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PAUL A. WARNER, ESQ. (SBN 112168)
1624 Santa Clara Drive, Suite 220
te
Roseville, CA 95661 fin 2 «
Telephone: (916) 996-3100 wit LUIU
wo
Facsimile: (916) 789-7557
Attorneys for Plaintiff Voyager Restaurant Group, Inc.
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF PLACER
VOYAGER RESTAURANT GROUP, INC., Case No. S-CV-0035599
a California corporation
DECLARATION OF PAUL WARNER IN
Plaintiff, SUPPORT OF MOTION FOR AN ORDER
TO STRIKE ANSWER AND CROSS- -
V. COMPLAINT DEFENDANTS FOR NON-
RESPONSE TO DISCOVERY [CCP 2023
SONORA GASOLINE CORPORATION, a et seq.|
California corporation formerly known as
SONORA PETROLEUM, INC., a California
corporation, GURRAJ SINGH GREWAL, Date: July 10, 2018
SABAL FINANCIAL GROUP LP, a Time: 8:30 a.m.
Dept.: 40
Delaware limited partnership; 2012-SIP-1
VENTURE LLC, a Delaware limited liability
company as successor to TENNESSEE Trial Date: August 27, 2018
COMMERCE BANK, a Tennessee State
chartered bank, ROSEVILLE PETROLEUM, “UNLIMITED CIVIL CASE”
INC., a California corporation, NIRMAL
SINGH, and DOES ONE through TWENTY,
inclusive,
Defendants.
I, Paul Warner, declare:
I am an attorney licensed to practice in the State of California and am attorney of record for
Plaintiff Voyager Restaurant Group, Inc., herein. I have personal knowledge of each fact stated
in this declaration except for those matters stated on information and belief, and as to those
DECLARATION OF PAUL WARNER IN SUPPORT OF MOTION FOR AN ORDER TO STRIKE ANSWER
AND CROSS-COMPLAINT DEFENDANTS FOR NON-RESPONSE TO DISCOVERY [CCP 2023 et seq.]
matters, I am informed and believe them to be true.
1. On December 10, 2014, I filed the Complaint in this action on behalf of Voyager
Restaurant Group, Inc.
2. On December 22, 2015, I filed the First Amended Complaint.
3. On February 24, 2016, attorney Jack Burstein filed an Answer to the First Amended
Complaint along with a Cross-complaint against Voyager Restaurant Group, Inc., and
others on behalf of Sonora Gasoline Corporation (formerly known as Sonora Petroleum,
Inc.) and Gurraj S. Grewal.
10 4. On December 1, 2017, I served Form Interrogatories, Special Interrogatorries, Requests
1] for Admission, Requests for Production of Documents, and Notice of Deposition to
12 Defendants Gurraj Singh Grewal (“Grewal”) and Sonora Gasoline Corporation
(“Sonora”). (See Exhibit A, attached hereto and incorporated herein by this reference, a
14
true and correct copy of a Proof of Service which was attached to the Form Interrogatories
1)
propounded).
16
5. On December 29, 2017, I spoke with Attorney Jack Burstein on behalf of Defendants
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Grewal and Sonora regarding the re-scheduling of depositions to accommodate Grewal’s
travel and promise to provide responses to written discovery the first week of January
2018. (See Exhibit B, attached hereto and incorporated herein by this reference, a true and
correct copy of an email to attorney Jack Burstein).
6. On January 2, 2018, I requested an update on the status of the responses to written
discovery and the alternative location of depositions. (See Exhibit C, attached hereto and
incorporated herein by this reference, a true and correct copy of an email to attorney Jack
Burstein).
7. On January 4, 2018, I received an email from attorney Jack Burstein promising, on behalf
2
DECLARATION OF PAUL WARNER IN SUPPORT OF MOTION FOR AN ORDER TO STRIKE ANSWER
AND CROSS-COMPLAINT DEFENDANTS FOR NON-RESPONSE TO DISCOVERY [CCP 2023 etseq.]
of Defendants Grewal and Sonora, responses to written discovery by facsimile and
requesting additional time to respond to the request for production. (See Exhibit D,
N
attached hereto and incorporated herein by this reference, a true and correct copy of an
email from attorney Jack Burstein). No responses were received by facsimile.
8. On January 26, 2018, I was informed by email from Julie Steiner that her father, Jack
Burstein, had unexpectedly passed that morning. (See Exhibit E, attached hereto and
incorporated herein by this reference, a true and correct copy of an email to me from Julie
Steiner January 26, 2018).
10 9. On February 16, 2018, in response to my query as to the status of replacement counsel,
1] Donna Kenney of Mr. Burstein’s administrative staff, requested an extension of time until
April 3, 2018, to respond to a cross-complaint in a related matter. (See Exhibit F, attached
13
hereto and incorporated herein by this reference, a true and correct copy of an email to me
14
from Donna Kenney February 16, 2018).
15
10. On February 28, I was provided contact address and phone for Gurraj Singh Grewal. (See
16
Exhibit G, attached hereto and incorporated herein by this reference, a true and correct
17
copy of an email to me from the office of Smith and Burstein February 28, 2018).
11. On March 1, 2018, I was informed that Mr. Burstein’s clients were notified that they
should seek new counsel, along with the email address for Mr. Grewal. (See Exhibit H,
attached hereto and incorporated herein by this reference, a true and correct copy of an
email to me from Marissa Buck on behalf of Mr. Burstein’s widow, March 1, 2018).
12. Between May 4 and May 15, 2018, I attempted to obtain further information on contacting
Mr. Grewal, including identifying who picked up his filesfrom Mr. Burstein’s office, since
no substitution of attorney had been filed, he was not responding to email, would not take
or return my phone calls, and mail to the address provided was returned as not forwarded.
3
DECLARATION OF PAUL WARNER IN SUPPORT OF MOTION FOR AN ORDER TO STRIKE ANSWER
AND CROSS-COMPLAINT DEFENDANTS FOR NON-RESPONSE TO DISCOVERY [CCP 2023 et seq.]
(See Exhibit I,attached hereto and incorporated herein by this reference, a true and correct
copy of an email string between me and Marissa Buck May 4-15, 2018).
13. On May 4, 2018, I sent a letter in accordance with CCP 286 to the registered agent for
Sonora Gasoline Corporation, and possible addresses for Gurraj S. Grewal, including Mr.
Burstein, the Tennessee address, and the attorney who previously represented Mr. Grewal
in Ontario Canada. (See Exhibit J, attached hereto and incorporated herein by this
reference, a true and correct copy of a letter from me May 4, 2018). The letter to
Tennessee was returned, unable to forward. There has been no response from the other
10 addresses.
11 14. On May 4, 2018, I sent an email with a letter attached in accordance with CCP 286 to the
12 address provided by Marissa Buck (See Exhibit K, attached hereto and incorporated herein
13 by this reference, a true and correct copy of an email from me May 4, 2018). There has
14
been no response and the email delivery system provided no notification of inability to
15
deliver.
