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SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
Oct-31-2013 01:11 pm
Case Number: CUD-13-645401
Filing Date: Oct-31-2013 01:08 pm
Filed by:
Juke Box: 001 Image: 04258940
DECLARATION
SBERLO, YOEL, TRUSTEE FOR SBERLO FAMILY TRUST VS. YARNG
ALTAWAL et al
001004258940
Instructions:
Please place this sheet on top of the document to be scanned.27
28
LAW OFFICES OF
KAREN Y. UCHIYAMA,
1441 Baker Street
San Francis, California
ons
(415) 563-9300
@ 72 ORGINAL @
LAW OFFICES OF KAREN Y. UCHIYAMA
KAREN Y. UCHIYAMA - STATE BAR NO. 154414
AARON A. FARMER — STATE BAR NO. 268921
1441 Baker Street
San Francisco, California 94115
Telephone: (415) 563-9300
Facsimile: (415) 563-9304
Attorney for Plaintiff
YOEL SBERLO, TRUSTEE FOR SBERLO
FAMILY TRUST
COUNTY OF SAN FRANCISCO - LIMITED CIVIL JURISDICTION
YOEL SBERLO, TRUSTEE FOR SBERLO
FAMILY TRUST,
Case No. CUD-13-645401
DISCOVERY
DECLARATION OF KAREN Y.
UCHIYAMA, ESQ. IN SUPPORT OF
PLAINTIFF’S MOTION TO COMPEL
FURTHER RESPONSES TO REQUESTS
FOR ADMISSION, FORM
INTERROGATORIES, AND FOR
MONETARY SANCTIONS
Plaintiff,
Vv.
YARNG ALTAWAL, SUSAN ALTAWAL,
and DOES | through X, in occupancy,
Defendants.
Hearing:
Date: November 12, 2013
Time: 9:30 a.m.
Dept.: 501
eee eee
DECLARATION OF KAREN Y. UCHIYAMA IN SUPPORT
OF PLAINTIFF'S MOTION TO COMPEL FURTHER
RESPONSES27
28
LAW OFFICES OF
‘San Francisco, Calfomia
94115
415) 563-9900,
I, KAREN Y. UCHIYAMA, declare:
1. I am the attorney on record for Plaintiff YOEL SBERLO, TRUSTEE FOR
SBERLO FAMILY TRUST and licensed to practice law in all of the court in California. The
following statements are within my personal knowledge and I could and would testify to them if
called as a witness.
2. Since September 2013, I have been battling with Defendants’ attorneys,
Mark Hooshmand and Stephanie Foster over the scope of the discovery in this case.
3. On September 5, 2013, on behalf of Plaintiff YOEL SBERLO, TRUSTEE
FOR SBERLO FAMILY TRUST, I drafted and served special interrogatories (set no. 1), request
for production of documents and things (set no. 1), request for admission (set no. 1), form
interrogatories-general (set no. 1), and form interrogatories-unlawful detainer (set no. 1) upon
Defendant YARNG ALTAWAL via hand delivery to his attorney Mark Hooshmand by a
licensed process server. The requests for admission are attached as Exhibit “A,” the form
interrogatories-general are attached as Exhibit “B,” and the form interrogatories-unlawful
detainer are attached as Exhibit “C” to the Declaration of Karen Y. Uchiyama filed herewith. A
true and correct copy of the amended proof of service thereon is attached hereto as “Exhibit H.”
4. Defendants’ attorneys’ standard defense to a motion to compel is that their
opponent “failed to meet and confer.” Nothing is further from the truth. Defendants’ two
attorneys and my office have had ongoing arguments over discovery responses from Defendant
YARNG ALTAWAL.
5. On September 17, 2013, I drafted a meet and confer letter outlining
deficient discovery responses. A true and correct copy of my letter is attached hereto as “Exhibit
G.”
6. In response to my letter of September 17, 2013, a string of three emails
were exchanged between my office and Defendant’s attorneys’. Defendant’s attorneys’ did not
meet and confer on the form interrogatories. Rather they only responded concerning special
interrogatories, request for admissions, and request for production of documents. True and
correct copies of the emails are attached hereto as “Exhibit G.”
DECLARATION OF KAREN Y. UCHIYAMA IN SUPPORT
OF PLAINTIFF’S MOTION TO COMPEL FURTHER
RESPONSES27
28
LAW OFFICES OF
tS
(415) 588-8900
7. On October 1, 2013, after the hearing on Defendant’s motion for
protective order, there was an in person discussion concerning the discovery disputes between
Mark Hooshmand, Aaron Farmer, and me. An informal resolution of the discovery disputes was
not accomplished. Shockingly, at this meeting, Defendant’s attorney Mark Hooshmand informed
me that he was “not worried about being sanctioned by the Court in response to a motion to
compel.”
8. Thereafter, a series of three emails were exchanged between my office and
Defendant’s attorneys’. Defendants’ attorneys’ did not meet and confer on the form
interrogatories. Rather, they only responded concerning special interrogatories, request for
admissions, and request for production of documents. True and correct copies of the emails are
attached hereto as “Exhibit G.”
9. On October 3, 2013, wrote a letter to Defendant’s attorney proposing a
resolution of the outstanding discovery issues on some of the requests for admission, and the
special interrogatories in dispute. 4 true and correct copy of my letter is attached hereto as
“Exhibit G.”
10. On October 10, 2013, Defendant’s attorney wrote me a letter concerning
my proposed resolution. However, Defendant’s attorney did not commit to providing any
responses. Further, he was still silent concerning the form interrogatories. A true and correct
copy of this letter is attached hereto as “Exhibit G.”
11. Thereafter, a series of 10 emails were exchanged between my office and
Defendant’s attorneys’. Defendants’ attorneys’ did not meet and confer on the form
interrogatories. Rather, they only responded concerning special interrogatories, request for
admissions, and request for production of documents. True and correct copies of the emails are
attached hereto as “Exhibit G.”
12. On October 6, 2013, Defendant ALTAWAL provided supplemental
responses to the request for production of documents. Counsel is still meeting and conferring on
these responses.
13. On October 29, 2013, Defendant ALTAWAL provided supplemental
DECLARATION OF KAREN Y. UCHIYAMA IN SUPPORT
OF PLAINTIFF’S MOTION TO COMPEL FURTHER
RESPONSES28
LAW OFFICES OF
KAREN Y. UCHIYAMA
1441 Baker Street
Sin Francia, Cafomia
115
cars) 5809000
responses to Plaintiff's special interrogatories. Counsel is still meeting and conferring on these
responses.
14, The Court can now conclude that Defendant ALTAWAL and his attorneys
willfully refused to comply with the discovery process and forced me to have to file a motion to
compel. They should be compelled to provide proper responses. Defendant and his attorneys
should be sanctioned for the costs of this motion on the grounds that their conduct is an abuse of
the discovery process to prevent Plaintiff from obtaining relevant evidence in this case, and to be
unprepared at trial.
13. have spent over 2 hours attempting to resolve these disputes informally
with Defendant ALTAWAL/’s attorneys, and drafting this lengthy and time-consuming motion.
The Separate Statement is 23 pages long! I feel that my office had adequately threatened them
with a motion to compel further responses and seek monetary sanctions, but they just ignored me.
I anticipate spending another hour of my time at the hearing on this motion as well.
14. My billable hourly rate is $310.00.
15. Therefore, Plaintiffs requests a court order compelling further responses
from Defendant YARNG ALTAWAL to Plaintiff's request for admission (set no. 1), form
interrogatories-general (set no. 1), and form interrogatories-unlawful detainer (set no. 1).
16. Plaintiff also seeks monetary sanctions against Defendant YARNG
ALTAWAL and his attorneys for the cost of this motion in the amount of $4,385.00, which is
composed of the $60.00 filing fee and 15 hours of attorney’s fees ($4,325.00) to prepare this
Motion to Compel Further Responses; Memorandum of Points and Authorities, Separate
Statement, Declaration of Karen Y. Uchiyama, Esq. and for her attendance at the hearing on this
motion.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct. Executed this 30" day of October, 2013, in San Francisco,
Nese. Miley
KAREN Y. wparvama (77
California.
DECLARATION OF KAREN Y. UCHIYAMA IN SUPPORT
OF PLAINTIFF’S MOTION TO COMPEL FURTHER
RESPONSES,DISC-020
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
|_KAREN Y. UCHIYAMA, SBN 154414
1441 BAKER STREET
SAN FRANCISCO, CA 94115.
TELEPHONENO 415-563-9300 FAXNO (Optionay, 415-563-9304
E-MAIL ADDRESS (Optional).
ATTORNEY FOR (Name): Yoel Sberlo, Trustee for Sberlo Family Trust
SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Francisco
streetaporess 400 McAllister Street
maine aooress 400 McAllister Strett
ciryanozipcooet. San Francisco, CA 94102
sranckname Limited Civil Jurisdiction
‘SHORT TITLE:
Yoel Sberlo, Trustee for Sberlo Family Trust v. Altawal, et. al.
‘CASE NUMBER:
REQUESTS FOR ADMISSION
Truth of Facts [_] Genuineness of Documents CUD-13-645401
Requesting Party: Yoel Sberlo, Trustee for Sberlo Family Trust
Answering Party: Yarng Altawal
Set No.: One
INSTRUCTIONS
Requests for admission are written requests by a party to an action requiring that any other party to the action either admit or deny,
under oath, the truth of certain facts or the genuineness of certain documents. For information on timing, the number of admissions a
party may request from any other party, service of requests and responses, restrictions on the style, format, and scope of requests for
admission and responses to requests, and other details, see Code of Civil Procedure sections 94-95, 1013, and 2033.010-2033.420
and the case law relating to those sections.
