Reply To OppositionReplyCal. Super. - 4th Dist.September 4, 2019NO 0 9 A N Wn B L N N N N N N N N N N m m e m e d Re m pe ed pe el ee d e d pe d e m 0 N Y N R W N = O V R N Y E R W N e e Oo Electronically Filed by Superior Court of California, County of Orange, 11/22/2019 05:37:00 PM. DAVID H. YAMASAKI, Clerk of the Court By e Clerk, Deputy Clerk. 30-2019-01094465-CU-PO-CJ C ROA #31 THOMAS PEDERSEN (SBN 304747) 438 E Katella Ave, Suite 213 Orange, CA 92867 Tel (888) 320-5248 ext 401 Fax (714) 644-8208 thomaspedersen@thomaspedersenlaw.com Attorney for Defendant Zhen Lian McWilliams SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ORANGE, CENTRAL JUSTICE CENTER MICHAEL MCWILLIAMS, an individual, Case No. 30-2019-01094465-CU-PO-CIC 0.M., a Minor REPLY TO OPPOSITION TO Plaintiffs, DEFENDANT’S MOTION TO DECLARE PLAINTIFF A VEXATIOUS LITIGANT Vv. (CCP § 391 et seq); REQUIRE SECURITY FOR PENDING LITIGATION OR ZHEN LIAN MCWILLIAMS, an individual DISMISS; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION Defendant. OF THOMAS PEDERSEN; EXHIBITS; Hearing Date: December 2,2019 Hearing Time: Dept: C32 Reservation: 73146761 TO PLAINTIFF MICHAEL MCWILLIAMS: Defendant ZHEN LIAN MCWILLIAMS (hereinafter “Defendant”) submits this REPLY TO OPPOSITION TO DEFENDANT'S MOTION TO DECLARE PLAINTIFF A VEXATIOUS LITIGANT (CCP § 391 et seq); REQUIRE SECURITY FOR PENDING LITIGATION OR DISMISS. Almost nothing in Plaintiff Michael McWilliams’s Opposition is true; less is relevant to this case; less still is relevant to the motion at hand.! The Opposition as a whole, however, is illustrative as to how Plaintiff has conducted himself in this case, in 30-2018-01016395-CU-PO-CIJC, and in 16D009631. As discussed below and in the Declaration of Thomas Pedersen, attached, Plaintiff’s ! Counsel for Defendant concedes he is indeed “buried in student loan debt” as Plaintiff alleges. (Opposition, p. 6, In 9) -1- REPLY TO OPPOSITION TO MOTION TO DECLARE PLAINTIFF A VEXATIOUS LITIGANT O 0 0 3 O N nh B W R ) e m B O N 0 DN N N R R N R m m e k p m e m pe d pe ed p e d pe d pe ed ee d QW N N B W R = O D N YN B R W N ms actions which qualify him as a vexatious litigant under Code of Civil Procedure, sections 391 et seq., have continued since Defendant’s Motion was filed on October 11, 2019. Specifically, Plaintiff has “repeatedly file[d] unmeritorious motions, pleadings, or other papers,...or engage[d] in other tactics that are frivolous or solely intended to cause unnecessary delay.” (CCP §391(b)(3) 1. In case 30-2018-01016395-CU-PO-CJC, Plaintiff never filed his Responses to Requests for Admissions as he was ordered on September 16, 2019 by the Honorable Aaron Heisler, Judge Pro Tem. In case 30-2018-01016395-CU-PO-CJC, Plaintiff has yet to provide any answer to 10 of the Form Interrogatories he was ordered to answer at hearing on October 28, 2019. He further provided noncompliant answers to 13 of the Form Interrogatories he was ordered to answer at hearing on October 28, 2019. (Exh. 1) Plaintiff has yet to pay the sanctions ordered at this hearing. In case 30-2018-01016395-CU-PO-CIC, Plaintiff provided noncompliant responses to 11 Requests for Production of Documents he was ordered to answer at hearing on October 28, 2019. (Exh. 2) Plaintiff has yet to pay the sanctions ordered at this hearing. In case 16D009631, a subpoena was issued and is referenced on page 4, line 17 of the instant motion. After Michael McWilliam’s motion to quash was denied (Motion, Exh. 2), the subpoena yielded records showing $47,972.00 Cash Out by Plaintiff from that single casino. (Exh. 3) Plaintiff called the subpoena “a fallacious fishing expedition” in his motion to quash. (A claim repeated in Plaintiff’s Opposition to the instant motion, p. 16, In 2) None of that income was disclosed on the Income and Expense Declarations filed 7/08/2019; 2/28/2019; 10/02/2018; 4/19/2018; or 8/08/2017. Plaintiff's false I&E’s have been used to determine child support, spousal support, grant fee waivers, and obtain court appointed counsel. In case 16009631, On November 1, 2019, Plaintiff was sanctioned once again, this time for necessitating that Defendant to file motions to quash six defective subpoenas. (Exh. 4) Plaintiff has yet to pay the sanctions ordered at this hearing. -2- REPLY TO OPPOSITION TO MOTION TO DECLARE PLAINTIFF A VEXATIOUS LITIGANT o t DO 0 N S N n r bh W N P N R N N N N N N D me e e e d p e d e d pe d p e d e d e d je 0 N Y nn B W = O Y N N N U R W N em Oo Despite imposition of a domestic violence restraining order and repeated monetary sanctions, Plaintiff will not cease his harassment of Defendant. He continues to contact her employer. The sanctions go unpaid. Only the granting of this motion and the deterrent of posting -- deposit can stop Plaintiff. For the reasons stated herein, Respondent Zhen McWilliams respectfully requests that this Court: 1. Declare Plaintiff to be a vexatious litigant; 2. Require Plaintiff to furnish security for this case of at least $24,000 or dismiss; 3. Such other and further relief as the court shall deem proper. Dated: November 22, 2019 ~~ 4 a lL. PHOMAS PEDERSEN Attorney for DEFENDANT ZHEN LIAN MCWILLIAMS -3- REPLY TO OPPOSITION TO MOTION TO DECLARE PLAINTIFF A VEXATIOUS LITIGANT La NO 0 3 S N nt BA 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DECLARATION OF THOMAS PEDERSEN I, Thomas Pedersen declare: | 1 I am an attorney at law duly licensed to practice before all courts in the State of California. Iam the attorney of record for Defendant Zhen Lian McWilliams, in the above-entitled proceedings and, as such, I have knowledge of the matters contained herein and they are true and correct of my own personal knowledge, except for those matters stated upon information and belief as to those matters, I believe them to be true and correct. If called and sworn as a witness, I could and would testify competently thereto. 2, I make this declaration in support of Defendant’s Motion TO DECLARE PLAINTIFF A VEXATIOUS LITIGANT (CCP § 391 et seq); REQUIRE SECURITY FOR PENDING LITIGATION OR DISMISS. 3. I also represent Defendant in Orange County Superior Court case 30-2018-01016395- CU-PO-CJC in which she is defendant. Michael McWilliams is Plaintiff in 30-2018- 01016395-CU-PO-CJC. I also represent Defendant in Orange County Superior Court case 16D009631 in which she is Respondent. Michael McWilliams in Petitioner in 16D009631. 4. I was present in court on October 28, 2019, and I did not observe the Honorable Judge Hoffer to be “befuddled” as Plaintiff claims on page 2, line 2. 5. On page 5 of Plaintiff's Opposition he suggests I subpoena the Superior Court to obtain video of my “beet red face and diminutive chin.” I have no intention of doing so, but if Plaintiff wishes to do so, I offer to pay for a copy to be made and to pay postage for him to send a copy to the State Bar. 6. On pages 7, 8, and 22 of Plaintiff's Opposition he describes an event that did not occur. I was not at Harbor Court at any time on April 11, 2019. I have never raised my voice in any courthouse. I have never used profanity with Plaintiff. That said, I -4- REPLY TO OPPOSITION TO MOTION TO DECLARE PLAINTIFF A VEXATIOUS LITIGANT NO 0 0 O N wn dB W N ) e w N N B N RN RN R N R N D k e k e e m e m pe d e d je m p e d p a pe a «0 N N B A R W O N = O Y N Y R L em eo strongly agree with the content of the statements attributed to me on page 7 of his Opposition. 