Preview
ELECTRONICALLY FILED
superior Court of California,
LYLE D.
County of Placer
SOLOMON, ESQ. (SBN 226025)
—
P.O. Box 1411 10/26/2020
Rocklin, California By: Olivia Lucatuorto, Deputy Clerk
95677
Lp
(916) 532-2726
W
Attorney for Defendant/Cross-Complainant Russell Tarver in limited scope
BP
SUPERIOR COURT OF THE STATE OF CALIFORNIA
DW
FOR THE COUNTY OF PLACER
ON
TED ARTHUR KING ) Case No. SCV 0042357
Plaintiff )
So
)
V. ) DECLARATION OF LYLE D. SOLOMON
)
8
IN SUPPORT OF DEFENDANT/CROSS-
) COMPLAINANT RUSSELL
RUSSELL LEE TARVER TARVER
LD
) MOTIONS IN LIMINE
)
LW
Defendant. )
) Trial Date: | November 2, 2020
DW
) Time: 8:30 AM
And related cross-actions ) Dept: TBA
Bw
)
)
ew
)
)
)
ee
)
I,LYLE D. SOLOMON, declare:
ee
i I am an attorney licensed to practice in all the courts of the state of California and
the attorney, of record for Defendant/Cross-Complainant Russell Tarver, in this action.
RY
2 If called to testify, Icould truthfully testify, of my personal knowledge of the
matters set
RB
forth herein.
3.
SB
This Declaration ismade in support of Defendant’s Motion in Limine to Exclude all
evidence, tangible
RP
things, witnesses and documents not produced or identified during discovery. .
4, Attached as Exhibit “1” isa true and correct copy of Special Interrogatories, Set
One served on Plaintiff Ted A. King.
bo
cs Attached as Exhibit “2” isa true and correct copy of Form Interrogatories, Set
One served on Plaintiff Ted A. King.
6. Attached as Exhibit “3” is a true and correct copy of Request For Production of
Documents, Set One served on Plaintiff
pw
Ted A. King.
7. Attached as Exhibit
wW
“4” isa true and correct copy of Request For Admissions,
Dn
Set
One served on Plaintiff Ted A. King.
B
8. Attached as Exhibit “5” isa true and correct copy of Special Interrogatories, Set
Two served on Plaintiff Ted A. King.
9. Attached as
NA
Exhibit “6” isa true and correct copy of Defendant’s Motions to
Compel Responses to Discovery dated October 2, 2019.
10. Attached as Exhibit “7” is a true and correct copy of Defendant’s Motions to
10 Compel Responses to Discovery dated J anuary 7,,2020.
11 Il. Attached as Exhibit “8” isa true and correct copy of Plaintiff's Response to
12 Request for Admissions, dated April 13, 2020.
13 12. Attached as Exhibit “9” isa true and correct copy of Plaintiffs Response to
14 Request for Production of Documents, dated April 13, 2020.
15 13. Attached as Exhibit “10” is a true and correct copy of Plaintiff's Response to
16 Special Interrogatories Set, One, dated April 3, 2020.
17 14. Attached as Exhibit “11” is atrue and correct copy of Plaintiff's Response to
18 Special Interrogatories Set, Two, dated April 3, 2020.
19 15. Attached as Exhibit “12" is the Court’s ruling on Defendant’s Motion to Compel
20 Discovery Responses dated November 22, 2019,
21 16. Attached as Exhibit “13" is the Court’s ruling on Defendant’s Motion to Compel
22 Discovery Responses dated March 2, 2020.
23 I declare under penalty of perjury under the laws of the State of California that the
24 foregoing is true and corrected.
25 Executed on the 26" day of October, 2020 atRocklin, California.
26
27
PROOF OF SERVICE
{CCP §§ 1013; 2015.5}
wv
I,the undersigned, declare that:
WwW
Tam employed in the County of Placer, over
within above
the age of 18 years, and not a party to the
entitled
KR
action, My address is P.O. Box 1411 Rock
written below, I served lin, CA 9567 7. On’'the date
the document(s) shown below:
ww
DECLARATION
DH
OF LYLE D. SOLOMON IN SUPPORT
COMPLAINANT OF DEF ENDANT/CROSS-
RUSSELL TARVER MOTIONS IN LIMINE
N
[X] Via United States Postal Service. By depositing this piece of mail, properly
Express, overnight delivery, postage addressed with
attached, with the Unit ed States Postal
same date as is indicated below), a Service on the
true copy thereof enclosed in a sealed
postage thereon fully prepaid to the envelope with
10 address shown below.
