William Hardy vs. Winifred WilsonMotion to Compel Production/Inspection of Documents or ThingsCal. Super. - 4th Dist.April 21, 2017K A H N | R O V E N 5 5 5 0 T o p a n g a C a n y o n Bl vd ., Su it e 2 0 0 W O O D L A N D H U L L S , C A L I F O R N I A 9 1 3 6 7 P h o n e : ( 8 1 8 ) 8 8 8 - 9 1 7 1 Fa x: (8 18 ) 8 8 8 - 7 6 1 1 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Robert A. Kahn, State Bar No. 92746 Jonathan D. Roven, State Bar No. 284614 KAHN ROVEN, LLP 5550 Topanga Canyon Blvd., Suite 200 Woodland Hills, CA 91367 (818) 888-9171 Attorneys for Plaintiff William Hardy SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ORANGE William Hardy Plaintiff, v. Winifred Wilson, an individual; Cross Creek Care, Inc., a California corporation, Defendants. s t t t ” u t “ p t ? “ s e m e “ s s “ s g t ” “ e g g ? “ e g g “s mu t” “ n e g ” CASE NO: 30-2017-00916032-CU-PA-CJC NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO PLAINTIFF’S REQUESTS FOR PRODUCTION OF DOCUMENTS (SET ONE); REQUEST FOR MONETARY SANCTIONS AGAINST COUNSEL FOR DEFENDANT, DANIELS, FINE, ISRAEL, SCHONBUCH & LEBOVITZ, LLP IN THE AMOUNT OF $4,610; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF; DECLARATION OF JONATHAN D. ROVEN [Filed concurrently with Separate Statement and Proposed Order] Date: January 25, 2018 Time: 2:00 PM Location: Dept. C15 Reservation Number: 72691139 TO EACH PARTY AND THEIR ATTORNEYS OF RECORD HEREIN: YOU ARE HEREBY NOTIFIED THAT on January 25, 2018 at 2:00 PM or as soon thereafter as the matter can be heard in Dept. C15 of the above-entitled Court located at 700 Civic 1 MOTION TO COMPEL RESPONSES TO REQUESTS FOR PRODUCTION (SET ONE) K A H N | R O V E N 5 5 5 0 T o p a n g a C a n y o n Bl vd ., Su it e 2 0 0 W O O D L A N D H I L L S , C A L I F O R N I A 9 1 3 6 7 P h o n e : ( 8 1 8 ) 8 8 8 - 9 1 7 1 Fa x: {8 18 } 8 8 8 - 7 6 1 1 9 10 11 {| Dated: November 1, 2017 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Center Drive West, Santa Ana, CA 92701, Plaintiff WILLIAM HARDY will move the Court for an order compelling responses and further responses to discovery, and to rule on boilerplate objections and have all objections removed from discovery, in regard to Requests for Production of Documents (Set One) pursuant to Code of Civil Procedure Sections 2023, 2031. This shall also serve as notice of a Request for Sanctions against Defendant’s counsel, DANIELS, FINE, ISRAEL, SCHONBUCH & LEBOVITZ, LLP in the amount of $4,610. The motion will be based uponthis notice, the attached memorandum ofpoints and authorities in support thereof, the declaration of Jonathan Roven, the files and recordsin this action, and any further evidence and argumentthat the Court mayreceive at or before the hearing. KAHN ROVEN, jLLP ROBERT KAH JONATHAN D. ROVEN__ Attorneys for Plaintiff WILLIAM HARDY 2 MOTION TO COMPEL RESPONSES TO REQUESTS FOR PRODUCTION (SET ONE) K A H N | R O V E N 5 5 5 0 T o p a n g a C a n y o n Bl vd ., Su it e 2 0 0 W O O D L A N D H I L L S , C A L I F O R N I A 9 1 3 6 7 P h o n e : (8 18 ) 8 8 8 - 9 1 7 1 Fa x: (8 18 ) 8 8 8 - 7 6 1 1 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MEMORANDUM OF POINTS AND AUTHORITIES 1. STATEMENT OF FACTS Thisis a straightforward car accident case. Plaintiff was driving with Defendant as a passenger, when Defendant caused a car accident, which injured the Plaintiff, Plaintiffis in his mid-80s and is suffering from poor health. Plaintiff has filed a motion for trial preference based on his age and health. Plaintiff then went in ex parte and had the hearing for the motion fortrial preference advanced. There is an urgency to obtaining Defendant’s discovery responses as Plaintiff is trying to proceed to trial on a preferred basis. On August 7, 2017, Plaintiff served Form Interrogatories (Set One), Requests for Production of Documents (Set One), and Requests for Admissions (Set One). Exhibits 1, 2, and 3. On September8, 2017, Defendant requested a 2-week extension. Plaintiff agreed. Exhibit On September 25, 2017, Defendant requested another 2-week extension. Plaintiff agreed. Exhibit 4. On October 9, 2017, Defendant requested a 1-week extension. Plaintiff agreed. Exhibit 4. On October 16, 2017, Defendant requested a 1-day extension. Plaintiff agreed. Exhibit 4. On October 17, 2017, Defendant requested a 3-day extension. Plaintiff did not agree. Exhibit 4. On October 17, 2017, Defendant served boilerplate responses to all discovery. Not a single response was contained in discovery. Exhibits 5, 6, and 7. On October 20, 2017, Plaintiff’s counsel sent a meet and confer letter to Defendant’s counsel, requesting that Defendant remove all objections and send complete responses and a privilege log by October 27, 2017. Exhibit 8. No response. On October 30, 2017, Plaintiff's counsel sent another meet and conferletter, indicating that it has been nearly 3 months and Defendant has not given a single response, leaving Plaintiffno option but to turn to the Court. Exhibit 8. 3 MOTION TO COMPEL RESPONSES TO REQUESTS FOR PRODUCTION (SET ONE) K A H N | R O V E N 5 5 5 0 T o p a n g a C a n y o n Bi vd ., Su it e 2 0 0 W O O D L A N D H I L L S , C A L I F O R N I A 9 1 3 6 7 P h o n e : ( 8 1 8 ) 8 8 8 - 9 1 7 1 F a x : { 8 1 8 ) 8 8 8 - 7 6 1 1 O r d d W N 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Defendants counsel responded that they would like to discuss a stipulation to liability. They stated, “I asked you to call me regarding a stipulation re liability, but have received no call. What's better than discovery responses: a stipulation to liability. Please call me back.” Exhibit 8. Plaintiff’s counsel responded, “Please cite me some authority that says offering a stipulation to liability absolves a party from responding to discovery.” Exhibit 8. Defendant’s counsel responded, “Are you saying that you would rather do discovery than get a stipulation to liability? Do you plan on returning my calls about this? Iam at a complete loss as to what purpose your “meet and confer” efforts serve, when you refuseto return my calls despite my multiple requests.” Exhibit 8. Plaintiffs counsel called and left a message, and documented as such. Exhibit 8. To date, Defendant has not responded to a single discovery request. 2. ARGUMENT A. Plaintiff is Entitled to Discovery Responses. California's Discovery Act grants parties in litigation liberal rights to discovery. (Greyhound Corp. v. Sup. Ct. (1961) 56 Cal. 2d 355, 377-78; Colonial Life & Acc. Ins. Co. v. Sup. Ct. (1982) 31 Cal. 3d 785, 790; Emerson Elec. Co. v Sup. Ct. (1997) 16 Cal. 4th 1101, 1108.) A party is entitled to disclosure in discovery as “a matter ofright unless statutory or public policy considerations clearly prohibitit.” (Greyhound Corp. v. Sup. Court (1961) 56 Cal.2d 355, 378; Code Civ. Proc. §2017.010.) California courts havereiterated that discovery provisionsin the Civil Discovery Act of 1986, and the Civil Discovery Act which replacedit, are to be liberally construed in favor of disclosure. (Flagship Theatres ofPalm Des, LLC v Century Theatres, Inc. (2011) 198 Cal.App.4th 1366, 1383). Plaintiffs may seek information related not only to their claims, but to a defendant's contentions and defenses. (Code Civ. Proc. §§2017.010, 2030.010(b), 2033.010; Burke v. Sup. Ct. (1969) 71 Cal. 2d 276, 281-82.) The scope ofrelevant discovery is “relevancyto the subject matter” of the case, a broader concept than “relevancy to the issues.” (Pacific Tel. & Tel Co. v. Sup. Court. (1970) 2 Cal.3d 163, 172. 4 MOTION TO COMPEL RESPONSES TO REQUESTS FOR PRODUCTION (SET ONE) K A H N | R O V E N 5 5 5 0 T o p a n g a C a n y o n Bl vd ., S u i t e 2 0 0 W O O D L A N D H I L L S , C A L I F O R N I A 9 1 3 6 7 P h o n e : (8 18 ) 8 8 8 - 9 1 7 1 Fa x: (8 18 ) 8 8 8 - 7 6 1 1 B. Defendant's Objections to Plaintiffs' Requests for Production of Documents are Improper. A party responding to a request for production must timely reply to each request with a statement that it will produce the documents and things requested; a representation that it lacks the ability to comply; or an objection. (Code Civ. Proc. §§2031.210(a), 2031.220, 2031.280(b).) If only part of the request is objectionable, the party must respond to the remainder of the request. (Code Civ. Proc. §2031.240(a).) A statement that the responding party is unable to comply must affirm that a diligent and reasonable search has been conducted, and state the specific reason the party is unable to comply with the request. (Code Civ. Proc. §2031.230.) Objections must identify the specific document request that is objectionable, and set forth the specific grounds for any objection. (Code Civ. Proc. §2031.240(b).) If an objection to production is made on grounds that particular documentsare protected by privilege, a “privilege log” must be produced to allow examination ofthe claim ofprivilege. (Code Civ. Proc. §2031.240(c)(2).) Asset forth in Plaintiff’s Separate Statement, Defendant has not responded to a single request, but instead objects to all of them. Defendant has asserted identical boilerplate objections to each and every one of Plaintiffsrequests, including claims ofprivilege which Defendant has failed to substantiate despite Plaintiffs’ request for a privilege log. C. Defendant’s Actions Are Sanctionable. Where general boilerplate objections were made, courts have authority to compel further responses (but not to find a waiver ofprivilege objections). Best Products, Inc. v. Sup. Ct. (2004) 119 Cal.App.4th 1181, 1189. Making objections in a boilerplate fashion is improper and can be sanctioned. Korea Data Systems Co. Ltd. v. Superior Court (1997) 51 Cal. App. 4th 1513, 1516. “[TThe fact that a party is conducting discovery... shall not operate to delay the discovery of any other party.” C.C.P. § 2019.020. Objections without merit or too general and incomplete/evasive responses are sanctionable and can be compelled for a further response. C.C.P. §§ 2030.300, 2031.310, 2033.290. 5 MOTION TO COMPEL RESPONSES TO REQUESTS FOR PRODUCTION (SET ONE) K A H N | R O V E N 5 5 5 0 T o p a n g a C a n y o n Bl vd ., Su it e 2 0 0 W O O D L A N D H I L L S , C A L I F O R N I A 9 1 3 6 7 P h o n e : ( 8 1 8 ) 8 8 8 - 9 1 7 1 Fa x: {8 18 ) 8 8 8 - 7 6 1 1 > W w N D 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 The court shall impose a monetary sanction against any party, person, or attorney who unsuccessfully makes or opposes a motion to compela response. C.C.P. §§ 2030.290, 2031.310, 2033.290 Here, the Defendant provided only boilerplate objections, no responses. Plaintiff requests multiple times for responses, to no avail. Plaintiffhas no other option but to turn to the Court for assistance. Plaintiff's counsel has spent approximately 4 hours drafting this motion and supporting documents. Plaintiff’s counsel anticipates spending 1 hour reviewing Defendant’s Opposition. Plaintiff’s counsel anticipates spending 3 hours drafting a Reply. Plaintiff's counsel anticipates spending 5 hourstraveling to, from, and attending the hearing on this motion to compel. Plaintiff has spent $60 filing this motion. Plaintiff's counsel’s hourly rate is $350 based on his experience and skill. Plaintiff's counsel anticipates spending approximately 13 hours on this motion. Plaintiff requests sanctions in the amount of $4,610. 3. CONCLUSION Based on the foregoing, Plaintiff requests that Defendant is ordered to provide complete responses without objections, and production ofall documents responsiveto the requests, and that Defendant’s counsel ofrecord DANIELS, FINE, ISRAEL, SCHONBUCH & LEBOVITZ, LLP is sanctioned in the amount of $4,610. Dated: October 31, 2017 KAHN ROVEN, LLP ROBERT Al JONAT AND,ROVEN Attorneys for Plaintiff WILLIAM HARDY 6 MOTION TO COMPEL RESPONSES TO REQUESTS FOR PRODUCTION (SET ONE) K A H N | R O V E N 5 5 5 0 T o p a n g a C a n y o n Bl vd ., Su it e 2 0 0 W O O D L A N D H I L L S , C A L I F O R N I A 9 1 3 6 7 P h o n e : (8 18 ) 8 8 8 - 9 1 7 1 Fa x: (8 18 ) 8 8 8 - 7 6 1 1 D O ~ ~ o y U r 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DECLARATION OF JONATHAN ROVEN I, Jonathan Roven, declare as follows: 1. 1, Jonathan Roven, am an attorney at law duly authorized to practice law in all courts of the State of California. I am a memberofthe firm, KAHN ROVEN, LLP, attorneys of record for Plaintiff in this action. I have personal knowledge of all matters set forth herein and if called as a witness I could and would testify thereto. 