An answering party should consider carefully whether to admit or deny the truth of facts or the genuineness of documents. With limited
exceptions, an answering party will not be allowed to change an answer to a request for admission. There may be penalties if an
answering party fails to admit the truth of any fact or the genuineness of any document when requested to do so and the requesting
party later proves that the fact is true or that the document is genuine. These penalties may include, among other things, payment of
the requesting party’s attorney’s fees incurred in making that proof.
Unless there is an agreement or a court order providin: ise, He party must respond in writing to requests for
admission within 30-days-afterthey-are-served, or withlg 5 days after service in an unlawful detainer action. There may be significant
penalties if an answering party fails to provide a timely wi ach request for admission. These penalties may include,
among other things, an order that the facts in issue are deemed true or that the documents in issue are deemed genuine for purposes
of the case.
Answers to Requests for Admission must be given under oath. The answering party should use the following language at the end of
the responses:
| declare under penalty of perjury under the laws of the State of California that the foregoing answers are true and correct.
(DATE) (SIGNATURE)
These instructions are only a summary and are not intended to provide complete information about requests for admission. This
Requests for Admission form does not change existing law relating to requests for admissions, nor does it affect an answering party's
right to assert any privilege or to make any objection.
REQUESTS EF. ION
You are requested to admit within Sé-days-eftersenice, of within 5 service in an unlawful detainer action, of this Requests
for Admission that:
Each of the following facts is true (if more than one, number each fact consecutively).
Continued on Attachment 1
2. [) The original of each of the following documents, copies of which are attached, is genuine (if more than one, number each
document consecutively).
Continued on Attachment 2
a YO Deaf Jf
Karen Y. Uchiyama, Esq. » Agta. Lf, Ltr
{TYPE OR PRINT NAME) /JBIGNATURE OF PARTYOR JTTORNEY)
Page tof 1
‘Code of Gil Procedure,
Form Approved tr Opnonal Use REQUESTS FOR ADMISSION Chavos, 2000 Fee as05 san sat
Judicial Counc of California
ISC-020 [Rev. January 1, 2008}27
28
LAW OFFICES OF
KAREN Y, UCHIVAMA
1441 Baker St
San Francisco, California
ents
I,
1.
ATTACHMENT 1
DEFINITIONS AND INSTRUCTIONS
“PLAINTIFF” means plaintiff YOEL SBERLO, TRUSTEE FOR SBERLO
FAMILY TRUST, his employees, officers, directors, agents, attorneys and all
other persons acting on his behalf.
“DEFENDANT(S)” means all defendants named in the complaint, either
individually or collectively, including their employees, officers, directors,
agents, attorneys and all other persons acting on their behalf.
“YOU” or “YOUR” means Defendant YARNG ALTAWAL.
“DOCUMENT” means any written, printed, typed, recorded, magnetic,
punched, copied, graphic or other tangible thing in, upon, or from which
information may be conveyed, embodied, translated, or stored, including, but
not limited to, papers, records, books, telegrams, telexes, dictation or other
audio tapes, video tapes, computer tapes, computer disks, computer printouts,
microfilm, microfiche, laser disks, diaries, calendars, photographs, charts, view
graphs, drawings, sketches and all other writings or drafts thereof, as well as all
other tangible things subject to statute. This definition expressly includes,
without limitation, all originals, drafts, non-conforming copies, reproductions,
facsimiles of written, typed or printed material of any kind, books, letters,
contracts, minutes of meetings, memoranda, notes on desk calendars and
appointment books, canceled checks, invoices, correspondence, telegrams,
telex messages, intra-office communications, photographs and films, art work
and information stored on tape, computer disk or any other type of data storage
device. If copies of a document are not identical by reason of hand notations,
initials, identification marks or any other modification, each such non-identical
copy is a separate document within the meaning of this definition.
“COMMUNICATION” means any transmission from one person or entity to
another, including, without limitation, by personal meeting, telephone, letter,
REQUESTS FOR ADMISSION27
28
LAW OFFICES OF
KAREN Y. UCHIYAMA
1441 Baker St
San Francisco, California
ens
13.
electronic mail, teleconference, facsimile, telex, etc.
“PERSON(S)” means any natural person and any other cognizable entity,
including, without limitation, corporations, proprietorships, partnership, joint
ventures, consortiums, clubs, associations, foundations, governmental agencies
or instrumentalities, societies and orders. As used herein, the acts and
knowledge of a “person” are defined to include the acts and knowledge of that
person’s directors, officers, members, employees, licensees, representatives,
agents, attorneys and all other persons acting on that person's behalf.
“AND” shall mean “or” and “or” shall mean “and” whenever necessary to infer
the broadest possible meaning to a particular document request.
As used in these document requests, the singular shall include the plural and
the plural shall include the singular whenever necessary to infer the broadest
possible meaning to a particular request.
The terms “REFER TO,” “REFERRING TO,” “RELATE TO,” “RELATING
TO,” “PERTAIN TO,” or “PERTAINING TO” mean consisting of,
summarizing, explaining, describing, discussing, mentioning, concerning,
illustrating, referring to, alluding to, responding to, connected with,
commenting on, in respect of, about, regarding, discussing, involving,
reflecting, analyzing, constituting or referring to in any way.
“COMPLAINT” means the First Amended Complaint filed by Plaintiff in this
action.
“THE SUBJECT PROPERTY” means the real property located at 1780
McAllister Street, Unit #3, San Francisco, California 94115.
“IDENTIFY” means, in the case of PERSONS, list the name, address,
telephone number and facsimile number of any person responsive to the
requests. In all other requests, it means list, state, or name.
The term “THREE DAY NOTICE” refers to the Three Day Notice to Quit that
is attached to the First Amended Complaint in this action as “Exhibit 4.”
REQUESTS FOR ADMISSION24
25
26
27
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LAW OFFICES OF
KAREN Y. UCHIYAMA
1441 Baker St
San Francisco, California
94115
14. The term “TENANT IN OCCUPANCY” as defined by the San Francisco Rent
Ordinance and as used herein means an individual who otherwise meets the
definition of tenant as set forth in Ordinance Section 37.2(t), and who resides in a
rental unit as his or her principal place of residence.
15. The term “PRINCIPAL RESIDENCE” as defined by the San Francisco Rent
Ordinance and as used herein means one’s “Usual Place of Return.” More
particularly, the place listed on one’s motor vehicle registration, tax returns,
driver's license, voter registration, public agencies, and where an individual’s
personal possessions are located, and the place where the individual normally
returns to as his or her home, exclusive of military service, hospitalization,
vacation, family emergency, travel necessitated by employment or education, or
other reasonable temporary periods of absence.
16. The term “RENT” as defined by the San Francisco Rent Ordinance and as used
herein means he consideration, including any bonus, benefits or gratuity,
demanded or received for or in connection with the use or occupancy of a rental
unit, or the assignment of a lease for such a unit, including but not limited to
monies demanded or paid for parking, furnishings, food service, housing services
of any kind, or subletting as set forth in Ordinance Section 37.2(p).
REQUESTS FOR ADMISSION
Admit that the following facts are true:
REQUEST FOR ADMISSION NO. 1: That YOU allow other persons to stay, use or occupy
the Subject Property in exchange for RENT between January 1, 2012, and May 8, 2013.
REQUEST FOR ADMISSION NO. 2: That more than two PERSONS were simultaneously
living, using or occupying the SUBJECT PROPERTY as their PRINCIPAL RESIDENCE
between January 1, 2012, and May 8, 2013.
REQUEST FOR ADMISSION NO. 3: That Susan Altawal stopped using and occupying the
the SUBJECT PROPERTY as her PRINCIPAL RESIDENCE sometime in 2012.
REQUEST FOR ADMISSION NO. 4: That YOU did not inform PLAINTIFF that Susan
REQUESTS FOR ADMISSION27
28
LAW OFFICES OF
KAREN Y. UCHIYAMA.
1441 Baker St
‘San Francisco, California
94135
Altawal moved out of the SUBJECT PROPERTY in 2012.
REQUEST FOR ADMISSION NO. 5: That YOU did not obtain prior written consent from
PLAINTIFF for you to allow other persons to stay, use or occupy the SUBJECT PROPERTY in
exchange for RENT at any time between January 1, 2012, and May 8, 2013.
REQUEST FOR ADMISSION NO. 6: That YOUR tenancy at the SUBJECT PROPERTY is
subject to the rental contract attached to the COMPLAINT as “Exhibit 1.”
REQUEST FOR ADMISSION NO. 7: That the rental contract controlling YOUR tenancy at
the SUBJECT PROPERTY, otherwise known as Exhibit | to the COMPLAINT, prohibits
subletting.
REQUEST FOR ADMISSION NO. 10: That YOU gave keys to the SUBJECT PROPERTY
to other people between January 1, 2012, and May 8, 2013.
REQUEST FOR ADMISSION NO. 11: That YOU allowed PERSONS to stay, use, occupy
and sleep at the SUBJECT PROPERTY as his or her PRINCIPAL RESIDENCE without the
prior written consent of PLAINTIFF between January 1, 2012, and May 8, 2013.
REQUEST FOR ADMISSION NO. 12: That YOU sometimes collected more monthly RENT
from unauthorized occupants staying with YOU at the SUBJECT PROPERTY than the amount
of lawful monthly rent YOU paid to PLAINTIFF between January 1, 2012, and May 8, 2013.
REQUEST FOR ADMISSION NO. 13: That YOU are separated from SUSAN ALTAWAL as
YOUR spouse.
