Req For Admissions

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Robert J. Fletcher No. 119770
Attorney atLaw
P.O. Box 824
Tulare, CA93274
(559) 684-1795
Attorney for Defendants and
Cross-Complainants
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR TI{E COUNTY OF TULARE
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9
Case
No.: 10-238961
Courfney and Melody Gillespie,
Plaintifls,
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vs.
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Nicklas Hoffrnan; et. al.
iz
Defendants
REQUEST FOR ADMISSION
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And Related Cross-Action
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REQUEST FOR ADMISSION TO:
PLAINTIFF AND CROSS-DEFENDANT,

COURTNEY GILLESPTE
PROPOUNDED BY:
DEFENDANT AND CROSS-COMPLAINANT,

NICKLAS HOFFMAN. INDWIDUALLY
SET NUMBER:
ONE
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2A
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NOTICE
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UNDER THE PROVISIONS OF CALIT'ONNIA CODE OF CTYIL PROCEDURE

$s2033.10 THROUGH2033.420 yOU ARE HEREBY REQUESTED TO ADMrT THE
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TRUTH OF SPECIFIEI} MATTERS OF FACT, OPINION RELATING TO FACT, OR
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-lNicklas Hoffman's Request for Admission Set No. One

Gillespie vs.
Hoffman
Case
No. 10-238e61
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ft=t:
\-:_l \.__*-_
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APPLTCATION OF LAW TO FACT. YOU SHOULD CONSIDAR CAREFULLY YOUR

RESPONSE TO THIS REQUEST FOR ADMISSION. WITH LIMITED EXCEPTIONS,
AN ANSWERING PARTY WILL NOT BE ALLOWED TO CIIANGE AN ANSWER TO
A REQUEST FOR ADMISSION. THERE MAY BE PENALTIES IF YOU FAIL TO
ADMIT THE TRUTH OF AI{Y FACT PURSUANT TO THIS REQUEST AND THE
PROPOUNDING PARTY PROYES THAT THE FACT IS TRUE. THESE PENALTIES
MAY INCLUDE, BUT ARE NOT LIMITEI} TO, PAYMENT OF TI{E PROPOUNDING
PARTY'S ATTORNEY FEES INCURRED IN MAKING THAT PROOF. UNLESS
THERE IS AN AGREEMENT OR A COURT ORI}ER PROVII}ING OTI{ERWISE, YOU
MUST RESPOND IN WRITING, AND UNDER OATI{, TO THIS RAQUEST FOR
ADMISSION WITHIN 30 DAYS. THERE MAY BE SIGNIFICANT PENALTMS IF
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YOU FAIL TO PROVil)n A TIMELY WRITTEN RESPONSE TO EACH REQUEST
11
FOR ADMISSION. THESN PENALTIf,S MAY INCLUDE, BUT ARE NOT LIMITEI)
TO, AN ORDER THAT THE FACTS IN ISSUE ARE DEEMED TRUE FOR PURPOSES
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OF TIIE CASE.
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PLEASE ADMIT THE FOLLOWING:
1.
Please admit
that no integrated land sales contract was ever formed between you
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and any trustee of the H.M. Wysocki Irrevocable Trust.

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Dated: Januar-v 18.
201
By:
Robert J. Fletcher, Attorney for

Defendants and Cross-Complainants
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Nicklas Hoffrnan's Request for Admission Set No. One

Gillespie vs.
Hoffinan
Case
No. 10-238961
ROBERT J. FLETCHER
Attorney at Law
P.O. Box 824
Tulare, Califomia 9327 5
(ssg) 684-r79s
August 24,2012
Courtney Gillespie
Melody Gillespie
P.O. Box 8323
Porterville. CA 93258
Re: Gillespie vs. Hoffrnan and Wysocki Trust vs. Gillespie
Case No. 10-238961
Dear Gillespies:
This letter is a further attempt to meet and confer, as that phrase is used in
c.c.P. $2023.010 (i).

We are in receipt of the courl's order re-opening discovery in advance of the trial
in this matter set for December 17,2012.
This brings us back to the Requests for Admissions and Interrogatories that we
served on you January, 2011, over one year and a halfago. Enclosed for your references
are each ofyour inadequate responses that you each provided to those requests.
Please know that we demand not only priority in discovery at the present time on
the re-opening of discovery, but we also demand wholly adequate and non-evasive
responses now to these previously promulgated discovery requests.
I look forward to your responses to this latest written attempt to'omeet and
confer."
Thank you for your courtesy and attention in this regard.
Robert J. Fletcher
RIF/bf
enclosures
#
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ATTORNEY OR PARTY WITHOUT ATTORNEY {Name, sl6le 84. Dumiet 8nd ddEss):
Robert J. Fletcher No. I 19770

Attorney
at Law
P.O. Box 824
Tulare- CA 9327-{
TETFPHoNE NO.: (559) 684-l?95
FAX NO {Opltbr6t):
E-MA'L ADDRESS {aqlional}:
ATToRNEY FoR
(Naret: Defendants and Cross-Complainants
SUPERIOR COURT OF CALIFORNIA, COUNTY OF
TLTLARE
?31 S. X{ooneyBlvd.
Visalia" CA 93291
SHORT TITLE OF CASE:
Gillesnie vs. l{offman

CASE NUMgER:
FORM INTERROGATORIES*GENERAL
Asking
narg: Nicklas Hoffman. Indii'idualll'
10-238961
Answering Party: Melody Gillespie

Set No.: One
Each answer must be as complete and straightforward
as the information reasonably available to you, including the
information possessed by your attorneys or agents, permits. if
an interrogatory cannot be answered completely, answer it to
the extent possible.
(d) lf you do not have enough personal knowledge to fully
answer an interrogatory, say so, but make a reasonable and
good faith effort to get the information by asking other persons
or organizations, unless the information is equally available to
{c)
Sec. 1. Instructions to All Parties
(a) Interrogatories are written guestions prepared by a party

to an action that are sent to any other party in the action to be
answered under oath. The interrogatories below are form
interrogatories approved for use in civil cases^
(b) For time limitations, requirements for service on other
parties, and other details, see Code of Civil Procedure
sections 2030.01 0-2030.410 and the cases construing those
sections.
(c) These form interrogatories do not change existing law
ralating to interrogatories nor do they alfect an answering
party's right to assert afiy privilege or make any objection.
the asking partY.

(e) Whenever an intenogatory may be answered by
referring to a document, the documentmay be attached as an
exhibitto the response and refened to in the response' lf the
document has more than one page, refer to the page and
section where the answer to the interogatory can be found.
(0 Whenever an address and telephone number for the *
same person are requested in more than one interrogatolT,
you are required to furnish them in ansvrering only the flrst
interrogatory asking for that information.
{g) lf you ire asserting a privilege or making an objection to
an interrogatory, you must specifically assert the privilege or
state the objection in your written response.
{h) Your answsrs to these interrogatories must be verified' '
dated, and signed. You may wish to use the following form at
the end of your answers:
I declare under penalty of periury under the lavts sf"the
State of California that the foregoing answers are true and
See. 2. Instructions to the Asking Party
(a)
These interrogatories are designed for optional use by

parties in untimited civil cases where the amount demanded
exce eds $25,000. Separate i nterrogatories, Form
lnte rrogatories-Limited Ctvil Cases (Economic t-itigatio n)
(form DtSC-004), which have no subparts, are designed for
use in limited civil cases where the amount demanded is
$25,000 or iess, however, those intenogatories may also be
used in unlimited civil cases.
(b) Check the box next to each interrogatory that you want
the answering party to answer. Use care in choosing those
intenogatories that are applicable to the case.
(c) You ryray insert your own definition of INCIDENT in
$ection 4, but only where the action arises from a course of
conduct or a series of events occurring over a period of time.
carrect.
(d)
The interrogatories in section 16.0, Detundant's

