Motion for Terminating Sanctions in MATTHEW SQUIRES, et al vs. R.C. WEHMEYER CONSTRUCTION, INC., et al| Trellis.Law

On February 20, 2018 a Motion-Secondary was filed involving a dispute between Bordin, Jeffrey, Martinez, Gregorio, R.C. Wehmeyer Construction, Inc., Wehmeyer, Robert C., Squires, Matthew, Squires, Nicole, and Amercian Contractors Indemnity Company, Does 1 Through 20, Inclusive, R.C. Wehmeyer Construction, Inc., Robert C. Wehmeyer Design, Inc., Wehmeyer, Robert C., for (06) Unlimited Breach of Contract/Warranty in the District Court of San Mateo County.

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BRIAN W.
ATTORNEY AT
NEWCOMB,
LAW
C.S.B. #55156
MW—
brﬁuplnur Cour! ﬂﬁaliﬂnllﬂaunﬁl afiln Malia

UN 9/1 6/201 9

puts

770 MENLO AVENUE, SUITE 101
MENLO PARK, CA 94025
TEL: 650 322-7780
FAX: 650 322—7740
EMAIL: brianwnewcomb@gmail.com

Attorney for Defendants and Cross—Complainants
R.C. Wehmeyer Construction,
OLOOONOUO‘l-PQDNA |nc., dba Wehmeyer
Custom Homes, Robert C. Wehmeyer, and
Defendants American Contractors Indemnity
Company and Robert C. Wehmeyer Design, Inc.

ALBERT M. T. FINCH, III,State Bar #196478
IAN P. WILSON, State Bar # 271075
ERICKSEN ARBUTHNOT
100 BUSH STREET, SUITE 900
SAN FRANCISCO, CA 94104
TEL: 415 362-7126
FAX: 415 362-6401
EMAIL: afinch@ericksenarbuthnoth.Com
EMAIL: iwi|son@ericksenarbuthnoth.com

Attorneys for Defendant
R.C. Wehmeyer Construction, |nc., dba
Wehmever Custom Homes
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN MATEO
MATTHEW SQUIRES; NICOLE Case N0. 18 CIV 00846
SQUIRES, [Unlimited Jurisdiction]

Plaintiffs, DECLARATION OF BRIAN W.
NNNNNNNNNAAAAAAAAAA
NEWCOMB IN OPPOSITION TO
vs.
mVOUU‘l-POON—‘OQWNOUU‘I-POONA
SQUIRES MOTION FOR TERMINATING
SANCTIONS
R.C. WEHMEYER CONSTRUCTION,
|NC., dba WEHMEYER Date: September 27, 2019
CONSTRUCTION HOMES; ROBERT C. Time:
WVWW

9:00 AM
WEHMEYER, an individual; AMERICAN Dept.: 1, Law & Motion
CONTRACTORS INDEMNITY Judge: Leland S. Davis |||

COMPANY; and DOES 1through 20,
inclusive, Action Filed: February 20, 2018
Trial Date: November 12, 2019
Defendants.

R.C. WEHMEYER CONSTRUCTION,
|NC., dba WEHMEYER CUSTOM
HOMES; ROBERT C. WEHMEYER,
Cross-Complainants,

VS.

DECLARATION OF BRIAN W. NEWCOMB IN OPPOSITION TO PLAINTIFF SQUIRES MOTION
FOR TERMINATING SANCTIONS
MATTHEW SQUIRES; NICOLE )

SQUIRES; and ROES 1
-
10,

Cross-Defendants.
a

I, Brian W. Newcomb, declare as follows:

1. | am the attorney for Defendants and Cross-Complainants R.C.
OLOOONOUO‘l-PQDNA

Wehmeyer Construction, |nc., dba Wehmeyer Custom Homes (hereinafter

"Wehmeyer Construction") and Robert C. Wehmeyer. Please note the Squires’

Motion is only as to Defendants Robert C. Wehmeyer and R.C. Wehmeyer
Construction.

2. Previously | represented the Cross-Complainants Jeffrey Bordin and

Gregorio Martinez in this case.

