Motion To Compel Discovery

Motion

Cal. Super. - 4th Dist.February 14, 2017

© © 0 0 N N O O o h Ww W D N N N N N N D N D N D N N N N N M A a a d m d aa a m d e d e m e m 0 ~ N o O a A Ww W O N A O © O N O O O o h Ww W N D A John A. Mayers (CSB# 149149) Christopher B. Ghio (CSB# 259094) MULVANEY BARRY BEATTY LINN & MAYERS LLP 401 West A Street, 17th Floor San Diego, CA 92101-7994 Telephone: 619-238-1010 Facsimile: 619-238-1981 Attorneys for Plaintiff SCSF NEWCO, INC. a California corporation SUPERIOR COURT OF CALIFORNIA COUNTY OF ORANGE Plaintiff SCSF NEWCO, INC., a CASE NO. 30-2017-00903115-CU-BC-CJC California corporation, PLAINTIFF SCSF NEWCO, INC.’S NOTICE Plaintiff, OF MOTION AND MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR V. ADMISSION, SPECIAL INTERROGATORIES, AND REQUEST FOR ALETA SUTTON WILLIAMS, an PRODUCTION individual; MARK C. WILLIAMS, an individual; and DOES 1 through 10, DATE: March 19, 2018 inclusive TIME: 2:00 P.M. DEPT... C-17 JUDGE: Honorable Craig Griffin RESERVATION ID NO. 72748153 Defendant. TO: DEFENDANTS AND THEIR ATTORNEYS OF RECORD,IF ANY PLEASE TAKE NOTICE that on March 19, 2018, at 2:00 p.m., or as soon thereafter as the matter may be heard, in Department 17 of the above-entitled Court, located at 700 Civic Center Drive West, Santa Ana, California, the Honorable Craig Griffin presiding, Plaintiff SCSF NEWCO, INC., a California corporation, (“SCSF"), will move and hereby does move the Court for an order compelling Defendants ALETA SUTTON WILLIAMS, an individual and MARK C. WILLIAMS, an individual (“Responding Party”) to provide further responses to Request for Admission (Set One), Special Interrogatories (Set One), and Request for Production of Documents (Set One) propounded by SCSF on August 29, 2017 and requiring Responding Party to pay 1 NOTICE OF MOTION AND MOTIONQT144 RRRA17 1 M U L V A N E Y B A R R Y B E A T T Y L I N N & M A Y E R S L L P A T T O R N E Y S A T L A W 40 1 W E S T A ST RE ET , 17 TH F L O O R S A N DI EG O, CA LI FO RN IA 92 10 1- 79 44 T E L E P H O N E 61 9- 23 8- 10 10 FA CS IM IL E 61 9- 23 8- 19 81 appropriate monetary sanctions. This Motion is made on the grounds that said discovery is relevant to the subject matter of this action, does not relate to privileged matters and that Responding Party refusal to provide substantive responses (without objection) is without substantial justification. SCSF is entitled to an order compelling Responding Party to provide verified further responses to the written discovery requests, without objections. Furthermore, sanctions should be awarded to SCSF and against Responding Party, in the amount of $5,842.00 for time spentfor the preparation of this Motion and attendance at the hearing, and $60.00 for the costs associated with the Motion, for a total of $5,782.00. This Motion is made and based upon this Notice of Motion, the Declaration of Christopher B. Ghio, Separate Statement, the Memorandum of Points of Authorities, the Notice of Lodgment, the pleadings, documents, records and files herein, and upon such oral and documentary evidence as may be presented at the hearing on this Motion or of which the Court may take judicial notice. MULVANEY BARRY BEATTY LINN & MAYERS LLP DATED:February 2, 2018 a By’ ristopher B. Ghio Attorneys for Plaintiff SCSF NEWCO, INC, a California corporation 2 NOTICE OF MOTION AND MOTIONSTC 144 RRRA17 1