11 [ ] By Personal Delivery. By causing a true
parties copy thereof to be personally delivered
or persons or with the rece to the
12 addressee(s) enclosed in a sealed
ptio nist
envelope
or person havi ng char ge of the prem ises of the
at the address shown below.
13
Ted A.King
14 8016 Dicus Court
Citrus Heights, CA
15 95621
16 Ideclare under penalty of perjury under the laws
istrue and correct
of the State of California that the foregoing
and that this declaration
17 below.
was executed atRock lin, Cali fornia on the date given
18
19 DATED: _/ 9 lrufre Shed. Lora
20
21
22
23
24
25
26
27
28
EXHIBIT “1”
RUSSELL TARVER
4324 Kenneth
Fair Avenue
Oaks, CA
(916) 95628
532-8948
Defendant
In Pro Per
SUPERIOR
COURT OF CALIFORNI
A
COUNTY or PLACER
10 | TED ARTHUR KING;
)
I Plaintift,
. . ) Case No, Case No. Scy 0042357
12
)
)
vs, SPECIAL INTERROGATORIKS
'3 11 RUSSELL )
LEE TARVER, )
Defendant [CCP 2030.010)
14 | )
ee / )
And related First Amended )
Cross-Complaint
}
2, )
ee J
PROPOUNDI )
NG PARTY: Defendant, RUSSELL
RESPONDIN LEE T. ARVER
G PARTY.
Plaintiff, TED
SET NUMBER: ARTHUR KING
ONE (1)
Code of Ciyi] Procedure
§ 2030.220 requires that (a)
SpecialInterrogatories
Page |
7/23/2019
A\
ak: 95
(916) 532-8948
Defendant
In Pro Per
Ss UPERIOR
COURT OF CALIFORNI
A
COUNTY or PLAC ER
TED ARTH UR KING,
Plaintiff, Case No, Case No, SCV 0042357
Vs,
SPECIAL
INTERROG
RUSSELL LEE
ATORIKS
TARVER .
—. Defendant (Ccp § 2030.010)
———___
PROPOUND
ING PARTY:
Defendant,
RESPONDIN RUSSELL.
G PARTY: I, EE T. ARVER
Plaintiff TED
SET NUMBER: ARTH UR KING
ONE (1)
% +3
ode of Civil Procedure
§ 2030.229
forward Tequires that
as the informa (a)
tion reasonably
a vallable to the
te
I
Clearly in the response,
Se
shall If an objection
be clearly stated, ig based on a claim
I¢ an objection of Privilege,
is based on a cl the Particular
010 aim th
at the in Privilege invoke
i formation Sought q
isprotected Wor
The plaintiff js
the entitled to pre-trial
subject matter of discovery Proceedings
the Co mplaint. to seek
0 her ine] uding Th e re
s ondi
ng information directly
information fr part In ust furnis relevant to
ffort. See Deyo
om Sources unde h all in format io
y, Kilbourne r her Control that n that is available
(1979) g4 can be ascertained
Cal.App.3d 771, with reasonable
781; Code of Civil Procedure § 2030.010,
DR
S ES
FLIANL
ITTIIO
ONNS
S
2. As used herein, the term “writings” shal] have the
Code Section same meaning
253, as defined in Eviden
3. As used herein, the term “yoy” Shall refer to Plaintiff,
Tepresentative their attorney,
s, and anyone agents,
retained employees
to assist jn
complainant’s the furtherance
claims in this lawsuit,
of Defendant/Cros
g,
4. As used herein, the term “identify” in reference toa writing shal] mean to state: (1) the typ
21
22
SPECIAL INTERROGAT
23 ORIES
AL INTERROGAT
ORY No, 1:
24 Describe in detail the basis of your claim that RUSSELL
25 On the 1965 LEE TAR VER
Ford Thunderbird owes you money
owned by TARVER, for your wor!