3. This Declaration is filed in opposition to the Plaintiff and Cross-

Defendants Matthew and Nicole Squires Motion for Terminating Sanctions filed only

as t0 R.C. Wehmeyer Construction and Robert C. Wehmeyer.
4. The facts set forth herein are based upon my personal knowledge and if

called upon as a witness, |am competent to testify thereto.

5. Messrs. Bordin and Martinez previously hired me to represent them at

the time they were both employees of R.C. Wehmeyer Construction, Inc. The two

individuals
NNNNNNNNNAAAAAAAAAA

had worked on the Squires' home and subsequently learned that their
mVOUU‘l-POON—‘OQWNOUU‘I-POONA

conversations were being surreptitiously recorded. They never consented they were

being recorded, did not know they were being recorded and after learning they were

being recorded, hired me to represent them in seeking damages of $2,500 for each

of the surreptitious recordings. The damages were sought pursuant to Penal Code

§ 632. Mr. Wehmeyer also seeks damages pursuant to Penal Code § 632 for the

surreptitious recordings. There were additional employees of Wehmeyer
Construction that worked on the Squires' premises where the recordings took place

who chose not to pursue damage claims.

6. Penal Code § 632(3) provides in pertinent part as follows:

DECLARATION OF BRIAN W. NEWCOMB IN OPPOSITION TO PLAINTIFF SQUIRES MOTION
FOR TERMINATING SANCTIONS
"(a) Every person who, intentionally and without the consent of all
parties to a confidential communication, by means of any electronic
amplifying or recording device eavesdrops upon or records the
confidential communication, whether the communication is carried on
among the parties in the presence of one another or by means of a
telegraph, telephone, or other device, except a radio, shall be punished
by a fine not exceeding two thousand five hundred dollars ($2,500) per
violation, or imprisonment in a county jail not exceeding one year,...",
emphasis added.
OLOOONOUO‘l-PQDNA

7. Prior to filing the Cross—Complaint on behalf of Messrs. Bordin and

Martinez, | met with each of them and reviewed the case. They each requested |

represent them in pursuing their damage claims as a result of the surreptitious

recordings. The facts were reviewed with Messrs. Bordin and Martinez and each

was provided with an endorsed-filed copy of the Cross-Complaint filed on their

behalves.

8. After the filing of the Cross—Complaint, Nicole Squires served her first

Specially Prepared Interrogatories as well as first Form Interrogatories on each of the

Cross-Complainants, that is Messrs. Bordin and Martinez. Attached hereto as Exhibit

A is the Verified Response by Jeffrey Bordin to Nicole Squires First Form

Interrogatories. Attached hereto as Exhibit B is a Verified Response by Jeffrey

Bordin to Nicole Squires First Specially Prepared Interrogatories. Attached hereto as

Exhibit C is Gregorio Martinez Verified Response to Nicole Squires First Form

Interrogatories.
NNNNNNNNNAAAAAAAAAA Attached hereto as Exhibit D is Gregorio Martinez Verified Response
mVOUU‘l-POON—‘OQWNOUU‘I-POONA

to Nicole Squires First Specially Prepared Interrogatories.

9. Please note that of the four verifications set forth above, 1 belonging to

Messrs. Bordin and Martinez, they each signed those Verifications after reviewing the

Interrogatory Answers obtaining information such as biographical facts about each.

Additionally, each of these Cross—Complainants was duly noticed for Deposition by

the Squires as parties to the action. The undersigned appeared as attorney of record

for Cross-Complainant Mr. Bordin at his first deposition session. See Exhibit E

attached hereto which is a copy of the cover page for the Deposition and list of

attorneys appearing and for whom they appeared as well as the introductory

DECLARATION OF BRIAN W. NEWCOMB IN OPPOSITION TO PLAINTIFF SQUIRES MOTION
FOR TERMINATING SANCTIONS
questions. See also Declaration of Robert C. Wehmeyer who met with each of these

parties at the time they were working for him as employees when issues concerning

the litigation and the recordings were discussed with Messrs. Bordin and Martinez as

well as other employees who have been recorded.

