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81294-00002/2194154.12


EX PARTE APPLICATION TO ENJ OIN WITNESS AND COUNSEL INTIMIDATION

BERTRAM FIELDS (SBN 024199)
BFields@ggfirm.com
PIERCE ODONNELL (SBN 081298)
PODonnell@GreenbergGlusker.com
MARC M. STERN (SBN 126409)
MStern@GreenbergGlusker.com
AARON J . MOSS (SBN 190625)
AMoss@GreenbergGlusker.com
GREENBERG GLUSKER FIELDS CLAMAN &
MACHTINGER LLP
1900 Avenue of the Stars, 21st Floor
Los Angeles, California 90067-4590
Telephone: 310.553.3610
Fax: 310.553.0687
Attorneys for Trustee
ROCHELLE H. STERLING


SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES
In the Matter of
THE STERLING FAMILY
TRUST.
Case No. BP 152858
EX PARTE APPLICATION TO ENJOIN
DONALD T. STERLING AND HIS
COUNSEL FROM INTIMIDATION OF
WITNESSES AND COUNSEL
[C.C.P. 525, 526, 527; Cal. Rule of Court
3.1200 et seq.]
[[PROPOSED] ORDER AND
DECLARATIONS OF MERIL SUE
PLATZER, M.D., J AMES EDWARD SPAR,
M.D., PIERCE ODONNELL AND AARON J .
MOSS FILED CONCURRENTLY
HEREWITH]

Date: J une 19, 2014
Time: 8:30 a.m.
Dept.: 5 (Room 260)


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81294-00002/2194154.12
1

EX PARTE APPLICATION TO ENJ OIN WITNESS AND COUNSEL INTIMIDATION

EX PARTE APPLICATION
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE THAT Greenberg Glusker Fields Claman & Machtinger,
LLP (Greenberg Glusker), counsel for Petitioner Rochelle H. Sterling (Petitioner), will
appear on J une 19, 2014, at 8:30 a.m. in Department 5 of the above-entitled court, located at 111
N. Hill St., Los Angeles, California, and apply, ex parte, for an Order enjoining Donald T.
Sterling (Donald) and his counsel from: (1) directly or indirectly threatening, harassing and/or
intimidating any trial witness for Petitioner, including but not limited to Drs. J ames Edward Spar,
Meril S. Platzer and Stephen L. Read; and (2) directly or indirectly threatening, harassing and/or
intimidating Pierce ODonnell or any other lawyer or employee of the Greenberg Glusker law
firm. This ex parte application is made pursuant to California Code of Civil Procedure 525,
526, and 527 et seq. and California Rule of Court 3.1200 et seq.
Trial on this matter is currently set for J uly 7, 2014. Good cause exists for the Order
based upon the following:
1. Petitioners counsel has learned that Donald left threatening voicemail messages
last week for Dr. J ames Edward Spar and Dr. Meril S. Platzer, the two doctors who recently
examined Donald and certified that he was incapacitated. On Monday, J une 9, 2014, Donald
menacingly warned Dr. Platzer that Im gonna see that you lose your license and that Im
going to sue you for a large sum, I guarantee you. He then left a profanity-laden message for
Dr. Spar threatening to have you lose your license and get you fired, telling Dr. Spar to have
your insurance company call me, and stating Ill show you what I think of you when I see you
in court! The next day, Donalds counsel Bobby Samini followed up with a letter to each of
these doctors, accusing them of being part of a conspiracy, and threatening them with litigation
seeking damages for your illegal conduct. Mr. Samini demanded that the doctors stop
communicating with anyone other than Donald about Donalds medical condition,
notwithstanding that this would prevent them from testifying as witnesses in this case. Moreover,
Mr. Samini made these threats despite being well aware that Donald had explicitly waived all
doctor-patient confidentiality and privacy in connection with his mental evaluation. These are
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81294-00002/2194154.12
2

