Preview
Electronically
per t iF i
6/12/2023
y /s/ Priscilla Tovar
Collin J. Vierra (State Bar No. 322720) Deputy Clerk
EIMER STAHL LLP
99 S. Almaden Blvd., Ste. 600
San Jose, CA 95113-1605
Telephone: (408) 889-1668
Email: cvierra@eimerstahl.com
Attorney for Plaintiffs
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN MATEO
10 Robert Arntsen; Mary Lee; Arntsen Family Case No. 22-CIV-01148
Partnership, LP; and Brian Christopher Dunn
11 Custodianship; Dept. 21
12
Plaintiffs, Hon. Robert D. Foiles
13 Vv.
14 David M. Bragg; Silicon Valley Real Ventures EXHIBITS TO DECLARATION OF
LLC; SVRV 385 Moore, LLC; SVRV 387 COLLIN J. VIERRA IN SUPPORT OF
15 Moore, LLC; Gregory J. Davis; Kevin Wolfe; MOTION TO COMPEL AND FOR
Jason Justesen; Paramont Woodside, LLC; SANCTIONS AGAINST DEFENDANTS
16
and Paramont Capital, LLC; DAVID M. BRAGG AND SILICON
17 VALLEY REAL VENTURES, LLC
Defendants.
18
19
20
21
22
23
24
25
26
27
28 EXHIBITS TO 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 Page 1
INDEX
Exhibit A: Plaintiffs’ Requests for Production of Documents Directed to Defendants David M.
Bragg and Silicon Valley Real Ventures, LLC, Sets One through Four
Exhibit B: Plaintiffs’ Special Interrogatories Directed to Defendants David M. Bragg and Silicon
Valley Real Ventures, LLC, Sets One through Seven............ severedS
Exhibit C: Plaintiffs’ Requests for Admission Directed to Defendants David M. Bragg and Silicon
Valley Real Ventures, LLC, Sets One through Four........... seceesee
ee TB
10
Exhibit D: Form Interrogatories Directed to Defendants David M. Bragg and Silicon Valley Real
11
Ventures, LLC, Sets One through Five 100
12
13 Exhibit E: Defendants David M. Bragg and Silicon Valley Real Ventures, LLC’s Responses to
14 Plaintiffs’ Requests for Production, Sets One through Four. 141
15
Exhibit F: Defendants David M. Bragg and Silicon Valley Real Ventures LLC’s Responses to
16
Plaintiffs’ Special Interrogatories, Sets One through Seven. 172
17
18 Exhibit G: Defendants David M. Bragg and Silicon Valley Real Ventures LLC’s Responses to
19
Plaintiffs’ Requests for Admission, Sets One through Four. 210
20
21 Exhibit H: Defendants M. Bragg and Silicon Valley Real Ventures, LLC’s Responses to
22 Plaintiffs’ Form Interrogatories, Sets One through Four 232
23
Exhibit I: Plaintiffs’ Informal Discovery Conference Letters 250
24
25 Exhibit J: Email correspondence between Ryan Van Steenis and Collin Vierra regarding October
26 2022 meet and confer 266
27
28 EXHIBITS TO 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 Page 2
Exhibit K: Email correspondence between Ryan Van Steenis and Collin Vierra regarding
‘Leuthold realsv.com account’ 270
Exhibit L: April 17, 2023, Letter from Ryan Van Steenis to Commissioner regarding Informal
Discovery Conference Scheduled for April 20, 2023 273
Exhibit M: May 28,2021 Email from Robert Arntsen to David Bragg and Kurtis Kludt regarding
Moore Road Properties 276
Exhibit N: Email correspondence between Ryan Van Steenis, Collin Vierra, and Mark Poe
10 regarding ‘Search Terms’ 278
11
Exhibit O: September 22, 2022, Ryan Van Steenis Letter to Commissioner Halperin regarding
12
September 27, 2022, Informal Discovery Conference Submission for Defendants David M. Bragg
13
and Silicon Valley Real Ventures, LLC 284
14
15
Exhibit P: June 5, 2023, Collin Vierra Letter to Ryan Van Steenis regarding Production of David
16
Bragg’s Emails 288
17
18 Exhibit Q: Email between Collin Vierra and Ryan Van Steenis regarding Discovery Deficiencies
19 of David Bragg and Silicon Valley Real Ventures, LLC 291
20
Exhibit R: Email between Collin Vierra and Ryan Van Steenis regarding September 16, 2022
21
Meet and Confer. 293
22
23 Exhibit S: Email correspondence between Collin Vierra and Ryan Van Steenis regarding March
24
23, 2023 Meet And Confer 301
25
26
27
28 EXHIBITS TO 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 Page 3
Exhibit T: Email correspondence between Collin Vierra and Ryan Van Steenis regarding David
Bragg Discovery 304
Exhibit U: April 8, 2022 Letter from Collin Vierra to Defendants providing Notice of
Lawsuit 307
Exhibit V: Email correspondence between Collin Vierra, Ryan Van Steenis and Mark Poe
regarding Google Drive links 309
Exhibit W: Email correspondence between Collin Vierra, Ryan Van Steenis and Mark Poe
10 regarding document production 314
11
Exhibit X: Email correspondence between Ryan Van Steenis, Collin Vierra and Mark Poe
12
regarding September 16, 2022 Meet and Confer 325
13
14 Exhibit Y: Email correspondence between Ryan Van Steenis, Collin Vierra, Mark Poe and others
15
regarding submission of motion to compel and for sanctions 333
16
Exhibit Z: March 26, 2021 LPS letter to David Bragg regarding Central LAH, LLC........... 337
17
18 Exhibit AA: Orders from IDC Commissioner. 343
19
20
21
Dated: June 12, 2023
22
Collin J. Vierra
23
24
25
26
27
28 EXHIBITS TO 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 Page 4
Exhibit A
Exhibit Page 5
Collin J. Vierra (State Bar No. 322720)
EIMER STAHL LLP
99 Almaden Blvd., Suite 642
San Jose, CA 95113-1605
Telephone: (408) 889-1668
Email: cvierra@eimerstahl.com
Attorney for Plaintiffs
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN MATEO
Robert Arntsen; Mary Lee; Arntsen Family Case No. 22-CIV-01148
10 Partnership, LP; and Brian Christopher Dunn
Custodianship; Dept. 21
11
12 Plaintiffs, Hon. Robert D. Foiles
Vv.
13 PLAINTIFFS’ FIRST SET OF
David M. Bragg; Kurtis Stuart Kludt; Silicon REQUESTS FOR PRODUCTION OF
14 Valley Real Ventures LLC; SVRV 385 DOCUMENTS DIRECTED TO
Moore, LLC; SVRV 387 Moore, LLC; DEFENDANTS DAVID M. BRAGG AND
15
Gregory J. Davis; Paramont Woodside, LLC; SILICON VALLEY REAL VENTURES
16 and Paramont Capital, LLC; LLC
17 Defendants.
18
19
20
PROPOUNDING PARTIES: PLAINTIFFS
21
RESPONDING PARTIES: DAVID M. BRAGG;
2 SILICON VALLEY REAL VENTURES, LLC
23 SET NUMBER: ONE
24
25
26
27
28 1
PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO
DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC
Exhibit Page 6
Pursuant to California Code of Civil Procedure §§ 2031.010 et seq., Plaintiffs hereby
request that Defendants David M. Bragg and Silicon Valley Real Ventures, LLC identify and
produce the documents requested below to the law offices of Eimer Stahl LLP, 99 Almaden
Blvd., Ste. 642, San Jose, CA 95113-1605 on or before June 27, 2022.
I DEFINITIONS
The following Definitions shall apply to the Instructions and to each of the Requests:
1 “Action” refers to the above-captioned action, Case No. 22-CIV-01448, filed in
the Superior Court for the State of California, San Mateo County.
2. “All” shall include the term “each,” and vice-versa, as necessary, to bring within
the scope of the Request all responses that might otherwise be construed to be outside the scope
of the Request.
10
3 “Communication(s)” means the transmittal of information (in the form of facts,
11
ideas, inquiries, or otherwise), or attempt to transmit information, whether written, oral,
12
electronic, or by any other means.
13 4 “Concerning” means relating to, referring to, describing, evidencing, or
14 constituting.
15 5 “Defendants” refers to any of the Defendants named in the above-captioned
Action and all of their corporate parents, subsidiaries, attorneys, accountants, officers, directors,
16
employees, partners, agents, or representatives.
