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Sample Meet and Confer Letter With Specially Prepared Interrogatories to TD Service Company

Sample Meet and Confer Letter With Specially Prepared Interrogatories to TD Service Company

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Published by Barry Fagan Esq.
TD service Company

Lawrence J. Dreyfuss The Dreyfuss Firm, PLC 7700 Irvine Center Drive #710 Irvine, CA 92618

May 19

Re: Meet and Confer Letter Re: TD SERVICE COMPANY's Responses To Request For Admissions, Set No. One and Responses to Request for Specially Prepared Interrogatories and Form Interrogatories-General Sets No. 1.

Dear Mr. Dreyfuss:

TD service Company

Lawrence J. Dreyfuss The Dreyfuss Firm, PLC 7700 Irvine Center Drive #710 Irvine, CA 92618

May 19

Re: Meet and Confer Letter Re: TD SERVICE COMPANY's Responses To Request For Admissions, Set No. One and Responses to Request for Specially Prepared Interrogatories and Form Interrogatories-General Sets No. 1.

Dear Mr. Dreyfuss:

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BARRY S.

FAGAN

Lawrence J. Dreyfuss The Dreyfuss Firm, PLC 7700 Irvine Center Drive #710 Irvine, CA 92618

Sent Certified mail with return receipt service: 7010 0290 0002 5780 9460

May 19,2011

Re: Meet and Confer Letter Re: Tn SERVICE COMPANY's Responses To Request For Admissions, Set No. One and Responses to Request for Specially Prepared Interrogatories and Form Interrogatories-General Sets No. 1. Case No. SC112044.

Dear Mr. Dreyfuss:

Reference is made to TD SERVICE COMPAl..JV's ("Defendant") Responses to Request for Specially Prepared Interrogatories Set No.1, Request For Admissions, Set No. One and their responses to the concurrently served 17.1 form interrogatories, receipt of which is hereby acknowledged.

I find Defendant's responses to the request for admissions to be woefully defective. Not only are the Defendant's responses defective, they are also designed to prejudice the Plaintiff by running the proverbial non-judicial foreclosure clock out on Plaintiff, such that discovery cannot occur without extraordinary judicial remedies. Defendant has also been served with a Request for Beneficiary Statement pursuant to California Civil Code Section 2943(b), and UCC §3~502 as" ATTORNEY IN FACT" AND "AGENT" for Defendant Wells Fargo Bank and the Defendant TD SERVICE COMPANY is hereby reminded that it has 21 days from May 13, 2011 to comply with that requirement as well.

Plaintiff is hereby declaring that 811 of Defendant's Objections and Responses have no merit. The request for admissions, specially prepared interrogatories, and form interrogatories are sufficiently clear and concise. The request is not vague and ambiguous because Defendant knows exactly what Plaintiff is requesting due to the allegations in Plaintiff's complaint. It relates to a material dispute between the parties. No attorneyclient/work product privilege would be violated by responding to the Request for Admissions, Specially Prepared Interrogatories, and Form Interrogatories.

Defendant has admitted to being in possession of the DECLARATION OF DEFAULT and NOTICE TO SELL. (See Response to Request for Admissions Number 8)However, Defendant has attempted to mislead this Plaintiff and the Court by stating that it is in possession of a "DECLARATION" that was "EXECUvm BYANlNDlVlDUAL, ON BEHALF OF WELLS FARGO BANK ON MARCH 17, 2011 "(See Response to Form Interrogatories No.8) And than went on to claim in their Responses to Plaintiff's

PO BOX 1213, MALIBU, CA 90265-1213 PENDINGLAWSUIT@YAHOO.COM TEL. 310.717.1790

BARRY s. FAGAN

Specially Prepared Interrogatories that" THE DECLARATION WAS EXECUTED ON lyfARCH 17, 2011 BY AN lNQ1VWUA.L A CTING ON BEHALF OF WELLS FARGO BANK.TH4 T PERSON'S /:iAME. nnE. AND CONTACT lNfOBHA TlfllY4R-e NOT INCLUDED ON THE DECUBA lION"!!!!!! (See B.emOltw to PlaintifJ:§. S,peciallp Pre.ua",d lnterrovatories No. 1SJ.

