The Motion (ROA # 152) of Plaintiff Todd A. Mikles ("Plaintiff" or "Mikles") on behalf of all named Plaintiffs (collectively "Market Street Plaintiffs") to Compel the deposition of Defendant Dennis Dierenfield ("Defendant") and Production of Documents, and for Sanctions, is GRANTED IN PART, DENIED IN PART and will be HEARD IN PART.

Defendant's objections are OVERRULED. Defendant is directed to submit to a deposition within twenty (20) days of the hearing of this Motion. Unless counsel agree otherwise, Defendant's deposition shall be taken in person at a Conference Room located at 1020 State Street, Santa Barbara, California 93101. The Court will HEAR on the subject of protocols, if any, to be observed during the deposition. Defendant shall produce the documents to Plaintiff three (3) days prior to the deposition. Defendant's failure to submit a deposition was without substantial justification. Attorney Hahn's $375 hourly rate is reasonable. The services are reasonable and necessary. D