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1 DAVID J. TAPPEINER, State Bar No. 243979
THE LAW OFFICE OF DAVID J. TAPPEINER
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3 West Carrillo Street, Suite 216
Santa Barbara, CA 93101
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Telephone: (805) 708-6170
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Email: dtappsb@sbestateesq.com
5 Attorneys for Plaintiffs, Mark Sellars, Individually and as Trustee of the Rosemary Free Trust
u/d/t dated September 13, 2000, and Rebecca Morin, Conservator of the Estate and Person of
6 Rosemary Free Leahy
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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9 FOR THE COUNTY OF SANTA BARBARA - ANACAPA DIVISION
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11 MARK SELLARS, individually and as ) CASE NO.: 20CV04132
Trustee of the Rosemary Free Trust u/d/t )
12 dated September 13, 2000; and REBECCA ) [Assigned for all Purposes to the Hon.
MORIN, Conservator of the Estate and )
13 Person of Rosemary Free Leahy ) Thomas P. Anderle]
)
14 Plaintiff, ) PLAINTIFFS’ REPLY TO DEFENDANT
) CHANNE COLES AND THE LAW
15 ) OFFICE OF CHANNE G. COLES
vs. ) OPPOSITION TO PLAINTIFFS’
16 ) MOTION TO QUASH DEPOSITION
) SUBPOENA FOR BUSINESS RECORDS
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)
PATRICK LEAHY; CHANNE COLES, ) Date: June 12, 2024
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THE LAW OFFICE OF CHANNE G. ) Time: 10:00 a.m.
) Dept: 3
19 COLES, a California corporation; )
PATRICIA WOLLUM; SUSAN ) [Filed Concurrently with Plaintiffs’ Reply to
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REYNOLDS; HONOR HOME CARE ) Defendant Channe Coles and the Law Office of
21 SERVICES CALIFORNIA, INC., a ) Channe G. Coles Opposition to Plaintiffs’
Delaware corporation doing business in ) Motion for Protective Order and Declaration of
22 California; and DOES 1 to 10 inclusive; ) David J. Tappeiner]
)
23 ) Third Amended Complaint Filed:
) January 12, 2024
24 Defendants. )
)
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PLAINTIFFS’ REPLY TO DEFENDANT CHANNE COLES AND THE LAW OFFICE OF CHANNE G. COLES
OPPOSITION TO PLAINTIFFS’ MOTION TO QUASH DEPOSITION SUBPOENA FOR BUSINESS RECORDS
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1 I. INTRODUCTION
2 As set forth herein, and in the declaration of plaintiffs’ counsel (with supporting exhibits)
3 filed concurrently herewith, plaintiffs’ counsel has never experienced greater abuses of the
4 discovery process than the abuses engaged in by attorney Chris Kroes (“Mr. Kroes”), counsel for
5 Channe Coles and the Law Office of Channe G. Goles (the “Coles’ Defendants”), in this action.
6 Mr. Kroes has not only abused the discovery process; he has also knowingly lied to this Court, as
7 explained below, all of which is supported by irrefutable evidence.
8 This is a very serious issue. As such, this is the first time that undersigned counsel has
9 accused opposing counsel of knowingly lying to the Court. It is not an accusation that is made
10 lightly. However, as Mr. Kroes has refused to provide any explanation in response to undersigned
11 counsel’s inquiries, refuses to admit the misrepresentations he has made to this Court, and
12 continues to engage in harassing and abusive discovery practices, plaintiffs’ counsel has no choice
13 but to seek protective orders to prevent such continuing abuses, and to seek sanctions against Mr.
14 Kroes for the legal fees and costs incurred by Plaintiffs as a result of Mr. Kroes’ unrebutted
15 malfeasance.
16 Before filing this reply with the Court, as explained in plaintiffs’ counsel’s declaration filed
17 concurrently herewith, after discovering the lies made by Mr. Kroes and his staff, undersigned
18 counsel confronted Mr. Kroes with the evidence documenting the lies he has made to this Court.