Moreover, TD SERVICE COMPANY's May 9,2011 and May 10,2011 PAYOFF STATEMENT LETTERS to PLAINTIFF have indicated a $987.00 APPRAISAL FEE CHARGE, but when asked for any/all appraisals in Plaintiff's Specially Prepared Interrogatories, those appraisals were denied to even being in existence or ever being created by TD SERVICE COMPANY and yet they are attempting to bill almost $1,000 for these non-existent appraisals. Please see TO SERVICE COMPANY'S RESPONSES to Plaintiff's SPECIALLY PREPARED INTERROGATORIES numbers 7, 8, and 9 which were received by the Plaintiff from the Defendant's attorney on May 18,2011, some seven days after TD Service had billed for these non-existent appraisals.

Defendant's RESPONSES are NONSENSE AND UNETHICAL and are being made in bad faith simply to avoid responding to THE TRUTH OF THE MATTER ASSERTED. Or worse, in that TD Service Company Recorded a Notice of Default without having any legal authority to do so and is now liable to Plaintiff for Slander of Title. TD SERVICE COMPANY is on Notice of their legal violations under Civil Code sections 2923.5 and 2924.

A REQUEST FOR PRODUCTION OF DOCUMENTS IS BEING SERVED WITH THIS MEET AND CONFER LEITER AND GIVEN THAT DEFENDANT TD SERVICE COMPANY HAS ALREADY ADMITTED TO BEING IN POSSESSION OF CERTAIN DOCUMENTS THERE SHOULD BE NO CONTINUING NEED TO TAKE THEIR STATUTORILY PERMISSABLE TIME OF 35 DAYS TO COMPLY WITH THOSE DOCUMENT REQUESTS.

I respectfully request that Defendant TD SERVICE COMPANY provide me with clarification on both the "APPRAISAL ISSUES" and the "DECLARATION" that was "EXECUTED BYcJNIND1VlDUAL ON BEHALF OF WELLS FARGO BANK ON MARCH 17, 2011" along with the name, address, telephone and title of that INDIVIDUAL? If Defendant denies any of these requests, in part or in its entirety, I request that Defendant supplement its responses to form interrogatory 17.1, and state the reasons for the denial, if any. At all times hereto the request for admissions are from May 1, 2007 until the present.

This letter is being sent pursuant to my statutory obligation to "meet and confer" with you concerning the defects before bringing a motion to compel.

In order to avoid having this matter brought before the Court upon a motion to compel further responses to request for specially prepared interrogatories set no. 1, request for admissions, set no. one, and further responses to form interrogatory 17.1, and a request for monetary sanctions, I hereby request and require that you:

(1) You provide a full, complete, and unambiguous response to Form Interrogatories

PO BOX 1213, MALIBU, CA 90265-1213 PENDINGLAWSUIT@YAHOO.COM

TEL. 310.717.1790

BARRY So FAGAN

17.1, if your response to any of the request for admissions, special interrogatories or form interrogatories identified above are denied, and that your responses be verified and served not later than Thursday, May 26, 2011.

Alternatively, should TD SERVICE COMPANY declare that it needs more time to comply with Plaintiff's discovery demands, both parties can stipulate to halt this nonjudicial foreclosure until such time that compliance has occurred or when the Court determines that compliance must occur.

In the event that you should fail to comply with this request for clarification, and have made no other arrangements with me in this regard, please be advised that I will deem this present attempt at informal resolution to have been ineffective, and may thereafter proceed to Court and seek an order for monetary, evidentiary and/or termination sanctions. Such redress would be without prejudi etosuch additional and further rights and legal remedies as I may also consider pursue in this matter.

PO BOX 1213, MALIBU, CA 90265-1213 PENDINGLAWSUIT@YAHOO.COM TEL. 310.717.1790

- --~---. '""'"'.,.".._ ...

SINCE 1964

TD SERVICE COMPANY

May 10,2011

Barry Fagan

20475 Roca Chicha Dr. Malibu, CA 90265

Loan Number:

0999631666

TS Number: F525272

To Whom It May Concern:

Pursuant to your request, the following is a breakdown of the amount necessary to payoff the above

referenced loan "as of': June 9, 2011

Principal:

Interest (Per Diem, $72 I Per Day):

Appraisals:

Reconveyance Fee:

Property Presentation:

Late Fees:

I Fe at: & $987.00 $50.00 $14.00 iii 992?t

~

•• F ,.