SPEC IAL INTERROGATORY
No, 2;
‘|SpecialInterrogatories
Page 2
7/23/2019
SPECIAL INTERROGATORY
No, 3:
regain possession of his vehicle from the tow
SPE CIAL
mee, INTERROGATORY
yard,
NO. 4:
If you are you still on Probation or Parole for any
County of the criminal
or Placer County, Convictions you
give all details have in Sacrament
of the conv iction
will get off Probation and the nature
or Parole, of each crime and when you
SPECIAL INTERROGATORY
Please list
NO,, 5:
allfelonies you have been Convicted for in the Past 10 years, the nature of the felony, whethe:
State how much money RUSSELL TARVER Provided
by Jason Butler, to you for the Release of the 2015 Subaru owne
SPECIAL INTERROGATORY
NO. 7:
State in total how much money RUSSELL TARVER put up
the 2015 Subaru for all costs regarding
of Jason Butler, obtaining POssessior
SPECIAL INTERROGAT
ORY NO. 8;
State in detail your agreement with RUSSELL TARVER
sale of the 2015 concerning obtaining
Subaru, title and Ownership anc
SPECIAL INTERROGAT
ORY NO. 9;
Describe in detail all of the discussions you had with Jason
2015 Subaru. Butler regarding obtaining Possession of th
SPECIAL INTERROGAT
ORY NO. 10:
How were the Profits of the 2015 Subaru Supposed to be split?
SPECIAL IN TERROGATORY
No, 11:
Where was Jason Butler at the time you had the discussions with Jason Butler Tegarding his 2015
SpecialIntetrogatories
Page 3
7123/2019
AS
SPECIAL INTERROGA TORY NO. 12;
What was your understanding
of t hemedical
3 || the condition of Jason
discussions regarding Butler in December
his 2015 Subaru? 2018 When you hac
4 1/SPEC TAL ,
INTERROGA
TORY NO. 13:
If Jason Butler paid You to regain his Possession
you? of his 2015 Subaru, how much did Jason Butler pa
SPECIAL INTERROGATORY
No, 14:
Why didn’t you pay RUSSELL TA
for his expenses he laid out to get p
SPECIAL INTERROGAT
ORY NO. 15;
Were you on probation or Parole whi
14 ||SPECIAL when
INTERROGATO you moved
RY NO. 17
; out.
'S |! Did RUSSELL TARVER ever ask you to Pay additional
'6 |} tohis property? rent money for bringing in additional
. vehicle:
SPECIAL INTERROGATORY
No, 18:
Did RUSSELL TARVER ever ask
SPECIAL INTERROGATOR RVER evicted
Y NO. you.
20:
State any and allwitnesses’ names of who heard that
SPECIA, TARVER 8ave
L INTERROGATO you an ev iction
RY NeO.mt notice,
21
:
SK
Why did you leave the scene at 2101 March Road Roseville
2018? before the police arrived on December 8
//
SpecialInterrogatories
Page 4
7123/2019
ry
SPECIAL INTERROGATOR
Y NO. 22;
State how much money you Teceived from Jason Butler
SPECIAL INTERROGAT When You sold it back to
ORY NO, 23:
him.
What was the date that you sold Or returned the 2015
SPI EC IAL Subaru back to Jas ‘on
INTERROGAT Butler?