19 The lies are the claims by Mr. Kroes and his staff that they have been unable to access all of the
20 documents and media uploaded and shared with Mr. Kroes and other counsel using the file-sharing
21 platform known as Box.com (“BOX”).
22 Not once, in any response, has Mr. Kroes denied the evidence proving that he and his staff
23 have lied to this Court by claiming that they have been unable to access such documents and files.
24 Instead, Mr. Kroes’ responses to plaintiffs’ counsel’s inquiries regarding this issue have
25 deliberately avoided addressing the irrefutable evidence proving that Mr. Kroes and his staff have
26 lied to this Court. As Mr. Kroes has not denied the evidence which supports his lies to this Court,
27 undersigned counsel has no choice but to bring such matters before this Court.
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PLAINTIFFS’ REPLY TO DEFENDANT CHANNE COLES AND THE LAW OFFICE OF CHANNE G. COLES
OPPOSITION TO PLAINTIFFS’ MOTION TO QUASH DEPOSITION SUBPOENA FOR BUSINESS RECORDS
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2 II. THIS REPLY AND PLAINTIFFS’ REPLY TO THE COLES’ DEFENDANTS’
3 OPPOSITION TO PLAINTIFFS’ MOTION FOR PROTECTIVE ORDER MIRROR
4 EACH OTHER.
5 As the discovery issues are the same with respect to Plaintiffs’ Motions for a Protective
6 Order and to Quash the Deposition Subpoena for Business Records served by counsel for the
7 Coles’ Defendants, Plaintiff’s Reply set forth herein is mirrored in Plaintiffs’ Reply to the Coles’
8 Defendants’ Opposition to Plaintiffs’ Motion for Protective Order.
9 Procedural History
10 On January 19, 2024, Mr. Kroes filed a request with this Court to issue an Order to Show
11 Cause to Plaintiffs and their counsel as to why they should not be held in contempt in connection
12 with Plaintiffs’ discovery responses and initial document production in response to the Coles’
13 Defendants’ requests for production of documents (set one) and this Court’s order in connection
14 therewith dated December 27, 2023.
15 The Court issued the OSC on February 14, 2024. The evidentiary hearing was held on
16 March 28, 2024. After the hearing, this Court found that there was insufficient evidence to show
17 that Plaintiffs or their counsel willfully violated this Court’s orders. As detailed in Plaintiffs’
18 counsel’s Declaration filed concurrently herewith (“Tappeiner Declaration”), at the March 28,
19 2024 hearing, undersigned counsel explained that he had been unable to gain access to responsive
20 email correspondence from late 2021 through September 2023, when Plaintiff’s counsel resigned
21 as a partner of DT LAW PARTNERS, LLP (“DT LAW”), and joined RIMON LAW, P.C..
22 Plaintiff’s counsel also advised the Court at that hearing that, after working directly with the IT
23 person for DT LAW, it appeared that the above-referenced emails had been successfully
24 downloaded to Plaintiffs’ counsel’s computer shortly before the March 28, 2024 hearing.
25 Plaintiff’s counsel also estimated that he believed he could review those emails and serve a
26 supplemental production containing responsive email communications to Mr. Kroes in
27 approximately one-week.
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PLAINTIFFS’ REPLY TO DEFENDANT CHANNE COLES AND THE LAW OFFICE OF CHANNE G. COLES
OPPOSITION TO PLAINTIFFS’ MOTION TO QUASH DEPOSITION SUBPOENA FOR BUSINESS RECORDS
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1 In a continuing pattern of harassment and discovery abuse, despite the fact that this Court
2 found that there was no willful disobedience by Plaintiffs or their counsel, Mr. Kroes refused to
3 withdraw his meritless motion for terminating sanctions and monetary sanctions (the “Sanctions
4 Motion”) that he filed on March 20, 2024, which, for the most part, just repeats the same
5 allegations made by Mr. Kroes in connection with the contempt hearing.
