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1 John S. Rueppel (SBN: 267467)
Angie Lam (SBN: 244719)
2 JOHNSTON, KINNEY & ZULAICA LLP
101 Montgomery Street, Suite 1600
3 San Francisco, California 94104
4 Telephone: (415) 693-0550
Facsimile: (415) 693-0500
5 Email: john@jkzllp.com
angie.lam@jkzllp.com
6 Attorneys for Plaintiff,
Lisa Keith
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 IN THE COUNTY OF NAPA
10
LISA KEITH, CASE NO: 22CV001269
11
Plaintiff, [PROPOSED] ORDER GRANTING
12 PLAINTIFF, LISA KEITH’S NOTICE OF
13 v. MOTION AND MOTION TO COMPEL
DEPOSITION OF PERSON MOST
14 CELESTE WHITE, an individual, ROBERT KNOWLEDGEABLE; FURTHER
WHITE, an individual, the VALLEY ROCK RESPONSES; AND PRODUCTION OF
15 FOUNDATION, aka THE BAR 49 DOCUMENTS FROM PLATINUM
FOUNDATION, a charitable organization, and ADVISORS, LLC AND KENWOOD
16 DOES 1-50, INCLUSIVE, INVESTMENTS, LLC AND FOR
17 MONETARY SANCTIONS
Defendants.
18
Date: March 19, 2024
19 Time: 8:30 a.m.
Judge: Hon. Scott R.L. Young
20 Dept.: B
21 Complaint Filed: October 25, 2022
FAC Filed: March 8, 2023
22 Trial Date: April 2, 2024
23
[PROPOSED] ORDER
24
Plaintiff Lisa Keith’s (“Plaintiff”) Notice of Motion and Motion to Deposition of Person Most
25
Knowledgeable; Further Responses; and Production of Documents from Platinum Advisors, LLC and
26
Kenwood Investments, LLC and Monetary Sanctions (“Motion”) came on fore hearing before
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1
[PROPOSED] ORDER GRANTING MOTION TO COMPEL FURTHER RESPONSE
1 Honorable Scott R.L. Young on March 19, 2024, in Department B of the Superior Court of the County
2 of Napa.
3 Having considered the Motion, supporting papers and arguments of counsel, and with good
4 cause appearing, the Court GRANTS Plaintiff’s Motion and HEREBY ORDERS THAT:
5 1. Platinum Advisors LLC shall produce the person most knowledgeable for deposition
6 responsive to the Plaintiff’s Deposition Subpoena for Personal Appearance and Production of
7 Documents and Things on or before _____________________________.
8 2. Platinum Advisors LLC shall serve further responses to Plaintiff’s Deposition Subpoena for
9 Personal Appearance and Production of Documents and Things on or before
10 _____________________________.
11 3. Platinum Advisors LLC shall pay monetary sanctions to Plaintiff in the amount of
12 $________________ on or before _____________________.
13 4. Kenwood Investments LLC shall produce the person most knowledgeable for deposition
14 responsive to the Plaintiff’s Deposition Subpoena for Personal Appearance and Production of
15 Documents and Things on or before _____________________________.
16 5. Kenwood Investments LLC shall serve further responses to Plaintiff’s Deposition Subpoena for
17 Personal Appearance and Production of Documents and Things on or before
18 6. Kenwood Investments LLC shall pay monetary sanctions to Plaintiff in the amount of
19 $________________ on or before _____________________.
20
21 IT IS SO ORDERED.
22
23
24 Dated: March 19, 2024 By:
JUDGE OF THE SUPERIOR COURT
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[PROPOSED] ORDER GRANTING MOTION TO COMPEL FURTHER RESPONSE
1 PROOF OF SERVICE
2
STATE OF CALIFORNIA, CITY OF ANTIOCH AND COUNTY OF CONTRA COSTA
3
I am employed in the City and County of San Francisco, State of California. I am over the age of
4 18 years and not a party to the within action; my business address is Johnston Kinney & Zulaica LLP,
101 Montgomery Street, Suite 1600, San Francisco, California 94104. My electronic business address is
5 carolina@jkzllp.com.
6
On March 8, 2024, I served the foregoing document(s):
7
[PROPOSED] ORDER GRANTING PLAINTIFF, LISA KEITH’S NOTICE OF
8 MOTION AND MOTION TO COMPEL DEPOSITION OF PERSON MOST
KNOWLEDGEABLE; FURTHER RESPONSES; AND PRODUCTION OF
9 DOCUMENTS FROM PLATINUM ADVISORS, LLC AND KENWOOD
INVESTMENTS, LLC AND FOR MONETARY SANCTIONS
10
11 I served the documents on the person or persons listed below as follows:
12 Jeffrey E. Tsai
Kathleen S. Kizer
13 DLA PIPER LLP (US)
555 Mission Street, Suite 2400
14 San Francisco, CA 94105
Jeff.tsai@us.dlapiper.com
15 Katy.kizer@us.dlapiper.com
Attorneys for Defendants
16
SINGER ASSOCIATES, INC.
17
c/o Sharon Rollins Singer
18 33 Roble Road, Berkeley, CA 94705
19
[X] (BY EMAIL) Pursuant to Code of Civil Procedure section 1010.6, I caused the document(s) to
20 be electronically transmitted by me to the persons listed in the above email address(es). I did not receive
within a reasonable time after the transmission, any electronic message or other indication that the
21
transmission was unsuccessful.
22
I declare under penalty of perjury under the laws of the State of California that the foregoing is
23 true and correct.
24
Executed on March 8, 2024, at Antioch, California.
