On September 13, 2016 a
Request,Application
was filed
involving a dispute between
Lalani Nailau,
and
Albert K. Clarke,
Robert M. Pickle,
Susan M. Clarke,
The Pickle Marital Trust,
for Auto Unlimited (22)
in the District Court of Santa Clara County.
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1
| Richard E. Eichenbaum, Esq. SBN 157065
2 || CAPUTO & VAN DER WALDE LLP
| 51E. Campbell Avenue, Suite 120
Campbell, CA 95008
(408) 733-0100
4) (408) 733-0123 fax
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SANTA CLARA
5
6 Attorneys for Plaintiff
LALANI NAILAU
7
8 |
9
|
10) LALANI NAILAU,
uy Plaintiff,
R
VS.
SUSAN M. CLARKE and ALBERT K.
14. CLARKE and DOES 1-20,
15 Defendants.
16
7
18 LALANI NAILAU,
19 Plaintiff,
20 | vs.
21| SUSAN M. CLARKE, ALBERT K. CLARKE,
ROBERT M. PICKLE & THE PICKLE
2 MARITAL TRUST, ROBERT M. PICKLE AS
zB) TRUSTEE & DOES 1-25, inclusive.
Defendants.
24
BNR
ORDER GRANTING PLAINTIFF'S MOTION
TO COMPEL FURTHER DEPOSITION & PRODUCE
DOCUMENTS PURSUANT TO CCP § 2025.480
Case No.: 16C¥299824
ORDER GRANTING PLAINTIFF’S
MOTION TO COMPEL FURTHER
DEPOSITION & PRODUCE DOCUMENTS
PURSUANT TO CCP § 2025.480
Date: March 5, 2019
Time: 9:00 a.m,
Dept: 9
Complaint Filed:
Trial Date:
September 13, 2016
None
Case No.: 18CV321960
Complaint Filed: January 18, 2018
Trial Date: None
PAGE 1 CAPUTO & VAN DER WAALDE LLP
51 , CAMPBELL AVENUE, SUTFE 120
CAMPBELL, CA 95008 (408) 733-01001||
|
seo MOI AUN AW
BBB SE
—
Nn
e216
| cause appearing thereof,
im) The Plaintiff's Motion to Compel Further Deposition and Produce Documents Pursuant to
| ROBERT PICKLE
Plaintiff’ s Motion to Compel Further Deposition and Produce Documents Pursuant to CCP
§ 2025.480 was heard on March 5, 2019 before the Honorable Mary Arand in Department 9 of the
above Court. Richard E. Eichenbaum, Esq. appeared on behalf of Plaintiff. Bradley Kass, Esq.
appeared on behalf of Defendant ROBERT M. PICKLE.
After considering the papers on file herein, hearing the arguments of counsel and good
IT IS HEREBY ORDERED, as follows:
CCP § 2025.480 is hereby GRANTED.
2) Defense counsel, Bradley Kass, Esq., will produce Defendant Robert Pickle for further
deposition on a mutually agreeable date and time. Said deposition will be limited as to the
documents to be produced and not to unnecessarily repeat questions already asked to which
answers were given.
3) Defendant Robert Pickle is ordered to produce an unredacted, complete copy of the Pickle
Marital Trust (The Trust), including all amendments, addendums, and any other additions from The
Trust’s inception within fifteen (15) days from the date of this Order.
4) Plaintiff’ s request for monetary sanctions is GRANTED in the amount of $2,260.00
Defendant ROBERT PICKLE and his counsel shall pay this award to Plaintiffs counsel, Caputo &
Van Der Walde, LLP, within 20 calendar days of this Order.
APPROVED AS TO FORM
AND CONTENT:
Bradley Kass, Esq.
