On October 09, 2019 a
Party Discovery
was filed
involving a dispute between
Mcdow, Michael,
Tammi Saucer,
Tammi Saucer And Michael Mcdow, Husband And Wife,
and
Acclivity West, Llc,
American Alternative Investments, Llc,
Doe 11-50,
Does 12- 50,
Does 5, 11-50, Inclusive,
Fwi Alternative Marketing, Llc,
Gradient Financial Group, Llc,
Hbc Pacific,
Minnesota Life Insurance Company, Inc,
National Western Life Insurance Company,
Ponder, Jr, Craig,
Ponder, Matthew C.,
Ponder, Sr., Craig A.,
The Financial Wealth Coach, Inc.,
Vertical Capital Llc,
for Fraud
in the District Court of San Bernardino County.
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Melinda Jane Steuer
The Law Offices 0f Melinda Jane Steuer
1107 Second Street, Suite 230 l. a L aD
_
Sacramento, CA 95814 SbPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
Telephone: (916) 930-0045 SAN WiRNARL‘INQ [NSTRICT
Facsimile: (916) 314-4100
Email: msteuer@califomiainvestoradvocatacom OCT 27 2022
\DOONQUI$UJNh—‘
Attorney for Plaintiffs
av%.m__ ANTHONY? -RTIN‘SIZ. EFUTY
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN BERNARDINO
TAMMI SAUCER and MICHAEL MCDOW Case N0.: CIVDSl930403
husband and wife, G‘a—W’H
Plaintiffs, Assigned For All Purposes T0 Hon. Gilbert
V. Ochoa
CRAIG A. PONDER, SR., individually and NOTICE OF MOTION TO COMPEL
d/b/a PONDER FINANCIAL &
FURTHER RESPONSES TO FORM
RETIREMENT FIRM, INC.; and DOES 1-50, INTERROGATORIES, SET ONE AND TO
SPECIAL INTERROGATORIES, SET
inclusive,
ONE FROM DEFENDANTS AND FOR
NNNNNNNNNb—Ir—IWHHb—Ar—nr—Hb—I
SANCTIONS
Defendants.
WNQm-PWNHOCWNQL’I-PUJNHO
Date: January 3, 2023
Time: 8:30 am.
Dept: $24
Judge: Hon. Gilbert Ochoa
Complaint Filed: October 19, 2019
Trial Set For: February 5, 2022
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
NOTICE IS HEREBY GIVEN that 0n the date, at the time, and in the department set
forth above, Plaintiffs will move this honorable court for an order compelling further responses
t0 their First Set 0f Form Interrogatories and First Set of Special Interrogatories from Defendants
Craig A. Ponder, Sr. and d/b/a Ponder Financial & Retirement Firm, Inc.
OOWNQUIhMNH
Pursuant to Code 0f Civil Procedure § 2023.040, notice is further given that Plaintiffs
seek monetary sanctions from Defendants Craig A. Ponder, Sr., and d/b/a Ponder Financial &
Retirement Firm, Inc. jointly and severally, pursuant to C.C.P. §§ 2023.010, 2023.030(a),
2030.300(d), and California Rules of Court, Rule 3.1348(a).
This motion will be based on this Notice, the Memorandum of Points and Authorities
filed herewith, the Separate Statement filed herewith, the Declaration 0f Melinda Jane Steuer
filed herewith, the pleadings and records on file hereon, and such other and further oral and
documentary evidence as may be presented at, or prior to, the hearing of this motion.
Pursuant to Local Rule 561: TENTATIVE RULINGS (a) A judicial officer may provide
tentative rulings. A tentative ruling on a law and motion matter may be obtained by accessing the
court’s website at htt s://sb ~court.or0 after 3:00 p.m. on the court day before the hearing, 0r by
telephoning the court’s Administrative Assistants at the numbers below. (b) Any party who
wishes to orally argue the motion may appear on the date and time set for hearing, pursuant to
NNNNNNNNN—‘t—Iv—t—t—I—H—-—
California Rules of Court, Rule 3.1308 (a) (2) and Rule 3.1306. Failure t0 appear shall be
OOVOUI-PUJNflowooflO‘xUI-PMNH
deemed a waiver 0f oral argument. All posted tentative rulings shall become the final ruling 0f
Superior Court 0f California, County of San Bemardino 17 the Court 0n the scheduled hearing
date if no party appears. Should a hearing be held the Court may, in its discretion, modify or
affirm the tentative ruling and advise the parties of its ruling at the hearing or by further Order.
