Preview
FILED
Court ofCalifornia
Superior
County. of Placer
PAUL A. WARNER, ESQ. (SBN 112168)
1624 Santa Clara Drive, Suite 220
Roseville, CA 95661 AUGIO6 2018
Telephone: (916) 996-3100 Jake atters
Clerk
Executive Officer &
Facsimile: (916) 789-7557 By: S. HubRard, Deputy
Attorneys for Plaintiff Voyager Restaurant Group, Inc.
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF PLACER
10 VOYAGER RESTAURANT GROUP, INC., Case No. S-CV-0035599
11 a California corporation
DECLARATION OF PAUL WARNER IN
12 Plaintiff,
SUPPORT
TO COMPEL
OF MOTION
DEPOSITIONS
FOR AN
[CCP
ORDER
V. 2025.450]
13
SONORA GASOLINE CORPORATION, a
14 California corporation formerly known as
15 SONORA PETROLEUM, INC., a California Date: August 14, 2018
corporation, GURRAJ SINGH GREWAL, Time: 8:30 a.m.
16 SABAL FINANCIAL GROUP LP, a Dept.: 40
Delaware limited partnership; 2012-SIP-1
17 VENTURE LLC, a Delaware limited liability Trial Date: August 27, 2018
company as successor to TENNESSEE
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COMMERCE BANK, a Tennessee State “UNLIMITED CIVIL CASE”
19 chartered bank, ROSEVILLE PETROLEUM,
INC., a California corporation, NIRMAL
20 SINGH, and DOES ONE through TWENTY,
inclusive,
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22 Defendants.
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I, Paul Warner, declare:
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I am an attorney licensed to practice in the State of California and am attorney of record for
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herein. Ihave personal knowledge of each fact stated
26 Plaintiff Voyager Restaurant Group, Inc.,
27 in this declaration except for those matters stated on information and belief, and as to those
28 DECLARATION OF PAUL WARNER IN SUPPORT OF MOTION FOR AN ORDER TO COMPEL
DEPOSITIONS [CCP 2025.450]
matters, Iam informed and believe them to be true.
1.Attached hereto as Exhibit A and incorporated herein by this reference, is a true and
correct copy of a Notice of Deposition of Defendant Nirmal Singh and the Proof of
Service which was attached to the Form Interrogatories propounded.
2. Attached hereto as Exhibit B and incorporated herein by this reference, is a true and
DBD
correct copy of a Notice of Deposition of Defendant Roseville Petroleum Inc.’s Person
NY
Most Knowledgeable and the Proof of Service which was attached to the Form
Oo
Interrogatories propounded.
Oo
10 3. Attached hereto as Exhibit C and incorporated herein by this reference are true and
11 correct copies of email correspondence between Matthew Bradford as counsel for
12 RPI/Singh and Paul Warner as counsel for Voyager about rescheduling the RPI/Singh
13 depositions before Mr. Burstein’s demise.
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4. Attached hereto as Exhibit D and incorporated herein by this reference are true and
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correct copies of email correspondence between Matthew Bradford as counsel for
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RPI/Singh and Paul Warner as counsel for Voyager about taking the RPI/Singh
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18 depositions off calendar because of Mr. Burstein’s demise.
19 5. Attached hereto as Exhibit E and incorporated herein by this reference are true and
20 correct copies of email correspondence between Matthew Bradford as counsel for
21 RPI/Singh and Paul Warner as counsel for Voyager about continuing the depositions
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and waiving the discovery cut-off for them until Sonora/Grewal obtain new
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representation.
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25 6. Attached hereto as Exhibit F and incorporated herein by this reference are true and
26 correct copies of email correspondence between Matthew Bradford as counsel for
27
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28 DECLARATION OF PAUL WARNER IN SUPPORT OF MOTION FOR AN ORDER TO COMPEL
DEPOSITIONS [CCP 2025.450]
RPI/Singh and Paul Warner as counsel for Voyager about resetting the depositions in
July 2018.
7. Attached hereto as Exhibit G and incorporated herein by this reference are true and
correct copies of email correspondence between Matthew Bradford as counsel for
RPI/Singh and Paul Warner as counsel for Voyager about Singh being out of the
country through the end of August.
ND
8. I have expended approximately 4.5 hours preparing and filing the pleadings associated
with this motion at a rate of $250/hour.
ao
I declare under penalty of perjury under the laws of the State of California that the
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11 foregoing is true and correct.
12 DATED:
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28 OF PAUL WARNER IN SUPPORT OF MOTION FOR AN ORDER TO COMPEL
DECLARATION
DEPOSITIONS [CCP 2025.450]
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EXHIBIT A
Paul Anthony Warner (SBN 112168)
1624 Santa Clara Drive, Suite 220
Roseville, California 95661
Telephone: (916) 996-3100
Facsimile: (916) 789-7557
Attormey for Plaintiff Voyager Restaurant Group, Inc.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF PLACER
VOYAGER RESTAURANT GROUP, INC., a Case No.: S-CV-035599
California corporation a
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NOTICE OF DEPOSITION
Plaintiff,
il* v.
CCP § 2025.010 et seq.
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SONORA GASOLINE CORPORATION, a
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California corporation formerly known as
SONORA PETROLEUM, INC., a California
14 corporation, GURRAJ SINGH GREWAL,
SABAL FINANCIAL GROUP LP, a Delaware
15
limited partnership; 2012-SIP-1 VENTURE
16 LLC, a Delaware limited liability company as
successor to TENNESSEE COMMERCE
17 BANK, a Tennessee State chartered bank,
ROSEVILLE PETROLEUM, INC., a California
18
| corporation, NIRMAL SINGH, and DOES ONE
Lo through TWENTY, inclusive,
20 Defendants.
21
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PLACE: Law Offices of Paul A. Warner
23 1624 Santa Clara Drive, Suite 220
Roseville, Ca 95661
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DATE and TIME: Thursday, January 11, 2018 at 10:00am
25 DEPONENT: Nimal Singh
26
PLEASE TAKE NOTICE that on Thursday, January 11, 2018 at 10:00am
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Notice ofDeposition Singh and Request forProduction ofDocuments
and continuing from day to day thereafter, excluding Sundays and Holidays, all parties
represented by Paul A. Warner, Esq. will take the oral deposition of Nirmal Singh, before a
qualified notary public.