16
15. On May 4, 2018, I sent a letter to meet and confer requesting discovery responses to the
17
18 registered agent for Sonora Gasoline Corporation, and possible addresses for Gurraj S.
19 Grewal, including Mr. Burstein, the Tennessee address, and the attorney who previously
20 represented Mr. Grewal in Ontario Canada. (See Exhibit L, attached hereto and
21 incorporated herein by this reference, a true and correct copy of an email from me May 4,
22
2018). The letter to Tennessee was returned, unable to forward. There has been no
23
response from the other addresses.
24
25 16. On May 4, 2018, I sent an email with a letter to meet and confer requesting discovery
26 responses to the address provided by Marissa Buck (See Exhibit K, attached hereto and
27 incorporated herein by this reference, a true and correct copy of an email from me May 4,
4
28 DECLARATION OF PAUL WARNER IN SUPPORT OF MOTION FOR AN ORDER TO STRIKE ANSWER
AND CROSS-COMPLAINT DEFENDANTS FOR NON-RESPONSE TO DISCOVERY [CCP 2023 etseq.]
2018). There has been no response and the email delivery system provided no notification
of inability to deliver.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
s
Paul A. od
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28 DECLARATION OF PAUL WARNER IN SUPPORT
5
OF MOTION FOR AN ORDER TO STRIKE ANSWER
AND CROSS-COMPLAINT DEFENDANTS FOR NON-RESPONSE TO DISCOVERY [CCP 2023 etseq.]
EXHIBIT A
PRO OF O SEFRVICE
: County, California. ]am
States and am employed in Placer
. Lam a citizen of the United My business "
not a party to the above-entitled action.
the age of eighteen years and am
3 {lover 220, Roseville, CA, 95661.
1624 Santa Clara Drive, Suite
address is:
the follow ing doc ument(s) to be served:
On the date specified below, Icaused
‘
Interrogatories Set No. 1
: 1. Form
2. Special Interrogatories Set No.1
6 Set No. 1.
3. Request for Admissions
4. Request for the Production of Documents
' Production of Documents
5. Notice of Deposition with
5
described below occurred, and am
loyed inthe County where the mailing
9 (BY MAI L) I am emp correspon dence formail ing
for collection and processing of
familiar with the business practice attached a copy of this
readily ed a true copy eof
ther [towhi ch was
United es
Stat Postal Services. Iplac will be
10 || with the thereon fully prepaid. The envelope(s)
in a sealed envelope(s) with postage ness in
document(s)] on thisdayin the ordinary course of busi
the United States Postal Service
11 || deposited with
following ordi nary business practices.
Roseville, California,
12
to be delivered by hand to the
SERVICE) I caused such envelope(s)
13 (BY PERSONAL
addressee(s) listed below.
' by
14
document(s) listedabove to be served
IL E AND MAI L) I caused the
. (BY FA CS IM shown as follows and thereon
number(s ) d
liste belo w at the location(s)
said document( s) to the (as described in the
> || telefaxing
(s) with the United States Postal Service
prep
fully ; aid and depo sited the envelope
16 .
service by mail above).
17 listed above which have been
SERVICE) I caused the document(s) was
(BY ELECTRONIC below on July 7,2011. The transmission
by e-mail to the addressee(s) listed
1g ||scanned to be served
rted as complete without r.
erro
repo
to be served by placing a true copy
1g
EXPRESS) Icaused the document(s)
() (BY FEDERAL document(s)] ina sealed Federal Expr ess overnight
which was attached a copy of this picked up by a Federal
| 20 thereof [to
w. The over night envelope was then
bearing the addr ess(es) d
liste belo was deposited ina Federal
envelope ness address in Roseville, California, or
ess
|| Expr emp loyee atthe abov e busi expiration of the lastpick up
21 encoding for overnight delivery before the
Express marked drop box with
very tothe address(es) listedbelow.
22 || for overnight deli
| B. Burnstein, Esq.
/ Marc B. Robinson Jack
23 Il Matthew C. Bradford
LLP SMITH & BURNSTEIN
| ROBINSON BRADFORD 1730 Sonoma Blvd
(13255W. March Lane, Suite 230
24 Vallejo,CA 94590-6085
Stockton, CA 95219
25
of the State of Caljfornia that the
penalty of perjury under the laws
26 I declare under
| wt ,2017 at
and that this deck ration was executed
is true and correct
LAA
27 || foregoing
59 || Roseville, California.
axgeeet
PROOF OF SERVICE
EXHIBIT B
Paul Warner
From: Paul Warner
Sent: Friday, December 29, 2017 12:54 PM
To: smithandburstein@comcast.net
Subject: Parmar v Voyager / Voyager v Parmar et alCross Complaint
Attachments: pos015 Notice of Acknowledgement and Receipt Civil Summons Raj Cross-
Complaint.pdf
Mr. Burstein
in accordance with the authority you expressed to me to accept service ofthe Cross-complaint on behalf of Mr.
Grewal, please sign and return
the enclosed Notice of Acknowledgement and Receipt.
!also understand that contrary to your prior request to postpone Raj’sdeposition from December 18, 2017 and
the Sonora PMK deposition from December 26, 2017, to January 4 and 5,2018, to accommodate Raj’s travel, he willnot
appear. You have offered to waive any discovery time limitsand requested that the depositions be rescheduled to the
firstweek of February, 2018. You also indicated that you are prepared to provide the responses to the written discovery
the firstweek of January. | would ask that those responses include the document production requested, since you
intended to produce them at the depositions on January 4 and 5.
After review of the responses and documents, we will make a decision regarding rescheduling the
depositions. What isRaj’s availability inTennessee?
Ifthis does not reflect or comport with your understanding of our conversations and communications, please
contact me immediately so that we may resolve any misunderstanding or dispute.
Thank you.
PAUL ANTHONY WARNER, ESQ.
1624 SantaClaraDrive,Suite220
Roseville,
California95661
Telephone: 916.996.3100
Fax: 916.789.7557
CONFIDENTIALITY NOTICE:
The information contained inthis email transmission is confidential and may be legally privileged, legally protected
attorney work-product, ormay be inside information. The information isintended only forthe use of the recipient(s) named
above. If you have received this information in error,please immediately notify us by email toarrange forreturn of all
documents. Any unauthorized disclosure, copying, distribution,or the taking ofany action in reliance on the contents of
this information isstrictlyprohibited, and may be unlawful.
EXHIBIT C
Paul Warner
From: Paul Warner
Sent: Tuesday, January 2, 2018 3:59 PM
To: smithandburstein@comcast.net
Subject: Parmar vVoyager / Voyager v Parmar et al Cross Complaint
Attachments: pos015 Notice of Acknowledgement and Receipt CivilSummons RajCross-
Complaint.pdf
Mr. Burstein,
What isthe status of the discovery and document production, please?
Have you contacted Mr. Grewal regarding being deposed inTennessee?
Thank you.
PAUL ANTHONY WARNER, ESQ.
