Order_proposed_re_motion_to_compel_re_rfa1

Motion

Cal. Super. - 2nd Dist.March 2, 2018

OO 0 ON O N nn BA W N 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES NEW LINE MARKETING, INC., Plaintiff, V. REBECCA ALDABERT, Defendant. N r ” N r ” N r ” w r ’ w r ’ a a a a ’ El ec tr on ic al ly R e c e i v e d 0 2 / 0 7 / 2 0 1 9 11 :1 8 Case No. BC696378 HONORABLE JUDGE MICHAEL L. STERN [PROPOSED] ORDER RE NEW LINE MARKETING, INC.’S MOTION TO COMPEL FURTHER RESPONSES TO FIRST SET OF REQUESTS FOR ADMISSION TO DEFENDANT REBECCA ALDABERT AND REQUEST FOR MONETARY SANCTIONS DATE: February 15,2019 TIME: 8:30 a.m. DEPT: 62 RES. ID: 327080806407 On February 15, 2019, at about 8:30 a.m., or as soon thereafter as the matter could be heard, in Department 62, of the above entitled Court, Plaintiff New Line Marketing, Inc. (“New Line”) Motion to Compel Further Responses to New Line's First Set of Requests for Admission and Request for Monetary Sanctions (the “Motion”), came on for hearing. Both parties were represented by counsel. After considering all papers filed on this matter, and having heard from all counsel, the Court finds good cause exists to grant the Motion. Therefore, the Court ORDERS as follows: A. Defendant Rebecca Aldabert, shall serve, via electronic service, by no later than close of business on March 1, 2019, complete and straightforward, answers to each and every Request for Admission at issue, as set forth in the New Line’s Separate Statement, without objection; and [PROPOSED] ORDER RE NEW LINE’S MOTION TO COMPEL RE RFA #1 AND SANCTIONS OO 0 9 OO wn BA W O N N D N N N N N N N N N N O N = o e m e m e m e m p m p d p m p d pe 0 9 A N n n BA W N D = O V N N ERE W N D - = B. Defendant Rebecca Aldabert, Evan Cote (of Coast Litigation), and Scott Feig (of the Feig Law Firm), shall be joint and severally liable for, and shall pay to New Line, in the name of its attorney’s client trust account — Tovar & Cohen Attorney-Client Trust Account — monetary sanctions totaling $4,961.65. Payment of sanctions shall be made by no later than March 15, 2019. IT IS SO ORDERED. DATED: February _, 2019 By THE HONORABLE MICHAEL L. STERN, JUDGE, LOS ANGELES SUPERIOR COURT Respectfully submitted, TOVAR & COHEN, LLP By: Pr ‘ sw RENE TOVAR Attorneys for Plaintiff New Line Marketing, Inc. [PROPOSED] ORDER RE NEW LINE’S MOTION TO COMPEL RE RFA #1 AND SANCTIONS OO 0 ON Oo wn BA W o o d = N O N N N N N O N N N e m e m e m e m e m e m e e e e 0 J A N Un BRE W N , D O O N N N R E W I N D = O PROOF OF SERVICE CCP 1013(a) STATE OF CALIFORNIA, 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 5525 Oakdale Avenue, Suite 350, Woodland Hills, California 91364. On February 7, 2019, I served the foregoing document described as [PROPOSED] ORDER RE NEW LINE MA TING, INC.’S MOTION TO COMPEL FURTHER RESPONSES TO FIRST SET OF REQUESTS FOR ADMISSION TO DEFENDANT REBECCA ALDABERT AND REQUEST FOR MONETARY SANCTIONS in this action. by placing the true copies thereof enclosed in sealed envelopes addressed as stated on the attached mailing list. by ening __ the original _X_ a true copy of the above referenced document via email (as on een by California Rules of Court, Rule 2.251(b)(1)(B), to the addressee(s) below as ollows: Scott Feig, Esq. (of Feig Law Firm) at: feiglawfirm@gmail.com Evan Cote, Esq. (of Coast Litigation) at: evan@coastlitigation.com X BY E-Mail as authorized by CRC, Rules 2.251.(b)(1)(B) BY MAIL I am “readily familiar” with the firm's practice of collection and processing correspondence for mailing. Under that practice it would be deposited with United States Postal Service on that same day with postage thereon fully prepaid at Los Angeles, California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation or postage meter date is more than one day after date of deposit for mailing in affidavit. BY PERSONAL SERVICE. I delivered such envelope by hand to the offices of the addressee. Executed on February 7 2019, in the County of Los Angeles, State of California. STATE I declare under penalty of perjury under the laws of the State of California that the above is true and correct. ee or RENE TOVAR rk [PROPOSED] ORDER RE NEW LINE’S MOTION TO 1 COMPEL RE RFA #1 AND SANCTIONS