Motion Amended

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

PARKER LAW GROUP 555 Capitol Mall, Suite 1230 Sacramento, CA 95814 \OOOQON 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 21 CV38141 8 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: (9 1 6) 996-0400 Facsimile: (916) 668-5760 myles@parlawgroup.com kaitlvn@parlawgr0up.com Electronically Filed by Superior Court of CA, County of Santa Clara, on 11/24/2021 10:24 AM Reviewed By: F. Miller Case #21CV381418 Envelope: 7732763 Attorneys for BRYAN CARRERA SUPERIOR COURT OF CALIFORNIA IN AND FOR THE COUNTY OF SANTA CLARA BRYAN CARRERA, directly and derivatively on behalf ofAXON DESIGN, INC., Case N0. 21CV381418 AMENDED NOTICE 0F MOTION AND Plaintiff, V. JOHN NOORI, an individual; AXON DESIGN INC., a California Corporation dba MOTION T0 DEEM SPECIFIED REQUESTS ADMITTED (CCP § 2033.230) Date: December 14, 2021 Time: 9:00 am. Dept: 2 NTERRA GROUP; and DOES 1 through 50, inclusive, Defendants, and AXON DESIGN, INC., as a Nominal Defendant as t0 derivate claims Complaint Filed: March 29, 202] PLEASE TAKE NOTICE that 0n December 14, 2021 at 9:00 a.m., or as soon thereafter as the matter may be heard, in the courtroom so indicated 0f the Santa Clara County Superior Court, located at 191 North First Street, San Jose, CA 951 13, Plaintiff Bryan Carrera will and does hereby move this Court pursuant t0 Cal. Code OfCiV. 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 t0 Cal. Code 0f CiV. Proc. § 2033.280(c), Plaintiff further moves for an order imposing monetary sanctions in the amount 0f $1,620 against Defendant John Noori for the reasonable AMENDED NOTICE OF MOTION AND MOTIONI TO DEEM SPECIFIED REQUESTS ADMITTED F. Miller PARKER LAW GROUP I’ A 958‘ 4 L 4n»;- Igfi) Ecuamg-rtn 555 Cccnc' H‘s..- MQQ \O 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 attorney’s fees and costs in bringing this motion. This motion is made on the grounds that Defendant failed to provide any response to 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 ofthis 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 0n such evidence and argument as may be presented at the hearing of the motion. Pursuant to Local Rule 8(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 departments issuing tentative rulings will d0 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 t0 appear t0 the other side and the Court no later than 4:00 p.m. 0n 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 ifthe 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.scscohrtorg, 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 t0 the specific department where the matter is to be heard. PARKER L, W GROUP ATTO EYS DATED: November 18, 2021 A Pr ssion Corporation fivfis G. KYLOR KAITLYN M. BIGONI Attorneys for PlaintiffBRYAN CARRERA AMENDED NOTICE 0F MOTION AND MOTIOE TO DEEM SPECIFIED REQUESTS ADMITTED