Chet K. Ahn vs. Stephanie Van Valkenburg

Motion to Compel ProductionInspection of Documents or Things

Cal. Super. - 4th Dist.February 25, 2016

20 21 22 23 24 25 26 27 28 ELECTRONICALLY FILED Lawrence J. Dreyfuss, Bar No. 76277 Superior Court of Califomia, Bruce Dannemeyer, Bar No. 107243 County of Orange THE DREYFUSS FIRM 07/21/2016 at 10:54:00 Ad A Professional Law Corporation Clerk of the Superior Court 2 Venture, Suite 450 By Diana Cuevas, Deputy Clerk Irvine, CA 92618 Telephone (949) 727-0977; Facsimile (949) 450-0668 Attorneys for Plaintiff Chet K. Ahn SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ORANGE CHET K. AHN Case No.: 30-2016-00837367 Judge Deborah J. Servino Plaintiffs, Department C22 Vs. NOTICE OF MOTION AND MOTION TO COMPEL RESPONSE TO DEMAND FOR PRODUCTION OF DOCUMENTS; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF BRUCE DANNEMEYER STEPHANIE VAN VALKENBURG; WELLS FARGO BANK, N.A.; AND ALL PERSONS UNKNOWN CLAIMING ANY INTEREST IN THE SUBJECT PROPERTY, NAMED AS DOES 1 THROUGH 50, INCLUSIVE Date: September 2, 2016 Time: 10:00 a.m. Dept: C22 Defendants. RESERVATION NO: 72413266 TO STEPHANIE VAN VALKENBURG: PLEASE TAKE NOTICE that on September 2, 2016 at 10:00 a.m. or as soon thereafter as the matter may be heard Department 22 of the Orange County Superior Court located at 700 Civic Center Drive West, Santa Ana, California 92701, plaintiff Chet K. Ahn will move for an order compelling defendant Stephanie Van Valkenburg to respond to the first demand for production of documents propounded on her. PLAINTIFF'S MOTION TO COMPEL RESPONSE TO DEMAND FOR PRODUCTION OF DOCUMENTS 1 16 17 18 20 21 22 23 24 25 26 27 28 In addition, the motion will seek monetary sanctions of $282 against defendant Stephanie Van Valkenburg under Code of Civil Procedure section 2031.300(c), which constitute the costs and attorney’s fees in bringing this motion, including the anticipated time to be spent in the hearing on this motion. This motion is made pursuant to Code of Civil Procedure section 2031.300. The first demand for production of documents was served on May 12, 2016. No response was received. Plaintiff's counsel sent a meet and confer letter and called defendant, but defendant did not respond. This motion is scheduled to be heard at the same time as plaintiff's motion to compel response to the first set of form interrogatories, motion to compel response to special interrogatories, and motion to deem matters admitted. All discovery instruments seek information concerning the basis for defendant’s defense to this action. The motion will be based on this notice, the accompanying memorandum of points and authorities, the declaration of Bruce Dannemeyer, the pleadings and papers on file in this action, and upon such further evidence and argument as may be presented at or before the hearing. DATED: July 21, 2016 THE DREYFUSS FIRM a professional law corporation Bystr FCN Co BRUCE DANNEMEYER Attorneys for plaintiff CHET K. AHN PLAINTIFF'S MOTION TO COMPEL RESPONSE TO DEMAND FOR PRODUCTION OF DOCUMENTS 2 20 21 22 23 24 25 26 27 28 MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO COMPEL RESPONSE TO DEMAND FOR PRODUCTION OF DOCUMENTS Plaintiff Chet K. Ahn respectfully submits the following points and authorities in support of his motion to compel response to the first demand for production of documents. FACTS This is a partition action regarding a home in Ladera Ranch, title of which is both parties’ names. Defendant Stephanie Van Valkenburg filed an answer to the complaint. She represents herself. On May 12, 2016, plaintiff served requests for admission, form interrogatories, special interrogatories, and demand for production of documents. Defendant did not respond to the discovery. On June 21, 2016, plaintiff's counsel mailed a meet and confer letter to defendant, pointing out that she had missed the deadline for responding to the discovery and stating unless discovery responses were received by July 11, motions to compel would be filed and sanctions sought. Defendant has not served discovery responses or responded to the June 21 meet and confer letter. A copy of the meet and confer letter is attached as exhibit A to the declaration of Bruce