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Motion to Compel deposition of Damon Dunn

Posted on | September 7, 2010 | No Comments

Dr. Orly Taitz, pro se

29839 S. Margarita Pkwy, ste 100

Rancho Santa Margarita CA 93688

ph 949-683-5411 fax 949-766-7603

 

 

SUPERIOR COURT OF CA

ORANGE COUNTY

CENTRAL DIVISION

 

DR. ORLY TAITZ,

          PLAINTIFF,

     VS.

 

DAMON DUNN,et al

          DEFENDANTS

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 CASE NO.: 30-2010

00381664

NOTICE OF MOTION

 

MOTION TO COMPEL ATTENDANCE AT

DEPOSITION

 

To Brian T. Hildreth, attorney of record for Damon Dunn

PLEASE TAKE NOTICE that at 9 AM, on September 14th, or as soon after as the matter can be heard, in Department 33, Orange County Superior Court or as the case may be of the Orange County Superior Court, Plaintiff Orly Taitz will move the court for an order requiring deponent Damon Dunn to attend and testify at
his oral deposition originally scheduled to be held on August 25, 2010, at Rancho Santa Margarita, Orange County, California.
This motion is made on the grounds that  Attorney for the deponent refused to comply with the deposition subpoena as originally noticed. A copy
of the deposition notice is attached to this motion as Exhibit
1,  and incorporated by reference. Defendant’s refusal to attend the deposition
and produce the items specified in the deposition notice was
without substantial justification. The motion will be based on this notice of motion, the
attached memorandum of points and authorities, the declaration of
Orly Taitz, the record and files of this case, and any further oral or
documentary evidence introduced at the hearing of this motion.

Dated __09.03. 10.________.

Motion to compel deposition subpoena

Memorandum of points and authorities

 Plaintiff Taitz has served defendant Dunn with the deposition subpoena. Deposition was scheduled for August 25, 2010. For about a month there was no response from the defendant’s attorney Mr. Hildreth. Taitz called Hildreth office and talked to the secretary, who stated that she will need to check if the date is convenient for the client. Only a couple of days prior to the scheduled deposition the defendant’s attorney sent a letter, stating that the client will not appear at the deposition due to some deficiencies in the subpoena. Taitz asked Mr. Hildreth to clarify, what deficiency did he meant, in order to correct it, if indeed such deficiency existed and proceed with the deposition. Taitz pointed out to Mr. Hildreth, who resides in Sacramento, that the deposition subpoena is a form subpoena used by Orange County Superior court, it was not drafted by the plaintiff, but rather prepared by the court and signed by the clerk of the court, therefore it is a correct deposition subpoena for the Orange county Superior Court and defendant is expected to comply. The subpoena for deposition and production of documents is properly related to the issue of fraud committed by the defendant in order to be elected as a Republican candidate for CA secretary of state. Mr. Hildreth did not provide any explanation and at this time the refusal is nothing but an evasion technique by the attorney for the defense. Per  Code Civ. Proc. section 2031.310(c). the Plaintiff moves this court to compel the appearance of the defendant at the deposition.

/s/ Orly Taitz

Dr. Orly Taitz

29839 Santa Margarita Pkwy, ste 100

Rancho Santa Margarita, CA 92688

Certificate of Service

I certify under penalty of perjury that a true and correct copy of the above Motion to compel Deposition was served on 08.30.10 via mail and or e-mail, and , or fax on Brian   Hildreth, attorney for defendant Damon Dunn.

Brian Hildreth

720 Ninth str.

Sacramento Ca 95814

phone 916-442-7757  fax 916-442-7759

Dated this 09.03.2010

/s/ Orly Taitz

___________________________

Dr. Orly Taitz

Declaration of Orly Taitz

1. My name is Orly Taitz, I am over 18 years old, reside in Orange County, CA, don’t suffer from any mental impairment, have personal knowledge of the forementioned facts and declare under the penalty of perjury the following:

2. I served the defendant Damon Dunn with the deposition subpoena through his attorney Brian Hildreth.

2. For nearly a month Mr. Hildreth did not respond.

3. When I called to check, if the defendant will attend, Mr. Hildreth secretary stated that they are checking their client’s schedule.

4. Only a couple of days prior to the deposition Mr. Hildreth sent a letter, stating that his client will not appear at the deposition. Mr. Hildreth did not provide proper justification for the refusal.

5. Declarant further says not.

August 29, 2010

/s/ Dr. Orly Taitz 

29839 Santa Margarita pkwy, ste 100

Rancho Santa Margarita CA 92688

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