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1 LAW OFFICES OF SEQUOIA EVLESHIN
SEQUOIA EVLESHIN, Cal. Bar No. 342884
2 135 Whalebone Gulch Road,
3 Boulder Creek, CA 95006
(831) 600-6349
4 Email: evleshinlaw@gmail.com
5 Plaintiffs, SEQUOIA EVLESIN and NICOLE EVLESHIN,
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8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF SANTA CRUZ, SANTA CRUZ COURTHOUSE
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11 SEQUOIA EVLESHIN; NICOLE Case No. 21CV01686
EVLESHIN;
12 PLAINTIFF’S SPECIAL
13 INTERROGATORIES TO STEPHEN
Plaintiffs, MEYER, SET ONE
vs.
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STEPHEN MEYER; KARIN MEYER;
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and DOES 1 through 25, inclusive,
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Defendants,
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20 PROPOUNDING PARTY: SEQUOIA EVLESHIN
21 RESPONDING PARTY: STEPHEN MEYER
22 SET NO.: ONE
23 DISCOVERY: SPECIAL INTERROGATORIES
24 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
25 Pursuant to California Code of Civil Procedure section 2033.010 et seq., Sequoia
26 Evleshin (“Propounding Party”) hereby serves his first set of Special Interrogatories on
27 Stephen Meyer (“Responding Party”). Propounding Party requests that Responding Party
28 respond to the following Special Interrogatories under oath and with such information that
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PLAINTIFF’S SPECIAL INTERROGATORIES TO STEPHEN MEYER, SET ONE
1 is known or available to him within thirty (30) days from the date of service of these
2 Special Interrogatories.
3 DEFINITIONS
4 The following definitions apply to, are incorporated into, and are intended to define
5 the identified terms contained in the Special Interrogatories listed below:
6 1. The term “DESCRIBE IN DETAIL” means the following: (a) with respect to an
7 event, state whether an event occurred, the date of the event, the exact location, the identity
8 of participants, the subject matter, and what transpired; (b) with respect to a comment,
9 statement, or conversation, IDENTIFY who made the statement, IDENTIFY to YOUR
10 knowledge who witnessed and/or heard the statement, IDENTIFY the participants to the
11 conversation, and IDENTIFY who witnessed the conversation, (c) with respect to reasons
12 for a decision or action, STATE ALL FACTS relied upon in making the decision, and
13 IDENTIFY the individuals who provided those facts.
14 2. The term “IDENTIFY” means the following: (a) with respect to a natural person or
15 entity, provide the name, present or last known mailing address, street address, email
16 address, telephone number, and facsimile number of the individual; (b) with respect to an
17 event, state the date, location, subject matter of the event, and IDENTIFY the participants
18 in the event; and (c) with respect to a DOCUMENT, describe with such particularity as
19 would be sufficient for a document demand or a subpoena duces tecum which includes,
20 without limitation, the name(s) of the author or creator and the addressee(s), the subject
21 matter or title, the date of the DOCUMENT, and its present location and custodian; and (d)
22 when used in regard to alleged damages, shall mean to list the amount of any payment, the
23 address and telephone number of any PERSON to whom payments were made, the date
24 any payments became due, and the date any payments were made.
25 3. The term “STATE ALL FACTS” is used in its broadest sense and requests that the
26 response DESCRIBE IN DETAIL, without limitation, all circumstances, events, and
27 evidence pertaining to, relating to, alluding to, responding to, supporting, proving,
28 disproving, concerning, connected with, commenting on, in respect of, about, regarding,
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PLAINTIFF’S SPECIAL INTERROGATORIES TO STEPHEN MEYER, SET ONE
1 discussing, showing, describing, reflecting, analyzing, constituting, modifying,
2 mentioning, embodying, or touching upon the information in question.
3 4. The terms “YOU” or “YOUR” mean Stephen Meyer and shall include any
4 employees, independent contractors, brokers, partners, agents, affiliates, representatives,
5 and/or any other PERSONS and/or entities acting on his behalf.