The deposition may be recorded steno graphically by the instant visual display of the testimony.
DEPONENT AND DEPONENT’S ATTORNEY OF RECORD ARE FURTHER
NOTIFIED and required by the Code of Civil Procedure Section 2025.220(4) to produce at the
deposition the following books, documents, or other things which are in your possession or under
your control:
10
11 REQUEST NO. 1:
12 All writings, as that term is defined California Evidence Code Section 250, identified,
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referenced, or relied upon in response to PLAINTIFF’S Special Interrogatories Set No. One.
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REQUEST NO. 2:
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All writings, as that term is defined California Evidence Code Section 250, identified,
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17 © referenced, or relied upon in response to PLAINTIF F’S Request for Admissions Set No. One.
18 REQUEST NO. 3:
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| All writings, as that term is defined California Evidence Code Section 250, identified
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referenced, or relied upon in response to PLAINTIFF’S Form Interrogatories Set No. One.
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REQUEST NO. 4:
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23 All writings, as that term is defined California Evidence Code Section 250, which relate
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to YOUR lease of the property commonly known as the Arco AM/PM station at 2998 Foothills
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Blvd., Roseville, CA.
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REQUEST NO. 5:
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Notice ofDeposition Singh and Request forProduction of Documents
PROOF OF SERVICE
I am a citizen of the United States and am employed in Placer County, California. Iam
over the age of eighteen years and am not a party to the above-entitled action. My business
address is: 1624 Santa Clara Drive, Suite 220, Roseville, CA, 95661.
On the date specified below, I caused the following document(s) to be served:
Form Interrogatories Set No. 1
we
Special Interrogatories Set No.1
Gh
Request for Admissions Set No. 1.
Request for the Production of Documents
Notice of Deposition with Production of Documents
Nn
(X) (BY MAIL) Iam employed in the County where themailing described below occurred, and am
readily familiar with the business practice for collection and processing of correspondence for mailing
10 with the United States Postal Services. Iplaced a true copy thereof [to which was attached a copy of this
document(s)] ina sealed envelope(s) with postage thereon fullyprepaid. The envelope(s) will be
11 deposited with the United States Postal Service on this dayin the ordinary course of business in
Roseville, California, following ordinary business practices.
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13 () (BY PERSONAL SERVICE) I caused such envelope(s) to be delivered by hand to the
addressee(s) listed below.
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€) (BY FACSIMILE AND MAIL) I caused the document(s) listed above to be served by
15 and thereon
telefaxing said document(s) to the number(s) listed below atthe location(s) shown as follows
fully prepaid and deposited the envelope(s) with the United States Postal Service (as described inthe
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service by mail above).
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() (BY ELECTRONIC SERVICE) I caused the document(s) listedabove which have been
18 scanned tobe served by e-mail tothe addressee(s) listedbelow on July 7,2011. The transmission was
reported as complete without error.
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(BY FEDERAL EXPRESS) I caused the document(s) to be served by placing a true copy
20 thereof [towhich was attached acopy of this document(s)] in a sealed Federal Express overnight
envelope bearing the address(es) listedbelow. The overnight envelope was then picked up by a Federal
21 Express employee atthe above business address in Roseville, California, or was deposited in aFederal
Express marked drop box with encoding for overnight delivery before the expiration ofthe lastpick up
22 for overnight delivery tothe address(es) listedbelow.
23 Matthew C. Bradford / Marc B. Robinson Jack B. Burstein, Esq.
ROBINSON BRADFORD LLP SMITH & BURSTEIN
24 3439 Brookside Road, Suite 210 1730 Sonoma Blvd
Stockton, CA 95219 Vallejo,CA 94590-6085
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26 I declare under penalty of perjury under the laws of the State of California that the
27 foregoing is true and correct and that this declaration\was executed ths Z ,2017 at
28 Roseville, California.
——
PROOF OF SERVICE
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EXHIBIT B
Paul Anthony Warner (SBN 112168)
1624 Santa Clara Drive, Suite 220
Roseville, California 95661
Telephone: (916) 996-3100
Facsimile: (916) 789-7557
Attorney for Plaintiff Voyager Restaurant Group, Inc.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF PLACER
VOYAGER RESTAURANT GROUP, INC., af Case No.: S-CV-035599
California corporation
NOTICE OF DEPOSITION
10
Plaintiff, CCP § 2025.010 et seq.
rd Vv.
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SONORA GASOLINE CORPORATION, a
California corporation formerly known as
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SONOR A PETRO LEUM, INC., a California
14 corporation, GURRAJ SINGH GREWAL,
SABAL FINANCIAL GROUP LP, a Delaware
15
limited partnership; 2012-SIP-1 VENTURE
LLC, a Delaware limited liability company as"
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successor to TENNE SSEE COMM ERCE
17 BANK, a Tennessee State chartered bank,
ROSEVILLE PETROLEUM, INC., a California
18 and DOES ONE
corporation, NIRMAL SINGH,
19 through TWENTY, inclusive,
20 Defendants.
21
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PLACE: oe Law Offices of Paul A. Warner
1624 Santa Clara Drive, Suite 220
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Roseville, Ca 95661
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and TIME: Wednesday, January 10, 2018 at 10:00am
DATE
Person Most Knowledgeable at Roseville Petroleum, Inc.
25 DEPONENT:
26 TAKE NOTICE that on Wednesday, January 10, 2018 at 10:00am
PLEASE
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et =
Rosevilleand Request forProduction ofDocuments
Notice ofDeposition
and continuing from day to day thereafter, excluding Sundays and Holidays, allparties
represented by Paul A. Warner, Esq. will take the oral deposition of the Person Most
Knowledgeable at Roseville Petroleum, Inc., before a qualified notary public.
The areas of Inquiry will include:
1. Lease of the property at 2990-2998 Foothills Blvd., Roseville, CA, (“Property”) by
_ Roseville Petroleum Inc.
2. Knowledge of the Lease atthe Property with Voyager Restaurant Group, Inc.
3. Communications with the Receiver appointed by the Placer County Superior Court
10 for the Property.
id 4. Knowledge of any partnership agreement regarding Voyager Restaurant Group, Inc.
12 and/or the Property.