10. In or around November 2018, Mr. Bordin and Wehmeyer Construction
OLOOONOUO‘l-PQDNA

had a parting of the ways. As part of the ceasing to work for Wehmeyer
Construction, Mr. Bordin agreed to return the truck which was supplied by Wehmeyer
Construction for his use as well as the computer, charger, keyboard, pen, protective

cover and records of Wehmeyer Construction such as receipts reports, permit cards,

etc. Attached hereto as Exhibit F is a true and accurate copy of an email which |

forwarded to Robert C. Wehmeyer on December 5, 2018, at 3:17 PM regarding Jeff

Bordin returning the items to R.C. Wehmeyer Construction Inc. The email has

attached to it a list of items that Mr. Bordin prepared to memorialize what he returned

in accordance with the parties agreement to my office for delivery to Wehmeyer
Construction. The listwas prepared by Mr. Bordin and delivered to me on December

5, 2018.

11. The items which were delivered to me for return to Wehmeyer
Construction were listed by Mr. Bordin himself. See Exhibit F. Mr. Bordin does not

identify
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anywhere therein anything about drawings, plans, sketches, floor plans,
mVOUU‘l-POON—‘OQWNOUU‘I-POONA

change orders, notes, or a notebook containing any information whatsoever. No
such documents were delivered to me.

12. Mr. Wehmeyer in his Declaration points out he never saw Mr. Bordin

with a notebook and never saw a journal in Mr. Bordin’s possession. | attended the

deposition of Mr. Gregorio and have attached hereto accurate pages from Mr.

Martinez’ July 10, 2019 Deposition page 47 line 3, in response to Mr. Mengarelli’s

question to him at page 48 line 3: “Q. Would you make notes for the project?” His

answer, “A. No.” Mr. Mengarelli at page 47 line 12 to line 14 had this exchange with

Gregorio Martinez: “Q. Okay. And besides the Squires project, did you keep a

DECLARATION OF BRIAN W. NEWCOMB IN OPPOSITION TO PLAINTIFF SQUIRES MOTION
FOR TERMINATING SANCTIONS
notebook orjob journal for other projects? A. “No.” Page 47 lines 12-14.

13. Then Mr. Mengarelli on July 10, 2019, continuing the same deposition,

asks Gregorio Martinez “Q. Would you keep those notes or would you throw them

away when you were done with them? A. | would throw them away every time |

washed my truck.” Depo of July 10, 2019, page 47 lines 22-25.
OLOOONOUO‘l-PQDNA

14. Then in regard to the Squires’ counsel’s argument that Mr. Bordin had a

notebook the testimony is the opposite in Mr. Martinez’ recollection, as well as the

design person at Wehmeyer Design, ie. Katrina Hall.

15. In response to questions by Mr. Mengarelli at his July 10, 2019

Deposition, Mr. Mengarelli’s examination of Mr. Martinez at pgs. 47-48, Ins. 1-14 are

as follows:

“Q. Okay.
Did Rob Wehmeyer ever ask you to give him any of your notes
from the project?
A. BladBecause | didn’t keep any notes. The manager was Jeff
or In.
Q. Do you know whether or not Jeff Bordin kept notes?
A. |
don’t know.
Q. Did you ever see Jeff Bordin with a job journal?
A. |
don’t remember.
Q. How about a notebook?
A. No. Sometimes he had documents or a folder, but itwas always
different.”

Pages
NNNNNNNNNAAAAAAAAAA 47 and 48 of Mr. Martinez’ Deposition Transcript attached as Exhibit G,
mVOUU‘l-POON—‘OQWNOUU‘I-POONA

all the excerpts from the Martinez Deposition are attached hereto as Exhibit G.

16. Additionally, the Motion for Sanctions filed is replete with blatantly false

factual representations to this Court.

17. Emphasis of the false recitations are at pg. 1, Ins. 26 to 27 of the

Squires’ Memo of Points and Authorities, the author Ms. Glatt “...neither Bordin nor

Martinez authorized counsel for RCWC Brian W. Newcomb to file a Cross-

Complainant on their behalf against Plaintiffs.”

