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George Sharp
3525 Del Mar Heights Road, #620
San Diego, CA 92130
(310) 498-4455
(619) 446-6717 fax

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In Propria Persona
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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COUNTY OF SAN DIEGO, CENTRAL DIVISION
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GEORGE A. SHARP,
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)
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Plaintiff,
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v.
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STOCKTIPS.COM, AMERADA CORP.,
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LALUNA SERVICES, INC., TELUPAY
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INTERNATIONAL, INC., ECRYPT
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TECHNOLOGIES, INC., ALKAME
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HOLDINGS, INC., WELL POWER, INC.,
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TIGER OIL AND ENERGY, INC.,
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COASTAL INTEGRATED SERVICES, INC., )
EMPIRE STOCK TRANSFER, INC.,
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QUICKSILVER STOCK TRANSFER, INC., )
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ROBERT BANDFIELD, AWEBER
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SYSTEMS, INC. ADRIAN HERMAN
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THOMAS, HAROLD GEWERTER and
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DOES 8 through 500, inclusive,
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Defendants.
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_____________________________________ )
)

Case No. 37-2015-0008210-CU-NP-CTL
(Assigned for all purposes to Hon. Timothy
Taylor)
PLAINTIFF GEORGE SHARP’S
NOTICE OF MOTION AND MOTION
TO COMPEL FURTHER RESPONSES
TO REQUESTS FOR PRODUCTION OF
DOCUMENTS, SET TWO FROM
DEFENDANT COASTAL INTEGRATED
SERVICES; MEMORANDUM OF
POINTS AND AUTHORITIES;
DECLARATION OF GEORGE SHARP
IN SUPPORT THEREOF

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

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TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:

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PLEASE TAKE NOTICE that, on August 5, 2016 at 1:30 p.m. or as soon thereafter as

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counsel may be heard in Department 724 of the above-entitled court located at 330 W.

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Broadway, San Diego, California 92101, Plaintiff George Sharp (“Plaintiff”) will move the

-1MOTION TO COMPEL FURTHER RESPONSES, SET TWO

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

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Propounded to Defendant COASTAL INTEGRATED SERVICES, INC. (hereinafter “RPDs”),

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Requests Nos. 2 through 16 as set forth in the separate Statement of RPDs and Responses in

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

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

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filing of this motion to compel further responses.

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

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

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

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

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

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

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the time of hearing.

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Dated: May 24, 2016

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By.
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______________________________
George Sharp
In Propria Persona

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-2MOTION TO COMPEL FURTHER RESPONSES, SET TWO

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MEMORANDUM OF POINTS AND AUTHORITIES
1.

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

Defendant made identical blanket objections to each request.
Upon receipt of the Defendant’s responses, Plaintiff immediately attempted to meet and

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

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

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

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

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

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

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2.

SUMMARY OF RELEVANT FACTS

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

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

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

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

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for the divesture by the Defendants at over inflated prices.

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

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

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

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

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

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

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

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transmission of unsolicited commercial emails, and therefore irrelevant,

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immaterial, and not reasonably calculated to lead to the discovery of admissible

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evidence. Responding Party declines the request.

-3MOTION TO COMPEL FURTHER RESPONSES, SET TWO

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

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counsel. (Decl. Sharp ¶ 4; Exhibit “C” April 12, 2016 Request to Meet and Confer) The

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courtesy of a response was not received.

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

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

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

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

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

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Because defense counsel has failed to provide sufficient responses or to produce the
requested documents, this motion to compel further responses was necessary.

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3.

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

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

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Motion should be granted.

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A.

