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Electronically
Collin J. Vierra (State Bar No. 322720)
EIMER STAHL LLP by Superior Court of Calitornia, County of San Mateo
99 Almaden Blvd., Suite 600 ON 8/11/2023
San Jose, CA 95113-1605
By /s/ Haley Correa
Telephone: (408) 889-1668 Deputy Clerk
Email: cvierra@eimerstahl.com
Attorney for Plaintiffs Robert Arntsen,
Mary Lee. Arntsen Family Partnership, LP,
Brian Christopher Dunn Custodianship,
John Ho, and Jacky Huang
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN MATEO
10
11 Robert Arntsen; Mary Lee; Arntsen Family Case No. 22-CIV-01148
Partnership, LP; Brian Christopher Dunn
12 Custodianship, John Ho, and Quanyu Huang; Date: August 18, 2023
Time: 9:00 am
13
Plaintiffs, Dept. 21
14 Vv.
Hon. Robert D. Foiles
15 David M. Bragg; Silicon Valley Real Ventures
LLC; SVRV 385 Moore, LLC; SVRV 387 EXHIBITS TO REPLY
16 Moore, LLC; Gregory J. Davis; Kevin Wolfe; DECLARATION OF COLLIN J.
Jason Justesen; Paramont Woodside, LLC; VIERRA IN SUPPORT OF MOTION
17
Paramont Capital, LLC; Monks Family Trust; TO COMPEL AND FOR SANCTIONS
18 TEH Capital LLC; Caproc III, LLC; WZ AGAINST DEFENDANTS DAVID M.
Partners, LLC; McClan Trust; Wild Rose BRAGG AND SILICON VALLEY
19 Irrevocable Trust; Black Horse Holdings, REAL VENTURES, LLC
LLC; Phil Stoker; Diane Stoker; Scott O’Neil;
20 Dale Huish; and DOES 1-20,
21
Defendants.
22
23
24
25
26
27
28
Exhibit Page 1
EXHIBITS TO REPLY DECLARATION OF COLLIN J. VIERRA IN SUPPORT OF MOTION TO.
COMPEL AND FOR SANCTIONS AGAINST DEFENDANTS DAVID M. BRAGG AND
SILICON VALLEY REAL VENTURES, LLC
INDEX
Exhibit A: May 18, 2023 Letter from Plaintiffs’ counsel to counsel for David M. Bragg and Silicon
Valley Real Ventures, LLC regarding Bragg’s Spoliation and Other Discovery Abuses ........... 4
Exhibit B: July 10, 2023 Letter from Plaintiffs’ counsel to counsel for David M. Bragg and Silicon
Valley Real Ventures, LLC regarding Bragg’s Deficient Production of Google Materials and Other
Discovery Abuses 12
Exhibit C: Silicon Valley Real Ventures, LLC Webpage from March 17, 2022 14
10
Exhibit D: Screenshot of David M. Bragg’s LinkedIn Profile as of March 18, 2022 22
11
12 Exhibit E: Screenshot of David M. Bragg’s LinkedIn Profile as of August 9, 2023 26
13
Exhibit F: Email correspondence between Ryan Van Steenis and Collin Vierra regarding ‘Meet-
14
and-Confer Summary’ 31
15
16 Exhibit G: Screenshot from Google Drive showing Bragg-created and withheld file titled ‘387
17 Cap Table’ 35
18
Exhibit H: Screenshot from Google Drive showing Bragg-created and withheld file titled
19
“Bob Arntsen SVRV 387 Moore, LLC Investment-Subscription Agreement March 2019’.........39
20
21 Exhibit I: Screenshot from Google Drive showing Bragg-created and withheld file titled
22
“Bob Arntsen SVRV 387 Moore, LLC Investment-Subscription Agreement draft’ 41
23
24 Exhibit J: Email correspondence from David M. Bragg regarding ‘Moore Road status and update
25 4.30.2020’ received by Bob Arntsen failing to show Bcc’ed recipients 43
26
Exhibit K: Email correspondence from David M. Bragg regarding ‘Moore Road status and update
27
4.30.2020’ received by John Ho failing to show Bec’ed recipients. 47
28
Exhibit Page 2
EXHIBITS TO REPLY DECLARATION OF COLLIN J. VIERRA IN SUPPORT OF MOTION TO COMPEL
AND FOR SANCTIONS AGAINST DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL
VENTURES, LLC
Exhibit L: Email correspondence between Collin Vierra and Ran Van Steenis regarding meet and
confer for the parties’ discovery dispute, dated February 24, 2023 51
Exhibit M: Amendment Cover Sheet, Jn re David M. Bragg (U.S. Bank. E.D. Cal.. No. 22-
22700) 54
Exhibit N: Email correspondence between Collin Vierra, Mark Poe and Ryan Van Steenis
regarding ‘Further on Kludt’s (& Bragg’s) Responses to Plaintiff's RFPs” 67
Exhibit O: Email correspondence between Collin Vierra and Ryan Van Steenis regarding
10 September 16, 2022 Meet and Confer, including attachments..............
00. ccececceeeeeeeee eee enees 70
11
12
13
14 Dated: August 11, 2023 By: Cth WM
15 Collin J. Vierra
EIMER STAHL, LLP
16
Attorney for Plaintiffs
17
18
19
20
21
22
23
24
25
26
27
28
Exhibit Page 3
EXHIBITS TO REPLY DECLARATION OF COLLIN J. VIERRA IN SUPPORT OF MOTION TO COMPEL
AND FOR SANCTIONS AGAINST DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL
VENTURES, LLC
Exhibit A
Exhibit Page 4
Eimer Stahl LLP
EimerStahl..
99 South Almaden Boulevard
Suite 600
San J ose, California 95113
Tel 408-889-1668
Email cvierra@ eimerstahl.com
May 18, 2023
Re: Arntsen Family Partnership, LP et al. v. GregoryJ. Davis et al.,
Case No. 22-CIV-01148 (California Superior Court of San Mateo County)
Counsel:
We write in response to your recent communication regarding your clients’ (David M.
Bragg’s and Silicon Valley Real Ventures, LLC’s) previous and ongoing discovery abuses. If
necessary, Plaintiffs intend to raise these issues with the Commissioner at the next IDC and seek
terminating sanctions for your clients’ misconduct. Plaintiffs also reserve the right to raise these
issues with the bankruptcy court at the appropriate time.
Spoliatio
As your client stated at the parties’ recent meeting, in early 2023, he disposed of his cell
phone and failed to preserve any of his text messages. He did so after having produced zero text
messages in this action or in the bankruptcy action.
