Motion for Findings of Fact and Conclusions of Law in Steven Pappas v. Doreen Farr| Trellis.Law

On December 31, 2008 a Motion-Secondary was filed involving a dispute between Pappas, Steven, and Farr, Doreen, for civil in the District Court of Santa Barbara County.

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Jeffrey A. Lake, Esq. (State Bar No. 159234) SUI’Emé': cl? SITE pFOFWIA v .—
Kenneth
THEODORA
2029 Century
E. Johnson,
ORINGH
Park
Es

East,
.(State
ZR MILLER
Sixth
Bar No.

Floor
&
115814)
RICHMAN PC
CO“ V 0

MAR
AN

2 5
A

2003
BARA

FIN
_
”—’
Los Angeles. Califomia 90067-2907 GAR awn, Executive omcev
Telephone: (310) 557-2009 BY .
— J ____
Faesrmile: (310) 551-0283 MarileeA Jay. 0 cm
“TY
Stanley H. Green, [is . (State Bar No. 41851) [m- '—
STANLEY H. ORE-1E A LAW CORPORATION _
__
OOOONO‘UIJkWN—

468 N. Camden Drive, Second Floor GUI:
Beverly Hills, CA 90210
ST
Telephone: (310) 285-1753
Facsrmile (310) 285-1752

Attorneys for Contestant STEVEN PAPPAS

PC SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SANTA BARBARA
RICI/MAN

&
STEVEN PAPPAS, an individual. Case No. 1304851
MILLER

Contestant, [Assigned for All Purposes to the
vs.
Honorable]. William MeLatTerty,
ORINGHER
Department 5]
DOREEN FARR, an individual,
CONTESTANT‘S OBJECTIONS T0
Defendant. [PROPOSED] FINDINGS OF FACT
THEODORA
NNNNNNH—H—HH——~—
AND CONCLUSIONS OF LAW

Contestant Steven Pappas hereby submits his Objections to the [Proposed] Findings

of Fact and Conclusions of Law, submitted by Defendant on or about March 20, 2009.

As a preliminary matter. Contestant submits that the form ofthe decision entered by

the Court should be limited to the issue raised by the motion for nonsuit; speciﬁcally, the »

Court's decision that Contestant does not have a private right of action to challenge the

election results based upon alleged errors in compliance with the requirements of HAVA,
as implemented

'
Section
by
~
2 C.C.R.

20108(a)
§§

states:
20108

"The
c! seq.’

purpose
Defendant‘s

ofthis chapter
proposed ﬁndings

is to establish
of fact

standards
and

and
.

(footnote continued)

7433M ”2199205002 l
CONTESTANT'S OBJECT/0N5 TO PROPOSED FIND/NOS ‘
00424
conclusions of law improperly attempt to address issues going well beyond the scope of
I9 the Court's ruling. They also improperly request ﬁndings of fact on issues not relevant to

the issue decided by the Court, or which are not supported by the evidence, or both.

Contestant's objections to speciﬁc ﬁndings of fact and conclusions of law are stated

below:
OOOONQUIAL.)

Objection No. 1: Finding No. 12 (page 4, lines 23-27)

The proposed ﬁnding is incomplete, because itdoes not describe the Court's ruling
on the submitted legal issues. The following two sentences should be added at the

conclusion ofthe paragraph (page 4. line 27):

PC ”The Court ruled that Contestant Pappas did not have a private right of action under

HAVA. accepting the argument made by Defendant Farr at pages 18-20 of Defendant's
R/Cmmx

'Renewed Motion to Dismiss and Brief on HAVA lssues.‘ The Court did not rule on the
&
other issues argued in Defendant's Brief."
MILLER

Objection No.2: Finding No. 13 (page 5, lines 1-12)

The ﬁrst sentence accurately states that the Court granted Defendant's motion for
ORINGHER

non-suit. The second and third sentences should be stricken, because they improperly
attempt to add grounds beyond those which were identiﬁed by the Court as the basis for
TI/EODORA

granting the motion.
NNNNNNNNN—n—.—_—.—..—_—_

"l'l‘lhe motion for nonsuit must state the precise grounds upon which it is made . .
."

