Karina Pedigo

10920 Laurel Ave.

Whittier, CA 90605
562-504-8224
kvpedigo@hotmail.com
IN PRO PER

SUPERIOR COURT OF CALIFORNIA

COUNTY OF LOS ANGELES

Case No: 18WHFL01382

MANDATORY SETTLEMENT
LEWIS PEDIGO, CONFERENCE BRIEF
Petitioner TRIAL BRIEF
PETITIONER
KARINA PEDIGO , RESPONDENT

Respondent Date of Hearing: 08/02/2021

Time: 10:30 AM
Place: Stanley Mosk Courthouse, Dept.18

The
Petitioner
Respondent
submits the following MSC Brief in accordance with Local Rule 5.14.

1. STATISTICAL FACTS:

1. Date of Marriage: 08/23/1997Date of Separation: 12/01/2018

2. Length of Marriage: 21 years, 3 months, agreed by both parties.
3. We have NO MINOR children, however, we do have 2 sons, ages 22
& 23 that reside with the Respondent. The Petitioner also has a 34 year
old daughter from marriage #1 and a 25 year old son from
marriage #2. The petitioner’s daughter has not spoken to her dad since
2019. His son lives with his mother.

RESPONDENT’S MSC BRIEF

2. COMPLETION OF DISCLOSURE DOCUMENTS:

PETITIONER
RESPONDENT
has completed, filed with the court and served opposing side the following:
Income & Expense Declaration FL-150, with copies of bank statements &
federal taxes 2020
Final Declaration of Disclosure FL-140
Final Declaration Regarding Service of Declaration of Disclosure FL-141
Schedule of Assets & Debts FL-142
Property Declaration FL-160
Above mentioned documents you will find in attachment #1
Exhibits - (see attachment #2)
Appraisals & other forensic reports - (see attachment #3)

3. PROCEDURAL HISTORY:

We are here today from Whittier Court, Department 123 in hopes of finding resolution. The
case was filed by the petitioner in December of 2018 out of Whittier Court.
As demonstrated on the Registry of Action (attachment #4), the case stayed stagnant for a
period of 4 months. I must add to this brief that my self representation is not by choice. I have
studied sleepless nights to understand the legalities and procedures in order to attempt to
successfully finalize this divorce with fairness and acceptance. So please, be patient with me.
While the petitioner continued to live a lavishing lifestyle, the case remained stagnant. I
borrowed money from my parents and hired counsel Joel Garcia in May of 2019 who assisted
me in moving the case forward by propounding the following discovery:
1. Demand for Inspection & Production of Documents
2. Tangible Things & Other Properties
3. Request for Admission of the Truth of Facts & Genuineness of Documents
4. Form Interrogatories FL-145
5. Specially Prepared Interrogatories
(Please refer back to attachment #4 “Registry of Actions” for verification).

RESPONDENT’S MSC BRIEF

The petitioner’s counsel at the time, Carina Reyna was unable to provide these requests
(relying on an uncooperative client), so the petitioner seeked a new counsel. In order to get
acquainted with the case, new counsel Dennis Sanchez requested an extension and again,
requested a second extension, completely understandable.

In addition to the above mentioned orders, I, the respondent, have also submitted subpoenas to
Chase Bank, requesting financial records for the community property business and
petitioner’s personal accounts.(see attachment #5).

On 4/23/2021 we had another court hearing as I asked Commissioner Santos through a

request for order that the business be valued at date of separation and not trial. (please refer
back to attachment #4 “Register of Actions)
● Family Code section 2552 is based upon the premise that assets are, generally
speaking, to be valued at time of trial. However, there are many exceptions to this rule
that really are based upon one of two common scenarios:
● 2552b- (1) one party devotes post-separation time, skill and efforts to a business for
which they are the sole or key employee and which may have increased in value since
the date of separation by reason of contributions of such efforts (in which case, the
community estate ought not benefit from the separatizer's contributions after the
parties have split up) and
● (2) where one party who is in control of an asset intentionally runs it into
the ground, such that it is only fair that that asset be valued at date of
separation rather than time of trial.

