This was my second freelancing client from California. He hired me for a Motion to Compel, Declaration, and Separate Statement.

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MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES AND SPECIAL
INTERROGATORIES (SET ONE) AND MONETARY SANCTIONS
Benjamin Harper (SBN: 51XXXX)
HARPER LAW
619 W. Franklin Street, 5th Floor
Monterey, CA 93940
Tel: (831) 555-9340
Email: bHarper@Harperlaw.com
Attorneys for Plaintiffs,
CALI PEDIATRIC PHYSICAL THERAPY, INC. and
FRIENDS OF CALI PEDIATRIC THERAPY
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF RIVERSIDE
CALI PEDIATRIC PHYSICAL
THERAPY, INC, a California
corporation and
FRIENDS OF CALI PEDIATRIC
THERAPY, a California nonprofit
corporation,
Plaintiffs
v.
SUSAN SMITH, an individual, SUSIE
QUE SMITH TRUST, RACHEL
DOGGETT, an individual, and DOES 1
THROUGH 10, inclusive.
Defendants.
CASE NO: RES 74524
[Assigned to the Hon. Jane Brennan Dept. 3]
NOTICE OF MOTION AND MOTION TO
COMPEL FURTHER RESPONSES TO
PLAINTIFFS’ FORM INTERROGATORIES (SET
ONE) AND SPECIAL INTERROGATORIES (SET
ONE) PROPOUNDED TO DEFENDANT RITA
DOGGETT; MEMORANDUM OF POINTS AND
AUTHORITIES AND DECLARATION OF JOHN
DOE IN SUPPORT THEREOF; REQUEST FOR
SANCTIONS AGAINST DEFENDANT AND ITS
COUNSEL OF RECORD; STATEMENT IN
SUPPORT THEREOF
Date:
Time:
Dept: 3
RES ID
DECLARATION OF BENJAMIN HARPER
I, Benjamin Harper, Esq., hereby declare:
1. I am an attorney at law, duly licensed to practice before all the courts of the State of
California. I am a sole practitioner at Harper Law Firm, counsel of record for Plaintiff in this matter. I
have personal knowledge of the facts contained within this declaration, and if called as a witness, I
could and would competently testify thereto.
2. I am propounding, on behalf of Plaintiff Cali Pediatric Physical Therapy, Inc.; Friends of Cali
Pediatric Therapy, the attached First Set of Special Interrogatories, to Plaintiff Cali Pediatric and
Physical Therapy, Inc.

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MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES AND SPECIAL
INTERROGATORIES (SET ONE) AND MONETARY SANCTIONS
3. On February 13, 2018, I pounded on behalf of Plaintiff, leaps and bounds physical therapy
Inc., form interrogatories, specially prepared interrogatories, and request for production of documents,
on defendant Rachel Doggett.
4. On March 6, 2018 I received defend it Rachel Doggett responses to the form in a rocket Tori’s
specially prepared interrogatories and request for production of documents.
5. Upon reviewing defendant Rachel Doggett responses to plaintiff’s discovery requests, it was
evident that the defendant failed to properly answer the form interrogatories and specially prepared
interrogatories in their entirety, and also failed to produce documents responsive to the plaintiff’s
request for production of documents.
6. On April 16, 2018, correspondence was sent via US mail and email regarding the defendants’
insufficient responses to defendants’ counsel. Attached hereto as Exhibit B is a copy of said meet and
confer letter.
7. On April 20, 2018 I met and conferred with attorney gold regarding his clients’ insufficient
discovery responses and his unwillingness to provide further responses. We were unable to reach A
resolution. Attorney gold reiterated that his clients would not provide further discovery responses in
light of our meet and confer letter.
8. For the above reasons, plaintiff has no choice but to bring this motion to compel further
responses to form interrogatories and specially prepared interrogatories. The information sought is
necessary to properly litigate this matter and determine the parties liability with respect to all causes of
action brought forth in the complaint.
9. I attorney Benjamin Harper to Clara to penalty of perjury under the state of California that the
foregoing is true and correct to the best of my knowledge.
/s Benjamin Harper