05.31.12 motion to compel rfd (set two)

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RANDALLA.MILLER (BarNo. 116036)
1 AUSTA WAKILY (Bar No. 257424)
MILLERLLP
2 515 South Flower Street, Suite 2150
Los Angeles, CA 90071-2201
3 Telephone: 800.720.2126
Facsimile: 888.749.5812
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Attorneys for KNAPP, PETERSEN & CLARKE,
5 STEPHEN RAY GARCIA, STEPHEN M. HARRIS
and ANDRE JARDINI
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SUPERIOR COURT OF CALIFORNIA
COUNTY OF LOS ANGELES
STEPHEN M. GAGGERO; an individual; CASE NO.: BC286925
PACIFIC COAST MANAGEMENT, INC., a
Corporation; GINGERBREAD COURT LP, a' NOTICE OF MOTION AND MOTION TO
Limited Partnership; 511 OFW, LP a Limited COMPEL POST .JUDGMENT REQUEST
Partnership; MALIBU BROAD BEACH LP, a PRODUCTION OF DOCUMENTS (SET
Limited Partnership; MARINA GLENCOE TWO); MEMORANDUM OF POINTS AND
LP, a Limited Partnership; BLU HOUSE LLC, AUTHORITIES IN SUPPORT OF MOTION;
a Limited Liability Company; BOARDWALK DECLARATION OF AVSTA WAKILY
SUNSET LLC, a Limited Liability Company; -.
TRUSTEE of GIGANIN TRUST, JOSEPH
PRASKE; TRUSTEE of ARENZANO [SEPARATE STATEMENT FILED
TRUST, JOSEPH PRASKE; and TRUSTEE of CONCURRENTLY WITH THIS MOTION]
AQUASANTE FOUNDATION, JOSEPH
PRASKE,
Plaintiffs and Judgment Debtors,
v.
KNAPP, PETERSEN & CLARKE, STEPHEN
RAY GARCIA, STEPHEN M. HARRIS and
ANDRE JARDINI,
Defendants and Judgment Creditors.
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Date:
Time:.
Dept.:
July 20, 2012
1:30 P.M.
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NOTICE OF MOTION AND MOTION TO COMPEL PRODUCTION OF DOCUMENTS

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1 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
2 Please take notice that on July 20, 2012 at 1:30 a.m. at 111 North Hill Street, Los
3 Angeles, California 90012 or as soon thereafter as the matter may be heard, Defendants and
4 Judgment Creditors Knapp, Petersen and Clarke, Stephen Ray Garcia, Stephen Harris, and Andre
5 Jardini (KPC) will move this Court to compel Judgment Debtor, Stephen Gaggero to produce
6 documents in response to KPC's Request for Production of Documents (Set Two). This motion is
7 made pursuant to Code of Civil Procedure Sections 2023.010 and 2031.010, et seq. on the
8 following grounds:
9 1. KPC is entitled to the documents requested in Request for Production of
10 Documents (Set Two). Each request is designed to elicit information that will assist KPC in
11 enforcing their judgment. Mr. Gaggero has failed to provide a proper basis for withholding the
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documents and has failed to substantial his claims ofprivilege or objections.
2. Mr. Gaggero, aided by his attorney, David Chatfield, has abused the discovery
process by making, without substantial justification, unmeritorious objection and evasive
responses to discovery. Mr. Gaggero and Mr. Chatfield's objections were solely to delay and
obstruct KPC's post-judgment discovery. KPC therefore requests sanctions in the amount of
17 $5,000 and an award of attorney fees in bringing this motion in the amount of $10,840 jointly
18 against Mr. Gaggero and Mr. Chatfield.
19 This motion is based upon this notice of motion and motion, the attached memorandum of
20 points and authorities, the accompanying Declaration of Austa Wakily, and, all pleadings and
21 papers on file in this action, and such additional facts and argument as may be presented at or
22 before the time ofthe hearing.
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NOTICE OF MOTION AND MOTION TO COMPEL PRODUCTION OF DOCUMENTS

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Dated: May 31, 2012

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MILLERLLP
BY:~fMaW~AUSTA WAKILY, ESQ.
Attorneys for Defendants, KNAPP, PETERSEN &
CLARKE, STEPHEN RAY GARCIA, STEPHEN M.
HARRIS and ANDRE JARDINI
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NOTICE OF MOTION AND MOTION TO COMPEL PRODUCTION OF DOCUJ:v1ENTS

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1 I. INTRODUCTION
2 Judgment Debtor, Stephen Gaggero, a wealthy real estate developer, implemented a
3 complex estate plan in 1997, as part of an asset protection scheme to cheat his creditors. The
4 estate plan involved transferring all of his personal wealth to multiple corporations and
5 partnerships that were in turn owned by one of his trusts and/or foundation. Immediately after
6 implementing the estate plan, Mr. Gaggero's estate planning attorney, and trustee of his trusts,
7 Joseph Praske, appointed him as the "asset manager" of the trusts and foundation. As the asset
8 manager Mr. Gaggero retained complete control of all his property, including decisions relating to
9 refinancing, tax, insurance, buying, selling, improving, and designing some ultimate disposition.
10 Additionally, Mr. Gaggero continues to reap the fmancial benefit from the assets in the estate plan
11 through his personal tax returns. Despite, Mr. Gaggero's substantial wealth, he has refused to pay
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one penny towards the judgment.
Mr. Gaggero's present conduct is entirely consistent with his well-documented abuse of
the litigation and discovery process. The trial court in the underlying lawsuit found that:
"The evidence clearly and unequivocally supports the conclusion that although there was
no legal justification whatsoever for refusing to pay the judgment in full, Mr. Gaggero
never had any intention to payoff that obligation 100 cents on the dollar. Rather, his
absolutely single-minded focus was on delay as a tactic to force the VNBC judgment
creditors to accept a deeply discounted payoff. Every strategy devised or advocated by Mr.
Gaggero with respect to the VNBC judgrnentcreejitors w~s designed tQ make ilso difficult
and so expensive to continue the fight that they would capitulate.... (fn: In fact, it appears
this same strategy worked with respect to other judgment creditors" '
21 Using the same estate plan as a shield, Mr. Gaggero obstinately refuses to respond to post-
22 judgment discovery asserting claims of irrelevance, privilege, and invasion of privacy rights on
23 behalfofhis corporations, trusts, and partnerships. Mr. Gaggefo has refusedto produce documents
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24 relating to the implementation of his estate plan arguing the transfers are irrelevant to KPC's
25 enforcement efforts. In fact, according to Mr. Gaggero, KPC is only entitled to information about
26 his finances after the entry ofjudgment and in some instances only-to his current assets.Mr.
27 Gaggero maintains that after giving away $35,000,000 worth of assets as part ofthe estate plan he
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MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO COMPEL POST
JUDGMENT REQUEST FOR PRODUCTION OF DOCUMENTS

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1 is now destitute. KPC has made substantial efforts in attempting to resolve the present discovery
2 dispute without the Court's intervention, including substantially limiting and clarifying the
3 requested documents. Mr. Gaggero simply refuses to cooperate.
4 Remarkably, while claiming that is he is destitute in response to KPC's post-judgment
5 discovery, Mr. Gaggero, in his personal capacity, is presently litigating a third legal malpractice
6 lawsuit against KPC. In this pending lawsuit Mr. Gaggero claims that he lost the ability to
7 purchase three ocean front properties in Santa Monica exceeding $2,000,000.00.1
KPC,
8 respectfully requests that this Court compel Mr. Gaggero to produce documents requested in the
9 Requests for Production of Documents (Set Two). Additionally, KPC seeks an award of attorney
10 fees and costs they incurred in bringing this motion in the amount of $10,840.00. Finally, KPC
11 requests sanctions against Mr. Gaggero's attorney in the amount of $5,000 for his collusion in Mr.
12 Gaggero's efforts to defraud his judgment creditors and to commit a fraud on the courts.
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PROCEDURAL AND FACTUAL BACKGROUND
A. PROCEDURAL BACKGROUND
KPC filed the present Request for Production of Documents (Set Two) on January 31,
17 2012 seeking 38 categories of documents pertaining to Mr. Gaggero's estate plan, business,
18 entities, and general fmances. See Declaration of Austa Wakily (Decl. AW ~ 3, Exh. B). Mr.
19 Gaggero's responses were due on March 6,2012 . (ld. at ~ 3). On March 1,2012, Mr. Gaggero's
20 attorney, David Chatfield, requested a 30 day extension to respond citing to Mr. Gaggero's travel
21 schedule and other lawsuits as a basis for the request. (Id at ~ 4, Exh. C). As a matter of
22 professional courtesy Mr. Gaggero's deadline to respond was extended to March 20, 2012. (ld).
23 Mr. Gaggero served responses to KPC's Request for Production of Documents (Set Two) on
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25 1 KPC, pursuant to California Evidence Code Sections 452(d) and (h), respectfully requests that
this Court take judicial notice of the records and pleading filed in the present case, including the
26 Motion to Amend the Judgment to Add AdditioilalJudgrri~mt Debtors, and Mr. Gaggero's pending
lawsuits in Gaggero v Knapp, Petersen & Clarke, et aI, Los Angeles County Superior Court (Case
27 ND. BC286924) and Bunge v. 511 OF. W L.P., et aI, Los Angeles County Superior Court, (Case
No. SC100361).
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MOTION TO COMPEL POST TIJDGMENT REQUEST FOR PRODUCTION OF DOCUMENTS

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1 March 20, 2012. (Id., at ~ 5, Exh. D ). The responses included general boilerplate objections
2 stating in part "[r]equests for documents relating to assets transferred, sold or liquidated over a
3 decade are clearly irrelevant to his judgment enforcement and will not be produced by plaintiff'
4 among numerous other boilerplate and frivolous responses. (Id). Mr. Gaggero did not produce a
5 privilege log or any documents. (Id). KPC, through counsel, responded to Mr. Gaggero's
6 responses on April 2, 2012. (Id. ~ 6, Exh. E). After delays by Mr. Chatfield, the parties met and
7 conferred on April 19, 2012. (Id. ~~ 7-9, Exh. F). Mr. Chatfield agreed to (1) provide
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supplemental responses removing all boilerplate andlor or inapplicable objections, (2) provide a
"privilege log" for documents withheld pursuant to a claim of privilege, and (3) produce all
documents that are responsive to the requests that are not privileged. (Id. ~ 9, Exh. G).The
deadline to provide supplemental responses was April 30, 2012. (Id). Mr. Chatfield did not
produce any documents or a privilege log, serving only supplemental responses with baseless
objections. (Id. ~ 10, Exh. H). Mr. Chatfield did not respond to inquiries relating to his intention to
produce a privilege log or documents as he agreed during the meet and confer. (Id. ~ 11, Exh. 1).
KPC on May 11, 2012 afforded Mr. Gaggero another opportunity to resolve the discovery
disputes informally. (Id. ~ 11, Exh. J). Specifically, KPC, through counsel, sent Mr. Chatfield a 22
page letter stating the relevance of each documents requested, clarifying the scope of each request,
and providing case law and authority supporting each request. (Id). After two extensions Mr.
Gaggero was required to produce responsive documents and a privilege log no later than May 24,
2012. (Id.~. 14-15, Exh. K). Mr. Gaggero again refused. Rather, on May 24,2012 at 9:59 p.m.,
Mr. Chatfield notified KPC that a motion for protective order was filed relating to the requests.
(Id. ~ 16, Exh. L). The proposed protective order sought, among other things, to preclude KPC
from using evidence obtained in the present post-judgment collection efforts in their defense ofthe
pending legal lllaipractice lawsuit asserted against thc:In by Mr.. Gaggero. (lcl). In sum, Mr.
Gaggero is seeking the Court's aid to allow him to testify about his vast wealth in pursuing a
lawsuit while asserting that he is penniless in response to post-judgment discovery. (Id). KPC after
further delay tactics was forced to bring this motion. (Id. ~~ 17-18, Exh. M).
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MOTION TO COMPEL POST JUDGMENT REQUEST FOR PRODUCTION OF DOCUMENTS

