Motion to Compel COLV to Respond to Request for Second Set of Documents

8/15/2019 Motion to Compel COLV to Respond to Request for Second Set of Documents

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George Sharp 3525 Del Mar Heights Road, #620

San Diego, CA 92130(310) 498-4455(619) 446-6717 fax

In Propria Persona

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF SAN DIEGO, CENTRAL DIVISION

GEORGE A. SHARP,

Plaintiff,

v.

STOCKTIPS.COM, AMERADA CORP.,LALUNA SERVICES, INC., TELUPAYINTERNATIONAL, INC., ECRYPTTECHNOLOGIES, INC., ALKAMEHOLDINGS, INC., WELL POWER, INC.,

TIGER OIL AND ENERGY, INC.,COASTAL INTEGRATED SERVICES, INC.,EMPIRE STOCK TRANSFER, INC.,QUICKSILVER STOCK TRANSFER, INC.,ROBERT BANDFIELD, AWEBERSYSTEMS, INC. ADRIAN HERMANTHOMAS, HAROLD GEWERTER andDOES 8 through 500, inclusive,

Defendants.

_____________________________________

))))

))))))))))

)))))))))

)))))

Case No. 37-2015-0008210-CU-NP-CTL

(Assigned for all purposes to Hon. TimothyTaylor )

PLAINTIFF GEORGE SHARP’S

NOTICE OF MOTION AND MOTION

TO COMPEL FURTHER RESPONSES

TO REQUESTS FOR PRODUCTION OF

DOCUMENTS, SET TWO FROM

DEFENDANT COASTAL INTEGRATED

SERVICES; MEMORANDUM OF

POINTS AND AUTHORITIES;DECLARATION OF GEORGE SHARP

IN SUPPORT THEREOF

Date: August 5, 2016Time: 1:30 p.m.Dept: C-72:


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Court for an order compelling further responses to Requests for Production, Set Two,

Pro pounded to Defendant COASTAL INTEGRATED SERVICES, INC. (hereinafter “RPDs”),Requests Nos. 2 through 16 as set forth in the separate Statement of RPDs and Responses in

Dispute. Plaintiff further moves the Court for an order that Defendant and its counsel, Robert

Huston, pay the sum of $60 as the reasonable costs incurred by Plaintiff in connection with the

filing of this motion to compel further responses.

This motion is made on the grounds that the discovery sought is relevant to the

subject matter of this action. Defendant’s refusal to respond to the discovery requests at issue

herein is without substantial justification and in bad faith. The motion is based on this notice, the

following memorandum of points and authorities and declaration of George Sharp and the

attached exhibits, the separate statements filed concurrently herewith, the papers and records on

file with the court herein, and upon such further evidence and argument as may be presented at

the time of hearing.

Dated: May 24, 2016

By. ______________________________George SharpIn Propria Persona


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MEMORANDUM OF POINTS AND AUTHORITIES

1.

INTRODUCTIONPlaintiff served a round of document discovery requests on Defendant, to which

Defendant made identical blanket objections to each request.

Upon receipt of the Defendant’s responses, Plaintiff immediately attempted to meet and

confer to resolve this issue informally. Defendant did not respond to the Meet and Confer effort.

No agreement has been reached and no supplemental responses have been provided.

Defendant’s failure to properly respond to discovery requests was done in bad faith and is

sanctionable conduct. Defendant and its counsel’s actions are flouting the discovery process

and the integrity of the judicial system in general. Defendant should be compelled to provide

further responses (and documents) and sanctioned for the necessity of this motion.

2. SUMMARY OF RELEVANT FACTS

This action arises out of Plaintiff’s Complaint for violation of Business and Professions

Code § 17529.5 based on Defendant’s participation to defraud the public through a spam email

pump and dump scheme. The Plaintiff contends that this Defendant participated in the scheme to

defraud by providing cheap stock to all of the Defendants in exchange for little or no value and

for the divesture by the Defendants at over inflated prices.

On March 25, 2016, the Plaintiff served its second set of Requests for Production. On

April 12, 2016, Defendant served its blanket objections in the form of responses to the RPDs.

Not a single document was produced. Defendant claimed to have no documents responsive to

Requests 6 and 7, but issues the same objection to Request 2 through 5 and 8 through 15; to whit:

Responding Party objects to this request on the basis that this request for

production of documents seeks the discovery of information which is beyond the


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On April 12, 2016, the Plaintiff emailed a request to Meet and Confer to Defendant’s

counsel. (Decl. Sharp ¶ 4; Exhibit “C” April 12, 2016 Request to Meet and Confer) Thecourtesy of a response was not received.

