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THE STATE OF TEXAS
DEPOSITION SUBPOENA FOR BUSINESS RECORDS OF 360 Wraps. Inc.
DC-21-07469
CAUSE NO.
Tommy Strader and Angela Strader IN THE DISTRICT COURT
Plaintiffs,
DALLAS COUNTY, TEXAS
VS.
Starwood Capital Group, LLC d/b/a
Residence Inn by Marriott Chico; Starwood 95th
Capital Group Global 1, LLC; Marriott JUDICIAL DISTRICT
International, Inc.; and DOES 1 through 75,
inclusive
Defendants.
To: 360 Wraps, Inc., 775 N. Royal Lane, DFW Airport, TX 75261
YOU ARE HEREBY COMMANDED to produce documents on at 9:00
a.m. at the offices of Eric Ratinoff Law Corp., 401 Watt Avenue, Sacramento, CA 95864. A copy
of the Written Commission to Take the Out-of-State Deposition Subpoena for Business Records
of 360 Wraps, Inc., issued by Sacramento Superior Court, California, is attached as Exhibit A. The
form of the Deposition Subpoena for Business Records, to be issued by Eric Ratinoff Law Corp.,
401 Watt Avenue, Sacramento, CA 95864., is attached as Exhibit B.
FAILURE BY ANY PERSON WITHOUT ADEQUATE EXCUSE TO OBEY A
SUBPOENA SERVED UPON THAT PERSON MAY BE DEEMED A CONTEMPT OF THE
COURT FROM WHICH THE SUBPOENA IS ISSUED OR A DISTRICT COURT IN THE
COUNTY IN WHICH THE SUBPOENA IS SERVED, AND MAY BE PUNISHED BY FINE
OR CONFINEMENT, OR BOTH.
Issued at the instance of Plaintiff Tommy Strader by the District Clerk of Dallas County,
Texas, on
Dallas County District Clerk
Petition to Enforce Out-of-State Commission
and Obtain Testimony in Out-of-State Action Page 16 of 16
EXHIBIT A
Order Granting Written Commission for Out-Of-State Deposition
Subpoena for Business Records of 360 Wraps, Inc.
Petition to Enforce Out-of-State Commission
and Obtain Testimony in Out-of-State Action
Page 14 of 17
| “Erie 7 Ratinodt
ERIC RATINOFF
WaTHOUT ATTORNEY (lame, Stato
LAW CORP.
Bar munber, at con
COPY
FOR COURT
USE ONLY
401 Watt Avenue, SACRAMENTO, CA 95864
TELEPHONE NO. 916-970-9100 FAX NO. (Opsonas:9 16-246-1696
E-MAn ADDRESS,
ATTORNEY FOR (Nene: Tommy Strader
‘SUPERIOR COURT OF CALIFORNIA, COUNTY OF SACRAMENTO
‘STREET ADORESS: 720 Oth Street
(MALIN ADORESS: 720 9th Street
‘TY AND UP CODE:Sacramento, 95814
BRANCH HAME:Gordon D. Schaber Sacramento County Courthouse
q SHORT TITLE: Strader v. Starwood, et al.
‘CASE NUMBER:
COMMISSION TO TAKE DEPOSITION OUTSIDE CALIFORNIA
(J onvenep sy count ISSUED BY THE CLER 34-2017-00224470
OF THE K
COURT
1. ‘The Superior Court of Catifomia hereby authorizes the deposition, upon oral examination, of (identity af
360 Wraps, Inc., 775 N. Royal Lane, DFW Airport, TX 75261
deponent):
BY FAX
2. ‘The deposition ts to be taken in (state of the United States, territory, or insular possession subject to its
jurisdiction):
Dallas County, Texas
‘3. The deposition will be conducted (check ane):
a. LX) Under the supervision of a person who is authorized to administer oaths by the laws of the United States or those of the
place where the examination Is to be held, and who Is not otherwise disquafified under Califomia Code of
Civil Procedure
sections 2025.320 and 2025.340(b}-{f); or
b. (5) Before (name
of appointee):
who Is appointed to administer oaths and to take testimony.
4. The documents or things to be produced at the time and piace of the deposition are
CX) described in Attachment 4 fone.
5. cures Se required by the foreign jurisdiction to Initiate the process are contained in Attachment 5. Number of
pages
6. Under Califomia Code of Civil Procedure section 2026.01, Califomla authorizes that a commission to take an out-of-state
deposition may be issued by the clerk of the court or, if the foreign jurisdiction requires it, by order of the court.
r The Superior Court of the State of California hereby requests that process Issue in the above-referenced place where the
examination is to be held, requiring the attendance and enforcing the obligations of tte deponent to produce
documents and
answer questions.
pat: APRIG 20
Q Judge :
Count Seal
oan by A. PEMELTON
Soe
(O1SC-030
[Mew January {, 2006}
COMMISSION TO TAKE -
DEPOSITION OUTSIDE CALIFORNIA
Page ott
‘Code GW. roe, § 20260109)
‘WerstawDoc & Form Gulider=
ATTACHMENT 4
ATTORNEY OR PARTY WITHOUT ATTORNEY (Meme, Stats Gar number, ard adchanal: SUBP-025
EricJ. Ratinot SBN: 1 66204 FOR COURT
USE ONLY
[ERIC RATINOFF LAW CORP.
401 Watt Avenue
SACRAMENTO, CA 95864
TELEPHONE NO-9 1 6-970-9100 FAX NO. (Opt0989'916-246-1696
EMAIL ADDRESS (Optb8 eric
@ericratinoff.com
ATTORNEY FOR (Name): Tommy Strader
SUPERIOR COU
OF CALIFORNI
RT A, COUNTY OF SACRAMENTO
STREET ADDRESS: 720 Oth Street
WARING ADORESS:720 9th Street
CITY AND P CODE: Sacramento, 95814
BRANCH NAME: Gordon D. Schaber Sacra
County
mentoCourthouse
PLAINTIFF/ PETITIONER: Strader, et al.
DEFENDANT/ RESPONDENT: Starwood Capital Group, LLC 34-2017-00224470
‘NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION
Civ. Proc., §§ 1985.3,1985.6)
NOTICE TO CONSUMER OR EMPLOYEE
° (name): Angela Strader
PLEASE TAKE NOTICE THAT REQUESTING PARTY {name):Tommy Strader
SEEKS YOUR RECORDS FOR EXAMINATION by the parties to this action on (specity date)-May 19, 2021
‘The records are described in the subpoena directed to witness (specify name and
address of person or entity trom whom records
are sought}: 360 Wraps, Inc., 775 N. Royal Lane, DFW Airport, TX 75261
A copy
of the subpoena
is attached. :
IF YOU OBJECT to the production of these records, YOU MUST DO ONE OF THE FOLLOWIN
G BEFORE ‘THE DATE SPECIFIED.
IN ITEM a. OR b. BELOW:
action, , YOU
@. If you are a party to the above-entitied MUSt file @ motion pursuant to Cade of Civ Procedure section 1987.1 to
quash or modify the subpoena and give Notice of that motion to the witness and th ‘deposition officer named In the
i subpoena
at least five days before the date set for production of the records.
». Ifyou are not a party to this action, you must serve on the requesting party and on the witness,
before the date set for
of the records,
a written Objection that states the specific grounds on which production of such records
prohibited. You may use theform below to. object and state the grounds for your abjection. You must complete should be
the Proof of
Service on the reverse
site Indica! you ‘or mailed the
with the court. WARNING: IF YOUR OBJECTION IS NOT RECEIVED BEFORE THE DATE SPECIFIED INIInshould nat be filed
in. The
RECORDS MAY BE PRODUCED AND MAY BE AVAILABLE TO ALL PARTIES. ITEM 1, YOUR
3. YOU OR YOUR ATTORNEY MAY CONTACT THE UNDERSI IGNED to determine whether an agreement can
to cancal or limit the scope of the subpoena. It no such be reached inwriting
reement is reached, and If you are not byan
attorney in this action, YOU SHOULD CONSULT AN ATTORI INEY TO ADVISE YOU OF YOUR RIGHTS OF PRIVACY.
Data: April 16, 2021
Eric. Ratinoff__
{TYPEOA PRINT NAME) > /s/ Eric J. Ratinoft
(eonaTuREOr [7 ]mecuesmc panty [3C) attorney
OBJECTION BY NON-PARTY TO PRODUCTION OF RECORDS.
1.7) | object to.the production of al of my records specified In the subpoena.
2. [7] object only to the production of the following specified records:
3. The specific grounds for my objection are as foliows:
Date:
{TYPE OR PRINT NAME}
>
(SIGNATURE)
(Proot et service
on reverse) tel:
‘Form Adopted for Mandatory Use Pogo 112
‘Judicial Counc al NOTICE TO CONSUMER OA EMPLOYEE AND OBJECTION ‘Gade of Ga Procedure,
‘SUBP-025
fev. denuary 1, 2008) 19853.11
zaan.910-2020.510
Westertne Fae Bader
SUBP-025
PLAINTIFF/PETITIONER: Strader, et al. oa
DEFENDANT/RESPONDENT: Starwood Capital Group, LLC 34-2017-00224470
PROOF OF SERVICE OF NOTICE TO CONSUMER OR aero YEE AND OBJECTION
Civ. Proc., §§ 1985.3,1985.6)
[1] Personal Service [CX] mall
1. At the time of service | was at least 18 years of age and not a party to this legal
action.