ORY NO. 24:
Describe what the charges Were against you for the conviction
Were out on that you
Parole in 2012, had when you were released arid
SPE ‘C IAL INTERROGA
TORY NO, 25;
Describe in detail] any and all restrict;
released from incarceration
and whi
SPECIAL INTERROGATOR
Y NO. 26:
Describe in detai] why you have alle
Which date and describe the circumst
SPECIAL TERROGAT
ORY No, 27:
Dated: JU Ly 4 » 2019
Kiet Zee Ty At
RUSSE |
25
LL LEE TARVER
27
28
SpecialInterrogatories
Page 5
7/23/2019
|
—_—
PROOF OF SERVICE
(C.C.P. Sections 1005, 1013a, 2015.5)
age of eighteen
Ifa
and am nota
On the following Way, Roseville,
Postage date, Ise ved, CA
fully Pre-paid by depositing in
the following the U.S, Mail,
document s: ina sealed envelope;
Defendant’s Special] Interrogatories to Plaintiff TED KING
on the parties to the action addressed as follows:
TED ARTHUR KING
P.O. Box 982
Roseville, CA 95678
Signed under penalty
July 23, of perjury under
2019 in Citr us Heights, the laws of the
CA, State of California, on
Proof of Service
Page |
7123/2019
AD
SUPERIOR
COURT OF CALIFORNI
A
9 COUNTy
OF PLA CER
TED ARTHUR KING,
, )
Plaintiff, )
)
Case No, Case No, SCV 0042357
vs, }) SPECIAL INTERROGATOR
RUSSELL
LEE TA ) IE S
oo RVER,
Defendant ) [CCP § 2939
, ) 010)
And related First ‘
Amended Cross-Compl
aint
;
a )
eee )
PROPOUNDI )
NG PARTY: Defendant, RUSSELL
RESPONDIN LEE
G PARTY: T, ARVER
Plaintite, TED
SET NUMBER: ARTHUR KING
ONE (1)
Code of Civil Procedure §
and Straightforw 2030.220 requires
ard as the that (a) “Each
information answer
Teasonably in the response
available to shall be
the Tesponding a
Party permits
24 Propounding
Party,” Cap
objectionable, § 2030.240
28 the re mainder Tequires that
interrogatory of the interrogatory (a) “If only
OF to a part Shal
l a Part of
of an interrogatory, be answered, an interrogatory
the specific (b) If an obje i
8round ction js mad
for the objection e to a
shal] be set
SpecialInterrogatorie
s
fort
Page |
7/23/2019
A |
EXHIBIT “2”
i
ATTORNEYOR PARTY
RUSSELL WITHOUT
LEE ATTORNEY
TARVER (Name,State
Barnumber,
andaddress):
°
--In Pro Per
4324 Kenneth Avenue
Fair Oaks, CA.9
628
TELEPHONENO: (9] 2-8948
FAX NO.(Optional):
E-MAIL
ADDRESS (Optional):
ATTORNEYFOR (Name): Russell Lee Tarver, Defendant and Cross-complainant
SUPERIOR COURT OF CALIFORNIA, COUNTY OF PLACER
Bill Santucci Justice Center
SHORT TITLE OF CASE:
Tarver v. King
FORM INTERROGATORIES—GENERA
Asking Party: RUSSELL L CASE NUMBER:
LEE TARVER
Answering Party: TED ARTHUR KING SCV 0042357
Set No.: ONE
Sec. 1. Instructions to All Parties
(a) Interrogatoriesarewritten questions prepared by aparty
to an actionthatare sent to any other partyin theaction
answered under oath. tobe
The interrogatoriesbelow are
interrogatoriesapproved form
foruse in civil
cases.
(b) For time limitations,
requirements
Parties, for serviceon other (d) If youdo
and other details,see Code not have enough personal knowledge
ofCivilProcedure answer to fully
sections 2030.010-2030.410 an interrogatory,Say so,but
and the cases construing those good make areasonable and
sect
ions. faithefforttoget the information
Or by asking other persons
(c) These organizations, unless the information
form interrogatoriesdo isequally available
not change existinglaw theasking party. to
relatingtointerrogatoriesnor do they affectan answering
party'srighttoassert any (e) Whenever an interrogatory
privilegeor make any objection. may be answered by
referringto a document, thedocument
Sec. 2. Instructions to the exhibit may be attached as an
Asking Party to the response and referred
(a) These to inthe response. If the
interrogatories
are designed for document has more than one
Parties optional use by page, refer tothe page and
in unlimitedcivil
cases where the section where the answer
exce
amount demanded to theinterrogatory can be found.
eds $25,000. Separate interrogatories,
Form (f) Whenever an address
Interrogatories—-Limited and telephone number for
CivilCases (Economic Litigation) Same person are requested
the
(formDISC-004), which have inmore than one interrogatory,
no subparts, aredesigned for you are required tofurnish
use inlimitedcivil
cases them in answering onlythe first
where the amount demanded is interrogatoryasking for
$25,000 or less; that information.
however, those interrogatories (g) If
used inunlimited may also be you are asserting a privilegeor
civilcases. making an objection to
an interrogatory,
you must specifically
(b) Check the box next to each assert theprivilegeor
interrogatorythat you want State the objectionin yourwritten
the answering party toanswer. response.