7. “INCIDENT TWO?” described on page 8 of Plaintiff’s Opposition did not occur. However, Plaintiff has already been admonished by the Honorable Renee Wilson to not bring the minor child to court or even let the child know when court dates are. That Plaintiff would name the minor child as a party to this suit is very unfortunate and will soon be brought to the family court’s attention. 8. On page 13 of his Opposition, Plaintiff describes the same imaginary event, but this time occurring on April 2, 2019. I was not at Harbor Court at any time on April 2, 2019 and as of that date I had never met either party. 9. Plaintiffs Opposition, page 26, line 3, claims that Defendant lives in a $3,200,000 home and drives a new luxury vehicle. This false claim has been disproven in family court repeatedly. Defendant rents a modest apartment shared by 3 other family members and leases a Honda Civic. 10. Ihave no relationship with Defendant than that of an appropriate and ethical attorney- client relationship. Ihave met with her outside of the courthouse on only three occasions and on those three occasions there was at all times another female within eyesight as is my practice with all my clients who have been the victims of domestic violence. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on this, the 22nd day of November at Orange, California. OMAS PEDERSEN ~ Attorney for DEFENDANT ZHEN LIAN MCWILLIAMS -5- REPLY TO OPPOSITION TO MOTION TO DECLARE PLAINTIFF A VEXATIOUS LITIGANT Exhibit 1 Exhibit 1 MICHAEL MCWILLIAMS 7761 CITADEL CIRCLE WESTMINSTER, CA 92683 657-203-1298 MICHAEL MCWILLIAMS, IN PRO PER SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ORANGE, CENTRAL JUSTICE CENTER MICHAEL WARREN MCWILLIAMS, an ) CASE NO.30-2018-01016395-CU-PO-CJC individual: ) Plaintiff(s), PLAINTIFF'S ANSWER TO DEFENDANTS vs. REQUEST FOR INTERROGATORIES ) ZHEN LIAN MCWILLIAMS, ) DISC-001 ) AKA LIAN ZHEN, ZHEN LIAN ) ) Defendant(s). ) ) ) ) PLAINTIFFS ANSWERS ARE AS FOLLOWS: 1) DEFENDANT DID KNOWINGLY AND WITH MALICE ENGAGE IN PROSTITUTION AND EXTRA MARITAL AFFAIRS CONTRACTING NUMEROUS STD'S AND WITHOUT INFORMING SPOUSE KNOWINGLY AND WILLFULLY WITH MALICE PASSSED ON THOSE SAID STD’S TO PLAINTIFF. 2) MICHAEL MCWILLIAMS 2.3) 02/19/61 Los Angeles 2.5) 102 ridge valley #311 IRVINE CA 92618 2.6) 7750 BOLSA #46 MIDWAY CITY, CA 92655 2.7) NO 2.12) NO -1- INSERT DOCUMENT TITLE (e.g., MOTION TO STRIKE) 6.1) YES 6.2) EMOTIONAL PHYSICAL, LOSS OF CONSITIUM 4) HIPAA 5) HIPAA 6.6) HIPAA 7) HIPPA 8.1) NO 9.1) PLEASE REFER TO PETITION 10.0) HIPAA 10.2) HIPAA 10.3) HIPAA 11.1) N 1.2)N 12.1) MICHAEL MCWILLIAMS ON FILE 12.2) YES...ZHEN MCWILLIAMS ADMITTED GUILT 12.3) N 12.4) YES 12.6) PLEASE REFER TO LAWSUIT 13.1) NO 13.2) NA 17.1) do not recall I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. | /, Dated: 11/07/2019 ~ J i . MICHAEL MCWILLIAMS PLAINTIFF i. INSERT DOCUMENT TITLE (e.g., MOTION TO STRIKE) DISC-001 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): Thomas Pedersen (SBN 304747) |__ 438 E Katella Ave, Ste 213 Orange, CA 92867 TELEPHONE NO. 888-320-5248 ext 401 FAX NO. (Optional): 714-644-8208 E-MAIL ADDRESS (Optional): thomaspedersen@thomaspedersenlaw.com ATTORNEY FOR (Name): Zhen Lian McWilliams SUPERIOR COURT OF CALIFORNIA, COUNTY OF ORANGE CENTRAL JUSTICE CENTER 700 Civic Center Drive West, Santa Ana, CA 92701 SHORT TITLE OF CASE: MICHAEL MCWILLIAMS VS. ZHEN LIAN MCWILLIAMS Asking Party: ZHEN LIAN MCWILLIAMS Answering Party: MICHAEL MCWILLIAMS Set No: ONE (1) FORM INTERROGATORIES-GENERAL CASE NUMBER 30-2018-01016395-CU-PO-CIC Sec. 1. Instructions to All Parties (a) Interrogatories are written questions prepared by a party to an action that are sent to any other party in the action to be answered under oath. The interrogatories below are form interrogatories approved for use in civil cases. (b) For time limitations, requirements for service on other parties, and other details, see Code of Civil Procedure sections 2030.010-2030.410 and the cases construing those sections. {c) These form interrogatories do not change existing law relating to interrogatories nor do they affect an answering party's right to assert any privilege or make any objection. Sec. 2. Instructions to the Asking Party (a) These interrogatories are designed for optional use by parties in unlimited civil cases where the amount demanded exceeds $25,000. Separate interrogatories, Form Interrogatories-Limited Civil Cases (Economic Litigation) (form DISC-004), which have no subparts, are designed for use in limited civil cases where the amount demanded is $26,000 or less; however, those interrogatories may also be used in unlimited civil cases. (b) Check the box next to each interrogatory that you want the answering party to answer. Use care in choosing those interrogatories that are applicable to the case. (c) You may insert your own definition of INCIDENT in Section 4, but only where the action arises from a course of conduct or a series of events occurring over a period of time. (d) The interrogatories in section 16.0, Defendant's Contentions-Personal Injury, should not be used until the defendant has had a reasonable opportunity to conduct an investigation or discovery of plaintiff's injuries and damages. {e) Additional interrogatories may be attached. Sec. 3. Instructions to the Answering Party (a) An answer or other appropriate response must be given to each interrogatory checked by the asking party. (b) As a general rule, within 30 days after you are served with these interrogatories, you must serve your responses on the asking party and serve copies of your responses on all other parties to the action who have appeared. See Code of Civil Procedure sections 2030.260-2030.270 for details. Form Approved for Optional Use Judicial Council of California DISC-001 {Rev. January 1, 2008] (c) Each answer must be as complete and straightforward as the information reasonably available to you, including the information possessed by your attorneys or agents, permits. If an interrogatory cannot be answered completely, answer it to the extent possible. ‘ (d) If you do not have enough personal knowledge to fully answer an interrogatory, say so, but make a reasonable and good faith effort to get the information by asking other persons or organizations, unless the information is equally available to the asking party. (e) Whenever an interrogatory may be answered by referring to a document, the document may be attached as an exhibit to the response and referred to in the response. If the document has more than one page, refer to the page and section where the answer to the interrogatory can be found. (f) Whenever an address and telephone number for the same person are requested in more than one interrogatory, you are required to furnish them in answering only the first interrogatory asking for that information. (g) If you are asserting a privilege or making an objection to an interrogatory, you must specifically assert the privilege or state the objection in your written response. (h) Your answers to these interrogatories must be verified, dated, and signed. You may wish to use the following form at the end of your answers: | declare under penalty of perjury under the laws of the State of California that the foregoing answers are true and correct. FORM INTERROGATORIES-GENERAL (DATE) (SIGNATURE) Sec. 4. Definitions Words in BOLDFACE CAPITALS in these interrogatories are defined as follows: (a) (Check