Attorney for Defendant
DATED: ____ 2019
JUDGE OF THE SUPERIOR COURT
ORDER GRANTING PLAINTIFF'S MOTION PAGE 2 CAPUTO & VAN DER WALDELLP
TO COMPEL FURTHER DEPOSITION & PRODUCE FcAMPaELLN CA sevee| caver 7aa0100)
DOCUMENTS PURSUANT TO CCP § 2025.480
Document Filed Date
March 27, 2019
Case Filing Date
September 13, 2016
Category
Auto Unlimited (22)
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1 | Richard E. Eichenbaum, Esq. SBN 157065 2 || CAPUTO & VAN DER WALDE LLP | 51E. Campbell Avenue, Suite 120 Campbell, CA 95008 (408) 733-0100 4) (408) 733-0123 fax SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA 5 6 Attorneys for Plaintiff LALANI NAILAU 7 8 | 9 | 10) LALANI NAILAU, uy Plaintiff, R VS. SUSAN M. CLARKE and ALBERT K. 14. CLARKE and DOES 1-20, 15 Defendants. 16 7 18 LALANI NAILAU, 19 Plaintiff, 20 | vs. 21| SUSAN M. CLARKE, ALBERT K. CLARKE, ROBERT M. PICKLE & THE PICKLE 2 MARITAL TRUST, ROBERT M. PICKLE AS zB) TRUSTEE & DOES 1-25, inclusive. Defendants. 24 BNR ORDER GRANTING PLAINTIFF'S MOTION TO COMPEL FURTHER DEPOSITION & PRODUCE DOCUMENTS PURSUANT TO CCP § 2025.480 Case No.: 16C¥299824 ORDER GRANTING PLAINTIFF’S MOTION TO COMPEL FURTHER DEPOSITION & PRODUCE DOCUMENTS PURSUANT TO CCP § 2025.480 Date: March 5, 2019 Time: 9:00 a.m, Dept: 9 Complaint Filed: Trial Date: September 13, 2016 None Case No.: 18CV321960 Complaint Filed: January 18, 2018 Trial Date: None PAGE 1 CAPUTO & VAN DER WAALDE LLP 51 , CAMPBELL AVENUE, SUTFE 120 CAMPBELL, CA 95008 (408) 733-01001|| | seo MOI AUN AW BBB SE — Nn e216 | cause appearing thereof, im) The Plaintiff's Motion to Compel Further Deposition and Produce Documents Pursuant to | ROBERT PICKLE Plaintiff’ s Motion to Compel Further Deposition and Produce Documents Pursuant to CCP § 2025.480 was heard on March 5, 2019 before the Honorable Mary Arand in Department 9 of the above Court. Richard E. Eichenbaum, Esq. appeared on behalf of Plaintiff. Bradley Kass, Esq. appeared on behalf of Defendant ROBERT M. PICKLE. After considering the papers on file herein, hearing the arguments of counsel and good IT IS HEREBY ORDERED, as follows: CCP § 2025.480 is hereby GRANTED. 2) Defense counsel, Bradley Kass, Esq., will produce Defendant Robert Pickle for further deposition on a mutually agreeable date and time. Said deposition will be limited as to the documents to be produced and not to unnecessarily repeat questions already asked to which answers were given. 3) Defendant Robert Pickle is ordered to produce an unredacted, complete copy of the Pickle Marital Trust (The Trust), including all amendments, addendums, and any other additions from The Trust’s inception within fifteen (15) days from the date of this Order. 4) Plaintiff’ s request for monetary sanctions is GRANTED in the amount of $2,260.00 Defendant ROBERT PICKLE and his counsel shall pay this award to Plaintiffs counsel, Caputo & Van Der Walde, LLP, within 20 calendar days of this Order. APPROVED AS TO FORM AND CONTENT: Bradley Kass, Esq. Attorney for Defendant DATED: ____ 2019 JUDGE OF THE SUPERIOR COURT ORDER GRANTING PLAINTIFF'S MOTION PAGE 2 CAPUTO & VAN DER WALDELLP TO COMPEL FURTHER DEPOSITION & PRODUCE FcAMPaELLN CA sevee| caver 7aa0100) DOCUMENTS PURSUANT TO CCP § 2025.480