6 As further evidence of Mr. Kroes harassment and discovery abuses, on April 1, 2024, just
7 two court days following the contempt hearing, Mr. Kroes served a Deposition Subpoena for
8 Business Records (the “Subpoena”) on Plaintiffs’ counsel’s former law firm, DT LAW
9 PARTNERS, LLP. Mr. Kroes served the Subpoena before Plaintiffs’ counsel could complete the
10 supplemental production that was promised at the contempt hearing. As explained in the Tappeiner
11 Declaration, Mr. Kroes is, for the most part, seeking the same documents in the Subpoena which
12 have already been produced by Plaintiffs after a significant amount of time and effort.
13 It is abundantly clear that Mr. Kroes simply wants to try to harass and intimidate Plaintiffs
14 and to increase the costs of this litigation. Mr. Kroes service of the Subpoena before the
15 supplemental production had been served and his request for terminating sanctions when
16 significant discovery has been produced by Plaintiffs, and the trial in this matter is set
17 approximately nine (9) months from now, are prima facie evidence of Mr. Kroes’ harassment and
18 misuse of the discovery process.
19 As Mr. Kroes refused to withdraw the Sanctions Motion and served the Subpoena in bad
20 faith and without cause, on March 23 and 24, 2024, Plaintiff’s counsel filed a Motion to Quash the
21 Subpoena along with a Motion for a Protective Order. The hearing on all such motions has been
22 continued to June 12, 2024.
23 III. MR. KROES HAS LIED TO THIS COURT
24 Mr. Kroes has stated repeatedly that his office has been unable to access the voluminous
25 discovery produced by Plaintiffs on BOX. Such claims are false.
26 As explained in the Tappeiner Declaration, the evidence shows that employees at Mr.
27 Kroes’ office have, in fact, accessed BOX on multiple occasions. As such, in addition to Plaintiffs’
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PLAINTIFFS’ REPLY TO DEFENDANT CHANNE COLES AND THE LAW OFFICE OF CHANNE G. COLES
OPPOSITION TO PLAINTIFFS’ MOTION TO QUASH DEPOSITION SUBPOENA FOR BUSINESS RECORDS
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1 request for sanctions, Plaintiff’s also request that Plaintiffs be relieved of the any further burden
2 of having to print and hand-deliver documents to Mr. Kroes’ office.
3 IV. CONCLUSION
4 For all of the reasons set forth herein, and in the Tappeiner Declaration filed in support
5 hereof, Plaintiffs request that the Court grant the Motion to Quash the Deposition Subpoena for
6 Business Records and, as to sanctions, provided that the Court rules in Plaintiffs’ favor, Plaintiffs
7 request the opportunity to submit evidence to support their request for sanctions.
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THE LAW OFFICE OF DAVID J. TAPPEINER
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/s/ David J. Tappeiner
11 By:__________________________
DAVID J. TAPPEINER
12 Attorney for Plaintiffs
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PLAINTIFFS’ REPLY TO DEFENDANT CHANNE COLES AND THE LAW OFFICE OF CHANNE G. COLES
OPPOSITION TO PLAINTIFFS’ MOTION TO QUASH DEPOSITION SUBPOENA FOR BUSINESS RECORDS
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PROOF OF SERVICE
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2 MARK SELLARS vs PATRICK LEAHY, ET AL.
Santa Barbara County Superior Court - Anacapa Division - Case No. 20CV04132
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I am employed in the County of Santa Barbara, State of California. I am over the age of 18
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and not a party to this action. My business address is 3 West Carrillo Street, Suite 216, Santa
5 Barbara, California 93101. My electronic service address is dtappsb@sbestateesq.com
6 On June 6, 2024, I caused to be served the foregoing document described as:
PLAINTIFFS’ REPLY TO DEFENDANT CHANNE COLES AND THE LAW OFFICE
7 OF CHANNE G. COLES OPPOSITION TO PLAINTIFFS’ MOTION TO QUASH
DEPOSITION SUBPOENA FOR BUSINESS RECORDS, on the persons below by
8 delivering the original X true copies thereof by email, as follows:
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Attorney for Defendants Channe Coles and Law Office of Channe Coles
10 R. Chris Kroes, Esq.
The Law Offices of McCarthy & Kroes
11 125 East Victoria St. Suite A
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Santa Barbara, CA 93101
Chris@mccarthykroes.com
13 amanda@mccarthykroes.com
esmeralda@mccarthykroes.com
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Defendant – in Pro Per
Patrick Leahy
16 961 Randolph Road
Santa Barbara, CA 93111
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patsprod@yahoo.com
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Attorneys for Defendants Patricia Wollum and Susan Reynolds
19 Gregory K. Sabo, Esq.
David A. Napper, Esq.