one of the following): (1) INCIDENT includes the circumstances and events surrounding the alleged accident, injury, or other occurrence or breach of contract giving rise to this action or proceeding. Page 1of{8 Code of Civil Procedure, §§ 2030.010-2030.410, 2033.710 www. courtinfo.ca gov J (2) INCIDENT means (insert your definition here or on a separate, attached sheet labeled “Sec. 4(a)(2)"): {b) YOU OR ANYONE ACTING ON YOUR BEHALF includes you, your agents, your employees, your insurance companies, their agents, their employees, your attorneys, your accountants, your investigators, and anyone else acting on your behalf. (c) PERSON includes a natural person, firm, association, organization, parinership, business, trust, limited liability company, corporation, or public entity. (d) DOCUMENT means a writing, as defined in Evidence Code section 250, and includes the original or a copy of handwriting, typewriting, printing, photostats, photographs, electronically stored information, and every other means of recording upon any tangible thing and form of communicating or representation, including letters, words, pictures, sounds, or symbols, or combinations of them. (e) HEALTH CARE PROVIDER includes any PERSON referred to in Code of Civil Procedure section 667.7(e)(3). (f) ADDRESS means the street address, including the city, state, and zip code. Sec. 5. Interrogatories The following interrogatories have been approved by the Judicial Council under Code of Civil Procedure section 2033.710: CONTENTS 1.0 Identity of Persons Answering These Interrogatories 2.0 General Background Information-Iindividual 3.0 General Background Information-Business Entity 4.0 Insurance 5.0 [Reserved] 6.0 Physical, Mental, or Emotional Injuries 7.0 Property Damage 8.0 Loss of Income or Earning Capacity 9.0 Other Damages 10.0 Medical History 11.0 Other Claims and Previous Claims 12.0 Investigation-General 13.0 Investigation-Surveillance 14.0 Statutory or Regulatory Violations 15.0 Denials and Special or Affirmative Defenses 16.0 Defendant's Contentions Personal Injury 17.0 Responses to Request for Admissions 18.0 [Reserved] 19.0 [Reserved] 20.0 How the Incident Occurred-Motor Vehicle 25.0 fReserved] 30.0 [Reserved] 40.0 [Reserved] 50.0 Contract 60.0 [Reserved] 70.0 Unlawful Detainer [See separate form DISC-003] 101.0 Economic Litigation [See separate form DISC-004] 200.0 Employment Law [See separate form DISC-002] Family Law [See separate form FL-145] DISC-001 1.0 Identity of Persons Answering These interrogatories 1.1 State the name, ADDRESS, telephone number, and relationship to you of each PERSON who prepared or assisted in the preparation of the responses to these interrogatories. (Do not identify anyone who simply typed or reproduced the responses.) 2.0 General Background Information-individual 2.1 State: (a) your name; (b) every name you have used in the past; and (c) the dates you used each name. 2.2 State the date and place of your birth. [] 2.3 At the time of the INCIDENT, did you have a driver's license? If so state: (a) the state or other issuing entity; (b) the license number and type; (c) the date of issuance; and (d) all restrictions. [J 2.4 Atthe time of the INCIDENT, did you have any other permit or license for the operation of a motor vehicle? If so, state: (a) the state or other issuing entity; (b) the license number and type; (c) the date of issuance; and (d) all restrictions. 2.5 State: (a) your present residence ADDRESS; (b) your residence ADDRESSES for the past five years; and (c) the dates you lived at each ADDRESS. 2.6 State: (a) the name, ADDRESS, and telephone number of your present employer or place of self-employment; and (b) the name, ADDRESS, dates of employment, job title, and nature of work for each employer or self-employment you have had from five years before the INCIDENT until today. 2.7 State: (a) the name and ADDRESS of each school or other academic or vocational institution you have attended, beginning with high school; (b) the dates you attended; (c) the highest grade level you have completed; and (d) the degrees received. 2.8 Have you ever been convicted of a felony? If so, for each conviction state: (a) the city and state where you were convicted; (b) the date of conviction; (c) the offense; and {d) the court and case number. [] 2.9 Can you speak English with ease? If not, what language and dialect do you normally use? 1 2.10 Can you read and write English with ease? If not, what language and dialect do you normally use? DISC-001 [Rev. January 1, 2008] FORM INTERROGATORIES-GENERAL Page2o0f8 J 2.11 Atthe time of the INCIDENT were you acting as an agent or employee for any PERSON? If so, state: (a) the name, ADDRESS, and telephone number of that PERSON: and {b) a description of your duties. 2.12 At the time of the INCIDENT did you or any other person have any physical, emotional, or mental disability or condition that may have contributed to the occurrence of the INCIDENT? If so, for each person state: (a) the name, ADDRESS, and telephone number; (b) the nature of the disability or condition; and (c) the manner in which the disability or contributed to the occurrence of the INCIDENT. condition 2.13 Within 24 hours before the INCIDENT did you or any person involved in the INCIDENT use or take any of the following substances: alcoholic beverage, marijuana, or other drug or medication of any kind {prescription or not)? If so, for each person state: (a) the name, ADDRESS, and telephone number; (b) the nature or description of each substance: (¢) the quantity of each substance used or taken; {d) the date and time of day when each substance was used or taken; (e) the ADDRESS where each substance was used or taken; (f) the name, ADDRESS, and telephone number of each person who was present when each substance was used or taken; and (9) the name, ADDRESS, and telephone number of any HEALTH CARE PROVIDER who prescribed or furnished the substance and the condition for which it was prescribed or furnished. 3.0 General Background Information-Business Entity [] 3.1 Are you a corporation? If so, state: (a) the name stated in the current articles of incorporation; (b) all other names used by the corporation during the past 10 years and the dates each was used: (¢) the date and place of incorporation; (d) the ADDRESS of the principal place of business; and (e) whether you are qualified to do business in California. 3.2 Are you a partnership? If so, state: (a) the current partnership name; (b) all other names used by the partnership during the past 10 years and the dates each was used; {c) whether you are a limited partnership and, if so, under the laws of what jurisdiction; (d) the name and ADDRESS of each general partner; and (e) the ADDRESS of the principal place of business. 3.3 Are you a limited liability company? If so, state: (a) the name stated in the current articles of organization; {b) all other names used by the company during the past 10 years and the date each was used; (c) the date and place of filing of the articles of organization; (d) the ADDRESS of the principal place of business; and (e) whether you are qualified to do business in California. ] DISC-001 3.4 Are you a joint venture? If so, state: (a) the current joint venture name: (b) ali other names used by the joint venture during the past 10 years and the dates each was used; (c) the name and ADDRESS of each joint venturer; and (d) the ADDRESS of the principal place of business. 