(c) If the parties wish t0 submit on the tentative ruling, no appearance will be necessary if the
department’s judicial assistant is notified by 4:00 p.m. the day before the hearing. The tentative
will then become the final ruling. (d) The Court will not entertain a request for continuance
unless stipulated t0 by all parties and no further papers may be filed once the tentative ruling has
been posted. (e) The party prevailing on the motion shall serve all parties with written notice of
Notice of Motion to Compel Further Responses To Form Interrogatories, Set One and Special Interrogatories, Set
One From Defendants And For Sanctions
2
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'*\ n \ ‘1 ©va _, 1 ‘1‘ ENM‘KL Melinda Jane Steuer The Law Offices 0f Melinda Jane Steuer 1107 Second Street, Suite 230 l. a L aD _ Sacramento, CA 95814 SbPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO Telephone: (916) 930-0045 SAN WiRNARL‘INQ [NSTRICT Facsimile: (916) 314-4100 Email: msteuer@califomiainvestoradvocatacom OCT 27 2022 \DOONQUI$UJNh—‘ Attorney for Plaintiffs av%.m__ ANTHONY? -RTIN‘SIZ. EFUTY IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN BERNARDINO TAMMI SAUCER and MICHAEL MCDOW Case N0.: CIVDSl930403 husband and wife, G‘a—W’H Plaintiffs, Assigned For All Purposes T0 Hon. Gilbert V. Ochoa CRAIG A. PONDER, SR., individually and NOTICE OF MOTION TO COMPEL d/b/a PONDER FINANCIAL & FURTHER RESPONSES TO FORM RETIREMENT FIRM, INC.; and DOES 1-50, INTERROGATORIES, SET ONE AND TO SPECIAL INTERROGATORIES, SET inclusive, ONE FROM DEFENDANTS AND FOR NNNNNNNNNb—Ir—IWHHb—Ar—nr—Hb—I SANCTIONS Defendants. WNQm-PWNHOCWNQL’I-PUJNHO Date: January 3, 2023 Time: 8:30 am. Dept: $24 Judge: Hon. Gilbert Ochoa Complaint Filed: October 19, 2019 Trial Set For: February 5, 2022 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: NOTICE IS HEREBY GIVEN that 0n the date, at the time, and in the department set forth above, Plaintiffs will move this honorable court for an order compelling further responses t0 their First Set 0f Form Interrogatories and First Set of Special Interrogatories from Defendants Craig A. Ponder, Sr. and d/b/a Ponder Financial & Retirement Firm, Inc. OOWNQUIhMNH Pursuant to Code 0f Civil Procedure § 2023.040, notice is further given that Plaintiffs seek monetary sanctions from Defendants Craig A. Ponder, Sr., and d/b/a Ponder Financial & Retirement Firm, Inc. jointly and severally, pursuant to C.C.P. §§ 2023.010, 2023.030(a), 2030.300(d), and California Rules of Court, Rule 3.1348(a). This motion will be based on this Notice, the Memorandum of Points and Authorities filed herewith, the Separate Statement filed herewith, the Declaration 0f Melinda Jane Steuer filed herewith, the pleadings and records on file hereon, and such other and further oral and documentary evidence as may be presented at, or prior to, the hearing of this motion. Pursuant to Local Rule 561: TENTATIVE RULINGS (a) A judicial officer may provide tentative rulings. A tentative ruling on a law and motion matter may be obtained by accessing the court’s website at htt s://sb ~court.or0 after 3:00 p.m. on the court day before the hearing, 0r by telephoning the court’s Administrative Assistants at the numbers below. (b) Any party who wishes to orally argue the motion may appear on the date and time set for hearing, pursuant to NNNNNNNNN—‘t—Iv—t—t—I—H—-— California Rules of Court, Rule 3.1308 (a) (2) and Rule 3.1306. Failure t0 appear shall be OOVOUI-PUJNflowooflO‘xUI-PMNH deemed a waiver 0f oral argument. All posted tentative rulings shall become the final ruling 0f Superior Court 0f California, County of San Bemardino 17 the Court 0n the scheduled hearing date if no party appears. Should a hearing be held the Court may, in its discretion, modify or affirm the tentative ruling and advise the parties of its ruling at the hearing or by further Order. (c) If the parties wish t0 submit on the tentative ruling, no appearance will be necessary if the department’s judicial assistant is notified by 4:00 p.m. the day before the hearing. The tentative will then become the final ruling. (d) The Court will not entertain a request for continuance unless stipulated t0 by all parties and no further papers may be filed once the tentative ruling has been posted. (e) The party prevailing on the motion shall serve all parties with written notice of Notice of Motion to Compel Further Responses To Form Interrogatories, Set One and Special Interrogatories, Set One From Defendants And For Sanctions 2