Motion-Secondary: FELIPE RODRIGUEZ, ET AL. VS 1401 CAMDEN INC. ASSOCIATION

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 12/27/2022 05:31 PM Sherri R. Carter, Executive Officer/Clerk of Court, by C. Meeks,Deputy Clerk




                        1      Barry A. Ross, Esq. (SBN 58166)
                               Barry A. Ross, A Professional Corporation
                        2      23161 Mill Creek Drive, Suite 300
                        3      Laguna Hills, California 92653
                               Phone: (949) 544-7585
                        4      Fax: (949) 264-1133
                               Email: barry@rossrealestatelaw.com
                        5
                        6      Attorney for Plaintiffs Felipe Rodriguez and
                               Mary Barrett, husband and wife
                        7
                        8                                       SUPERIOR COURT OF STATE OF CALIFORNIA
                        9                 FOR THE COUNTY OF LOS ANGELES – BEVERLY HILLS COURTHOUSE
                       10
                       11      FELIPE RODRIGUEZ and MARY                                              )   Case No. 20SMCV01043
                               BARRETT, husband and wife,                                             )   Assigned for all purposes to the Honorable
                       12                                                                             )   Judge Helen Zukin
                       13                             Plaintiffs,                                     )   Dept. 207
                                                                                                      )   Unlimited Jurisdiction
                       14                                                                             )
                                          vs.                                                         )   PLAINTIFFS’ CONSOLIDATED
                       15                                                                                 OPPOSITION TO THE THREE (3)
                                                                                                      )   MOTIONS BY DEFENDANT 1401
                       16                                                                             )   CAMDEN INC. FOR AN ORDER
                               1401 CAMDEN INC. ASSOCIATION, a                                        )   COMPELLING (A) FURTHER
                       17      California non-profit mutual benefit                                   )   PRODUCTION OF DOCUMENTS AT
                               corporation, and Does 1 to 30, inclusive,                              )   DEPOSITION, (B) FURTHER
                       18                                                                                 RESPONSES TO DEPOSITION
                                                                                                      )   QUESTIONS, AND (C) REQUEST FOR
                       19                             Defendants.                                     )   MONETARY SANCTIONS OF $1750
                                                                                                      )   PER MOTION AGAINST PLAINTIFFS
                       20                                                                             )   AND THEIR COUNSEL AND THE
                                                                                                          COSTS ASSOCIATED WITH
                                                                                                      )   COMPELLING THE DEPOSITIONS;
                       21
                                                                                                      )   MEMORANDUM OF POINTS AND
                       22                                                                             )   AUTHORITIES; DECLARATION OF
                                                                                                      )   FELIPE RODRIGUEZ; DECLARATION
                       23                                                                             )   OF BARRY A. ROSS; AND REQUEST
                                                                                                          FOR SANCTIONS OF $4800;
                       24                                                                             )   [PROPOSED] ORDER
                                                                                                      )
                       25                                                                             )   Hearing Date: January 10, 2023
                                                                                                      )   Time:         8:30 a.m.
                       26                                                                                 Dept.:        207
                                                                                                      )
                       27                                                                             )
                                                                                                      )   Complaint Filed: August 6, 2020
                       28                                                                                 Trial Date: January 30, 2023


                                 PLAINTIFFS’ CONSOLIDATED OPPOSITION TO THE THREE (3) MOTIONS BY
                                                   DEFENDANT 1401 CAMDEN INC.
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