MOTION TO BE RELIEVED AS COUNSEL
August 5, 2026 Law and Motion Calendar Judge Nicole S. Healy Department 28 ________________________________________________________________________ 2:00 PM LINE 6 24-CIV-05711 WPS GLOBAL CONNEX, LLC VS. ROSIE BARRETT, ET AL
WPS GLOBAL CONNEX, LLC CRISOSTOMO G. IBARRA ROSIE BARRETT KUSCHA HATAMI FARD
MOTION TO BE RELIEVED AS COUNSEL
TENTATIVE RULING:
The unopposed motions of Kuscha Hatami Fard and Bruno Tarabichi to be relieved as counsel of record for defendants Rosie Barrett and James E. Barrett Corp. are GRANTED.
Pursuant to California Rules of Court, rule 3.1362(e), the order does not become effective until proof of service of a copy of the signed order on the client has been filed with the court.
August 5, 2026 Law and Motion Calendar Judge Nicole S. Healy Department 28 ________________________________________________________________________ 2:00 PM LINE 7 25-CIV-00220 MARTIN MOUTON VS. EAST PALO ALTO COMMUNITY ALLIANCE AND NEIGHBORHOOD DEVELOPMENT ORGANIZATION
MARTIN MOUTON PRO PER EAST PALO ALTO COMMUNITY ALLIANCE AND NEIGHBORHOOD E. FORREST SHRYOCK DEVELOPMENT ORGANIZATION
DEFENDANT EAST PALO ALTO COMMUNITY ALLIANCE NEIGHBORHOOD DEVELOPMENT ORGANIZATION’S MOTION TO COMPEL PLAINTIFF TO PROVIDE FURTHER RESPONSES TO WRITTEN DISCOVERY
TENTATIVE RULING:
On January 21, 2026, this court denied defendant East Palo Alto Community Alliance Neighborhood Development Organization’s Motion to Compel Plaintiff’s Responses to Written Discovery and Request for Sanctions. The court issued a tentative ruling, finding that the motion was defective because defendant failed to submit a separate statement. Defendant has now filed what appears to be the same motion. The motion is again DENIED.
Plaintiff did not respond to either motion. The parties are ORDERED TO APPEAR at a case management conference on August 26, 2026 in Department 28 at 9:00 am to discuss the status of this case.
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The Notice of Hearing, again, states the wrong address for Department 28. Department 28 is located 800 North Humboldt St., San Mateo, CA, 94401. Defendant is again cautioned to include the correct address in any future notices.
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Defendant seeks to compel responses to Form Interrogatories, Special Interrogatories, and Requests for Production of Documents from plaintiff Martin Mouton claiming that plaintiff failed to provide timely responses. Defendant cites Code of Civil Procedure, sections 2030.290, subd. (b), and 2031.300, subd. (b), as authority for this Motion. (Deft.’s Mem., at pp. 3:25-4:12.)
These code sections apply where the responding party fails to serve timely responses to discovery. However, defendant acknowledges that plaintiff served responses to this discovery. (Babojanov Decl., ¶ 3.) Although plaintiff’s responses consisted solely of objections (id., exh. C), defendant must file a motion to compel further responses to the extent it contends that plaintiff’s objections are without merit. (See Code Civ. Proc., §§ 2030.300, subd. (a) [on receipt of a response to interrogatories, propounding party may move for an order compelling further response if the propound party deems that an objection to an interrogatory is without merit or too general], 2031.310, subd. (a) [upon receipt of response to an inspection demand, the demanding party may move for an order compelling further response if the demanding party deems that an objection in the response is without merit or too general].)
Additionally, a motion to compel
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