Y our position that this does not constitute spoliation is frivolous. Plaintiffs threatened
your clients with litigation in 2021 (and your clients were engaged in substantial litigation even
before that, including litigation involving the Moore Road Project). Plaintiffs sent your clients an
explicit preservation notice both electronically and by mail at the outset of this action (which is
reattached to this letter for your convenience). Plaintiffs sent your clients repeated document
requests for text messages in this action. Plaintiffs initiated an action against your client in the
bankruptcy court, upon which the court ordered the parties to participate in a discovery
conference.
Y et, apparently after each of these events occurred, your client willfully disposed of his
cell phone including all text messages thereon. That is willful spoliation under both state and
federal law, and Plaintiffs intend to seek all available remedies, as necessary, in each court.
Document Productions
Y our recent communications indicate that you intend to let your clients continue self-
collecting documents. As Plaintiffs made clear last summer, that is unacceptable. Y our clients
repeatedly have asserted that their document productions were complete, only for Plaintiffs to
discover thousands more responsive documents that your clients were withholding. As Plaintiffs
made clear last year, you—not Bragg—should take direct responsibility for collecting, searching,
and producing responsive materials.
Exhibit Page 5
May 18, 2023
Page 2
Production Methodology
The recent list of search terms you provided is also unacceptable. To take one example, it
is unreasonable to include only the search term “Moore Rd” rather than the singular word
“Moore”. As another example, it is unacceptable not even to include the Plaintiff Bob Arntsen’s
first name in the list of search terms. As Plaintiffs noted during the last IDC, Plaintiffs provided a
“minimum” set of search terms and procedures in September 2022. Y ou never responded to that
proposal, which was merely a starting point.
Production Sources
Y our clients repeatedly have made false statements about their sources of responsive
documents. For example, at the parties’ recent meeting, your client stated that he does not have
any documents or communications in his personal email account that were not also included in
his work account. Contrary to that assertion, Plaintiffs have identified numerous such documents
obtained from third parties. You have also reasserted that there are no “loose files” on your
clients’ devices or in hard-copy format. As Plaintiffs said before, email communications and
cloud files that Plaintiffs have obtained prove that your clients worked with responsive hard-
copy documents and created responsive documents on their device(s) outside of GSuite. These
documents should be produced.
Relevant Time
Y ou have asserted that communications post-dating the commencement of this litigation
cannot be reasonably calculated to lead to the discovery of admissible evidence. That position is
also meritless. To the extent your clients engaged in non-privileged communications (and/or
created documents) about relevant events after those events occurred (and after this litigation
commenced), Plaintiffs are entitled to discover those communications and documents. To take an
obvious example, if your clients told a third party after this case commenced that, “Bob is suing
us for the loan that we told him was for the Moore Road Project but which we actually misused,”
that communication would plainly would be responsive and Plaintiffs would be entitled to
discover it.
Timing of Productions and Responses
It has been nearly a year since your clients first were served with discovery in this action,
and their productions and written responses still are woefully incomplete. Plaintiffs reserve the
right to seek all appropriate remedies for this obstruction, as necessary, in each court.
Plaintiffs’ Prior Productions
Y ou assured Plaintiffs in 2022 that you retained the files for this case when you departed
from your prior firm. Y et at the parties’ recent meeting, you stated that you did not retain the
documents that Plaintiffs had Bates-stamped and circulated in this action, nor the email by which
Exhibit Page 6
May 18, 2023
Page 3
they did so. At your request, Plaintiffs circulated these documents to you again on May 2, 2023
with an expiration date of May 9, 2023 via the exact same method that they did previously, yet
our records indicate you did not download the production.
Sincerely,
Cite Waa
Collin James Vierra
Exhibit Page 7
Eimer Stahl LLP
EimerStahl..
99 South Almaden Boulevard
Suite 641
San Jose, California 95113
Tel 408-889-1668
Email cvierra@eimerstahl.com
April 8, 2022
Re: Arntsen Family Partnership, LP et al. v. Gregory J. Davis et al.,
Case No. 22-CIV-01148 (California Superior Court of San Mateo County)
Dear Defendant:
You are hereby being served in the above-captioned case, of which you may previously
have received notice. If you are represented by counsel, please ask your counsel to promptly
confirm your receipt of these papers by contacting me by phone or email as indicated below.
Please also use the provided pre-paid envelope to promptly return one completed copy of the
Acknowledgment of Receipt accompanying this letter.
Pursuant to California law, you are instructed to preserve all materials, whether in
tangible or intangible form, that may be relevant to this dispute or which may lead to the
discovery of information relevant to this dispute, including but not limited to emails and
attachments, calendar entries, text and instant messages, spreadsheets, powerpoints, financial
records, loan records, databases, correspondence, memoranda, handwritten documents, printed
documents, draft documents, invoices and receipts, planning documents, construction
documents, contracts or other legal documents, photographs and other media files, voicemails,
and all copies of the foregoing in any form. To that end, you are instructed to modify any settings
or procedures that would cause you to intentionally or unintentionally destroy any such
materials, including by removing auto-deletion settings on your computers, mobile devices,
telephones, and other electronic devices, and including by halting any procedures that would
cause you to destroy any such tangible materials. Materials that must be preserved include but
are not limited to those relating to all operations of Silicon Valley Real Ventures, SVRV 385
Moore Road, SVRV 387 Moore Road, Paramont Capital, and Paramont Woodside. If you fail to
preserve any such materials, Plaintiffs will pursue all available sanctions and remedies. (See,
e.g., Cal. Code Civ. Proc. §§ 2023.010, 2023.030(a)-(d); Cal. Evid. Code § 413; Cal. Penal Code
§ 135; R.S. Creative, Inc. v. Creative Cotton Ltd. (1999) 75 Cal.App.4th 486; Williams v. Russ
(2008) 167 Cal.App.4th 1215).
Sincerely,
(pte Wear
Collin James Vierra
Work: 408-889-1668
Mobile: 408-915-8266
Email: cvierra@eimerstahl.com
Exhibit Page 8
From: SecureXfer_ESDS
To: Vierra, Collin
Subject: D. Bragg Google Drive Production
Date: Tuesday, May 2, 2023 11:04:44 AM
WARNING: External Email
NOTE: this deliverable will expire on 5/09/2023.
You have received this m« ge because Eimer Stahl Discovery Solutions (ESDS) has sent you a secure data
transfer or ESDS is requesting a secure data transfer from you back to ESDS.
By following the link below you will be able to register with our system and download the data that has been sent to
you, or to send data back to ESDS. If you have registered previously, you will not need to register again.
Below are instructions for registering and how to download the data being sent to you.