2. lserveda Copy of the Notice to Consumer or Employee and Objection as follows (check elther
a or b}:
aC] Personal service. | personally delivered the Notice to Consumer or Employee and Objection as follows:
(1) Name of person served: (3) Date served:
(2) Address where served: (4) served:
bv. GO) mait | deposited the Notice to Consumer or Employee and Objection in the United States mall,
In a sealed envelope
with postage fully prepald. The envelope was addressed as follows:
{1) Name of person served: See Attached Service List {3} Date of mailing: April 16, 2021
(2) Address: See Attached Service List
(4) Place ofIaling (oly and state.
(5)| ama resi of ordent
employed in the county where the Notice to Consumer or Employee and Objection was mailed.
¢ My residence or business address Is (specify): 401 Watt Avenue, Sacramento
, CA 95864
d. My phone number ts (specify): 916-970-9100
\ declare under penalty of perjury under the laws of the State of California that foregoing is true and correct.
Date: April 16, 2021 |
(TYPE OF PRIN
NAMETOF PERS
WHO SERVED)
ON TURE OF |
PROOF OF SERVICE OF OBJECTION TO PRODUCTIONLO
RECORDS
F
(Code Civ. Proc., §§ 1985.3,1985.6)
Personal Service [—] Mail
1 At the time of service | was at least 18 years of age and not a party to this legal action.
2. I served a copy of the Objection to Production of Records as follows {compiete either a or bj:
a ON THE REQUESTING PARTY
(1) [1] Personal service. | personally delivered the Objection to Production of Records as follows:
(1) Nameof person served:
(ii) Date served:
(W) Address where served: (lv) Time served:
(2) () Mail. | depositethe
d Objection to Production af Records in the United States mall, in a sealed envelope with
postage fully prepaid. The envelope was addressed as follows:
() Name of person served:
(ii} Date of malting:
(ii) Address:
(iv) Place of mailing (city and state):
(v) am a resident of or employed In the county where the Objection to Production of Records was malted.
b. ONTHE WITNESS
ayn Personal service. | personally delivered the Objection to Production of Records as follows:
() Name of person served: (ii) Date served:
(ji) Address where served: (iv) Time served:
(2) (=) Mall. | depositethe
d Objtoect
Production ion
of Records inthe United States mail, in a sealed envelope with
Postage fully prepaid. The envelope was addressed as follows:
() Name of person served: (ii) Date of mailing:
(0) Address: {iv) Place of malling (city and state):
(v) I am a resident of or employed in the county where ‘the Objection to Production of Records was mailed.
3. My residence or business address Is (specify):
4.” My phone number is (specity):
''dectare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
(TYPE OR PRINT WAME OF PERSON WHO SERVED)
>
{SIGNAOF PERSONTUR
WHO SERVED)
E —_
‘SuBe. 025 | Rev. January
#, 2008) NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION Pegs zota
MAILING LisT
John Demas ATTORNEY FOR PLAINTIFF ANGELA
Demas Law Group, P.C. STRADER
701 Howe Avenue, Suite A-1
Sacramento, CA 95825
jnd@demaslawgroup.com
ariana@demaslawgroup.com
James Donahue ATTORNEYS FOR DEFENDANTS/CROSS
Michael Myers COMPLAINANTS STARWOOD CAPITAL
Kirstopfor K. Helm GROUP, LLC, dba RESIDENCE INN BY
Donahue Davies MARRIOTT CHICO; STARWOOD CAPITAL
PO Box 277010 GROUP GLOBAL 1 LLC, MARRIOTT
10
Sacramento, CA 95827 INTERNATIONAL, INC., PILLAR HOTELS
11 khelm@donahuedavies.com AND RESORTS, LLC; IM CHICO | LP AND
jdonahue@donahuedavies.com IM CHICO 1 OPCO, LLC.
12 khelmy ah lavies.com
ScOXx{ uedavies. m2.
13
14
15 Stephanie Forman, Esq. ATTORNEYS FOR CROSS-
Roger W. Backlar, Esq. DEFENDANT/CROSS-
16 Tharpe & Howell LLP COMPLAINANT/DEFENDANT
15250 Ventura Boulevard, Ninth Floor HONEYWELL INT ERNATIONAL INC.
17 Sherman Oaks, CA 91403
rbackl: ‘howell.com
18 sforman@tharpe-howell.com
19 Jeannine L. Lee ATTORNEYS FOR CROSS-
Kadee L. Anderson DEFENDANT/CROSS-
20 Stinson LLP COMPLAINANT/DEFENDANT
50 South Sixth St, Ste. 2600 HONEYWELL INTERNATIONAL INC.
21 Minneapolis, MN 55402
Kadee.anderson@stinson.com
22
23
24
25
26
27
28
-l-
Sumair S. Sandhu ATTORNEYS FOR
Sandhu Law Corp. DEFENDANT/CROSS-
180 Promenade Circle, Ste. 300 DEFENDANT UNICONTROL,
Sacramento, CA 95834 INC. dba CLEVELAND
ssandhu@sanhulg.com CONTROLS
Krsto Mijanovic ATTORNEY FOR CROSS-DEFENDANT
Sinny B. Thai AND CROSS-COMPLAINANT A.O.
Steven A. Scordalakis: SMITH CORPORATION
Haight Brown & Bonesteel LLP
555 S. Flower Street, 49" F}
Los Angeles, CA 90071
sscordalaki: hbblaw.cor
kmijanovic@hbblaw.com
sthai@hbblaw.com
10 edocs@hbblaw.com
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2.
SUBP-010
ATTORNEY OR PARTY WITHOUT ATTORNEY
(Masa, Stpto Bar number, and FOR COURT
USE ONLY
}-Eric J. Ratis SBN: 166204
ERICJ SATINOFF LAW CORP.
401 Watt Avenue, SACRAMENTO, CA 95864
TEEHONEHO916-970-9100 Faxn0.916-246-1696
EMAL. com
ATTORN
For puoneiTo
EYmmy Strader
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SACRAMENTO
‘STREET ADORESS:720 9th Street
MAILING ADDRESS:720 9th Street
rT ano zip CODE:Sacramento, 95814
BRANCH NAME Gordon D. Schaber Sacramento County Courthouse
PLAINTIFFIPETITIONER: Strader, et al.
DEFENOANTIRESPONDENT: Starwood Capital Group,
DEPOSITION SUBPOENA
FOR PRODUCTION OF BUSINESS RECORDS 34-2017-00224470
THE PEOPLE OF THE STATE OF CALIFORNIA, TO address,
and telephone number of ffi :
360 Wraps. Inc.. 775 N. Royal lane. DFW Airport. 75261 telephone number: 214-432-9029
1. YOU ARE ORDERED TO PRODUCE THE BUSINESS RECORDS desc in ribe
item 3, as follows:
d
Ta (name of deposition officer):Record Retrieval Solutions
On (data) :May 19, 2021 At (time): 10:00 a.m.
Location (address):210 S Sierra Avenue, Suite 211, Oakdale, CA 95361
Do not relea
the requested
se records to the deposition officer prior to the date and time stated above.
a. (22) by celivering a true, legible, and durable copy of the business records described in tem 3, enclosed in a sealed inner
wrap with the
per tite and numbe of the action,
r name of witness, and date of subpoena clearly written on it. The inner
‘wrapper shall then be enciosed in an outer envelope or wrapper, sealed, ‘and mailed ta the deposition officer
at the
addressin item 1
b. [1 by delivering @ true, legible, and durable copy of the business records described in item 3 to the deposition officer
at the
witness's address, on receipt of payment In cash or by check of the reasonable costs ofpreparing the copy, as determined
under Evidence Code section 1563(b).
cc. [] by making the original business records describad in item 3 available for inspection at your business address by
the
‘attomey's representative and permitting copying at your business address under reasonable conditions
during normal
business hours.
2._ The records are to be produced by.the date and time shown in item 1 (but not sooner than 20 days after the issuence of the
* deposition subpoena, or 15 days after service, whichever date is later). Reason costs of locating
abl records,
e makir them
availableor copying them, and postage, if any, are recoverable @8 set forth In Evidence Code section 1563(b). The records
@ccompanied by an
shall be
effidavit of the custodian or other qualified witness pursuant to Evidence Code section 1561.
3. The recordsto be produced are described as follows (if ‘Stored information
is demanded, the form or
forms in which each type of information is to be produced may be specified): See Attachment 3
T) Continued on Attachment 3.
