Motion-Secondary: CRYSTAL, NORMAN - DECEDENT

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                                Electronically FILED by Superior Court of California, County of Los Angeles 10/4/2021 2:28 PM Sherri R. Carter, Executive Officer/Clerk, By Hyo Suh, Deputy Clerk




                1    James L. Leestma, Esq. SBN 207311
                     LAW OFFICE OF JAMES LAMBERT LEESTMA
                2    7301 Topanga Canyon Boulevard, Suite 202
                     Canoga Park. California 91303
                3    Telephone: (818) 407-5070
                     Facsimile: (818)230-0414
                4     Email: james@advanceinheritance.com

                5    Attorneys for Felicia Lamonica Fisher,
                     Respondent
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                8                                  SUPERIOR COURT OF THE STATE OF CALIFORNIA

                9                            FOR THE COUNTY OF LOS ANGELES (CENTRAL DISTRICT)

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              11     Estate of                                                         )         Case No: 18STPB07326
                                                                                       )
              12                                                                       )         RESPONSE OF FELICIA LAMONICA
                                                                                       )         FISHER TO:
              13                                                                       )
                                                                                       )         MOTION TO COMPEL FURTHER RESPONSES
              14                                                                       )         TO INSPECTION DEMANDS FROM FELICIA
                                                                                       )         LAMONICA FISHER, FOR COMPLIANCE
              15                      NORMAN CRYSTAL                                   )         WITH INSPECTION DEMANDS, AND
                                                                                       )         REQUEST FOR SANCTIONS AGAINST
              16                                                                       )         FELICIA LA MONICA FISHER AND THE LA W
                                                                                       )         OFFICE OF JAMES LAMBERT LEESTMA IN
              17                                                                       )         THE AMOUNT OF $12,320
                                                                                       )
              18                                                                       )         Date:    10-13-21
                                                                                       )         Time:    3:00 p.m.
              19                                                                       )         Dept:    67
                                                                                       )         Judne:    Hon. Daniel Juarez
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              21               Felicia Lamonica Fisher (''Felicia") responds to the Motion to Compel, etc. ('"Motion") as

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                     follows :

              23                1.       Felicia's Privacv Interests Outweigh the Intrusion Into her Personal Life to Justify

              24     Producing Further Documents in Response to RFPs 17 (Income) and 18 (Expenses). Felicia alleges

              25     that her privacy interests outweigh any interest that Chilan and her attorneys have in looking at her

              26      income and/or expenses. More specifically, the spirit of the discovery statutes is to provide each side

              27      with adequate information to prepare their case for trial. The Discovery responses of Felicia provide

              28      Chilan with more than sufficient information about Felicia's finances to prepare her case.



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                                                                    RESPONSE TO MOTION. ETC.