Contentions-Personal Injury, should not be used until the
defendant has had a reasonable opportunity to conductan
investigation or discovery of plainiiffs injuries and damages.
(e) Additional interrogatories may be attached.
Sec.
@ArE)
Sec. 4. Definitions
Words in BOLDFACE CAPITALS in these interrogatories
are defined as follows:
3. Instructions to the Answering Party
{a) An answer or other appropriate response must be

given to each interrogatory checked by the asking party.
(a) {Check one of the following):

tt ) INCIDENT includes the circumstances and
events surrounding the alleged eccident, injury, or
other occurrence or breach of contract giving rise to
this action or Proceeding.
l---l
ib) As a general rule, within 30 days after you are served

with these interrogatories, you must serve your responses on
the asking party and serve copies of your responses on all '
other parties to the action who have appeared. See Code of
Qivil Procedure sections 2030.260-2030.270 for details
Fom ApproYed for Optima! Use
ludiciat Csndl sf Califmla
DISC-oO1 lRe. January 1,:0081
FOR M INTERROGATORIES_GENERAL
'
.- '' {_-r r*lt-/
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{SIGruATURE)
,.-
Code of Civil Ptocedure.
ss 2030.01$.?030 410 2033.71C

v&\v coutunb.ca.qav
tl':'!1lt-",t*:tJ
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Dtsc-001
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INCIDENT means (insert your definition here ar

on e separafe, attached sheef /abeled $ec.
a$)Q)):
The formation of an integrated land sales
agreement betn'een answering parfy and
any trustee of the H.M. Wysocki
Irrevocable Trust.
{b} You oR ANyoNE ACTtNe ON YOUR BEHALF
includes you, your agents, your employees, your insurance

companies, their agents, their employees, your attomeys, your
accountanF, your investigators, and anyone else acting on
your behalf.
{c} PERSON inc{udes a natural person, firm, association,

organization, partnership, business, trust, timited liability
company, corporation, or public entity.
(d) DOCUMENT means a writing, as defined in Evidence
Code section ?50, and includes the original or a copy of
ha ndwriting, typewriting, printing, photosta ts, photo gra phs,
electronically stored information, and every other means of
recording upon any t*ngible thing and form of communicating
orrepresentation, including letters, words, pictures, sounds, or
symbols, or combinations of them.
(e) HEALTH CARE PROVIBER includes any
1.0 ldentity of Persons Answerlng These lnterrogatorles
E ft
State the name, ADDRES$, telephone number, and

relationship to you of each PERSON who prepared or
assisted in the preparation of the responses to these
interrogatories. {Do not identify anyone who simply typed or
re pro du ce
2.0 General Background
(a) your name;

(b) every name you have used
V
[l
1.0 ldenti$ of Persons Answering These Interrogatories
(a) the state or other issuing entity:
ib) the license number and type;

{c) the date of issuance; and
[7l
lZ
18.0 fReservedJ
19.0 fReservedJ
20.0 How the Incident Occurred-Motor Vehicle
25.0 fReservedJ
30.0 fReservedJ
40.0 fReservedJ
50.0 Contract
60.0 fReservedJ
70.0 Unlawtul DetainerfSee separafe form DISC-0031
101 .0 Economic Litigation fSee separafe form D|SC-0441
200.0 Emptoyment Law fSee separafe form DlSC402l
Family Law fSee seperafe form FL-l451
:DISC-001 [Rev. January 1. 2008i
z.s
set
years; and
z.e st"t*'
(a) the name, ADDRE$S, and telephone number of your
lZ
z,z st"t*,
(a) the name
and ADDRESS of each school or other

academic or vocational institution you have attended,
beginning with high school:
(b) the dates you attended;
(c) the higheetgrade level you hav completed; and
(d) the degrees received.
@ Z.s
Have you ever been convicted of a felony? lf so, for
each conviction state:

{a) the city and state where you were convicted,
(b) the date of conviction;
(c) the offense; and
(d) the court and case number.
V Z.s Can you speak
English with ease?
lf not,
what
language and dialect do you normally use?
fl
Z.f O Can you read and write English with ease? if not, what
language and dialect do you normally use?
Page 2 of
FORM INTERROGATORIES-GENERAL
qlb
'***
all restrictions.
present employer or place oi self-employment; and

(b) the name, ADDRES$, dates of employment, job title,
and nature of work for each employer or
self-employment you have had from five years before
the lllClDENT until todav. '
5.0 fReservedJ
(d)
{a) your present re$idence ADDRE$$;

{b) your residence ADDRE$SES for the past five
(c) the dates you lived at each ADDRESS.
?.0 General 6ackground information-lndividual

3.0 Genera I Background Information-Business Entity
4.0 lnsurance
6.0 Physical, Mental, or Emotional lnjuries
7.0 Property Damage
8.0 Loss of lncome or Earning Capacity
9.0 Other Damages
10,0 Medical History
11.0 Other Claims and Previous Claims
1 2.0 lnvestigation-Genera I
1 3.0 lnvestigation-Surveilla nce
14.0 Statutory or Regulatory Violations
15.0 Denials and Special orAtfirmative Defenses
'l 6.0 Defenda nt's C ontentions Perso nal njury
17.0 Responses to Request for Admissions
e S Atthe time of the INCIDENT, did you have a driver's

license? lf so state:
(a) the state orother issuing entity;
(b) the license number and type;
(c) the date of issuance; and
(d) all restrictions.
state:
The following interrogatories have been approved by the

Judicial Council under Code of Civil Procedure section 2033.71O:
CONTENTS
Z.Z State the date and place of your birth.
L] z+ Atthetimeofthe|NC|DENT,did you have any other

permit or license for the operation of a moior vehicle? lf so,
(f)
5. Interrogatories
in the past; and
(c) the dates you used each name.
referred to in Code of Civil Procedure section 667.7(eX3).
Sec.
lnformation-individual
|7l z.t st"t*'
PERSON
ADDRESS means the street address, including the city.

state, anC rip code.
d fhe responses.J
4
I{l
2.11 Atthetime of ihe INCIDENT were you acting as an

agent or employee for any PER$ON? lf so, shte:
(a) the name, A,DORESS, and telephone number of that
I I
PERSON: and
past 10 years and the dates each was used,
(b) a description of your duties.
V Z.n At the time of the INCIDENT did
you or any other

person have any physical, emotional, or mentai disability or
condition that may have contributed to the occunence of the
INCIOENT? lf so, for each person shte:
{a) the name, ADDRESS, and telephone number;
(b) the nature of the disability or condition; and
(c) the manner in which the disability or condition
contributed to the occurrence of the INCIDENT.
fl
Z.fa Within24hoursbeforethe INCIDENT didyou or any

person involved in the INCIDENT use or take any of the
(c) the name and ADDRE$S of each joint venturer; and

(d) the ADDRESS of the principal place of business.
il
S Are you an unincorporated association?

lf so, state:
{a) the current unincorporated association name;
{b) all other names used by the unincorporated association
during the past 10 years and the dates each was used;
and
(c) the ADDRE$$ of the principal place of busrness.
f]
f O Have you done business under a fictitious name during

the past 10 years? lf so, for each tictitious name shte:
following substiances: alcoholic beverage, marijuana, or
other drug or medication of any kind (prescription or not)? lf

so, for each person state:
(a) the name, ADDRE$S, and telephone number;
(b) the nature or description qf each substance;
(c) the quantity of each substance used or taken;
{d} fte date and time of day when each substance was used
or taken:
{e) the ADDRESS where each subsiance was used or
(f)
the name, ADDRE$S, and telephone number of each

person who was presentwhen each substance was used
or taken; and
{g) the name. ADDRESS, and telephone number of any
HEALTH CARE PROVIDER who prescribed or furnished
the substance and the condition for which it was
prescribed or furnished.
t]
(c)
| |
(a) identify the license or registration;
(bi state the narne of the public entity; and

(c) state the dates of issuance and expiration.
4.0 lnrurance
f] +.f ,Atthetimeofthe INCIDENT, was there ineffect any
policy of insurance through which you were or might be
insured in any manner ffor example, primary, pro-rata, or

excess liability coverage or medical expense coverage) for
the damages, claims, or actions that have arisen out of the
INCIDENT? lf so, for each policy state:
(a) the kind of coverage;
*
(b) the name and ADDRESS of the insurance company;
(c) the name, ADDRESS, and telephone number of each
named insured;
(d) the policy number;
ie) the limits of coverage for each type of coverage contained in the policy;
(f) whether any reservation of rights or controversy . or
coverage dispute exists between you and the insurance
company; and
10 years and the dates each was used;

the date and place of incorporation;
{d) the ADDRESS of the principal place of business; and
(e) whether you are qualified to do business in California.
(c)
Are you a partnership? lf so, state:
(a) the current partnership name;

(b) all other names used by the partnership during the past
10 years and the dates each was used;
(g) the name, ADDRF$S, and telephone numberof .the"
(c) whether you are a limited partnership and. if so, under
f]
S.S Are you a limited liability company? lf so, state:

ia) the name stated in the current articles of organization;
(b) all other names used by the company during the past 10
years and the date each was used;
(c) the date and place of filing of the articles of organization;
(d) the ADDRESS of the principal place of business; and
(e) whether you are qualified to do business in Califrornia.
DiSC$01 {Rev. January 1.20081
3.7 Vlithin the past five years has any public entity registered or licensed your business? if so, for each license or
registration:
Information-Business Entity
the laws of what jurisdiction;

