2022-07-12 Subpoena for Records #1 - 55075 Monroe StreetPLAINTIFF/PETITIONER:JAMESSCOTTMORROW ET AL.,
DEFENDANT/RESPONDENT: BRENT DILL ET AL.,
i
AFFIDAVIT OF CUSTODIAN OF RECORDS
(California Evidence Code § 1561)
Records Produced by: CITY OF LAQUINTA
CASE NUMBER:
PSC1905078
- - - -. .............
(374871- 1)
Records Pertaining to: MONROE STREET PROPERTY-556-15 MUnrot S+ctt-- I LG Q,' G, q 2253
Date of Birth: / / j11A Social Security #: ###-##--##- n1A
1 hereby declare, under penalty of perjury, that the following statements are true and correct to the best of my
knowledge. I, the undersigned, am the duly authorized Custodian of Records (or other qualified witness) for the above
referenced records provider.
These records were originally prepared / created via: (Please check all that apply to the original made of preparation)
❑ Handwritten notes
oTranscription
In Computer generated forms
❑ Data entry
t,�4ther r
J e
t?l Ovo5 �cm-'
'n �e S
The enclosed records are comprised of the following: (Please check all that apply)
❑ Medical ❑ Billing ❑ Films/X-Rays El Insurance o Employment / Payroll
O Seholasilc '10ther AS Y.Q �tlr-ellt e_(� a6\x-
1ATo the best of my knowledge, all of the records referred to above were prepared or compiled by the personnel of the
above named business, in the ordinary course of business, at or near the time of the acts, conditions or events recorded.
1 have the authority to certify that the records produced herewith are a true and correct copy of ALL of the records
under my custody and control pertaining to the above named individual as described in the Subpoena or Authorization
served with this affidavit. I have delivered all of the records / items requested to the requesting party.
pA thorough search of our files, carried out under my direction revealed no documents, records or other materials
requested under the Subpoena or Authorization for the following reason:
r1/A- ___`_All records for the time period in question have been destroyed in accordance with our document retention policy-
Vr� ,Records do exist, but none within the time limits set forth in the request-
y%K ____,A thorough search has been performed and no such records were found-
h1,4- _(other)
LCAU'o
Print Narne 6 Signature
-7 2-i ZG22!a% ��oth4arL •goV
Date Contact phone and email addre
Certiti4ation of Professional Photo o ier NA-
i, the undersigned, declare under penalty of perjury that the foregoing is true and correct and that the attached copy of
ecords was transmitted or distributed to the authorized person(s) or entities. I further declare that I made true and
accurate copies of all records produced to me by the Custodian of Records of the above named records provider and will
maintain the confidentiality of the information contained within.
Signature
sueP-010
RWhrxY
ANNA K. GREENSiIN SON' CA- 225429
WFBM, LLP
19900 MACARTHUR BLVD. SUITE 1150
IRVINE, CA 92612
TELEPHONE NO.: (714) 034.2522 FAX NO.:
E-MAIL ADDRESS:
ATTORNEY FOR (Narnv)t: SUSAN HARVEY AND DESERT PACIFIC PROPERTIES, INC.
STREET ADDRESS: PALM SPRINGS COURTHOUSE
MAILING ADDRESS: 3266 E. TAHQUITZ CANYON WAY
CITY AND ZIP CODE: PALM SPRINGS, CA 92262-
BRANCH NAME:
PLAINTIFFIPETITIONER: JAMES SCOTT MORROW ET AL.,
1)EFEN DANT(RESPONDENT: BRENT DILL ET AL.,
DEPOSITION SUBPOENA
FOR PRODUCTION OF BUSINESS RECORDS
FOR COURTUSF ONLY
.. .- - I CASE NUMBLR-
PSC 1905078
THE PEOPLE OF THE STATE OF CAUFORNIA, TO (name, address, and telephone number of deponent, Nknown):
CITY OF LADUINTA (76D) 777-70DO
78495 CALLE TAMPICO, LA QUINTA, CA 92263
1- YOU ARE ORDERED TO PRODUCE THE BUSINESS RECORDS described in item 3. as follows:
To (name of deposition officer): RecordTrak (800) 220-3200
On (dale) : 07/27/2022 At (time): 10:00 AM
Location .(address : 130 Webster Street. Suite 100 Oakland_ CA 94607
Do not release the requested records to the deposition officer prior to the date and time stated above.
a. = by delivering a true, legible, and durable copy of the business records described in item 3, enclosed in a sealed
inner wrapper with the title and number of the action, name of witness, and date of subpoena clearly written on it_
The inner wrapper shall then be enclosed in an outer envelope or wrapper, sealed, and mailed to the deposition
officer at the address in item 1.
b [KX] by delivering a true, legible, and durable copy of the business records described in item 3 to the deposition officer at the
witness's address, on receipt of payment in cash or by check of the reasonable costs of preparing the copy, as determined under
Evidence Code section 1563(b).