13 5. Sale of the property at 2990-2998 Foothills Blvd., Roseville, CA, (“Property”) by
14 Sonora Gasoline Corporation.
15 The deposition may be recorded steno graphically by the instant visual display of the testimony.
16 OF RECORD ARE. FURTHER
‘DEPONENT AND DEPONENT’S ATTORNEY
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NOTIFIED and required by the Code of Civil Procedure Section 2025.220(4) to produce at the
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deposition the following books, documents, or other things which are in your possession or under
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20 your control:
21 REQUEST NO. 1:
22 Section 250, identified,
All writings, as that term is defined California Evidence Code
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referenced, or relied upon in response to PLAINTIFF’S Special Interrogatories Set No. One.
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REQUEST NO. 2:
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26 All writings, as that term is defined California Evidence Code Section 250, identified]
27 referenced, or relied upon in response to PLAINTIFF’S Request for Admissions Set No. One.
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REQUEST NO. 3:
oe
Notice ofDeposition Rosevilleand Request forProduction of Documents
All writings, as that term is defined California Evidence Code Section 250, identified,
referenced, or relied upon in response toPLAIN TIFF’S Form Interrogatories Set No. One.
REQUEST NO. 4:
All writings, as that term is defined California Evidence Code Section 250, which relate
|to YOUR lease of the property commonly known as the Arco AM/PM station at 2998 Foothills
Blvd., Roseville, CA.
REQUEST NO. 5:
All writings, as that term is defined California Evidence Code Section 250, which relate
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11 to Plaintiff's lease of the property which includes the restaurant premises at 2998 Foothills Blvd.
12 Roseville, CA, attached as Exhibit A to the Complaint.
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REQUEST NO. 6:
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All writings, as that term is defined California Evidence Code Section 250, which relate;
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to YOUR communication with the Receiver appointed by the Court for the property at 2990-
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17 2998 Foothills Blvd., Roseville, CA.
pare. 3 DE 7 (py) VY
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21 PAUL A. wanna
Attorney for Plaintiff
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Voyager Restaurant Group, Inc., a California
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corporation
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Notice of DepositionRosevilleand Request forProduction of Documents
PROOF OF SERVICE
I am a citizen of the United States and am employed in Placer County, California. I am
over the age of eighteen years and am not a party to the above-entitled action. My business _
address is: 1624 Santa Clara Drive, Suite 220, Roseville, CA, 95661.
On the date specified below, Icaused the following document(s) to be served:
Form Interrogatories Set No. 1
Special Interrogatories Set No.1
WN
Request for Admissions Set No. 1.
Request for the Production of Documents
VR
- Notice of Deposition with Production of Documents
(X) (BY MAIL) Iam employed inthe County where the mailing described below occurred, and am
readily familiar with the business practice for collection and processing of correspondence for mailing
the United States Postal Services. Iplaced a true copy thereof [towhich was attached a copy of this
10 with
in a sealed envelope(s) with postage thereon fully prepaid. The envelope(s) will be
document(s)]
11 deposited with the United States Postal Service on this day inthe ordinary course of business in
Roseville, California, following ordinary business practices.
t2
Cc, (BY: PERSONAL SERVICE) I caused such envelope(s) to be delivered by hand tothe
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addressee(s) listed below.
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C) (BY FACSIMILE AND MAIL) I caused the document(s) listedabove to be served by
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said document(s) to the number(s) listedbelow at the location(s) shown as follows and thereon
telefaxing
prepaid and deposited the envelope(s) with the United States Postal Service (as described in the
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fully
service by mail above). .
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(_) (BY ELECTRONIC SERVICE) I caused the document(s) listedabove which have been
served by e-mail to the addressee(s) listed below on J uly7, 2011. The transmission was
18 scanned to be
reported as complete without error.
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(BY FEDERAL EXPRESS) I caused the document(s) to be served by placing a true copy
[towhich was attached a copy of this document (s] ina sealed Federal Express overnight
20 thereof
bearing the address(es) listed below. The overnight envelope was then picked up by a Federal
envelope
employee atthe above business address in Roseville, California, or was deposited ina Federal
21. Express pick up
drop box with encoding forovernight delivery before the expiration of the last
Express marked
22 for overnight delivery tothe address(es) listed below.
23 Matthew C. Bradford / Marc B. Robinson Jack B. Burstein, Esq.
ROBINSON BRADFORD LLP SMITH & BURSTE IN
24 3439 Brookside Road, Suite 210 1730 Sonoma Blvd
Stockton, CA 95219 Vallejo,CA 94590-6085
25
under penalty of perjury under the laws of the State of California that the
26 I declare
WO te
nine) was executed/this /. 2, / J, 2017 at
tal
27 foregoing is true and correct and that this
28 Roseville, California.
PROOF OF SERVICE
1 of 1 ©
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EXHIBIT C
Paul Warner
From: Paul Warner
Sent: Friday, December 29, 2017 3:38 PM
To: ‘Matthew Bradford’
Cc: smithandburstein@comcast.net
Subject: Voyager v Sonora SCV 0035599
Gentlemen,
depositions of Nirmal Singh on January 11, 2018 and the PMK of Roseville
|would liketo reschedule the noticed
Petroleum on January 10, 2018 to January 17, 2018.
Please advise ifthiswould 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:
email transmission isconfidential and may be legally privileged, legally protected
The information contained in this
information. The information isintended only forthe use of the recipient(s) named
attorney work-product, or may be inside
inerror, please immediately notifyus by email toarrange forreturn of all
above. If you have received this information
on,
distributi orthe taking ofany action in reliance on the contents of
documents. Any unauthorized e,
disclosur copying,
this information isstrictlyprohibited, and may be .
unlawful
Paul Warner
From: Matthew Bradford
Wednesday, January 3, 2018 1:06 PM
Sent:
To: Paul Warner
Ce: Marc Robinson; smithandburstein@comcast.net
Subject: Re: Voyager v Sonora
PMK of Roseville Petroleum and personally on January 10 and 11.
Mr. Singh isnot available for his deposition as the
Matthew C.Bradford, Esq.
Robinson Bradford, LLP
Direct Line: 858.480.6968
12:49 PM, Paul Warner wrote:
On Wed, Jan 3, 2018 at
for deposition on Thursday, January 4, 2018 or
isto confirm that Mr. Burstein will not be producing witnesses
| This
| Friday, January 5, 2018.