4. IF YOU HAVE BEEN SERVED WITH THIS SUBPOENA AS A CUSTODIAN OF CONSUMER OR EMPLOYEE
CODE OF CIVIL PROCEDURE SECTION 1965.3 OR 1985.6 AND A MOTION TO QUASH OR AN OBJECTION RECORDS
HAS BEEN
UNDER
SERVED ON YOU, A COURT ORDER OR AGREEMENT OF THE PARTIES, WITNESSES, AND CONSUMER OR EMPLOYEE
AFFECTED MUST BE OBTAINED BEFORE YOU ARE REQUIRETO D PRODUCE CONSUMER OR EMPLOYEE RECORDS.
DISOBEDIENCE OF THIS SUBPOENA MAY BE PUNISHED AS CONTEMPT BY THIS COURT.
YOU WILL ALSO BE LIABLE
FOR THE SUM OF FIVE HUNDRED DOLLARS AND ALL DAMAGES RESULTING FROM YOUR FAILURE TO OBEY.
Date issued pril 16, 2021
Eric J. Ratinoff_ D _/s/Eric
J. Ratinoff
(HYPER PRINT NAME (SIGNATURE
OF PERSON ‘SUING SUBPOENA)
Aftomey for Tommy Strader 0
(Proof
of service on reverse) erTruey
Form Adopted
tor Mandatory Use Pago totz
DEPOSITION SUBPOENA FOR PRODUCTION ‘Code of Cait Pronsdure,
§§ 2020.610-2020,
SUBSTpor aaa ea OF BUSINESS RECORDS 8007.1
‘www cour.ca.90¥
‘Westlaw
Doc & Form Bullder~
SUBP-010
L PLAINTIFF/PETITIONER: Strader, et al.
134-2017-00224470
DEFENDANT/RESPONDENT: Starwood Capital Group, LLC_
PROOF
OF SERVICE OF FOR
PRODUCTION OF BUSINESS RECORDS
1. oe Deposition Subpoene for Production of Business Records by personally delivering
a copy to the person served
a. Person served (name):360 Wraps, Inc., 775 N. Royal lane, DFW Airport,
TX 75261
b. Address where served:
¢. Date ofdoivery:
@. Time of delivery:
e. (1) J Witness foes ware paid.
Amount: .
(2) Co Copying fees were paid.
Amount:
f. Fee for service:
2. | received this subpoena for service on (date):
3. Person serving:
a. (J Nota registered California process server,
b. LJ Califomia sheriff or marshal.
c. C_] Registered Califomia process server.
d. L_] Employee or independent contractor ofa registered California process server.
e. [_] Exempt trom registration under Business and Professions Code section 22350(b).
1. Registered professional photocopier.
9. [_) Exempt trom registration under Business and Professions Code section 22451,
h. Name, address, telephone number, and, if applicable, county of registration and
number.
| declare under penalty of perjury under the laws of the State of (For California sheriff or marshal use only)
California that the foregoing is true and correct {certify that the foregoing Is true and correct.
Date: Date:
b b
(SIGNATURE) (SIGNATURE)
‘SUBP-O10
Rev. January 1, 201) DEPOSITION SUBPOENA FOR PRODUCTION Page2of2
OF BUSINESS RECORDS
ATTACHMENT 3
1 Any and all Corporate Tax Retums for 2012 including, but not limited to, 1120-S
returns for 360 Wraps, Inc.
2. Any and all Corporate Tax Returns for 2013 including, but not limited to, 1 120-S
returns for 360 Wraps, Inc.
3 Any and all Corporate Tax Returns for 2014 including, but not limited to, 1120-S
returns for 360 Wraps, Inc.
4 Any and all Corporate Tax Returns for 2015 including, but not limited to, 1120-S
returns for 360 Wrap, Inc.
5 _ Any and all Corporate Tax Returns for 2016 including, but not limited to, 1120-S
retums for 360 Wrap, Inc.
6. Any and all Corporate Tax Retums for 2017 including, but not limited to, 1120-S
returns for-360 Wrap, Inc.
7. Any and all Corporate Tax Returns for 2018 including, but not limited to, 1120-S
returns for 360 Wrap, Inc.
8, Any and all Corporate Tax Returns for 2019 including, but not limited to, 1120-S
returns for 360 Wrap, Inc.
9. Any and all Corporate Tax Returns for 2020 including, but not limited to, 1120-S
retums for 360 Wrap, Inc.
10. Any and all individual K1s for each owner for 2012 for 360 Wraps, Inc.
1 Any and all individual K1s for each owner for 2013 for 360 Wraps, Inc.
12. Any and’all individual K1s for each owner for 2014 for 360 Wraps, Inc.
13 Any and all individual K1s for each owner for 2015 for 360 Wraps, Inc.
14. Any and all individual K1s for each owner for 2016 for 360 Wraps, Inc.
15 Any and all individual K1s for each owner for 2017 for 360 Wraps, Inc.
16. Any and all individual K1s for each owner for 2018 for 360 Wraps, Inc.
17. Any and all individual K1s for each owner for2019 for 360 Wraps, Inc.
18. Any and all individual K1s for each owner for 2020 for 360 Wraps, Inc.
19. Any and all year-end balance sheets for 2012 for 360 Wraps, Inc.
20. Any and all year-end balance sheets for 2013 for 360 Wraps, Inc.
21 Any and all year-end balance sheets for 2014 for 360 Wraps, Inc.
22. Any and all year-end balance sheets for 2015 for 360 Wraps, Inc.
23 Any and all year-end balance sheets for 2016 for 360 Wraps, Inc.
Any and all year-end balance sheets for 2017 for 360 Wraps, Inc.
25. Any and all year-end balance sheets for oe for 360 Wraps, Inc.
26. Any and all year-end balance sheets for 2019 for 360 Wraps, Inc.
27. Any and all year-end balance sheets for 2020 for 360 Wraps, Inc.
28 Any and all year end Profit and Loss Statements for 2012 for 360 Wraps, Ine.
29. Any and all year end Profit and Loss Statements for 2013 for 360 Wraps, Inc.
30. Any and all year end Profit and Loss ee for 2014 for 360 Wraps, Inc.
31 Any and all year end Profit and Loss Statements for 2015 for 360 Wraps, Inc.
32. Any and all year endProfit and Loss Statements for 2016 for 360 Wraps, Inc.
33. Any and all year end Profit and Loss Statements for 2017 for 360 Wraps, Inc.
34. Any and all year end Profit and Loss Statements for 2018 for360 Wraps, Inc.
35. Any and all year end Profit and Loss Statements for 2019 for 360 Wraps, Inc.
36. Any and all year end Profit and Loss Statements for 2020 for 360 Wraps, Inc.
37. Any and all year-to-date Profit and Loss Statements for 2012 for 360 Wraps. Inc.
38. and a year-to-date Profit and Loss Statements for 2013 for 360 ‘Wraps, Inc.
39 Any and all year-to-date Profit and Loss Statements for 2014 for 360 Wraps, Inc.
40. Any and all aoa. Profit and Loss Statements for 2015 for 360 Wraps, Inc.
4). Any and all year-to-date Profit and Loss Statements for 2012 for 360 Wraps, Inc.
42. Any and all year-to-date Profit and Loss Statements for 2013 for 360 Wraps, Inc.
43. Any and all year-to-date Profit and Loss Statements for 2014 for 360 Wraps, Inc.
44. Any and all year-to-date Profit and Loss Statements for 2015 for 360 Wraps, Inc.
45. Any and all year-to-date Profit and Loss Statements for 2016 for 360 Wraps, Inc.
46. Any and all year-to-date Profit and Loss Statements for 2017 for 360 Wraps, Inc.
47. Any and all year-to-date Profit and Loss Statements for 2018 for 360 Wraps, Inc.
48. Any and all year-to-date Profit and Loss Statements for amd for 360 Wraps, Inc.
0. Any and all year-to-date Profit and Loss Statements for 2020 for 360 Wraps, Inc.
51. Any and all monthly Profit and Loss Statements for 2020.
52. Any and all corporate bank en for the year 2012 for 360 Wraps, Inc.
53. Any and all corporate bank statements for the year 2013 for 360 Wraps, Inc.
54. Any and all corporate bank statements for the year 2014 for 360 Wraps, Inc.
55. Any and all corporate bank statements for the year 2015 for 360 ‘Wraps, Inc.
56. Any and all corporate bank statements for the year 2016 for 360 Wraps, Inc.
57. Any and allcorporate bank statements for the year 2017 for 360 Wraps, Inc.
58. Any and all corporate bank statements for the year 2018 for 360 Wraps, Inc.
59, Any and all corporate bank statements for the year 2019 for 360 Wraps, Inc.
60. Any and all corporate bank statements for the year 2020 for 360 Wraps, Inc.
Any and all corporate bank statements for the year 2021 for 360 Wraps, Inc.
62. Any and all bank statement including, but not limited to, Annual Statements for a
active accounts for 2012 for 360 Wraps, Inc.
63. Any and all bank statement including, but not limited to, Annual Statements for all
active accounts for 2013 for 360 Wraps, Inc.
64. Any and all bank statement including, but not limited to, Annual Statements for all
active accounts for 2014 for 360 Wraps, Inc.
. Any and all bank statement including, but not limited to, Annual Statements for all
active accounts for 2015 for 360 Wraps, Inc.