Use care in choosing those (h)
interrogatoriesthatare applicable
Your answers to these interrogatories
tothe case, dated, must be verified,
(c) You may insert and signed. You may wish touse
your own definition
of INCIDENT the followingform at
Section 4, butonly in the end of your answers:
where theaction arisesfrom a
Conduct course of ! declare
or a seriesof events Occurring over under penalty of perjury under
aperiod of time. State of California the laws ofthe
(d) The interrogatoriesinsection that the foregoing answers
16.0,Defendant's correct. are true and
Contentions--Personal Injury,should not be used until
the
defendant has had a reasonable Opportunity toconduct an
investigation
or discovery of plaintiff's (DATE)
injuriesand damages. (SIGNATURE)
(e) Additionalinterrogatoriesmay be attached. Sec. 4. Definitions
Sec. 3. Instructions to the Answering
Preview
ELECTRONICALLY FILED superior Court of California, LYLE D. County of Placer SOLOMON, ESQ. (SBN 226025) — P.O. Box 1411 10/26/2020 Rocklin, California By: Olivia Lucatuorto, Deputy Clerk 95677 Lp (916) 532-2726 W Attorney for Defendant/Cross-Complainant Russell Tarver in limited scope BP SUPERIOR COURT OF THE STATE OF CALIFORNIA DW FOR THE COUNTY OF PLACER ON TED ARTHUR KING ) Case No. SCV 0042357 Plaintiff ) So ) V. ) DECLARATION OF LYLE D. SOLOMON ) 8 IN SUPPORT OF DEFENDANT/CROSS- ) COMPLAINANT RUSSELL RUSSELL LEE TARVER TARVER LD ) MOTIONS IN LIMINE ) LW Defendant. ) ) Trial Date: | November 2, 2020 DW ) Time: 8:30 AM And related cross-actions ) Dept: TBA Bw ) ) ew ) ) ) ee ) I,LYLE D. SOLOMON, declare: ee i I am an attorney licensed to practice in all the courts of the state of California and the attorney, of record for Defendant/Cross-Complainant Russell Tarver, in this action. RY 2 If called to testify, Icould truthfully testify, of my personal knowledge of the matters set RB forth herein. 3. SB This Declaration ismade in support of Defendant’s Motion in Limine to Exclude all evidence, tangible RP things, witnesses and documents not produced or identified during discovery. . 4, Attached as Exhibit “1” isa true and correct copy of Special Interrogatories, Set One served on Plaintiff Ted A. King. bo cs Attached as Exhibit “2” isa true and correct copy of Form Interrogatories, Set One served on Plaintiff Ted A. King. 6. Attached as Exhibit “3” is a true and correct copy of Request For Production of Documents, Set One served on Plaintiff pw Ted A. King. 7. Attached as Exhibit wW “4” isa true and correct copy of Request For Admissions, Dn Set One served on Plaintiff Ted A. King. B 8. Attached as Exhibit “5” isa true and correct copy of Special Interrogatories, Set Two served on Plaintiff Ted A. King. 9. Attached as NA Exhibit “6” isa true and correct copy of Defendant’s Motions to Compel Responses to Discovery dated October 2, 2019. 10. Attached as Exhibit “7” is a true and correct copy of Defendant’s Motions to 10 Compel Responses to Discovery dated J anuary 7,,2020. 11 Il. Attached as Exhibit “8” isa true and correct copy of Plaintiff's Response to 12 Request for Admissions, dated April 13, 2020. 13 12. Attached as Exhibit “9” isa true and correct copy of Plaintiffs Response to 14 Request for Production of Documents, dated April 13, 2020. 15 13. Attached as Exhibit “10” is a true and correct copy of Plaintiff's Response to 16 Special Interrogatories Set, One, dated April 3, 2020. 17 14. Attached as Exhibit “11” is atrue and correct copy of Plaintiff's Response to 18 Special Interrogatories Set, Two, dated April 3, 2020. 19 15. Attached as Exhibit “12" is the Court’s ruling on Defendant’s Motion to Compel 20 Discovery Responses dated November 22, 2019, 21 16. Attached as Exhibit “13" is the Court’s ruling on Defendant’s Motion to Compel 22 Discovery Responses dated March 2, 2020. 23 I declare under penalty of perjury under the laws of the State of California that the 24 foregoing is true and corrected. 25 Executed on the 26" day of October, 2020 atRocklin, California. 