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1 B. FACTUAL BACKGROUND
2 Mr. Gaggero created an estate plan in or about 1997. (Id. ~ 20, Exh. N). As part of the
3 estate plan Mr. Gaggero transferred approximately $35,000,000 into various entities, including
4 limited partnerships and limited liability companies. (Id). At the time of the transfer Mr. Gaggero
5 was sole the owner of all the entities into which he transferred his assets. (Id). He subsequently
6 transferred his ownership interests in the entities into one of two trusts or a foundation. (Id). Mr.
7 Gaggero continued to retain control over all assets that he transferred as an "asset manager" for the
8 properties and the trusts and foundation. (Id). Based on Mr. Gaggero's and Mr. Praske's
9 testimony during the Gaggero v. Yura trial, Mr. Gaggero's transfer of his assets into his various
10 entities and subsequently into one of his trusts was nothing more than an attempt to shield his
11 assets from creditors. (Id). Mr. Gaggero is the equitable owner of all assets that are a part of his
12 estate plan and KPC as the judgment creditors are entitled to all documents relating to his estate.
13 KPC, on April 10, 2012 filed a Motion to Amend the Judgment to add Mr. Gaggero's
14 trusts, foundation, and business entities as his alter egos. The Motion was granted on May 29,
15 2012. (Id). The amended judgment precludes Mr. Gaggero's further baseless objections on·
16 grounds of irrelevance and privacy, Mr. Gaggero's continued refusal to produce documents will be
17 clearly in bad faith and warrants sanctions.
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19 III. DISCUSSION
20 A. LEGAL STANDARD
21 Post-judgment discovery is accorded the widest scope for inquiry concerning property and
22 business affairs ofthe debtor; the object of the proceedings being to compel the judgment debtor
23 to give information concerning his property. "Public policy does not support a judgment debtor's
24 attempt to be fess than candid about his assets and- ability to pay the-judgment especially when a
25 defmite legislative policy has established a procedure for aiding judgment creditors' collection of
26 their judgments." Youngv. Keele (1987) 188 Cal.App.3d 1090, 1093.
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Here, the critical timeframe in ascertaining Mr. Gaggero's assets is approximately 15 years
ago when he implemented the estate plan. (Id. ~~ 13, 20, Exh. J, N). Mr. Gaggero seeks to curtail
the scope ofdiscovery to assets in his personal name after the entry ofjudgment and in some cases
to his current assets. (rd. ~~ 9-10, G, H). This is plainly wrong and contrary to case law. Troy v.
Superior Court (1986) 186 Cal.App.3d 1006, 1114 Gudgment debtor required to answer questions
relating to the transfer of any assets within the last 10 years). KPC is entitled to documents
relating to Mr. Gaggero's estate plan implemented over 15 years ago.
Mr. Gaggero has also objected to documents relating to his business entities and his
employment asserting a myriad of boilerplate and improper objections. (DecL AW ~ 10, Exh. H).
Case law is clear that KPC is entitled to information relating to Mr. Gaggero'sbusiness affairs.
Troy, supra 186 Cal.App.3d at 1114 citing Martin-Trigona v. Gouletas (7th Cir. 1980) 634 F.2d
354, 360 Gudgment debtor is obligated to answer questions relating to partners, co-shareholders,
co-officers and co-directors, and the contents of a will could reveal the existence and location of
assets owned by the judgment debtor). Additionally, documents relating to a judgment debtor's
employment records for the preceding five years are relevant and proper inquiry for post-judgment
discovery. Id. Mr. Gaggero's continued objections and refusal to provide these documents on
grounds of Constitutional right to privacy, third party privacy, or irrelevance are clearly be in bad
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B. KPC'S REQUESTS SEEK DOCUMENTS THAT WILL AID IN THE
ENFORCEMENT OF THEIR JUDGMENT
Estate Plan: Requests 1-6, 15 seek documents relating to the Arenzano Trust, Giganin
Trust, and Aqua Sante Foundation and all entities or assets within the estate plan. Mr. Gaggero
testified that he implemented an estate plan 15 years ago which is comprised of the two trusts,
foundation, and multiple business entities. Mr. Gaggero is the trustor of these trusts and the
26 manager ofthe trusts,foundation, and assets within the estate plan. (Decl. AW ~·13, Exh. J).
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Trusts and Foundations Generally: Requests 7-10 seek documents relating to all trusts
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MOTION TO CO:tv1PEL POST JUDGMENT REQUEST FOR PRODUCTION OF DOCUMENTS

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1 "estate plan." An example is the Terra Mar trust associated with Mr. Gaggero which has been
2 identified in the Bunge v. 511 G.F. W L.P., et aI, (2008) Los Angeles County Superior Court,(Case
3 No. SCI00361). (Decl. AW ~ 13, Exh. J).
4 General Finances: Requests 11-13, 25, 37 seek documents relating to Mr. Gaggero's
5 ability to live a lavish lifestyle, including vacationing overseas, living on a 1,500 acre ranch, and
6 spending hundreds ofthousands of dollars pursuing lawsuits, while claiming he is destitute. These
7 requests seek information concerning Mr. Gaggero's sources of income, financial benefits, right or
8 access to payments of any kind. (Id. ~ 13, Exh. J).
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Assets: Requests 14, 20, 28, 30, and 36 seeks documents designed to elicit information
about Mr. Gaggero's current assets, millions of dollars he transferred to third parties, and
information about his ownership interest in the Canada Larga ranch. These documents will aid
KPC in identifying the present legal title ofthe properties as well as ascertaining the consideration
Mr. Gaggero received as part of the transfer which can be used to satisfy the judgment. (Id. ~ 13,
Exh.J).
Post-Judgment Discovery: Request 16 seeks documents relating to attempts of other
judgment creditors in enforcing their judgment against Mr. Gaggero. KPC is clearly entitled to all
documents relating to Mr. Gaggero's involvement in post-judgment discovery. (Id. ~ 13, Exh. J).
Business Entities: Requests 18, 33-34 seek documents relating to any entity, broadly
defined as a corporation, limited liability company, limited liability partnership, general
partnership, trusts, foundation, or other partnership or association in which Mr. Gaggero is an
officer or member in his personal capacity. The requests also seek information relating to any
partr1ership in which Pacific Coast Management or Avalon Corporation is the general partner. (Id.
~ 13, Exh. J).
C. MR. GAGGERO HAS IGNORED IDS OBLIGATION TO COMPLY WITH
POST-DISCOVERY
Mr. Gaggero in response to requests, 1-5, 7-10, 15, asserts that responsive documents are
"helieved to be" in:MI. Praske's possession or control. (Id. ~, 10-11, Exh. H). First, Mr. Gaggero,
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1 pursuant to the Code of Civil Procedure Section 2031.230, must "affirm that a diligent search and
2 a reasonable inquiry has been made in an effort to comply with that demand." (Decl. AW ~~ 6,
3 9,13, Exh. E, G, J). To the extent Mr. Gaggero claims that he is unable to comply, he must state
4 "whether the inability to comply is because the particular item or category has never existed, has
5 been destroyed, has been lost, misplaced or stolen, or has never been, or is no longer, in the
6 possession, custody or control ofthe responding party. (ld). The statement shall set forth the name
7 and address of any natural person or organization known or believed by that party to have
8 possession, custody or control ofthat item or category of item." (Id). Second, Mr. Gaggero must at
9 a minimum request the documents relating to his estate plan from his estate planning attorney,
10 Joseph Praske, who has an ethical obligation comply with his client's request. Mr. Gaggero did
11 not comply with the requests despite the noticed provided by KPC in the meet and confer
12 correspondence to Mr. Chatfield. (Id). Finally, Mr. Praske in Bunge v. 511 OF. W L.P has filed a .
13 motion for protective order relating to Mr. Gaggero's trust documents. Mr. Gaggero is actively
14 involved in that lawsuit as it relates to his business entities. Clearly Mr. Gaggero is fully aware
15 whether Mr. Praske has possession of the trust documents, but is intentionally refusing to comply
16 with his obligation.
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D. MR. GAGGERO IS REQUIRED TO IDENTIFY WITH PARTICULARITY
DOCUMENTS WITHHELD PURSUANT TO ANY OBJECTION, INCLUDING
CLAIMS OF PRIVILEGE
20 California Code of Civil Procedure § 2031.240(b)(1) requires Mr. Gaggero to identify with
21 particularity documents withheld pursuant to any objection, including but not limited to claims of
22 privilege. Hernandez v. Superior Court (2003) 112 Cal. App. 4th 285, 291. Mr. Gaggero is
23 required to set forth clearly the extent of, and the specific ground for, the objection. If an objection
24 is based on a clilim of privilege, the particular privilege invoked shall be stated. ffanobjection is
25 based on a claim that the infonnation sought is protected work product under Chapter 4
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26 (commencing with Section 2018.010), that claim shall be expressly asserted." Code Civ. Proc. §§
27 203I.240(b)(1), (2). Importantly, objections made to requests for production of documents that do
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1 not exists or are not in the attorney's or party's possession violate an attorney's ethical duty under
2 the Business and Professions Code to act truthfully and constitute bad faith. Bihun v. AT&T Info.
3 Sys. (1993) 13 Cal. App. 4th 976,991 n 5.
4 The purpose of a "privilege log" is to provide a specific factual description of documents
5 In aid of substantiating a claim of privilege in connection with a request for document
6 production." Hernandez, supra 112 Cal. App. 4th 285 at 292 citing Korea Data Systems Co. v.
7 Superior Court (1997) 51 Cal. App. 4th 1513, 1516-1517. The information in a privilege log or
8 accompanying any other claim ofprivilege must be sufficiently specific to permit the trial court to
9 determine whether each withheld document is or is not privileged. Kaiser Found. Hosp. v.
10 Superior Court (1998) 66 Cal. App. 4th 1217, 1228.
11 Mr. Gaggero, as the party who is seeking to assert this privilege has "[t]he burden of
12 showing the need for such protection." San Diego Professional Assn. v. Superior Court (1962) 58
13 Cal. 2d 194, 204. Mr. Gaggero must provide a specific factual description for each document
14 withheld sufficient to substantiate a claim of privilege in connection with a request for document
15 production. Hernandez, supra 112 Cal. App. 4th 285 at 292 citing Korea Data Systems Co. v.
16 Superior Court (1997) 51 Cal. App. 4th 1513,1516-1517. Mr. Gaggero has not established that
17 any of the documents he is seeking to withhold is subject to any privilege, thus, KPC respectfully
18 requests that this Court compel Mr. Gaggero to produce all documents without further objection.
19 (Decl. AW ~ 10, Exh. H).
20 E. MR. GAGGERO CANNOT ASSERT THE ATTORNEY-CLIENT OR
ATTORNEY WORK-PRODUCT PRIVILEGE TO COMMITT A FRAUD
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22 The attorney-client privilege authorizes a client to refuse to disclose, and to prevent others
23 from disclosing, information communicated in confidence to the attorney and legal advice
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24 received in return. Evid. Code, § 954. The privilege does not apply where the "services of the
25 lawyer were sought or obtained to enable or aid anyone to commit or plan to commit a crime or a
26 fraud." Evid. Code, § 956. To invoke crime/fraud exception to attorney-client privilege, the
27 proponent must make prima facie showing that services of lawyer were sought or obtained to
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1 enable or to aid anyone to commit or plan to commit crime or fraud. State Farm Fire & Casualty
2 Co. v. Superior Court (1997) 54 Cal.App.4th 625. Here, Mr. Gaggero, while he was a judgment
3 debtor, retained Mr. Praske to implement an asset protection scheme to conceal his assets from
4 creditors. (Decl. AW ~ 20, Exh. N). Mr. Praske continues his work relating to the estate plan as the
5 trustee ofthe trusts or foundation and in his capacity as an officer of the various business entities.
6 Id.
7 Importantly, Mr. Gaggero only asserts this privilege as part of his efforts to defraud
8 judgment creditors. (Id. ~~16-17, 20, Exh. L, N). Mr. Gaggero in pursuing a breach of contract
9 lawSl.lit against in Gaggero v. Yura did not assert the attorney client privilege relating to his estate
10 plan. (Id. ~ 20, N). In fact both he and Mr. Praske testified in great lengths about the
11 implementation of the estate plan and Mr. Gaggero's authority to command resources within the
12 estate to purchase property in excess of 1 million dollars. (Id). Mr. Gaggero's cannot assert the
13 attorney-client privilege selectively to defraud his judgment creditors. Finally, Mr. Praske's
14 knowledge of the fraud is irrelevant for the crime-fraud exception to the attorney client privilege
15 to apply; instead, the application of it turns on Mr. Gaggero's intent. Freedom Trust v. Chubb
16 Group ofIns. Companies (1999) 38 F.Supp.2d 1170. There is no doubt that Mr. Gaggero was and
17 is perpetrating a fraud in implementing the estate plan designed to conceal his assets from his
18 judgment creditors.
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F. THE CONSTITUTIONAL RIGHT TO PRIVACY DOES NOT PERMIT A
20 JUDGMENT DEBTOR TO DEFRAUD CREDITORS
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It is well settled that the right of privacy is not absolute and it may be abridged to
accommodate a compelling public interest. Moskowitz v. Superior Court, 137 Cal.App.3d 313,
316 (1982) (emphasis added). One such interest is uncovering the truth in legalproceedings by
allowing broad discovery. Id. When the right of privacy and the public interest conflict, the court
must balancethe inten.~stsfor a fair resolution ofthe lawsuit. Here, Mr. Gaggero seeks toassertthe .
constitutional right to privacy for each response, without any description as to. what documents he
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1 is withholding pursuant to the privacy, and for the sole purpose to defraud his creditors. The
2 constitutional right to privacy does not support this proposition.
3 G. KPC'S MOTION TO AMEND THE JUDGMENT OBVIATES MR.
GAGGERO'S REFUSAL TO PRODUCE DOCUMENTS ON GROUNDS OF
4 PRIVACY
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On May 29, 2012 KPC's Motion to Amend the Judgment to Add Additional Judgment
Debtors came on for hearing before Judge Robert L. Hess. Judge Hess granted the motion adding
Pacific Coast Management, 511 OFW LP, Gingerbread Court LP, Malibu Broad Beach LP,
Marina Glencoe LP, Blu House LLC, Boardwalk Sunset LLC, and Joseph Praske, trustee, of the
Giganin Trust, Arenzano Family Trust, and Aquasante Foundation as judgment debtors. Mr.
Gaggero, therefore, can no longer assert the privacy rights of the trusts, foundation, and entities in
support ofhis refusal to comply with post-judgment discovery. (Id. ~20, Exh. N).
IV. CONCLUSION
For the foregoing reasons, judgment creditors KPC, respectfully request this Court to
produce documents in response to the Request for Production of
MILLERLLP
By: rbh- We1 A
RANDALL A. MILLER,C;Q~
AUSTA WAKILY,ESQ.
Attorneys for Knapp, Petersen & Clarke, StephenRay
Garcia,.Stephen M. Harris, and Andre Jardini
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MOTION TO COJvfPEL POST JUDGMENT REQUEST FOR PRODUCTION OF DOCUMENTS

