On April 10, 2015 a
Motion-Secondary
was filed
involving a dispute between
Maneatis, Caroline,
and
Does 3 To 25,
Harbor View Hotels, Inc,
Hilton Franchise Holdings, Llc,
for (06) Unlimited Breach of Contract/Warranty
in the District Court of San Mateo County.
Preview
RECEIVED
MAR 2 9 2017
CLERK OF THE SUPERIOR COURT
1 Gregory P. Arakawa (State Bar No. W5 OCOUNTY
garakawa@wshblaw.com
2 Steven R. Disharoon (State Bar No. 273170)
sdisharoon@wshblaw.com
3 WOOD, SMITH, HENNING & BERMAN LLP
\
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:\0
a?
‘4
4
5
6
1401 Willow Pass Road,
Concord,
Phone: 925
Suite 700
California 94520-7982
222 3400 o Fax: 925 356 8250
Attorneys for Defendant HARBOR VIEW HOTELS, INC. (erroneously sued as "HARBOR
VIEW HOLDINGS, INC")
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 IN AND FOR COUNTY OF SAN MATEO
10
C/x/
11 CAROLINE MANEATIS, individually and
g Case No. W533327
z 8N§
dba CARA MIA,
12
g ; §§ [PROPOSED] ORDER GRANTING
133
Egg DEFENDANT'S MOTION TO COMPEL
.5 3”Dis; 13 Plaintiff, AND REQUEST FOR SANCTIONS
025;:
14
2;;
If E
fig v. Date:
Time:
April 27, 2017
9:00 am.
g gg 15
’5'“ g [egg HARBOR VIEW HOLDINGS, INC., et al., Dept: Law and Motion
_ o w
._J
gig)
5 E 16 Defendants. Action Filed: 04/10/2015
8 RE] 17
Trial Date: 08/07/17
3 ____
H
9
_ _ __
18 21:23”?
1
\ 19
.
Proposed Order Received
438127
i
(gm 20
llllllllllllll|_|_|l_|1||_|l|lIll
21 Defendant HARBOR VIEW HOTELS, WC.'S ("Defendant") filed a Motion to Compel
L”j
77
responses [0 two sets of supplemental discoveryit served on?laintiff€AROLINE ‘viANEATiS
23 ("Plaintiff'),
:0 24
and included a request for monetary sanctions. The Motion came on regularly for
hearing on April 27, 2017, at 9:00 am, in the Law and Motion Department of the above-entitled
CT)
25
.7. court. Party appearances are reflected in the record. Having reviewed the parties‘ submissions,
>
I
26
27
the Court rules as follows:
1. Defendant's Motion is GRANTED. Plaintiff is ordered to provide filll and
28 complete verified responses without objections to Defendant within 10 days of this Order;
LEGAL206142-l 126/7070467.l _1_
[PROPOSED] ORDER GRANTING DEFENDANT'S MOTION TO COMPEL AND REQUEST FOR SANCTIONS
2. The Court orders sanctions against Plaintiffs in the sum of $1,190.00 . Said
sanctions are owed jointly and severally by Plaintiff and her counsel, and shall be paid to counsel
for Defendant Within 10 days of this Order.
IT IS SO ORDERED.
\lONUl-b-UJN
DATED: March , 2017
00
JUDGE OF THE SUPERIOR COURT
LLP
8250
700
BERMAN
356
94520-7982
SUITE
925
8| FAX
Law
ROAD.
at
o
CALIFORNIA
HENNING 3400
PASS
Anomeys
222
925
WILLOW
SMITH,
CONCORD.
1401TELEPHONE
WOOD,
LEGAL206142-l126/7070467.l -2-
[PROPOSED] ORDER GRANTING DEFENDANT'S MOTION TO COMPEL AND REQUEST FOR SANCTIONS
’
PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF CONTRA COSTA
I am employed in the County of Contra Costa, State of California. I am over the age of
eighteen years and not a party to the within action. My business address is 1401 Willow Pass
Road, Suite 700‘, Concord, CA 94520-7982.
