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FROM :SITAM LAL GROUP FAX NO. : 4888771548 Aug. 23 2684 @5:53PM Pl2
FILED BY FAX
Hab Siam, State Bar No. 214787 ALAMEDA COUNTY
SIAM LAW GROUP A Loa
2921 S. Winchester Blvd. “gus » 2004
Campbell, CA 95008 CLERK OF
Telephone: . (408) 873-0303 THE
By SUPERIOR
Corinna Garden Cour be RT
Fax Number: (408) 877-1548 Put
CASE NUMBER:
RGO3106646
Attorneys for Plaintiff Gwen R. Sykes
NI
SUPERIOR COURT OF THE STATE OF CALIFORNIA
to
COUNTY OF ALAMEDA
wo
10 GWEN R. SYKES, Case No, RGO3106646
1 Plaintiff, DECLARATION OF HAB SIAM IN
y OPPOSITION TO DEFENDANT'S
12 ; MOTION FOR EVIDENCE SANCTIONS
13 DOUGLAS 8YRES, an individual, and AND ATTORNEYS? FEES
DOES 1-20, inclusive
14 BY FAX
Defendants.
15 DATE: August 31, 2004
‘TIME: 2:00 p.m.
16 DEPT: 31
17 TRIAL DATE: October 1, 2004
18 I,Hab Siam, declare as follows:
19 lL. Tam an attorney at law licensed to practice before allthe courts of the State of
20 California and the attorney of record for plaintiff Gwen Sykes.
21 2. If called as a witness, Icould and would competently testify to the facts set forth
22 in this declaration, all of which are in my own personal knowledge.
23 3. Mr. Buell represented Gwen in this action from its July 2003 inception until May
24 2004, During that entire time, the parties engaged in extensive discovery proceedings-and
25 generated an enormous volume of files. Those discovery proceedings included numerous
26 depositions of Gwen and other parties, numerous interrogatorics, numerous document requests,
27 and numerous third-parly records subpoenas.
28 1
DEFENDANT’S MOTION FOR EVIDENCE SANCTIONS AND ATTORNEYS FEES
Case No, RG03106646
FROM :SIAM LAW GROUP FAs NO. :46B8771545 Aug. 23 26884 85:54PM P1S
4. In May 2004, Mr. Buell filed amotion to withdraw [rom this case, and I agreed to
substitute into this cage in reliance on an understanding thai all discovery had been stayed for 30
days into June 2004. Exhibit A contains a true and correct copy of a May 4, 2004 letterfrom Mr,
Buell to Mr. Piser confirming thai understanding,
5, My expectation was that fwould spend May 2004 clearing my other pending
matters, would spend much of June 2004 getting familiar with the voluminous files that had been
generated in this case, would spend July 2004 finishing discovery, would spend two weeks in
July 2004 and August 2004 completing a long-scheduled transfer and consolidation of my two
offices into one office, and spend August 2004 and September 2004 with expert discovery and
preparing for trial.
6. However, immediately upon my substitution into this case, Mr. Piser began
serving numerous additional deposition notices, deposition subpocnas, interrogatories, document
requests, and third-party records subpoenas, all of which have continued to this day, including
records subpoenas for production after the discovery cut-off date. Since June 2004, I have spent
nearly all of my time on this case dealing with the avalanche of new work initiated by Doug, but
Thave always fully cooperated with Mr. Piser in every possible way and sought to accommodate
Mr. Piser in every possible way.
7 Very shortly after I substituted inte thiscase, Doug filed two motions tocompel,
which together sought a total of approximately $900 in monctary sanctions. 1made the
determination to not oppose those motions because opposing them and appearing atthe hearings
would cost Gwen more money (han a non-opposition.
8. Aficr those unopposed motions to compel were granted, Gwen served the
interrogatory responses and the requested documents, Inadvertently, the actual document
production response may not have been produced to Mr, Piscr (although the documents
themselves were indisputably produced), but Ibelieved in good faith that the response itselfwas
also served and I’m willing to serve another.
