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DocuSign Envelope ID: B2EC2241-95BB-4836-9B97-AC876D255F5B
Maya Castro
777 Silver Spur Road, Suite 235
Rolling Hills Estates, CA 90274
Email: mayas.castro@ yahoo.com
Phone: (424) 392-0002
Plaintiff in Pro Per
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SONOMA
MAYA CASTRO, an individual, Case No. SCV -269513
Plaintiff, REQUEST FOR JUDICIAL NOTICE IN
SUPPORT OF PLAINTIFF’S MOTION
10 vs. FOR SUMMARY JUDGMENT AND/OR
ADJUDICATION
11 SPURGEON PAINTING, INC., a Califomia
Corporation; THOMAS BOY D MEACHAM
12 IIL, an individual; TIJA BUCKALEW, an
Date:
individual and DOES 1-50,
Time:
13
Dept: 18
Defendants.
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TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
16
PLEASE TAKE NOTICE that, pursuant to Rule 323 of the Califormia Rules of Court and
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Section 452 of the Califomia Evidence Code, and in support of Plaintiff's motion for summary
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19 judgment and/or adjudication, Plaintiff respectfully requests the court to take judicial notice of the
20 following documents:
21 1. A true and correct copy of the Responses to Request for Production, Set One propounded
22 upon Meacham, attached hereto as Exhibit A.
23 2 A true and correct copy of the Responses to Request forA dmissions, Set One propounded
24
upon Meacham, attached hereto as Exhibit B.
25
A true and correct copy of the October 15, 2021 Plaintiff's Complaint, attached hereto as
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Exhibit C.
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Request for Judicial Notice
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DocuSign Envelope ID: B2EC2241-95BB-4836-9B97-AC876D255F5B
A true and correct copy of the Defendantsfiled theirjoint First Amended A nswer, attached
hereto as Exhibit D.
A tme and correct copy of the Responses to Request for Production, Set Two propounded
upon Meacham, attached hereto as Exhibit E.
A tme and correct copy of the Responses to Request for Production, Set One propounded
upon Buckalew, attached hereto as Exhibit F.
A tmueand correct copy of the Responses to Responses to Special Interrogatories, Set One
propounded upon Meacham, attached hereto as Exhibit G.
10 This Request is made in support of Plaintiff's concurrently filed Motion for Summary
11 Judgment and/or Adjudication. This Request is based on this Notice, the attached memorandum
12 of points and authorities, all pleadings, records and files in this action, and upon such further
13 evidence and argument as may be presented at any hearing on this matter.
14
15
Respectfully Submitted,
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17
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19 DocuSigned by:
20
4/21/2023
Dated ee a Castro
——---5- a
Maya Castro, Plaintiff'in Pro Per
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Request for Judicial Notice
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DocuSign Envelope ID: B2EC2241-95BB-4836-9B97-AC876D255F5B
PROOF OF SERVICE
STATE OF CALIFORNIA
COUNTY OF SONOMA
I am a resident of the state of Califomia and over the age of 18 and not a party to the
within action. My business address is: 777 Silver Spur Rd. Suite 235 Rolling Hills Estates CA
90274
4/21/2023
On -a 5 I served the following documents:
REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF PLAINTIFF’S MOTION FOR
SUMMARY JUDGMENT AND/OR ADJUDICATION
10 I penomaly da rervie documents listed above to the parties or person authorized to
receive service of process for the party on (date) —-- a at (time) Jo
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12 By United States Mail.
Iplaced the envelope forcollection and mailing, following our ordinary business practices.
13
I am readily familiar with this business practice forcollecting and processing correspondence for
14 mailing. On the same day that correspondence is placed for collection and mailing, it is deposited
in the ordinary course of business with the United States Postal Service, in a sealed envelope with
15 postage fully prepaid. The envelope or package was placed in the mail at
Califomia.
16
17 By Email.
I caused the above-transcribed documents to be transmitted by email to
18 daqui@ smithdollar.com.
19 I declare under penalty of perjury under the laws of the state of Califomia that the
20 foregoing is true and correct.
21
22 4/21/2023 Rolling Hills Estates
Executed on aaa Califomia.
23 DocuSigned by:
24 Luis Castro (wis Castro
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Name of Declarant Signature of Declarant
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Request for Judicial Notice
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DocuSign Envelope ID: B2EC2241-95BB-4836-9B97-AC876D255F5B
CASTRO vs. SPURGEON PAINTING, INC., etal.
Court Case No.: SCV -269513
MAILING LIST
Diane A qui, Esq.
SMITH DOLLAR PC
418 B Street, 4th Floor
Santa Rosa, CA 95401
daqui@ smithdollar.com
ATTORNEY FOR DEFENDANTS
SPURGEON PAINTING, INC.;
10 THOMAS BOYD MEACHAM
Il; and TIA BUCKALEW.
11
12
13
14
15
16
17
18
19
20
21
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23
24
25
26
27
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Request for Judicial Notice
Exhibit A
Diane Aqui, SBN 217087
daqui@smithdollar.com
SMITH DOLLAR PC
Attorneys at Law
418 B Street, Fourth Floor
Santa Rosa, California 95401
Telephone: (707) 522-1100
Facsimile: (707) 522-1101
Attorneys for Defendants SPURGEON PAINTING, INC., THOMAS BOYD MEACHAM III, and
TIA BUCKALEW
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONOMA
10 MAYA CASTRO, an individual, CASE NO.: SCV-269513
11 Plaintiff, THOMAS BOYD MEACHAM IIL,'S
V. RESPONSES TO MAYA CASTRO’S
12 REQUEST FOR PRODUCTION OF
SPURGEON PAINTING, INC., a California DOCUMENTS, SET ONE
13 Corporation; THOMAS BOYD MEACHAM
III, an individual; TIA BUCKALEW, an [CCP § 2031.210 et seq.]
14 individual and DOES 1-50,
Judge: Hon. Jennifer V. Dollard
15 Defendants.
Complaint Filed: October 15, 2021
16 Trial Date: March 17, 2023
17
18 PROPOUNDING PARTY: MAYA CASTRO
19 RESPONDING PARTY: THOMAS BOYD MEACHAM III
20 SET NUMBER: ONE
21 TO MAYA CASTRO AND TO [HIS/HER] ATTORNEY OF RECORD:
22 Defendant THOMAS BOYD MEACHAM III (hereinafter “Responding Party”), pursuant to
23 the provisions of section 2031.210 et seg. of the California Code of Civil Procedure, hereby
24 responds to the Request for Production of Documents, Set One, propounded by MAYA CASTRO
25 (hereinafter “Propounding Party”) as follows:
26 Mil
nm 27 Mil
<4 28 1273543 -1-
THOMAS BOYD MEACHAM III'S RESPONSES TO MAYA CASTRO’S REQUEST FOR PRODUCTION OF
DOCUMENTS, SET ONE
RESPONSES TO REQUESTS FOR PRODUCTION
REQUEST FOR PRODUCTION NO. 1:
ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 2.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1:
In addition to documents previously produced (employee file, payroll records, January 15,
2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding
party will produce.
REQUEST FOR PRODUCTION NO. 2:
ALL COMMUNICATIONS IDENTIFIED in YOUR response to Special Interrogatory No.
10 4
11 RESPONSE TO REQUEST FOR PRODUCTION NO. 2:
12 In addition to documents previously produced (employee file, payroll records, January 15,
13 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding
14 party will produce.
15 REQUEST FOR PRODUCTION NO. 3:
16 ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 6.
17 RESPONSE TO REQUEST FOR PRODUCTION NO. 3:
18 In addition to documents previously produced (employee file, payroll records, January 15,
19 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding
20 party will produce.
21 REQUEST FOR PRODUCTION NO. 4:
22 ALL COMMUNICATIONS IDENTIFIED in YOUR response to Special Interrogatory
23 No. 8.
24 RESPONSE TO REQUEST FOR PRODUCTION NO. 4:
25 In addition to documents previously produced (employee file, payroll records, January 15,
26 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding
~ 27 party will produce.