1624 SantaClaraDrive,Suite220
Roseville,
California95661
Telephone: 916.996.3100
Fax: 916.789.7557
CONFIDENTIALITY NOTICE:
The information contained in thisemail transmission is confidential and may be legallyprivileged, legallyprotected
attorney work-product, or may be inside information. The information is intended only forthe use of the recipient(s) named
above. If you have received this information in error,please immediately notify us by email to arrange forreturn of all
documents. Any unauthorized disclosure, copying, distribution,or the taking of any action in reliance on the contents of
this information isstrictlyprohibited, and may be unlawful.
From: Paul Warner [mailto:pwarner@pacdining.com]
Sent: Friday, December 29, 2017 12:54 PM
To: smithandburstein@comcast.net
Subject: Parmar v Voyager / Voyager v Parmar etal Cross Complaint
Mr. Burstein
In accordance with the authority you expressed to me to accept service of the Cross-complaint on behalf of Mr.
Grewal, please sign and return
the enclosed Notice of Acknowledgement and Receipt.
|also understand that contrary to your prior request to postpone Raj’sdeposition from December 18, 2017 and
the Sonora PMK deposition from December 26, 2017, to January 4 and 5,2018, to accommodate Raj’s travel,he willnot
EXHIBIT D
Paul Warner
From: SMITH AND BURSTEIN
Sent: Thursday, January 4, 2018 9:04 AM
To: Paul Warner
Subject: Re: Voyager v Sonora
Mr. Warner:
| will be faxing you the answers to form interrogatories, special interrogatories and request for
admissions (with verifications to follow). |am asking for an additional 15 days to respond to the
request for production of documents.
Jack Burstein
On January 3, 2018 at 12:49 PM Paul Warner wrote:
This is to confirm that Mr. Burstein willnot be producing witnesses for deposition on Thursday, January
4, 2018 or Friday, January 5,2018.
PAUL ANTHONY WARNER, ESQ.
1624 SantaClaraDrive,Suite220
Roseville,
California95661
Telephone: 916.996.3100
Fax: 916.789.7557
CONFIDENTIALITY NOTICE:
The information contained inthis email transmission isconfidential and may be legally privileged, legally
protected attorney work-product, or may be inside information. The information isintended only for the
use of the recipient(s) named above. If you have received thisinformation in error, please immediately
notify us by email to arrange for return of alldocuments. Any unauthorized disclosure, copying,
distribution, orthe taking of any action in reliance on the contents of thisinformation is strictlyprohibited,
and may be unlawful.
EXHIBIT E
Paul Warner
From: SMITH AND BURSTEIN
Sent: Friday, January 26, 2018 1:12 PM
To: Paul Warner
Subject: RE: Voyager v Sonora SCV 0035599
Mr. Warner,
My name is Julie Steiner, | am Jack Burstein's daughter. |wanted to let you know that Mr. Burstein
passed away unexpectedly this morning. | am in the process of figuring out the next steps, how to
notifty attorneys, clients, etc. but wanted to reply to your email.
Thank you
On January 26, 2018 at 11:42 AM Paul Warner wrote:
our telephone conversation today wherein you indicated that you would check with your
Confirming
client regarding making him available for deposition in my office on February 5, 2018.
Thank you
From: Matthew Bradford [mailto:matthew@robinsonbradford.net]
Sent: Thursday, January 18, 2018 4:25 PM
To: SMITH AND BURSTEIN
Cc: Paul Warner
Subject: Re: Voyager v Sonora SCV 0035599
Mr. Singh isavailable on Jan 30 or 31 for his deposition.
Matthew C. Bradford, Esq.
Robinson Bradford, LLP
Direct Line: 858.480.6968
2018 at 3:27 PM, SMITH AND BURSTEIN wrote:
On Mon, Jan 1,
lam scheduled for a hearing on January 17, 2018. ! am free on January 18th, 19th and
the 22nd.
Jack Burstein
On December 29, 2017 at 3:38 PM Paul Warner
wrote:
Gentlemen,
|would liketo reschedule the noticed depositions of Nirmal Singh on
January 11, 2018 and the PMK of Roseville Petroleum on January 10,
2018 to January 17, 2018.
Please advise ifthis would comport with your calendars.
Thank you.
PAUL ANTHONY WARNER, ESQ.
- 1624 SantaClaraDrive,Suite220
Roseville,
California95661
Telephone: 916.996.3100
Fax: 916.789.7557
CONFIDENTIALITY NOTICE:
The information contained in this email transmission isconfidential and
legally privileged, legallyprotected attorney work-product, or may
may be
be inside information. The information is intended only forthe use of the
named above. If youhave received thisinformation in error,
recipient(s)
please immediately notify us by email to arrange for return of all
documents. Any unauthorized disclosure, copying, ion,
distribut or the
of any action in reliance on the contents of this information is
taking
strictlyprohibited, and may be unlawful.
EXHIBIT F
Paul Warner
From: SMITH AND BURSTEIN
Sent: Friday, February 16, 2018 2:38 PM
To: Paul Warner
Subject: Parmar LLL v. Voyager Restaurant, etal.
Good afternoon Mr. Warner.
This will confirm our conversation on February 15, 2018, wherein you kindly granted Mr. Grewal an
extension to respond to Cross-Complainant Voyager's First Amended Cross-Complaint. In that
regard, Mr. Grewal's response is due April 3, 2018.
Thank you again for your cooperation in this matter.
Donna Kenney
EXHIBIT G
Paul Warner
From: S| 1 AND BURSTEIN
Sent: Wednesday, February 28, 2018 5:19 PM
To: Paul Warner
Subject: Re: ex parte application to continue trial
Mr. Warner,
Thank you for your email. | am not an attorney and do not represent Mr. Grewal in that
case. Provided below is Mr. Grewal's contact information for you to contact him directly.
Gurraj Singh Grewal
863 Tennessee Avenue North
Parsons, TN
38363
615-566-0142
On February 28, 2018 at9:51 AM Paul Warner wrote:
| willbe appearing in Placer County Superior Court Department, 42 at 8 AM on Thursday. March 1st in
the matter ofVoyager versus Sonora. SCV 0035599 requesting in order to continue the trialand reopen
discovery.
Paul Warner
From: Marissa Buck
Sent: Thursday, March 1,2018 12:06 PM
To: Paul Warner
Subject: RE: ex parte application to continue trial
Thank you, Mr. Warner. Please letme know ifyou have any other questions.
Best,
MARISSA E. BUCK, ESQ.
707.261.7074 |MBUCK@DPF-LAW.COM
From: Paul Warner [mailto:pwarner@pacdining.com]
Sent: Thursday, March 01, 2018 11:33 AM
To: Marissa Buck
Subject: FW: ex parte application to continue trial
Ms. Buck,
Thank you for taking the time to explain your representation on behalf of Mr. Burstein’s widow, and that Mr. Burstein’s
clients have been notified that they should seek new counsel. |also appreciate your confirming an email for Mr. Grewal
— foxoilgas@yahoo.com.
PAUL ANTHONY WARNER, ESO.