17
6. “Document(s)” shall have the broadest meaning possible under California law,
18
including, but not limited to, the Definition of “writing” in California Evidence Code § 250, and
19 includes all originals and drafts, in any and all languages, of any nature whatsoever, in Your
20 (defined below) possession, custody, or control, regardless of where located, and includes, but is
21 not limited to, letters, correspondence, logs, drafts, contracts, prospective contracts, agreements,
records, studies, surveys, resolutions, tabulations, notes, summaries, memoranda, electronically
22
stored information (“ESI”), electronic mail (“e-mail”), instant messages, calendar or diary
23
entries, handwritten notes, working papers, worksheets, spreadsheets, diagrams, minutes,
24
agendas, bulletins, periodicals, circulars, advertisements, notices, announcements, invoices,
25 statements, checks (front and back), bank statements, ledgers, orders, vouchers, instructions,
26 drawings, charts, graphs, manuals, brochures, pamphlets, schedules, telegrams, teletypes,
27 photographs, audio tapes, voicemail messages, videotapes, electronic recordings, facsimile
28 2
PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO
DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC
Exhibit Page 7
transmissions, and information of whatever kind, either stored on computers, including computer
disks, hard drives and other media for storage of ESI, or information recorded on any medium,
and every other written, typed, recorded, transcribed, filed, or graphic matter, whether sent,
received, or neither, and both sides thereof, including non-identical copies and drafts, in the
custody, possession, or control of the parties responding to this Request, their agents,
accountants, employees representatives, or attorneys, and things similar to any of the foregoing,
however denominated by the parties required to produce hereunder.
7
“Identify,” when used in reference to an individual, means that Person’s name,
address, telephone number, e-mail address, employer, and job title or position.
8 “Identify,” when used in any context other than as defined in the preceding
paragraph, shall mean a description of the subject to be identified and specification of the
10
Documents or Communications in which the subject is or was recorded, described, or referred
11
and all other information necessary to fully identify the subject.
12 9 “Meeting” means the contemporaneous presence, whether in person or through
13 any means of Communication, of any natural Persons, whether or not such presence was by
14 chance or prearranged and whether or not the Meeting was formal, informal, or occurred in
connection with some other activity.
15
10. “Person” means any natural person, public or private corporation, whether or not
16
organized for profit, governmental entity, partnership, association, cooperative, joint venture,
17
sole proprietorship, or other legal entity. With respect to a business entity, the term “Person”
18 includes any natural person acting formally or informally as a director, trustee, officer, agent,
19 attorney, or other representative of the business entity.
20 11. “Project” means the project described in the above-captioned Action to purchase,
develop, and/or sell the properties located at 385 Moore Road and 387 Moore Road in
21
Woodside, California.
22
12. “Referring” or “Relating to” or “Related to” means all Documents that comprise,
23
explicitly or implicitly refer to, were reviewed in conjunction with, or were created, generated, or
24 maintained as a result of the subject matter of the Request, including, without limitation, all
25 Documents that reflect, record, memorialize, embody, discuss, evaluate, consider, review, or
26 report on the subject matter of the Request.
27 13. “You,” “Your,” and “Yourself” refer to the Defendants to whom the following
28 3
PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO
DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC
Exhibit Page 8
Requests are addressed and their agents, representatives, officers, directors, accountants,
insurance companies, attorneys, investigators, affiliates, predecessors, and successors in interest,
parents, divisions, subsidiaries, area and regional offices, and employees, including Persons or
entities outside the United States, or anyone acting on Your behalf.
14. The connectives “and” and “or shall be construed either disjunctively or
conjunctively, as necessary, to bring within the scope of the Request all responses that might
otherwise be construed to be outside of its scope.
15. The use of the singular form of any word includes the plural and vice versa, and
the masculine, feminine, or neuter form of any words includes each of the other genders.
16. The use of any tense of any verb shall also include within its meaning all other
tenses of that verb.
10
Il. INSTRUCTIONS
11
1 These Requests are continuing and require further and supplemental production
12
by You whenever You acquire or locate additional Documents between the time of these
13 Requests and the final resolution of this Action.
14 2. All Documents shall be produced in the order they are kept in the ordinary course
15 of business and shall be produced in their original folders, binders, covers, or containers or
facsimile thereof.
16
3 If a Document was prepared in several copies, or if additional copies were
17
subsequently made, and any such copies were not identical or are no longer identical by reason
18
of subsequent notation or modification of any kind whatsoever, including, without limitation,
19 handwritten notations on the front or back of the Document, all such non-identical copies shall
20 be produced.
21 4 Documents shall be produced in such fashion as to Identify the department,
branch, or office in which they were located and, where applicable, the natural Person in whose
22
possession they were found, and the business address of each Document’s custodian(s).
23
5 Documents shall be identified with the specific Request number to which the
24
Documents respond. See Cal. Code Civ. Proc. § 2031.280(a).
25 6 Documents attached to each other should not be separated.
26 7 These Requests relate to all Documents which are in Your possession, custody, or
27 control, or in the possession, custody, or control of Your predecessors, successors, parents,
28
4
PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO
DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC
Exhibit Page 9
subsidiaries, divisions, or affiliates, or their respective officers, directors, agents, attorneys,
accountants, employees, partners, or other Persons occupying similar positions or performing
similar functions.
8 The Documents to be produced pursuant to these Requests specifically embrace,
in addition to Documents within Your possession, custody, or control, all Documents within the
possession, custody, or control of any of Your agents, accountants, representatives, or attorneys.
9 Documents also embrace originals and identical copies (whether different from
the original because of notes made thereon or otherwise) of the Documents described in these
Requests.
10. The fact that a Document has been or will be produced by another party does not
relieve You of the obligation to produce Your copy of the same Document, even if the two
10
Documents are identical in all respects.
11
11. You shall produce the original of each Document described below or, if the
12 original is not in Your custody, then a copy thereof, and in any event, all non-identical copies
13 which differ from the original or from the other copies produced for any reason, including, but
14 not limited to, the making of notes thereon.
12. If any Document falls within the scope of any Request, but is not being produced,
15
or is being produced with portions redacted, pursuant to any claim of privilege or confidentiality,
16
please provide a log containing the following information:
17
(a) the name of the privilege claimed (i.e., attorney-client, attorney work-
18 product, etc.);
19 (b) the name of the Person or entity claiming privilege and the name of the
20 attorney, if any, with respect to whom the privilege is claimed;
21 (c) the facts upon which You rely as the basis for claiming any privilege as to
the specific information or Document;
22
(d) the name of such Document; Identify the type of Document (i.e., letter,
23
memo, etc.); set forth the subject matter thereof; Identify the Person who prepared it, and
24 each Person (if any) who signed it; Identify each Person to whom it was directed,
25 circulated, or shown; and Identify each Person now in possession of the Document. If any
26 Document is produced in redacted form, the word “redacted” is to be placed in the
27 redacted section of the Document; and
28 5
PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO
DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC
Exhibit Page 10
(e) whenever a Document is not produced in full or is produced in redacted
form, so indicate on the Document and state with particularity the reason or reasons it is
not being produced in full and describe to the best of Your knowledge, information, and
belief, and with as much particularity as possible, those portions of the Document which
are not being produced.
13. In the event that any Document called for by these Requests has been destroyed or
discarded, that Document is to be identified by stating:
(a) the nature of the Document;
(b) the names of any addressor or addressee;
(c) if there are any indicated or blind copies;
(d) the Document’s date, subject matter, number of pages, and attachments or
10
appendices;
11
(e) all Persons to whom the Document was distributed, shown, or explained;
12 (f) its date of destruction or discard and manner of destruction or discard; and
13 (g) the Persons authorizing and/or carrying out such destruction or discard.
14 14. With respect to any Documents which You contend would be in some way
“burdensome” “oppressive” to produce, please state the specific reasons for that objection.
15
15. If You object to part of any Request, please furnish Documents responsive to the
16
remainder of the Request.
17
16. Each Request refers to all Documents that are either known by Defendants to
18 exist or that can be located or discovered by reasonably diligent efforts of Defendants.
19 17. The Documents produced in response to these Requests shall include all
20 attachments and enclosures.
18. All electronic Documents shall be produced in such fashion as to identify the
21
location, i.e., the network file folder, hard drive, back-up tape, or other location, where the
2
Documents are stored and, where applicable, the natural Person in whose possession they were
2.
found and the business address of each Document’s custodian(s).
24
Il. RELEVANT PERIOD
25 Unless otherwise noted, all Requests herein refer to the time period of January 1, 2017
26 through the date of production, inclusive, and shall include all Documents that relate, in whole or
27 in part, to such period even though dated, prepared, or received prior or subsequent to that
28 6
PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO
DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC
Exhibit Page 11
period. If a Document prepared prior or subsequent to the Relevant Period is necessary for a
correct or complete understanding of any Document covered by a Request, You must produce
the prior or subsequent Document as well. If any Document is undated and the date of its
preparation cannot be determined, the Document shall be produced if otherwise responsive to the
Request.