Sender SecureXfer_ESDS
Link : https://sftp.cimerstahl_com/bds/Login.do?id=A044583446&p 1=02j00hrsbffgjeffhleeibji20
Sent To : rjvan: nis@gmail.com
Ce cvierra@eimerstahl.com; esds@eimerstahl.com
Expires : 5/9/23, 11:59:00 PM CDT
Files:
1. GOOGLE-BRAGG 001.zip
To receive a secure data delivery from ESDS:
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7. If you would like to send a secure data delivery back to ESDS, follow the instructions below, starting with #6.
To send a secure data delivery to ESDS:
Exhibit Page 9
1. Click on the link included in this me: ge.
2. If thi is the first time sending a data delivery to ESDS, you will be required to register. During registration you
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3. Ifyou have previously sent a secure data delivery to ESDS, you do not need to register. Instead, you will be
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4 After you log in, click on the blue link titled ‘Received’.
Under the ‘Subject’ column select the message you would like to respond to.
Afier the message opens, select the ‘Reply Securely’ button.
Enter any additional information within the m« ge body section.
8. Select the ‘Add Files and Send Reply’ button towards the bottom of the screen. . Navigate to the location of the
files you would like to send and select them.
9. Click the ‘Send’ button.
10. A confirmation message will display indicating that your files were sent succ fully.
Please contact ESDS@eimerstahl.com if you need additional a stance.
Thi: ystem is the property of Eimer Stahl Discovery Solutions, LLC. All activity is monitored and logged.
Unauthorized a including attempts to locate or access files without explicit authorization is prohibited.
Eimer Stahl Discovery Solutions, LLC intends this system for file transfer only, not for storage.
Our policy is to purge files older than seven (7) calendar days.
By using this system, you acknowledge that you accept these terms.
Exhibit Page 10
Jelivery Information
Package name D. Bragg Google Drive Production
To rjvansteenis@gmail.com
cc cvierra@eimerstahl.com; esds@eimerstahl.com
Subject D. Bragg Google Drive Production
From SecureXfer_ESDS
Date 05/02/2023 08:00 AM
Date expires 05/09/2023 11:59 PM
Secure message Mr. Van Steenis,
On behalf of Collin Vierra, counsel for Plaintiffs, please find a re-delivery of the FTP link
provided in September 2022.
Email notification message NOTE: this deliverable will expire on 5/09/2023.
You have received this PiPEa peqause Eimer Stahl Discovery Solutions (ESDS) has sent
you a secure data transfer or ESDS is requesting a secure data transfer from you back to
ESDS.
Exhibit B
Exhibit Page 12
Eimer Stahl LLP
EimerStahl..
99 South Almaden Boulevard
Suite 600
San J ose, California 95113
Tel 408-889-1668
Email cvierra@ eimerstahl.com
July 10, 2023
Re: Arntsen Family Partnership, LP et al. v. Gregory J. Davis et al.,
Case No. 22-CIV-01148 (California Superior Court of San Mateo County)
Counsel:
We write in response to your identification of the search terms that your client supposedly
used in the “examination of his personal gmail and drive.”
First, the document you provided does not accurately reflect Plaintiffs’ proposed search
parameters from September 2022.
Second, the list of search terms supposedly used by your clients is woefully insufficient,
for the reasons we have articulated previously.
Third, your client only provided emails in his May 19, 2023 “production”—not Google
Drive documents. The only four Google Drive links provided were links to .eml email files.
Therefore, it is not accurate to say that your client searched his personal Google Drive.
Fourth, your client clearly did not even properly search his email account using the terms
provided. As we have stated many times previously, third-party discovery has revealed emails that
would have hit upon the terms supposedly used that your clients still have never produced.
Lastly, we reiterate that there are numerous other deficiencies with your clients’ supposed
searches and productions, which we have articulated many times previously. Each of these
continues to demonstrate why your clients cannot be trusted to self-collect and -produce
documents. Your clients’ discovery responses are now well over a year overdue.
Plaintiffs reserve all rights regarding your clients’ repeated and ongoing discovery
violations.
Sincerely,
(Hts Wor
Collin James Vierra
Exhibit Page 13
Exhibit C
Exhibit Page 14
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DAVE BRAGG
Dave was born and raised in a Real Estate Development family
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a and started working in the industry in 1989. Dave made his first
investment in real estate at the age of 21. His geographical focus
or has been Northern and Southern California, Texas, and Oregon
Dave has worked in Silicon Valley since 1998 and is actively
involved in the Bay Area community.
Dave Bragg is the managing partner at Silicon Valley Real
I WANGLG] Ventures. He oversees the daily operations of the firm and is
DESL SRL Seals
responsible for raising capital, evaluating investment dealflow and
setting strategic vision for SVRV shareholders. His main focus is
identifying and executing on innovative investment strategies
Dave has over 15 years of experience in real estate investing, fund
management and operations.
Exhibit Page 15
Dave is a consummate entrepreneur, having financed and
developed over $100 million of real estate during his career. He
continues to invest in California and International real estate and
has successfully raised financing for 25+ projects. Dave lives with
his family in Atherton, CA where he is active in community service
and philanthropy. In the past, he has served as a state licensed
General Contractor (Builder) where he scaled his Silicon Valley
construction company from 1 to 40 employees with 200 clients
over a four-year period. Notable clients include individuals from
Apple, Google, Facebook, LinkedIn, Yahoo, eBay and many from
the Venture Capital community. He has worked as firefighter in
the community for over 10 years. In 2003, he was deployed to the
Middle East, where he was among the first group of Marines to
lead the ground invasion into Iraq
Dave volunteers hundreds of hours each year to serve the local
community. He has served on the Menlo-Atherton Little League
Baseball Board of Directors, the Menlo-Atherton Pop Warner
Football Board of Directors, coaches youth baseball, soccer and
football, volunteers as a fundraiser for Jerry's Kids, co-chairs the
Menlo Park food and toy drive, serves as a house captain for
Rebuilding Together Peninsula, and is a donor-builder for Dreams
Happen Playhouse
KURTIS KLUDT
Kurtis was born and raised in Silicon Valley. Kurtis is a financial
engineer in the public equity markets and residential property
a =
market. He is CEO of ANA Holdings (Angel Networking Access),
&> diversified management and consulting company. Kurtis handles
\ ee public equities, real estate and start-up investments
Exhibit Page 16
Kurtis is an avid researcher and analyst of public equity markets,
investment opportunities, and new technologies. He is an angel
investor and a financial adviser. He is an avid follower of the real
estate market in Silicon Valley and brings a strong track record in
investor fund acquisition $100M of public equities transacted
since inception with Charles Schwab and Interactive Brokers.
Specialty research areas of fund management real estate,
dividend income, growth stocks, commodities, IPOs, and the
technology sector.