3.5 Are you an unincorporated association? If so, state: (a) the current unincorporated association name; (b) all other names used by the unincorporated association during the past 10 years and the dates each was used; and (c) the ADDRESS of the principal place of business. 3.6 Have you done business under a fictitious name during the past 10 years? If so, for each fictitious name state: (a) the name; (b) the dates each was used; (c) the state and county of each fictitious name filing; and (d) the ADDRESS of the principal place of business. 3.7 Within the past five years has any public entity regis- tered or licensed your business? If so, for each license or registration: (a) identify the license or registration; (b) state the name of the public entity; and (c) state the dates of issuance and expiration. 4.0 Insurance [] LJ 5.0 6.0 4.1 Atthe time of the INCIDENT, was there in effect any policy of insurance through which you were or might be insured in any manner (for example, primary, pro-rata, or excess liability coverage or medical expense coverage) for the damages, claims, or actions that have arisen out of the INCIDENT? If so, for each policy state: (a) the kind of coverage; (b) the name and ADDRESS of the insurance company; (c) the name, ADDRESS, and telephone number of each named insured; (d) the policy number; (e) the limits of coverage for each type of coverage con- tained in the policy; (f) whether any reservation of rights or controversy or coverage dispute exists between you and the insurance company; and {g) the name, ADDRESS, and telephone number of the custodian of the policy. 4.2 Are you self-insured under any statute for the damages, claims, or actions that have arisen out of the INCIDENT? If so, specify the statute. [Reserved] Physical, Mental, or Emotional Injuries 6.1 Do you attribute any physical, mental, or emotional injuries to the INCIDENT? (If your answer is “no,” do not answer interrogatories 6.2 through 6.7). 6.2 identify each injury you attribute to the INCIDENT and the area of your body affected. DISC-001 [Rev. January 1, 2008} FORM INTERROGATORIES-GENERAL Page 3 of 8 6.3 Do you still have any complaints that you attribute to the INCIDENT? If so, for each complaint state: (a) a description; {b) whether the complaint is subsiding, remaining the same, or becoming worse; and {c) the frequency and duration. 6.4 Did you receive any consultation or examination (except from expert witnesses covered by Code of Civil Procedure sections 2034.210-2034.310) or treatment from a HEALTH CARE PROVIDER for any injury you attribute to the INCIDENT? If so, for each HEALTH CARE PROVIDER state: (a) the name, ADDRESS, and telephone number: {b) the type of consultation, examination, or provided; {c) the dates you received consultation, examination, or treatment; and (d) the charges to date. treatment 6.5 Have you taken any medication, prescribed or not, as a result of injuries that you attribute to the INCIDENT? If so, for each medication state: (a) the name; {b) the PERSON who prescribed or furnished it; (c) the date it was prescribed or furnished: (d) the dates you began and stopped taking it; and {e) the cost to date. 6.6 Are there any other medical services necessitated by the injuries that you attribute to the INCIDENT that were not previously listed (for example, ambulance, nursing, prosthetics)? If so, for each service state: (a) the nature; (b) the date; {c) the cost; and (d) the name, ADDRESS, and telephone number of each provider. 6.7 Has any HEALTH CARE PROVIDER advised that you may require future or additional treatment for any injuries that you attribute to the INCIDENT? If so, for each injury state: (a) the name and ADDRESS of each HEALTH CARE PROVIDER; {b) the complaints for which the treatment was advised: and (c) the nature, duration, and estimated cost of the treatment. 7.0 Property Damage ] 7.1 Do you attribute any loss of or damage to a vehicle or other property to the INCIDENT? If so, for each item of property: (a) describe the property; (b) describe the nature and location of the damage to the property; DISC-001 (c) state the amount of damage you are claiming for each item of property and how the amount was calculated: and (d) if the property was sold, state the name, ADDRESS, and telephone number of the seller, the date of sale, and the sale price. J 7.2 Has a written estimate or evaluation been made for any item of property referred to in your answer to the preceding interrogatory? If so, for each estimate or evaluation state: (a) the name, ADDRESS, and telephone number of the PERSON who prepared it and the date prepared: (b) the name, ADDRESS, and telephone number of each PERSON who has a copy of it; and (¢) the amount of damage stated. 1] 7.3 Has any item of property referred to in your answer to interrogatory 7.1 been repaired? If so, for each item state: (a) the date repaired, (b) a description of the repair; (c) the repair cost; (d) the name, ADDRESS, and telephone number of the PERSON who repaired it; (e) the name, ADDRESS, and telephone number of the PERSON who paid for the repair. 8.0 Loss of Income or Earning Capacity 8.1 Do you attribute any loss of income or earning capacity to the INCIDENT? (if your answer is “no,” do not answer interrogatories 8.2 through 8.8). 8.2 State: (a) the nature of your work; (b) your job title at the time of the INCIDENT; and (c) the date your employment began. 8.3 State the last date before the INCIDENT that you worked for compensation. 8.4 State your monthly income at the time of the INCIDENT and how the amount was calculated. 8.5 State the date you returned to work at each place of employment following the INCIDENT. 8.6 State the dates you did not work and for which you lost income as a result of the INCIDENT. 8.7 State the total income you have lost to date as a result of the INCIDENT and how the amount was calculated. 8.8 Will you lose income in the future as a result of the INCIDENT? If so, state: (a) the facts upon which you base this contention; (b) an estimate of the amount; {c) an estimate of how long you will be unable to work; and (d) how the claim for future income is calculated. OiSC-001 [Rev. January 1, 2008] FORM INTERROGATORIES-GENERAL Paged of 8 9.0 Other Damages 9.1 Are there any other damages that you attribute to the INCIDENT? If so, for each item of damage state: (a) the nature; ) (b) the date it occurred; (c) the amount; and {d) the name, ADDRESS, and telephone number of each PERSON to whom an obligation was incurred. 9.2 Do any DOCUMENTS support the existence or amount of any item of damages claimed in interrogatory 9.1? If so, describe each document and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT. 10.0 Medical History 10.1 At any time before the INCIDENT did you have com- plaints or injuries that involved the same part of your body claimed to have been injured in the INCIDENT? If so, for each state: (a) a description of the complaint or injury; (b) the dates it began and ended; and (c) the name, ADDRESS, and telephone number of each HEALTH CARE PROVIDER whom you consulted or who examined or treated you. 10.2 List all physical, mental, and emotional disabilities you had immediately before the INCIDENT. (You may omit mental or emotional disabilities unless you attribute any mental or emotional injury to the INCIDENT.) 