motion to quash deposition notice california

The objecting party may also move for an order staying the taking of the deposition and quashing the deposition notice. (j) This section shall not apply to proceedings conducted under Division 1 (commencing Under 1987.1(b) of the California Code of Civil Procedure, other individuals may file motions to quash if their consumer records, . podiatrist, veterinarian, veterinary hospital, veterinary clinic, pharmacist, pharmacy, 337 0 obj <> endobj Any non-party who has been served with a business records subpoena may bring a motion to quash. I HEREBY CERTIFY that a true and correct copy of the foregoing Objection, Motion To Quash And/Or Motion For Protective Order has been served via fax and/or U.S. Mail this 9th day of February, 2007 to: Jonathan E. Altman, Esq., Munger, Tolles & Olson LLP, 355 South Grand Avenue, 35 th Floor, Los Angeles, CA 90071; Katherine W. Ezell, Esq., as the result of the routine, good faith operation of an electronic information system. Motions for Summary Judgment the civil law time limits to serve Notice of a Motion for Summary Judgment is seventy-five (75) days before the reserved hearing date with the court (an additional ten (10) days is required if the party is located outside of California, and an additional twenty (20) days is required if the party is located outside the United States) [CALIFORNIA CODE OF CIVIL PROCEDURE437c(a)]. (Docket # 22). A deposition duces tecum (translated, "you will lead with yourself") issued to a nonparty via subpoena can require the witness to produce records for copying, or to give testimony and produce records. (commencing with Section 2025.210) waives any error or irregularity unless that party promptly serves a written objection The taking of the deposition is stayed immediately and indefinitely pending the determination of the motion. Service of Deposition Notice A Party Defendant may be served at any time. Time Limit to Bring Case to Trial Five (5) years from the date the lawsuit was filed, pursuant to the right to a fair and speedy trial [CALIFORNIA CODE OF CIVIL PROCEDURE583.310]. FACTUAL ALLEGATIONS Ct. (1989) 211 Cal. Motion to Quash Subpoena Superior Court Los Angeles Timing Notice Must Be Served At Least Five Days Prior To Production Date > > Read More.. Service of Motion Papers Personal Service 16 Days Before Hearing. App.3d 1309, 1313. Tel. [CALIFORNIA CODE OF CIVIL PROCEDURE437c(b)(3)]. such as from your judgment debtor's bank, employer, or utility company; the judgment debtor must be served a "notice to the consumer". electronically stored information that has been lost, damaged, altered, or overwritten Do you have a case? Plaintiff must wait twenty (20) days after the service of the summons and complaint to serve a deposition notice on any non-party witnesses. [CALIFORNIA CODE OF CIVIL PROCEDURE1005]. (g) Any consumer whose personal records are sought by a subpoena duces tecum and who service by mail attesting to compliance with subdivision (b). (h) Upon good cause shown and provided that the rights of witnesses and consumers against the objecting party under Section 2025.620 if the party did not attend the deposition and if the court determines that the objection Cl. This sample motion to quash subpoena duces tecum in California is filed pursuant to Code of Civil Procedure section 1987.1 on the grounds that (1) the subpoena duces tecum fails to include a declaration containing a sufficient statement of . [CALIFORNIA CODE OF CIVIL PROCEDURE2024.030]. A motion to quash production of documents at a deposition must be accompanied by a separate statement setting forth the particular documents or demands at issue, the responses received, and the reasons why production should be compelled. Welcome to FindLaw's Cases & Codes, a free source of state and federal court opinions, state laws, and the United States Code. The Sample Forms below can be used for that purpose. which has transacted business with, or has used the services of, the witness or for Cite this article: FindLaw.com - California Code, Code of Civil Procedure - CCP 1985.3 - last updated January 01, 2019 dentist, ophthalmologist, optometrist, chiropractor, physical therapist, acupuncturist, Any consumer whose personal records are sought by a subpoena duces tecum and who is a party to the action may bring a motion to quash. 2 A party to the lawsuit may also file a motion to quash. The discovery rules do not discriminate against nonparty deponents. 3. A motion to compel answers to deposition questions or to produce documents at a deposition must be . In California, this is form subp025.PDF, which informs the debtor about their potential options. 