C. [ X j by making the original business records described in item 3 available for inspection at your business address by the
attorney's representative and permitting copying at your business address under reasonable conditions during normal
business hours.
2 The records are to be produced by the date and time shown in item 1 (but not sooner than 20 days alter the issuance of the
deposition subpoena, or 15 days after service, whichever date is later)_ Reasonable costs of locating records, making them available or
copying them, and postage, if any, are recoverable as set forth in Evidence Code section 1563(b). The records shall be accompanied by
an affidavit of the custodian or other qualified witness pursuant fo Evidence Code section 1561.
3. The records to be produced are described as follows (f electronically stored information is demanded, the form or forms
in wh,ch each Type of information Is to be produced may be specified)_
akj Continued on Attachment 3.
4 IF YOU HAVE BEEN SERVED WITH THIS SUBPOENA AS A CUSTODIAN OF CONSUMER OR EMPLOYEE RECORDS UNDER
CODE OF CIVIL PROCEDURE SECTION 1985.3 OR 1985.6 AND A MOTION TO QUASH OR AN OBJECTION HAS BEEN SERVED
ON YOU, A COURT ORDER OR AGREEMENT OF THE PARTIES, WITNESSES, AND CONSUMER OR EMPLOYEE AFFECTED
MUST BE OBTAINED BEFORE YOU ARE REQUIRED TO PRODUCE CONSUMER OR EMPLOYEE RECORDS.
DISOBEDIENCE OF THIS SUBPOENA MAY BE PUNISHED AS CONTEMPT BY THIS COURT. YOU WILL ALSO BE LIABLE FOR THE SUM OF
FIVE HUNDRED DOLLARS AND ALL DAMAGES RESULTING FROM YOUR FAILURE TO OBEY.
Date issued. June 29, 2D22
ANNA K. GREENSTIN , !SJ ANNA K. GREENSTIN
(TYPE OR PRINT NAME] (SIGNATURE? OF PERSJN ISSUINGSUBPOENA)
Alturngy For SAN HA RV ' Y ANO DESERT PACII,FIC PROPERTIES, INC.
(TITLE)
(Proof of Service) on reverse)
Rigo i 01 Z
ram Adopled for Ma,,Om",Use
Ledo or C�vA P,oCMure, rjrj ZOCq 41(�pZ0 7eAO,
judKAa` cou,lcd Or cworrha DEP05ITION SUBPOENA FOR PRODUCTION Gover rimeM Code. §6"7.1
SLBPQ10 1Rer Jam&yi,20121 OF BUSINESS RECORDS
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
1s
19
20
21
22
23
24
25
26
27
28
ATTACII\LENT 3
DEFINITIONS AND INSTRUCTIONS
1. "YOU" and "YOUR" mean CJTY OF LA QU1NTA and any PERSON (which; as
used in these requests, the teen "PERSON" as used herein means in the plural a`s well as the
singular and natural person, firm, association, partnership, corporation, public: entity, or any other
form of legal entity or governmental body unless the context indicates othenvise) acting on CITY
OF LA QUTNTA'S behalf, including but not limited to Agentsf employees, attorneys, accountants,
I investigators, part-ners, representatives, subcontractors, vendors, and insurance 4onipames.
2. "PROPERTY" means that real property located at 55075 Monroe Street, La Quinta,
Califomia 92253 (hereinafter referred to as "PROPERTY").
3. "DOCL'MF.NT" and " DOCi JMF,NTS" are defined as a `writing" pursuant to
California Evidence Code § 250, which includes handwriting, typewriting, printing, photostating,
photographing, and every other weans of recording upon any tangible thing and form of
communication or representation_ including letters, words, pictures, sounds, or symbols, or
combinations of them. The terms "DOCUMENT— and "DOCUMENTS" also include any
documents and/or information contained ut the memory of computer systems, on diskettes, or on
CD RC1(4is.
4. "REFERENCE TO" or "REFERENCING" or "PERTAINING" niearts consisting
of, relating to, evidencing. containing. discussing, showing, pertaining, reflecting, conferrin&
relating or referring to in any way, directly or indiroctly, and wlicn. used in reference to the
DOMMENTS, also include DOCUMENTS underlying, supporting, necessary for the
understaoding or, noxv or prey=ioush= attaebad or appended to, or used in the preparation of any
document referred to or requested by any request.