1624 SantaClaraDrive,Suite220
Roseville,
California
95661
Telephone: 916.996.3100
Fax: 916.789.7557
CONFIDENTIALITY NOTICE:
The information contained in thisemail transmission isconfidential and may be legally privileged, legally protected
attorney work-product, or may be inside information. The information isintended only for the use of the recipient(s) named
above. If you have received thisinformation inerror, please immediately notifyus by email toarrange for return of all .
documents. Any unauthorized disclosure, copying, distribution,or the taking of any action inreliance on the contents of
thisinformation is prohibited,
strictly and may be unlawful.
From: SMITH AND BURSTEIN [mailto:smithandburstein@comcast.net]
Sent: Wednesday, February 28, 2018 5:19 PM
To: Paul Warner
Subject: Re: ex parte application to continue trial
Mr. Warner,
Thank you for your email. | am not an attorney and do not represent mir. Grewal in that
case. Provided below is Mr. Grewal's contact information for you to contact him directly.
Gurraj Singh Grewal
863 Tennessee Avenue North
Parsons, TN
38363
615-566-0142
On February 28, 2018 at9:51 AM Paul Warner wrote:
|will be appearing in Placer County Superior Court Department, 42 at 8 AM on Thursday. March 1st in
the matter ofVoyager versus Sonora. SCV 0035599 requesting in order to continue the trialand reopen
discovery.
EXHIBIT I
Paul Warner
From: Marissa Buck
Sent: Tuesday, May 15,2018 11:05 AM
To: Paul Warner
Subject: RE: Voyager Restaurant Group Incv Sonora Gasoline Corporation et alSCV0035599
Mr. Warner,
|apologize for the delay in getting back to you, | was out of town and am catching up on my emails.
The information you requested issubject to the attorney-client privilege between me and my client. However, |can tell
you that my client released the fileson April 17, 2018 and we have already provided you with allof the known contact
information we have for Mr. Grewal. We have no further information regarding this former client and we would
appreciate it you
if would cease contacting my office or my client with regard to this matter.
Best,
MARISSA E.BUCK, ESQ.
707.261.7074 |MBUCK@DPF-LAW.COM
From: Paul Warner [mailto:pwarner@pacdining.com]
Sent: Wednesday, May 09, 2018 3:45 PM
To: Marissa Buck
Subject: RE: Voyager Restaurant Group Inc v Sonora Gasoline Corporation et alSCV0035599
|understand, and |appreciate your assistance. Could you please tellme exactly how and to whom Grewal’s fileswere
released, and when?
Thank you
From: Marissa Buck
Sent: Wednesday, May 9, 2018 3:43 PM
To: Paul Warner
Subject: RE: Voyager Restaurant Group Inc v Sonora Gasoline Corporation et al SCV0035599
Mr. Warner,
|have given you allthe contact information we have forMr. Grewal and, as stated below, my client has already released
allof his files.I’m sorry we are unable to help you further.
Best,
MARISSA E.BUCK, ESQ.
707.261.7074 |MBUCK@DPF-LAW.COM
From: Pau! Warner [mailto:pwarner@pacdining.com]
Sent: Wednesday, May 09, 2018 11:11 AM
To: Marissa Buck
Subject: RE: Voyager Restaurant Group Inc v Sonora Gasoline Corporation et alSCV0035599
He does not respond to email and does not take our calls.
From: Marissa Buck
Sent: Tuesday, May 8, 2018 5:42 PM
To: Paul Warner
Subject: RE: Voyager Restaurant Group Inc v Sonora Gasoline Corporation etal SCV0035599
That isthe only address we have for him.
|would recommend contacting him by phone or email.
Best,
MARISSA E.BUCK, ESQ.
707.261.7074 |MBUCK@DPF-LAW.COM
From: Paul Warner [mailto:pwarner@pacdining.com]
Sent: Tuesday, May 08, 2018 5:35 PM
To: Marissa Buck
Subject: RE: Voyager Restaurant Group Inc v Sonora Gasoline Corporation et alSCV0035599
That isthe address which isnot deliverable
From: Marissa Buck
Sent: Tuesday, May 8, 2018 1:09 PM
To: Paul Warner
Subject: RE: Voyager Restaurant Group Inc v Sonora Gasoline Corporation etal SCV0035599
Mr. Warner,
Please see below forthe contact information that Mr. Grewal provided to Mr. Burstein’s office. His fileswere picked up
from Mr. Burstein’s former office in Vallejo.
Gurraj Singh Grewal
863 Tennessee Avenue North
Parsons, TN 38363
Tel: 615-566-0142
Email: foxoilgas@yahoo.com
Best,
MARISSA E.BUCK, ESQ.
707.261.7074 |MBUCK@DPF-LAW.COM
From: Paul Warner [mailto:pwarner@pacdining.com]
Sent: Tuesday, May 08, 2018 11:36 AM
To: Marissa Buck
Subject: RE: Voyager Restaurant Group Inc v Sonora Gasoline Corporation et alSCV0035599
Ms. Buck
No substitution ofattorney has been filed or served. The address given by the office to correspond with Mr. Grewal
returns as not forwarded. To what address were the filessent?
Thank you.
Paul Warner
From: Marissa Buck
Sent: Monday, May 7, 2018 5:57 PM
To: Paul Warner
Ce: smithandburstein@comcast.net
Subject: RE: Voyager Restaurant Group Inc v Sonora Gasoline Corporation et al SCVO0035599
Mr. Warner,
We are inreceipt ofyour letters to Mr. Grewal regarding discovery in case number SCV-0035599, and noticed that
copies ofyour letters were also sent to Mr. Burstein’s office. As you are already aware from our prior conversation, Mr.
Burstein’s law practice isinthe process of closing down following his death and we are assisting in that process. We
represent Mr. Burstein’s widow and do not represent any of hisformer clients,including Mr. Grewal.
|have confirmed with our client that allof Mr. Grewal’s filesfor this case have been released to him. Thus, it isno
longer necessary or proper to include us or Mr. Burstein’s office on any of your future communications or filings
regarding this case. Thank you.
Best,
MARISSA E.BUCK, ESQ.
707.261.7074 |MBUCK@DPF-LAW.COM
From: Paul Warner [mailto:pwarner@pacdining.com]
Sent: Friday, May 04, 2018 3:21 PM
To: foxoilaas@yahoo.com; smithandburstein@comcast.net; Marissa Buck; jmahli@malhilaw.com
Subject: Voyager Restaurant Group Inc v Sonora Gasoline Corporation et al SCV0035599
Mr. Grewal,
Please review and respond to the attached correspondence and discovery.
Thank you.
PAUL ANTHONY WARNER, ESQ.
1624 SantaClaraDrive,Suite
220
Roseville,
California
95661
Telephone: 916.996.3100
Fax: 916.789.7557
CONFIDENTIALITY NOTICE:
The information contained in thisemail transmission isconfidential and may be legally privileged, legally protected
attorney work-product, or may be inside information. The information isintended only forthe use of the recipient(s) named
above. If you have received thisinformation in error, please immediately notifyus by email toarrange forreturn of all
documents. Any unauthorized disclosure, copying, distribution,or the taking ofany action inreliance on the contents of
thisinformation is strictly
prohibited, and may be unlawful.