$1,941.35

Sub Total:

T.D. Service Co. Fee's & Cost's:

Total Amount Owed:

If you intend to payoff the loan after the "as of' date shown above, please contact our office for updated figures. All funds must be in the form of a cashier's check or certified check and are subject to beneficiary's approval.

·Tt L £

Please have one check made payable to Wells Fargo Bank in the amount of:

Please have a second check made payable to T.D. Service Co. in the amount of:

$1,941.35

Please reference the T.S. Number on each check.

Sfl,ould you have any urther questions, please do not hesitate to call.

I I

Sint

(714) 543·TDSC (8372) llil (800) 843·0260 ., FAX: (714) 541·4130 III WWw'TDSF.COM

1820 E. FIRST STREET, SUITE 210, SANTA ANA, C~ 92705 IiJ p.o. BO)~ 11988. SANTA ANA r:». 9-;711.105>..<'

SINCE 1964

TD SERVICE COMPANY

May 9,2011

Barry Fagan

20475 Roca Chica Drive Malibu, CA 90265

Loan Number:

0999631666

TS Number: F525272

ToWhom It May Concern:

Pursuant to your request, the following is a breakdown of the amount necessary to reinstate the above

referenced loan "as of': June 9, 2011

$1; C $987.00 UP F

Past Due Payments:

Appraisal:

Property Preservation:

Late Charges:

• 6, i2U'

Sub Total:

T.D. Service Co. Fee's & Cost's:

Total Amount Owed:

$1,941.35

.......

If you intend to reinstate the loan after the "as of' date shown above, please contact our office for updated figures. All funds must be in the form of a cashiers check or certified check and are subject to beneficiary's approval.

• F £

Please have one check made payable to Wells Fargo Bank in the amount of:

Please have a second check made payable to T.D. Service Co. in the amount of:

$1,941.35

Please reference the T.S. Number on each check and have both checks sent to T.o. Service Co.

(714) 543-TDSC (8372) !O! (800) 843-0260 I'll FAX: (714) 541-4130 i!l WWW.TDSF.COM

1820 E. FIRST STREET. SUITE 210, SANTA ANA. CA 92705 If] p.o. BOX 11988. SANTA At--IA. C:A 9?711.10P.'"

2

RESPONSES TO SPECIALLY PREPARED INTERROGATORIES 1

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Lawrence 1. Dreyfuss, Bar No. 76277 THE DREYFUSS FIRM

A Professional Law Corporation 7700 Irvine Center Drive, Suite 710 Irvine, California 92618

(949) 727-0977; Facsimile (949) 450-0668

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Attorneys for Defendant T.D. Service Company

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SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES, WEST DISTRICT

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10 BARRY S. FAGAN, an individual; ) Case No.: SC112044
)
11 Plaintiff, )
12 vs. ) RESPONSES TO SPECIALLY PREPARED
) INTERROGATORIES
13 WELLS FARGO BANK, a national banking )
association; AMERICAN SECURITIES )
14 COMPANY; a California Corporation; T.D. )
15 Service Company; A California Corporation; )
EBERT APPRAISAL SERVICE INC., a )
16 California corporation; 20475 ROCA CHICA )
DR., MALIBU, CALIFORNIA 90625, real )
17 property, in rem, and DOES 1 to 50, )
18 INCLUSIVE, )
)
19 Defendants ) 20

PROPOUNDING PARTY: BARRY S. FAGAN

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RESPONDING PARTY:

T.D. SERVICE COMPANY

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SET NUMBER:

ONE (1)

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T.D. Service Company ("Responding Party") responds to propounding party Barry S.

Fagan's specially prepared interrogatories, set number one, under oath pursuant to code of Civil Procedure § 2033.010 et seq., as follows:

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RESPONSES TO SPECIALL Y PREPARED INTERROGATORIES 2

PRELIMINARY STATEMENT

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Responding Party has not fully completed its investigation of the facts relating to this case, has not completed its discovery in this action, and has not completed its preparation for trial. All of these responses are based only upon the information and documents presently available to and specifically known by Responding Party. It is anticipated that further discovery,

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independent investigation, legal research, and analysis will supply additional facts and add new meaning to the known facts, as well as establish entirely new factual conclusions and legal contentions, all of which may lead to the discovery of additional documents, further information and additional witnesses, thereby resulting in changes in and variances from the following

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responses.