28
1273543 -2-
THOMAS BOYD MEACHAM III'S RESPONSES TO MAYA CASTRO’S REQUEST FOR PRODUCTION OF
DOCUMENTS, SET ONE
REQUEST FOR PRODUCTION NO. 5:
ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 10.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5:
In addition to documents previously produced (employee file, payroll records, January 15,
2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding
party will produce.
REQUEST FOR PRODUCTION NO. 6:
ALL COMMUNICATIONS IDENTIFIED in YOUR response to Special Interrogatory No.
12.
10 RESPONSE TO REQUEST FOR PRODUCTION NO. 6:
11 In addition to documents previously produced (employee file, payroll records, January 15,
12 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding
13 party will produce.
14 REQUEST FOR PRODUCTION NO. 7:
15 ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 14.
16 RESPONSE TO REQUEST FOR PRODUCTION NO. 7:
17 In addition to documents previously produced (employee file, payroll records, January 15,
18 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding
19 party will produce.
20 REQUEST FOR PRODUCTION NO. 8:
21 ALL COMMUNICATIONS IDENTIFIED in YOUR response to Special Interrogatory
22 No. 16.
23 RESPONSE TO REQUEST FOR PRODUCTION NO. 8:
24 In addition to documents previously produced (employee file, payroll records, January 15,
25 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding
26 party will produce.
~ 27 Mil
28
1273543 -3-
THOMAS BOYD MEACHAM III'S RESPONSES TO MAYA CASTRO’S REQUEST FOR PRODUCTION OF
DOCUMENTS, SET ONE
REQUEST FOR PRODUCTION NO. 9:
ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 18.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9:
In addition to documents previously produced (employee file, payroll records, January 15,
2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding
party will produce.
REQUEST FOR PRODUCTION NO. 10:
ALL COMMUNICATIONS IDENTIFIED in YOUR response to Special Interrogatory
No. 20.
10 RESPONSE TO REQUEST FOR PRODUCTION NO. 10:
11 In addition to documents previously produced (employee file, payroll records, January 15,
12 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding
13 party will produce.
14 REQUEST FOR PRODUCTION NO. 11:
15 ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 22.
16 RESPONSE TO REQUEST FOR PRODUCTION NO. 11:
17 In addition to documents previously produced (employee file, payroll records, January 15,
18 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding
19 party will produce.
20 REQUEST FOR PRODUCTION NO. 12:
21 ALL COMMUNICATIONS IDENTIFIED in YOUR response to Special Interrogatory
22 No. 24.
23 RESPONSE TO REQUEST FOR PRODUCTION NO. 12:
24 In addition to documents previously produced (employee file, payroll records, January 15,
25 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding
26 party will produce.
~ 27 Mil
28
1273543 -4-
THOMAS BOYD MEACHAM III'S RESPONSES TO MAYA CASTRO’S REQUEST FOR PRODUCTION OF
DOCUMENTS, SET ONE
REQUEST FOR PRODUCTION NO. 13:
ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 26.
RESPONSE TO REQUEST FOR PRODUCTION NO. 13:
In addition to documents previously produced (employee file, payroll records, January 15,
2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding
party will produce.
REQUEST FOR PRODUCTION NO. 14:
ALL COMMUNICATIONS IDENTIFIED in YOUR response to Special Interrogatory
No. 28.
10 RESPONSE TO REQUEST FOR PRODUCTION NO. 14:
11 In addition to documents previously produced (employee file, payroll records, January 15,
12 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding
13 party will produce.
14 REQUEST FOR PRODUCTION NO. 15:
15 ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 30.
16 RESPONSE TO REQUEST FOR PRODUCTION NO. 15:
17 In addition to documents previously produced (employee file, payroll records, January 15,
18 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding
19 party will produce.
20 REQUEST FOR PRODUCTION NO. 16:
21 ALL COMMUNICATIONS IDENTIFIED in YOUR response to Special Interrogatory
22 No. 32.
23 RESPONSE TO REQUEST FOR PRODUCTION NO. 16:
24 In addition to documents previously produced (employee file, payroll records, January 15,
25 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding
26 party will produce.
~ 27 Mil
28
1273543 -5-
THOMAS BOYD MEACHAM III'S RESPONSES TO MAYA CASTRO’S REQUEST FOR PRODUCTION OF
DOCUMENTS, SET ONE
REQUEST FOR PRODUCTION NO. 17:
ALL COMMUNICATIONS IDENTIFIED in YOUR response to Special Interrogatory
No. 42.
RESPONSE TO REQUEST FOR PRODUCTION NO. 17:
In addition to documents previously produced (employee file, payroll records, January 15,
2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding
party will produce.
REQUEST FOR PRODUCTION NO. 18:
ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 67.
10 RESPONSE TO REQUEST FOR PRODUCTION NO. 18:
11 Responding party objects to this discovery request on the grounds that it is not reasonably
12 calculated to lead to the discovery of admissible evidence. Responding party further objects as this
13 is improper discovery regarding punitive damages. Responding party objects to this request on the
14 grounds that it constitutes an invasion of third party’s privacy, as guaranteed by the California
15 Constitution, Article I, Section]. Responding party objects to this discovery request on the grounds
16 that it is vague and ambiguous and is therefore also burdensome and oppressive. Responding party
17 further objects as the discovery request is meant only to harass and is an improper use of the
18 discovery statutes.
19 REQUEST FOR PRODUCTION NO. 19:
20 ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 68.
21 RESPONSE TO REQUEST FOR PRODUCTION NO. 19:
22 Responding party objects to this discovery request on the grounds that it is not reasonably
23 calculated to lead to the discovery of admissible evidence. Responding party further objects as this
24 is improper discovery regarding punitive damages. Responding party objects to this request on the
25 grounds that it constitutes an invasion of third party’s privacy, as guaranteed by the California
26 Constitution, Article I, Section]. Responding party objects to this discovery request on the grounds
wa 27 that it is vague and ambiguous and is therefore also burdensome and oppressive. Responding party
om 28
1273543 -6-
THOMAS BOYD MEACHAM III'S RESPONSES TO MAYA CASTRO’S REQUEST FOR PRODUCTION OF
DOCUMENTS, SET ONE
objects to this discovery request on the grounds that it is violative of CCP §2030.060 (f) and is
compound, conjunctive or disjunctive, and is therefore burdensome and oppressive. Responding
party further objects as the discovery request is meant only to harass and is an improper use of the
discovery statutes.
REQUEST FOR PRODUCTION NO. 20:
ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 69.
RESPONSE TO REQUEST FOR PRODUCTION NO. 20:
Responding party objects to this discovery request on the grounds that it is not reasonably
calculated to lead to the discovery of admissible evidence. Responding party objects to this request
10 on the grounds that it constitutes an invasion of third party’s privacy, as guaranteed by the
11 California Constitution, Article I, Section]. Responding party objects to this discovery request on
12 the grounds that it is vague and ambiguous and is therefore also burdensome and oppressive.
13 Responding party objects to this discovery request on the grounds that it is over broad and
14 burdensome. Responding party further objects as the discovery request is meant only to harass and
15 is an improper use of the discovery statutes.
16 REQUEST FOR PRODUCTION NO. 21:
17 ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 70.
18 RESPONSE TO REQUEST FOR PRODUCTION NO. 21:
19 Responding party objects to this discovery request on the grounds that it is not reasonably
20 calculated to lead to the discovery of admissible evidence. Responding party objects to this request
21 on the grounds that it constitutes an invasion of third party’s privacy, as guaranteed by the
22 California Constitution, Article I, Section]. Responding party objects to this discovery request on
23 the grounds that it is vague and ambiguous and is therefore also burdensome and oppressive.
24 Responding party objects to this discovery request on the grounds that it is over broad and
25 burdensome. Responding party further objects as the discovery request is meant only to harass and
26 is an improper use of the discovery statutes.
wa 27 Mil
om 28
1273543 -7-
THOMAS BOYD MEACHAM III'S RESPONSES TO MAYA CASTRO’S REQUEST FOR PRODUCTION OF
DOCUMENTS, SET ONE
REQUEST FOR PRODUCTION NO. 22:
ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 72.
