On September 26, 2011 a
Party Discovery
was filed
involving a dispute between
Corrales, Gilbert,
Corrales, Lorraine,
and
for Trust
in the District Court of San Bernardino County.
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supemo
F L El
‘3
i
Harvey M. Payne(SBN 175523)
III
ngmsggm ggfikgfim
N BERNARDINO
nA
LAW OFFICES 0F HARVEY M. PAYNE III msmuchf
10085 Carroll Canyon Road, Ste. 210
OCT l 3 2022
San Diego, California 92131
858-271-1900
\OOOQQLJIAUJNu—n
Attorney for Petitioner
Gilbert Corrales
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
In the matter ofthe ) CASE No.: PROPS] 100680
)
PETE CORRALES AND CARMEN C.
G. ) [BY FAX]
CORRALES REVOCABLE TRUST Dated )
November 25, 1994 )
PETITIONER GILBERT CORRALES’
)
OPPOSITION T0 LORRAINE
CORRALES’ MOTION T0 COMPEL
)
Gilbert Corrales,
FURTHER RESPONSES To FORM
)
INTERROGATORIES AND FOR
)
SANCTIONS; REQUEST FOR
Petitioner )
MONETARY SANCTIONS AGAINST
) LORRAINE CORRALES AND HER
vs. ) ATTORNEY LOUIE A. RUIZ
)
NNNNNNNNN—t—ip—tr—IHH—n—Ar—At—A
Lorraine Corrales ) DATE: October 25, 2022
) TIME: 9:00 a.m.
Respondent ) DEPT: S36
WNQMANNHOOOONONMAWN'flO
)
Petitioner, Gilbert Corrales, hereby submits the following opposition to Lorraine
Corrales’ ‘Motion to compel further responses to form interrogatories-general (set one) and
request for monetary sanctions against Petitioner Gilbert Corrales and his counsel Harvey M.
Payne III pursuant to CCP §2023.010 in the sum of $2,347.50, and hereby requests monetary
sanctions against Lorraine Corrales and her attorney Louie A. Ruiz in the amount of $2,485.00
for the time and expense of having to respond to a motion to compel which should have never
been filed in the first place after Respondent was informed of the deficiency in the definition of
-1-
PETITIONER GILBERT CORRALES’ OPPOSITION TO LORRAINE CORRALES’ MOTION TO COMPEL
FURTHER RESPONSES TO FORM INTERROGATORIES AND FOR SANCTIONS; REQUEST FOR
MONETARY SANCTIONS AGAINST LORRAINE CORRALES AND HER ATTORNEY LOUIE A. RUIZ
the word ‘Incident’ which affected the vast majority of form interrogatories for which
Respondent now complains.
I.
SUMMARY 0F CASE
\OOONQLIIAWNh—I
This is not the first time the parties are in front of this court on a discovery dispute. The
patties were last in front of the court when Respondent went to great lengths to prevent her
deposition from being taken in person. The lengthy procedural history of this case, including
Respondent’s delays in producing information, is set forth within Petitioner’s briefing within
opposition to the motion for protective order. More recently, at the mediation in this matter, it
was discovered that Respondent still has not produced all financial information in that additional
records were obtained from Morgan Stanley, on the day of the mediation, at the request of the
mediator, that Respondent had never been produced before despite requests, years ago, to d0 so.
To date, discovery has shown that Respondent never gave Petitioner his rightful portion
of his parent’s inheritance; Respondent has failed to account for hundreds of thousands of dollars
in rent and other assets; she has kept Petitioner’s money in her own personal trust for whom
Petitioner is not a beneficiary; has used Petitioner’s money for her own purposes and attempted
to make herself the backstop beneficiary of Petitioner’s estate without knowledge to Petitioner,
NNNNNNNNN—I—Ih—IH—IH—Ir—Au—p—d
and despite the fact that Petitioner has a son for whom he has always wanted his estate to go to.
wflQthbJN—‘OOOONQMAUJNHO
In summary, Respondent has taken advantage of Petitioner, believing she could get away with it,
both during his life and upon his death, and now does not want to own up to it.
II.
