Case 8:11-cv-00485-AG-AJW Document 496

Filed 04/13/12 Page 1 of 2 Page ID #:12092

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Marc Steven Colen, sbn 108275 The Colen Law Firm 5737 Kanan Road, Ste. 347 Agoura Hills, CA 91301 Tele: 818.716.2891 Fax: 818.597.4631 Attorney for Defendants Todd Sankey, The Sankey Firm, Inc., Neil Sankey, and Sankey Investigations, Inc.

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION

) ( Lisa Liberi, et al., ) ) ) Plaintiffs, ) ) vs. ) ) Orly Taitz, et al., ) ) Defendants ) ) __________________________ )

Case No.: 8:11-cv-00485 AG (AJWx) Hon. Andrew Guilford Courtroom 10D NOTICE OF MOTION AND MOTION BY DEFENDANTS TODD SANKEY AND THE SANKEY FIRM, INC.S TO WITHDRAW ADMISSIONS PURSUANT TO FRCP 36(B) Date Action Filed: May 4, 2009 Discovery Cut-Off: March 5, 2012 Final Pre-Trial Conf.: May 21, 2012 Trial Date: June 5, 2012 Requested Hear. Date: May 7, 2012

TO: THE COURT, ALL PARTIES, AND/OR THEIR ATTORNEYS OF RECORD:

LIBERI V. TAITZ CASE NO.: 8:11-CV-00485 AG NOTICE OF MOTION AND MOTION PURSUANT TO FRCP 36(B)

Case 8:11-cv-00485-AG-AJW Document 496

Filed 04/13/12 Page 2 of 2 Page ID #:12093

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COME NOW Defendants Todd Sankey and The Sankey Firm, Inc. and submit their Notice of Motion and Motion to withdraw inadvertent admissions pursuant to Federal Rules of Civil Procedure Rule 36(B). This motion is made upon the following bases: 1. Federal Rules of Civil Procedure Rule 36(B) permits the Honorable Court to grant relief to the moving parties by permitting them to withdraw the inadvertently late responses to requests for admissions. 2. 3. 4. 5. 6. Proper responses, without objections, have been served. Upholding the admissions would effectively eliminate any The admissions are contrary to the truth. There can be no prejudice to the Plaintiffs. Responses without objections have been served.

presentation by Todd Sankey and The Sankey Firm on the merits.

This motion to withdraw admissions are based upon this Notice of Motion and Motion, the Memorandum of Points and Authorities filed herewith, the Declaration of Todd Sankey filed herewith as well as the Court file and all other tangible and/or testimonial evidence provided at the hearing on this matter. The hearing on this motion is requested to be take place on May 7, 2012 at 10:00 AM, or such other date or time that the Court prefers. Dated 12 April 2012

Marc Steven Colen

_____________________________ Marc Steven Colen The Colen Law Firm Attorney for Defendants Todd Sankey and The Sankey Firm, Inc.
LIBERI V. TAITZ CASE NO.: 8:11-CV-00485 AG NOTICE OF MOTION AND MOTION PURSUANT TO FRCP 36(B)