Wmc-Sa, Inc. vs. Readylink, Inc

Motion to Strike or Tax Costs

Cal. Super. - 4th Dist.August 2, 2013

t o S O x X a u 28 VAUGHN & VAUGHN Donald A. Vaughn, Esq. (Bar No. 110070) Evan J. Topol, Esq. (Bar No. 274932) VAUGHN & VAUGHN 501 West Broadway, Suite 1770 San Diego, CA 92101 Tel: (619) 237-1717 Fax: (619) 237-0447 Attorneys for Plaintiff, WMC-SA. INC. SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ORANGE, CENTRAL JUSTICE CENTER WMC-SA. INC.. a California corporation, Plaintiff’, V. READYLINK, INC.. a Nevada corporation; SUVARNA DURGIAH: and DOES 1 through 50, Defendants. Case No. 30-2013-00666494-CU-BC-CIC (Consolidated for purposes oftrial with Case No. 30-2013-00669286) NOTICE OF MOTION AND MOTION TO STRIKE AND/OR TAX COSTS Judge: Hon. Frederick Horn Dept.: C64 Date: November 7.2018 Time: 1:30 p.m. Complaint Filed: August 2.2013 Trial Date: June 25, 2018 TO DEFENDANT READYLINK. INC. AND TO ITS ATTORNEYS OF RECORD: YOU AND EACH OF YOU WILL PLEASE TAKE NOTICE that. at 1:30 p.m. on November 7. 2018 in Department C64 Ofthe above-entitled Court located at 700 Civic Center Drive West. Santa Ana. CA 92701. Plaintiff WMC-SA. INC. (“Plaintiff or “WMC") will. and hereby does, move to strike and/or. in the alternative. tax the costs claimed by Defendant ReadyLink. Inc. on the basis that the costs claimed by defendant ReadyLink. Inc. are not recoverable under CCP sections 1032 and 1033.5 and/or California law. The instant Motion will be based upon the instant Notice of Motion and Motion. upon the accompanying Memorandum of Points and Authorities. upon the concurrently-filed Declaration ot Donald A. Vaughn, upon the records, files and pleadings in this action, and upon such other 1 NOTICE OF MOTION AND MOTION TO STRIKE AND/OR TAX COSTS 28 VAUGHN & VAUGHN and further oral and documentary evidence as may be properly received by the Court at or before the time of the hearing. Respectfully submitted. Dated: October 3, 2018 VAUGHN & VAUGHN § Ge\ DONALD A. VAUGHN L) EVAN J. TOPOL Attorneys for Plaintiff WMC-SA, INC. 2 NOTICE OF MOTION AND MOTION TO STRIKE AND/OR TAX COSTS h o VAUGHN & VAUGHN WMC-SA, INC. v. READYLINK, INC,, et al. Orange County Superior Court Case No. 30-2013-00666494-CU-BC-CJC PROOF OF SERVICE I, Monica Reitano, declare as follows: I am a citizen of the United States and am employed in the County of San Diego, California. I am over the age of 18 and not a party to the within action. My business address is 501 West Broadway. Suite 1770, San Diego, California 92101. On October 3, 2018, I served the following document: NOTICE OF MOTION AND MOTION TO STRIKE AND/OR TAX COSTS on the following parties and/or counsel of record: Gerald A. Klein, P.C. Attorneys for Defendant, Mark Wilson, P.C. READYLINK, INC. Klein & Wilson 4770 Von Karman Avenue Newport Beach, CA 92660 E-Mail: klein‘kleinandwilson.com E-Mail: wilsonzkleinandwilson.com E-Mail: christine/wkleinandwilson.com Telephone: (949) 631-3300 Facsimile: (949) 631-3703 [] BY ELECTRONIC MAIL: 1 caused said document(s) to be delivered via electronic mail to the electronic mail addresses set forth above. [X] BY ELECTRONIC SERVICE: I caused said document(s) to be delivered via electronic mail to the electronic mail addresses set forth above through Orange County Superior Court Electronic Filing Service website. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that I executed this Proof of Service an October 3, 2018, at San Diego, California. / Mes Monica Reitano PROOF OF SERVICE