On October 28, 2009 a
Party Discovery
was filed
involving a dispute between
Chang, Michael,
and
Farmers Group, Inc,
Farmers Group, Inc., A California Corp,
Farmers Insurance Company, Inc,
Farmers Insurance Company, Inc. A California Corporation,
Farmers Insurance Exchange Insurance Exchange,
Truck Insurace Exchange,
for (18) Unlimited Insurance Coverage
in the District Court of San Mateo County.
Preview
Gregg S. Garrison (SBN 141653)
GARRISON LAW CORPORATION
161 Cortez Avenue SAN 7<0 COVhlTY
Half Moon Bay, CA 94019
Telephone: (650) 726-1111
G 08 2gf3
Facsimile: (650) 726-9315
up+W Coutt
I
Herman I. Kalfen (SBN 160592)
1 Embarcadero Center, Suite 500
San Francisco, CA 94111
Telephone: (415) 315-1710
Facsimile: (415) 433-5992
Attorney for PlaintiffMichael Chang, an Individual
10 SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN MATEO
V+ u Case No. 489065
a 13 MICHAELCHANG, an individual,
Plaintiff, *UNLIMITEDCIVILCASE~
gg=14 vs.
NOTICE OF PLAINTIFF MICHAEL
FARMER'S INSURANCE COMPANY, INC., CHANG'S MOTION TO COMPEL
WQ ge 4~o15 FARMER'S GROUP, INC., FARMER' FARMERS RESPONSE TO SPECIAL
16 INSURANCE EXCHANGE AND TRUCK INTERROGATORIES, SET ONE AND FOR
INSURANCE EXCHANGE, reciprocal inter- SANCTIONS
17
insurance exchanges; Does 1 to 99, Inclusive,
18 Defendants. Hearing Date: September lZ, 2013
Time: 9:00 a.m.
19 Dept: L&M
20 Trial Date: November 25, 2013
21 BY FAX
22
23
PLEASE TAKE NOTICE THAT, on ~ lg:, 2013, or as soon thereafter,
Plaintiff MICHAEL CHANG will bring this Motion to Compel Defendant Farmers
24
Insurance Company to provide Supplemental Response to Special Interrogatories, Set One
26 and for Sanctions
27 PlaintifFs Motion to Compel is based on this Notice, and the Motion with Points and
28
-1-
Notice of Plaintiff Michael Chang'sMotion to Compel Farmers Insurance Response to SpecialAdmissions,
Set One and For Sanctions
Authorities in Support, and the Separate Statement of Facts in Dispute and Good Faith
Attempt at Informal Settlement, and Declarations in support, including the Declaration of
Gregg S. Garrison and Exhibits attached thereto, and all documents and testimony as may
be presented upon hearing of the matter.
7 GARRISON LAW CORPORATION
10
DATED: August 6, 2013
11
12
BY
Gregg S. ~~arrison, JD, REA, CEP
Attorney for Michael Chang
17
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19
20
21
22
23
24
25
26
27
28
-2-
Notice of Plaintiff Michael Chang'sMotion to Compel Farmers Insurance Response to SpecialAdmissions,
SetOne and For Sanctions
Document Filed Date
August 08, 2013
Case Filing Date
October 28, 2009
Category
(18) Unlimited Insurance Coverage
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Gregg S. Garrison (SBN 141653) GARRISON LAW CORPORATION 161 Cortez Avenue SAN 7<0 COVhlTY Half Moon Bay, CA 94019 Telephone: (650) 726-1111 G 08 2gf3 Facsimile: (650) 726-9315 up+W Coutt I Herman I. Kalfen (SBN 160592) 1 Embarcadero Center, Suite 500 San Francisco, CA 94111 Telephone: (415) 315-1710 Facsimile: (415) 433-5992 Attorney for PlaintiffMichael Chang, an Individual 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN MATEO V+ u Case No. 489065 a 13 MICHAELCHANG, an individual, Plaintiff, *UNLIMITEDCIVILCASE~ gg=14 vs. NOTICE OF PLAINTIFF MICHAEL FARMER'S INSURANCE COMPANY, INC., CHANG'S MOTION TO COMPEL WQ ge 4~o15 FARMER'S GROUP, INC., FARMER' FARMERS RESPONSE TO SPECIAL 16 INSURANCE EXCHANGE AND TRUCK INTERROGATORIES, SET ONE AND FOR INSURANCE EXCHANGE, reciprocal inter- SANCTIONS 17 insurance exchanges; Does 1 to 99, Inclusive, 18 Defendants. Hearing Date: September lZ, 2013 Time: 9:00 a.m. 19 Dept: L&M 20 Trial Date: November 25, 2013 21 BY FAX 22 23 PLEASE TAKE NOTICE THAT, on ~ lg:, 2013, or as soon thereafter, Plaintiff MICHAEL CHANG will bring this Motion to Compel Defendant Farmers 24 Insurance Company to provide Supplemental Response to Special Interrogatories, Set One 26 and for Sanctions 27 PlaintifFs Motion to Compel is based on this Notice, and the Motion with Points and 28 -1- Notice of Plaintiff Michael Chang'sMotion to Compel Farmers Insurance Response to SpecialAdmissions, Set One and For Sanctions Authorities in Support, and the Separate Statement of Facts in Dispute and Good Faith Attempt at Informal Settlement, and Declarations in support, including the Declaration of Gregg S. Garrison and Exhibits attached thereto, and all documents and testimony as may be presented upon hearing of the matter. 7 GARRISON LAW CORPORATION 10 DATED: August 6, 2013 11 12 BY Gregg S. ~~arrison, JD, REA, CEP Attorney for Michael Chang 17 18 19 20 21 22 23 24 25 26 27 28 -2- Notice of Plaintiff Michael Chang'sMotion to Compel Farmers Insurance Response to SpecialAdmissions, SetOne and For Sanctions