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Code of Civil Procedure section 2017.010 states, in part:

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

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

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

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

Plaintiff Has a Right to Discovery from Defendant

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

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“The civil discovery statutes are ‘intended to accomplish the following results’ (1) to give

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greater assistance to the parties in ascertaining the truth and in checking and preventing perjury;

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(2) to provide an effective means of detecting and exposing false, fraudulent and sham claims

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and defenses; (3) to make available, in a simple, convenient and inexpensive way, facts which

-4MOTION TO COMPEL FURTHER RESPONSES, SET TWO

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

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of trial as to the real value of their claims and defenses, thereby encouraging settlement; (5) to

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expedite litigation; (6) to safeguard against a surprise; (7) to prevent delay; (8) to simplify and

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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Defendant Has Failed to Sufficiently Respond to Plaintiff’s RPDs

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B.

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

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

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

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

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Code Civ. Proc. § 2031.210(a).

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An agreement to comply must state that the production and inspection demanded will be

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allowed (in whole or in part) and that the documents or things in the responding party’s

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possession, custody, or control will be produced. Code Civ. Proc. § 2031.220. In addition,

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“compliance” is satisfied by producing the documents either as they are kept in the usual course

-5MOTION TO COMPEL FURTHER RESPONSES, SET TWO

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

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

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

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

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

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

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

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

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(1990).

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

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

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

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These responses and the refusal to produce documents are insufficient and require an
order compelling further responses and documents.
Moreover, none of Defendant’s written responses to the RPDs at issue comply with the

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

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

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with the RPDs must be provided.

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C.

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Warranted

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

The Imposition of Sanctions against Defendant and Its Counsel Is

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Misuses of the discovery processes include, but are not limited to the
following: . . .
(c) Employing a discovery method in a manner or to an extent that causes

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unwarranted annoyance, embarrassment, or oppression, or undue burden

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expense.

-6MOTION TO COMPEL FURTHER RESPONSES, SET TWO

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(d) Failing to respond or to submit to an authorized method of discovery.

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(e) Making, without substantial justification, an unmeritorious objection to

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discovery.

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(f) Making an evasive response to discovery.

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Code of Civil Procedure section 2023.030 states, in pertinent part:

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To the extent authorized by the chapter governing any particular

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discovery method or any other provision of this title, the Court, after notice to any

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affected party, person or attorney, and after opportunity for hearing, may impose

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the following sanctions against any one engaging in conduct that is a misuse of

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the discovery process:

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(a) The Court may impose a monetary sanction ordering that (1)

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engaging in the misuse of the discovery process, or any attorney advising that

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conduct, or both, pay the reasonable expenses, including attorneys’ fees, incurred

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by anyone as a result of that conduct. (Emphasis added.)

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Moreover, Code Civ. Proc. § 2030.300(d) requires a court to impose a monetary sanction

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“against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel

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further response” to a discovery request unless it finds that the one subject to the sanction acted

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with substantial justification or that other circumstances make the imposition of the sanction

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unjust.

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In this case, Defendant’s responses to the RPDs at issue were made in bad faith when it

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issued blanket objections and did not produce a single document in response to 15 requests.

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The discovery propounded on Defendant were authorized methods of discovery, and its

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and its counsel’s actions in failing to provide proper responses constitute a misuse of the

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discovery process, as do the failures to substantively meet and confer. As a result of

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Defendant’s action, Plaintiff has been forced to file the instant motion. Based on Defendant’s

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-7MOTION TO COMPEL FURTHER RESPONSES, SET TWO

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

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counsel.

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4.

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

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

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

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

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Dated: May 24, 2016

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By.

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______________________________
George Sharp
In Propria Persona

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-8MOTION TO COMPEL FURTHER RESPONSES, SET TWO

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DECLARATION OF GEORGE SHARP

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I, George Sharp, declare as follows:

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1.

I am over 18 years of age and am the Plaintiff in this case. I have personal

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knowledge of the facts stated herein, and if called as a witness would truthfully and competently

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testify to the following.

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2.

On March 25, 2016, I served Request for Production of Documents, Set Two on

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the Defendant Coastal Integrated Services, Inc. Attached as Exhibit “A” is a true and correct

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copy of these discovery requests.