RESPONSE TO REQUEST FOR PRODUCTION NO. 22:
Responding party objects to this discovery request on the grounds that it is vague and
ambiguous and is therefore also burdensome and oppressive. Responding party further objects as
the discovery request is meant only to harass and is an improper use of the discovery statutes.
REQUEST FOR PRODUCTION NO. 23:
ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 74.
RESPONSE TO REQUEST FOR PRODUCTION NO. 23:
10 Responding party objects to this discovery request on the grounds that it is burdensome and
11 oppressive. Responding party objects to this discovery request on the grounds that it is not
12 reasonably calculated to lead to the discovery of admissible evidence. Responding party objects to
13 this request on the grounds that it constitutes an invasion of third party’s privacy, as guaranteed by
14 the California Constitution, Article I, Section]. Responding party further objects as the discovery
15 request is meant only to harass and is an improper use of the discovery statutes.
16 REQUEST FOR PRODUCTION NO. 24:
17 ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 76.
18 RESPONSE TO REQUEST FOR PRODUCTION NO. 24:
19 Responding party objects to this discovery request on the grounds that it is vague and
20 ambiguous as to “relating to human resources”, and is therefore also burdensome and oppressive.
21 REQUEST FOR PRODUCTION NO. 25:
22 ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 78.
23 RESPONSE TO REQUEST FOR PRODUCTION NO. 25:
24 Responding party objects to this discovery request on the grounds that it is vague and
25 ambiguous, and is therefore also burdensome and oppressive. Responding party objects to this
26 discovery request on the grounds that it is burdensome and oppressive.
~ 27 Mil
28
1273543 -8-
THOMAS BOYD MEACHAM III'S RESPONSES TO MAYA CASTRO’S REQUEST FOR PRODUCTION OF
DOCUMENTS, SET ONE
REQUEST FOR PRODUCTION NO. 26:
ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 80
RESPONSE TO REQUEST FOR PRODUCTION NO. 26:
Responding party objects to this discovery request on the grounds that it is vague and
ambiguous, and is therefore also burdensome and oppressive. Responding party objects to this
discovery request on the grounds that it is burdensome and oppressive.
REQUEST FOR PRODUCTION NO. 27:
ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 82
RESPONSE TO REQUEST FOR PRODUCTION NO. 27:
10 Responding party objects to this discovery request on the grounds that it is vague and
11 ambiguous, and is therefore also burdensome and oppressive. Responding party objects to this
12 discovery request on the grounds that it is burdensome and oppressive.
13 REQUEST FOR PRODUCTION NO. 28:
14 ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 84
15 RESPONSE TO REQUEST FOR PRODUCTION NO. 28:
16 Responding party objects to this discovery request on the grounds that it is vague and
17 ambiguous, and is therefore also burdensome and oppressive. Responding party objects to this
18 discovery request on the grounds that it is burdensome and oppressive.
19 REQUEST FOR PRODUCTION NO. 29:
20 ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 86
21 RESPONSE TO REQUEST FOR PRODUCTION NO. 29:
22 Responding party objects to this discovery request on the grounds that it is vague and
23 ambiguous, and is therefore also burdensome and oppressive. Responding party objects to this
24 discovery request on the grounds that it is overbroad, and burdensome and oppressive. Responding
25 party further objects as the discovery request is meant only to harass and is an improper use of the
26 discovery statutes. Responding party further objects to the extent this discovery request violates
~ 27 Code Civ. Proc., §§ 1985.3, 1985.6.
28
1273543 -9-
THOMAS BOYD MEACHAM III'S RESPONSES TO MAYA CASTRO’S REQUEST FOR PRODUCTION OF
DOCUMENTS, SET ONE
REQUEST FOR PRODUCTION NO. 30:
ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 87.
RESPONSE TO REQUEST FOR PRODUCTION NO. 30:
Responding party did not identify any documents in his response to Special Interrogatory
No. 87, as he objected to that discovery request on the grounds that it is violative of CCP §2030.060
(f) and is compound, conjunctive or disjunctive, and is therefore burdensome and oppressive.
REQUEST
FOR PRODUCTION NO. 31:
10
rin i ayes ny cl ending yr |
11
12
13
14 Dated: October 4, 2022
15
SMITH DOLLAR PC
16
17
18 Diane Aqui
Attorneys for SPURGEON PAINTING, INC.
19 THOMAS BOYD MEACHAM III, and TIA
BUCKALEW
20
21
22
23
24
25
26
27
> atl 28
1273543 -10-
THOMAS BOYD MEACHAM III'S RESPONSES TO MAYA CASTRO’S REQUEST FOR PRODUCTION OF
DOCUMENTS, SET ONE
Documents for Request for Production Responses 1-31
new word template
Maya
Tija Buckalew
Mon 2/22/2021 10:54 AM
To: Boyd Meacham
We need to change Maya's pay this week
Start date 1/18/21.
Has been paid $4,800 so far.
Not sure how you wanted to figure her annual salary since she will be with us SO weeks not 53 (this year).
Tija Buckalew
707-763-7185/707-228-8910
M-Th 7:30-4:30
~
“Serving
the North Bay since 1976"
Spur 000012
Re: last check
Peggy Fischer
Thu 4/8/2021 10:30 AM
To: Tija Buckalew
Hi Tija,
Ihave enclosed a check stub for your review and approval
for Maya's final manual check
Please let me know if this is correct
Thank you
Peggy Fischer
Payroll and New Accounts Specialist
peggyf@payrollmasters.com
707-307-6118
707-226-1412 FAX
From: Tija Buckalew
Sent: Thursday, April 8, 2021 8:38 AM
To: Peggy Fischer
Subject: Re: last check
t forgot she needs also needs to be paid $118,50 for accrued vacation. We don’t normally have that so
if you need you can list that as misc wages.
Please let me know you received this.
Best,
Tija
Tija Buckalew
Spurgeon Painting, Inc
707-763-7185
707-228-8910
a
From: Tija Buckalew
Sent: Thursday, April 8, 2021 8:14:35 AM
To: Peggy Fischer
Subject: last check
Good momning Peggy,
Spur 000013
I need to get a last check prepared. Usually, when this happens Gloriebeth gives me the net ammount and sends
me a stub, | write the check myself and we add it to next weeks payroll. Does that work for you?
4355 Maya Castro
$1119.29
I will need you to reimburse her $23.67 for medical deductions.
We dig this on our 4/2 payroll with employee EE if you need to look back and review haw
Gloriebeth handled it,
am leaving the office shortly, If you need to reach me please call my cell and not the office. 707-228-8910. |will
have email access and can respond,
Thank you,
Tija Buckalew
707-763-7185/707-228-8910
M-Th 7:30-4:30
a os
“Serving
the North Bay since 1976”
Spur 000014
Re: last check
Peggy Fischer
The 4/8/2021 12:24 PM
To: Tija Buckalew
Hi Tija,
You approved the manual check that you will be writing on your end
and we will process with the next payroll , if you have everything you need
| think we are all good here too,
Thank you
Have a great day!
Peggy Fischer
Payroll and New Accounts Specialist
peggyf@payrollmasters.com
707-307-6118
707-226-1412 FAX
From: Tija Buckalew
Sent: Thursday, April 8, 2021 12:20 PM
To: Peggy Fischer
Subject: RE: last check
All looks good. Sorry | wasn’t in the office and when I called you didn’t answer. Do you still need to talk to me?
Thanks,
Tija Buckalew
707-763-7185/707-228-8910
M-Th 7:30-4:30
=} Pry LA
A
Vy
Pe A TG
“Serving the North Bay since 1976"
From: Peggy Fischer
‘Sent: Thursday, April 8, 2021 10:30 AM
To: Tija Buckalew
Subject: Re: last check
Spur 000015,
We did this on our 4/2 payroll with employee (EE if you need to look back and review how
Gloriebeth handled it
lam leaving the office shortly. If you need to reach me please call my cell and not the office, 707-228-8910, | will
have email access and can respond.