27
28 2
DECLARATION OF HAB SIAM IN OPPOSITION TO
DEFENDANT'S MOTION FOR EVIDENCE SANCTIONS AND ATTORNEYS’ VERS
Case No. RGO3106646
FROM SIAM LAW GROUP FAX NO. ! 4888771548 Aug. 23 2664 @S:54Ph Pid
9. At some point in Angust 2004, Mr. Piser sent me one letter saying generally that
Mr. Piser was dissatisfied with the inlerrogatory responses, but Mr. Piser failed to specify the
nature of his dissatisfaction and didn’t inform me that a motion for cvidence sanctions was being
considered, Mr, Piser also sent a letterasking for the document production response, and |
believe that J had onc delivered to Mr. Piser. Additionally, |received that lelter while trying to
handle allof the matters relating to this case that Doug has initiated, including discovery, a
bifurcation motion, a summary judgment motion, depositions, and third-party records subpoenas,
while also somehow trying to become familiar with the voluminous files (hat were gencrated in
this case before {substituted in.
10 10, Upon reviewing Doug’s motion for evidence sanctions, I immediately offered Mr,
11 Piser the right to continue with any necessary depositions to accommodate any concems that he
12 might have — including discovery that he believes isnecessary after the discovery cut-off date.
13 Exhibit B contains a true and correct copy of my letterto Mr. Piser on that issue,
14 11. Tm willing to cooperate in any reasonable manner to ensure that Mr. Piser can
15 adequately prepare for trial,including making Gwen available for additional depositions aflerthe
16 discovery cut-off date.
17 12. In good faith, Ibelieve thal Doug has received adequate inierrogatory responses.
18 13, In good faith, |believe that Doug has received every document that is relevant to
19 this case, including the documents requested by the document production request at issue in this
20 motion.
2) 14. In good faith, Ibelieve that | instructed Mr. John T.incoln to deliver a document
22 production response 1o Mr. Piser’s office, but Idon’t have any written documentation indicating
23 ihat the delivery was made. I’m willing to send another document production response.
24 15. P’ve always believed that Mr. Piser and 1worked well iogether, and I’ve always
been willing to accommodate Mr. Piser’s requests to the greatest extent possible, and I’m willing
26 to do so again with respect to the matters that are the subject of his motion.
27
3
28
DECLARATION OF HAB SIAM IN OPPOSITION TO
DEFENDANT'S MOTION FOR EVIDENCE SANCTIONS AND ATTORNEYS’ [RES
Case No, RG03106646
FROM :SIAM LAL! GROUP FAX NO. :4688771548 Aug. 23 2864 85:54PM P15
16, Unfortunately, I don’t believe that Mr. Piser has made reasonable and good faith
efforts to informally resolve the currently pending discovery dispute, allhough I’m certain that
we would have been able to do so given a sufficient opportunity.
a]
17. In good faith,I believe that Doug has full knowledge of Gwen’s claims, of
wm
Gwen's evidence, of Gwen’s documents, of Gwen’s witnesses, and of everything relating to this
case,
18. Doug has subpocnaed and received every conccivable document that relates to
this case, many of which I’ve never seen due to my inability to keep up with the enormous and
relentless scope of Doug’s discovery.
10 19. Doug has subpoenaed Gwen for many days and many hours, and she remains
1 available for further deposition ».cvenafter the discovery cut-off date.
12 20. ‘Inat least two separate papers filed in this case and served on Mr. Piser, Gwen’s
13 entire case is spelled out in detail.
14 21. In this case, Tcharge my reduced rate of $300 per hour. I’ve spent six hours
15 responding to this motion. For the hearing on this motion, Iestimate that I’llspend an additional
16 30 minutes for a total of 6,5 hours. The filing fee is $36.30.
17 22. Consequently, Gwen’s reasonable costs and expenses in responding to this motion
18 are $1,986.30.
19 we KK
20 I declare under penalty of perjury under the laws of the State of California that the
ai foregoing istrue and correct,
22 Dated: August 23, 2004
23
24
Hab Siam
25
26
27
4
28
DECLARATION OF LAB STAM IN OPPOSITION TO
DEFENDANT'S MOTION FOR EVIDENCE SANCTIONS AND ATTORNEYS’ FEES
Case No. RG03 106646
FROM :SIAM LAL! GROUP FAX NO. : 4638771548 Aug. 23 2684 5:54PM P16
EXHIBIT A
May 4, 2004 Letter from E. Rick Buell, TTto Steven B. Piser
[Attached]
10
ll
12
13
14
15
16
7
19
20
21
23
24
25
26
28
ExusitT A To DECLARATION OF HAB SIAM Sykesv.Sykes/Cage
No. RCO3106646
FAX NO. :46eerris4e Aug. 23 2684 @S:55PM Pir
FROM :STAM LAL! GROUP
Law OfficeseAof B,OCRick Buell, 11
A PPE: CMON ih ee ge
CaM, CAGE A a Fl
he ale
ga,
PUA tedbib
kas ive
ed: aS ion muy
May 4, 20h
VIA EACSIMGE
Steven B, Piser, Esq.