IV. REQUESTS FOR PRODUCTION
REQUEST NO. 1:
All Communications between You and (1) the Plaintiffs and (2) anyone affiliated with
Silicon Valley Real Ventures, LLC relating to Plaintiffs’ investments with Silicon Valley Real
Ventures, LLC between January 1, 2012 and the present.
REQUEST NO. 2:
10
All Communications relating to the Project between You and any third parties involved
11
with the Project, including but not limited to real estate agents, realtors, brokers, loan officers,
12
lending agents, engineers, architects, landscape architects, inspection officers or agencies, and
13 permitting officials or agencies.
14 REQUEST NO. 3:
15 All Communications with any members of the Geyer family relating to the Project.
REQUEST NO. 4:
16
All Communications related to the sale or transfer of the Moore Road properties to
17
Silicon Valley Real Ventures, LLC, including all Communications with the sellers of the Moore
18
Road properties and their agents.
19 REQUEST NO. 5:
20 All financial, accounting, and governance Documents relating to Plaintiffs’ investments
21 with Silicon Valley Real Ventures, LLC between January 1, 2012 and the present, including but
not limited to bills, checks, receipts, certificates, ownership tables, projections, analyses, account
22
statements, tax records, balance sheets, income statements, cash flow statements, profit or loss
23
statements, investment agreements, operating agreements, and subscription agreements.
24
REQUEST NO. 6:
25 All financial, accounting, and governance Documents relating to the Project., including
26 but not limited to bills, checks, receipts, certificates, ownership tables, projections, analyses,
27 account statements, tax records, balance sheets, income statements, cash flow statements, profit
7
28
PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO
DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC
Exhibit Page 12
or loss statements, investment agreements, operating agreements, and subscription agreements.
REQUEST NO. 7:
All Communications with, Documents provided to, and Documents received from,
Gregory J. Davis, Paramont Capital, LLC, and/or Paramont Woodside, LLC.
REQUEST NO. 8:
All Communications with, Documents provided to, and Documents received from, Kurtis
S. Kludt relating to Plaintiffs’ investments with Silicon Valley Real Ventures, LLC, including
the Project, between January 1, 2012 and the present.
REQUEST NO. 9:
All Documents relating to any loans that Plaintiffs extended to Silicon Valley Real
Ventures, LLC, including Documents reflecting the conditions on which the loans were extended
10
and how the loan proceeds were used.
11
REQUEST NO. 10:
12 Documents sufficient to show all Your joint or individual accounts, securities, financial
13 assets, real assets, personal assets, or any other assets, including but not limited to savings
14 accounts, checking accounts, retirement accounts, investment accounts, vehicles, real estate, and
land, worth $10,000 or more.
15
REQUEST NO. 11:
16
All Documents related to the sale of the Moore Road Properties, including Documents
17
sufficient to show any agreements with real estate brokers involved in the transaction.
18
19
20 Dated: May 27, 2022 py CA UH
21 Collin J. Vierra
EIMER STAHL, LLP
22
Attorney for Plaintiffs Robert Arntsen,
23 Mary Lee, the Arntsen Family
Partnership, LP, and the Brian
24
Christopher Dunn Custodianship
25
26
27
28 8
PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO
DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC
Exhibit Page 13
CollinJ. Vierra (State Bar No. 322720)
EIMER STAHL LLP
99 Almaden Blvd., Suite 642
San Jose, CA 95113-1605
Telephone: (408) 889-1668
Email: cvierra@ eimerstahl.com
Attorney for Plaintiffs
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN MATEO
Robert Amtsen; Mary Lee; Arntsen Family Case No. 22-CIV-01148
10 Partnership, LP; and Brian Christopher Dunn
Custodianship; Dept. 21
11
12 Plaintiffs, Hon. Robert D. Foiles
Vv.
13 PLAINTIFFS’ SECOND SET OF
David M. Bragg; Kurtis Stuart K]udt; Silicon REQUESTS FOR PRODUCTION OF
14 Valley Real Ventures LLC; SVRV 385 DOCUMENTS DIRECTEDTO
Moore, LLC; SVRV 387 Moore, LLC; DEFENDANTS DAVIDM. BRAGG AND
15 Gregory J. Davis; Paramont Woodside, LLC; SILICON VALLEY REAL VENTURES
16 and Paramont Capital, LLC; LLC
17 Defendants.
18
19
20
PROPOUNDING PARTIES: PLAINTIFFS
21
RESPONDING PARTIES: DAVID M. BRAGG;
SILICON VALLEY REAL VENTURES, LLC
23 SET NUMBER: TWO
24
25
26
27
28 1
PLAINTIFFS’ SECOND SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO
DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC
Exhibit Page 14
Pursuantto Califomia Code of Civil Procedure §§ 2031.010 et seq., Plaintiffs hereby
request that Defendants David M. Bragg and Silicon Valley Real Ventures, LLC identify and
produce the documents requested below to the law offices of Eimer Stahl LLP, 99 Almaden
Blvd., Ste. 642, San Jose, CA 95113-1605 on or before August5, 2022.
I DEFINITIONS
The following Definitions shall apply to the Instructions and to each of the Requests:
1 “Action” refers to the above-captioned action, Case No. 22-CIV-01448, filed in
the Superior Court for the State of Califomia, San Mateo County.
2 “All” shall include the term “each,” and vice-versa, as necessary, to bring within
the scope of the Request all responses that might otherwise be construed to be outside the scope
of the Request.
10
3 “Communication(s)” means the transmittal of information (in the form of facts,
11
ideas, inquiries, or otherwise), or attempt to transmit information, whether written, oral,
12
electronic, or by any other means.
13 4 “Concerning” means relating to, referring to, describing, evidencing, or
14 constituting.
15 5. “Defendants” refers to any of the Defendants named in the above-captioned
Action and all of their corporate parents, subsidiaries, attorneys, accountants, officers, directors,
16
employees, partners, agents, or representatives.
17
6 “Document(s)” shall have the broadest meaning possible under California law,
18
including, but not limited to, the Definition of “writing” in California Evidence Code § 250, and
19 includes all originals and drafts, in any and all languages, of any nature whatsoever, in Y our
20 (defined below) possession, custody, or control, regardless of where located, and includes, but is
21 not limited to, letters, correspondence, logs, drafts, contracts, prospective contracts, agreements,
records, studies, surveys, resolutions, tabulations, notes, summaries, memoranda, electronically
22
stored information (“ESI”), electronic mail (“e-mail”), instant messages, calendar or diary
23
entries, handwritten notes, working papers, worksheets, spreadsheets, diagrams, minutes,
24
agendas, bulletins, periodicals, circulars, advertisements, notices, announcements, invoices,
25 statements, checks (front and back), bank statements, ledgers, orders, vouchers, instructions,
26 drawings, charts, graphs, manuals, brochures, pamphlets, schedules, telegrams, teletypes,
27 photographs, audio tapes, voicemail messages, videotapes, electronic recordings, facsimile
28 2
PLAINTIFFS’ SECOND SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO
DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC
Exhibit Page 15
transmissions, and information of whatever kind, either stored on computers, including computer
disks, hard drives and other media for storage of ESI, or information recorded on any medium,
and every other written, typed, recorded, transcribed, filed, or graphic matter, whether sent,
received, or neither, and both sides thereof, including non-identical copies and drafts, in the
custody, possession, or control of the parties responding to this Request, their agents,
accountants, employees representatives, or attorneys, and things similar to any of the foregoing,
however denominated by the parties required to produce hereunder.
7 “Identify,” when used in reference to an individual, means that Person’s name,
address, telephone number, e-mail address, employer, and job title or position.
8 “Identify,” when used in any context other than as defined in the preceding
paragraph, shall mean a description of the subject to be identified and specification of the
10
Documents or Communications in which the subject is or was recorded, described, or referred
11
and all other information necessary to fully identify the subject.
12 9 “Meeting” means the contemporaneous presence, whether in person or through
13 any means of Communication, of any natural Persons, whether or not such presence was by
14 chance or prearranged and whether or not the Meeting was formal, informal, or occurred in
connection with some other activity.
15
10. “Person” means any natural person, public or private corporation, whether or not
16
organized for profit, governmental entity, partnership, association, cooperative, joint venture,
17
sole proprietorship, or other legal entity. With respect to a business entity, the term “Person”
18 includes any natural person acting formally or informally as a director, trustee, officer, agent,
19 attoney, or other representative of the business entity.
20 11. “Project” means the project described in the above-captioned A ction to purchase,
21 develop, and/or sell the properties located at 385 Moore Road and 387 Moore Road in
Woodside, Califomia.