If any information within the scope of the attorney-client privilege or the attorney work

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product doctrine is disclosed in these responses, Responding Party has not done so intentionally,

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and reserves its right to assert those privileges at any time in these proceedings, and further

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reserves the right to demand the return of all privileged information, including any copies or

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abstracts of that information. To the extent that this response might arguably waive an otherwise

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assertable objection or claim of privilege, such waiver shall be limited to this response only and

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shall not extend to any further discovery requests or subpoenas.

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INTERROGATORY NO. 1:

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Please IDENTIFY the owner of the SUBJECT PROPERTY as of the date of filing of the

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Notice of Default (NOD).

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RESPONSE TO NO.1:

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T.D. Service Company has no personal knowledge as to the identity of the owner of the

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Subject Property as of the date of the filing of the Notice of Default. According to the Trustee's

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2

RESPONSES TO SPECIALLY PREPARED INTERROGATORIES 3

--,-,------------,--------------------------------

Sale Guaranty obtained by T.D. in relation to the subject foreclosure, title of the property is

vested in Barry Fagan as trustee of the Barry Fagan Living Trust, dated November 20,2005.

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INTERROGTORYNO.2:

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DESCRIBE the basis for YOUR authority to institute a Non-Judicial Foreclosure action

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against Plaintiff.

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RESPONSE TO NO.2:

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T.D. Service Company was retained by Wells Fargo Bank, N.A. to be substituted in as

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trustee to process the nonjudicial foreclosure by power of sale contained within the Short Form

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Deed of Trust of record against the Subject Property. It was authorized by Wells Fargo Bank,

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N.A. to execute the Notice of Default as allowed by Civil Code § 2924, and was substituted in as

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trustee by substitution dated March 21, 2011.

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INTERROGATORY NO. 3:

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DESCRIBE your relationship to the Subject PROPERTY and state with particularity

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every fact and legal theory on which the Defendant relies on or will rely to support the allegation

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that each transfer made of Plaintiff's Deed of Trust along with the Note was legitimate.

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RESPONSE TO NO.3:

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This interrogatory is objected to as being compound and as containing improper subparts.

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Without waiving these objections, T.D. Service Company responds that it has no "relationship"

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to the Subject PROPERTY. It is the substituted trustee under the Deed of Trust. Further, T.D. i

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that capacity is only required to comply with the statutory framework contained within Civil

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Code § 2924 et seq., and it is not making any allegations regarding any transfers of the Deed of

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Trust or Note since those issues are outside the scope ofT.D. Service Company's responsibilities

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as substituted trustee.

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RESPONSES TO SPECIALLY PREPARED INTERROGATORIES 4

INTERROGATORY NO.4:

DESCRIBE and identify any party, person or entity known or suspected by T.D. Service

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Company or any of your officers, employees, independent contractors or other agents, or

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servants of your company who might possess or claim foreclosure rights under the subject loan

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or mortgage and/or note.

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RESPONSE NO.4:

8

The Deed of Trust indicates that Wells Fargo Bank, N.A. is the beneficiary, and T.D.

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Service Company is not aware of any other entities or persons claiming any right to act as

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beneficiary under that Deed of Trust. As substituted trustee, T.D. Service Company is entitled to

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process the nonjudicial foreclosure pursuant to the power of sale contained within the Short

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Form Deed of Trust.

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INTERROGTORY NO.5:

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DESCRIBE if any investor/certificate holder approve or authorize the initiation of

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foreclosure proceedings on Plaintiff's property? Describe who noticed the default, on whose

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instruction was the trustee instructed to act and what trustee or entity acted. Who held the

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security interest at the time the default was noticed? Who was responsible for ensuring

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California Code § 2923.5 requirements were satisfied prior to filing such documents.

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RESPONSE TO NO.5:

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This interrogatory is objected to as being compound and containing improper subparts.

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Without waiving these objections, T.D. responds that its dealings have solely been with Wells

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Fargo Bank, N.A. as beneficiary. T.D. Service Company processed the Notice of Default and

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caused it to be recorded on March 22,2011. In its capacity as beneficiary Wells Fargo Bank,

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N.A. would be responsible for satisfying the obligations contained within Civil Code § 2923.5.