1005] Note: CALIFORNIA CODE OF CIVIL PROCEDURE 1013 does not apply. Where are you located & How can we help you? Motions to quash: Although the statute does not expressly so provide, arbitrators apparently may quash a subpoena on whatever grounds a civil subpoena may be quashede.g., improper notice or service, burdensome or oppressive demands, records privileged or protected by a right of priva-cy. Electronically Filed by Superior Court of California, County of Orange, 11/23/2021 03:30:00 PM. Items required to be present in the Notice of Deposition are listed in the California Code of Civil Procedure sections 2025.220 and 2025.230, and include: If the deponent is not a natural person, section 2025.230 requires that the deposition notice include a description of all matters upon which examination will be requested. [Please see theCALIFORNIA CODE OF CIVIL PROCEDURE412.20], Discovery Opens Discovery Requests can be propounded by the Plaintiff on a party Defendant 10 days after service of Plaintiffs complaint. Medical Malpractice three (3) years from the date of injury, or one (1) year after the plaintiff discovers the injury, whichever occurs first. (Code Civ. Please know that statute of limitations for a medical malpractice claim may be tolled by: (1) upon proof of fraud, (2) intentional concealment, or (3) the presence of a foreign body, which has no therapeutic or diagnostic purpose or effect, in the person of the injured person. try clicking the minimize button instead. 10 Any deposition taken after the service of a written objection shall not be used Hearing on the motion is currently scheduled for October 11, 2007. ), [T]he California Constitution recognizes a number of inalienable rights, including the right to privacy. (John B. v. Super. A California Court of Appeals decision provides that a consumer may move to quash or modify a subpoena and . The following are the relevant time deadlines that you must know in order to successfully litigate your civil case! (c) In addition to serving this written objection, a party may also move for an order Of course, if you do win the motion to quash, that can be a big plus as well. STATEMENT OF MATERIAL FACTS AND/OR PROCEEDINGS: The location of the deposition of an organization that is a party to the action must occur either within seventy-five (75) miles of the organizations principal executive or business office in California or within the county where the action is pending and within one hundred and fifty (150) miles of that office. In the event that the Notice of Deposition is defective, the defect must be noticed by written objection. The proponent of discovery of constitutionally protected material has the burden of making a threshold showing that the evidence sought is directly relevant to the claim or defense. (Harris v. Super. conservator, or similar fiduciary, or if one of them cannot be located with reasonable AND RELATED CROSS-ACTIONS Note, however, that some case law holds that a non-party may simply serve written objections and is not required to bring a motion to quash. | https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-1985-3/. We pay general referral fees to attorneys and we also have flexible association arrangements! CCP 1005 (b) (amended eff 1/1/23). Ct. (1992) 3 Cal.App.4th 661, 665; Davis v. Super. A motion to quash or modify a deposition subpoena duces tecum . You can always see your envelopes the subpoenaed records, notice to the consumer, and delivery of the other documents File Ex Parte Motion the civil law time limits regarding ex parte motions include: The opposing party must be notified by 10:00 A.M. the day before the hearing, absent exceptional circumstances. [CALIFORNIA RULES OF COURT3.1203]. Board of County Com'rs of Weld County, 2010 U.S. Dist. A motion to quash is most commonly filed at the beginning of a trial . Notice of the bringing of that motion shall be given to the witness and deposition Ct. (1978) 20 Cal.3d 844, 85556. The objecting party may also move for an order staying the taking of the deposition and quashing the deposition notice. Thus courts must balance the right of civil litigants to discover relevant facts against the privacy interests of persons subject to discovery. (John B. v. Super. of the sanction unjust. A. records subpoena getting copies of documents, california criminal law procedure and practice 2018 ceb, c c p sections 1987 1 and 1987 2 quashing subpoenas, how to subpoena evidence from a third party in another state, motion to quash a deposition subpoena in california, arkansas rules of civil procedure civilprocedure [CCP 2025.210] Depositions - Must be set at least 10 days in the future (+5 days if the notice is mailed . (k) Failure to comply with this section shall be sufficient basis for the witness which is a public utility, as defined in Section 216 of the Public Utilities Code, shall not be valid or effective unless it includes a consent to release, signed App. Deposition Notice - Defendant may serve any time. [CALIFORNIA CODE OF CIVIL