22
12. “Referring” or “Relating to” or “Related to” means all Documents that comprise,
23
explicitly or implicitly refer to, were reviewed in conjunction with, or were created, generated, or
24 maintained as a result of the subject matter of the Request, including, without limitation, all
25 Documents that reflect, record, memorialize, embody, discuss, evaluate, consider, review, or
26 report on the subject matter of the Request.
27 13. “You,” “Your,” and “Yourself” refer to the Defendants to whom the following
28 3
PLAINTIFFS’ SECOND SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO
DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC
Exhibit Page 16
Requests are addressed and their agents, representatives, officers, directors, accountants,
insurance companies, attomeys, investigators, affiliates, predecessors, and successors in interest,
parents, divisions, subsidiaries, area and regional offices, and employees, including Persons or
entities outside the United States, or anyone acting on Y our behalf.
14, The connectives “and” and ee?
“or” shall be construed either disjunctively or
conjunctively, as necessary, to bring within the scope of the Request all responses that might
otherwise be construed to be outside of its scope.
15. The use of the singular form of any word includes the plural and vice versa, and
the masculine, feminine, or neuter form of any words includes each of the other genders.
16. The use of any tense of any verb shall also include within its meaning all other
tenses of that verb.
10
I. INSTRUCTIONS
11
1 These Requests are continuing and require further and supplemental production
12
by Y ou wheneverY ou acquire or locate additional Documents between the time of these
13 Requests and the final resolution of this Action.
14 2 All Documents shall be produced in the order they are kept in the ordinary course
15 of business and shall be produced in their original folders, binders, covers, or containers or
facsimile thereof.
16
3 If a Document was prepared in several copies, or if additional copies were
17
subsequently made, and any such copies were not identical or are no longer identical by reason
18
of subsequent notation or modification of any kind whatsoever, including, without limitation,
19 handwritten notations on the front or back of the Document, all such non-identical copies shall
20 be produced.
21 4 Documents shall be produced in such fashion as to Identify the department,
branch, or office in which they were located and, where applicable, the natural Person in whose
22
possession they were found, and the business address of each Document’s custodian(s).
23
5. Documents shall be identified with the specific Request number to which the
24
Documents respond. See Cal. Code Civ. Proc. § 2031.280(a).
25 6 Documents attached to each other should not be separated.
26 7 These Requests relate to all Documents which are in Y our possession, custody, or
27 control, or in the possession, custody, or control of Y our predecessors, successors, parents,
28 4
PLAINTIFFS’ SECOND SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO
DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC
Exhibit Page 17
subsidiaries, divisions, or affiliates, or their respective officers, directors, agents, attorneys,
accountants, employees, partners, or other Persons occupying similar positions or performing
similar functions.
8 The Documents to be produced pursuant to these Requests specifically embrace,
in addition to Documents within Y our possession, custody, or control, all Documents within the
possession, custody, or control of any of Y our agents, accountants, representatives, or attorneys.
9 Documents also embrace originals and identical copies (whether different from
the original because of notes made thereon or otherwise) of the Documents described in these
Requests.
10. The fact that a Document has been or will be produced by another party does not
relieve Y ou of the obligation to produce Y our copy of the same Document, even if the two
10
Documents are identical in all respects.
11
11. Y ou shall produce the original of each Document described below or, if the
12 original is not in Y our custody, then a copy thereof, and in any event, all non-identical copies
13 which differ from the original or from the other copies produced for any reason, including, but
14 not limited to, the making of notes thereon.
12. If any Document falls within the scope of any Request, but is not being produced,
15
or is being produced with portions redacted, pursuant to any claim of privilege or confidentiality,
16
please provide a log containing the following information:
17
(a) the name of the privilege claimed (i.e., attorney-client, attomey work-
18 product, etc.);
19 (b) the name of the Person or entity claiming privilege and the name of the
20 attomey, if any, with respect to whom the privilege is claimed;
21 (c) the facts upon which Y ou rely as the basis for claiming any privilege as to
the specific information or Document;
22
(d) the name of such Document; Identify the type of Document (i.e., letter,
23
memo, etc.); set forth the subject matter thereof; Identify the Person who prepared it, and
24 each Person (if any) who signed it; Identify each Person to whom it was directed,
25 circulated, or shown; and Identify each Person now in possession of the Document. If any
26 Document is produced in redacted form, the word “redacted” is to be placed in the
27 redacted section of the Document; and
28 5
PLAINTIFFS’ SECOND SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO
DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC
Exhibit Page 18
(e) whenever a Document is not produced in full or is produced in redacted
form, so indicate on the Document and state with particularity the reason or reasons it is
not being produced in full and describe to the best of Y our knowledge, information, and
belief, and with as much particularity as possible, those portions of the Document which
are not being produced.
13. In the event that any Document called for by these Requests has been destroyed or
discarded, that Document is to be identified by stating:
(a) the nature of the Document;
(b) the names of any addressor or addressee;
(c) if there are any indicated or blind copies;
(d) the Document’s date, subject matter, number of pages, and attachments or
10
appendices;
11
(e) all Persons to whom the Document was distributed, shown, or explained;
12 (f) its date of destruction or discard and manner of destruction or discard; and
13 (g) the Persons authorizing and/or carrying out such destruction or discard.
14 14, With respect to any Documents which Y ou contend would be in some way
“burdensome” or “oppressive” to produce, please state the specific reasons for that objection.
15
15. If Y ou object to part of any Request, please furnish Documents responsive to the
16
remainder of the Request.
17
16. Each Request refers to all Documents that are either known by Defendants to
18 exist or that can be located or discovered by reasonably diligent efforts of Defendants.
19 17. The Documents produced in response to these Requests shall include all
20 attachments and enclosures.
21 18. All electronic Documents shall be produced in such fashion as to identify the
location, i.e., the network file folder, hard drive, back-up tape, or other location, where the
22
Documents are stored and, where applicable, the natural Person in whose possession they were
23
found and the business address of each Document’s custodian(s).
24
I. RELEVANT PERIOD
25 Unless otherwise noted, all Requests herein refer to the time period of January 1, 2017
26 through the date of production, inclusive, and shall include all Documents that relate, in whole or
27 in part, to such period even though dated, prepared, or received prior or subsequent to that
28 6
PLAINTIFFS’ SECOND SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO
DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC
Exhibit Page 19
period. If a Document prepared prior or subsequent to the Relevant Period is necessary for a
correct or complete understanding of any Document covered by a Request, Y ou must produce
the prior or subsequent Document as well. If any Document is undated and the date of its
preparation cannot be determined, the Document shall be produced if otherwise responsive to the
Request.
IV. REQUESTS FOR PRODUCTION
REQUEST NO. 12:
On an ongoing basis, all non-privileged Communications between Y ou and any other
Defendant in this A ction relating to this litigation or any aspect thereof, including without
limitation service, procedure, discovery, evidence, strategy, trial, damages, or judgment.
REQUEST NO. 13:
10
All Documents stored in or accessible through the Google Workspace (formerly known
11
as G Suite) or Google Drive accounts of woodsidemoore385@ gmail.com,
12
woodsidemoore387@ gmail.com, d@realsv.com, or any other account through which Y ou
13 conducted SV RV -related business.
14
15
16
Dated: July 6, 2022 py CLA UE
17
CollinJ. Vierra
18 EIMER STAHL, LLP
19 Attorney for Plaintiffs Robert Arntsen,
20 Mary Lee, the Arntsen Family
Partnership, LP, and the Brian
21 Christopher Dunn Custodianship
22
23
24
25
26
27
28 7
PLAINTIFFS’ SECOND SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO
DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC
Exhibit Page 20
CollinJ. Vierra (State Bar No. 322720)
EIMER STAHL LLP
99 Almaden Blvd., Suite 642
San Jose, CA 95113-1605
Telephone: (408) 889-1668
Email: cvierra@ eimerstahl.com
Attorney for Plaintiffs
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN MATEO
Robert Amtsen; Mary Lee; Arntsen Family Case No. 22-CIV-01148
10 Partnership, LP; and Brian Christopher Dunn
Custodianship; Dept. 21
11
12 Plaintiffs, Hon. Robert D. Foiles
Vv.