2. On August 7, 2017, Plaintiff served Requests for Production ofDocuments (Set One). Exhibit 1. On September 8, 2017, Defendant requested a 2-week extension. Plaintiff agreed. Exhibit 2. On September25, 2017, Defendant requested another 2-week extension. Plaintiff agreed. Exhibit 2. On October 9, 2017, Defendant requested a 1-week extension. Plaintiff agreed. Exhibit 2. On October 16, 2017, Defendant requested a 1-day extension. Plaintiff agreed. Exhibit 2. On October 17, 2017, Defendant requested a 3-day extension. Plaintiff did not agree. Exhibit 2. On October 17, 2017, Defendant served boilerplate responses to all discovery. Not a single response was contained. Exhibit 3. On October 20, 2017, Plaintiffs counsel sent a meet and confer letter to Defendant’s counsel, requesting that Defendant remove all objections and send complete responses and a privilege log by October 27, 2017. Exhibit 4. No response. On October 30, 2017, Plaintiffs counsel sent another meet and conferletter, indicating that it has been nearly 3 months and Defendant has not given a single response, leaving Plaintiff no option butto turn to the Court. Exhibit 4. Defendant’s counsel responded that they would like to discuss a stipulation to liability. Theystated, “I asked you to call me regarding a stipulation re liability, but have received no call. What's better than discovery responses: a stipulation to liability. Please call me back.” Exhibit 4. 7 MOTION TO COMPEL RESPONSES TO REQUESTS FOR PRODUCTION (SET ONE) K A H N | R O V E N 5 5 5 0 T o p a n g a C a n y o n Bl vd ., Su it e 2 0 0 W O O D L A N D H I L L S , C A L I F O R N I A 9 1 3 6 7 P h o n e : (8 18 ) 8 8 8 - 9 1 7 1 Fa x: (8 18 ) 8 8 8 - 7 6 1 1 s o w N D 10 11 12 13 14 15 16 17 18 18 20 21 22 23 24 25 26 27 28 Plaintiff's counsel responded, “Please cite me some authority that says offering a stipulationto liability absolves a party from responding to discovery.” Exhibit 4. Defendant’s counsel responded, “Are you saying that you would rather do discovery than geta stipulation to liability? Do you plan on returning my calls about this? Iam at a complete loss as to what purpose your “meet and confer” efforts serve, when you refuse to return my calls despite my multiple requests.” Exhibit 4. Plaintiff's counsel called and left a message, and documented as such. Exhibit 4. To date, Defendant has not responded to a single request for production norhas a single document been produced. 3. Plaintiff's counsel has spent approximately 4 hours drafting this motion and supporting documents. Plaintiff’s counsel anticipates spending 1 hour reviewing Defendant’s Opposition. Plaintiff's counsel anticipates spending 3 hours drafting a Reply. Plaintiff's counsel anticipates spending 5 hours traveling to, from, and attending the hearing on this motion to compel. Plaintiff has spent $60 filing this motion. Plaintiff’s counsel’s hourly rate is $350 based on his experience and skill. Plaintiff’s counsel anticipates spending approximately 13 hours on this motion. Plaintiff requests sanctions in the amount of $4,610. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on October 31, 2017 in Woodland Hills, CA. | Jonathan Rov \ 8 MOTION TO COMPEL RESPONSES TO REQUESTS FOR PRODUCTION (SET ONE) Exhibit 1 K A H N | R O V E N 55 50 To pa ng a Ca ny on Bl vd , Su it e 20 0 W O O D L A N D H I L L S , C A L I F O R N I A 9 1 3 6 7 P h o n e : (B 18 ) 88 8- 91 71 Fa x (8 18 ) 88 8. 76 11 10 11 12 13 14 15 ile 17 18 19 20 21 22 23 24 25 26 27 28 - Robert A. Kahn, State Bar No. 92746 Jonathan D. Roven, State Bar No. 284614 KAHN IROVEN,LLP 5550 Topanga Canyon Blvd., Suite 200 Woodland Hills, CA 91367 (818) 888-9171 Attorneys for PlaintiffWilliam Hardy SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ORANGE William Hardy CASE NO: 30-2017-00916032-CU-PA-CIC Plaintiff, PLAINTIFF WILLIAM HARDY'’S REQUEST FOR PRODUCTION OF ) ) ) V. DOCUMENTS TO DEFENDANT ) ) ) Winifred Wilson, an individual; Cross WINIFRED WILSON Creek Care, Inc., a California corporation, Defendants. ) DEMANDING PARTY: PLAINTIFF WILLIAM HARDY RESPONDING PARTY: DEFENDANT WINIFRED WILSON SET NUMBER: ONE TO DEFENDANTS AND ITS ATTORNEYS OF RECORD HEREIN: PLEASE TAKE NOTICEthat PlaintiffWILLIAM HARDY, an individual, pursuant to California Code of Civil Procedure, Section 2031, hereby demands that the above named Defendant produce for inspection and copying each of the documents or categories of documents hereinafter described, by delivering them to the KAHN ROVEN, LLP, 5550 Topanga Canyon Boulevard, Suite 200, Woodland Hills, CA 91367, within thirty (30) daysofservice (plus five (5) daysifthis demand was served by mail). 1 PLAINTIFF WILLIAM HARDY’S REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT WINIFRED WILSON K A H N | R O V E N 55 50 T o p a n g a C a n y o n Bl vd . Su it e 2 0 0 W O O D L A N D HI LL S, C A L I F O R N E A 91 36 7 Ph on e: (8 18 ) 88 8- 91 71 Fa x: {B 18 ) R8 8. 76 11 10 11 12 13 14 15 16 17 18 i9 20 21 22 23 24 25 26 27 28 | If objection is made to only part of an item or category of item requested in this demand, said response shall contain a statement of compliance,or a representation of inability to comply with respect to the remainder of that item or category. A statement that Defendant will comply with this demand shall state that the production and inspection will be allowed either in whole or in part and that all documents or things in a demanded category that are in the possession, custody or control ofDefendant and to which no objection is being made will be included in the production. A representation ofinability to comply with any particular item or category of items demanded shall affirm that a diligent search and a reasonable inquiry has been made in an effort to comply with the demand and the statement shall also specify whether the inability to complyis because the particular item or category ofitem, (a) has never existed, (b) has been destroyed, {c) has beenlost, misplaced, or stolen, or (d) has never been, or is no longer, in the possession, custody or control ofDefendant, as well as the name and address of any natural person or organization known or believed by Defendant to have possession, custody, or control of that item or category ofitem. DEFINITIONS AND INSTRUCTIONS 1. The term "document" shall be given a meaning atleast as broad as the word "writing" is given in Evidence Code §250, and includes every non-identical copy (i.e., any "document" which initially was identical in all respects to another "document" but which is no longeridentical by virtue ofany notation or modification of any kind, including, without limiting the generally ofthe foregoing, notes or modifications on the backs or margins ofpages thereof, or on copies thereof, or by virtue of attachments thereto) of a "document." "Document" also means and includes, withoutlimitation, any written, recorded, or graphic matter, whether produced, reproduced, or stored on paper, cards, tapes, film, electronic facsimile, computer storage devices, memories, data cells, or other data compilations from which information can be obtained, including originals, copies, and drafts, including but not limited to papers, books, projections, 2 PLAINTIFF WILLIAM HARDY’S REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT WINIFRED WILSON K A H N { R O V E N 5 5 5 ( T o p a n g a C a n y o n Bi vd ., Su it e 2 0 0 W O O D L A N D [{ I1 1S , C A L I F O R N I A 9 1 3 6 7 Ph on e: (8 18 ) 88 8- 91 71 Fa s: (8 18 ) R8 8- 76 11 10 11 12 13 14 15 ie 17 18 19 20 21 22 23 24 25 26 27 28 - _ - accounting books, accounting ledgers, surveys,letters, emails, text messages, tangible things, correspondence, telegrams, cables, telex messages, memoranda, notes, notations, work papers, manuscripts, minutes, reports, recordings oftelephone conversations, interviews, conferences, or other meetings, affidavits, statements, summaries, opinions, reports, studies, analyses, evaluations, appraisals, estimates, projections,charts, schedules, work sheets, proposals, contracts, agreements, statistical records, accident reports, desk calendars, appointment books, diaries, medical records, medical reports,lists, tabulations, sound recordings, computer print-outs, data processing output and input, microfilms, photographs or negatives thereof, motion pictures, videotapes,all other records kept by electronic, photographic, or mechanical means, and all things similar to the foregoing, however denominated, and any or all matter or material applied to any ofthe above. DOCUMENTSshall also be defined as any electronic communication sent and received by mobile phone, PDA,or other electronic device, including but not limited to text messages, emails, electronic messages in any application, voice mails, voice recordings, videos, Whatsapp messages and Facebook messages) YOU sent to anyone, aside from your attorneys, regarding the incident which is the subject ofthis litigation. 2. YOU or YOUR refers to the PLAINTIFF and all persons acting on your behalf, including but is not limited to, your family members, representatives, attorneys, agents, employees, investigators, accountants, bookkeepers, and appointees, whether they be hired, retained, or appointed by you, your attorneys,or their representatives. 3. In responding to this request, you are to identify and produce all documents and other things in your possession, custody and control, including all documents and other things in the possession, custody, and control ofpersonsacting on your behalf. 4, The term "person(s) acting on your behalf" includes, but is not limited to, your family members, representatives, attorneys, agents, employees, investigators, accountants, bookkecepers, and appointees, whether they be hired, retained, or appointed by you, your attorneys, or their representatives. 3 PLAINTIFF WILLIAM HARDY’S REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT WINIFRED WILSON K A H N | R O V E N 55 50 T o p a n g a C a n y o n Bl vd ., Su it e 2 0 0 W O O D L A N D HI LL S, C A L I F O R N I A 91 36 7 Ph on e: (B 18 ) B8 8- 91 71 Fa s: (8 18 ) 88 B- 76 11 10 11 12 13 14 15 16 17 18 1s 20 21 22 23 24 25 26 27 28 5. "And" as well as "or" are intended to be construed liberally so as to bring within the scope of each request all documents and other things which might otherwise be construed to be outside the scope ofthat request. Similarly, the singular is intended to include the plural, and vice versa, whichever results in the broader request. 6. In the event that any document or other thing called for by any request has been destroyed, discarded, or otherwise disposed of, that documentor other thing is to be identified as completely as possible, and the following informationis to be provided: date ofdisposal, manner of disposal, reason for disposal, person authorizing the disposal, and person disposing ofthe document or otherthing. 7. If you claim that any privilege orthe attorney work-product doctrine is applicable to any documentor otherthing, the production of which is sought by any request, you shall, with respect to that document or other thing: (a) State the date ofthe origination, drafting, making or taking thereof: (b) Identify each and every author, maker or originator thereof; (c) Identify each and every person who appeared or participated in the preparation thereof; (d) Identify each and every person who received the document or other thing; (e) State the present location ofthe document or other thing and all copies thereof; ® Identify each and every person who has or ever had possession, custody or control ofthe documentor other thing or any copy thereof. 8. Though the following requests are to be construed liberally, they are not intended to encompass documents which are privileged or protected bythe attorney work-product doctrine. Therefore, should a request encompass both protected and non-protected documents please produce the non-protected documents and the non-privileged portions ofprotected documents and provide a privilege log for those documents which are protected. 4 PLAINTIFF WILLIAM HARDY’S REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT WINIFRED WILSON K A H N | R O V E N 55 50 To pa ng a Ca ny on B h d , Su it e 20 0 W O O D L A N D HI LL S, C A L I F O R N I A 91 36 7 T h o n e : (8 18 ) 88 8- 91 71 Fa x: (8 18 ) 88 8- 76 11 10 11 12 13 14 15 16 17 is 19 20 21 22 23 24 25 26 27 28 DEMAND FOR PRODUCTION 1. Any and all photographs ofthe scene ofthe accident. 2. Any and all photographs ofthe vehicle of the Propounding Party. 3. Any and all photographs of the vehicle ofthe requesting Responding Party. 4. Any and all photographs of any other vehicles and/or objects involved in the accident. 5. Any and all photographs of Plaintiff's person, purporting to depictvisible signs ofinjuries claimed to have been suffered in the accident. 6. Any and all statements, in any form, ofpersons who witnessed or claim to have witnessed the accident, and/or the events immediately prior to and/or subsequent to the accident {i.e., while any party to the accident was still at the scene thereof). 