Kurtis works with and supports non-profit organizations such as
the National Multiple Sclerosis Society, Leukemia & Lymphoma
Society, and Poppy Foundation Animal Hospital
Kurtis graduated with honors from the UCLA College of Letters
and Science in conjunction with the Anderson School of
Management, where he earned his B.S. degree in Business
Economics
PETE SAMIS
W Pete Samis was born in San Jose, CA where his dad worked as a
general contractor building custom homes in Saratoga and Los
Gatos. When Pete was 10 years old he started to work for his
dad during the summer earning 25 cents a hour. After high school
oud he joined the Airforce and was stationed in Las Vegas where he
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worked as a Carpenter Specialist
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After working on residential and commercial projects in in Las
SAWS Vegas for 20 years, including for celebrities including Robert
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Goulet, Jerry Lewis, Liberace and Wayne Newton and on large
public works projects on the UNLV campus and at city hall, Pete
Exhibit Page 17
returned to the Bay Area with Cupertino Kitchen Design (Remodel
West) and American Kitchen & Bath. As the General Manager of
Thor Construction from 2011-213, Pete led more than 25 full house
remodel projects. During his time at Silicon Valley Real Ventures
as Vice President of Construction he has worked on numerous
development deals in the capacity of a project manager, general
contractor, and construction supervision
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Contact Us
Please get in touch if you would like to learn about how we can help you build OUR OFFICE
your own dream home, or how one of our developments could be a good fit
205 Constitution Dr
for you!
Exhibit Page 18 Menlo Park, CA 94025
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Exhibit Page 19
In the Community
SVRV values its deep connection in the local community.
DREAMS HAPPEN 2017 PLAYHOUS: FIREHOUSE
Since 1993, Stanford Shopping Center has hosted and produced the biennial Dreams
] Happen event benefiting Rebuilding Together Peninsula. Playhouses have sold for amounts
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C4LY, ranging from $13,000 to $101,000
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ber In 2017 the SVRV staff helped local firefighters build "Station 2," a classically themed
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DREAMS HAPPEN 2015 PLAYHOUS: FIRE LOOKOUT
SVRV contributes materials and our staff's labor every second year to help build a Fire
House themed playhouse designed by Larry Kahle & John Onken and built buy San Mateo
County Firefighters, IAFF Local 2400 FIRE LODKOIi, Pm
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Exhibit Page 20
HOMER FIELD AT WILLIE MAYS BALLPARK
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SVRV built the new stadium for Atherton's Homer Field at Willie Mays Ballpark, completed
in 2015
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Exhibit Page 21
Exhibit D
Exhibit Page 22
3/18/22, 1:46 PM (2) Experience | Dave Bragg | LinkedIn
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Home My Network Jobs Messaging Notifications Mew WorkY
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Engineer/Acting Captain at Menlo Park Fire Protection...
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Engineer/Acting Captain
Menlo Park Fire Protection District - Full-time
Nov 2003 - Present - 18 yrs 5 mos
Menlo Park, California, United States
Managing Director/CEO of Silicon Valley Real Estate Ventures
BRE#01997389
Silicon Valley Real Ventures
Jul 2014 - Present - 7 yrs 9 mos
Menlo Park, CA
Silicon Valley Real Ventures offers international investors access to the
Silicon Valley economy. We invest in a high end single family, multi family
and commercial real estate. We are a diverse team of professionals sharing
Silicon Valley opportunities with the world.
Silicon Valley Real Ventures
a SVRV (Silicon Valley Real Ventures) is a fully integrated
Private Equity firm with specializations in Venture Capit...
Founding Partner
VIP Car Vault LLC
Apr 2013 - Jun 2017 - 4 yrs 3 mos
Redwood City, CA
Built the business around VIP car storage. In a partnership with
AutoVino.org we offer VIP car storage. Our brilliant partners continue the
work.
Founding Partner/CEO
Exhibit Page 23
https://www.linkedin.com/in/davebraggsvrv/details/experience/ 1/3
3/18/22, 1:46 PM (2) Experience | Dave Bragg | LinkedIn
fy 3 Home My Network Jobs Messaging Notifications Me Work
California Luxury Properties & Development offers investment opportunities
in luxury homes in Silicon Valley.
Founder and CEO
Thor Construction
May 2009 - Sep 2013 - 4 yrs 5 mos
Menlo Park, CA
Built and grew this real estate construction company from 1 to 40
employees with 200 clients over a four-year period. Invested in and raised
financing for 20+ real estate projects. Notable clients include executives at
Apple, Google, Facebook, LinkedIn, Yahoo, and eBay. Projects included both
residential and commercial, small, and large construction projects.
Founder/CEO
Bragg Investment Group, LLC
May 2006 - May 2010 - 4 yrs 1 mo
CA & TX
Privately held company that purchased, managed, and maintained
residential real estate assets. We operated in Menlo Park, San Mateo, Santa
Barbara County, Laguna Niguel, Orange County, Solvang, and Lompoc
(California) and in Austin and Killeen (Texas).
