthe transmission report(s)
l9 properly issued by one or more of Rummonds Law Finn's computers is (are) made a pan
ofthis proof of service pursuant to California Rules of Court.
20
21
I declare under penalty of perjury under the laws of the State of California that the
22 foregoing istrue and correct, and that this is executed 0n Febru 8, 2021 in Aptos, California.
23
24
Kili A. Nielsen
25
26
27
28
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ATTORNEY OR PARTY WITHOUT ATIORNEY (Name, storebar number. and address): FOR COURT USE ONLY Jomes S.Rummonds SBN 59954 RUMMONDs LAW FIRM 3n CA Bonita Drive, Aptos. 95003 TELEPHONE No: 331.655.2911 FAX No: 831.662.3407 ATTORNEY FOR {Name}: Rudolf Leone, Jr.. Humphrey: Leone Equestrian; Jill Inc. E-FILED SUPERIOR COURT OF CALIFORNIA - COUNTY OF FRESNO 2/8/2021 4:19 PM Clvll Dlvlslon Superior Court of California 1 130 O Street County of Fresno Fresno, California 9372] —2220 By: S. Nunez, Deputy PLAINTIFF/PEI'WONERI RUDOLF LEONE, JR.. e! al‘ DEFENDANT/RESPONDENT: KAHN. SOARES & CONWAy_ LLP CASE NUMBER: OPPOSITION TO REQUEST FOR PRETRIAL DISCOVERY CONFERENCE 9C ECG04570 1 Plainfiffls) request a D Defendonfis) D Cross-comploinonfls) Pretrial Discovery Conference filed D Cross-defendonffs) D Other{s) on 2/1/2021 Opposition to by Defendani This opposition relates to: A dispute regarding o request for production of documents, sef 1 propounded on 4/29/2020 A dispute regarding form or special interrogatories, set l propounded on 4/29/2020 . D A dispute regarding o deposition subpoena directed 0T for deposition scheduled for D A dispute regarding o deposition notice, production of documents at a depOSIfion or deposi’rion questions related To the deposifion of scheduled for D A dispute regarding monetary, issue, evidence or Terminating sanctions reloTed to D with Local fhe Privilege is Rule basis for the 2.] .I7(B). refusal ’roproduce documents and c:priviiege log isattached which complies The pcrfies hove engaged in the following meaningful meet 0nd confer efforts prior f0 filing this opposition: (Describe in detail oII meet and confer effort including any narrowing of the issues or resolutions reached via these efforts.) Defense counsel correctly states that on October 2. 2020. Plaintiff sought and wos granted firne ’ro obtain documentafion reques’red, On January I9, 2021 ,defense counsel did send Plaintiff's counsel o Meet 0nd Confer letter which Plaintiff did nof answer within the requested time. Plaintiff's counsel, during the time imposed by the meet and confer, wos in the midst of depositions, final discovery, private mediofion, and 0 Mandatory Settlement Conference in o case scheduled fo go to trial on March 1, 202]. Plaintiff shou1d hove responded, especially because defense counsel has been accommodafing in her extension of professional cour‘fesies. Plaintiff'scounsel assures the Court and Defendant fhof he is making persistent effofls To obtain the requesfed discovery. ofiorney is working with his clients, Plaintiff's the clients' office staff, ond Plaintiff's accountant to obtain the documents. Plaintiff‘s counsel needs These documents as well to prove ifs case. PCV‘“ R054 9 opposmon To REQUEST Fox PREIRIAL DISCOVERY CONFERENCE Fresno Counmflgfiflg 5?}1'} Mandatory A brief summary of why the requested discovery should be denied, including The focts ond legal arguments in support iscs follows: (Excepfing o privilege log ifchecked above, no pleadings. exhibits, declorofions, or attachments shall be aflochedJ Plaintiff agrees That there is no real substantive dispute regarding Defendant's discovery requests. Plaintiff understands the urgency of the need to present these documents 0nd appreciates Defendant's pofience f0 date. understood It is ’rhof The filing of ’rhe Request for c1 Pretrial Discovery Conference tolls the time for filing o motion to compel discovery on the disputed issues for the number of days between the filing of the request and issuance by the Court of c1 subsequent order pertaining to the discovery dispute. PorTy received the REQUEST FOR PRETRIAL DISCOVERY CONFERENCE 0n: 2{4!202] Dale Pursuant To Locol Rule 2.] .1 7(A}(] ), this opposition is being filed within five (5) coufl days of service of The request for a Pre1riol Discovery Conference, exfended five (5)days for service by mail, and hos been served on The opposing party. Opposing Party was served with o copy of the OPPOSITION TO REQUEST FOR PRETRIAL DISCOVERY CONFERENCE on: 2/8/2021 O e A ' | declare under penalty of perjury under The laws of the State of C oing is e Emd\correcf. February 8, 2021 James S. Rummonds ——~ i. Name Date Type or Print f fifg’nomré‘ef‘Por‘ry ormaipiréwm PCV-71 Mandatory R0519 V/ OPPOSITION To REQUEST Eon PnEmIAL DQCOVERY c/oNf’ERENCE Fresno COUWSUperIor Coufl Local Rule 2.].17 PROOF 0F SERVICE I am employed in the County of Santa Cruz, California. I am over the age of 1 8 years and not a pany to the within entitled action. My business address is 311 Bonita Drive, Aptos, mgww California 95003. On the date hereinbelow, I served the foregoing document(s) described as: OPPOSITION TO REQUEST FOR PRETRIAL DISCOVERY CONFERENCE on all other panics and/or their attomey(s) of record to this action by placing a true copy thereof in a sealed envelope as follows: Marshall C. Whitney \OWNQ Kristi D. Marshal] Whitney, Thompson & Jeffcoach 8050 N. Palm Avenue, Suite ll0 10 Fresno, California 937] 1 Email: mwhitney@wtjlaw.com 11 Email: kmarshall@wtjlaw.com 12 [X ] (By U.S. Mail) I am a resident of, or employed in, the county where the mailing occurs. 13 I am over the age of l8 yeaxs and not a party to the cause. l am readily familiar with this business’ practice for collecting and processing correspondence for mailing with the 14 United States Postal Services at Aptos, California. On the same day that correspondence 15 is placed for collection and mailing, it isdeposited in the ordinary course of business with the United States Postal Services, in a sealed envelope with postage fully prepaid. 16 [X ] (By Email) On this date, by electronic transmission (email) to the parties and/or to their 17 attomey(s) 0f record stated above and/or attached list, to their known email address(es). 18 The document(s) was/were transmitted by electronic transmission. The transmission was reported as complete and without error. A copy ofthe transmission report(s) l9 properly issued by one or more of Rummonds Law Finn's computers is (are) made a pan ofthis proof of service pursuant to California Rules of Court. 20 21 I declare under penalty of perjury under the laws of the State of California that the 22 foregoing istrue and correct, and that this is executed 0n Febru 8, 2021 in Aptos, California. 23 24 Kili A. Nielsen 25 26 27 28