6 5. The terms “PERSON” or “PERSONS” mean any natural person, corporation,
7 association, partnership, firm, enterprise, governmental body, or other agency or body, as
8 well as any other entity, however formed.
9 6. The term “SUBJECT PROPERTY” shall mean the real property and dwelling
10 located at 135 Whalebone Gulch Road, in Boulder Creek, California.
11 7. The term “WHALEBONE TREE THINNING ASSOCIATION” hereinafter
12 referred to as “WHATT”, shall mean that association of people which was created for the
13 purpose of harvesting lumber.
14 8. The term, “FOREST MANAGEMENT AGREEMENT” shall mean that document
15 which was signed by the members WHATT.
16 9. The term “AGREEMENT” shall mean that document which was executed by
17 Plaintiffs and defendants dated 7/18/19 for the sale of the SUBJECT PROPERTY.
18 10. The term “SELLER’S QUESTIONNAIRE” shall mean that document which was
19 transmitted to the Plaintiffs 8/2/19.
20 11. The term “ADDENDUM A” shall mean that document which was transmitted to
21 the Plaintiffs 8/2/19 by YOU.
22 12. The term “PRELIMINARY TITLE REPORT” shall mean that document which was
23 transmitted to the Plaintiffs 8/2/19 by YOU.
24 13. The term “TRANSFER DISCLOSURE STATEMENT” shall mean that document
25 which was transmitted to the Plaintiffs 8/2/19 by YOU.
26 14. The term “ST. CLAIRES ROAD” refers to that road which leads from Whalebone
27 Gulch Road through the SUBJECT PROPERTY.
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PLAINTIFF’S SPECIAL INTERROGATORIES TO STEPHEN MEYER, SET ONE
1 15. The term “LUMBER HARVESTING PLAN” refers to the manner and methods
2 lumber would be harvested.
3 16. The term “UP COMING LOGGING ROYALTY PLAN” refers to that phrase used
4 by YOU in the AGREEMENT and ADDENDUM A.
5 17. The terms “DOCUMENT” or “DOCUMENTS” mean any handwriting,
6 typewriting, printing, photographing, photocopying, transmitting by electronic mail or
7 facsimile, and every other method of recording information upon any tangible thing, any
8 form of COMMUNICATION or representation, including, without limitation, letters,
9 words, pictures, sounds, symbols, or combinations thereof, and any record thereby created
10 or data compilation from which information can be obtained through a detection device
11 into usable form, regardless of the manner in which the record has been stored. The terms
12 “DOCUMENT” or “DOCUMENTS” shall include, without limitation, both tangible
13 documents (such as letters, memoranda, reports, studies, notes, minutes, diary entries,
14 including calendar entries indicating date of and participants to any meetings, notes or
15 records of telephone conversations, conferences or other oral COMMUNICATIONS and
16 appointment records, time records, ledgers, journals, financial or accounting records,
17 personnel records, payroll records, annual reports, work papers, schedules, photographs,
18 recordings, charts, graphs, transcriptions, tapes, and discs) as well as electronic data
19 residing upon computers, hand-held devices, servers, cloud-based services, and all forms
20 of data retention mechanisms within the possession, custody, or control of Responding
21 Party (such as electronic mail (email) messages, text messages, MMS messages, electronic
22 message attachments, telegrams, electronic documents, instant messages, website postings,
23 back-up data, iMessages, social media postings, electronic data processing materials), and
24 shall include any other “writing” as defined by Evidence Code section 250. The terms
25 “DOCUMENT” or “DOCUMENTS” shall also include, without limitation, each copy or
26 version of a DOCUMENT that is not identical in all respects with or that contains any
27 notation not appearing on said DOCUMENT, including, without limitation, drafts prepared
28 in connection with any such DOCUMENTS, whether used or not.