Thank you,
Tija Buckalew
707-763-7185/707-228-8910
M-Th 7:30-4:30
a
fa
Le] PT
Pex
N tN Cf
vy
—
=
“Serving the North Bay since 1976"
Spur 000016
Maya Castro termination
Tija Buckalew
Thu 4/2 f2021 11:48 AM
To: Agi Macdonald
Cc: Adan Amaya ;CIO0276@arrowbenefitstechnology.com
Hello Agi,
Thank you for your previous email introducing yourself
Here is a termination | need processed.
Thank you and | look forward to working with you
Tija Spurgeon Buckalew
707-763-7185/707-228-8910
M-Th 7:30-4:30
1
—
fa eS Ba Ld Fz.ra
: Cee
tt
Ly
“Serving the North Bay since 1976"
| i
VAYA
a
a saa
From: Agi Macdonald
Sent: Friday, April 16, 2021 2:52 PM
To: Tija Buckatew
Spur 000017
Ce: Adan Amaya; CID0276@arrowbenefitstechnology.com
Subject: Arrow Benefits Account Management Team
Good afternoon Tija,
2020 was a year of many changes for our world. 2020 was also a year of change for Arrow Benefits. We had
many of the client service managers that we all loved move out of the business to care for children, move out of
state to find more affordability or drop out of insurance all together to be there for their family’s needs.
You and your company are important to us and we want to assure you of the steps that we have taken to give you
the excellent customer service you have always received from Arrow Benefits.
| will be your new Account Manager going forward. I’ve been with Arrow Benefits Groups for 6 years and bring a
wealth of knowledge and expertise! | am determined to meet your service needs and look forward to creating 2
working relationship with you.
‘d like to schedule a meeting to get acquainted and discuss some new service improvements we have launched.
Please let me know what day(s) and time(s} works best for you.
We appreciate working with you and look forward to do so for many years.
a
Sincerely,
Agi Macdonald { Account Manager
1465 N, McDowell Blvd #180 | Petaluma | CA 94954
Direct Line: 207-242-6685 | F: 207-992-3781 | www.arrowbenefitsaroup.com,
Benefits | COBRA | FSA | Dental | Mobile | In The News
Arrow Benefits Group
CA Lic #0M56067 - Privacy
Information
and Disclaimer
hitps://securemail-arrowbenefitseroup.com
[bypass)
Spur 000018
Small Business
#44 KAISER PERMANENTE SUBSCRIBER TERMINATION
AND TRANSFER FORM
Use this form for billed customers to request subseriber/account terminations and/or subscriber/account transfers from
one enrollment unit to another within the same customer ID and region. Do not use this form for new subscriber
enrollments and/or dependent additions or terminations.
COMPANY INFORMATION
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TERMINATION/TRANSFER REQUEST CODES
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plan changes 14 Marita! status change:
2 Subscriber retired 11 Change in geographic
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‘Death of employee's
spouse
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Spur 000019
Re: 3/17/21 Doctor's appointment
Boyd Meacham
Tue 3/16/2021 4:56 PM
Tox Spurgeon Painting
Cc: Tija Buckalew
Hey Maya,
That's fine,
on Qutlook for iOS
From: Maya Castro
Sent: Tuesday, March 16, 2021 3:48:01 PM
To: Boyd Meacham
Ce: Tija Buckalew
Subject: 3/17/21 Doctor's appointment
Hi Boyd,
| have a doctor's appointment at 1:00pm. That was the only time they could get me in this week, if it's
okay with you I'd like to limit the amount of hours I'm off work by coming in at 6:30 tomorrow and then
leaving for my appointment at 12:00. I'll make up the remaining two hours on Thursday/Friday by
coming in again at 6:30 and leaving at 3:30, again if that's okay with you.
Thank you,
Maya Castro
Operations Manager
Office: 707-763-7185/ cell: 707-776-7911
«< ss
“Serving the North Bay since 1976"
Spur 000020
PROOF OF SERVICE
Iam employed in the County of Sonoma, State of California. I am over the age of 18 years
and not a party to the within action. My business address is 418 B Street, Fourth Floor, Santa Rosa,
CA 95401. On October 4, 2022, I served the attached THOMAS BOYD MEACHAM III'S
RESPONSES TO MAYA CASTRO’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET
ONE on the parties to this action by serving:
Maya Castro In Pro Per
777 Silver Spur Rd, Suite 235 Telephone: (424) 392-0002
Rolling Hills Estates, CA 90274 Facsimile:
Email: mayas.castro@yahoo.com
/X/ BY EMAIL OR ELECTRONIC TRANSMISSION: Based on a court order or an agreement
of the parties to accept service by e-mail or electronic transmission, I caused the documents to be
sent to the persons at the e-mail addresses listed above. No electronic message or other indication
that the transmission was unsuccessful was received within a reasonable time after the transmission.
10
I declare under penalty of perjury under the laws of the State of California that the foregoing is true
11 and correct.
12
13
Dated: October 4, 2022
— st healer
Stephanie D. Abbott
14
1273543
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25
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27
a *
a> 28
<— -1-
Proof of Service
Exhibit B
Diane Aqui, SBN 217087
daqui@smithdollar.com
SMITH DOLLAR PC
Attorneys at Law
418 B Street, Fourth Floor
Santa Rosa, California 95401
Telephone: (707) 522-1100
Facsimile: (707) 522-1101
Attorneys for Defendants SPURGEON PAINTING, INC., THOMAS BOYD MEACHAM III, and
TIA BUCKALEW
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONOMA
10 MAYA CASTRO, an individual, CASE NO.: SCV-269513
11 Plaintiff, THOMAS BOYD MEACHAM IIL,'S
V. RESPONSES TO MAYA CASTRO’S
12 REQUEST FOR ADMISSIONS, SET ONE
SPURGEON PAINTING, INC., a California
13 Corporation; THOMAS BOYD MEACHAM [CCP § 2033.210 et seq.]
III, an individual; TIA BUCKALEW, an
14 individual and DOES 1-50, Judge: Hon. Jennifer V. Dollard
15 Defendants. Complaint Filed: October 15, 2021
Trial Date: March 17, 2023
16
PROPOUNDING PARTY: MAYA CASTRO
17
RESPONDING PARTY: THOMAS BOYD MEACHAM III
18
SET NUMBER: ONE
19
TO MAYA CASTRO AND TO [HIS/HER] ATTORNEY OF RECORD:
20
Pursuant to the provisions of section 2033.210 et seg. of the California Code of Civil
21
Procedure, Defendant THOMAS BOYD MEACHAM IIL, (hereinafter “Responding Party”), hereby
22
responds to the Request for Admissions, Set One, propounded by MAYA CASTRO (hereinafter
23
“Propounding Party”), as follows:
24
RESPONSES TO REQUESTS FOR ADMISSION
25
REQUEST FOR ADMISSION NO. 1:
26
Admit that on or about April 19, 2018 through August 2018, PLAINTIFF entered into an
>
“27
EMPLOYMENT CONTRACT with Spurgeon, for EMPLOYMENT to be rendered as a painter.
<$4 28
-1-
THOMAS BOYD MEACHAM IIL'S RESPONSES TO MAYA CASTRO’S REQUEST FOR ADMISSIONS, SET
ONE
RESPONSE TO REQUEST FOR ADMISSION NO. 1:
Admit
REQUEST FOR ADMISSION NO. 2:
Admit that on or about April 19, 2018 through August 2018, PLAINTIFF worked through
the summer and RESIGNED at the end of that summer.
