Motion StrikeCal. Super. - 3rd Dist.January 15, 2014al P o o - 1 2 5 4 5 6 a 8 9 10 Ll tz 13 14 18 19 20 21 22 23 24 2 26 Pai 28 15 16 47 oO 6018-100470324 2017100409:92 Page 2ofik__ NANCY Q. SU, SBN 279714 as ELE Dawn __ | RESURGENCE LEGAL GROUP, PC SUPE PLACER || 10805 Holder Street, Suite 203 cour Cypress, CA 90630 OCT 05 2017 ‘|| C1) 877/440-0860 (F) 714/226-0024 - JAKE CHATTERS EMAIL: CAAttorney@ ResurgenceLegal.com EXECUTIVE OFFICER & CLERK By: C. Vallan-Brown, Deputy || Refer to File Number: CA034719 CAND | Attorney for Plaintiff SUPERIOR COURT OF CALIFORNIA COUNTY OF PLACER, PLACER JUDICIAL DISTRICT BILL SANTUCCI JUSTICE CENTER RESURGENCE CAPITAL, LLC, Plaintitt CASE NO.: MCV0060300 NOTICE OF MOTION AND MOTION TO v. STRIKE ANSWER PURSUANT TO CODE ENCHANTED E DOUTHERD A/K/A ENCHANTED E DOUTHERD BODINE A/K/A ENCHANTED DOUTHEREDBODIN, and DOES 1 through 15 inclusive Defendant(s). 2023.030, 2030.010, 2030.300 DATE: November 2, 2017 TIME: 8:30 a.m. DEPT: 32 COMPLAINT FILED: January 15, 2014 a d N a e N e ee ? Se rr ea e? Ne st e! ae ! en n” Se re ! St eg S e ” Se e! ee e? S e e ” TO DEFENDANT ENCHANTED E DOUTHERD A/K/A ENCHANTED E DOUTHERD BODINE A/K/A ENCHANTED DOUTHEREDBODIN: PLEASE TAKE NOTICE that on October 26, 2017 at 8:30 a.m. or as soon thereafter as the matter can be heard in Department 32 of the above-entitled court, located at 10820 JUSTICE CENTER DRIVE, ROSEVILLE, CA 95678RESURGENCE CAPITAL, LLC (hereinafter "Plaintiff"), will move the Court for an order striking the answer of Defendant, ENCHANTED E DOUTHERD A/K/A ENCHANTED E DOUTHERD BODINE A/K/A ENCHANTED DOUTHEREDBODIN (hereinafter “Defendant"), and entering their default. This Motion to Strike Defendant's Answer is based on: (1) Defendant's failure to respond to Plaintiff's discovery requests; 1 NOTICE OF MOTION ‘AND MOTION TO'STRIKE ANSWER PURSUANT TO CODE OF CIVIL PROCEDURE, §3 7998-010, 2023.030, OF CIVIL “PROCEDURE "§ 2023.010,--°- cra c o O D D D H h RF YW Bw 10 ¢ ~ 6018-100470324 2017160409:02 Page 3 of 16... 5 (2) Defendant's failure to comply with the Tentative Ruling issued on August 9, 2017, ordering Defendant to respond to the discovery Form Interrogatories and Request for Production of Documents without objection or claim of privilege or work product, to Form Interrogatories and Request for Production of Documents; This Motion will be based on this Notice, the Declaration of Plaintiffs Counsel, the Memorandum of Points and Authorities attached hereto, the records and papers on file herein, and on such other evidence, both oral and documentary, as may be presented at the time of the hearing of this Motion. Dated: October 4, 2017 RESURGENCE LEGAL GROUF, PC By: ho NANCY Q. SU, SBN 279714 ooo “Attorney for Plaintiff ~~ NOTICE OF MOTION AND MUON TO STRIKE ANSWER PURSUANT TO CODE OF CIVIL PROCEDURE §8,2093.010, 2023.030,