RESPONDENT IMPROPERLY USES A COWOUND AND CONJUNCTIVE
DEFINITION OF THE TERM ‘INCIDENT’
A. Form Interrogatory Nos. 2.3, 2.4, 2.6(b), 2.12. 2.13, 9.1, 9.2, 12.1, 12.2, 12.3, 12.4,
12.5, 12.6, 13.1, and 13.2
In propounding form interrogatories, Respondent defined the term “Incident” to mean
“Administration ofthe Pete G. Corrales and Carmen C. Corrales Revocable Trust, Dated
-2-
PETITIONER GILBERT CORRALES’ OPPOSITION TO LORRAINE CORRALES’ MOTION TO COMPEL
FURTHER RESPONSES TO FORM INTERROGATORIES AND FOR SANCTIONS; REQUEST FOR
MONETARY SANCTIONS AGAINST LORRAINE CORRALES AND HER ATTORNEY LOUIE A. RUIZ
Document Filed Date
October 13, 2022
Case Filing Date
September 26, 2011
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supemo F L El ‘3 i Harvey M. Payne(SBN 175523) III ngmsggm ggfikgfim N BERNARDINO nA LAW OFFICES 0F HARVEY M. PAYNE III msmuchf 10085 Carroll Canyon Road, Ste. 210 OCT l 3 2022 San Diego, California 92131 858-271-1900 \OOOQQLJIAUJNu—n Attorney for Petitioner Gilbert Corrales IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO In the matter ofthe ) CASE No.: PROPS] 100680 ) PETE CORRALES AND CARMEN C. G. ) [BY FAX] CORRALES REVOCABLE TRUST Dated ) November 25, 1994 ) PETITIONER GILBERT CORRALES’ ) OPPOSITION T0 LORRAINE CORRALES’ MOTION T0 COMPEL ) Gilbert Corrales, FURTHER RESPONSES To FORM ) INTERROGATORIES AND FOR ) SANCTIONS; REQUEST FOR Petitioner ) MONETARY SANCTIONS AGAINST ) LORRAINE CORRALES AND HER vs. ) ATTORNEY LOUIE A. RUIZ ) NNNNNNNNN—t—ip—tr—IHH—n—Ar—At—A Lorraine Corrales ) DATE: October 25, 2022 ) TIME: 9:00 a.m. Respondent ) DEPT: S36 WNQMANNHOOOONONMAWN'flO ) Petitioner, Gilbert Corrales, hereby submits the following opposition to Lorraine Corrales’ ‘Motion to compel further responses to form interrogatories-general (set one) and request for monetary sanctions against Petitioner Gilbert Corrales and his counsel Harvey M. Payne III pursuant to CCP §2023.010 in the sum of $2,347.50, and hereby requests monetary sanctions against Lorraine Corrales and her attorney Louie A. Ruiz in the amount of $2,485.00 for the time and expense of having to respond to a motion to compel which should have never been filed in the first place after Respondent was informed of the deficiency in the definition of -1- PETITIONER GILBERT CORRALES’ OPPOSITION TO LORRAINE CORRALES’ MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES AND FOR SANCTIONS; REQUEST FOR MONETARY SANCTIONS AGAINST LORRAINE CORRALES AND HER ATTORNEY LOUIE A. RUIZ the word ‘Incident’ which affected the vast majority of form interrogatories for which Respondent now complains. I. SUMMARY 0F CASE \OOONQLIIAWNh—I This is not the first time the parties are in front of this court on a discovery dispute. The patties were last in front of the court when Respondent went to great lengths to prevent her deposition from being taken in person. The lengthy procedural history of this case, including Respondent’s delays in producing information, is set forth within Petitioner’s briefing within opposition to the motion for protective order. More recently, at the mediation in this matter, it was discovered that Respondent still has not produced all financial information in that additional records were obtained from Morgan Stanley, on the day of the mediation, at the request of the mediator, that Respondent had never been produced before despite requests, years ago, to d0 so. To date, discovery has shown that Respondent never gave Petitioner his rightful portion of his parent’s inheritance; Respondent has failed to account for hundreds of thousands of dollars in rent and other assets; she has kept Petitioner’s money in her own personal trust for whom Petitioner is not a beneficiary; has used Petitioner’s money for her own purposes and attempted to make herself the backstop beneficiary of Petitioner’s estate without knowledge to Petitioner, NNNNNNNNN—I—Ih—IH—IH—Ir—Au—p—d and despite the fact that Petitioner has a son for whom he has always wanted his estate to go to. wflQthbJN—‘OOOONQMAUJNHO In summary, Respondent has taken advantage of Petitioner, believing she could get away with it, both during his life and upon his death, and now does not want to own up to it. II. RESPONDENT IMPROPERLY USES A COWOUND AND CONJUNCTIVE DEFINITION OF THE TERM ‘INCIDENT’ A. Form Interrogatory Nos. 2.3, 2.4, 2.6(b), 2.12. 2.13, 9.1, 9.2, 12.1, 12.2, 12.3, 12.4, 12.5, 12.6, 13.1, and 13.2 In propounding form interrogatories, Respondent defined the term “Incident” to mean “Administration ofthe Pete G. Corrales and Carmen C. Corrales Revocable Trust, Dated -2- PETITIONER GILBERT CORRALES’ OPPOSITION TO LORRAINE CORRALES’ MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES AND FOR SANCTIONS; REQUEST FOR MONETARY SANCTIONS AGAINST LORRAINE CORRALES AND HER ATTORNEY LOUIE A. RUIZ