Motion to Compel Discovery in LARRY RIPALDI vs. LANCE STOKES| Trellis.Law

On December 11, 2013 a Motion,Ex Parte was filed involving a dispute between Ripaldi, Larry, and Stokes, Lance, for OTHER (CIVIL) in the District Court of Dallas County.

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FILED
DALLAS COUNTY
7/15/2014 10:47:57 AM
GARY FITZSIMMONS
DISTRICT CLERK

NO. DC-13-14542

LARRY RIPALDI, § IN THE DISTRICT COURT
Plaintiff, §
§
v. § 101st JUDICIAL DISTRICT
§
LANCE STOKES, §
Defendant § OF DALLAS COUNTY

MOTION TO COMPEL DISCOVERY

TO THE HONORABLE JUDGE OF SAID COURT:

COMES NOW, LARRY RIPALDI, Plaintiff in the above-numbered and

entitled cause, and files this his Motion to Compel Discovery and, pursuant to

Texas Rule of Civil Procedure 215, seeks an order compelling production of

documents and things, and as grounds therefore would respectfully show the Court

as follows:

1. On or about March 5, 2014, Plaintiff served upon Defendant its First

Request for Production to Defendant A true and correct copy of this discovery

item is attached hereto as Exhibit "A" and fully incorporated herein by reference.

2. Defendant, on April 3, 2014, served responses to Plaintiffs First

Request for Production. A true and correct copy of such responses are attached

MOTION TO COMPEL DISCOVERY PAGE 1 OF6

Page 1 of 26
as Exhibit "B" and fully incorporated herein by reference. As is shown, in

Defendant's responses to Requests for Production nos. 3 - 8 and no. 10, he has

asserted no objections, and responded: "To the extent such documents exist and are

in possession, custody and control of Defendant, the foregoing documents are kept

in the regular course of business and will be produced as such at a mutually

convenient time and location."

3. Plaintiffs counsel contacted Defense counsel by email on May 29,

2014 and June 11, 2014, and on June 20, 2014 by email and mailed letter,

requesting the documents and things Defendant agreed to produce without objection

as to Requests for Production nos. 3 - 8 and no. 10, and "subject to" certain stated

objections as to Requests for Production nos. 1 and 2. True and correct copies of

such emails and letter to Defendant's attorney in this regard is attached hereto as

Exhibit "C" and incorporated herein by reference. In response to such

communications, Plaintiffs counsel has still received no response. Accordingly,

Plaintiff asserts this motion.

Production ofDocuments

4. Plaintiff is entitled, under TEXAS RULE OF CIVIL PROCEDURE 196.2 to

production and inspection of the requested items, and Defendant should be

compelled to produce same. Inasmuch as Defendant has agreed to produce
MOTION TO COMPEL DISCOVERY PAGE 2 OF 6

Page 2 of 26
compliant items "in the regular course of business ... at a mutually convenient time

and location", and has repeatedly failed to do so, fairness requires that he now be

required to produce them, or accurate copies thereof, at the offices of Plaintiffs

counsel.

Improperly Asserted Ogections

5. In addition, Plaintiff would show that Defendant's objections asserted

in response to Plaintiffs requests for production no. 1, 2 and 9 are groundless, and

should be overruled, requiring Defendant to produce compliant documents.

6. Defendant has forced Plaintiff to file this motion by its continued

failure to produce discoverable items. Accordingly, pursuant to TEX. R. CIV. PRO.

215.1(d), Plaintiff is entitled to recover all reasonable and necessary attorney's fees

and expenses incurred in bringing this motion.

WHEREFORE, Plaintiff prays that, upon notice and hearing, Defendant be

compelled to produce the requested documents and items, that Defendant's

objections above stated be overruled, for his reasonable attorneys fees and

expenses, and for general relief in accordance withTEX. R. Clv. PRO. 215.

MOTION TO COMPEL DISCOVERY PAGE30F6

Page 3 of 26
Respectfully submitted,

By: u~~~~~'a14
Rich' uL. Armstrong
1400 Gables Court, Suite 103
Plano, Texas 75075
(972) 424-5297
(972) 516-0577 FAX
ric@armstrongthelawfirm.com
State Bar I.D. No. 01322200
ATTORNEYS FOR PLAINTIFF

MOTION TO COMPEL DISCOVERY PAGE40F6
Page 4 of 26
CERTIFICATE OF CONFERENCE

Counsel for Movant has personally attempted to contact the counsel for

respondent to resolve the matters presented as follows:

By email sent July 9, 2014 at 2:43p.m.;
By email sent July 11,2014at 10:32 a.m.; and
By phone voice mail message on July 11, 2014 at approximately 1:59 p.m.