49% Fourteenth Street
Saakte210
Oakland CA Gd6t2
Re: Sues wv.
Sykes
Dear Steve:
This letterwill contin our telephone conversanon of a dew minutes ago. Glen Zwang
wil! he filing a motion for an order permitting me towithdraw as Gwen's attorney of record.
Glenn's hopes to filethis motion tomorrow, but certainly by the end ofthe week. Glenn will
seek to sed ihe hearing date 21 days out. By this letter |am asking Glenn to fix you a eapy of the
MOVERE Papers.
This ewter will forther confirm that,in lightafthis motion, you have agreed-to suspend all 1
pending matters for 30 days with dhe exeeption of the deposition for the Custodian of Revords of
Dr. Smith, which is set to go fonwvard on Monday. You explained to me that Dr, Smith hae
agreed to produce the missing pages from his records tomorrow, and that, if he does, you mest
likely will cancel the deposition, ‘This letterwill alse confirm that the deposition of Dr. Cole is
att
Thank you for your consideration, Either Glen or Twillkeep you posted regarding the
withdrawal ration.
Sinceraly yours,
ne
ny a “ own,
cn othem
a eas Med
i Mon,
E. Rick Buell, i
FROM :SIAM LAL! GROUP FAX NO. : 4638771548 Aug. 23 2684 5:55PM Pls
EXHIBIT B
Letter from Hab Siam to Steven B, Piger
[Attached]
10
11
12
14
1s
16
7
18
19
20
21
22
23
24
25
26
28
PAUIBIT B TO DECLARATION OF ITAB SIAM Sykesv.Sykea/Case
No.RG03106646
FROM :SIAM LAL! GROUP FAX NO. : 4888771548 Aug. 235 2684 @5:55PM Pig
Cte ok asoos
2921SoulWinchester
vd.
Siam LAW GRouP (408)
873-0303
Dircet
Telophane
(408)
877-1548
Fax
HabSiom@isbeglobal.
net
August 22, 2004
Sent by Fax Only
Steven B. Piser
499 Fourteenth Street
Suite 210
Oakland, CA 94612
Re: Discovery Issues
Dear Mr, Piser:
I’ve now finally had a chance to review your motion for discovery sanctions, and I’m
surprised to learn that you believe you’re cntitled to an evidence exclusion order,
In any event, please understand that I’m prepared to make any document available to
you that you believe you've requested but not received. In addition, I’m prepared to make
Gwen available once again for deposition — without regard to the discovery cut-off date — on
any documents or issues thatyou reasonably believe arise from any such documents.
As soon as possible, please advise me as towhich documents you believe you need.
Sincerely,
SIAM LAW GROUP
one
Hab Siam
FROM :SITAM LAL! GROUP FAX NO. : 4888771545 Aug. 23 2684 @5:55PM Pee
SIAM l AW GROUP 2921SouthWinchester
Blvd.
Campbell,
CA 95008
(408)
873-0303Direct
Telephone
(408)
877-1848Fax
Recipient(s) Vax Number(s) Tel. Number(s}
Steven B, Piser (510) 832-1717 (510) 835-5582
Sender Fax Number Tel. Number
Hab Siam (408) 877-1548 (408) 873-0303
Date: 8/22/2004 Pages: 2 (including cover page)
Subject: Discovery Issucs
Notes: Please see the attached letter,
FROM :S1AM LAL GROUP FAX NO. :4@58r?1546 Aug. 23 2884 5:55PM Pel
SEMCIMG REPOET
Aug. 22 2HM4 Bai 2ePM
OUR LOGO : STAM LAW GROUP
YOUR FAX NO. : 4888771548
NO. OTHER FACSIMILE START TIME USAGE TIME MODE PAGES RESULT
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TO TURM OFF REPORT, PRESS "MENU? Had,
THEN SELECT OFF BY USING '+? GR ’-*.