18. The facts testified under oath by Mr. Bordin in Vol. |of his Deposition in

response to Ms. Glatt’s question about Exhibit 3 to the deposition which was Mr.

DECLARATION OF BRIAN W. NEWCOMB IN OPPOSITION TO PLAINTIFF SQUIRES MOTION
FOR TERMINATING SANCTIONS
Bordin’s response to a question about Exhibit 3 which was his written response to the

Squires’ First Form Interrogatories. See page 27 of the subject deposition excerpts

attached hereto as Exhibit H. At page 28, lines 4 to page 29, line 6. Mr. Bordin

testified in that response to Ms. Glatt’s question that his signature is 0n the

Verification to his response. The questions by Ms. Glatt and responses by Mr. Bordin
OLOOONOUO‘l-PQDNA

are as follows:

“Q. These are your first set of responses and these are your second.
So the first time you responded, and I’m showing him with the
verification, was May 21St, 2018; is that correct?
A. Yes.
Q. And that is your signature?
A. Yes.
Q. That states you’re a party to this matter?
A. Yes.
Q. That states you’re familiar with the documents?
A. Yes.
Q. And that those answers are true, to the best of your knowledge?
A. Yes.
Q. So these are the supplemental responses. Is that your
signature?
A. Yes.
th
end that supplemental response is dated September 13 2018?
2. ,

. es.
Q. So you met with your attorney? And I’m not asking for the
contents of the conversation, I’m asking you, you met with your
attorney and signed these documents; correct?
A. Yes.
Q. Did you review the information prior to signing the documents
that are contained here?
A. Yes.”
NNNNNNNNNAAAAAAAAAA

mVOUU‘l-POON—‘OQWNOUU‘I-POONA

16. Whereas Ms. Glatt misrepresents to this Court in her Brief that

“Plaintiffs learned that Mr. Newcomb did not represent Mr. Bordin or Mr. Martinez

personally, and that neither understand the cross-claim for alleged recordings was in

their individual capacity. (Glatt Dec., Mengarelli Dec.).” Thus, Ms. Glatt wrote that

Mr. Mengarelli made the identical representation to this Court. Mr. Mengarelli was at

Mr. Bordin’s deposition on October 16, 2018. See page 2 of the 10/16/2018

Deposition Transcript attached hereto as Exhibit H.

17. Now, when we compare the testimony of Mr. Bordin in response to Ms.

Glatt’s question and Mr. Bordin’s testimony, we learn the true facts are as follows at

DECLARATION OF BRIAN W. NEWCOMB IN OPPOSITION TO PLAINTIFF SQUIRES MOTION
FOR TERMINATING SANCTIONS
page 34, lines 4 to 14 of Mr. Bordin’s Deposition Transcript of his October 16, 2018

deposition taken by April Glatt attached excerpts attached as Exhibit H.
nn

Q. this your firstlawsuit?
{Ees.
Do you know why you’re suing Matt and Nikki?
p>p>p> Recordings, illegally being recorded.
What were you illegally recorded about?
OLOOONOUO‘l-PQDNA Anything that |spoke about 0n that property.
Anything? So tell me about what you spoke about on that
property.
> | spoke about the project, |spoke about - - |couldn’t recall allthe
conversations that |had while being at their property.”

18. These examples of factual misrepresentations are not isolated

occurrences in the moving papers filed by Squires’ counsel.

19. Ms. Glatt presented to this Court the representation to this Court that

Mr. Bordin’s testimony at the last deposition 0n June 28, 2019 (Exhibit I) as follows:

“Bordin also testified that, while he worked for RCWC, he created a
form to use to document change orders. (Id. at 1113). According to
Bordin, he would ‘handwrite out’ change orders for this project on this
form and give it to Wehmeyer, who would then keep it. (Id. 1113.)
Bordin testified that he also kept information about the project in a
notebook, which he left in his desk when he stopped working for
RCWC. (Id. at 1113.) Bordin testified that he last remembered seeing
the notebook in November 2018 and that Wehmeyer knew about it.

(|d.)” Page 5 of Brief authored by Ms. Glatt, lines 1-7.

