CV-21-004498 – GERONIMO, EVANGELINA vs ROUBACH, MAJID, MD – Plaintiff’s Motion to Exclude and Object to Deposition taken by Carlos M. Ambriz of Cassel Ginn’s Attorney for Majid Roubach MD taken on June 23,2022 – HEARING REQUIRED.
The Court intends to DENY the motion.  The moving papers are deficient in that they fail to include the required elements (notice, supporting memorandum, etc.) pursuant to Cal. Rules of Ct., rule 3.1112. In addition, the motion fails to identify the provisions of the Discovery Act under which Plaintiff seeks relief in this instance. Moreover, while the Court presumes that Plaintiff may be attempting to obtain an order suppressing the June 2023 deposition pursuant to Code Civ. Proc. § 2025.520(g), Plaintiff has failed to demonstrate the meet-and-confer efforts required by that section. Moreover, the Court questions whether Plaintiff brought the instant motion seasonably, as it appears she delayed in this regard for over 5 months, during which time she submitted