On March 28, 2016 a
Party Discovery
was filed
involving a dispute between
Lopez-Burton, Christina,
and
Town Of Apple Valley, A General Law City,
for Writ of Mandate
in the District Court of San Bernardino County.
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1 Eric J Benink Esq SBN 187434 eEqNa FOR A
NO p
erice
kkbs law com NO
2 V D Slavens SBN 217132
ncent Esq
vslavens a kkbs law com 2416
3 KRAUSE KALFAYAN BENINK SLAVENS LLP
550 West C Street Suite 530 Rq
4 San Diego CA 92101 QqE
619 232 0331 ph oFP
s
619 232 4019 fax
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Attorneys for Petitioner and Plaintiff
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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FOR THE COUNTY OF SAN BERNARDINO
lo CH RISTINA LOPEZ BURTON Case No CIVDS1604968
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Assigned to Hon Gilbert G Ochoa
12 Petitioner and Plaintiff PETITIONER AND PLAINTIFF
CHRISTINA LOPEZ BURTON S
13
NOTICE OF MOTION AND MOTION TO
COMPEL RESPONSES TO REQUESTS
19
FOR PRODUCTION OF DOCUMENTS
is
TOWN OF APPLE VALLEY a general law
DATE December 27 2016
16 city and DOES l 10
TIME 8 30 a m
DEPT S33
i
ia Respondents and Defendants
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TO THE COURT AND ALL PARTIES AND THEIR ATTORNEYS OF RECORD
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NOTICE IS HEREBY GIVEN that on December 27 2016 at 8 30 a m in Department
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S33 of the Superior Court of California for the County of San Bernardino 247 West Third
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Street San Bernardino CA 92415 the Honorable Gilbert G Ochoa presiding Petitioner and
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Plaintiff Christina Lopez Burton will move and hereby does move the Court pursuant to Code
26
Civil Procedure 2031 300 d
of section subdivision
for an order compelling Respondent and
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Defendant Town of Apple Valley Town to serve responses to Lopez Burton s Requests for
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Production of Documents Set No 1 RPDs without objection Lopez Burton also seek
Notice ofMotion toCompel Case CIVDS1604968
i monetary sanctions in the amount of 1 460 against the Town pursuant to Code of Civil
2 Procedure section 2031 300 subdivision c
3 This motion is based on the fact that Burton Lopez propounded the RPDs to the Town
4 on August 25 2016 and the Town has failed to serve any responses As set forth in the
5 Declaration of Eric J Benink filed herewith Lopez Burton s counsel inquired about the failure
6 to respond but received has no explanation from the Town s counsel
This motion is based on this notice of motion the memorandum of points and authorities
8
filed herewith the Declaration of Eric J Benink filed herewith and any other evidence or
9
argument that the court receives at the hearing on this matter
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ii
12 November 9 2016 KRAUSE KALFAYAN BENINK
DATED
SLAVENS LLP
13
14 y f
c t
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Eric J Benink Esq
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Attorneys for Petitioner Plaintiff
i
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2
Notice of MotiontoCompei Case CIVDS 1604968
Document Filed Date
November 09, 2016
Case Filing Date
March 28, 2016
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Preview
y mp 11 U p 1 Eric J Benink Esq SBN 187434 eEqNa FOR A NO p erice kkbs law com NO 2 V D Slavens SBN 217132 ncent Esq vslavens a kkbs law com 2416 3 KRAUSE KALFAYAN BENINK SLAVENS LLP 550 West C Street Suite 530 Rq 4 San Diego CA 92101 QqE 619 232 0331 ph oFP s 619 232 4019 fax 6 Attorneys for Petitioner and Plaintiff 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF SAN BERNARDINO lo CH RISTINA LOPEZ BURTON Case No CIVDS1604968 11 Assigned to Hon Gilbert G Ochoa 12 Petitioner and Plaintiff PETITIONER AND PLAINTIFF CHRISTINA LOPEZ BURTON S 13 NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO REQUESTS 19 FOR PRODUCTION OF DOCUMENTS is TOWN OF APPLE VALLEY a general law DATE December 27 2016 16 city and DOES l 10 TIME 8 30 a m DEPT S33 i ia Respondents and Defendants 19 20 TO THE COURT AND ALL PARTIES AND THEIR ATTORNEYS OF RECORD 21 22 NOTICE IS HEREBY GIVEN that on December 27 2016 at 8 30 a m in Department 23 S33 of the Superior Court of California for the County of San Bernardino 247 West Third 24 Street San Bernardino CA 92415 the Honorable Gilbert G Ochoa presiding Petitioner and z5 Plaintiff Christina Lopez Burton will move and hereby does move the Court pursuant to Code 26 Civil Procedure 2031 300 d of section subdivision for an order compelling Respondent and 27 Defendant Town of Apple Valley Town to serve responses to Lopez Burton s Requests for 28 Production of Documents Set No 1 RPDs without objection Lopez Burton also seek Notice ofMotion toCompel Case CIVDS1604968 i monetary sanctions in the amount of 1 460 against the Town pursuant to Code of Civil 2 Procedure section 2031 300 subdivision c 3 This motion is based on the fact that Burton Lopez propounded the RPDs to the Town 4 on August 25 2016 and the Town has failed to serve any responses As set forth in the 5 Declaration of Eric J Benink filed herewith Lopez Burton s counsel inquired about the failure 6 to respond but received has no explanation from the Town s counsel This motion is based on this notice of motion the memorandum of points and authorities 8 filed herewith the Declaration of Eric J Benink filed herewith and any other evidence or 9 argument that the court receives at the hearing on this matter io ii 12 November 9 2016 KRAUSE KALFAYAN BENINK DATED SLAVENS LLP 13 14 y f c t 15 Eric J Benink Esq 16 Attorneys for Petitioner Plaintiff i 18 19 20 21 22 23 24 25 26 27 28 2 Notice of MotiontoCompei Case CIVDS 1604968