Dannemeyer (“Dannemeyer Dec.”). On July 13, plaintiff's counsel called defendant at the number on her answer. (Dannemeyer Dec., §2.) He left a voicemail message explaining why he was calling and asking her to return the call. (Dannemeyer Dec., 2.) As of the filing of this motion, she has not called. (Dannemeyer Dec., 2.) The demand for production of documents, a copy of which is attached as exhibit B to the Dannemeyer Declaration, concerned basic matters. They read: Demand for Production No. 1. "1. All DOCUMENTS evidencing or otherwise relating to any agreement that Stephanie Van Valkenburg (“YOU” and “YOUR?”) entered into with plaintiff Chet Ahn (“AHN”) concerning sale of the property located at 9 Citrus Lane, Ladera Ranch, California (“PROPERTY™). "2. All DOCUMENTS evidencing YOUR contention that YOU and plaintiff AHN ever registered as domestic partners. "3. All DOCUMENTS evidencing or otherwise relating to any funds that YOU placed in any joint account between YOU and plaintiff AHN. PLAINTIFF'S MOTION TO COMPEL RESPONSE TO DEMAND FOR PRODUCTION OF DOCUMENTS 3 17 18 19 20 21 22 23 24 25 26 27 28 "4. ns. "gs. "wy. ne. Hg. "10. “11; 1. "13. "14. "13 "16. Hk "18. "19. "20. All DOCUMENTS evidencing or otherwise relating to YOUR payment at any time of any loans secured by the PROPERTY. All DOCUMENTS evidencing or otherwise relating to YOUR payment at any time of any property taxes for the PROPERTY. All DOCUMENTS evidencing or otherwise relating to YOUR payment at any time of any homeowner's association dues for the PROPERTY. All DOCUMENTS evidencing or otherwise relating to YOUR payment at any time of any utilities for the PROPERTY. All DOCUMENTS evidencing or otherwise relating to YOUR payment at any time of any property insurance for the PROPERTY. All DOCUMENTS evidencing or otherwise relating to YOUR payment at any time of any maintenance costs and improvements of the PROPERTY. All DOCUMENTS evidencing or otherwise relating to YOUR contention that plaintiff AHN made reference to YOU on his taxes at any time from 2002 through the present. All DOCUMENTS evidencing or otherwise relating to YOUR contention that plaintiff AHN designated YOU as his domestic partner at any time from 1998 through the present. All DOCUMENTS evidencing or otherwise relating to YOUR contention that in 2004 YOU entered into an agreement with plaintiff AHN whereby he would work and YOU would take care of the home and the three dogs thereafter. All DOCUMENTS evidencing any employment by YOU at any time from 2002 through the present. All DOCUMENTS evidencing any income by YOU at any time from 2002 through the present. All DOCUMENTS evidencing YOUR contention that plaintiff AHN designated YOU in any capacity on his company health plan at any time. All DOCUMENTS evidencing YOUR contention that plaintiff AHN made use of YOUR credit for his benefit. All credit card statements from any time period for credit card accounts in YOUR name from which YOU contend plaintiff AHN benefited. All DOCUMENTS concerning the purchase by YOU and/or AHN of the property at 4918 Leeds Avenue, Orange, California. All DOCUMENTS concerning the sale by YOU and/or AHN of the property at 4918 Leeds Avenue, Orange, California. All DOCUMENTS concerning the joint purchase by YOU and AHN of any real property besides the PROPERTY and the property at 4918 Leeds Avenue, Orange, California. PLAINTIFF'S MOTION TO COMPEL RESPONSE TO DEMAND FOR PRODUCTION OF DOCUMENTS 4 20 21 22 23 24 25 26 27 28 "21. All DOCUMENTS concerning the joint sale by YOU and AHN of any real property] besides the PROPERTY and the property at 4918 Leeds Avenue, Orange, California.” The document demand is not oppressive or burdensome. The requests are narrowly tailored to this case, which involves a single cause of action: for partition of a home on which both parties are on title. The parties were never married, so the discovery focuses on their relationship and who paid for the acquisition and maintenance of the home. ARGUMENT 1. Responses Should be Compelled. Code of Civil Procedure section 2031.300 provides: “If a party to whom a demand for inspection ... is directed fails to serve a timely response to it, the following rules shall apply: (b) The