Subject: Re: Notice of Motion for Sanctions, Meet and Confer Letter re Demurrer to Cross-Complaint
From: Seth Wiener <[email-masked]>
To: "Andrew G. Watters" <[email-masked]>
Date: Thu, 28 Jan 2021 20:27:05 +0000 (UTC)

Andrew,
You are simply wrong that the full motion is required.  The section makes clear that only  a notice of motion needs to be served.
I also have not received any supplemental discovery responses from you.  Please let me know if you intend to provide any.  

Law Offices of Seth W. Wiener
609 Karina Court
San Ramon, CA 94582
(925) 487-5607
www.sethwienerlaw.com

    On Thursday, January 28, 2021, 12:13:01 PM PST, Andrew G. Watters <[email-masked]> wrote:  
 
 The full motion is required.  128.5(f)(1)(B).  And be prepared for a 
sanctions motion back, because this is ridiculous.

Andrew G. Watters
[email-masked]
+1 (415) 261-8527
https://www.andrewwatters.com

On 1/28/2021 12:08 PM, Seth Wiener wrote:
> Andrew,
> 
> Only the Notice of Motion is required to be served at this time.  You 
> have 21 days to withdraw the cross-complaint, and if not, Plaintiff will 
> proceed with the Motion for Sanctions.  The meet and confer letter does 
> outline some of the defects with the Cross-Complaint.
> 
> Law Offices of Seth W. Wiener
> 609 Karina Court
> San Ramon, CA 94582
> (925) 487-5607
> www.sethwienerlaw.com
> 
> 
> 
> [snip]