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3.

On April 12, 2016, I received by email a series of objections from Defendant’s

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Counsel which were to be considered as responses to my Request for Production of Documents,

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Set Two. Attached as Exhibit “B” is a true and correct copy of these discovery responses.

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4.

On April 12, 2016, I sent a Meet and Confer request to Defendant’s Counsel,

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Robert Huston, regarding responses to the document requests. Attached as Exhibit “C” is a true

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copy of this Meet and Confer letter.

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5.

I have not received any response to my initial effort to Meet and Confer.

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6.

On May 23, 2016, I sent a second Meet and Confer request to Defendant’s

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Counsel, Robert Huston, regarding responses to the document requests. Attached as Exhibit “D”

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is a true copy of this Meet and Confer letter.

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7.

On May 24, 2016, I received a response to my second Meet and Confer letter

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from Defendant’s Counsel, Robert Huston. Attached as Exhibit “E” is a true copy of this Meet

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and Confer letter.

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8.

I have advanced $60 as a filing fee for this motion.

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I declare under penalty of perjury under the laws of the State of California that the

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foregoing is true and correct. This declaration was executed on May 24, 2016 in San Diego,

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California.

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____________________________
George Sharp
-9MOTION TO COMPEL FURTHER RESPONSES, SET TWO

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PROOF OF SERVICE - CCP. 1013A, CG 002015.5

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STATE OF CALIFORNIA, COUNTY OF SAN DIEGO

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

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

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

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George@George-Sharp.com.

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

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

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MOTION TO COMPEL FURTHER RESPONSES TO REQUESTS FOR PRODUCTION

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OF DOCUMENTS, SET TWO FROM DEFENDANT COASTAL INTEGRATED

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SERVICES; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF

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

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addressed as follows:

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Kenneth Stone

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THE STONE LAW GROUP

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Karl@KRInternetLaw.com

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Robert Huston

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Bob_Huston@Yahoo.com

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

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

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

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I certify under penalty of perjury that the foregoing is true and correct and that this
declaration was executed May 24, 2016.

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____________________

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George Sharp

-10MOTION TO COMPEL FURTHER RESPONSES, SET TWO

EXHIBIT “A”

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George Sharp
3525 Del Mar Heights Road, #620
San Diego, CA 92130
(310) 498-4455
(619) 446-6717 fax

4

In Propria Persona

2

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SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN DIEGO, CENTRAL DIVISION

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GEORGE SHARP,

)
)
)
Plaintiff,
)
)
v.
)
)
)
STOCKTIPS.COM, AMERADA CORP.,
)
LALUNA SERVICES, INC., TELUPAY
)
INTERNATIONAL, INC., ECRYPT
)
TECHNOLOGIES, INC., ALKAME
)
)
HOLDINGS, INC., WELL POWER, INC.,
COASTAL INTEGRATED SERVICES, INC., )
)
and DOES 1 through 500, inclusive,
)
)
)
Defendants.
)
___________________________________ )
)

Case No.: 37-2015-00008210-CU-NP-CTL
(Assigned for all purposes to Hon. Timothy
Taylor)
REQUEST FOR PRODUCTION OF
DOCUMENTS BY DEFENDANT
COASTAL INTEGRATED SERVICES,
INC., SET TWO
Trial Date:

none

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PROPOUNDING PARTY:

Plaintiff George Sharp

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RESPONDING PARTY:

Defendant Coastal Integrated Services, Inc.

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SET NUMBER:

Two

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TO DEFENDANT COASTAL INTEGRATED SERVICES, INC. AND ITS

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ATTORNEY OF RECORD:

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Pursuant to California Code of Civil Procedure Section 2031, plaintiff George Sharp

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hereby requests that defendant Coastal Integrated Services, Inc., hereinafter “COASTAL”,
-1_____________________________________________________________________________
REQUEST FOR PRODUCTION OF DOCUMENTS BY DEFENDANT COASTAL INTEGRATED SERVICES, INC., SET TWO

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

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

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DEFINITIONS
1.