7. Any and all statements, in any form, secured or obtained in any way from the Plaintiff(s). 8. Any and all reports by law enforcement agencies regarding the occurrence ofthis accident including, but not limited to, traffic accident reports and supplements thereto, arrest reports, and booking reports. 9. Any and all estimates of the cost of repairs to the property ofthe Defendant(s), including, but notlimited to, the vehicle ofthe Defendant(s) allegedly damaged as a result of the accident. 10. Any and all repairbills for repairs actually made to the vehicle ofthe Defendant(s) as a result of the accident. 11. Any and all documents in your possession, custody or control evidencing that you were covered by automobile liability insurance atthe time ofthe subject accident. Such documents shall include, but are not limited to, a legible copy ofsaid policy, declaration page and insurance card. 12. Any and all documents reflecting each cellular, mobile, telephone, voice or data communication received or transmitted by anyone in the vehicle you were driving which occurred within 30 minutes before and after the subject incident. 13. Any and all documents identified in your responses to Form Interrogatories (Set One). 5 PLAINTIFF WILLIAM HARDY’S REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT WINIFRED WILSON K A H N I R O V E N 5 5 5 0 T o p a n g a C a n y o n Bl vd , Su it e 2 0 0 W O O D L A N D H I L L S , C A L I F O R N I A 9 1 3 6 7 Ph on e: (8 18 ) 88 8- 91 71 Fa x: (B 18 ) 88 8- 76 11 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 14. Any and all documents reflecting ownership of Responding Party’s vehicle. 15. A true and correct copy of Responding Party’s driver's license. 16. Any and all DOCUMENTS anyone sent to YOU, but notincluding those sent to YOU by YOURattorneys, or YOURattorneys to YOU, regarding the incident which is the subject of this litigation. Dated: August 7, 2017 Attorneys for Plainti William Hardy 6 PLAINTIFF WILLIAM HARDY’S REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT WINIFRED WILSON PROOF OF SERVICE (STATE) The undersigned declares that 1 am employed in the County ofLos Angeles, State of California; I am over the age of eighteen years and am not a party to this action; my business addressis 5550 Topanga Canyon Boulevard, Suite 200, Woodland Hills, California 91367, in said County and State. On the date set forth below I served the following document: PLAINTIFF WILLIAM HARDY’S REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT WINIFRED WILSON on the interested parties in this action, by placing true copies thereofin a sealed envelope addressed as follows: Scott M. Leavitt Daniels, Fine, Israel, Schonbuch & Lebovits, LLP 180! Century Park East Ninth Floor Los Angeles, California 90067 BY MAIL X Byplacing said documentsin an envelope or package and then sealing said envelope and depositing the same, with postage thereon fuily prepaid, at a post office or, mailbox, subpost office, substation or mail chute or otherlike facility regularly maintained by the United States Postal Service, at Woodland Hills, California; that there is a regular communication between the place of mailing and the place(s) so addressed. BY FAX - In addition to service by mail, I transmitted a copy ofthe foregoing document(s) this date via telecopierto the facsimile number(s) shown above, BY OVERNIGHT DELIVERY SERVICE -_- By placing said document(s) in an envelope or package designated by the overnight delivery carrier, and then sealing said envelope and depositing the same with fees paid or provided forin a box or other facility regularly maintained by the overnight delivery carrier or delivered to an authorized carrier or driver authorized by the express service carrierto receive documents Federal Express collection box at Woodland Hills, California; that there is a regular communication between the place of deposit and the place(s) so addressed. BY E-MAIL/ELECTRONIC TRANSMISSION MAIL Based upon a court order or an agreement of the parties to accept service by electronic transmission,1 caused the above referenced documents(s) to be sentto the person(s) at the electronic notification address(es) listed below. 1 did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. BY PERSONAL SERVICE By delivering such envelope by hand to the offices of addressee. I declare under penalty ofperjury, under the laws ofthe State of California, that the foregoing is true and correct. Executed on August 7, 2017 at Woodland Hills, California. B BETH MARK Sung (Please Print) Signature S- Exhibit 2 Jonathan Roven te From: Katherine Bruce Sent: Friday, September 08, 2017 4:40 PM To: Jonathan Roven Cc: Claire Evans Subject: 3010-27: Hardy v. Wilson - Def Discov Resp Importance: High Follow Up Flag: Flag for follow up Flag Status: Completed Hi Jonathan, Please accept this email as confirmation of the voicemail that I left for you a moment ago regarding the above-entitled matter. Defendants have responses to Plaintiff's first set of form interrogatories, requests for admissions, and requests for documents due on 9/11/2017. We require more time to gather the information and documents requested and provide verified responses. Please grant us a 2 week extension up to and including 9/25/2017, in orderto respond to the aforementioned discovery requests. We thank you in advance for your courtesy and cooperation in this matter and hope to hear from you soon. Warmest regards, Katherine A. Bruce Daniels, Fine, Israel, Schonbuch & Lebovits, LLP 1801 Century Park East, 9th Floor Los Angeles, California 90067 Phone: {310) 556-7900 Fax: (310) 556-2807 PRIVILEGE AND CONFIDENTIALITY NOTICE This email communication may contain CONFIDENTIAL INFORMATION WHICH ALSO MAY BE LEGALLY PRIVILEGED and is intended only for the use of the intended recipients identified above. If you are not the intended recipient of this communication, you are hereby notified that any unauthorized review, use, dissemination, distribution, downloading, or copying of this communication is strictly prohibited. if you are not the intended recipient and have received this communication in error, please immediately notify us by reply email, delete the communication and destroy all copies. DANIELS, FINE, ISRAEL, SCHONBUCH & LEBOVITS, LLP Circular 230 Disclosure: To assure compliance with Treasury Department rules governing tax practice, we hereby inform you that any advice contained herein {including in any attachment) (1) was not written or intended to be used, and cannot be used, by you or any taxpayer for the purpose of avoiding any penalties that may be imposed on you or any taxpayer and (2) may not be used or referred to by you or any other person in connection with promoting, marketing or recommending to another person any transaction or matter addressed herein. Jonathan Roven VST From: Claire Evans Sent: Monday, September 25, 2017 10:03 AM To: Beth Mark Cc: Katherine Bruce; Jonathan Roven Subject: William Hardy vs. Winifred Wilson et al. Our File No.: 3010-027 Good Morning Beth: Thank you for granting a two week extension on our responses to your discovery requests in the above referenced matter. Our discovery is now due Monday, October 9, 2017. Greatly appreciated. Claire Evans Legal Secretary to Katherine A. Bruce, Esq., and Jeffrey Y. Tsao, Esq. Daniels, Fine, Israel, Schonbuch & Lebovits, LLP 1801 Century Park East, 9th Floor Los Angeles, California 90067 Phone: (310) 556-7900 ext. 4336 Fax: (310) 556-2807 Jonathan Roven 00D From: Claire Evans Sent: Monday, October 09, 2017 2:27 PM To: Jonathan Roven Cc: Katherine Bruce Subject: Hardy, William vs. Wilson, Winifred - 3010.027 Importance: High Good Afternoon Mr. Roven: This e-mail will confirm our request for a 1 week extension from today left with your voicemail. Our request would have our discovery due today ultimately due October 16, 2017. Please confirm receipt, consideration and hopeful granting of this request. Claire Evans Legal Secretary to Katherine A. Bruce, Esq., and Jeffrey Y. Tsao, Esq. Daniels, Fine, Israel, Schonbuch & Lebovits, LLP 1801 Century Park East, 9th Floor Los Angeles, California 90067 Phone: {310} 556-7900 ext. 4336 Fax: (310) 556-2807 Jonathan Roven POET From: Katherine Bruce Sent: Monday, October 16, 2017 12:10 PM To: Jonathan Roven Cc: Claire Evans; Robert Kahn Subject: RE: Hardy v Wilson - Winifred Wilson Deposition I'm sorry; | don't know why that was sent out that way. I'll draft and send an amended notice of Plaintiff's deposition to 11/6/2017, in Orange County. Does Plaintiff still live in Orange County? | don't think he is a resident at Cross Creek any longer. Also, | confirmed my client's availability for her deposition on 11/8/2017 in Orange County. Please let me know the date and time. On a related note, | should find out by today, whether my client has had enough time to return verified responses. lam worried that won't happen until the end of the day and | don't want to miss mail cut-off. Can we have a one-day extension to 10/17/2017 to send you verified responses? Best, Katherine A. Bruce Daniels, Fine, Israel, Schonbuch & Lebovits, LLP 1801 Century Park East, 9th Floor Los Angeles, California 90067 Phone: (310) 556-7900 Fax: (310) 556-2807 PRIVILEGE AND CONFIDENTIALITY NOTICE This email communication may contain CONFIDENTIAL INFORMATION WHICH ALSO MAY BE LEGALLY PRIVILEGED and is intended only for the use of the intended recipients identified above.If you are not the intended recipient of this communication, you are hereby notified that any unauthorized review, use, dissemination, distribution, downloading, or copying of this communication is strictly prohibited. If you are not the intended recipient and have received this communication in error, please immediately notify us by reply email, delete the communication and destroy all copies. DANIELS, FINE, ISRAEL, SCHONBUCH & LEBOVITS,LLP Circular 230 Disclosure: To assure compliance with Treasury Departmentrules governing tax practice, we hereby inform you that any advice contained herein (including in any attachment) (1) was not written or intended to be used, and cannot be used, by you or any taxpayerfor the purpose of avoiding any penalties that may be imposed on you or any taxpayer and (2) may not be used or referred to by you or any other person in connection with promoting, marketing or recommending to another person any transaction or matter addressed herein. aOriginal Message----- From: Jonathan Roven [mailto:jon@krinjurylaw.com] Sent: Monday, October 16, 2017 8:25 AM Jonathan Roven 00 From: Claire Evans Sent: Tuesday, October 17, 2017 3:54 PM To: Jonathan Roven Cc: Katherine Bruce Subject: William Hardy vs. Winifred Wilson - 3010-027 Follow Up Flag: Follow Up Flag Status: Completed Dear Mr. Roven: Sorry to be such a pest. This e-mail echoes my voicemail requests left today with your office. Our client will provide us verified responses by Friday and, therefore, we are requesting an extension to serve our discovery responses this Friday, October 20, 2017. We await your gracious consideration and granting of our request. Thank you. Claire Evans Legal Secretary to Katherine A. Bruce, Esq, and Jeffrey Y. Tsao, Esq. Daniels, Fine, Israel, Schonbuch & Lebovits, LLP 1801 Century Park East, 9th Floor Los Angeles, California 90067 Phone: (310) 556-7900 ext. 4336 Fax: (310) 556-2807 Jonathan Roven m From: Jonathan Roven Sent: Wednesday, October 18, 2017 8:15 AM To: Claire Evans Cc: Katherine Bruce; Robert Kahn Subject: Re: William Hardy vs. Winifred Wilson - 3010-027 Ms. Evans, We sincerely apologize but we cannot grant any more extensions. The discovery was served on August 5. We are on a fast track with this case. My client is not well so we have to movethis case along as fast as we can. JONATHAN D. ROVEN INJURY LAWYER | KAHN ROVEN,LLP 5550 Topanga Canyon Boulevard, Suite 200 Woodland Hills, CA 91367 = (818)888-9171 & (818) 888- 7611 KAHN ROVEN. Where YOU matter. From: Claire Evans Date: Tuesday, October 17, 2017 at 3:53 PM To: Jonny Roven Cc: Katherine Bruce Subject: William Hardy vs. Winifred Wilson - 3010-027 Dear Mr. Roven: Sorry to be such a pest. This e-mail echoes my voicemail requests left today with your office. Our client will provide us verified responses by Friday and, therefore, we are requesting an extension to serve our discovery responsesthis Friday, October 20, 2017. We await your gracious consideration and granting of our request. Thank you. Claire Evans Legal Secretary to Katherine A. Bruce, Esq, and Jeffrey Y. Tsao, Esq. Daniels, Fine, Israel, Schonbuch & Lebovits, LLP 1801 Century Park East, 9th Floor Los Angeles, California 90067 Phone: (310) 556-7900 ext. 4336 Exhibit 3 w h B x W N O O 0 0 3 