5. "CO1VfX1L.1N1CA'rION" or "CC1A•lR• uNICAT1ONS" mean and refer to any contact
fX4564".1
9111 M
1
2
3
4
5
6
7
9
10
I1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
between tvvo or more persons, which shall include. -without lunitation, written contact by such
means as letters, memoranda, telegrams, telex. phone messages. facsimiles, emails, or other
I DOCIJM NT'S.
6. "RELEVANT TIME PERIOD" shall mean the time period tram September 11,
12017, to the present.
DOCUMENTS TO BE PRODUCED:
1. Any acid all property inspections PERTAINING to the real property located at
55075 Monroe Street, La Quinta, California 92253 (hereinafter referred to as "PROPERTY') for
the RE,LEV.ANT TIME PERIOD.
2. Any and all building pen -nit applications submitted to YOU, for the RELEVANT
TIME PERIOD, PERTAINING to the PROPERTY.
3. AJiy and all temporary building permit applications submitted to YOU, from the
RELEVANT TIME PERIOD, PERTAINING to the PROPERTY.
4. Atiy and all temporary building permits issued by YOU, from the RELEVANT
TIME PERIOD, PERTAININTG to the PROPERTY.
5. Any and all constniction permit applications submitted to YOU, from the
RELEVANT TIME PERIOD, PERTAINING to the PROPERTY.
6. Any and all eonstntction perntits issued by YOU, from the RELEVANT TIME
PERIOD_ PERTAINING to the PROPERTY.
7. Any and all temporary construction pennit applications submitted to YOU, from
the RELEVANT TIME PERIOD, PERTAINING to thr PROPERTY.
8. Any and all temporary construction pentiits issued by YOU, from the RELEVANT
TIME: PERIOD. PERT.AdNING to the PROPERTY.
9. Copies of v11y and all Slion-Tenti Vacation Rental (hereinafter "STVR")
6045697.1
W13.3 5233
-2-
6045 W.1
5013,3 <23;
I applications subinitted to YOU. from the RELEV .ANT TIME PERIOD, PERTAINING to the
2 PROPERTY.
3 1 D. :Uuy and all STVR permits. active or suspended, issued to the PROPERTY during
4
tho.. Rw I.1•.VAN'F TIME PERIOD.
5
G 11. Any and all DOCUMF.,NTS PERMAININGto STVR Noise Compliance Devices at
7 the PROPERTY, including but not limited to Minut, NolseAware, or Party Squasher, front the
g RELEVANT TINIE PERIOD.
9 12. Copies of sviy parking violations issued at the PROPERTY during the RELEVANT
10 TIME PERIOD.
tl
13. Proof of payment for any parking violation fines made relating to the PROPERTY
12
dwing the RELEVANT TIME PERIOD.
13
14 14. Copies of any and all STVR citations issued to the PROPERTY during the
15 RELEVANT TIME PERIOD.
lG 15. Copies of any and all noise ordinance violation reports made pertaining to the
17 PROPERTY during the RELEVANT TIME; PERIOD.
18 16. Copies of any and all noise ordinance violation fines issued to the PROPERTY
19
during the RI LEVANT TIME PERIOD.
20
21 17. Proof ofpayntent for any and all noise ordinance violation fines made during the
22 REI.FVAKT TJME PERIOD; relating to the PROPERTY.
23 19. Copies of any and all viol ationsfines issued to the PROPERTY during the
24 RELE\•'} K,r TIME PERIOD.
25 19. Proof of payment. for anti and all violations fines relating to the PROPERTY during
26 the RELEVANT TIME- PERIOD.
27
20. Copies of an building capacity violations/citations issued during the RELEVANT
2s
-3-
1
2
3
4
5
6
7
8
9
10 1112
13
14
15
16
17
19
19
20
21
22
23
24
25
26
27
2S
I TIME PERIOD to the PROPERTY.
21. Copies of any and all appeals made to YOU during the RirI. EVANT TIME
PERIOD pertaining to the PROPERTY.
22. Any and all DOCUMENTS PERTAINING to ► omplaints made to the ST VR 24/7
Complaint Reporting 1-iotline during the RELF..VANT T1?%4E PERIOD about the PROPERTY.
23. Copies of any and all neighbor complaints ?Wade during the RELEVANT TIME
PERIOD PERTAINING to the PROPERTY.
24. Any and all DOCUMENTS PERTAINING to any Fire Department calls made to or
from the PROPERTY during the RELEVANT TIME PERIOD.
25. Copies of any and all reports of fire department visits to the PROPERTY made
during the RELEVANT TIME PERIOD.