66. Any and all bank statement including, but not limited to, Annual Statements for all
active accounts for 2016 for 360 Wraps, Inc.
67. Any and ali bank statement including, but not limited to, Annual Statements for all
active accounts for 2017 for 360 Wraps, Inc.
68. Any and all bank statement including, but not limited to, Annual Suen for all
active accounts for 2018 for 360 Wraps, Inc.
69. Any and all bank statement including, but not limited to, Annual Statements for all
active accounts for 2019 for 360 Wraps, Inc.
70. Any and all bank statement including, but not limited to, Annual Statements for all
active accounts for 2020 for 360 Wraps, Inc.
71. Any and all bank statements including, but not limited to, monthly statements for each
month for 2020 for 360 Wraps, Inc.
72. Any and all payroll paid to owners by owner for 2012 for 360 Wraps, Inc. :
73. Any and all payroll paid.to owners by owner for 2013 for 360 Wraps, Inc.
74. Any and all payroll paid to owners by owner for 2014 for 360 Wraps, Inc.
75. Any and all payroll paid to owners by owner for 2015 for 360 Wraps, Inc.
76. Any and all payroll paid to owners by owner for 2016 for 360 Wraps, Inc.
77.Any and all payroll paid to owners by owner for 2017 for 360 Wraps, Inc.
2B. Any and all payroll paid to owners by owner for2018 for 360 Wraps, Inc.
79. Any and all payroll paid to owners by owner for 2019 for 360 Wraps, Inc.
80. Any and all payroll paid to owners by owner for 2020 for 360 Wraps, Inc.
81. Any and all owner's distribution paid to owners by owner for 2012 for 360 Wraps, Inc.
82. Any and all owner's distribution paid to owners by owner for 2013 for 360 Wraps, Inc.
83.Any and all owner's distribution paid to owners by owner for 2014 for360 Wraps, Inc,
84. Any and all owner's distribution paid to owners by owner for 2015 for 360 Wraps, Inc.
85. Any and all owner's distribution paid to owners by owner for 2016 for 360 Wraps, Inc.
86. Any and all owner's distribution paid to owners by owner for 2017 for 360 Wraps, Inc.
87. Any and i owner's distribution paid to owners by owner for 2018 for 360 Wraps, Inc.
88. Any and all owner's distribution paid to owners by owner for 2019 for 360 Wraps, Inc.
89. Any and all owner's distribution paid to owners by. owner for 2020 for 360 Wraps, Inc.
90. Any and all analysis of changes in ownership equity for 2012 for 360 Wraps, Inc.
91. Any and all analysis of changes in ownership equity for 2013 for 360 Wraps, Inc.
92. Any and all analysis of changes in ownership equity for 014 for 360 Wraps, Inc.
93. Any and all analysis of changes in ownership equity for 2015 for 360 Wraps, Inc.
94. Any and all analysis of changes in ownership equity for 2016 for 360 Wraps, Inc.
95. Any and all analysis of changes in ownership equity for 2017 for 360 Wraps, Inc.
96. Any and all analysis of changes in ownership equity for 2018 for 360 Wraps, Inc.
97, Any and all analysis of changes in ownership equity for 2019 for 360 Wraps, Inc.
98. Any and ailanalysis of changes in ownership equity for 2020 for 360 Wraps, Inc.
99. Any and all correspondence, emails, letters and/or text messages with any prospective
franchisee regarding franchising 360 Wraps, Inc.
100. Any and all documents relating to bonuses that Tommy Strader received from 360
Wraps, Inc. in 2012.
101. Any and all documents relating to bonuses that Tommy Strader received from 360
Wraps, Inc. in 2013.
102. Any and all documents relating to bonuses that Tommy Strader received from 360
Wraps, Inc. in 2014.
103. Any and all documents relating to bonuses that Tommy Strader received from 360
Wraps, Inc. in 2015..
104, Any and all documents relating to bonuses that Tommy Strader received from 360
Wraps, Inc. in 2016.
105. Any and all documents relating to bonuses that Tommy Strader received from 360
Wraps, Inc. in 2017.
106. Any and all documents relating to bonuses that Tommy Strader received from 360
Wraps, Inc. in2018.
107. Any and all documents relating to bonuses that Tommy Strader received from 360
Wraps, Inc. in 2019.
108. Any and all documents relating to bonuses that Tommy Strader received from 360
Wraps, Inc. in 2020.
109. Any and all documents relating to income that Tommy Strader received from 360
Wraps, Inc. in 2012.
110. Any and all docurnents relating to bonuses that Tommy Strader received from 360
Wraps, Inc. in 201 =
111. Any and all documents relating to bonuses that Tommy Strader received from 360
Wraps, Inc. in 2014,
112. Any and all documents relating to bonuses that Tommy Strader received from 360
‘Wraps, Inc. in 2015.
113. Any and all documents relating to bonuses that Tommy Strader received from 360
Wraps, Inc. in 2016.
114. Any and all documents relating to bonuses that Tommy Strader received from 360
Wraps, Inc. in 201 -
115. Any and all documents relating to bonuses.that Tommy Strader received from 360
‘Wraps, Inc. in 2018,
116. Any and all documents relating to bonuses that Tommy Strader received from 360
Wraps, Inc. in 2019.
117. Any and all documents relating to bonuses that Tommy Strader received from
360
Wraps, Inc. in 2020.
118. Any and all documents relating to disbursements that Tommy Strader received
from
360 Wraps, Inc. in 2012.
119. Any and all documents relating to disbursements that Tommy Strader received from
360 Wraps, Inc. in 2013.
120. Any and all documents relating to disbursements that Tommy Strader received from
360 Wraps, Inc. in 2014.
121. Any and all documents relating to disbursements that Tommy Strader received
from
360 Wraps, Inc. in 2015.
122. Any and all documents relating to disbursements that Tommy Strader received
from
360 Wraps, Inc. in 2016.
123. Any and all documents relating to a that Tommy Strader received from
360 Wraps, Inc. in 2017.
124. Any and all documents relating to disbursements that Tommy Strader received from.
360 Wraps, Inc. in 2018.
125. Any and ali documents relating to disbursements that Tommy Strader received oon
360 Wraps, Inc. in 2019.
126. Any and all documents ee to disbursements that Tommy Strader received from
360 Wraps, Inc. in 2020.
127. Any and all payroll records from 360 Wraps, Inc. Teflecting payments made to Tommy
Strader for 2012.
128. Any and all Payroll records from 360 Wraps, Inc. reflecting payments made to
Tommy Strader for 2013.
129. Any and all payroll records from 360 Wraps, Inc. reflecting payments made to
‘Tommy Strader for 2014.
130. “Any and all payroll records from 360 Wraps, Inc. reflecting a made to
Tommy Strader for 2015.
131. Any and all payroll records from 360 Wraps, Inc. reflecting payments made to
Tommy Strader for 2016.
132. Any and all payroll records from 360 Wraps, Inc, reflecting payments made to
Tommy Strader for 2017.
133. Any and all payroll records from 360 Wraps, Inc. reflecting payments made to Tommy
Strader for 2018.
a Any and all payroll records from 360 Wraps, Inc. reflecting payments made to
Tommy Strader for 2019.
135. Any and all payroll records from 360 Wraps, Inc. reflecting payments made to
Tommy Strader for 2020.
136. Any and all documents related to how Tommy Strader’s bonus was calculated for the
year 2012.
137. Any and all penne telated to how Tommy Strader's bonus was a for the
year 2013.
138. Any and all documents related to how Tommy Strader’s bonus was calculated for the
year 2014.
'
139. Any and all documents related to how Tommy Strader’s bonus was calculated for the
year 2015.
140. Any and all documents related to how Tommy Strader’s bonus was calculated for the
year 2016.
i - Any and all documents related to how Tommy Strader’s bonus was calculated for the
year 2017.
142. Any and all documents related to how Tommy Strader’s bonus was calculated for the
year 2018.
143. Any and all documents related to how Tommy Strader’s bonus was calculated for the
year 2019.
144. Any and all documents related to how Tommy Strader’s bonus was calculated for the
year 2020.
145. Any and all documents related to Tommy Strader's interest in 360 Wraps, Inc. being
bought out.
146. Any and all copies of Tommy Strader's W-2 forms for the year 2012.
147. Any and all copies of Tommy Strader’s W-2 forms for the year 2013.
148. Any and all copies of Tommy Strader's W-2 forms for the year 2014.
149. Any and all copies of Tommy Strader's W-2 forms for the year 2015
150. Any and all copies of Tommy Strader’s W-2 forms for the year 2016.
151. Any and ail copies of Tommy Strader’s W-2 forms for the year 2017.
152. Any and all copies of Tommy Strader’s W-2 forms for the year 2018.
153. Any and all copies of Tommy Strader's w-2 forms for the year 2019.
154. Any and all copies of Tommy Strader’s W-2 forms for the year 2020.
ATTACHMENT 5
-THE STATE OF TEXAS
SUBPOENA FOR WITNESS DEPOSITION/SUBPOENA DUCES TECUM
PURSUANT TO TEXAS RULES OF CIVIL PROCEDURE 176 AND 201
CAUSENO, Sacramento CA 34-2017-00224470 IN THE JUDICIAL DISTRICT COURT
OF DALLAS COUNTY, TEXAS
Tommy Strader & Angela Strader vs, Starwood Capital Group, LLC et al.