RESPONSE TO REQUEST FOR ADMISSION NO. 2:
Admit
REQUEST FOR ADMISSION NO. 3:
Admit that on or about January
Preview
| DocuSign Envelope ID: B2EC2241-95BB-4836-9B97-AC876D255F5B Maya Castro 777 Silver Spur Road, Suite 235 Rolling Hills Estates, CA 90274 Email: mayas.castro@ yahoo.com Phone: (424) 392-0002 Plaintiff in Pro Per SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SONOMA MAYA CASTRO, an individual, Case No. SCV -269513 Plaintiff, REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF PLAINTIFF’S MOTION 10 vs. FOR SUMMARY JUDGMENT AND/OR ADJUDICATION 11 SPURGEON PAINTING, INC., a Califomia Corporation; THOMAS BOY D MEACHAM 12 IIL, an individual; TIJA BUCKALEW, an Date: individual and DOES 1-50, Time: 13 Dept: 18 Defendants. 14 15 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 16 PLEASE TAKE NOTICE that, pursuant to Rule 323 of the Califormia Rules of Court and 17 Section 452 of the Califomia Evidence Code, and in support of Plaintiff's motion for summary 18 19 judgment and/or adjudication, Plaintiff respectfully requests the court to take judicial notice of the 20 following documents: 21 1. A true and correct copy of the Responses to Request for Production, Set One propounded 22 upon Meacham, attached hereto as Exhibit A. 23 2 A true and correct copy of the Responses to Request forA dmissions, Set One propounded 24 upon Meacham, attached hereto as Exhibit B. 25 A true and correct copy of the October 15, 2021 Plaintiff's Complaint, attached hereto as 26 Exhibit C. 27 28 Request for Judicial Notice | DocuSign Envelope ID: B2EC2241-95BB-4836-9B97-AC876D255F5B A true and correct copy of the Defendantsfiled theirjoint First Amended A nswer, attached hereto as Exhibit D. A tme and correct copy of the Responses to Request for Production, Set Two propounded upon Meacham, attached hereto as Exhibit E. A tme and correct copy of the Responses to Request for Production, Set One propounded upon Buckalew, attached hereto as Exhibit F. A tmueand correct copy of the Responses to Responses to Special Interrogatories, Set One propounded upon Meacham, attached hereto as Exhibit G. 10 This Request is made in support of Plaintiff's concurrently filed Motion for Summary 11 Judgment and/or Adjudication. This Request is based on this Notice, the attached memorandum 12 of points and authorities, all pleadings, records and files in this action, and upon such further 13 evidence and argument as may be presented at any hearing on this matter. 14 15 Respectfully Submitted, 16 17 18 19 DocuSigned by: 20 4/21/2023 Dated ee a Castro ——---5- a Maya Castro, Plaintiff'in Pro Per 21 22 23 24 25 26 27 28 Request for Judicial Notice | DocuSign Envelope ID: B2EC2241-95BB-4836-9B97-AC876D255F5B PROOF OF SERVICE STATE OF CALIFORNIA COUNTY OF SONOMA I am a resident of the state of Califomia and over the age of 18 and not a party to the within action. My business address is: 777 Silver Spur Rd. Suite 235 Rolling Hills Estates CA 90274 4/21/2023 On -a 5 I served the following documents: REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT AND/OR ADJUDICATION 10 I penomaly da rervie documents listed above to the parties or person authorized to receive service of process for the party on (date) —-- a at (time) Jo 11 12 By United States Mail. Iplaced the envelope forcollection and mailing, following our ordinary business practices. 13 I am readily familiar with this business practice forcollecting and processing correspondence for 14 mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service, in a sealed envelope with 15 postage fully prepaid. The envelope or package was placed in the mail at Califomia. 16 17 By Email. I caused the above-transcribed documents to be transmitted by email to 18 daqui@ smithdollar.com. 19 I declare under penalty of perjury under the laws of the state of Califomia that the 20 foregoing is true and correct. 21 22 4/21/2023 Rolling Hills Estates Executed on aaa Califomia. 23 DocuSigned by: 24 Luis Castro (wis Castro 25 Name of Declarant Signature of Declarant 26 27 28 Request for Judicial Notice | DocuSign Envelope ID: B2EC2241-95BB-4836-9B97-AC876D255F5B CASTRO vs. SPURGEON PAINTING, INC., etal. Court Case No.: SCV -269513 MAILING LIST Diane A qui, Esq. SMITH DOLLAR PC 418 B Street, 4th Floor Santa Rosa, CA 95401 daqui@ smithdollar.com ATTORNEY FOR DEFENDANTS SPURGEON PAINTING, INC.; 10 THOMAS BOYD MEACHAM Il; and TIA BUCKALEW. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Request for Judicial Notice Exhibit A Diane Aqui, SBN 217087 daqui@smithdollar.com SMITH DOLLAR PC Attorneys at Law 418 B Street, Fourth Floor Santa Rosa, California 95401 Telephone: (707) 522-1100 Facsimile: (707) 522-1101 Attorneys for Defendants SPURGEON PAINTING, INC., THOMAS BOYD MEACHAM III, and TIA BUCKALEW SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONOMA 10 MAYA CASTRO, an individual, CASE NO.: SCV-269513 11 Plaintiff, THOMAS BOYD MEACHAM IIL,'S V. RESPONSES TO MAYA CASTRO’S 12 REQUEST FOR PRODUCTION OF SPURGEON PAINTING, INC., a California DOCUMENTS, SET ONE 13 Corporation; THOMAS BOYD MEACHAM III, an individual; TIA BUCKALEW, an [CCP § 2031.210 et seq.] 14 individual and DOES 1-50, Judge: Hon. Jennifer V. Dollard 15 Defendants. Complaint Filed: October 15, 2021 16 Trial Date: March 17, 2023 17 18 PROPOUNDING PARTY: MAYA CASTRO 19 RESPONDING PARTY: THOMAS BOYD MEACHAM III 20 SET NUMBER: ONE 21 TO MAYA CASTRO AND TO [HIS/HER] ATTORNEY OF RECORD: 22 Defendant THOMAS BOYD MEACHAM III (hereinafter “Responding Party”), pursuant to 23 the provisions of section 2031.210 et seg. of the California Code of Civil Procedure, hereby 24 responds to the Request for Production of Documents, Set One, propounded by MAYA CASTRO 25 (hereinafter “Propounding Party”) as follows: 26 Mil nm 27 Mil <4 28 1273543 -1- THOMAS BOYD MEACHAM III'S RESPONSES TO MAYA CASTRO’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE RESPONSES TO REQUESTS FOR PRODUCTION REQUEST FOR PRODUCTION NO. 1: ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 2. RESPONSE TO REQUEST FOR PRODUCTION NO. 1: In addition to documents previously produced (employee file, payroll records, January 15, 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding party will produce. REQUEST FOR PRODUCTION NO. 2: ALL COMMUNICATIONS IDENTIFIED in YOUR response to Special Interrogatory No. 10 4 11 RESPONSE TO REQUEST FOR PRODUCTION NO. 2: 12 In addition to documents previously produced (employee file, payroll records, January 15, 13 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding 14 party will produce. 15 REQUEST FOR PRODUCTION NO. 3: 16 ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 6. 17 RESPONSE TO REQUEST FOR PRODUCTION NO. 3: 18 In addition to documents previously produced (employee file, payroll records, January 15, 19 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding 20 party will produce. 21 REQUEST FOR PRODUCTION NO. 4: 22 ALL COMMUNICATIONS IDENTIFIED in YOUR response to Special Interrogatory 23 No. 8. 24 RESPONSE TO REQUEST FOR PRODUCTION NO. 4: 25 In addition to documents previously produced (employee file, payroll records, January 15, 26 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding ~ 27 party will produce. 28 1273543 -2- THOMAS BOYD MEACHAM III'S RESPONSES TO MAYA CASTRO’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE REQUEST FOR PRODUCTION NO. 5: ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 10. RESPONSE TO REQUEST FOR PRODUCTION NO. 5: In addition to documents previously produced (employee file, payroll records, January 15, 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding party will produce. REQUEST FOR PRODUCTION NO. 6: ALL COMMUNICATIONS IDENTIFIED in YOUR response to Special Interrogatory No. 12. 10 RESPONSE TO REQUEST FOR PRODUCTION NO. 6: 11 In addition to documents previously produced (employee file, payroll records, January 15, 12 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding 13 party will produce. 14 REQUEST FOR PRODUCTION NO. 7: 15 ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 14. 