26. Copies of any and all Fire Inspection reports made during the RELEVANT TIME
PERIOD PERTAINING to the PROPERTY.
27. Copies of any and all Fire Department approvals PERTAINING to the PROPERTY
during the RELEVANT TIME PERIOD.
28. Copies of any and all Alcohol Beverage Control ("ABC") approvals or licenses
submitted to YOU during the RELEVANT TIME PERIOD PERTAINING to the PROPERTY.
29. Copies of any and all Outdoor Dining Planning Applications submitted to YOU
during the RELEVANT TIME PERIOD PERTAINING to the PROPERTY.
30. Any and all banquet hall food handler licenses!pennits issued by YOU during the
RELE, VAA I' 'ITME PER10D PERTAINING to the PROPERTY.
31. Copies of any and all COMMUNICATIONS made during the RELEVANT TIME
PERIOD YOU amid James Scott about the PROPERTY.
32. Copies of any and all COMMUNICATI( S made during the RELEVANT TIME
694569'-1
ctpl-j a2jj
4-
6tw=WA
'013-35131
I PERIOD between YOU and Danielle about tI}c PROPERTY.
2 33. Copies of any and all C:OM-MLINICATIONS made during the RELEVANTTIME
3 PERIOD between YOU and Forbes Realtv about the PROPERTY.
4
34. Copies of any and all COMMUNICATIONS made during the RELEVANT TIME
5
PERIOD between YOU and R-vaji Nall about the PROPERTY.
G
7 35. Copies of any and all COMMUNICATIONS made during the RELEVANT TIME
g PERIOD to YOU about the PROPERTY.
9 36. Copies of any and all COMMUNICATIONS during the RELEVANT TIME
10 PERIOD froiu YOU about the PROPERTY.
11
END OF DOCUMENT.
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
2R
. i.
��p AMERICAN
d atafied 1' PB BUSINESS BANK 055100
Lao aHCAsi.. sur. sou
1210 N. Jefferson St., Suite P t�g-0 jo Anaheim, CA 92807 16-4280/1220
(714) 632-3480
O
TO THE � A
ORDER OF �
DATE `71Al2-g AMOUNT
� f �
SO
PAY f i i ` �n
r Z
AUTHORIZED SIGNATURE NP
11■0 5 5 L0011' 1: L 2 204 280 7l: 04 50 200011'
ATTORNEY Oft PARI*Y W 1111OUT ATTORNEY: f1 LEPHONE NO.:
CASE NUN MER:
ANNA K. GRET:NST)N S11N CA: 225.129 (714) 634•2522
PSC1905078
A,111M. LLP
199UO MACARTHUR BLVD., SUITI•: 1150
IRWNE. CA 92612
ATTORNEY FOR: SUSAN HARVi:Y AND DESERT PACIFIC PROPERTIES, INC.
NAMF OCOUIT, WVL-RSIDE
STRFFT ADDRESS: PALM SPRINGS COURTHOUSE
MAILING ADDRESS: 3255 F_, T'AHQUIT7.. CANYON WAY
CrFY AND ZIP CODE: PALM SPRINGS, CA 92262-
GRANCI I NANT-.
PLA1NTEF'F/PETITIONFR• i-%Nws eorr WRRIDW FT Al...
PROOF OF SERVICE
DEFENDM'TlRCSPONDr'NT: BRENT BILL ET AI...
PROOF Of SERVICE — CCP 1013a, 2015.5.
1 am employed in the couttla• of Alameda. I am over the age of eighteen (18) years and not a party to the within action; my business address is 130
Webster Street, Suite 100. 6,11and, CA 94607.
On the elate set forth helon _' I served the within copies of deposition subpoenas, uicluding Notice to Consumer pursuant to CC? 1985.3 / Notice to
Employ pursuant to 1985_6 (if applicable), on the following parties in said action, by mail, facsimile or by a -snail to the following address/fax
number or a -nail address as follows:
NUSSAMAN LLF
AM JOHN J. FLYNN
18 10 1 VON KARMAN AVE.
S-IF 1800
DUVNE, CA 92612
i llyYul(alnossama n.co n►_
JACKSON TIDUS
ATTN: CHARLES M. CLARK
2031) MAIN STRFFT,
SUITE 1200
IRVINC. CA 9261.4
cclark(d jacksontidus lass:
(949)752-0597
MURCHISON etc CUMMING, LLP
ATTN: PETER A. MARTD4
18201 VON Kr1RMAN AVENUE
SUITE 1100
rRVNF.. CA 92612
pinartin�anwnauwnlrn. CUM-
(714) 972.1404
1 declare raider penalty of perjure that 1he roregoittg is trite and correct_
Exexutad on .Tune 29. 2022 at Oakland. Califclrnia.