“YOU” or “YOUR” means Defendant COASTAL INTEGRATED

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

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

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its behalf, at his request or with his authorization.

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2.

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

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

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

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

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subcontractors, employees, representatives and affiliates.

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5.

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

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

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depicting, embodying, constituting or reporting.

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6.

“COMMUNICATION” means any meeting, conversation, discussion,

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

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between two or more PERSONS.

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7.

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

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

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

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

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

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

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DOCUMENTS contemporaneously or subsequently created that have any non-conforming notes

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or other markings. Without limiting the generality of the foregoing, the terms “DOCUMENT”

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and “DOCUMENTS” include, but are not limited to, correspondence, memoranda, notes,

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records, letters, envelopes, telegrams, messages, studies, analyses, contracts, agreements,
-2_____________________________________________________________________________
REQUEST FOR PRODUCTION OF DOCUMENTS BY DEFENDANT COASTAL INTEGRATED SERVICES, INC., SET TWO

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

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

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

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

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

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

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

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

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

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

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

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8.

If any DOCUMENT is withheld under a claim of privilege, to assist the

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Court and the parties hereto in determining the validity of the claim of privilege, you are asked to

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

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

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claimed, together with the following information regarding said document:

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a)

the date of the DOCUMENT;

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b)

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

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

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business and home addresses and telephone numbers;

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c)

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

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

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telephone numbers;

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d)

the nature and substance of said DOCUMENT set forth with sufficient

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particularity to enable the Court and the parties hereto to identify the

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DOCUMENT;

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e)

the identity of each PERSON who has custody, control or possession of
the original DOCUMENT and/or copy thereof;

-3_____________________________________________________________________________
REQUEST FOR PRODUCTION OF DOCUMENTS BY DEFENDANT COASTAL INTEGRATED SERVICES, INC., SET TWO

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f)

the number of pages in the DOCUMENT;

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g)

the basis upon which any privilege is claimed;

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h)

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

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and
i)

the number of the document request to which such DOCUMENT relates
or corresponds.

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DOCUMENT REQUESTS
REQUEST FOR PRODUCTION NO. 2
All documents relating to the formation of the corporation currently known as Coastal
Integrated Services, Inc, its predecessors, affiliates and subsidiaries.

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REQUEST FOR PRODUCTION NO. 3

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All documents relating to the assignments and resignations of any officers and directors

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

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REQUEST FOR PRODUCTION NO. 4

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

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

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REQUEST FOR PRODUCTION NO. 5

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

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predecessors since May 2, 2009.

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REQUEST FOR PRODUCTION NO. 6

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

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relations programs on behalf of Coastal Integrated Services, Inc.

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REQUEST FOR PRODUCTION NO. 7

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

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marketing of Coastal Integrated Services, Inc. common stock.

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-4_____________________________________________________________________________
REQUEST FOR PRODUCTION OF DOCUMENTS BY DEFENDANT COASTAL INTEGRATED SERVICES, INC., SET TWO

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REQUEST FOR PRODUCTION NO. 8

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

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

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REQUEST FOR PRODUCTION NO. 9

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

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options, and warrants in Coastal Integrated Services, Inc.

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REQUEST FOR PRODUCTION NO. 10

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

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

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REQUEST FOR PRODUCTION NO. 11

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

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between Coastal Integrated Services, Inc., or its predecessors and any other entity.

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REQUEST FOR PRODUCTION NO. 12

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

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predecessors.

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REQUEST FOR PRODUCTION NO. 13

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

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REQUEST FOR PRODUCTION NO. 14

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

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OTC Markets or other market facilitators or regulators.

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REQUEST FOR PRODUCTION NO. 15

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

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

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not).

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REQUEST FOR PRODUCTION NO. 16

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All contracts entered into by Coastal Integrated Services, Inc. or its predecessors.