PAUL ANTHONY WARNER, ESQ.
1624 SantaClaraDrive,Suite220
Roseville,
California
95661
Telephone: 916.996.3100
Fax: 916.789.7557
May 4, 2018
Sonora Gasoline Corporation /Gurraj Singh Grewal Estate of Jack B. Burstein, Esq.
% Amandeep Singh SMITH & BURSTEIN
1556 Shaw Avenue 1730 Sonoma Blvd
Colvis, CA 93611 Vallejo,CA 94590-6085
smithandburstein@comeast.net
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PAUL A. WARNER, ESQ. (SBN 112168) 1624 Santa Clara Drive, Suite 220 te Roseville, CA 95661 fin 2 « Telephone: (916) 996-3100 wit LUIU wo Facsimile: (916) 789-7557 Attorneys for Plaintiff Voyager Restaurant Group, Inc. IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF PLACER VOYAGER RESTAURANT GROUP, INC., Case No. S-CV-0035599 a California corporation DECLARATION OF PAUL WARNER IN Plaintiff, SUPPORT OF MOTION FOR AN ORDER TO STRIKE ANSWER AND CROSS- - V. COMPLAINT DEFENDANTS FOR NON- RESPONSE TO DISCOVERY [CCP 2023 SONORA GASOLINE CORPORATION, a et seq.| California corporation formerly known as SONORA PETROLEUM, INC., a California corporation, GURRAJ SINGH GREWAL, Date: July 10, 2018 SABAL FINANCIAL GROUP LP, a Time: 8:30 a.m. Dept.: 40 Delaware limited partnership; 2012-SIP-1 VENTURE LLC, a Delaware limited liability company as successor to TENNESSEE Trial Date: August 27, 2018 COMMERCE BANK, a Tennessee State chartered bank, ROSEVILLE PETROLEUM, “UNLIMITED CIVIL CASE” INC., a California corporation, NIRMAL SINGH, and DOES ONE through TWENTY, inclusive, Defendants. I, Paul Warner, declare: I am an attorney licensed to practice in the State of California and am attorney of record for Plaintiff Voyager Restaurant Group, Inc., herein. I have personal knowledge of each fact stated in this declaration except for those matters stated on information and belief, and as to those DECLARATION OF PAUL WARNER IN SUPPORT OF MOTION FOR AN ORDER TO STRIKE ANSWER AND CROSS-COMPLAINT DEFENDANTS FOR NON-RESPONSE TO DISCOVERY [CCP 2023 et seq.] matters, I am informed and believe them to be true. 1. On December 10, 2014, I filed the Complaint in this action on behalf of Voyager Restaurant Group, Inc. 2. On December 22, 2015, I filed the First Amended Complaint. 3. On February 24, 2016, attorney Jack Burstein filed an Answer to the First Amended Complaint along with a Cross-complaint against Voyager Restaurant Group, Inc., and others on behalf of Sonora Gasoline Corporation (formerly known as Sonora Petroleum, Inc.) and Gurraj S. Grewal. 10 4. On December 1, 2017, I served Form Interrogatories, Special Interrogatorries, Requests 1] for Admission, Requests for Production of Documents, and Notice of Deposition to 12 Defendants Gurraj Singh Grewal (“Grewal”) and Sonora Gasoline Corporation (“Sonora”). (See Exhibit A, attached hereto and incorporated herein by this reference, a 14 true and correct copy of a Proof of Service which was attached to the Form Interrogatories 1) propounded). 16 5. On December 29, 2017, I spoke with Attorney Jack Burstein on behalf of Defendants 17 Grewal and Sonora regarding the re-scheduling of depositions to accommodate Grewal’s travel and promise to provide responses to written discovery the first week of January 2018. (See Exhibit B, attached hereto and incorporated herein by this reference, a true and correct copy of an email to attorney Jack Burstein). 6. On January 2, 2018, I requested an update on the status of the responses to written discovery and the alternative location of depositions. (See Exhibit C, attached hereto and incorporated herein by this reference, a true and correct copy of an email to attorney Jack Burstein). 7. On January 4, 2018, I received an email from attorney Jack Burstein promising, on behalf 2 DECLARATION OF PAUL WARNER IN SUPPORT OF MOTION FOR AN ORDER TO STRIKE ANSWER AND CROSS-COMPLAINT DEFENDANTS FOR NON-RESPONSE TO DISCOVERY [CCP 2023 etseq.] of Defendants Grewal and Sonora, responses to written discovery by facsimile and requesting additional time to respond to the request for production. (See Exhibit D, N attached hereto and incorporated herein by this reference, a true and correct copy of an email from attorney Jack Burstein). No responses were received by facsimile. 8. On January 26, 2018, I was informed by email from Julie Steiner that her father, Jack Burstein, had unexpectedly passed that morning. (See Exhibit E, attached hereto and incorporated herein by this reference, a true and correct copy of an email to me from Julie Steiner January 26, 2018). 10 9. On February 16, 2018, in response to my query as to the status of replacement counsel, 1] Donna Kenney of Mr. Burstein’s administrative staff, requested an extension of time until April 3, 2018, to respond to a cross-complaint in a related matter. (See Exhibit F, attached 13 hereto and incorporated herein by this reference, a true and correct copy of an email to me 14 from Donna Kenney February 16, 2018). 15 10. On February 28, I was provided contact address and phone for Gurraj Singh Grewal. (See 16 Exhibit G, attached hereto and incorporated herein by this reference, a true and correct 17 copy of an email to me from the office of Smith and Burstein February 28, 2018). 11. On March 1, 2018, I was informed that Mr. Burstein’s clients were notified that they should seek new counsel, along with the email address for Mr. Grewal. (See Exhibit H, attached hereto and incorporated herein by this reference, a true and correct copy of an email to me from Marissa Buck on behalf of Mr. Burstein’s widow, March 1, 2018). 12. Between May 4 and May 15, 2018, I attempted to obtain further information on contacting Mr. Grewal, including identifying who picked up his filesfrom Mr. Burstein’s office, since no substitution of attorney had been filed, he was not responding to email, would not take or return my phone calls, and mail to the address provided was returned as not forwarded. 3 DECLARATION OF PAUL WARNER IN SUPPORT OF MOTION FOR AN ORDER TO STRIKE ANSWER AND CROSS-COMPLAINT DEFENDANTS FOR NON-RESPONSE TO DISCOVERY [CCP 2023 et seq.] (See Exhibit I,attached hereto and incorporated herein by this reference, a true and correct copy of an email string between me and Marissa Buck May 4-15, 2018). 13. On May 4, 2018, I sent a letter in accordance with CCP 286 to the registered agent for Sonora Gasoline Corporation, and possible addresses for Gurraj S. Grewal, including Mr. Burstein, the Tennessee address, and the attorney who previously represented Mr. Grewal in Ontario Canada. (See Exhibit J, attached hereto and incorporated herein by this reference, a true and correct copy of a letter from me May 4, 2018). The letter to Tennessee was returned, unable to forward. There has been no response from the other 10 addresses. 