13 PLAINTIFFS’ THIRD SET OF
David M. Bragg; Kurtis Stuart K]udt; Silicon REQUESTS FOR PRODUCTION OF
14 Valley Real Ventures LLC; SVRV 385 DOCUMENTS DIRECTEDTO
Moore, LLC; SVRV 387 Moore, LLC; DEFENDANTS DAVIDM. BRAGG AND
15 Gregory J. Davis; Paramont Woodside, LLC; SILICON VALLEY REAL VENTURES
16 and Paramont Capital, LLC; LLC
17 Defendants.
18
19
20
PROPOUNDING PARTIES: PLAINTIFFS
21
RESPONDING PARTIES: DAVID M. BRAGG;
Preview
Electronically per t iF i 6/12/2023 y /s/ Priscilla Tovar Collin J. Vierra (State Bar No. 322720) Deputy Clerk EIMER STAHL LLP 99 S. Almaden Blvd., Ste. 600 San Jose, CA 95113-1605 Telephone: (408) 889-1668 Email: cvierra@eimerstahl.com Attorney for Plaintiffs SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN MATEO 10 Robert Arntsen; Mary Lee; Arntsen Family Case No. 22-CIV-01148 Partnership, LP; and Brian Christopher Dunn 11 Custodianship; Dept. 21 12 Plaintiffs, Hon. Robert D. Foiles 13 Vv. 14 David M. Bragg; Silicon Valley Real Ventures EXHIBITS TO DECLARATION OF LLC; SVRV 385 Moore, LLC; SVRV 387 COLLIN J. VIERRA IN SUPPORT OF 15 Moore, LLC; Gregory J. Davis; Kevin Wolfe; MOTION TO COMPEL AND FOR Jason Justesen; Paramont Woodside, LLC; SANCTIONS AGAINST DEFENDANTS 16 and Paramont Capital, LLC; DAVID M. BRAGG AND SILICON 17 VALLEY REAL VENTURES, LLC Defendants. 18 19 20 21 22 23 24 25 26 27 28 EXHIBITS TO 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 Page 1 INDEX Exhibit A: Plaintiffs’ Requests for Production of Documents Directed to Defendants David M. Bragg and Silicon Valley Real Ventures, LLC, Sets One through Four Exhibit B: Plaintiffs’ Special Interrogatories Directed to Defendants David M. Bragg and Silicon Valley Real Ventures, LLC, Sets One through Seven............ severedS Exhibit C: Plaintiffs’ Requests for Admission Directed to Defendants David M. Bragg and Silicon Valley Real Ventures, LLC, Sets One through Four........... seceesee ee TB 10 Exhibit D: Form Interrogatories Directed to Defendants David M. Bragg and Silicon Valley Real 11 Ventures, LLC, Sets One through Five 100 12 13 Exhibit E: Defendants David M. Bragg and Silicon Valley Real Ventures, LLC’s Responses to 14 Plaintiffs’ Requests for Production, Sets One through Four. 141 15 Exhibit F: Defendants David M. Bragg and Silicon Valley Real Ventures LLC’s Responses to 16 Plaintiffs’ Special Interrogatories, Sets One through Seven. 172 17 18 Exhibit G: Defendants David M. Bragg and Silicon Valley Real Ventures LLC’s Responses to 19 Plaintiffs’ Requests for Admission, Sets One through Four. 210 20 21 Exhibit H: Defendants M. Bragg and Silicon Valley Real Ventures, LLC’s Responses to 22 Plaintiffs’ Form Interrogatories, Sets One through Four 232 23 Exhibit I: Plaintiffs’ Informal Discovery Conference Letters 250 24 25 Exhibit J: Email correspondence between Ryan Van Steenis and Collin Vierra regarding October 26 2022 meet and confer 266 27 28 EXHIBITS TO 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 Page 2 Exhibit K: Email correspondence between Ryan Van Steenis and Collin Vierra regarding ‘Leuthold realsv.com account’ 270 Exhibit L: April 17, 2023, Letter from Ryan Van Steenis to Commissioner regarding Informal Discovery Conference Scheduled for April 20, 2023 273 Exhibit M: May 28,2021 Email from Robert Arntsen to David Bragg and Kurtis Kludt regarding Moore Road Properties 276 Exhibit N: Email correspondence between Ryan Van Steenis, Collin Vierra, and Mark Poe 10 regarding ‘Search Terms’ 278 11 Exhibit O: September 22, 2022, Ryan Van Steenis Letter to Commissioner Halperin regarding 12 September 27, 2022, Informal Discovery Conference Submission for Defendants David M. Bragg 13 and Silicon Valley Real Ventures, LLC 284 14 15 Exhibit P: June 5, 2023, Collin Vierra Letter to Ryan Van Steenis regarding Production of David 16 Bragg’s Emails 288 17 18 Exhibit Q: Email between Collin Vierra and Ryan Van Steenis regarding Discovery Deficiencies 19 of David Bragg and Silicon Valley Real Ventures, LLC 291 20 Exhibit R: Email between Collin Vierra and Ryan Van Steenis regarding September 16, 2022 21 Meet and Confer. 293 22 23 Exhibit S: Email correspondence between Collin Vierra and Ryan Van Steenis regarding March 24 23, 2023 Meet And Confer 301 25 26 27 28 EXHIBITS TO 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 Page 3 Exhibit T: Email correspondence between Collin Vierra and Ryan Van Steenis regarding David Bragg Discovery 304 Exhibit U: April 8, 2022 Letter from Collin Vierra to Defendants providing Notice of Lawsuit 307 Exhibit V: Email correspondence between Collin Vierra, Ryan Van Steenis and Mark Poe regarding Google Drive links 309 Exhibit W: Email correspondence between Collin Vierra, Ryan Van Steenis and Mark Poe 10 regarding document production 314 11 Exhibit X: Email correspondence between Ryan Van Steenis, Collin Vierra and Mark Poe 12 regarding September 16, 2022 Meet and Confer 325 13 14 Exhibit Y: Email correspondence between Ryan Van Steenis, Collin Vierra, Mark Poe and others 15 regarding submission of motion to compel and for sanctions 333 16 Exhibit Z: March 26, 2021 LPS letter to David Bragg regarding Central LAH, LLC........... 337 17 18 Exhibit AA: Orders from IDC Commissioner. 343 19 20 21 Dated: June 12, 2023 22 Collin J. Vierra 23 24 25 26 27 28 EXHIBITS TO 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 Page 4 Exhibit A Exhibit Page 5 Collin J. Vierra (State Bar No. 322720) EIMER STAHL LLP 99 Almaden Blvd., Suite 642 San Jose, CA 95113-1605 Telephone: (408) 889-1668 Email: cvierra@eimerstahl.com Attorney for Plaintiffs SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN MATEO Robert Arntsen; Mary Lee; Arntsen Family Case No. 22-CIV-01148 10 Partnership, LP; and Brian Christopher Dunn Custodianship; Dept. 21 11 12 Plaintiffs, Hon. Robert D. Foiles Vv. 13 PLAINTIFFS’ FIRST SET OF David M. Bragg; Kurtis Stuart Kludt; Silicon REQUESTS FOR PRODUCTION OF 14 Valley Real Ventures LLC; SVRV 385 DOCUMENTS DIRECTED TO Moore, LLC; SVRV 387 Moore, LLC; DEFENDANTS DAVID M. BRAGG AND 15 Gregory J. Davis; Paramont Woodside, LLC; SILICON VALLEY REAL VENTURES 16 and Paramont Capital, LLC; LLC 17 Defendants. 18 19 20 PROPOUNDING PARTIES: PLAINTIFFS 21 RESPONDING PARTIES: DAVID M. BRAGG; 2 SILICON VALLEY REAL VENTURES, LLC 23 SET NUMBER: ONE 24 25 26 27 28 1 PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC Exhibit Page 6 Pursuant to California Code of Civil Procedure §§ 2031.010 et seq., Plaintiffs hereby request that Defendants David M. Bragg and Silicon Valley Real Ventures, LLC identify and produce the documents requested below to the law offices of Eimer Stahl LLP, 99 Almaden Blvd., Ste. 642, San Jose, CA 95113-1605 on or before June 27, 2022. I DEFINITIONS The following Definitions shall apply to the Instructions and to each of the Requests: 1 “Action” refers to the above-captioned action, Case No. 22-CIV-01448, filed in the Superior Court for the State of California, San Mateo County. 2. “All” shall include the term “each,” and vice-versa, as necessary, to bring within the scope of the Request all responses that might otherwise be construed to be outside the scope of the Request. 10 3 “Communication(s)” means the transmittal of information (in the form of facts, 11 ideas, inquiries, or otherwise), or attempt to transmit information, whether written, oral, 12 electronic, or by any other means. 13 4 “Concerning” means relating to, referring to, describing, evidencing, or 14 constituting. 15 5 “Defendants” refers to any of the Defendants named in the above-captioned Action and all of their corporate parents, subsidiaries, attorneys, accountants, officers, directors, 16 employees, partners, agents, or representatives. 17 6. “Document(s)” shall have the broadest meaning possible under California law, 18 including, but not limited to, the Definition of “writing” in California Evidence Code § 250, and 19 includes all originals and drafts, in any and all languages, of any nature whatsoever, in Your 20 (defined below) possession, custody, or control, regardless of where located, and includes, but is 21 not limited to, letters, correspondence, logs, drafts, contracts, prospective contracts, agreements, records, studies, surveys, resolutions, tabulations, notes, summaries, memoranda, electronically 22 stored information (“ESI”), electronic mail (“e-mail”), instant messages, calendar or diary 23 entries, handwritten notes, working papers, worksheets, spreadsheets, diagrams, minutes, 24 agendas, bulletins, periodicals, circulars, advertisements, notices, announcements, invoices, 25 statements, checks (front and back), bank statements, ledgers, orders, vouchers, instructions, 26 drawings, charts, graphs, manuals, brochures, pamphlets, schedules, telegrams, teletypes, 27 photographs, audio tapes, voicemail messages, videotapes, electronic recordings, facsimile 28 2 PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC Exhibit Page 7 transmissions, and information of whatever kind, either stored on computers, including computer disks, hard drives and other media for storage of ESI, or information recorded on any medium, and every other written, typed, recorded, transcribed, filed, or graphic matter, whether sent, received, or neither, and both sides thereof, including non-identical copies and drafts, in the custody, possession, or control of the parties responding to this Request, their agents, accountants, employees representatives, or attorneys, and things similar to any of the foregoing, however denominated by the parties required to produce hereunder. 