16 RESPONSE TO REQUEST FOR PRODUCTION NO. 7: 17 In addition to documents previously produced (employee file, payroll records, January 15, 18 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding 19 party will produce. 20 REQUEST FOR PRODUCTION NO. 8: 21 ALL COMMUNICATIONS IDENTIFIED in YOUR response to Special Interrogatory 22 No. 16. 23 RESPONSE TO REQUEST FOR PRODUCTION NO. 8: 24 In addition to documents previously produced (employee file, payroll records, January 15, 25 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding 26 party will produce. ~ 27 Mil 28 1273543 -3- THOMAS BOYD MEACHAM III'S RESPONSES TO MAYA CASTRO’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE REQUEST FOR PRODUCTION NO. 9: ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 18. RESPONSE TO REQUEST FOR PRODUCTION NO. 9: In addition to documents previously produced (employee file, payroll records, January 15, 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding party will produce. REQUEST FOR PRODUCTION NO. 10: ALL COMMUNICATIONS IDENTIFIED in YOUR response to Special Interrogatory No. 20. 10 RESPONSE TO REQUEST FOR PRODUCTION NO. 10: 11 In addition to documents previously produced (employee file, payroll records, January 15, 12 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding 13 party will produce. 14 REQUEST FOR PRODUCTION NO. 11: 15 ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 22. 16 RESPONSE TO REQUEST FOR PRODUCTION NO. 11: 17 In addition to documents previously produced (employee file, payroll records, January 15, 18 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding 19 party will produce. 20 REQUEST FOR PRODUCTION NO. 12: 21 ALL COMMUNICATIONS IDENTIFIED in YOUR response to Special Interrogatory 22 No. 24. 23 RESPONSE TO REQUEST FOR PRODUCTION NO. 12: 24 In addition to documents previously produced (employee file, payroll records, January 15, 25 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding 26 party will produce. ~ 27 Mil 28 1273543 -4- THOMAS BOYD MEACHAM III'S RESPONSES TO MAYA CASTRO’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE REQUEST FOR PRODUCTION NO. 13: ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 26. RESPONSE TO REQUEST FOR PRODUCTION NO. 13: In addition to documents previously produced (employee file, payroll records, January 15, 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding party will produce. REQUEST FOR PRODUCTION NO. 14: ALL COMMUNICATIONS IDENTIFIED in YOUR response to Special Interrogatory No. 28. 10 RESPONSE TO REQUEST FOR PRODUCTION NO. 14: 11 In addition to documents previously produced (employee file, payroll records, January 15, 12 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding 13 party will produce. 14 REQUEST FOR PRODUCTION NO. 15: 15 ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 30. 16 RESPONSE TO REQUEST FOR PRODUCTION NO. 15: 17 In addition to documents previously produced (employee file, payroll records, January 15, 18 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding 19 party will produce. 20 REQUEST FOR PRODUCTION NO. 16: 21 ALL COMMUNICATIONS IDENTIFIED in YOUR response to Special Interrogatory 22 No. 32. 23 RESPONSE TO REQUEST FOR PRODUCTION NO. 16: 24 In addition to documents previously produced (employee file, payroll records, January 15, 25 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding 26 party will produce. ~ 27 Mil 28 1273543 -5- THOMAS BOYD MEACHAM III'S RESPONSES TO MAYA CASTRO’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE REQUEST FOR PRODUCTION NO. 17: ALL COMMUNICATIONS IDENTIFIED in YOUR response to Special Interrogatory No. 42. RESPONSE TO REQUEST FOR PRODUCTION NO. 17: In addition to documents previously produced (employee file, payroll records, January 15, 2021 offer letter) and those in possession of Plaintiff (medical records, text messages), Responding party will produce. REQUEST FOR PRODUCTION NO. 18: ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 67. 10 RESPONSE TO REQUEST FOR PRODUCTION NO. 18: 11 Responding party objects to this discovery request on the grounds that it is not reasonably 12 calculated to lead to the discovery of admissible evidence. Responding party further objects as this 13 is improper discovery regarding punitive damages. Responding party objects to this request on the 14 grounds that it constitutes an invasion of third party’s privacy, as guaranteed by the California 15 Constitution, Article I, Section]. Responding party objects to this discovery request on the grounds 16 that it is vague and ambiguous and is therefore also burdensome and oppressive. Responding party 17 further objects as the discovery request is meant only to harass and is an improper use of the 18 discovery statutes. 19 REQUEST FOR PRODUCTION NO. 19: 20 ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 68. 21 RESPONSE TO REQUEST FOR PRODUCTION NO. 19: 22 Responding party objects to this discovery request on the grounds that it is not reasonably 23 calculated to lead to the discovery of admissible evidence. Responding party further objects as this 24 is improper discovery regarding punitive damages. Responding party objects to this request on the 25 grounds that it constitutes an invasion of third party’s privacy, as guaranteed by the California 26 Constitution, Article I, Section]. Responding party objects to this discovery request on the grounds wa 27 that it is vague and ambiguous and is therefore also burdensome and oppressive. Responding party om 28 1273543 -6- THOMAS BOYD MEACHAM III'S RESPONSES TO MAYA CASTRO’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE objects to this discovery request on the grounds that it is violative of CCP §2030.060 (f) and is compound, conjunctive or disjunctive, and is therefore burdensome and oppressive. Responding party further objects as the discovery request is meant only to harass and is an improper use of the discovery statutes. REQUEST FOR PRODUCTION NO. 20: ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 69. RESPONSE TO REQUEST FOR PRODUCTION NO. 20: Responding party objects to this discovery request on the grounds that it is not reasonably calculated to lead to the discovery of admissible evidence. Responding party objects to this request 10 on the grounds that it constitutes an invasion of third party’s privacy, as guaranteed by the 11 California Constitution, Article I, Section]. Responding party objects to this discovery request on 12 the grounds that it is vague and ambiguous and is therefore also burdensome and oppressive. 13 Responding party objects to this discovery request on the grounds that it is over broad and 14 burdensome. Responding party further objects as the discovery request is meant only to harass and 15 is an improper use of the discovery statutes. 16 REQUEST FOR PRODUCTION NO. 21: 17 ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 70. 18 RESPONSE TO REQUEST FOR PRODUCTION NO. 21: 19 Responding party objects to this discovery request on the grounds that it is not reasonably 20 calculated to lead to the discovery of admissible evidence. Responding party objects to this request 21 on the grounds that it constitutes an invasion of third party’s privacy, as guaranteed by the 22 California Constitution, Article I, Section]. Responding party objects to this discovery request on 23 the grounds that it is vague and ambiguous and is therefore also burdensome and oppressive. 