Motion to Compel Discovery with Sanctions in Pacific Office Designs, Inc vs SPOT ON CONSULTING GROUP et al| Trellis.Law

On July 09, 2020 a Party Discovery was filed involving a dispute between Pacific Office Designs, Inc, and Exemplis, Llc, Jonathan Ronald Laddy, Kelly Pauline Playle, Nancy Lopez, Paul De Vries, Spot On Consulting Group, for Breach of Contract/Warranty Unlimited(06) in the District Court of Santa Clara County.

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20CV368229
Santa Clara — Civil

A. Floresca

Teresa C. Chow, SBN 237694 Electronically Filed
Alexis B. Cruz, SBN 312842 by Superior Court of CA,
BAKER & HOSTETLER LLP County of Santa Clara,
11601 Wilshire Boulevard on 11/29/2021 5:33 PM
Suite 1400
Los Angeles, CA 90025-0509
Reviewed By: A. Floresca
Telephone: 310.820.8800 Case #20CV368229
Facsimile: 310.820.8859 Envelope: 7750350
Email: tchow@bakerlaw.com
acruz@bakerlaw.com

Attorneys for Defendants
EXEMPLIS, LLC and NANCY LOPEZ

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF SANTA CLARA
10

1 PACIFIC OFFICE DESIGNS, INC., a Case No.: 20CV368229
California corporation,
Le 12 [Honorable Socrates P. Manoukian]
ase
Hoa Plaintiff,
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BSzZ 13 SUPPLEMENTAL BRIEF IN SUPPORT
mes
zs Vv. OF EXEMPLIS, LLC AND NANCY
wes
zea 14 LOPEZ’ OPPOSITION TO PLAINTIFF’S
M< SPOT ON CONSULTING GROUP, a MOTION TO COMPEL FURTHER
15 Professional Accountancy Corporation; RESPONSES TO FIRST DEMAND FOR
JONATHAN RONALD LADDY; INSPECTION OF DOCUMENTS AND
16 EXEMPLIS, LLC; a California Limited FOR SANCTIONS
Liability Company; PAUL DE VRIES;
17 KELLY PAULINE PLAYLE; NANCY [Filed concurrently with Supplemental
LOPEZ, and DOES 1-150, inclusive, Declaration of Teresa C. Chow; and
18 Declaration of Peter Ching]
Defendants.
19 Hearing

20 Date: December 7, 2021
Time: 9:00 a.m.
21 Dept.: 20

22
Action Filed: 08/26/20
23 Trial Date: None

SUPPLEMENTAL BRIEF ISO OPPOSITION TO PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES TO FIRST DEMAND FOR
INSPECTION OF DOCUMENTS AND FOR SANCTIONS; CASE NO.: 20CV368229
IL INTRODUCTION

Defendants Exemplis, LLC (“Exemplis”) and Nancy Lopez (collectively, “Defendants”)

hereby submit this Supplemental Brief in support of their Opposition to Plaintiff Pacific Office

Design, Inc.’s (“Plaintiff”) Motion to Compel Further Responses to First Demand for Inspection

of Documents and for Sanctions (“Motion”), pursuant to the Court’s order dated September 8,

2021. Defendants have now submitted extensive briefing that shows the incredible overbreadth

of Request for Production (“RFP”) No. 7 and the unreasonableness of Plaintiff’s relentless

demands for Exemplis to amend its response to indicate that it will fully comply with RFP No. 7

as worded, meaning that Exemplis would need to conduct a second search for responsive

10 documents and electronically stored information (“ESI”). Exemplis should not be required to do

1 either. Based on the parties’ months-long meet and confer earlier this year, Exemplis has already
Le 12 gathered nearly 50,000 pages of documents and ESI and, following an extensive review for
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BSzZ 13 responsiveness and applicable privileges, produced about 3,500 pages of those documents and
mezs
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zea 14 ESI. This is compounded by the fact that Plaintiff now has document productions from all
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15 defendants, and has completed its review of those productions, but has not yet identified any

16 document or ESI that it believes is missing from Exemplis’ document productions.