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RESPONSES TO SPECIALL Y PREPARED INTERROGATORIES 5

INTERROGATORY NO. 6:

DESCRIBE your business relationship with American Securities Company and with

3

Wells Fargo Bank.

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RESPONSE TO NO.6:

6

This interrogatory is objected to as being compound, and as containing improper

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subparts. Without waiving these objections, T.D. Service Company responds that it has no

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"business relationship" with American Securities Company or with Wells Fargo Bank. Wells

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Fargo Bank, N.A. retained T.D. Service Company as substituted trustee to process the

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nonjudicial foreclosure.

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INTERROGATORY NO.7:

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DESCRIBE any and all Appraisals that YOU OR ANYONE ACTING ON YOUR

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BEHALF commissioned CONCERNING the SUBJECT PROPERTY within the past four (4)

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years.

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RESPONSE TO NO.7:

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Neither T.D. Service Company nor anyone acting on its behalf commissioned any

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appraisals of the SUBJECT PROPERTY within the past four years, or at all.

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INTERROGATORY NO.8:

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DESCRIBE any and all Appraisals that YOU OR ANYONE ACTING ON YOUR

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BEHALF received CONCERNING the SUBJECT PROPERTY within the past four (4) years.

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RESPONSE TO NO.8

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Neither T.D. Service Company nor anyone acting on its behalf received any appraisals of

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the Subject Property within the past four years, or at all.

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2

RESPONSES TO SPECIALLY PREPARED INTERROGATORIES 6

INTERROGATORY NO.9:

IDENTIFY each and every PERSON who has personal knowledge of any Appraisals

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YOU OR ANYONE ACTING ON YOUR BEHALF commissioned or received concerning the

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SUBJECT PROPERTY within the past four (4) years.

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RESPONSE TO NO.9:

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T.D. Service Company is not aware of any appraisals concerning the Subject Property

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within the past four years, or at all.

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INTERROGATORY NO. 10:

II

DESCRIBE each and every communication given by YOUR OR ANYONE ACTING

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ON YOUR BEHALF to PLAINTIFF concerning the SUBJECT PROPERTY from January 1,

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2011 to the present.

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RESPONSE TO NO.1 0:

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T.D. Service Company is not aware of any communications between plaintiff and T.D.

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Service Company with the exception of the service on plaintiff of the Notice of Default prepared

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by T.D. Service Company and the Substitution of Trustee whereby T.D. Service Company was

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substituted in as trustee to process the subject foreclosure. There have also been emails between

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plaintiff and T.D. Service Company's counsel, and these are ongoing.

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INTERRAGORYNO.ll:

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DESCRIBE each and every communication RECEIVED by YOU OR ANYONE

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ACTING ON YOUR BEHALF from PLAINTIFF relating to the SUBJECT PROPERTY from

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January 1,2011 to the present.

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RESPONSES TO SPECIALLY PREPARED INTERROGATORIES 7

RESPONSE TO NO. 11:

T.D. Service Company received from plaintiff a copy of the complaint with various

3

exhibits and the notice of pending action. There have also been exchanges of emails between

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plaintiff and counsel for T.D. Service Company, and these are ongoing.

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INTERROGATORY NO. 12:

7

IDENTIFY each and every DOCUMENT that embodies or memorializes, in whole or in

8

part, any communication between YOU OR ANYONE ACTING ON YOUR BEHALF and

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PLAINTIFF relating to the SUBJECT PROPERTY from January 1,2011 to the present.

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RESPONSE TO NO. 12:

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The documents embodying the communications consist of the Notice of Default, the

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Substitution of Trustee, the fax from plaintiff containing the complaint and other documents, and

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the emails between plaintiff and defense counsel.

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INTERROGATORY NO. 13:

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IDENTIFY each and every PERSON who has personal knowledge of any

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communication between YOU OR ANYONE ACTING ON YOUR BEHALF and PLAINTIFF

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relating to the SUBJECT PROPERTY from January 1,2011 to the present.

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RESPONSE TO NO. 13:

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Plaintiff is aware of the communications. Richard Stone and Lawrence Dreyfuss are

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aware of the communications between plaintiff and T.D.' s counsel. Frances DePalma, vice

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president of operations, and Cindy Gasparovic, trustee's sale officer, are aware of the

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documentation contained within the T.D. Service Company file including the Notice of Default

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and Substitution of Trustee.