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DECLARATION OF AUSTA WAKILY IN SUPPORT OF MOTION
TO COMPEL POST JUDGMENT REQUEST FOR PRODUCTION OF DOCUMENTS
I, Austa Wakily, declare:
1. I am an attorney licensed to practice law by the State Bar of California. I am an
associate at the law firm Miller LLP and the attorney of record for the defendants and judgment
creditors, Knapp, Petersen & Clarke, Stephen Ray Garcia, Stephen Harris, and Andre Jardini
(collectively referred to as "KPC") in this action. I first became involved in the handling of the
post-judgment enforcement efforts in this action in mid-November 2012. I am also the attorney of
record in another lawsuit involving judgment debtor Stephen Gaggero against KPC for purported
legal malpractice. Since that time I have become familiar with the pleadings, records and files in
this action including the appeal and the amended judgment, including numerous transcripts and
various lawsuits in which Stephen Gaggero has been a party.
2. KPC obtained a judgment against Mr. Gaggero on May 19, 2008 in the amount of
$1,327,697,994.50 and amended on December 28, 2010 to include attorney fees and costs after
Mr. Gaggero unsuccessfully appealed the underlying judgment. KPC's judgment as of December
28,2012 totaled $1,841,535.80. Attached as Exhibit A is a true and correct copy ofthe amended
judgment.
3. I personally drafted 38 Requests for Pl:oduction of Documents (Set Two) pursuant
to Code of Civil Procedure § 708.030. Attached as Exhibit B is a true and correct copy of the
requests served on January 31, 2012. The requests were specifically drafted to obtain information
to aid in the collection of the judgment including information relating to Mr. Gaggero's estate
plan, entities and assets within the estate plan, and third parties who have knowledge, possession,
or control of Gaggero's assets. Mr. Gaggero's respons_es were due on March6, 2012..
4. Mr. Gaggero's counsel ofrecord, David Chatfield, on March 1,2012 sent a letter to
our. office requesting a.30 day extension due in part to Gaggero's travel schedule and other
litigation. As a professional courtesy Mr. Chatfield, on March 2, 2012 was granted a two week
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MOTION TO COMPEL POST JUDGMENT REQUEST FOR PRODUCTION OF DOCUJv.IENTS

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extension. Mr. Gaggero's deadline to respond was extended to March 20, 2012. Attached as
Exhibit C are copies ofthe letters relating to the extension.
5. Mr. Gaggero, through his counsel, served responses on March 20, 2012. No
documents were produced with the responses. A copy ofthe responses is attached as Exhibit D
6. After receiving and reviewing the responses I sent a letter dated April 2, 2012 to
Mr. Chatfield proposing to meet and confer on April 6, 2012 in an attempt to avoid having to
bring a motion to compel. Attached as Exhibit E is a copy ofmy letter to Mr. Chatfield.
7. Mr. Chatfield responded by email on April 3, 2012 stating that he was not available
to meet and confer on April 9, 2012 but was available any time after 10:00 on April 12, 2012.
Based on Mr. Chatfield's response I proposed to meet and confer on April 12,2012 at 3:00 pm.
Mr. Chatfield responded by email on April 6, 2012 agreeing to meet and confer on April 12, 2012
and extending our deadline to file a motion to compel to May 11,2012. Attached as Exhibit F is
a copy ofthe email.
8. I received a call from Mr. Chatfield's secretary on April 11, 2012 stating that Mr.
Chatfield could not make the scheduled meet and confer on April 12, 2012 due to an urgent
matter. Mr. Chatfield's secretary further informed me that he would be available to reschedule
the meet and confer to April 19,2012 at 3:00 p.m. and that we would also receive a one week
extension to file a motion to compel to May 18, 2012. I sent an email to Mr. Chatfield
confirming my conversation with his secretary. The email is included as part ofExhibit F.
9. On April 19, 2012 I called Mr. Chatfield to discuss the responses to the request for
production of documents. Mr. Chatfield agreed to (1) provide supplemental responses removing
all boilerplate and/or or inapplicable objections, (2) provide a "privilege log" for documents
withheld pursuant to a claim ofprivilege, and (3) produce all documents that are responsive to the
requests·that are not privileged. The deadline to provide supplemental responses was April 30,
2012. A copy ofmy email to Mr. Chatfield confirming our discussions is attached as Exhibit G.
10. Mr. Gaggero, through is counsel, served supplemental responses on April 30, 2012.
Mr. Gaggero again did not produce any documents. Attached as Exhibit H is a true and correct
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MOTION TO COMPEL POST TIJDGMENT REQUEST FOR PRODUCTION OF DOCUMENTS

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copy of Mr. Gaggero's supplemental responses to the request for production of documents (set
two).
11. After reviewing the supplemental responses served on May 2, 2012 it became
readily apparent that Mr. Gaggero had no intention of producing the requested documents. My
agreement with Mr. Chatfield to allow him to supplement his responses to April 30, 2012
required him to comply with the three conditions to which he agreed. Mr. Gaggero's
supplemental responses did not include a privilege log or any document production. Additionally,
while the supplemental responses have removed the "General Objections" each objection
continues to assert imorooer boilerolate objections.......L .a. oJ ,
12. I sent Mr. Chatfield an email on May 2,2012 inquiring whether he would produce
a privilege log. Mr. Chatfield did not respond. Attached as Exhibit I is a copy of this email
communication.
13. I sent Mr. Chatfield a twenty one page meet and confer letter on May 11, 2012
addressing the deficiencies in the supplemental responses, limiting the scope of certain request,
and clarifying the requests. Attached as Exhibit J is a copy of the meet and confer letter sent on
May 11,2012.
14. In the letter I provide Mr. Gaggero to respond to the Meet and Confer no later than
May 15,2012. Mr. Chatfield emailed me on May 14,2012 requesting a two week extension of
our respective-deadlines due to a deadline to file an opposition In a reIated motion. I responded
on May 14,2012 agreeing to provide him a one week extension to May 22, 2012. Attached as
Exhibit K is a copy ofthe email correspondence.
15. On May 21,2012, Mr. Chatfield's assistant, Dawn Masters called me to request an
additional two day extension for Mr. Chatfield to respond to the meet and confer letter dated May
11~2012.(agreedto provide Mr. Chatfield until May 24, 2012 to respond conditioned on a two
day extension for filing the motion to compel to May 31, 2012. Attached with Exhibit K is a copy
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of my email to Mr. Chatfield and Ms. Masters confmning my telephone conversation with Ms.
27 Masters.
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16. Mr. Chatfieldemailed me on May 24,2012 at 9:59 p.m. to state that he has filed a
motion for protective order. Attached as Exhibit L is a copy of Mr. Chatfield's email to me and
the proposed protective order. After reviewing the protective order I believe that Mr. Gaggero's
purpose in seeking the order is to prohibit KPC from using evidence obtained from post-judgment
discovery against him in his pending legal malpractice lawsuit against KPC. (Exh. L, ~ 4
Protective Order). I previously explained to Mr. Chatfield in response to a protective order in the
debtor examination proceeding that we will not agree to any protective order that will allow Mr.
Gaggero to commit perjury in prosecuting a lawsuit against KPC while also precluding them
from enforcing their judgment. This is documented in my email attached with Exhibit L.
17. I responded to Mr. Chatfield's email on May 25, 2012 to clarify his misstatements
that were confirmed in my emails. I also informed him that we would proceed with filing a
motion to compel based on his client's failure to cooperate with post-judgment discovery.
Attached as Exhibit M is a copy ofmy email to Mr. Chatfield.
18. Mr. Chatfield responded requesting further meet and confers on the discovery and
requesting that I do not file a motion to compel. In response I emailed Mr. Chatfield to confirm
that he produced with his May 24, 2012 supplemental responses the privilege log he stated he
would produce on April 30, 2012. Mr. Chatfield confirmed that he has not produced a privilege
log and intends to comply. I explained in a response that his client's deadline to respond was May
24~ 2012requiring actual -compliance and not another assertion of an intent to comply. Attached -
with ~~itit-M is a copy ofthe email.,~',,:;',.,.';; :.~,,,~./ .... ;.' '.
19. KPC subsequently received 15 pages of documents produced in response to
Request for Production of Documents (Set Two). The documents are considerably insufficient in
responding to KPC's requests.
20. On May 29, -2012 KPC'sMotion to Amend the Judgment to Add AdditionaI"
Judgment Debtors came on for hearing before Judge Robert L. Hess. Judge Hess granted the
motion adding Pacific Coast Management, 511 OFW LP, Gingerbread Court LP, Malibu Broad
Beach LP, Marina Glencoe LP, Blu House LLC, Boardwalk Sunset LLC, and Joseph Praske,
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MOTION TO COJ:v1PEL POST JUDGMENT REQUEST FOR PRODUCTION OF DOCUMENTS