Counsel for the Movant has caused to be delivered to counsel for Respondent, and

counsel for Respondent has received, a copy of the proposed motion. At least one

attempt to contact the counsel for Respondent followed the receipt by counsel for

Respondent of the proposed motion. Counsel for Respondent has failed to respond

or attempt to resolve the matters presented.

MOTION TO COMPEL DISCOVERY PAGE 50F6
Page 5 of 26
CERTIFICATE OF SERVICE

The undersigned attorney hereby certifies that a true and correct copy of the

foregoing motion was served on all counsel of record in compliance with the TEXAS

RULES OF CIVIL PROCEDURE 21 and 21a on this the 15th day ofJuly, 2014.

MOTION TO COMPEL DISCOVERY PAGE 6 OF6
Page 6 of 26
Exhibit "A"
Page 7 of 26
NO. DC-13-14542

LARRY RIPALDI, § IN THE DISTRICT COURT
Plaintiff, §
§
v. § 101st JUDICIAL DISTRICT
§
LANCE STOKES, §
Defendant. § OF DALLAS COUNTY, TEXAS

PLAINTIFF'S FIRST REQUEST FOR
PRODUCTION TO DEFENDANT

TO: Defendant, Lance Stokes by and through his attorney of record, Michael T. Savage,

Ackerman & Savage, L.L.C., 8226 Douglas Avenue, Suite 330, Dallas, Texas 75225

Pursuant to Rule 196 of the TEXAS RULES OF CIVIL PROCEDURE, Plaintiff, Lal'ry Ripaldi,
herein requests that you make available for copying and Inspection the items herein requested to
be produced at Armstrong, the Law Fil'm, P.C., 1400 Gables Court, Suite 103, Plano, Texas
75075, on or before thirty (30) days after set·vice hereof. Response to this Request for
Production is also requested within thirty (30) days of service. Unless otherwise requested,
·please produce odginals and all existing copies of all documents and things denominated. Unless
otherwise indicated in a Request for Production of Documents, the que.~tions shall refer to the
time period January 1, 2012 until the present date.

PLAINTIFF'S FIRST REQUEST JIOR PRODUCTION TO DEFENDANT I'AGE I OF 8

Page 8 of 26
RespeotfuJly submitted,

By:
Rio atd L. Armstrong
1400 Gables Court, Suite 103
Plano, Texas 75075
(972) 424-5297
(972) 516-0577 FAX
l'ic@armstl'Ongthel!!Wflrm.com
State Bat· I. D. No. 01322200
ATTORNEYS FOR PLAINTIFF

CERTIFICATE OF SERVICE

The undersigned attorn<;>y hereby certifies that a ti'Ue and co1'!'ect copy of "Plaintiffs First
Request for Production to Defendant" was served on opposing counsel in compliance with the
TEXAS RULES OF CIVIL PROOBDURE on the 5th day of arch, 2014,

PLAINTIFF'S FIRST REQU£ST FOR PRODUCTION TO DEFENDANT

Page 9 of 26
DEFINITIONS

For the pUI'pose of Plaintiff's First Request for Production to Defendant, the following
Wol'ds are defined as follows:

(1) "Plaintiff" - Larry Ripaldi;

(2) "Defendant" - Lance Stokes;

(3) "Cotton Snaps, Inc." - Cotton Snaps, Inc.;

(4) "You" or "your"- Lance Stokes, his legal counsel, servants, employees, private
investigators, agents, representatives and all other persons acting on behalf of or
purporting to act on behalf of;

(5) "Identify"

a. When used in reference to a person, "identify" or "identification" means to
state his/her full name, present or last known residence address, present or
last known business address and telephone number.

b. When used in reference to a public or private corporation, govemmental
entity, partnership, m· othe1· legal Ol' business entity, "identify" or
"identification" means to state its full name, present or last known
business address or operating address, the name of its chief exec\Jtive
officer and telephone number.

c. When used in reference to a document, "identify" or "identification" shall
include statement of the following:

1, The title, heading, or caption, if any, of such document;

2. The identifying number(s), letter(s), 01' combination thereof, if any;
and the significance or mea11ing of such number(s), letter(s), or
combination thereof, if necessary to an understanding of the
document and evaluation of any claim of protection from
discovery.