10.3 At any time after the INCIDENT, did you sustain injuries of the kind for which you are now claiming damages? If so, for each incident giving rise to an injury state: (a) the date and the place it occurred; (b) the name, ADDRESS, and telephone number of any other PERSON involved; (c) the nature of any injuries you sustained; (d) the name, ADDRESS, and telephone number of each HEALTH CARE PROVIDER who you consulted or who examined or treated you; and (e) the nature of the treatment and its duration. 11.0 Other Claims and Previous Claims 11.1 Except for this action, in the past 10 years have you filed an action or made a written claim or demand for compensation for your personal injuries? If so, for each action, claim, or demand state: (a) the date, time, and place and location (closest street ADDRESS or intersection) of the INCIDENT giving rise to the action, claim, or demand; (b) the name, ADDRESS, and telephone number of each PERSON against whom the claim or demand was made or the action filed; DiscC-001 (c) the court, names of the parties, and case number of any action filed; (d) the name, ADDRESS, and telephone number of any attorney representing you: (e) whether the claim or action has been resolved or is pending; and (f) a description of the injury. 11.2 In the past 10 years have you made a written claim or demand for workers' compensation benefits? If so, for each claim or demand state: (a) the date, time, and place of the INCIDENT giving rise to the claim; (b) the name, ADDRESS, and telephone number of your employer at the time of the injury; (c) the name, ADDRESS, and telephone number of the workers’ compensation insurer and the claim number; (d) the period of time during which you received workers’ compensation benefits; (e) a description of the injury; (f) the name, ADDRESS, and telephone number of any HEALTH CARE PROVIDER who provided services: and (g) the case number at the Workers’ Compensation Appeals Board. 12.0 Investigation-General 12.1 State the name, ADDRESS, and telephone number of each individual: (a) who witnessed the INCIDENT or the events occurring immediately before or after the INCIDENT; (b) who made any statement at the scene of the INCIDENT; (c) who heard any statements made about the INCIDENT by any individual at the scene; and (d) who YOU OR ANYONE ACTING ON YOUR BEHALF claim has knowledge of the INCIDENT (except for expert witnesses covered by Code of Civil Procedure section 2034). 122 Have YOU OR ANYONE ACTING ON YOUR BEHALF interviewed any individual concerning the INCIDENT? If so, for each individual state: (a) the name, ADDRESS, and telephone number of the individual interviewed; (b) the date of the interview; and (c) the name, ADDRESS, and telephone number of the PERSON who conducted the interview. 12.3 Have YOU OR ANYONE ACTING ON YOUR BEHALF obtained a written or recorded statement from any individual concerning the INCIDENT? If so, for each statement state: (a) the name, ADDRESS, and telephone number of the individual from whom the statement was obtained; (b) the name, ADDRESS, and telephone number of the individual who obtained the statement; (c) the date the statement was obtained; and (d) the name, ADDRESS, and telephone number of each PERSON who has the original statement or a copy. DISC-001 [Rev. January 1, 2008] FORM INTERROGATORIES-GENERAL Page Sof 8 12.4 Do YOU OR ANYONE ACTING ON YOUR BEHALF know of any photographs, films, or videotapes depicting any place, object, or individual concerning the INCIDENT or plaintiff's injuries? If so, state: (a) the number of photographs or feet of film or videotape: (b) the places, objects, or persons photographed, filmed, or videotaped; (c) the date the photographs, films, or videotapes were taken; (d) the name, ADDRESS, and telephone number of the individual taking the photographs, films, or videotapes: and {e) the name, ADDRESS, and teléphone number of each PERSON who has the original or a copy of the photographs, films, or videotapes. [] 12.5 Do YOU OR ANYONE ACTING ON YOUR BEHALF know of any diagram, reproduction, or model of any place or thing (except for items developed by expert witnesses covered by Code of Civil Procedure sections 2034.210~ 2034.310) concerning the INCIDENT? If so, for each item state: (a) the type (i.e., diagram, reproduction, or model); (b) the subject matter; and (c) the name, ADDRESS, and telephone number of each PERSON who has it. 12.6 Was a report made by any PERSON concerning the INCIDENT? If so, state: (a) the name, title, identification number, and employer of the PERSON who made the report; {b) the date and type of report made; (c) the name, ADDRESS, and telephone number of the PERSON for whom the report was made; and (d) the name, ADDRESS, and telephone number of each PERSON who has the original or a copy of the report. [[]127 Have YOU OR ANYONE ACTING ON YOUR BEHALF inspected the scene of the INCIDENT? If so, for each inspection state: (a) the name, ADDRESS, and telephone number of the individual making the inspection (except for expert witnesses covered by Code of Civili Procedure sections 2034.210-2034.310); and (b) the date of the inspection. 13.0 Investigation-Surveillance 13.1 Have YOU OR ANYONE ACTING ON YOUR BEHALF conducted surveillance of any individual involved in the INCIDENT or any party to this action? If so, for each sur- veillance state: (a) the name, ADDRESS, and telephone number of the individual or party; (b) the time, date, and place of the surveillance; (c) the name, ADDRESS, and telephone number of the individual who conducted the surveillance; and (d) the name, ADDRESS, and telephone number of each PERSON who has the original or a copy of any surveillance photograph, film, or videotape. DISC-001 13.2 Has a written report been prepared on the surveillance? if so, for each written report state: (a) the title; (b) the date; (c) the name, ADDRESS, and telephone number of the individual who prepared the report; and (d) the name, ADDRESS, and telephone number of each PERSON who has the original or a copy. 14.0 Statutory or Regulatory Violations 14.1 Do YOU OR ANYONE ACTING ON YOUR BEHALF contend that any PERSON involved in the INCIDENT violated any statute, ordinance, or regulation and that the violation was a legal (proximate) cause of the INCIDENT? if so, identify the name, ADDRESS, and telephone number of each PERSON and the statute, ordinance, or regulation that was violated. 14.2 Was any PERSON cited or charged with a violation of any statute, ordinance, or regulation as a result of this INCIDENT? If so, for each PERSON state: (a) the name, ADDRESS, and telephone number of the PERSON; (b) the statute, ordinance, or regulation allegedly violated; (c) whether the PERSON entered a plea in response to the citation or charge and, if so, the plea entered; and (d) the name and ADDRESS of the court or administrative agency, names of the parties, and case number. 