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-5_____________________________________________________________________________
REQUEST FOR PRODUCTION OF DOCUMENTS BY DEFENDANT COASTAL INTEGRATED SERVICES, INC., SET TWO

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Dated: March 25, 2016

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By.

______________________________
George Sharp

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-6_____________________________________________________________________________
REQUEST FOR PRODUCTION OF DOCUMENTS BY DEFENDANT COASTAL INTEGRATED SERVICES, INC., SET TWO

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PROOF OF SERVICE - CCP. 1013A, CG 002015.5
STATE OF CALIFORNIA, COUNTY OF SAN DIEGO

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I, the undersigned, reside in the County of San Diego, State of California. I am over the
age of eighteen (18) years and not a party to the within action. My business address is 3525 Del
Mar Heights Road, Suite 620, San Diego, California 92130. My email address is
George@George-Sharp.com.
On March 25, 2016, at approximately 8:45 a.m., I served true copies of the foregoing
documents described as REQUEST FOR PRODUCTION OF DOCUMENTS BY
DEFENDANT COASTAL INTEGRATED SERVICES, INC., SET TWO on the interested
parties in this action, addressed as follows:

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Kenneth Stone
THE STONE LAW GROUP
Karl@KRInternetLaw.com

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Robert Huston
Bob_Huston@Yahoo.com

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BY EMAIL: The documents were scanned and uploaded to the One Legal internet
website with the instruction to forward the documents to the interested parties. I am "readily
familiar" with the practice of uploading to One Legal for email forwarding.
I certify under penalty of perjury that the foregoing is true and correct and that this
declaration was executed March 25, 2016.

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____________________
George Sharp

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-7_____________________________________________________________________________
REQUEST FOR PRODUCTION OF DOCUMENTS BY DEFENDANT COASTAL INTEGRATED SERVICES, INC., SET TWO

EXHIBIT “B”

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Robert J. Huston III, SB # 45366
10 Jetty Drive
Corona del Mar, CA 92625
Tel: (949) 230-0259
E-mail: bob_huston@yahoo.com

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Attorney for Defendant COASTAL INTEGRATED SERVICES, INC.

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SUPERIOR COURT OF THE STATE OF CALIFORNIA

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FOR THE COUNTY OF SAN DIEGO, CENTRAL JUDICIAL DIVISION

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GEORGE A. SHARP
Plaintiff,

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vs.
STOCKTIPS.COM, AMERADA CORP.,
LALUNA SERVICES, INC., TELUPAY
INTERNATIONAL, INC.ALKAME
HOLDINGS, INC., WELL POWER, INC.,
TIGER OIL AND ENERGY, INC.,and
DOES 1 through 500, inclusive;

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Defendants.
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__________________________________

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CASE NO.37-2015-00008210-CU-NP-CTL
(Assigned for all purposes to Hon. Timothy
Taylor)
Department C-72
COASTAL INTEGRATED SERVICES,
INC.’S RESPONSES TO PLAINTIFF
GEORGE SHARP’S REQUEST FOR
PRODUCTION OF DOCUMENTS, SET
TWO
Trial Date:

None

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PROPOUNDING PARTY: Plaintiff George A. Sharp

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RESPONDING PARTY:

Defendant Coastal Integrated Services, Inc.

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SET NUMBER:

One

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TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

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Defendant Coastal Integrated Services, Inc. hereby responds to Plaintiff George A.

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Sharp’s Form Interrogatories, Set One as follows:

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1
DEFENDANT COASTAL’S RESPONSES TO PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS

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

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

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

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

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

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

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

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

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

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

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

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to the proof of subsequently discovered material facts.

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

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responses herein.

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Response to Request for Production No. 2:

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

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

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

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

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calculated to lead to the discovery of admissible evidence.

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

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

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

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

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

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Responding Party declines the request.