REQUEST FOR ADMISSION NO. 14: That YOU are divorcing SUSAL ALTAWAL.
REQUEST FOR ADMISSION NO. 15: That SUSAL ALTAWAL vacated the SUBJECT
PROPERTY to live in a womens’ shelter in 2012.
REQUEST FOR ADMISSION NO. 16: That YOU could not afford to pay the monthly rent
for the SUBJECT PROPERTY without SUSAN ALTAWAL/’s income.
REQUEST FOR ADMISSION NO. 17: That YOU did not have $2,271.00 in your bank
account(s) on the day the Three Day Notice to Pay Rent or Quit expired on May 6, 2013.
REQUEST FOR ADMISSION NO. 18: That YOU deposited the RENT that YOU collected
from others into YOUR bank account from which YOU wrote rent checks to PLAINTIFF.
REQUESTS FOR ADMISSION27
28
LAW OFFICES OF
KAREN Y. UCHIYAMA,
1441 Baker St
San Francisco, California
gents
REQUEST FOR ADMISSION NO. 19: That one or more of the occupants who moved out of
the SUBJECT PROPERTY left his or her keys with the clerk at the corner store for YOU to pick
up.
REQUEST FOR ADMISSION NO. 20: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00334” attached to this request on the date listed to the
photograph.
REQUEST FOR ADMISSION NO. 21: That YOU received RENT from the person in the
photograph labeled “SBERLO 00334” attached to this request in exchange for their use or
occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 22: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00334” attached to this request.
REQUEST FOR ADMISSION NO. 23: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00334” attached to this
request to use or occupy the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 24: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00335” attached to this request on the date listed to the
photograph.
REQUEST FOR ADMISSION NO. 25: That YOU received RENT from the person in the
photograph labeled “SBERLO 00335” attached to this request in exchange for their use or
occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 26: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00335” attached to this request.
REQUEST FOR ADMISSION NO. 27: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00335” attached to this
request to use or occupy the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 28: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00336” attached to this request on the date listed to the
photograph.
REQUESTS FOR ADMISSION27
28
LAW OFFICES OF
KAREN Y. UCHIYAMA
1441 Baker St
San Francisco, Caifomia
REQUEST FOR ADMISSION NO. 29: That YOU received RENT from the person in the
photograph labeled “SBERLO 00336” attached to this request in exchange for their use or
occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 30: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00336” attached to this request.
REQUEST FOR ADMISSION NO. 31: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00336” attached to this
request to use or occupy the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 32: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00337” through “SBERLO 00338” attached to this
request on the date listed to the photograph.
REQUEST FOR ADMISSION NO. 33: That YOU received RENT from the person in the
photograph labeled “SBERLO 00337” through “SBERLO 00338” attached to this request in
exchange for their use or occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 34: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00337” through “SBERLO 00338” attached to
this request.
REQUEST FOR ADMISSION NO. 35: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00337” through “SBERLO
00338” attached to this request to use or occupy the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 36: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00339” through “SBERLO 00340” attached to this
request on the date listed to the photograph.
REQUEST FOR ADMISSION NO. 37: That YOU received RENT from the person in the
photograph labeled “SBERLO 00339” through “SBERLO 00340” attached to this request in
exchange for their use or occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 38: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00339” through “SBERLO 00340” attached to
REQUESTS FOR ADMISSION27
28
LAW OFFICES OF
KAREN Y. UCHIYAMA.
1443 Baker St
‘San Francisco, Califonia
96118
this request.
REQUEST FOR ADMISSION NO. 39: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00339” through “SBERLO
00340” attached to this request to use or occupy the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 40: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00341” through “SBERLO 00342” attached to this
request on the date listed to the photograph.
REQUEST FOR ADMISSION NO. 41: That YOU received RENT from the person in the
photograph labeled “SBERLO 00341” through “SBERLO 00342” attached to this request in
exchange for their use or occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO, 42: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00341” through “SBERLO 00342” attached to
this request.
REQUEST FOR ADMISSION NO. 43: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00341” through “SBERLO
00342” attached to this request to use or occupy the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 44: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00343” through “SBERLO 00344” attached to this
request on the date listed to the photograph.
REQUEST FOR ADMISSION NO. 45: That YOU received RENT from the person in the
photograph labeled “SBERLO 00343” through “SBERLO 00344” attached to this request in
exchange for their use or occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 46: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00343” through “SBERLO 00344” attached to
this request.
REQUEST FOR ADMISSION NO. 47: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00343” through “SBERLO
00344” attached to this request to use or occupy the SUBJECT PROPERTY.
REQUESTS FOR ADMISSION27
28
LAW OFFICES OF
KAREN Y. UCHIYAMA,
481 Baker St.
‘San Francisco, California
94118
REQUEST FOR ADMISSION NO. 48: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00345” through “SBERLO 00346” attached to this
request on the date listed to the photograph.
REQUEST FOR ADMISSION NO. 49: That YOU received RENT from the person in the
photograph labeled “SBERLO 00345” through “SBERLO 00346” attached to this request in
exchange for their use or occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 50: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00345” through “SBERLO 00346” attached to
this request.
REQUEST FOR ADMISSION NO. 51: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00345” through “SBERLO
00346” attached to this request to use or occupy the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 52: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00347” through “SBERLO 00348” attached to this
request on the date listed to the photograph.
REQUEST FOR ADMISSION NO. 53: That YOU received RENT from the person in the
photograph labeled “SBERLO 00347” through “SBERLO 00348” attached to this request in
exchange for their use or occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 54: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00347” through “SBERLO 00348” attached to
this request.
REQUEST FOR ADMISSION NO. 55: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00347” through “SBERLO
00348” attached to this request to use or occupy the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 56: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00349” through “SBERLO 00350” attached to this
request on the date listed to the photograph.
REQUEST FOR ADMISSION NO. 57: That YOU received RENT from the person in the
REQUESTS FOR ADMISSION27
28
LAW OFFICES OF
KAREN Y. UCHIYAMA
1444 Baker St
San Francisco, California
9418
photograph labeled “SBERLO 00349” through “SBERLO 00350” attached to this request in
exchange for their use or occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 58: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00349” through “SBERLO 00350” attached to
this request.
REQUEST FOR ADMISSION NO. 59: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00349” through “SBERLO
00350” attached to this request to use or occupy the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 60: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00351” through “SBERLO 00352” attached to this
request on the date listed to the photograph.
REQUEST FOR ADMISSION NO. 61: That YOU received RENT from the person in the
photograph labeled “SBERLO 00351” through “SBERLO 00352” attached to this request in
exchange for their use or occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 62: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00351” through “SBERLO 00352” attached to
this request.
REQUEST FOR ADMISSION NO. 63: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00351” through “SBERLO
00352” attached to this request to use or occupy the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 64: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00353” through “SBERLO 00354” attached to this
request on the date listed to the photograph.
REQUEST FOR ADMISSION NO. 65: That YOU received RENT from the person in the
photograph labeled “SBERLO 00353” through “SBERLO 00354” attached to this request in
exchange for their use or occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 66: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00353” through “SBERLO 00354” attached to
REQUESTS FOR ADMISSION27
28
LAW OFFICES OF
KAREN Y. UCHIYAMA
1441 Baker St
‘San Francisco, Calforia
41s
this request.
REQUEST FOR ADMISSION NO. 67: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00353” through “SBERLO
00354” attached to this request to use or occupy the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 68: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00355” through “SBERLO 00356” attached to this
request on the date listed to the photograph.
REQUEST FOR ADMISSION NO. 69: That YOU received RENT from the person in the
photograph labeled “SBERLO 00355” through “SBERLO 00356” attached to this request in
exchange for their use or occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 70: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00355” through “SBERLO 00356” attached to
this request.
REQUEST FOR ADMISSION NO. 71: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00355” through “SBERLO
00356” attached to this request to use or occupy the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 72: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00357” through “SBERLO 00358” attached to this
request on the date listed to the photograph.
REQUEST FOR ADMISSION NO. 73: That YOU received RENT from the person in the
photograph labeled “SBERLO 00357” through “SBERLO 00358” attached to this request in
exchange for their use or occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 74: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00357” through “SBERLO 00358” attached to
this request.
REQUEST FOR ADMISSION NO. 75: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00357” through “SBERLO
00358” attached to this request to use or occupy the SUBJECT PROPERTY.
REQUESTS FOR ADMISSION27
28
LAW OFFICES OF
KAREN Y. UCHIVAMA
1441 Baker St
‘San Francisca, Calionia
94118
REQUEST FOR ADMISSION NO. 76: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00359” through “SBERLO 00360” attached to this
request on the date listed to the photograph.
REQUEST FOR ADMISSION NO. 77: That YOU received RENT from the person in the
photograph labeled “SBERLO 00359” through “SBERLO 00360” attached to this request in
exchange for their use or occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 78: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00359” through “SBERLO 00360” attached to
this request.
REQUEST FOR ADMISSION NO. 79: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00359” through “SBERLO
00360” attached to this request to use or occupy the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 80: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00334” attached to this request on the date listed to the
photograph.
REQUEST FOR ADMISSION NO. 81: That YOU received RENT from the person in the
photograph labeled “SBERLO 00361” attached to this request in exchange for their use or
occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 82: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00361” attached to this request.
REQUEST FOR ADMISSION NO. 83: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00361” attached to this
request to use or occupy the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 84: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00362” through “SBERLO 00363” attached to this
request on the date listed to the photograph.