15.0 Denials and Special or Affirmative Defenses 1 156.1 Identify each denial of a material allegation and each special or affirmative defense in your pleadings and for each: 3 (a) state all facts upon which you base the denial or special or affirmative defense; (b) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of those facts; and (c) identify all DOCUMENTS and other tangible things that support your denial or special or affirmative defense, and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT. 16.0 Defendant's Contentions-Personal Injury J] 16.1 Do you contend that any PERSON, other than you or plaintiff, contributed to the occurrence of the INCIDENT or the injuries or damages claimed by plaintiff? If so, for each PERSON: (a) state the name, ADDRESS, and telephone number of the PERSON; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. J 16.2 Do you contend that plaintiff was not injured in the INCIDENT? If so: (a) state all facts upon which you base your contention; (b) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (c) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. DISC-001 [Rev. January 1, 2008] FORM INTERROGATORIES-GENERAL Pagefof 8 ] 16.3 Do you contend that the injuries or the extent of the injuries claimed by plaintiff as disclosed in discovery proceedings thus far in this case were not caused by the INCIDENT? If so, for each injury: (a) identify it; (b) state all facts upon which you base your contention; {c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. ] 16.4 Do you contend that any of the services furnished by any HEALTH CARE PROVIDER claimed by plaintiff in discovery proceedings thus far in this case were not due to the INCIDENT? if so: (a) identify each service; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. J] 16.5 Do you contend that any of the costs of services furnished by any HEALTH CARE PROVIDER claimed as damages by plaintiff in discovery proceedings thus far in this case were not necessary or unreasonable? If so: (a) identify each cost; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. 1] 16.6 Do you contend that any part of the loss of earnings or income claimed by plaintiff in discovery proceedings thus far in this case was unreasonable or was not caused by the INCIDENT? If so: (a) identify each part of the loss; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. ] 16.7 Do you contend that any of the property damage claimed by plaintiff in discovery Proceedings thus far in this case was not caused by the INCIDENT? If so: (a) identify each item of property damage; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. DISC-001 ] 16.8 Do you contend that any of the costs of repairing the property damage claimed by plaintiff in discovery proceedings thus far in this case were unreasonable? If so: (a) identify each cost item; (b) state all facts upon which you base your contention; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of the facts; and (d) identify all DOCUMENTS and other tangible things that support your contention and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. 1] 16.9 Do YOU OR ANYONE ACTING ON YOUR BEHALF have any DOCUMENT (for example, insurance bureau index reports) concerning claims for personal injuries made before or after the INCIDENT by a plaintiff in this case? If so, for each plaintiff state: (a) the source of each DOCUMENT; {b) the date each claim arose; {(c) the nature of each claim; and (d) the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT. ] 16.10 Do YOU OR ANYONE ACTING ON YOUR BEHALF have any DOCUMENT conceming the past or present physical, mental, or emotional condition of any plaintiff in this case from a HEALTH CARE PROVIDER not previously identified (except for expert witnesses covered by Code of Civil Procedure sections 2034.210-2034.310)? If so, for each plaintiff state: (a) the name, ADDRESS, and telephone number of each HEALTH CARE PROVIDER; (b) a description of each DOCUMENT; and (c) the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT. 17.0 Responses to Request for Admissions 17.1 Is your response to each request for admission served with these interrogatories an unqualified admission? If not, for each response that is not an unqualified admission: (a) state the number of the request; (b) state all facts upon which you base your response; (c) state the names, ADDRESSES, and telephone numbers of all PERSONS who have knowledge of those facts; and (d) identify all DOCUMENTS and other tangible things that support your response and state the name, ADDRESS, and telephone number of the PERSON who has each DOCUMENT or thing. 18.0 [Reserved] 19.0 [Reserved] 20.0 How the Incident Occurred-Motor Vehicle J 20.1 State the date, time, and place of the INCIDENT (closest street ADDRESS or intersection). [(J20.2 For each vehicle involved in the INCIDENT, state: (a) the year, make, model, and license number; (b) the name, ADDRESS, and telephone number of the driver; DISC-001 {Rev. January 1, 2008} FORM INTERROGATORIES-GENERAL Page7of 8 (c) the name, ADDRESS, and telephone number of each occupant other than the driver; (d) the name, ADDRESS, and telephone number of each registered owner; (e) the name, ADDRESS, and telephone number of each lessee; {f) the name, ADDRESS, and telephone number of each owner other than the registered owner or lien holder; and (9) the name of each owner who gave permission or consent to the driver to operate the vehicle. [[J203 state the ADDRESS and location where your trip began and the ADDRESS and location of your destination. J 20.4 Describe the route that you followed from the beginning of your trip to the location of the INCIDENT, and state the location of each stop, other than routine traffic stops, during the trip leading up to the INCIDENT. J 20.5 State the name of the street or roadway, the lane of travel, and the direction of travel of each vehicle involved in the INCIDENT for the 500 feet of travel before the INCIDENT. [J206 Did the INCIDENT occur at an intersection? If so, describe all traffic control devices, signals, or signs at the intersection. J] 20.7 Was there a traffic signal facing you at the time of the INCIDENT? If so, state: (a) your location when you first saw it; (b) the color; {c) the number of seconds it had been that color; and (d) whether the color changed between the time you first saw it and the INCIDENT. ] 20.8 State how the INCIDENT occurred, giving the speed, direction, and location of each vehicle involved: (a) just before the INCIDENT; (b) at the time of the INCIDENT; and (c) just after the INCIDENT. 1] 20.9 Do you have information that a malfunction or defect in a vehicle caused the INCIDENT? If so: (a) identify the vehicle; {b) identify each malfunction or defect; (c) state the name, ADDRESS, and telephone number of each PERSON who is a witness to or has information about each malfunction or defect; and (d) state the name, ADDRESS, and telephone number of each PERSON who has custody of each defective part. [T2010 Do you have information that any malfunction or defect in a vehicle contributed to the injuries sustained in the INCIDENT? If so: (a) identify the vehicle, (b) identify each malfunction or defect; (c) state the name, ADDRESS, and telephone number of each PERSON who is a witness to or has information about each malfunction or defect; and DISC-001 (d) state the name, ADDRESS, and telephone number of each PERSON who has custody of each defective part. 1] 20.11 State the name, ADDRESS, and telephone number of each owner and each PERSON who has had possession since the INCIDENT of each vehicle involved in the INCIDENT. 