EX PARTE APPLICATION TO ENJ OIN WITNESS AND COUNSEL INTIMIDATION

clear-cut attempts to intimidate the key witnesses in this case and dissuade them from testifying
truthfully.
2. On J une 9, Donald also called Petitioners counsel, Pierce ODonnell, with
Mr. Samini on the line. On that call, Donald threatened to sue everyone, including
Mr. ODonnell personally, and vowed he was going to spend whatever money he has to litigate
just to make Mr. ODonnells life miserable. Amidst a slew of expletives directed at
Mr. ODonnell, Donald shouted I am going to take you out ODonnell! which Mr. ODonnell
understood to mean that Mr. Sterling would kill him or have him killed.
3. With the trial in this case scheduled to begin in less than three weeks, and in order
to preserve the integrity of the judicial process and ensure a fair trial, Petitioner respectfully
requests that the Court address this matter on an ex parte basis and enjoin Donald and his counsel
from: (1) directly or indirectly threatening, harassing and/or intimidating any trial witness for
Petitioner, including but not limited to Drs. J ames Edward Spar, Meril S. Platzer and Stephen
Read; and (2) directly or indirectly threatening, harassing and/or intimidating Pierce ODonnell or
any other lawyer or employee of the Greenberg Glusker law firm.
Pursuant to Rule of Court 3.1203, and as set forth in the accompanying Declaration of
Aaron J . Moss (Moss Decl.), Petitioners counsel provided both telephonic and written notice
of this application to counsel for Donald T. Sterling prior to 10:00 a.m. on Wednesday, J une 18,
2014:

Maxwell M. Blecher, Esq.
Blecher Collins Pepperman & J oye
515 South Figueroa Street, Suite 1750
Los Angeles, CA 90071
(213) 622-4222
mblecher@blechercollins.com

Bobby Samini, Esq.
Samini Scheinberg, P.C.
949 South Coast Drive, Suite 420
Costa Mesa, CA 92626
(949) 724-0900
bsamini@saminilaw.com

See Moss Decl., 7, Exh. 15. Counsel for interested party Steven A. Ballmer waived notice. Id.,
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Exh. 16.
This Ex Parte Application is based upon the Application, the attached Memorandum of
Points and Authorities, the supporting declarations of Dr. James Edward Spar, Dr. Meril S.
Platzer, Pierce O'Donnell and Aaron J. Moss filed concunently herewith, the accompanying
exhibits, all pleadings and papers on file in this action, and on such other oral and documentary
evidence and argument as may be presented at or before the hearing on this Application.
DATED: June 19,2014
8r294-000a221.94154.12
GREENBERG GLTJSKER FIELDS CLAMAN
&MACHTIN
AARONW{OSS(S e062s)
Attorneys for Trustee Rochelle H. Sterling
EX PARTE APPLICATION TO ENJOIN WITNESS AND COLINSEL INTIMIDATION
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81294-00002/2194154.12
1

EX PARTE APPLICATION TO ENJ OIN WITNESS AND COUNSEL INTIMIDATION

MEMORANDUM OF POINTS AND AUTHORITIES
I. INTRODUCTION
Desperate to regain his position as a Trustee of the Sterling Family Trust (the Trust),
Donald T. Sterling (Donald) and his attorney have resorted to intimidating doctors who will be
key witnesses in this proceeding, which will establish that Donalds removal as a Trustee
complied with the provisions of the Trust. Last week, Donald and his counsel sent threatening
voicemail messages and letters to the physicians who examined Donald and certified that he was
incapacitated. These are the very witnesses whose testimony will be used by Petitioner Rochelle
H. Sterling (Petitioner) to validate Donalds removal as a Trustee of the Trust and to confirm
the $2 Billion sale of the Los Angeles Clippers basketball team. A more direct assault on the
integrity of the judicial system is difficult to imagine.
On Monday, J une 9, 2014, Donald left a voicemail message for Dr. Meril Platzer in which
he accused her of being involved in a conspiracy to find that [he] was incompetent and
promised that Im gonna see that you lose your license . . . . Im going to sue you for a large
sum, I guarantee you. Minutes later, Donald left a voicemail for Dr. J ames Spar. He called him
a stupid fucking doctor, and threatened to have you lose your license and get you fired. He
told Dr. Spar to have your lawyer and your insurance company call me, and stated Ill show
you what I think of you when I see you in court! Audio recordings and written transcripts of
these voicemails are attached as Exhibits 1 and 2 (Dr. Platzer) and Exhibits 4 and 5 (Dr. Spar) to
the concurrently filed declarations.
Also on J une 9, Donald telephoned Petitioners counsel, Pierce ODonnell. Among his
statements in a profanity-laden tirade, Donald shouted I am going to take you out ODonnell!
which Mr. ODonnell understood to mean that Mr. Sterling would kill him or have him killed.
Declaration of Pierce ODonnell (ODonnell Decl.), 9.
This campaign of intimidation is not limited to Donald, but has been joined by his
counsel, Bobby Samini. Mr. Samini was on the phone during Donalds J une 9 call to
Mr. ODonnell. Then, on J une 10, 2014, the day after Donald made his threatening phone calls to
the physicians who deemed him to be incapacitated, Mr. Samini sent letters to each of these
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81294-00002/2194154.12
2

