Sewby LLC, et al. vs PIERCE LAW GROUP, LLP, et al.

produce documents responsive to Plaintiff's RFP, Set One but has failed to permit the inspection by failing to produce a single document responsive to Plaintiff's requests. On February 21, 2025, Plaintiff electronically served their RFP, Set One. (Rucker Decl. P.4, Exh. 1.) On March 25, 2025, Defendant served its Responses. (Rucker Decl. P.5, Exh. 2.) As part of their response, Defendant promised production of documents responsive to Request Nos. 1, 2, 4, 5, 6, 7, 8, 10, 14, 89, 90, 91, 92, 93, 94, 95, 96, 97, 99, 100, and 106. (Rucker Decl.

P.5.) Despite this, Plaintiff maintains Defendant has not produced a single document responsive to Plaintiff's RFP, Set One. (Rucker Decl. P.6.) Plaintiff tried to meet and confer regarding the discovery, but FCA has yet to respond. (Rucker Decl. P.12.) In opposition, FCA argues on April 8, 2025, FCA sent Plaintiff's counsel a written service letter by email expressly advising "below is a link to Defendant FCA US LLC's Initial RFP Document Production with reference to the above-captioned action," and provided a SharePoint link identified as "Gomez - Initial RFP Document Production Link" containing the production. (Fonseca Decl.

Exh B.) As a result, FCA has made the production and the court "cannot compel FCA to perform an act it completed long before this Motion was filed." Plaintiff has not filed a Reply. Counsel for FCA has filed a declaration, under penalty of perjury, that the documents were produced on April 8, 2025. (Fonseca Decl. P.P.4-8, Exh. B.) As such, the court DENIES the motion. Sanctions Plaintiff seeks $1,155.00 in sanctions against Defendant as a result of having to bring this motion. As the court has denied the motion, the court DENIES the request for monetary sanctions.

The court notes that this motion could have been avoided entirely by counsel engaging in a good faith meet and confer. Both sides are admonished that in the future they must communicate directly in person or by phone or videoconference prior to bringing a dispute such as this before the court.

al. vs PIERCE LAW GROUP, LLP, et al. motion to quash service of plaintiffs' complaint Date of Hearing: August 25, 2026 Trial Date: None set Department: 529 Case No.: 25STCV18500 Moving Party: Specially Appearing Defendant Pierce Law Group, LLP Responding Party: Plaintiffs Sewby LLC and Jaleh Factor BACKGROUND On June 26, 2025, Plaintiffs Sewby LLC

and Jaleh Factor filed a complaint against Pierce Law Group, LLP and Estate of David Albert Pierce for negligence, legal malpractice, and breach of fiduciary duty. Sewby LLC and Jaleh Factor bring this legal-malpractice action against Pierce Law Group, LLP, alleging deficient representation in prior Florida litigation arising from a joint-venture dispute over fashion-mask manufacturing and distribution during the COVID-19 pandemic. Plaintiffs contend that Pierce Law failed to pursue direct-damage claims distinct from receivership derivative claims in Miami-Dade County proceedings, resulting in losses. [Tentative] Ruling Specially Appearing Defendant Pierce Law Group, LLP's Motion to Quash Service of Summons of Plaintiff's Complaint is GRANTED.

DISCUSSION Specially Appearing Defendant Pierce Law Group, LLP moves this court for an order quashing service of summons and complaint upon Pierce Law on the grounds that service of summons was not made according to any of the statutorily authorized methods for service of summons. "When a defendant challenges the court's personal jurisdiction on the ground of improper service of process 'the burden is on the plaintiff to prove the existence of jurisdiction by proving, inter alia, the facts requisite to an effective service.'" (Summers v.

McClanahan (2006) 140 Cal.App.4th 403, 413.)¿ PLG argues Pierce Law was never personally served with the Summons and Complaint as required by law. Specifically, the proof of service filed by plaintiffs on April 23, 2026 alleges that Pierce Law was served via substitute service through Pessah Law Group. However, Pessah Law Group is neither authorized to accept service on behalf of Pierce Law nor has ever been designated as Pierce Law's agent for service of process. In opposition, Plaintiffs argue PLG is asking the court to ignore its own public representations that following the death of its founder, David Albert Pierce, PLG would be shutting down and "key Pierce Law Group Personnel" would move the firm's entertainment practice to Pessah Law Group.

PLG further directed visitors to "visit us at our new home" at Pessah Law Group. As a result of these statements, Plaintiffs relied on those representations and attempted the professional courtesy of service by Notice and Acknowledgment through Pierce Law's longtime counsel, Freeman Mathis & Gary LLP. Counsel declined so Plaintiff instructed the process server to serve PLG through Aditya S. Ezhuthachan, managing partner of Pierce Law Group LLP. The process server then executed substituted service under Code of Civil Procedure section 415.20 by serving the office PLG at its "new home" and leaving the summons and complaint with the individual apparently in charge.

Plaintiff notes that the individual apparently in charge was Controller of PLG, Ben Kuerschner. As a result, the service was proper. The court finds Plaintiff has failed to meet their burden establishing service was

proper. While Plaintiff has presented evidence that supports an inference that Pierce Law directed former clients to Pessah, that inference is not the same as proof that service at Pessah was PLG's usual place of business. Telling clients "please visit us at our new home" can be read either as PLG representing that itself now operates at that location or as a referral message telling former clients where its former lawyers and staff can now be found. As noted by Defendant, Plaintiff has not established Ben's connection to PLG, other than speculating that it was Ben Kuerschner.

And under Chinese Theater, LLC v. Starline Tours USA, Inc. (2025) 115 Cal.App.5th 1048, a co-located relationship with a separate entity or personnel transitions to a separate firm do not establish the defendant's own office for substituted service. Moreover, actual notice does not confer jurisdiction where there has been complete failure to comply with the statute. (See American Express Centurion Bank v. Zara (2011) 199 Cal.App.4th 383, 392.) Based on the foregoing, Specially Appearing Defendant Pierce Law Group, LLP's Motion to Quash Service of Summons of Plaintiff's Complaint is GRANTED.

Case Number: 25STCV24211 Hearing Date: August 25, 2026 Dept: 529 ROBERT AMES vs AMICA MUTUAL INS CO. MOTION TO COMPEL FURTHER DISCOVERY Date of Hearing: August 25, 2026 Trial Date: June 14, 2027 Department: 529 Case No.: 25STCV24211 Moving Party: Defendant Amica Mutual Insurance Company Responding Party: Plaintiff Robert Ames Meet and Confer: Yes. Feasel Decl. BACKGROUND On August 18, 2025, Plaintiff Robert Ames filed a complaint against Amica Mutual Insurance Company for declaratory relief, breach of contract, and breach of implied covenant of good faith and fair dealing.

Plaintiff alleges he filed various insurance claims involving vandalism against various vehicles he owned and insured by Defendant. [TENTATIVE] RULING Defendant Amica Mutual Insurance Company's Motion to Compel Plaintiff's Further Responses to Discovery Requests is DENIED. DISCUSSION Defendant Amica Mutual Insurance Company moves the court for an order compelling Plaintiff Robert Ames to serve further responses to Defendant's discovery request on the grounds that Plaintiff has failed, without justification, to serve full, complete and proper responses to Defendant's discovery requests.

A motion to compel further responses be brought based on responses to requests for admission ("RFA") that: (1) provide evasive or incomplete answers; or (2) make