XXX
XXX
Petitioners, In Pro Per
XXX BANKRUPTCY COURT CENTRAL DISTRICT STATE OF XXX
| In RE:
XXXX Debtors XXX Plaintiffs XXX & XXX Defendants |
Adv. Case # 9:XXX
BK Case No:XXX Chapter 7 Declaration of Plaintiffs Honorable Judge XXX Date: Time: Courtroom: |
DECLARATION OF PLAINTIFF’S MOTION TO COMPEL DISCOVERY RESPONSES; MEMORANDUM OF POINTS OF AUTHORITY IN SUPPORT THEREOF; and MONETARY SANCTIONS TO COMPEL DISCOVERY
To The Honorable Judge XXXt:
Plaintiffs XXXX, being duly sworn, depose and state as follows:
- THAT on XXXX, this Honorable Court issued an Order denying Plaintiffs’ Motion to Compel Discovery on the ground that the said Motion failed to adhere to XXXX. This Court thereby advised that Plaintiffs could file the said Motion without the said stipulation, if the Motion is accompanied by a Declaration in that effect.
- THAT Plaintiffs hereby file this Declaration pursuant to the said Court Order,.
- THAT on or about [ENTER DATE], Defendant(s) responded to the Plaintiffs’ requests in the following manner:
REQUEST NUMBER 1. Provide a copy of the check (s) evidencing and establishing your allegation that Defendants paid Teena Colebrook in full for her items consigned with Timeless Treasures.
DEFENDANTS RESPONSE TO REQUEST #1 Objection. Plaintiff has them. Without waiving the objection, all accounting concerning XXXX consigned items as well as payment dates, check numbers and date payment cleared the bank was provided to XXX via her ConsignPro account, to which she had access to for over 3 years, and for 6 additional months after the store was closed. It was also emailed to her. With that said I am able to provide copies of the cleared checks. I ordered them from Wells Fargo. I will not be able to do this for all consignment checks as I no longer bank with WF and they are $12.00 for each check for which I have no money to pay.
DEFICIENCIES. Plaintiff does not have these check copies. Said copies were never emailed despite a promise to do so. According to James at Wells Fargo check copies are $5 per check not $12 as Defendant’s state and take from 7-10 business days to produce upon request. As Defendant stated in their January 19th, 2021 response that they had been ordered there is no reason for their non-production. These check copies are relevant to show how much Plaintiff Colebrook was paid versus what she is owed.
REQUEST NUMBER 4. Provide written proof of your evidence that Plaintiff was accused of fraud in other BK proceedings. Provide documentary evidence, email, or testimony that your current attorney told you to put this irrelevant information into your answer.
DEFENDANTS RESPONSE TO REQUEST #4 To the extent available, Defendant will produce these documents.
DEFENDANTS ATTORNEY EMAIL RESPONSE TO A REQUEST FOR MISSING DISCOVERY DATED APRIL XXX. #4. See case number 2:14-bk-10853-WB. See the attached court docket, and docket #32, the Motion For Relief From the Stay that I personally mailed to you on 5/12/2014. so, you already have this document from your XXX bankruptcy case.
DEFICIENCIES. Plaintiff Colebrook asserts that submitting this claim from 2014 into this court is irrelevant to the current case and was meant to defame and slander Colebrook. Attorney XXXX fails to note that plaintiff submitted a sworn affidavit rebutting every statement of Attorney XXX then client. Nothing further was heard from Attorney XXX or his client after Colebrook’s sworn affidavit proved his client was committing perjury. It is relevant to the case as it shows that Defendants and their attorney are not being candid with the court.
REQUEST NUMBER 7. Photocopies of any and all documents including all internal customer record(s) (commonly known as a customer ledger, account histories, or A/R Ledgers) that show the invoice dates, numbers, and amount and the payments received by movant from Defendant, for the account relationship between movant(s) and Defendant(s) for the Applicable Period.
DEFENDANTS RESPONSE TO REQUEST #7 Objection, vague, ambiguous, and confusing. Without waiving the objections. TTHC had sales reports for each day, however Defendant does not have them because she does not have the ConsignPro software or records.
DEFICIENCIES. Plaintiffs state that the request is not confusing, and Defendant is able to request the records from ConsignPro, they are relevant to the case to prove what if anything was itemized in the store and paid out to all plaintiffs and what they are still owed.
REQUEST NUMBER 8. Any and all documents which Defendant(s)intend to introduce into evidence or mark as an exhibit at the trial in this adversary proceeding.
DEFENDANTS RESPONSE TO REQUEST #8 See Defendants Rule 7026 initial disclosures, which documents will be or have been provided.
DEFENDANTS ATTORNEY EMAIL RESPONSE TO A REQUEST FOR MISSING DISCOVERY DATED APRIL 19TH, 2021. #8. Defendants are still looking for documents.
DEFICIENCIES. Plaintiffs are still waiting for said documents and these are relevant to prepare for trial.