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RESPONSES TO SPECIALLY PREPARED INTERROGATORIES 8

INTERROGATORY NO. 14:

IDENTIFY each and every PERSON (with the exception of expert and rebuttal

3

witnesses) that YOU intend to call as a witness to testify during the trial in the instant action, and

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for each PERSON, provide a brief statement concerning what the nature of that person's

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testimony will be at trial.

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RESPONSE TO NO. 14:

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This interrogatory is objected to as seeking information protected as attorney work

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product and as being premature. T.D. Service Company has not yet determined which witnesses

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it intends to call at trial or what issue, if any, may exist at trial, since the case is not currently at

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issue.

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INTERROGATORY NO. 15:

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IDENTIFY the name, address, telephone and title of the Declarant who executed the

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written "DECLARATION OF DEF AUL T AND DEMAND FOR SALE" as indicted in the

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March 22,2011 Notice of Default under recorded instrument number 20110427084.

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RESPONSE TO NO. 15:

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The declaration was executed on March 17, 2011 by an individual acting on behalf of

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Wells Fargo Bank. That person's name, title, and contact information are not included on the

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declaration.

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INTERROGATORY NO. 16:

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IDENTIFY the reason why the Plaintiffs original Wells Fargo Bank loan number

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65065058255341998 was changed in the March 22,2011 NOTICE OF DEFAULT recorded

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instrument number 20110427084 to loan number 0999631666 with a T.S. NO. F525272 CA

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code F.

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RESPONSES TO SPECIALLY PREPARED INTERROGATORIES 9

RESPONSE TO NO. 16:

T.D. Service Company objects to Interrogatory No. 16 as assuming facts which are not in

3

evidence or admitted. T.D. Service Company has no knowledge of plaintiffs original Wells

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Fargo loan number or whether it was changed, and if so, why. The loan number of 0999631666

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is the number listed on the case information report submitted by Wells Fargo Bank to T.D.

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Service Company when the file was referred for processing. The reference to TS No. F525272

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CA, Unit Code F refers to T.D. Service Company's own internal designation for this foreclosure

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file.

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INTERROGATORY NO. 17:

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IDENTIFY the true name, address and telephone number of Investor No. 175263872 as

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referenced to in the March 22,2011 Notice of Default recorded Instrument number

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20110427084.

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16

RESPONSE TO NO. 17:

17

T.D. Service Company has no information concerning the No. 175263872 included

18

within the Notice of Default. This was a number provided to T.D. Service Company by Wells

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Fargo Bank, N.A. when the file was opened, and T.D. Service Company is not aware of its

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significance.

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INTERROGATORY NO. 18:

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IDENTIFY the Title Policy number as written by American Title for Plaintiffs May

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2007 loan #6506505825534 1998 and further IDENTIFY the true name of the ENTITY that

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funded the Plaintiff s loan through the FED WIRE TRANSFER.

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2

Company's duties pursuant to the statutory framework contained within Civil Code § 2924 et

RESPONSE TO NO. 18:

T.D. Service Company has no information concerning any title policy underlying the

3

subject loan or wire transfer, and this information is beyond the scope ofT.D. Service

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6 seq.
7
8 DATED: May J~, 2011
9
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13 1040-2571
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15
16
17
18 THE DREYFUSS FIRM

A Professional Law Corporation

LA WREjl\JCE .

Attorneys for De a T.D. Service Company

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RESPONSES TO SPECIALLY PREPARED INTERROGATORIES 10

1

VERIFICATION STATE OF CALIFORNIA, COUNTY OF LOS ANGELES

I have read the foregoing Responses to Specially Prepa,red Interrogatories

and know its contents, o CHECK APPLICABLE PARAGRAPHS

c:J I am a party to this action. The matters stated in the foregoing document are true of my own knoWledge except as to

those matters which are statad on information and belief, and as to those matters I believe them to be true.