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trustee, of the Giganin Trust, Arenzano Family Trust, and Aquasante Foundation as judgment
debtors. Attached as Exhibit N is a true and correct copy of the Motion to Amend the Judgment
and signed order.
21. Mr. Chatfield notified me immediately after the Court granted KPC's Motion to
Amend the Judgment that he will file a notice of appeaL Based on Mr. Chatfield's statements
and Mr. Gaggero's numerous appeals I believe that he will appeal the Court's ruling and continue
refusing to cooperate with post-judgment discovery on that basis.
22. Based on Mr. Chatfield's and Mr. Gaggero's tactics in abusing the discovery
process I believe that any request for further meet and confers is solely as a delay tactic and will
not result in the production of any documents. As a result, it has been necessary to bring this
motion.
23. I personally drafted and reviewed each request in the Request for Production of
Documents (Set Two). Each of the requests is likely to lead to information that will aid KPC in
enforcing their judgment.
24. In order to bring this, I expended no less 20 hours preparing the motion and
accompanying separate statement, declaration, and exhibits. Additionally, I spent 20 hours
reviewing Mr. Gaggero's responses and supplemental responses to the request for production of
document, preparing the meet and correspondences to Mr. Chatfield, and meeting and conferring
with Mr. Chatfield. I expect to spend additIonal five (5) hours preparing-any reply briefs and
attending the hearing on this matter.
25. My hourly rate is $240. I seek an award of attorney's fees for $10,800 for 45 hours
ofwork at $240 per hour, plus the $40.00 filing fee for a total of$10,840.
I declare under penalty of perjury under the laws of the State of California that the
foregoing IS true and correct and that this declaration was executed on May g/,2012 at Los
Angeles, California.
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MOTION TO COJv.lPEL POST JUDGMENT REQUEST FOR PRODUCTION OF DOCUMENTS

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2-8
MILLERLLP
Los ANGELES
RANDALL A. :MILLER (State Bar No.. 116036)
LORI S. BLITSTIEN (State Bar No. 149004)
. VIKRAM SOHAL (State Bar No. 240251)
lfiLLER LLP
515 South Flower Street, Suite 2150
Los Angeles, California 90071
Telephone: 213.493.6400
Facsimile: 888.749.5812
Attorneys for Defendants
KNAPP, PETERSEN & CLARKE,
STEPHEN RAY GARCIA, STEPHEN M.
HARRIS and ANDRE JARDINI
SUPERIOR COURT OF CALIFORNIA
COUNTY OF LOS ANGELES - UNLIMITED CIVIL JURISDICTION
STEPHEN M. GAGGERO, an individual,
Plaintiff,
v.
HARRIS and ANDRE JARDINI,
Defendants.
CASE NO. BC 286925
(P.D:QP~~l AMENDED JUDGMENT IN
FAVOR OF DEFENDANTS
The California Court ofAppeal having affirmed this Court's findings that Plaintiff
STEPHEN M. GAGGERO ("Plaintiff") failed to C81TY his burden ofproofwith respect to any of '
his cla.irD.s, and a judgment having been-enteted infavor· ofDefendants KNAPP, PETERSEN & .
CLARKE, STEPHEN RAY GARCIA, STEPHEN M. HARRIS and ANDRE JARDINI
. . (collecTIvely.,·"Defendants''rancfa.gamst:f>Iallitiffon each cause ofaction ofthe SecondAIllended
Complaint and awarding Defendants $1,202,994.50 in·attorneys' fees and $124,702.90 in costs,
[pROPOSED] ANIENDED JUDGMENT IN FAVOR OF DEFENDANTS

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MILLERLLP
Los ANGELES
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plus post-judgment interest at the legal rate, and this Court having now heard and ruled upon
Defendants' Motion for Attorneys' Fees and Costs on Appeal in favor ofDefendants and against
Plaintiff,
IT IS HEREBY ORDERED AND ADJUDGED THAT:
1. Plaintiff shall take nothing by way ofhis Second Amended Complaint and
judgment shall be entered as to all causes ofaction ofthe Second Amended Complaint in favor of
Defendants KNAPP, PETERSEN & CLARKE, STEVEN RAY GARCIA, STEPHEN HARRIS
and ANDRE JARDINI and against Plaintiff STEPHEN M. GAGGERO;
2. Defendants shall be awarded attorneys' fees in the sum of$1,395,718.40 (which
figure includes the award of$192,723.90 in attomeys' fees on appeal) and costs in the sum of
$125,224.90 (which figure includes the award of$522.00 in costs on appeal), plus post-judgment
interest at the legal rate; and
3. Defendants shall be awarded $320,591.78 in interest accrued on the previous
judgment as ofNovember 18, 2010 at the rate of$3.54.24 per day for 905 days.
Dated: ~"-=·a~b.",,,.,-.!~~·*,___
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[PROPOSED] AMENDED JUDGMENT IN FAVOR OF DEFENDANTS

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_PROOF OF SERVICE
I am a resident ofthe State of California, over the age of eighteen years, and not a
party to the within action. My business address is MILLER LLP, 515 South Flower Street, Suite
2150, Los Angeles, California 90071. On December 13,2010) served the within documents:
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NOTICE OF LODGING OF [PROPOSEDl.AMENDED JUDGMENT
by transmitting via facsimile the document(s) listed above to the fax number(s) set
forth below on this date before 5:00 p.m. -
by placing the document(s) listed above in a sealed envelope with postage
thereon fully prepaid, in the United States mail at Los Angeles, California
addressed as set forth below.
bv causing to be nersonallv served to the nerson(s) at the address(es) set forth
below. ~ .L • ~ . L ' , • ,
By causing such document to be transmitted by electronic mail to the office ofthe
addressees'.
by causing such document(s) to be sent overnight via Federal Express; I enclosed
such document(s) in an envelope/package provided by Federal Express addressed
to the person(s) at the address (es) set forth below and I placed the
envelope/package for collection at a drop box provided by Federal Express.
David Blake Chatfield
Westlake Law Group
Gary L. Bostwick, Esq.
Jean-Paul Jassy, Esq.
Bostwick & Jassy LLP2625 Townsgate Road, Suite 330
Westlake Village, CA 91361 12400 Wilshire Blvd., Suite 400
Los Angeles, CA 90025
I am readily familiar with the fum's practice ofcollection and processing correspondence
for inailfug.Under that practice ifwoUJ.d De deposited with the U.S. Postal Service on that sariJ.e
day with postage thereon fully prepaid in the ordinary course ofbusiness. I am aware that on
motion ofthe party served, service is presumed invalid ifpostal cancellation date or postage
meter date is more than one day after date ofdeposit for mailing in affidavit.
_I declare under penalty ofp.erjury under the laws ofthe State of California that the above
is true and correct.
Executed 011 December 13, 2010,at Los Angeles, California.
Susy Koshkak ' .
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MILLERLLP 1Lt'lS ANl~E1.F-" .
PROOF OF SERVICE

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Randall A. Miller
ScottNewman
Austa Wakily
MILLERLLP
(BarNo. 116036)
(Bar No. 238788)
(Bar No. 257424)
Telephone: 800.720.2126
Facsimile: 888.749-5812
Attorneys for KNAPP, PETERSEN & CLARKE,
STEPHEN RAY GARCIA, STEPHEN M. HARRIS
and ANDRE JARDINI
SUPERlOR COURT OF CALIFORNIA
COUNTY OF LOS ANGELES
STEPHEN M. GAGGERO,
Plaintiff,
v.
HARRIS and ANDRE JARDINI,
Defendants.
CASE NO.: BC286925
[Assigned for all purposes to Judge Honorable
Judge Robert L. Hess, Department 24]
REQUEST FOR PRODUCTION OF
DOCUMENTS TO PLAINTIFF STEPHEN
M.GAGGERO
~URSUANTTOCODEOFCnnL
PROCEDURE § 708.030]
20 PROPOUNDING PARTY:
21 RESPONDING PARTY:
22 SET NUMBER:
DEFENDANT, KNAPP, PETERSEN & CLARKE
PLANTIFF STEPf.fEN M. GAGGERO
TWO
23 Defendant Knapp, Petersen & Clarke, pursuant to California Code of Civil Procedure
24 sectiQUS 70S.030(a)and 2031.010, et seq., requests that plaintiff, Stephen Gaggero, provide a
25 written response under oath and produce all documents resJ?~nsive to the fol!0wing~e9.ttests for
26 Production of Documents within thirty (30) days of service, to the -law offices of Miller LLP,
27 located at 515 South Flower St., Suite 2150, Los Angeles, California 90071.
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REQUEST FORPRODUCTION OF DOCUlv.1EN:rS TO PLAINTIFF STEPHEN M. GAGGERO

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DEFINITIONS
"YOU" and "YOUR" means Responding Party and his agents, employee,
3 employer, attorney, accountant, investigator, or anyone else acting on Responding Party's behalf.
4 2. "COMMUNICATIONS" should be construed ill the broadest possible sense and
5 includes, but is not limited to, any transmittal and/or receipt ofinformation, whether such was by
6 chance, prearranged, formaJ. or informal, and specifically includes conversations, telegrams, audio
7 or media visual letters .or memoranda, formal statements, press releases, and newspaper and
8 magazine articles.
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3. "DOCUMENT" means any writings or recordings as defined by California
Evidence Code section 250, including recorded or graphic material of any kind, whether prepared
by YOU or another PERSON that is in YOUR possession, custody, or control. The term includes
agreements; .contracts; letters; telegrams; inter-office COIV.IMUNICATIONS; memoranda; reports;
records; instructions; specifications; notes; notebooks; scrapbooks; diaries; plans; drawings;
sketches; blueprints; diagrams; photographs; photocopies; charts; graphs; descriptions; drafts,
whether they resulted in a final DOCUMENT; minutes ofmeetings, conferences, and telephone or
other conversations or COMMUNICATIONS; invoices; purchase orders; bills of lading;
recordings; published or unpublished speeches or articles; publications; transcripts of telephone
conversations; phone mail; electronic-mail; ledgers; financial statements; microfilm; microfiche;
tape or disc recordIDgs; and computer print-outs. The term "DOCUJv.lENT" also includes
electronically stored data from which information can be obtained either directly or by translation
through detection devices or readers; any such DOCUMENT is to be produced in a reasonably
legible and usable form. The term "DOCUMENT"includes all drafts of a DOCUMENT and all
copies that differ in any respect from the original, including an)T no!a.tion, un4erlinirlg, marking,_or _
information not on the original. The term- also includes infonnationstored ·in, or accessible
throug1J., computer or ()t11er}'nf'orm~[tioD. r(;:trieval systems(ine.ludiognany .computeLarchives or
back-up systems), together with instructions and all other materials necessary to use or illterpret
27 such data compilations.
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REQUEST FORPRODUCTION OF DOCUMENTS TO PLAINTIFF STEPHEN M. GAGGERO

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1 4. ENTITY includes but is not limited to corporation, limited liability company,
2 limited liability partnership, general partnership, trusts, foundation, .or other partnership or·
3 association.
4 5. ESTATE PLAN includes but is not limited to the preparation of any plan of
5 administration and disposition of YOUR property, owned by YOU at any time in any capacity,
6 before or after death including will, trust, gifts, or power of attorney, or any other method of estate
7 planning. ESTATE PLAN also refers to the "Estate Plan" YOU testified about during the
8 GAGGERO V. YURA trial. ESTATE PLAN further refers to the transfer of any assets owned by
9 you at any time to any PERSON or ENTITY.
10 6. "GAGGERO V. YURA" refers to the Los Angeles Superior Court case, Gaggero v.
11 Yura, etal, Case No. BC239810.
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7. PERSON" or "PERSONS"· means any natural PERSON, firm, association,
organization, partnership, business, trust, corporation, and private or public ENTITY.
8. "938 PROPERTY" refers to real property located at 938 Palisades Beach Road,
Santa Monica, California.
9. "PROPERTIES" refer collectively to the real properties located at 938 Palisades
"17 Beach Road, Santa Monica, California; 940 Palisades Beach Road, Santa Monica, California; and
18 944 Palisades Beach Road, Santa Monica, California.
19 10. "RELATE," "RELATING," "REFER," or "REFERRING" means containing,
20 constituting, considering, comprising, concerning, discussing, regarding, describing, reflecting,
21 studying, commenting or reporting on, mentioning, analyzing, or referring, alluding, or pertaining
22 to, in whole or in part.
23 11.· The singular ofany word in.clu~esthe plural and the:plural includes the singular.
24 12. The terms "or" and~ "and" shall be read in the conjunctive and in the disjunctive
25 wherever theyappear, andne~tller 5>f the,S~ words E;hall beiut~r:pretedto limit:the scope oLa
26 request for information.
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REQUEST FOR PRODUCTION OF DOCUMENTS TO PLAINTIFF STEPHEN M. GAGGERO