REQUEST FOR ADMISSION NO. 85: That YOU received RENT from the person in the
photograph labeled “SBERLO 00362” through “SBERLO 00363” attached to this request in
REQUESTS FOR ADMISSION27
28
LAW OFFICES OF
KAREN Y. UCHIYAMA
1441 Baker St
‘San Francisco, California
94115
exchange for their use or occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 86: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00362” through “SBERLO 00363” attached to
this request.
REQUEST FOR ADMISSION NO. 87: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00362” through “SBERLO
00363” attached to this request to use or occupy the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 88: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00364” through “SBERLO 00365” attached to this
request on the date listed to the photograph.
REQUEST FOR ADMISSION NO. 89: That YOU received RENT from the person in the
photograph labeled “SBERLO 00364” through “SBERLO 00365” attached to this request in
exchange for their use or occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 90: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00364” through “SBERLO 00365” attached to
this request.
REQUEST FOR ADMISSION NO. 91: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00364” through “SBERLO
00365” attached to this request to use or occupy the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 92: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00366” through “SBERLO 00367” attached to this
request on the date listed to the photograph.
REQUEST FOR ADMISSION NO. 93: That YOU received RENT from the person in the
photograph labeled “SBERLO 00366” through “SBERLO 00367” attached to this request in
exchange for their use or occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 94: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00366” through “SBERLO 00367” attached to
this request.
REQUESTS FOR ADMISSION.27
28
LAW OFFICES OF
KAREN Y. UCHIYAMA,
1441 Baker St
‘San Francisco, California
ents
REQUEST FOR ADMISSION NO. 95: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00366” through “SBERLO
00367” attached to this request to use or occupy the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 96: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00368” through “SBERLO 00369” attached to this
request on the date listed to the photograph.
REQUEST FOR ADMISSION NO. 97: That YOU received RENT from the person in the
photograph labeled “SBERLO 00368” through “SBERLO 00369” attached to this request in
exchange for their use or occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 98: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00368” through “SBERLO 00369” attached to
this request.
REQUEST FOR ADMISSION NO. 99: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00368” through “SBERLO
00369” attached to this request to use or occupy the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 100: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00370” through “SBERLO 00371” attached to this
request on the date listed to the photograph.
REQUEST FOR ADMISSION NO. 101: That YOU received RENT from the person in the
photograph labeled “SBERLO 00370” through “SBERLO 00371” attached to this request in
exchange for their use or occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 102: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00370” through “SBERLO 00371” attached to
this request.
REQUEST FOR ADMISSION NO. 103: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00370” through “SBERLO
00371” attached to this request to use or occupy the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 104: That YOU sublet the SUBJECT PROPERTY to the
REQUESTS FOR ADMISSION27
28
LAW OFFICES OF
KAREN Y. UCHIYAMA
1441 Baker St
‘San Francisco, California
person in photograph labeled “SBERLO 00372” through “SBERLO 00373” attached to this
request on the date listed to the photograph.
REQUEST FOR ADMISSION NO. 105: That YOU received RENT from the person in the
photograph labeled “SBERLO 00372” through “SBERLO 00373” attached to this request in
exchange for their use or occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 106: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00372” through “SBERLO 00373” attached to
this request.
REQUEST FOR ADMISSION NO. 107: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00372” through “SBERLO
00373” attached to this request to use or occupy the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 108: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00374” through “SBERLO 00375” attached to this
request on the date listed to the photograph.
REQUEST FOR ADMISSION NO. 109: That YOU received RENT from the person in the
photograph labeled “SBERLO 00374” through “SBERLO 00375” attached to this request in
exchange for their use or occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 110: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00374” through “SBERLO 00375” attached to
this request.
REQUEST FOR ADMISSION NO. 111: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00374” through “SBERLO
00375” attached to this request to use or occupy the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 112: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00376” through “SBERLO 00377” attached to this
request on the date listed to the photograph.
REQUEST FOR ADMISSION NO. 113: That YOU received RENT from the person in the
photograph labeled “SBERLO 00376” through “SBERLO 00377” attached to this request in
REQUESTS FOR ADMISSION:27
28
LAW OFFICES OF
KAREN Y. UCHIYAMA
1441 Baker St
‘San Francisco, California
ans
exchange for their use or occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 114: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00376” through “SBERLO 00377” attached to
this request.
REQUEST FOR ADMISSION NO. 115: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00376” through “SBERLO
00377” attached to this request to use or occupy the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 116: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00378” through “SBERLO 00379” attached to this
request on the date listed to the photograph.
REQUEST FOR ADMISSION NO, 117: That YOU received RENT from the person in the
photograph labeled “SBERLO 00378” through “SBERLO 00379” attached to this request in
exchange for their use or occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 118: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00378” through “SBERLO 00379” attached to
this request.
REQUEST FOR ADMISSION NO. 119: That YOU-did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00378” through “SBERLO
00379” attached to this request to use or occupy the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 120: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00380” through “SBERLO 00381” attached to this
request on the date listed to the photograph.
REQUEST FOR ADMISSION NO. 121: That YOU received RENT from the person in the
photograph labeled “SBERLO 00380” through “SBERLO 00381” attached to this request in
exchange for their use or occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO, 122: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00380” through “SBERLO 00381” attached to
this request.
REQUESTS FOR ADMISSION27
28
LAW OFFICES OF
KAREN Y. UCHIYAMA
1441 Baker St
‘san Francisco, California
94115
REQUEST FOR ADMISSION NO, 123: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00380” through “SBERLO
00381” attached to this request to use or occupy the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 124: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00382” through “SBERLO 00383” attached to this
request on the date listed to the photograph.
REQUEST FOR ADMISSION NO. 125: That YOU received RENT from the person in the
photograph labeled “SBERLO 00382” through “SBERLO 00383” attached to this request in
exchange for their use or occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 126: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00382” through “SBERLO 00383” attached to
this request.
REQUEST FOR ADMISSION NO. 127: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00382” through “SBERLO
00383” attached to this request to use or occupy the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 128: That YOU sublet the SUBJECT PROPERTY to the
person in photograph labeled “SBERLO 00384” through “SBERLO 00385” attached to this
request on the date listed to the photograph.
REQUEST FOR ADMISSION NO. 129: That YOU received RENT from the person in the
photograph labeled “SBERLO 00384” through “SBERLO 00385” attached to this request in
exchange for their use or occupancy of the SUBJECT PROPERTY.
REQUEST FOR ADMISSION NO. 130: That YOU gave keys to the SUBJECT PROPERTY
to the person in the photograph labeled “SBERLO 00384” through “SBERLO 00385” attached to
this request.
REQUEST FOR ADMISSION NO. 131: That YOU did not obtain prior written consent from
PLAINTIFF to allow the person in the photograph labeled “SBERLO 00384” through “SBERLO
00385” attached to this request to use or occupy the SUBJECT PROPERTY.
REQUESTS FOR ADMISSION27
28
LAW OFFICES OF
‘San Francisco, California
ants
DATED: September ¥_, 2013
KAREN&. UCHIY.
Attorney for Plaintiff
YOEL SBERLO, TRUSTEE FOR
SBERLO FAMILY TRUST
By: KiZ CL fever —
AMA ESQ.
DECLARATION OF KAREN Y. UCHIYAMA, ESQ.
I, Karen Y. Uchiyama declare:
1. I am presently the attorney of record for YOEL SBERLO, TRUSTEE FOR
SBERLO FAMILY TRUST, Plaintiff in this action.
2. 1 am propounding to Defendant YARNG ALTAWAL the attached set of
Requests for Admission.
3. This set of requests for admission will cause the total number of requests
propounded to the party to whom they are directed to exceed the number of 35 requests permitted
by Section 2033.030 of the Code of Civil Procedure.
4. I have previously propounded a total of -0- Requests for Admission to this
party.
5. This set of requests for admission contains a total of 131 requests.
6. Iam familiar with the issues and the discovery conducted by all of the
parties in the case.
7. I have personally examined each of the questions in this set of Requests
for Admission.
8. This number of questions is warranted under Section 2033.030 of the
Code of Civil Procedure because of the expedience of using this method of discovery to provide
to the responding parties the opportunity to conduct an inquiry, investigation, or search of files or
records to supply the information sought, and the relative simplicity of this case warrants
poe aa Bt ate a at
uillizing this method of discovery rather tr
REQUESTS FOR ADMISSION1 9. None of these questions in this set of requests for admission is being
2 | propounded for any improper purpose, such as to harass the parties, or the attorney for the
3 | parties, to which it is directed, or to cause unnecessary delay or needless increase in the cost of
4 | litigation.
5 I declare under penalty of perjury under the laws of the State of California that the
6 | foregoing is true and correct, and that this declaration was executed on September F, 2013.
Cee YUL. [plane
8 KAREN Y. YCHIYAMA
Attorney for eee
YOEL SBERLO, a, FOR SBERLO
10 FAMILY TRUST
27
28
LAW OFFICES OF
KAREN Y. UCHIYAMA
1441 Baker St
San Francisco, Calfomia
94118
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ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address)
KAREN Y. UCHIYAMA (SBN 154414)
|_ LAW OFFICES OF KAREN Y. UCHIYAMA.
144] BAKER STREET
SAN FRANCISCO, CA 94115
TELEPHONE NO. 415-563-9300
FAX NO, (Optional): 415-563-9304
E-MAIL ADDRESS (Optionai).
ATTORNEY FOR (Name): PLAINTIFF YOEL SBERLO, TRUSTEE FOR SBERLO FAMILY TRUST.
400 MCALLISTER STREET
SAN FRANCISCO, CA 94102
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO
SHORT TITLE OF CASE.
Yoel Sberlo, Trustee for Sberlo Family Trust v. Atlawal, et. al.