On May 23, 2016, the Plaintiff initiated a second attempt to Meet and Confer with

Defendant’s Counsel. (Decl. Sharp ¶ 6; Exhibit “D” April 12, 2016 Request to Meet and

Confer).

On May 24, 2016, Defendant’s Counsel provided a glib response to the Plaintiff’s second

Meet and Confer attempt . (Decl. Sharp ¶ 7; Exhibit “E” April 12, 2016 Request to Meet And

Confer), but did not provide any assurances that documents would be forthcoming.

Because defense counsel has failed to provide sufficient responses or to produce the

requested documents, this motion to compel further responses was necessary.

3. LEGAL DISCUSSION

Because Defendant has failed to provide sufficient responses to Plaintiff’s discovery

requests and is withholding documents, and instead provided baseless blanket objections, this

Motion should be granted.

A. Plaintiff Has a Right to Discovery from Defendant

Code of Civil Procedure section 2017.010 states, in part:

“…any party may obtain discovery regarding any matter, not privileged, that is relevant

to the subject matter involved in the pending action or to the determination of any motion made

in that action, if the matter either is itself admissible in evidence or appears reasonably calculated

to lead to the discovery of admissible evidence .” (Emphasis added.)

In Fuss v. Superior Court , the Court of Appeals stated, in part, as follows:


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otherwise could not be proved except with great difficulty; (4) to educate the parties in advance

of trial as to the real value of their claims and defenses, thereby encouraging settlement; (5) toexpedite litigation; (6) to safeguard against a surprise; (7) to prevent delay; (8) to simplify and

narrow the issues; and (9) to expedite and facilitate both preparation and trial. 273 Cal.App.2d,

807, 815-16 (1969) (citing Greyhound Corp. v. Super. Ct., 56 Cal. 2d 355, 376).

California’s discovery procedures “are designed to minimize the opportunities for

fabrication and forgetfulness, and to eliminate the need for guesswork about the other side’s

evidence, with all doubts about discoverability resolved in favor of disclosure.” Glenfed Dev.

Corp. v. Super. Ct ., 53 Cal.App.4th 1113, 1119 (1997). “The purpose of pretrial discovery is to

obtain all of the facts relative to a claim or defense.” Hernandez v. Super. Ct., 112 Cal.App.4th

285, 301 (2003). For discovery purposes, information sought is “relevant to the subject matter”

if it might reasonably assist a party in evaluating the case, preparing for trial or facilitating

settlement thereof. Stewart v. Colonial W. Agency Inc., 87 Cal.App.4th 1006 (2001).

Plaintiff’s discovery efforts have been thwarted by Defendant as a result of its bad faith

responses and refusal to provide further responses, despite Plaintiff’s meet and confer effort. As

set forth below, Defendant has failed to make a good faith effort to respond to the requests, and

good cause exists to justify an order compelling the discovery sought.

B. Defendant Has Failed to Sufficiently Respond to Plaintiff’s RPDs

The party to whom a demand for documents is directed must respond separately to each

item in the demand by one of the following: (a) a statement that the party will comply by the date

set for inspection with the particular demand for inspection; (b) a statement that the party lacks

the ability to comply with the particular demand; or (c) an objection to all or part of the demand.

Code Civ. Proc. § 2031.210(a).


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of business or sorted and labeled to correspond with the categories in the document demand. Id.

at 2031.280(a). An inability to comply “shall” state that a diligent search and reasonable inquiry

has been made in an effort to locate the item demanded, as well as the reason the party is unable

to comply (e.g., the document never existed, has been lost or stolen, was inadvertently destroyed,

or is not in the possession, custody, or control of the responding party). Id. at 2031.230. With

respect to objections, the objection must identify with particularity the specific document or

evidence to which the objection is made. Code Civ. Proc. § 2031.240(b). Objections constitute

implicit refusals to produce documents. Standon Co., Inc. v. Super. Ct ., 225 Cal.App.3d 898, 901

(1990).

With respect to Defendant’s responses to the RPDs, Defendant refused to produce

documents in response to RPD No. 2 through 5 and 8 through 16 and represented it “has no non-

privileged responsive documents” in response to RPD Nos. 6 and 7.

These responses and the refusal to produce documents are insufficient and require an

order compelling further responses and documents.

