Document for Abel vs McCutchan, JR

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                                Richard Abel
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                  707 Hahman Drive, No. 9301
             2    Santa Rosa, CA 95405
                  Telephone: (707) 340-3894
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             4    Plaintiff,  In pro per

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                                         SUPERIOR COURT OF THE STATE OF CALIFORNIA

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                                                       FOR THE COUNTY OF SONOMA

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                   RICHARD ABEL, an individual;                                Case Number:       SCV-263456
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                                                                               AMENDED NOTICE OF MOTION AND
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                                            Plaintiff;                         MOTION TO COMPEL FURTHER
                           v.                                                  RESPONSES, AND FOR MONETARY
            13                                                                 SANCTIONS AGAINST DEFENDANT
                   B. EDWARD McCUTCHAN JR. an                                  SUNDERLAND/McCUTCHAN, INC.
            14                                                                  [CCP §§ 2030.300, 2031.310, 2033.290]
                   individual; SUNDERLAND/McCUTCHAN,
            15     LLP, a general partnership; and DOES 1
                                                                               Date:           March 23, 2022
                   through 100, inclusive;
            16                                                                 Time:           3:00 p.m.
            17                              Defendants.                        Dept:           18
                                                                               Trial Date:     October 7, 2022
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                  TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD:
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                           PLEASE TAKE NOTICE that on March 23, 2022, at 3:00 p.m. or as soon thereafter as
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                  the matter may be heard in Department 18 of the Sonoma County Superior Court, located at
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                  3055 Cleveland Avenue, Santa Rosa, CA 95403, plaintiff Richard Abel ("Plaintiff") will move
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                  the court for an order compelling defendant Sunderland/McCutchan, Inc. ("Responding Party" or
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                  "Defendant" herein) to serve full and complete verified responses, without objections, to the
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                  Request for Admissions, Form Interrogatories, and Request for Production of Documents, Set
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                  One, served on Responding Party on September 16, 2021.
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                           This motion is made pursuant to Code Civ.Proc. §§ 2030.300, 2031.310, and 2033.290,
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                  on the grounds that (1) the questions are relevant to the subject matter of this action and are not

                                              AMENDED NOTICE OF MOTION AND MOTION TO COMPEL
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