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PLAINTIFF’S SPECIAL INTERROGATORIES TO STEPHEN MEYER, SET ONE
1 SPECIAL INTERROGATORIES
2 SPECIAL INTERROGATORY NO. 1:
3 STATE ALL FACTS relating to Addendum A.
4 SPECIAL INTERROGATORY NO. 2:
5 STATE ALL FACTS as to why the decision was made to transmit Addendum A on
6 7/18/19 and then again on 8/2/19.
7 SPECIAL INTERROGATORY NO. 3:
8 State all dates for which Charles Harmon was employed by YOU as a real estate agent.
9 SPECIAL INTERROGATORY NO. 4:
10 STATE ALL FACTS relating to the document recorded in Book 4715, Page 405, Official
11 Records of Santa Cruz County for the SUBJECT PROPERTY.
12 SPECIAL INTERROGATORY NO. 5:
13 STATE ALL FACTS relating to the document recorded in Book 4715, Page 407, Official
14 Records of Santa Cruz County for the SUBJECT PROPERTY.
15 SPECIAL INTERROGATORY NO. 6:
16 STATE ALL FACTS relating to the document recorded in Book 2003, Page 16, Official
17 Records of Santa Cruz County for the SUBJECT PROPERTY.
18 SPECIAL INTERROGATORY NO. 7:
19 STATE ALL FACTS relating to the meeting on 5/4/19 with Joseph Mosko and other
20 potential members of WHATT.
21 SPECIAL INTERROGATORY NO. 8:
22 IDENTIFY ALL DOCUMENTS relating to the UP COMING LOGGING ROYALTY
23 PLAN on 8/3/19.
24 SPECIAL INTERROGATORY NO. 9:
25 STATE ALL FACTS as to why the decision was made to not transmit the documents in
26 your possession on 8/3/19 which related to the UP COMING LOGGING ROYALTY
27 PLAN.
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PLAINTIFF’S SPECIAL INTERROGATORIES TO STEPHEN MEYER, SET ONE
1 SPECIAL INTERROGATORY NO. 10:
2 STATE ALL FACTS relating to YOUR response to question Section V, Subsection A,
3 question # 9 of the SELLER’S QUESTIONNAIRE.
4 SPECIAL INTERROGATORY NO. 11:
5 STATE ALL FACTS relating to YOUR response to question V, Subsection F, question #
6 3 of the SELLER’S QUESTIONNAIRE.