26 27 PROOF OF SERVICE {CCP §§ 1013; 2015.5} wv I,the undersigned, declare that: WwW Tam employed in the County of Placer, over within above the age of 18 years, and not a party to the entitled KR action, My address is P.O. Box 1411 Rock written below, I served lin, CA 9567 7. On’'the date the document(s) shown below: ww DECLARATION DH OF LYLE D. SOLOMON IN SUPPORT COMPLAINANT OF DEF ENDANT/CROSS- RUSSELL TARVER MOTIONS IN LIMINE N [X] Via United States Postal Service. By depositing this piece of mail, properly Express, overnight delivery, postage addressed with attached, with the Unit ed States Postal same date as is indicated below), a Service on the true copy thereof enclosed in a sealed postage thereon fully prepaid to the envelope with 10 address shown below. 11 [ ] By Personal Delivery. By causing a true parties copy thereof to be personally delivered or persons or with the rece to the 12 addressee(s) enclosed in a sealed ptio nist envelope or person havi ng char ge of the prem ises of the at the address shown below. 13 Ted A.King 14 8016 Dicus Court Citrus Heights, CA 15 95621 16 Ideclare under penalty of perjury under the laws istrue and correct of the State of California that the foregoing and that this declaration 17 below. was executed atRock lin, Cali fornia on the date given 18 19 DATED: _/ 9 lrufre Shed. Lora 20 21 22 23 24 25 26 27 28 EXHIBIT “1” RUSSELL TARVER 4324 Kenneth Fair Avenue Oaks, CA (916) 95628 532-8948 Defendant In Pro Per SUPERIOR COURT OF CALIFORNI A COUNTY or PLACER 10 | TED ARTHUR KING; ) I Plaintift, . . ) Case No, Case No. Scy 0042357 12 ) ) vs, SPECIAL INTERROGATORIKS '3 11 RUSSELL ) LEE TARVER, ) Defendant [CCP 2030.010) 14 | ) ee / ) And related First Amended ) Cross-Complaint } 2, ) ee J PROPOUNDI ) NG PARTY: Defendant, RUSSELL RESPONDIN LEE T. ARVER G PARTY. Plaintiff, TED SET NUMBER: ARTHUR KING ONE (1) Code of Ciyi] Procedure § 2030.220 requires that (a) SpecialInterrogatories Page | 7/23/2019 A\ ak: 95 (916) 532-8948 Defendant In Pro Per Ss UPERIOR COURT OF CALIFORNI A COUNTY or PLAC ER TED ARTH UR KING, Plaintiff, Case No, Case No, SCV 0042357 Vs, SPECIAL INTERROG RUSSELL LEE ATORIKS TARVER . —. Defendant (Ccp § 2030.010) ———___ PROPOUND ING PARTY: Defendant, RESPONDIN RUSSELL. G PARTY: I, EE T. ARVER Plaintiff TED SET NUMBER: ARTH UR KING ONE (1) % +3 ode of Civil Procedure § 2030.229 forward Tequires that as the informa (a) tion reasonably a vallable to the te I Clearly in the response, Se shall If an objection be clearly stated, ig based on a claim I¢ an objection of Privilege, is based on a cl the Particular 010 aim th at the in Privilege invoke i formation Sought q isprotected Wor The plaintiff js the entitled to pre-trial subject matter of discovery Proceedings the Co mplaint. to seek 0 her ine] uding Th e re s ondi ng information directly information fr part In ust furnis relevant to ffort. See Deyo om Sources unde h all in format io y, Kilbourne r her Control that n that is available (1979) g4 can be ascertained Cal.App.3d 771, with reasonable 781; Code of Civil Procedure § 2030.010, DR S ES FLIANL ITTIIO ONNS S 2. As used herein, the term “writings” shal] have the Code Section same meaning 253, as defined in Eviden 3. As used herein, the term “yoy” Shall refer to Plaintiff, Tepresentative their attorney, s, and anyone agents, retained employees to assist jn complainant’s the furtherance claims in this lawsuit, of Defendant/Cros g, 4. As used herein, the term “identify” in reference toa writing shal] mean to state: (1) the typ 21 22 SPECIAL INTERROGAT 23 ORIES AL INTERROGAT ORY No, 1: 24 Describe in detail the basis of your claim that RUSSELL 25 On the 1965 LEE TAR VER Ford Thunderbird owes you money owned by TARVER, for your wor! SPEC IAL INTERROGATORY No, 2; ‘|SpecialInterrogatories Page 2 7/23/2019 SPECIAL INTERROGATORY No, 3: regain possession of his vehicle from the tow SPE CIAL mee, INTERROGATORY yard, NO. 4: If you are you still