- PAUL ANTHONY WARNER, ESO.
| 1624 SantaClaraDrive,Suite220
| Roseville, 95661
California
| Telephone: 916.996.3100
| Fax: 916.789.7557
~ CONFIDENTIALITY NOTICE:
isconfidential and may be legally privileged, legally protected
_ The information contained in this email transmission
isintend ed only for the use of the recipient(s)
work-product, or may be inside information. The information
| attorney immedi ately notify us by email to arrange for return of
If you have received this information in error,please
named above. any action inreliance on the contents
ure,
disclos copying, ution,
distrib orthe taking of
alldocuments. Any unauthorized
information is prohibited,
strictly and may be unlawful.
_ of this
Paul Warner
From: Matthew Bradford
Sent: Wednesday, January 3, 2018 1:13 PM
To: Paul Warner
Subject: © Re: Voyager v Sonora
Itwill be easier to get you a new date ifyou combine the PMK and Nirmal's depositions.
Matthew C: Bradford, Esq.
Robinson Bradford, LLP
Direct Line: 858.480.6968
On Wed, Jan 3,2018 at 1:05 PM, Matthew Bradford wrote:
| Mr. Singh isnot available for his deposition as the PMK of Roseville Petroleum and personally on January 10 and 11.
Matthew C. Bradford, Esq.
Robinson Bradford, LLP
Direct Line: 858.480.6968
On Wed, Jan 3,2018 at 12:49 PM, Paul Warner wrote:
This isto confirm that Mr. Burstein will not be producing witnesses for deposition on Thursday, January 4, 2018 or
_. Friday, January 5, 2018.
if
i
Po
| PAUL ANTHONY WARNER, ESQ.
|| 1624Santa ClaraDrive,Suite220
| Roseville,
California
95661
[| Telephone:916.996.3100
| Fax:916.789.7557
| CONFIDENTIALITY NOTICE:
_ The information contained in this 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
Paul Warner
From: Paul Warner
Sent: Wednesday, January 3,2018 2:14 PM
To: ‘Matthew Bradford’
Subject: RE: Voyager v Sonora
When will he be available?
From: Matthew Bradford [mailto:matthew@robinsonbradford.net]
Sent: Wednesday, January 3, 2018 1:06 PM
To: Paul Warner
Cc: Marc Robinson ; smithandburstein@comcast.net
Subject: Re: Voyager vSonora
for his deposition as the PMK of Roseville Petroleum and personally on January 10 and 11.
Mr. Singh isnot available
Matthew C.Bradford, Esq.
Robinson Bradford, LLP
Direct Line: 858.480.6968
On Wed, Jan 3,2018 at 12:49 PM, Paul Warner wrote:
Burstein will not be producing witnesses for deposition on Thursday, January 4, 2018 or.
| This isto confirm that Mr.
| Friday, January 5,2018.
_ PAUL ANTHONY WARNER, ESQ.
1624 SantaClara Suite
Drive, 220
| Roseville,
California
95661
| Telephone: 916.996.3100
| Fax:916.789.7557
_ CONFIDENTIALITY NOTICE:
transmission isconfidential and may be legally privileged, legally protected
| The information contained in this email
The information isintended only for the use of the recipient(s)
_ attorney work-product, or may be inside information.
please immediately notify us by email to arrange for return of
_ named above. If you have received thisinformation in error,
or the taking of any action inreliance on the contents ©
' alldocuments. Any unauthorized disclosure, copying, distribution,
| of thisinformation is prohibited,
strictly and may be unlawful.
1
Paul Warner
From: Paul Warner
Sent: Friday, January 26, 2018 11:43 AM
To: ‘Matthew Bradford’; ‘SMITH AND BURSTEIN’
Subject: RE: Voyager vSonora SCV 0035599
Confirming our telephone conversation today wherein you indicated that you would check with your 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
On Mon, Jan 1,2018 at 3:27 PM, SMITH AND BURSTEIN wrote:
_ 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 toJanuary 17, 2018.
Please advise if thiswould comport with your calendars.
Thank you.
PAUL ANTHONY WARNER, ESQ.
1624 SantaClaraDrive,Suite220
Roseville,
California
95661
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EXHIBIT D
Paul Warner
From: Matthew Bradford
Sent: Monday, January 29, 2018 11:59 AM
To: Paul A. Warner
Subject: Fwd: FW: Voyager v Sonora SCV 0035599
you should go forward with Nirmal's Singh's depo untilnew counsel isobtained.
Given that news, | don't think
Matthew C. Bradford, Esq.
Robinson Bradford, LLP
Direct Line: 858.480.6968
a--an=---Forwarded message ----------
From: Paul Warner
Date: Mon, Jan 29, 2018 at 10:39 AM
Subject: FW: Voyager v Sonora SCV 0035599
To: Matthew Bradford
From: SMITH AND BURSTEIN [mailto:smithandburstein@comcast.net]
Sent: Friday, January 26, 2018 1:12 PM
To: Paul Warner
Subject: RE: Voyager v Sonora SCV 0035599
Mr. Warner,
Jack Burstein's daughter. |wanted to let you know that Mr. Burstein
My name is Julie Steiner, | am
| am in the process of figuring out the next steps, how to
passed away unexpectedly this morning.
attorneys, clients, etc. but wanted to reply to your email.
notifty
Thank you
AM Paul Warner wrote:
On January 26, 2018 at 11:42
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EXHIBIT E
Paul Warner
From: Matthew Bradford
Sent: Friday, February 2,2018 12:48 PM
To: Paul Warner :
SMITH AND BURSTEIN; COOKSEY & COMPANY LLC
Cc:
v Sonora Placer SCV 0035599 Deposition of Roseville Petroleum, Inc. and
- Subject: Re: Voyager
Nirmal Singh
Agreed.
Matthew C. Bradford, Esq.