4. ORDERS REGARDING SPOUSAL SUPPORT:

A. I knowingly give up forever any right to request spousal support.

B. I ask that the court terminate my spouse’s ability to request spousal support.
C. X I request that the court order my spouse to pay me reasonable spousal support
because:
1. X This is a long term-marriage; we have been married for 10 or more
years.
2. X My spouse was the sole financial provider; I only worked outside
the home for a portion of the marriage.
3. I have/had a Domestic Violence Restraining Order against my
spouse.

RESPONDENT’S MSC BRIEF

 4. I am currently in school, trying to get a degree to get a higher paying
job.
5. X See attached Declaration Regarding Spousal Support,
(see attachment 6)
D.I request that the court reserve jurisdiction over the issue of spousal
support for both Petitioner & Respondent.

5. ORDERS REGARDING DIVISION OF COMMUNITY PROPERTY:

A. There are no community property assets to divide.

B. X We have community property assets to divide:
1. We have real property (a house, condo, townhouse, etc.) that was purchased
during the marriage. The legal description of this property is: home was
purchased by petitioner & I in June 2016. Home is located in
Bullhead City & is listed on AIRBNB as a vacation rental.

The petitioner pockets that money.

See attached bank loan/mortgage statement, AIRBNB info &

appraisal. (please refer back to attachment #3 for appraisal)

My proposal for division is:

Sell the home & equally divide the equity of the home. Currently the
home’s equity is approximately $180k

2. We have a business that started during the marriage. Inaugurated in 2005, (see
attachment#7) the petitioner is the concrete pump operator; if the petitioner
hired a 2nd pumper, I am unaware. Our 2 sons worked as second pump
operators throughout the years, however, both have quit due to the petitioner’s
inability to treat people with respect and consideration.
The first year, we purchased (1) concrete pump through T/A Pumps Sales Inc.
in Stanton. (See attachment#7). The business received a loan from the
petitioner’s parents that was paid in full in 2012. A second pump was
purchased in 2018 (see attachment#7).

RESPONDENT’S MSC BRIEF

I, the Respondent, reconciled every month and maintained the Quickbooks
A/R & A/P files up to par, without any discrepancies. External flash drive is in
my possession.
During the marriage, the business ran successfully, bringing profit and a
comfortable life, allowing us to travel and purchase recreational vehicles &
vessels. Over the 13 years that I was involved, the business checking account
was used for business and non business related expenses, with only 1 business
credit card that would be paid in full every month. The business was not in
debt nor in the negative.
I have attached the business’ Profit & Loss reports & federal & state taxes for
the time frame that I was involved- 7/1/2005 to 2018. I’ve also attached my
business appraisal. (see attachment#8).
**NOTE:
I must make it very clear that since the date of separation (12/1/2018), the
petitioner has kept me out of the loop on all matters, including community
property matters, business matters, financial matters, investment matters etc. It
is very hard to work with a forensic accountant when you are dealing with an
uncooperative party who refuses to comply with the court rules. Though the
law implements these rules of discovery for a reason such as assisting in
evaluating, preparing & facilitating a settlement, the petitioner on the other
hand, has left me with my jaw dropped in disbelief over his unethical,
unlawful, irresponsible behavior. Cruelty & disrespect come to mind when I
tell you that after almost a quarter of a century married to this individual, I
have never met such an ugly human being. Since the date of separation
12/1/2018, the business took a nose-dive and not because of covid, but because
I believe the petitioner is purposely dissipating the marital assets. I’ve attached
the following material as to prove that I am in the right to be concerned :
Post Marriage- (see attachment #9)
1. Lawsuit- “Court Judgement” for $59k
2. Notice of License Suspension- Contractors State License Board
3. Bank Statements show suspicious activities.

I ask that you grant me the date of the Valuation to be “Date of

Separation”.(Ca. Family Code 2552b)

RESPONDENT’S MSC BRIEF

 GOOD FAITH SETTLEMENT OFFER

Petitioner’s Respondent’s Good Minus Debt Settlement

Appraisal Appraisal Faith Offer
Offer

Business 63,000 318,000 225,000 40,000 60,000

Home 280,000 330,000 265,000 149,000 60,000

Spousal 0 1,054 per CA 600 per 400 per month

Alimony month or 20,000
Guidelines

140,000

In order for me to have a fair trial, & get equal division of our community
property, it is in my best interest to present these exhibits. The petitioner’s
credibility is in question. I believe that his dishonesty & uncooperation are an
intentional motive to mislead during settlement.