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INSTRUCTIONS
In responding to the following Requests for Production, YOU are required to
3 furnish all information and items within YOUR possession, custody or control, including
4 information in the possession, custody or control of YOUR employees, agents, attorney, or
5 investigators, and all persons acting in YOUR behalf.
6 2. If YOU object to any request because YOU contend that YOU have previously
7 produced some or all responsive DOC1JJ.1ENTS, or that sonie or all of the responsive
DOCUMENTS were produced by the DEFENDANTS or are in DEFENDANTS' possession,
custody, or control, include in YOUR response the Bates stamp number or otherwise identify with
particularity all DOCUMENTS that YOU contend relieve YOU ofllie obligation to respond to the
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requests.
3. If any requested DOC1JJ.1ENT was, but no longer is in YOUR possession or
subject to YOUR control, or has been misplaced, destroyed, discarded, or otherwise disposed of,
please state so, and for each DOCUMENT provide: (a) Its date; (b) The identity of all
PERSON(S) who prepared or participated in preparing the DOCUMENT; (c) The identity of all
PERSON(S) who received the DOCUMENT; (d) The number of pages ofthe DOCUMENT; (e)
The subject matter of the DOCUMENT; (f) Ifmisplaced, the last time or place it was in YOUR
possession and a description of the efforts made to locate the DOCUMENT; (g) If disposed of,
the date and reason for disposal, the manner of disposition, the identity of PERSON(S) who
20 authorized disposal.
21 4. For each DOCUMENT withheld under a claim of privilege state the specific
22 privilege asserted and: (a) The type ofthe DOCUMENT, e.g., a letter, memorandum, etc.; (b) The
23 title ofthe DOCUMENT, ifany; (c) The date the DOCUMENT was prepared; Cd.) Theidentity of
24 its author(s); (e) The identity of all PERSON(S), who prepared or participated inpteparing the
25 DO~UI1El'rr? (f) _Th.~ id~ntity ofthe:PERSQN(S}to whomit was addressed andfol"to whom the- . -
26 copies were directed to be transmitted; (g) The identity of the PERSON(S) to whom the
27 DOCUMENT or a copy was transmitted, directe~ delivereci or s~nt; (4) The present location of
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1 the DOCillv1ENT and the identity ofthe PERSON(S) who presently have custody ofit anc1!orwho
2 have in the past had custody ofthe DOCUMENT; (i) A sufficient description ofthe DOCUMENT
3 to identify it in its subject matter without revealing information for which a privilege is claimed;
4 G) All other facts that support YOUR claim for privilege.
5 5. TRUST PROTECTOR refers to any PERSON or ENTITY appointed under the
6 trust instrument to direct or restrain the trustee in relation to the administration of the trust. The
7 TRUST PROTECTOR holds a power to direct the trustee in matters relating to the trust.
8 6. In responding to the following-Requests for Production (Set One), YOU must make
9 a diligent search of all records in YOUR possession or available to YOU or YOUR
10 representatives. If YOU cannot comply in full with these Requests then YOU must comply to the
11 fullest extent possible and specify the reaSons for YOUR inability to comply with the remainder.
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13 DOCUMENT REQUESTS
14 REQUEST FOR PRODUCTION NO.1.
15 All DOCUMENTS that RELATE to the Arenzano Trust.
17 All DOCUMENTS that RELATE to the Giganin Trust.
19 All DOCUMENTS that RELATE to the Aquasante Foundation.
21 All DOCUMENTS that RELATE to any trust or foundation that is part of YOUR ESTATE
22 PLAN.
-24 All DOCUMENTS that RELATE to YOUR ESTATE PLAN.
26 All DOCUMENTS RELATING to any CO:MMIJNICATION REFERENCING YOUR
27 ESTATE PLAN.
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2 All DOCUMENTS that RELATE to any trust in which YOU are the trustor regardless of
3 YOUR present income or financial interest.
5 All DOCUMENTS that RELATE to any trust in which YOU are a TRUST PROTECTOR,
6 regardless ofYOUR present income or financial interest.
8 All DOCUMENTS that RELATE to any trust in which YOU are a beneficiary, regardless of
. 9 YOUR present income or financial interest.
10 REQUEST FOR PRODUCTION NO. 10.
11 All DOCUMENTS that RELATE to any trust in which YOU are in class of beneficiaries,
12 regardless ofYOUR present income or financial interest.
14 All DOC1Th1ENTS that RELATE to bills, fees, invoices, or charges paid on YOUR behalf by
15 any PERSON or ENTITY including, but not limited to, Pacific Coast Management and Avalon
16 Corporation since 2001.
17 REQUEST FOR PRODUCTION NO. 12..
18 All DOC1Th1ENTS that RELATE to travel expenses paid by YOU or any PERSON or
19 ENTITY on your behalf since 2001.
20, REQUEST FOR PRODUCTION NO. 13.
21 All DOCUMENTS that RELATE to litigation expenses paid by YOU or any PERSON or
22 ENTITY on your behalf since 2001.
24 All DOCUMENTS that RELATE to the transfer of any asset ·owned at any time by YOU in
25 any capacity.
26 /11
27 /11
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-6-
REQUEST FORPRODUCTION OF DOCU1v.IENTS TO PLAINTIFF STEPHEN M. GAGGERO

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2 All DOCUJv.[ENTS that RELATE to the transfer of any asset owned at any time by YOU as
3 part ofYOUR ESTATE PLANNING.
5 All DOCUMENTS that RELATE to any postjudgment discovery in any matter to which YOU
6 responded.
7 REQUEST FORPRODUCTION NO. 17.
8 All DOCUMENTS that RELATE to any judgment debtor exam ofYOU since 2001.
10 All DOCUMENTS that RELATE to any ENTITY ofwhich YOU are an officer or member.
12 All DOCUMENTS that RELATE to any property at which YOU have resided since January
13 201l.
15 All DOCUMENTS that RELATE to real property located at 3501 Canada Larga, Ventura
16 California, 9300l.
18 All DOCUMENTS that RELATE to any tax DOCUMENTS filed by YOU or on YOUR
19. behalf.
20 REQUEST FOR PRODUCTION NO. 2i-
21 All DOCUMENTS that RELATE to any taxes paid on YOUR behalf, including but not limited
22 to, in YOUR capacity as the equitable owner ofany ENTITY.
24 All DOCUMENTS that RELATEto any income tax returns including, but-not limited to,W-
252's, 1099's, K-1's, whetherprePctred for fe4e!~,~tate,91" m~(;:ipal that R:ELATE to X()psinc~
26 January 1,2005.
27 / Il
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-7-
REQUEST FORPRODUCTIQN OF DOCUMENTS TO PLAINTIFF STEPHEN M. GAGGERO

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1 REQUEST F.OR PRODUCTION NO. 24.
2 All DOCUMENTS that RELATE to anymoney givento YOU for any purpose since 2010.
4 All DOCUMENTS that RELATE to any income earned by YOUR since 2010
6 All banks statements for any personal or business account in which YOU have legal or
7 equitable interest.
9 All savings accounts in institutions that represent accounts in which YOU have an equitable
10 interest.
12 All deeds, leases, mortgages, or any other DOCUMENT evidencing any interest or ownership,
13 including equitable interest or ownership, by YOU in real property at any time since 1997.
15 All DOCUMENTS evidencing any inter~st or ownership, including equitable interest or
16 ownership, by YOU in any asset at any time since 1997.
18 All stock certificates or other DOCUMENTS evidencing ownership of stocks and bonds held
19 by YOU in any capacity.
21 All DOCUMENTS RELATING to Pacific Coast Management Corporation.
23 All DOCUMENTS RELATING to Avalon Corporation.
25 All DOCUMENTSlillLATING tOatlY ENTITY ill. which Pacific Cost Management
26 Corporation is a general partner.
27 III
28
-8-
REQUEST FOR PRODUCTION OF DOCUMENTS TO PLAINTIFF STEPHENM. GAGGERO

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2 All DOCUMENTS RELATING to any ENTITY in which Avalon Corporation is a general
3 partner.
5 All DOCUMENTS RELATING to any lawsuit in which YOU are involved as a representative
6 for any PERSON or ENTITY.
8 All DOCUMENTS that RELATE to insurance policies that insure loss to any property, real or
9 personal, which YOU own, including equitable ownership, individually or jointly with any other
10 PERSON.
12 All DOCUMENTS that RELATE to any debt incurred by YOU since 2005.
14 All DOCUMENTS that RELATE to payment ofany debtincurred by YOU.
15
Dated: January 31,2012
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MILLERLLP
By: ~ WAL"~ t
RANDALL A. MILDrR'~Q.
. SCOTTNEWMAN,-ESQ;
AUSTA WAKI:LY, ESQ.
Attorneys for Knapp, Petersen & Clarke, Stephen Ray
Garcia,.Stephen M. Harris, and Andre Jardini
-9-
REQUEST FOR PRODUCTION OF DOCUMENTS TO PLAINTIFF S1EPHEN M. GAGGERO

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. PROOF OF SERVICE
I am a resident ofthe State of California, over the age of eighteen years, and not a party to
the within action. My business address is Miller LLP, 515 South Flower Street, Suite 2150, Los
Ange~es, CA 90071.,.2201. On January 31. 2012, I served the within documents:
o
n
D
o
by transmitting via facsimile the document(s) listed above to the faxnumber(s) set
forth below on this date before 5:00 p.m.
by placing the document(s) listed above in a sealed envelope with postage thereon
fully prepaid, in the United States mail at Los Angeles~ California addressed as set
forth below.
by causing to be personally served to the person(s) at the addressees) set forth below
on this date before 5:00 p.m.
by causing such document to be transmitted by electronic mail to the office ofthe
addressees as set forth below on this date before 5:00 p.m.
by causing such document(s) to be sent overnight via Federal Express; I enclosed
such document(s) in an envelope/package provided by Federal Express addressed to
the person(s) at the address (es) set forth below and I placed the envelope/package
for collection at a drop box provided by Federal Express.
SEE ATTACHED SERVICE LIST
I am readily familiar with the firm's practice ofcollection 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 in the ordinary course ofbusiness. I am aware that on
motion ofthe party served, service is'presumed invalid ifpostal cancellation date or postage meter
date is more than one day after date ofdeposit for ma.ili:hgin affidavit:
I declare under penalty ofperjury under the laws ofthe State of Californiathat the above is
true and correct.
-10-

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David Blake Chatfield, Esq.
WESTLAKE LAW GROUP
2625 Townsgate Road, Suite 330
Westlake Village, CA 91361
Stephen M. Gaggero
3501 Canada Larga
Ventura, CA 93001
SERVICE LIST
Attorneysfor Plaintiff, STEPHENM.
GAGGERO
Ph. (805) 267-1220
Fax: (805) 267-1211
Email:
Plaintiff
Ph.
Fax:
Email:
-11-

"
)
-- - --------------- -----------
Exhibit "C"