on Probation or Parole for any County of the criminal or Placer County, Convictions you give all details have in Sacrament of the conv iction will get off Probation and the nature or Parole, of each crime and when you SPECIAL INTERROGATORY Please list NO,, 5: allfelonies you have been Convicted for in the Past 10 years, the nature of the felony, whethe: State how much money RUSSELL TARVER Provided by Jason Butler, to you for the Release of the 2015 Subaru owne SPECIAL INTERROGATORY NO. 7: State in total how much money RUSSELL TARVER put up the 2015 Subaru for all costs regarding of Jason Butler, obtaining POssessior SPECIAL INTERROGAT ORY NO. 8; State in detail your agreement with RUSSELL TARVER sale of the 2015 concerning obtaining Subaru, title and Ownership anc SPECIAL INTERROGAT ORY NO. 9; Describe in detail all of the discussions you had with Jason 2015 Subaru. Butler regarding obtaining Possession of th SPECIAL INTERROGAT ORY NO. 10: How were the Profits of the 2015 Subaru Supposed to be split? SPECIAL IN TERROGATORY No, 11: Where was Jason Butler at the time you had the discussions with Jason Butler Tegarding his 2015 SpecialIntetrogatories Page 3 7123/2019 AS SPECIAL INTERROGA TORY NO. 12; What was your understanding of t hemedical 3 || the condition of Jason discussions regarding Butler in December his 2015 Subaru? 2018 When you hac 4 1/SPEC TAL , INTERROGA TORY NO. 13: If Jason Butler paid You to regain his Possession you? of his 2015 Subaru, how much did Jason Butler pa SPECIAL INTERROGATORY No, 14: Why didn’t you pay RUSSELL TA for his expenses he laid out to get p SPECIAL INTERROGAT ORY NO. 15; Were you on probation or Parole whi 14 ||SPECIAL when INTERROGATO you moved RY NO. 17 ; out. 'S |! Did RUSSELL TARVER ever ask you to Pay additional '6 |} tohis property? rent money for bringing in additional . vehicle: SPECIAL INTERROGATORY No, 18: Did RUSSELL TARVER ever ask SPECIAL INTERROGATOR RVER evicted Y NO. you. 20: State any and allwitnesses’ names of who heard that SPECIA, TARVER 8ave L INTERROGATO you an ev iction RY NeO.mt notice, 21 : SK Why did you leave the scene at 2101 March Road Roseville 2018? before the police arrived on December 8 // SpecialInterrogatories Page 4 7123/2019 ry SPECIAL INTERROGATOR Y NO. 22; State how much money you Teceived from Jason Butler SPECIAL INTERROGAT When You sold it back to ORY NO, 23: him. What was the date that you sold Or returned the 2015 SPI EC IAL Subaru back to Jas ‘on INTERROGAT Butler? ORY NO. 24: Describe what the charges Were against you for the conviction Were out on that you Parole in 2012, had when you were released arid SPE ‘C IAL INTERROGA TORY NO, 25; Describe in detail] any and all restrict; released from incarceration and whi SPECIAL INTERROGATOR Y NO. 26: Describe in detai] why you have alle Which date and describe the circumst SPECIAL TERROGAT ORY No, 27: Dated: JU Ly 4 » 2019 Kiet Zee Ty At RUSSE | 25 LL LEE TARVER 27 28 SpecialInterrogatories Page 5 7/23/2019 | —_— PROOF OF SERVICE (C.C.P. Sections 1005, 1013a, 2015.5) age of eighteen Ifa and am nota On the following Way, Roseville, Postage date, Ise ved, CA fully Pre-paid by depositing in the following the U.S, Mail, document s: ina sealed envelope; Defendant’s Special] Interrogatories to Plaintiff TED KING on the parties to the action addressed as follows: TED ARTHUR KING P.O. Box 982 Roseville, CA 95678 Signed under penalty July 23, of perjury under 2019 in Citr us Heights, the laws of the CA, State of California, on Proof of Service Page | 7123/2019 AD SUPERIOR COURT OF CALIFORNI A 9 COUNTy OF PLA CER TED ARTHUR KING, , ) Plaintiff, ) ) Case No, Case No, SCV 0042357 vs, }) SPECIAL INTERROGATOR RUSSELL LEE TA ) IE S oo RVER, Defendant ) [CCP § 2939 , ) 010) And related First ‘ Amended Cross-Compl aint ; a ) eee ) PROPOUNDI ) NG PARTY: Defendant, RUSSELL RESPONDIN LEE G PARTY: T, ARVER Plaintite, TED SET NUMBER: ARTHUR KING ONE (1) Code of Civil Procedure § and Straightforw 