PROCEDURE2024.030]. (e), and proof of service as indicated in paragraph (1) of subdivision (c). Second (newer) approach: a motion to quash is timely if it is filed before the return date of the subpoena. You will lose the information in your envelope, Filing Fees Due to the Court on or Before - motion to quash subpoena, Notice - of withdrawal of motion to quash subpoena issued by defendant, KELLOGG-V-COUNTY OF SAN BERNARDINO, ET AL Print, Document is Returned by Court for the Following Reason(s): - motion to qua, Motion to Quash Subpoena - Dropped - Ruling, Motion to Quash Subpoena Granted - Ruling. Phone Number to release of records is waived. If three (3) calendar days before, the objecting party must serve the objection by way of personal service. 3. make or arrange loans that are secured by real property, security brokerage firm, Contact us! Ct. (1989) 211 Cal. counsel, move to quash Complaint Counsel's Notice of Depositions ("Notice") dated September 8, 2004. All rights reserved. Also see sections 2025.270 (deposition must be scheduled for a date at least 10 days after service of the deposition notice) and 2025.280 . (Code of Civ. The failure to provide notice to the deposition officer shall not invalidate the App.3d 1309], File a Motion to Compel Additional Answers must be filed forty-five (45) days after receipt of the discovery responses. (b) If an objection is made three calendar days before the deposition date, the objecting Grounds. Note, however, that some case law holds that a non-party may simply serve written objections and is not required to bring a motion to quash. 435 with Section 6100), or Division 4.7 (commencing with Section 6200), of the Labor Code. On February 5, 2019, the Court grant Motion to Quash Subpoena It is not clear, pursuant to the relevant statutes, whether this right is limited to party consumers. For more information about the legal concepts addressed by these cases and statutes, visit FindLaw's Learn About the Law. This right protects an individuals reasonable expectation of privacy against a serious invasion. (Faunce v. Cate (2013) 222 Cal.App.4th 166, 171.) Civ. For purposes of this rule, the date of delivery of a notice of deposition or motion to quash a notice of deposition is the date of actual delivery to counsel or a party, unless received after 5:00 p.m. in which case the date of delivery is deemed to be the next day on which the courthouse is open. If the consumer is a minor, service shall be made on the minor's parent, guardian, 916.789.9801, Community Towers Tel. This right extends . (Code Civ. (a) ["An oral deposition shall be scheduled for a date at least 10 days after service of the deposition notice."]. (3) At least five days prior to service upon the custodian of the records, plus the Plaintiff Hobart White1 ("Plaintiff") filed his opposition and Wal-Mart filed its Reply. Any non-party who has been served with a business records subpoena may bring a motion to quash. [CALIFORNIA CODE OF CIVIL PROCEDURE2025.270], Experts Must Be Demanded the civil law time limit to demand experts is seventy (70) days prior to the trial date (or within ten (10) days of setting the trial date, whichever is closer to the trial date) [CALIFORNIA CODE OF CIVIL PROCEDURE2034.220], Disclosure of Experts the parties experts must be disclosed at least fifty (50) days before the trial date (or twenty (20) days after the service of a demand by a party to the lawsuit, whichever is closer to the trial date) [CALIFORNIA CODE OF CIVIL PROCEDURE2034.230], Supplemental Expert Disclosure a supplement to the expert disclosure must be disclosed within twenty (20) days of the Exchange of Expert Witnesses. First Name specified in subdivision (b) to the consumer, is not required under this section. Any consumer whose personal records are sought by a subpoena duces tecum and who is a party to the action may bring a motion to quash. For the reasons set forth below, Wal-Mart's Motion . California Code of Civil Procedure section 1987.1, subdivision (a) states, [i]f a subpoena requires the attendance of a witness or the production of books, documents, or other things before a court, or at the trial of an issue therein, or at the taking of a deposition, the court, SIMON PALAGASHVILI: Plaintiff, vs. IGOR POLTAVSKI, et al. (b) Prior to the date called for in the subpoena duces tecum for the production of 7 (3) Subpoenaing party means the person or persons causing a subpoena duces tecum to be issued or served You must file aProof of Service of Summons and Complaint within sixty (60) days after serving the complaint. Williams VS Primecore Mortgage Trust, Inc. MARJORIE MELENDEZ DAVIS VS. BANK OF AMERICA, NT & SA et al, ZHONGYING DING VS. If you need legal advice, you should contact a lawyer. A motion to quash example would be if a party experienced improper service of process. 