IVIt:l1 V I I C. I 1 •..,,",1-' VllVVI"IY' ........... _.,,. - ....... -.~
DAVID EH.AKJ;; CHATF'II':I.D
I'!:MAI1..: DAVlbBL,.AKEC@HOTMAfL,COM
Scott Newman
MillerLLP
'WESTLAKE LAW GROUP
2625 TOWNSGATE ROAD' SUITE 3S0
WESTLAKE VILLAGe;, CALIFORNIA 9136'1
(80S) 267-12.20
PAX (805) .267-121 1
'March 1,2012
Los Angeles, CA 90071~2201
Via Facsimile & U.S. Mail
Re: Gaggero v. Knapp, Petersen & Clarke, et al.
No. BC286925
Dear Mr. Nevvman:
lam writing this letter to request a 30 day extension to respond to the Request for Production of
Documents to Plaintiff Stephen M. Gaggero currently due on March 6, 2012 in the above
referenced case. As you are aware, when these Requests were served, Mr. Gaggero was in trial
and, in addition, Mr. Gaggero has been out ofstate for the past two weeks and will only be in
tOWTI for one day next week, not returning until March 23.• 2012. In addition., what little time.Mr.
Gaggero had between the trial and his trip was spent going over approximately 1OO~OOO
documents to find documents responsive to your production demands in the case ofGaggero v.
Knapp, Petersen & Clarke relating to their bandling ofthe Yura case.
I have had absolutely no time to work with Mr. Gaggero on his responses to your extensive
document Requests in thls case and will be unable to do so until afler his return. on March 23,
2012. Therefore, werequest that youprovide us with a 30 -day extension so that! may have a
reasonable opportunity to work with Mr. Gaggero to provide meaningful responses to your
Requests and allow for a diligent search for responsive documents. Mr. Gaggero's unavailability
is well known to your firm as it has been disclosed by Mr. Gaggero's counsel~ Blecher and
Collins, in the other Knapp, Petersen & Clark case in relation to discovery served in that matter.
Kindly provide us "vith your agreement to the requested extension by tomorrow, March 2, 2012.
Thank you for your anticipated courtesy and cooperation in this matter.
DBCIk't

LOS ANGELES
MILLER I LLPCITY NATIONAL PLAZA
515 South Flower Street
Suite 2150
213.493.6400
TEL: 800.720.2126 I FAX: 888.749.5812
www.rnillerllp.com
VIA MAIL AND FASCIMILE
David Blake Chatfield
Westlake Law Group
Westlake·Village, California 91361
Facsimile: (805) 267-1220
¥arch 2, 2012
Reply To:
scott@mlllerllp.com
RE: Gaggero v. Knapp, Petersen & Clarke, et aI, Los Angeles Superior Court
(BC286925)
Mr. Chatfield,
This is in response to your l~tter dated March 1, 2012.requesting a 30 day extension to
respond to the post-judgment request for production of documents propounded to Stephen M.
Gaggero. Notwithstanding:Mr. Gaggero's vacation schedule, you have had sufficient time to
respond to the documents. We wi1i, however, grant you a 2 week extension to respond as a
matter of professionril courtesy. The deadline to both provide responses and produce all
responsive documents is now March 20, 2012. .
ScottNewman
:MILLER ILLP

-_._--.._. --. -----..-..-.__.. -_. -_.__.- ...._- _... --.. j._.__._----_._-_..._._-_. -._..- -_..__.__._---_._----------) ._--- -_.. - -- ._. _._... _- _... -_. ---- --_._-
1 WESTLAKE LAW GROUP
2 David Blake Chatfield (State Bar No. 88991)
Westlake Village, CA 91361
3 Telephone: (805) 267-1220
4 Facsimile: (805) 267-1211
5 Attorneys for Plaintiff
Stephen M. Gaggero
6
7
8
9
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
10 STEPHEN M. GAGGERO, an individual, )
)
11
12 VS.
Plaintiff, . )
)
)
.)
13 KNAPP, PETERSEN AND CLARKE, a . )
California corporation; STEVEN RAY )
14 GARCIA, an individual; STEPHEN M. )
HARRIS, an individual; ANDRE JARDINI, )
15 an individual; DOES 1 through 50, inclusive, )
. . )
16
Defendants.
17
CASE NO.: BC286925
PLAINTIFF STEPHEN M. GAGGERO'S
RESPONSES TO DEFENDANT KNAPP,
PETERSEN & CLARK'S REQUEST FOR
PRODUCtION OF DoCUMENTS
[PURSUANT TO CODE OF CIVIL
PROCEDURE § 708.030]
18 PROPOUNDING PARTY:
19 RESPONDING PARTY:
. DEFENDANT KNAPP, PETERSEN & CL.A1tKB
PLAINTIFF STEPBBN M. GAGGERO
20 SET NuMBER:
21
22
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24
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- - - •• _ •• _. __ ~• • • • ___. _ ._._ ............ -: ___ ._ ••• __ ••••••••• _ • - M" •••• _ •• ___ • • • _ •• _ _ • • • • . , _ .
ONE--··
-- --------··---'-2T- :- -.----- ---. --.-.-- ..-- -.----~.-.~-.- - -:-- .--~----.:. -- .-. -~..-: ---.- -- -.--- ~-- -.---:-:-.- .~------.--.-- ---------------- - - ---- -..--- ---. -------
..........._... 2.b

......._..._- ..- -- . __ ._...._, .'..... _..... -.- -- ...- .._..........._. _.. -_...._.... _-/')- .... - .-... - .. _........-: "-'-_.. _-'- _..
1 PlaintiffStephenM. Gaggero (''Plaintiff') hereby responds and objects to Defendant
2 Knapp, Petersen & Clarke's (''Defendant'') Request for Production ofDocUlP.ents. The response
3 contains both general and specific objections, which are incorporated .into each individual
4 response.
5 PRELThfiNARYSTATEMENT
6 Nothing in this response shall be construed as waiving any rights or objections that might
7 otherwise be available to Plaintiff, Plaintiffmakes this response subject to and without waiver of:
8 (1) the right to make additional objections or seek protective orders in the event additional
9 review offiles results in further information;
10 (2) the right to object to other discovery directed to the subject matter ofthe Requests; and
11 (3) the right to revlse, correct, supplement, or clarify the response.
12 GENERAL OBJECTIONS
13 1. Plaintiffobjects generally to the Requests, and to each individual Request, on the
14 grounds that they are. overly broad and unduly burdensome and harassing in that they are clearly
15 not li:r.i:rited to docUment~ necessary to aid in the enforcement ofthe judgment for fees and costs in
16 this matter. Requests for documents relating to assets transferred, sold or liquidated over a decade
17 ago are clearly irrelevant to this judgment enforcement and will not be produced byplaintiff.
18 2. Plaintiffobjects generally to the Requests, and to each individual Request, to the
19 extent that they call for information protected from discovery or disclosure by anyprivilege or
"-:' --.---:~--.: .,-.:-~~ -.-~'~ :--: --.~'.'--.-.",::.--._-._-:.- "._." :~"- .... "___7 ....."._" _. ~ ", __ :"_.: ~~_~_~ .... "'~.._ ~ _':_.'.'_-. .' ._. .. _.....: ..._.._~ . . . . . _. _ ....
20 doctrine, including, without limitation, the attorney-client privilege, the attorney work product
21 doctrine, and anyprivilege or doctrine that protects infoITnation from discovery or disClosure
22 because it otherwise reflects the impressions, conclusions, opinions, legal research, litigation plans
23 or theories ofPlaintiffs attorneys. By providing certain information requested herein, Plaintiff
24 does notwaiveanypriyilege or protection that is or maybe applicable to such information.
25 3. Plaintiffobjects gel?-erally to the Requests, and to each individualRequest; to the
-26 - -extentoiliattb.gycallforIDiorrnatien-proteotedfrom·discov€ry:oLdi.sclosurebytheIights QfIJriyl3.c.y
_.._-.. --- - ·--~T -.·gUaraD:teeaoy.tJie-catirormaConstitutibn-®a::tD.e-oniteI't-States.-C<Y.llstitu.!iQE-:Eyprgyiqing-cert-a:jn,-- ._..._--
f.-=====d8= -,w-€J~atiBE-:re'i:aestru:1J:l~i:R,Rl.a~.Qes--not...w.aiV:e....arL~I2.tivilege_oL12.I.ote.c_tio.n...th.atjs or may be
1

/--, ... -_._.-- ... _.. - _ ... _...... -_ ..._.-._._.. -.-._. ).... __.. __...... -
1 applicable to such information.
3 extent tha{theypmport to impose upon Plaintiffobligations beyond those imposed under the Code
4 of Civil Procedure or Court Rules.
6 extent that they request information that is in the possession, custody or control of:Defendants.
7 6. Plaintiffobjects generally to the Requests, and to each individual Reqll:est, to the
8 extent that they seek information that is not in the custody or control ofPlaintiff. Plaintifffurther
9 objects generally to the Requests to the extent that they seek information that is publicly available,
10 or to which Plaintiffhas aCcess equal to as Plaintiff, or which PlaintiffOr Plaintiffs counsel could
.11 obtain with equal effort.
12 7. Plaintiffobjects generally to the Requests, and to each individual request, to the
13 extent that they seek disclosure ofinformation that is confidential and/or proprietary.
14 8. Plaintiff objects generally to the Requests, and to each Request, because they are
15 vague, ambiguous, unintelligible, undated, unsigned, and overly broad, in that they contain
16 undefined terms or pmport to impose definitions that are both internally inconsistent and
----------n- ·-mcompatltrle witlrb1'ditrary,-common;-·orestablished-meanings:--Aecordingly,·iti.-mterpreting-and- .-----._.-
18 construing the requests, Plaintiffwill give words their ordinary meaning, common, and established
19 :ine~g~, s?_that._tJ:1e.r~SIJonses and objections will not be subject to misinterpretation. When the
__ .. "..... :. _':_'::::" __ :.:~ .. _M. __ .~. __.::_ ...._ ••" __ ' __ '_::-.__.::-'..::_..__ .. " ..,': .... _. :__ ~.•.. _ ~_.-: ... . _...... .
20 response uses the present tense, plaintiffwill presume that defendants are referring to the present
21 time. When the request uses the word "since" plaintiffunderstands the word to have the meaning
22 set forth in Webster's dictionary "after a time in the past.;'
23 9. Plaintiffobjects to the definition ofthe terms "you" and "your" set forth in
24 _Paragraph 1 ofDefendant'spe:fi.nitions in that it collectiyely n~fers to Plaintiff, together with his
25 a.gents, eri::llJloyee~-ern:ployet, attorney, accountant, investigator, or anyone else acting onPla:ifitiff's
- 26 -behalf, on the groundthatsuG-hanj~~xpansiy.e_use impose.s-aburden,gJ::efl.t~r thEtI:l.wll,atisr~9....uJ:tfig,"by
---.--.-.- .---·-2T~ llie-:-Ca1If6rmaRUleso:f-CI.VlI.-PrQce1im~rIDrdlJI.a:k~rtr~-r~:q-g:~~t~-oy~rly-broad'1IDd~y-1Jm:.de~oIl1~-·------ .--
!--======4cl9t=Cl..B.!-!U0J~l1Q.t..other:Wise-reasonably-calcnla1e.di.o~e.ad to me discovery ofevidence relevant to the
2

