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
Hearing Date
June 03, 2019
Type
Contract/Warranty Breach - Seller Plaintiff (no fraud/negligence) (General Jurisdiction)
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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