Party Discovery: IN THE MATTER OF IN RE REVOCABLE LIVING TRUST AGREEMENT OF CHARLES ACTIS/CONSOLIDATED WITH CASE NO. PES-05-287457

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Document Scanning Lead Sheet
Jan-30-2006 8:12 am

Case Number: PTR-05-287341
Filing Date: Jan-25-2006 8:11
Juke Box: 001 Image: 01372713
GENERIC PROBATE PLEADING

IN THE MATTER OF IN RE REVOCABLE LIVING TRUST AGREEMENT OF CHARLES AC

001P01372713

Instructions:
Please place this sheet on top of the document to be scanned.wo eo Ht AH WH kk WY NY

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DAVID J. FRIEDENBERG, ESQ.
SBN 25026

2171 Junipero Serra Bivd., Ste. 620
Daly City, CA 94014

Telephone: (650) 755-6622
Facsimile: (650) 755-4312

Attomey for Respondent
EVA KNOTT

SUPERIOR COURT OF THE STATE OF CALIFORNIA
CITY AND COUNTY OF SAN FRANCISCO

IN RE REVOCABLE LIVING TRUST
AGREEMENT OF CHARLES ACTIS
DATED NOVEMBER 2, 2004, AND
WILL DATED NOVEMBER 2, 2004

CAROL MITCHELL,
Petitioner,
ve

EVA KNOTT, Trustee and Beneficiary
under the REVOCABLE LIVING TRUST
AGREEMENT OF CHARLES ACTIS
DATED 11/2/04, NICHOLAS FERRERO,
a minor and a will and trust beneficiary
and NATALIE FERRERO, a minor and a
will and trust beneficiary,

Respondents.

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Case No. PTR-05-287341
(Related Case No. PES-05-287457)

RULE 335 STATEMENT IN SUPPORT
OF MOTION FOR ORDER
COMPELLING IDENTIFICATION AND
PRODUCTION OF DOCUMENTS, AND
FOR ATTORNEYS FEES, COSTS AND
SANCTIONS

Date: February 17, 2006
Time:9:00 a.m.
Dept: Law & Motion, Dept. 612

COMES NOW RESPONDENT EVA KNOTT and pursuant to California Rule of Court

335, submits the following statements of discovery Requests, Petitioner’s Responses, and

Reasons (documents should be identified and/or produced.) for Respondent’s request for an

Order compelling identification and production of records and documents.

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RULE 335 STATEMENT REGARDING IDENTIFICATION OF DOCUMENTS.oO eo ND A F&F WN =

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I SECOND AMENDED NOTICE OF DEPOSITION AND FOR PRODUCTION OF
DOCUMENTS

Request No. 6

Any correspondence between you (including your agents and employees) and any of the persons

identified by you in any of your Responses to Interrogatories in this action, as having knowledge

of any of the facts in this litigation, excluding Eva Knott and David J. Friedenberg.

Response to Request No. 6:

Attached hereto are Bates Stamp documents 200034 through 200085 excepting therefrom

documents, if any, subject to the work product privilege.

Reason to compel Identification of Withheld Documents :

This matter is set for Summary Judgment on March 8, 2006 and Respondent is entitled to know

which documents are being withheld pursuant to alleged attorney work privilege.

Dated: January 2 2006

DAVID J FRIEDENBERG, ESQ.
Attorney for Respondent EVA KNO

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RULE 335 STATEMENT REGARDING IDENTIFICATION OF DOCUMENTS