17 Notwithstanding these efforts, Defendants have participated in several informal discovery

18 conferences (“IDC(s)”) to work with Plaintiff in good faith to reach a resolution that would

19 reasonably limit the scope of RFP No. 7. As part of this IDC process, Defendants provided

20 Plaintiff with: (1) the specific Bates numbers from Exemplis’ document productions that

21 correspond to nearly every person, entity, and transaction identified in RFP No. 7 (which itself

22 demonstrates that a second search for documents and ESI would be duplicative); (2) a proposal

23 that would enable Exemplis to amend its response to RFP No. 7 to represent that it will produce

24 all responsive documents (which Plaintiff was purportedly looking for); and (3) information

25 regarding the specific steps that Exemplis took to preserve evidence related to the subject

26 phishing incident (which was not requested in RFP No. 7, but was provided after Plaintiff

27 represented to Exemplis and the Court that this information was needed to limit RFP No. 7).
28 Unfortunately, Plaintiff would not agree to Exemplis’ proposal and failed to offer any limitations

1
SUPPLEMENTAL BRIEF ISO OPPOSITION TO PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES TO FIRST DEMAND FOR
INSPECTION OF DOCUMENTS AND FOR SANCTIONS; CASE NO.: 20CV368229
to RFP No. 7, despite instruction from the Court to do so and Plaintiff’s representations that it

was interested in resolving the matter.

Now, with their Supplemental Brief, Defendants respectfully request that the Court deny

the Motion and Plaintiffs request for sanctions, or, alternatively, order Defendants to amend their

response to RFP No. 7 subject to reasonable substantive and temporal limitations, as determined

by the Court.

IL. STATEMENT OF SUPPLEMENTAL FACTS

A Defendants Timely Objected to the Scope of RFP No. 7

Plaintiff propounded the First Demand for Inspection of Documents on Defendants

10 (“Requests”), which cast a wide net, requesting Defendants’ documents and ESI related to the

1 subject phishing incident, and Exemplis’ policies and procedures, investigations, employee
Le 12 reprimands/terminations, purchase orders, Plaintiff's account, and more. (See Declaration of
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BSzZ 13 Teresa Chow ISO Opposition (“Oppo. Chow Decl.”), 43.)
mezs
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zea 14 As discussed at length in Defendants’ Opposition brief, RFP No. 7 casts the widest net,
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15 requesting a// documents and ESI that Defendants preserved in response to Plaintiff's February 7,

16 2020 written demand to Exemplis, which Plaintiff attached to RFP No. 7. (See Oppo. Chow

17 Decl., 93.) In effect, RFP No. 7 is 19 document requests in one because it requests all documents

18 and ESI preserved by Exemplis without time limitation for the following persons, entities, and

19 transactions:

20
Nancy Lopez, Exemplis;
21 Mariela Holguin, Exemplis;
Trina Dunn, Exemplis;
22 Kelly Playle, Spot On Consulting Group;
Jonathan Laddy, Spot On Consulting Group;
23 Mark Ferguson, Pacific Office Designs;
Bill.com;
24
“Amrit” of Bill.Com Holdings, Inc.;
25 9 Officer Ken Charlesworth, Task Force Agent, California Highway Patrol;
10 Santa Clara County District Attorney;
26 lL San Jose Police Department;
12 Automated Clearing House;
27 13 JP Morgan Bank;
14. Chase Bank, San Antonio, Texas;
28
15. Purchase Order PO10753;
2
SUPPLEMENTAL BRIEF ISO OPPOSITION TO PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES TO FIRST DEMAND FOR
INSPECTION OF DOCUMENTS AND FOR SANCTIONS; CASE NO.: 20CV368229
16. Purchase Order PO11029;
17. Purchase Order PO10749;
18 Purchase Order PO11045; and
19. December 20, 2019 Payment.

(bid.)
With an unlimited timeframe, this means that a second search related to Trina Dunn, for

example, would include documents and ESI having nothing to do with Plaintiff, the identified

transactions, or the subject phishing incident. (See Oppo. Chow Decl., 43.) Because of this,

Exemplis timely objected to RFP No. 7, in pertinent part, on the grounds that it was (1) overbroad

as to time and scope and (2) not reasonably calculated to lead to the discovery of admissible

10 evidence. (/d. at 4.)