PLAINTIFF'S FIRST REQUEST FOR PRODUCTION TO DEFENDANT PAG~30F8

Page 10 of 26
3. The date appearing on such document; if no date appears thereon,
the answet· shall so state and shall give the date ot· approximate
date on which such document was prepared;

4,. The numbet• of pages and the general nature or description of such
document (i.e.,whether it is a letter, memorandum, minutes of a
meeting, etc.), with sufficient particularity so as to enable such
document to be precisely identified;

5. The name and capacity of the person who signed such document; if
it was not signed, the answer shall so state and shall give the name
of the person or persons who pt·epared it;

6. The name and capacity of the person to whom such doettment was
addressed and the name and capacity of such person, othet· than
such add1·essee, to whom such document, or a copy thereof, was
sent; and

7. The physical location of the document and the name of its
custodian or custodians.

d. When used in reference to a crime, "identify" or "identification" shall
mean to state:

1. The criminal offense of which the particular person was convicted;

2. The cotu·t of original jurisdiction which entt.wed the judgment; and

3. The date the judgment of conviction was entered.

e. When used in reference to a photograph or video g1·aphic evidence,
include statement of:

1. Who took the photograph(s) Ol' videotape(s), iflmown;

2. Where such photogmph(s) or videotape(s) were taken; and

3. When such photogt·aph(s) or videotape(s) were taken.

(6) "Document" as used herein shall mean all writings however titled or styled, notes,
representations and means of communication or recordation of any kind,
including the odginal and all non-identical copies, whether diffet·entfrom the
original by reason of any notation made on such copies or otherwise; inner-office
electronic mail, electronic mail ("E-mail") including, without limitation,
photographs, chatts, graphs, and any of such previously described items stored or
archived on or in microfiche, microfilm, video tapes, streaming Ol' digitally stored

l'LAINTlFF'S FIRST Rl!:QUEST FOR PRODUCTION TO DEFENDANT

Page 11 of 26
video, analog and digital recordings, motion pictures, computer tapes, computer
card, computer hard dl'!ve (local or remote), computer discs, NAS drives, Random
Access Memory (RAM) SDRAM, flash 01' thumb drives, se1·vers (local or
remote), in an electronic retri<.wal system, any electl'onic or mechanical storage
device Ol' system, or on software media of any kind, including without limitation:
tapes, cassettes, mlcrocassettes, films, discs, compact discs (whether audio or
video),recordings, and transcl'iptions of any audio, video, Ol' other recordings.

(7) "Agreement" - Shall mean any written agreements, letters of intent, or any
contracts signed between Plaintiff and the Defendant during and including the
pel'iod of January 1, 2012 through the date of service of this discovery request.

(8) "Representation(s)" " All verbal, written, or recorded statements.

INSTRUCTlONS

1. Each Request for Production l'equests documents that are in the custody or control of
Defendant, or that said Defendant has the power to obtain.

2. Each Request for Production shall be construed independently and not by reference to
any other Request for Production he1·ein for purposes of limitation.

3. All documents produced shall be grouped, categorized, indexed or otherwise classified
according to the document request to which a document is responsive. A written
l'esponse to this Request is required.

4, To the extent any of the following Requests for Production calls for a document that
Defendant believes to be subject to a claim of privilege, produce all those documents
called for in that Request not subject to a claim of privilege and so much of each
document subject to a claim that does not contain privileged information. With respect to
any document or any portion of any document withheld because of a claim of privilege,
state in writing the basis for your claim of privilege with respect to such document or
portion of document as follows:

PLAINTIFF'S FIRST REQUEST FOR PRODUCTION TO DEFENDANT

Page 12 of 26
a. the date appearing on the document, or if no date appears, the date on which the
document was prepared;

b. the name ofperson(s) to whom the document was addressed;

c. the name of each person, other than the addressee(s) identified in (b) above, to
whom the document, 01' a copy thereof, was sent or with whom the document was
discussed;

d. the name of the person(s) who signed the document, or if not signed, the name of
the person(s) who prepared it;

e. the name of each pe1·son making any contribution to the authorship of the
document;

f. the job title or position of each pe1·son identified in (b), (c), (d), and (e) above;

g. the date the document was received or discussed by each of the persons identified
in (b) or (c) above;

h, the general nature or description of the document and the number of pages of
which it consists;

i. the name of the person(s) who has (have) custody of the document; and

j, the specific ground(s) on which the claim of pl'ivilege rests.