EX PARTE APPLICATION TO ENJ OIN WITNESS AND COUNSEL INTIMIDATION

doctors. See Exh. 3 (letter to Dr. Platzer) and Exh. 6 (letter to Dr. Spar). In those letters,
Mr. Samini accused Drs. Spar and Platzer of committing interference with prospective economic
advantage as part of a conspiracy and threatened them with litigation seeking damages for your
illegal conduct. Id. Mr. Samini also instructed both doctors to have no further communication
with anyone concerning Mr. Sterlings medical condition . . . without his prior written consent.
Id. As discussed below, Mr. Saminis letters ignored that Donald had explicitly waived, in
writing, any applicable doctor-patient privilege or confidentiality expectations in connection with
the medical evaluations relating to his service as a Trustee of the Trust.
With the J uly 7, 2014, trial date in this matter less than three weeks away, Petitioner seeks
the ex parte assistance of this Court to prevent such improper tactics in this proceeding. Had
Donalds threats been made a day later, after this proceeding had been instituted, they would have
been a textbook example of criminal witness intimidation. See Penal Code 136.1 (prohibiting
anyone from preventing or attempting to prevent or dissuade any witness from attending or giving
testimony at any trial or proceeding). Donald and his lawyer instructed Drs. Spar and Platzer not
to say anything about Donalds condition to anyone besides Donald an instruction which, if
followed, would obviously prevent them from preparing for or participating in the upcoming trial
on this matter. These demands were backed up with threats of lawsuits and the loss of jobs and
professional licenses and were clearly designed to dissuade the doctors from testifying or to
recant their previous evaluations of Donald.
This Court should exercise its broad inherent powers to protect the affected individuals
and the integrity of the judicial process. Donald and his lawyers should be ordered to refrain
from harassing, threatening and/or intimidating Petitioners witnesses, including Drs. Spar,
Platzer and Read. In addition, the Court should order Donald to refrain from harassing,
threatening, and/or intimidating Pierce ODonnell or any lawyer or employee of the Greenberg
Glusker law firm.

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81294-00002/2194154.12
3

EX PARTE APPLICATION TO ENJ OIN WITNESS AND COUNSEL INTIMIDATION

II. BACKGROUND FACTS
A. Relevant Provisions of the Trust
Doctors Spar, Platzer and Read are the key witnesses in this case, which concerns the
propriety of Donalds removal as a Trustee of the Trust. Paragraph 7.5.c. of the Trust provides:
Any individual who is deemed incapacitated, as defined in
Paragraph 10.24., shall cease to serve as a Trustee of all trusts
administered under this document. Each individual who agrees to
serve as a Trustee of any trust administered under this document
(A) shall cooperate in any examination reasonably appropriate to
carry out the provisions of this Paragraph 7.5.c., (B) waives the
doctor-patient and/or psychiatrist-patient privilege with respect to
the results of such examination, and (C) shall allow a Co-Trustee
or the Current Beneficiaries of the trust to review the individuals
individually identifiable health information or other medical
records, waiving any privacy rights governed by the Health
Insurance Portability and Accountability Act of 1996, 42 U.S.C.
1320d (HIPAA), and the regulations thereunder, including 45
C.F.R. 160-164, to the extent required to implement this
Paragraph 7.5.c. An individuals obligation to comply with the
provisions of this Paragraph 7.5.c. is specifically enforceable.
Exh. 8, 7.5.c. (emphasis added).
Paragraph 10.24. defines incapacity, and derivations thereof, and provides that [a]n
individual shall be deemed to be incapacitated if . . . two licensed physicians who, as a regular
part of their practice are called upon to determine the capacity of others, and neither of whom is
related by blood or marriage to any Trustee or beneficiary, examine the individual and certify in
writing that the individual is incapacitated. Exh. 9 (emphasis added). Paragraph 7.5.c. of the
Trust, quoted above, includes language waiving an individual Trustees privilege and privacy
rights for purposes of determining whether the individual is incapacitated and ceases to serve as a
Trustee. Exh. 8. When the Trust was restated on December 18, 2013, Donald and Petitioner both
signed the Acceptance by Trustee, which expressly acknowledges this waiver. Exh. 10.
1