2030.220 requires ard as the that (a) “Each information answer Teasonably in the response available to shall be the Tesponding a Party permits 24 Propounding Party,” Cap objectionable, § 2030.240 28 the re mainder Tequires that interrogatory of the interrogatory (a) “If only OF to a part Shal l a Part of of an interrogatory, be answered, an interrogatory the specific (b) If an obje i 8round ction js mad for the objection e to a shal] be set SpecialInterrogatorie s fort Page | 7/23/2019 A | EXHIBIT “2” i ATTORNEYOR PARTY RUSSELL WITHOUT LEE ATTORNEY TARVER (Name,State Barnumber, andaddress): ° --In Pro Per 4324 Kenneth Avenue Fair Oaks, CA.9 628 TELEPHONENO: (9] 2-8948 FAX NO.(Optional): E-MAIL ADDRESS (Optional): ATTORNEYFOR (Name): Russell Lee Tarver, Defendant and Cross-complainant SUPERIOR COURT OF CALIFORNIA, COUNTY OF PLACER Bill Santucci Justice Center SHORT TITLE OF CASE: Tarver v. King FORM INTERROGATORIES—GENERA Asking Party: RUSSELL L CASE NUMBER: LEE TARVER Answering Party: TED ARTHUR KING SCV 0042357 Set No.: ONE Sec. 1. Instructions to All Parties (a) Interrogatoriesarewritten questions prepared by aparty to an actionthatare sent to any other partyin theaction answered under oath. tobe The interrogatoriesbelow are interrogatoriesapproved form foruse in civil cases. (b) For time limitations, requirements Parties, for serviceon other (d) If youdo and other details,see Code not have enough personal knowledge ofCivilProcedure answer to fully sections 2030.010-2030.410 an interrogatory,Say so,but and the cases construing those good make areasonable and sect ions. faithefforttoget the information Or by asking other persons (c) These organizations, unless the information form interrogatoriesdo isequally available not change existinglaw theasking party. to relatingtointerrogatoriesnor do they affectan answering party'srighttoassert any (e) Whenever an interrogatory privilegeor make any objection. may be answered by referringto a document, thedocument Sec. 2. Instructions to the exhibit may be attached as an Asking Party to the response and referred (a) These to inthe response. If the interrogatories are designed for document has more than one Parties optional use by page, refer tothe page and in unlimitedcivil cases where the section where the answer exce amount demanded to theinterrogatory can be found. eds $25,000. Separate interrogatories, Form (f) Whenever an address Interrogatories—-Limited and telephone number for CivilCases (Economic Litigation) Same person are requested the (formDISC-004), which have inmore than one interrogatory, no subparts, aredesigned for you are required tofurnish use inlimitedcivil cases them in answering onlythe first where the amount demanded is interrogatoryasking for $25,000 or less; that information. however, those interrogatories (g) If used inunlimited may also be you are asserting a privilegeor civilcases. making an objection to an interrogatory, you must specifically (b) Check the box next to each assert theprivilegeor interrogatorythat you want State the objectionin yourwritten the answering party toanswer. response. Use care in choosing those (h) interrogatoriesthatare applicable Your answers to these interrogatories tothe case, dated, must be verified, (c) You may insert and signed. You may wish touse your own definition of INCIDENT the followingform at Section 4, butonly in the end of your answers: where theaction arisesfrom a Conduct course of ! declare or a seriesof events Occurring over under penalty of perjury under aperiod of time. State of California the laws ofthe (d) The interrogatoriesinsection that the foregoing answers 16.0,Defendant's correct. are true and Contentions--Personal Injury,should not be used until the defendant has had a reasonable Opportunity toconduct an investigation or discovery of plaintiff's (DATE) injuriesand damages. (SIGNATURE) (e) Additionalinterrogatoriesmay be attached. Sec. 4. Definitions Sec. 3. Instructions to the Answering