Discovery - Round 1
Discovery - Round 1
Key Docs in the order obtained by Plaintiff / Buyer : mls <2 in person showings> Vierra report Wheeler Report util disclosure <offer> <counteroffer> <contract formed> TDS , SPQ, Seller's AVID, KW List of disclosure docs, KW DIA, KW TDS completion advisory, KW Scope of Duty, KW Coastal Estates Advisory, Murrer Report, 2015 Report, Email 20210420 // Complete DA Docs Folder(pvt for now) Big Claims (pvt)
Key Docs in the order obtained / created / signed/ executed by Seller : 2015 Report Vierra report, Wheeler Report, mls , TDS , SPQ, Seller's AVID, KW List of disclosure docs, KW DIA, KW TDS completion advisory, KW Scope of Duty, KW Coastal Estates Advisory util disclosure <counteroffer> <contract formed> Email 20210420 // Complete DA Docs Folder(pvt for now) Big Claims (pvt)
Discovery - Set 1 - Canary Requests to Forstein
They may not have been formatted quite right, but we did best we could without legal support and on a budget...
Cover Letter (12 pages) gDoc pdf
Spreadsheet with 50 acts of fraud (14 pages) gSheet pdf
Admit Document - 1st Request (26 pages) gDoc pdf
Request for Documents - 1st Request (15 pages) gDoc pdf
Deliverables from Forstein to Canary
There was a lot of information that was clearly missing. When notified Gorman acknowledge that and more was coming. What was delivered was also incomplete based on facts known to Canary et al.
Response to Admit pdf analysis
Response to Production of Docs pdf
Response to Doc Demand , set 1 pdf
Production of Documents (folder) view
Canary response to Forstein Discovery (34 pages) gDoc
Response to Form Interrogatories pdf
Discovery Set 1 - Forstein Requests to Canary
We do NOT feel they did the best they could given complaint information and information they should have known. These felt designed for insincere time sink.
Admissions pdf rtf
Interrogatories -Form pdf
Interrogatories - Special pdf rtf
Demand for Docs pdf rtf
Deliverables from Canary to Forstein
We did not respond on pleading paper with more proper formatting because we viewed everything but form interrogatories to have been engaged in in bad faith by Attorney Gorman -- as is explained in the response documents.
Admit Response gDoc r2 - 11/28 r3- 12/10
Response - Form Int. gDoc r2 - 11/28 r3 - 12/10
Response - Speciall Int gSheet r2 -11/28 r3 - 12/10
Demand for Docs gDoc r2 - 12/3 r3 - 12/10
Canary - Informal Discovery and Dialogue with Forstein and his attorney starting 10/17/2024 (expand for list)
10/17/2024 - Email -Clarification of Facts related to admit doc requests from Gorman
10/17/2024 - Email - docs detailing our request/demand for an extension of condition contengency period - authentisign comment
10/19/2024 - Emai lDRAFT - response to micah answers and docs (not sent)
10/21/2024 - Email - exhibit 37 - email between Micah, Kent and Travaille << travaille sent additional context that sinks here more >>, kent man in middle due to lack of docs, incomplete responses
10/21/2024 - Email - binding arbitration opt out < mican and ken don't konw about travailles comment yet >
10/21/2024 - Email - quotes from Micah's email about pricing at 720k and 820k
10/24/2024 - Email - TDS and the word "representations"
10/25/2024 - Email - RE David Madariaga and Jennifer Ascunsion - cc'd to politicians and included Gorman and Forstein
10/25/2024 - Email - RE David Madariaga and Jennifer Ascunsion - f/u with Gorman and Forstein after Gorman counseled me on decorum and protocal (and case precedents) - formed vs created- notice of summary document
10/25/2024 - Email - copy of email to katy grant et al related to vallarta, letter for court reform, admit doc and disocvoery process clarity, seller co demand round 1 - (DA), Termite inspector got atty, txn coordinator (DA), Coldwell Banker (DA), Home Inspectors (DA) CA PE Board
10/25/2024 - Email - Meet and confer on first doc deliery and discvoery - perjury exists - 35 page document
10/25/2024 - Email - Meet and confer on admits - SPQ concerns
10/28/2024 - Email - Push back on Ken - Not to Micah on Attorney setup, notice of more proper discovery requests
10/28/2024 - Email - Shared pre ratification emal to Kent with them with an intro --
10/28/2024 - Email - Shared email with Pamela related to our lease termination notice
10/29/2024 - Email - work done prior to using docs to understand them, revocable contracts, Jue v Smiser, two CA Bar documents - requst to ken for case precedents
10/30/2024 - Email - Notic e of Motion hearing with Vierra - Motion Hearing Exhibit 1 (22 pages)
10/30/2024 - Emails - Doc Deman 2 (2a, 2b, 2c, 2d)
11/4/2024 - Email - GC 1 through GC 7 // Painter 1 through Painter 7 - notice of docs pending - why is technology family taking up indefensible position on cat urine? GC 6 // Sharing w his family (preliminary send to Ken only)
11/5/2024 - Email - GC 1 through GC 7 // Painter 1 through Painter 7 forwarded to Forstein
11/6/2024 - Email - Witness Testimony - 3 neighbors - docs attached
11/12/2024 - Email - The case of the 1st floor deflecion that ened in multi industry racketeering
11/13/2024 - Email - Vierra 1st ammended complaint and support docs - draft to Goreman and Forstein