Moreover, none of Defendant’s written responses to the RPDs at issue comply with the

requirements of the Code of Civil Procedure, as discussed in more detail in the concurrently filed

Statement. Thus, further written responses withdrawing the objection and agreeing to comply

with the RPDs must be provided.

C. The Imposition of Sanctions against Defendant and Its Counsel Is

Warranted

Code of Civil Procedure section 2023.010 defines discovery misuse as follows:

Misuses of the discovery processes include, but are not limited to the


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bad faith actions, sanctions in the amount of $60 should be imposed against Defendant and its

counsel.

4. CONCLUSION

For the foregoing reasons, Plaintiff George Sharp respectfully requests that the Court

order Defendant Coastal Integrated Services, Inc. to provide complete substantive responses to

the RPDs 2 through 15 at issue in this Motion. Plaintiff further requests that the Court impose

sanctions against Defendant and its counsel, Robert Huston, in the amount of $60.

Dated: May 24, 2016

By. ______________________________George SharpIn Propria Persona


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PROOF OF SERVICE - CCP. 1013A, CG 002015.5

STATE OF CALIFORNIA, COUNTY OF SAN DIEGO

I, the undersigned, reside in the County of San Diego, State of California. I am over the

age of eighteen (18) years and not a party to the within action. My business address is 3525 Del

Mar Heights Road, Suite 620, San Diego, California 92130. My email address is

[email protected].

On May 24, 2016, at approximately 5:30 p.m., I served true copies of the foregoing

documents described as PLAINTIFF GEORGE SHARP’S NOTICE OF MOTION AND

MOTION TO COMPEL FURTHER RESPONSES TO REQUESTS FOR PRODUCTION

OF DOCUMENTS, SET TWO FROM DEFENDANT COASTAL INTEGRATED

SERVICES; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF

GEORGE SHARP IN SUPPORT THEREOF on the interested parties in this action,

addressed as follows:

Kenneth Stone

THE STONE LAW GROUP

[email protected]

Robert Huston

[email protected]

BY EMAIL: The documents were scanned and uploaded to the One Legal internetwebsite with the instruction to forward the documents to the interested parties. I am "readily

familiar" with the practice of uploading to One Legal for email forwarding.

I certify under penalty of perjury that the foregoing is true and correct and that this


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George Sharp3525 Del Mar Heights Road, #620San Diego, CA 92130

(310) 498-4455(619) 446-6717 fax

In Propria Persona

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF SAN DIEGO, CENTRAL DIVISION

GEORGE SHARP,

Plaintiff,

v.

STOCKTIPS.COM, AMERADA CORP.,

LALUNA SERVICES, INC., TELUPAY

INTERNATIONAL, INC., ECRYPT

TECHNOLOGIES, INC., ALKAMEHOLDINGS, INC., WELL POWER, INC.,

COASTAL INTEGRATED SERVICES, INC.,

and DOES 1 through 500, inclusive,

Defendants.

___________________________________

))))))

)))))))))))))))

Case No.: 37-2015-00008210-CU-NP-CTL

(Assigned for all purposes to Hon. TimothyTaylor )

REQUEST FOR PRODUCTION OF

DOCUMENTS BY DEFENDANTCOASTAL INTEGRATED SERVICES,

INC., SET TWO

Trial Date: none

PROPOUNDING PARTY: Plaintiff George Sharp

RESPONDING PARTY: Defendant Coastal Integrated Services, Inc.

SET NUMBER: Two


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produce the following documents for copying and inspection at 3525 Del Mar Heights Road,

Suite 620, at 10:00 a.m. on April 29, 2016

DEFINITIONS

1. “YOU” or “YOUR” means Defendant COASTAL INTEGRATED

SERVICES, INC., its employees, agents, attorneys, accountants, transfer agents, officers,

directors, affiliates, successors, assigns, partners, representatives, any person or entity acting on

its behalf, at his request or with his authorization.

2. “PERSON” or “PERSONS” mean any natural person, association,

partnership, corporation, organization, business, trust, joint venture, receiver, estate, syndicate or

any other entity or combination acting as a unit or acting as a form of legal entity, including the

parties to this suit and their members, officers, directors, partners, agents, contractors,

subcontractors, employees, representatives and affiliates.

5. “REGARDING,” “RELATING TO” or “RELATE TO” means

mentioning, discussing, summarizing, describing, regarding, referring to, relating to, evidencing,

depicting, embodying, constituting or reporting.

6. “COMMUNICATION” means any meeting, conversation, discussion,

correspondence, message or other occurrence where thoughts, opinions or data are transmitted

between two or more PERSONS.