Answering Party: Yarng Altawal
Set No.: One
FORM INTERROGATORIES—GENERAL
Asking Party: Yoel Sberlo, Trustee for Sberlo Family Trust
‘CASE NUMBER
CUD-13-645401
Sec. 1. Instructions to All Parties
(a) Interrogatories are written questions prepared by a party
to an action that are sent to any other party in the action to be
answered under oath. The interrogatories below are form
interrogatories approved for use in civil cases.
(b) For time limitations, requirements for service on other
parties, and other details, see Code of Civil Procedure
sections 2030.010-2030.410 and the cases construing those
sections.
(c) These form interrogatories do not change existing law
relating to interrogatories nor do they affect an answering
party's right to assert any privilege or make any objection.
Sec. 2. Instructions to the Asking Party
(a) These interrogatories are designed for optional use by
parties in unlimited civil cases where the amount demanded
exceeds $25,000. Separate interrogatories, Form
Interrogatories—Limited Civil Cases (Economic Litigation)
(form DISC-004), which have no subparts, are designed for
use in limited civil cases where the amount demanded is
$25,000 or less; however, those interrogatories may also be
used in unlimited civil cases.
(b) Check the box nex
Preview
NA SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Document Scanning Lead Sheet Oct-31-2013 01:11 pm Case Number: CUD-13-645401 Filing Date: Oct-31-2013 01:08 pm Filed by: Juke Box: 001 Image: 04258940 DECLARATION SBERLO, YOEL, TRUSTEE FOR SBERLO FAMILY TRUST VS. YARNG ALTAWAL et al 001004258940 Instructions: Please place this sheet on top of the document to be scanned.27 28 LAW OFFICES OF KAREN Y. UCHIYAMA, 1441 Baker Street San Francis, California ons (415) 563-9300 @ 72 ORGINAL @ LAW OFFICES OF KAREN Y. UCHIYAMA KAREN Y. UCHIYAMA - STATE BAR NO. 154414 AARON A. FARMER — STATE BAR NO. 268921 1441 Baker Street San Francisco, California 94115 Telephone: (415) 563-9300 Facsimile: (415) 563-9304 Attorney for Plaintiff YOEL SBERLO, TRUSTEE FOR SBERLO FAMILY TRUST COUNTY OF SAN FRANCISCO - LIMITED CIVIL JURISDICTION YOEL SBERLO, TRUSTEE FOR SBERLO FAMILY TRUST, Case No. CUD-13-645401 DISCOVERY DECLARATION OF KAREN Y. UCHIYAMA, ESQ. IN SUPPORT OF PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES TO REQUESTS FOR ADMISSION, FORM INTERROGATORIES, AND FOR MONETARY SANCTIONS Plaintiff, Vv. YARNG ALTAWAL, SUSAN ALTAWAL, and DOES | through X, in occupancy, Defendants. Hearing: Date: November 12, 2013 Time: 9:30 a.m. Dept.: 501 eee eee DECLARATION OF KAREN Y. UCHIYAMA IN SUPPORT OF PLAINTIFF'S MOTION TO COMPEL FURTHER RESPONSES27 28 LAW OFFICES OF ‘San Francisco, Calfomia 94115 415) 563-9900, I, KAREN Y. UCHIYAMA, declare: 1. I am the attorney on record for Plaintiff YOEL SBERLO, TRUSTEE FOR SBERLO FAMILY TRUST and licensed to practice law in all of the court in California. The following statements are within my personal knowledge and I could and would testify to them if called as a witness. 2. Since September 2013, I have been battling with Defendants’ attorneys, Mark Hooshmand and Stephanie Foster over the scope of the discovery in this case. 3. On September 5, 2013, on behalf of Plaintiff YOEL SBERLO, TRUSTEE FOR SBERLO FAMILY TRUST, I drafted and served special interrogatories (set no. 1), request for production of documents and things (set no. 1), request for admission (set no. 1), form interrogatories-general (set no. 1), and form interrogatories-unlawful detainer (set no. 1) upon Defendant YARNG ALTAWAL via hand delivery to his attorney Mark Hooshmand by a licensed process server. The requests for admission are attached as Exhibit “A,” the form interrogatories-general are attached as Exhibit “B,” and the form interrogatories-unlawful detainer are attached as Exhibit “C” to the Declaration of Karen Y. Uchiyama filed herewith. A true and correct copy of the amended proof of service thereon is attached hereto as “Exhibit H.” 4. Defendants’ attorneys’ standard defense to a motion to compel is that their opponent “failed to meet and confer.” Nothing is further from the truth. Defendants’ two attorneys and my office have had ongoing arguments over discovery responses from Defendant YARNG ALTAWAL. 5. On September 17, 2013, I drafted a meet and confer letter outlining deficient discovery responses. A true and correct copy of my letter is attached hereto as “Exhibit G.” 6. In response to my letter of September 17, 2013, a string of three emails were exchanged between my office and Defendant’s attorneys’. Defendant’s attorneys’ did not meet and confer on the form interrogatories. Rather they only responded concerning special interrogatories, request for admissions, and request for production of documents. True and correct copies of the emails are attached hereto as “Exhibit G.” DECLARATION OF KAREN Y. UCHIYAMA IN SUPPORT OF PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES27 28 LAW OFFICES OF tS (415) 588-8900 7. On October 1, 2013, after the hearing on Defendant’s motion for protective order, there was an in person discussion concerning the discovery disputes between Mark Hooshmand, Aaron Farmer, and me. An informal resolution of the discovery disputes was not accomplished. Shockingly, at this meeting, Defendant’s attorney Mark Hooshmand informed me that he was “not worried about being sanctioned by the Court in response to a motion to compel.” 8. Thereafter, a series of three emails were exchanged between my office and Defendant’s attorneys’. Defendants’ attorneys’ did not meet and confer on the form interrogatories. Rather, they only responded concerning special interrogatories, request for admissions, and request for production of documents. True and correct copies of the emails are attached hereto as “Exhibit G.” 9. On October 3, 2013, wrote a letter to Defendant’s attorney proposing a resolution of the outstanding discovery issues on some of the requests for admission, and the special interrogatories in dispute. 4 true and correct copy of my letter is attached hereto as “Exhibit G.” 10. On October 10, 2013, Defendant’s attorney wrote me a letter concerning my proposed resolution. However, Defendant’s attorney did not commit to providing any responses. Further, he was still silent concerning the form interrogatories. A true and correct copy of this letter is attached hereto as “Exhibit G.” 11. Thereafter, a series of 10 emails were exchanged between my office and Defendant’s attorneys’. Defendants’ attorneys’ did not meet and confer on the form interrogatories. Rather, they only responded concerning special interrogatories, request for admissions, and request for production of documents. True and correct copies of the emails are attached hereto as “Exhibit G.” 12. On October 6, 2013, Defendant ALTAWAL provided supplemental responses to the request for production of documents. Counsel is still meeting and conferring on these responses. 13. On October 29, 2013, Defendant ALTAWAL provided supplemental DECLARATION OF KAREN Y. UCHIYAMA IN SUPPORT OF PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES28 LAW OFFICES OF KAREN Y. UCHIYAMA 1441 Baker Street Sin Francia, Cafomia 115 cars) 5809000 responses to Plaintiff's special interrogatories. Counsel is still meeting and conferring on these responses. 14, The Court can now conclude that Defendant ALTAWAL and his attorneys willfully refused to comply with the discovery process and forced me to have to file a motion to compel. They should be compelled to provide proper responses. Defendant and his attorneys should be sanctioned for the costs of this motion on the grounds that their conduct is an abuse of the discovery process to prevent Plaintiff from obtaining relevant evidence in this case, and to be unprepared at trial. 13. have spent over 2 hours attempting to resolve these disputes informally with Defendant ALTAWAL/’s attorneys, and drafting this lengthy and time-consuming motion. The Separate Statement is 23 pages long! I feel that my office had adequately threatened them with a motion to compel further responses and seek monetary sanctions, but they just ignored me. I anticipate spending another hour of my time at the hearing on this motion as well. 14. My billable hourly rate is $310.00. 15. Therefore, Plaintiffs requests a court order compelling further responses from Defendant YARNG ALTAWAL to Plaintiff's request for admission (set no. 1), form interrogatories-general (set no. 1), and form interrogatories-unlawful detainer (set no. 1). 16. Plaintiff also seeks monetary sanctions against Defendant YARNG ALTAWAL and his attorneys for the cost of this motion in the amount of $4,385.00, which is composed of the $60.00 filing fee and 15 hours of attorney’s fees ($4,325.00) to prepare this Motion to Compel Further Responses; Memorandum of Points and Authorities, Separate Statement, Declaration of Karen Y. Uchiyama, Esq. and for her attendance at the hearing on this motion. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed this 30" day of October, 2013, in San Francisco, Nese. Miley KAREN Y. wparvama (77 California. DECLARATION OF KAREN Y. UCHIYAMA IN SUPPORT OF PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES,DISC-020 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY |_KAREN Y. UCHIYAMA, SBN 154414 1441 BAKER STREET SAN FRANCISCO, CA 94115. TELEPHONENO 415-563-9300 FAXNO (Optionay, 415-563-9304 E-MAIL ADDRESS (Optional). ATTORNEY FOR (Name): Yoel Sberlo, Trustee for Sberlo Family Trust SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Francisco streetaporess 400 McAllister Street maine aooress 400 McAllister Strett ciryanozipcooet. San Francisco, CA 94102 sranckname Limited Civil Jurisdiction ‘SHORT TITLE: Yoel Sberlo, Trustee for Sberlo Family Trust v. Altawal, et. al. ‘CASE NUMBER: REQUESTS FOR ADMISSION Truth of Facts [_] Genuineness of Documents CUD-13-645401 Requesting Party: Yoel Sberlo, Trustee for Sberlo Family Trust Answering Party: Yarng Altawal Set No.: One INSTRUCTIONS Requests for admission are written requests by a party to an action requiring that any other party to the action either admit or deny, under oath, the truth of certain facts or the genuineness of certain documents. For information on timing, the number of admissions a party may request from any other party, service of requests and responses, restrictions on the style, format, and scope of requests for admission and responses to requests, and other details, see Code of Civil Procedure sections 94-95, 1013, and 2033.010-2033.420 and the case law relating to those sections. An answering party should consider carefully whether to admit or deny the truth of facts or the genuineness of documents. With limited exceptions, an answering party will not be allowed to change an answer to a request for admission. There may be penalties if an answering party fails to admit the truth of any fact or the genuineness of any document when requested to do so and the requesting party later proves that the fact is true or that the document is genuine. These penalties may include, among other things, payment of the requesting party’s attorney’s fees incurred in making that proof. Unless there is an agreement or a court order providin: ise, He party must respond in writing to requests for admission within 30-days-afterthey-are-served, or withlg 5 days after service in an unlawful detainer action. There may be significant penalties