25.0 [Reserved] 30.0 [Reserved] 40.0 [Reserved] 50.0 Contract 1 50.1 For each agreement alleged in the pleadings: (a) identify each DOCUMENT thatis part of the agreement and for each state the name, ADDRESS, and telephone number of each PERSON who has the DOCUMENT; state each part of the agreement not in writing, the name, ADDRESS, and telephone number of each PERSON agreeing to that provision, and the date that part of the agreement was made; (c) identify all DOCUMENTS that evidence any part of the agreement not in writing and for each state the name, ADDRESS, and telephone number of each PERSON who has the DOCUMENT; (d) identify all DOCUMENTS that are part of any modification to the agreement, and for each state the name, ADDRESS, and telephone number of each PERSON who has the DOCUMENT; state each modification not in writing, the date, and the name, ADDRESS, and telephone number of each PERSON agreeing to the modification, and the date the modification was made; (f) identify all DOCUMENTS that evidence any modification of the agreement not in writing and for each state the name, ADDRESS, and telephone number of each PERSON who has the DOCUMENT. (b Roel ) (e ~~ ] 50.2 Was there a breach of any agreement alleged in the pleadings? If so, for each breach describe and give the date of every act or omission that you claim is the breach of the agreement. ] 50.3 Was performance of any agreement alleged in the pleadings excused? If so, identify each agreement excused and state why performance was excused. 1 50.4 Was any agreement alleged in the pleadings terminated by mutual agreement, release, accord and satisfaction, or novation? If so, identify each agreement terminated, the date of termination, and the basis of the termination. J 50.5 Is any agreement alleged in the pleadings unenforce- able? If so, identify each unenforceable agreement and state why it is unenforceable. 1 50.6 is any agreement alleged in the pleadings ambiguous? If so, identify each ambiguous agreement and state why it is ambiguous. 60.0 [Reserved] DISC-001 [Rev. January 1. 2008] FORM INTERROGATORIES-GENERAL PageBof 8 POS-030 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, amd address): FOR COURT USE ONLY THOMAS PEDERSEN (SBN 304747) 438 E. Katella Ave., Ste 213 Orange, CA 92867 veLepHone No. (888) 320-5248 FAX NO. (optionap:(7 14) 644-8208 EMAIL ADDRESS (Optonaithomaspedersen@thomaspedersenlaw.com ATTORNEY For (Name) ZHEN LIAN MCWILLIAMS SUPERIOR COURT OF CALIFORNIA, COUNTY OF ORANGE streer aooress: 700 Civic Center Drive West MAILING ADDRESS: Same city ano zip cove: Santa Ana 92701 ranch name: Central Justice Center PETITIONERPLAINTIFE: MICHAEL MCWILLIAMS RESPONDENT/DEFENDANT:ZHEN LIAN MCWILLIAMS CASE NUMBER: PROOF OF SERVICE BY FIRST-CLASS MAIL-CIVIL 30-2018-01016395-CU-PO-CIC {Do not use this Proof of Service to show service of a Summons and Complaint.) 1. lam over 18 years of age and not a party to this action. { am a resident of or employed in the county where the mailing took place. 2. My residence or business address is: 438 E. Katella Ave., Ste 213 Santa Ana, CA 92867 3. On (date):06/13/2019 I mailed from (city and state): Orange, CA the following documents (specify): REQUESTS FOR ADMISSIONS (SET ONE); REQUESTS FOR PRODUCTION (SET ONE); FORM INTERROGATORIES-GENERAL (SET ONE) - The documents are listed in the Attachment to Proof of Service by First-Class Mail-Civil (Documents Served) (form POS-030(D)). 4. served the documents by enclosing them in an envelope and (check one): a. [7] depositing the sealed envelope with the United States Postal Service with the postage fully prepaid. b. [_] placing the envelope for collection and mailing following our ordinary business practices. | am readily familiar with this business's practice for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service in a sealed envelope with postage fully prepaid. 5. The envelope was addressed and mailed as follows: a. Name of person served: MICHAEL MCWILLIAMS b. Address of person served: 7761 CITADEL CIRCLE WESTMINSTER, CA 92863 [C1 The name and address of each person to whom | mailed the documents is listed in the Attachment to Proof of Service by First-Class Mail-Civil (Persons Served} (POS-030(P)). 1 declare under penalty of perjury under the laws of the State of California that t Date: 06/13/2019 foregoing is true and correct. JOSE CASARES {TYPE OR PRINT NAME OF PERSON COMPLETING THIS FORM) Bo pore x Doone Lie PROOF OF SERVICE BY FIRST-GLASS MAIL-CIVIL Code of i Procedre, §5 1013, 10132 Judicial Council of California wvav.courtinfo.ca.gov POS030 {Naw January 1, 2005] {Proof of Service} IGNATURE OF PERSON COMPLETING THIS FORM) ~ Exhibit 2 Exhibit 2 10 11 12 13 14 15 16 17 18 18 20 21 22 23 24 25 26 27 28 MICHAEL MCWILLIAMS 102 RIDGE VALLEY #311 IRVINE, CA 92618 PLAINTIFF, In Pro Per SUPERIOR COURT OF CALIFORNIA COUNTY OF ORANGE Case No.: 30-2018-01016395-CU-PO-CIC MICHAEL MCWILLIAMS J Co ) PLAINTIFF MICHAEL MCWILLIAMS Plaintiff(s) ) RESPONSES TO DEFENDANT ZHEN y LIAN MCWILLIAMS REQUEST FOR vs. y PRODUCTION ZHEN LIAN MCWILLIAMS | SET NUMBER ONE Defendant(s) ) PROPOUNDING PARTY: ZHEN LIAN MCWILLIAMS RESPONDING PARTY: MICHAEL MCWILLIAMS SET NUMBER: ONE RESPONDING PARTY hereby answers PROPOUNDING PARTY’s Request for Production: RESPONSE TO REQUEST FOR PRODUCTION NUMBER 1: Please re-phrase question RESPONSE TO REQUEST FOR PRODUCTION NUMBER 2: Please re-phrase question RESPONSE TO REQUEST FOR PRODUCTION NUMBER 3: NONE 1 RESPONSES TO REQUEST FOR PRODUCTION 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 RESPONSE TO REQUEST FOR PRODUCTION NUMBER 4: Telephone calls from Zhen Lian McWilliams “Johns”... Zhen Lian McWilliams Self-Admission RESPONSE TO REQUEST FOR PRODUCTION NUMBER 35: Please re-phrase question RESPONSE TO REQUEST FOR PRODUCTION NUMBER 6: HIPAA RESPONSE TO REQUEST FOR PRODUCTION NUMBER 7: Plaintiff ONLY Contracted STD’s from STD infested Zhen Lian McWilliams RESPONSE TO REQUEST FOR PRODUCTION NUMBER 8: Defendant Zhen Lian McWilliams-Self Admission--Witnesses RESPONSE TO REQUEST FOR PRODUCTION NUMBER 9: Defendant Zhen Lian McWilliams -Self Admission--Witnesses RESPONSE TO REQUEST FOR PRODUCTION NUMBERI10: Defendant Zhen Lian McWilliams-Self Admission--Witnesses RESPONSE TO REQUEST FOR PRODUCTION NUMBER 11: Defendant Zhen Lian McWilliams-Self Admission-Witnesses 2 RESPONSES TO REQUEST FOR PRODUCTION 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 RESPONSE TO REQUEST FOR PRODUCTION NUMBER 12 The document requested are in possession of Plaintiff and will be included in this production See attached receipt NORDTROMS RACK See attached EliteSingles.com PAID MEMBERSHIP RECEIPT RESPONSE TO REQUEST FOR PRODUCTION NUMBER13: Defendant Zhen Lian McWilliams-Self Admission-Witnesses I declare under penalty of perjury under the laws of the State of California that the foregoing 7 7 2 F 4 A “ALAA ge MICHAEL MCWILLIAMS PLAINTIFF is true and correct. Dated: 011/07/2019 3 RESPONSES TO REQUEST FOR PRODUCTION Exhibit 3 Exhibit 3 Bes CASINO 11871 Carson St. Hawanan Garoens, CA 90716 562-860-5887 October 1, 2019 VIA FEDERAL EXPRESS Santiago A. Martin Law Office of Santiago A. Martin 2700 North Main Street, Suite 1040 Santa Ana, CA 92705 Re: Deposition Subpoena for Production of Business Records: Michael McWilliams vs. Zhen McWilliams; Case No. 160009631 Dear Mr. Martin: This is in response to a subpoena received on July 8, 2019 in connection with the above- referenced case. Per the direction of the counsel who served the subpoena, Thomas Pedersen, we arc sending you copies of the enclosed responsive documents. Should you have any questions, please contact the undersigned. Sincerely, 4 KEITH #4. SHARP General Counsel Hawatian Gardens Casino Hawaiian Gardens Casino 07/09/2019 13:42 MTL Cash In/Out MTL Days from 01/01/2012 to 07/09/2019 Player ID: P000070113 - BEST