Plaintift Defendant
TO ANY SHERIFF OR CONSTABLE OF THE STATE OF TEXAS OR OTHER PERSON AUTHORIZED
Preview
THE STATE OF TEXAS DEPOSITION SUBPOENA FOR BUSINESS RECORDS OF 360 Wraps. Inc. DC-21-07469 CAUSE NO. Tommy Strader and Angela Strader IN THE DISTRICT COURT Plaintiffs, DALLAS COUNTY, TEXAS VS. Starwood Capital Group, LLC d/b/a Residence Inn by Marriott Chico; Starwood 95th Capital Group Global 1, LLC; Marriott JUDICIAL DISTRICT International, Inc.; and DOES 1 through 75, inclusive Defendants. To: 360 Wraps, Inc., 775 N. Royal Lane, DFW Airport, TX 75261 YOU ARE HEREBY COMMANDED to produce documents on at 9:00 a.m. at the offices of Eric Ratinoff Law Corp., 401 Watt Avenue, Sacramento, CA 95864. A copy of the Written Commission to Take the Out-of-State Deposition Subpoena for Business Records of 360 Wraps, Inc., issued by Sacramento Superior Court, California, is attached as Exhibit A. The form of the Deposition Subpoena for Business Records, to be issued by Eric Ratinoff Law Corp., 401 Watt Avenue, Sacramento, CA 95864., is attached as Exhibit B. FAILURE BY ANY PERSON WITHOUT ADEQUATE EXCUSE TO OBEY A SUBPOENA SERVED UPON THAT PERSON MAY BE DEEMED A CONTEMPT OF THE COURT FROM WHICH THE SUBPOENA IS ISSUED OR A DISTRICT COURT IN THE COUNTY IN WHICH THE SUBPOENA IS SERVED, AND MAY BE PUNISHED BY FINE OR CONFINEMENT, OR BOTH. Issued at the instance of Plaintiff Tommy Strader by the District Clerk of Dallas County, Texas, on Dallas County District Clerk Petition to Enforce Out-of-State Commission and Obtain Testimony in Out-of-State Action Page 16 of 16 EXHIBIT A Order Granting Written Commission for Out-Of-State Deposition Subpoena for Business Records of 360 Wraps, Inc. Petition to Enforce Out-of-State Commission and Obtain Testimony in Out-of-State Action Page 14 of 17 | “Erie 7 Ratinodt ERIC RATINOFF WaTHOUT ATTORNEY (lame, Stato LAW CORP. Bar munber, at con COPY FOR COURT USE ONLY 401 Watt Avenue, SACRAMENTO, CA 95864 TELEPHONE NO. 916-970-9100 FAX NO. (Opsonas:9 16-246-1696 E-MAn ADDRESS, ATTORNEY FOR (Nene: Tommy Strader ‘SUPERIOR COURT OF CALIFORNIA, COUNTY OF SACRAMENTO ‘STREET ADORESS: 720 Oth Street (MALIN ADORESS: 720 9th Street ‘TY AND UP CODE:Sacramento, 95814 BRANCH HAME:Gordon D. Schaber Sacramento County Courthouse q SHORT TITLE: Strader v. Starwood, et al. ‘CASE NUMBER: COMMISSION TO TAKE DEPOSITION OUTSIDE CALIFORNIA (J onvenep sy count ISSUED BY THE CLER 34-2017-00224470 OF THE K COURT 1. ‘The Superior Court of Catifomia hereby authorizes the deposition, upon oral examination, of (identity af 360 Wraps, Inc., 775 N. Royal Lane, DFW Airport, TX 75261 deponent): BY FAX 2. ‘The deposition ts to be taken in (state of the United States, territory, or insular possession subject to its jurisdiction): Dallas County, Texas ‘3. The deposition will be conducted (check ane): a. LX) Under the supervision of a person who is authorized to administer oaths by the laws of the United States or those of the place where the examination Is to be held, and who Is not otherwise disquafified under Califomia Code of Civil Procedure sections 2025.320 and 2025.340(b}-{f); or b. (5) Before (name of appointee): who Is appointed to administer oaths and to take testimony. 4. The documents or things to be produced at the time and piace of the deposition are CX) described in Attachment 4 fone. 5. cures Se required by the foreign jurisdiction to Initiate the process are contained in Attachment 5. Number of pages 6. Under Califomia Code of Civil Procedure section 2026.01, Califomla authorizes that a commission to take an out-of-state deposition may be issued by the clerk of the court or, if the foreign jurisdiction requires it, by order of the court. r The Superior Court of the State of California hereby requests that process Issue in the above-referenced place where the examination is to be held, requiring the attendance and enforcing the obligations of tte deponent to produce documents and answer questions. pat: APRIG 20 Q Judge : Count Seal oan by A. PEMELTON Soe (O1SC-030 [Mew January {, 2006} COMMISSION TO TAKE - DEPOSITION OUTSIDE CALIFORNIA Page ott ‘Code GW. roe, § 20260109) ‘WerstawDoc & Form Gulider= ATTACHMENT 4 ATTORNEY OR PARTY WITHOUT ATTORNEY (Meme, Stats Gar number, ard adchanal: SUBP-025 EricJ. Ratinot SBN: 1 66204 FOR COURT USE ONLY [ERIC RATINOFF LAW CORP. 401 Watt Avenue SACRAMENTO, CA 95864 TELEPHONE NO-9 1 6-970-9100 FAX NO. (Opt0989'916-246-1696 EMAIL ADDRESS (Optb8 eric @ericratinoff.com ATTORNEY FOR (Name): Tommy Strader SUPERIOR COU OF CALIFORNI RT A, COUNTY OF SACRAMENTO STREET ADDRESS: 720 Oth Street WARING ADORESS:720 9th Street CITY AND P CODE: Sacramento, 95814 BRANCH NAME: Gordon D. Schaber Sacra County mentoCourthouse PLAINTIFF/ PETITIONER: Strader, et al. DEFENDANT/ RESPONDENT: Starwood Capital Group, LLC 34-2017-00224470 ‘NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION Civ. Proc., §§ 1985.3,1985.6) NOTICE TO CONSUMER OR EMPLOYEE ° (name): Angela Strader PLEASE TAKE NOTICE THAT REQUESTING PARTY {name):Tommy Strader SEEKS YOUR RECORDS FOR EXAMINATION by the parties to this action on (specity date)-May 19, 2021 ‘The records are described in the subpoena directed to witness (specify name and address of person or entity trom whom records are sought}: 360 Wraps, Inc., 775 N. Royal Lane, DFW Airport, TX 75261 A copy of the subpoena is attached. : IF YOU OBJECT to the production of these records, YOU MUST DO ONE OF THE FOLLOWIN G BEFORE ‘THE DATE SPECIFIED. IN ITEM a. OR b. BELOW: action, , YOU @. If you are a party to the above-entitied MUSt file @ motion pursuant to Cade of Civ Procedure section 1987.1 to quash or modify the subpoena and give Notice of that motion to the witness and th ‘deposition officer named In the i subpoena at least five days before the date set for production of the records. ». Ifyou are not a party to this action, you must serve on the requesting party and on the witness, before the date set for of the records, a written Objection that states the specific grounds on which production of such records prohibited. You may use theform below to. object and state the grounds for your abjection. You must complete should be the Proof of Service on the reverse site Indica! you ‘or mailed the with the court. WARNING: IF YOUR OBJECTION IS NOT RECEIVED BEFORE THE DATE SPECIFIED INIInshould nat be filed in. The RECORDS MAY BE PRODUCED AND MAY BE AVAILABLE TO ALL PARTIES. ITEM 1, YOUR 3. YOU OR YOUR ATTORNEY MAY CONTACT THE UNDERSI IGNED to determine whether an agreement can to cancal or limit the scope of the subpoena. It no such be reached inwriting reement is reached, and If you are not byan attorney in this action, YOU SHOULD CONSULT AN ATTORI INEY TO ADVISE YOU OF YOUR RIGHTS OF PRIVACY. Data: April 16, 2021 Eric. Ratinoff__ {TYPEOA PRINT NAME) > /s/ Eric J. Ratinoft (eonaTuREOr [7 ]mecuesmc panty [3C) attorney OBJECTION BY NON-PARTY TO PRODUCTION OF RECORDS. 1.7) | object to.the production of al of my records specified In the subpoena. 2. [7] object only to the production of the following specified records: 3. The specific grounds for my objection are as foliows: Date: {TYPE OR PRINT NAME} > (SIGNATURE) (Proot et service on reverse) tel: ‘Form Adopted for Mandatory Use Pogo 112 ‘Judicial Counc al NOTICE TO CONSUMER OA EMPLOYEE AND OBJECTION ‘Gade of Ga Procedure, ‘SUBP-025 fev. denuary 1, 2008) 19853.11 zaan.910-2020.510 Westertne Fae Bader SUBP-025 PLAINTIFF/PETITIONER: Strader, et al. oa DEFENDANT/RESPONDENT: Starwood Capital Group, LLC 34-2017-00224470 PROOF OF SERVICE OF NOTICE TO CONSUMER OR aero YEE AND OBJECTION Civ. Proc., §§ 1985.3,1985.6) [1] Personal Service [CX] mall 1. At the time of service | was at least 18 years of age and not a party to this legal action. 