PLAINTIFF'S FIRST REQUEST FOR PRODUCTION TO ))l!.FENDANT !'AGE GOF 8

Page 13 of 26
Exhibit "B"
Page 14 of 26
DOCUMENTS TO BE PRODUCED

I. All Agreements between Cotton Snaps Inc., and Larry Ripaldi.

2. All Agreements between Lance Stokes individually and Larry Ripaldi.

3. All documents which evidence, or which tend to evidence, any oral agreement(s)
between Cotton Snaps, Inc. and Larry Ripaldi.

4. All documents which you contend evidence any oral agreement(s) between Lance Stokes
individually and Larry Ripaldi.

5. All documents which tend to support, Ol' which you contend support, the allegation in
your counterclaim that the instant suit is brought in an attempt to deprive the Defendant of any
benefit confen'ed or 1·eceived as a result of his remaining ownership interest in Cotton Snaps, Inc.

6. All documents which tend to support, 01'which you contend supp01t, the aiiegation in
your counterclaim that the instant suit isbrought to coerce the Defendant into the payment of
money to prevent the interference of the Plaintiff with the Defendant's other endeavors.

7. All documents which tend to support, or which you contend support, the allegation in
your counterclaim that "this cause of action is brought in bad faith as defined by Rule 13 of the
Texas Rules of Civil Pmcedure."

8. All documents which tend to support, Ol'which you contend support, the allegation in
your counterclaim that, prior to the filing of this lawsuit, Plaintiff and the attorney who filed this
action made "other spurious claims against the Plaintiff in furtherance oftheir scheme Ol' design."

9. All documents which evidence, tend to support, 01' which you contend evidence or tend to
support, Plaintiff's non-entitlement to recover equitable relief due to the doctrine of unclean
hands.

PLAINTIFF'S FlltST REQUEST FOR PRODUCTION TO DEFENDANT

Page 15 of 26
I 0. All-documents which evidence, tend to suppol't, m· which you contend evidence or tend to
suppot'l, each of the following affirmative defenses asserted in your pleadings:
a. failure of condition precedent;
b. offset;
c. repudiation;
d. unconscionability;
e. mlst11ke;
f. 11Ccord and satisfaction;
g. novation;
h. the parole evidence rule;
i. estoppel;
j. fi'llud;
k. failure of consideration;
I. illegality;
m. laches;
n. waiver; and
0. ratification.

PLAINTIFF'S FIRST REQUEST FOR PRODUCTION TO DEFENDANT PAGE80F8

Page 16 of 26
CAusE NO. DC-13·14542

LARRY RIPALDI, § IN THE DISTRICT COURT
Plaintiff, §
§
v. § JOIST JUDICIAL DISTRICT
§
LANCE STOKES, §
Defendant. § OF DALI,AS COUNTY, TEXAS

DEFENDANT'S RESPONSES TO PLAINTIFF'S
FIRST REQUEST FOR PRODUCTION TO DEFENDANT

To: Plaintiff, Larry Ripaldl, by and through his attorney, Richard L. Armstrong, Armstrong, The
Law Finn, P.C., 1400 Gables Court, Suite 103, Plano, Texas 75075.

NOW COMES Defendant, Lance Stokes, in the above-entitled and numbered cause and

serves these responses to Plaintiff's First Request for Production is as follows:

BEOUESTS FOR PRODUCTION

I. All Agreements between Cotton Snaps Inc., and Larry Ripaldi.

RESPONSE:

Defendant objects to this request for the reason that it is so broad on its face that it clearly requires
production of irrelevant documents. Brad Canvay & A$socs. Inc. v. Moye, 124 S.W.2d 892 (Tex.
App. -Texarkana 1987, no writ).

Defendant objects to this request for the reason that the probative value of the infonnation sought is
so slight compared to the burden on the Defendant! f discovery is allowed. Independent Insulating
Glass/Southwest, Inc. v. Street, 122 W.W.2d 798 (Tex. App. -Fort Worth 1987, writdism'd). TEX.
R. CIV. P. 192.4.

Subject to the above and foregoing objections and without waiving them, Defendant responds:

To the extent such documents exist and are in possession, custody and control of Defendant, the
foregoing documents are kept In the regular course of business and will be produced as such at a
mutually convenient time and location.

2. All Agreements between Lance Stokes individually and Larry Ripaldi.

RESPONSE:

DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION
DIS.I68590.DOC PAGE ·I

Page 17 of 26
Defendant objects to this request for the reason that it Is so broad on its face that it clearly requires
production of Irrelevant documents. Brad Carway & Assocs. Inc. v.Moye, 124 S. W.2d 892 (Tex.
App. -Texarkana 1987, no writ).