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FROM :SITAM LAL GROUP FAX NO. : 4888771548 Aug. 23 2684 @5:53PM Pl2 FILED BY FAX Hab Siam, State Bar No. 214787 ALAMEDA COUNTY SIAM LAW GROUP A Loa 2921 S. Winchester Blvd. “gus » 2004 Campbell, CA 95008 CLERK OF Telephone: . (408) 873-0303 THE By SUPERIOR Corinna Garden Cour be RT Fax Number: (408) 877-1548 Put CASE NUMBER: RGO3106646 Attorneys for Plaintiff Gwen R. Sykes NI SUPERIOR COURT OF THE STATE OF CALIFORNIA to COUNTY OF ALAMEDA wo 10 GWEN R. SYKES, Case No, RGO3106646 1 Plaintiff, DECLARATION OF HAB SIAM IN y OPPOSITION TO DEFENDANT'S 12 ; MOTION FOR EVIDENCE SANCTIONS 13 DOUGLAS 8YRES, an individual, and AND ATTORNEYS? FEES DOES 1-20, inclusive 14 BY FAX Defendants. 15 DATE: August 31, 2004 ‘TIME: 2:00 p.m. 16 DEPT: 31 17 TRIAL DATE: October 1, 2004 18 I,Hab Siam, declare as follows: 19 lL. Tam an attorney at law licensed to practice before allthe courts of the State of 20 California and the attorney of record for plaintiff Gwen Sykes. 21 2. If called as a witness, Icould and would competently testify to the facts set forth 22 in this declaration, all of which are in my own personal knowledge. 23 3. Mr. Buell represented Gwen in this action from its July 2003 inception until May 24 2004, During that entire time, the parties engaged in extensive discovery proceedings-and 25 generated an enormous volume of files. Those discovery proceedings included numerous 26 depositions of Gwen and other parties, numerous interrogatorics, numerous document requests, 27 and numerous third-parly records subpoenas. 28 1 DEFENDANT’S MOTION FOR EVIDENCE SANCTIONS AND ATTORNEYS FEES Case No, RG03106646 FROM :SIAM LAW GROUP FAs NO. :46B8771545 Aug. 23 26884 85:54PM P1S 4. In May 2004, Mr. Buell filed amotion to withdraw [rom this case, and I agreed to substitute into this cage in reliance on an understanding thai all discovery had been stayed for 30 days into June 2004. Exhibit A contains a true and correct copy of a May 4, 2004 letterfrom Mr, Buell to Mr. Piser confirming thai understanding, 5, My expectation was that fwould spend May 2004 clearing my other pending matters, would spend much of June 2004 getting familiar with the voluminous files that had been generated in this case, would spend July 2004 finishing discovery, would spend two weeks in July 2004 and August 2004 completing a long-scheduled transfer and consolidation of my two offices into one office, and spend August 2004 and September 2004 with expert discovery and preparing for trial. 6. However, immediately upon my substitution into this case, Mr. Piser began serving numerous additional deposition notices, deposition subpocnas, interrogatories, document requests, and third-party records subpoenas, all of which have continued to this day, including records subpoenas for production after the discovery cut-off date. Since June 2004, I have spent nearly all of my time on this case dealing with the avalanche of new work initiated by Doug, but Thave always fully cooperated with Mr. Piser in every possible way and sought to accommodate Mr. Piser in every possible way. 7 Very shortly after I substituted inte thiscase, Doug filed two motions tocompel, which together sought a total of approximately $900 in monctary sanctions. 1made the determination to not oppose those motions because opposing them and appearing atthe hearings would cost Gwen more money (han a non-opposition. 8. Aficr those unopposed motions to compel were granted, Gwen served the interrogatory responses and the requested documents, Inadvertently, the actual document production response may not have been produced to Mr, Piscr (although the documents themselves were indisputably produced), but Ibelieved in good faith that the response itselfwas also served and I’m willing to serve another. 