20. Mr. Bordin’s prior testimony under oath at his deposition on October 16,

2018, before
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losing his job at R.C. Wehmeyer Construction Inc. in response to Ms.
mVOUU‘l-POON—‘OQWNOUU‘I-POONA

Glatt’s question is the opposite of Mr. Bordin’s testimony referenced in Ms. Glatt’s

Brief, where she refers to Mr. Bordin’s deposition of June 28, 2019. Squires’ counsel

gives the source on “P. 13” which is not a deposition reference, itis simply 1113 in her

Declaration.

21. Mr. Bordin in response to questions by Ms. Glatt in his deposition on

October 16, 2019, Ms. Glatt did not inform the Court of the facts stated by Mr. Bordin

on October 16, 2019, when perhaps his memory was better because itwas a year

closer in time approximately to the job.

22. Ms. Glatt in examining Mr. Bordin on October 16, 2019, asked Mr.

DECLARATION OF BRIAN W. NEWCOMB IN OPPOSITION TO PLAINTIFF SQUIRES MOTION
FOR TERMINATING SANCTIONS
Bordin the following to which he replied:

“Q. Did you ever put in writing a change order?
p> Me, personally, no.
Do you know of any change orders ever put in writing by anyone
during the course of the project?
es.
Who did that?
>p>p>
OCDmNODO‘l-bOJN-A
Rob.
Did you ever see them?
No.”

Page 44 of Mr. Bordin’s Deposition, lines 5-13, October 16, 2019, attached

hereto as Exhibit H.

23. Please note that Mr. Bordin’s reply indicates he never saw a change

order. Mr. Wehmeyer has stated consistently and does so in his Declaration filed

herein he does not do change orders on anyjob, he liststhe change as a line item on

the

Dated:
bi—weekly

paragraph 21at

September
bill

page
to

/((
8.
the

2019
homeowner

Brian

Custom
American
W.
Attorney for
R.C.
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with

Newcomb

Homes,
the

Defendants
W
Wehmeyer Construction,
Robert
Contractors
price.

and

C.
M Wehmeyer

Cross-Complainants

Indemnity
|nc.,

Wehmeyer,
Declaration,

dba Wehmeyer
Defendants
Company and
Robert C. Wehmeyer Design, Inc.
NNNNNNNNNAAAAAAAAAA

mNO701#CDN—‘OCOQNODU1LO9N—\

CKICIVISQUIRESVS.WEHMEYER/BWNDecOppMotTermSanctions.09.1 9(AFC&BWN)
6. 1

DECLARATION OF BRIAN W. NEWCOMB IN OPPOSITION TO PLAINTIFF SQUIRES MOTION
FOR TERMINATING SANCTIONS
Exhibit
Exhibit A
BRIAN W‘ NEWCOMB, C.S.B. #55156
ATTORNEY AT LAW
770 MENLO AVENUE, SUITE 101
MENLO PARK, CA 94025
TEL: 650 3227780
FAX: 650 322~7740
EMAIL: brianwnewcomb@gmail.com
(O&NOUUT-b-ODN—X

Attorney for Defendants and Cross-Complainants
R.C. Wehmeyer Construction, |nc., dba Wehmeyer
Custom Homes, Robert C. Wehmeyer, Cross-
Complainants Jeffrey Bordin, Gregorio Martinez
and Defendant American Contractors Indemnity
Companv

SUPERIOR COURT OF THE STATE OF CALIFORNlA
IN AND FOR THE COUNTY OF SAN MATEO
MATTHEW SQUIRES; NICOLE Case No. 18 CIV 00846
SQUIRES, [Unlimited Jurisdiction]

vs.
Plaintiffs, CROSS-COMPLAINANT JEFFREY
BORDIN’S
SQUIRES’
RESPONSE TO
FIRST FORM
WE
Mﬁ77/VW
INTERROGATORIES
R.C. WEHMEYER CONSTRUCTION,
INC., dba WEHMEYER
CONSTRUCTION HOMES; ROBERT C.
WEHMEYER, an individual; AMERICAN
CONTRACTORS INDEMNITY
COMPANY; and DOES 1 through 20,
inclusive,

Defendants;
mVGJCh-booN-A.O(OOONO301-hOON—XO

NNNNNMNNNAAAAAAAAAA

RC. WEHMEYER CONSTRUCTION,
INC., dba WEHMEYER CUSTOM
HOMES; ROBERT C.~WEHMEYER;
JEFFREY BORDIN; and GREGORIO
MARTINEZ,
Cross-Complainants,

vs.