24 Responding party objects to this discovery request on the grounds that it is over broad and 25 burdensome. Responding party further objects as the discovery request is meant only to harass and 26 is an improper use of the discovery statutes. wa 27 Mil om 28 1273543 -7- THOMAS BOYD MEACHAM III'S RESPONSES TO MAYA CASTRO’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE REQUEST FOR PRODUCTION NO. 22: ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 72. RESPONSE TO REQUEST FOR PRODUCTION NO. 22: Responding party objects to this discovery request on the grounds that it is vague and ambiguous and is therefore also burdensome and oppressive. Responding party further objects as the discovery request is meant only to harass and is an improper use of the discovery statutes. REQUEST FOR PRODUCTION NO. 23: ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 74. RESPONSE TO REQUEST FOR PRODUCTION NO. 23: 10 Responding party objects to this discovery request on the grounds that it is burdensome and 11 oppressive. Responding party objects to this discovery request on the grounds that it is not 12 reasonably calculated to lead to the discovery of admissible evidence. Responding party objects to 13 this request on the grounds that it constitutes an invasion of third party’s privacy, as guaranteed by 14 the California Constitution, Article I, Section]. Responding party further objects as the discovery 15 request is meant only to harass and is an improper use of the discovery statutes. 16 REQUEST FOR PRODUCTION NO. 24: 17 ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 76. 18 RESPONSE TO REQUEST FOR PRODUCTION NO. 24: 19 Responding party objects to this discovery request on the grounds that it is vague and 20 ambiguous as to “relating to human resources”, and is therefore also burdensome and oppressive. 21 REQUEST FOR PRODUCTION NO. 25: 22 ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 78. 23 RESPONSE TO REQUEST FOR PRODUCTION NO. 25: 24 Responding party objects to this discovery request on the grounds that it is vague and 25 ambiguous, and is therefore also burdensome and oppressive. Responding party objects to this 26 discovery request on the grounds that it is burdensome and oppressive. ~ 27 Mil 28 1273543 -8- THOMAS BOYD MEACHAM III'S RESPONSES TO MAYA CASTRO’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE REQUEST FOR PRODUCTION NO. 26: ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 80 RESPONSE TO REQUEST FOR PRODUCTION NO. 26: Responding party objects to this discovery request on the grounds that it is vague and ambiguous, and is therefore also burdensome and oppressive. Responding party objects to this discovery request on the grounds that it is burdensome and oppressive. REQUEST FOR PRODUCTION NO. 27: ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 82 RESPONSE TO REQUEST FOR PRODUCTION NO. 27: 10 Responding party objects to this discovery request on the grounds that it is vague and 11 ambiguous, and is therefore also burdensome and oppressive. Responding party objects to this 12 discovery request on the grounds that it is burdensome and oppressive. 13 REQUEST FOR PRODUCTION NO. 28: 14 ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 84 15 RESPONSE TO REQUEST FOR PRODUCTION NO. 28: 16 Responding party objects to this discovery request on the grounds that it is vague and 17 ambiguous, and is therefore also burdensome and oppressive. Responding party objects to this 18 discovery request on the grounds that it is burdensome and oppressive. 19 REQUEST FOR PRODUCTION NO. 29: 20 ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 86 21 RESPONSE TO REQUEST FOR PRODUCTION NO. 29: 22 Responding party objects to this discovery request on the grounds that it is vague and 23 ambiguous, and is therefore also burdensome and oppressive. Responding party objects to this 24 discovery request on the grounds that it is overbroad, and burdensome and oppressive. Responding 25 party further objects as the discovery request is meant only to harass and is an improper use of the 26 discovery statutes. Responding party further objects to the extent this discovery request violates ~ 27 Code Civ. Proc., §§ 1985.3, 1985.6. 28 1273543 -9- THOMAS BOYD MEACHAM III'S RESPONSES TO MAYA CASTRO’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE REQUEST FOR PRODUCTION NO. 30: ALL DOCUMENTS IDENTIFIED in YOUR response to Special Interrogatory No. 87. RESPONSE TO REQUEST FOR PRODUCTION NO. 30: Responding party did not identify any documents in his response to Special Interrogatory No. 87, as he objected to that discovery request on the grounds that it is violative of CCP §2030.060 (f) and is compound, conjunctive or disjunctive, and is therefore burdensome and oppressive. REQUEST FOR PRODUCTION NO. 31: 10 rin i ayes ny cl ending yr | 11 12 13 14 Dated: October 4, 2022 15 SMITH DOLLAR PC 16 17 18 Diane Aqui Attorneys for SPURGEON PAINTING, INC. 19 THOMAS BOYD MEACHAM III, and TIA BUCKALEW 20 21 22 23 24 25 26 27 > atl 28 1273543 -10- THOMAS BOYD MEACHAM III'S RESPONSES TO MAYA CASTRO’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE Documents for Request for Production Responses 1-31 new word template Maya Tija Buckalew Mon 2/22/2021 10:54 AM To: Boyd Meacham We need to change Maya's pay this week Start date 1/18/21. Has been paid $4,800 so far. Not sure how you wanted to figure her annual salary since she will be with us SO weeks not 53 (this year). Tija Buckalew 707-763-7185/707-228-8910 M-Th 7:30-4:30 ~ “Serving the North Bay since 1976" Spur 000012 Re: last check Peggy Fischer Thu 4/8/2021 10:30 AM To: Tija Buckalew Hi Tija, Ihave enclosed a check stub for your review and approval for Maya's final manual check Please let me know if this is correct Thank you Peggy Fischer Payroll and New Accounts Specialist peggyf@payrollmasters.com 707-307-6118 707-226-1412 FAX From: Tija Buckalew Sent: Thursday, April 8, 2021 8:38 AM To: Peggy Fischer Subject: Re: last check t forgot she needs also needs to be paid $118,50 for accrued vacation. We don’t normally have that so if you need you can list that as misc wages. Please let me know you received this. Best, Tija Tija Buckalew Spurgeon Painting, Inc 707-763-7185 707-228-8910 a From: Tija Buckalew Sent: Thursday, April 8, 2021 8:14:35 AM To: Peggy Fischer Subject: last check Good momning Peggy, Spur 000013 I need to get a last check prepared. Usually, when this happens Gloriebeth gives me the net ammount and sends me a stub, | write the check myself and we add it to next weeks payroll. Does that work for you? 4355 Maya Castro $1119.29 I will need you to reimburse her $23.67 for medical deductions. We dig this on our 4/2 payroll with employee EE if you need to look back and review haw Gloriebeth handled it, am leaving the office shortly, If you need to reach me please call my cell and not the office. 707-228-8910. |will have email access and can respond, Thank you, Tija Buckalew 707-763-7185/707-228-8910 M-Th 7:30-4:30 a os “Serving the North Bay since 1976” Spur 000014 Re: last check Peggy Fischer The 4/8/2021 12:24 PM To: Tija Buckalew Hi Tija, You approved the manual check that you will be writing on your end and we will process with the next payroll , if you have everything you need | think we are all good here too, Thank you Have a great day! Peggy Fischer Payroll and New Accounts Specialist peggyf@payrollmasters.com 707-307-6118 707-226-1412 FAX From: Tija Buckalew Sent: Thursday, April 8, 2021 12:20 PM To: Peggy Fischer Subject: RE: last check All looks good. Sorry | wasn’t in the office and when I called you didn’t answer. Do you still need to talk to me? Thanks, Tija Buckalew 707-763-7185/707-228-8910 M-Th 7:30-4:30 =} Pry LA A Vy Pe A TG “Serving the North Bay since 1976" From: Peggy Fischer ‘Sent: Thursday, April 8, 2021 10:30 AM To: Tija Buckalew Subject: Re: last check Spur 000015, We did this on our 4/2 payroll with employee (EE if you need to look back and review how Gloriebeth handled it lam leaving the office shortly. If you need to reach me please call my cell and not the office, 707-228-8910, | will have email access and can respond. Thank you, Tija Buckalew 707-763-7185/707-228-8910 M-Th 7:30-4:30 a fa Le] PT Pex N tN Cf vy — = “Serving the North Bay since 1976" Spur 000016 Maya Castro termination Tija Buckalew Thu 4/2 f2021 11:48 AM To: Agi Macdonald Cc: Adan Amaya ;CIO0276@arrowbenefitstechnology.com Hello Agi, Thank you for your previous email introducing yourself Here is a termination | need processed. Thank you and | look forward to working with you Tija Spurgeon Buckalew 707-763-7185/707-228-8910 M-Th 7:30-4:30 1 — fa eS Ba Ld Fz.ra : Cee tt Ly “Serving the North Bay since 1976" | i VAYA a a saa From: Agi Macdonald Sent: Friday, April 16, 2021 2:52 PM To: Tija Buckatew Spur 000017 Ce: Adan Amaya; CID0276@arrowbenefitstechnology.com Subject: Arrow Benefits Account Management Team Good afternoon Tija, 2020 was a year of many changes for our world. 