Timmsen v. Forest
O°\la\m¢-WNHO\O®\IONM&WN—
E. Olson. Inc. (1970) 6 Cal. App. 3d 860, 868. "[O]nly the grounds

speciﬁed [by counsel] should be considered by the lower court in its ruling, . . Id. See

also Lora! Corp. v. Maya: (1985) I74 Cal. App. 3d 268, 272 (“The grounds for the nonsuit

motion should be clearly speciﬁed to give the plaintiff the opportunity to cure any
defects")

procedures for processing. transmitting, and maintaining voter registration records in a
manner that conforms with the statewide voter registration list requirements set forth in the
Help America Vote Act of 2002 (HAVA)." (citations omitted)

74333|llf2|992l05002
2
CONTESTANT‘S OBJECT/CNS T0 PROPOSED FINDINGS

00425
Here, the Court considered argument on March 16. 2009, in connection with issues

relating to the Help America Vote Act of 2002, 42 U.S.C. § 15301 et seq. ("HAVA"). The

Court concluded that Contestant did not have a private right of action to challenge the

election results on the basis of HAVA. The Court did not rule upon any ofthe other issues

argued by the parties at the March 16. 2009, hearing. Defendant did not assert any

grounds
OOWQOMJBWN

for her nonsuit motion, other than the Court‘s ruling that Contestant lacked a

private right ofaction under HAVA.
Based upon the foregoing, Contestant submits that proposed Finding No. l3 should

be stricken. and replaced with the following:

PC “13. Upon the resting of Contestant's case, the Court granted a motion for non-suit

in favor of Defendant Farr. As more fully set forth in the Conclusions of Law below, the
RICHMAN

N
.— Court concluded that Contestant Pappas did not have a private right of action to challenge
&
w the election results based upon alleged errors in compliance with the requirements of
MILLER

:4:-
HAVA. as implemented by 2 C.C.R. §§ 20108 et seq."

Objection No. 3: Finding No. 15 (page 5:lines 16—24)
ORINGMER

0\ The disparaging comments made concerning the questioning of these witnesses

\I should be eliminated. including the reference to "repetitive" testimony (page 5, line I6)
THEODORA

00 and to "redundant and extended examination by counsel for contestant." (Page 5, line 24.)

35 Objection No. 4: Finding 16 (page 5 line 25 to page 6 line 13)

NO In ruling on a motion for nonsuit, the Court must "disregard” conﬂicting evidence
N and givle] to plaintiff‘s evidence all the value to which it is legally entitled, herein

NN indulging in every legitimate inference which may be drawn from that evidence." Estate

N La) of Lances (l932) 2l6 Cal. 397. 400-0l; see also Loral Corp. v. Mayes (1985) l74 Cal.

NA App. 3d 268, 272 ("The evidence most favorable to the plaintiff must be accepted as true

N K11
unless itis inherently incredible")
N Ch The ﬁfth sentence, stating that the Court has made "no determination on the

N \1 accuracy or reliability" of Ms. Baxter's testimony or the information contained in the

N 00 exhibits which she described in her testimony should be stricken in its entirety. (Page 6,

7433M IRIWZ 05002 3
CONTESTANT’S OBJECT/0N8 T0 PROPOSED FINDINGS ,,
00426
t.
lines 9-] l.) The Coun should accept Ms. Baxter‘s testimony as true for purposes of ruling
on the nonsuit motion.

The sixth sentence, stating that "all objections to the accuracy and content of the

exhibits prepared by Ms. Baxter were reserved," is factually incorrect. All of these

exhibits were received into evidence, with Defendant reserving objections only to the title
OOWQOxUIJEWN—

ofeertain exhibits. The sixth sentence should be stricken because it is not supported by the

record. (Page 6, lines Il-l3.)
In addition, Ms. Baxter should be identiﬁed as the "former campaign coordinator."

rather than "former campaign manager" as erroneously stated at Page 5, line 25.

PC Objection No. 5: Finding No. 17 (Page 6, lines 14-27)

The ﬁrst sentence, at Page 6, lines 14-15, should be stricken, because the evidence
RIC/[MAN

of "registration and voter fraud" was not conﬁned to the testimony of this witness. In
at
addition, this issue is not relevant to the issue of whether HAVA creates a private right of
MILLER

action. which was the only stated basis for the nonsuit motion.

