MOTION TO QUASH DEPOSITION SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS AND DEPOSITION SUBPOENA FOR PERSONAL APPEARANCE

MOVING PARTY: Defendants Thomas E. Morgan, III, Covina Hills MHC, LLC, Covina Hills GP, LLC, Juanita Springs Associates, LP and Covina Hills MHC, LLC

RESPONDING PARTY(S): Plaintiff Richard Pech

PROOF OF SERVICE:

ANALYSIS

Motion to Quash Business Records Subpoena and Deposition for Personal Appearance

Discussion

Defendants Thomas E. Morgan, III, Covina Hills MHC, LLC, Covina Hills GP, LLC, Juanita Springs Associates, LP and Covina Hills MHC, LLC move to quash the deposition subpoena for production of business records and deposition subpoena for personal appearance on attorney Warren J. Kessler.

Plaintiff’s argument that this motion is untimely under Civil Code § 1985.3(g) is not persuasive. That section applies to notice given to the witness and deposition officer, not the court. Moreover, § 1985.3(g) expressly states that non-compliance does not invalidate the