Defendant objects to this request for the reason that the probative value of the information sought is
so slight compared to the burden on the Defendant if discovery Is allowed. Independent Insulating
Glass/Southwest, Inc. v. Street, 722 W.W.2d 798 (Tex. App. -Fort Wo11h 1987, writdism'd). TEx.
R. CIV. P. 192.4.
Subject to the above and foregoing objections and without waiving them, Defendant responds:

To the extent such documents exist and are in possession, custody and control of Defendant, the
foregoing documents are kept in the regular course of business and will be produced as such at a
mutually convenient time and location.

3. All documents which evidence, or which tend to evidence, any oral agreement(s) between
Cotton Snaps, Inc. and Larry Ripaldi.

RESPONSE:

4. All documents which you contend evidence any oral agreement(s) between Lance Stokes
individually and Larry Ripaldi.

RESPONSE:

5. All documents which tend to support, or which you contend support, the allegation in your
counterclaim that the instant suit is brought in an attempt to deprive the Defendant of any benefit
conferred or received as a result of his remaining ownership interest in Cotton Snaps, Inc.

RESPONSE:
To the extent such documents exist and are in possession, custody and control of Defendant, the
foregoing documents are kept in the regular course of business and will be produced as such at a
mutually convenient time and location.

6. All documents which tend to support, or which you contend support, the allegation in your
counterclaim that the instant suit is brought to coerce the Defendant into the payment of money to
prevent the interference of the Plaintiff with the Defendant's other endeavors.

DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTJON
DIS·168590.DOC PAGE·2

Page 18 of 26
RESPONSE:

7. All documents which tend to support, or which you contend support, the allegation in your
counterclaim that "this cause of action Is brought in bad faith as defined by Rule 13 of the Texas
Rules of Civil Procedure."

RESPONSE:

8. All documents which tend to support, or which you contend support, the allegation in your
counterclaim that, prior to the filing of this lawsuit, Plaintiff and the attorney who filed this action
made "other spurious claims against the Plaintiff in furtherance of their scheme or design."

RESPONSE:

9. All documents which evidence, tend to support, or which you contend evidence or tend to
support, Plaintiff's non-entitlement to recover equitable relief due to the doctrine of unclean hands.

RESPONSE:

Defendant objects to this request in that it invades the attorney's trial strategy and it is therefore,
work product. Such information is protected by Tex. R. Civ. P. 192.5, in that it constitutes the
mental impressions, opinions, or trial strategy of an attorney. Hickman v. Taylor, 329 U.S. 495
(1946); National Union Fire Ins. Co. V. Valdez, 863 S.W.2d 458, (Tex. 1993); Owens Coming
Fiberglass Corp. V. Caldwell, 818 S.W.2d 749 (Tex. 1991, orig. Proceeding); Toyota Motor Sales
U.S.A. Inc. v.Heard, 774 S.W.2d 316 (Tex. App. -Houston [141h Dist.] 1989, orig. Proceeding);
Wileyv. Williams, 769 S.W.2d 715 (Tex. App. -Austin 1989, orig. Proceeding).

Information or material responsive to this request has been withheld.

I0. All documents which evidence, tend to support, or which you contend evidence or tend to
support, each of the following affirmative defenses asserted in your pleadings:

DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION
DIS·I68590.DOC PAGE-3

Page 19 of 26
a. failure of condition precedent;
b. offset;
c. repudiation;
d. unconscionability;
e. mistake;
f, accord and satisfaction;
g. novation;
h. the parole evidence rule;
I. estoppel;
J. fraud;
k. failure of consideration;
I. Illegality;
m. laches;
n. waiver; and
o. ratification.

RESPONSE:

Respectfully Submitted,

ACKERMAN & SAVAGE, L.L.C,
Allorneys and Counselors
8226 Douglas Avenue, Suite 330
Dallas, Texas 7 2
(214) 346-42 0( lephone)
(214) 346· ( simile)

By:

State
hial@ackenuansavage.cw
STEVEN T. RAMOS
State Bar No. 00784812
ramos@ackerroansavaae.com
MICHAEL T. SAVAGE
State Bar No. 17688805
mtsavage@ackermansavage.com

ATTORNEYS FOR DEFENDANT

DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION
DIS·I68590.DOC PAGE-4

Page 20 of 26
CERTIFICATE OF SERVICE

I certifY that a true and correct copy of the above document was served upon all parties or
theirattomeysofrecord on this 3'd day of April, 2014, pursuant to Tex. R. Civ. P. 21 and21a. The
document was delivered by:

Richard L. Armstrong via facsimile: 972-516-0577
Armstrong, The Law Firm, P.C. a11djlrst class mall
1400 Gables Court, Suite I03
Plano, Tel!as 75075

DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION
DIS·I68590,DOC PAGE-5

Page 21 of 26
Exhibit "C"
Page 22 of 26
Richard l. Armstrong
From: Richard L. Armstrong [richard@armstrcngthelawflrm.com]
Sent: Thursday, May 29, 2014 12:07 PM
To: 'Michael savage'
cc: 'Cathy Blasberg'
Subject: Discovery

Michael,

I have reviewed your discovery responses served on us earlier.

In regard to your responses to our First Request for Production, while preserving our right to challenge any or
all of your objections, I would like to receive the documents and things that you agreed to produce In your
responses. Please let me know if you are willing to produce them via mail, flash drive or similar means, or
whether I must come to your office to view them. Please let me have your response to this request by Monday,
June 2nd.

In regard to your responses to our Request for Admissions and Interrogatories, based on your responses I will
need to take your client's deposition. Please let me know dates that he could be available for his deposition at
your office during the months of June and July.

Thank you.

Armstrong
'11/E lAW fi'JRM ,l'.C.
"Our K11owledge. Your Power." ""

www.AnnstrongThcLawFh·n1.com

A-V Rated- Martimlale-Hubbcll Pee•· Review

RICHARD l. ARMSTRONG
rlc®annstrongiiJslawnrm.com
1400 Gnbles Com•t, suue 103
Plnuo, 'l'cx~ts 75075
Ph: 972.424.5297
Fx: 972.516.0577

CONFIDENTIALITY NOTICE
"THIS E·MAIL IS COVERED BY THE ELECTRONIC COMMUNICATIONS PRIVACY ACT, 18 U.S.C., SECTIONS 2610 • 2621. THE
INFORMATION CONTAINED IN THIS E-MAIL MESSAGE AND DOCUMENTS ACCOMPANYING SAME ARE LEGALLY PRIVILEGED AND
CONFIDENTIAL INFORMATION INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED HEREIN. IF THE READER OF THIS
MESSAGE IS NOT THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION/DISTRIBUTION OR COPY OF THIS
E-MAIL IS STRICTLY PROHIBITED. IF YOU RECEIVED THIS E-MAIL IN ERROR, PLEASE IMMEDIATELY NOTIFY US BY TELEPHONE AND
RETURN THE ORIGINAL MESSAGE TO US AT THE ADDRESS ABOVE VIA THE UNITED STATES POSTAL SERVICE."

"THIS COMMUNICATION DOES NOT REFLECT AN INTENTION BY THE SENDER, OR BY HIS CLIENT OR PRINCIPAL, TO CONDUCT ANY
TRANSACTION OR MAKE ANY AGREEMENT BY ELECTRONIC OR OTHER MEANS. NOTHING CONTAINED IN THIS COMMUNICATION OR
ANY ATTACHMENT THERETO SHALL BE DEEMED TO SATISFY THE REQUIREMENTS FOR A 'WRITING', AND NOTHING CONTAINED
THEREIN SHALL CONSTITUTE A CONTRACT OR ELECTRONIC SIGNATURE UNDER THE 'ELECTRONIC SIGNATURES IN GLOBAL AND
NATIONAL COMMERCE ACT, ANY VERSION OF THE ELECTRONIC TRANSACTIONS ACT, OR ANY OTHER STATUTE GOVERNING
ELECTRONIC TRANSACTIONS."

Page 23 of 26 1
Richard L. Armstrong
From: Richard L. Armstrong [rlchard@armstrongthelawflrm.com)
Sent: Wednesday, June 11,201410:27 AM
To: 'Michael savage'
Cc: 'Cathy Blasberg'
Subject: Second request for document production; Request for deposition dates

Michael,

This follows a previous request I made for document production on by email on May 29th. In that email I
requested the documents and things you agreed to produce in your responses to our First Request for
Production, while maintaining our existing objections. Please let me know if you are willing to produce the
compliant items by mall, flash drive, or similar means, or whether I must come to your office to view them.

Please also let me know dates that your client could be available for his deposition at your office during the
months of June and July.

Kindly let me have your response by Friday, June 13. Thanks.

Thank you.

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July 15, 2014

Case Filing Date

December 11, 2013

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Motion,Ex Parte: LARRY RIPALDI vs. LANCE STOKES

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