11 14. On May 4, 2018, I sent an email with a letter attached in accordance with CCP 286 to the 12 address provided by Marissa Buck (See Exhibit K, attached hereto and incorporated herein 13 by this reference, a true and correct copy of an email from me May 4, 2018). There has 14 been no response and the email delivery system provided no notification of inability to 15 deliver. 16 15. On May 4, 2018, I sent a letter to meet and confer requesting discovery responses to the 17 18 registered agent for Sonora Gasoline Corporation, and possible addresses for Gurraj S. 19 Grewal, including Mr. Burstein, the Tennessee address, and the attorney who previously 20 represented Mr. Grewal in Ontario Canada. (See Exhibit L, attached hereto and 21 incorporated herein by this reference, a true and correct copy of an email from me May 4, 22 2018). The letter to Tennessee was returned, unable to forward. There has been no 23 response from the other addresses. 24 25 16. On May 4, 2018, I sent an email with a letter to meet and confer requesting discovery 26 responses to the address provided by Marissa Buck (See Exhibit K, attached hereto and 27 incorporated herein by this reference, a true and correct copy of an email from me May 4, 4 28 DECLARATION OF PAUL WARNER IN SUPPORT OF MOTION FOR AN ORDER TO STRIKE ANSWER AND CROSS-COMPLAINT DEFENDANTS FOR NON-RESPONSE TO DISCOVERY [CCP 2023 etseq.] 2018). There has been no response and the email delivery system provided no notification of inability to deliver. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. s Paul A. od 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DECLARATION OF PAUL WARNER IN SUPPORT 5 OF MOTION FOR AN ORDER TO STRIKE ANSWER AND CROSS-COMPLAINT DEFENDANTS FOR NON-RESPONSE TO DISCOVERY [CCP 2023 etseq.] EXHIBIT A PRO OF O SEFRVICE : County, California. ]am States and am employed in Placer . Lam a citizen of the United My business " not a party to the above-entitled action. the age of eighteen years and am 3 {lover 220, Roseville, CA, 95661. 1624 Santa Clara Drive, Suite address is: the follow ing doc ument(s) to be served: On the date specified below, Icaused ‘ Interrogatories Set No. 1 : 1. Form 2. Special Interrogatories Set No.1 6 Set No. 1. 3. Request for Admissions 4. Request for the Production of Documents ' Production of Documents 5. Notice of Deposition with 5 described below occurred, and am loyed inthe County where the mailing 9 (BY MAI L) I am emp correspon dence formail ing for collection and processing of familiar with the business practice attached a copy of this readily ed a true copy eof ther [towhi ch was United es Stat Postal Services. Iplac will be 10 || with the thereon fully prepaid. The envelope(s) in a sealed envelope(s) with postage ness in document(s)] on thisdayin the ordinary course of busi the United States Postal Service 11 || deposited with following ordi nary business practices. Roseville, California, 12 to be delivered by hand to the SERVICE) I caused such envelope(s) 13 (BY PERSONAL addressee(s) listed below. ' by 14 document(s) listedabove to be served IL E AND MAI L) I caused the . (BY FA CS IM shown as follows and thereon number(s ) d liste belo w at the location(s) said document( s) to the (as described in the > || telefaxing (s) with the United States Postal Service prep fully ; aid and depo sited the envelope 16 . service by mail above). 17 listed above which have been SERVICE) I caused the document(s) was (BY ELECTRONIC below on July 7,2011. The transmission by e-mail to the addressee(s) listed 1g ||scanned to be served rted as complete without r. erro repo to be served by placing a true copy 1g EXPRESS) Icaused the document(s) () (BY FEDERAL document(s)] ina sealed Federal Expr ess overnight which was attached a copy of this picked up by a Federal | 20 thereof [to w. The over night envelope was then bearing the addr ess(es) d liste belo was deposited ina Federal envelope ness address in Roseville, California, or ess || Expr emp loyee atthe abov e busi expiration of the lastpick up 21 encoding for overnight delivery before the Express marked drop box with very tothe address(es) listedbelow. 22 || for overnight deli | B. Burnstein, Esq. / Marc B. Robinson Jack 23 Il Matthew C. Bradford LLP SMITH & BURNSTEIN | ROBINSON BRADFORD 1730 Sonoma Blvd (13255W. March Lane, Suite 230 24 Vallejo,CA 94590-6085 Stockton, CA 95219 25 of the State of Caljfornia that the penalty of perjury under the laws 26 I declare under | wt ,2017 at and that this deck ration was executed is true and correct LAA 27 || foregoing 59 || Roseville, California. axgeeet PROOF OF SERVICE EXHIBIT B Paul Warner From: Paul Warner Sent: Friday, December 29, 2017 12:54 PM To: smithandburstein@comcast.net Subject: Parmar v Voyager / Voyager v Parmar et alCross Complaint Attachments: pos015 Notice of Acknowledgement and Receipt Civil Summons Raj Cross- Complaint.pdf Mr. Burstein in accordance with the authority you expressed to me to accept service ofthe Cross-complaint on behalf of Mr. Grewal, please sign and return the enclosed Notice of Acknowledgement and Receipt. !also understand that contrary to your prior request to postpone Raj’sdeposition from December 18, 2017 and the Sonora PMK deposition from December 26, 2017, to January 4 and 5,2018, to accommodate Raj’s travel, he willnot appear. You have offered to waive any discovery time limitsand requested that the depositions be rescheduled to the firstweek of February, 2018. You also indicated that you are prepared to provide the responses to the written discovery the firstweek of January. | would ask that those responses include the document production requested, since you intended to produce them at the depositions on January 4 and 5. After review of the responses and documents, we will make a decision regarding rescheduling the depositions. What isRaj’s availability inTennessee? Ifthis does not reflect or comport with your understanding of our conversations and communications, please contact me immediately so that we may resolve any misunderstanding or dispute. Thank you. PAUL ANTHONY WARNER, ESQ. 1624 SantaClaraDrive,Suite220 Roseville, California95661 Telephone: 916.996.3100 Fax: 916.789.7557 CONFIDENTIALITY NOTICE: The information contained inthis email transmission is confidential and may be legally privileged, legally protected attorney work-product, ormay be inside information. The information isintended only forthe use of the recipient(s) named above. If you have received this information in error,please immediately notify us by email toarrange forreturn of all documents. Any unauthorized disclosure, copying, distribution,or the taking ofany action in reliance on the contents of this information isstrictlyprohibited, and may be unlawful. EXHIBIT C Paul Warner From: Paul Warner Sent: Tuesday, January 2, 2018 3:59 PM To: smithandburstein@comcast.net Subject: Parmar vVoyager / Voyager v Parmar et al Cross Complaint Attachments: pos015 Notice of Acknowledgement and Receipt CivilSummons