7 SPECIAL INTERROGATORY NO. 12:
8 STATE ALL FACTS relating to YOUR response to question V, Subsection G, of the
9 SELLER’S QUESTIONNAIRE.
10 SPECIAL INTERROGATORY NO. 13:
11 STATE ALL FACTS relating to YOUR response to question V, Subsection M, of the
12 SELLER’S QUESTIONNAIRE.
13 SPECIAL INTERROGATORY NO. 14:
14 STATE ALL FACTS relating to the FOREST MANAGEMENT AGREEMENT.
15 SPECIAL INTERROGATORY NO. 15:
16 STATE ALL FACTS relating to any repairs of the upstairs plumbing or sink of the
17 SUBJECT PROPERTY.
18 SPECIAL INTERROGATORY NO. 16:
19 STATE ALL FACTS relating to the UP COMING LOGGING ROYALTY PLAN.
20 SPECIAL INTERROGATORY NO. 17:
21 IDENTIFY ALL DOCUMENTS relating to the UP COMING LOGGING ROYALTY
22 PLAN.
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PLAINTIFF’S SPECIAL INTERROGATORIES TO STEPHEN MEYER, SET ONE
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2 Dated: //2022
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4 LAW OFFICES OF SEQUOIA EVLESHIN
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PLAINTIFF’S SPECIAL INTERROGATORIES TO STEPHEN MEYER, SET ONE
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1 LAW OFFICES OF SEQUOIA EVLESHIN SEQUOIA EVLESHIN, Cal. Bar No. 342884 2 135 Whalebone Gulch Road, 3 Boulder Creek, CA 95006 (831) 600-6349 4 Email: evleshinlaw@gmail.com 5 Plaintiffs, SEQUOIA EVLESIN and NICOLE EVLESHIN, 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF SANTA CRUZ, SANTA CRUZ COURTHOUSE 10 11 SEQUOIA EVLESHIN; NICOLE Case No. 21CV01686 EVLESHIN; 12 PLAINTIFF’S SPECIAL 13 INTERROGATORIES TO STEPHEN Plaintiffs, MEYER, SET ONE vs. 14 15 STEPHEN MEYER; KARIN MEYER; 16 and DOES 1 through 25, inclusive, 17 Defendants, 18 19 20 PROPOUNDING PARTY: SEQUOIA EVLESHIN 21 RESPONDING PARTY: STEPHEN MEYER 22 SET NO.: ONE 23 DISCOVERY: SPECIAL INTERROGATORIES 24 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 25 Pursuant to California Code of Civil Procedure section 2033.010 et seq., Sequoia 26 Evleshin (“Propounding Party”) hereby serves his first set of Special Interrogatories on 27 Stephen Meyer (“Responding Party”). Propounding Party requests that Responding Party 28 respond to the following Special Interrogatories under oath and with such information that -1- 000671 000001 PLAINTIFF’S SPECIAL INTERROGATORIES TO STEPHEN MEYER, SET ONE 1 is known or available to him within thirty (30) days from the date of service of these 2 Special Interrogatories. 3 DEFINITIONS 4 The following definitions apply to, are incorporated into, and are intended to define 5 the identified terms contained in the Special Interrogatories listed below: 6 1. The term “DESCRIBE IN DETAIL” means the following: (a) with respect to an 7 event, state whether an event occurred, the date of the event, the exact location, the identity 8 of participants, the subject matter, and what transpired; (b) with respect to a comment, 9 statement, or conversation, IDENTIFY who made the statement, IDENTIFY to YOUR 10 knowledge who witnessed and/or heard the statement, IDENTIFY the participants to the 11 conversation, and IDENTIFY who witnessed the conversation, (c) with respect to reasons 12 for a decision or action, STATE ALL FACTS relied upon in making the decision, and 13 IDENTIFY the individuals who provided those facts. 14 2. The term “IDENTIFY” means the following: (a) with respect to a natural person or 15 entity, provide the name, present or last known mailing address, street address, email 16 address, telephone number, and facsimile number of the individual; (b) with respect to an 17 event, state the date, location, subject matter of the event, and IDENTIFY the participants 18 in the event; and (c) with respect to a DOCUMENT, describe with such particularity as 19 would be sufficient for a document demand or a subpoena duces tecum which includes, 20 without limitation, the name(s) of the author or creator and the addressee(s), the