Linked}
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Exhibit Page 24
https://www.linkedin.com/in/davebraggsvrv/details/experience/ 2/3
3/18/22, 1:46 PM (2) Experience | Dave Bragg | LinkedIn
fy 3 Home My Network Jobs Messaging Notifications
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Me Work
Exhibit Page 25
https://www.linkedin.com/in/davebraggsvrv/details/experience/ 3/3
Exhibit E
Exhibit Page 26
8/9/23, 10:26 AM (6) Dave Bragg | Linkedin
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Home My Network Jobs Messaging Notifications Mey For Business ¥ Post a job
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Dave Bragg ‘iliant/Handsome) - 2nd
Captain at Menlo Park Fire Protection District
S Menlo Park Fire Protection District,
‘S College of San Mateo
San Francisco Bay Area - Contact info
500+ connections
é Deidre Sparks, JD is a mutual connection
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1,185 followers
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Electronically Collin J. Vierra (State Bar No. 322720) EIMER STAHL LLP by Superior Court of Calitornia, County of San Mateo 99 Almaden Blvd., Suite 600 ON 8/11/2023 San Jose, CA 95113-1605 By /s/ Haley Correa Telephone: (408) 889-1668 Deputy Clerk Email: cvierra@eimerstahl.com Attorney for Plaintiffs Robert Arntsen, Mary Lee. Arntsen Family Partnership, LP, Brian Christopher Dunn Custodianship, John Ho, and Jacky Huang SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN MATEO 10 11 Robert Arntsen; Mary Lee; Arntsen Family Case No. 22-CIV-01148 Partnership, LP; Brian Christopher Dunn 12 Custodianship, John Ho, and Quanyu Huang; Date: August 18, 2023 Time: 9:00 am 13 Plaintiffs, Dept. 21 14 Vv. Hon. Robert D. Foiles 15 David M. Bragg; Silicon Valley Real Ventures LLC; SVRV 385 Moore, LLC; SVRV 387 EXHIBITS TO REPLY 16 Moore, LLC; Gregory J. Davis; Kevin Wolfe; DECLARATION OF COLLIN J. Jason Justesen; Paramont Woodside, LLC; VIERRA IN SUPPORT OF MOTION 17 Paramont Capital, LLC; Monks Family Trust; TO COMPEL AND FOR SANCTIONS 18 TEH Capital LLC; Caproc III, LLC; WZ AGAINST DEFENDANTS DAVID M. Partners, LLC; McClan Trust; Wild Rose BRAGG AND SILICON VALLEY 19 Irrevocable Trust; Black Horse Holdings, REAL VENTURES, LLC LLC; Phil Stoker; Diane Stoker; Scott O’Neil; 20 Dale Huish; and DOES 1-20, 21 Defendants. 22 23 24 25 26 27 28 Exhibit Page 1 EXHIBITS TO REPLY DECLARATION OF COLLIN J. VIERRA IN SUPPORT OF MOTION TO. COMPEL AND FOR SANCTIONS AGAINST DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES, LLC INDEX Exhibit A: May 18, 2023 Letter from Plaintiffs’ counsel to counsel for David M. Bragg and Silicon Valley Real Ventures, LLC regarding Bragg’s Spoliation and Other Discovery Abuses ........... 4 Exhibit B: July 10, 2023 Letter from Plaintiffs’ counsel to counsel for David M. Bragg and Silicon Valley Real Ventures, LLC regarding Bragg’s Deficient Production of Google Materials and Other Discovery Abuses 12 Exhibit C: Silicon Valley Real Ventures, LLC Webpage from March 17, 2022 14 10 Exhibit D: Screenshot of David M. Bragg’s LinkedIn Profile as of March 18, 2022 22 11 12 Exhibit E: Screenshot of David M. Bragg’s LinkedIn Profile as of August 9, 2023 26 13 Exhibit F: Email correspondence between Ryan Van Steenis and Collin Vierra regarding ‘Meet- 14 and-Confer Summary’ 31 15 16 Exhibit G: Screenshot from Google Drive showing Bragg-created and withheld file titled ‘387 17 Cap Table’ 35 18 Exhibit H: Screenshot from Google Drive showing Bragg-created and withheld file titled 19 “Bob Arntsen SVRV 387 Moore, LLC Investment-Subscription Agreement March 2019’.........39 20 21 Exhibit I: Screenshot from Google Drive showing Bragg-created and withheld file titled 22 “Bob Arntsen SVRV 387 Moore, LLC Investment-Subscription Agreement draft’ 41 23 24 Exhibit J: Email correspondence from David M. Bragg regarding ‘Moore Road status and update 25 4.30.2020’ received by Bob Arntsen failing to show Bcc’ed recipients 43 26 Exhibit K: Email correspondence from David M. Bragg regarding ‘Moore Road status and update 27 4.30.2020’ received by John Ho failing to show Bec’ed recipients. 47 28 Exhibit Page 2 EXHIBITS TO REPLY DECLARATION OF COLLIN J. VIERRA IN SUPPORT OF MOTION TO COMPEL AND FOR SANCTIONS AGAINST DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES, LLC Exhibit L: Email correspondence between Collin Vierra and Ran Van Steenis regarding meet and confer for the parties’ discovery dispute, dated February 24, 2023 51 Exhibit M: Amendment Cover Sheet, Jn re David M. Bragg (U.S. Bank. E.D. Cal.. No. 22- 22700) 54 Exhibit N: Email correspondence between Collin Vierra, Mark Poe and Ryan Van Steenis regarding ‘Further on Kludt’s (& Bragg’s) Responses to Plaintiff's RFPs” 67 Exhibit O: Email correspondence between Collin Vierra and Ryan Van Steenis regarding 10 September 16, 2022 Meet and Confer, including attachments.............. 00. ccececceeeeeeeee eee enees 70 11 12 13 14 Dated: August 11, 2023 By: Cth WM 15 Collin J. Vierra EIMER STAHL, LLP 16 Attorney for Plaintiffs 17 18 19 20 21 22 23 24 25 26 27 28 Exhibit Page 3 EXHIBITS TO REPLY DECLARATION OF COLLIN J. VIERRA IN SUPPORT OF MOTION TO COMPEL AND FOR SANCTIONS AGAINST DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES, LLC Exhibit A Exhibit Page 4 Eimer Stahl LLP EimerStahl.. 99 South Almaden Boulevard Suite 600 San J ose, California 95113 Tel 408-889-1668 Email cvierra@ eimerstahl.com May 18, 2023 Re: Arntsen Family Partnership, LP et al. v. GregoryJ. Davis et al., Case No. 22-CIV-01148 (California Superior Court of San Mateo County) Counsel: We write in response to your recent communication regarding your clients’ (David M. Bragg’s and Silicon Valley Real Ventures, LLC’s) previous and ongoing discovery abuses. If necessary, Plaintiffs intend to raise these issues with the Commissioner at the next IDC and seek terminating sanctions for your clients’ misconduct. Plaintiffs also reserve the right to raise these issues with the bankruptcy court at the appropriate time. Spoliatio As your client stated at the parties’ recent meeting, in early 2023, he disposed of his cell phone and failed to preserve any of his text messages. He did so after having produced zero text messages in this action or in the bankruptcy action. Y our position that this does not constitute spoliation is frivolous. Plaintiffs threatened your clients with litigation in 2021 (and your clients were engaged in substantial litigation even before that, including litigation involving the Moore Road Project). Plaintiffs sent your clients an explicit preservation notice both electronically and by mail at the outset of this action (which is reattached to this letter for your convenience). Plaintiffs sent your clients repeated document requests for text messages in this action. Plaintiffs initiated an action against your client in the bankruptcy court, upon which the court ordered the parties to participate in a discovery conference. Y et, apparently after each of these events occurred, your client willfully disposed of his cell phone including all text messages thereon. That is willful spoliation under both state and federal law, and Plaintiffs intend to seek all available remedies, as necessary, in each court. Document Productions Y our recent communications indicate that you intend to let your clients continue self- collecting documents. As Plaintiffs made clear last summer, that is unacceptable. Y our clients