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December 11, 2020
El Dorado County, CA
AUTO TORT - UNLIMITED
ESTATE OF DAVID ALLEN ROTTMAN (Defendant)
KYLE O'BRIEN (Plaintiff)
DAVID ALLEN ROTTMAN (Defendant)
TERRI WILLOW ROTTMAN (Defendant)
CIERRA TOLBERT (Plaintiff)
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(1) Plaintiffs’ Motion to Deem Admitted Requests for Admission. (2) Plaintiffs’ Motion to Compel Responses to Requests for Production. (3) Plaintiffs’ Motion to Compel Responses to Interrogatories. Plaintiff’s counsel declares: on June 1, 2020 form interrogatories, requests for production, and requests for admission were served on State Farm Insurance Company attorneys representing deceased defendant David Rottman’s estate in this action; unverified responses were served on plaintiff on June 22, 2020; defense counsel claimed that the defendant estate had no personal knowledge regarding the underlying facts; and despite a request for responses and production, deceased defendant David Rottman’s estate failed to provide verifications for the responses. Plaintiff moves to compel answers to interrogatories and production of documents without objections; and to deem admitted the requests for admission. Plaintiff further requests an award of monetary sanctions in th........
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