On Marcbg, 2017, I served the following document(s) described as [PROPOSED]
ORDER GRANTING DEFENDANT'S MOTION TO COMPEL on the interested parties in
this action as follows:
\DOO\10\UI-I>
SEE ATTACHED SERVICE LIST
BY MAIL: I placed true copies of the foregoing document(s) enclosed in sealed
envelopes addressed as shown on the Service List. I am “readily familiar” with Wood, Smith,
Henning & Berrnan’s practice for collecting and processing correspondence for mailing with the
United States Postal Service. Under that practice, it would be deposited with the United States
Postal Service that same day in the ordinary course of business. Such envelope(s) were placed for
collection and mailing with postage thereon fully prepaid at Concord, California, on that same day
LLP
following ordinary business practices.
8250
700
356
I declare under penalty of perjury under the laws of the State of California that the
‘
BERMAN
94520-7982
SUITE
foregoing is true and correct. ‘
925
&
Executed on Maxcfifl, 2017,
FAX
Law
ROAD.
o at Concord, California.
at
CALIFORNIA
HENNING 3400
simian
PASS
Anomeys
222
925
WILLOW
SMITH.
CONCORD.
Alexandra| D. ReeT’ res:
1401TELEPHONE
55.15
WOOD,
r
l. ;
I.
l.,
“”7“-.."
T
'..
LEGAL106I42-1126/7070467J -1-
[PROPOSED] ORDER GRANTING DEFENDANT'S MOTION TO COMPEL AND REQUEST FOR SANCTIONS
SERVICE LIST
Maneatis v. Hilton San Francisco Airport Bayfront
SMSC; CV 533327
John T. Hansen
Attorney at Law
582 Market Street, 17111
Floor
San Francisco, CA 94104
Tel.: (415) 444-6684 (O)/510-910-1392 (M)
Fax: 510-538-9233
OKOOONO‘I‘JIADJNfl
Email: ihansenlaw101@gmail.com
Attornevs for Plaintiff
LLP
8250
700
356
BERMAN
94520-7982
SUITE
925
& Law
FAX
ROAD.
O
at
CALIFORNIA
3400
NNHHHI—‘i—l—DD—ID—dl—li—t
HENNING
PASS
Ahomeys
222
925
WILLOW
SMiTH,
HOCOONO‘IUI-D-UJNH
CONCORD.
1401TELEPHONE
WOOD.
Ix) IQ
“VOW-PL»)
NNNNNN
LEGAL:06142-1126/7070467.1 -2-
[PROPOSED] ORDER GRANTING DBFENDANT'S MOTION TO COMPEL AND REQUEST FOR SANCTIONS
Document Filed Date
March 29, 2017
Case Filing Date
April 10, 2015
Category
(06) Unlimited Breach of Contract/Warranty
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RECEIVED MAR 2 9 2017 CLERK OF THE SUPERIOR COURT 1 Gregory P. Arakawa (State Bar No. W5 OCOUNTY garakawa@wshblaw.com 2 Steven R. Disharoon (State Bar No. 273170) sdisharoon@wshblaw.com 3 WOOD, SMITH, HENNING & BERMAN LLP \ b5 :\0 a? ‘4 4 5 6 1401 Willow Pass Road, Concord, Phone: 925 Suite 700 California 94520-7982 222 3400 o Fax: 925 356 8250 Attorneys for Defendant HARBOR VIEW HOTELS, INC. (erroneously sued as "HARBOR VIEW HOLDINGS, INC") 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR COUNTY OF SAN MATEO 10 C/x/ 11 CAROLINE MANEATIS, individually and g Case No. W533327 z 8N§ dba CARA MIA, 12 g ; §§ [PROPOSED] ORDER GRANTING 133 Egg DEFENDANT'S MOTION TO COMPEL .5 3”Dis; 13 Plaintiff, AND REQUEST FOR SANCTIONS 025;: 14 2;; If E fig v. Date: Time: April 27, 2017 9:00 am. g gg 15 ’5'“ g [egg HARBOR VIEW HOLDINGS, INC., et al., Dept: Law and Motion _ o w ._J gig) 5 E 16 Defendants. Action Filed: 04/10/2015 8 RE] 17 Trial Date: 08/07/17 3 ____ H 9 _ _ __ 18 21:23”? 