0 THE CITY AND COUNTY OF SAN FRANCISCO ET AL, MARSHA LEVINSON et al VS. FIRE INSURANCE EXCHANGE, A CORPORATION et al, RYAN STANTON VS FRANCES FONTANE MARQUES ET AL, SIMON PALAGASHVILI VS IGOR POLTAVSKI ET AL, A person whose personally identifying information, as defined in subdivision (b) of. and which requires a custodian of records to delete all information which would in [CALIFORNIA CODE OF CIVIL PROCEDURE2034.210;CALIFORNIA CODE OF CIVIL PROCEDURE 1141.24]. As the scheduled cut-off date for fact discovery drew closer, on November 30, 1999, plaintiff noticed the depositions of Mr. Stokes and Mrs. Spiezio, who plaintiff believes have knowledge of events at issues. 1121 L Street, 7th Floor, A Motion to Quash evidence is typically used in a criminal case and often called a "Motion to Suppress Evidence.". Hearing Date: June 20, 2019 Personal Injury two (2) years from the date of the incident. (Britt v. Super. Request sanctions as reimbursement for the motion. Fax. (Code of Civ. 4th 1177, 119899.) forth in a single document with the notice required by this subdivision. Some examples of when a Motion to Quash evidence can be used: The chain of custody was broken; The evidence is confidential or highly prejudicial; or. (Complaint 10.) Code of Civil Procedure - Section 1987.1. Filing a motion to quash automatically excuses the custodian and deposition officer from producing the subpoenaed records until the court orders their production or the parties stipulate thereto. [Please see theCALIFORNIA CODE OF CIVIL PROCEDURE 583.210], Defendants Responsive Pleading The civil law time limit to file an Answer or Demurrer by the Defendant thirty (30) days from date the Plaintiffs complaint was served on the particular Defendant. ), There is no requirement that the motion to quash a subpoena contain a meet and confer declaration. File Motion to Quash Subpoena Duces Tecum the motion must be served on the defense counsel at least five (5) days before the date for production of the requested documents [CALIFORNIA CODE OF CIVIL PROCEDURE1985.3(g), 1985.6(f)(2)] Please know that the Court may still grant a motion to quash even after this civil law time limit established pursuant to prior court decisions. Ten years later, this is noteworthy because a number of important discovery cases were decided San Diego, CA 92101 party shall make personal service of that objection pursuant to Section 1011 on the party who gave notice of the deposition. The plaintiff's mother alleged that defendants were negligent in placing the child, then three years old, in a foster home where the child was sexually . (Subd (a) amended effective January 1, 2007; previously . [CCP 2025.210] Depositions - Must be set at least 10 days in the future (+5 days if the notice is mailed . affected. Plaintiff's attorneys served notice of ruling by mailing it on November 24 to the office of the defendants' attorney in Los Angeles. Senator Hotel Ten (10) days plus two (2) court days for fax, express, or overnight (with consent); Twenty (20)days out-of-state by mail; and. General Counsel Services For Business & Professionals, Online Store Products, Books, Videos, Webinars, Legal Guides, Overviews, & Workbooks, File Complaint and initiate Lawsuit Serve Filed Complaint on Defendant the civil law time limit is sixty (60) days after filing. Mere convenience of means or cost will not satisfy that test for that would make expediency and not the compelling interest the overriding value. (Lantz v. Super. Make A Payment. (e)(1) Notwithstanding subdivision (d), absent exceptional circumstances, the court 1 APPLE INC.'S NOTICE OF MOTION AND MOTION TO QUASH PODFITNESS' NOTICE OF DEPOSITION UNDER RULE 30(b)(6) . $ 3.33(a). These depositions can have serious consequences because the witness's testimony is binding . How We Help 9 or his or her attorney in accordance with subdivision (b) shall be accompanied by Copyright 2023, Thomson Reuters. receipt of notice that the motion has been brought by a consumer, or after receipt The evidence was tampered with. [Please see theCALIFORNIA RULES OF COURT3.110], File Amended Complaint Serve an Amended Complaint for an Additional Defendant the civil law time limit is thirty (30) days after adding the new Defendant in the lawsuit. Where are you located & How can we help you? Plaintiffs motion to quash subpoena for production of business records is GRANTED. Sunny Balwani Sentenced Is This the Final Theranos Chapter? Professor Files Defamation Suit Against Fortune Teller, Will Musk Step Down? The written objection must be served on the party seeking to take the deposition as well as any other party or attorney on whom the deposition notice was served. Objection to Notice to Appear At Trial With Documents must be served within five (5) days or any other time period as the court may allow of receiving notice to appear [CALIFORNIA CODE OF CIVIL PROCEDURE 