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2
DEFENDANT COASTAL’S RESPONSES TO PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS

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Response to Request for Production No. 3:

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

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

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

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

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calculated to lead to the discovery of admissible evidence.

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

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

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

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

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

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Responding Party declines the request.

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Response to Request for Production No. 4:

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

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

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

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

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

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request.

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Response to Request for Production No. 5:

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

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

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

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

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

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request.

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DEFENDANT COASTAL’S RESPONSES TO PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS

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Response to Request for Production No. 6:

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

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

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

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possession, custody or control.

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Response to Request for Production No. 7:

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

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

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

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possession, custody or control.

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Response to Request for Production No. 8:

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

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

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

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

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

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request.

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Response to Request for Production No. 9:

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

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

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

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

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

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request.

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Response to Request for Production No. 10:

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

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

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DEFENDANT COASTAL’S RESPONSES TO PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS

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

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

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

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request.

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Response to Request for Production No. 11:

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

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

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

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

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

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request.

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

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and thus places an undue burden on this Def endant to respond.

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Response to Request for Production No. 12:

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

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

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

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

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

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request.

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

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and thus places an undue burden on this Def endant to respond.

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Response to Request for Production No. 13:

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

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

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

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

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DEFENDANT COASTAL’S RESPONSES TO PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS

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

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request.

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

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

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

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

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

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Responding Party declines the request.

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Response to Request for Production No. 14:

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

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

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

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

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

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request.

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Responding Party further objects to this request on the basis that it is overly broad
and thus places an undue burden on this Def endant to respond.

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

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

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

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

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

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

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for the Plaintiff as for the Responding Party.

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Response to Request for Production No. 15:

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

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

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DEFENDANT COASTAL’S RESPONSES TO PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS

VERIFICATION BY PARTY
(C.C.P. §2015.5)

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STATE OF CALIFORNIA )
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COUNTY OF RIVERSIDE )
I, John Newman am the president of Coastal Integrated Services, Inc., a defendant
in the above-entitled action. I have read the foregoing and know the contents thereof, and
I certify that the same is true of my own knowledge, except as to those matters which are
therein stated upon my information or belief, and as to those matters which I believe it to
be true.
I declare, under penalty of perjury, under the laws of the State of California, that the
foregoing is true and correct.
Executed this 12 th day of April, 2016, at Thousand Palms, California.

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_____________________________________
JOHN NEWMAN

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DEFENDANT COASTAL’S RESPONSES TO PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS

EXHIBIT “C”

George Sharp
From:
Sent:
To:
Subject:

George Sharp <george@george-sharp.com>
Tuesday, April 12, 2016 1:11 PM
'Robert Huston'
RE: COLV Response to Request for Production of Documents, Set 2

Mr. Huston:
This email shall be construed as an attempt to meet and confer on your response to my Request for Production, Set Two. Your responses contain blanket
objections intended to obfuscate documents and deny my right to discovery. You have not produced a single document.
Furthermore, you continue to be lax in your response to the first set of Requests for Production and have not even provided the courtesy of my previous Meet
and Confer emails.
This is my final attempt to obtain the responsive documents before I file a Motion to Compel and seek sanctions.
Respectfully,
George Sharp
310-498-4455
From: Robert Huston [mailto:bob_huston@yahoo.com]
Sent: Tuesday, April 12, 2016 12:52 PM
To: George Sharp; Kenneth Stone, Esq.
Subject: COLV Response to Request for Production of Documents, Set 2

Attached.
Robert J. Huston III
Attorney at Law
"We must reject the idea that every time that a law is broken society is guilty rather than the lawbreaker. It is time to restore the American precept
that each individual is accountable for his actions."
Ronald Reagan
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EXHIBIT “D”

GEORGE A. SHARP
3525 Del Mar Heights Road, #620
San Diego, CA 92130
310-498-4455
Fax: 619-446-6717
Email: george@clippercp.com