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Yass Sepeidnameh, Esq.
21 Chapman Glucksman
11900 West Olympic Boulevard, Suite 800
22 Los Angeles, CA 90064-0704
service@cgdrlaw.com
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dnapper@cgdrlaw.com
24 gsabo@cgdrlaw.com;
ysepidnameh@cgdrlaw.com
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PLAINTIFFS’ REPLY TO DEFENDANT CHANNE COLES AND THE LAW OFFICE OF CHANNE G. COLES
OPPOSITION TO PLAINTIFFS’ MOTION TO QUASH DEPOSITION SUBPOENA FOR BUSINESS RECORDS
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Defendant – in Pro Per
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Patrick Leahy
2 c/o Knight Broadcasting
1101 S. Broadway STE C
3 Santa Maria, CA 93454
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X BY EMAIL-PDF TRANSMISSION: I electronically served the document listed above to the
5 electronic service addresses of the persons as shown above.
6 X (STATE) I declare under penalty of perjury under the laws of the State of California that the
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foregoing is true and correct.
8 Executed on June 6, 2024, at Santa Barbara, California.
9 /s/ David J. Tappeiner
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David J. Tappeiner
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PLAINTIFFS’ REPLY TO DEFENDANT CHANNE COLES AND THE LAW OFFICE OF CHANNE G. COLES
OPPOSITION TO PLAINTIFFS’ MOTION TO QUASH DEPOSITION SUBPOENA FOR BUSINESS RECORDS
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Preview
1 DAVID J. TAPPEINER, State Bar No. 243979 THE LAW OFFICE OF DAVID J. TAPPEINER 2 3 West Carrillo Street, Suite 216 Santa Barbara, CA 93101 3 Telephone: (805) 708-6170 4 Email: dtappsb@sbestateesq.com 5 Attorneys for Plaintiffs, Mark Sellars, Individually and as Trustee of the Rosemary Free Trust u/d/t dated September 13, 2000, and Rebecca Morin, Conservator of the Estate and Person of 6 Rosemary Free Leahy 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 9 FOR THE COUNTY OF SANTA BARBARA - ANACAPA DIVISION 10 11 MARK SELLARS, individually and as ) CASE NO.: 20CV04132 Trustee of the Rosemary Free Trust u/d/t ) 12 dated September 13, 2000; and REBECCA ) [Assigned for all Purposes to the Hon. MORIN, Conservator of the Estate and ) 13 Person of Rosemary Free Leahy ) Thomas P. Anderle] ) 14 Plaintiff, ) PLAINTIFFS’ REPLY TO DEFENDANT ) CHANNE COLES AND THE LAW 15 ) OFFICE OF CHANNE G. COLES vs. ) OPPOSITION TO PLAINTIFFS’ 16 ) MOTION TO QUASH DEPOSITION ) SUBPOENA FOR BUSINESS RECORDS 17 ) PATRICK LEAHY; CHANNE COLES, ) Date: June 12, 2024 18 THE LAW OFFICE OF CHANNE G. ) Time: 10:00 a.m. ) Dept: 3 19 COLES, a California corporation; ) PATRICIA WOLLUM; SUSAN ) [Filed Concurrently with Plaintiffs’ Reply to 20 REYNOLDS; HONOR HOME CARE ) Defendant Channe Coles and the Law Office of 21 SERVICES CALIFORNIA, INC., a ) Channe G. Coles Opposition to Plaintiffs’ Delaware corporation doing business in ) Motion for Protective Order and Declaration of 22 California; and DOES 1 to 10 inclusive; ) David J. Tappeiner] ) 23 ) Third Amended Complaint Filed: ) January 12, 2024 24 Defendants. ) ) 25 // // 26 // // 27 28 ________________________________________________________________________________________________________ PLAINTIFFS’ REPLY TO DEFENDANT CHANNE COLES AND THE LAW OFFICE OF CHANNE G. COLES OPPOSITION TO PLAINTIFFS’ MOTION TO QUASH DEPOSITION SUBPOENA FOR BUSINESS RECORDS -1 1 I. INTRODUCTION 2 As set forth herein, and in the declaration of plaintiffs’ counsel (with supporting exhibits) 3 filed concurrently herewith, plaintiffs’ counsel has never experienced greater abuses of the 4 discovery process than the abuses engaged in by attorney Chris Kroes (“Mr. Kroes”), counsel for 5 Channe Coles and the Law Office of Channe G. Goles (the “Coles’ Defendants”), in this action. 