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 FAKAB\DISCOV\3010-027.rdfp0l -ww{wh)-ob}.docx DANIELS, FINE, ISRAEL, SCHONBUCH & LEBOVITS, LLP 1801 CENTURY PARK EAST, NINTH FLOOR LOS ANGELES, CALIFORNIA B0087 TELEPHONE (310) 556-7900 FACSIMILE (310) 556.2807 Scott M., Leavitt, State Bar No. 157407 Katherine A. Bruce, State Bar No. 288694 Attorneys For Defendants WINIFRED WILSON and CROSS CREEK CARE, INC. SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ORANGE WILLIAM HARDY, Case No. 30-2017-00916032-CU-PA-CIC {Complaint Filed: May 26, 2017) Plaintiff, [Hon. Peter Wilson, Dept, C15] Vs. DEFENDANT WINIFRED WILSON'S OBJECTIONS TO PLAINTIFF WILLIAM WINIFRED WILSON, an individual; CROSS HARDY’S REQUEST FOR PRODUCTION CREEK CARE, INC., a California corporation; OF DOCUMENTS, SET ONE D 1 TO 19, Defendants. PROPOUNDING PARTY Plaintiff WILLIAM HARDY RESPONDING PARTY : Defendant WINIFRED WILSON SET NUMBER : ONE COME(S) NOW Defendant(s) WINIFRED WILSON (“Responding Party(ies)’s”) and respond(s) to Plaintiff(s) WILLIAM HARDYs (“Plaintiff’s” and/or “Propounding Party(ies)’s”) First of Request for Production ofDocuments pursuant to Code ofCivil Procedure section 2031.210 as follows: PRELIMINARY STATEMENT These responses are made solely for the purpose ofthis action. Each response is subject to all appropriate objections which would require the exclusion ofany evidence contained herein if the material were offered at the time of trial. All objections and grounds are reserved and i DEFENDANT WINIFRED WIL.SON'S OBJECTIONS TO PLAINTIFF WILLIAM HARDY'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE D A N I E L S , F I N E , I S R A E L , S C H O N B U C H & L E B O V I T S , t i e 1 8 0 1 C E N T U R Y P A R K E A S T , N I N T H F L O O R L O S A N G E L E S , C A L I F O R N I A 9 0 0 8 7 T E L E P H O N E ( 3 1 0 ) § 5 6 - 7 9 0 0 F A C S I M I L E ( 3 1 0 ) 5 5 6 - 2 8 0 7 H W 10 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 may be interposed at the time oftrial. The responding party has not yet completed its investigation ofthe facts relating to this action,its discovery in this action, orits preparation fortrial ofthis action. Consequently, these responses are given without prejudice to the right of any responding party to produce at the time oftrial any and all subsequently discovered evidence relating to the proofof presently known material facts, and to produceall evidence, whenever discovered, relating to the proofof subsequently discovered material facts, OBJECTIONS TO DEMANDS FOR PRODUCTION OF DOCUMENTS REQUEST FOR PRODUCTION NO. 1.: Any and all photographs ofthe scene of the accident. OBJECTION TO REQUEST FOR PRODUCTION NO. 1.: Responding Party(ies) object(s) to this request on the grounds set forth in the preliminary statement above and the grounds set forth here: (1) vague and ambiguous/insufficient description; (2) calls for a legal conclusion; (3) calls for speculation; (4) calls for premature disclosure of expert opinion/information/identity and/or improper disclosure of consultants; (5) unreasonably invadesright to privacy ofresponding party(ies); (6) calls for disclosure of privileged attorney client communications and/or work product; (7) calls for irrelevant information/materials not reasonably calculated to lead to the discovery ofadmissible evidence; (8) overbroad & unduly burdensome; (9) duplicative; (10) seeks information/materials already produced/disclosed and/or available to requesting party at the same burden and/or expense; (11) calls for or requires responding party to summarize and/or audit information and/or materials at the same burden/expense as requesting party; (12) calls for privileged and/or protected information/materials protected by case law, statute, regulations, rules, ordinances, and/or constitutions; (13) compound; (14) assumes facts; (15) calls for or requires expert opinion from a lay person or otherwise seeks premature or impermissible disclosure of expert identification and/or opinion; (16) shotgun style interrogatory/request; (17) requires response to prove the non- existence ofa thing or fact; (18) Singer v. Superior Court(1960) 54 Cal.2d 318; Burke v. Superior 2 DEFENDANT WINIFRED WILSON’S OBJECTIONS TO PLAINTIFF WILLIAM HARDY'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE , L L P D A N I E L S , F I N E , I S R A E L , S C H O N B U C H & L E B O V I T S 1 8 0 1 C E N T U R Y P A R K E A S T , N I N T H F L O O R L O S A N G E L E S , C A L I F O R N I A 9 0 0 E 7 T E L E P H O N E ( 3 1 0 ) 5 5 8 - 7 9 0 0 F A C S I M I L E ( 3 1 0 ) 5 5 6 - 2 8 0 7 o e a v n w n o n 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Court (1969) 71 Cal.2d 276; (19) not reasonably accessible electronically stored information and/or production ofelectronically stored information in all forms; (20) improperly expands(via instructions, definitions, or otherwise) the permissible scope of responding party’s duty under the Code; (21) oppression; (22) calis for a narrative; (23) calls for a compilation, audit, abstract, or summary ofdocuments; (24) impermissible pre-trial punitive damages discovery; (25) tax privilege; (26) trade secret privilege; and (27) collateral source. Responding Party(ies) reserve(s) its/their right(s) to amend and/or supplementthis response. REQUEST FOR PRODUCTION NO.2.: Any and all photographs of the vehicle of the Propounding Party. OBJECTION TO REQUEST FOR PRODUCTION NO. 2.: Responding Party(ies) object(s) to this request on the grounds set forth in the preliminary statement above and the grounds set forth here: (1) vague and ambiguous/insufficient description; (2) calls for a legal conclusion; (3) calls for speculation; (4) calls for premature disclosure ofexpert opinion/information/identity and/or improper disclosure of consultants; (5) unreasonably invadesright to privacy of responding party(ies); (6) calls for disclosure of privileged attorney client communications and/or work product; (7) calls for irrelevant information/materials not reasonably calculated to lead to the discovery of admissible evidence; (8) overbroad & unduly burdensome; (9) duplicative; (10) seeks information/materials already produced/disclosed and/or available to requesting party at the same burden and/or expense; (11) calls for or requires responding party to summarize and/or audit information and/or materials at the same burden/expense as requesting party; (12) calls for privileged and/or protected information/materials protected by case law,statute, regulations, rules, ordinances, and/or constitutions; (13) compound; (14) assumes facts; (15) calls for or requires expert opinion from a lay person or otherwise seeks premature or impermissible disclosure of expert identification and/or opinion; (16) shotgun style interrogatory/request; (17) requires response to prove the non- existence ofa thing or fact; (18) Singer v. Superior Court(1960) 54 Cal.2d 318; Burke v. Superior Court (1969) 71 Cal.2d 276; (19) not reasonably accessible electronically stored information 3 DEFENDANT WINIFRED WILSON’S OBJECTIONS TO PLAINTIFF WILLIAM HARDY'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE D A N I E L S , F I N E , I S R A E L , S C H O N B U C H & L E B O V I T S , L u e 1 8 0 1 C E N T U R Y P A R K E A S T , N I N T H F L O O R L O S A N G E L E S , C A L I F O R N I A 9 0 0 5 7 T E L E P H O N E ( 3 1 0 ) 5 5 6 - 7 9 0 0 F A C S I M I L E { 3 1 0 ) 5 5 6 - 2 8 0 7 and/or production ofelectronically stored information in all forms; (20) improperly expands(via instructions, definitions, or otherwise) the permissible scope of responding party’s duty underthe Code; (21) oppression; (22) calls for a narrative; (23) calls for a compilation, audit, abstract, or summary of documents; (24) impermissible pre-trial punitive damages discovery; (25) tax privilege; (26) trade secret privilege; and (27) collateral source. Responding Party(ies) reserve(s) its/their right(s) to amend and/or supplementthis response. REQUEST FOR PRODUCTION NO.3. Any and all photographs of the vehicle ofthe requesting Responding Party. OBJECTION TO REQUEST FOR PRODUCTION NO. 3.: Responding Party(ies) object(s) to this request on the groundsset forth in the preliminary statement above and the grounds set forth here: (1) vague and ambiguous/insufficient description; (2) calls for a legal conclusion; (3) calls for speculation; (4) calls for premature disclosure of expert opinion/information/identity and/or improper disclosure of consultants; (5) unreasonably invades right to privacy of responding party(ies); (6) calls for disclosure of privileged attorney client communications and/or work product; (7) calls for irrelevant information/materials not reasonably calculated to lead to the discovery ofadmissible evidence; (8) overbroad & unduly burdensome; (9) duplicative; (10) seeks information/materials already produced/disclosed and/or available to requesting party at the same burden and/or expense; (11) calls for or requires responding party to summarize and/or audit information and/or materials at the same burden/expense as requesting party; (12) calls for privileged and/or protected information/materials protected by case law, statute, regulations, rules, ordinances, and/or constitutions; (13) compound; (14) assumesfacts; (15) calls for or requires expert opinion from a lay person or otherwise seeks premature or impermissible disclosure of expert identification and/or opinion; (16) shotgun style interrogatory/request; (17) requires responseto prove the non- existence of a thing or fact; (18) Singer v. Superior Court(1960) 54 Cal.2d 318; Burke v. Superior Court (1969) 71 Cal.2d 276; (19) not reasonably accessible electronically stored information and/or production ofelectronically stored information in all forms; (20) improperly expands(via 4 DEFENDANT WINIFRED WILSON’S OBJECTIONS TO PLAINTIFF WILLIAM HARDY'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE D A N I E L S , F I N E , I S R A E L , S C H O N B U C H & L E B O V I T S , L L P 1 8 0 1 C E N T U R Y P A R K E A S T , N I N T H F L O O R L O S A N G E L E S , C A L I F O R N I A 9 0 0 8 7 T E L E P H O N E ( 3 1 0 ) 5 5 6 - 7 9 0 0 F A C S I M I L E ( 3 1 0 ) 5 5 6 - 2 8 0 7 t o O O s N N a s w 10 11 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 instructions, definitions, or otherwise) the permissible scope ofresponding party’s duty under the Code; (21) oppression; (22) calls for a narrative; (23) calls for a compilation, audit, abstract, or summary ofdocuments; (24) impermissible pre-trial punitive damages discovery; (25) tax privilege; (26) trade secret privilege; and (27) collateral source. Responding Party(ies) reserve(s) its/their right(s) to amend and/or supplement this response. REQUEST FOR PRODUCTION NO. 4. Any and all photographs of any other vehicles and/or objects involved in the accident. OBJECTION TO REQUEST FOR PRODUCTION NO.4.: Responding Party(ies) object(s) to this request on the groundsset forth in the preliminary statement above and the grounds set forth here: (1) vague and ambiguous/insufficient description; (2) calls for a legal conclusion; (3) calls for speculation; (4) calls for premature disclosure of expert opinion/information/identity and/or improper disclosure of consultants; (5) unreasonably invades right to privacy of responding party(ies); (6) calls for disclosure of privileged attorney client communications and/or work product; (7) calls for irrelevant information/materials not reasonably calculated to lead to the discovery of admissible evidence; (8) overbroad & unduly burdensome; (9) duplicative; (10) seeks information/materials already produced/disclosed and/or available to requesting party at the same burden and/or expense; (11) calls for or requires responding party to summarize and/or audit information and/or materials at the same burden/expense as requesting party; (12) calls for privileged and/or protected information/materials protected by case law,statute, regulations, rules, ordinances, and/or constitutions; (13) compound; (14) assumes facts; (15) calls for or requires expert opinion from a lay person or otherwise seeks premature or impermissible disclosure of expert identification and/or opinion; (16) shotgun style interrogatory/request; ( 17) requires response to prove the non- existence of a thing or fact; (18) Singer v. Superior Court(1960) 54 Cal.2d 318; Burke v. Superior Court (1969) 71 Cal.2d 276; (19) not reasonably accessible electronically stored information and/or production of clectronically stored information in all forms; (20) improperly expands(via s DEFENDANT WINIFRED WILSON’S OBJECTIONS TO PLAINTIFF WILLIAM HARDY'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE , L L P D A N I E L S , F I N E , I S R A E L , S C H O N B U C H & L E B O V I T S 