(d) ihe name and ADDRESS of each general partner; and
(e) the ADDRESS of the principal p,lace of business.
the state and county of each fictitious name filing; and
(d) the ADDRESS of the principal place of business.
3.1 Are you a corporation? lf so, state:

(a) fne name stated in the current articles of incorporation;
(b) all other names used by the corporation during the past
tl 3.2
{a) the name;

(b) the dates each was used;
tal(en;
3.0 General Background
Dtsc_001
3.4 Are you a jointventure? lf so, state:
(a) the current jointvenfure name;
(b) all other names used by the joint venture during the
custodian of the policy.
g Z Are you self-insured under any statute for the damages,
claims, or actions that have arisen out of the INCIDENT?

so, specify the statute.
lf
5.0 fReservedJ
6.0 Physical, Mental, or Emotional Injuries
f]
o f Do you a*ribute any physical, mental, or emotional

injuries to the INCIDENT? f/f your answer is "no," do not
answer interrogaiorles 6.2 through 6.7).
A Z ldentify each injury you attribute

the area of your body affected.
FORM INTERROGATORIES-GENERAL
to ihe INCIDENT and
Pags 3 ot 8
f] O.e Do you still have any compfaints that you attribute
Dlsc-00't
(c) statetheamountof damage you are claiming for each
to
item of property and how the amount was calculated; and

state the name, ADDRE$S, and
telephone number of the seller, the date of sale, and the
sale nrice.
the INGIDENT? lf so, for each complaint strate:

(a) a description;
(bi whether the complaint is subsiding, remaining the same,
or becoming worse; and
(c) the frequency and duration.
O.+ Did you receive any consultation
or
examination
{except from expert witnesses covered by Code
of
Civil
(d) if the property was sold,
J I Z Has a written estimate or evaluation been made for any

itern of properiy referred to in your answer to the preceding
interrogatory? !f so, for each estimate or evaluation state:
Procedure sections 2034.214-2434.310i or treatment ftom a

HEALTH CARE PROVIDER for any injury you attribute to
the INCIDENT? lf so. for each HEALTH CARE PROVIDER
state:
{a)
the
name, ADDRESS, and telephone number of the
PERSON who prepared it and the date prepared;
ib) the name, ADDRESS, and telephone number of each
(a) the name, ADDRESS, and telephone number;

(b) the type of consultation, examination, or treatmeni
PERSON who has a copy of it; and
(c) the arnount of damage stated.
provided;
(c) the dates you received consultation, examination, or

treatment, and
(di the chargesto date.
f]
e.S Have you taken any medication, prescribed or not, as
n Zg
result of injuries that you attribute to the INCIDENT? lf so,

for each medication state:
(a) the name;
(b) the PERSON who prescribed or furnished it;
(c) the date it was prescribed or furnished,
(d) the dates you began and stopped taking it; and
(e) the cost to date.
(d) the name, ADDRESS, and telephone number

PERSON who repaired it;
{e) the name, ADDRESS, and telephone number
(for
example, ambulance,
of
the
Do you attribute any loss of income or earning capacity
to the INCIDENT? {rf yaur answer
rb
'ho." do nat answer
intenogatories 8.2 through 8.8).
nursing,
prosthetics)? if so, for each service state:

(a) the nature;
(b) the date;
(c) the cost; and
{d) the name, ADDRE$S, and telephone number
ofeach provider.
f]
the
8.0 Loss of lncome or Earning Capacity
services necessitated by
the injuries that you attribute io the INCIDENT that were not
previously listed
of
PERSON who Paid for the rePair.
f]
I-*| O.O Are there any other medical
Hasanyitemof propertyreferred to in your answer to
interrogatory 7.1 been repaired? lf so, foroach item state:

(a) the date repaired;
(b) a description of the repair;
(c) the repair cost;
[_l
e.z st"t",
(ai the nature of your work;

(b) your job title at the time of the INCIDENT;
and
(c) the date your employment began.
f]
O.Z Has any HEALTH CARE PROVIDER advised that you

may require future or additional treatment for any injuries
thatyouattributetothe INCIDENT? lf so, for each injury
State the last date before the INCIDENT that you
worked for co mpensatio n-
L
-J
e.+ State your monthly income at the time of the INCIOENT
f]
f]
e.o State the dates you did not work and for which you lost
f]
g
$hte the total income you have lost to date as a result
of the INCIDENT and how the amount was calculated'
and how the amount was calculated-
state:
of each HEALTH CARE

PROVIDER;
{b} dre complaints for which the treatrnent was advised; and
{c) the nature, duration, and estimated cost of the
(a) the name and ADDRESS
featment.
7.0 Property Damage
I 7.1 Do you attribute any loss of or damage io a vehicle or

other property to the INCIDENT? - lf so, for each item of
property:
(a) describe the proPerty;
(b) describe the nature and location
property;
of the damage to
the
S $tate the date you returned to work at each place of

employment following the INCIDENT.
income as a result of the INCIDENT.
Will you lose income in the future as a result of the
INCIDENT? lf so, state:

(ai the facts upon which you base this contentlon;
{b) an estimate of the amount:
(c) an estimaie of how long you will be unable to work; and
(d) how the claim for future income is calculated'
l'.i
;t
sCOOt [ReY. January 1. ?008]
',,r*
Page 4 o{ 8
FORM lNTERROGATORIES_GENERAL
G,,
,G.
Dtsc40?
9.0 Other Damages
(c) the court, names of the parties, and case number of anv
lr, .Arethere any other damages thatyou attribute to the

INCIDENT? lf so, for each item of damage state:
{a) the nature;
(b) the date itoccurred;
(c) the amount; and
(d) the name, ADDRESS, and telephone number of each
PERSON to whom an obligation was incurred.
| | 9.2
action filed;
{d) the name, ADDRE$S, and telephone number of

atiorney representing you;
(e) whether the claim or action has been resolved or is
(f)
I |
Do any DOCUMENTS supportthe existence or amount
of any item of damages claimed in interrogatory g.1? lf so,

describe each document and state the name, ADDRESS,
and tetephone number cf the pERSON who has each
DOCUMENT.
pending; and
a description of the injury.
11.2 In the past 10 years have you made a written claim or

demand for workers, compensation benefits? lf so. for each
claim or demand state:
{a) the date, tirne, and place of ihe INCIDENT giving rise to
the claim;
{b) the neme, ABDRESS, and telephone number of your
emptoyer et the time of the injury;
(c) the name, ADDRESS, and telephone number
did you have com_
plaints or injuries that involved the sarne part of your body
claimed to have been injured in the INCIDENT? lf so. tor
(f) the name, ADDRESS, and telephone
each state:
(a) a description of the complaintor injury;

(b) the dates it began and ended; and
{c) tne name, ADDRESS, and telephone number of each
HEALTH CARE PROVIDFR whom you consulted or
who examined or treated vou.
| | 10.2 List all physical,

ar
12.0 lnvestigation-General
V n.l
State the name, ADDRESS, and tetephone number of

each individual:
(a) who witnessed the lNClDEhlT or the events occurrino
immediatety before or after the lNClDEtrlT;
(b) who made any statement at the scene of the INCIDENT;
{c) vrho heard any statements made about the INCIDENT bv
any individual atthe scene; and
(d) who YoU OR ANYONE AcTtNG ON youR BEHALF
mental, and emotional disabilities vou
emotional djsabiJifies unless you aftribuie any
lO.S At any time after rhe INC|DENT, did you sustain

of the kind for which you are now claiming
damages? lf so, for each incident giving rise to an injury
injuries
of the INCIDENT (except for

expert witnesses covered by Code of Civil procedure
claim has knowledge
state:
section 2034).
ia)
the date and the place itoccurred;

(b) ihe name, ADDRESS, and telephone number of any
other PERSON involved:
{c) the nafure of any injuries you sustained;
II/I IZ.Z
HAVE YOU OR ANYONE ACTING ON YOUR

BEHALF interviewed any 'individuat concerning the
INCIDENT? lf so, for each individual siate;
(d) the name, ADDRESS, and telephone number of each
HEALTH CARE PROVTDER who you consulted or who

examined or treated you; and
(e) the nature of the treatment and its duration.
lf .f
of
the
of
the
PERSON who conducted the interview
Except for this action, in the past 10 years have you
filed an action or made a written claim or demand for

compensation for your personal injuries? lf so, for each
action, claim, or demand state:
(a) the date, time, and place and location (closest street
ADDRESS or intersection) of the INCIDENT giving rise
to the action, claim, or demand;
(b) he name, ADDRESS, and telephone number of each