2. lserveda Copy of the Notice to Consumer or Employee and Objection as follows (check elther a or b}: aC] Personal service. | personally delivered the Notice to Consumer or Employee and Objection as follows: (1) Name of person served: (3) Date served: (2) Address where served: (4) served: bv. GO) mait | deposited the Notice to Consumer or Employee and Objection in the United States mall, In a sealed envelope with postage fully prepald. The envelope was addressed as follows: {1) Name of person served: See Attached Service List {3} Date of mailing: April 16, 2021 (2) Address: See Attached Service List (4) Place ofIaling (oly and state. (5)| ama resi of ordent employed in the county where the Notice to Consumer or Employee and Objection was mailed. ¢ My residence or business address Is (specify): 401 Watt Avenue, Sacramento , CA 95864 d. My phone number ts (specify): 916-970-9100 \ declare under penalty of perjury under the laws of the State of California that foregoing is true and correct. Date: April 16, 2021 | (TYPE OF PRIN NAMETOF PERS WHO SERVED) ON TURE OF | PROOF OF SERVICE OF OBJECTION TO PRODUCTIONLO RECORDS F (Code Civ. Proc., §§ 1985.3,1985.6) Personal Service [—] Mail 1 At the time of service | was at least 18 years of age and not a party to this legal action. 2. I served a copy of the Objection to Production of Records as follows {compiete either a or bj: a ON THE REQUESTING PARTY (1) [1] Personal service. | personally delivered the Objection to Production of Records as follows: (1) Nameof person served: (ii) Date served: (W) Address where served: (lv) Time served: (2) () Mail. | depositethe d Objection to Production af Records in the United States mall, in a sealed envelope with postage fully prepaid. The envelope was addressed as follows: () Name of person served: (ii} Date of malting: (ii) Address: (iv) Place of mailing (city and state): (v) am a resident of or employed In the county where the Objection to Production of Records was malted. b. ONTHE WITNESS ayn Personal service. | personally delivered the Objection to Production of Records as follows: () Name of person served: (ii) Date served: (ji) Address where served: (iv) Time served: (2) (=) Mall. | depositethe d Objtoect Production ion of Records inthe United States mail, in a sealed envelope with Postage fully prepaid. The envelope was addressed as follows: () Name of person served: (ii) Date of mailing: (0) Address: {iv) Place of malling (city and state): (v) I am a resident of or employed in the county where ‘the Objection to Production of Records was mailed. 3. My residence or business address Is (specify): 4.” My phone number is (specity): ''dectare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. (TYPE OR PRINT WAME OF PERSON WHO SERVED) > {SIGNAOF PERSONTUR WHO SERVED) E —_ ‘SuBe. 025 | Rev. January #, 2008) NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION Pegs zota MAILING LisT John Demas ATTORNEY FOR PLAINTIFF ANGELA Demas Law Group, P.C. STRADER 701 Howe Avenue, Suite A-1 Sacramento, CA 95825 jnd@demaslawgroup.com ariana@demaslawgroup.com James Donahue ATTORNEYS FOR DEFENDANTS/CROSS Michael Myers COMPLAINANTS STARWOOD CAPITAL Kirstopfor K. Helm GROUP, LLC, dba RESIDENCE INN BY Donahue Davies MARRIOTT CHICO; STARWOOD CAPITAL PO Box 277010 GROUP GLOBAL 1 LLC, MARRIOTT 10 Sacramento, CA 95827 INTERNATIONAL, INC., PILLAR HOTELS 11 khelm@donahuedavies.com AND RESORTS, LLC; IM CHICO | LP AND jdonahue@donahuedavies.com IM CHICO 1 OPCO, LLC. 12 khelmy ah lavies.com ScOXx{ uedavies. m2. 13 14 15 Stephanie Forman, Esq. ATTORNEYS FOR CROSS- Roger W. Backlar, Esq. DEFENDANT/CROSS- 16 Tharpe & Howell LLP COMPLAINANT/DEFENDANT 15250 Ventura Boulevard, Ninth Floor HONEYWELL INT ERNATIONAL INC. 17 Sherman Oaks, CA 91403 rbackl: ‘howell.com 18 sforman@tharpe-howell.com 19 Jeannine L. Lee ATTORNEYS FOR CROSS- Kadee L. Anderson DEFENDANT/CROSS- 20 Stinson LLP COMPLAINANT/DEFENDANT 50 South Sixth St, Ste. 2600 HONEYWELL INTERNATIONAL INC. 21 Minneapolis, MN 55402 Kadee.anderson@stinson.com 22 23 24 25 26 27 28 -l- Sumair S. Sandhu ATTORNEYS FOR Sandhu Law Corp. DEFENDANT/CROSS- 180 Promenade Circle, Ste. 300 DEFENDANT UNICONTROL, Sacramento, CA 95834 INC. dba CLEVELAND ssandhu@sanhulg.com CONTROLS Krsto Mijanovic ATTORNEY FOR CROSS-DEFENDANT Sinny B. Thai AND CROSS-COMPLAINANT A.O. Steven A. Scordalakis: SMITH CORPORATION Haight Brown & Bonesteel LLP 555 S. Flower Street, 49" F} Los Angeles, CA 90071 sscordalaki: hbblaw.cor kmijanovic@hbblaw.com sthai@hbblaw.com 10 edocs@hbblaw.com 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 | 27 28 2. SUBP-010 ATTORNEY OR PARTY WITHOUT ATTORNEY (Masa, Stpto Bar number, and FOR COURT USE ONLY }-Eric J. Ratis SBN: 166204 ERICJ SATINOFF LAW CORP. 401 Watt Avenue, SACRAMENTO, CA 95864 TEEHONEHO916-970-9100 Faxn0.916-246-1696 EMAL. com ATTORN For puoneiTo EYmmy Strader SUPERIOR COURT OF CALIFORNIA, COUNTY OF SACRAMENTO ‘STREET ADORESS:720 9th Street MAILING ADDRESS:720 9th Street rT ano zip CODE:Sacramento, 95814 BRANCH NAME Gordon D. Schaber Sacramento County Courthouse PLAINTIFFIPETITIONER: Strader, et al. DEFENOANTIRESPONDENT: Starwood Capital Group, DEPOSITION SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS 34-2017-00224470 THE PEOPLE OF THE STATE OF CALIFORNIA, TO address, and telephone number of ffi : 360 Wraps. Inc.. 775 N. Royal lane. DFW Airport. 75261 telephone number: 214-432-9029 1. YOU ARE ORDERED TO PRODUCE THE BUSINESS RECORDS desc in ribe item 3, as follows: d Ta (name of deposition officer):Record Retrieval Solutions On (data) :May 19, 2021 At (time): 10:00 a.m. Location (address):210 S Sierra Avenue, Suite 211, Oakdale, CA 95361 Do not relea the requested se records to the deposition officer prior to the date and time stated above. a. (22) by celivering a true, legible, and durable copy of the business records described in tem 3, enclosed in a sealed inner wrap with the per tite and numbe of the action, r name of witness, and date of subpoena clearly written on it. The inner ‘wrapper shall then be enciosed in an outer envelope or wrapper, sealed, ‘and mailed ta the deposition officer at the addressin item 1 b. [1 by delivering @ true, legible, and durable copy of the business records described in item 3 to the deposition officer at the witness's address, on receipt of payment In cash or by check of the reasonable costs ofpreparing the copy, as determined under Evidence Code section 1563(b). cc. [] by making the original business records describad in item 3 available for inspection at your business address by the ‘attomey's representative and permitting copying at your business address under reasonable conditions during normal business hours. 2._ The records are to be produced by.the date and time shown in item 1 (but not sooner than 20 days after the issuence of the * deposition subpoena, or 15 days after service, whichever date is later). Reason costs of locating abl records, e makir them availableor copying them, and postage, if any, are recoverable @8 set forth In Evidence Code section 1563(b). The records @ccompanied by an shall be effidavit of the custodian or other qualified witness pursuant to Evidence Code section 1561. 3. The recordsto be produced are described as follows (if ‘Stored information is demanded, the form or forms in which each type of information is to be produced may be specified): See Attachment 3 T) Continued on Attachment 3. 