subject 21 matter or title, the date of the DOCUMENT, and its present location and custodian; and (d) 22 when used in regard to alleged damages, shall mean to list the amount of any payment, the 23 address and telephone number of any PERSON to whom payments were made, the date 24 any payments became due, and the date any payments were made. 25 3. The term “STATE ALL FACTS” is used in its broadest sense and requests that the 26 response DESCRIBE IN DETAIL, without limitation, all circumstances, events, and 27 evidence pertaining to, relating to, alluding to, responding to, supporting, proving, 28 disproving, concerning, connected with, commenting on, in respect of, about, regarding, -2- 000672 000002 PLAINTIFF’S SPECIAL INTERROGATORIES TO STEPHEN MEYER, SET ONE 1 discussing, showing, describing, reflecting, analyzing, constituting, modifying, 2 mentioning, embodying, or touching upon the information in question. 3 4. The terms “YOU” or “YOUR” mean Stephen Meyer and shall include any 4 employees, independent contractors, brokers, partners, agents, affiliates, representatives, 5 and/or any other PERSONS and/or entities acting on his behalf. 6 5. The terms “PERSON” or “PERSONS” mean any natural person, corporation, 7 association, partnership, firm, enterprise, governmental body, or other agency or body, as 8 well as any other entity, however formed. 9 6. The term “SUBJECT PROPERTY” shall mean the real property and dwelling 10 located at 135 Whalebone Gulch Road, in Boulder Creek, California. 11 7. The term “WHALEBONE TREE THINNING ASSOCIATION” hereinafter 12 referred to as “WHATT”, shall mean that association of people which was created for the 13 purpose of harvesting lumber. 14 8. The term, “FOREST MANAGEMENT AGREEMENT” shall mean that document 15 which was signed by the members WHATT. 16 9. The term “AGREEMENT” shall mean that document which was executed by 17 Plaintiffs and defendants dated 7/18/19 for the sale of the SUBJECT PROPERTY. 18 10. The term “SELLER’S QUESTIONNAIRE” shall mean that document which was 19 transmitted to the Plaintiffs 8/2/19. 20 11. The term “ADDENDUM A” shall mean that document which was transmitted to 21 the Plaintiffs 8/2/19 by YOU. 22 12. The term “PRELIMINARY TITLE REPORT” shall mean that document which was 23 transmitted to the Plaintiffs 8/2/19 by YOU. 24 13. The term “TRANSFER DISCLOSURE STATEMENT” shall mean that document 25 which was transmitted to the Plaintiffs 8/2/19 by YOU. 26 14. The term “ST. CLAIRES ROAD” refers to that road which leads from Whalebone 27 Gulch Road through the SUBJECT PROPERTY. 28 -3- 000673 000003 PLAINTIFF’S SPECIAL INTERROGATORIES TO STEPHEN MEYER, SET ONE 1 15. The term “LUMBER HARVESTING PLAN” refers to the manner and methods 2 lumber would be harvested. 3 16. The term “UP COMING LOGGING ROYALTY PLAN” refers to that phrase used 4 by YOU in the AGREEMENT and ADDENDUM A. 5 17. The terms “DOCUMENT” or “DOCUMENTS” mean any handwriting, 6 typewriting, printing, photographing, photocopying, transmitting by electronic mail or 7 facsimile, and every other method of recording information upon any tangible thing, any 8 form of COMMUNICATION or representation, including, without limitation, letters, 9 words, pictures, sounds, symbols, or combinations thereof, and any record thereby created 10 or data compilation from which information can be obtained through a detection device 11 into usable form, regardless of the manner in which the record has been stored. The terms 12 “DOCUMENT” or “DOCUMENTS” shall include, without limitation, both tangible 13 documents (such as letters, memoranda, reports, studies, notes, minutes, diary entries, 14 including calendar entries indicating date of and participants to any meetings, notes or 15 records of telephone conversations, conferences or other oral COMMUNICATIONS and 16 appointment records, time records, ledgers, journals, financial or accounting