Llerena v. Birney CA2/4
On January 3, 2020, Llerena filed the operative motor vehicle negligence form complaint against Birney. The form complaint stated that “[t]he following causes of action are attached and the statements above apply to each . . . : [¶] a. Motor Vehicle [¶] b. General Negligence.” No attachment was provided with Llerena’s form complaint, and no factual allegations were provided. Birney timely filed an answer to Llerena’s complaint.
On September 15, 2020, Birney propounded to Llerena a set of requests for admissions. When Llerena did not respond, Birney sent Llerena a meet and confer letter informing Llerena that she would file a discovery motion if Llerena did not provide complete and verified responses by November 30, 2020. In response the same day, Llerena’s counsel, Martin Jerisat, stated that no responses could be provided “as the clients are not cooperating.” Jerisat also stated that he would soon file a motion to be relieved as counsel.
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