Objection No. 6: Finding No. 18 (Page 7 line I to Page 8, line 3)
ORI.\'GHER

This ﬁnding should be stricken in its entirety, because it impennissibly asks the

Court to conclude that the testimony of the witness "is simply mistaken or otherwise
false."
THEODORA

There
NNNNNNMNNv—_——o—nn—————n
is no basis for this conclusion. The witness inspected the original
registration card as well as a photocopy. and testiﬁed credibly that neither the signature nor
OONOUIAWN—‘OOOOQONUIJEWM-

the handwriting on the card was made by her. Her testimony was clear and direct. She

had no reason to lie. For purposes of this motion for nonsuit. the Court should accept her

testimony as credible.

Objection No. 7: Finding Nos. 20 to 41 (Page 8 line 12 to Page 17. line 2)
Because the Court ruled that Contestant Pappas did not have a private right of
action under HAVA. the proposed ﬁndings with respect to "County Registration and

Election Procedures" are inappropriate and should be stricken in their entirety. There are

two reasons for this request:
First. the proposed Findings are not relevant to the stated basis for the Court's

7433M l/2l992 05002
4
CONTESTANT'S OBJECT/0N5 T0 PROPOSED F IND/NOS
0042'?
decision. The Court held that Contestant lacks standing to raise any issue concerning these

procedures. The request for detailed factual ﬁndings on these issues is inconsistent with the

Court's stated reason for its decision.

Second, Contestant rested its case immediately upon receiving the Court's ruling
that Contestant lacked standing to raise the HAVA issues. Had the Court not issued this

ruling.
OOOOQO‘V‘ADJN

Contestant would have called additional witnesses, and offered additional evidence,

on the subjects addressed in Proposed Findings Nos. 20 to 4]. It is inconsistent for

Defendant to move for nonsuit on the basis that Contestant lacks standing to raise these

issues, only to then ask the Court to issue detailed factual ﬁndings on these issues. If the
PC Court believes it appropriate to enter detailed ﬁndings on these issues, Contestant will
request an opportunity to reopen the record and present additional evidence.
RIC/[MAN

Objection No. 8: Finding No. 29 (Page I] line 19 to page 12 line 14)
&
Assuming argucndo that the Court overrulcs Objection No. 7, Contestant objects to
MILLER

the all but the ﬁrst sentence of this proposed Finding on the ground that it does not

accurately reflect the evidence. Instead, it reflects the argument of counsel, as well as a
URINGIIL‘R

great deal of speculation as to why a "suggested" driver's license may be returned for a

particular registrant.
THEODOR/I
NNNNNNNNN——-—-————-—-—-—-

The language proposed by Defendant's counsel should be stricken, and replaced

with the following:
OOQOWAWN—OOOONONLI‘éwN—

“29. A 'Y--EXACT' match may itself occur in one of two circumstances. lhe ﬁrst
occurs when there is an exact match between the name, DOB, and driver's license number

(or other identiﬁcation number) submitted for the registrant in the D]- ﬁle and the

corresponding identiﬁcation information associated with the registrant's name in the DMV
database. The second occurs when there is not an exact match. but where the information
is sufﬁciently close to produce a suggested exact California Driver's License (CDL) match

for the registrant, which is provided in the CL ﬁle (ﬁeld 14) that is returned by the

California Secretary of State (SOS). The DI. ﬁle corresponds to the CL ﬁle."

74333|.lf2|992.05002
5
CONTESTA NT‘S OBJECT/0N8 70 PROPOSED FINDINGS
004 28 ~
_.
Objection No. 9: Finding No. 3] (Page 13 lines 3 to 17)

Assuming arguendo that the Court overrules Objection No. 7, Contestant objects to

this proposed Finding on the ground that it does not accurately reﬂect the evidence.

The proposed ﬁnding asserts that registrants returned from Calvalidator as a "NO

MATCH" are ﬂagged as ﬁrst time federal voters by the County EIMS, and required to

provide
OOOOVO‘UIADJN

acceptable identiﬁcation at the time they vote, or vote by provisional ballot ifthey
fail to do so. In fact. the evidence provides examples where this was not done, By way of
example. the evidence shows that a Mr. Andrew Kalandjian registered on October I4.

