1 KIMBERLY L HERNANDEZ

3809 EAST PITT AVE.

2 FRESNO, CA 93725
8052720108
3 DEFENDANT IN PROPRIA PERSONA

6 Superior Court of the State of California

For the County of FRESNO
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9 DAVID CORTEZ ) Case No. 16CECL005012

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10 Plaintiff, )
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11 vs. )
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FRANK D’AMBROSIO )
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Defendants. )
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PROPOUNDING PARTY: DEFENDANT: Kimberly Hernandez
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RESPONDING PARTY: PLAINTIFF: David Cortez
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20 SET NO.: ONE

21 TO: PLAINTIFF DAVID CORTEZ:

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PLEASE TAKE NOTICE THAT pursuant to California Code of Civil Procedure §§ 2031.010
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and 2031.210 et. seq., you are directed to respond separately, under oath and in writing, to each and
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every category of documents set forth herein, within five (5) days of service of this request.
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26 PLEASE TAKE NOTICE THAT, within five (5) days of service of this request, you are

27 directed to produce for inspection and copying of the same, all the documents and materials described
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REQUESTS FOR PRODUCTION OF DOCUMENTS, SET ONE
 1 below which are in your possession, custody, and/or control to: KIMBERLY HERNANDEZ 105
2 Pollasky Ave. Clovis, CA 93612
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Moreover, pursuant to this Code, the responding party is required to serve a written response,
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5 under oath, to this Demand within five (5) days after service. The response shall identify the

6 documents falling within the category specified and that inspection and related activities will be
7 permitted as requested, unless the request is objected to, in which event the reasons for objection
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shall be stated.
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Unless otherwise indicated, a copy of the documents requested mailed to the address shown

11 above shall be sufficient for this production of documents.

12 DEFINITIONS
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1. “YOU” or “YOU OR ANYONE ACTING ON YOUR BEHALF” means you, the
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Plaintiff, DAVID CORTEZ, your agents, your employees, your insurance companies, their agents,
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their employees, your attorneys, your accountants, your investigators, and anyone else acting on your
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17 behalf.

18 2. “YOUR” or “YOURSELF” means DAVID CORTEZ, your agents, your employees,

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your insurance companies, their agents, their employees, your attorneys, your accountants, your
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investigators, and anyone else acting on your behalf.
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3. “DOCUMENT” means a writing, as defined in Evidence Code § 250, and includes the
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23 original or a copy of handwriting, type-writing, printing, photostating, photographing, and every

24 other means of recording upon any tangible thing and form of communicating or representation,
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including letters, words, pictures, sounds, or symbols, or combinations of them.
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4. “PERSON” includes a natural person, firm, association, organization, partnership,
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business, trust, limited liability company, corporation, or public entity.
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REQUESTS FOR PRODUCTION OF DOCUMENTS, SET ONE
 1 5. “DEFENDANT” or “DEFENDANT OR ANYONE ACTING ON THEIR BEHALF”
2 in this set of request for production of documents means the Defendant, Kimberly L. Hernandez.
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6. “SUBJECT PROPERTY” means the real property located at 5291 West Yale Ave.,
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Fresno, CA 93722
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7. “LEASE AGREEMENT” means the Lease Agreement executed for the Lease of the

7 real property located at 5291 West Yale Ave.

8 PRODUCTION CATEGORIES
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REQUEST NUMBER 1
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Any and all DOCUMENTS identified in YOUR responses to the Form Interrogatories, Set
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One, concurrently served on you by DEFENDANT.
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13 REQUEST NUMBER 2

14 Any and all DOCUMENTS that evidence, memorialize, or tend to reflect in any way, YOUR
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ownership of the SUBJECT PROPERTY.
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REQUEST NUMBER 3
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Any and all DOCUMENTS that evidence, memorialize, or tend to reflect in any way, on any
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19 application for, renewal of, or issuance by the County of Fresno , of a Permit or Certificate of

20 Occupancy for the SUBJECT PROPERTY for the period from date you claim to have acquired
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ownership through the date of production specified herein.
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REQUEST NUMBER 4
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Any and all DOCUMENTS that evidence, memorialize, or tend to reflect in any way, on
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25 all notices of abatement, or other communications whether written or oral, received by YOU OR