if an answering party fails to provide a timely wi ach request for admission. These penalties may include, among other things, an order that the facts in issue are deemed true or that the documents in issue are deemed genuine for purposes of the case. Answers to Requests for Admission must be given under oath. The answering party should use the following language at the end of the responses: | declare under penalty of perjury under the laws of the State of California that the foregoing answers are true and correct. (DATE) (SIGNATURE) These instructions are only a summary and are not intended to provide complete information about requests for admission. This Requests for Admission form does not change existing law relating to requests for admissions, nor does it affect an answering party's right to assert any privilege or to make any objection. REQUESTS EF. ION You are requested to admit within Sé-days-eftersenice, of within 5 service in an unlawful detainer action, of this Requests for Admission that: Each of the following facts is true (if more than one, number each fact consecutively). Continued on Attachment 1 2. [) The original of each of the following documents, copies of which are attached, is genuine (if more than one, number each document consecutively). Continued on Attachment 2 a YO Deaf Jf Karen Y. Uchiyama, Esq. » Agta. Lf, Ltr {TYPE OR PRINT NAME) /JBIGNATURE OF PARTYOR JTTORNEY) Page tof 1 ‘Code of Gil Procedure, Form Approved tr Opnonal Use REQUESTS FOR ADMISSION Chavos, 2000 Fee as05 san sat Judicial Counc of California ISC-020 [Rev. January 1, 2008}27 28 LAW OFFICES OF KAREN Y, UCHIVAMA 1441 Baker St San Francisco, California ents I, 1. ATTACHMENT 1 DEFINITIONS AND INSTRUCTIONS “PLAINTIFF” means plaintiff YOEL SBERLO, TRUSTEE FOR SBERLO FAMILY TRUST, his employees, officers, directors, agents, attorneys and all other persons acting on his behalf. “DEFENDANT(S)” means all defendants named in the complaint, either individually or collectively, including their employees, officers, directors, agents, attorneys and all other persons acting on their behalf. “YOU” or “YOUR” means Defendant YARNG ALTAWAL. “DOCUMENT” means any written, printed, typed, recorded, magnetic, punched, copied, graphic or other tangible thing in, upon, or from which information may be conveyed, embodied, translated, or stored, including, but not limited to, papers, records, books, telegrams, telexes, dictation or other audio tapes, video tapes, computer tapes, computer disks, computer printouts, microfilm, microfiche, laser disks, diaries, calendars, photographs, charts, view graphs, drawings, sketches and all other writings or drafts thereof, as well as all other tangible things subject to statute. This definition expressly includes, without limitation, all originals, drafts, non-conforming copies, reproductions, facsimiles of written, typed or printed material of any kind, books, letters, contracts, minutes of meetings, memoranda, notes on desk calendars and appointment books, canceled checks, invoices, correspondence, telegrams, telex messages, intra-office communications, photographs and films, art work and information stored on tape, computer disk or any other type of data storage device. If copies of a document are not identical by reason of hand notations, initials, identification marks or any other modification, each such non-identical copy is a separate document within the meaning of this definition. “COMMUNICATION” means any transmission from one person or entity to another, including, without limitation, by personal meeting, telephone, letter, REQUESTS FOR ADMISSION27 28 LAW OFFICES OF KAREN Y. UCHIYAMA 1441 Baker St San Francisco, California ens 13. electronic mail, teleconference, facsimile, telex, etc. “PERSON(S)” means any natural person and any other cognizable entity, including, without limitation, corporations, proprietorships, partnership, joint ventures, consortiums, clubs, associations, foundations, governmental agencies or instrumentalities, societies and orders. As used herein, the acts and knowledge of a “person” are defined to include the acts and knowledge of that person’s directors, officers, members, employees, licensees, representatives, agents, attorneys and all other persons acting on that person's behalf. “AND” shall mean “or” and “or” shall mean “and” whenever necessary to infer the broadest possible meaning to a particular document request. As used in these document requests, the singular shall include the plural and the plural shall include the singular whenever necessary to infer the broadest possible meaning to a particular request. The terms “REFER TO,” “REFERRING TO,” “RELATE TO,” “RELATING TO,” “PERTAIN TO,” or “PERTAINING TO” mean consisting of, summarizing, explaining, describing, discussing, mentioning, concerning, illustrating, referring to, alluding to, responding to, connected with, commenting on, in respect of, about, regarding, discussing, involving, reflecting, analyzing, constituting or referring to in any way. “COMPLAINT” means the First Amended Complaint filed by Plaintiff in this action. “THE SUBJECT PROPERTY” means the real property located at 1780 McAllister Street, Unit #3, San Francisco, California 94115. “IDENTIFY” means, in the case of PERSONS, list the name, address, telephone number and facsimile number of any person responsive to the requests. In all other requests, it means list, state, or name. The term “THREE DAY NOTICE” refers to the Three Day Notice to Quit that is attached to the First Amended Complaint in this action as “Exhibit 4.” REQUESTS FOR ADMISSION24 25 26 27 28 LAW OFFICES OF KAREN Y. UCHIYAMA 1441 Baker St San Francisco, California 94115 14. The term “TENANT IN OCCUPANCY” as defined by the San Francisco Rent Ordinance and as used herein means an individual who otherwise meets the definition of tenant as set forth in Ordinance Section 37.2(t), and who resides in a rental unit as his or her principal place of residence. 15. The term “PRINCIPAL RESIDENCE” as defined by the San Francisco Rent Ordinance and as used herein means one’s “Usual Place of Return.” More particularly, the place listed on one’s motor vehicle registration, tax returns, driver's license, voter registration, public agencies, and where an individual’s personal possessions are located, and the place where the individual normally returns to as his or her home, exclusive of military service, hospitalization, vacation, family emergency, travel necessitated by employment or education, or other reasonable temporary periods of absence. 16. The term “RENT” as defined by the San Francisco Rent Ordinance and as used herein means he consideration, including any bonus, benefits or gratuity, demanded or received for or in connection with the use or occupancy of a rental unit, or the assignment of a lease for such a unit, including but not limited to monies demanded or paid for parking, furnishings, food service, housing services of any kind, or subletting as set forth in Ordinance Section 37.2(p). REQUESTS FOR ADMISSION Admit that the following facts are true: REQUEST FOR ADMISSION NO. 1: That YOU allow other persons to stay, use or occupy the Subject Property in exchange for RENT between January 1, 2012, and May 8, 2013. REQUEST FOR ADMISSION NO. 2: That more than two PERSONS were simultaneously living, using or occupying the SUBJECT PROPERTY as their PRINCIPAL RESIDENCE between January 1, 2012, and May 8, 2013. REQUEST FOR ADMISSION NO. 3: That Susan Altawal stopped using and occupying the the SUBJECT PROPERTY as her PRINCIPAL RESIDENCE sometime in 2012. REQUEST FOR ADMISSION NO. 4: That YOU did not inform PLAINTIFF that Susan REQUESTS FOR ADMISSION27 28 LAW OFFICES OF KAREN Y. UCHIYAMA. 1441 Baker St ‘San Francisco, California 94135 Altawal moved out of the SUBJECT PROPERTY in 2012. REQUEST FOR ADMISSION NO. 5: That YOU did not obtain prior written consent from PLAINTIFF for you to allow other persons to stay, use or occupy the SUBJECT PROPERTY in exchange for RENT at any time between January 1, 2012, and May 8, 2013. REQUEST FOR ADMISSION NO. 6: That YOUR tenancy at the SUBJECT PROPERTY is subject to the rental contract attached to the COMPLAINT as “Exhibit 1.” REQUEST FOR ADMISSION NO. 7: That the rental contract controlling YOUR tenancy at the SUBJECT PROPERTY, otherwise known as Exhibit | to the COMPLAINT, prohibits subletting. REQUEST FOR ADMISSION NO. 10: That YOU gave keys to the SUBJECT PROPERTY to other people between January 1, 2012, and May 8, 2013. REQUEST FOR ADMISSION NO. 11: That YOU allowed PERSONS to stay, use, occupy and sleep at the SUBJECT PROPERTY as his or her PRINCIPAL RESIDENCE without the prior written consent of PLAINTIFF between January 1, 2012, and May 8, 2013. REQUEST FOR ADMISSION NO. 12: That YOU sometimes collected more monthly RENT from unauthorized occupants staying with YOU at the SUBJECT PROPERTY than the amount of lawful monthly rent YOU paid to PLAINTIFF between January 1, 2012, and May 8, 2013. REQUEST FOR ADMISSION NO. 13: That YOU are separated from SUSAN ALTAWAL as YOUR spouse. REQUEST FOR ADMISSION NO. 14: That YOU are divorcing SUSAL ALTAWAL. REQUEST FOR ADMISSION NO. 15: That SUSAL ALTAWAL vacated the SUBJECT PROPERTY to live in a womens’ shelter in 2012. REQUEST FOR ADMISSION NO. 16: That YOU could not afford to pay the monthly rent for the SUBJECT PROPERTY without SUSAN ALTAWAL/’s income. REQUEST FOR ADMISSION NO. 17: That YOU did not have $2,271.00 in your bank account(s) on the day the Three Day Notice to Pay Rent or Quit expired on May 6, 2013. REQUEST FOR ADMISSION NO. 18: That YOU deposited the RENT that YOU collected from others into YOUR bank account from which YOU wrote rent checks to PLAINTIFF. REQUESTS FOR ADMISSION27 28 LAW OFFICES OF KAREN Y. UCHIYAMA, 1441 Baker St San Francisco, California gents REQUEST FOR ADMISSION NO. 19: That one or more of the occupants who moved out of the SUBJECT PROPERTY left his or her keys with the clerk at the corner store for YOU to pick up. REQUEST FOR ADMISSION NO. 20: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00334” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO. 21: That YOU received RENT from the person in the photograph labeled “SBERLO 00334” attached to this request in exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 22: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00334” attached to this request. REQUEST FOR ADMISSION NO. 23: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00334” attached to this request to use or occupy the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 24: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00335” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO. 25: That YOU received RENT from the person in the photograph labeled “SBERLO 00335” attached to this request in exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 26: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00335” attached to this request. REQUEST FOR ADMISSION NO. 27: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00335” attached to this request to use or occupy the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 28: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00336” attached to this request on the date listed to the photograph. REQUESTS FOR ADMISSION27 28 LAW OFFICES OF KAREN Y. UCHIYAMA 1441 Baker St San Francisco, Caifomia REQUEST FOR ADMISSION NO. 29: That YOU received RENT from the person in the photograph labeled “SBERLO 00336” attached to this request in exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 30: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00336” attached to this request. REQUEST FOR ADMISSION NO. 31: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00336” attached to this request to use or occupy the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 32: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00337” through “SBERLO 00338” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO. 33: That YOU received RENT from the person in the photograph labeled “SBERLO 00337” through “SBERLO 00338” attached to this request in exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 34: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00337” through “SBERLO 00338” attached to this request. REQUEST FOR ADMISSION NO. 35: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00337” through “SBERLO 00338” attached to this request to use or occupy the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 36: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00339” through “SBERLO 00340” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO. 37: That YOU received RENT from the person in the photograph labeled “SBERLO 00339” through “SBERLO 00340” attached to this request in exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 38: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00339” through “SBERLO 00340” attached to REQUESTS FOR ADMISSION27 28 LAW OFFICES OF KAREN Y. UCHIYAMA. 