On July 15, 2003 a
Motion-Secondary
was filed
involving a dispute between
Gwen R. Sykes,
and
Douglas Sykes,
for Unlimited Civil
in the District Court of Alameda County.
Preview
05-27-2004 12:57 FROM
“1c
STEVEN B. PISER, SBN 62414
LAW
A
OFFICES
Professional
OF STEVEN
Corporation
B. PISER
FILED
ALAMEDA COUNTY
i) 499 Fourteenth Srreet, Suite 210
Oakland, California 94612
Ww
Telephone 510-835-5582 MAY 2 7 2004
CLERK OF THE SUPER;
BP
Attomey for Douglas G. Sykes OR CouatT
By US :
Deputy
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF ALAMEDA
GWEN R. SYKES, ) Case No. RGO3106646
)
Plainuff, } MEMORANDUM OF POINTS AND
- ) AUTHORITIES IN SUPPORT OF
v, ) MOTION TO COMPEL FURTHER
) RESPONSES TO FORM AND SPECIAL
DOUGLAS SYKES,; an individual, DOES-I---) INTERROGATORIES AND FOR
14 through 20, inclusive, SANCTIONS AGAINST GWEN ROWE-
LEE
15 Defendants
Date: June 18, 2004 B
16 Time: 2:00 p.m.
Dept: 31 Y FAX
17 Trial Date: October 1, 2004
18 A court shall order further responses where a response to an interrogatory isinadequate or
evasive. Code of Civil Procedure section 2030(1). Unless the court finds that the party who
refused to comply with the Discovery Act acted with substantial justification, sanctions should be
awarded. Code of Civil Procedure section 2023(b).
Dated: May 27, 2004 LAW OFFI S OF STEVEN B. PISER
A Professi al Corporation
Legal
By:
FiledBy
hom B. Piser
ttomey for Defendant
ouglas Sykes
One
LawOffices
of
1
STEVEN
B. PISER
MEMO ISO MTN TO COMPEL COMPLIANCE WITH SUBPOENA AND FOR SANCTIONS
MAY 27 2684 13:@1
PAGE . 85
Document Filed Date
May 27, 2004
Case Filing Date
July 15, 2003
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Preview
05-27-2004 12:57 FROM “1c STEVEN B. PISER, SBN 62414 LAW A OFFICES Professional OF STEVEN Corporation B. PISER FILED ALAMEDA COUNTY i) 499 Fourteenth Srreet, Suite 210 Oakland, California 94612 Ww Telephone 510-835-5582 MAY 2 7 2004 CLERK OF THE SUPER; BP Attomey for Douglas G. Sykes OR CouatT By US : Deputy IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF ALAMEDA GWEN R. SYKES, ) Case No. RGO3106646 ) Plainuff, } MEMORANDUM OF POINTS AND - ) AUTHORITIES IN SUPPORT OF v, ) MOTION TO COMPEL FURTHER ) RESPONSES TO FORM AND SPECIAL DOUGLAS SYKES,; an individual, DOES-I---) INTERROGATORIES AND FOR 14 through 20, inclusive, SANCTIONS AGAINST GWEN ROWE- LEE 15 Defendants Date: June 18, 2004 B 16 Time: 2:00 p.m. Dept: 31 Y FAX 17 Trial Date: October 1, 2004 18 A court shall order further responses where a response to an interrogatory isinadequate or evasive. Code of Civil Procedure section 2030(1). Unless the court finds that the party who refused to comply with the Discovery Act acted with substantial justification, sanctions should be awarded. Code of Civil Procedure section 2023(b). Dated: May 27, 2004 LAW OFFI S OF STEVEN B. PISER A Professi al Corporation Legal By: FiledBy hom B. Piser ttomey for Defendant ouglas Sykes One LawOffices of 1 STEVEN B. PISER MEMO ISO MTN TO COMPEL COMPLIANCE WITH SUBPOENA AND FOR SANCTIONS MAY 27 2684 13:@1 PAGE . 85