Motion Admissions Deemed Admitted

Cal. Super. - 6th Dist.March 29, 2021

PARKER LAW GROUP 35514 Eacrame' u C. A 2 3’3 gm:- /5: Czpnc s if; \OOONOUIA 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 21CV381418 Santa Clara - Civil Port J. Parker, SBN 179256 Myles G. Taylor, SBN 298687 Kaitlyn M. Bigoni, SBN 308455 PARKER LAW GROUPATTORNEYS A Professional Corporation 555 Capitol Mall, Suite 1230 Sacramento, CA 95814 Telephone: (916) 996-0400 Facsimile: (916) 668-5760 myles@parlawgroup.com kaitlyn@parlawgroup.com Attorneys for BRYAN CARRERA Electronically Filed by Superior Court of CA, County of Santa Clara, on 8/30/2021 4:47 PM Reviewed By: Y. Chavez Case #21CV381418 Envelope: 7170211 SUPERIOR COURT OF CALIFORNIA IN AND FOR THE COUNTY OF SANTA CLARA BRYAN CARRERA, directly and derivatively on behalf ofAXON DESIGN, INC., Plaintiff, v. JOHN NOORI, an individual; AXON DESIGN INC., a California Corporation dba NTERRA GROUP; and DOES 1 through 50, inclusive, Defendants, and AXON DESIGN, INC., as a Nominal Defendant as to derivate claims PLEASE TAKE NOTICE that on Case N0. 21CV381418 NOTICE OF MOTION AND MOTION TO DEEM SPECIFIED REQUESTS ADMITTED (CCP § 2033.230) Complaint Filed: March 29, 2021 , 0r as soon thereafter as the matter may be heard, in the courtroom so indicated of the Santa Clara County Superior Court, located at , Plaintiff Bryan Carrera will and does hereby move this Court pursuant to Cal. Code 0f Civ. Proc § 2033.280 for an order that the truth of any matters specified in his Request for Admissions, Set One, be deemed admitted by Defendant John Noori. Pursuant to Cal. Code of Civ. Proc. § 2033.280(c), Plaintiff further moves for an order imposing monetary sanctions in the amount of $1,620 against Defendant John Noori for the NOTICE OF MOTION AND MOTION TO IIJEEM SPECIFIED REQUESTS ADMITTED havez Dept. 2 Time: 9:00am Date: 12-14-2021 December 14, 2021 at 9:00am 191 North First St. San Jose, CA 95113 PARKER LAW GROUP :30 Eacramcr k: CA 935‘4 C4. V.":|| Tn. IE: 555 Cam b.) \OOOQQUI# 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 reasonable attomey’s fees and costs in bringing this motion. This motion is made on the grounds that Defendant failed to provide any response t0 the Request for Admissions, including after meet and confer efforts by Plaintiff’s counsel, as set forth in the Declaration ofMyles G. Taylor filed in support of this motion. The Motion is based on this Notice, the Memorandum of Points and Authorities, the Declaration of Myles G. Taylor, the exhibits attached thereto, the records and files in this action, and on such evidence and argument as may be presented at the hearing of the motion. Pursuant to Local Rule S(E): The Court follows CRC 3.1308(a)(1) for those departments that have elected to issue tentative rulings in civil law and motion and discovery matters. Counsel and litigants are responsible for determining whether the department hearing their motion has made this election. Those depafiments issuing tentative rulings will do so generally by 2:00 p.m., and no later than 3:00 p.m., on the court day preceding the scheduled hearing. If the Court has not directed oral argument, a party contesting a tentative ruling must give notice of its intention to appear to the other side and the Court no later than 4:00 pm. on the court day preceding the scheduled hearing. Appearances may be made by telephone (through CourtCall) or in person. The tentative ruling will automatically become the order ofthe Court on the scheduled hearing date if the Court has not directed oral argument and if the contesting party fails to timely notice an objection to the other side and the Court. Tentative rulings will be posted on the Court's website, www.scscourt.org, where further information may be found. If a party does not have access to the internet, the tentative ruling may be accessed by calling Court Services at (408) 882-2515. Questions about these procedures may be addressed to the specific department where the matter is to be heard. PARKER LAW GROUP ATTORNEYS DATED: August 30, 2021 A Pro sio oration MYLES G. TAYLOR KAITLYN M. BIGONI Attorneys for PlaintiffBRYAN CARRERA NOTICE 0F MOTION AND MOTION TO gEEM SPECIFIED REQUESTS ADMITTED