MATTHEW SQUIRES; NICOLE
SQUIRES; and ROES 1 -
10,

Cross—Defendants.

///

CRoss-COMPLAINANT JEFFREY BORDIN’S RESPONSE To NICOLWQ
‘ ‘WW“’
FIRST FORM INTERROGATORIES
RESPONDING PARTY: Cross—Compiainant Jeffrey Bordin.

PROPOUNDING PARTY: Plaintiff and Cross-Defendant Nicoie Squires.

SET NUMBER: One.

TO: Plaintiff and Cross-Defendant Nicole Squires AND TO HER
ATTORNEYS
(DmNODU'i-bOONA
OF RECORD Michael Mengarelli of Kelly Litigation Group and April S.

Glatt of Chauvel & Glatt LLP.

Jeffrey Bordin hereby provides Responses to Nicole Squires’ First Form

lnterrogatories served on April 10, 2018 as follows:

GENERAL OBJECTION
Jeffrey Bordin is engaged in continuing discovery in this case. Therefore, alt

the answers contained herein are based upon such information and documents as

are presently available and known t0 Jeffrey Bordin and discloses only those

contentions which presently occur to him. There are potential witnesses which have

not been deposed, documents which have not been reviewed or obtained, analysis

which has not been completed, and other discovery and investigation which has not

been finished. Discovery and investigation are continuing. Jeffrey Bordin therefore

provides the following Responses to Nicole Squires First Form lnterrogatories without

prejudice to present at trialfurther documentary or oral evidence or analysis not yet

obtained
NNNNNNNNNAAAAAAAAAA
or completed.
mNODU'I-hOJN-AOCDmNCJUT-hOJN-Ao

The Responses are made solely for the purpose of and in relation to this

action. Each answer is given subject to all appropriate objections (including, but not

iimited to, objections of competency, relevancy, materiality, propriety, and

admissibility) which would require the exclusion of any statement contained herein if

the Interrogatory were asked of, or any statement contained herein were made by, a

witness present and testifying in court. AH such objections and ground therefore are

reserved and may be interposed at the time of trial. Except for facts explicitly

admitted herein, no admission "of
any nature whatsoever is to be implied or inferred.

The fact that any Interrogatory herein has been answered should not be taken as an

CROSS»COMPLAINANT JEFFREY BORDIN’S RESPONSE TO NICOLE SQUIRES’
FIRST FORM INTERROGATORIES
admission or a concession of the existence of any fact set forth or assumed by each

interrogatory, nor that such answer constitutes evidence of any fact thus set forth or

assumed. All answers must be construed as given on the basis of present

fecollection.

The fact that Jeffrey Bordin has responded to part or all of any Interrogatory is
(OOO'NIODU‘l-PCDNA

not intended and shall not be construed to be a waiver by him of all or any part of any

objection to any lnterrogatory.

RESPONSES
Response to Form Interrogatorv (hereinafter “FI”) No. 1.1:

Brian W. Newcomb, 770 Menlo Ave., Ste. 101, Menlo Park, CA 94205.
Response to Fl No. 2.1 La):

Jeffrey Bordin.

Response to Fl No. 2.2:

Objection, my age isirrelevant t0 the subject matter of this action.

Response to Fl No. 2.3 (aHdL
Objection, this is not an auto accident, my driver’s license and whether I am
licensed is irrelevant to the subject matter of this action.

Response to Fl No. 2.5 (chL
can be contacted
mVQO‘I-bODN-AOCOWNCJU‘lﬁQJN—AO

I
NNNNNNNNNAAAAAAAAAA through Brian W. Newcomb, Attorney at Law, 770 Menlo

Ave., Ste. 101, Menlo Park, CA 94025.
Response to Fl No. 2.6 (ath
Robert C. Wehmeyer Construction, Inc. I have been with Robert C.