Re: Sharp v StockTips - SD Sup Court Case. No. 37-2015-00008210
ATTTEMPT TO MEET AND CONFER
Mr. Huston:
This is email is written in a second attempt to Meet and Confer with respect to your
blanket objections to the Request for Production of Documents, Set Two.
It appears that your client wishes to assert boilerplate objections in violation of the spirit
of the Discovery Act. Indeed, one court held such boilerplate objections sanctionable.
Korea Data Systems Co. v. Superior Court (Aamazing Technologies Corp.), 51 Cal. App.
4th 1513, 1516 (1997).
With respect to your repeated objections based on “scope and issues of lawsuit”, I refer
you to Code of Civil Procedure § 2017(a) [CCP § 2017.010] which clearly states: “any
party may obtain discovery regarding any matter, not privileged, that is relevant to the
subject matter involved in the pending action or to the determination of any motion made
in that action . . .”
Pursuant to Code of Civil Procedure § 2017.010,
“Unless otherwise limited by order of the court in accordance with this title, any party
may obtain discovery regarding any matter, not privileged, that is relevant to the subject
matter involved in the pending action or to the determination of any motion made in that
action, if the matter either is itself admissible in evidence or appears reasonably
calculated to lead to the discovery of admissible evidence. . . .” [Emphasis Added].
Discovery is relevant to the subject matter of the litigation if it might reasonably assist a
party in evaluating the case, preparing for trial, or facilitating settlement thereof.
Gonzalez v. Sup. Ct. (1995) 33 Cal.App.4th 1599, 1611; Stewart v. Colonial Western
Agency, Inc. (2001) 87 Cal.App.4th 1006, 1013. Further, the relevancy to the subject
matter is applied liberally. Any doubt is resolved in favor of permitting discovery.
Colonial Life & Acc. Ins. Co. v. Sup. Ct. (1982) 31 Cal.3d 785, 790. Further, this is
never a proper objection for the refusal to answer the interrogatory. Coy v. Superior
Court of Contra Costa County (1962) 58 Cal 2d 210 (Objection interposed as reason for
not answering written interrogatories that they were irrelevant and immaterial to issues of
case could not be used to deny discovery).
The basic premise of discovery is that the discovery statutes are construed broadly, so as
to uphold the right to discovery wherever possible. Greyhound Corp., at 377-378. The