Robinson Bradford, LLP
Direct Line: 858.480.6968
at 12:46 PM, Paul Warner wrote:
On Fri,Feb 2,2018
| Mr. Bradford
today wherein we agreed to continue the depositions of Roseville
| This will confirm our telephone conversation
for Monday, February 5, 2018, waiving the discovery cut-off, until
- Petroleum, Inc. and Nirmal Singh scheduled
Mr. Gr
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FILED Court ofCalifornia Superior County. of Placer PAUL A. WARNER, ESQ. (SBN 112168) 1624 Santa Clara Drive, Suite 220 Roseville, CA 95661 AUGIO6 2018 Telephone: (916) 996-3100 Jake atters Clerk Executive Officer & Facsimile: (916) 789-7557 By: S. HubRard, Deputy Attorneys for Plaintiff Voyager Restaurant Group, Inc. IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF PLACER 10 VOYAGER RESTAURANT GROUP, INC., Case No. S-CV-0035599 11 a California corporation DECLARATION OF PAUL WARNER IN 12 Plaintiff, SUPPORT TO COMPEL OF MOTION DEPOSITIONS FOR AN [CCP ORDER V. 2025.450] 13 SONORA GASOLINE CORPORATION, a 14 California corporation formerly known as 15 SONORA PETROLEUM, INC., a California Date: August 14, 2018 corporation, GURRAJ SINGH GREWAL, Time: 8:30 a.m. 16 SABAL FINANCIAL GROUP LP, a Dept.: 40 Delaware limited partnership; 2012-SIP-1 17 VENTURE LLC, a Delaware limited liability Trial Date: August 27, 2018 company as successor to TENNESSEE 18 COMMERCE BANK, a Tennessee State “UNLIMITED CIVIL CASE” 19 chartered bank, ROSEVILLE PETROLEUM, INC., a California corporation, NIRMAL 20 SINGH, and DOES ONE through TWENTY, inclusive, 21 22 Defendants. 23 I, Paul Warner, declare: 24 I am an attorney licensed to practice in the State of California and am attorney of record for 25 herein. Ihave personal knowledge of each fact stated 26 Plaintiff Voyager Restaurant Group, Inc., 27 in this declaration except for those matters stated on information and belief, and as to those 28 DECLARATION OF PAUL WARNER IN SUPPORT OF MOTION FOR AN ORDER TO COMPEL DEPOSITIONS [CCP 2025.450] matters, Iam informed and believe them to be true. 1.Attached hereto as Exhibit A and incorporated herein by this reference, is a true and correct copy of a Notice of Deposition of Defendant Nirmal Singh and the Proof of Service which was attached to the Form Interrogatories propounded. 2. Attached hereto as Exhibit B and incorporated herein by this reference, is a true and DBD correct copy of a Notice of Deposition of Defendant Roseville Petroleum Inc.’s Person NY Most Knowledgeable and the Proof of Service which was attached to the Form Oo Interrogatories propounded. Oo 10 3. Attached hereto as Exhibit C and incorporated herein by this reference are true and 11 correct copies of email correspondence between Matthew Bradford as counsel for 12 RPI/Singh and Paul Warner as counsel for Voyager about rescheduling the RPI/Singh 13 depositions before Mr. Burstein’s demise. 14 4. Attached hereto as Exhibit D and incorporated herein by this reference are true and 15 correct copies of email correspondence between Matthew Bradford as counsel for 16 RPI/Singh and Paul Warner as counsel for Voyager about taking the RPI/Singh 17 18 depositions off calendar because of Mr. Burstein’s demise. 19 5. Attached hereto as Exhibit E and incorporated herein by this reference are true and 20 correct copies of email correspondence between Matthew Bradford as counsel for 21 RPI/Singh and Paul Warner as counsel for Voyager about continuing the depositions 22 and waiving the discovery cut-off for them until Sonora/Grewal obtain new 23 representation. 24 25 6. Attached hereto as Exhibit F and incorporated herein by this reference are true and 26 correct copies of email correspondence between Matthew Bradford as counsel for 27 2 28 DECLARATION OF PAUL WARNER IN SUPPORT OF MOTION FOR AN ORDER TO COMPEL DEPOSITIONS [CCP 2025.450] RPI/Singh and Paul Warner as counsel for Voyager about resetting the depositions in July 2018. 7. Attached hereto as Exhibit G and incorporated herein by this reference are true and correct copies of email correspondence between Matthew Bradford as counsel for RPI/Singh and Paul Warner as counsel for Voyager about Singh being out of the country through the end of August. ND 8. I have expended approximately 4.5 hours preparing and filing the pleadings associated with this motion at a rate of $250/hour. ao I declare under penalty of perjury under the laws of the State of California that the 10 11 foregoing is true and correct. 12 DATED: 13 14 15 16 17 18 19 20 21 ee 23 24 25 26 27 3 28 OF PAUL WARNER IN SUPPORT OF MOTION FOR AN ORDER TO COMPEL DECLARATION DEPOSITIONS [CCP 2025.450] 10 11 12 13 14 id 16 17 18 193 20 21 22 23 24 25 26 27 28 EXHIBIT A Paul Anthony Warner (SBN 112168) 1624 Santa Clara Drive, Suite 220 Roseville, California 95661 Telephone: (916) 996-3100 Facsimile: (916) 789-7557 Attormey for Plaintiff Voyager Restaurant Group, Inc. SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF PLACER VOYAGER RESTAURANT GROUP, INC., a Case No.: S-CV-035599 California corporation a 10 NOTICE OF DEPOSITION Plaintiff, il* v. CCP § 2025.010 et seq. i2 SONORA GASOLINE CORPORATION, a 13 California corporation formerly known as SONORA PETROLEUM, INC., a California 14 corporation, GURRAJ SINGH GREWAL, SABAL FINANCIAL GROUP LP, a Delaware 15 limited partnership; 2012-SIP-1 VENTURE 16 LLC, a Delaware limited liability company as successor to TENNESSEE COMMERCE 17 BANK, a Tennessee State chartered bank, ROSEVILLE PETROLEUM, INC., a California 18 | corporation, NIRMAL SINGH, and DOES ONE Lo through TWENTY, inclusive, 20 Defendants. 