Wehmeyer Construction, Inc. for approximately one (1) year.

Response to Fl No. 2.7 La)-(d):

My education, ifany, is irrelevant to the subject matter of this action.

Response to Fl No. 2.8 (aHd):

No.

///

CROSS—COMPLAINANT JEFFREY BORDIN’S RESPONSE TO NICOLE SQUIRES’
FIRST FORM iNTERROGATORlES
Response to Fl No. 2‘9:

Yes.

Response to Fl No. 5‘10:

Yes.

Response
COOONODU‘I-bOON—X
to Fl No. 2.11 (aHb):

At time of the INCIDENT, I was employed by Robert C. Wehmeyer
Construction, Inc. and working on the Squires house in the course of a remodel.

Response to Fl No. 2.12 (ch):
No.

Response to Fl No. 2.13 (qu):
No.

Response to Fl No. 4.1 (aHg):

Not to my knowledge.

Response to Fl No. 4.2:

No.

Response to Fl No. 6.1 :

No.

Responsé to Fl No. 6.2:

No
NNNNMNNNNAAAAAAAAAA
part of my body affected the Cross—Defendants violation my rights of

privacy and Penal
OO‘QODO‘IbODN—kocom'ﬁmm-th—XO
Code § 632.

Response to Fl No. 6.34a)-ﬁ:):

Inever had any complaints regarding physical injuries caused by the violation

of my rights of privacy.

Resmnse to Fl No. 6.4LaHd):

No.

Response to Fl No. aﬂal-Le):

N0.

Case Info

Judge

Chou, Danny Y. Track Judge’s New Case

Case No.

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Document Filed Date

September 16, 2019

Case Filing Date

February 20, 2018

County

Parties

AMERCIAN CONTRACTORS INDEMNITY COMPANY Defendant
BORDIN, JEFFREY Cross Complainant
DOES 1 THROUGH 20, INCLUSIVE Defendant
LINN, PETER J. Attorneys for Plaintiffs
MARTINEZ, GREGORIO Cross Complainant
MENGARELLI, MICHAEL Attorney
MENGARELLI, MICHAEL Attorney for the Plaintiff
MONARCA ROOFERS, INC Cross Defendant
NEWCOMB, BRIAN W. Attorney
NEWCOMB, BRIAN W. Attorney for the Defendant
R.C. WEHMEYER CONSTRUCTION, INC. Cross Complainant
R.C. WEHMEYER CONSTRUCTION, INC. Defendant
ROBERT C. WEHMEYER DESIGN, INC. Defendant
ROES 1 THROUGH 10 Cross Defendant
SQUIRES, MATTHEW Cross Defendant
SQUIRES, MATTHEW Plaintiff
SQUIRES, NICOLE Cross Defendant
SQUIRES, NICOLE Plaintiff
WEHMEYER, ROBERT C. Cross Complainant
WEHMEYER, ROBERT C. Defendant
ZOES 1 THROUGH 10, INCLUSIVE Cross Defendant
April Glatt Attorneys for Plaintiffs
Richard Kelly Attorney
John Hedger Attorney
Albert Finch Attorney
Ian Wilson Attorneys for Defendants
Thomas Walsh Attorneys for Plaintiffs
Cecil Hedger Attorneys for Defendants
Michael Mengoli Attorneys for Plaintiffs
April Gilbert Attorney
Thomas Jones Attorneys for Plaintiffs
Richard Wehmeyer Attorney
Michael Megan Attorney
Robert Kelly Attorneys for Plaintiffs
James Walsh Attorneys for Plaintiffs
Tracy Walsh Attorney
Lance Wilson Attorney
Albert Moorman Attorney
Eric Hove Attorney
Reginaldo Villarreal Attorneys for Defendants

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Motion-Secondary: MATTHEW SQUIRES, et al vs. R.C. WEHMEYER CONSTRUCTION, INC., et al

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Parties