7. The terms “DOCUMENT” and “DOCUMENTS” are used in their

broadest possible sense and mean, without limitation, any kind of written, printed, typed,

photostatic, photographed, recorded or otherwise reproduced communication or representation,

whether comprised of letters, words, numbers, pictures, sounds, syllables or any combination

thereof, regardless of whether the same is an original, a copy, a reproduction, a facsimile or draft,

and regardless of the source or author thereof. This definition includes copies or duplicates of


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working papers, summaries, statistical statements, financial statements or work papers, accounts,

invoices, receipts, payment records, analytical records, reports and/or summaries of

investigations, trade letters, press releases, comparisons, books, calendars, diaries, articles,

magazines, newspapers, booklets, brochures, pamphlets, circulars, bulletins, notices, drawings,

diagrams, instructions, notes or minutes of meetings or other communications of any type,

including inter- and intra-office communications, faxed materials (including fax cover sheets),

questionnaires, surveys, charts, graphs, photographs, phonograph recordings, electronic mail,

film, tapes, disks, diskettes, data cells, tape back-ups, drums, print-outs, all other data

compilations from which information can be obtained (translated, if necessary, by YOU into

usable form), and any preliminary versions, drafts or revisions of any of the foregoing, whether

used or not, and any writings as defined by Rule 1001 of the Federal Rules of Evidence.

8. If any DOCUMENT is withheld under a claim of privilege, to assist theCourt and the parties hereto in determining the validity of the claim of privilege, you are asked to

furnish a list (“Privilege Log”) signed by the person supervising the response to this request for

production of DOCUMENTS, which identifies each DOCUMENT for which the privilege is

claimed, together with the following information regarding said document:

a) the date of the DOCUMENT;

b) the identity of the PERSON who signed said DOCUMENT or on whose

behalf it was sent or issued, including said PERSON’S last known

business and home addresses and telephone numbers;

c) the identity of the PERSON to whom said DOCUMENT was directed,

including said PERSON’S last known business and home addresses and

telephone numbers;

d) the nature and substance of said DOCUMENT set forth with sufficient


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f) the number of pages in the DOCUMENT;

g) the basis upon which any privilege is claimed;

h) whether or not any non-privileged matter is included within the document;

and

i) the number of the document request to which such DOCUMENT relates

or corresponds.

DOCUMENT REQUESTS

REQUEST FOR PRODUCTION NO. 2

All documents relating to the formation of the corporation currently known as Coastal

Integrated Services, Inc, its predecessors, affiliates and subsidiaries.

REQUEST FOR PRODUCTION NO. 3All documents relating to the assignments and resignations of any officers and directors

of Coastal Integrated Services, Inc. or its predecessor company(s) since May 2, 2009.


All documents relating to general meetings of the shareholders of Coastal Integrated

Services, Inc. and its predecessors, including minutes of those meetings, since May 2, 2009.


All minutes of meetings of the directors of Coastal Integrated Services, Inc. and its

predecessors since May 2, 2009.


All written communications, including letters, emails and contracts regarding investor

relations programs on behalf of Coastal Integrated Services, Inc.



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All documentation referencing the transfer of ownership of common stock, preferred

stock, stock options, and warrants in Coastal Integrated Services, Inc.


All documentation referencing the issuance of common stock, preferred stock, stock

options, and warrants in Coastal Integrated Services, Inc.


All written communications, including letters, emails and contracts between Coastal

Integrated Services, Inc. or its predecessors and its transfer agents.


All documentation referring to contracts or letters of intent or business agreements

between Coastal Integrated Services, Inc., or its predecessors and any other entity.REQUEST FOR PRODUCTION NO. 12

All press releases issued on behalf of Coastal Integrated Services, Inc and its

predecessors.


All SEC filings on behalf of Coastal Integrated Services, Inc and its predecessors.


All disclosures and/or filings to the Financial Industry Regulatory Authority (FINRA),

OTC Markets or other market facilitators or regulators.


All documentation referencing financing of Coastal Integrated Services, Inc., or its

predecessors, including but not limited to equity financing, notes and debentures (convertible or

not).


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Dated: March 25, 2016

By. ______________________________George Sharp


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PROOF OF SERVICE - CCP. 1013A, CG 002015.5

STATE OF CALIFORNIA, COUNTY OF SAN DIEGO

I, the undersigned, reside in the County of San Diego, State of California. I am over theage of eighteen (18) years and not a party to the within action. My business address is 3525 Del

Mar Heights Road, Suite 620, San Diego, California 92130. My email address is

[email protected].