1 8 0 1 C E N T U R Y P A R K E A S T , N I N T H F L O O R L O S A N G E L E S , C A L I F O R N I A 9 0 0 6 7 T E L E P H O N E ( 3 1 0 ) 5 5 6 - 7 9 0 0 F A C S I M I L E ( 3 1 0 ) 5 5 6 - 2 8 0 7 O o a 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 instructions, definitions, or otherwise) the permissible scope ofresponding party’s duty under the Code; (21) oppression; (22)calls for a narrative; (23) calls for a compilation, audit, abstract, or summary of documents; (24) impermissible pre-trial punitive damages discovery; (25) tax privilege; (26) trade secret privilege; and (27) collateral source. Responding Party(ies) reserve(s) its/their right(s) to amend and/or supplementthis response. REQUEST FOR PRODUCTION NO. 5.: Any and all photographs of Plaintiff’s person, purporting to depict visible signs of injuries claimed to have been suffered in the accident. OBJECTION TO REQUEST FOR PRODUCTION NO.5.: Responding Party(ies) object(s) to this request on the grounds set forth in the preliminary statement above and the grounds set forth here: (1) vague and ambiguous/insufficient description; (2)calls for a legal conclusion; (3) calls for speculation; (4) calls for premature disclosure of expert opinion/information/identity and/or improper disclosure of consultants; (5) unreasonably invades right to privacy of responding party(ies); (6) calls for disclosure of privileged attorney client communications and/or work product; (7) calls for irrelevant information/materials not reasonably calculated to lead to the discovery ofadmissible evidence; (8) overbroad & unduly burdensome; (9) duplicative; (10) seeks information/materials already produced/disclosed and/or available to requesting party at the same burden and/or expense; (11) calls for or requires responding party to summarize and/or audit information and/or materials at the same burden/expense as requesting party; (12) callsfor privileged and/or protected information/materials protected by case law,statute, regulations,rules, ordinances, and/or constitutions; (13) compound; (14) assumes facts; (15) calls for or requires expert opinion from a lay person or otherwise seeks premature or impermissible disclosure of expert identification and/or opinion; (16) shotgun style interrogatory/request; (17) requires response to prove the non- existence ofa thing or fact; (18) Singer v. Superior Court(1960) 54 Cal.2d 318; Burke v. Superior Court (1969) 71 Cal.2d 276; (19) not reasonably accessible electronically stored information and/or production ofelectronically stored information in all forms: (20) improperly expands(via 6 DEFENDANT WINIFRED WILSON'S OBJECTIONS TO PLAINTIFF WILLIAM HARDY'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE D A N I E L S , F I N E , I S R A E L , S C H O N B U C H & L E B O V I T S , L i p 1 8 0 1 C E N T U R Y P A R K E A S T , N I N T H F L O O R L O S A N G E L E S , C A L I F O R N I A 9 0 0 6 7 T E L E P H O N E ( 3 1 0 ) 5 5 6 - 7 9 0 0 F A C S I M I L E ( 2 1 0 ) 5 5 8 6 - 2 8 0 7 S H W w O 0 0 9 A N 10 11 12 13 14 16 17 18 19 20 21 22 23 24 25 26 27 28 instructions, definitions, or otherwise) the permissible scope of responding party’s duty under the Code; (21) oppression; (22) calls for a narrative; (23) calls for a compilation, audit, abstract, or summary of documents; (24) impermissible pre-trial punitive damages discovery; (25) tax privilege; (26) trade secret privilege; and (27) collateral source. Responding Party(ies) reserve(s) its/their right(s) to amend and/or supplement this response. REQUEST FOR PRODUCTION NO.6. Any andall statements,in any form, ofpersons who witnessed or claim to have witnessed the accident, and/or the events immediately prior to and/or subsequentto the accident (i.e, while any party to the accident wasstill at the scene thereof). OBJECTION TO REQUEST FOR PRODUCTION NO.6. Responding Party(ies) object(s) to this request on the grounds set forth in the preliminary statement above and the grounds set forth here: (1) vague and ambiguous/insufficient description; (2) calls for a legal conclusion; (3) calls for speculation; (4) calls for premature disclosure ofexpert opinion/information/identity and/or improper disclosure of consultants; (5) unreasonably invades right to privacy of responding party(ies); (6) calls for disclosure of privileged attorney client communications and/or work product; (7) calls for irrelevant information/materials not reasonably calculated to lead to the discovery ofadmissible evidence; (8) overbroad & unduly burdensome; (9) duplicative; (10) seeks information/materials already produced/disclosed and/or available to requesting party at the same burden and/or expense; (11) calls for or requires responding party to summarize and/or audit information and/or materials at the same burden/expense as requesting party; (12) calls for privileged and/or protected information/materials protected by case law, statute, regulations, rules, ordinances, and/or constitutions; (13) compound; (14) assumesfacts; (15) calls for or requires expert opinion from a lay person or otherwise seeks premature or impermissible disclosure of expert identification and/or opinion; (16) shotgun style interrogatory/request; (17) requires response to prove the non- existence ofa thing or fact; (18) Singer v. Superior Court(1960) 54 Cal.2d 318; Burke v. Superior Court (1969) 71 Cal.2d 276; (19) not reasonablyaccessible electronically stored information 7 DEFENDANT WINIFRED WILSON’S OBJECTIONS TO PLAINTIFF WILLIAM HARDY'S ’ REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE » D A N I E L S , F I N E , I S R A E L , S C H O N B U C H & L E B O V I T S . L i p 1 8 0 1 C E N T U R Y P A R K E A S T , N I N T H F L O O R L O S A N G E L E S , C A L I F O R N I A 9 0 0 6 7 T E L E P H O N E ( 3 1 0 ) 5 5 6 - 7 9 0 0 F A C S I M I L E ( 3 1 0 ) 5 5 6 - 2 8 0 7 N O o e 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 and/or production of electronically stored information in all forms; (20) improperly expands(via instructions, definitions, or otherwise) the permissible scope ofresponding party’s duty underthe Code; (21) oppression; (22) calls for a narrative; (23) calls for a compilation, audit, abstract, or summaryofdocuments; (24) impermissible pre-trial punitive damages discovery; (25) tax privilege; (26) trade secretprivilege; and (27) collateral source. Responding Party(ies) reserve(s) its/their right(s) to amend and/or supplementthis response. REQUEST FOR PRODUCTION NO. 7.: Any and all statements, in any form, secured or obtained in any way from the Plaintiff(s). OBJECTION TO REQUEST FOR PRODUCTION NO. 7.: Responding Party(ies) object(s) to this request on the grounds set forth in the preliminary statement above and the grounds set forth here: (1) vague and ambiguous/insufficient description; (2)calls for a legal conclusion; (3) calls for speculation; (4)calls for premature disclosure of expert opinion/information/identity and/or improper disclosure of consultants; (5) unreasonably invadesright to privacy of responding party(ies); (6) calls for disclosure of privileged attorney client communications and/or work product; (7) calls for irrelevant information/materials not reasonably calculated 10 lead to the discovery ofadmissible evidence; (8) overbroad & unduly burdensome; (9) duplicative; (10) seeks information/materials already produced/disclosed and/or available to requesting party at the same burden and/or expense; (11) calls for or requires responding party to summarize and/or audit information and/or materials at the same burden/expense as requesting party; (12) calls for privileged and/or protected information/materials protected by case law,statute, regulations, rules, ordinances, and/or constitutions; (13) compound; (14) assumes facts; (15) calls for or requires expert opinion from a lay person or otherwise seeks premature or impermissible disclosure of expert identification and/or opinion; (16) shotgun style interrogatory/request; (17) requires response to prove the non- existence ofa thing or fact; (18) Singer v. Superior Court(1960) 54 Cal.2d 318; Burke v. Superior Court (1969) 71 Cal.2d 276; (19) not reasonably accessible electronically stored information 8 DEFENDANT WINIFRED WILSON’S OBJECTIONS TO PLAINTIFF WILLIAM HARDY'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE 1 8 0 1 C E N T U R Y P A R K E A S T , N I N T H F L O O R L O S A N G E L E S , C A L I F O R N I A S 0 0 8 7 T E L E P H O N E ( 3 1 0 ) 8 5 6 - 7 9 0 0 F A C S I M I L E { 3 1 0 ) 6 5 8 - 2 8 0 7 D A N I E L S , F I N E , I S R A E L , S C H O N B U C H & L E B O V I T S , L L P w r O e 1 O N t h o N 10 11 12 13 14 15 16 18 19 20 21 22 23 24 25 26 27 28 and/or production of electronically stored information in all forms; (20) improperly expands(via instructions, definitions, or otherwise) the permissible scope ofresponding party’s duty under the Code; (21) oppression; (22) calls for a narrative; (23) calls for a compilation, audit, abstract, or summary of documents; (24) impermissible pre-trial punitive damagesdiscovery; (25) tax privilege; (26) trade secret privilege; and (27) collateral source. Responding Party(ies) reserve(s) its/their right(s) to amend and/or supplementthis response. REQUEST FOR PRODUCTION NO. 8.: Any and all reports by law enforcement agencies regarding the occurrence ofthis accident including, but not limited to, traffic accident reports and supplements thereto, arrest reports, and booking reports. OBJECTION TO REQUEST FOR PRODUCTION NO.8.: Responding Party(ies) object(s) to this request on the grounds set forth in the preliminary statement above and the grounds set forth here: (1) vague and ambiguous/insufficient description; (2) calls for a legal conclusion; (3) calls for speculation; (4) calls for premature disclosure of expert opinion/information/identity and/or improper disclosure of consultants; (5) unreasonably invadesright to privacy of responding party(ies); (6) calls for disclosure of privileged attorney client communications and/or work product; (7) calls for irrelevant information/materials not reasonably calculated to lead to the discovery ofadmissible evidence; (8) overbroad & unduly burdensome; (9) duplicative; (10) seeks information/materials already produced/disclosed and/or available to requesting party at the same burden and/or expense; (11) calls for or requires responding party to summarize and/or audit information and/or materials at the same burden/expense as requesting party; (12) calls for privileged and/or protected information/materials protected by case law, statute, regulations, rules, ordinances, and/or constitutions; (13) compound; (14) assumesfacts; (15) calls for or requires expert opinion from a lay person or otherwise seeks premature or impermissible disclosure of expert identification and/or opinion; (16) shotgun style interrogatory/request; (17) requires response to prove the non- existence ofa thing or fact; (18) Singer v. Superior Court(1960) 54 Cal.2d 318; Burke v. Superior 9 DEFENDANT WINIFRED WILSON’S OBJECTIONS TO PLAINTIFF WILLIAM BARDY'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE L O S A N G E L E S , C A L I F O R N I A 9 0 0 6 7 T E L E P H O N E ( 3 1 0 ) 5 5 6 - 7 9 0 0 F A C S I M I L E { 3 1 0 ) 5 5 6 - 2 8 0 7 D A N I E L S , F I N E , I S R A E L , S C H O N B U C H & L E B O W V I T S , w r 1 8 0 1 C E N T U R Y P A R K E A S T , N I N T H F L O O R S a C N 0 1 O N w n Il 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Court (1969) 71 Cal.2d 276; (19) not reasonably accessible electronically stored information and/or production ofelectronically stored information in all forms; (20) improperly expands(via instructions, definitions, or otherwise) the permissible scope of responding party’s duty under the Code; (21) oppression; (22) calls for a narrative; (23) calls for a compilation, audit, abstract, or summary ofdocuments; (24) impermissible pre-trial punitive damages discovery; (25) tax privilege; (26) trade secret privilege; and (27) collateral source. Responding Party(ies) reserve(s) its/their right(s) to amend and/or supplementthis response. REQUEST FOR PRODUCTION NO. 9.: Any and all estimates of the cost of repairs to the property of the Defendant(s), including, but not limited to, the vehicle of the Defendant(s) allegedly damaged as a result of the accident. OBJECTION TO REQUEST FOR PRODUCTION NO. 9.: Responding Party(ies) object(s) to this request on the groundsset forth in the preliminary statement above and the grounds set forth here: (1) vague and ambiguous/insufficient description; (2) calls for a legal conclusion; (3) calls for speculation; (4) calls for premature disclosure of expert opinion/information/identity and/or improper disclosure of consultants; (5) unreasonably