2020 was also a year of change for Arrow Benefits. We had many of the client service managers that we all loved move out of the business to care for children, move out of state to find more affordability or drop out of insurance all together to be there for their family’s needs. You and your company are important to us and we want to assure you of the steps that we have taken to give you the excellent customer service you have always received from Arrow Benefits. | will be your new Account Manager going forward. I’ve been with Arrow Benefits Groups for 6 years and bring a wealth of knowledge and expertise! | am determined to meet your service needs and look forward to creating 2 working relationship with you. ‘d like to schedule a meeting to get acquainted and discuss some new service improvements we have launched. Please let me know what day(s) and time(s} works best for you. We appreciate working with you and look forward to do so for many years. a Sincerely, Agi Macdonald { Account Manager 1465 N, McDowell Blvd #180 | Petaluma | CA 94954 Direct Line: 207-242-6685 | F: 207-992-3781 | www.arrowbenefitsaroup.com, Benefits | COBRA | FSA | Dental | Mobile | In The News Arrow Benefits Group CA Lic #0M56067 - Privacy Information and Disclaimer hitps://securemail-arrowbenefitseroup.com [bypass) Spur 000018 Small Business #44 KAISER PERMANENTE SUBSCRIBER TERMINATION AND TRANSFER FORM Use this form for billed customers to request subseriber/account terminations and/or subscriber/account transfers from one enrollment unit to another within the same customer ID and region. Do not use this form for new subscriber enrollments and/or dependent additions or terminations. COMPANY INFORMATION Company name (Custoner D/frroiment unt ‘Spurgeon Painting, inc. 63659— Giting comact name (oiegse pring Telaghone surter Tha Buckalew (_r07 763 ~ 7185 Enea ‘Fax tumber tispurgecapainting com TE RMINATION OR TRANSFER REQUESTS [referto the rules oo ‘Subserber rane ‘Subscriber medical Subsctiper Social Toemination Terminationer | Indicate new record punter Security rursber ansfer etiective ‘ranster reason | enroiimentunit date (tee page2, cote faeiect =| pequired for wransters “7 fom sable Mays Castro Osat/2021 TERMINATION/TRANSFER REQUEST CODES Termination reason codes ‘Transfer reason codes {reler to page 2 for adcitional information) 1 Emphoyment terminsted 10 Open exroliment plan changes 14 Marita! status change: 2 Subscriber retired 11 Change in geographic service sea” + Marege ‘Death of employee's spouse 3 Leave of absence ‘12 Loss of coverage. + Divorce or ancutment 4 Lap + Spouse or dependent loss of coverage + Legal separation + Reaching Iitetime maximum 5 Mibtary duty 15 Dependent status change-t 13 Employment status change: + Beth 6 Subscriber deceased + Start or termination of employment of the + Adoption or placement for adoption 7 Enrolled in eeror omployte’s spouse + Death of dependent cid ‘Startof, oF return from, foave of absence + Newty eligible dependents cue to employer 8 Loss of disabled status ‘Change from salaried to hourly or vice versa change in eligibility rules 9 Sutscrber requested Chang? from part time to ful time or Dependext loss of eligibility cue to age, vice versa student Stans. OF mations + Employee retirement * StrikeoF lockout * Signiicant change in health coverageof the employes or spouse attritutable to the ‘spouse's employment “Fox arabes react code 11, sabes & completed Group Emolment/Crange Form by the subacsbe proviing the new access. For treaty reason codes 14 or 15, sabia a competed Gap Enoimers range sagas by the wtaciber I adding oF removing a dependents! tus Fe s.tscrte accom Raster o page 2 ter actions ielaematon Sut 40524916 Jamaary 2087 Page tof? Spur 000019 Re: 3/17/21 Doctor's appointment Boyd Meacham Tue 3/16/2021 4:56 PM Tox Spurgeon Painting Cc: Tija Buckalew Hey Maya, That's fine, on Qutlook for iOS From: Maya Castro Sent: Tuesday, March 16, 2021 3:48:01 PM To: Boyd Meacham Ce: Tija Buckalew Subject: 3/17/21 Doctor's appointment Hi Boyd, | have a doctor's appointment at 1:00pm. That was the only time they could get me in this week, if it's okay with you I'd like to limit the amount of hours I'm off work by coming in at 6:30 tomorrow and then leaving for my appointment at 12:00. I'll make up the remaining two hours on Thursday/Friday by coming in again at 6:30 and leaving at 3:30, again if that's okay with you. Thank you, Maya Castro Operations Manager Office: 707-763-7185/ cell: 707-776-7911 «< ss “Serving the North Bay since 1976" Spur 000020 PROOF OF SERVICE Iam employed in the County of Sonoma, State of California. I am over the age of 18 years and not a party to the within action. My business address is 418 B Street, Fourth Floor, Santa Rosa, CA 95401. On October 4, 2022, I served the attached THOMAS BOYD MEACHAM III'S RESPONSES TO MAYA CASTRO’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE on the parties to this action by serving: Maya Castro In Pro Per 777 Silver Spur Rd, Suite 235 Telephone: (424) 392-0002 Rolling Hills Estates, CA 90274 Facsimile: Email: mayas.castro@yahoo.com /X/ BY EMAIL OR ELECTRONIC TRANSMISSION: Based on a court order or an agreement of the parties to accept service by e-mail or electronic transmission, I caused the documents to be sent to the persons at the e-mail addresses listed above. No electronic message or other indication that the transmission was unsuccessful was received within a reasonable time after the transmission. 10 I declare under penalty of perjury under the laws of the State of California that the foregoing is true 11 and correct. 12 13 Dated: October 4, 2022 — st healer Stephanie D. Abbott 14 1273543 15 16 17 18 19 20 21 22 23 24 25 26 27 a * a> 28 <— -1- Proof of Service Exhibit B Diane Aqui, SBN 217087 daqui@smithdollar.com SMITH DOLLAR PC Attorneys at Law 418 B Street, Fourth Floor Santa Rosa, California 95401 Telephone: (707) 522-1100 Facsimile: (707) 522-1101 Attorneys for Defendants SPURGEON PAINTING, INC., THOMAS BOYD MEACHAM III, and TIA BUCKALEW SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONOMA 10 MAYA CASTRO, an individual, CASE NO.: SCV-269513 11 Plaintiff, THOMAS BOYD MEACHAM IIL,'S V. RESPONSES TO MAYA CASTRO’S 12 REQUEST FOR ADMISSIONS, SET ONE SPURGEON PAINTING, INC., a California 13 Corporation; THOMAS BOYD MEACHAM [CCP § 2033.210 et seq.] III, an individual; TIA BUCKALEW, an 14 individual and DOES 1-50, Judge: Hon. Jennifer V. Dollard 15 Defendants. Complaint Filed: October 15, 2021 Trial Date: March 17, 2023 16 PROPOUNDING PARTY: MAYA CASTRO 17 RESPONDING PARTY: THOMAS BOYD MEACHAM III 18 SET NUMBER: ONE 19 TO MAYA CASTRO AND TO [HIS/HER] ATTORNEY OF RECORD: 20 Pursuant to the provisions of section 2033.210 et seg. of the California Code of Civil 21 Procedure, Defendant THOMAS BOYD MEACHAM IIL, (hereinafter “Responding Party”), hereby 22 responds to the Request for Admissions, Set One, propounded by MAYA CASTRO (hereinafter 23 “Propounding Party”), as follows: 24 RESPONSES TO REQUESTS FOR ADMISSION 25 REQUEST FOR ADMISSION NO. 1: 26 Admit that on or about April 19, 2018 through August 2018, PLAINTIFF entered into an > “27 EMPLOYMENT CONTRACT with Spurgeon, for EMPLOYMENT to be rendered as a painter. <$4 28 -1- THOMAS BOYD MEACHAM IIL'S RESPONSES TO MAYA CASTRO’S REQUEST FOR ADMISSIONS, SET ONE RESPONSE TO REQUEST FOR ADMISSION NO. 1: Admit REQUEST FOR ADMISSION NO. 2: Admit that on or about April 19, 2018 through August 2018, PLAINTIFF worked through the summer and RESIGNED at the end of that summer. RESPONSE TO REQUEST FOR ADMISSION NO. 2: Admit REQUEST FOR ADMISSION NO. 3: Admit that on or about January