6 Mr. Kroes has not only abused the discovery process; he has also knowingly lied to this Court, as 7 explained below, all of which is supported by irrefutable evidence. 8 This is a very serious issue. As such, this is the first time that undersigned counsel has 9 accused opposing counsel of knowingly lying to the Court. It is not an accusation that is made 10 lightly. However, as Mr. Kroes has refused to provide any explanation in response to undersigned 11 counsel’s inquiries, refuses to admit the misrepresentations he has made to this Court, and 12 continues to engage in harassing and abusive discovery practices, plaintiffs’ counsel has no choice 13 but to seek protective orders to prevent such continuing abuses, and to seek sanctions against Mr. 14 Kroes for the legal fees and costs incurred by Plaintiffs as a result of Mr. Kroes’ unrebutted 15 malfeasance. 16 Before filing this reply with the Court, as explained in plaintiffs’ counsel’s declaration filed 17 concurrently herewith, after discovering the lies made by Mr. Kroes and his staff, undersigned 18 counsel confronted Mr. Kroes with the evidence documenting the lies he has made to this Court. 19 The lies are the claims by Mr. Kroes and his staff that they have been unable to access all of the 20 documents and media uploaded and shared with Mr. Kroes and other counsel using the file-sharing 21 platform known as Box.com (“BOX”). 22 Not once, in any response, has Mr. Kroes denied the evidence proving that he and his staff 23 have lied to this Court by claiming that they have been unable to access such documents and files. 24 Instead, Mr. Kroes’ responses to plaintiffs’ counsel’s inquiries regarding this issue have 25 deliberately avoided addressing the irrefutable evidence proving that Mr. Kroes and his staff have 26 lied to this Court. As Mr. Kroes has not denied the evidence which supports his lies to this Court, 27 undersigned counsel has no choice but to bring such matters before this Court. 28 ________________________________________________________________________________________________________ PLAINTIFFS’ REPLY TO DEFENDANT CHANNE COLES AND THE LAW OFFICE OF CHANNE G. COLES OPPOSITION TO PLAINTIFFS’ MOTION TO QUASH DEPOSITION SUBPOENA FOR BUSINESS RECORDS -2 1 2 II. THIS REPLY AND PLAINTIFFS’ REPLY TO THE COLES’ DEFENDANTS’ 3 OPPOSITION TO PLAINTIFFS’ MOTION FOR PROTECTIVE ORDER MIRROR 4 EACH OTHER. 5 As the discovery issues are the same with respect to Plaintiffs’ Motions for a Protective 6 Order and to Quash the Deposition Subpoena for Business Records served by counsel for the 7 Coles’ Defendants, Plaintiff’s Reply set forth herein is mirrored in Plaintiffs’ Reply to the Coles’ 8 Defendants’ Opposition to Plaintiffs’ Motion for Protective Order. 9 Procedural History 10 On January 19, 2024, Mr. Kroes filed a request with this Court to issue an Order to Show 11 Cause to Plaintiffs and their counsel as to why they should not be held in contempt in connection 12 with Plaintiffs’ discovery responses and initial document production in response to the Coles’ 13 Defendants’ requests for production of documents (set one) and this Court’s order in connection 14 therewith dated December 27, 2023. 