repeatedly have asserted that their document productions were complete, only for Plaintiffs to discover thousands more responsive documents that your clients were withholding. As Plaintiffs made clear last year, you—not Bragg—should take direct responsibility for collecting, searching, and producing responsive materials. Exhibit Page 5 May 18, 2023 Page 2 Production Methodology The recent list of search terms you provided is also unacceptable. To take one example, it is unreasonable to include only the search term “Moore Rd” rather than the singular word “Moore”. As another example, it is unacceptable not even to include the Plaintiff Bob Arntsen’s first name in the list of search terms. As Plaintiffs noted during the last IDC, Plaintiffs provided a “minimum” set of search terms and procedures in September 2022. Y ou never responded to that proposal, which was merely a starting point. Production Sources Y our clients repeatedly have made false statements about their sources of responsive documents. For example, at the parties’ recent meeting, your client stated that he does not have any documents or communications in his personal email account that were not also included in his work account. Contrary to that assertion, Plaintiffs have identified numerous such documents obtained from third parties. You have also reasserted that there are no “loose files” on your clients’ devices or in hard-copy format. As Plaintiffs said before, email communications and cloud files that Plaintiffs have obtained prove that your clients worked with responsive hard- copy documents and created responsive documents on their device(s) outside of GSuite. These documents should be produced. Relevant Time Y ou have asserted that communications post-dating the commencement of this litigation cannot be reasonably calculated to lead to the discovery of admissible evidence. That position is also meritless. To the extent your clients engaged in non-privileged communications (and/or created documents) about relevant events after those events occurred (and after this litigation commenced), Plaintiffs are entitled to discover those communications and documents. To take an obvious example, if your clients told a third party after this case commenced that, “Bob is suing us for the loan that we told him was for the Moore Road Project but which we actually misused,” that communication would plainly would be responsive and Plaintiffs would be entitled to discover it. Timing of Productions and Responses It has been nearly a year since your clients first were served with discovery in this action, and their productions and written responses still are woefully incomplete. Plaintiffs reserve the right to seek all appropriate remedies for this obstruction, as necessary, in each court. Plaintiffs’ Prior Productions Y ou assured Plaintiffs in 2022 that you retained the files for this case when you departed from your prior firm. Y et at the parties’ recent meeting, you stated that you did not retain the documents that Plaintiffs had Bates-stamped and circulated in this action, nor the email by which Exhibit Page 6 May 18, 2023 Page 3 they did so. At your request, Plaintiffs circulated these documents to you again on May 2, 2023 with an expiration date of May 9, 2023 via the exact same method that they did previously, yet our records indicate you did not download the production. Sincerely, Cite Waa Collin James Vierra Exhibit Page 7 Eimer Stahl LLP EimerStahl.. 99 South Almaden Boulevard Suite 641 San Jose, California 95113 Tel 408-889-1668 Email cvierra@eimerstahl.com April 8, 2022 Re: Arntsen Family Partnership, LP et al. v. Gregory J. Davis et al., Case No. 22-CIV-01148 (California Superior Court of San Mateo County) Dear Defendant: You are hereby being served in the above-captioned case, of which you may previously have received notice. If you are represented by counsel, please ask your counsel to promptly confirm your receipt of these papers by contacting me by phone or email as indicated below. Please also use the provided pre-paid envelope to promptly return one completed copy of the Acknowledgment of Receipt accompanying this letter. Pursuant to California law, you are instructed to preserve all materials, whether in tangible or intangible form, that may be relevant to this dispute or which may lead to the discovery of information relevant to this dispute, including but not limited to emails and attachments, calendar entries, text and instant messages, spreadsheets, powerpoints, financial records, loan records, databases, correspondence, memoranda, handwritten documents, printed documents, draft documents, invoices and receipts, planning documents, construction documents, contracts or other legal documents, photographs and other media files, voicemails, and all copies of the foregoing in any form. To that end, you are instructed to modify any settings or procedures that would cause you to intentionally or unintentionally destroy any such materials, including by removing auto-deletion settings on your computers, mobile devices, telephones, and other electronic devices, and including by halting any procedures that would cause you to destroy any such tangible materials. Materials that must be preserved include but are not limited to those relating to all operations of Silicon Valley Real Ventures, SVRV 385 Moore Road, SVRV 387 Moore Road, Paramont Capital, and Paramont Woodside. If you fail to preserve any such materials, Plaintiffs will pursue all available sanctions and remedies. (See, e.g., Cal. Code Civ. Proc. §§ 2023.010, 2023.030(a)-(d); Cal. Evid. Code § 413; Cal. Penal Code § 135; R.S. Creative, Inc. v. Creative Cotton Ltd. (1999) 75 Cal.App.4th 486; Williams v. Russ (2008) 167 Cal.App.4th 1215). Sincerely, (pte Wear Collin James Vierra Work: 408-889-1668 Mobile: 408-915-8266 Email: cvierra@eimerstahl.com Exhibit Page 8 From: SecureXfer_ESDS To: Vierra, Collin Subject: D. Bragg Google Drive Production Date: Tuesday, May 2, 2023 11:04:44 AM WARNING: External Email NOTE: this deliverable will expire on 5/09/2023. You have received this m« ge because Eimer Stahl Discovery Solutions (ESDS) has sent you a secure data transfer or ESDS is requesting a secure data transfer from you back to ESDS. By following the link below you will be able to register with our system and download the data that has been sent to you, or to send data back to ESDS. If you have registered previously, you will not need to register again. Below are instructions for registering and how to download the data being sent to you. Sender SecureXfer_ESDS Link : https://sftp.cimerstahl_com/bds/Login.do?id=A044583446&p 1=02j00hrsbffgjeffhleeibji20 Sent To : rjvan: nis@gmail.com Ce cvierra@eimerstahl.com; esds@eimerstahl.com Expires : 5/9/23, 11:59:00 PM CDT Files: 1. GOOGLE-BRAGG 001.zip To receive a secure data delivery from ESDS: 1. Click on the link included in this message. 2. If thi is the first time r ving a secure data delivery from ESDS, you will be required to register. During registration you will be asked to enter your em: address and to create a unique password. After you have completed the registration proce: . you will receive an email that contains an account activation link. Follow this link to activate your account. Once your account has been activated, you will be presented with a login screen. Enter your newly created user credentials to log in. 3. Ifyou have previously received a secure data delivery from ESDS, you do not need to register. Instead, you will be prompted to enter your user credentials (your email address) and the password you previously created. 