NOSSAMAN LLP
ATTN: GABRIELA S. PEREZ
777 S Figueroa Street,
3 4th Floor
Los Angeles, CA 90017
"pCrCz'@nossa111w1. cozn-,
(213)612-7801
BLASDEL GUINAN LAWYERS
AITN� DL4ATE C_ BLASDEL
P.O. BOX 1747
PALM SPRINGS, CA 92263
dianela?bgdesertlaw com;
(760)320-0211
/S_/-Mrnihy Mms
Doroth'v Mays
RccordTr k
PLAINTIFFIPETIT-_ R:JAM5S SCOTT MORROW ET At - _.... — -- CASF14LIMBER -
PSC1905078
DEFENDANTfRESPONVENT: BRENT DILL ET AL..
PROOF OF SF..RVICE OF NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION
(Code Civ. Proc., §§ 1985.3,1985.6)
=Personal Service = Mail
1. At the time of service I was at least 16 years of age and not a party to this legal action.
2 1 served a copy of the Notice to Consumer or Employee and Objection as follows (check either a or b):
Personal service. I personally delivered the Notice to Consumer or Employee and Objection as follows:
(1) Name of person served: (3) Date served:
(2) Address whereserved: (4) Timeserved:
b- rx" Mail. I deposited the Notice to Consumer or Employee and Objecl+on in the United States mail, in a sealed envelope
with postage fully prepaid. The envelope was addressed as follows:
(1) Name of person served: JOHN J. FLYNN (3) Date of mailing: 06129/2022
(2) Address: NOSSAMAN LLP (4) Place of mailing (city andstate):
16101 VON BARMAN AVE. IRIVNE, CA 92612 Oakland, CA 94607
(5) 1 am a resident of or employed in the county where the Notice to Consumer or Employee and Objection was mailed.
c My residence or business address is(specify): 130 Webster Street, Suite 100 Oakland, CA 94607
d. My phone number is (specify): (800) 220-3200
1 declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Date: 06129/2022
Dorothy Mays ISi Dorothy Mays
(TYPE OR PRINT NAME OF PERSON WHO SERVED) JhKiNAr
_ PROOF OF SERVICE OF OBJECTION TO PRODUCTION OF RECORDS
(Code Civ. Proc., §§1985.3,1985_6)
= Personal Service M Mail
1 At the time of service I was at least 18 years of age and not a party to this legal action.
2. 1 served a copy of the Objection to Production of Records as follows (complete either a orb):
a. ON THE REQUESTING PARTY
(1) M Personal service. I personally delivered the Objection to Production of Records as follows:
(i) Name of person served: (iii) Date served:
(ii) Address whereserved: (iv) Time served:
(2) Mail. I deposited the Objection to Production of Records in the United States mail, in a sealed envelope with
L___J postage fully prepaid. The envelope was addressed as follows:
(i) Name of person served: (iii) Date of mailing_
00 Address: (iv) Place of mailing (city andstate):
(v) I am a resident of or employed in the county where the Objection to Production of Records was mailed.
b. ON THE WITNESS
(1) [] Personal service. I personally delivered the Objection to Production of Records as follows:
(i) Name of person served: (iii) Date served:
(ii) Address where served: (iv)Time served
(2) Mail. I deposited the Objection to Production of Records in the United States mail, in a sealed envelope with
postage fully prepaid. The envelope was addressed as follows:
(i) Name of person served: (iii) Date of mailing:
(ii) Address: (iv) Place of mailing (city andstate):
(v) I am a resident of or employed in the county where the Objection to Production of Records was mailed
3. My residence or business address is(specify).-
4 My phone number is(spw#y):
i declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Date:
t
(TYPE OR PRINT NAME OF PERSONWHOSERVEO)
(SIGNATURE OF PERSON WHOSERVED)
suer-025[Rev January 1.2MI NOTICE TO CONSUMER OR EMPLOYEEAND OBJECTION Page 2of2
PLAiNTIFFWETITIONER:,IAMES SCOTT MORROW ET AL.,
OEFENDANDRESPONDENT, BRENT DILL ET AL.