2008, as a ﬁrst time voter in Santa Barbara County. He is listed as a "NO MATCH" on the

PC CL report and was also ﬂagged on the Calvalidator Failed Records Report as "ID Not

Veriﬁed. contract registrant." (Exhibits 1, l 17.) However he was not ﬂagged at the poll
RICIIJIAN

where he voted to show identiﬁcation and did not provide identiﬁcation at the time of
&
registration. (Exhibit 3 at p. 5654.)
MILLER

The language proposed by Defendant's counsel should be stricken, and replaced

with the following:
0Rl.\'GH£R

"3]. Of the newly registered voters in the 18 precincts at issue. only 367 were

ﬂagged as '1D Required,‘ so that polling place workers would know to ask the voter to
TIIEODOR/l

show identiﬁcation
NNNNNNNNN————————-——-
when casting a vote. (Exhibit 103.) However, there were at least

l,4l0 others who registered by 'original afﬁdavit' during the September 26 to October 20,

2008, time period.
OONO‘MAWN—OOOONO‘LI-w—
whose names appear on the 'Calvalidator Failed Report,‘ but who were

not ﬂagged to show identiﬁcation and who voted in the election. (Exhibit 106.) An
additional 160 persons registered by original afﬁdavits between June 4 and September 26,

2008. whose names appear on the Calvalidator Failed Report, but who were not ﬂagged to

show identiﬁcation and who voted in the election. (Exhibits 116. H7, 1 I8.) The evidence

also shows that certain voters were returned on the CL ﬁle as a 'NO MATCH,“ but not

ﬂagged at the poll to show identiﬁcation and did not provide identiﬁcation at the time of
registration."

7433M ”21902 05002
6
CON TESTAN 7"S OBJECT/0N5 TO PROPOSED FINDINGS

00429
Obiection No. 10: FindingNo. 32 (Page 13 line 18 to page 14 line 2)

Assuming arguendo that the Court overrules Objection No. 7, Contestant objects to

this proposed Finding on the ground that it is inaccurate and incomplete. The proposed

language should be stricken, and replaced with the following:
“32. The evidence shows that no outreach was conducted, prior to the certiﬁcation
of the
OOOOQOUIAWN
election results, with respect to the 1,410 voters identiﬁed on Exhibit 106. Linda
Rhoads testiﬁed that the Registrar's normal method of outreach was not conducted

following October 15. 2008, due to an unexplained computer problem. This is consistent

with the gap in the Calvalidator records produced by the Registrar's ofﬁce prior to trial.
PC When reviewing Exhibit 1,Renee Bischof acknowledged that no names were listed for the
period of October 15 through December 17, 2008, and had no explanation for that
RIC/[MAN

omission. (l Tr. 149.) The combined testimony of Bischof and Rhoads leads to the
&
conclusion that at the very least no outreach was conducted during the critical period
MILLER

following October 15. 2008, when over 6,000 registration forms were submitted. There is

no evidence that any successful outreach was conducted following that period and prior to
ORIA‘GHER

certiﬁcation ofthe election."

Objection
NNNNNNN_#——_.—_.—_._
No. 11: Finding No. 33 (Page 14 lines 3-12)
THEODORA

Assuming arguena’o that the Court overrules Objection No. 7. Contestant objects to
this proposed
WSQmAwN—OOOONO\UIAWN—
Finding on the ground that itis inaccurate and not supported by the evidence.
The evidence presented on this issue is included in Contestant's proposed revision to
Finding No. 32, as stated in Objection No.9 above.

Objection No. 12: Finding No. 39 (Page 16 lines l-l6)
Assuming arguena’o that the Court overrules Objection No. 7, Contestant objects to

this proposed Finding on the ground that itis inaccurate and not supported by the evidence.

The evidence presented on this issue is included in Contestant's objections to Finding Nos.
31, 32, and 33 (Objection Nos. 9.10, and l1 above). and in Contestant's Proposed Findings
A. B. C, D. E and F (Objections Nos. l4-l9 below). The proposed language should be

N stricken, and replaced with the following:

74333l.ll2|992.05002
7
CONTESTA/VT‘S OBJECT/0N3 T0 PROPOSED FINDINGS
00430
"39. The total number ofvoters registered in the l8 precincts at issue stood at about

5,000 in mid-September 2008. It jumped to over 15,000 by October 20, 2008. The main

reason for this was that large voter registration drives were conducted in September and

October 2008, mostly on the campuses of UCSB and Santa Barbara City College. A total

of 9,943 registration cards were submitted to and accepted by the Registrar between

September
Oomxtc'xuubwm

26 and October 20, 2008. (Exhibit llS.) Of these, 6,092 registration cards

were submitted during the ﬁnal four business days of the registration period, between