RajCross- Complaint.pdf Mr. Burstein, What isthe status of the discovery and document production, please? Have you contacted Mr. Grewal regarding being deposed inTennessee? Thank you. PAUL ANTHONY WARNER, ESQ. 1624 SantaClaraDrive,Suite220 Roseville, California95661 Telephone: 916.996.3100 Fax: 916.789.7557 CONFIDENTIALITY NOTICE: The information contained in thisemail transmission is confidential and may be legallyprivileged, legallyprotected attorney work-product, or may be inside information. The information is intended only forthe use of the recipient(s) named above. If you have received this information in error,please immediately notify us by email to arrange forreturn of all documents. Any unauthorized disclosure, copying, distribution,or the taking of any action in reliance on the contents of this information isstrictlyprohibited, and may be unlawful. From: Paul Warner [mailto:pwarner@pacdining.com] Sent: Friday, December 29, 2017 12:54 PM To: smithandburstein@comcast.net Subject: Parmar v Voyager / Voyager v Parmar etal Cross Complaint Mr. Burstein In accordance with the authority you expressed to me to accept service of the Cross-complaint on behalf of Mr. Grewal, please sign and return the enclosed Notice of Acknowledgement and Receipt. |also understand that contrary to your prior request to postpone Raj’sdeposition from December 18, 2017 and the Sonora PMK deposition from December 26, 2017, to January 4 and 5,2018, to accommodate Raj’s travel,he willnot EXHIBIT D Paul Warner From: SMITH AND BURSTEIN Sent: Thursday, January 4, 2018 9:04 AM To: Paul Warner Subject: Re: Voyager v Sonora Mr. Warner: | will be faxing you the answers to form interrogatories, special interrogatories and request for admissions (with verifications to follow). |am asking for an additional 15 days to respond to the request for production of documents. Jack Burstein On January 3, 2018 at 12:49 PM Paul Warner wrote: This is to confirm that Mr. Burstein willnot be producing witnesses for deposition on Thursday, January 4, 2018 or Friday, January 5,2018. PAUL ANTHONY WARNER, ESQ. 1624 SantaClaraDrive,Suite220 Roseville, California95661 Telephone: 916.996.3100 Fax: 916.789.7557 CONFIDENTIALITY NOTICE: The information contained inthis email transmission isconfidential and may be legally privileged, legally protected attorney work-product, or may be inside information. The information isintended only for the use of the recipient(s) named above. If you have received thisinformation in error, please immediately notify us by email to arrange for return of alldocuments. Any unauthorized disclosure, copying, distribution, orthe taking of any action in reliance on the contents of thisinformation is strictlyprohibited, and may be unlawful. EXHIBIT E Paul Warner From: SMITH AND BURSTEIN Sent: Friday, January 26, 2018 1:12 PM To: Paul Warner Subject: RE: Voyager v Sonora SCV 0035599 Mr. Warner, My name is Julie Steiner, | am Jack Burstein's daughter. |wanted to let you know that Mr. Burstein passed away unexpectedly this morning. | am in the process of figuring out the next steps, how to notifty attorneys, clients, etc. but wanted to reply to your email. Thank you On January 26, 2018 at 11:42 AM Paul Warner wrote: our telephone conversation today wherein you indicated that you would check with your Confirming client regarding making him available for deposition in my office on February 5, 2018. Thank you From: Matthew Bradford [mailto:matthew@robinsonbradford.net] Sent: Thursday, January 18, 2018 4:25 PM To: SMITH AND BURSTEIN Cc: Paul Warner Subject: Re: Voyager v Sonora SCV 0035599 Mr. Singh isavailable on Jan 30 or 31 for his deposition. Matthew C. Bradford, Esq. Robinson Bradford, LLP Direct Line: 858.480.6968 2018 at 3:27 PM, SMITH AND BURSTEIN wrote: On Mon, Jan 1, lam scheduled for a hearing on January 17, 2018. ! am free on January 18th, 19th and the 22nd. Jack Burstein On December 29, 2017 at 3:38 PM Paul Warner wrote: Gentlemen, |would liketo reschedule the noticed depositions of Nirmal Singh on January 11, 2018 and the PMK of Roseville Petroleum on January 10, 2018 to January 17, 2018. Please advise ifthis would comport with your calendars. Thank you. PAUL ANTHONY WARNER, ESQ. - 1624 SantaClaraDrive,Suite220 Roseville, California95661 Telephone: 916.996.3100 Fax: 916.789.7557 CONFIDENTIALITY NOTICE: The information contained in this email transmission isconfidential and legally privileged, legallyprotected attorney work-product, or may may be be inside information. The information is intended only forthe use of the named above. If youhave received thisinformation in error, recipient(s) please immediately notify us by email to arrange for return of all documents. Any unauthorized disclosure, copying, ion, distribut or the of any action in reliance on the contents of this information is taking strictlyprohibited, and may be unlawful. EXHIBIT F Paul Warner From: SMITH AND BURSTEIN Sent: Friday, February 16, 2018 2:38 PM To: Paul Warner Subject: Parmar LLL v. Voyager Restaurant, etal. Good afternoon Mr. Warner. This will confirm our conversation on February 15, 2018, wherein you kindly granted Mr. Grewal an extension to respond to Cross-Complainant Voyager's First Amended Cross-Complaint. In that regard, Mr. Grewal's response is due April 3, 2018. Thank you again for your cooperation in this matter. Donna Kenney EXHIBIT G Paul Warner From: S| 1 AND BURSTEIN Sent: Wednesday, February 28, 2018 5:19 PM To: Paul Warner Subject: Re: ex parte application to continue trial Mr. Warner, Thank you for your email. | am not an attorney and do not represent Mr. Grewal in that case. Provided below is Mr. Grewal's contact information for you to contact him directly. Gurraj Singh Grewal 863 Tennessee Avenue North Parsons, TN 38363 615-566-0142 On February 28, 2018 at9:51 AM Paul Warner wrote: | willbe appearing in Placer County Superior Court Department, 42 at 8 AM on Thursday. March 1st in the matter ofVoyager versus Sonora. SCV 0035599 requesting in order to continue the trialand reopen discovery. Paul Warner From: Marissa Buck Sent: Thursday, March 1,2018 12:06 PM To: Paul Warner Subject: RE: ex parte application to continue trial Thank you, Mr. Warner. Please letme know ifyou have any other questions. Best, MARISSA E. BUCK, ESQ. 707.261.7074 |MBUCK@DPF-LAW.COM From: Paul Warner [mailto:pwarner@pacdining.com] Sent: Thursday, March 01, 2018 11:33 AM To: Marissa Buck Subject: FW: ex parte application to continue trial Ms. Buck, Thank you for taking the time to explain your representation on behalf of Mr. Burstein’s widow, and that Mr. Burstein’s clients have been notified that they should seek new counsel. |also appreciate your confirming an email for Mr. Grewal — foxoilgas@yahoo.com. PAUL ANTHONY WARNER, ESO. 1624 SantaClaraDrive,Suite220 Roseville, California 95661 Telephone: 916.996.3100 Fax: 