Esther Tendo Atam
13621 Arcturus Ave.
Gardena, CA 90249
Natashchan1@yahoo.com
Plaintiff in Pro Per
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES
ESTHER TENDO ATAM,
Plaintiff
vs.
SOUTHERN CALIFORNIA PERMANENTE
MEDICAL GROUP (SCPMG), A
CALIFORNIA CORPORATION, ET AL., et
al.
Defendants
Case No.: 22STCV37929
NOTICE OF MOTION TO COMPEL
FURTHER DISCOVERY
Judge: Elaine Lu
Dpt.: 26
Hearing Date:
TO THE SUPERIOR COURT, TO DEFENDANTS, AND TO THEIR
ATTORNEYS OF RECORD AND TO HON. ELAINE LU:
NOTICE IS HEREBY GIVEN that on ________________________ at _________.M.,
or as soon after that as the matter can be heard, in Dept. 26 of the above-entitled Court located at
111 North Hill Street, Los Angeles, CA 90012, Plaintiff, Esther Tendo Atam (“Plaintiff”), will
move the Court for an order compelling the Defendant to provide full, complete, and straight
forward responses to Plaintiff’s Discovery Requests without objections as set forth herein.
This motion will be based on the grounds that Defendant has failed to comply with
Plaintiff regarding the First Set of Discovery Request, and sent Plaintiff false and/or fraudulent
records, as alleged herein.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
2
MOTION TO COMPEL FURTHER DISCOVERY
Further, the motion will be based on this Notice of Motion the Motion itself and the
averments therein, on any records and files already filed in this case, and on such evidence as
may be presented at the hearing of the motion.
Dated:
Respectfully submitted,
________________________________
Esther Tendo Atam
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
3
MOTION TO COMPEL FURTHER DISCOVERY
Esther Tendo Atam
13621 Arcturus Ave.
Gardena, CA 90249
Natashchan1@yahoo.com
Plaintiff in Pro Per
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES
ESTHER TENDO ATAM,
Plaintiff
vs.
SOUTHERN CALIFORNIA PERMANENTE
MEDICAL GROUP (SCPMG), A
CALIFORNIA CORPORATION, ET AL., et
al.
Defendants
Case No.: 22STCV37929
MOTION TO COMPEL FURTHER
DISCOVERY
Judge: Elaine Lu
Dpt.: 26
Hearing Date:
COMES NOW, Plaintiff ESTHER TENDO ATAM, pro se, pursuant to Code of Civil
Procedure sections 2023.010, et seq. and 2031.210, et seq., and hereby moves this Court for an
Order to Compel the Defendant to strictly comply with Plaintiff’s Discovery Requests as alleged
herein.
Pursuant to CCP 2031.310(a), Plaintiff is entitled to move this Court to compel the
production of documents or things if the Defendant’s response (1) agrees to comply, but
compliance is incomplete, (2) the responding party’s indication of inability to comply is
incomplete, inadequate, or evasive, or (3) an objection to a request is made that is too general or
without merit. In the instant action, the Defendant’s Objection is incomplete because it lacks
proof of a privilege log to evaluate any of Defendant’s privilege claims. Further, the objections
are evasive, incomplete, and inadequate.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
4
MOTION TO COMPEL FURTHER DISCOVERY
Defendant (SCPMG/KAISER) has failed to strictly comply with the Plaintiff’s Discovery
Requests and thus the court should make an order that Defendant complies with Plaintiffs’
Discovery Requests and imposing a monetary sanction for the failure to respond.
Pursuant to CCP 2031.310(b)(1), Plaintiff has good cause to demand the further
production of documents and/or information that Defendant relies on in their Defense, and all
other information in their custody as specifically requested by Plaintiff. The requested
information will help establish the basis for Plaintiff’s claims, and will shed light on Plaintiff’s
assertions. The foregoing creates a good cause obligating Defendant to respond accordingly to
Plaintiff’s Discovery requests.
WHEREFORE, Plaintiff requests this Court grant the following Order(s):
1. THAT Defendant provides a Statement of Compliance with Respect to Plaintiff’s
Discovery Requests;
2. THAT this Court overrule Defendant’s improper objections, and compel
Defendant to produce anything withheld on the bases thereof;
3. THAT Defendant produces a privilege log to evaluate any of its privilege claims;
and
4. THAT this Court grant any other Order it deems just.
DATED:
Respectfully submitted,
Respectfully submitted,
________________________________
Esther Tendo Atam
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
5
MOTION TO COMPEL FURTHER DISCOVERY
CERTIFICATE OF SERVICE
I hereby certify that on [ENTER DATE], a copy of the foregoing document has been
sent to the Defendants in the following address:
Lisa M. Magorien, Esq. (SBN: 259877)
lmagorien@lbbklaw.com
LAGASSE BRANCH BELL + KINKEAD LLP
4365 Executive Drive, Suite 950
San Diego, CA 92121
Telephone: (858) 345-5080
Facsimile: (858) 345-5025.
Attorney for Defendant
DATED:
Respectfully submitted,
________________________________
Esther Tendo Atam
At Legal writing experts, we would be happy to assist in preparing any legal document you need. We are international lawyers and attorneys with significant experience in legal drafting, Commercial-Corporate practice and consulting. In the last few years, we have successfully undertaken similar assignments for clients from different jurisdictions. If given this opportunity, The LegalPen will be able to prepare the legal document within the shortest time possible. You can send us your quick enquiry ( here )