26 ANYONE ACTING ON YOUR BEHALF from any and all government agencies or departments
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REQUESTS FOR PRODUCTION OF DOCUMENTS, SET ONE
 1 within the County of Fresno that relate in any way to the SUBJECT PROPERTY for the period from
2 August 1, 1989 through the date of production specified herein.
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REQUEST NUMBER 5
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Any and all DOCUMENTS that evidence, memorialize, or tend to reflect in any way, on any
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communications whether written, oral or via electronic mail sent to YOU OR ANYONE ACTING

7 ON YOUR BEHALF by DEFENDANT FRANK D’AMBROSIO and/or KIMBERLY

8 HERNANDEZ OR ANYONE ACTING ON THEIR BEHALF that relate in any way to the
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SUBJECT PROPERTY for the period from August 1, 1989, to the date of production specified
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herein.
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REQUEST NUMBER 6
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13 Any and all DOCUMENTS that evidence, memorialize, or tend to reflect in any way, on

14 all notices or other communications, whether written or oral, sent by YOU OR ANYONE ACTING
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ON YOUR BEHALF to DEFENDANT FRANK D’AMBROSIO and/or KIMBERLY HERNANDEZ
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OR ANYONE ACTING ON THEIR BEHALF that relate in any way to the SUBJECT PROPERTY
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for the period from August 1, 1989 through the date of production specified herein.
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19 REQUEST NUMBER 7

20 Any and all DOCUMENTS that evidence, memorialize, or tend to reflect in any way, on
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any repairs or other modifications made by YOU OR ANYONE ACTING ON YOUR BEHALF to
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the SUBJECT PROPERTY for the period from August 1, 1989 through the date of production
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specified herein.
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25 REQUEST NUMBER 8

26 Any and all DOCUMENTS that evidence, memorialize, or tend to reflect in any way, on
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REQUESTS FOR PRODUCTION OF DOCUMENTS, SET ONE
 1 any application for, renewal of, or issuance by any County of Fresno governmental agencies or
2 departments , of a Permit for, any additional structures or other work on the SUBJECT PROPERTY
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for the period from August 1, 1989 through the date of production specified herein.
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REQUEST NUMBER 9
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Any and all DOCUMENTS from Chicago Title pertaining to SUBJECT PROPERTY escrow

7 #1713333.

8 REQUEST NUMBER 10
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Any and all DOCUMENTS that evidence, memorialize, or reflect in any way any agreement between
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Sergio D’Ambrosio and Angelina D’Ambrosio.
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REQUEST NUMBER 11
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13 Any and all DOCUMENT that evidenced, memorialize, or tend to reflect in any way, the

14 consideration in which the Deed of Trust made on August 14, 1989, naming you as beneficiary was
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secured. Specifically, any promissory notes, any financial institution’s records reflecting any loans
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made by you to Sergio D’Ambrosio and/or Angelina D’ Ambrosio.
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REQUEST NUMBER 12
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19 Any and all Documents reflecting payment made to any Notary Public utilized for any documents to

20 which they affixed their seal and/or signature pertaining to SUBJECT PROPERTY from August of
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1989 to present.
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REQUEST NUMBER 13
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Any and all Documents pertaining to you or any agent acting on your behalf that evidenced,
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25 memorialized or tend to reflect in anyway the ownership of Paralegal Services, A California

26 Company and/or DRC Legal

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REQUEST NUMBER 14
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REQUESTS FOR PRODUCTION OF DOCUMENTS, SET ONE
 1 Copy of and/or Certificate of Trust for the “Cortez Family Trust”
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Dated: ________________ __________________________________________
5 Kimberly L. Hernandez,
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Defendant

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REQUESTS FOR PRODUCTION OF DOCUMENTS, SET ONE
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2 PROOF OF SERVICE
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I am over the age of 18 and not a party to this action.
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I am a resident of or employed in the county where the mailing occurred; my
5 business/residence address is: ADDRESS OF PERSON SERVING PAPERS.
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On I served the foregoing document(s) described as: REQUESTS FOR PRODUCTION OF
7 DOCUMENTS, SET ONE to the following parties:

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[X] (By U.S. Mail) I deposited such envelope in the mail at Fresno, California with postage
10 thereon fully prepaid. I am aware that on motion of the party served, service is
presumed in valid in postal cancellation date or postage meter date is more than
11 one day after date of deposit for mailing in affidavit.
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[X] By Fax
13 I declare under penalty of perjury under the laws of the State of California that the foregoing
is true and correct.
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16 DATED: ______________

17 _______________________________________
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REQUESTS FOR PRODUCTION OF DOCUMENTS, SET ONE