1
The Acceptance By Trustee states, The undersigned hereby accept the office of Trustee and
agree to serve in accordance with the terms and conditions of service as set forth in this
document, specifically including those terms and conditions of service imposed pursuant to
Paragraph 7.5.c. Exh. 10 (emphasis added).
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81294-00002/2194154.12
4

EX PARTE APPLICATION TO ENJ OIN WITNESS AND COUNSEL INTIMIDATION

B. Determination of Donalds Incapacity
Donald, who is 80 years old, was examined by Dr. Meril S. Platzer on May 19, 2014, and
by Dr. J ames Edward Spar on May 22, 2014. Declaration of Dr. Meril Sue Platzer, M.D.
(Platzer Decl.) at 3; Declaration of Dr. J ames Edward Spar, M.D. (Spar Decl.) at 3. Both
Dr. Platzer and Dr. Spar are licensed physicians who, as a regular part of their practice, are called
upon to determine the capacity of others, and both Dr. Platzer and Dr. Spar are board-certified by
the American Board of Psychiatry and Neurology. Platzer Decl., 2-3; Spar Decl., 2.
Following their examinations of Donald, both Dr. Platzer and Dr. Spar certified in writing
that Donald was incapable of carrying out the duties as a Trustee of the Trust. Exh. 12 (Dr.
Platzer certification); Exh. 13 (Dr. Spar certification). Dr. Stephen L. Read is also board-certified
by the American Board of Psychiatry and Neurology and specializes in geriatric psychiatry and
has frequently been appointed by courts to determine capacity. Dr. Read has confirmed the
methodology and conclusions of Drs. Spar and Platzer. Exh. 14.
Pursuant to Paragraph 7.5.c. of the Trust, Donald ceased serving as a Trustee of the Trust
on May 29, 2014, when the second of the two licensed physicians written certifications of his
incapacity was issued and received by Petitioner. Exh. 8, 7.5.c. Petitioner, through her counsel,
promptly delivered notice of Donalds removal as a Trustee of the Trust to Donald, through his
counsel, on May 29, 2014 (the May 29 Notice). Exh. 7. The May 29 Notice, which included a
full copy of the Trust, specifically identified Drs. Spar and Platzer as having certified that Donald
was incapable of carrying out his duties as Trustee of the Trust. Id.

C. Donalds Attempts to Intimidate the Testifying Doctors
On Monday, J une 9, 2014, Donald left a threatening voicemail for Dr. Platzer. Exhs. 1, 2.
Introducing himself as Donald Sterling, attorney, Donald stated that Dr. Platzer was nothing
but a fraud and a liar and a cheat. Id. He said Im going to see that you lose your license and
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Im suing you for conspiracy, so have your lawyer call me . . . . Im going to sue you for a large
sum, I guarantee you.
2
Exhs. 1, 2.
Minutes later, Donald left a similar voicemail for Dr. Spar. Donald began the message by
stating Im going to leave my name, Donald Sterling . . . and Im going to have you lose your
license. Exhs. 4, 5. Donald then accused the doctor of participating in a conspiracy and
instructed the doctor to have your lawyer and your insurance company call me. Id. Donald
also threatened to get you fired . . . because youre nothing but a tramp. Id. Finally, Donald
stated Ill show you what I think of you when I see you in court. Have your insurance company
call me. My name is Donald Sterling in case youve forgotten. Id.
On J une 10, 2014, Donalds counsel, Bobby Samini, sent letters to Drs. Spar and Platzer
(Exhs. 3, 6), in which he instructed them to have no further communication with anyone
concerning Mr. Sterlings medical condition . . .without his prior written consent. Mr. Saminis
letters also alleged that Drs. Spar and Platzer are part of a conspiracy, and threatened them with
litigation seeking damages for your illegal conduct. Id. Mr. Saminis letters ignore that Donald
waived any applicable doctor-patient privilege or confidentiality pursuant to Paragraph 7.5.c. of
the Trust, a provision that Donald specifically acknowledged in a signed writing, and a copy of
which Petitioners counsel had provided to Donalds counsel Maxwell Blecher over a week
earlier as part of the May 29 Notice. Exhs. 7, 8. Furthermore, the day before Mr. Samini sent his
letters to Drs. Spar and Platzer accusing them of breaching confidentiality, Mr. ODonnell had
sent Mr. Samini an email informing him that Donald had expressly waived any doctor-patient
privilege and confidentiality under Paragraph 7.5.c. of the Trust and that Donalds signed
acceptance of the Trust included an agreement to be subject to the provisions of Paragraph 7.5.c.
Exh. 11. Indeed, Mr. ODonnells email was sent in response to Mr. Saminis specific demand
that Petitioner provide evidence of any written consent provided by Donald Sterling which
would allow the release of his medical records to your firm (or any other third party.) Exh. 11.