15 The Court issued the OSC on February 14, 2024. The evidentiary hearing was held on 16 March 28, 2024. After the hearing, this Court found that there was insufficient evidence to show 17 that Plaintiffs or their counsel willfully violated this Court’s orders. As detailed in Plaintiffs’ 18 counsel’s Declaration filed concurrently herewith (“Tappeiner Declaration”), at the March 28, 19 2024 hearing, undersigned counsel explained that he had been unable to gain access to responsive 20 email correspondence from late 2021 through September 2023, when Plaintiff’s counsel resigned 21 as a partner of DT LAW PARTNERS, LLP (“DT LAW”), and joined RIMON LAW, P.C.. 22 Plaintiff’s counsel also advised the Court at that hearing that, after working directly with the IT 23 person for DT LAW, it appeared that the above-referenced emails had been successfully 24 downloaded to Plaintiffs’ counsel’s computer shortly before the March 28, 2024 hearing. 25 Plaintiff’s counsel also estimated that he believed he could review those emails and serve a 26 supplemental production containing responsive email communications to Mr. Kroes in 27 approximately one-week. 28 ________________________________________________________________________________________________________ PLAINTIFFS’ REPLY TO DEFENDANT CHANNE COLES AND THE LAW OFFICE OF CHANNE G. COLES OPPOSITION TO PLAINTIFFS’ MOTION TO QUASH DEPOSITION SUBPOENA FOR BUSINESS RECORDS -3 1 In a continuing pattern of harassment and discovery abuse, despite the fact that this Court 2 found that there was no willful disobedience by Plaintiffs or their counsel, Mr. Kroes refused to 3 withdraw his meritless motion for terminating sanctions and monetary sanctions (the “Sanctions 4 Motion”) that he filed on March 20, 2024, which, for the most part, just repeats the same 5 allegations made by Mr. Kroes in connection with the contempt hearing. 6 As further evidence of Mr. Kroes harassment and discovery abuses, on April 1, 2024, just 7 two court days following the contempt hearing, Mr. Kroes served a Deposition Subpoena for 8 Business Records (the “Subpoena”) on Plaintiffs’ counsel’s former law firm, DT LAW 9 PARTNERS, LLP. Mr. Kroes served the Subpoena before Plaintiffs’ counsel could complete the 10 supplemental production that was promised at the contempt hearing. As explained in the Tappeiner 11 Declaration, Mr. Kroes is, for the most part, seeking the same documents in the Subpoena which 12 have already been produced by Plaintiffs after a significant amount of time and effort. 13 It is abundantly clear that Mr. Kroes simply wants to try to harass and intimidate Plaintiffs 14 and to increase the costs of this litigation. Mr. Kroes service of the Subpoena before the 15 supplemental production had been served and his request for terminating sanctions when 16 significant discovery has been produced by Plaintiffs, and the trial in this matter is set 17 approximately nine (9) months from now, are prima facie evidence of Mr. Kroes’ harassment and 18 misuse of the discovery process. 19 As Mr. Kroes refused to withdraw the Sanctions Motion and served the Subpoena in bad 20 faith and without cause, on March 23 and 24, 2024, Plaintiff’s counsel filed a Motion to Quash the 21 Subpoena along with a Motion for a Protective Order. The hearing on all such motions has been 22 continued to June 12, 2024. 23 III. MR. KROES HAS LIED TO THIS COURT 24 Mr. Kroes has stated repeatedly that his office has been unable to access the voluminous 25 discovery produced by Plaintiffs on BOX. Such claims are false. 26 As explained in the Tappeiner Declaration, the evidence shows that employees at Mr. 27 Kroes’ office have, in fact, accessed BOX on multiple occasions. As such, in addition to Plaintiffs’ 28 ________________________________________________________________________________________________________ PLAINTIFFS’ REPLY TO DEFENDANT CHANNE COLES AND THE LAW OFFICE OF CHANNE G. COLES OPPOSITION TO PLAINTIFFS’ MOTION TO QUASH DEPOSITION SUBPOENA FOR BUSINESS RECORDS -4 1 request for sanctions, Plaintiff’s also request that Plaintiffs be relieved of the any further burden 2 of having to print and hand-deliver documents to Mr. Kroes’ office. 