2022-12-05 - Rosewood Ct 57865 Subpoena - Internal CorrespondenceMonika Radeva
From: Monika Radeva
Sent: Monday, December 5, 2022 9:05 AM
To: Laurie McGinley
Cc: Monika Radeva
Subject: SUBPOENA for Records - 57865 Rosewood Ct - Due 12/5/2022
Attachments: 4588.pdf, Subpoena for Records 2022-11-29 - 57865 Rosewood Ct.pdf
Follow Up Flag: Follow up
Flag Status: Completed
I contacted Nationwide Legal this morning, we can email them the response to
dsolutions@nationwidelegal.com
Reference in the Subject Line: Control # OC114014 (listed on the cover page of the subpoena
packet we received)
I will prepare shortly and send it out.
Monika Radeva, CMC I City Clerk
City of La Quinta
78495 Calle Tampico, La Quinta, CA 92253
Tel: (760) 777-7035
MRadeva@laquintaca.gov
From: Monika Radeva <mradeva@laquintaca.gov>
Sent: Monday, December 5, 2022 8:31 AM
To: Monika Radeva <mradeva@laquintaca.gov>
Cc: Laurie McGinley <Imcginley@laquintaca.gov>
Subject: SUBPOENA for Records - 57865 Rosewood Ct - Due 12/5/2022
The response for this subpoena has been drafted - link below.
N:\900 RISK MANAGEMENT\Subpoenas for Records & Depositions\Rosewood Ct 5786 - Raymond
Stockstill III v. CalAtlantic Group 2022
We just need to call them to find out if we can produce them electronically or if we should mail a
thumb drive, adjust the response letter, and send it out. I'd like to get this out today if possible.
1. YOU ARE ORDERED TO PRODUCE THE BUSINESS RECORDS described in item 3, as follows:
To (name of deposition otfrcer):ldationwide Legal, LLC
on (date) :December 9, 2022 At (time):10:04 a.m.
Location (address):1609 .Tames M. Wood Blvd 2nd rlr, Los Angeles, CA 90015, 877) 326-2679
Do not release the requested records to the deposition officer prior to the date and time stated above.
Monika Radeva, CMC I City Clerk
City of La Quinta
78495 Calle Tampico, La Quinta, CA 92253
Tel: (760) 777-7035
i
MRadeva@laguintaca.gov
From: Amy Yu <Ayu@laguintaca.gov>
Sent: Wednesday, November 30, 2022 9:44 AM
To: AJ Ortega <Aortega@laquintaca.gov>; Monika Radeva <mradeva@laquintaca.gov>
Cc: Laurie McGinley <Imcginley@lag uintaca.gov>
Subject: RE: SUBPOENA for Records - 57865 Rosewood Ct - Due 12/5/2022
Hi Monika,
In the Engineering Archive, 06233 and 05209 relates to the Subject Property. Rough grading permit is attached.
That's all the records I found.
Amy Yu I Associate Engineer
City of La Quinta - Public Works
N 78495 Calle Tampico o La Quinta, CA 92253
Ph. 760.777.7047
Main: 760.777.7000
Q-
www.la uintaca.
q 9ov
www.playinlaquinta.com
From: AJ Ortega <Aortega@laquintaca.gov>
Sent: Wednesday, November 30, 2022 7:43 AM
To: Monika Radeva <mradeva@laquintaca.gov>; Amy Yu <Ayu@laquintaca.gov>
Cc: Laurie McGinley <Imcginley@lag uintaca.gov>
Subject: RE: SUBPOENA for Records - 57865 Rosewood Ct - Due 12/5/2022
Monika,
I reviewed the records that returned from Laserfiche for the referenced address, these appear to be all the
permit records at the property — The tract construction plan set number is 00457 and per the permit
miscellaneous information it is a Plan 1SC.
The grading plans can be found in the engineering archive with the Tract Number 32279.
AJ
From: Monika Radeva <mradeva@laquintaca.gov>
Sent: Tuesday, November 29, 2022 6:11 PM
To: AJ Ortega <Aortega@laquintaca.gov>; Amy Yu <Ayu@laquintaca.gov>
Cc: Monika Radeva <mradeva@laguintaca.gov>; Laurie McGinley <Imcginley@laquintaca.gov>
Subject: SUBPOENA for Records - 57865 Rosewood Ct - Due 12/5/2022
Hi AJ and Amy,
The City was served with the attached subpoena for records for the property located at
57865 Rosewood Ct.
h'S 0BJ-BC ' PROPERTY' as used herein shall rmcaii the propeM located a[ 57865 Rosewood
Court, La QtLinta, CA 92253,
N
Page 7 of the attached PDF lists the documents requested - it is all building and
engineering plans and related documents.
Please take a look and provide all responsive documents that you have by end -
of -day on Monday, 12/5/2022.
DOCUMENTS TO RE PRODUCED
1. Any and all DOCUMENTS which refer or relate to the SUBJECT PROPERTY.
2_ Any and all DOCUMENTS which evidence, constitute, refer, or relate to YOUR review
of the PLANS.
3, Any and all DOCUMENTS which evidence, constitute, refer, or relate to YOUR
approval of the PLANS.
4. Any and all DOCUMENTS which rvidence, constitute, refer, or relate to YOUR review
of the REVISED PLANS.
5. Any and all DOCUMENTS which evidence, constitute, refer, or relate to YOUR
approval of the REVISED PLANS.
b. Any and all DOCUMENTS which relate to the preparation of the L-MORANDUM.
7. Any and all DCHCUMENTS which relate to the statement in the Fxecutive Summary of
the MEMORANDUM that "The September $ storm was categorized as a 240-year event in north
La Quint and between a 400 -year to 1,000-year event in south La Quinta."
8. Any and all DOCUMENTS which evidence, constitute, refer, or relate to YOUR ru"cw
of the PLUMBING PLANS.
9. Any and a] I DOCUMENTS wh ich evidence. constitute, refer, or relate to YOUR
approval of the PLLTMBTNG PLANS.
IT Any and all DOCUMENTS which evidence, constitute, refer, or rclatc to YOUR review
of the ATRJUM DRAIN STANDARD DETAIL.
11, Any and all DOCUMENTS which evidence, constitute. refer, or relate to YOUR
approval of the ATRIUM DRAIN STANDARD DETAIL.
12. Any and all DOCUMENTS which evidence, constitute, refer, or relate tea YOUR review
of the IIF.CFMBER 11, 2006 LOT 13-15 PRECISE GRADING PLAN .
13_ Any and a]i DOCUMENTS which evidence. constitute, refer, or relate to YOUR
apprmral of the DECEMBER 11, 2006 LOT 13-15 PRECISE GPADTNC PLAN_
Thank you.
Monika Radeva, CMC I City Clerk
City of La Quinta
78495 Calle Tampico, La Quinta, CA 92253
Tel: (760) 777-7035
O� MRadeva@laquintaca.gov
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