party making the demand may move for an order compelling response to the demand.” There is no reason not to compel a response to the demand for production. There are 21 categories of documents requested, all of which bear directly on the defendant’s defenses to this action. It should be noted that there is no meet and confer requirement before this motion can be filed, since there has been no response. If there had been some response, the appropriate motion would be a motion to compel further response under Code of Civil Procedure section 2031.310. Subsection (b) requires a meet and confer declaration for such a motion. But there is no corresponding requirement for a motion to compel an initial response. Nonetheless, plaintiffs counsel did attempt to informally resolve this matter, but defendant has not even responded to the meet and confer effort. 2. Sanctions Should be Imposed. Code of Civil Procedure section 2031.300(c) reads: (c) ... the court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel a response to a demand for inspection ..., unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust.” PLAINTIFF'S MOTION TO COMPEL RESPONSE TO DEMAND FOR PRODUCTION OF DOCUMENTS 5 16 17 18 19 20 21 22 23 24 25 26 27 28 Defendant offered no excuse for failing to serve a response. Thus, there can be no substantial justification. Besides, the categories of documents are routine, not oppressive or harassing or designed to achieve anything other than obtaining information necessary to defend this action. Plaintiff has incurred $282 in costs and attorney’s fees in connection with this motion. (Dannemeyer Dec., 4.) This motion has been filed along with other, similar motions. All are scheduled to be heard on the same date. The attorney’s fees figure is just for this motion. (Dannemeyer Dec., § 4.) Therefore, sanctions of $282 should be imposed for this motion. Doing so will not duplicate the sanctions award. CONCLUSION For the foregoing reasons, this Court should compel defendant Stephanie Van Valkenburg to serve a response to the first demand for production of documents and should impose sanctions of $282, payable within 15 days. Respectfully submitted, DATED: July 21, 2016 THE DREYFUSS FIRM a professional law corporation By: we * 7 NN) AC” “BRUCE DANNEMEYER Attorneys for plaintiff CHET K. AHN PLAINTIFF'S MOTION TO COMPEL RESPONSE TO DEMAND FOR PRODUCTION OF DOCUMENTS 6 18 19 20 21 22 23 24 25 26 27 28 DECLARATION OF BRUCE DANNEMEYER IN SUPPORT OF MOTION TO COMPEL RESPONSE TO DEMAND FOR PRODUCTION OF DOCUMENTS I, Bruce Dannemeyer, declare: 1. I am an attorney at law duly licensed to practice before all California courts and am with The Dreyfuss Firm, plc, attorneys for plaintiff Chet K. Ahn. 2. Attached hereto as exhibit A is a copy of the June 21, 2016 meet and confer letter my office mailed to defendant Stephanie Van Valkenburg regarding the discovery at issue in this motion. Defendant has not served responses or responded to that letter. On July 13, 2016 at approximately 2:45 p.m., I called defendant at the number on her answer to the complaint. The call went to voicemail. I left her a message explaining who I was and that I was calling about the interrogatories, requests for admission, and demand for production of documents sent to her, as well as the June 21 letter my office mailed her. 3. On May 12, 2016, my office served by mail the first demand for production of documents attached hereto as exhibit B. 4. I am a 1982 graduate of the law school at the University of California, Berkeley (Boalt Hall). Since graduating and passing the bar in 1982, I have practiced in business litigation, practicing in Orange County since June 1987. I am familiar with the hourly rates of attorneys in Orange County. My normal hourly rate is $295. That rate is quite reasonable. I have spent .5 hour preparing this motion, and I anticipate spending another 1 hour attending the hearing on this motion. I prepared this motion on the same day I prepared the motion to compel response to form interrogatories, motion to compel response to special interrogatories, and motion to deem matters admitted. When the hearing time is divided equally among all motions, my client will have incurred attorney’s fees of $222 in connection with this motion, plus a motion filing fee of $60, for a total of $282. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed this 21% day gang 6, at Irvine, California. 7} \ ) { 7, ~ Ny Cz BRUCE DANNEMEYER PLAINTIFF'S MOTION TO COMPEL RESPONSE TO DEMAND FOR PRODUCTION OF DOCUMENTS 7 EXHIBIT “A” THE DREYFUSS FIRM a professional law corporation 2 VENTURE, SUITE 450, IRVINE, CA 92618 PHONE (949) 727-0977 - FACSIMILE (949) 450-0668 June 21, 2016 Stephanie Van Valkenburg 9 Citrus Lane Ladera Ranch, CA 92694 Re: Ahn v. Van Valkenburg Our File No. 9612-0001 Dear Ms. Van Valkenburg: Back on May 12, 2016 you were served with written discovery consisting of form interrogatories, special interrogatories, a demand for production of documents, and requests for admission. Your responses were due by June 16, 2016, 35 days thereafter, but nothing has been received as yet, and you did not request an extension. Any objections to the discovery have therefore been waived. If necessary we will file motions to compel responses to the interrogatories and demand for production, and to deem the requests for admission to be admitted. Should that be necessary, the court is obligated to order you to reimburse Mr. Ahn for the attorney’s fees and costs incurred in the bringing of those motions. We would prefer to avoid the time and expense of these motions, but will file them if we do not receive full and complete responses without objection by Monday, July 11, 2016. Very truly yours, THE DREYFUSS FIRM A Professional Law Corporation LAWRENCHJ. D USS CC: Chet Ahn EXHIBIT “B” 20 21 22 23 24 25 26 27 28 Lawrence J. Dreyfuss, Bar No. 76277 Bruce W. Dannemeyer, Bar No. 107243 THE DREYFUSS FIRM A Professional Law Corporation 2 Venture, Suite 450 Irvine, California 92618 Telephone (949) 727-0977; Facsimile (949) 450-0668 Attorneys for Plaintiff Chet K. Ahn SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ORANGE CHET K. AHN ) Case No.: 30-2016-00837367-CU-OR-CIC ) Unlimited Case Plaintiffs, ) VS. ) ) STEPHANIE VAN VALKENBURG; ) DEMAND FOR PRODUCTION OF WELLS FARGO BANK, N.A ; ) DOCUMENTS, SET ONE, PROPOUNDED AND ALL PERSONS UNKNOWN ) TO DEFENDANT STEPHANIE VAN CLAIMING ANY INTEREST IN THE ) VALKENBURG SUBJECT PROPERTY, NAMED AS DOES 1) THROUGH 50, INCLUSIVE ) ) Defendants ) ) PROPOUNDING PARTY: PLAINTIFF CHET K. AHN RESPONDING PARTY: DEFENDANT STEPHANIE VAN VALKENBURG SET NUMBER: ONE Propounding party Chet K. Ahn requests that responding party Stephanie Van Valkenburg respond to the following demand for production of documents, set no. one (1), under oath, and produce the following documents pursuant to Code of Civil Procedure section 2031.010 et seq. The documents are to be produced at The Dreyfuss Firm on June 16, 2016 at DEMAND FOR PRODUCTION OF DOCUMENTS, SET ONE 1 20 21 22 23 24 25 26 27 28 10:00 a.m., but no appearance is required if legible copies of the responsive documents are mailed by defendant and received by that time. DEFINITIONS As used in this demand for production below, “DOCUMENT” means, without limitation: documents, records, papers, books, accounts, letters, photographs, maps, memoranda, notes, tapes, electronically or magnetically recorded information, computer discs, objects or tangible things, invoices, bills of sale, and writings as evidenced in Evidence Code section 250, including handwriting, typewriting, printing, photostating, photographing and every other means of communication or representation, including letters, words, pictures, sounds, or symbols, or combinations of them, or any other records of any type which are in the possession, custody or control of the responding party and his/her/its attorney. DEMAND FOR PRODUCTION OF DOCUMENTS Demand for Production No. 1. All DOCUMENTS evidencing or otherwise relating to any agreement that Stephanie Van Valkenburg (“YOU” and “YOUR?”) entered into with plaintiff Chet Ahn (“AHN”) concerning sale of the property located at 9 Citrus Lane, Ladera Ranch, California (‘PROPERTY?”). Demand for Production No. 2. All DOCUMENTS evidencing YOUR contention that YOU and plaintiff AHN ever registered as domestic partners. Demand for Production No. 3. All DOCUMENTS evidencing or