1 \ 19 . Proposed Order Received 438127 i (gm 20 llllllllllllll|_|_|l_|1||_|l|lIll 21 Defendant HARBOR VIEW HOTELS, WC.'S ("Defendant") filed a Motion to Compel L”j 77 responses [0 two sets of supplemental discoveryit served on?laintiff€AROLINE ‘viANEATiS 23 ("Plaintiff'), :0 24 and included a request for monetary sanctions. The Motion came on regularly for hearing on April 27, 2017, at 9:00 am, in the Law and Motion Department of the above-entitled CT) 25 .7. court. Party appearances are reflected in the record. Having reviewed the parties‘ submissions, > I 26 27 the Court rules as follows: 1. Defendant's Motion is GRANTED. Plaintiff is ordered to provide filll and 28 complete verified responses without objections to Defendant within 10 days of this Order; LEGAL206142-l 126/7070467.l _1_ [PROPOSED] ORDER GRANTING DEFENDANT'S MOTION TO COMPEL AND REQUEST FOR SANCTIONS 2. The Court orders sanctions against Plaintiffs in the sum of $1,190.00 . Said sanctions are owed jointly and severally by Plaintiff and her counsel, and shall be paid to counsel for Defendant Within 10 days of this Order. IT IS SO ORDERED. \lONUl-b-UJN DATED: March , 2017 00 JUDGE OF THE SUPERIOR COURT LLP 8250 700 BERMAN 356 94520-7982 SUITE 925 8| FAX Law ROAD. at o CALIFORNIA HENNING 3400 PASS Anomeys 222 925 WILLOW SMITH, CONCORD. 1401TELEPHONE WOOD, LEGAL206142-l126/7070467.l -2- [PROPOSED] ORDER GRANTING DEFENDANT'S MOTION TO COMPEL AND REQUEST FOR SANCTIONS ’ PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF CONTRA COSTA I am employed in the County of Contra Costa, State of California. I am over the age of eighteen years and not a party to the within action. My business address is 1401 Willow Pass Road, Suite 700‘, Concord, CA 94520-7982. On Marcbg, 2017, I served the following document(s) described as [PROPOSED] ORDER GRANTING DEFENDANT'S MOTION TO COMPEL on the interested parties in this action as follows: \DOO\10\UI-I> SEE ATTACHED SERVICE LIST BY MAIL: I placed true copies of the foregoing document(s) enclosed in sealed envelopes addressed as shown on the Service List. I am “readily familiar” with Wood, Smith, Henning & Berrnan’s practice for collecting and processing correspondence for mailing with the United States Postal Service. Under that practice, it would be deposited with the United States Postal Service that same day in the ordinary course of business. Such envelope(s) were placed for collection and mailing with postage thereon fully prepaid at Concord, California, on that same day LLP following ordinary business practices. 8250 700 356 I declare under penalty of perjury under the laws of the State of California that the ‘ BERMAN 94520-7982 SUITE foregoing is true and correct. ‘ 925 & Executed on Maxcfifl, 2017, FAX Law ROAD. o at Concord, California. at CALIFORNIA HENNING 3400 simian PASS Anomeys 222 925 WILLOW SMITH. CONCORD. Alexandra| D. ReeT’ res: 1401TELEPHONE 55.15 WOOD, r l. ; I. l., “”7“-.." T '.. LEGAL106I42-1126/7070467J -1- [PROPOSED] ORDER GRANTING DEFENDANT'S MOTION TO COMPEL AND REQUEST FOR SANCTIONS SERVICE LIST Maneatis v. Hilton San Francisco Airport Bayfront SMSC; CV 533327 John T. Hansen Attorney at Law 582 Market Street, 17111 Floor San Francisco, CA 94104 Tel.: (415) 444-6684 (O)/510-910-1392 (M) Fax: 510-538-9233 OKOOONO‘I‘JIADJNfl Email: ihansenlaw101@gmail.com Attornevs for Plaintiff LLP 8250 700 356 BERMAN 94520-7982 SUITE 925 & Law FAX ROAD. O at CALIFORNIA 3400 NNHHHI—‘i—l—DD—ID—dl—li—t HENNING PASS Ahomeys 222 925 WILLOW SMiTH, HOCOONO‘IUI-D-UJNH CONCORD. 1401TELEPHONE WOOD. Ix) IQ “VOW-PL») NNNNNN LEGAL:06142-1126/7070467.1 -2- [PROPOSED] ORDER GRANTING DBFENDANT'S MOTION TO COMPEL AND REQUEST FOR SANCTIONS