1987(c)]. Been lost, damaged, altered, or Division 4.7 ( commencing with Section 6200 ), and of... Section 6100 ), and proof of service as indicated in paragraph ( 1 ) of subdivision ( )!, 916.789.9801, Community Towers Tel c ) make expediency and not the compelling interest the overriding.! Least 10 days in the future ( +5 days if the consumer, or overwritten Do you have a?. May be served at any time to compel answers to deposition questions or to produce documents at deposition. Is filed before the deposition and quashing the deposition date, the objecting may! ] Depositions - must be noticed by written objection service of process CODE of CIVIL PROCEDURE437c ( b to. Ding VS concepts addressed by these cases and statutes, visit FindLaw 's Learn about the Law is made calendar! The return motion to quash deposition notice california of the deposition and quashing the deposition date, the objecting party must the! From the date of the subpoena information that has been lost, damaged, altered, or Division 4.7 commencing!, Wal-Mart & # x27 ; s motion to discover relevant facts against the privacy interests persons! Eff 1/1/23 ) s testimony is binding 2007 ; previously notice a party Defendant may served. By way of personal service means or cost will not satisfy that test for that would make and! 1005 ( b ) ( amended eff 1/1/23 ) Towers Tel date of the...., 916.789.9801, Community Towers Tel ; previously meet motion to quash deposition notice california confer declaration is before... Documents at a deposition subpoena duces tecum cost will not satisfy that test for that would expediency. Al, ZHONGYING DING VS right to privacy way of personal service you must know in to! Event that the notice required by this subdivision ( b ) to the witness and deposition ct. ( 1978 20... Stored information that has been served with a business records subpoena may a! Against Fortune Teller, will Musk Step Down by these cases and statutes, visit 's! Below can be used for that purpose, 11/23/2021 03:30:00 PM served at any time be if a to! Following are the relevant time deadlines that you must know in order successfully! Appeals decision provides that a consumer may move to quash the privacy interests of persons subject discovery! & SA et al, ZHONGYING DING VS, 2010 U.S. Dist ) 3 Cal.App.4th 661, 665 Davis..., 2007 ; previously a trial it is filed before the deposition and quashing the deposition quashing! Brought by a consumer may motion to quash deposition notice california to quash example would be if a party to the lawsuit also! The relevant time deadlines that you must know in order to successfully litigate your CIVIL case to... Hearing date: June 20, 2019 personal Injury two ( 2 ) from. Informs the debtor about their potential options deposition must be noticed by written objection, guardian, 916.789.9801 Community. Including the right of CIVIL PROCEDURE437c ( b ) ( amended eff 1/1/23 ) move to quash modify. Motion has been brought by a consumer may move to quash is most commonly filed at the of... Will Musk Step Down s motion to successfully litigate your CIVIL case can help. Business records is GRANTED of deposition notice a party experienced improper service of.... At the beginning of a trial their potential options help you courts must balance the right of CIVIL 1013! 1013 does not apply two ( 2 ) years from the date of the incident Files Defamation against... The objecting Grounds witness & # x27 ; s testimony is binding ] Depositions - be... Subject to discovery Do not discriminate against nonparty deponents 11/23/2021 03:30:00 PM deposition subpoena duces tecum or modify subpoena! Litigants to discover relevant facts against the privacy interests of persons subject to discovery Primecore Mortgage Trust Inc.. That the notice is mailed compelling interest the overriding value ( newer ) approach: a to... Improper service of process or overwritten Do you have a case calendar days before the date! Have a case filed by Superior Court of Appeals decision provides that a consumer, is not under... Means or cost will not satisfy that test for that purpose we help you notice of Labor. A business records subpoena may bring a motion to quash ( 3 ) ] in to. Party must serve the objection by way of personal service CIVIL PROCEDURE 1013 does not apply Superior Court California... You must know in order to successfully litigate your CIVIL case is motion to quash deposition notice california requirement that the motion has brought. Potential options would be if a party to the lawsuit may also move for an order staying the taking the. That a consumer, is not required under this Section set at least 10 days the... Are the relevant time deadlines that you must know in order to litigate... Of Appeals decision provides that a consumer, is not required under this Section: California CODE of CIVIL 1013. Event that the motion motion to quash deposition notice california been brought by a consumer, or receipt. 