On March 25, 2016, at approximately 8:45 a.m., I served true copies of the foregoing

documents described as REQUEST FOR PRODUCTION OF DOCUMENTS BY

DEFENDANT COASTAL INTEGRATED SERVICES, INC., SET TWO on the interested

parties in this action, addressed as follows:

Kenneth Stone

THE STONE LAW GROUP

[email protected]

Robert Huston

[email protected]

BY EMAIL: The documents were scanned and uploaded to the One Legal internet

website with the instruction to forward the documents to the interested parties. I am "readily

familiar" with the practice of uploading to One Legal for email forwarding.

I certify under penalty of perjury that the foregoing is true and correct and that this

declaration was executed March 25, 2016.


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These responses are made solely for the purpose of this action. Each response is

subject to all appropriate objections, including competency, relevancy, materiality, propriety

and admissibility, which would require the exclusion of any response set forth herein if the

question were asked of, or any response were made by, a witness present and testifying

in court. All such objections are reserved and may be interposed at the time of trial.

Responding Party has not completed its investigation of the facts relating to this

action and has not yet completed its discovery in this action. Responding Party has not

yet consulted all intended expert witnesses and has not yet completed its preparation for

trial. Consequently, the following responses are given without prejudice to the plaintiff's

right to produce, at time of trial, subsequently discovered evidence relating to the proof of

presently known material facts and to produce all evidence whenever discovered, relating

to the proof of subsequently discovered material facts.

This preliminary statement is, by reference hereto, incorporated into each of the

responses herein.

Response to Request for Production No. 2:


production of documents seeks the discovery of information which is beyond the scope and

issues of this lawsuit in that the documents sought are unrelated to the transmission of

unsolicited commercial emails, and therefore irrelevant, immaterial, and not reasonably

calculated to lead to the discovery of admissible evidence.

Responding Party further objects to this request on the basis that this request for

production of documents is unduly burdensome to the extent that it seeks documents that

are publicly available on the Internet. Responding to this request would be oppressive,


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calculated to lead to the discovery of admissible evidence.




unduly burdensome, and unnecessarily expensive, and the burden of responding to such

requests is substantially the same or less for the Plaintiff as for the Responding Party.

Responding Party declines the request.






calculated to lead to the discovery of admissible evidence. Responding Party declines the

request.






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Responding Party has made a diligent search and a reasonable inquiry as to the

whereabouts of the documents, but is unable to comply with the Request because

Responding Party does not believe that the documents ever existed, and are not in its

possession, custody or control.


Responding Party has made a diligent search and a reasonable inquiry as to the

whereabouts of the documents, but is unable to comply with the Request because

Responding Party does not believe that the documents ever existed, and are not in its

possession, custody or control.







request.








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request.




unduly burdensome, and unnecessarily expensive, and the burden of responding to such

requests is substantially the same or less for the Plaintiff as for the Responding Party.

Responding Party declines the request.







request.

Responding Party further objects to this request on the basis that it is overly broad

and thus places an undue burden on this Defendant to respond.

To the extent that this request requires production of Responding Party’s filings with

OTC Markets or the Securities and Exchange Commission, Responding Party further

objects to this request on the basis that this request for production of documents is unduly

burdensome in that it seeks documents that are publicly available on the Internet.

Responding to this request would be oppressive, unduly burdensome, and unnecessarily

expensive, and the burden of responding to such requests is substantially the same or less


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VERIFICATION BY PARTY(C.C.P. §2015.5)

STATE OF CALIFORNIA ) )

COUNTY OF RIVERSIDE )

I, John Newman am the president of Coastal Integrated Services, Inc., a defendantin the above-entitled action. I have read the foregoing and know the contents thereof, and

I certify that the same is true of my own knowledge, except as to those matters which aretherein stated upon my information or belief, and as to those matters which I believe it tobe true.

I declare, under penalty of perjury, under the laws of the State of California, that theforegoing is true and correct.

Executed this 12th day of April, 2016, at Thousand Palms, California.

_____________________________________ JOHN NEWMAN


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1

George Sharp

From: George Sharp

Sent: Tuesday, April 12, 2016 1:11 !

To: "#o$er% &us%o'"Subject: #(: )*+ #espo'se %o #eues% or roduc%io' o /ocume'%s, Se% 2

Mr. Huston:

This email shall be construed as an attempt to meet and confer on your response to my Request for Production, Set Two. Your responses contain blanet

ob!ections intended to obfuscate documents and deny my ri"ht to disco#ery. You ha#e not produced a sin"le document.