CASE NUMBER i
PSC1906078
PROOF OF SERVICE OF NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION
(Code Civ. Proc., §§ 1986.3,1985.6)
Personal Service ® Mail
1 Al the time of service I was at least 18 years of age and not a party to this legal action.
2 1 served a copy of the Notice to Consumer or Employee and Objection as follows (check either a orb):
a. L7 Personal service. I personally delivered the Notice to Consumer or Ernptoyee and Objection as follows:
(11 Name of person served: (3) Date served:
(2) Address where served: (4) Time served:
b '� Mail. I deposited the Nouce to Consumer or Employee and Objection in the United States mail, in a sealed envelope
with postage fully prepaid. The envelope was addressed as follows:
(1) Name of person served: GABRIEL_A S. PEREZ (3) Date of mailing: 06/29/2022
(2) Address: NOSSAMAN LLP (4) Place of mailing (city and State)-,
777 S Figueroa Street, Los Angeles, CA 90017 Oakland, CA 94607
(6) 1 am a resident of or employed in the county where the Notice to Consumer or Employee and Objection was mailed.
c- My residence or business address is(specify): 130 Webster Street, Suite 100 Oakland, CA 94607
d- My phone number is(specify).- (8170) 220-3200
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Date: 0612912022
Dorothy Mays /S/ Dorothy Mays
(TYPE OR PR INT NAMF. OF PERSON WHO SERVED)
-------------
PROOF OF SERVICE OF OBJECTION TO PRODUCTION OF RECORDS
(Code Civ. Proc., §§ 1985.3,1985.6)
Personal Service = Mail
1. At the time of service I was at least 18 years of age and not a party to this legal action.
2. 1 served a copy of the Objection to Production of Records as follows (comp)ete either a orb):
a. ON THE REQUESTING PARTY
(1) [_� Personal service, I personally delivered the Objection to Production of Records as follows:
(i) Name of person served: (iii) Date served:
(ii) Address where served: (iv) Time served:
(2) Mail, I deposited the ObojecUon to Production of Records in the United States mail, in a sealed envelope with
postage fully prepaid. The envelope was addressed as follows:
(i) Name of person served: (iii)Date of mailing.-
(ii) Address: (iv) Place of mailing (city andstate):
(v) I am a resident of or employed in the county where the Objection to Production of Records was mailed.
b- ON THE WITNESS
(1) Personal service. I personally delivered the Objection to Production of Records as follows:
(i) Name of person served: (iii) Date served:
(ii) Address where served: (iv) Time served:
(2) O Mail. 1 deposited the Objection to Production of Records in the United States mail, in a sealed envelope with
postage fully prepaid. The envelope was addressed as follows:
(i) Name of person served: (iii) Date of mailing:
(ii) Address: (iv) Place of mailing (city andstate):
(v) i am a resident of or employed in the county where the Objection to Production of Records was mailed.
3 My residence or business address is(specify):
4. My phone number is(speeify):
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct
Date-,
(TYPE OR DRINT NAME OF PERS014WHOSFRVEOI
jS7GNAlURE OF PERSON WHnSFRVFl7)
SUSP-025(Rev Jantroy1.2CO81 NOTICE TO CONSUMER OR EMPL•OYEEAND OBJECTION Page 2of2
AT TORNf~Y OR PAR T LVITHOU7 AITORNEY (Name SWe BAr rwmiu C4 dnd 6 MOSs)
ANNAK GREENSTIN SON CA: 225429
WFBM, LLP
19900 MACARTHUR BIND SUITE 1150
IRVINE, CA 92612
TELEPHONE NO., (714) 634-2522 FAX NO.:
EMAIL ADDRESS:
ATTORNEY FOR INarwj: SUSAN HARVEYAND DEsEKr PACIFIC PROPERTIES, INC.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF RIVERSIDE
STREET ADDRESS: PALM SPRINGS COURTHOUSE
IIIAILING ADDRESS: 3255 E. TAHQUITZ CANYON WAY
CITY AND ZIP CODE: PALM SPRINGS, CA 92262-
BRANCH NAME:
PLAIN71FF(PETITIONER: JAMES SCOTT MORROW ET AL.,
OEFENDANT(RESPONDENT- BRENT DILL ET AL.,
NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION
(Code Civ, Proc., §§ 1985.3,1965.6)
NOTICE TO CONSUMER OR EMPLOYEE
SUBP-025
FOR! COURT USE onLY I
CASE NUMF ECR
PSC 1906078
TO (name): MONROE STREET PROPERTY
1 PLEASE TAKE NOTICE THAT REQUESTING PARTY (name): SUSAN HARVEY AND DESERT PACIFIC PROPERTIES, INC.
SEEKS YOUR RECORDS FOR EXAMINATION by the parties to this action on (specify date): 07/27/2022
The records are described in the subpoena directed to witness (specify name and address of person or entity from whom records
are sought): CITY OF LAQUINTA 79496 CALLE TAMPICO ,LA DUINTA, CA 92263
A copy of the subpoena is attached.