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1 claims or defenses ofthe parties. Plaintiffwill respond to the requests o:iJly on behalfofbimsel£
2 Because the definition includes Plaintiffs attorneys, Plaintiff also objects to the extent that the
. 3 requests seek information protected from disclosure by the attorney-client privilege; the attorney
4 work product doctrine, and any other applicable privileges.
5 10_ Plaintiffobjects to each and every request oli the grounds, and to the extent, that it
6 seeks information outside the relevant time period.
7 11. Plaintiff objects to the definition ofthe definition ofESTATB PLAN set forth in
8 Defendant's Definitions in that it includes but is not limited to the preparation of any plan of
9 administration and disposition ofPlaintiffsproperty, owned by Plaintiffat any time in any
10 capacity, before or after·death including will, trust, gifts, or·power ofatton;iey, ot any other method
11 ofestate planning and further refers to the transfer ofany assets owned by Phrintiff.at any time to
12 any PERSON or ENTITY·collectively on the ground that such an eXpansive group of definitions
13 imposes a burden greater than what is required by the California Ru1es of Civil Procedure ahd
14 makes the requests overly broad, unduly burdensome, and/or not otherwIse reasonably calculated
15 to lead to the disc·overy ofevidence relevant to the inquiry into Plaintiffs Current assets, which is
16 the sole subject ofthis discovery_
-~. -----..·---17-· ..------. _ u _ _ • _ _ _ • • _ • - • • • - • • • - -:-RESP{)NSE8-T(j-D(jeUMENT.RE0l:ffiS!{,·S·_-·-.-------.- --.---------. -.---___._.
18 DOCUMENT REQUEST NO.1:
19 All DOCillv1ENTS that RELATE to the Aremano Trust.
-": -:-- "- --.:~-:- -"."."- .. _. - .
20 RESPONSE TO DOCUMENTREQUEST NO.1:
21 Plaintiffincorporates by reference each and every General Objection set forth above as
22 though fully set forth herein. Plairitiff objects to this request on the grounds that it is overly broad,
23 undulyburdensome and harassing. Plaintifffurther objects to this request on the grounds that it .
24 seeks.documents that are neither relevant !lor reasonably calculated to lead to the discovery of
25 adillissible eVidencem this action: Plaintifffuttherobjectsto this request orii:he grounds that it
-26 -calls-for thepI0duc-tionofirrele-yantdo_G:um~ntscthatare__pI.Qtect{';)9-ir9111~Q.lo§ill~1JYj>1~l1.tjJf)
- .- -.-:-- -~27 -:-anQt:lJlXd.parneS'"~Constiru:t1onaTI:y.PIQte.:-ct~dTightQrFriya;cy.-P-l-aiP.1i;f:f-:furtb:er:-objeet-s-t~d:bi?rectuest- .._n~••• _ _ •
l---======'~ _0fl-th~~at-i.t.seeks-documentsJhai.are 12IOte.cte.d1to.m..disclosure by: the attorney-client
3

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1 priVilege and/or the attorney work-product doctrine.
2 Subject to and without waiving the foregoing objections and limitations, Plaintiffresponds
3 as follows: Plaintiffhas no documents responsive to this request in his possession or control.
5 All DOCUMENTS that RELATE to the Giganin Trust.
6 RESPONSE TO DOCUMENT REQUEST NO.2:
8 though fully set forth herein. Plaintiff objects to this request on the grounds that it is overly broad,
9 undulyburdensome and harassing. Plaintifffurther objects to this request on the grounds that it
10 seeks documents that are neither relevant nor reasonably calculated to lead to the discovery of
11 admissible evidence in tbis action. Plaintifffurther objects to thi$ request on the grounds that it
12 calls for the production ofirrelevant documents that are protected fromdisc1osure by plaintiff's
13 and.third parties' Constitutionally protected rights ofprivacy. Plaintiff further objects to this
14 request on the grounds that it seeks documents that are protected from disclosure by the attotney-
15 clientprivilege and/or the attorney work-product doctrine.
-,
-- -'-------1/--- -ag-folloWs:-Ptamttffliaffno-dbcuments-resp'OTIsive-to-tbis-reqnest-irr-bis-possession-or--col1tml~----.------ -.--.----
19 All_~.O~~~S tha~;RELATE to theAquasante Foundation.
..• .0_. .•. ",":", _". : .~" ~
20 RESPONSE TO DOCUMENTREQUEST NO.3:
22 though :fully set forth herein_ Plaintiffobjects to this request on the grounds that it is overly broad,
23 unduly burdensome and harassing. Plaintifffurther objects to this request on the grounds that it
24 seeks.documents that are neitherreleV'ant norreasonably calculated to lead to the discovery of
25achriissible evidence irithls action. Plaintifffurther objects to tJ:lls request on the grounds that it -
26 - -Galls for the productionc-ofirrelevantdocUID.€nts tb.at~are.pIOtected~fr.OrrHlis.Closur~by pla.:irl.ti:Ef's _'.
- --.- -----£7ana:tl:lifdp~es"'-~Cofi$fimtlonaJlyprntecteah~t-=a:tpriya:cy::Pl~t:iff fuJ:th~rQbj-~pts:-to-:-tbi-s:-request- --" --.
4

iI
1 privilege and/or the attomeywork-product doctrine.
3 as follows: Plailltiffhas no documents responsive to this request in his possession or control.
5 All DOCUMENTS that RELATE to any trust or foundation that is part ofYODRESTATE
6 PLAN.
7 RESPONSE TO DOCUl.ffiNT REQUEST NO.4:
9 though fully set forth herein. Plaintiffobjects to this request on the grounds that it is overly broad,
10 undulyburdensome and harassing. 'Plaintifffurther objects to this request on the grounds that it
. 11 seeks documents that are neither relevant nor reasonably calculatedto lead to the discovery of .
12 admissible evidence in this action. Plaintifffurther objects to this request on the grounds that it
13 calls for the production ofirrelevant documents that are protected from .disclosure by plaintiff's
14 and third parties' Constitutionally protected right ofprivacy. Plaintifffurther objects to this request
15 on the grounds that it seeks documents that are protected from disclosure by the attorney-client
16 privilege and/or the attorney work-product doctrine.
--- ---------.-t?- -.------------Subjecttcnl11_d-withoutwai-vrngthe-forego:ing-objecticns-and Jimitations;--Plaintiff-respl:mds-------- .
19 DOClJMENT REQUEST NO.5:
20
21
22
23
24
25
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All DOCUMENTS that RELATE to YOUR ESTATE PLAN.
RESPONSE TO DOCUMENT REQUEST NO.5:
Plaintiffincorporates by reference each and every General Objection set forth above as
though fully set forth herein. Plaintiffobjects to this request on the grounds that it is overlybroad,
.un9-uly burdensome and harassirlg. Plaintiff:furtIJ.er objects to this request on the grounds that it
seeks documents that are neither-relevant riorreasonablycalculatedtb leadto the discovery of
,admissible evidence m-tbisaGtiQn._PlaintifIfurthercobje.ctsjQ,tbiSIe'lu.~st()lJ.J:l:le_gr,plIDq§1hatjt...
------. ---:-- -L,7-: ~cans~-ror~t11e-pr.o_ductt<TIL!J.firre-lwant-dQ:c.1IDl~utsib:~t-We'1'rotect~d-fr9~-:disclcSUTe-by-pl~~s----..- - ------
~=====-,?~8!=l=-&l,a..ill-{-ld;bir:d-;t:!arties' Constitutionally:J2I.o:te_cj:~d.Jight o£privacy. Plaintifffurther obiects to this re uest
5
I

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2 privilege and!or the attorney work-product doctrine.
3 Subject to and without waivrng the foregoing objections and limitations, Plaintiffresponds
4 as follows: Plaintiffhas no documents responsive to this requestin his possession or control.
6 All DOCillv1ENTS RELATING to any COM1v.[uNICATION REFERENCING YOUR
7 ESTATE PLAN.
8 RESPONSE TO DOCUMENT REQDEST NO.6:
10 though fully set forth herein. Plaintiff objects to this request on the grounds that it is overly broad
11 in time and scope and as such are·undulyburdensome and harassing. Plaintifffurther objects that
12 the req1l:-est on the grounds is vague and ambiguous such that plaintiffcannot fOrin a meaningful
13 response. Plaintifffurther objects to this request on the grounds that it seeks documents that are
14 neither relevant nor reasonably calculated to lead to the discovery ofadmissible evidence in this
15 action. Plaintifffurther objects to this request On the grounds that it calls for the prodUction of
16 irrelevant documents that are protected from disclosure byplaintiff's and third parties'
--··-·----·---rr-·--C6;iistltutionallyprotected-rlght-ofprivacy.-Plaintifffurther-obj-ects·-to--tbis--request-·on-the--grounds---·-·-·----·--
18 that it seeks documents that areprotected from disclosure by the attorney-client privilege and!or
19 the attorney work-product doctrine.
.....:. ::'..~. ,-:- -::_,"'.:'...._--- ~-.--...-~:-. '_."-'" :":'.- .'.' . . . .
21· All DOCillv1ENTS that RELATE to any trust in which YOU are the trustor regardless of
22 YOUR present income or financial illterest.
24 Plaintiffincorporatesby reference each and every General Objection set forth above as
25 tliough fully set forth herein. Plamtlff0bjecls fotliis request on the grounds that it is overly broad,
..26 unduly burdensome.andharassing,~PlaintifffurtheLQbjec.tstQ_tbis;re_q.u.estQn the gr~:n.U1.dsJ:b.at it.
- -._.-.---. ---2T ·-seaG3--documerits11iatare.Iiettlier.r.eIevantn<5Ire.-a-s-o"1fa:b-lTG~ai-c-giate-d:tQ-:-le.-a.d.i~:r-:th.e-9isc.overy~()f··-· -~--- ----.-.:--
~===='1:6:.i)1]0000t:=aElmj-ss-jb1.~~Jl.~m-tbis-actiQn~ P.lam:tifffuItheLobj_e_cisJ:.o-1his...r.e_qJl_e.sj: on the grounds that it
6

t • - .. _ .. - •.•.
;
. . .. - .. ( ..--').. ... _. ..... _. " _. - ... -_.... - _._-
--->
1 calls for the production ofirrelevant documents thatare protect~dfrom disclOSUre byplaintiff's
2 and third parties' Constitutionallyprotected right ofprivacy. Plaintifffurther objects to tbis request
4 privilege and/or the attomey work-product doctrine.
6 as follows: Plaintiffhas no documents responsive to this request in bis possession or control.
8 All DOCUMENTS that RELATE to any trust in wbich YOU are a TRUST :PROTECTOR.
10 Plaintiffincorporates by reference'each and'every General Objection set forth above ·as
11 though fully set forth herein. Plaintiffobjects to this request on the grounds.that it is overlybroad,
12 undulyburdensome and harassing. Plaintifffurther objects to this request on the grounds that it
13 seeks documents that are neither relevant nor reasonably calculated to lead to the discovery of
15 calls for the production ofirrelevant documents that are protected from disclosure byplaintiffs
16 and third parties'. Constitutionallyprotected right ofprivacy. Plaintifffurther objects to this request
..----._-- -'--'17-'- -on tD1l"grouna.stna:tit-se-eks-dtrcumentsihat-are'protected-from-disclosure-'by-me-·att0mey"'c-lient· '-' .-.-.-----
18 privilege and/or the attor;neywork-product doctrine.
19 Subject to and without waivingthe foregoing objections and lii:nitations, Plaintiffresponds
',.-': .... -.-.-,... -.~--.-----:-' .. ~ ~ ...~ - ~:. ~ "-' :'"-.': ---.... _.... .--.:.-.::....- .. ":- ::-,: -" .-.. ',' . ~ ......., .. ',:'~ ~-.: .... - -' ' . - . - - .-:."
22 All DOCUMENTS that RELATE to any trust in wbich YoU are a beneficiary; regardless
23 ofregardless ofYOUR present income or financial interest.
25 - Plaintiffiricorponites by reference each and every General Objection set forth above.as
.--26 .,thQugh fullysetforth.herein. ..Plainti:ff.obje_cts.tQ~tbkr.e_que8t.onthe_gcolJ.l:l,ds that.itis,.()vpr]y"b;tIt~g., ,
.~- -----~L.7- --unaUly15uta.ensome allil-haraS"BID:g-;-~Plaintifffg;rth-erqb.j~·ct~;-tQ-t;bis-r~ql1est-~m-fue-grelil14~-fuat-:it-:-.-: -~--
1----=====":'')1,0Q-~==I"P"~"iO>~d,ftc.JJm.ents..:that.are..neitb.er...r.ele.Y~t.n.o.I..Ie.as.anabl)U<.aiculated to leadto the discovery of _
7

