GARY ROBINSON

0000 Lindblade Dr. #10a

Los Angeles, CA 90066

310-398-0000

Plaintiff

 

 

 

 

MUNICIPAL COURT OF CALIFORNIA

COUNTY OF LOS ANGELES

West Los Angeles

1633 Purdue Avenue,

Los Angeles, CA 90025

GARY ROBINSON,

Plaintiff,

vs.

Alex Gorby,

Maxser & Co. LTD,

David Devlin, Does one through ten inclusive,

Defendants.

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Case No.: No. 00T05214

REQUEST FOR ADMISSIONS

 

 

REQUESTS FOR ADMISSION, SET NUMBER 1, ARE HEREBY PROPOUNDED TO : David Devlin, By Gary Robinson.

To Defendant, David Devlin, and Muchison & Cumming, his Attorneys:

Plaintiff, Gary Robinson, hereby request that you admit within 30 days from the date of the service of this request, the truth of the matters of fact herein listed.

    1. Defendant, David Devlin, has an ownership interest in Maxser & Co. Ltd, and/ or some or all of its incorporated businesses.
    2. Defendant, David Devlin, has been promised an ownership interest in Maxser & Co. Ltd, and/ or some or all of its incorporated businesses.
    3. Defendant, David Devlin, received three copies of this complaint, Case No. 00T05214.
    4. Defendant, David Devlin, gave one or more copies of this complaint, Case No. 00T05214. to Defendant, Alex Gorby.
    5. Defendant, David Devlin, discussed this complaint, Case No. 00T05214. with Defendant, Alex Gorby.
    6. Defendant, David Devlin, has knowledge that the Defendant, David Devlin's defence of this law suit is being paid for in whole or part by Defendant, Alex Gorby, and/or Maxser & Co. LTD.
    7. Defendant, David Devlin, made a oral agreed with Plaintiff, Gary Robinson, that Plaintiff Gary Robinson's probationary period of employment would end after successfully completing, three months of employment.
    8. Defendant, David Devlin, made a oral agreed with Plaintiff, Gary Robinson, to give Plaintiff, Gary Robinson, Company paid health insurance after successfully completing, three months of employment.
    9. All employees who have worked at the job that the Plaintiff was working regardless of shift who completed the said three month probationary period received said company paid health insurance benefits.
    10. Defendant, David Devlin, knows that Plaintiff, Gary Robinson, received a year end bonus.
    11. Defendant, David Devlin, knows that all employees did not receive a year end bonuses.
    12. Defendant, David Devlin, knows that room rentals increased during the period of Plaintiff, Gary Robinson's employment as compared to comparable shifts, day of week, and time of year.
    13. Defendant, David Devlin, knows that motel rentals increased during the period of Plaintiff, Gary Robinson's employment.
    14. Defendant, David Devlin, employed the son of a more or less close friend at the Jolly Roger Hotel.
    15. Defendant, David Devlin, knows that the above referenced son was repeatedly tardy to work.
    16. Defendant, David Devlin, knows that the above referenced son's repeated tardiness forced Plaintiff, Gary Robinson, to work overtime as the result of the tardiness.
    17. Defendant, David Devlin, knows that Plaintiff, Gary Robinson, after repeatedly complaining to Defendant, David Devlin, complained to Alex Gorby about the above referenced son's tardiness.
    18. Defendant, David Devlin, knows that the above referenced son was terminated by Defendant, Alex Gorby.
    19. Defendant, David Devlin, blames Plaintiff, Gary Robinson, for the above referenced son's termination.
    20. Defendant, David Devlin, falsely denied making the above referenced agreement to pay for Plaintiff's health insurance.
    21. Defendant, David Devlin, terminated Plaintiff Gary Robinson's employment.
    22. Defendant, David Devlin, had no just cause for the termination of Plaintiff, Gary Robinson.
    23. Defendant, David Devlin, terminated Plaintiff, Gary Robinson, believing that the Plaintiff would make a complaint to the State Labor Board in reference to the Defendant's denial of promised health insurance benefits.

Dated _______________

_________________________________

Gary Robinson
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