27 28 2 DECLARATION OF HAB SIAM IN OPPOSITION TO DEFENDANT'S MOTION FOR EVIDENCE SANCTIONS AND ATTORNEYS’ VERS Case No. RGO3106646 FROM SIAM LAW GROUP FAX NO. ! 4888771548 Aug. 23 2664 @S:54Ph Pid 9. At some point in Angust 2004, Mr. Piser sent me one letter saying generally that Mr. Piser was dissatisfied with the inlerrogatory responses, but Mr. Piser failed to specify the nature of his dissatisfaction and didn’t inform me that a motion for cvidence sanctions was being considered, Mr, Piser also sent a letterasking for the document production response, and | believe that J had onc delivered to Mr. Piser. Additionally, |received that lelter while trying to handle allof the matters relating to this case that Doug has initiated, including discovery, a bifurcation motion, a summary judgment motion, depositions, and third-party records subpoenas, while also somehow trying to become familiar with the voluminous files (hat were gencrated in this case before {substituted in. 10 10, Upon reviewing Doug’s motion for evidence sanctions, I immediately offered Mr, 11 Piser the right to continue with any necessary depositions to accommodate any concems that he 12 might have — including discovery that he believes isnecessary after the discovery cut-off date. 13 Exhibit B contains a true and correct copy of my letterto Mr. Piser on that issue, 14 11. Tm willing to cooperate in any reasonable manner to ensure that Mr. Piser can 15 adequately prepare for trial,including making Gwen available for additional depositions aflerthe 16 discovery cut-off date. 17 12. In good faith, Ibelieve thal Doug has received adequate inierrogatory responses. 18 13, In good faith, |believe that Doug has received every document that is relevant to 19 this case, including the documents requested by the document production request at issue in this 20 motion. 2) 14. In good faith, Ibelieve that | instructed Mr. John T.incoln to deliver a document 22 production response 1o Mr. Piser’s office, but Idon’t have any written documentation indicating 23 ihat the delivery was made. I’m willing to send another document production response. 24 15. P’ve always believed that Mr. Piser and 1worked well iogether, and I’ve always been willing to accommodate Mr. Piser’s requests to the greatest extent possible, and I’m willing 26 to do so again with respect to the matters that are the subject of his motion. 27 3 28 DECLARATION OF HAB SIAM IN OPPOSITION TO DEFENDANT'S MOTION FOR EVIDENCE SANCTIONS AND ATTORNEYS’ [RES Case No, RG03106646 FROM :SIAM LAL! GROUP FAX NO. :4688771548 Aug. 23 2864 85:54PM P15 16, Unfortunately, I don’t believe that Mr. Piser has made reasonable and good faith efforts to informally resolve the currently pending discovery dispute, allhough I’m certain that we would have been able to do so given a sufficient opportunity. a] 17. In good faith,I believe that Doug has full knowledge of Gwen’s claims, of wm Gwen's evidence, of Gwen’s documents, of Gwen’s witnesses, and of everything relating to this case, 18. Doug has subpocnaed and received every conccivable document that relates to this case, many of which I’ve never seen due to my inability to keep up with the enormous and relentless scope of Doug’s discovery. 10 19. Doug has subpoenaed Gwen for many days and many hours, and she remains 1 available for further deposition ».cvenafter the discovery cut-off date. 12 20. ‘Inat least two separate papers filed in this case and served on Mr. Piser, Gwen’s 13 entire case is spelled out in detail. 14 21. In this case, Tcharge my reduced rate of $300 per hour. I’ve spent six hours 15 responding to this motion. For the hearing on this motion, Iestimate that I’llspend an additional 16 30 minutes for a total of 6,5 hours. The filing fee is $36.30. 17 22. Consequently, Gwen’s reasonable costs and expenses in responding to this motion 18 are $1,986.30. 