4. After you log in, click on the blue link titled ‘Received’. 5. Under the subject column, select the message containing the data delivery that you would like to download. 6. After the message opens, select the box next to the files you would like to download. Select the ‘Download’ button. 7. If you would like to send a secure data delivery back to ESDS, follow the instructions below, starting with #6. To send a secure data delivery to ESDS: Exhibit Page 9 1. Click on the link included in this me: ge. 2. If thi is the first time sending a data delivery to ESDS, you will be required to register. During registration you will be ked to enter your email address and to create a unique password. After you have completed the re} ration proce , you will receive an email that contains an account activation link. Follow this link to activate your account. Once your account has been activated, you will be presented with a login screen. Enter your newly created user credentials to log in. 3. Ifyou have previously sent a secure data delivery to ESDS, you do not need to register. Instead, you will be prompted to enter your user credentials (your email address) and the unique password you previously created. 4 After you log in, click on the blue link titled ‘Received’. Under the ‘Subject’ column select the message you would like to respond to. Afier the message opens, select the ‘Reply Securely’ button. Enter any additional information within the m« ge body section. 8. Select the ‘Add Files and Send Reply’ button towards the bottom of the screen. . Navigate to the location of the files you would like to send and select them. 9. Click the ‘Send’ button. 10. A confirmation message will display indicating that your files were sent succ fully. Please contact ESDS@eimerstahl.com if you need additional a stance. Thi: ystem is the property of Eimer Stahl Discovery Solutions, LLC. All activity is monitored and logged. Unauthorized a including attempts to locate or access files without explicit authorization is prohibited. Eimer Stahl Discovery Solutions, LLC intends this system for file transfer only, not for storage. Our policy is to purge files older than seven (7) calendar days. By using this system, you acknowledge that you accept these terms. Exhibit Page 10 Jelivery Information Package name D. Bragg Google Drive Production To rjvansteenis@gmail.com cc cvierra@eimerstahl.com; esds@eimerstahl.com Subject D. Bragg Google Drive Production From SecureXfer_ESDS Date 05/02/2023 08:00 AM Date expires 05/09/2023 11:59 PM Secure message Mr. Van Steenis, On behalf of Collin Vierra, counsel for Plaintiffs, please find a re-delivery of the FTP link provided in September 2022. Email notification message NOTE: this deliverable will expire on 5/09/2023. You have received this PiPEa peqause Eimer Stahl Discovery Solutions (ESDS) has sent you a secure data transfer or ESDS is requesting a secure data transfer from you back to ESDS. Exhibit B Exhibit Page 12 Eimer Stahl LLP EimerStahl.. 99 South Almaden Boulevard Suite 600 San J ose, California 95113 Tel 408-889-1668 Email cvierra@ eimerstahl.com July 10, 2023 Re: Arntsen Family Partnership, LP et al. v. Gregory J. Davis et al., Case No. 22-CIV-01148 (California Superior Court of San Mateo County) Counsel: We write in response to your identification of the search terms that your client supposedly used in the “examination of his personal gmail and drive.” First, the document you provided does not accurately reflect Plaintiffs’ proposed search parameters from September 2022. Second, the list of search terms supposedly used by your clients is woefully insufficient, for the reasons we have articulated previously. Third, your client only provided emails in his May 19, 2023 “production”—not Google Drive documents. The only four Google Drive links provided were links to .eml email files. Therefore, it is not accurate to say that your client searched his personal Google Drive. Fourth, your client clearly did not even properly search his email account using the terms provided. As we have stated many times previously, third-party discovery has revealed emails that would have hit upon the terms supposedly used that your clients still have never produced. Lastly, we reiterate that there are numerous other deficiencies with your clients’ supposed searches and productions, which we have articulated many times previously. Each of these continues to demonstrate why your clients cannot be trusted to self-collect and -produce documents. Your clients’ discovery responses are now well over a year overdue. Plaintiffs reserve all rights regarding your clients’ repeated and ongoing discovery violations. Sincerely, (Hts Wor Collin James Vierra Exhibit Page 13 Exhibit C Exhibit Page 14 cis weeny - 4 Sa WY Wie vy i 1 Ce a SDipsyehs % PROPERTY LISTINGS ee AVAILABLE (/AVAILABLE-LISTIN — SOLD (/SOLD-LISTINGS) ——— = CUSTOM HOMES (/CUSTOM-H@MES DEVELOPMENT (/DEVELOPME lo, L ABOUT (/ABOUT) Fagley, Fe aN W900 000" Ga zz ie Co ne te Se oe hs ee oe aesse { DAVE BRAGG Dave was born and raised in a Real Estate Development family ss > a and started working in the industry in 1989. Dave made his first investment in real estate at the age of 21. His geographical focus or has been Northern and Southern California, Texas, and Oregon Dave has worked in Silicon Valley since 1998 and is actively involved in the Bay Area community. Dave Bragg is the managing partner at Silicon Valley Real I WANGLG] Ventures. He oversees the daily operations of the firm and is DESL SRL Seals responsible for raising capital, evaluating investment dealflow and setting strategic vision for SVRV shareholders. His main focus is identifying and executing on innovative investment strategies Dave has over 15 years of experience in real estate investing, fund management and operations. Exhibit Page 15 Dave is a consummate entrepreneur, having financed and developed over $100 million of real estate during his career. He continues to invest in California and International real estate and has successfully raised financing for 25+ projects. Dave lives with his family in Atherton, CA where he is active in community service and philanthropy. In the past, he has served as a state licensed General Contractor (Builder) where he scaled his Silicon Valley construction company from 1 to 40 employees with 200 clients over a four-year period. Notable clients include individuals from Apple, Google, Facebook, LinkedIn, Yahoo, eBay and many from the Venture Capital community. He has worked as firefighter in the community for over 10 years. In 2003, he was deployed to the Middle East, where he was among the first group of Marines to lead the ground invasion into Iraq Dave volunteers hundreds of hours each year to serve the local community. He has served on the Menlo-Atherton Little League Baseball Board of Directors, the Menlo-Atherton Pop Warner Football Board of Directors, coaches youth baseball, soccer and football, volunteers as a fundraiser for Jerry's Kids, co-chairs the Menlo Park food and toy drive, serves as a house captain for Rebuilding Together Peninsula, and is a donor-builder for Dreams Happen Playhouse KURTIS KLUDT Kurtis was born and raised in Silicon Valley. Kurtis is a financial