21 22 PLACE: Law Offices of Paul A. Warner 23 1624 Santa Clara Drive, Suite 220 Roseville, Ca 95661 24 DATE and TIME: Thursday, January 11, 2018 at 10:00am 25 DEPONENT: Nimal Singh 26 PLEASE TAKE NOTICE that on Thursday, January 11, 2018 at 10:00am 27 28 =f Notice ofDeposition Singh and Request forProduction ofDocuments and continuing from day to day thereafter, excluding Sundays and Holidays, all parties represented by Paul A. Warner, Esq. will take the oral deposition of Nirmal Singh, before a qualified notary public. The deposition may be recorded steno graphically by the instant visual display of the testimony. DEPONENT AND DEPONENT’S ATTORNEY OF RECORD ARE FURTHER NOTIFIED and required by the Code of Civil Procedure Section 2025.220(4) to produce at the deposition the following books, documents, or other things which are in your possession or under your control: 10 11 REQUEST NO. 1: 12 All writings, as that term is defined California Evidence Code Section 250, identified, 13 referenced, or relied upon in response to PLAINTIFF’S Special Interrogatories Set No. One. 14 REQUEST NO. 2: 15 All writings, as that term is defined California Evidence Code Section 250, identified, 16 17 © referenced, or relied upon in response to PLAINTIF F’S Request for Admissions Set No. One. 18 REQUEST NO. 3: 19 | All writings, as that term is defined California Evidence Code Section 250, identified 20 referenced, or relied upon in response to PLAINTIFF’S Form Interrogatories Set No. One. 21 REQUEST NO. 4: 22 23 All writings, as that term is defined California Evidence Code Section 250, which relate ' 24 to YOUR lease of the property commonly known as the Arco AM/PM station at 2998 Foothills 25 Blvd., Roseville, CA. 26 REQUEST NO. 5: 27 28 i Notice ofDeposition Singh and Request forProduction of Documents PROOF OF SERVICE I am a citizen of the United States and am employed in Placer County, California. Iam over the age of eighteen years and am not a party to the above-entitled action. My business address is: 1624 Santa Clara Drive, Suite 220, Roseville, CA, 95661. On the date specified below, I caused the following document(s) to be served: Form Interrogatories Set No. 1 we Special Interrogatories Set No.1 Gh Request for Admissions Set No. 1. Request for the Production of Documents Notice of Deposition with Production of Documents Nn (X) (BY MAIL) Iam employed in the County where themailing described below occurred, and am readily familiar with the business practice for collection and processing of correspondence for mailing 10 with the United States Postal Services. Iplaced a true copy thereof [to which was attached a copy of this document(s)] ina sealed envelope(s) with postage thereon fullyprepaid. The envelope(s) will be 11 deposited with the United States Postal Service on this dayin the ordinary course of business in Roseville, California, following ordinary business practices. 12 13 () (BY PERSONAL SERVICE) I caused such envelope(s) to be delivered by hand to the addressee(s) listed below. 14 €) (BY FACSIMILE AND MAIL) I caused the document(s) listed above to be served by 15 and thereon telefaxing said document(s) to the number(s) listed below atthe location(s) shown as follows fully prepaid and deposited the envelope(s) with the United States Postal Service (as described inthe 16 service by mail above). 17 () (BY ELECTRONIC SERVICE) I caused the document(s) listedabove which have been 18 scanned tobe served by e-mail tothe addressee(s) listedbelow on July 7,2011. The transmission was reported as complete without error. 19 (BY FEDERAL EXPRESS) I caused the document(s) to be served by placing a true copy 20 thereof [towhich was attached acopy of this document(s)] in a sealed Federal Express overnight envelope bearing the address(es) listedbelow. The overnight envelope was then picked up by a Federal 21 Express employee atthe above business address in Roseville, California, or was deposited in aFederal Express marked drop box with encoding for overnight delivery before the expiration ofthe lastpick up 22 for overnight delivery tothe address(es) listedbelow. 23 Matthew C. Bradford / Marc B. Robinson Jack B. Burstein, Esq. ROBINSON BRADFORD LLP SMITH & BURSTEIN 24 3439 Brookside Road, Suite 210 1730 Sonoma Blvd Stockton, CA 95219 Vallejo,CA 94590-6085 25 26 I declare under penalty of perjury under the laws of the State of California that the 27 foregoing is true and correct and that this declaration\was executed ths Z ,2017 at 28 Roseville, California. —— PROOF OF SERVICE L-i9f 1 10 £1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 EXHIBIT B Paul Anthony Warner (SBN 112168) 1624 Santa Clara Drive, Suite 220 Roseville, California 95661 Telephone: (916) 996-3100 Facsimile: (916) 789-7557 Attorney for Plaintiff Voyager Restaurant Group, Inc. SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF PLACER VOYAGER RESTAURANT GROUP, INC., af Case No.: S-CV-035599 California corporation NOTICE OF DEPOSITION 10 Plaintiff, CCP § 2025.010 et seq. rd Vv. 12 SONORA GASOLINE CORPORATION, a California corporation formerly known as 13 SONOR A PETRO LEUM, INC., a California 14 corporation, GURRAJ SINGH GREWAL, SABAL FINANCIAL GROUP LP, a Delaware 15 limited partnership; 2012-SIP-1 VENTURE LLC, a Delaware limited liability company as" 16 successor to TENNE SSEE COMM ERCE 17 BANK, a Tennessee State chartered bank, ROSEVILLE PETROLEUM, INC., a California 18 and DOES ONE corporation, NIRMAL SINGH, 19 through TWENTY, inclusive, 20 Defendants. 21 22 PLACE: oe Law Offices of Paul A. Warner 1624 Santa Clara Drive, Suite 220 23 Roseville, Ca 95661 24 and TIME: Wednesday, January 10, 2018 at 10:00am DATE Person Most Knowledgeable at Roseville Petroleum, Inc. 25 DEPONENT: 26 TAKE NOTICE that on Wednesday, January 10, 2018 at 10:00am PLEASE 27 28 et = Rosevilleand Request forProduction ofDocuments Notice ofDeposition and continuing from day to day thereafter, excluding Sundays and Holidays, allparties represented by Paul A. Warner, Esq. will take the oral deposition of the Person Most Knowledgeable at Roseville Petroleum, Inc., before a qualified notary public. The areas of Inquiry will include: 1. Lease of the property at 2990-2998 Foothills Blvd., Roseville, CA, (“Property”) by _ Roseville Petroleum Inc. 2. Knowledge of the Lease atthe Property with Voyager Restaurant Group, Inc. 3. Communications with the Receiver appointed by the Placer County Superior Court 10 for the Property. id 4. Knowledge of any partnership agreement regarding Voyager Restaurant Group, Inc. 12 and/or the Property. 