2
The Court should note that a second persons voice can be heard in Donalds voicemail to
Dr. Platzer. While the identity of that person is unknown, he or she appears to be prompting
Donald.

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81294-00002/2194154.12
6

EX PARTE APPLICATION TO ENJ OIN WITNESS AND COUNSEL INTIMIDATION

D. Donalds Attempt to Intimidate Petitioners Counsel
On Monday J une 9, Donald Sterling called Petitioners counsel, Pierce ODonnell, at his
office, with Mr. Samini on the line. ODonnell Decl., 6. Donald shouted profanities at
Mr. ODonnell before screaming, I am going to take you out, ODonnell! Id. at 7-9.
Mr. ODonnell understood Donalds words to mean that Donald threatened to kill him or have
him killed. Id. at 9.

III. ARGUMENT
A. Justice Requires that this Court Enjoin Donald and his Attorneys from any
Further Attempts to Threaten, Intimidate or Influence the Testimony of
Witnesses.
The harassment or intimidation of witnesses harms members of the public and threatens
the integrity of the judicial process. Donald and Mr. Saminis improper tactics demand swift and
decisive action by this Court. Donalds phone calls and Mr. Saminis letters were clearly
intended to harass and intimidate Drs. Spar and Platzer (as well as Mr. ODonnell). It is clear
from Petitioners initial Ex Parte Petition filed on J une 11 that Drs. Spar and Platzer will be key
witnesses in this proceeding. By instructing Drs. Spar and Platzer to have no further
communication with anyone concerning Mr. Sterlings medical condition, (Exhs. 3, 6) Donald
and Mr. Samini unambiguously sought to preclude those physicians from preparing for trial with
the assistance of either their own counsel or Petitioners counsel. The clear implication of
Donalds and Mr. Saminis communications is that, in order to avoid the wrath of a litigious
billionaire, Drs. Spar and Platzer should either not testify at all, or should testify in a manner
beneficial to Donald. This is a patent attempt to preclude Petitioner from carrying out her duties
under Probate Code 15622, 16000, 16007 and 16013(b) and from establishing on J uly 7 that all
proper procedures were followed in connection with the removal of Donald as a Trustee of the
Trust.
In addition to threatening testifying witnesses, Donald threatened to kill Mr. ODonnell, or
have him killed. ODonnell Decl., 9. Regardless of whether Donalds threat to take out
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81294-00002/2194154.12
7

EX PARTE APPLICATION TO ENJ OIN WITNESS AND COUNSEL INTIMIDATION

Mr. ODonnell was meant in earnest, it cannot be doubted that Donald has both the means and the
stature to arrange for an act of violence. Given the extremity of Donalds recent conduct, his
threat is a serious matter and should be treated as serious by this Court.
Threatening and/or intimidating a witness is a crime. Penal Code 136.1 makes it illegal
where a person knowingly or maliciously prevents or dissuades [or attempts to prevent or
dissuade] any witness or victim from attending or giving testimony at any trial, proceeding, or
inquiry authorized by law. Moreover, California law is clear that [i]f the defendants actions or
statements are ambiguous, but reasonably may be interpreted as intending to achieve the future
consequence of dissuading the witness from testifying, the offense has been committed. People
v. Wahidi (2013) 222 Cal.App.4th 802, 806, citing People v. Ford (1983) 145 Cal.App.3d 985,
989-990.
3
Furthermore, where a member of the California bar participates in dissuading a
witness from testifying at a civil trial, he or she commits a violation of Penal Code 136.1. See
Holmes, 145 Cal.App.3d at 942-43.
This Court has broad discretion to fashion a remedy to prevent Donald and his counsel
from attempting to compromise the fairness of the J uly 7 trial. Code of Civil Procedure (CCP)
526 allows for an injunction when it appears by [] affidavits that the commission or
continuance of some act during the litigation would produce . . . great or irreparable injury to a
party to the action or where the obligation arises from a trust. CCP 526(a)(2). CCP 527
allows for a preliminary injunction where affidavits show that sufficient grounds exist therefor.
A preliminary injunction can be granted absent a noticed motion where [i]t appears from facts
shown by affidavit [] that great or irreparable injury will result to the applicant before the matter
can be heard on notice. CCP 527.
Moreover, courts have inherent power to exercise reasonable control over all
proceedings connected with pending litigation . . . in order to insure the orderly administration of
justice. Rutherford v. Owens-Illinois, Inc. (2007) 16 Cal.4th 953, 967. See also CCP 177