4. IF YOU HAVE BEEN SERVED WITH THIS SUBPOENA AS A CUSTODIAN OF CONSUMER OR EMPLOYEE CODE OF CIVIL PROCEDURE SECTION 1965.3 OR 1985.6 AND A MOTION TO QUASH OR AN OBJECTION RECORDS HAS BEEN UNDER SERVED ON YOU, A COURT ORDER OR AGREEMENT OF THE PARTIES, WITNESSES, AND CONSUMER OR EMPLOYEE AFFECTED MUST BE OBTAINED BEFORE YOU ARE REQUIRETO D PRODUCE CONSUMER OR EMPLOYEE RECORDS. DISOBEDIENCE OF THIS SUBPOENA MAY BE PUNISHED AS CONTEMPT BY THIS COURT. YOU WILL ALSO BE LIABLE FOR THE SUM OF FIVE HUNDRED DOLLARS AND ALL DAMAGES RESULTING FROM YOUR FAILURE TO OBEY. Date issued pril 16, 2021 Eric J. Ratinoff_ D _/s/Eric J. Ratinoff (HYPER PRINT NAME (SIGNATURE OF PERSON ‘SUING SUBPOENA) Aftomey for Tommy Strader 0 (Proof of service on reverse) erTruey Form Adopted tor Mandatory Use Pago totz DEPOSITION SUBPOENA FOR PRODUCTION ‘Code of Cait Pronsdure, §§ 2020.610-2020, SUBSTpor aaa ea OF BUSINESS RECORDS 8007.1 ‘www cour.ca.90¥ ‘Westlaw Doc & Form Bullder~ SUBP-010 L PLAINTIFF/PETITIONER: Strader, et al. 134-2017-00224470 DEFENDANT/RESPONDENT: Starwood Capital Group, LLC_ PROOF OF SERVICE OF FOR PRODUCTION OF BUSINESS RECORDS 1. oe Deposition Subpoene for Production of Business Records by personally delivering a copy to the person served a. Person served (name):360 Wraps, Inc., 775 N. Royal lane, DFW Airport, TX 75261 b. Address where served: ¢. Date ofdoivery: @. Time of delivery: e. (1) J Witness foes ware paid. Amount: . (2) Co Copying fees were paid. Amount: f. Fee for service: 2. | received this subpoena for service on (date): 3. Person serving: a. (J Nota registered California process server, b. LJ Califomia sheriff or marshal. c. C_] Registered Califomia process server. d. L_] Employee or independent contractor ofa registered California process server. e. [_] Exempt trom registration under Business and Professions Code section 22350(b). 1. Registered professional photocopier. 9. [_) Exempt trom registration under Business and Professions Code section 22451, h. Name, address, telephone number, and, if applicable, county of registration and number. | declare under penalty of perjury under the laws of the State of (For California sheriff or marshal use only) California that the foregoing is true and correct {certify that the foregoing Is true and correct. Date: Date: b b (SIGNATURE) (SIGNATURE) ‘SUBP-O10 Rev. January 1, 201) DEPOSITION SUBPOENA FOR PRODUCTION Page2of2 OF BUSINESS RECORDS ATTACHMENT 3 1 Any and all Corporate Tax Retums for 2012 including, but not limited to, 1120-S returns for 360 Wraps, Inc. 2. Any and all Corporate Tax Returns for 2013 including, but not limited to, 1 120-S returns for 360 Wraps, Inc. 3 Any and all Corporate Tax Returns for 2014 including, but not limited to, 1120-S returns for 360 Wraps, Inc. 4 Any and all Corporate Tax Returns for 2015 including, but not limited to, 1120-S returns for 360 Wrap, Inc. 5 _ Any and all Corporate Tax Returns for 2016 including, but not limited to, 1120-S retums for 360 Wrap, Inc. 6. Any and all Corporate Tax Retums for 2017 including, but not limited to, 1120-S returns for-360 Wrap, Inc. 7. Any and all Corporate Tax Returns for 2018 including, but not limited to, 1120-S returns for 360 Wrap, Inc. 8, Any and all Corporate Tax Returns for 2019 including, but not limited to, 1120-S returns for 360 Wrap, Inc. 9. Any and all Corporate Tax Returns for 2020 including, but not limited to, 1120-S retums for 360 Wrap, Inc. 10. Any and all individual K1s for each owner for 2012 for 360 Wraps, Inc. 1 Any and all individual K1s for each owner for 2013 for 360 Wraps, Inc. 12. Any and’all individual K1s for each owner for 2014 for 360 Wraps, Inc. 13 Any and all individual K1s for each owner for 2015 for 360 Wraps, Inc. 14. Any and all individual K1s for each owner for 2016 for 360 Wraps, Inc. 15 Any and all individual K1s for each owner for 2017 for 360 Wraps, Inc. 16. Any and all individual K1s for each owner for 2018 for 360 Wraps, Inc. 17. Any and all individual K1s for each owner for2019 for 360 Wraps, Inc. 18. Any and all individual K1s for each owner for 2020 for 360 Wraps, Inc. 19. Any and all year-end balance sheets for 2012 for 360 Wraps, Inc. 20. Any and all year-end balance sheets for 2013 for 360 Wraps, Inc. 21 Any and all year-end balance sheets for 2014 for 360 Wraps, Inc. 22. Any and all year-end balance sheets for 2015 for 360 Wraps, Inc. 23 Any and all year-end balance sheets for 2016 for 360 Wraps, Inc. Any and all year-end balance sheets for 2017 for 360 Wraps, Inc. 25. Any and all year-end balance sheets for oe for 360 Wraps, Inc. 26. Any and all year-end balance sheets for 2019 for 360 Wraps, Inc. 27. Any and all year-end balance sheets for 2020 for 360 Wraps, Inc. 28 Any and all year end Profit and Loss Statements for 2012 for 360 Wraps, Ine. 29. Any and all year end Profit and Loss Statements for 2013 for 360 Wraps, Inc. 30. Any and all year end Profit and Loss ee for 2014 for 360 Wraps, Inc. 31 Any and all year end Profit and Loss Statements for 2015 for 360 Wraps, Inc. 32. Any and all year endProfit and Loss Statements for 2016 for 360 Wraps, Inc. 33. Any and all year end Profit and Loss Statements for 2017 for 360 Wraps, Inc. 34. Any and all year end Profit and Loss Statements for 2018 for360 Wraps, Inc. 35. Any and all year end Profit and Loss Statements for 2019 for 360 Wraps, Inc. 36. Any and all year end Profit and Loss Statements for 2020 for 360 Wraps, Inc. 37. Any and all year-to-date Profit and Loss Statements for 2012 for 360 Wraps. Inc. 38. and a year-to-date Profit and Loss Statements for 2013 for 360 ‘Wraps, Inc. 39 Any and all year-to-date Profit and Loss Statements for 2014 for 360 Wraps, Inc. 40. Any and all aoa. Profit and Loss Statements for 2015 for 360 Wraps, Inc. 4). Any and all year-to-date Profit and Loss Statements for 2012 for 360 Wraps, Inc. 42. Any and all year-to-date Profit and Loss Statements for 2013 for 360 Wraps, Inc. 43. Any and all year-to-date Profit and Loss Statements for 2014 for 360 Wraps, Inc. 44. Any and all year-to-date Profit and Loss Statements for 2015 for 360 Wraps, Inc. 45. Any and all year-to-date Profit and Loss Statements for 2016 for 360 Wraps, Inc. 46. Any and all year-to-date Profit and Loss Statements for 2017 for 360 Wraps, Inc. 47. Any and all year-to-date Profit and Loss Statements for 2018 for 360 Wraps, Inc. 48. Any and all year-to-date Profit and Loss Statements for amd for 360 Wraps, Inc. 0. Any and all year-to-date Profit and Loss Statements for 2020 for 360 Wraps, Inc. 51. Any and all monthly Profit and Loss Statements for 2020. 52. Any and all corporate bank en for the year 2012 for 360 Wraps, Inc. 53. Any and all corporate bank statements for the year 2013 for 360 Wraps, Inc. 54. Any and all corporate bank statements for the year 2014 for 360 Wraps, Inc. 55. Any and all corporate bank statements for the year 2015 for 360 ‘Wraps, Inc. 56. Any and all corporate bank statements for the year 2016 for 360 Wraps, Inc. 57. Any and allcorporate bank statements for the year 2017 for 360 Wraps, Inc. 58. Any and all corporate bank statements for the year 2018 for 360 Wraps, Inc. 59, Any and all corporate bank statements for the year 2019 for 360 Wraps, Inc. 60. Any and all corporate bank statements for the year 2020 for 360 Wraps, Inc. Any and all corporate bank statements for the year 2021 for 360 Wraps, Inc. 62. Any and all bank statement including, but not limited to, Annual Statements for a active accounts for 2012 for 360 Wraps, Inc. 63. Any and all bank statement including, but not limited to, Annual Statements for all active accounts for 2013 for 360 Wraps, Inc. 64. Any and all bank statement including, but not limited to, Annual Statements for all active accounts for 2014 for 360 Wraps, Inc. . Any and all bank statement including, but not limited to, Annual Statements for all active accounts for 2015 for 360 Wraps, Inc. 66. Any and all bank statement including, but not limited to, Annual Statements for all active accounts for 2016 for 360 Wraps, Inc. 67. Any and ali bank statement including, but not limited to, Annual Statements for all active accounts for 2017 for 360 Wraps, Inc. 68. Any and all bank statement including, but not limited to, Annual Suen for all active accounts for 2018 for 360 Wraps, Inc. 69. Any and all bank statement including, but not limited to, Annual Statements for all active accounts for 2019 for 360 Wraps, Inc. 70. Any and all bank statement including, but not limited to, Annual Statements for all active accounts for 2020 for 360 Wraps, Inc. 71. Any and all bank statements including, but not limited to, monthly statements for each month for 2020 for 360 Wraps, Inc. 72. Any and all payroll paid to owners by owner for 2012 for 360 Wraps, Inc. : 73. Any and all payroll paid.to owners by owner for 2013 for 360 Wraps, Inc. 74. Any and all payroll paid to owners by owner for 2014 