invadesright to privacy ofresponding party(ies); (6) calls for disclosure of privileged attorney client communications and/or work product; (7) calls for irrelevant information/materials not reasonably calculated to lead to the discovery ofadmissible evidence; (8) overbroad & unduly burdensome; (9) duplicative; (10) seeks information/materials already produced/disclosed and/or available to requesting party at the same burden and/or expense; (11) calls for or requires responding party to summarize and/or audit information and/or materials at the same burden/expenseas requesting party; (12) calls for privileged and/or protected information/materials protected by case law, statute, regulations, rules, ordinances, and/or constitutions; (13) compound; (14) assumes facts; (15) calls for or requires expert opinion from a lay person or otherwise secks premature or impermissible disclosure of expert identification and/or opinion; (16) shotgun style interrogatory/request; (17) requires response to prove the non- 10 DEFENDANT WINIFRED WILSON'S OBJECTIONS TO PLAINTIFF WILLIAM HARDY’S : REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE D A N I E L S , F I N E , I S R A E L , S C H O N B U C H & L E B O V I T S , L L P 1 8 0 1 C E N T U R Y P A R K E A S T , N I N T H F L O O R L O S A N G E L E S , C A L I F O R N I A S O 0 8 7 T E L E P H O N E ( 3 1 0 ) 5 5 6 - 7 9 0 0 F A C S I M I L E ( 3 9 0 ) 5 5 6 - 2 8 0 7 N o W W 0 0 0 A t h n w 10 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 existence of a thing or fact; (18) Singer v. Superior Court(1960) 54 Cal.2d 318; Burke v. Superior Court (1969) 71 Cal.2d 276; (19) not reasonably accessible electronically stored information and/or production of electronically stored information in all forms; (20) improperly expands(via instructions, definitions, or otherwise) the permissible scope ofresponding party’s duty under the Code; (21) oppression; (22) calls for anarrative; (23) calls for a compilation, audit, abstract, or summary of documents; (24) impermissible pre-trial punitive damages discovery; (25) tax privilege; (26) trade secret privilege; and (27) collateral source. Responding Party(ies) reserve(s) its/their right(s) to amend and/or supplement this response. REQUEST FOR PRODUCTION NO. 10.: Any and all repair bills for repairs actually madeto the vehicle of the Defendant(s) as a result ofthe accident. OBJECTION TO REQUEST FOR PRODUCTION NO. 10.: Responding Party(ies) object(s) 10 this request on the grounds set forth in the preliminary statement above and the grounds set forth here: (1) vague and ambiguous/insufficient description; (2) calls for a legal conclusion; (3) calls for speculation; (4) calls for premature disclosure of expert opinion/information/identity and/or improper disclosure of consultants; (5) unreasonably invades right to privacy of responding party(ies); (6) calls for disclosure of privileged attorney client communications and/or work product; (7) callsfor irrelevant information/materials not reasonably calculated to lead to the discovery of admissible evidence; (8) overbroad & unduly burdensome; (9) duplicative; (10) seeks information/materials already produced/disclosed and/or available to requesting party at the same burden and/or expense; (11) calls for or requires responding party to summarize and/or audit information and/or materials at the same burden/expense as requesting party; (12) calls for privileged and/or protected information/materials protected by case law, statute, regulations, rules, ordinances, and/or constitutions; (13) compound; (14) assumes facts; (15) calls for or requires expert opinion from a lay person or otherwise seeks premature or impermissible disclosure of expert identification and/or opinion; (16) shotgun style interrogatory/request; (17) requires response to prove the non- il DEFENDANT WINIFRED WILSON’S OBJECTIONS TO PLAINTIFF WILLIAM HARDY'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE L O S A N G E L E S , C A L I F O R N I A 8 0 0 6 7 T E L E P H O N E ( 3 1 0 ) 5 5 6 - 7 9 0 0 F A C S I M I L E ( 3 1 0 ) 5 5 6 - 2 8 0 7 D A N I E L S , F I N E , I S R A E L , S C H O N B U C H & L E B O V I T S , L L P 1 8 0 1 7 C E N T U R Y P A R K E A S T , N I N T H F L O O R B W N o O e a S N 10 tl 12 13 14 15 16 17 18 19 20 2} 22 23 25 26 27 28 existence ofa thing or fact; (18) Singer v. Superior Court(1960) 54 Cal.2d 318; Burke v. Superior Court (1969) 71 Cal.2d 276; (19) not reasonably accessible electronically stored information and/or production ofelectronically stored information in all forms; (20) improperly expands(via instructions, definitions, or otherwise) the permissible scope of responding party’s duty under the Code; (21) oppression; (22) calls for a narrative; (23) calls for a compilation, audit, abstract, or summary of documents; (24) impermissible pre-trial punitive damages discovery; (25) tax privilege; (26) trade secret privilege; and (27) collateral source. Responding Party(ies) reserve(s) its/their right(s) to amend and/or supplementthis response. REQUEST FOR PRODUCTION NO. 11.: Any and all documents in your possession, custody or control evidencing that you were covered by automobile liability insurance at the time of the subject accident. Such documents shall include, but are notlimited to, a legible copy of said policy, declaration page and insurance card. OBJECTION TO REQUEST FOR PRODUCTION NO. 11. Responding Party(ies) object(s) to this request on the grounds set forth in the preliminary statement above and the groundsset forth here: (1) vague and ambiguous/insufficient description; (2) calls for a legal conclusion; (3) calls for speculation; (4) calls for premature disclosure of expert opinion/information/identity and/or improper disclosure of consultants; (5) unreasonably invades right to privacy of responding party(ies); (6) calls for disclosure of privileged attorney client communications and/or work product; (7) calls for irrelevant information/materials not reasonably calculated to lead to the discovery ofadmissible evidence; (8) overbroad & unduly burdensome; (9) duplicative; (10) seeks information/materials already produced/disclosed and/or available to requesting party at the same burden and/or expense; (11) calls for or requires responding party to summarize and/or audit information and/or materials at the same burden/expense as requesting party; (12) calls for privileged and/or protected information/materials protected by case law, statute, regulations, rules, ordinances, and/or constitutions; (13) compound; (14) assumes facts; (15) calls for or requires expert opinion from a 12 DEFENDANT WINIFRED WILSON'S OBJECTIONS TO PLAINTIFF WILLIAM HARDY'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE 1 8 0 1 C E N T U R Y P A R K E A S T , N I N T H F L O O R L O S A N G E L E S , C A L I F O R N I A 8 0 0 6 7 T E L E P H O N E ( 3 1 0 ) 5 5 6 . 7 9 0 0 F A C S I M I L E ( 3 1 0 ) 5 5 6 - 2 8 0 7 D a A M I E L S , F I N E , I S R A E L , S C H O N B U C H & L L E B O V I T S , L L P L H W o e 3 O N a 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 lay person or otherwise seeks premature or impermissible disclosure of expert identification and/or opinion; (16) shotgun style interrogatory/request; (17) requires response to prove the non- existence of a thing or fact; (18) Singer v. Superior Court(1960) 54 Cal.2d 318; Burke v. Superior Court (1969) 71 Cal.2d 276; (19) not reasonably accessible electronically stored information and/or production ofelectronically stored information in all forms; (20) improperly expands(via instructions, definitions, or otherwise) the permissible scope of responding party’s duty under the Code; (21) oppression; (22) calls for a narrative; (23) calls for a compilation, audit, abstract, or summary of documents; (24) impermissible pre-trial punitive damages discovery; (25) tax privilege; (26) trade secret privilege; and (27) collateral source. Responding Party(ies) reserve(s) its/their right(s) to amend and/or supplementthis response. REQUEST FOR PRODUCTION NO. 12.: Any and all documents reflecting each cellular, mobile, telephone, voice or data communication received or transmitted by anyonein the vehicle you were driving which occurred within 30 minutes before and after the subject incident. OBJECTION TO REQUEST FOR PRODUCTION NO. 12. Responding Party(ies) objeci(s) to this request on the grounds set forth in the preliminary statement above and the grounds set forth here: (1) vague and ambiguous/insufficient description; (2) calls for a legal conclusion; (3) calls for speculation; (4) calls for premature disclosure of expert opinion/information/identity and/or improper disclosure of consultants; (5) unreasonably invades right to privacy ofresponding party(ies); (6) calls for disclosure of privileged attorney client communications and/or work product; (7) calls for irrelevant information/materials not reasonably calculated to lead to the discovery ofadmissible evidence; (8) overbroad & unduly burdensome; (9) duplicative; (10) seeks information/materials already produced/disclosed and/or available to requesting party at the same burden and/or expense; (11) calls for or requires responding party to summarize and/or audit information and/or materials at the same burden/expense as requesting party; (12) calls for privileged and/or protected information/materials protected by case law, statute, regulations, rules, ordinances, and/or 13 DEFENDANT WINIFRED WILSON'S OBJECTIONS TO PLAINTIFF WILLIAM HARDY'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE D A N I E L S , F I N E , I S R A E L , S C H O N B U C H & L L E B O V I T S , Lu pe 1 8 0 1 C E N T U R Y P A R K E A S T , N I N T H F L O O R L O S A N G E L E S , C A L I F O R N I A 8 0 0 6 7 T E L E P H O N E ( 3 1 0 ) 5 5 6 - 7 9 0 0 F A C S I M I L E ( 3 1 0 ) S 5 6 - 2 8 Q 7 0 N N N h B a W N ) N o 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 constitutions; (13) compound; (14) assumesfacts; (15) calls for or requires expert opinion from a lay person or otherwise seeks premature or impermissible disclosure of expert identification and/or opinion; (16) shotgun style interrogatory/request; (17) requires response to prove the non- existence ofa thing or fact; (18) Singer v. Superior Court(1960) 54 Cal.2d 318; Burke v. Superior Court (1969) 71 Cal.2d 276; (19) not reasonably accessible electronically stored information and/or production of electronically stored information in all forms; (20) improperly expands(via instructions, definitions, or otherwise) the permissible scope ofresponding party’s duty under the Code; (21) oppression; (22) calls for a narrative; (23) calls for a compilation, audit, abstract, or summary ofdocuments; (24) impermissible pre-trial punitive damages discovery; (25) tax privilege; (26) trade secret privilege; and (27) collateral source. Responding Party(ies) reserve(s) its/their right(s) to amend and/or supplement this response. REQUEST FOR PRODUCTION NO. 13. Any and all documents identified in your responses to Form Interrogatories (Set One). OBJECTION TO REQUEST FOR PRODUCTION NO. 13. Responding Party(ies) object(s) to this request on the grounds set forth in the preliminary statement above and the grounds set forth here: (1) vague and ambiguous/insufficient description; (2) calls for a legal conclusion; (3) calls for speculation; (4) calls for premature disclosure of expert opinion/information/identity and/or improper disclosure of consultants; (5) unreasonably invades right to privacy ofresponding party(ies); (6) calls for disclosure of privileged attorney client communications and/or work product; (7) calls for irrelevant information/materials not reasonably calculated to lead to the discovery ofadmissible evidence; (8) overbroad & unduly burdensome; (9) duplicative; (10) seeks information/materials already produced/disclosed and/or available to requesting party at the same burden and/or expense; (11) calls for or requires responding partly to summarize and/or audit information and/or materials at the same burden/expense as requesting party; (12) calls for privileged and/or protected information/materials protected by case law, statute, regulations, rules, ordinances, and/or 14 DEFENDANT WINIFRED WILSON'S OBJECTIONS TO PLAINTIFF WILLIAM HARDY'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE 1 8 0 1 C E N T U R Y P A R K E A S T , N I N T H F L O O R L O S A N G E L E S , C A L I F O R N I A S O 0 B 7 T E L E P H O N E ( 3 1 0 ) 5 5 8 - 7 9 0 0 F A C S I M I L E ( 3 1 0 ) 5 5 6 - 2 8 0 7 D A N I E L S , F I N E , I S R A E L , S C H O N B U C H & L E B O V I T S , L L P © 0 3 O N w n b s W w N e N O R N N N N N N O N D Y m m m m e e p d m e me a e d e e r se d p a G W N N B W N e O W N A A N W n B R