1 B. Defendants Have Already Gathered Nearly 50,000 Pages of Documents and

Le 12 ESI Pursuant to the Parties’ Months-Long Meet and Confer
ase
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BSzZ 13 The parties engaged in a months-long meet and confer on Defendants’ timely objections
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wes and responses to the Requests, including RFP No. 7. (Supplemental Declaration of Teresa Chow
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15 (“Supp. Chow Decl.”), 42.) This meet and confer was productive, and the parties ultimately

16 agreed that Exemplis would conduct a search for documents and ESI responsive to the Requests,

17 filtered by certain persons/entities, search terms (i.e., specific transactions, including all of the

18 ones identified in RFP No. 7), and timeframes. (/bid.) These did not include several persons and

19 entities appearing in Plaintiff's February 7, 2020 written demand, and at no point did Plaintiff

20 raise this as an issue during the parties’ months-long meet and confer. (Ibid.) Defendants

21 engaged in this months-long meet and confer with the understanding that they would conduct one

22 comprehensive search for documents and ESI responsive to the Requests. (/bid.)

23 As a result of these efforts, Defendants gathered nearly 50,000 pages of documents and

24 ESI and, following an extensive review for responsiveness and applicable privileges, which took

25 well over 100 hours, produced about 3,500 pages of those documents and ESI. (Supp. Chow

26 Decl., {3.) By way of comparison, defendants Spot On Consulting Group, Jonathan Ronald

27 Laddy, and Kelly Pauline Playle—Plaintiff’s certified public accountants and the parties who

28 transmitted about $281,000 on Plaintiffs behalf without verifying the purported change in

3
SUPPLEMENTAL BRIEF ISO OPPOSITION TO PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES TO FIRST DEMAND FOR
INSPECTION OF DOCUMENTS AND FOR SANCTIONS; CASE NO.: 20CV368229
Exemplis’ bank account information—have only produced 249 pages worth of documents and

ESI. (Ibid.)
To date, Plaintiff has not identified any document or ESI that it believes is missing from

Defendants’ document productions, despite being asked to do so by the Court at the IDCs on

November 4, 2021 and November 18, 2021, and having confirmed that it has now reviewed all

defendants’ productions. (See Supp. Chow Decl., 4 - Exhibit 16.)

Cc. Defendants Have Already Produced Thousands of Pages of Documents and

ESI Responsive to RFP No. 7

Since the filing of their Opposition brief, and the resolution of other pending discovery

10 matters that were before the Court, Defendants have confirmed that their document productions

1 are also responsive to RFP No. 7, which they informed Plaintiff of. (Supp. Chow Decl., 95 -
Le 12 Exhibit 16.) Accordingly, on November 17, 2021, Defendants proposed amending their response
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BSzZ 13 to RFP No. 7 “(subject to and without waiving all appropriate objections) to include a statement
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zea 14 that [their] prior productions are responsive to RFP No. 7.” (/bid.) Unfortunately, Plaintiff
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15 rejected this proposal, demanding that the Exemplis Defendants amend their response to say that

16 they “ha[ve] or will produce all non-privileged responsive documents,” effectively demanding

17 full compliance. (Jbid.)

18 In addition, Defendants have also identified the specific Bates numbers from their

19 document productions that correspond to the persons, entities, and transactions identified in the

20 written demand attached to RFP No. 7. (Supp. Chow Decl., 46 - Exhibit 16.) Although Plaintiff

21 did not request it, Defendants provided this information to Plaintiff in order to show that: (1) the

22 productions contain documents and ESI that relate to every transaction, and all but four

23 persons/entities!, identified in its February 7, 2020 written demand; and (2) a second search for

25 ! Defendants’ productions do not include documents and ESI regarding Jonathan Laddy, “Amrit” of Bill.com
Holdings, Inc., Officer Ken Charlesworth, or the Santa Clara County District Attorney. (Declaration of Peter Ching
26 (“Ching Decl.”), 2-3.) This is because at or near the time of the subject phishing incident, Jonathan Laddy was the
Managing Principal of defendant Spot On Consulting Group (“Spot On”) and was not the person at Spot On handling
27 Plaintiff's account with Exemplis. (/d. at §4.) Defendants are unfamiliar with who Amrit of Bill.com Holdings, Inc.
is, but know that Bill.com was a third-party payment platform utilized by Spot On to conduct its business at or near
28 the time of the incident. (/d. at §5.) Defendants’ productions do, however, include documents and ESI related to
Bill.com. (/bid.) Lastly, Defendants are also unfamiliar with who Officer Ken Charlesworth is, but know that
4
SUPPLEMENTAL BRIEF ISO OPPOSITION TO PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES TO FIRST DEMAND FOR
INSPECTION OF DOCUMENTS AND FOR SANCTIONS; CASE NO.: 20CV368229
documents and ESI using the persons, entities, and transactions identified in Plaintiff's written

demand would be duplicative of Defendants’ prior productions. (/bid.)