3
This statute applies where a party attempts to dissuade a witness from offering testimony in a
civil proceeding. See Penal Code136(2)(ii), (iv) & (v); see also In re Holmes (1983) 145
Cal.App.3d 934, 937, 942-43.
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81294-00002/2194154.12
8

EX PARTE APPLICATION TO ENJ OIN WITNESS AND COUNSEL INTIMIDATION

(Every judicial officer shall have power to preserve and enforce order. . . in proceedings before
him . . . .); Probate Code 17001. This inherent authority allows courts to fashion remedies as
necessary to protect litigants rights. Slesinger v. Walt Disney Co. (2007) 155 Cal.App.4th 736,
762 (finding that where a partys deliberate and egregious misconduct in the course of litigation
renders sanction short of dismissal inadequate to protect the fairness of trial, California courts
necessarily have the power to preserve their integrity by dismissing the action); see also Bd. of
Supervisors v. Superior Court (1994) 23 Cal.App.4th 830, 848; Peat, Marwick, Mitchell & Co. v.
Superior Court (1988) 200 Cal.App.3d 272, 287-289 (affirming order precluding evidence in
order to preserve the integrity of the judicial process where one partys interference with a third
party witness was an abuse of the litigation process).
The attempts to influence Drs. Spar and Platzer by Donald and his counsel threaten great,
irreparable and imminent injury to Petitioners claims. CCP 526, 527. If this conduct is not
immediately and decisively redressed, Drs. Spar and Platzer, along with Mr. ODonnell, will
continue to live in fear of the repercussions. Donald and Mr. Samini have threatened the careers
and livelihoods of Drs. Spar and Platzer. As set forth in her declaration, Dr. Platzer understands
the recent communications of Donald and Mr. Samini as an attempt to bully her into changing
my opinion regarding Mr. Sterlings incapacity. Platzer Decl., 6. Dr. Spar likewise believes
these communications were for the purpose of trying to get me to recant or withdraw my
conclusions regarding Mr. Sterlings mental state. Spar Decl., 8. Mr. ODonnell understands
Donalds threat to take him out as meaning that Donald was going to kill him or have him
killed. ODonnell Decl., 9. Such abuse must be stopped.

IV. CONCLUSION
The Court should do everything in its power to ensure that Drs. Spar and Platzer,
Mr. ODonnell, and all of the participants at the J uly 7 trial may prepare for and testify at trial
without any concern for their lives or livelihoods.
WHEREFORE Petitioner respectfully requests an Order:
1. Enjoining Donald T. Sterling and his counsel from directly or indirectly
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threatening, harassing and/or intimidating any trial witness for Petitioner, including but not
limited to Drs. James Edward Spar, Meril S. Platzer and Stephen Read;
2. Enjoining Donald T. Sterling and his counsel from directly or indirectly
threatening, harassing and/or intimidating Pierce O'Donnell or any other lawyer or employee of
the Greenberg Glusker law firm; and
3. For such further Orders as this Court deems appropriate.
DATED: June 19,24ru GREENBtrRG GLIJSKER FIELDS CLAMAN
Sterling
8 r29 4 -000 02 /2 19 4 | s 4 . 12
& MACHTNGERLLP /
AARON J:-I\4OSS ( te062s)
Attorneys for Trustee Rochelle H.
EX PARTE APPLICATION TO ENJOIN WITNESS AND COLTNSEL INTIMIDATION