for 360 Wraps, Inc. 75. Any and all payroll paid to owners by owner for 2015 for 360 Wraps, Inc. 76. Any and all payroll paid to owners by owner for 2016 for 360 Wraps, Inc. 77.Any and all payroll paid to owners by owner for 2017 for 360 Wraps, Inc. 2B. Any and all payroll paid to owners by owner for2018 for 360 Wraps, Inc. 79. Any and all payroll paid to owners by owner for 2019 for 360 Wraps, Inc. 80. Any and all payroll paid to owners by owner for 2020 for 360 Wraps, Inc. 81. Any and all owner's distribution paid to owners by owner for 2012 for 360 Wraps, Inc. 82. Any and all owner's distribution paid to owners by owner for 2013 for 360 Wraps, Inc. 83.Any and all owner's distribution paid to owners by owner for 2014 for360 Wraps, Inc, 84. Any and all owner's distribution paid to owners by owner for 2015 for 360 Wraps, Inc. 85. Any and all owner's distribution paid to owners by owner for 2016 for 360 Wraps, Inc. 86. Any and all owner's distribution paid to owners by owner for 2017 for 360 Wraps, Inc. 87. Any and i owner's distribution paid to owners by owner for 2018 for 360 Wraps, Inc. 88. Any and all owner's distribution paid to owners by owner for 2019 for 360 Wraps, Inc. 89. Any and all owner's distribution paid to owners by. owner for 2020 for 360 Wraps, Inc. 90. Any and all analysis of changes in ownership equity for 2012 for 360 Wraps, Inc. 91. Any and all analysis of changes in ownership equity for 2013 for 360 Wraps, Inc. 92. Any and all analysis of changes in ownership equity for 014 for 360 Wraps, Inc. 93. Any and all analysis of changes in ownership equity for 2015 for 360 Wraps, Inc. 94. Any and all analysis of changes in ownership equity for 2016 for 360 Wraps, Inc. 95. Any and all analysis of changes in ownership equity for 2017 for 360 Wraps, Inc. 96. Any and all analysis of changes in ownership equity for 2018 for 360 Wraps, Inc. 97, Any and all analysis of changes in ownership equity for 2019 for 360 Wraps, Inc. 98. Any and ailanalysis of changes in ownership equity for 2020 for 360 Wraps, Inc. 99. Any and all correspondence, emails, letters and/or text messages with any prospective franchisee regarding franchising 360 Wraps, Inc. 100. Any and all documents relating to bonuses that Tommy Strader received from 360 Wraps, Inc. in 2012. 101. Any and all documents relating to bonuses that Tommy Strader received from 360 Wraps, Inc. in 2013. 102. Any and all documents relating to bonuses that Tommy Strader received from 360 Wraps, Inc. in 2014. 103. Any and all documents relating to bonuses that Tommy Strader received from 360 Wraps, Inc. in 2015.. 104, Any and all documents relating to bonuses that Tommy Strader received from 360 Wraps, Inc. in 2016. 105. Any and all documents relating to bonuses that Tommy Strader received from 360 Wraps, Inc. in 2017. 106. Any and all documents relating to bonuses that Tommy Strader received from 360 Wraps, Inc. in2018. 107. Any and all documents relating to bonuses that Tommy Strader received from 360 Wraps, Inc. in 2019. 108. Any and all documents relating to bonuses that Tommy Strader received from 360 Wraps, Inc. in 2020. 109. Any and all documents relating to income that Tommy Strader received from 360 Wraps, Inc. in 2012. 110. Any and all docurnents relating to bonuses that Tommy Strader received from 360 Wraps, Inc. in 201 = 111. Any and all documents relating to bonuses that Tommy Strader received from 360 Wraps, Inc. in 2014, 112. Any and all documents relating to bonuses that Tommy Strader received from 360 ‘Wraps, Inc. in 2015. 113. Any and all documents relating to bonuses that Tommy Strader received from 360 Wraps, Inc. in 2016. 114. Any and all documents relating to bonuses that Tommy Strader received from 360 Wraps, Inc. in 201 - 115. Any and all documents relating to bonuses.that Tommy Strader received from 360 ‘Wraps, Inc. in 2018, 116. Any and all documents relating to bonuses that Tommy Strader received from 360 Wraps, Inc. in 2019. 117. Any and all documents relating to bonuses that Tommy Strader received from 360 Wraps, Inc. in 2020. 118. Any and all documents relating to disbursements that Tommy Strader received from 360 Wraps, Inc. in 2012. 119. Any and all documents relating to disbursements that Tommy Strader received from 360 Wraps, Inc. in 2013. 120. Any and all documents relating to disbursements that Tommy Strader received from 360 Wraps, Inc. in 2014. 121. Any and all documents relating to disbursements that Tommy Strader received from 360 Wraps, Inc. in 2015. 122. Any and all documents relating to disbursements that Tommy Strader received from 360 Wraps, Inc. in 2016. 123. Any and all documents relating to a that Tommy Strader received from 360 Wraps, Inc. in 2017. 124. Any and all documents relating to disbursements that Tommy Strader received from. 360 Wraps, Inc. in 2018. 125. Any and ali documents relating to disbursements that Tommy Strader received oon 360 Wraps, Inc. in 2019. 126. Any and all documents ee to disbursements that Tommy Strader received from 360 Wraps, Inc. in 2020. 127. Any and all payroll records from 360 Wraps, Inc. Teflecting payments made to Tommy Strader for 2012. 128. Any and all Payroll records from 360 Wraps, Inc. reflecting payments made to Tommy Strader for 2013. 129. Any and all payroll records from 360 Wraps, Inc. reflecting payments made to ‘Tommy Strader for 2014. 130. “Any and all payroll records from 360 Wraps, Inc. reflecting a made to Tommy Strader for 2015. 131. Any and all payroll records from 360 Wraps, Inc. reflecting payments made to Tommy Strader for 2016. 132. Any and all payroll records from 360 Wraps, Inc, reflecting payments made to Tommy Strader for 2017. 133. Any and all payroll records from 360 Wraps, Inc. reflecting payments made to Tommy Strader for 2018. a Any and all payroll records from 360 Wraps, Inc. reflecting payments made to Tommy Strader for 2019. 135. Any and all payroll records from 360 Wraps, Inc. reflecting payments made to Tommy Strader for 2020. 136. Any and all documents related to how Tommy Strader’s bonus was calculated for the year 2012. 137. Any and all penne telated to how Tommy Strader's bonus was a for the year 2013. 138. Any and all documents related to how Tommy Strader’s bonus was calculated for the year 2014. ' 139. Any and all documents related to how Tommy Strader’s bonus was calculated for the year 2015. 140. Any and all documents related to how Tommy Strader’s bonus was calculated for the year 2016. i - Any and all documents related to how Tommy Strader’s bonus was calculated for the year 2017. 142. Any and all documents related to how Tommy Strader’s bonus was calculated for the year 2018. 143. Any and all documents related to how Tommy Strader’s bonus was calculated for the year 2019. 144. Any and all documents related to how Tommy Strader’s bonus was calculated for the year 2020. 145. Any and all documents related to Tommy Strader's interest in 360 Wraps, Inc. being bought out. 146. Any and all copies of Tommy Strader's W-2 forms for the year 2012. 147. Any and all copies of Tommy Strader’s W-2 forms for the year 2013. 148. Any and all copies of Tommy Strader's W-2 forms for the year 2014. 149. Any and all copies of Tommy Strader's W-2 forms for the year 2015 150. Any and all copies of Tommy Strader’s W-2 forms for the year 2016. 151. Any and ail copies of Tommy Strader’s W-2 forms for the year 2017. 152. Any and all copies of Tommy Strader’s W-2 forms for the year 2018. 153. Any and all copies of Tommy Strader's w-2 forms for the year 2019. 154. Any and all copies of Tommy Strader’s W-2 forms for the year 2020. ATTACHMENT 5 -THE STATE OF TEXAS SUBPOENA FOR WITNESS DEPOSITION/SUBPOENA DUCES TECUM PURSUANT TO TEXAS RULES OF CIVIL PROCEDURE 176 AND 201 CAUSENO, Sacramento CA 34-2017-00224470 IN THE JUDICIAL DISTRICT COURT OF DALLAS COUNTY, TEXAS Tommy Strader & Angela Strader vs, Starwood Capital Group, LLC et al. Plaintift Defendant TO ANY SHERIFF OR CONSTABLE OF THE STATE OF TEXAS OR OTHER PERSON AUTHORIZED