Document for ARNTSEN FAMILY PARTNERSHIP, LP, et al vs. GREGORY J DAVIS, et al

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                                1   Collin J. Vierra (State Bar No. 322720)
     EIMER STAHL LLP
 2   99 Almaden Blvd., Suite 600
     San Jose, CA 95113-1605
 3   Telephone: (408) 889-1668
     Email: cvierra@eimerstahl.com
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     Attorney for Plaintiffs Robert Arntsen,
 5   Mary Lee. Arntsen Family Partnership, LP,
     Brian Christopher Dunn Custodianship,
 6   John Ho, and Quanyu Huang
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 8                    SUPERIOR COURT OF THE STATE OF CALIFORNIA
                                      COUNTY OF SAN MATEO
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      Robert Arntsen; Mary Lee; Arntsen Family        Case No. 22-CIV-01148
11    Partnership, LP; Brian Christopher Dunn
      Custodianship, John Ho, and Quanyu Huang;       Date: September 15, 2023
12                                                    Time: 9:00 a.m.
13                  Plaintiffs,                       Dept. 21
      v.
14                                                    Hon. Robert D. Foiles
      David M. Bragg; Silicon Valley Real Ventures
15    LLC; SVRV 385 Moore, LLC; SVRV 387              SUPPLEMENTAL REPLY
      Moore, LLC; Gregory J. Davis; Kevin Wolfe;      DECLARATION OF COLLIN J.
16    Jason Justesen; Paramont Woodside, LLC;         VIERRA IN SUPPORT OF MOTION TO
17    Paramont Capital, LLC; Monks Family Trust;      COMPEL AND FOR SANCTIONS
      TEH Capital LLC; Caproc III, LLC; WZ            AGAINST DEFENDANTS DAVID M.
18    Partners, LLC; McClan Trust; Wild Rose          BRAGG AND SILICON VALLEY REAL
      Irrevocable Trust; Black Horse Holdings,        VENTURES, LLC
19    LLC; Phil Stoker; Diane Stoker; Scott O’Neil;
      Dale Huish; and DOES 1–20,
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21                  Defendants.

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           SUPPLEMENTAL REPLY DECLARATION OF COLLIN J. VIERRA IN SUPPORT OF MOTION
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            I, Collin James Vierra, attest as follows:
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            1.       I am over 18 years of age, of sound mind, and otherwise competent to make this
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     Declaration. I am not a party to this action.
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            2.       A true and correct copy of an email correspondence between Bragg’s counsel, Mr.
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     Van Steenis, and me is attached hereto as Exhibit A.
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            3.       A true and correct copy of the letter I attached to my September 7, 2023 email to
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     Mr. Van Steenis is attached hereto as Exhibit B.
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            4.       A true and correct copy of the letter I attached to my September 11, 2023 email to
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     Mr. Van Steenis is attached hereto as Exhibit C.
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            5.       True and correct copies of screenshots taken on September 11, 2023 showing that
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     the SVRV Google accounts for Kurtis Kludt and Lukas Leuthold have been “suspended” are
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     attached hereto as Exhibits D and E, respectively. Kludt and Leuthold previously provided
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     Plaintiffs access to these accounts after Bragg refused, even though Bragg is the administrator of
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     the accounts.
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            6.       Bragg has not provided written discovery responses since September 2022. (See
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     Separate Statement ISO Motion to Compel and for Sanctions.) He also continues to withhold
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     numerous responsive documents.
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            7.       Bragg has not attended a single party deposition to date, nor that of his own brother,
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     Rich Bragg.
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            I swear under penalty of perjury under the laws of the State of California that to the best of
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     my knowledge the foregoing is true and correct.
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25   Dated: September 12, 2023                              By: ______________________
26                                                              Collin J. Vierra
                                                                EIMER STAHL, LLP
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                                                                Attorney for Plaintiffs
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           SUPPLEMENTAL REPLY DECLARATION OF COLLIN J. VIERRA IN SUPPORT OF MOTION