I}Q I am ~ an Officer CJ a partner 0 a of T. D. Service Company

,

a party to this action, and am authorlzed to make this verification for and on Its behalf, and I make this verification for that reason, I I I am informed and believe and on that ground allege that the matters stated In the foregoing document are true. I I The matters stated In the foregoing document are true of my own knowledgs, except as to those matters wh ieh are stated on information and belief, and as to those matters I believe them to be true.

o I am one of the attorneys for

2i party to this action. Such party is absent from the county of aforesaid where such attorneys have their offices, and I mak~ this verification for and on behalf of that party for that reason. I am informed and believe and on that ground allege that the matters stated in the foregoing document are true.

f""",A'

Executed on )"lav I /, 201 J. ,at ,:;,;S~a::=-n.!:.:t""a~~=4-- _

I declare under pe~alty of perjury under the laws of the State of CZ:~~~ "~:_)foregOI:g is ,true,:n~/correGL

Pa t r~ ck Dabl es z , ~~/'::;"I/!..:~:..,'£""'dd,~. ,""- ~'=":.....::;' _;v;.:-e~<'-:7"'t--- ---. _

iype or Print Name '---- Sjllnat e

.t_

, California.

PROOF OF SERVICE!'-=----

1D1aB (31 CCP RoYle"~ 5/11B8

STATE OF CALIFORNIA, COUNTY OF I am employed in the county of

I am over the age of 18 and not a party to the within action; my business address is:

, State of California,

On,

I served the foregoing document described as

_______________ ~ on in this action

o by placinq the true copies thereof enclosed in sealed envelopes addressed as stated on the attached mailing list:

o by placing 0 the original 0 a true copy thereof enclosed in sealed envelopes addressed as follows:

! lay MAIL

I I ~I deposited such envelope in the mail at , California,

The envelope was mailed with postage thereon fully prepaid.

~ As follows: I am "readily familiar" with the finm's practice of collection and processing correspondence for mailing, Under that practice it would be deposited with U,S. postal service on that same day with postage thereon fully prepaid at

California In the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposlt for mailing in affidavit

El(ecuted on , at I California.

o ""(BY PERSONAL SERVICE) I delivered such envelope by hand to the offices of the addressee.

Executed on , at , California,

C (State) 1 declare under penalty of perjury under the laws of the State of California that the above is true and correct,

o (Federal) I declare that I am employed in the office of a member of the bar of this court at whose direction the service was mads,

TyP8 or Prim Name

Signature

"(BY MAIL SIGNATURE MUST BE OF PERSON OE"OSITING ENV~~OPE IN MAIL. SLOT, 90X, DR gAG)

"(fOR peR80NA~ SERVICE SIGNATURI: MUST g. 'l'HAT Of' M!;SSEN~~F\)

So~~bs'

L;k.PlUs

Rov. 7/~9

VERIFICATION STATE OF CALIFORNIA, COUNTY. OF LOS ANGELES

I have read the foregoing Responses to Form Interrogatories

____________ -=~_---------------------- and know its contents.

CJ CHECK APPLICABLE PARAGRAPHS

D I am a party to this action. The matters stated in the foregoing document are true of my own knowledge except as to those matters which are stated on information and belief, and as to those matters I believe them to be true,

u£] I am W an Officer C a partner CJ a of T.D. Service Company

,

a party to this action, and am authorized to make this verification for and on its behalf, and I make this verlflcation for that

reason. D I am informed and ,believe and on that ground allege that the matters stated In the foregoing document are true. 0 The matters stated in the foregoing document are true of my own knowledge, except as to those matters which are stated on information and belief, and as to those matters I believe them to be true.

D I am one of the attorneys for

a party to this action. Such party is absent from the county of aforesaid where such attorneys have their offices, and I make this verification for and on behalf of that party for that reason. I am informed and believe and on that ground allege that the matters stated in the foregoing document are true.

Executed on May! 11 2011 . at San a A , California.

I declare under penalty of perjury under the laws of the State of C~~~h /h~~reg:~~2~e and correct

Patdck Dobiesz· / ~:.....'~.,;;.:(0:;.:;¥£_';:_. """-::7L-':,.L.:l:::_Y_..".,...--;;p~ _

Type or Print Name L //

PROOF OF SERVICEi~ ,

101:16 (3) CCP Ravlsad 51111l-8

STATE OF CALIFORNIA, COUNTY OF I am employed in the county of

i am over the age of 18 and not a party to the within action; my business address is:

, State of California.

On,

I served the foregoing document described as

________________ on in this action

o by pla.cing the true copies thereof enclosed in sealed envelopes addressed as stated on the attached mailing list:

CJ by placing D the original 0 a true copy thereof enclosed in sealed envelopes addressed as follows:

L lay MAIL

I "'I deposited such envelope in the mail at , California.