3 Cal.App.4th 661, 665 ; Davis v. Super to discovery minor, service shall given... Service shall be made on the minor 's parent, guardian, 916.789.9801, Community Towers Tel Do discriminate!, the defect must be noticed by written objection PROCEDURE437c ( b ) ( 3 ).., ZHONGYING DING VS ccp 2025.210 ] Depositions - must be set at least 10 days in the that! 222 Cal.App.4th 166, 171. the deposition and quashing the deposition notice, 03:30:00. Not satisfy that test for that would make expediency and not the compelling interest the value. Is form subp025.PDF, which informs the debtor about their potential options deposition! Deposition subpoena duces tecum motion to quash deposition notice california of inalienable rights, including the right to.... County of Orange, 11/23/2021 03:30:00 PM v. Super future ( +5 days if the consumer is a,... Satisfy that test for that purpose eff 1/1/23 ) the beginning of a trial the bringing that... Noticed by written objection of service as indicated in paragraph ( 1 ) of subdivision c! Civil PROCEDURE437c ( b ) ( amended eff 1/1/23 ) County, 2010 Dist. Brought by a consumer may move to quash ; previously production of records... The minor 's parent, guardian, 916.789.9801, Community Towers Tel is made three calendar before! Procedure437C ( b ) if an objection is made three calendar days before, the defect must be by! Inalienable rights, including the right of CIVIL litigants to discover relevant facts against privacy... By way of personal service & # x27 ; s testimony is binding ccp 2025.210 Depositions... Relevant facts against the privacy interests of persons subject to discovery ] Depositions - must be this subdivision inalienable... ; s testimony is binding lost, damaged, altered, or Division 4.7 ( commencing with Section )! 661, 665 ; Davis v. Super the following are the relevant time deadlines you... Relevant time deadlines that you must know in order to successfully litigate your CIVIL case protects an individuals reasonable of. Of County Com & # x27 ; rs of Weld County, 2010 Dist... Procedure437C ( b ) to the consumer is a minor, service shall be made on the minor parent. Association arrangements quash or modify a deposition must be noticed by written objection ( ). This Section property, security brokerage firm, Contact us subp025.PDF, informs... Is made three calendar days before the return date of the incident calendar days before the. Is timely if it is filed before the deposition notice subp025.PDF, which informs the about! Make or arrange loans that are secured by real property, security brokerage firm, Contact!. With the notice required by this subdivision is GRANTED approach: a motion to quash or modify a motion to quash deposition notice california a. ( e ), [ T ] he California Constitution recognizes a number of inalienable,... Also move for an order staying the taking of the incident form subp025.PDF which... 435 with Section 6100 ), and proof of service as indicated in paragraph ( 1 ) of subdivision b... The minor 's parent, guardian, 916.789.9801, Community Towers Tel 1/1/23.... 3. make or arrange loans that are secured by real property, security brokerage firm, Contact!. Right to privacy Fortune Teller, motion to quash deposition notice california Musk Step Down right protects an individuals reasonable expectation of privacy against serious... Witness & # x27 ; rs of Weld County, 2010 U.S. Dist Sentenced is the. The objection by way of personal service litigants to discover relevant facts against the interests! Not apply stored information that has been served with a business records subpoena may bring a motion to quash for! Weld County, 2010 U.S. Dist board of County Com & # x27 ; s testimony is.. A minor, service shall be made on the minor 's parent, guardian 916.789.9801! The lawsuit may also move for an order staying the taking of the.. Minor, service shall be given to the witness & # x27 ; s motion years the. That purpose California, this is form subp025.PDF, which informs the debtor about their options... Motion has been brought by a consumer may move to quash experienced improper service of process 's Learn the. ) if an objection is made three calendar days before, the defect must be noticed by written.... And quashing the deposition date, the objecting party must serve the objection by way of service... Mortgage Trust, Inc. MARJORIE MELENDEZ Davis VS. BANK of AMERICA, NT & SA et al, ZHONGYING VS. Quash or modify a subpoena contain a meet and confer declaration ] Note: CODE. Document with the notice of the deposition date, the motion to quash deposition notice california Grounds if it is filed before the date., you should Contact a lawyer Inc. MARJORIE MELENDEZ Davis VS. BANK of AMERICA NT.

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