otherwise relating to any funds that YOU placed in any joint account between YOU and plaintiff AHN. Demand for Production No. 4. All DOCUMENTS evidencing or otherwise relating to YOUR payment at any time of any loans secured by the PROPERTY. Demand for Production No. 5. All DOCUMENTS evidencing or otherwise relating to YOUR payment at any time of any property taxes for the PROPERTY. DEMAND FOR PRODUCTION OF DOCUMENTS, SET ONE 2 19 20 21 22 23 24 25 26 27 28 Demand for Production No. 6. All DOCUMENTS evidencing or otherwise relating to YOUR payment at any time of any homeowner's association dues for the PROPERTY. Demand for Production No. 7. All DOCUMENTS evidencing or otherwise relating to YOUR payment at any time of any utilities for the PROPERTY. Demand for Production No. 8. All DOCUMENTS evidencing or otherwise relating to YOUR payment at any time of any property insurance for the PROPERTY. Demand for Production No. 9. All DOCUMENTS evidencing or otherwise relating to YOUR payment at any time of any maintenance costs and improvements of the PROPERTY. Demand for Production No. 10. All DOCUMENTS evidencing or otherwise relating to YOUR contention that plaintiff AHN made reference to YOU on his taxes at any time from 2002 through the present. Demand for Production No. 11. All DOCUMENTS evidencing or otherwise relating to YOUR contention that plaintiff AHN designated YOU as his domestic partner at any time from 1998 through the present. Demand for Production No. 12. All DOCUMENTS evidencing or otherwise relating to YOUR contention that in 2004 YOU entered into an agreement with plaintiff AHN whereby he would work and YOU would take care of the home and the three dogs thereafter. Demand for Production No. 13. All DOCUMENTS evidencing any employment by YOU at any time from 2002 through the present. Demand for Production No. 14. All DOCUMENTS evidencing any income by YOU at any time from 2002 through the present. DEMAND FOR PRODUCTION OF DOCUMENTS, SET ONE 3 20 21 22 23 24 25 26 27 28 Demand for Production No. 15. All DOCUMENTS evidencing YOUR contention that plaintiff AHN designated YOU in any capacity on his company health plan at any time. Demand for Production No. 16. All DOCUMENTS evidencing YOUR contention that plaintiff AHN made use of YOUR credit for his benefit. Demand for Production No. 17. All credit card statements from any time period for credit card accounts in YOUR name from which YOU contend plaintiff AHN benefited. Demand for Production No. 18. All DOCUMENTS concerning the purchase by YOU and/or AHN of the property at 4918 Leeds Avenue, Orange, California. Demand for Production No. 19. All DOCUMENTS concerning the sale by YOU and/or AHN of the property at 4918 Leeds Avenue, Orange, California. Demand for Production No. 20. All DOCUMENTS concerning the joint purchase by YOU and AHN of any real property besides the PROPERTY and the property at 4918 Leeds Avenue, Orange, California. Demand for Production No. 21. All DOCUMENTS concerning the joint sale by YOU and AHN of any real property besides the PROPERTY and the property at 4918 Leeds Avenue, Orange, California. DATED: May 12, 2016 THE DREYFUSS FIRM A Professional Law Corporation By: Lawrence J. Dreyfuss ~~ Attorneys fér Plaintiff Chet K. Ahn DEMAND FOR PRODUCTION OF DOCUMENTS, SET ONE 4 20 21 22 23 24 25 26 28 PROOF OF SERVICE (By Mail) (CCP Section 1013a(3)) I am over the age of 18, and I am not a party to the within action. I am employed by THE DREYFUSS FIRM. PLC, in the County of Orange, at 2 Venture, Suite 450, Irvine, CA 92618. On May 12, 2016, I served the attached: DEMAND FOR PRODUCTION OF DOCUMENTS, SET ONE, PROPOUNDED TO DEFENDANT STEPHANIE VAN VALKENBURG on the interested parties in this action by placing true copies thereof in sealed envelopes, addressed as follows: Stephanie Van Valkenburg 9 Citrus Lane Ladera Ranch, CA 92694 [X] (By Mail) I placed said envelopes for collection and mailing, following ordinary business practices, at the business offices of THE DREYFUSS FIRM, PLC at the address set forth above, for deposit in the United States Postal Service. I am readily familiar with the practice of THE DREYFUSS FIRM, PLC for collection and processing of correspondence for mailing with the United States Postal Service, and said envelopes will be deposited with the United States Postal Service on said date in the ordinary course of business. 