The envelope was mailed with postage thereon fully prepaid.

o As follows: I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing.

Under that practice it would be deposited with U.S. postal service on that same day with postage thereon fufiy prepaid at _________________ California in the ordinary course of business. I am aware that on motion of the

party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit.

Executed on , at , California.

L I "'*(BY PERSONAL SERVICE) , delivered such envelope by hand to the offices of the addressee.

Executed on , at , California.

LJ(State) I declare under penalty of perjury under the laws of the State of Califomia that the above is true and correct.

CJ (Federal) I declare that I am employed in the office of a member of thE! bar of this court at whose direction the service was made.

Type Dr Print Name

Signature

'(SY MAIL SIGNATUr..E MUST BE OF PERSON DEPOSITING ENVELope IN MAIL SLOT, !lOX, OR BAG)

',(FO!\ F'ERSONAL SI:RVlCE SIGI"JAiURE MUST BE. TI;IIT OF ME:SS!!NGER)

So~~~lSce.Pfhs

Rev. 7188

VERtFICA TtON STATE OF CALIFORNIA, COUNTY OF LOS ANGELES

I have read the 'Foregoing R.esponses to Reauests for Admission

____________ --==~----------------------- and know its contents.

D CHECK APPLICABLE PARAGRAPHS

i I I am a party to this action. The matters stated in the foregoing document are true of my own knowledge except as to those matters which are stated on information and belief, and as to those matters I believe them to be true.

r .x. I I am GJ an Officer Cl a partner CJ a of T. D. Servi ce Company

----------------------------------------~~-~--~~~-~~~~-.- '

a party to th is action, and am authorized to make this verification for and on its behalf, and I make this verification for that

reason. 0 I am informed and believe and on that ground allege that the matters stated in the foregoing document are true. D The matters stated in the foregoing document are true of my own knowledge, except as to those matters which are statso on information and belief. and as to thosa matters I believe them to be true.

. ':::=J I am one of the attorneys for

a party to this action, Such party is absent from the county of aforesaid where such attorneys have their offices, and I make' (his verification for and on behalf of that party for that reason. I am informed and believe and on that ground allege that the matters stated In the foregoing document are true.

Executed on May Ii r 2011 ,at santa Ana, , California.

I declare under penalty of perjury under the laws of the State of Cal'Aiafh~!)he foregOin_9 is true and correct

t> /J~ r--'/ ;

Pat:r i c k Dab i e § z I((_:.__/_".;/_.,.,.~"",-~. --'ii'~~'-'o' "":;_...Z""·"?£,"" .... o......,.o~,..__--------

Type or Print Name Slg,;atur

PROOF OF SERVICEi' /' .17

10130 (3) cep Iil~vlo'ld 511IBB -_./~. -

STATE OF CALIFORNIA, COUNTY OF I am employed in the county of

! am over the age of 18 and not a party to the within action; my business address is:

, state of Califomia_

On,

I served the foregoing document described as

__________________ on in this action

I by placing the true copies thereof enclosed in sealed envelopes addressed as stated on the attached mailing list;

o by placing CJ the original 0 a true copy thereof enclosed in sealed envelopes addressed as follows:

DGYMA1L

D '" deposited such envelope in the mail at , California.

The envelope was mailed with postage thereon fully prepaid,

o As IOl[OWS: I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing, Under that practice it would be depos1ted with U.S. postal service on that same day with postage thereon fully prepaid at

California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit.

Executed on i at , California_

CJ '''(BY PERSONAL SERVICE) I delivered such envelope by hand to the offices of the addressee,

E::.;ecuted on , at , California

D (State) I declare under penalty of perjury under the laws of the State of California that the above is true and correct,

LJ (Federal) I declare that I am employed in the office of a member of the bar of this court at Whose direction the service was made.

Type or Print Name

Signature

"[BY MAIL SIGNATURE MUS't BE o~ PERSON OEP051TING I;NVELOPE IN MIlIL S~OT. 90X, OR 9AG)

"(!'OR PERSONAL seFMCI! SIGNATUR" MUST as T~IAT OF MI!SScNGER)

Sofu~s. Rev. 7199

~LMUs

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