October 15 and 20, 2008. (Exhibit 1 I3.)
Objection No. [3: Finding No. 40 (Page 16 lines 17-22)

PC Assuming arguendo that the Court overrules Objection No. 7, Contestant objects to

this proposed Finding on the ground that it isinaccurate and not supported by the evidence.
R/cmux

The evidence presented on this issue is included in Contestant's objections to Finding Nos.
&
3], 32, and 33 (Objection Nos. 9,10, and l1 above), and in Contestant's Proposed Findings
MILLER

A, B, C, D, E, and F (Objections Nos. l4-l9 below).
Objection No. 14 (Add Findiu A re New Registrant Files Not Submitted to
ORIA‘GIIER

Calvalidatorl
NMNNNN————..——.__._._

Assuming arguendo that the Court overrules Objection No. 7, Contestant requests
THEODORA

that the Court
gﬂgmAWN—OOOOHO‘U‘AWN—
make the following ﬁnding. based upon the unrebuttcd testimony of Ms.

Baxter and the exhibits identiﬁed during her testimony:
"A. A total of 264 new registrant ﬁles were never submitted to Calvalidator, as

shown by a comparison ofthe master registration records with the content ofthe DL ﬁles

produced by the Registrar ofVoters. (Exhibits 1 I6, 1l8.)"
Objection No. 15 (Add Finditjg B re Calvalidator Failed Report Records Not

Produced At Trial!
Assuming arguendo that the Court overrules Objection No. 7, Contestant requests

that the Court make the following ﬁnding. based upon the unrebutted testimony of Ms.

N Baxter and the exhibits identiﬁed during her testimony:

"mil/21992 05002 8
CONTESTANT'S OBJECT/0N5 T0 PROPOSED FINDINGS
00431
"B. The actual number of new registrants whose names were not submitted to

Calvalidator in this category could be higher than the number identiﬁed above. due to the

fact that the Registrar's Ofﬁce never produced the Calvalidator Failed Reports for October

20 and December 19. 2008. which should cover 1.109 registrants (October 20th) and 141

registrants (December 19th), respectively (Exhibit 102.)"

Objection N0. 16 (Add Finding C re Mail In Registration Forms)
OOOONO‘UIJi

Assuming arguendo that the Court overrules Objection No. 7, Contestant requests

that the Court make the following ﬁnding, based upon the testimony of Ms. Bischoﬁ‘, Ms.

Baxter, and the exhibits identiﬁed during their testimony:

PC "C. Registration forms were received by mail, and are marked by the Registrar‘s

Ofﬁce with the designation 'M.‘ Only 5 mail-in registrations were accompanied by a copy
RIC/IMAM

ofthe voter‘s identiﬁcation. (Exhibit 19.) An additional 133 new voters registered by mail
&
and voted in the election. but did not provide identiﬁcation with their registration and were
MILL£R

not ﬂagged to show identiﬁcation at the polls. (Exhibit 98. 104.)"

Objection No. 17 (Add FindimLD re Registration Cards Marked " L)
0Rl.\‘G//£R

Assuming arguendo that the Court overrules Objection No. 7, Contestant requests

that the Court make the follOWing ﬁnding. based upon the testimony of Ms. Bischoff, Ms.
Tusoooiu

Baxter, and the exhibits identiﬁed during their testimony:
"D.
NNNNNNNNN—-—————_H——
In addition to the registration cards marked 'M,‘ other registration cards are
OONONMAWN—OOOOVO‘UIAUJN—

marked 'U' as shorthand for 'Unknown.‘ These include cards submitted to the Secretary of
State's ofﬁce, or sent from other Counties. Ms. Rhoads acknowledged that some or all of
these cards could have been mailed by the voter to the Secretary of State or to the Registrar

of Voters in another County, in which case the registrant should have been required to

provide identiﬁcation when voting. A total of 371 registration cards are marked 'U,‘ and

were submitted by voters who had no prior registration, voted in the election, were not

ﬂagged to show identiﬁcation at the polls. and appear on the Calvalidator Failed Records

report. (Exhibit 99. 101.)"

743131”2199105002
9
CONTES‘TANT'S ()IL/ECTIUNS TO PROPOSED FINDINGS ‘
00432
Objection N0. 18 (Add Finding E re Unsigned Cards and Unidentifed
Registrants)
Contestant requests that the Court make the following ﬁnding. based upon the

testimony os. Bischoff, Ms. Baxter, and the exhibits identiﬁed during their testimony:
"E. The evidence presented shows that not less than l2 registration cards were

accepted which did not include the registrant's last name or which were not signed by the

—
registrant. (ll Tr. l6}; Exhibits 47, 53.)"