PERSOh! against whom the claim or demand was made
or the action filed:
OISC-001 iRw. Januery 1,2009)
(a) the name, ADDRES$, and telephone number
individual interviewed;
{b) the date of the interview, and
11.0 Other Clairns and Previous Claims
f]
number of anv
Board.
mental or emotional injury to the INCIDENT.)
f]
the
HEALTH CARE PROVIDER who provided services, and

(g) the case number at the Workers, Compensation Appeals
had immediately before the INCIDENT. (you may omit
mental
of
workers' compensation insurer and the clarm numDer;

(d) the period of time during which you received workers,
compensation benefits;
(e) a description of the injury;
10.0 Medical History
| | 10.1 At any time before the INCIDENT
anv
r-:-l
IV
| 12.3
Have YOU OR ANYONE ACTTNG ON YOUR

BEHALf obtained a written or recorded statement from any
individual concerning the fNCIDENT? lf so, for each
statement state:
(a) ihe name, ADDRE$S, and telephone number
of
the
individualfrom whom the statement was obtained;
of the
individual who obtained the statement;
(c) the date the statement was obtained; and
(d) the name, r{DORESS, and telephone number of each
PERSON vrho has the original statement or a copy.
(b) the name, ADDRFSS, and telephone number
FORM INTERROGATO RIES_GENERAL
Pags 5 ol 8
@ e.+
Do
you oR ANyoNE AcrNG oN youR
BEHALF
know of any photographs, fllms, or videotapes depicting any
place, object, or individual concerning the INCIDENT or
pfaintiffs fnjuries? lf so, state:
(a) the ti{e;

(b) the date;
(c) the name, ADDRESS, and telephone number of lhe
individual who prepared the report; and
name, ADDRESS, and telephone number of each
PERSON who has the original or a copy.
(di the
videobped:
or
videotapes were
taken:
(d) the name, ADDRES$, and telephone number of ihe

individual taking the photographs, films, or videotapes,
and
(e) the name, ADDRESS, and telephone number of each

PERSON who has the original or a copy of the
{4.0 $iatutory or Regulatory Violations

f r+.r Do you oR ANyoNE AcnruG oN youR BEHALF
contend that any PERSON involved in the INCIOENT
violated any slatute, ordinance, or regulation and that the
violation was a legal (proximate) cause of the INCIDENT? lf
so, identify the name, ADDRES$, and lelephone number of
each PERSON and the statute. ordinance. or requlation that
was violated.
photographs, films, or videotapes.
V tZ.S Do YOU OR ANYONE ACTING ON YOUR BEHALF

know of any diagram, reproduction, or model of any place or
- thing (except for items developed by expert witnesses
covered by Code of Civil Procedure sections 2A34.21O2034.310) concerning fte INCIDENT? lf so, foreach item
(a) the type {i.e., diagram, reproduction, or model);

(b) the subject matter; and
(c) the name, ADDRESS, and telephone numberof each
FERSON who haE it.
*lA
the
lttcloeruT? lf so. sbre:

(a) the name, title, identiiication number, and employer of
the PERSON who made the report;
(b) the date and type of report made;

(c) the name, ADDRE$$, and telephone number
of
15.0 Denials and Special or Atrirmative Defenses
PERSON for whom the report was mad6; and

PERSON who has the original or a copy of the repori-
BEHALF inspected the scene of the INCIDENT? tf so, for

each inspection state:
sections 2434.21 C-2034.31 0); a nd

(b) the date of lhe inspection.
1
of all PERSONS who have knowledge of thosefacts;

and
(c) identify all DOCUMENTS and other tangible thingsthat
supporl your denial cr special or affirmative defense, and
lz.z Have YoU oR ANYONE ACTING oN YouR
(a) the name, ADDRE$S, and telephone nurnber of the

individual making the inspection (except for expeft
witnesses covered by Code of Civil Procedure
state the name, ADDRES$, and telephone number of

the PER9ON who has each DOGUMENT'
16.0 Befendant's Contentions-Personal Iniury
f]
3.0 Investigation-Surveillance
fl
te.r Have YOU oR ANYoNE ACTING oN YoUR BEHALF

conducted surveillance of any individual involved in the
INCIDENT or any party to this action? lf so, for each surveillance state:
(a) the name, ADDRES$, and telephone number
of
the
individual or party;
(b) the time, date, and place of the surveillance;
(c) the name, ADDRES$, and te{ephone number of the
individual who conducted the surveillance; and
{d) the name, ADDRESS, and telephone number of each
PER$ON who has the original or a copy of any
surveillance photograph, fi lm, or videotape.
lr,,
f S.f ldentify each denial of a material allegation and each

special or affirmative defense in your pleadings and for
each:
(a) state all facts upon which you base the denial or special
or affirmative defense;
(b) s&te the names, ADDRESSES, and telephone numbers
the
{d) thename, ADDRES$, and telephone number ofeach
fl
| 14.2 Was any PERSON cited or charged with a violation of

any statute, ordinance. or regulation as a result of this
INCIDENT? lf so, for each PERSON siate:
{a) the name, ADDRESS, and telephone number of the
PERSON;
(b) the statute, ordinance, or regulation allegedly violated;
{c) whetherthe PER$ON entred a plea in response to the
citation or charge and, if so, the plea entered; and
(d) the name and ADDRESS of the court or administrative
agency, names of the parties, and case number.
state:
12.6 Was a report made by any FERSON concerning
f O.r Do you contend that any PERSON, other than you or

plaintiff. contributed to the occurrence of the INCIDENT or
the injuries or damages claimed by plaintiff? lf so, for each
PERSON:
ia) state the name, ADDRE$S, and telephone number,-o*f.
the PER$ON:
(b) state all facts upon which you base your contention;
(c) state the names, ADDRESSES, and telephone numbers
of all PERSONS who have knowledge of the facts; and
(d) identify all DOCUMENTS and other hngible things that
support your contention and state the name, ADgRESS'
and telephone number of the PERSON who has each
DOCUMENT or thing.
f O.e Do you contend that plaintiff was not injured in the
INCIDENT? lf so:
(a) state all facts upon which you base your contention;
(b) state the names, ADDRESSES, and telephone numbers
of all PERSONS vrho have knowledge of the facts; and
(c) identify all DOCUMENTS and othertangible things that
support your contention and state the name, ADDRESS'
DOCUMENT or thing.
FORM INTERROGATORIES_GENERAL
fin
Dlsc-001
surveillance? lf so, for each written report state:
{a} the number of photographs or feet of film or videotape;

(b) the places, objects, orpersons photographed, fiimeci, or
(c) the date the phoiographs, films,
rc.2 Has a rvritten report been prepared on the
Pag 6 ol
.4
FK
.l
16.3
Do you ccntend that the injuries or the extent of the

injuries claimed by plaintiff as disclosed in discovery
proceedings 'rhus fur in this case were not caused by the
INCIDENT? lf so. for each injury:
(ai identify it;
{bi state ali fucts upon which you base your contentlon;
{c) sftate the names, ADDRE$SES, and telephone numbers
of all PER$ONS who have knowledge of the facts; and
(d) identify all DOCUMENTS and othertangibte thingsthat
support your contention and state the name, ADDRESS,
and ielephone number of the pERSON who has each
DOCUMENT orthing.
116.4 Do you contend that any of the services furnished by

any HEALTH CARE PROVTDER ctaimed by ptaintiff .in
discovery proceedings thus far in this case were not due to
the INCIDENT? lf so:
(a) identify each service;
{b) state all facts upon which you base yourcontention;
(d) identify all DOCUMENTS and otrrer tangible things that
DOCUMENT orthing.
I 116.5 Do you contend
Drsc401
f,
f]
O.e Do you contend that any part of the loss of earnings or

income claimed by plaintiff in disccvery proceedings thus far
in this case was unreasonable or was not caused by tre
O.Z Do you contend thai any of the property damage

claimed by plaintiff in discovery Proceedings thus far in this
case was not caused by the INCIDENT? lf so:
ia) identify each item of property damage;
{b) state all facts upon which you base your contention;
(c) shte the names, ADDRESSES, and telephone numbers
id) identify all DOCUMENTS and other tangible things that
support your contention and state the name, ADDRFSS,
DOCUMENT or thing.
OISC-o01 [Rev. Jenuary 1, 2098]
16.9
Do YoU OR ANYONE ACTTNG ON YOUR BEHALF
have any DOCUMENT (for example, insurance bureau
16.10 Do YOU ORANYONE ACTING