records, 17 personnel records, payroll records, annual reports, work papers, schedules, photographs, 18 recordings, charts, graphs, transcriptions, tapes, and discs) as well as electronic data 19 residing upon computers, hand-held devices, servers, cloud-based services, and all forms 20 of data retention mechanisms within the possession, custody, or control of Responding 21 Party (such as electronic mail (email) messages, text messages, MMS messages, electronic 22 message attachments, telegrams, electronic documents, instant messages, website postings, 23 back-up data, iMessages, social media postings, electronic data processing materials), and 24 shall include any other “writing” as defined by Evidence Code section 250. The terms 25 “DOCUMENT” or “DOCUMENTS” shall also include, without limitation, each copy or 26 version of a DOCUMENT that is not identical in all respects with or that contains any 27 notation not appearing on said DOCUMENT, including, without limitation, drafts prepared 28 in connection with any such DOCUMENTS, whether used or not. -4- 000674 000004 PLAINTIFF’S SPECIAL INTERROGATORIES TO STEPHEN MEYER, SET ONE 1 SPECIAL INTERROGATORIES 2 SPECIAL INTERROGATORY NO. 1: 3 STATE ALL FACTS relating to Addendum A. 4 SPECIAL INTERROGATORY NO. 2: 5 STATE ALL FACTS as to why the decision was made to transmit Addendum A on 6 7/18/19 and then again on 8/2/19. 7 SPECIAL INTERROGATORY NO. 3: 8 State all dates for which Charles Harmon was employed by YOU as a real estate agent. 9 SPECIAL INTERROGATORY NO. 4: 10 STATE ALL FACTS relating to the document recorded in Book 4715, Page 405, Official 11 Records of Santa Cruz County for the SUBJECT PROPERTY. 12 SPECIAL INTERROGATORY NO. 5: 13 STATE ALL FACTS relating to the document recorded in Book 4715, Page 407, Official 14 Records of Santa Cruz County for the SUBJECT PROPERTY. 15 SPECIAL INTERROGATORY NO. 6: 16 STATE ALL FACTS relating to the document recorded in Book 2003, Page 16, Official 17 Records of Santa Cruz County for the SUBJECT PROPERTY. 18 SPECIAL INTERROGATORY NO. 7: 19 STATE ALL FACTS relating to the meeting on 5/4/19 with Joseph Mosko and other 20 potential members of WHATT. 21 SPECIAL INTERROGATORY NO. 8: 22 IDENTIFY ALL DOCUMENTS relating to the UP COMING LOGGING ROYALTY 23 PLAN on 8/3/19. 24 SPECIAL INTERROGATORY NO. 9: 25 STATE ALL FACTS as to why the decision was made to not transmit the documents in 26 your possession on 8/3/19 which related to the UP COMING LOGGING ROYALTY 27 PLAN. 28 -5- 000675 000005 PLAINTIFF’S SPECIAL INTERROGATORIES TO STEPHEN MEYER, SET ONE 1 SPECIAL INTERROGATORY NO. 10: 2 STATE ALL FACTS relating to YOUR response to question Section V, Subsection A, 3 question # 9 of the SELLER’S QUESTIONNAIRE. 4 SPECIAL INTERROGATORY NO. 11: 5 STATE ALL FACTS relating to YOUR response to question V, Subsection F, question # 6 3 of the SELLER’S QUESTIONNAIRE. 7 SPECIAL INTERROGATORY NO. 12: 8 STATE ALL FACTS relating to YOUR response to question V, Subsection G, of the 9 SELLER’S QUESTIONNAIRE. 10 SPECIAL INTERROGATORY NO. 13: 11 STATE ALL FACTS relating to YOUR response to question V, Subsection M, of the 12 SELLER’S QUESTIONNAIRE. 13 SPECIAL INTERROGATORY NO. 14: 14 STATE ALL FACTS relating to the FOREST MANAGEMENT AGREEMENT. 15 SPECIAL INTERROGATORY NO. 15: 16 STATE ALL FACTS relating to any repairs of the upstairs plumbing or sink of the 17 SUBJECT PROPERTY. 18 SPECIAL INTERROGATORY NO. 16: 19 STATE ALL FACTS relating to the UP COMING LOGGING ROYALTY PLAN. 20 SPECIAL INTERROGATORY NO. 17: 21 IDENTIFY ALL DOCUMENTS relating to the UP COMING LOGGING ROYALTY 22 PLAN. 23 24 25 26 27 28 -6- 000676 000006 PLAINTIFF’S SPECIAL INTERROGATORIES TO STEPHEN MEYER, SET ONE 1 2 Dated: //2022 3 4 LAW OFFICES OF SEQUOIA EVLESHIN 5 6 7 Sequoia Evleshin, 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -7- 000677 000007 PLAINTIFF’S SPECIAL INTERROGATORIES TO STEPHEN MEYER, SET ONE