Objection No. 19 (Add Finding F re Omission of Essential Information)
Contestant requests that the Court make the following ﬁnding, based upon the

I’C testimony of Ms. Bischoff, Ms. Baxter. and the exhibits identiﬁed during their testimony:
"F. The evidence presented shows that not less than 5 registration cards were
RIC/{MAN

accepted which omitted essential information such as the registrant's date of birth or place
&
ofbirth. (ll Tr. 17]; Exhibit 48.)"
MILLER

Obiection No. 20: Conclusions of Law Nos. 1 to 25 and 27 to 29 (Page [7 line 5

to Page
NN—-——-——n-—-—-—-—-—-—-

31 line l2}
ORIA‘GIIER

The Court ruled that Contestant Pappas did not have a private right of action under

HAVA. This conclusion is addressed in Conclusion of Law No. 26. The other proposed
T115000!”

Conclusions of Law address issues which were not identiﬁed as grounds for the nonsuit

motion and are thus improper and should be stricken in their entirety. There are two

reasons for this request:

First, the proposed Conclusions are not relevant to the stated basis for the Court‘s

decision. The Court held that Contestant lacks standing to raise issues concerning the

procedures mandated by HAVA. The motion for nonsuit was based upon this ruling. The

request for detailed conclusions of law on other issues, which were not addressed in the

Court‘s ruling on the motion for nonsuit. is inconsistent with the Court's stated reason for
its decision.

Second. Contestant rested its ease immediately upon receiving the Court's ruling
that Contestant lacked standing to raise the HAVA issues. Had the Court not issued this
74333lJ/7l99205002
10
C ONTESTANT'S OBJECT/0N3 TO PROPOSED F IND/NOS
00433‘
ruling. Contestant would have called additional witnesses, and offered additional evidence,

on some or all of the subjects addressed in the Proposed Conclusions of Law. It is

inconsistent for Defendant to move for nonsuit on the basis that Contestant lacks standing

to raise these issues, only to then ask the Court to issue conclusions of law on these issues.

Objection No. 2]: Conclusion No. 8 (Page 18 lines l9 to 26)
OOOOQO‘VIAKAN—

Assuming arguendo that the Court overrules Objection No. 20, Contestant objects

to this proposed Conclusion on the ground that it is inaccurate and not supported by the

evidence. The third and fourth sentences should be stricken. as unsupported by the

evidence, as stated in Contestant's objections to Finding Nos. 31, 32. and 33 (Objections
PC Nos. 9-1] above), and in Contestant's Proposed Findings A, B, C, D, E and F (Objections
Nos. l4-l9).
RIC/[MAN

Objection No.22: Conclusion No. l4 (Page 20 line 27 to new 2] line 11)
&
Assuming argucndo that the Court overrules Objection No. 20, Contestant objects
MILLER

to this proposed Conclusion on the ground that it is inaccurate and not supported by the

evidence. Defendant could have cross-petitioned in this proceeding had she believed that
ORLVGHER

the same irregularities affected the votes cast in other precincts. The evidence does not

support the argument that the registration irregularities affected other precincts. This
TI/sODO/u

proposed Conclusion should be stricken in its entirety.

Objection
muomt—Oomuomvbww—

NNNNNNNNN—_

Case Info

Judge

Sterne, Colleen K Track Judge’s New Case

Case No.

(Subscribe to View)

Document Filed Date

March 25, 2009

Case Filing Date

December 31, 2008

County

Parties

Cappello, A Barry Attorney
Farr, Doreen Respondent
Holland, Joseph E Non- Party
Pappas, Steven Petitioner
Seymour, Philip Attorneys for Defendants
Woocher, Fredric D Attorney
Jeffrey Lake Attorney
Charles Robinson Attorney
David Birnbaum Attorney
Stanley Green Attorney
Margaret Wu Attorney
Erich Luschei Attorney
STANLEY GREEN Attorney
Gustavo Lavayen Attorney
Kenneth Johnson Attorney
Rachel Deutsch Attorneys for Defendants
John Doyle Attorney
David Baum Attorney

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Motion-Secondary: Steven Pappas v. Doreen Farr

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