*T-l have
any DOCUMENT concerning
oN YOUR BEHALF
the past or present

physical, mental, or emotional condition of any plaintiff in
this case from a HEALTH CARE PROVIDER not previously

identified (except for expert witnesses covered by Code of
Civif Procedure sections 2034.21A-?034.310)? lf so, for
each plaintiff state:
{a) the name, ADDRE$$, and telephone number of each
(b)
HEALTH CARE PROVIDER;

a description of each DOCUMENT; and
ic) the name, ADDRE$$, and telephone number of
the
PERSON who has each OOCUMENT.
17.0 Responses to Request for Admissions
f, ll .t
Is your response to each request for admissian served

with these interrogatories an unqualified admission? lf not,
for each response that is not an unqualified admission:
(a) state the numberof the request;

(b) state atl facts upon which you base your response;
INCIDFNT? lf so:
ia) identify each partof the loss;
(b) state all fucts upon which you base your contention;
(d) idenfify all DOCUMENT$ and other tangibte things that
support your centention and state the name, ADDRFSS,
and telephone number of the PER$ON who has each
DOCUMFNT or thing.
If
property damage claimed by piaintiff in discovery
index reports) concerning claims for personal injuries made

before or after the INCIDENT by a plaintiff in this case? lf
so, for each plaintiff state:
(a) the source of each DOCUMENT;
(b) the date each claim arose;
(c) the nafure of each claim: and
(d) the name, ADDRES$, and telephone number of the
PERSON who has each DOCUMENT.
that any of the costs of servjces
O.S Do you contend that any of the costs of repairing the
proceedings thus far in this case were unreasonable? lf so:

(a) identify each cost item;
ib) state all facts upon which you base your contention;
ic) state the names, ADDRESSES, and telephone numbers
of all PERSON$ who have knowledge of the fucts; and
(d) identify all DOCUMENTS and othertangibte things that
DOCUMENT or thino.
furnished by any HEALTH CARE PRAVIDER claimed as

damages by plaintiff in discovery proceedings thus far in
this case were not necessary or unreasonable? lf so:
(a) identify each cost,
(b) state all iacts upon which you base yourcontention;
(c) state the names, ADDRES$ES, and telephone numbers
(d) identifu all DOCUMENTS and othertangibte thingsthat
support your contantion and state the name, ADDRESS,
and telephone number of the PER$ON who has each
DOCUMENT orthing.
(c)
state the names, ADDRESSES, and telephone numbers.

of all PERSONS who have knowledge of those facts;
and
(d) identify all DOCUMENTS and other tangible things that

support your response and state the name, ADDRESS,
DOCUMENT orthino.
18.4 fReserved]
19.0
/ReservedJ
20.0 How the Incident Occurred-Motor Vehicle
f] Zo.r
State the date, time,
and place of the lt{clDENT
(closest street ADBRESS or intersection).
ZO.Z
For each vehicle involved in the lNClDEl,lT, state:
(a) the year, make, model, and license numbor;

(b) the name, ADDRESS, and telephone number
of
the
driver;
FORM INTERROGATORIES-G ENERAL
Page ? of

occupant otherthan the driver:
(d) the name, AODRESS, and telephone number
registered owner;
of
(e) the name, ADDRESS, and telephone number

lessee;
of
Dlsc-o01
(d) state the name, ADDRES$, and telephone number of
each
each PERSOhI who has custody of each defective part.
of each
f]
each
{f) the name, ADDRESS, and telephone number of each

owner other than the registered owner or lien holder;
and
(g)
ihe name of each owner who gave
permission or
consent to the driver to operate the vehicle.
fl
f]
f]
ZO.e State the ADDRESS and location where your trip

began and the ADDRE$S and location of your destination.
ZO.+ Describe
the route that you followed from the
beginning of your trip to the location of the INCIDENT, and

state the location of each stop, other than routine traffic
stops, during the trip leading up to the INCIDENT.
INCIDENT.
25,0 fReserved]
30.0 fReserved,l
40.0 fReservedJ
50.0 Contract
[7}
DOCUMENT that
travel, and the direction of travel of each vehicle involved in
(b) state each part of the agreement not in writing, the

PERSON agreeing to that provision, and the date that
INCIDENT.
(c)
ZO.S State the name of the stfeet
or roadway, the tane of
part of the agreement was madei

identify all DOCUMENTS that evidence any part of the
agreement not in writing and for each state the name,

ADDRESS, and telephone number of each PERSON
the INCIDENT occur at an intersection? lf so,

describe all traffic control devices, signals, or signs at the
ZO.A Did
who has the DOCUMENT;
DOCUMENTS that are part of any

to the agreement, and for each state the
{d} identify
lZa.Z Was there a traffic signal facing you at the time of the
PERSON who has the DOCUMENT;
(e) stateeachmodificationnotin writing, the date, and the

name, ADDRE$S, and telephone number of each
PERSON agreeing to the modification, and the date the
(f)
eO.g State how the INCIBENT occurred, giving the speed,

direction, and location of each vehicle involved:
{a) just before the lNClDEltlT;
{b) at the time of the INCIDENT; and (c) just
after the INCIDENT.
ZO.g Do you have information that a malfunction or defect in
a vehicle caused the INCIDENT? If so:
(a) identify the vehicle;
(b) identify each malfunction or deiect;
the name, ADDRE$S, and telaphone number of

each PER$ON who is a witness to or has information
{c) state
all
modification
INCIDENT? lf so, state:

(a) your location when you first saw it;
(b) the color;
(c) the number of seconds it had been that color: and
(d) whether the color changed between the time you first
saw it and the INCIDENT.
in the pleadings:
is part of the agreement

and for each state the name, ADDRESS, and telephone
numberofeach PERSON who hasthe DOCUMENT;
intersection.
SO.f For each agreement alleged
{a) ideniify each
the INCIDENT for the 5O0 feet of travel before the
ZO.r1 State the name, ADDREss, and telephone number of
each owner and each pERSON who has had oossession

since the INCIDENT of each vehicle involved in the
modification was made;

idendfy all DOCUMENTS that evidence any modification
of the agreement not in writing and for each state the
name, ADDRES$, and telephone number of each
PERSON who has the DOCUMENT.
|7l
SO.Z
|lZ|
SO.S
|7|
SO.+
about each malfuncfion or defeci, and
Was there a breach of any agreement alleged in the

pleadings? lf so, for each breach describe and give th dete
of every act or omission that you ciaim is the breach of the
agreement.
Was performance of any agreement alleged in the

pleadings excused? lf so, identify each agreement excused
and state why performance was excusedWas any agreement alleged in the pleadings terminated
by mufual agreement, release, accord and satisfaction, or

novation? lf so, identify each agreement terminated, the date
{d) state the name, ADDRESS, and telephone number of
of termination, and the basis of the termination.
each PERSON who has custody of each defective part.
f]zO.f O Do you have information that any malfunction or

defect in a vehicle contributed to the injuries sustained in the
INCIDENT? tf so:
{a) identify the vehicle;
(b) identify each malfunction or defect;
{c) state the name, ADDRE$S, and telephone numbejr of
each PERSON who is a vritness to or has information
about each malfunction or defuct and
fl
ls any agreement alleged in the pleadings unenforceable? lf so, identify each unenforceable agreement and
SO.S
state why it is unenforceable.
[|
pleadings ambiguous?
lf so, identify each ambigrrous agreement and state why it is
SO.O ls any agreement alleged in the
ambigLlous.
60.0 fReservedJ
FORM INTERROGATORIESIGENERAL
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DECLARATION BY Carly Bauqh
I
9
t,
Cn
r\{ lfuirrc[}l
. do herebv decrare as ro'orvs:
l0
l1
I am not a parry- ofinterest to the above entitled case, and am over I 8 years ofage.
l2
t3
l4
I personalty
served Reply to Admissions by First Class lvlail using the United States Postal service
in Porterville California:
to: Robert J. Fletcher
15
P.O. Box 824
16
Tulare,
t1
II
I declare under penaltv of perj ury, ptlrsuant to the lalvs of The State of California that the foregoing
CA
93?74
are true and correct.

18
l9
Date: March
7, 20ll
20
2l
22
23
24
25
26
27
?8
ly Cillepic,
rcy
Gilltroic
qintiffs
REPLY'I'O DEFENDAN'TS ADMISSIONS AND INTEROCATORIES
_t
-)
Robert J. Fletcher No. 1 19770

Attorney at Law
P.O. Box 824
Tulare- C493274
(s59) 684-r79s
Attorney for Defendants and
Cross-Complainants
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF TULARE
"7
Case No.: 10-238961
Courtney and Melody Gillespie,
Plaintiffs,
t0
vs.
l1
Nicklas Hofknan; et. al.
t2
Defendants
Rf,QUEST FOR ADMISSION
-tJ
l4
l5
)
)
)
And Related Cross-Action
16
REQUEST FOR ADMISSION TO:
PLAINTIFF AND CROSS.DEFENDANT.