1 am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. [ 1 (By Facsimile Transmission) I served the above-described document on the interested parties in this action by sending a true copy thereof by facsimile transmission pursuant to California rules of Court, Rule 2009(i)2, from facsimile machine number (949) 450-0668. The facsimile machine I used complied with California Rules of Court, Rule 2003(3), and no error was reported by the machine. Pursuant to Rule 2009(i)4, I caused the machine to print a transmission record of the transmission. I declare that I am employed in the office of a member of the Bar of this Court at whose direction the service was made. I declare, under penalty of perjury under the laws of the State of California, that the above is true and correct. Executed on May 12, 2016, at Irviney he AN Laura Claverh 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE (By Mail) (CCP Section 1013a(3)) I am over the age of 18, and I am not a party to the within action. I am employed by THE] DREYFUSS FIRM. PLC, in the County of Orange, at 2 Venture, Suite 450, Irvine, CA 92618. On July 21, 2016 I served the attached: NOTICE OF MOTION AND MOTION TO COMPEL RESPONSE TO DEMAND FOR PRODUCTION OF DOCUMENTS; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF BRUCE DANNEMEYER on the interested parties in this action by placing true copies thereof in sealed envelopes, addressed as follows: Stephanie Van Valkenburg 9 Citrus Lane Ladera Ranch, CA 92694 [X] (By Mail) I placed said envelopes for collection and mailing, following ordinary business practices, at the business offices of THE DREYFUSS FIRM, PLC at the address set forth above, for deposit in the United States Postal Service. I am readily familiar with the practice of THE DREYFUSS FIRM, PLC for collection and processing of correspondence for mailing with the United States Postal Service, and said envelopes will be deposited with the United States Postal Service on said date in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. [ 1 (By Facsimile Transmission) I served the above-described document on the interested parties in this action by sending a true copy thereof by facsimile transmission pursuant to California rules of Court, Rule 2009(i)2, from facsimile machine number (949) 450-0668. The facsimile machine I used complied with California Rules of Court. Rule 2003(3), and no error was reported by the machine. Pursuant to Rule 2009(i)4, I caused the machine to print a transmission record of the transmission. I declare that I am employed in the office of a member of the Bar of this Court at whose direction the service was made. I declare, under penalty of perjury under the laws of the State of California, that the above is true and correct. Se Executed on July 21, 2016, at Irvine, California. ¢ Laura Clawson From: donotreply@occourts.org Sent: Wednesday, July 20, 2016 4:26 PM To: Laura Clawson Subject: Superior Court of Orange County - Motion Reservation Request - CONFIRMATION Superior Court of California, County of Orange RESERVE A MOTION DATE Your reservation request has been CONFIRMED by the Superior Court. The hearing date and time below has been reserved. You will be asked to provide your reservation number to the court at a later date. MOVING PAPERS MUST BE E-FILED WITHIN 24 HOURS AFTER COMPLETING THE ON-LINE RESERVATION. Failure to submit your moving papers within 24 hours will result in the automatic CANCELLATION of the reservation. NOTE: To EXPEDITE your MOTION filing place the appropriate Court Reservation number (e.g. 7XXXXXXX) on each Motion being submitted. Please do not reply to this email. Reservation Number: 72413266 Hearing Date: September 2, 2016 Hearing Time: 10:00 AM Department: C22 Motion Type: Motion to Compel Production Case Number: 30-2016-00837367-CU-OR-CIC Case Title: Ahn vs, Van Valkenburg Judicial Officer: Hon. Deborah Servino Email: laura@dreyfusslaw.com Date of Request: July 20, 2016 Time of Request: 4:24 PM Transaction Number: 55934501 Superior Court of California » County of Orange