On July 15, 2003 a
Request,Application
was filed
involving a dispute between
Gwen R. Sykes,
and
Douglas Sykes,
for Unlimited Civil
in the District Court of Alameda County.
Preview
e © Ruan ~
STEVEN B. PISER, SBN 62414 ed
LAW OFFICES OF STEVEN B. PISER
A Professional Corporation
499 Fourteenth Street, Suite 210
Oakland, California 94612
P
Telephone 510-835-5582
negele & D
Attorney for Douglas G. Sykes ALAMEDA COUNTY
AUG 1 3 2004
CLERIAOF THE SLFFERIO URT
oy Geant ches yy
Béputy
8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 IN AND FOR THE COUNTY OF ALAMEDA
10 GWEN R. SYKES, ) Case No. RG03106646
)
11 Plaintiff, ) DEFENDANT’S EX PARTE
) APPLICATION IS SUPPORT OF ORDER
12 Vv. ) SHORTENING TIME FOR HEARING ON
) MOTION FOR SANCTIONS
13 DOUGLAS SYKES, an individual, DOES 1_ +)
through 20, inclusive, ) DATE: August 13, 2004
14 ) TIME: 8:45 a.m.
Defendants ) DEPT: 31
15 )
16
)
17 Defendant Douglas Sykes hereby applies to this Court for an order shortening time for
18 service of notice and hearing on his motion for evidence sanctions and attorneys’ fees arising out
19 of plaintiff's failure to comply with two court orders regarding discovery.
20 - This application is made on the ground that the discovery which is the subject of this
21 motion has been ordered by the court and has not been produced; that the mandatory settlement
22 conference in this matter isscheduled for September 7, 2004, and trial of this action isset for
23 October 1,2004; that if the matter isheard on normal notice, defendant’s trial preparation will be
24 severely hampered; and that the subject matter of the discovery sought iscentral to plaintiff's
25 case, including, but not limited to expert witness discovery and preparation..
26 Therefore, defendant requests that the service of the notice of motion and accompanying
27 papers, a true and correct copy of which is attached hereto, be shortened so that service by fax or
28 personal delivery to the office of the attorney of record for plaintiff Gwen R. Sykes, by 12:00
LawOffices
of
I
STEVEN
8. PISER
‘md
1 p.m. on August 13, 2004 is sufficient notice of the proceeding.
2 Dated: August 12, 2004 Respectfully submitted,
LAW OFFICES OF STEVEN B. PISER
3 A Professional Corporation
4
By: |=
Steven B Piser
Attorney for Defendant
Douglas Sykes
10
ll
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
LawOffices
of
STEVEN
B. PISER
Document Filed Date
August 13, 2004
Case Filing Date
July 15, 2003
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
e © Ruan ~ STEVEN B. PISER, SBN 62414 ed LAW OFFICES OF STEVEN B. PISER A Professional Corporation 499 Fourteenth Street, Suite 210 Oakland, California 94612 P Telephone 510-835-5582 negele & D Attorney for Douglas G. Sykes ALAMEDA COUNTY AUG 1 3 2004 CLERIAOF THE SLFFERIO URT oy Geant ches yy Béputy 8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE COUNTY OF ALAMEDA 10 GWEN R. SYKES, ) Case No. RG03106646 ) 11 Plaintiff, ) DEFENDANT’S EX PARTE ) APPLICATION IS SUPPORT OF ORDER 12 Vv. ) SHORTENING TIME FOR HEARING ON ) MOTION FOR SANCTIONS 13 DOUGLAS SYKES, an individual, DOES 1_ +) through 20, inclusive, ) DATE: August 13, 2004 14 ) TIME: 8:45 a.m. Defendants ) DEPT: 31 15 ) 16 ) 17 Defendant Douglas Sykes hereby applies to this Court for an order shortening time for 18 service of notice and hearing on his motion for evidence sanctions and attorneys’ fees arising out 19 of plaintiff's failure to comply with two court orders regarding discovery. 20 - This application is made on the ground that the discovery which is the subject of this 21 motion has been ordered by the court and has not been produced; that the mandatory settlement 22 conference in this matter isscheduled for September 7, 2004, and trial of this action isset for 23 October 1,2004; that if the matter isheard on normal notice, defendant’s trial preparation will be 24 severely hampered; and that the subject matter of the discovery sought iscentral to plaintiff's 25 case, including, but not limited to expert witness discovery and preparation.. 26 Therefore, defendant requests that the service of the notice of motion and accompanying 27 papers, a true and correct copy of which is attached hereto, be shortened so that service by fax or 28 personal delivery to the office of the attorney of record for plaintiff Gwen R. Sykes, by 12:00 LawOffices of I STEVEN 8. PISER ‘md 1 p.m. on August 13, 2004 is sufficient notice of the proceeding. 2 Dated: August 12, 2004 Respectfully submitted, LAW OFFICES OF STEVEN B. PISER 3 A Professional Corporation 4 By: |= Steven B Piser Attorney for Defendant Douglas Sykes 10 ll 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 LawOffices of STEVEN B. PISER