On February 11, 2020 a
Party Discovery
was filed
involving a dispute between
Bettis, Danny K,
Spitzzeri, Paul,
and
Spitzzeri, Paul,
for Trust
in the District Court of San Bernardino County.
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SUPERIOR CC URT bF GALlFORNIA
COUNTY OF SAy BERNARDINO
SAN BF R STRICT
Paymon Z Bidari 1943991
Bidari Civil Defense AUG 1 9 2020
2
9th
1440 N Harbor Blvd Flaor
g Fullerton Ca y2835 181 M
1
714 525 557Q K MSERLY TILLEY DEPUTY
4
714 525 5571
YbidariL BidariCivillletense cam
g Attarney for Respondent and Trustee Paul R Spitzzeri
7
SUPERIOR COURT OF CALIFORNIA COUNTY OF SAT BERNARDINO
CENTRAL JUSTICE CENTER
8
g MAE THERESA DUFORD REVOCABLE CASE NO TRUPS 200Q017
LIVING TRUST dated June 7 1993 and 1
1 MAE
Restatement of the THERESA j REPLY TO 4PPOSITION T4 MOTION
DUFORD REVOCABLE LIVING TRUST TQ AMEIVDED MQTI0IV TO QUASH
11
dated July 10 003 and SECOND 1 SUBPOENA DUCES TECUM
AMENDMENT TO AND
12 COMPLETE j DECLARATION OF PAYMON BIDARI
RESTATEMENT OF MAE THERESA
13 DUFORD REVOCABLE TRUST Hearing Date August 26 2Q20
ACi M NT dated August 2 2UUy Time y UO AM
14
Location Dept S37P
15
DANNY K BETTIS Assigned to the Honorable Tara Reilly
16
Petitioner
17
vs
18
YAUL R SPITLG RI SUCC SSUR
19 TRUSTEE OF MAE THERESA DUFORD
REVOCABLE LIVING TRUST DATED
20 JUNE 7 1993 AS AMENDED
21
Respondent respectfull submits this R PLl to Pztitioner s Upposition to 1 lotion to
22
Quash on the on the follawing grounds
23
Z4
1 Pctitinncr thc di
s counscl ahuccd c vcry Pr cc
hy ht aining
25 financial records via a sub oena she did not notify defense of and
which she is now using as the basis for the need to obtain
26 aclditiunal rec rds
27
2 Petiti ner s counsel s unlawful intrusion into the Trustor s
2 finanrial affairs rniist hP canrtinnr rl ac ShP has rnmmitt rl cNrinne
state and federal Tiolations
1
REPLY TO OPPOSiTION TO A40TTON TO QUASH SUBPOE IA DUCES
1
2
3 Ncithcr thc law nor thc Trust at hand requirc thc disclasrarc af
financial records to Petitioner
3
4
5 I STATENIENT OF FACTS
g Petitioner s
attorney declares in her opposition that on May 29 202 she issued a
subpaena to Hawaii Financial Adt isors Inc
7 Declaration of Ashley VVedding page 1 lines
g 13 28 page 2 lines 1 6 attache d to Opp4sition to Motian ta Quash
g As not d at the Augi st 19 2020 haarilzg Petitioner s COL1tIS 1 never noti ed ciefense
cQunsel of d is Please Notice to C dated
1 subpoena se nsumer May 29 QZQ attaclaed as
11 Exhibit 1 to th t Reply j
12 The Notrce to Consuxner dated May 29 2Q20 was addr ssed to Attorney Ro ert Freeinan
13 at PO BGX IG1 Fullerton Ca Sze Exhibit 1 and D eclaratin n of Paymnn Ridari attached a
id Exhi ii 2 ta this Reply
1 Furtherrnare Petitioner s c4r nsel concedes she unilaterally personatl y rez iewed these
16 records after wliich she noted there wer dePosits into tlie 1 rust account L ecl ration af
i7 Ashley Wedding page 2 lines 7 1 1
ig And as such she would now like to se Trustor s bank recorcls
g Petitionzr s counsel s unlawfi l intrusioii into thz Tn stor s finayYcial afflirs must Ue
2 sanctianed as s13e has comniitted serious state and federal violatians
How cc uld Patitic ner s counsal give nUtice to an at orney of not record an this case while
22 he r videci n tice t defense c unsel c f the uh aena t the hank
2g wi y a arY t PetitioYxer s counsel NOT I11 I1C10I1 C I S I COl CiS L1Litll now She issued the
24 subpoena in May 2 2Q and yet she waited until two days ago to disclose khe fact that she
2 obtained these recordG and after personaliy reading them she finds the need and the basis for
2 additional documents
z7
28