3 IV. CONCLUSION 4 For all of the reasons set forth herein, and in the Tappeiner Declaration filed in support 5 hereof, Plaintiffs request that the Court grant the Motion to Quash the Deposition Subpoena for 6 Business Records and, as to sanctions, provided that the Court rules in Plaintiffs’ favor, Plaintiffs 7 request the opportunity to submit evidence to support their request for sanctions. 8 THE LAW OFFICE OF DAVID J. TAPPEINER 9 10 /s/ David J. Tappeiner 11 By:__________________________ DAVID J. TAPPEINER 12 Attorney for Plaintiffs 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ________________________________________________________________________________________________________ PLAINTIFFS’ REPLY TO DEFENDANT CHANNE COLES AND THE LAW OFFICE OF CHANNE G. COLES OPPOSITION TO PLAINTIFFS’ MOTION TO QUASH DEPOSITION SUBPOENA FOR BUSINESS RECORDS -5 PROOF OF SERVICE 1 2 MARK SELLARS vs PATRICK LEAHY, ET AL. Santa Barbara County Superior Court - Anacapa Division - Case No. 20CV04132 3 I am employed in the County of Santa Barbara, State of California. I am over the age of 18 4 and not a party to this action. My business address is 3 West Carrillo Street, Suite 216, Santa 5 Barbara, California 93101. My electronic service address is dtappsb@sbestateesq.com 6 On June 6, 2024, I caused to be served the foregoing document described as: PLAINTIFFS’ REPLY TO DEFENDANT CHANNE COLES AND THE LAW OFFICE 7 OF CHANNE G. COLES OPPOSITION TO PLAINTIFFS’ MOTION TO QUASH DEPOSITION SUBPOENA FOR BUSINESS RECORDS, on the persons below by 8 delivering the original X true copies thereof by email, as follows: 9 Attorney for Defendants Channe Coles and Law Office of Channe Coles 10 R. Chris Kroes, Esq. The Law Offices of McCarthy & Kroes 11 125 East Victoria St. Suite A 12 Santa Barbara, CA 93101 Chris@mccarthykroes.com 13 amanda@mccarthykroes.com esmeralda@mccarthykroes.com 14 15 Defendant – in Pro Per Patrick Leahy 16 961 Randolph Road Santa Barbara, CA 93111 17 patsprod@yahoo.com 18 Attorneys for Defendants Patricia Wollum and Susan Reynolds 19 Gregory K. Sabo, Esq. David A. Napper, Esq. 20 Yass Sepeidnameh, Esq. 21 Chapman Glucksman 11900 West Olympic Boulevard, Suite 800 22 Los Angeles, CA 90064-0704 service@cgdrlaw.com 23 dnapper@cgdrlaw.com 24 gsabo@cgdrlaw.com; ysepidnameh@cgdrlaw.com 25 26 27 28 ________________________________________________________________________________________________________ PLAINTIFFS’ REPLY TO DEFENDANT CHANNE COLES AND THE LAW OFFICE OF CHANNE G. COLES OPPOSITION TO PLAINTIFFS’ MOTION TO QUASH DEPOSITION SUBPOENA FOR BUSINESS RECORDS -6 Defendant – in Pro Per 1 Patrick Leahy 2 c/o Knight Broadcasting 1101 S. Broadway STE C 3 Santa Maria, CA 93454 4 X BY EMAIL-PDF TRANSMISSION: I electronically served the document listed above to the 5 electronic service addresses of the persons as shown above. 6 X (STATE) I declare under penalty of perjury under the laws of the State of California that the 7 foregoing is true and correct. 8 Executed on June 6, 2024, at Santa Barbara, California. 9 /s/ David J. Tappeiner 10 David J. Tappeiner 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ________________________________________________________________________________________________________ PLAINTIFFS’ REPLY TO DEFENDANT CHANNE COLES AND THE LAW OFFICE OF CHANNE G. COLES OPPOSITION TO PLAINTIFFS’ MOTION TO QUASH DEPOSITION SUBPOENA FOR BUSINESS RECORDS -7