Play IN L.A Player Name: MICHAEL MCWILLIAMS Cash IN Cash Out All Cash In; $7,205.00 All Cash Out: $47,972.00 CTR Cash In: $0.00 CTR Cash Out: $16,200.00 Not in CTR: $7,205.00 Notin CTR: $31,772.00 Not in GTR(%): 100% Not in CTR(%): MTL Days: MTL Days: Not in GTR MTL Days: Not in CTR MTL Days: Not in CTR AVG: $1,441.00 Not in CTR AVG: $3177.20 No MTL Day Cash IN Cash Out 1 04/27/2017 0.00 3,200.00 2 08/23/2017 15.00 0.00 3 02/10/2018 60.00 0.00 4 02/20/2018 0.00 16,200.00 5 04/11/2018 4,000.00 0.00 6 05/06/2018 3,100.00 3,772.00 7 05/31/2018 0.00 3,800.00 8 08/27/2018 30.00 0.00 9 11/20/2018 0.00 1,700.00 10 12/19/2018 0.00 4,300.00 11 01/27/2019 0.00 2,704.00 12 02/06/2019 0.00 1,815.00 13 02/08/2019 0.00 2,220.00 14 02/17/2018 0.00 5,261.00 15 03/24/2019 0.00 3,000.00 Hawaiian Gardens Casino MTL Cash InfOut 1 [] CORRECTED {if checked) FAYER'S name, street address, city or town, state or province, country, Zip | 1REAls OMB No. 1545-0115 or foreign postal code, and telephone no. Hawaian Gardens Casino, inc. $ 20) £ 8 iiscettanecus 3 " iri & 11871 Carson St. #hoysities peels Hawaiian Gardens, CA 80716 $ Form 1099-MI SC 3 Other income 4 Federal income tax withheld: Copy B Phone: 562-860-8890 $ 18000.00 i$ For Recipient PAYER'S TIN RECIPIENT'S TIN 5 Fishing baat proceeds 6 Medical and health care payments 33-0691298 0 $ $ Michael Warren Mcwilliams 7761 Citadel Circle Westminster, CA 92683 RECIPIENT'S name, street address, city of (own, stale or province, country, and ZIP of foreign postal codz 7 Nonemployee compensation 3 8 Substitute payments in licu of dividends or interest $ 9 Payer made direct sales of $5,000 or more of consumer products to a buyer (recipient) for resale » i] 10 Crop insurance proceeds $ This is important tax information and is heing furnished to the IRS. If you are required to file a relurn, a negligence penalty or other sanction may be imposed on you i 11 12 this income is taxable and the IRS determines that it Account number (see instructions) FATCA filing 13 Excess golden parachute 14 Gross proceeds paid t o an has not been requirement payments attomey B6308867 reported. [] $ $ 15a Section 409A deferrals 15b Section 409A income 16 State tax withheld 17 State/Payer’s state no. 18 State income 8 eee eres snennee eed $ eens 3 $ $ $ Form 1099-MiSC (keep for your records) wwser.irs.gov/Form1099MISC Dzpartment of the Treasury - intemal Reven ue Service [1 CORRECTED (if checked) Telephone: PAYER'S name, street address, cily or lown, stale or province, country, ZIP or foreign postal cade, and telephone no, Hawaiian Gardens Casino 11871 Carson Street Hawaiian Gardens CA 20716 562-860-5887 OMB No. 1545-0115 33-0681298 PAYER'S Federal identification number RE and ZIP or foreign postal code RECIPIENT'S nama, street address, cily or town, stale or province, country, Michael Warren Mcwillians 7761 Citadel Circle Westminster CA 92683 1 Rens $ 201 7 Miscellaneous 2 Royaties income $ rom 1099-MISC 3 Otherincome {4 Federal income tax withheld $ 8500.00 |$ Copy B § Fishing boal proceeds 6 Medical and health care For Re cip fent payments $ $ 7 Nonemployee compensation | 8 Substitute payments in lieu This is important tax of dividends or inlerest information and is teing furnished to $ $ the lnlernal Revenue § Payor mada direct sales of §5,000 or more of consumer products to a buyer (recipient) for resale + 3 10 Crop insurance proceads $ Service. If you are required to file a return, @ negligence penally or other 1 12 sanction may be imposed on you if this income is taxable and the IRS 13 Excess golden parachute 14 Gross proceeds paid to an sltomey determines that it has not been Account number (sea instructions) FATCA filing payments requirement $ $ reported. 16 State tax withheld 17 State/Payer’s state no. 18 sate income 15a Section 408A daferrals 15b Section 409A inceme $ 5 Department of the Treasury - ignat Revenue Service Form 1099-MISC Hawaiian Gardens Casino 07/09/2019 14:09 ‘PLAYER ID PO00070113 : FIRST NAME MICHAEL : | MIDDLE NAME | WARREN ; er INL LAST NAME MCWILLIAMS + | BESTPayINLA PICTURE TIMESTAMP | 3 i 3 i pre i bo SR La Se Hawaiian Gardens Casino Exhibit 4 Exhibit 4 SUPERIOR COURT OF CALIFORNIA FOR THE COUNTY OF ORANGE MINUTE ORDER 11/1/2019 Judge / Commissioner: RENEE E. WILSON Dept.: H13 at 9:00 AM Clerk: C. CORONA Bailiff: A. GONZALEZ Reporter: S. GUMM 13168 Case Type: DISSOLUTION WITH CHILD Case Number: 16D009631 Case Name: MICHAEL MCWILLIAMS VS ZHEN MCWILLIAMS Appearances: MICHAEL MCWILLIAMS, PETITIONER, MOVING PARTY - PROTECTIVE ORDER, RESPONDING PARTY - PROTECTIVE ORDER JEFFREY HEATH, APPOINTED ATTORNEY THOMAS PEDERSEN, ATTORNEY FOR RESPONDENT MOTION - QUASH Filed on 8/27/2019 By RESPONDENT ZHEN LIAN MCWILLIAMS MOTION - QUASH Filed on 8/21/2019 By RESPONDENT ZHEN LIAN MCWILLIAMS ORDER TO SHOW CAUSE - CONTEMPT Filed on 5/30/2019 By RESPONDENT ZHEN LIAN MCWILLIAMS Tentative Ruling: Motion 1 - Quash Depo Subpoenas to Sub-Zero Wolf and Cover Showroom. Motion #2 Quash Depo Subpoenas to USC Credit Union, Honda, Discovery, Amex Tentative - Grant Per Responsive Declaration filed 10/21/19 RP indicated he was retracting subpoenas on all but did not include Cover Showroom. All subpoenas were defective as RP does not qualify under B&P Code 22451, All subpoenas were vague and over broad per CCP 2017.010. Sanctions are granted in sum of $600.00 as subpoenas were not withdrawn until filing of motion, In open Court at 8:54 am: Court will address the Motions first. MINUTE ORDER 11/1/2019 16D009631 Page1of2 Petitioner and Respondent's counsel present and state they have reviewed the Court's tentative. Petitioner offers oral argument. Discussion ensues. Court's tentative becomes the order of the Court. Matter trails for Court to address Contempt matter. In open Court at 9:42 am: Petitioner and his Court appointed counsel present. Respondent's counsel present as well. Court is advised Respondent is not present. Respondent's counsel requests a continuance as he needs to subpoena witnesses. Petitioner's counsel opposes the request and does not waive time. Petitioner's counsel requests the Contempt matter to be dismissed. Respondent's counsel states he is not ready to proceed with today's Contempt matter. Court orders today's Contempt matter dismissed. Court adjourns at 9:42 am. #5 MINUTE ORDER 11/1/2019 16D009631 Page2 of 2 S w N o OW 0 NN A 10 11 . 12 13 14 15 16 17 18 19 20 21 22 23 24 23 26 27 28 PROOF OF SERVICE I am over the age of 18 and not a party to this action. I am a resident of or employed in the county where the mailing occurred; my business/residence address is: 438 E Katella Ave, Ste 213, Orange, CA 92867 On November 22, 2019 I served the foregoing documents described as: REPLY TO OPPOSITION TO DEFENDANT’S MOTION TO DECLARE PLAINTIFF A VEXATIOUS LITIGANT (CCP § 391 et seq); REQUIRE SECURITY FOR PENDING LITIGATION OR DISMISS; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF THOMAS PEDERSEN; EXHIBITS to the following parties: Michael McWilliams 102 Ridge Valley #311 Irvine, CA 92618 [X] BY MAIL as follows: I am “readily familiar” with the firm’s practice of collection and processing correspondence for mailing. Under that practice it would be deposited with the U.S Postal Service on that same day with postage thereon fully prepaid at Orange, California in the ordinary course of business. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. DATED: November 22, 2019 } e Casares PROOF OF SERVICE