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27 Carolina Ramos
4861-9495-8764, v. 2
28
3
[PROPOSED] ORDER GRANTING MOTION TO COMPEL FURTHER RESPONSE
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1 John S. Rueppel (SBN: 267467) Angie Lam (SBN: 244719) 2 JOHNSTON, KINNEY & ZULAICA LLP 101 Montgomery Street, Suite 1600 3 San Francisco, California 94104 4 Telephone: (415) 693-0550 Facsimile: (415) 693-0500 5 Email: john@jkzllp.com angie.lam@jkzllp.com 6 Attorneys for Plaintiff, Lisa Keith 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN THE COUNTY OF NAPA 10 LISA KEITH, CASE NO: 22CV001269 11 Plaintiff, [PROPOSED] ORDER GRANTING 12 PLAINTIFF, LISA KEITH’S NOTICE OF 13 v. MOTION AND MOTION TO COMPEL DEPOSITION OF PERSON MOST 14 CELESTE WHITE, an individual, ROBERT KNOWLEDGEABLE; FURTHER WHITE, an individual, the VALLEY ROCK RESPONSES; AND PRODUCTION OF 15 FOUNDATION, aka THE BAR 49 DOCUMENTS FROM PLATINUM FOUNDATION, a charitable organization, and ADVISORS, LLC AND KENWOOD 16 DOES 1-50, INCLUSIVE, INVESTMENTS, LLC AND FOR 17 MONETARY SANCTIONS Defendants. 18 Date: March 19, 2024 19 Time: 8:30 a.m. Judge: Hon. Scott R.L. Young 20 Dept.: B 21 Complaint Filed: October 25, 2022 FAC Filed: March 8, 2023 22 Trial Date: April 2, 2024 23 [PROPOSED] ORDER 24 Plaintiff Lisa Keith’s (“Plaintiff”) Notice of Motion and Motion to Deposition of Person Most 25 Knowledgeable; Further Responses; and Production of Documents from Platinum Advisors, LLC and 26 Kenwood Investments, LLC and Monetary Sanctions (“Motion”) came on fore hearing before 27 28 1 [PROPOSED] ORDER GRANTING MOTION TO COMPEL FURTHER RESPONSE 1 Honorable Scott R.L. Young on March 19, 2024, in Department B of the Superior Court of the County 2 of Napa. 3 Having considered the Motion, supporting papers and arguments of counsel, and with good 4 cause appearing, the Court GRANTS Plaintiff’s Motion and HEREBY ORDERS THAT: 5 1. Platinum Advisors LLC shall produce the person most knowledgeable for deposition 6 responsive to the Plaintiff’s Deposition Subpoena for Personal Appearance and Production of 7 Documents and Things on or before _____________________________. 8 2. Platinum Advisors LLC shall serve further responses to Plaintiff’s Deposition Subpoena for 9 Personal Appearance and Production of Documents and Things on or before 10 _____________________________. 11 3. Platinum Advisors LLC shall pay monetary sanctions to Plaintiff in the amount of 12 $________________ on or before _____________________. 13 4. Kenwood Investments LLC shall produce the person most knowledgeable for deposition 14 responsive to the Plaintiff’s Deposition Subpoena for Personal Appearance and Production of 15 Documents and Things on or before _____________________________. 16 5. Kenwood Investments LLC shall serve further responses to Plaintiff’s Deposition Subpoena for 17 Personal Appearance and Production of Documents and Things on or before 18 6. Kenwood Investments LLC shall pay monetary sanctions to Plaintiff in the amount of 19 $________________ on or before _____________________. 20 21 IT IS SO ORDERED. 22 23 24 Dated: March 19, 2024 By: JUDGE OF THE SUPERIOR COURT 25 26 27 28 2 [PROPOSED] ORDER GRANTING MOTION TO COMPEL FURTHER RESPONSE 1 PROOF OF SERVICE 2 STATE OF CALIFORNIA, CITY OF ANTIOCH AND COUNTY OF CONTRA COSTA 3 I am employed in the City and County of San Francisco, State of California. I am over the age of 4 18 years and not a party to the within action; my business address is Johnston Kinney & Zulaica LLP, 101 Montgomery Street, Suite 1600, San Francisco, California 94104. My electronic business address is 5 carolina@jkzllp.com. 6 On March 8, 2024, I served the foregoing document(s): 7 [PROPOSED] ORDER GRANTING PLAINTIFF, LISA KEITH’S NOTICE OF 8 MOTION AND MOTION TO COMPEL DEPOSITION OF PERSON MOST KNOWLEDGEABLE; FURTHER RESPONSES; AND PRODUCTION OF 9 DOCUMENTS FROM PLATINUM ADVISORS, LLC AND KENWOOD INVESTMENTS, LLC AND FOR MONETARY SANCTIONS 10 11 I served the documents on the person or persons listed below as follows: 12 Jeffrey E. Tsai Kathleen S. Kizer 13 DLA PIPER LLP (US) 555 Mission Street, Suite 2400 14 San Francisco, CA 94105 Jeff.tsai@us.dlapiper.com 15 Katy.kizer@us.dlapiper.com Attorneys for Defendants 16 SINGER ASSOCIATES, INC. 17 c/o Sharon Rollins Singer 18 33 Roble Road, Berkeley, CA 94705 19 [X] (BY EMAIL) Pursuant to Code of Civil Procedure section 1010.6, I caused the document(s) to 20 be electronically transmitted by me to the persons listed in the above email address(es). I did not receive within a reasonable time after the transmission, any electronic message or other indication that the 21 transmission was unsuccessful. 22 I declare under penalty of perjury under the laws of the State of California that the foregoing is 23 true and correct. 24 Executed on March 8, 2024, at Antioch, California. 25 26 27 Carolina Ramos 4861-9495-8764, v. 2 28 3 [PROPOSED] ORDER GRANTING MOTION TO COMPEL FURTHER RESPONSE