A W N = O D constitutions; (13) compound; (14) assumes facts; (15) calls for or requires expert opinion from a lay person or otherwise seeks premature or impermissible disclosure of expert identification and/or opinion; (16) shotgun style interrogatory/request; (17) requires response to prove the non- existence of a thing or fact; (18) Singer v. Superior Court(1960) 54 Cal.2d 318; Burke v. Superior Court (1969) 71 Cal.2d 276; (19) not reasonably accessible electronically stored information and/or production of electronically stored information in all forms; (20) improperly expands(via instructions, definitions, or otherwise) the permissible scope ofresponding party’s duty under the Code; (21) oppression; (22) calls for a narrative; (23) calls for a compilation, audit, abstract, or summary ofdocuments; (24) impermissible pre-trial punitive damages discovery; (25) tax privilege; (26) trade secret privilege; and (27) collateral source. Responding Party(ies) reserve(s) its/their right(s) to amend and/or supplement this response. REQUEST FOR PRODUCTION NO. 14.: Any and all documents reflecting ownership of Responding Party’s vehicle. OBJECTION TO REQUEST FOR PRODUCTION NO. 14.: Responding Party(ies) object(s) to this request on the grounds set forth in the preliminary statement above and the grounds set forth here: (1) vague and ambiguous/insufficient description; (2) calls for a legal conclusion; (3) calls for speculation; (4) calls for premature disclosure ofexpert opinion/information/identity and/or improper disclosure of consultants; (5) unreasonably invades right to privacy of responding party(ies); (6) calls for disclosure of privileged attorney client communications and/or work product; (7) calls for irrelevant information/materials not reasonably calculated to lead to the discovery of admissible evidence; (8) overbroad & unduly burdensome; (9) duplicative; (10) seeks information/materials already produced/disciosed and/or available 10 requesting party at the same burden and/or expense; (11) calls for or requires responding party to summarize and/or audit information and/or materials at the same burden/expense as requesting party; (12) calls for privileged and/or protected information/materials protected by case law, statute, regulations, rules, ordinances, and/or constitutions; (13) compound; (14) assumes facts; (15) calls for or requires expert opinion from a 15 DEFENDANT WINIFRED WILSON'S OBJECTIONS TO PLAINTIFF WILLIAM HARDY’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE D A N I E L S , F I N E , I S R A E L , S C H O N B U C H & L E B O V I T S , L L P 1 8 0 1 C E N T U R Y P A R K E A S T , N I N T H F L O O R L O S A N G E L E S , C A L I F O R N I A 9 0 0 8 7 T E L E P H O N E ( 3 1 0 ) 5 5 6 - 7 9 0 0 F A C S I M I L E ( 3 1 0 ) 5 5 6 - 2 8 0 7 w n HE H W N LE E C E E E E 10 H 12 13 14 15 16 17 19 20 21 22 23 24 25 26 27 28 lay person or otherwise seeks premature or impermissible disclosure of expert identification and/or opinion; (16) shotgun style interrogatory/request; (17) requires responseto prove the non- existence of a thing or fact; (18) Singer v. Superior Court(1960) 54 Cal.2d 318; Burke v. Superior Court (1969) 71 Cal.2d 276; (19) not reasonably accessible electronically stored information and/or production of electronically stored information in all forms; (20) improperly expands(via instructions, definitions, or otherwise) the permissible scope ofresponding party’s duty under the Code; (21) oppression; (22) calls for a narrative; (23) calls for a compilation, audit, abstract, or summary ofdocuments; (24) impermissible pre-trial punitive damages discovery; (25) tax privilege; (26) trade secret privilege; and (27) collateral source. Responding Party(ies) reserve(s) its/their right(s) to amend and/or supplement this response. REQUEST FOR PRODUCTION NQ. 15.: A true and correct copy ofResponding Party’s driver’s license. OBJECTION TO REQUEST FOR PRODUCTION NQ. 15.: Responding Party(ies) object(s) to this request on the grounds set forth in the preliminary statement above and the groundsset forth here: (1) vague and ambiguous/insufficient description; (2) calls for a legal conclusion; (3) calls for speculation; (4) calls for premature disclosure of expert opinion/information/identity and/or improper disclosure of consultants; (5) unreasonably invades right to privacy of responding party(ies); (6) calls for disclosure of privileged attorney client communications and/or work product; (7) calls for irrelevant information/materials not reasonably calculated to lead to the discovery ofadmissible evidence; (8) overbroad & unduly burdensome; (9) duplicative; (10) seeks information/materials already produced/disclosed and/or available to requesting party at the same burden and/or expense; (11) calls for or requires responding party to summarize and/or audit information and/or materials at the same burden/expense as requesting party; (12) calls for privileged and/or protected information/materials protected by case law, statute, regulations, rules, ordinances, and/or constitutions; (13) compound; (14) assumesfacts; (15) calls for or requires expert opinion from a lay person or otherwise seeks premature or impermissible disclosure of expert identification and/or 16 DEFENDANT WINIFRED WILSON’S OBJECTIONS TO PLAINTIFF WILLIAM HARDY’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE T E L E P H O N E ( 8 3 1 0 ) 5 5 6 - 7 9 0 0 F A C S I M I L E ( 3 1 0 ) 5 5 8 - 2 8 0 7 I S R A E L , S C H O N B U C H & L E B O V I T S , L u p 1 8 0 1 7 C E N T U R Y P A R K E A S T , N I N T H F L O O R L O S A N G E L E S , C A L I F O R N I A 8 0 0 8 7 D A N I E L S , F I N E , opinion; (16) shotgun style interrogatory/request; (17) requires response to prove the non- existence of a thing or fact; (18) Singer v. Superior Court(1960) 54 Cal.2d 318; Burke v. Superior Court (1969) 71 Cal.2d 276; (19) not reasonably accessible electronically stored information and/or production of electronically stored information in all forms; (20) improperly expands(via instructions, definitions, or otherwise) the permissible scope of responding party's duty under the Code;(21) oppression; (22) calls for a narrative; (23) calls for a compilation, audit, abstract, or summary ofdocuments; (24) impermissible pre-trial punitive damages discovery; {25) tax privilege; (26) trade secret privilege; and (27) collateral source. Responding Party(ies) reserve(s) its/their right(s) to amend and/or supplement this response. REQUEST FOR PRODUCTION NO. 16.: Any and all DOCUMENTS anyone sent to YOU, but not including those sent to YOU by YOUR attorneys, or YOUR attorneys to YOU, regarding the incident which is the subject ofthis litigation, OBJECTION TO REQUEST FOR PRODUCTION NO. 16.: Responding Party(ies) object(s) to this request on the grounds set forth in the preliminary statement above and the groundsset forth here: (I) vague and ambiguous/insufficient description; (2) calls for a legal conclusion; (3) calls for speculation; (4) calls for premature disclosure of expert opinion/information/identity and/or improper disclosure ofconsultants; (5) unreasonably invades right to privacy ofresponding party(ies); (6) calls for disclosure of privileged attorney client communications and/or work product; (7) calls for irrelevant information/materials not reasonably calculated to lead to the discovery of admissible evidence; (8) overbroad & unduly burdensome; (9) duplicative; (10) seeks information/materials already produced/disclosed and/or available to requesting party at the same burden and/or expense; (11) calls for or requires responding party to summarize and/or audit information and/or materials at the same burden/expense as requesting party; (12) calls for privileged and/or protected information/materials protected by case law, statute, regulations, rules, ordinances, and/or constitutions; (13) compound; (14) assumes facts; (15) calls for or requires expert opinion from a 17 DEFENDANT WINIFRED WILSON'S OBJECTIONS TO PLAINTIFF WILLIAM HARDY’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE D A N I E L S , F I N E , I S R A E L , S C H O N B U C H & L E B O W I T S , L i p 1 8 0 1 C E N T U R Y P A R K E A S T , N I N T H F L O O R L O S A N G E L E S , C A L I F O R N I A S 0 0 6 7 T E L E P H O N E ( 3 1 0 ) 5 5 6 - 7 9 0 0 F A C S I M I L E ( 3 1 0 ) 5 5 6 - 2 8 0 7 O e N N n n a 10 11 12 13 14 15 16 18 19 20 21 22 23 24 25 26 27 28 lay person or otherwise seeks premature or impermissible disclosure of expert identification and/or opinion; (16) shotgun style interrogatory/request; (17) requires response to prove the non- existence of a thing or fact; (18) Singer v. Superior Court(1960) 54 Cal.2d 318; Burke v. Superior Court (1969) 71 Cal.2d 276; (19) not reasonably accessible electronically stored information and/or production ofelectronically stored information in all forms; (20) improperly expands(via instructions, definitions, or otherwise) the permissible scope ofresponding party’s duty under the Code; (21) oppression; (22) calls for a narrative; (23) calls for a compilation, audit, abstract, or summary ofdocuments; (24) impermissible pre-trial punitive damages discovery; (25) tax privilege; (26) trade secret privilege; and (27) collateral source. Responding Party(ies) reserve(s) its/their right(s) to amend and/or supplement this response. Date: 10/17/2017 DANIELS, FINE, ISRAEL, SCHONBUCH & LEBOVITS, LLP BoAT Scott M. Leavitt Katherine A. Bruce Attorneys For Defendants WINIFRED WILSON and CROSS CREEK CARE, INC. 18 DEFENDANT WINIFRED WILSON’S OBJECTIONS TO PLAINTIFF WILLIAM HARDY’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE PROOF OF SERVICE State of California ) County of Los Angeles ) I am a resident ofthe State of California, over the age of eighteen years, and not a party to the within action. My business address is 1801 Century Park East, Ninth Floor, Los Angeles, California 90067. On October 17, 2017, 1 served the within document(s): DEFENDANT WINIFRED WILSON’S OBJECTIONS TO PLAINTIFF WILLIAM HARDY’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE by placing a true copy thereof in sealed envelopesas stated on the attached mailing list. [1] BY FACSIMILE TRANSMISSION I transmitted said document(s) via facsimile machine pursuant to C.R.C. rule 2.306 to fax number FACSIMILE NUMBER. The facsimile machine I used complied with rule 2.306 and no error was reported by the machine. Pursuant to rule 2.306, I caused the machine to print a transmission record of the transmission, a copy ofwhich is attached to this declaration. BY MAIL [am “readily familiar” with the firm's practice of collection and processing correspondence for mailing. Under that practice a true copy would be deposited with U.S, postal service on that same day with postage thereon fully prepaid at Los Angeles, California in the ordinary course of business. 