7 “Identify,” when used in reference to an individual, means that Person’s name, address, telephone number, e-mail address, employer, and job title or position. 8 “Identify,” when used in any context other than as defined in the preceding paragraph, shall mean a description of the subject to be identified and specification of the 10 Documents or Communications in which the subject is or was recorded, described, or referred 11 and all other information necessary to fully identify the subject. 12 9 “Meeting” means the contemporaneous presence, whether in person or through 13 any means of Communication, of any natural Persons, whether or not such presence was by 14 chance or prearranged and whether or not the Meeting was formal, informal, or occurred in connection with some other activity. 15 10. “Person” means any natural person, public or private corporation, whether or not 16 organized for profit, governmental entity, partnership, association, cooperative, joint venture, 17 sole proprietorship, or other legal entity. With respect to a business entity, the term “Person” 18 includes any natural person acting formally or informally as a director, trustee, officer, agent, 19 attorney, or other representative of the business entity. 20 11. “Project” means the project described in the above-captioned Action to purchase, develop, and/or sell the properties located at 385 Moore Road and 387 Moore Road in 21 Woodside, California. 22 12. “Referring” or “Relating to” or “Related to” means all Documents that comprise, 23 explicitly or implicitly refer to, were reviewed in conjunction with, or were created, generated, or 24 maintained as a result of the subject matter of the Request, including, without limitation, all 25 Documents that reflect, record, memorialize, embody, discuss, evaluate, consider, review, or 26 report on the subject matter of the Request. 27 13. “You,” “Your,” and “Yourself” refer to the Defendants to whom the following 28 3 PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC Exhibit Page 8 Requests are addressed and their agents, representatives, officers, directors, accountants, insurance companies, attorneys, investigators, affiliates, predecessors, and successors in interest, parents, divisions, subsidiaries, area and regional offices, and employees, including Persons or entities outside the United States, or anyone acting on Your behalf. 14. The connectives “and” and “or shall be construed either disjunctively or conjunctively, as necessary, to bring within the scope of the Request all responses that might otherwise be construed to be outside of its scope. 15. The use of the singular form of any word includes the plural and vice versa, and the masculine, feminine, or neuter form of any words includes each of the other genders. 16. The use of any tense of any verb shall also include within its meaning all other tenses of that verb. 10 Il. INSTRUCTIONS 11 1 These Requests are continuing and require further and supplemental production 12 by You whenever You acquire or locate additional Documents between the time of these 13 Requests and the final resolution of this Action. 14 2. All Documents shall be produced in the order they are kept in the ordinary course 15 of business and shall be produced in their original folders, binders, covers, or containers or facsimile thereof. 16 3 If a Document was prepared in several copies, or if additional copies were 17 subsequently made, and any such copies were not identical or are no longer identical by reason 18 of subsequent notation or modification of any kind whatsoever, including, without limitation, 19 handwritten notations on the front or back of the Document, all such non-identical copies shall 20 be produced. 21 4 Documents shall be produced in such fashion as to Identify the department, branch, or office in which they were located and, where applicable, the natural Person in whose 22 possession they were found, and the business address of each Document’s custodian(s). 23 5 Documents shall be identified with the specific Request number to which the 24 Documents respond. See Cal. Code Civ. Proc. § 2031.280(a). 25 6 Documents attached to each other should not be separated. 26 7 These Requests relate to all Documents which are in Your possession, custody, or 27 control, or in the possession, custody, or control of Your predecessors, successors, parents, 28 4 PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC Exhibit Page 9 subsidiaries, divisions, or affiliates, or their respective officers, directors, agents, attorneys, accountants, employees, partners, or other Persons occupying similar positions or performing similar functions. 8 The Documents to be produced pursuant to these Requests specifically embrace, in addition to Documents within Your possession, custody, or control, all Documents within the possession, custody, or control of any of Your agents, accountants, representatives, or attorneys. 9 Documents also embrace originals and identical copies (whether different from the original because of notes made thereon or otherwise) of the Documents described in these Requests. 10. The fact that a Document has been or will be produced by another party does not relieve You of the obligation to produce Your copy of the same Document, even if the two 10 Documents are identical in all respects. 11 11. You shall produce the original of each Document described below or, if the 12 original is not in Your custody, then a copy thereof, and in any event, all non-identical copies 13 which differ from the original or from the other copies produced for any reason, including, but 14 not limited to, the making of notes thereon. 12. If any Document falls within the scope of any Request, but is not being produced, 15 or is being produced with portions redacted, pursuant to any claim of privilege or confidentiality, 16 please provide a log containing the following information: 17 (a) the name of the privilege claimed (i.e., attorney-client, attorney work- 18 product, etc.); 19 (b) the name of the Person or entity claiming privilege and the name of the 20 attorney, if any, with respect to whom the privilege is claimed; 21 (c) the facts upon which You rely as the basis for claiming any privilege as to the specific information or Document; 22 (d) the name of such Document; Identify the type of Document (i.e., letter, 23 memo, etc.); set forth the subject matter thereof; Identify the Person who prepared it, and 24 each Person (if any) who signed it; Identify each Person to whom it was directed, 25 circulated, or shown; and Identify each Person now in possession of the Document. If any 26 Document is produced in redacted form, the word “redacted” is to be placed in the 27 redacted section of the Document; and 28 5 PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC Exhibit Page 10 (e) whenever a Document is not produced in full or is produced in redacted form, so indicate on the Document and state with particularity the reason or reasons it is not being produced in full and describe to the best of Your knowledge, information, and belief, and with as much particularity as possible, those portions of the Document which are not being produced. 13. In the event that any Document called for by these Requests has been destroyed or discarded, that Document is to be identified by stating: (a) the nature of the Document; (b) the names of any addressor or addressee; (c) if there are any indicated or blind copies; (d) the Document’s date, subject matter, number of pages, and attachments or 10 appendices; 11 (e) all Persons to whom the Document was distributed, shown, or explained; 12 (f) its date of destruction or discard and manner of destruction or discard; and 13 (g) the Persons authorizing and/or carrying out such destruction or discard. 14 14. With respect to any Documents which You contend would be in some way “burdensome” “oppressive” to produce, please state the specific reasons for that objection. 15 15. If You object to part of any Request, please furnish Documents responsive to the 16 remainder of the Request. 17 16. Each Request refers to all Documents that are either known by Defendants to 18 exist or that can be located or discovered by reasonably diligent efforts of Defendants. 19 17. The Documents produced in response to these Requests shall include all 20 attachments and enclosures. 18. All electronic Documents shall be produced in such fashion as to identify the 21 location, i.e., the network file folder, hard drive, back-up tape, or other location, where the 2 Documents are stored and, where applicable, the natural Person in whose possession they were 2. found and the business address of each Document’s custodian(s). 24 Il. RELEVANT PERIOD 25 Unless otherwise noted, all Requests herein refer to the time period of January 1, 2017 26 through the date of production, inclusive, and shall include all Documents that relate, in whole or 27 in part, to such period even though dated, prepared, or received prior or subsequent to that 28 6 PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC Exhibit Page 11 period. If a Document prepared prior or subsequent to the Relevant Period is necessary for a correct or complete understanding of any Document covered by a Request, You must produce the prior or subsequent Document as well. If any Document is undated and the date of its preparation cannot be determined, the Document shall be produced if otherwise responsive to the Request. IV. REQUESTS FOR PRODUCTION REQUEST NO. 1: All Communications between You and (1) the Plaintiffs and (2) anyone affiliated with Silicon Valley Real Ventures, LLC relating to Plaintiffs’ investments with Silicon Valley Real Ventures, LLC between January 1, 2012 and the present. REQUEST NO. 2: 10 All Communications relating to the Project between You and any third parties involved 11 with the Project, including but not limited to real estate agents, realtors, brokers, loan officers, 12 lending agents, engineers, architects, landscape architects, inspection officers or agencies, and 13 permitting officials or agencies. 