1443 Baker St ‘San Francisco, Califonia 96118 this request. REQUEST FOR ADMISSION NO. 39: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00339” through “SBERLO 00340” attached to this request to use or occupy the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 40: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00341” through “SBERLO 00342” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO. 41: That YOU received RENT from the person in the photograph labeled “SBERLO 00341” through “SBERLO 00342” attached to this request in exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO, 42: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00341” through “SBERLO 00342” attached to this request. REQUEST FOR ADMISSION NO. 43: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00341” through “SBERLO 00342” attached to this request to use or occupy the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 44: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00343” through “SBERLO 00344” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO. 45: That YOU received RENT from the person in the photograph labeled “SBERLO 00343” through “SBERLO 00344” attached to this request in exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 46: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00343” through “SBERLO 00344” attached to this request. REQUEST FOR ADMISSION NO. 47: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00343” through “SBERLO 00344” attached to this request to use or occupy the SUBJECT PROPERTY. REQUESTS FOR ADMISSION27 28 LAW OFFICES OF KAREN Y. UCHIYAMA, 481 Baker St. ‘San Francisco, California 94118 REQUEST FOR ADMISSION NO. 48: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00345” through “SBERLO 00346” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO. 49: That YOU received RENT from the person in the photograph labeled “SBERLO 00345” through “SBERLO 00346” attached to this request in exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 50: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00345” through “SBERLO 00346” attached to this request. REQUEST FOR ADMISSION NO. 51: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00345” through “SBERLO 00346” attached to this request to use or occupy the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 52: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00347” through “SBERLO 00348” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO. 53: That YOU received RENT from the person in the photograph labeled “SBERLO 00347” through “SBERLO 00348” attached to this request in exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 54: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00347” through “SBERLO 00348” attached to this request. REQUEST FOR ADMISSION NO. 55: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00347” through “SBERLO 00348” attached to this request to use or occupy the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 56: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00349” through “SBERLO 00350” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO. 57: That YOU received RENT from the person in the REQUESTS FOR ADMISSION27 28 LAW OFFICES OF KAREN Y. UCHIYAMA 1444 Baker St San Francisco, California 9418 photograph labeled “SBERLO 00349” through “SBERLO 00350” attached to this request in exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 58: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00349” through “SBERLO 00350” attached to this request. REQUEST FOR ADMISSION NO. 59: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00349” through “SBERLO 00350” attached to this request to use or occupy the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 60: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00351” through “SBERLO 00352” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO. 61: That YOU received RENT from the person in the photograph labeled “SBERLO 00351” through “SBERLO 00352” attached to this request in exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 62: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00351” through “SBERLO 00352” attached to this request. REQUEST FOR ADMISSION NO. 63: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00351” through “SBERLO 00352” attached to this request to use or occupy the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 64: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00353” through “SBERLO 00354” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO. 65: That YOU received RENT from the person in the photograph labeled “SBERLO 00353” through “SBERLO 00354” attached to this request in exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 66: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00353” through “SBERLO 00354” attached to REQUESTS FOR ADMISSION27 28 LAW OFFICES OF KAREN Y. UCHIYAMA 1441 Baker St ‘San Francisco, Calforia 41s this request. REQUEST FOR ADMISSION NO. 67: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00353” through “SBERLO 00354” attached to this request to use or occupy the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 68: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00355” through “SBERLO 00356” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO. 69: That YOU received RENT from the person in the photograph labeled “SBERLO 00355” through “SBERLO 00356” attached to this request in exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 70: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00355” through “SBERLO 00356” attached to this request. REQUEST FOR ADMISSION NO. 71: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00355” through “SBERLO 00356” attached to this request to use or occupy the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 72: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00357” through “SBERLO 00358” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO. 73: That YOU received RENT from the person in the photograph labeled “SBERLO 00357” through “SBERLO 00358” attached to this request in exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 74: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00357” through “SBERLO 00358” attached to this request. REQUEST FOR ADMISSION NO. 75: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00357” through “SBERLO 00358” attached to this request to use or occupy the SUBJECT PROPERTY. REQUESTS FOR ADMISSION27 28 LAW OFFICES OF KAREN Y. UCHIVAMA 1441 Baker St ‘San Francisca, Calionia 94118 REQUEST FOR ADMISSION NO. 76: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00359” through “SBERLO 00360” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO. 77: That YOU received RENT from the person in the photograph labeled “SBERLO 00359” through “SBERLO 00360” attached to this request in exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 78: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00359” through “SBERLO 00360” attached to this request. REQUEST FOR ADMISSION NO. 79: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00359” through “SBERLO 00360” attached to this request to use or occupy the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 80: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00334” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO. 81: That YOU received RENT from the person in the photograph labeled “SBERLO 00361” attached to this request in exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 82: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00361” attached to this request. REQUEST FOR ADMISSION NO. 83: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00361” attached to this request to use or occupy the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 84: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00362” through “SBERLO 00363” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO. 85: That YOU received RENT from the person in the photograph labeled “SBERLO 00362” through “SBERLO 00363” attached to this request in REQUESTS FOR ADMISSION27 28 LAW OFFICES OF KAREN Y. UCHIYAMA 1441 Baker St ‘San Francisco, California 94115 exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 86: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00362” through “SBERLO 00363” attached to this request. REQUEST FOR ADMISSION NO. 87: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00362” through “SBERLO 00363” attached to this request to use or occupy the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 88: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00364” through “SBERLO 00365” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO. 89: That YOU received RENT from the person in the photograph labeled “SBERLO 00364” through “SBERLO 00365” attached to this request in exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 90: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00364” through “SBERLO 00365” attached to this request. REQUEST FOR ADMISSION NO. 91: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00364” through “SBERLO 00365” attached to this request to use or occupy the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 92: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00366” through “SBERLO 00367” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO. 93: That YOU received RENT from the person in the photograph labeled “SBERLO 00366” through “SBERLO 00367” attached to this request in exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 94: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00366” through “SBERLO 00367” attached to this request. REQUESTS FOR ADMISSION.27 28 LAW OFFICES OF KAREN Y. UCHIYAMA, 1441 Baker St ‘San Francisco, California ents REQUEST FOR ADMISSION NO. 95: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00366” through “SBERLO 00367” attached to this request to use or occupy the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 96: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00368” through “SBERLO 00369” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO. 97: That YOU received RENT from the person in the photograph labeled “SBERLO 00368” through “SBERLO 00369” attached to this request in exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 98: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00368” through “SBERLO 00369” attached to this request. REQUEST FOR ADMISSION NO. 99: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00368” through “SBERLO 00369” attached to this request to use or occupy the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 100: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00370” through “SBERLO 00371” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO. 101: That YOU received RENT from the person in the photograph labeled “SBERLO 00370” through “SBERLO 00371” attached to this request in exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 102: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00370” through “SBERLO 00371” attached to this request. REQUEST FOR ADMISSION NO. 103: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00370” through “SBERLO 00371” attached to this request to use or occupy the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 104: That YOU sublet the SUBJECT PROPERTY to the REQUESTS FOR ADMISSION27 28 LAW OFFICES OF KAREN Y. UCHIYAMA 1441 Baker St ‘San Francisco, California person in photograph labeled “SBERLO 00372” through “SBERLO 00373” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO. 105: That YOU received RENT from the person in the photograph labeled “SBERLO 00372” through “SBERLO 00373” attached to this request in exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 106: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00372” through “SBERLO 00373” attached to this request. REQUEST FOR ADMISSION NO. 107: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00372” through “SBERLO 00373” attached to this request to use or occupy the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 108: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00374” through “SBERLO 00375” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO. 109: That YOU received RENT from the person in the photograph labeled “SBERLO 00374” through “SBERLO 00375” attached to this request in exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 110: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00374” through “SBERLO 00375” attached to this request. REQUEST FOR ADMISSION NO. 111: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00374” through “SBERLO 00375” attached to this request to use or occupy the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 112: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00376” through “SBERLO 00377” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO. 113: That YOU received RENT from the person in the photograph labeled “SBERLO 00376” through “SBERLO 00377” attached to this request in REQUESTS FOR ADMISSION:27 28 LAW OFFICES OF KAREN Y. UCHIYAMA 1441 Baker St ‘San Francisco, California ans exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 114: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00376” through “SBERLO 00377” attached to this request. REQUEST FOR ADMISSION NO. 115: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00376” through “SBERLO 00377” attached to this request to use or occupy the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 116: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00378” through “SBERLO 00379” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO, 117: That YOU received RENT from the person in the photograph labeled “SBERLO 00378” through “SBERLO 00379” attached to this request in exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 118: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00378” through “SBERLO 00379” attached to this request. REQUEST FOR ADMISSION NO. 119: That YOU-did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00378” through “SBERLO 00379” attached to this request to use or occupy the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 120: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00380” through “SBERLO 00381” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO. 121: That YOU received RENT from the person in the photograph labeled “SBERLO 00380” through “SBERLO 00381” attached to this request in exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO, 122: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00380” through “SBERLO 00381” attached to this request. REQUESTS FOR ADMISSION27 28 LAW OFFICES OF KAREN Y. UCHIYAMA 1441 Baker St ‘san Francisco, California 94115 REQUEST FOR ADMISSION NO, 123: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00380” through “SBERLO 00381” attached to this request to use or occupy the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 124: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00382” through “SBERLO 00383” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO. 125: That YOU received RENT from the person in the photograph labeled “SBERLO 00382” through “SBERLO 00383” attached to this request in exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 126: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00382” through “SBERLO 00383” attached to this request. REQUEST FOR ADMISSION NO. 127: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00382” through “SBERLO 00383” attached to this request to use or occupy the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 128: That YOU sublet the SUBJECT PROPERTY to the person in photograph labeled “SBERLO 00384” through “SBERLO 00385” attached to this request on the date listed to the photograph. REQUEST FOR ADMISSION NO. 129: That YOU received RENT from the person in the photograph labeled “SBERLO 00384” through “SBERLO 00385” attached to this request in exchange for their use or occupancy of the SUBJECT PROPERTY. REQUEST FOR ADMISSION NO. 130: That YOU gave keys to the SUBJECT PROPERTY to the person in the photograph labeled “SBERLO 00384” through “SBERLO 00385” attached to this request. REQUEST FOR ADMISSION NO. 131: That YOU did not obtain prior written consent from PLAINTIFF to allow the person in the photograph labeled “SBERLO 00384” through “SBERLO 00385” attached to this request to use or occupy the SUBJECT PROPERTY. REQUESTS FOR ADMISSION27 28 LAW OFFICES OF ‘San Francisco, California ants DATED: September ¥_, 2013 KAREN&. UCHIY. Attorney for Plaintiff YOEL SBERLO, TRUSTEE FOR SBERLO FAMILY TRUST By: KiZ CL fever — AMA ESQ. DECLARATION OF KAREN Y. UCHIYAMA, ESQ. I, Karen Y. Uchiyama declare: 1. I am presently the attorney of record for YOEL SBERLO, TRUSTEE FOR SBERLO FAMILY TRUST, Plaintiff in this action. 2. 1 am propounding to Defendant YARNG ALTAWAL the attached set of Requests for Admission. 3. This set of requests for admission will cause the total number of requests propounded to the party to whom they are directed to exceed the number of 35 requests permitted by Section 2033.030 of the Code of Civil Procedure. 4. I have previously propounded a total of -0- Requests for Admission to this party. 5. This set of requests for admission contains a total of 131 requests. 6. Iam familiar with the issues and the discovery conducted by all of the parties in the case. 7. I have personally examined each of the questions in this set of Requests for Admission. 8. This number of questions is warranted under Section 2033.030 of the Code of Civil Procedure because of the expedience of using this method of discovery to provide to the responding parties the opportunity to conduct an inquiry, investigation, or search of files or records to supply the information sought, and the relative simplicity of this case warrants poe aa Bt ate a at uillizing this method of discovery rather tr REQUESTS FOR ADMISSION1 9. None of these questions in this set of requests for admission is being 2 | propounded for any improper purpose, such as to harass the parties, or the attorney for the 3 | parties, to which it is directed, or to cause unnecessary delay or needless increase in the cost of 4 | litigation. 5 I declare under penalty of perjury under the laws of the State of California that the 6 | foregoing is true and correct, and that this declaration was executed on September F, 2013. Cee YUL. [plane 8 KAREN Y. YCHIYAMA Attorney for eee YOEL SBERLO, a, FOR SBERLO 10 FAMILY TRUST 27 28 LAW OFFICES OF KAREN Y. UCHIYAMA 1441 Baker St San Francisco, Calfomia 94118 REQUESTS FOR ADMISSIONSBERLO 00334SBERLO 002368 in B oe Q 2 8 Ba2 & ay as 6 3 g gae SBERLO 00338a SSMS SBERLO 00339Oredd O1WSRSQ a m 2 & Oo Si s $g m BD & o By & 3vreOd OTH2ES : : : aac OneO yeh SBERLO 00345cee ee oe : i is So 9¥e00 O1NaES:DE Be 2 B m a 2 oO 2 8 g agoF a 2 Oo 8 8 &gD a g 2 oF 8 8 ges ee poe fe Lge00 O1NSES DNg 3 2 5 8 8 8 oS NS Se aseseoo O1NSES2 a B 2 o at 8 &>wo a my B 2 oO 3 3_ es ae SBERLO 00357< = a a ee . oe — oe Ree awo @ 2B é o 3 3SBERLO 00360oe ge $S£00 OTYSES:ee ee ee 29¢00 O1USES:eeieee sasha! SBERLO 00363— alee SBERLO 00364g al 2 °o 8 3 8of g my 2 oO 8 32 @ g 2 ° 8 $— age0d O1W3ESol a By 2 oF 3 gSBERLO 00370® i 2 oO & g@ o ae Be 2 O€ 8 SF vnalee pee a¥2£00 O1NSES: hey i Ro Ry ie ar bat oe i oe =g 2 z ° = aa ae ve ae Es co _ eet SBERLO 00378a oO m 2 oO g 4Sc Winey ee reuie) We SBERLO 00378ae erie ed) SBERLO 00379Q oS oO 2 o 8 8a o mh 2 2 a & 8SBERLO 00383a cS yeed0 OTHSESDISC-001 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address) KAREN Y. UCHIYAMA (SBN 154414) |_ LAW OFFICES OF KAREN Y. UCHIYAMA. 144] BAKER STREET SAN FRANCISCO, CA 94115 TELEPHONE NO. 415-563-9300 FAX NO, (Optional): 415-563-9304 E-MAIL ADDRESS (Optionai). ATTORNEY FOR (Name): PLAINTIFF YOEL SBERLO, TRUSTEE FOR SBERLO FAMILY TRUST. 400 MCALLISTER STREET SAN FRANCISCO, CA 94102 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO SHORT TITLE OF CASE. Yoel Sberlo, Trustee for Sberlo Family Trust v. Atlawal, et. al. Answering Party: Yarng Altawal Set No.: One FORM INTERROGATORIES—GENERAL Asking Party: Yoel Sberlo, Trustee for Sberlo Family Trust ‘CASE NUMBER CUD-13-645401 Sec. 1. Instructions to All Parties (a) Interrogatories are written questions prepared by a party to an action that are sent to any other party in the action to be answered under oath. The interrogatories below are form interrogatories approved for use in civil cases. (b) For time limitations, requirements for service on other parties, and other details, see Code of Civil Procedure sections 2030.010-2030.410 and the cases construing those sections. (c) These form interrogatories do not change existing law relating to interrogatories nor do they affect an answering party's right to assert any privilege or make any objection. Sec. 2. Instructions to the Asking Party (a) These interrogatories are designed for optional use by parties in unlimited civil cases where the amount demanded exceeds $25,000. Separate interrogatories, Form Interrogatories—Limited Civil Cases (Economic Litigation) (form DISC-004), which have no subparts, are designed for use in limited civil cases where the amount demanded is $25,000 or less; however, those interrogatories may also be used in unlimited civil cases. (b) Check the box nex