What is more, on November 23, 2021, Defendants provided Plaintiff with information

regarding the specific steps that Exemplis took to preserve evidence related to the subject

phishing incident. (Supp. Chow. Decl., {7 - Exhibit 16.) This information was not requested in

RFP No. 7, but was provided after Plaintiff represented to Exemplis (and the Court at the IDCs)

that this information was needed to determine how to limit RFP No. 7. (/bid.) Plaintiff did not

acknowledge the preservation information until November 29, 2021, the day this Supplemental

Brief was due for filing, and blatantly misconstrued the information provided, made unfounded

10 accusations against Defendants, and did not propose any limitations to RFP No. 7 as it indicated

1 it would. (Jbid.)
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12 D. Defendants’ November 24, 2021 Proposal to Plaintiff Regarding an Amended
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zea 14 Defendants have now attended two IDCs, and provided the information discussed above
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15 to Plaintiff, in a good-faith effort to resolve their pending dispute with Plaintiff over the scope of

16 RFP No. 7. (See Supp. Chow. Decl., §2-7.) To that end, on November 24, 2021, Defendants

17 sent another proposal to Plaintiff, limiting the scope of RFP No. 7 as follows:

18 To reasonably narrow the scope of RFP No. 7 and the preservation demand, we
propose that any search of the designated persons/entities be run with each of the
19 designated transactions (e.g., Trina Dunn AND PO10753). Doing this will
reasonably narrow the timeframe and scope of the person/entity searches based on
20 the transactions that you have identified as being related to the phishing
incident. To the extent that there are any documents falling outside of these
21 limitations that could be relevant, those would be covered by the extensive
number of other RFPs that you propounded. For example, the IT policies and
22 procedures that Exemplis searched for are not covered by the preservation
demand, but were nonetheless produced in response to other RFPs.
23
If you are amenable to this proposal, and subject to our client’s approval, then
24 Exemplis can amend its response to RFP No. 7 to represent that it will produce all
responsive documents since they have already been captured by its prior
25 searches. We have confirmed that the designated transactions post-date 2018, the
starting timeframe we agreed on during our prior meet and confer, and that
26 Exemplis’ prior searches were for responsive documents up until the time it
27

28 Plaintiff filed a police report in connection with the incident. (/d. at §6.) Exemplis was not involved with that filing
or any submission to the Santa Clara County District Attorney. (/bid.)
5
SUPPLEMENTAL BRIEF ISO OPPOSITION TO PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES TO FIRST DEMAND FOR
INSPECTION OF DOCUMENTS AND FOR SANCTIONS; CASE NO.: 20CV368229
retained BakerHostetler in late January 2020, in connection with the phishing
incident.
(Cd. at 8 - Exhibit 16, emphasis added.) Despite Plaintiff's indication that it was “very

interested in any informal resolution that would avoid further briefing,” Plaintiff did not

acknowledge the proposal until November 29, 2021, the day this Supplemental Brief was

due for filing. (/bid.) Plaintiff rejected the proposal and again demanded full compliance

with RFP No. 7, ignoring the Court’s directives at the IDCs to limit the scope of the

request. (Ibid.)