14 REQUEST NO. 3: 15 All Communications with any members of the Geyer family relating to the Project. REQUEST NO. 4: 16 All Communications related to the sale or transfer of the Moore Road properties to 17 Silicon Valley Real Ventures, LLC, including all Communications with the sellers of the Moore 18 Road properties and their agents. 19 REQUEST NO. 5: 20 All financial, accounting, and governance Documents relating to Plaintiffs’ investments 21 with Silicon Valley Real Ventures, LLC between January 1, 2012 and the present, including but not limited to bills, checks, receipts, certificates, ownership tables, projections, analyses, account 22 statements, tax records, balance sheets, income statements, cash flow statements, profit or loss 23 statements, investment agreements, operating agreements, and subscription agreements. 24 REQUEST NO. 6: 25 All financial, accounting, and governance Documents relating to the Project., including 26 but not limited to bills, checks, receipts, certificates, ownership tables, projections, analyses, 27 account statements, tax records, balance sheets, income statements, cash flow statements, profit 7 28 PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC Exhibit Page 12 or loss statements, investment agreements, operating agreements, and subscription agreements. REQUEST NO. 7: All Communications with, Documents provided to, and Documents received from, Gregory J. Davis, Paramont Capital, LLC, and/or Paramont Woodside, LLC. REQUEST NO. 8: All Communications with, Documents provided to, and Documents received from, Kurtis S. Kludt relating to Plaintiffs’ investments with Silicon Valley Real Ventures, LLC, including the Project, between January 1, 2012 and the present. REQUEST NO. 9: All Documents relating to any loans that Plaintiffs extended to Silicon Valley Real Ventures, LLC, including Documents reflecting the conditions on which the loans were extended 10 and how the loan proceeds were used. 11 REQUEST NO. 10: 12 Documents sufficient to show all Your joint or individual accounts, securities, financial 13 assets, real assets, personal assets, or any other assets, including but not limited to savings 14 accounts, checking accounts, retirement accounts, investment accounts, vehicles, real estate, and land, worth $10,000 or more. 15 REQUEST NO. 11: 16 All Documents related to the sale of the Moore Road Properties, including Documents 17 sufficient to show any agreements with real estate brokers involved in the transaction. 18 19 20 Dated: May 27, 2022 py CA UH 21 Collin J. Vierra EIMER STAHL, LLP 22 Attorney for Plaintiffs Robert Arntsen, 23 Mary Lee, the Arntsen Family Partnership, LP, and the Brian 24 Christopher Dunn Custodianship 25 26 27 28 8 PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC Exhibit Page 13 CollinJ. Vierra (State Bar No. 322720) EIMER STAHL LLP 99 Almaden Blvd., Suite 642 San Jose, CA 95113-1605 Telephone: (408) 889-1668 Email: cvierra@ eimerstahl.com Attorney for Plaintiffs SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN MATEO Robert Amtsen; Mary Lee; Arntsen Family Case No. 22-CIV-01148 10 Partnership, LP; and Brian Christopher Dunn Custodianship; Dept. 21 11 12 Plaintiffs, Hon. Robert D. Foiles Vv. 13 PLAINTIFFS’ SECOND SET OF David M. Bragg; Kurtis Stuart K]udt; Silicon REQUESTS FOR PRODUCTION OF 14 Valley Real Ventures LLC; SVRV 385 DOCUMENTS DIRECTEDTO Moore, LLC; SVRV 387 Moore, LLC; DEFENDANTS DAVIDM. BRAGG AND 15 Gregory J. Davis; Paramont Woodside, LLC; SILICON VALLEY REAL VENTURES 16 and Paramont Capital, LLC; LLC 17 Defendants. 18 19 20 PROPOUNDING PARTIES: PLAINTIFFS 21 RESPONDING PARTIES: DAVID M. BRAGG; SILICON VALLEY REAL VENTURES, LLC 23 SET NUMBER: TWO 24 25 26 27 28 1 PLAINTIFFS’ SECOND SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC Exhibit Page 14 Pursuantto Califomia Code of Civil Procedure §§ 2031.010 et seq., Plaintiffs hereby request that Defendants David M. Bragg and Silicon Valley Real Ventures, LLC identify and produce the documents requested below to the law offices of Eimer Stahl LLP, 99 Almaden Blvd., Ste. 642, San Jose, CA 95113-1605 on or before August5, 2022. I DEFINITIONS The following Definitions shall apply to the Instructions and to each of the Requests: 1 “Action” refers to the above-captioned action, Case No. 22-CIV-01448, filed in the Superior Court for the State of Califomia, San Mateo County. 2 “All” shall include the term “each,” and vice-versa, as necessary, to bring within the scope of the Request all responses that might otherwise be construed to be outside the scope of the Request. 10 3 “Communication(s)” means the transmittal of information (in the form of facts, 11 ideas, inquiries, or otherwise), or attempt to transmit information, whether written, oral, 12 electronic, or by any other means. 13 4 “Concerning” means relating to, referring to, describing, evidencing, or 14 constituting. 15 5. “Defendants” refers to any of the Defendants named in the above-captioned Action and all of their corporate parents, subsidiaries, attorneys, accountants, officers, directors, 16 employees, partners, agents, or representatives. 17 6 “Document(s)” shall have the broadest meaning possible under California law, 18 including, but not limited to, the Definition of “writing” in California Evidence Code § 250, and 19 includes all originals and drafts, in any and all languages, of any nature whatsoever, in Y our 20 (defined below) possession, custody, or control, regardless of where located, and includes, but is 21 not limited to, letters, correspondence, logs, drafts, contracts, prospective contracts, agreements, records, studies, surveys, resolutions, tabulations, notes, summaries, memoranda, electronically 22 stored information (“ESI”), electronic mail (“e-mail”), instant messages, calendar or diary 23 entries, handwritten notes, working papers, worksheets, spreadsheets, diagrams, minutes, 24 agendas, bulletins, periodicals, circulars, advertisements, notices, announcements, invoices, 25 statements, checks (front and back), bank statements, ledgers, orders, vouchers, instructions, 26 drawings, charts, graphs, manuals, brochures, pamphlets, schedules, telegrams, teletypes, 27 photographs, audio tapes, voicemail messages, videotapes, electronic recordings, facsimile 28 2 PLAINTIFFS’ SECOND SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC Exhibit Page 15 transmissions, and information of whatever kind, either stored on computers, including computer disks, hard drives and other media for storage of ESI, or information recorded on any medium, and every other written, typed, recorded, transcribed, filed, or graphic matter, whether sent, received, or neither, and both sides thereof, including non-identical copies and drafts, in the custody, possession, or control of the parties responding to this Request, their agents, accountants, employees representatives, or attorneys, and things similar to any of the foregoing, however denominated by the parties required to produce hereunder. 7 “Identify,” when used in reference to an individual, means that Person’s name, address, telephone number, e-mail address, employer, and job title or position. 8 “Identify,” when used in any context other than as defined in the preceding paragraph, shall mean a description of the subject to be identified and specification of the 10 Documents or Communications in which the subject is or was recorded, described, or referred 11 and all other information necessary to fully identify the subject. 12 9 “Meeting” means the contemporaneous presence, whether in person or through 13 any means of Communication, of any natural Persons, whether or not such presence was by 14 chance or prearranged and whether or not the Meeting was formal, informal, or occurred in connection with some other activity. 15 10. “Person” means any natural person, public or private corporation, whether or not 16 organized for profit, governmental entity, partnership, association, cooperative, joint venture, 17 sole proprietorship, or other legal entity. With respect to a business entity, the term “Person” 18 includes any natural person acting formally or informally as a director, trustee, officer, agent, 19 attoney, or other representative of the business entity. 20 11. “Project” means the project described in the above-captioned A ction to purchase, 21 develop, and/or sell the properties located at 385 Moore Road and 387 Moore Road in Woodside, Califomia. 22 12. “Referring” or “Relating to” or “Related to” means all Documents that comprise, 23 explicitly or implicitly refer to, were reviewed in conjunction with, or were created, generated, or 24 maintained as a result of the subject matter of the Request, including, without limitation, all 25 Documents that reflect, record, memorialize, embody, discuss, evaluate, consider, review, or 26 report on the subject matter of the Request. 