19 we KK 20 I declare under penalty of perjury under the laws of the State of California that the ai foregoing istrue and correct, 22 Dated: August 23, 2004 23 24 Hab Siam 25 26 27 4 28 DECLARATION OF LAB STAM IN OPPOSITION TO DEFENDANT'S MOTION FOR EVIDENCE SANCTIONS AND ATTORNEYS’ FEES Case No. RG03 106646 FROM :SIAM LAL! GROUP FAX NO. : 4638771548 Aug. 23 2684 5:54PM P16 EXHIBIT A May 4, 2004 Letter from E. Rick Buell, TTto Steven B. Piser [Attached] 10 ll 12 13 14 15 16 7 19 20 21 23 24 25 26 28 ExusitT A To DECLARATION OF HAB SIAM Sykesv.Sykes/Cage No. RCO3106646 FAX NO. :46eerris4e Aug. 23 2684 @S:55PM Pir FROM :STAM LAL! GROUP Law OfficeseAof B,OCRick Buell, 11 A PPE: CMON ih ee ge CaM, CAGE A a Fl he ale ga, PUA tedbib kas ive ed: aS ion muy May 4, 20h VIA EACSIMGE Steven B, Piser, Esq. 49% Fourteenth Street Saakte210 Oakland CA Gd6t2 Re: Sues wv. Sykes Dear Steve: This letterwill contin our telephone conversanon of a dew minutes ago. Glen Zwang wil! he filing a motion for an order permitting me towithdraw as Gwen's attorney of record. Glenn's hopes to filethis motion tomorrow, but certainly by the end ofthe week. Glenn will seek to sed ihe hearing date 21 days out. By this letter |am asking Glenn to fix you a eapy of the MOVERE Papers. This ewter will forther confirm that,in lightafthis motion, you have agreed-to suspend all 1 pending matters for 30 days with dhe exeeption of the deposition for the Custodian of Revords of Dr. Smith, which is set to go fonwvard on Monday. You explained to me that Dr, Smith hae agreed to produce the missing pages from his records tomorrow, and that, if he does, you mest likely will cancel the deposition, ‘This letterwill alse confirm that the deposition of Dr. Cole is att Thank you for your consideration, Either Glen or Twillkeep you posted regarding the withdrawal ration. Sinceraly yours, ne ny a “ own, cn othem a eas Med i Mon, E. Rick Buell, i FROM :SIAM LAL! GROUP FAX NO. : 4638771548 Aug. 23 2684 5:55PM Pls EXHIBIT B Letter from Hab Siam to Steven B, Piger [Attached] 10 11 12 14 1s 16 7 18 19 20 21 22 23 24 25 26 28 PAUIBIT B TO DECLARATION OF ITAB SIAM Sykesv.Sykea/Case No.RG03106646 FROM :SIAM LAL! GROUP FAX NO. : 4888771548 Aug. 235 2684 @5:55PM Pig Cte ok asoos 2921SoulWinchester vd. Siam LAW GRouP (408) 873-0303 Dircet Telophane (408) 877-1548 Fax HabSiom@isbeglobal. net August 22, 2004 Sent by Fax Only Steven B. Piser 499 Fourteenth Street Suite 210 Oakland, CA 94612 Re: Discovery Issues Dear Mr, Piser: I’ve now finally had a chance to review your motion for discovery sanctions, and I’m surprised to learn that you believe you’re cntitled to an evidence exclusion order, In any event, please understand that I’m prepared to make any document available to you that you believe you've requested but not received. In addition, I’m prepared to make Gwen available once again for deposition — without regard to the discovery cut-off date — on any documents or issues thatyou reasonably believe arise from any such documents. As soon as possible, please advise me as towhich documents you believe you need. Sincerely, SIAM LAW GROUP one Hab Siam FROM :SITAM LAL! GROUP FAX NO. : 4888771545 Aug. 23 2684 @5:55PM Pee SIAM l AW GROUP 2921SouthWinchester Blvd. Campbell, CA 95008 (408) 873-0303Direct Telephone (408) 877-1848Fax Recipient(s) Vax Number(s) Tel. Number(s} Steven B, Piser (510) 832-1717 (510) 835-5582 Sender Fax Number Tel. Number Hab Siam (408) 877-1548 (408) 873-0303 Date: 8/22/2004 Pages: 2 (including cover page) Subject: Discovery Issucs Notes: Please see the attached letter, FROM :S1AM LAL GROUP FAX NO. :4@58r?1546 Aug. 23 2884 5:55PM Pel SEMCIMG REPOET Aug. 22 2HM4 Bai 2ePM OUR LOGO : STAM LAW GROUP YOUR FAX NO. : 4888771548 NO. OTHER FACSIMILE START TIME USAGE TIME MODE PAGES RESULT 41 15188321717 Rug. 22 G2:21PM a" 46 SND a2 OK TO TURM OFF REPORT, PRESS "MENU? Had, THEN SELECT OFF BY USING '+? GR ’-*. FOR FAX ADVANTAGE ASSISTANCE, PLEASE CALL 1—-G@A-HELP-FAK (435-7329).