engineer in the public equity markets and residential property a = market. He is CEO of ANA Holdings (Angel Networking Access), &> diversified management and consulting company. Kurtis handles \ ee public equities, real estate and start-up investments Exhibit Page 16 Kurtis is an avid researcher and analyst of public equity markets, investment opportunities, and new technologies. He is an angel investor and a financial adviser. He is an avid follower of the real estate market in Silicon Valley and brings a strong track record in investor fund acquisition $100M of public equities transacted since inception with Charles Schwab and Interactive Brokers. Specialty research areas of fund management real estate, dividend income, growth stocks, commodities, IPOs, and the technology sector. Kurtis works with and supports non-profit organizations such as the National Multiple Sclerosis Society, Leukemia & Lymphoma Society, and Poppy Foundation Animal Hospital Kurtis graduated with honors from the UCLA College of Letters and Science in conjunction with the Anderson School of Management, where he earned his B.S. degree in Business Economics PETE SAMIS W Pete Samis was born in San Jose, CA where his dad worked as a general contractor building custom homes in Saratoga and Los Gatos. When Pete was 10 years old he started to work for his dad during the summer earning 25 cents a hour. After high school oud he joined the Airforce and was stationed in Las Vegas where he ff mM i worked as a Carpenter Specialist a w AT es After working on residential and commercial projects in in Las SAWS Vegas for 20 years, including for celebrities including Robert ea ee ea reli Goulet, Jerry Lewis, Liberace and Wayne Newton and on large public works projects on the UNLV campus and at city hall, Pete Exhibit Page 17 returned to the Bay Area with Cupertino Kitchen Design (Remodel West) and American Kitchen & Bath. As the General Manager of Thor Construction from 2011-213, Pete led more than 25 full house remodel projects. During his time at Silicon Valley Real Ventures as Vice President of Construction he has worked on numerous development deals in the capacity of a project manager, general contractor, and construction supervision a Oe ee ie PE ee a b Contact Us Please get in touch if you would like to learn about how we can help you build OUR OFFICE your own dream home, or how one of our developments could be a good fit 205 Constitution Dr for you! Exhibit Page 18 Menlo Park, CA 94025 A NA (i eo Name =aBair Island lk 4, First Name Last Name Tes™ Email Address 2dwood City North Fair Oaks ‘orton East Palo Alto Subject * ark Atherton Baylands Nature Preserve a Menlo.Park eos Iris & B. Gerald Cantor pee Center for Visual Arts Palo Alto & Message ss Shoreline: (htt aB://may n/maps? "8376883: sa al 124 DOtmiABAi|HSina s Oso NA RerAwts RERBAPIGBIG)e 4 SEND MESSAGE Exhibit Page 19 In the Community SVRV values its deep connection in the local community. DREAMS HAPPEN 2017 PLAYHOUS: FIREHOUSE Since 1993, Stanford Shopping Center has hosted and produced the biennial Dreams ] Happen event benefiting Rebuilding Together Peninsula. Playhouses have sold for amounts Vy \) C4LY, ranging from $13,000 to $101,000 4 a ae ber In 2017 the SVRV staff helped local firefighters build "Station 2," a classically themed ed firehouse. DREAMS HAPPEN 2015 PLAYHOUS: FIRE LOOKOUT SVRV contributes materials and our staff's labor every second year to help build a Fire House themed playhouse designed by Larry Kahle & John Onken and built buy San Mateo County Firefighters, IAFF Local 2400 FIRE LODKOIi, Pm SA CoN Pd In 2015 the fire-themed playhouse was styled after the wildland fire lookout towers | ill Exhibit Page 20 HOMER FIELD AT WILLIE MAYS BALLPARK Sepa SVRV built the new stadium for Atherton's Homer Field at Willie Mays Ballpark, completed in 2015 y i es ‘ Le, Ti aa 1 | =‘ | a te ee ——il PROPERTY LISTINGS AVAILABLE (/AVAILABLE-LISTINGS) SOLD (/SOLD-LISTINGS) CUSTOM HOMES (/CUSTOM-HOMES) DEVELOPMENT (/DEVELOPMENT) [ABOUT] (/ABOUT) SVRV, 165 CONSTITUTION DRIVE, MENLO PARK, CA, 94025, UNITED STATES Exhibit Page 21 Exhibit D Exhibit Page 22 3/18/22, 1:46 PM (2) Experience | Dave Bragg | LinkedIn fy 3 t as = -= 9 a -= 8 Home My Network Jobs Messaging Notifications Mew WorkY @ Dave Bragg Engineer/Acting Captain at Menlo Park Fire Protection... ce Experience Engineer/Acting Captain Menlo Park Fire Protection District - Full-time Nov 2003 - Present - 18 yrs 5 mos Menlo Park, California, United States Managing Director/CEO of Silicon Valley Real Estate Ventures BRE#01997389 Silicon Valley Real Ventures Jul 2014 - Present - 7 yrs 9 mos Menlo Park, CA Silicon Valley Real Ventures offers international investors access to the Silicon Valley economy. We invest in a high end single family, multi family and commercial real estate. We are a diverse team of professionals sharing Silicon Valley opportunities with the world. Silicon Valley Real Ventures a SVRV (Silicon Valley Real Ventures) is a fully integrated Private Equity firm with specializations in Venture Capit... Founding Partner VIP Car Vault LLC Apr 2013 - Jun 2017 - 4 yrs 3 mos Redwood City, CA Built the business around VIP car storage. In a partnership with AutoVino.org we offer VIP car storage. Our brilliant partners continue the work. Founding Partner/CEO Exhibit Page 23 https://www.linkedin.com/in/davebraggsvrv/details/experience/ 1/3 3/18/22, 1:46 PM (2) Experience | Dave Bragg | LinkedIn fy 3 Home My Network Jobs Messaging Notifications Me Work California Luxury Properties & Development offers investment opportunities in luxury homes in Silicon Valley. Founder and CEO Thor Construction May 2009 - Sep 2013 - 4 yrs 5 mos Menlo Park, CA Built and grew this real estate construction company from 1 to 40 employees with 200 clients over a four-year period. Invested in and raised financing for 20+ real estate projects. Notable clients include executives at Apple, Google, Facebook, LinkedIn, Yahoo, and eBay. Projects included both residential and commercial, small, and large construction projects. Founder/CEO Bragg Investment Group, LLC May 2006 - May 2010 - 4 yrs 1 mo CA & TX Privately held company that purchased, managed, and maintained residential real estate assets. We operated in Menlo Park, San Mateo, Santa Barbara County, Laguna Niguel, Orange County, Solvang, and Lompoc (California) and in Austin and Killeen (Texas). Linked} About Accessibility Talent Solutions Questions? Select Language Marketing Solutions Visit our Help Center. 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Sales Solutions Mobile Small Business Safety Center Exhibit Page 24 https://www.linkedin.com/in/davebraggsvrv/details/experience/ 2/3 3/18/22, 1:46 PM (2) Experience | Dave Bragg | LinkedIn fy 3 Home My Network Jobs Messaging Notifications 8 Me Work Exhibit Page 25 https://www.linkedin.com/in/davebraggsvrv/details/experience/ 3/3 Exhibit E Exhibit Page 26 8/9/23, 10:26 AM (6) Dave Bragg | Linkedin BH 3 t = ° £ @ & Home My Network Jobs Messaging Notifications Mey For Business ¥ Post a job a ee a Dave Bragg ‘iliant/Handsome) - 2nd Captain at Menlo Park Fire Protection District S Menlo Park Fire Protection District, ‘S College of San Mateo San Francisco Bay Area - Contact info 500+ connections é Deidre Sparks, JD is a mutual connection Activity 1,185 followers Dave Bragg commented on a post + Imo Congratulations Dave Bragg commented on a post + 8mo Opal! Congrats