27 13. “You,” “Your,” and “Yourself” refer to the Defendants to whom the following 28 3 PLAINTIFFS’ SECOND SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC Exhibit Page 16 Requests are addressed and their agents, representatives, officers, directors, accountants, insurance companies, attomeys, investigators, affiliates, predecessors, and successors in interest, parents, divisions, subsidiaries, area and regional offices, and employees, including Persons or entities outside the United States, or anyone acting on Y our behalf. 14, The connectives “and” and ee? “or” shall be construed either disjunctively or conjunctively, as necessary, to bring within the scope of the Request all responses that might otherwise be construed to be outside of its scope. 15. The use of the singular form of any word includes the plural and vice versa, and the masculine, feminine, or neuter form of any words includes each of the other genders. 16. The use of any tense of any verb shall also include within its meaning all other tenses of that verb. 10 I. INSTRUCTIONS 11 1 These Requests are continuing and require further and supplemental production 12 by Y ou wheneverY ou acquire or locate additional Documents between the time of these 13 Requests and the final resolution of this Action. 14 2 All Documents shall be produced in the order they are kept in the ordinary course 15 of business and shall be produced in their original folders, binders, covers, or containers or facsimile thereof. 16 3 If a Document was prepared in several copies, or if additional copies were 17 subsequently made, and any such copies were not identical or are no longer identical by reason 18 of subsequent notation or modification of any kind whatsoever, including, without limitation, 19 handwritten notations on the front or back of the Document, all such non-identical copies shall 20 be produced. 21 4 Documents shall be produced in such fashion as to Identify the department, branch, or office in which they were located and, where applicable, the natural Person in whose 22 possession they were found, and the business address of each Document’s custodian(s). 23 5. Documents shall be identified with the specific Request number to which the 24 Documents respond. See Cal. Code Civ. Proc. § 2031.280(a). 25 6 Documents attached to each other should not be separated. 26 7 These Requests relate to all Documents which are in Y our possession, custody, or 27 control, or in the possession, custody, or control of Y our predecessors, successors, parents, 28 4 PLAINTIFFS’ SECOND SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC Exhibit Page 17 subsidiaries, divisions, or affiliates, or their respective officers, directors, agents, attorneys, accountants, employees, partners, or other Persons occupying similar positions or performing similar functions. 8 The Documents to be produced pursuant to these Requests specifically embrace, in addition to Documents within Y our possession, custody, or control, all Documents within the possession, custody, or control of any of Y our agents, accountants, representatives, or attorneys. 9 Documents also embrace originals and identical copies (whether different from the original because of notes made thereon or otherwise) of the Documents described in these Requests. 10. The fact that a Document has been or will be produced by another party does not relieve Y ou of the obligation to produce Y our copy of the same Document, even if the two 10 Documents are identical in all respects. 11 11. Y ou shall produce the original of each Document described below or, if the 12 original is not in Y our custody, then a copy thereof, and in any event, all non-identical copies 13 which differ from the original or from the other copies produced for any reason, including, but 14 not limited to, the making of notes thereon. 12. If any Document falls within the scope of any Request, but is not being produced, 15 or is being produced with portions redacted, pursuant to any claim of privilege or confidentiality, 16 please provide a log containing the following information: 17 (a) the name of the privilege claimed (i.e., attorney-client, attomey work- 18 product, etc.); 19 (b) the name of the Person or entity claiming privilege and the name of the 20 attomey, if any, with respect to whom the privilege is claimed; 21 (c) the facts upon which Y ou rely as the basis for claiming any privilege as to the specific information or Document; 22 (d) the name of such Document; Identify the type of Document (i.e., letter, 23 memo, etc.); set forth the subject matter thereof; Identify the Person who prepared it, and 24 each Person (if any) who signed it; Identify each Person to whom it was directed, 25 circulated, or shown; and Identify each Person now in possession of the Document. If any 26 Document is produced in redacted form, the word “redacted” is to be placed in the 27 redacted section of the Document; and 28 5 PLAINTIFFS’ SECOND SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC Exhibit Page 18 (e) whenever a Document is not produced in full or is produced in redacted form, so indicate on the Document and state with particularity the reason or reasons it is not being produced in full and describe to the best of Y our knowledge, information, and belief, and with as much particularity as possible, those portions of the Document which are not being produced. 13. In the event that any Document called for by these Requests has been destroyed or discarded, that Document is to be identified by stating: (a) the nature of the Document; (b) the names of any addressor or addressee; (c) if there are any indicated or blind copies; (d) the Document’s date, subject matter, number of pages, and attachments or 10 appendices; 11 (e) all Persons to whom the Document was distributed, shown, or explained; 12 (f) its date of destruction or discard and manner of destruction or discard; and 13 (g) the Persons authorizing and/or carrying out such destruction or discard. 14 14, With respect to any Documents which Y ou contend would be in some way “burdensome” or “oppressive” to produce, please state the specific reasons for that objection. 15 15. If Y ou object to part of any Request, please furnish Documents responsive to the 16 remainder of the Request. 17 16. Each Request refers to all Documents that are either known by Defendants to 18 exist or that can be located or discovered by reasonably diligent efforts of Defendants. 19 17. The Documents produced in response to these Requests shall include all 20 attachments and enclosures. 21 18. All electronic Documents shall be produced in such fashion as to identify the location, i.e., the network file folder, hard drive, back-up tape, or other location, where the 22 Documents are stored and, where applicable, the natural Person in whose possession they were 23 found and the business address of each Document’s custodian(s). 24 I. RELEVANT PERIOD 25 Unless otherwise noted, all Requests herein refer to the time period of January 1, 2017 26 through the date of production, inclusive, and shall include all Documents that relate, in whole or 27 in part, to such period even though dated, prepared, or received prior or subsequent to that 28 6 PLAINTIFFS’ SECOND SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC Exhibit Page 19 period. If a Document prepared prior or subsequent to the Relevant Period is necessary for a correct or complete understanding of any Document covered by a Request, Y ou must produce the prior or subsequent Document as well. If any Document is undated and the date of its preparation cannot be determined, the Document shall be produced if otherwise responsive to the Request. IV. REQUESTS FOR PRODUCTION REQUEST NO. 12: On an ongoing basis, all non-privileged Communications between Y ou and any other Defendant in this A ction relating to this litigation or any aspect thereof, including without limitation service, procedure, discovery, evidence, strategy, trial, damages, or judgment. REQUEST NO. 13: 10 All Documents stored in or accessible through the Google Workspace (formerly known 11 as G Suite) or Google Drive accounts of woodsidemoore385@ gmail.com, 12 woodsidemoore387@ gmail.com, d@realsv.com, or any other account through which Y ou 13 conducted SV RV -related business. 14 15 16 Dated: July 6, 2022 py CLA UE 17 CollinJ. Vierra 18 EIMER STAHL, LLP 19 Attorney for Plaintiffs Robert Arntsen, 20 Mary Lee, the Arntsen Family Partnership, LP, and the Brian 21 Christopher Dunn Custodianship 22 23 24 25 26 27 28 7 PLAINTIFFS’ SECOND SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO DEFENDANTS DAVID M. BRAGG AND SILICON VALLEY REAL VENTURES LLC Exhibit Page 20 CollinJ. Vierra (State Bar No. 322720) EIMER STAHL LLP 99 Almaden Blvd., Suite 642 San Jose, CA 95113-1605 Telephone: (408) 889-1668 Email: cvierra@ eimerstahl.com Attorney for Plaintiffs SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN MATEO Robert Amtsen; Mary Lee; Arntsen Family Case No. 22-CIV-01148 10 Partnership, LP; and Brian Christopher Dunn Custodianship; Dept. 21 11 12 Plaintiffs, Hon. Robert D. Foiles Vv. 13 PLAINTIFFS’ THIRD SET OF David M. Bragg; Kurtis Stuart K]udt; Silicon REQUESTS FOR PRODUCTION OF 14 Valley Real Ventures LLC; SVRV 385 DOCUMENTS DIRECTEDTO Moore, LLC; SVRV 387 Moore, LLC; DEFENDANTS DAVIDM. BRAGG AND 15 Gregory J. Davis; Paramont Woodside, LLC; SILICON VALLEY REAL VENTURES 16 and Paramont Capital, LLC; LLC 17 Defendants. 18 19 20 PROPOUNDING PARTIES: PLAINTIFFS 21 RESPONDING PARTIES: DAVID M. BRAGG;