Order Proposed Order Granting Plaintiffs Motion To Compel Further Responses To Special Interrogatories Set One

Motion

Cal. Super. - 2nd Dist.February 22, 2018

El ec tr on ic al ly Re ce iv ed 03 /0 8/ 20 19 12 :4 4 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STANLEY D. SALTZMAN (SBN: 90058) STEPHEN P. O’DELL (SBN: 132279) MARLIN & SALTZMAN, LLP 29800 Agoura Road, Suite 210 Agoura Hills, California 91301 (818) 991-8080; Fax: 991-8081 PETER M. HART (SBN: 198691) ASHLIE E. FOX (SBN: 294407) LAW OFFICES OF PETER M. HART 12121 Wilshire Blvd., Suite 725 Los Angeles, California 90025 (310) 207-2277; Fax (509) 561-6441 Attorneys for Plaintiff, SCOTT TARTER SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES - CENTRAL DIVISION SCOTT TARTER, for himself and for all other current and former aggrieved California employees, Plaintiff, Vs. SOUTH EAST PERSONNEL LEASING, INC.; and DOES 1 to 100, inclusive, Defendants. Case No. BC694862 (Assigned for all purposes to: Hon. Stuart M. Rice, Judge, Dept. 49) [PROPOSED] ORDER GRANTING PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES SET ONE DATE : June 6, 2019 TIME : 8:30 a.m. DEPT. : 49 RESERVATION ID: 311367817495 Action Filed: February 22, 2018 Trial Date: ~~ None Set J [Proposed] Order Granting Plaintiff’s Motion to Compel Further Responses to Special Interrogatories Set One 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Plaintiff’s Motion to Compel Further Responses to Special Interrogatories Set One came on for hearing, as calendared, before this Court. Plaintiff was represented by and through its counsel of record, Marlin & Saltzman, LLP. South East Personnel Leasing, Inc. was represented by and through its counsel of record, Gordon, Rees, Scully, Mansukhani, LLP. Having read and considered the motion, opposition, and reply papers, and having received the oral argument of counsel, the Court hereby rules as follows: IT IS ORDERED THAT: Plaintiff’s Motion to Compel Further is granted. SoCal South is hereby ordered to provide further responses to Plaintiff’s Special Interrogatories, Set One, Nos. 1-3, consisting of substantive answers, without objections, and that comply in all other respects I do I'm discussing it up and I will release to you right now with the requirements of the Code of Civil Procedure, within ten (10) days from the date this order is signed. Dated: Honorable Stuart M. Rice JUDGE OF THE SUPERIOR COURT FOR THE COUNTY OF LOS ANGELES B. [Proposed] Order Granting Plaintiff’s Motion to Compel Further Responses to Special Interrogatories Set One 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STATE OF CALIFORNIA ) ) ss. COUNTY OF LOS ANGELES ) I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action. My business address is 29800 Agoura Road, Suite 210, Agoura Hills, California 91301. On March 8, 2019, I served the foregoing document described as [PROPOSED] ORDER GRANTING PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES SET ONE on all interested parties in said action: SEE ATTACHED SERVICE LIST [X] (VIA US MAIL) I caused such envelope(s) to be deposited in the mail at Agoura Hills, California with postage thereon fully prepaid. I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. It is deposited with the U.S. Postal Service on that same day in the ordinary course of business. I am aware that on motion of 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] (VIA FEDERAL EXPRESS) I caused to have served such document(s) by depositing them in the drop box at Agoura Hills, California, for priority overnight next day delivery. [1] (VIA FACSIMILE) I caused such document to be faxed to the persons identified with fax numbers on the attached Mailing List. [1] (VIA PERSONAL SERVICE) I delivered such envelope(s) by hand to the offices of the addressee. [1] (VIA E-MAIL) I caused to have such documents sent by electronic service [Fed. Rule Civ. Proc. Rule 5(b)(2)(a)] by electronically mailing a true and correct copy through Marlin & Saltzman’s electronic mail system to the e-mail address(s) set forth below, or as stated on the attached service list per agreement in accordance with Federal Rules of Civil Procedure rule 5(b). [X] (STATE) I declare under penalty of perjury under the laws of the State of California that the above is true and correct. [1] (FEDERAL) 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. Executed on March 8, 2019, at Agoura Hills, California. 3. [Proposed] Order Granting Plaintiff’s Motion to Compel Further Responses to Special Interrogatories Set One 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Scott Tarter v. South East Personnel Leasing LASC Case No. BC694862 Service List Roger M. Mansukhani, Esq. Eric R. Deitz, Esq. Amanda K. Mayo, Esq. GORDON REES SCULLY MANSUKHANI LLP 633 W. Fifth Street, Suite 5200 Los Angeles, CA 90071 Telephone: (213) 576-5000 Facsimile: (213) 680-4470 edeitz@grsm.com amayo(@grsm.com Attorneys for Defendant South East Personnel Leasing, Inc. Peter M. Hart, Esq. Ashlie E. Fox LAW OFFICES OF PETER M. HART 12121 Wilshire Blvd., Suite 725 Los Angeles, CA 90025 Telephone: (310) 207-0109 Facsimile: (509) 561-6441 hartpeter@msn.com ashlie.fox.loph@gmail.com Co-Counsel for Plaintiff 4- [Proposed] Order Granting Plaintiff’s Motion to Compel Further Responses to Special Interrogatories Set One