il. THE COURT SHOULD DENY PLAINTIFF’S MOTION TO COMPEL A

FURTHER RESPONSE TO REP NO. 7
10
A A Second Search for Documents and ESI Responsive to RFP No. 7 Would Be
1
Duplicative of Defendants’ Initial Search and Unduly Burdensom
Le 12
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mezs compel and the responding party has a valid objection to production on the grounds that the
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15
sources, or the burdens of producing the documents or ESI outweigh any benefits. (Cal. Code
16
Civ. Proc. §§ 2017.020, subd. (a), 2031.310, subd. (g).)
17
Most importantly, the Court should deny Plaintiff's Motion because a second search for
18
documents and ESI responsive to RFP No. 7 as phrased would be cumulative/duplicative of
19
Defendants’ initial search. As discussed above, this initial search was comprehensive. Exemplis
20
gathered nearly 50,000 pages of documents and ESI and, following an extensive review for
21
responsiveness and applicable privileges, which took well over 100 hours, produced about 3,500
22
pages of those documents and ESI. Defendants have not only confirmed that their prior
23
document productions are responsive to RFP No. 7, but also that nearly 97% of those productions
24
correspond to the persons, entities, and transactions identified in Plaintiff's February 7, 2020
25
written demand. Defendants have even provided Plaintiff with the specific Bates numbers from
26
their prior productions that relate to said persons, entities, and transactions in order to
27
demonstrate that any further search would yield the same exact documents and ESI.
28

6
SUPPLEMENTAL BRIEF ISO OPPOSITION TO PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES TO FIRST DEMAND FOR
INSPECTION OF DOCUMENTS AND FOR SANCTIONS; CASE NO.: 20CV368229
In addition, the Court should deny Plaintiff's Motion because a second search for and

review of documents and ESI responsive to RFP No. 7 as phrased would impose an undue burden

on Exemplis—a burden Exemplis has already shouldered in this case. In its Motion papers,

Plaintiff complained about how long it took Exemplis to make its prior document productions.

Requiring Exemplis to conduct a second search and review will take even longer because

Exemplis anticipates it will yield substantially more than the 50,000 pages of documents and ESI

that were initially gathered pursuant to person/entity, search term, and timeframe limitations.

(Ching Decl., {§7-8.) This is because the search would need take place across Exemplis’ entire

system, not just as to certain custodians. It is also important to note that it is because of the initial

10 person/entity, search term, and timeframe limitations that Exemplis would be required to run a

1 second search in order to fully respond to RFP No. 7 as phrased.
Le 12 Further, it took well over 100 hours (and tens of thousands of dollars) for Exemplis’
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BSzZ 13 counsel to review those documents and ESI for responsiveness and applicable privileges.
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zea 14 Exemplis anticipates it will take even longer to review the documents and ESI pulled from a
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15 second search because there are no substantive and timeframe limitations in RFP No. 7. And to

16 what end? Exemplis’ initial review only yielded about 3,500 pages of responsive, non-privileged

17 documents and ESI out of 50,000 pages. Defendants should not have to endure this burden where

18 they have already produced thousands of pages worth of documents and ESI that are responsive

19 to RFP No. 7, and where Plaintiff has not yet identified any document/ESI missing from

20 Defendants’ prior productions (and has had several opportunities to do so) or made any proposals

21 to limit the scope of the request.

22 Iv. ALTERNATIVELY, THE COURT SHOULD LIMIT THE SCOPE OF RFP NO. 7

23 If the Court does not deny Plaintiff's Motion (which it should), then at a minimum it

24 should limit the scope of RFP No. 7. (See Cal. Code Civ. Proc. §§ 2017.020, subd. (a), 2031.310,

25 subd. (g).) Implementing Defendants’ November 24, 2021 proposal would limit RFP No. 7 so

26 that any search of the designated persons/entities be run with each of the designated transactions

27 (e.g., Trina Dunn AND PO10753). Doing this will reasonably narrow the timeframe and scope
28 of the person/entity searches based on the transactions that Plaintiff has identified as being

7
SUPPLEMENTAL BRIEF ISO OPPOSITION TO PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES TO FIRST DEMAND FOR
INSPECTION OF DOCUMENTS AND FOR SANCTIONS; CASE NO.: 20CV368229
related to the phishing incident. This approach would then enable Exemplis to amend its

response to RFP No. 7 to represent that it will produce all responsive documents since they have

already been captured by its prior searches. Also, the proposal would eliminate the need for a

second, duplicative search, and would provide Plaintiff with information that is reasonably

calculated to lead to the discovery of admissible evidence. (Jbid.)

Vv. THE COURT SHOULD DENY PLAINTIFF’S REQUEST FOR SANCTIONS

There can be no doubt that Defendants oppose Plaintiff's Motion with substantial

justification and have worked extensively with Plaintiff (and the Court) in good faith to resolve the

matter, despite having already pulled nearly 50,000 pages of documents and ESI pursuant to the

10 parties’ previous months-long meet and confers. (See Cal. Code Civ. Proc. § 2031.310, subd. (h).)

