1 Ryan J Smythe (SBN #310247)

2 4299 Saint Andrews Drive

Chino Hills, CA 91709
3 Telephone: (909) 614-1726
Facsimile: (619) 413-4498
4 Ryan@Smythelaw.com
5
Attorney for Plaintiffs,
6 BERNARDO MAGANA and YESENIA GONZALEZ

7 SUPERIOR COURT OF THE STATE OF CALIFORNIA

8 COUNTY OF ORANGE
9

10 BERNARDO MAGANA, & Case No.: 30-2018-00984428-CU-CJC

YESENIA GONZALEZ, Dept. C64 –Hon. Frederick Horn
11
Plaintiffs,
12 DEMAND FOR INSPECTION OF REAL
v. PROPERTY
13

14 STERLING PROPERTY MANAGEMENT, Date: 01/21/2018

INC., a California corporation; PRISON Time: 10:00 a.m.
15 MUTINY GENERAL PARTNERSHIP, an Location: 14382 Red Hill Ave, #17,
unknown business entity; CAPITALVEST, Tustin, CA 92780
16 INC., a California corporation; and DOES 1
17 through 25 inclusive,

18 Defendants.

19 PROPOUNDING PARTY.: : Plaintiffs, Bernardo Magana & Yesenia Gonzales

20 RESPONDING PARTY.: : Defendant, Prison Mutiny General Partnership
21 SET NO.: : ONE (1)
22 PLEASE TAKE NOTICE, that in accordance with the provisions of § 2031.010(d) of the
23 Code of Civil Procedure, Plaintiffs, BERNARDO MAGANA & YESENIA GONZALES hereby
24 demands that defendant PRISON MUTINY GENERAL PARTNERSHIP permit the inspection
25 and photographing (both still photos and video graphic form) of the real property which forms
26 the basis of the subject litigation, commonly referred to as 14382 Red Hill Avenue, #17, Tustin,
27 California at 10:00 a.m. on January 21, 2018
28
DEMAND FOR INSPECTION, SET NO ONE.
1
 1

2 DEMAND FOR INSPECTION

3 Demand For Inspection No. 1:

4 That certain real property located at 14382 Red Hill Avenue, #17, Tustin, California

5 including any and all dwellings, and adjacent property, in addition to the real property itself.

6 Please note that this inspection demand includes not only the physical inspection of the

7 property, but such non-destructive testing as may be required. It further includes the complete

8 photographing of the property by still photos in addition to videotape or other film recording

9 and reproduction.

10 Pursuant to C.C.P. §2031.030(c)(4) the propounding party does not anticipate that the

11 referenced activity will permanently alter or destroy the property in question. Propounding

12 party expressly reserves the right to have the attendance at the inspection of

13 any and all experts (designated or otherwise) so chosen by propounding party.

14

15

16

17
DATED: 12/14/2018
18
By:__________________________
19 Ryan James Smythe
20 Attorney for Plaintiffs Bernardo
Magana & Yesenia Gonzales
21

22

23

24

25

26
27

28
DEMAND FOR INSPECTION, SET NO ONE.
2
 1
PROOF OF SERVICE
2
STATE OF CALIFORNIA, ORANGE
3
I am employed in the County of San Diego, State of California. I am over the age of
4 eighteen years and not a party to or interested in the within entitled cause. My business address
5 is 3810 31st, San Diego, CA 92104.

6 On December 14, 2018, I caused to the following documents: DEMAND FOR

INSPECTION to be served on the interested parties to this action by:
7
Edward W. Seo
8
Craig L. Dunkin
9 LEWIS BRISBOIS BISGAARD & SMITH
LLP
10 633 West 5th Street, Suite 4000
Los Angeles, CA 90071
11 Telephone: (213) 250-1800
Facsimile: (213) 250-7900
12

13 Attorneys for Defendants,

PRISON MUTINY GENERAL
14 PARTNERSHIP
15 BY MAIL: by placing a true copy thereof enclosed in a sealed envelope with first class
postage thereon fully prepaid in the United States Post Office at San Diego, California.
16
I am readily familiar with the business practices for the collection and processing of
17 correspondence for mailing with the United States Post Office.

18 BY PERSONAL DELIVERY: by causing to be hand delivered, a true copy thereof to

the person(s) addressed above.
19
20
BY FACSIMILE: by telecopying a true copy thereof to the party(ies) at the facsimile
21 number(s) as set forth above.

22 I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
23

24 Executed on December 14, 2018, San Diego, California.

25
______________________________
26
Flavia Riccitelli
27

28
DEMAND FOR INSPECTION, SET NO ONE.
3