2
REPLY TO UPPQSTTION TQ A30TI N TC QUASH SLTBPQEVA L UCES
Document Filed Date
August 19, 2020
Case Filing Date
February 11, 2020
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SUPERIOR CC URT bF GALlFORNIA COUNTY OF SAy BERNARDINO SAN BF R STRICT Paymon Z Bidari 1943991 Bidari Civil Defense AUG 1 9 2020 2 9th 1440 N Harbor Blvd Flaor g Fullerton Ca y2835 181 M 1 714 525 557Q K MSERLY TILLEY DEPUTY 4 714 525 5571 YbidariL BidariCivillletense cam g Attarney for Respondent and Trustee Paul R Spitzzeri 7 SUPERIOR COURT OF CALIFORNIA COUNTY OF SAT BERNARDINO CENTRAL JUSTICE CENTER 8 g MAE THERESA DUFORD REVOCABLE CASE NO TRUPS 200Q017 LIVING TRUST dated June 7 1993 and 1 1 MAE Restatement of the THERESA j REPLY TO 4PPOSITION T4 MOTION DUFORD REVOCABLE LIVING TRUST TQ AMEIVDED MQTI0IV TO QUASH 11 dated July 10 003 and SECOND 1 SUBPOENA DUCES TECUM AMENDMENT TO AND 12 COMPLETE j DECLARATION OF PAYMON BIDARI RESTATEMENT OF MAE THERESA 13 DUFORD REVOCABLE TRUST Hearing Date August 26 2Q20 ACi M NT dated August 2 2UUy Time y UO AM 14 Location Dept S37P 15 DANNY K BETTIS Assigned to the Honorable Tara Reilly 16 Petitioner 17 vs 18 YAUL R SPITLG RI SUCC SSUR 19 TRUSTEE OF MAE THERESA DUFORD REVOCABLE LIVING TRUST DATED 20 JUNE 7 1993 AS AMENDED 21 Respondent respectfull submits this R PLl to Pztitioner s Upposition to 1 lotion to 22 Quash on the on the follawing grounds 23 Z4 1 Pctitinncr thc di s counscl ahuccd c vcry Pr cc hy ht aining 25 financial records via a sub oena she did not notify defense of and which she is now using as the basis for the need to obtain 26 aclditiunal rec rds 27 2 Petiti ner s counsel s unlawful intrusion into the Trustor s 2 finanrial affairs rniist hP canrtinnr rl ac ShP has rnmmitt rl cNrinne state and federal Tiolations 1 REPLY TO OPPOSiTION TO A40TTON TO QUASH SUBPOE IA DUCES 1 2 3 Ncithcr thc law nor thc Trust at hand requirc thc disclasrarc af financial records to Petitioner 3 4 5 I STATENIENT OF FACTS g Petitioner s attorney declares in her opposition that on May 29 202 she issued a subpaena to Hawaii Financial Adt isors Inc 7 Declaration of Ashley VVedding page 1 lines g 13 28 page 2 lines 1 6 attache d to Opp4sition to Motian ta Quash g As not d at the Augi st 19 2020 haarilzg Petitioner s COL1tIS 1 never noti ed ciefense cQunsel of d is Please Notice to C dated 1 subpoena se nsumer May 29 QZQ attaclaed as 11 Exhibit 1 to th t Reply j 12 The Notrce to Consuxner dated May 29 2Q20 was addr ssed to Attorney Ro ert Freeinan 13 at PO BGX IG1 Fullerton Ca Sze Exhibit 1 and D eclaratin n of Paymnn Ridari attached a id Exhi ii 2 ta this Reply 1 Furtherrnare Petitioner s c4r nsel concedes she unilaterally personatl y rez iewed these 16 records after wliich she noted there wer dePosits into tlie 1 rust account L ecl ration af i7 Ashley Wedding page 2 lines 7 1 1 ig And as such she would now like to se Trustor s bank recorcls g Petitionzr s counsel s unlawfi l intrusioii into thz Tn stor s finayYcial afflirs must Ue 2 sanctianed as s13e has comniitted serious state and federal violatians How cc uld Patitic ner s counsal give nUtice to an at orney of not record an this case while 22 he r videci n tice t defense c unsel c f the uh aena t the hank 2g wi y a arY t PetitioYxer s counsel NOT I11 I1C10I1 C I S I COl CiS L1Litll now She issued the 24 subpoena in May 2 2Q and yet she waited until two days ago to disclose khe fact that she 2 obtained these recordG and after personaliy reading them she finds the need and the basis for 2 additional documents z7 28 2 REPLY TO UPPQSTTION TQ A30TI N TC QUASH SLTBPQEVA L UCES