Supreme Court in Greyhound Corp., found that the basic purpose of discovery is to take
the game element out of trial preparation by enabling parties to obtain the evidence
necessary to evaluate and resolve their dispute beforehand. Id., at 376.
The basic purpose of discovery is to take the game element out of trial preparation by
enabling parties to obtain the evidence necessary to evaluate and resolve their dispute
beforehand. Greyhound Corp. v. Superior Court (1961) 56 Cal.2d 355, 376; Emerson
Elec. Co. v. Superior Court (1997) 16 Cal.4th 1101, 1107.
Scope and issues of lawsuit, i.e. relevancy, is not a valid objection. Discovery is relevant
to the subject matter of the litigation if it might reasonably assist a party in evaluating the
case, preparing for trial, or facilitating settlement thereof. Gonzalez v. Sup. Ct. (1995) 33
Cal.App.4th 1599, 1611; Stewart v. Colonial Western Agency, Inc. (2001) 87
Cal.App.4th 1006, 1013. Further, the relevancy to the subject matter is applied liberally.
Any doubt is resolved in favor of permitting discovery. Colonial Life & Acc. Ins. Co. v.
Sup. Ct. (1982) 31 Cal.3d 785, 790. Further, this is never a proper objection for the
refusal to provide discovery responses. See Coy v. Superior Court of Contra Costa
County (1962) 58 Cal 2d 210 (Objection interposed as reason for not answering written
interrogatories that they were irrelevant and immaterial to issues of case could not be
used to deny discovery). Further, the requested documents are directly relevant to this
litigation. The course and scope of the dealing between the parties is key in interpreting
the contract and the relationship between the parties. The propounded discovery is
necessary to this case in that it establishes who were the potential beneficiaries of the
spam email pump and dump scheme, as well as those in control of the company when it
willingly participated in the scheme, including potential alter-egos. The discovery will
also aid in establishing potential witnesses.
With respect to your repeated assertion that certain documents are available on the
internet, as you know, these documents may not be admissible as they are not certified
and receiving certified copies would be an undue burden and expense on me, the
Plaintiff. Instead of providing a straightforward response to this interrogatory as required
by the Code, you improperly refer the propounding party to the internet. This is contrary
to Cal. Code of Civ. Proc. § 2030.220; See also Deyo v. Kilbourne, 84 Cal.App.3d 771,
783-784 (1978) (“it is not proper to answer by stating, “See my deposition”, “See my
pleading”, or “See the financial statement.”).Your client, as a corporation is bound to
keep corporate documents and should have access to authentic documents. Should it be a
burden to copy these documents, I am prepared to accept verified electronic versions.
As for your assertion that certain requests are burdensome, the true test of burdensome
and harassing is whether the amount of work required to respond to the request is so
great, and the utility of the information sought so minimal, that it defeats the ends of
justice to require responses. See Columbia Broadcasting Systems, Inc. v. Sup. Ct.
(Rolfe), 263 Cal. App. 2d 12, 21 (1968) (“As the court said in Greyhound Corp. v.
Superior Court, 56 Cal.2d 355, 383-384, . . . a trial court ‘In the exercise of its discretion
the court should weigh the relative importance of the information sought against the
hardship which its production might entail.’”). All discovery imposes some burden, but
“[t]he objection of burden is valid only when that burden is demonstrated to result in
injustice.” West Pico Furniture, Co. v. Superior Court (Pacific Finance Loans), 56 Cal. 2d
407, 418 (1961). The party objecting must present evidence showing the “quantum of
work required” to respond to the discovery request. West Pico, 56 Cal. 2d at 417. You do
not even attempt to make such a showing. The mere fact that the response may be

expensive and burdensome did not justify a refusal to responds to the discovery. See
Alpine Mut. Water Co. v. Superior Court of Ventura County (1968) 259 Cal App 2d 45.
Further, an objection on the grounds of burden was not valid unless the burden results in
injustice. See Pantzalas v. Superior Court of Los Angeles County (1969) 272 Cal App 2d
499.
This is my final attempt to get a commitment from you on providing me with complete
and appropriate responses to my document requests. If I do not hear from you by the end
of business tomorrow with assurances that documents are forthcoming, I will file a
Motion to Compel and seek sanctions.

Respectfully,

George A. Sharp
310-498-4455

EXHIBIT “E”

George Sharp
From:
Sent:
To:
Cc:
Subject:

Robert Huston <bob_huston@yahoo.com>
Tuesday, May 24, 2016 2:08 PM
George Sharp
Kenneth Stone
Re: Sharp v StockTips - Your Client: Coastal Integrated Services, Inc. MEET AND CONFER ATTEMPT NUMBER TWO

Mr. Sharp:
Thank you for the recitation of hornbook California discovery law. Given the state of the pleadings when my client's discovery responses were
prepared (my client's name not mentioned and no specific facts alleged re my client's purported conduct) the responses were entirely appropriate.
Now that you have at long last amended your pleading to directly name my client and to allege a small quantum of fact concerning its alleged
statutory violations, I will review the previous responses in that light and will give you a written conclusion by Monday, which may or may not
include some modified responses.
Robert J. Huston III
Attorney at Law
"We must reject the idea that every time that a law is broken society is guilty rather than the lawbreaker. It is time to restore the American precept
that each individual is accountable for his actions."
Ronald Reagan
On Monday, May 23, 2016 3:04 PM, George Sharp <george@george-sharp.com> wrote:

Please see attached

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