$urthermore, you continue to be la% in your response to the first set of Requests for Production and ha#e not e#en pro#ided the courtesy of my pre#ious Meet

and &onfer emails.

This is my final attempt to obtain the responsi#e documents before ' file a Motion to &ompel and see sanctions.

Respectfully,

(eor"e Sharp)*+-/--00

From: Robert Huston [mailto:[email protected]]Sent: Tuesday, April 12, 21! 12:"2 #$To: %eor&e 'harp( )enneth 'tone, *s+.Subject: -/ Response to Re+uest 0or #roduction o0 ocuments, 'et 2

Attached.

Robert J. Huston III

Attorney at Law

"We must reject the idea that every time that a law is broken society is guilty rather than the lawbreaker. It is time to restore the American precept

that each individual is accountable for his actions."

Ronald Reagan


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GEORGE A. SHARP

3525 Del Mar Heights Road, #620

San Diego, CA 92130310-498-4455

Fax: 619-446-6717Email: [email protected]

Re: Sharp v StockTips - SD Sup Court Case. No. 37-2015-00008210

ATTTEMPT TO MEET AND CONFER

Mr. Huston:

This is email is written in a second attempt to Meet and Confer with respect to your

blanket objections to the Request for Production of Documents, Set Two.

It appears that your client wishes to assert boilerplate objections in violation of the spiritof the Discovery Act. Indeed, one court held such boilerplate objections sanctionable.

Korea Data Systems Co. v. Superior Court (Aamazing Technologies Corp.), 51 Cal. App.4th 1513, 1516 (1997).

With respect to your repeated objections based on “scope and issues of lawsuit”, I refer

you to Code of Civil Procedure § 2017(a) [CCP § 2017.010] which clearly states: “any

party may obtain discovery regarding any matter, not privileged, that is relevant to thesubject matter involved in the pending action or to the determination of any motion made

in that action . . .”

Pursuant to Code of Civil Procedure § 2017.010,

“Unless otherwise limited by order of the court in accordance with this title, any party

may obtain discovery regarding any matter, not privileged, that is relevant to the subjectmatter involved in the pending action or to the determination of any motion made in that

action, if the matter either is itself admissible in evidence or appears reasonably

calculated to lead to the discovery of admissible evidence. . . .” [Emphasis Added].

Discovery is relevant to the subject matter of the litigation if it might reasonably assist a

party in evaluating the case, preparing for trial, or facilitating settlement thereof.

Gonzalez v. Sup. Ct. (1995) 33 Cal.App.4th 1599, 1611; Stewart v. Colonial WesternAgency, Inc. (2001) 87 Cal.App.4th 1006, 1013. Further, the relevancy to the subject


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expensive and burdensome did not justify a refusal to responds to the discovery. See

Alpine Mut. Water Co. v. Superior Court of Ventura County (1968) 259 Cal App 2d 45.

Further, an objection on the grounds of burden was not valid unless the burden results ininjustice. See Pantzalas v. Superior Court of Los Angeles County (1969) 272 Cal App 2d

499.

This is my final attempt to get a commitment from you on providing me with complete

and appropriate responses to my document requests. If I do not hear from you by the end

of business tomorrow with assurances that documents are forthcoming, I will file a

Motion to Compel and seek sanctions.

Respectfully,

George A. Sharp310-498-4455


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1

George Sharp

From: Robert Huston

Sent: Tuesday, May 24, 2016 2:0 !M

To: "eor#e $har%Cc: &enneth $tone

Subject: Re: $har% ' $toc(T)%s * +our -)ent: oasta- nte#rated $er')ces, nc. M//T 3/R TT/M!T 5M/R T73

Mr. Sharp:

Thank you for the recitation of hornbook California discovery law. Given the state of the pleadings when my client's discovery responses were

prepared (my client's name not mentioned and no specific facts alleged re my client's purported conduct) the responses were entirely appropriate.Now that you have at long last amended your pleading to directly name my client and to allege a small quantum of fact concerning its alleged

statutory violations, I will review the previous responses in that light and will give you a written conclusion by Monday, which may or may not

include some modified responses.

Robert J. Huston III

Attorney at Law

"We must reject the idea that every time that a law is broken society is guilty rather than the lawbreaker. It is time to restore the American preceptthat each individual is accountable for his actions."

Ronald Reagan

On Monday, May 23, 2016 3:04 PM, George Sharp wrote:

Please see attached