MELODY GILLESPTE
PROPOTJNDED BY:
DEFENDANT AND CROSS-COMPLAINANT.

NICKLAS HOFFMAN. INDIYIDUALLY
SET NUMBER:
ONE
t7
18
L9
20
t1
zl
NOTICE
22
23
UNDER THE PROVISIONS OF CALIFORNIA CODE OF CTYIL PROCADURE
yOU ARE HEREBY REQUESTED TO ADMrT THE

$$2033.10 THROUGHaA38.4a0
24
TRUTII OF SPNCIFIED MATTERS OF FACT. OPINION RELATING TO FACT. OR
25
-1-
Nicklas Hoffmaa's Request for Admission Set No. One

Gillespie vs. Hoffman
Case No. 1o-238e61
.t-'.
l.. i-r"r'
l -\t"-'
{7:'
i7a
i1
::,',J
Ii
l
-,!'
!',:-,".i4'
.j
LJ
f7
GillesPie
c/o P.O. Box 8323
1ll Melody
tl
2ll Porterville, California
,l
il
4l
sl
6l
7
TULARE COUNTY SUPE,RIOR COURT
9
10
VISALiA DIVISIO}'{
Melody and CourtneY GillesPie
11
t2
13
Plaintiffs,
Case
No. 10-238961
2ND
REPLY TO DEFENDANT'S ADMISSIONS:
vs.
Nicklas Hofftnan. et al.,
)
Defendants.
l4
15
)
)
)
RELATED CASE PCL 138180
t6
11
LI
l8
19
known Melody Gillespie for approximately 25

Defendants Nicklas Hoffinan and Nickol Gerritsma have
years' Most of the questions asked are over
years, and have knorvn Courtney Gillespie approximately 16
the possession of the defendants' and' or already
burdensome. duplicative, within the knowledge aiready in
beendecided/testifiedtoinpCLl3g180.
plaintiffsbelievetheseinteffogatoliesareintendedforharass-
sales contract" has

20 ment. The term created by Mr. Fletcher, attorney for the defendants, "integrated land
Court, is not in Blacks Law Dictionary, Bouviers
2l not even been defined by the State or Federal Supreme
corpus juris secundum, not in American
Law Dictionary, none of the dictionades on the intemet, not in the
22
could find' Theref':re' Mr' Fletcher has obfusJurispruclence, and not in any real estate law books Plaintiffs
piaintiffs ability to respond. Then uses the same term to define "lNL)
questionradrnission beyond
cated the
definition'
24 CIDENT", in which most of the questions revolve around that
25
26
27
28
ly Gillespie,
Inthebeginningoftlreadrnissionslinterrogatories,Mr'Fletcherstates:
..LiNDERTHEPROVISIONSoFCALIFORNIACODEoFCIVILPROCEDURE
REQUESTED TO 4D-M!LIHE TRUTH OF
$$2033.i0 2033.42AYOU ene HEREBY
SPECIFIEDMATTERSoFFACT,OPTNIONRELATINGToFACT,oRAPPLICA.
TIONoFLAwToFACT.YoUSHOULDCONSIDERCAREFULLYYOUR
LIMITED EXCEPTIONS'
RESPONSE TO THIS REQUEST FOR ADMISSION, WITH
ANANSWERINGPARTywTIT-NOTBEALLOWEDToCHANGEANANSWER
1
rey Gillespie
aintiffs
REPLYTOADMISSIONSANDINTERROGATORIES
TO A REQUEST FOR ADMISSION. THER MAY BE PENALTIES IF YOU FAIL

TO
ADMIT THE TRUTH OF ANY FACT PRUSUANT TO THIS REQUEST AND THE
PROPOLINDING PARTY PROVES THAT THE FACT IS TRUE. THESE PENALTIES
MAY INCLUDE, BUT ARE NOT LIMITED To, PAYMENT oF THE PROPOU}.{DING
PART'S ATTORNEY FEES INCURRED IN MAKING THAT PROOF. UNLESS
THERE IS AN AGREEMENT OR A COURT ORDER PROVIDING OTHERWISE,
YOU MUST RESPOND IN WRITING, AND LINDER OATH, TO THIS REQUEST
FOR ADMISSION WITHIN 30 DAYS.''
2
3
IA
5
1.
Mr. Fletcher stated rve could not change our answers, and because he did not like our answers, nou'he wants us, the plaintiffs, to change the answers.
2.
Defendant Hoffman has answered most of the questions in his PCLl38130 trialtestimony,
and it lvould appeal'that Mr. Fletcher wants Plaintiffs to refute Defendant Hoffman's testi-
nrony in previous court hearings. FIe was already deposed in the court during trial, and
cannot change his testimony, so it appears that Mr. Fletcher wants us to change it for Defendant Hoffman, by Mr. Fletcher's obfuscation of the admission and interrogatories for us
10
ll
to answer.
t2
3,
rnan's personal knowledge and Mr. Fletcher needs to talk to his client for those answers. It
T3
is over reaching, over burdensome and irrelevant for us to answer questions that Defendant
L4
t5
Hoffnan already knows. There are some questions that have to do with sensitive personal
inforrnation' Plaintiffs object to releasing personal information because Defendant Hoffman
i6
has already, on two occasions, used identity theft to harass and vex
t7
Hoffman states that he can find anything about anyone on the internet, and he has already
used Cyber staiking against our daughter, and has rcvealed where our daughter, a single
18
Hoffman, oithe property already purchased by Plaintiffs, and the letter is attached to plaintiff s complaint for injunction. There is already a restraining order against Defendant
a1
zl
Hoffman for his activities against the Plaintiffs. For Defendant Hoffman to use his attomey
to compel that infotmation is in violation of the spirit of the resfi.aining order. See case
22
-.)
L)
nunber n-n7521.
.t
+.
24
the scope of knowledge of Defendant Hoffman, or already answered in another court case.
26
:y Gillespic
rintiffs
In order for Plaintiffs to change their answers, they must be given clearly defined terms
rvritten in plain simple language that is easily understandable, must not already be within
25
28
is. This was
done shortly after Plaintiffs refused to sign a commercial rental agreement with Defendant
2A
27
Plaintiffs. Defendant
mother, can be forrnd by exhibiting a map on the internet of where her house
t9
/ Gillespiel
The rest of the questions are either premature, or are within the scope of Defendant Hoff-
'
Nicklas has already testified to the existepce of a land sales contract. He also stated it was for
the
purchase of property' He is the one who drew up the contract. My name is not
on any agreement
REPLY TO ADMISSIONS AND INTERROGATOzuES
with Nicklas or WYSOCKI TRUST, BUT I AM DIRECTLY AFFECTED BY the agreement befween my husband Courtney Gillespie and Nicklas Hoffman. See Motion for judicial notice filed
Feb. 15, 2011 and the trial transcript of PCL 138180. I do not know what an "integrated land sales
contract" is, and cannot find the definition. The questions must be in plain sirnple ianguage, that is
easy to understand. An integrated conffact, has been defined by the supreme couft, but the supreme
court has not defined "integrated land sales contract. I can only refer to previous testimony as to
understand what Nicklas interrded when he drew up the contract. For whatever name Nicklas wants
to giye the contract, he took my money every month for it when I handed it to him' I have nothing
to add to the testimony and documents presented by Defendant Hoffman gave in case number 10-
237521 and PCL 138180.
1.1 This is rvithin the knorvledge of the defendants. Olrjection, irrelevant material, over burdensome, duplicative, defendants already have the information in their possession is oppressive. Plain-
10
tiffs believe this are intended for harassment, we have no one helpirrg us to prepare the interogato-
11
ries.
I2
13
2.
Object due to relevance. I do not understand "formation of an integrated land sales agreement." I
can only refer to the answer of ( 1), other than that,
t4
I stick with my original answer: Move to strike
due to being vague and arnbiguous. There is no definition of the term "formation integrated land
plaintiffs' complaint, therefore it is up to the defendants to define
Nicklas
sales agreement in the
t6
Hoffman has already stated many times there is a land sales agreement in PCL 136180 transcript
11
LI
and was also ruled upon by Hon. Glade Roper in Case PCL i38180, and has been filed into the
above named case. See Motion
18
forjudicial notice filed Feb. 15,2411.
19
2.1 Objection, irrelevant material, over burdensome, duplicative, defendants already have the information in their possession is oppressive. Plaintiffs believe this are interided for harassment' I
20
object to personal material being given because lvir'. Hoffman has used Courtney's personal infor-
2l
mation to shut off our utilities, has put it up on the internet, and passed out the information to the
neighbors, and the church we used to go.
22
2.2 SameObjection
23
ready have the inforrnation in their possession is oppressive. Piaintiffs believe this are intended for
aA
.La
harassment.
25
2.5
as in (2.1), irrelevant material, over burdensome, duplicative, defendants al-
Same Objection as (2.2), irrelevant material, over burdensome, duplicative, defendants already
hahave the inforrnation iri their possession, is oppressive. Plaintiffs believe this are intended for
26
rassment. It is already part of 3 court records.
27
2.6
28
ly Gillcspie,
Same Objection as (2.5), irrelevant material, over burdensome, duplicative, defendants already
have the infonnation in their posscssion. Plaintiffs believe this are intended for harassment-
rey Gillespie
airtiffs
it'
15
2
a
2'7
Same Objection as (2.6),
If I have no schooling, or if I have a doctorate,
does that change the
outcome of our complaint? Irelevant material, over burdensome, duplicative, defendants