1am aware that on motion ofthe party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. [1 BYPERSONAL SERVICE I caused personal delivery by ATTORNEY SERVICE of said document(s) to the offices ofthe addressee(s) as set forth on the attached mailing list. [1 BY OVERNIGHT DELIVERY SERVICE caused such envelope to be deposited with an overnight delivery service (Overnite Express/Federal Express) for delivery the next court day, or at most, within two court days of the above date. [7] BY E-MAIL OR ELECTRONIC TRANSMISSION. Based on a court order or an agreement of the parties to accept service by e-mail or electronic transmission, 1 caused the documents to be sent to the persons at the e-mail addresseslisted on the service list. 1 did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. (State) I declare under penalty of perjury underthe laws ofthe State of California that the above is true and correct. [7] (Federal) Ideclare that I am employed in the office ofa member ofthe bar ofthis court at whose direction the service was made. Executed on October 17, 2017, at Los Angeles, California. ;Sg ong Pot N ve N ae Katherine A. Bruce 19 DEFENDANT WINIFRED WILSON’S OBJECTIONS TO PLAINTIFF WILLIAM HARDY’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE 0 0 N Y R s Ww W N Y N O R D N N N N N m e e m e m e m me w e s p m e m m m p e 0 0 N N A w m S s W N = C e e N N B R W N = O o SERVICE LIST Jonathan Roven, Esq., [SBN 284614] Kahn Roven, LLP 5550 Topanga Canyon Boulevard, Suite 200 Woodland Hills, California 91367 Tel: (818) 888-9171; Fax: (818) 888-7611 jon@krinjurylaw.com Attorneysfor Plaintiff WILLIAMHARDY 3010-027 20 DEFENDANT WINIFRED WILSON’S OBJECTIONS TO PLAINTIFF WILLIAM HARDY'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE Exhibit 4 Jonathan Roven UE From: Jonathan Roven Sent: Friday, October 20, 2017 4:20 PM To: Katherine Bruce (bruce@dfis-law.com) Cc: Robert Kahn (robert@krinjurylaw.com) Subject: Hardy v Wilson - Meet and Confer Follow Up Flag: Follow up Flag Status: Flagged Dear Counsel, As anticipated, Defendant objected to every single discovery request and did not provide a single discovery response. These discovery requests were served on August 7, 2017. After many extensions, Defendant has had until October16, 2017 (over 2 months) to respond. Boilerplate objections are sanctionable and are deemed a waiver of objections. Where general boilerplate objections were made, courts have authority to compel further responses (but not to find a waiver of privilege objections). Best Products, Inc. v. Sup. Ct. (2004) 119 Cal.App.4th 1181, 1189. Making objections in a boilerplate fashion is improper and can be sanctioned. Korea Data Systems Co. Ltd. v. Superior Court (1997) 51 Cal. App. 4th 1513, 1516. “[T]he fact that a party is conducting discovery... shall not operate to delay the discovery of any other party.” C.C.P. § 2019.020. Objections without merit or too general and incomplete/evasive responses are sanctionable and can be compelled for a further response. C.C.P. §§ 2030.300, 2031.310, 2033.290. Privileges were also asserted. Therefore, Plaintiff requests a privilege log by 5PM October 27, 2017. This matter is on a fast track towards trial due to my client's health. We can’t afford the time for these games. Therefore, we must receive complete responses without objection to Defendant's discovery no later than Friday, October 27, 2017. Should we not receive responses by 5PM that day, we will have no choice butto turn to the Court for assistance and seek sanctions including reasonable attorney’s fees. JONATHAN D. ROVEN INJURY LAWYER | KAHN ROVEN,LLP 5550 Topanga Canyon Boulevard, Suite 200 Woodland Hills, CA 91367 a (818) 888-9171 & (818) 888- 7611 KAHN ROVEN. Where YOU matter. Jonathan Roven Oe From: Jonathan Roven Sent: Monday, October 30, 2017 10:42 AM To: Katherine Bruce (bruce@dfis-law.com) Cc: Robert Kahn (robert@krinjurylaw.com) Subject: RE: Hardy v Wilson - Meet and Confer Counsel, it has now been nearly 3 months since we served our discovery responses. We still have not received a single response. You are leaving us with no option but to turn to the Court. JONATHAN D. ROVEN INJURY LAWYER | KAHN ROVEN, LLP 5550 Topanga Canyon Boulevard, Suite 200 Woodland Hills, CA 91367 a (818) 888-9171 & (818) 888- 7611 KAHN ROVEN. Where YOU matter. From: Jonathan Roven Sent: Friday, October 20, 2017 4:20 PM To: Katherine Bruce (bruce@dfis-law.com) Cc: Robert Kahn (robert@krinjurylaw.com) Subject: Hardy v Wilson - Meet and Confer Dear Counsel, As anticipated, Defendant objected to every single discovery request and did not provide a single discovery response. These discovery requests were served on August 7, 2017. After many extensions, Defendant has had until October16, 2017 {over 2 months) to respond. Boilerplate objections are sanctionable and are deemed a waiver of objections. Where general boilerplate objections were made, courts have authority to compel further responses (but not to find a waiver of privilege objections). Best Products, Inc. v. Sup. Ct. (2004) 119 Cal.App.4th 1181, 1189. Making objections in a boilerplate fashion is improper and can be sanctioned. Korea Data Systems Co. Ltd. v. Superior Court (1997) 51 Cal. App. 4th 1513, 1516. “[T]he fact that a party is conducting discovery... shall not operate to delay the discovery of any other party.” C.C.P. § 2019.020. Objections without merit or too general and incomplete/evasive responses are sanctionable and can be compelled for a further response. C.C.P. §§ 2030.300, 2031.310, 2033.290. Privileges were also asserted. Therefore, Plaintiff requests a privilege log by 5PM October 27, 2017. This matter is on a fast track towards trial due to my client's health. We can’t afford the time for these games. Therefore, we must receive complete responses without objection to Defendant’s discovery no later than Friday, October 27, 2017. Should we not receive responses by 5PM that day, we will have no choice but to turn to the Court for assistance and seek sanctions including reasonable attorney’s fees. JONATHAN D. ROVEN INJURY LAWYER | KAHN ROVEN, LLP 5550 Topanga Canyon Boulevard, Suite 200 Woodland Hills, CA 81367 A (818)888-9171 & (818) 888- 7611 KAHN ROVEN. Where YOU matter. Jonathan Roven 00 From: Katherine Bruce Sent: Monday, October 30, 2017 12:53 PM To: Jonathan Roven Cc: Robert Kahn Subject: RE: Hardy v Wilson - Meet and Confer Follow Up Flag: Follow Up Flag Status: Flagged F asked you to call me regarding a stipulation re liability, but have received no call. What's better than discovery responses: a stipulation to liability. Please call me back. Thanks, Katherine A. Bruce Daniels,Fine, Israel, Schonbuch & Lebovits, LLP 1801 Century Park East, 9th Floor Los Angeles, California 90067 Phone: (310) 556-7900 Fax: (310) 556-2807 PRIVILEGE AND CONFIDENTIALITY NOTICE This email communication may contain CONFIDENTIAL INFORMATION WHICH ALSO MAY BE LEGALLY PRIVILEGED and is intended only for the use of the intended recipients identified above. if you are not the intended recipient of this communication, you are hereby notified that any unauthorized review, use, dissemination, distribution, downloading, or copying of this communication is strictly prohibited. If you are not the intended recipient and have received this communication in error, please immediately notify us by reply email, delete the communication and destroy all copies. DANIELS, FINE, ISRAEL, SCHONBUCH & LEBOVITS, LLP Circular 230 Disclosure: To assure compliance with Treasury Departmentrules governing tax practice, we hereby inform you that any advice contained herein (including in any attachment) {1} was not written or intended to be used, and cannot be used, by you or any taxpayer for the purpose of avoiding any penalties that may be imposed on you or any taxpayer and {2) may not be used or referred to by you or any other person in connection with promoting, marketing or recommending to another person any transaction or matter addressed herein. From: Jonathan Roven [mailto:jon@krinjurylaw.com] Sent: Monday, October 30, 2017 10:42 AM To: Katherine Bruce Cc: Robert Kahn Subject: RE: Hardy v Wilson - Meet and Confer Counsel, it has now been nearly 3 months since we served our discovery responses. Westill have not received a single response. You are leaving us with no option but to turn to the Court. Jonathan Roven LE From: Jonathan Roven Sent: Tuesday, October 31, 2017 3:14 PM To: Katherine Bruce Cc: Robert Kahn Subject: Re: Hardy v Wilson - Meet and Confer Attachments: image001.png; image002.png; image003.png Please cite me some authority that says offering a stipulation to liability absolves a party from responding to discovery. PLEASE NOTE MY NEW EMAIL ADDRESS: jon@KRinjurylaw.com JONATHAN D. ROVEN INJURY LAWYER | KAHN ROVEN, LLP 5550 Topanga Canyon Boulevard, Suite 200 Woodland Hills, CA 91367 a (818) 888-9171 & (818) 888-7611 KAHN ROVEN. Where YOU matter. From: Katherine Bruce Date: Monday, October 30, 2017 at 12:53 PM To: Kahn Roven Cc: Robert Kahn Subject: RE: Hardy v Wilson - Meet and Confer I asked you to call me regarding a stipulation re liability, but have received no call. What's better than discovery responses: a stipulation to liability. Please call me back. Thanks, Katherine A. Bruce Daniels, Fine, Israel, Schonbuch & Lebovits, LLP 1801 Century Park East, 9th Floor Los Angeles, California 90067 Phone: (310) 556-7900 Fax: (310) 556-2807 PRIVILEGE AND CONFIDENTIALITY NOTICE This email communication may contain CONFIDENTIAL INFORMATION WHICH ALSO MAY BE LEGALLY PRIVILEGED and is intended only for the use of the intended recipients identified above. If you are not the intended recipient of this communication, you are hereby notified that any unauthorized review, use, dissemination, distribution, downloading, or copying of this communication is strictly prohibited. if you are not the intended recipient and have received this communication in error, please immediately notify us by reply email, delete the communication and destroy all copies. Jonathan Roven From: Katherine Bruce Sent: Tuesday, October 31, 2017 3:19 PM To: Jonathan Roven Cc: Robert Kahn; Claire Evans Subject: RE: Hardy v Wilson - Meet and Confer Are you saying that you would rather do discovery than get a stipulation to liability? Do you plan on returning mycalls about this? | am at a complete loss as to what purpose your “meet and confer” efforts serve, when you refuse to return my calls despite my multiple requests. Katherine A. Bruce Daniels, Fine, Israel, Schonbuch & Lebovits, LLP 1801 Century Park East, Sth Floor Los Angeles, California 90067 Phone: (310) 556-7900 Fax: (310) 556-2807 PRIVILEGE AND CONFIDENTIALITY NOTICE This email communication may contain CONFIDENTIAL INFORMATION WHICH ALSO MAY BE LEGALLY PRIVILEGED and is intended only for the use of the intended recipients identified above. If you are not the intended recipient of this communication, you are hereby notified that any unauthorized review, use, dissemination, distribution, downloading, or copying of this communication is strictly prohibited. if you are not the intended recipient and have received this communication in error, please immediately notify us by reply email, delete the communication and destroy all copies. DANIELS, FINE, ISRAEL, SCHONBUCH & LEBOVITS, LLP Circular 230 Disclosure: To assure compliance with Treasury Department rules governing tax practice, we hereby inform you that any advice contained herein {including in any attachment) {1) was not written or intended to be used, and cannot be used, by you or any taxpayer for the purpose of avoiding any penalties that may be imposed on you or any taxpayer and (2) may not be used or referred to by you or any other person in connection with promoting, marketing or recommending to another person any transaction or matter addressed herein. From: Jonathan Roven [mailto:jon@krinjurylaw.com] Sent: Tuesday, October 31, 2017 3:14 PM To: Katherine Bruce Cc: Robert Kahn Subject: Re: Hardy v Wilson - Meet and Confer Please cite me some authority that says offering a stipulation to liability absolves a party from responding to discovery. PLEASE NOTE MY NEW EMAIL ADDRESS: jon@KRinjurylaw.com JONATHAN D. ROVEN INJURY LAWYER | KAHN ROVEN, LLP 5550 Topanga Canyon Boulevard, Suite 200 Woodland Hills, CA 91367 0. (818) 888-9171 LJ. (818) 888-7611 Jonathan Roven m From: Jonathan Roven Sent: Tuesday, October 31, 2017 3:30 PM To: Katherine Bruce Cc: Robert Kahn; Claire Evans Subject: RE: Hardy v Wilson - Meet and Confer f just called you and left a message. JONATHAN D. ROVEN INJURY LAWYER | KAHN ROVEN, LLP 5550 Topanga Canyon Boulevard, Suite 200 Woodland Hills, CA 91367 4a (818)888-9171 & (818) 888- 7611 KAHN ROVEN. Where YOU matter. From: Jonathan Roven Sent: Tuesday, October 31, 2017 3:21 PM To: Katherine Bruce Cc: Robert Kahn; Claire Evans Subject: Re: Hardy v Wilson - Meet and Confer I'd rather keep our conversations in writing so we keep a clear record. Thanks. PLEASE NOTE MY NEW EMAIL ADDRESS: jon@KRinjurylaw.com @ JONATHAN D. ROVEN INJURY LAWYER | KAHN ROVEN, LLP 5550 Topanga Canyon Boulevard, Suite 200 Woodland Hills, CA 91367 2 (818)888-9171 & (818) 888-7611 KAHN ROVEN. Where YOU matter. From: Katherine Bruce Date: Tuesday, October 31, 2017 at 3:18 PM To: Kahn Roven PROOF OF SERVICE (STATE) The undersigned declares that I am employed in the County of Los Angeles, State of California; I am over the age ofeighteen years and am not a party to this action; my business address is 5550 Topanga Canyon Boulevard, Suite 200, Woodland Hills, California 91367,in said County and State. On the date set forth below I served the document to which this Proof of Service is attached on the interested parties in this action, by placing true copies thereof in a sealed envelope addressed as follows: Scott M. Leavitt Daniels, Fine, Israel, Schonbuch & Lebovits, LLP 1801 Century Park East Ninth Floor Los Angeles, California 90067 BY MAIL -X__ By placing said documents in an envelope or package and then sealing said envelope and depositing the same, with postage thereon fully prepaid, by certified mail, return receipt requested, at a post office or, mailbox, subpost office, substation or mail chute or otherlike facility regularly maintained by the United States Postal Service, at Woodland Hills, California; that there is a regular communication between the place of mailing and the place(s) so addressed. I declare under penalty of perjury, under the lawsof the State of California, that the foregoing is true and correct, Executed on November 1, 2017, at Woodland Hills, California. EN BETH MARK “A RA YY -< (Please Print) Signature