1 In addition to submitting extensive briefing on the matter, Defendants have engaged in two IDCs
2s 12 with the Court and several further meet and confers with Plaintiff, and provided Plaintiff with an
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15 sanctions on Defendants in connection with Plaintiff's Motion would be unjust. (See ibid.)

16 VI. CONCLUSION

17 Defendants respectfully request that the Court deny the Motion and Plaintiff's request for

18 sanctions, or, alternatively, order Defendants to amend their response to RFP No. 7 subject to

19 reasonable substantive and temporal limitations, as determined by the Court.

21 Dated: November 29, 2021 BAKER & HOSTETLER LLP

22
By:
23 Teresa C. Chow
Alexis B. Cruz
24
Attorneys for Defendants
25 EXEMPLIS, LLC and NANCY LOPEZ
26

8
SUPPLEMENTAL BRIEF ISO OPPOSITION TO PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES TO FIRST DEMAND FOR
INSPECTION OF DOCUMENTS AND FOR SANCTIONS; CASE NO.: 20CV368229
PROOF OF SERVICE

Iam employed in Los Angeles County, California. I am over the age of eighteen years
and not a party to the within-entitled action. My business address is 11601 Wilshire Boulevard,
Suite 1400, Los Angeles, CA 90025-0509. On November 29, 2021, I served a copy of the within
document(s) in a sealed envelope, addressed as follows:

SUPPLEMENTAL BRIEF IN SUPPORT OF EXEMPLIS, LLC AND NANCY LOPEZ’
OPPOSITION TO PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES TO
FIRST DEMAND FOR INSPECTION OF DOCUMENTS AND FOR SANCTIONS

M VIA EMAIL: by causing to be electronically transmitted a copy of the document
listed above via email to the address(es) as set forth below, in accordance with the
parties’ agreement to be served electronically pursuant to Code of Civil Procedure
section 1010.6 and California Rule of Court 2.251(a) or court order. No error
messages were received after said transmissions.

10
SEE ATTACHED SERVICE LIST.
11
25 12 I declare under penalty of perjury under the laws of the State of California that the above
ase is true and correct.
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Andi onz:

PROOF OF SERVICE
CASE NO.: 20CV368229
SERVICE LIST

Terry J. Mollica Glen H. Olives
MOLLICA LAW LAW OFFICE OF GLEN H. OLIVES
560 First Street, Suite B201 4701 Soquel Drive, Suite E
Benecia, CA 94510 Soquel, CA 95073
Telephone: 925.239.2380 Telephone: 408.505.6889
Facsimile: 925.239.2382 Email: gho57942@gmail.com
Email: tjm@caattnys.com
Attorneys for Plaintiff
Attorneys for Plaintiff PACIFIC OFFICE DESIGNS, INC.
PACIFIC OFFICE DESIGNS, INC.

Randall J. Dean
Mark E. DiMaria
10
CHAPMAN GLUCKSMAN,
1 DEAN & ROEB
11900 W. Olympic Blvd., Suite 800
Le 12 Los Angeles, CA 90064
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15
Attorneys for Defendants
16 SPOT ON CONSULTING GROUP,
JONATHAN R. LADDY, CPA AND
17 KELLY P. PLAYLE
18

PROOF OF SERVICE
CASE NO.: 20CV368229

Case Info

Judge

Socrates P. Manoukian Track Judge’s New Case

Case No.

(Subscribe to View)

Document Filed Date

November 29, 2021

Case Filing Date

July 09, 2020

County

Parties

Exemplis, LLC Defendant
Jonathan Ronald Laddy Defendant
Kelly Pauline Playle Defendant
Mark E. DiMaria Attorney For The Defendant
Nancy Lopez Defendant
Pacific Office Designs, Inc Plaintiff
Paul De Vries Defendant
SPOT ON CONSULTING GROUP Defendant
Teresa C Chow Attorney For The Defendant
Terry John Mollica Attorney For The Plaintiff
Glen Olives Attorneys for Plaintiffs
Randall Dean Attorneys for Defendants
Alexis Cruz Attorneys for Defendants
Peter Ching Attorney

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Party Discovery: Pacific Office Designs, Inc vs SPOT ON CONSULTING GROUP et al

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