I ask that the court order the petitioner to show the detailed financial data
that he shared with his forensic accountants to determine the value of the
business.

I have read countless hours of literature in hopes that my exhibits meet all the
requirements to be entered into evidence. I have not done anything wrong, but
simply watch the petitioner tamper with the community funds. After almost 3
years, he had every opportunity to redeem himself. And after reading his brief,
I can see that this man has a dark soul.
So for the sake of a fair trial, my goal now is to attack the petitioner’s
credibility in hopes that the court will assist me in bringing justice. These
exhibits show a pattern of dishonesty.

Exhibit A
Petitioner’s FL-150 Income & Expense Declaration Dated 3/1/2021
was compared to the business checking account statements & personal
statements.The results are that the petitioner is not being honest. (See
attachment #2)

RESPONDENT’S MSC BRIEF

Exhibit B
Petitioner’s FL-150 Income & Expense Declaration Dated 2/26/2020
was compared to the business checking account statements & personal
statements. The results are that the petitioner is not being honest. (See
attachment#2)

Exhibit C
Petitioner’s FL-150 Income & Expense Declaration Dated 10/19/2019
was compared to the business checking account statements & personal
statements. The results are that the petitioner is not being honest. (See
attachment#2)

Exhibit D
Once again, the petitioner’s credibility is in question when he tells his
attorney he makes no profit from our Arizona home that he lists on
AIRBNB as a vacation rental.
According to the Business Checking Acct statements for timeframe
4/1/2020 to 4/30/2021 there are 38 deposits from AIRBNB, totalling
$29183.16. Our mortgage payments are $1013.92 per month,
$12167.04 per year. Leaving $17016.12 for utilities, taxes and
maintenance? Really?
Please refer to page 4 of the Court Transcript for hearing date 3/4/2021
@Whittier Court where the petitioner's counsel states that there is “no
profit.” (see attachment #2).

Exhibit E
My son Lewis Jr shared with me some texts his father, the petitioner,
recently sent him. (see attachment #2).
It shouldn’t have to come to this your honor. I am not a vicious person.
But when you deal with ugly, you have to become ugly. It’s unfortunate
because I know this is not in my nature. But what am I supposed to do?
I am wife #3. He’s left the first 2 with nothing & is going to try to do
the same thing again. Now he’s working on #4. Calling one of his bank
accounts “my next wife”? He has no shame and no dignity. He’s
mocking everyone with no remorse. And I’m not going to quit until his
true character is revealed.

RESPONDENT’S MSC BRIEF

 3. X We have the following community property assets, my proposal for
division is:

DESCRIPTION OF ASSET Ị APPROX VALUE Ị PETITIONER Ị RESPONDENT

Furniture:

Vehicles:

2015 Chevy Camaro $12k Petitioner to 100%

surrender pink slip

2004 Tahoe Boat & Trailer $10k 50% 50%

Sandrail $5k 50% 50%

2018 & 2007 work trucks In the possession

included in the business of the petitioner
valuation report

Bank Accounts:
Pensions/Retirement Accts: I had $1800 in
a 401k that I
cashed out to
pay the rent
due to lack of
funds.

Other Assets: Investment in the possession of the 50% 50%

petitioner $1k
in Dinars

TOTALS:

C. There are no community property debt to divide

D. We have the following community property debts, my proposal for division is:

DESCRIPTION OF DEBT APPROX VALUE PETITIONER RESPONDENT

Credit Cards:

RESPONDENT’S MSC BRIEF

 Loans:

Other Debts:

Totals:
*NOTE: Pre separation the business was not in debt.
Now the petitioner lists in his latest brief personal credit card debt as business related.
He has listed in his business appraisal 2 questionable loans of large sums of money,
claiming they are business related. He is also stating that the business has a debt with
his parents.
The exhibits I have provided have determined that the petitioner’s word is worthless.
Therefore, I ask the court to order the petitioner to provide legit, authenticized proof
of these so-called business related debts.

8/1/2021 Karina Pedigo

Submitted on By The Respondent:

RESPONDENT’S MSC BRIEF