On October 05, 2017 a
Trial Materials
was filed
involving a dispute between
Big Washington, Llc, A California Limited Liability Company,
and
Benhong,
Ruth M. Fry As Trustee Of The T & R Fry Family Trust,
Thomas H. Fry As Trustee Of The T&R Fry Family Trust,
for 26-CV Other Real Property-Civil Unlimited
in the District Court of Kern County.
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1 William L. Alexander (State Bar Number 126607)
Elizabeth Estrada (State Bar Number 232302)
2 Alexander & Associates, PLC
3 1925 G Street
Bakersfield, CA 93301
4 Phone: (661) 316-7888
Email: walexander@alexander-law.com; service@alexander-law.com
5
6 Attorneys for Defendants, Thomas H. Fry and Ruth M. Fry
as Trustees of the T & R Fry Family Trust
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF KERN – METROPOLITAN DIVISION
10 BIG WASHINGTON, LLC, a California ) Case No. BCV-17-102341 BCB
Limited Liability Company, )
11 ) DEFENDANTS’ FIRST AMENDED
Plaintiff, ) EXHIBIT LIST
12 )
13 vs. )
) Assigned to: Hon. Bernard C. Barmann, Jr.
14 BENHONG (AMERICA) RECYCLING CO. ) Div.: H
LTD, a California Limited Liability Company; ) Trial date: December 5, 2022
15 ) Time: 9:00 a.m.
and THOMAS H. FRY and RUTH M. FRY as
16 Trustees of the T & R FRY FAMILY TRUST; )
and DOES 1 – 100, inclusive, ) Complaint Filed: October 6, 2017
17 )
Defendants. )
18
)
19 )
20 Defendants, Thomas H. Fry and Ruth M. Fry as Trustees of the T&R Fry Family Trust,
21 respectfully submit the attached amended list of exhibits to be marked as an exhibit and introduced
22 into evidence at the time of trial in this matter. Defendants also reserve the right to rely on all
23 depositions, all deposition exhibits, pleadings, and discovery responses.
24
25 Dated: November 29, 2022 ALEXANDER & ASSOCIATES
26
27 By: /s/ Elizabeth Estrada /s/
ELIZABETH ESTRADA
28 Attorneys for Defendants
1
Alexander & Associates
Attorneys at Law
1925 G Street
Bakersfield, CA 93301
(661) 316-7888
DEFENDANTS’ AMENDED WITNESS LIST
Exh. No. Document Description
201 October 28, 2011 Lease Agreement
202 Lease Agreement Amendment No. 1
203 July 10, 2015 Agreement for Sale of Agricultural Plastics
204 December 7, 2015 Letter of Intent to Purchase
205 December 11, 2015 Unlawful Detainer Judgment
206 December 29, 2015 Purchase and Escrow Instructions
207 December 30, 2015 First Amendment for Sale of Agricultural Plastics
208 January 13, 2016 Email Trail Between T. Mizote and J. Marshall
209 May 11, 2016 Notice of Right to Reclaim Abandoned Property
210 November 27, 2016 Offer, Agreement and Escrow Instructions
211 2016 Email Trail Between T. Mizote and C. Smith
212 Special Interrogatories, Set One, Propounded to Big Washington, LLC
213 Big Washington, LLC's Responses to Special Interrogatories, Set One
214 Requests for Admissions, Set One, Propounded to Big Washinton, LLC
215 Big Washington, LLC's Responses to Requests for Admissions, Set One
216 Declaration of Ben Eilenberg Dated 11/3/2020
217 Declaration of Ben Eilenberg Dated 10/6/2021
218 Declaration of Ben Eilenberg Dated 12/7/2021
219 Declaration of Ben Eilenberg Dated 4/13/2022
220 Checks from Fry to Calcot
221 April 7, 2015 Letter to Fry From Calcot
Document Filed Date
November 30, 2022
Case Filing Date
October 05, 2017
Category
26-CV Other Real Property-Civil Unlimited
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1 William L. Alexander (State Bar Number 126607) Elizabeth Estrada (State Bar Number 232302) 2 Alexander & Associates, PLC 3 1925 G Street Bakersfield, CA 93301 4 Phone: (661) 316-7888 Email: walexander@alexander-law.com; service@alexander-law.com 5 6 Attorneys for Defendants, Thomas H. Fry and Ruth M. Fry as Trustees of the T & R Fry Family Trust 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF KERN – METROPOLITAN DIVISION 10 BIG WASHINGTON, LLC, a California ) Case No. BCV-17-102341 BCB Limited Liability Company, ) 11 ) DEFENDANTS’ FIRST AMENDED Plaintiff, ) EXHIBIT LIST 12 ) 13 vs. ) ) Assigned to: Hon. Bernard C. Barmann, Jr. 14 BENHONG (AMERICA) RECYCLING CO. ) Div.: H LTD, a California Limited Liability Company; ) Trial date: December 5, 2022 15 ) Time: 9:00 a.m. and THOMAS H. FRY and RUTH M. FRY as 16 Trustees of the T & R FRY FAMILY TRUST; ) and DOES 1 – 100, inclusive, ) Complaint Filed: October 6, 2017 17 ) Defendants. ) 18 ) 19 ) 20 Defendants, Thomas H. Fry and Ruth M. Fry as Trustees of the T&R Fry Family Trust, 21 respectfully submit the attached amended list of exhibits to be marked as an exhibit and introduced 22 into evidence at the time of trial in this matter. Defendants also reserve the right to rely on all 23 depositions, all deposition exhibits, pleadings, and discovery responses. 24 25 Dated: November 29, 2022 ALEXANDER & ASSOCIATES 26 27 By: /s/ Elizabeth Estrada /s/ ELIZABETH ESTRADA 28 Attorneys for Defendants 1 Alexander & Associates Attorneys at Law 1925 G Street Bakersfield, CA 93301 (661) 316-7888 DEFENDANTS’ AMENDED WITNESS LIST Exh. No. Document Description 201 October 28, 2011 Lease Agreement 202 Lease Agreement Amendment No. 1 203 July 10, 2015 Agreement for Sale of Agricultural Plastics 204 December 7, 2015 Letter of Intent to Purchase 205 December 11, 2015 Unlawful Detainer Judgment 206 December 29, 2015 Purchase and Escrow Instructions 207 December 30, 2015 First Amendment for Sale of Agricultural Plastics 208 January 13, 2016 Email Trail Between T. Mizote and J. Marshall 209 May 11, 2016 Notice of Right to Reclaim Abandoned Property 210 November 27, 2016 Offer, Agreement and Escrow Instructions 211 2016 Email Trail Between T. Mizote and C. Smith 212 Special Interrogatories, Set One, Propounded to Big Washington, LLC 213 Big Washington, LLC's Responses to Special Interrogatories, Set One 214 Requests for Admissions, Set One, Propounded to Big Washinton, LLC 215 Big Washington, LLC's Responses to Requests for Admissions, Set One 216 Declaration of Ben Eilenberg Dated 11/3/2020 217 Declaration of Ben Eilenberg Dated 10/6/2021 218 Declaration of Ben Eilenberg Dated 12/7/2021 219 Declaration of Ben Eilenberg Dated 4/13/2022 220 Checks from Fry to Calcot 221 April 7, 2015 Letter to Fry From Calcot