13 5. Sale of the property at 2990-2998 Foothills Blvd., Roseville, CA, (“Property”) by 14 Sonora Gasoline Corporation. 15 The deposition may be recorded steno graphically by the instant visual display of the testimony. 16 OF RECORD ARE. FURTHER ‘DEPONENT AND DEPONENT’S ATTORNEY 17 NOTIFIED and required by the Code of Civil Procedure Section 2025.220(4) to produce at the 18 deposition the following books, documents, or other things which are in your possession or under 19 20 your control: 21 REQUEST NO. 1: 22 Section 250, identified, All writings, as that term is defined California Evidence Code 23 referenced, or relied upon in response to PLAINTIFF’S Special Interrogatories Set No. One. 24 REQUEST NO. 2: 25 26 All writings, as that term is defined California Evidence Code Section 250, identified] 27 referenced, or relied upon in response to PLAINTIFF’S Request for Admissions Set No. One. 28 REQUEST NO. 3: oe Notice ofDeposition Rosevilleand Request forProduction of Documents All writings, as that term is defined California Evidence Code Section 250, identified, referenced, or relied upon in response toPLAIN TIFF’S Form Interrogatories Set No. One. REQUEST NO. 4: All writings, as that term is defined California Evidence Code Section 250, which relate |to YOUR lease of the property commonly known as the Arco AM/PM station at 2998 Foothills Blvd., Roseville, CA. REQUEST NO. 5: All writings, as that term is defined California Evidence Code Section 250, which relate 10 11 to Plaintiff's lease of the property which includes the restaurant premises at 2998 Foothills Blvd. 12 Roseville, CA, attached as Exhibit A to the Complaint. 13 REQUEST NO. 6: 14 All writings, as that term is defined California Evidence Code Section 250, which relate; 15 to YOUR communication with the Receiver appointed by the Court for the property at 2990- 16 17 2998 Foothills Blvd., Roseville, CA. pare. 3 DE 7 (py) VY 18 19 20 21 PAUL A. wanna Attorney for Plaintiff 22 Voyager Restaurant Group, Inc., a California 23 corporation 24 25 26 27 28 2 Bi Notice of DepositionRosevilleand Request forProduction of Documents PROOF OF SERVICE I am a citizen of the United States and am employed in Placer County, California. I am over the age of eighteen years and am not a party to the above-entitled action. My business _ address is: 1624 Santa Clara Drive, Suite 220, Roseville, CA, 95661. On the date specified below, Icaused the following document(s) to be served: Form Interrogatories Set No. 1 Special Interrogatories Set No.1 WN Request for Admissions Set No. 1. Request for the Production of Documents VR - Notice of Deposition with Production of Documents (X) (BY MAIL) Iam employed inthe County where the mailing described below occurred, and am readily familiar with the business practice for collection and processing of correspondence for mailing the United States Postal Services. Iplaced a true copy thereof [towhich was attached a copy of this 10 with in a sealed envelope(s) with postage thereon fully prepaid. The envelope(s) will be document(s)] 11 deposited with the United States Postal Service on this day inthe ordinary course of business in Roseville, California, following ordinary business practices. t2 Cc, (BY: PERSONAL SERVICE) I caused such envelope(s) to be delivered by hand tothe 13 addressee(s) listed below. 14 C) (BY FACSIMILE AND MAIL) I caused the document(s) listedabove to be served by 15 said document(s) to the number(s) listedbelow at the location(s) shown as follows and thereon telefaxing prepaid and deposited the envelope(s) with the United States Postal Service (as described in the 16 fully service by mail above). . 17 (_) (BY ELECTRONIC SERVICE) I caused the document(s) listedabove which have been served by e-mail to the addressee(s) listed below on J uly7, 2011. The transmission was 18 scanned to be reported as complete without error. 19 (BY FEDERAL EXPRESS) I caused the document(s) to be served by placing a true copy [towhich was attached a copy of this document (s] ina sealed Federal Express overnight 20 thereof bearing the address(es) listed below. The overnight envelope was then picked up by a Federal envelope employee atthe above business address in Roseville, California, or was deposited ina Federal 21. Express pick up drop box with encoding forovernight delivery before the expiration of the last Express marked 22 for overnight delivery tothe address(es) listed below. 23 Matthew C. Bradford / Marc B. Robinson Jack B. Burstein, Esq. ROBINSON BRADFORD LLP SMITH & BURSTE IN 24 3439 Brookside Road, Suite 210 1730 Sonoma Blvd Stockton, CA 95219 Vallejo,CA 94590-6085 25 under penalty of perjury under the laws of the State of California that the 26 I declare WO te nine) was executed/this /. 2, / J, 2017 at tal 27 foregoing is true and correct and that this 28 Roseville, California. PROOF OF SERVICE 1 of 1 © 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 EXHIBIT C Paul Warner From: Paul Warner Sent: Friday, December 29, 2017 3:38 PM To: ‘Matthew Bradford’ Cc: smithandburstein@comcast.net Subject: Voyager v Sonora SCV 0035599 Gentlemen, depositions of Nirmal Singh on January 11, 2018 and the PMK of Roseville |would liketo reschedule the noticed Petroleum on January 10, 2018 to January 17, 2018. Please advise ifthiswould 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: email transmission isconfidential and may be legally privileged, legally protected The information contained in this information. The information isintended only forthe use of the recipient(s) named attorney work-product, or may be inside inerror, please immediately notifyus by email toarrange forreturn of all above. If you have received this information on, distributi orthe taking ofany action in reliance on the contents of documents. Any unauthorized e, disclosur copying, this information isstrictlyprohibited, and may be . unlawful Paul Warner From: Matthew Bradford Wednesday, January 3, 2018 1:06 PM Sent: To: Paul Warner Ce: Marc Robinson; smithandburstein@comcast.net Subject: Re: Voyager v Sonora PMK of Roseville Petroleum and personally on January 10 and 11. Mr. Singh isnot available for his deposition as the Matthew C.Bradford, Esq. Robinson Bradford, LLP Direct Line: 858.480.6968 12:49 PM, Paul Warner wrote: On Wed, Jan 3, 2018 at for deposition on Thursday, January 4, 2018 or isto confirm that Mr. Burstein will not be producing witnesses | This | Friday, January 5, 2018. - PAUL ANTHONY WARNER, ESO. | 1624 SantaClaraDrive,Suite220 | Roseville, 95661 California | Telephone: 916.996.3100 | Fax: 916.789.7557 ~ CONFIDENTIALITY NOTICE: isconfidential and may be legally privileged, legally protected _ The information contained in this email transmission isintend ed only for the use of the recipient(s) work-product, or may be inside information. The information | attorney immedi ately notify us by email to arrange for return of If you have received this information in error,please named above. any action inreliance on the contents ure, disclos copying, ution, distrib orthe taking of alldocuments. Any unauthorized information is prohibited, strictly and may be unlawful. _ of this Paul Warner From: Matthew Bradford Sent: Wednesday, January 3, 2018 1:13 PM To: Paul Warner Subject: © Re: Voyager v Sonora Itwill be easier to get you a new date ifyou combine the PMK and Nirmal's depositions. Matthew C: Bradford, Esq. Robinson Bradford, LLP Direct Line: 858.480.6968 On Wed, Jan 3,2018 at 1:05 PM, Matthew Bradford wrote: | Mr. Singh isnot available for his deposition as the PMK of Roseville Petroleum and personally on January 10 and 11. Matthew C. Bradford, Esq. Robinson Bradford, LLP Direct Line: 858.480.6968 On Wed, Jan 3,2018 at 12:49 PM, Paul Warner wrote: This isto confirm that Mr. Burstein will not be producing witnesses for deposition on Thursday, January 4, 2018 or _. Friday, January 5, 2018. if i Po | PAUL ANTHONY WARNER, ESQ. || 1624Santa ClaraDrive,Suite220 | Roseville, California 95661 [| Telephone:916.996.3100 | Fax:916.789.7557 | CONFIDENTIALITY NOTICE: _ The information contained in this 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 Paul Warner From: Paul Warner Sent: Wednesday, January 3,2018 2:14 PM To: ‘Matthew Bradford’ Subject: RE: Voyager v Sonora When will he be available? From: Matthew Bradford [mailto:matthew@robinsonbradford.net] Sent: Wednesday, January 3, 2018 1:06 PM To: Paul Warner Cc: Marc Robinson ; smithandburstein@comcast.net Subject: Re: Voyager vSonora for his deposition as the PMK of Roseville Petroleum and personally on January 10 and 11. Mr. Singh isnot available Matthew C.Bradford, Esq. Robinson Bradford, LLP Direct Line: 858.480.6968 On Wed, Jan 3,2018 at 12:49 PM, Paul Warner wrote: Burstein will not be producing witnesses for deposition on Thursday, January 4, 2018 or. | This isto confirm that Mr. | Friday, January 5,2018. _ PAUL ANTHONY WARNER, ESQ. 1624 SantaClara Suite Drive, 220 | Roseville, California 95661 | Telephone: 916.996.3100 | Fax:916.789.7557 _ CONFIDENTIALITY NOTICE: transmission isconfidential and may be legally privileged, legally protected | The information contained in this email The information isintended only for the use of the recipient(s) _ attorney work-product, or may be inside information. please immediately notify us by email to arrange for return of _ named above. If you have received thisinformation in error, or the taking of any action inreliance on the contents © ' alldocuments. Any unauthorized disclosure, copying, distribution, | of thisinformation is prohibited, strictly and may be unlawful. 1 Paul Warner From: Paul Warner Sent: Friday, January 26, 2018 11:43 AM To: ‘Matthew Bradford’; ‘SMITH AND BURSTEIN’ Subject: RE: Voyager vSonora SCV 0035599 Confirming our telephone conversation today wherein you indicated that you would check with your 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 On Mon, Jan 1,2018 at 3:27 PM, SMITH AND BURSTEIN wrote: _ 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 toJanuary 17, 2018. Please advise if thiswould comport with your calendars. Thank you. PAUL ANTHONY WARNER, ESQ. 1624 SantaClaraDrive,Suite220 Roseville, California 95661 10 11.. 12 13 14 15 16 17 18 19 20 yal 22 23 24 25 26 27 28 EXHIBIT D Paul Warner From: Matthew Bradford Sent: Monday, January 29, 2018 11:59 AM To: Paul A. Warner Subject: Fwd: FW: Voyager v Sonora SCV 0035599 you should go forward with Nirmal's Singh's depo untilnew counsel isobtained. Given that news, | don't think Matthew C. Bradford, Esq. Robinson Bradford, LLP Direct Line: 858.480.6968 a--an=---Forwarded message ---------- From: Paul Warner Date: Mon, Jan 29, 2018 at 10:39 AM Subject: FW: Voyager v Sonora SCV 0035599 To: Matthew Bradford From: SMITH AND BURSTEIN [mailto:smithandburstein@comcast.net] Sent: Friday, January 26, 2018 1:12 PM To: Paul Warner Subject: RE: Voyager v Sonora SCV 0035599 Mr. Warner, Jack Burstein's daughter. |wanted to let you know that Mr. Burstein My name is Julie Steiner, | am | am in the process of figuring out the next steps, how to passed away unexpectedly this morning. attorneys, clients, etc. but wanted to reply to your email. notifty Thank you AM Paul Warner wrote: On January 26, 2018 at 11:42 10 id 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 EXHIBIT E Paul Warner From: Matthew Bradford Sent: Friday, February 2,2018 12:48 PM To: Paul Warner : SMITH AND BURSTEIN; COOKSEY & COMPANY LLC Cc: v Sonora Placer SCV 0035599 Deposition of Roseville Petroleum, Inc. and - Subject: Re: Voyager Nirmal Singh Agreed. Matthew C. Bradford, Esq. Robinson Bradford, LLP Direct Line: 858.480.6968 at 12:46 PM, Paul Warner wrote: On Fri,Feb 2,2018 | Mr. Bradford today wherein we agreed to continue the depositions of Roseville | This will confirm our telephone conversation for Monday, February 5, 2018, waiving the discovery cut-off, until - Petroleum, Inc. and Nirmal Singh scheduled Mr. Gr