already
have the information in their possession is oppressive. Plaintiffs believe this are
intended
for ha-
rassment.
2.8
cofirplaint? Irrelevant material, over burdensome, duplicative, defendants already have the
information in their possession, is oppressive. Plaintiffs believe this are intended for harassment.
Same Objection as (2.5),
If I do have a criminal record,
does that change the outcome of our
2.9
Same Objection as (2.5), irreievant material, over burdensome, duplicative, defendants

already
have the information in their possession.is oppressive. Plaintiffs believe this
are intended for ha8
rassment.
2.10 Same Objection
l0
have the information in their possession, and is oppressive. Plaintiffs believe this are intended
for
harassment.
2.1
11
IL
not understand rvhat kind of answer defendant is looking
i3
fied to the land sales contract in PCL
t5
16
t7
l8
38
I 80, therefore
for.
Defendant Hoffman has already testi-
I believe this is irrelevant material, over
burdensome, duplicative, defendants already have the information in their possession is oppressive.
Plaintiffs believe this are intended for harassment. I do not have anlthing to add to Defendants testirnony already submitred to the courl in pcl l3g1g0 and 10-237521.
2'12 Objection, definition is not in plain simple easy to understand language. I do not understand
what kind of answer defendant is looking for. Defendant Hoffman has already testified to
the land
sales contract in PCL 138180, AND DID
Nor TESTIFY rr{Ar EITHER MysELF oR My
20
2T
harassment. I do not have anything to add to Defendants testimony already

submitted to the court in
PCL
22
L3
1381
80 and 10-237 5Zt.
2.13 Objection, definition is not in plain simple easy to understand language. I do not understand
what kind of answer defendant is looking for. Defendant Hoffman has already testified to the land
24
sales contract in PCL
25
HUSBAND WAS STONED, INTOXICATED, OR TINDER THE INFLUENCE OF ANY SUBSTANCE WHEN THE TWO MEN SIGNED THE CONTRACT, therefore I believe this is inele-
26
27
28
aintiffs
Objection, definition of INCIDENT is not in plain simple easy to understand language. I do
HUSBAND WAS OF MENTAL INCAPACITY WHEN THE TWO MEN SIGNED THE CONTRACT, therefore I believe this is irrelevant material, over burdensome, duplicative, defendants already have the information in their possession is oppressive. Plaintiffs believe this
are intended for
19
cy Ciltespie
irelevant material, over burdensome, duplicative, defendants already
lt
t4
y Gillespie,
as (2.5)
13 8 t
80, AND DID
NoT TESTIFY THAT EITHER MYSELF oR My
vant material' over burdensome, duplicative, defendants already have the information in their possession is oppressive. Plaintiffs believe this are intended for harassment. I do not have
anything to
add to Defendants testimony already submitted to the court in PCL I 3I 1 g0 and, le-237
5Zl .
REPLY TO ADMISSIONS AND INTERROGATORIES
t
I
2
3
+
5
l2' 1 objection' definition of INCIDENT

is not in plain simple easy to understand
language. I do
not undetstand r'vhat kind of answer
defendant is looking for. Defendant
Hoffman has arready testified to the la'd sares contracr in pcl
r3grg0, AND ALL oF THE cIRcuMSTANcEs
suR_
ROLINDING THE AGREEMENT, IT Is
WITHIN THE DEFENDANT,S KNOWLEDGE,
theTefore I believe this is irlelevant material,
over burdensome, duplicative, defendants
already have the
information in their possession is oppressive.
Plaintiffs believe this are intended for harassment.
I
do not have anything to add to Defendants
testimony already submitted to the court pcl j g g0
in
l
I
and 10-237521.
12'2 objectio'' definition of INCIDENT

ranguage. I do
not understand what kind of answer defendant
is looking for. Defendant Hoffrnan has
already testified to the laird sales contract in PCL 1
3 8 1 80, therefore I believe this
is irrelevant material. over
burdensome' duplicative, defendants already
have the information in their possession
is oppressive.
ThetranscriptandrulingattachedtoMotionforjudicialnoticefiledFeb.
15,2011. plaintiffsbelieve this are intended for harassment.
I do not have anything to add to
t0
11
Defendants testimonv al-
t2
ready submined to the court in pCL
1a
IJ
l2'3 objection
t4
language' I do not understand what kind

of answer defendant is looking
has already testified to the land sales
contract in PCL I 3 g 1 g0, therefore
15
1
16
1
1't
tt
18
I
I
I
I3glg0
and 10_237521.
due to rclevance. definition of INCIDENT

for.
Defendant Hoffman
I believe this is iffelevant

material' over burdensome, duplicative, defendants
already have the information in their possession
is oppressive' see the transcript and ruling
attached to Motion for judicial notice filed
Feb. 15,
201 l ' Plaintiffs believe this are intended
for harassment. Nicklas Hoffrnan was the only
one de-
posed about the land sales contract

signed by him and
anything to add to Def-endants
Mr. Gillespie in pcl- 13 g I g0. I do not have

testimony already submitted to the court in pcll3gl g0 and 10-
19
237s21,
20
12'4 obiection due to relevance. definition of INCIDENT

2T
22
t,)
language' I do not understatld what kind of answer

defendant is looking
has already testified to the land sales contract
in PCL 13 8 1 80, therefore
for.
Defendant Hoffman
I believe this is irelevant

material, over burdensome, duplicative, defendants already
have the information in their possession
is oppressive. see tlre transcript and ruling attached to
Motion forjudicial notice filed
Feb. 15,
1A
L+
25
26
27
' Plaintiffs beiieve this are intended for harassment. Nicklas Hoffrnan was the only one deposed about the land sales contract signed by him
and Mr. Gillespie in pcl, 13 g 180. I do not have
201 l
anything to add to Defendants testimony already submitted

to the court in pCL l3glg0 and l0237521'attached to Motion forjudicial notice filed Feb. 15,20i
l. Most of the question is irrelevant
material, oppressive and constitutes harassrnent.
28
;illespie,
Gillespie
tiffs
l2'6 objection
2
a
J
4
due to relevance. definition of INCIDENT is not in plain

simple easy to understand
Ianguage' I do not understand what kind of answer

defendant is looking
has already testified to the land sales contract in PCL
138180, therefore
for.
Defendant Hoffinan
I believe this is irrelevant

material, over burdensome, duplicative, defendants
already have the information in their possession
is oppressive. See the transcript and ruling attached
to Motion for judicial notice filed Feb. 15,
1' Plaintiffs believe this are intended for
201
posed about the land sales contfact signed by hirn and