2. IF YOU OBJECT to the production of these records, YOU MUST DO ONE OF THE FOLLOWING BEFORE THE DATE SPECIFIED.
IN ITEM a. OR b. BELOW:
a If you are a party to the above -entitled action, you must file a motion pursuant to Code of Civil Procedure section 1987.1 to
quash or modify the subpoena and give notice of that motion to the witness and the deposition officer named in the subpoena
at least five days before the date set for production of the records.
b. If you are not a party to this action, you must serve on the requesting party and on the witness, before the date set for
production of the records, a written objection that states the specific grounds on which production of such records should be
prohibited. You may use the form below to object and state the grounds for your objection. You must complete the Proof of
Service on the reverse side indicating whether you personally served or mailed the objection, The objection should not be filed
with the court_ WARNING: IF YOUR OBJECTION IS NOT RECEIVED BEFORE THE DATE SPECIFIED IN ITEM 1, YOUR
RECORDS MAY BE PRODUCED AND MAY BE AVAILABLE TO ALL PARTIES-
1 YOU OR YOUR ATTORNEY MAY CONTACT THE UNDERSIGNED to determine whether an agreement can be reached in writing
to cancel or limit the scope of the subpoena_ If no such agreement is reached, and if you are not otherwise represented by an
attorney in this action, YOU SHOULD CONSULT AN ATTORNEY TO ADVISE YOU OF YOUR RIGHTS OF PRIVACY.
Date: 06129/2022
ANNA K. GREENSTIN
TYPE OR PRINT NAME)
fSl ANNA K. GREENSTIN
(SIGNATURE OF Q RE-QUE.S71NG PARTY l-_. ] ATTORNEY)
OBJECTION BY NON-PARTY TO PRODUCTION OF RECORDS
I j I object to the production of all of my records specified in the subpoena
2. [_� I object only to the production of the following specified records:
3 The specific grounds for my objection are as follows:
Date:
{TYPE; OR PRINT IJAME)
Form Apoplaa for Mandafarylfse
J0icial Council d Ca Itorn is
SUAP.029 (RV January 1 2MT
(SIGNATURE)
(?roof oI service on ievetw) Page 102
NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION °�" 85.3 "85.6.
§§ 19Ei5.3 1965.6,
2= 010-2020 510
wwn• coutdo ca 90r
N,^
Mm^lG ? 130 Webster Street, Suite
100
::
Oakland, CA 946D7
Phone: (800) 355-5771
Fax: 4610) 486.3652
Email: rcu(&.magI]Als.com
* 3 7 4 8 7 1 1
June 29. 2022 863735
CITY OF LAQUINTA Re: MONROE STREET PROPERTY
CUSTODIAN OF RECORDS
78495 CALLS TAMPICO
LA QUINTA, CA 92253 A.K.A.: 55075 MONROE STREET
SSH: M-104-0-
00B. / / D()D: / /
Fuz N: 374871 TA(3#: l
Dear Record Custodian:
Attached please find a subpoena for the release of records pertaining to above referenced
individual.
The use of the subpoena complies with the requirements of 45 CFR 164.512(e)(1). "A
covered entity may disclose protected health information in the course of any judicial or
administrative proceeding: (ii) in response to a subpoena..."
Proper notice has been given to the individual who is subject of these records. A copy of
the notice and proof of service of the notice as required by CCP 1985.3 (or 1985.6) is
also attached to this request.
Please contact our office at your earliest convenience to arrange for the records to be copied or for
pricing approval for your ofxice to supply a copy of the records. Should you have any questions,
please do not hesitate to call.
Very Truly Yours.
Records Representatii�e
Phone: (800) 3WS771
PLEASE SIGN A TTACHED AFFIDA VIT
S-07/ l 112022
OAKLAND RECORD CUSTODIAN FEE ACCotwT
130 WEBSTER STREET. SUITE 100
OAKLAND, CA W07
(510) 465.3200 Inv. #: 06292022
RE: MONROE STREET PROPERTY 374871,001
PAY FIFTEEN AND 00/100 DOLLARS
000-220-BANOrr3mroom
VMV] C-010N AV,AX Ukl-*PQ V" WAY" PI40T6CiM
3-738D 2M
863735
TOTHE ME AMWJNT 8
ORDER of 06/29/2022 $15.00
CITY OF LAQUINTA
Attn: CUSTODIAN OF RECORDS NOT VALID OVER $10M.00 �
78495 CALLE TAMPICO
LA OUINTA, CA 92253
MUMS
e' 86 3 7 3 51i` 1: 2 360 7 360 i1: 0 70 2 2 1 015ia
RECORDTRAK (510) 46532M
D612912022
Status: WAIT..
Case: MONROE STREET PROPERTY Office: C
COURT: CA-RCSC-PALM PSC1906078 CITY OF LAQUINTA
AMOUNT: 15.00
INVOICE: 06292022
VOUCHER NUMBER: 863735 RT PREPARER: ACOOMBS
RT #: 374871 Tag: 1 C.CT05 CITYAGREE: Y
OW29/2022
NO. 863735
$l w� uwum *w twpwr k(IEOtOERfiDYYO{Mt44f�11S11F'fiWINf1C161iIg1AGfRIFlAN10WW.GlL P1f2
REQUEST FOR RECORDS
Attn: Medical Records Department
Records for Monroe Street Property are being requested for
litigation processing.
Doctor ID #: 863177
City of Laquinta
78495 Calle Tampico
La Quinta, CA 92253
datafled'"
Sent:7/12/2022 Ph.#(714) 632-3480
Ship via: Order: 6922403-1
PATIENT INFORMATION
Name: Monroe Street Property -
AKA: 55075 Monroe Street
SSN:
DOB:
MR/ID #:
REQUEST NOTES:
374871-1 Serve on or after 7/11/2022. (1 of 2) Custodian of Records
Please choose your method of record submission
The maximum fee limit for this request is $15. Additional fees must have prior approval.
Upload records to our HIPAA compliant portal at https://secure.datafied.com/records
The fastest and most secure way to submit your records.
Send Encrypted Email with Records
If you have an encrypted email service you may email records to: erecords@datafied.com
Fax records to (800) 922-3892, Datafied's secure fax line
Please use this page as your cover sheet. Number of pages
Mail records to 1210 N. Jefferson St. Suite P, Anaheim, CA 92807
Please include this page as your cover sheet when mailing the records.
If you have an In -House copy service. Please fill out fields below and fax back to us at (800) 922-3892
Company Name: Contact Number: Expected Copy Date:
If you have any questions please visit https://secure.datafied.com/records or call (714) 632-3480
Litigation Request - 7/12/2022
00J3
CERTIFICATE OF NO RECORDS
i datafled'"
Attn : Medical Records Department
City of Laquinta
78495 Calle Tampico
La Quinta, CA 92253
If you do not have the requested records for Monroe Street
Property, please complete the information below and fax back
to (800) 922-3892
PATIENT INFORMATION
Name: Monroe Street Property
SSN:
DOB:
MR/ID #:
REQUEST NOTES
374871-1 Serve on or after 7/1112022. (1 of 2) Custodian of Records
Order: 6922403-1
Please check the appropriate box below and sign prior to to faxing to (800) 922-3892
This patient is not on our list of assigned patients and has never been seen here.
Patient was not seen during the requested time frame.
Patient scheduled appointment but was never treated.
These medical records have been lost or destroyed.
Similar patient data exists as:
Other
Explain
I have searched for this patient by name, date of birth and social security number (if provided).
i declare under penalty and under the laws of
Executed
Signed:
(DATE)
that the foregoing is true and correct.
(STATE)
at ,
(CITY) (STATE)
Print Name:
(SIGNATURE OF THE CUSTODIAN OF RECORD)
If you have any questions please call (714) 632-3480
APS CN R - 7/12/2022
nn?a
To Request On -Site Scanning
Fax This Page to (800) 922-3892
� dataf led' -
Order: 6922403-1
Request to have a Datafied representative scan the records on site
Visit https,//secure_datafied.com/records to schedule record scanning or fill out the information below
then fax this page to us at (800) 922-3892
Your facility's preferred days and hours for scanning:
Monday Tuesday Wednesday Thursday Friday
Open for Lunch?
Size of Records:
❑Yes []No
inches
Facility Address: 78495 Calle Tampico, La Quinta, CA 92253
Address of Records (if different):
Requested Fee (if applicable): $
Contact Person -
Special Instructions:
Status: ❑ Ready to scan ❑ Not ready to scan yet ❑ Do not have records
Tired of handling record requests? We can do it for you, for free!
Datafied helps physicians and hospitals eliminate the time consuming and costs related to retrieving, copying,
tracking and managing medical records requests. Visit https://secure.datafied.com/records to learn more.
City of Laquinta
Doctor ID: 863177
78495 Calle Tampico
La Quinta, CA 92253
PATIENT INFORMATION
Name: Monroe Street Property - AKA: 55075 Monroe
Street
SSN:
DOB:
MR/ID #:
KRY4%TAW94fter 7/11/2022. (1 of 2) Custodian of
Records
If you have any questions please visit https://secure.datafied.com/records or call (714) 632-3480
7/12/2022
0091)