j ....................._......_...... '). _....
1 admissible evidence in this action. Plaintifffurther objects to this request onthe grounds that it
2 calls for the production ofirrelevant documents that are protected from disclosure byplaintiff's
3 and third parties' Constitutionallyprotected right ofprivacy. Plaintifffurther objects to this request
4 on the grounds that it seeks documents that are protected from disclosure by the attomey-client
5 .privilege and/or the attorney work-product doctrine.
8 DOCUMENT REQUEST NO. 10:
9 All DOCUMENTS that RELATE to any trust in which YOU are in class ofbeneficiaries,
10 regardless ofYOUR present income ot financial interest.
11 RESPONSE TO DOCUMENT REQUEST NO.. 10:
13 though fully set forth herein. Plaintiff objects to this request on the groUnds that it is overly broad,
14 unduly burdensome and harassing. Plaintifffurther objects to tbis request on the grounds that it
15 seeks documents that are neither relevantnor reasonably calculated to lead to the· discovery of
.-.-.-.....-.- ····-·17----ca.1t§f6r-tne-production·of:irretevant-dacuments-that-are-protected-from-disclelstITe-by-plainti:ff.s-····_---.-.-.
18 and third parties' Constitutionallyprotected right ofprivacy. Plaintifffurther objects to this request
19 on t11~.W?~ds t~~t _its.ee~__~ocuments that are protected fro:rn disclosure by the attorney-client
• • • • • • ~ __. : . _ •• _ •••• _ _ _ .0 • • • ~ • • • • : _.__ .~ :'::'~'• • _~~_~'" • • • • _. "." • • •.'.: • • • _. _ . , , _ • • • _
20 privilege and/or the attorney work-product doctrine.
21 -Subject to and without waiving the foregoing objections and limitations, Plaintiffresponds
24 All DOCUMENTS that RELATE to bills, f~es; irlvoices, or charges paid on YOURbehalf
25 hy any PERSON-orENTITY ili.bluding, but notl.itnited to, PacmcCoastManagementand A'Valon
_.. 26 (Jmporation smce 2001.
...--....-.---."--2"'7- -o-UcrD10>1.'SE·-To-n·O-C'i"-'m~T.cp-n'E'-O'F'FE'-Qq:>.N()-11~--------------------.--.-.---------.-.- ..------- ----... •., ~~-"J;.}-~.l-~" _~ . ", -. • .Ul.UEil.~~..~. _UJ,!J.O:_~~_ .... ,- . . ~. . . . . . _ .
----,========<7Jb RlaiJJti.;f;Ej;gco:kpO-Iates.b_r..r.eferenc.e each..and eye Gen.e.raLOb.ection set forth above as
8

i
/
...-._..... J)..... ...:'. _1
1 though fully set forth herein. Plaintiffobjects to this request on the grounds that it is overly broad
2 as to time and scope as to be unduly burdensome and harassing. Plaintifffurther objects to this
3 request on the grounds that it seeks documents that are neither relevant nor reasonably calculated
4 to lead to the discovery of admissible evidence in this action. Plaintifffurther objects to this
5 request on the grounds that it calls for the production ofirrelevant documents that are protected
6 from disclosure by plaintilfs and third parties' Constitutionallyprotected right ofprivacy. Plaintiff
7 further objects to this request on the grounds that it seeks documents that are protected from
8 disclosure by the attorney-client privilege and/or the attorney work-product doctr:iile.
,.
10 All DOCUMENTS ·that RELATE to travel expenses paid byYOU or anY-PERSON or
11 ENTITY on your behalfsince· 2001.
12 RESPONSE TO DOCUMENT REQUEST NO. 12:
15 as to time and scope as to be undulyburdensome and harassing. Plaintifffurther objects to this
.-_.--........-'-'17' ··to le·a:d·tQ-tne-msc-overy-ofac1rn±s·sible-eviderrceintbis-actron:·-Plainti-ff-further··ebjects-te-this-····--- --.------"--.
18 request on the grounds that it cG-lls for the production ofirrelevant documents that are protected
19 fro~ cl?-sc~?.sut~_bYI'.~~~ffs ~~ ~~~~~S'C?l1S~!U~?~~ll)T}')rot~c~edright ofprivacy. Plaitltir:, ..c.
20 further objects to this request on the grounds that it seeks documents' that are protected from
21 disclosure bythe attorney-client privilege and/or the attotneywork-product doctrine.
23 All DOCUMENTS that RELATE to litigation expenses paid by YOU or any PERSON or
24 ENTITY onyour behalfsince 2001.
25 RESPONSE TO DOCUMENT REQtJESTNO. 13:
- 26 -Plaintiffineorporates byreferenG€_eacaaIldeyery Gene:tal Qb.jecJiQ:r:l.-setJ9rthaboye .~p....
-_..-- --- ... '-'27'-- ~ougfi:I'illlyserfQfE1f"nerein.--Plainttf:fo:bj~Gtrt:Q"1biST~-qg;~t-Ql.:rtJ:r~·grounds1:1J.at-it·i-s~-over}y-bre>ad-:-. -:-"....-- .-
~====~").~Q-=H::a~Y,nd3.k.Q -e-as to-b.e-undubw.urdens.ome..andltar.a.ssin ...J:laintifffurther ob·ects to this
9

I " ...... _.... - ' " .._.... . .._.... /) -'. - ......
.....1
3 request on the grounds that it calls for the production ofirrelevant documentsthat are protected
4 from disclosure by plaintiff's and thirdparties' Constitutionally protected right ofprivacy. Plaintiff
6 disclosure bythe attorney-client privilege andlor the attorney work-product doctrine.
8 All DO~NTS that RELATE to the transfer of any asset owned at any time by YOU in
9 any capacity.
10 RE~PONSE TO DOCUMENT'REQUESTNO. 14: .
11 Plaintiffincorporates byrefetence each and every General Objection set forth above as
12 though fully setforth herein. Plaintiffobjects to this request on the grounds that it is overlybroad
13 as to time and scope so as to be unduly burdensome and harassing. Plaintifffurther objects to this
14 request on the grounds that it seeks documents that are neither relevant not reasonably calculated
15 to lead to the discovery of admissible evidence in tbis action. Plaintiff further objects to tbis
--·--------·---·-li-·-fromilisclosu:re-by-plaffitiff''s"andtbird-parties2
-Constitutionall-y-pi'0teetea-rightofpri-v-ae-y-;-P-laintiff .----.-
19 .. ~sc1o~~e.by th.e attorney-c~~~t p.r:i~lege andlor :the_~ttomey workwptoduct doctrine.
.~ -- ':. .- . ' . . ... _.
21 All DOCUMENTS that RELATE to the transfer ofany asset owned at any time by YOU as
22 part ofYOUR ESTATE PLANNlNG.
24 .. ... l?laintiffincorpora!es byreference each and every General Objection set forth above as
25thougli fully set Iorfuherem: Plaintiffobjects to thisrequestonthe grounds thatit is overlybroad
... - .. 26 .. as to hothtime_and SG0pe that is und1!lyJ2'l1:td~:r:tEi()m~._ang_J:J.ar~~~igg._:Pl~ti.fffH;ti:1le:r 9bject~_t~tltiE_
-- -- -.- ..- --"'27- ~iequesron fIle-grounds-tha;rirS'e-e-krlm;;mP;~;Q.t~~tb:atw.e-n~itb:er-rel~v:ap:t-n:m-Ieas01'l~b.l-y-ea:le.lliateEl~-.'-.'-- .---.
--=====,<18~.=IJdi.Q,Jead to-the..disco~eI¥ of.admissible eYidence in this action. Plaintiff:further 0bjects to this
10

,~
~.. _.... _.. --j
. _.................. ~ l- ... '" ... . . . " - .... - ....-_..
. (/
I request on the grounds that it calls for the production of:irrelevant documents that are protected
2 from disclosure by plaintiffs and third parties' Constitutionallyprotected right ofprivacy. Plaintiff
3 further objects to this request on the grounds that it seeks documents that are protect~d from
4 disclosure bythe attorney-client privilege and!or the attorney work-product doctrine.
6 All DOCUMENTS that RELATE to any post judgment discoveryin.anymatterto which YOU
7 responded.
8 RESPONSE TO DOCUMENT REQUESTNO. 16:
10 though fully set forth herein.·Plaintiffobjects to this request on the grounds that it is overly broad
11 as to time and scope as to be unduly..burdensome and harassing. Piaintifffurther.objects to this
15 from disclosure by plaintiffs and third parties' Constitutionally protected right ofprivacy. Plaintiff
16 further objects to this request on the grounds that it seeks docuinents that are protected from
----·-·...··----...17·-- jdlsclosure··15y the-a'ttonrey:.-c1ient"privile-ge-·andlorib:e-·attomey-work-=-prod:uet-doetrine;--- ..........--_. .... ....--.......
19 ..__ .. . ._A.1:~ DO~~N!~ i?:at RE~!?-!E.:~o:.aIl~J~dgment d~b~~r~xam.ofYOU since 200l..' ..... -.~ ::...........
20 RESPONSE TO DOCUMENT REQUEST NO..17:
23 as to time and scope as to be unduly burdensome and harassing. Plaintifffurther objects to this
24 request onthe grounds that it seeks documents that are neitherrelevant nor reasonably calculated
25 to lead to the discovery of admissible-evidence ill this action. Plain.tifffurtherobjects totbis
.26 requeston the grounds thatitca1ls.for.tb.eproduGtion.ofirrelevantdocum..ents.1h~ta:reprotec;t~cd
- ......... -.----- ·-Z'T -.from-msclosUie.oy"'plallfiiffs anCl.~t1llrCl. parn:es'":"e.bnstituti:an:lIlly:p::rQt~(,)te-d-right-of-Pri:~ae-y:-Pl-aiJ1~
--====:=k~-=It::fI.:Jrth.~I::.e1>j:€..G.:ts.=tQ...tbi.s...:r;e'luest.on....tb.e~o.undsJ:b.atit.se_ekB-dnc_um.e.n:ts that are rotected from
11

. __ . -- -"'- .. . __ . -', --} ... . ... _ .. _._----)- ._- .. -.,.- --.
1 disclosure by the attorney-client privilege and!or the attorney work-product doctrine.
3 All DOCUMENTS that RELATE to any ENTITY ofwhich YOU are an officer or member.
4 RESPONSE TO DOCUMENT REQUEST NO. J8:
6 .though fully set forth herein. Plaintiffobjects to this request on the grounds that it is overly broad
7 as to time and scope and therefore undulyburdensQIile and harassing. Plaintifffurther objects to
8 this request on the grounds that it seeks dOCu:r:i1ents that are neither relevant nor reasonably
9 calculated to lead to the discovery of admissible evidence in this action. Plaintifffurther objects to
10 this reauest on the QIounds that it calls for the production of-irrelevant documents that are.J. _ _ .
11 protected from disclosure byplaintiff's and third parties' Constitutionally protected right of
12 privacy. Plaintifffurther objects to this request on the grounds that it seeks docu:r:i1ents that are
13 protected from disclosure by the attorney-clientprivilege and/or the attorney work-product
14 doctrine.
16 as follows: Plaintiffhas no documents responsive to this request.
-.--- ---- ·--YT·-nO-CUMENTREOUESTNO.-19:--·---··-- --.----------..-- ...--------- '__'_'_H ____.__,.__u _ _ _ _ _ _ . _ . _ _ _ _ _ - - - " - - - " - - . - . - - - . - . - - - -
18 All DOCUMENTS that RELATE to any property at whichYOU have resided since January
19 2011.
22 though fully set forth herein. Plaintiff objects to this request on the grounds that it is overly broad,
23 undulyburdensome and harassing_ Plaintifffurther objects to this request on the grounds that it
_24 seeks documents that are neither relevant nor reasonably calculated to leadJO the discovery of
25 admissible evidence in this action..Plaintifffurther objects to this request on the gtotinds that it
--- ..26 -0aB~~foFthe-preduGtion,ofirreleovantdoouments·ib.at.areprotected.£rom.disclo.sureob¥_plaintiffs
-.-.-..-:-.~.-----~Z7 andtliITa:pames-:'-:-CQnsfifutionaIly-pr.Qte.Gtei1rig1In>:fpriyac_y.~£ll-aintiif:fgrtl;rerobje-cts1::o-tbis-request- -:- - -:----
~====;bi1= -@R=tJao®=gf~a-8=fuat..fl~ks..-<loCJJments.Jha:La:re"pmtectecLfro:milisclo.su.re. b;¥ihe atto.mex-client
12

05.31.12 motion to compel rfd (set two)

05.31.12 motion to compel rfd (set two)

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