Mr. Gillespie in
harassment. Nicklas Hoffman was the only one de-
pcl-
anything to add to Defendants testimony already submitted

to the court in
)71 <1
13g1g0. I do not have
pcl- l3g1g0
and 10-
t0
ft
ll
12'7 objection due to relevance. definition of INCIDENT is not

in plain simple easy to understand
language. I do not understand rvhat kind of ansr.ver defendant
is looking for. Defendant Hoffman
has already testified to the land sales contract in PCL 138180,
therefore I believe this is irrelevant
material, over burdensorne, duplicative, defendants already have
the information in their possession
is oppressive. See the transcript and ruling attached to Motion
1' Plaintiffs believe this are intended for
forjudicial notice filed Feb.
T2
201
13
posed about the land sales contract signed by him and
t4
anything to add to Defendants testimony already submitted to

the court in
237521.
t5
harassment. Nicklas Hoffman was the only one de-
Mr, Gillespie in pCL
13 g
pcl
I3gI
g0 and I 0-
t6
l'7
LI
sales contract has already been adjudicated in case
13'
existence of the land
PCL 138180, the transcript and ruling attached

to lvlotion for judicial notice filed Feb. 15,2011 . Most of the question
is irrelevant material, oppressive and constitutes harassment. We have not conducted
any surveillance of anyone, we don,t
19
have
20
in case number 10'237521is just a small part of the suryeillance

antics Mr. Hoffrnan has been
doing, and continues to do.
2l
22
24
25
26
27
28
tirne' Mr. Hoffinan, however,
l3'2 object
has been. See case number 10-23752L What has bee' stated
due to relevance. Move to strike due to being vague

and ambiguous. The previously
defined tetm "INCIDENT", does not appear in any of the pleadings,

and the existence of the land
sales contract has alre4dy been adjudicated in case PCL 138180,
the transcript
and ruling attached

to Motion forjudicial notice filed Feb. 15,2a11, Most of the question
is inelevant material, op-
pressive and constitutes harassment. There are affidavits photos

in case nurnber 10-237521 about
Mr' Hoffman's surueillance of the Gillespies, and their friends and neighbors,
hiding
in bushes, be-
hind the fence. across the street, standing on a mound. He has

his nine year old daughter ride her
horse on the street yelling out that the Gillespies are
.,die,,.
thieves, and screaming
for us to
The
times and dates are a matter of record in case number rc-237 521 ,
what is recorded in that case is
'Gillespie,
Gillespie
1g0. I do not have
object due to relevance. Move to strike due to being vague and ambiguous.
The previously
defined tenn "INCIDENT", does not appear in any of the pleadings,
and the
18
:y
15,
irtiffs
very small paff of what he is doing, but the rest will eventually make it into the record soon. Those
are the only records
I am arvare of that have been recorded on his surveillance of the Gillespies,
other than police reports of the dates given in 10-237521.

3
A
?
l
8
i0
15,1 Objection; vague and ambiguous. There have been several pleadings filed into the above
named case,
it is unciear
as to
which ones are being referred
to. If refening to cross-complaint, it is
premature and rnisplaced, as answer has not been filed yet.
17.1 Objection; vague and ambiguous. Objection due to relevance, inapplicable. Move to strike
due to being vague and ambiguous. There is no definition of the term integrated land sales contract
in the plaintiffs' complaint, therefore it is up to the defendants to define

ready stated many times there is a land sales agreement in PCL l3
ruled upon
b1,
it.
Nicklas Hoffman has al-
80 transcript and was also
Hon. Glade Roper in Case PCL 138180, and has been filed into the above named
case. See Motion for judicial notice filed Feb. 15,201l. I have nothing to add that has not already
been submitted to the court in PCL 138180 and case number 10737521'.
11
50.1 Objection, the alleged agreement was drawn up by Nicklas Hoffman and is equally available
T2
to both sides. He has his own copies, and have been served several copies of what the Gillespies
13
t4
have in tlvo other related couft cases as well as the above named case.
50.2 Objection; relevance, Plaintiffs filed a complaint for injunction, not for any breach of contract,
calls for legal conclusions, calls for expert opinion: objection to the language, pleadings is plural,
15
agreement is singular; vague and ambiguous due to sentence is compound, it is unclear as to which
l6
pleadings are being refen'ed to; over burdensome, oppressive, all information is rvithin Defendant's
1',7
possessiou.
18
calls for legal conclusiorls, calls for expert opinion; objection to the language, pleadings is plural,
19
agreement is singular: vague and ambiguous due to sentence is compound, it is unclear as to which
20
pleadings are being referred to; over burdensome, oppressive, all information is within Defendant's
2I
possession.
22
calls for legal conclusions, calis for expert opinion; objection to the language, pleadings is plural,
LJ
agreement is singular; vague and ambiguons due to sentence is compound, it is unclear as to which
24
pleadings are being referred to; over burdensome, oppressive, all information is within Defendant's
possession. Plaintiffs are not aware of any such termination, or stating such in any pleadings, and
25
26
50.5 Objection; relevance, Plaintiffs filed
27
agreements, calls for legal conclusions,,calls for expeft opinion; , over burdensome, oppressive, all
28
ly Gillespie,
do not know what pleadings def-endants are referring to.

a
complaint for injunction, not for unenforceabilily
information is within Defendant's possession.
rcy Gillwpie
aintiffs
of
I
2
3
A
T
5
6
not for ambiguity of any

50.6 objection; relevance, Plaintiffs filed a complaint for injunction,
opinion; objection to the language, pleadings
agreement, calls for legal conclusions, calls for expert
to sentence is compound' it is unclear as
is plural, agfeement is singular; vague and ambiguous due
oppressive, ali information that Plainto which pleadings are being referred to; over burdensome,
tiffs' have is within Defendant's
possession'
that the foregoing is true and corI declare under penalty of perjury under the laws of the State of California
rect, to the best of my knowledge and understanding'
7
8
9
10
11
12
13
l4
15
t6
t7
18
19
2A
2l
22
L7
24
25
26
27
28
ly Gillespie'
rey Gillespie
rintiffs
1lltl
DECLARATION BY CarlY Baugh
?ll
-ll
.ll
|tn\-
'll
, do hereby declare as follows:
4ll
lil
tl
II
il
ll
6ll
I am not aparfy ofinterest to the above sntitled case, and am over 18 years ofage'
?ll
I personally served Reply to Admissions by First Class Mail using the United States Postal service
tl
sll
in Porterrille California:
ll
tl
ef
I
10
1
111
I
I
12l
to: Robeft J. Fletclrer

P.O. Box 824
Tulare,
CA 93274
that the foregoing

I declare under penalty of perjury, pursuant to the laws of The State of California
are true and correct.
13
t4
Date: March
7,
2011
15
T6
t7
18
19
2A
2l
22
/1
24
25
26
27
28
ly Gillespie,
rey
Gillespit
aiDtiffr

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I

Robert J. Fletcher No. 119770

SUPERIOR COURT OF THE STATE OF CALIFORNIA

IN AND FOR TI{E COUNTY OF TULARE

Courfney and Melody Gillespie,

Nicklas Hoffrnan; et. al.

REQUEST FOR ADMISSION

And Related Cross-Action

REQUEST FOR ADMISSION TO:

PLAINTIFF AND CROSS-DEFENDANT,

DEFENDANT AND CROSS-COMPLAINANT,

UNDER THE PROVISIONS OF CALIT'ONNIA CODE OF CTYIL PROCEDURE

TRUTH OF SPECIFIEI} MATTERS OF FACT, OPINION RELATING TO FACT, OR

-lNicklas Hoffman's Request for Admission Set No. One

APPLTCATION OF LAW TO FACT. YOU SHOULD CONSIDAR CAREFULLY YOUR

AN ANSWERING PARTY WILL NOT BE ALLOWED TO CIIANGE AN ANSWER TO

A REQUEST FOR ADMISSION. THERE MAY BE PENALTIES IF YOU FAIL TO

YOU FAIL TO PROVil)n A TIMELY WRITTEN RESPONSE TO EACH REQUEST

PLEASE ADMIT THE FOLLOWING:

and any trustee of the H.M. Wysocki Irrevocable Trust.

Dated: Januar-v 18.

Robert J. Fletcher, Attorney for

Nicklas Hoffrnan's Request for Admission Set No. One

Tulare, Califomia 9327 5

c.c.P. $2023.010 (i).

Robert J. Fletcher No. I 19770

(Naret: Defendants and Cross-Complainants

SUPERIOR COURT OF CALIFORNIA, COUNTY OF

Gillesnie vs. l{offman

narg: Nicklas Hoffman. Indii'idualll'

Answering Party: Melody Gillespie

Sec. 1. Instructions to All Parties

(a) Interrogatories are written guestions prepared by a party

the asking partY.

See. 2. Instructions to the Asking Party

These interrogatories are designed for optional use by

The interrogatories in section 16.0, Detundant's

3. Instructions to the Answering Party

{a) An answer or other appropriate response must be

(a) {Check one of the following):

ib) As a general rule, within 30 days after you are served

.- '' {_-r r*lt-/

Code of Civil Ptocedure.

ss 2030.01$.?030 410 2033.71C

INCIDENT means (insert your definition here ar

includes you, your agents, your employees, your insurance

{c} PERSON inc{udes a natural person, firm, association,

(e) HEALTH CARE PROVIBER includes any

1.0 ldentity of Persons Answerlng These lnterrogatorles

State the name, ADDRES$, telephone number, and

2.0 General Background

(a) your name;

1.0 ldenti$ of Persons Answering These Interrogatories

(a) the state or other issuing entity:

ib) the license number and type;

(a) the name, ADDRE$S, and telephone number of your

and ADDRESS of each school or other

Have you ever been convicted of a felony? lf so, for

each conviction state: