On May 09, 2018 a
Party Discovery
was filed
involving a dispute between
Martin-Brown, Lawanna,
and
California Schools Risk Management Jpa,
Donahue, Stephen,
San Bernardino City Unified School District,
for PI Motor Vehicle
in the District Court of San Bernardino County.
Preview
i
suP iaR cau r oF c i oRr i
couNrY oF s e rv aRraer o
SAN i3ER F 3 DISTRit T
1 RY v D MiLr Ex SBN 256799
CUMMINGS MCCLOREY DAVIS ACHO c ASSOCIATES P C MAR 2 1 2019
2
3801 University Avenue Suite 560
Riverside CA 92501 gr
3
SAP ANT iF P ci i o
951 276 4420
4 951 276 4405 fax
EXEMPT PER GOV CODE 6103
5
Attorneys for Defendants
6 San Bernardino City Unified School District
California Schools Risk Management JPA Stephen Donahue
7
g SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF SAN BERNARDINO
10
w NA MARTIN BROWN Case No CIVDS1811454
11
individually
12
Plaintiffs DEFENDANT S SEPARATE
13 STATEMENT IN SUPPORT OF
14
FURTHER RESSONSES TO REQUES S
15 SAN BERNARDINO CITY UlvIFIED FOR PRODUCTION SET ONE AND
SCHOOL DISTRICT CALIFORNIA FOR SANCTIONS
16 SCHOOLS RISK MANAGEMENT JPA
STEPHEN DONAHUE and DOES 1 25 Date April 23 2019
17
Inclusive Time 8 30 a m
18 Dept S30
Defendants
19
1
20
21 This Separate Statement is submitted in support of Defendants SAN BERNARDINO
22 CITY UNIFIED SCHOOL DISTRICT s Motion to Compel Plaintiff LAWANNA MARTIN
23
BROWN Further Responses to its Requests for Production Set One and for Sanctions against
24 Plaintiff her
and counsel of record As required under California Rules of Court 3 1345 this
25
statement provides information relating to the discovery requests and responses at issue in the
26 motion as follows
27
28
Cummings McClorey
Davis Acho
Associates P C
3801 University Avenue 1
Suite 560
a eTSde cn 9zsot
Telephone 951 276 4420 SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO
Fa S ie 9si z 6 aaos
REQUEST FOR PRODUCTION OF DOCjJMENTS SET ONE
1 REQUEST FOR PRODUCTION NO 2
2 The Government Tort Claims YOU submitted to Defendant pursuant to Government Code
3 911 2 for any and all injuries YOU claim YOU sustained as a result of the SUBJECT
4 INCIDENT
5 RESPONSE TO REOUEST FOR PRODUCTION NO 2
6 OBJECTION This interrogatory is objected to on the grounds it is irrelevant vague and
7 ambiguous overbroad and not reasonably calculated to lead to the discovery of admissible
8 evidence This discovery request is in violation of Plaintiffs constitutionally protected right to
9 privacy under Article I section Iof the California Constitution Vinson v Superior Court 1987
10 43 Cal 3d 833 842 and Davis v Superior Court 1992 7 Ca1 App 4th 1008 1014 1016
11 However the asserted objections do not necessarily mean or imply that such information exists
12 Overbroad and calls for a narrative that would include all the evidence that plaintiff may present
13 at trial Flora Crane Services Inc v Superior Court 1965 234 Ca1 App 2d 767 SavOn Drugs
14 Inc v Superior Court 1975 15 Ca1 3d 1 Burke v Superior Court 1969 71 Ca1 2d 276 Synder
15 v Superior Court 2007 157 Ca1 App 4th 1530 Ciry ofLong Beach v Superior Court 1976 64
16 Ca1 App 3d 65
17 SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO 2
18 OBJECTION This interrogatory is objected to on the grounds it is irrelevant vague and
19
ambiguous overbroad and not reasonably calculated to lead to the discovery of admissible
20 evidence This discovery request is in violation of Plaintiff s constitutionally protected right to
21 privacy under Article I section Iof the California Constitution Vinson v Superior Court 1987
22 43 Ca1 3d 833 842 and Davis v Superior Court 1992 7 Cal App 4th 1008 1014 1016
23
However the asserted objections do not necessarily mean or imply that such information exists
24
Overbroad and calls for a narrative that would include all the evidence that plaintiff may present
25 at trial Flora Crane Services Inc v Superior Court 1965 234 Ca1 App 2d 767 Sav On Drugs
26 Inc v Superior Court 1975 15 Ca1 3d 1 Burke v Superior Court 1969 71 Cal 2d 276 Synder
27 v Superior Court 2007 157 Ca1 App 4th 1530 City of Long Beach v Superior Court 1976 64
28 Cal App 3d 65 Without waiving the
foregoing or
any other objections
Responding Party
Cummings McCbrey
Davis Acho
Associates P C
3801 University Avenue 2
Suite 560
Riverside cn92sot
Telephone 951 276 4420 SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO
Facsimile 951 276 4405 REQUEST FOR PRODUCTION OF DOCUMENTS SET ONE
Document Filed Date
March 21, 2019
Case Filing Date
May 09, 2018
Category
PI Motor Vehicle
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i suP iaR cau r oF c i oRr i couNrY oF s e rv aRraer o SAN i3ER F 3 DISTRit T 1 RY v D MiLr Ex SBN 256799 CUMMINGS MCCLOREY DAVIS ACHO c ASSOCIATES P C MAR 2 1 2019 2 3801 University Avenue Suite 560 Riverside CA 92501 gr 3 SAP ANT iF P ci i o 951 276 4420 4 951 276 4405 fax EXEMPT PER GOV CODE 6103 5 Attorneys for Defendants 6 San Bernardino City Unified School District California Schools Risk Management JPA Stephen Donahue 7 g SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF SAN BERNARDINO 10 w NA MARTIN BROWN Case No CIVDS1811454 11 individually 12 Plaintiffs DEFENDANT S SEPARATE 13 STATEMENT IN SUPPORT OF 14 FURTHER RESSONSES TO REQUES S 15 SAN BERNARDINO CITY UlvIFIED FOR PRODUCTION SET ONE AND SCHOOL DISTRICT CALIFORNIA FOR SANCTIONS 16 SCHOOLS RISK MANAGEMENT JPA STEPHEN DONAHUE and DOES 1 25 Date April 23 2019 17 Inclusive Time 8 30 a m 18 Dept S30 Defendants 19 1 20 21 This Separate Statement is submitted in support of Defendants SAN BERNARDINO 22 CITY UNIFIED SCHOOL DISTRICT s Motion to Compel Plaintiff LAWANNA MARTIN 23 BROWN Further Responses to its Requests for Production Set One and for Sanctions against 24 Plaintiff her and counsel of record As required under California Rules of Court 3 1345 this 25 statement provides information relating to the discovery requests and responses at issue in the 26 motion as follows 27 28 Cummings McClorey Davis Acho Associates P C 3801 University Avenue 1 Suite 560 a eTSde cn 9zsot Telephone 951 276 4420 SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO Fa S ie 9si z 6 aaos REQUEST FOR PRODUCTION OF DOCjJMENTS SET ONE 1 REQUEST FOR PRODUCTION NO 2 2 The Government Tort Claims YOU submitted to Defendant pursuant to Government Code 3 911 2 for any and all injuries YOU claim YOU sustained as a result of the SUBJECT 4 INCIDENT 5 RESPONSE TO REOUEST FOR PRODUCTION NO 2 6 OBJECTION This interrogatory is objected to on the grounds it is irrelevant vague and 7 ambiguous overbroad and not reasonably calculated to lead to the discovery of admissible 8 evidence This discovery request is in violation of Plaintiffs constitutionally protected right to 9 privacy under Article I section Iof the California Constitution Vinson v Superior Court 1987 10 43 Cal 3d 833 842 and Davis v Superior Court 1992 7 Ca1 App 4th 1008 1014 1016 11 However the asserted objections do not necessarily mean or imply that such information exists 12 Overbroad and calls for a narrative that would include all the evidence that plaintiff may present 13 at trial Flora Crane Services Inc v Superior Court 1965 234 Ca1 App 2d 767 SavOn Drugs 14 Inc v Superior Court 1975 15 Ca1 3d 1 Burke v Superior Court 1969 71 Ca1 2d 276 Synder 15 v Superior Court 2007 157 Ca1 App 4th 1530 Ciry ofLong Beach v Superior Court 1976 64 16 Ca1 App 3d 65 17 SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO 2 18 OBJECTION This interrogatory is objected to on the grounds it is irrelevant vague and 19 ambiguous overbroad and not reasonably calculated to lead to the discovery of admissible 20 evidence This discovery request is in violation of Plaintiff s constitutionally protected right to 21 privacy under Article I section Iof the California Constitution Vinson v Superior Court 1987 22 43 Ca1 3d 833 842 and Davis v Superior Court 1992 7 Cal App 4th 1008 1014 1016 23 However the asserted objections do not necessarily mean or imply that such information exists 24 Overbroad and calls for a narrative that would include all the evidence that plaintiff may present 25 at trial Flora Crane Services Inc v Superior Court 1965 234 Ca1 App 2d 767 Sav On Drugs 26 Inc v Superior Court 1975 15 Ca1 3d 1 Burke v Superior Court 1969 71 Cal 2d 276 Synder 27 v Superior Court 2007 157 Ca1 App 4th 1530 City of Long Beach v Superior Court 1976 64 28 Cal App 3d 65 Without waiving the foregoing or any other objections Responding Party Cummings McCbrey Davis Acho Associates P C 3801 University Avenue 2 Suite 560 Riverside cn92sot Telephone 951 276 4420 SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO Facsimile 951 276 4405 REQUEST FOR PRODUCTION OF DOCUMENTS SET ONE