916.789.7557 CONFIDENTIALITY NOTICE: The information contained in thisemail transmission isconfidential and may be legally privileged, legally protected attorney work-product, or may be inside information. The information isintended only for the use of the recipient(s) named above. If you have received thisinformation inerror, please immediately notifyus by email toarrange for return of all . documents. Any unauthorized disclosure, copying, distribution,or the taking of any action inreliance on the contents of thisinformation is prohibited, strictly and may be unlawful. From: SMITH AND BURSTEIN [mailto:smithandburstein@comcast.net] Sent: Wednesday, February 28, 2018 5:19 PM To: Paul Warner Subject: Re: ex parte application to continue trial Mr. Warner, Thank you for your email. | am not an attorney and do not represent mir. Grewal in that case. Provided below is Mr. Grewal's contact information for you to contact him directly. Gurraj Singh Grewal 863 Tennessee Avenue North Parsons, TN 38363 615-566-0142 On February 28, 2018 at9:51 AM Paul Warner wrote: |will be appearing in Placer County Superior Court Department, 42 at 8 AM on Thursday. March 1st in the matter ofVoyager versus Sonora. SCV 0035599 requesting in order to continue the trialand reopen discovery. EXHIBIT I Paul Warner From: Marissa Buck Sent: Tuesday, May 15,2018 11:05 AM To: Paul Warner Subject: RE: Voyager Restaurant Group Incv Sonora Gasoline Corporation et alSCV0035599 Mr. Warner, |apologize for the delay in getting back to you, | was out of town and am catching up on my emails. The information you requested issubject to the attorney-client privilege between me and my client. However, |can tell you that my client released the fileson April 17, 2018 and we have already provided you with allof the known contact information we have for Mr. Grewal. We have no further information regarding this former client and we would appreciate it you if would cease contacting my office or my client with regard to this matter. Best, MARISSA E.BUCK, ESQ. 707.261.7074 |MBUCK@DPF-LAW.COM From: Paul Warner [mailto:pwarner@pacdining.com] Sent: Wednesday, May 09, 2018 3:45 PM To: Marissa Buck Subject: RE: Voyager Restaurant Group Inc v Sonora Gasoline Corporation et alSCV0035599 |understand, and |appreciate your assistance. Could you please tellme exactly how and to whom Grewal’s fileswere released, and when? Thank you From: Marissa Buck Sent: Wednesday, May 9, 2018 3:43 PM To: Paul Warner Subject: RE: Voyager Restaurant Group Inc v Sonora Gasoline Corporation et al SCV0035599 Mr. Warner, |have given you allthe contact information we have forMr. Grewal and, as stated below, my client has already released allof his files.I’m sorry we are unable to help you further. Best, MARISSA E.BUCK, ESQ. 707.261.7074 |MBUCK@DPF-LAW.COM From: Pau! Warner [mailto:pwarner@pacdining.com] Sent: Wednesday, May 09, 2018 11:11 AM To: Marissa Buck Subject: RE: Voyager Restaurant Group Inc v Sonora Gasoline Corporation et alSCV0035599 He does not respond to email and does not take our calls. From: Marissa Buck Sent: Tuesday, May 8, 2018 5:42 PM To: Paul Warner Subject: RE: Voyager Restaurant Group Inc v Sonora Gasoline Corporation etal SCV0035599 That isthe only address we have for him. |would recommend contacting him by phone or email. Best, MARISSA E.BUCK, ESQ. 707.261.7074 |MBUCK@DPF-LAW.COM From: Paul Warner [mailto:pwarner@pacdining.com] Sent: Tuesday, May 08, 2018 5:35 PM To: Marissa Buck Subject: RE: Voyager Restaurant Group Inc v Sonora Gasoline Corporation et alSCV0035599 That isthe address which isnot deliverable From: Marissa Buck Sent: Tuesday, May 8, 2018 1:09 PM To: Paul Warner Subject: RE: Voyager Restaurant Group Inc v Sonora Gasoline Corporation etal SCV0035599 Mr. Warner, Please see below forthe contact information that Mr. Grewal provided to Mr. Burstein’s office. His fileswere picked up from Mr. Burstein’s former office in Vallejo. Gurraj Singh Grewal 863 Tennessee Avenue North Parsons, TN 38363 Tel: 615-566-0142 Email: foxoilgas@yahoo.com Best, MARISSA E.BUCK, ESQ. 707.261.7074 |MBUCK@DPF-LAW.COM From: Paul Warner [mailto:pwarner@pacdining.com] Sent: Tuesday, May 08, 2018 11:36 AM To: Marissa Buck Subject: RE: Voyager Restaurant Group Inc v Sonora Gasoline Corporation et alSCV0035599 Ms. Buck No substitution ofattorney has been filed or served. The address given by the office to correspond with Mr. Grewal returns as not forwarded. To what address were the filessent? Thank you. Paul Warner From: Marissa Buck Sent: Monday, May 7, 2018 5:57 PM To: Paul Warner Ce: smithandburstein@comcast.net Subject: RE: Voyager Restaurant Group Inc v Sonora Gasoline Corporation et al SCVO0035599 Mr. Warner, We are inreceipt ofyour letters to Mr. Grewal regarding discovery in case number SCV-0035599, and noticed that copies ofyour letters were also sent to Mr. Burstein’s office. As you are already aware from our prior conversation, Mr. Burstein’s law practice isinthe process of closing down following his death and we are assisting in that process. We represent Mr. Burstein’s widow and do not represent any of hisformer clients,including Mr. Grewal. |have confirmed with our client that allof Mr. Grewal’s filesfor this case have been released to him. Thus, it isno longer necessary or proper to include us or Mr. Burstein’s office on any of your future communications or filings regarding this case. Thank you. Best, MARISSA E.BUCK, ESQ. 707.261.7074 |MBUCK@DPF-LAW.COM From: Paul Warner [mailto:pwarner@pacdining.com] Sent: Friday, May 04, 2018 3:21 PM To: foxoilaas@yahoo.com; smithandburstein@comcast.net; Marissa Buck; jmahli@malhilaw.com Subject: Voyager Restaurant Group Inc v Sonora Gasoline Corporation et al SCV0035599 Mr. Grewal, Please review and respond to the attached correspondence and discovery. Thank you. PAUL ANTHONY WARNER, ESQ. 1624 SantaClaraDrive,Suite 220 Roseville, California 95661 Telephone: 916.996.3100 Fax: 916.789.7557 CONFIDENTIALITY NOTICE: The information contained in thisemail transmission isconfidential and may be legally privileged, legally protected attorney work-product, or may be inside information. The information isintended only forthe use of the recipient(s) named above. If you have received thisinformation in error, please immediately notifyus by email toarrange forreturn of all documents. Any unauthorized disclosure, copying, distribution,or the taking ofany action inreliance on the contents of thisinformation is strictly prohibited, and may be unlawful. PAUL ANTHONY WARNER, ESQ. 1624 SantaClaraDrive,Suite220 Roseville, California 95661 Telephone: 916.996.3100 Fax: 916.789.7557 May 4, 2018 Sonora Gasoline Corporation /Gurraj Singh Grewal Estate of Jack B. Burstein, Esq. % Amandeep Singh SMITH & BURSTEIN 1556 Shaw Avenue 1730 Sonoma Blvd Colvis, CA 93611 Vallejo,CA 94590-6085 smithandburstein@comeast.net