REQUEST NUMBER 11. Any and all state and federal tax returns from 2016 through 2020.
DEFENDANTS RESPONSE TO REQUEST #11 To the extant available. Defendant will produce these documents.
DEFENDANTS ATTORNEY EMAIL RESPONSE TO A REQUEST FOR MISSING DISCOVERY DATED APRILXXX. #11. they will be provided upon receipt.
DEFICIENCIES. Plaintiffs assert that Defendant has had ample time to request and receive these documents from the IRS and/or her bookkeepers. These returns are essential for Plaintiffs to prove that Defendants have failed to speak with candor to the court and may have committed perjury.
REQUEST NUMBER 13. Provide all names and all statements of the 5 or more banks that upon information and belief Plaintiff believes Defendant has or has had access to since 2016 through present; Both business and personal, including all credit card accounts, with addresses, which you now have available for cash advances and state amount balances of each checking, savings, and credit card(s).
DEFENDANTS RESPONSE TO REQUEST #13. The banks which personal and business accounts were held during the operation of the store were as follows: Wells Fargo, US Bank, Rabo Bank. Defendant does not have the accounts or bank statements. Defendant currently banks with Chase Bank. Both accounts were opened long after the store closed. Defendant does not have a savings or a line of credit. To the extent available. Defendant will produce these documents.
DEFENDANTS ATTORNEY EMAIL RESPONSE TO A REQUEST FOR MISSING DISCOVERY DATED APRIL XXX. There are not 5 bank accounts, so the documents do not exist. Bank statements have been provided for the banks which Defendants have or had accounts and to which they have access. If you think there are more bank accounts, tell us. Or go subpoena the records.
DEFICIENCIES.
Plaintiffs have received incomplete records from XXX Bank and Rabobank. Plaintiffs have received no records from US Bank or Chase Bank or any credit cards that Defendants had during XXX. Plaintiffs assert that full bank records are necessary to prove our claims of fraud and nonpayment to certain creditors. Plaintiffs called 3 of the known banks though the District attorney’s office stated that there were more than 2 accounts and less than 10 in Defendants names.
WELLS FARGO
According to XXX at XXX retention period is 7 years; check copies are $5 per check both personal and business accounts even on closed accounts not $12 as Defendants stated and take from 7-10 business days to produce upon request. Statements are free and take 7-10 business days to receive.
US BANK
Per – XXX at US Bank on XXX. XXX statements are free, 4-5 or more $7 a statement. Time to produce them depends on the type of request and how long account has been closed but no longer than 30 days.
MECHANICS BANK (formerly RABOBANK)
Lisa at Mechanics Bank (formerly Rabobank) on 2276 Broad St. (805) 541-5500 states retention period is 5 years. Longest it would take would be about a week to send out from request.
REQUEST NUMBER 14. Any and all consignment payments that Defendants have forwarded to plaintiffs in the past four years.
DEFENDANTS RESPONSE TO REQUEST #14 Defendant has ordered the cleared checks for consignment payments for Teena Colebrook. XXX is not a TTHC consignor, therefore has never been paid. And Defendant is unable to provide this information for Kevin Rock or Colleen Craig without the ConsignPro software, as she is unable to see the check numbers and dates posed. Documents will be produced upon receipt from the banks.
DEFENDANTS ATTORNEY EMAIL RESPONSE TO A REQUEST FOR MISSING DISCOVERY DATED APRIL 19TH, 2021 #14. by definition you already have the documents. XXX is not a TTHC consignor, therefore has never been paid.
DEFICIENCIES. Answer is insufficient, If Defendants had ordered the cleared checks as stated they should have produced them by now. Defendants know and have always known that XXX is the husband of Roxanne as he bought the couples marital property to the store and was introduced as her husband. His wife is too distraught over the whole situation to deal with it and asked her husband XXX r to deal with the case. Defendants can request information from ConsignPro and have still not produced requested documents months later. Plaintiffs assert that these documents are essential to the case for proving the defendants have not been truthful.
REQUEST NUMBER 17. Any and all dates, names, addresses, telephone number, receipts and correspondence between Defendant(s) and any friends, family members, associates, or employee(s) of the Defendants, relating to the any and all “transfers” of plaintiff’s artwork, whether sold, given away, or donated.
DEFENDANTS RESPONSE TO REQUEST #17 No such documents existed. There are no family members, friends or employees who have transferred any property of Plaintiff and or have ever owned, purchase, received as a gift or donation any item consigned by Plaintiff. Plaintiff consigned with TTHC over a 3-year period of time. Pursuant to the signed contract. TTHC had the right to donate any item considered abandoned under the time frames listed in the signed contract. As a general rule, TTHC donated largely to Mission Thrift and the Assistance League. Thousands of items were donated each year from the smallest teacup to the largest TV cabinet. Items were not tracked that way. Any items left at the time of the store closing went to 805 Premier for the sales. This list was provided via email to Plaintiff after the sale was complete. She stated the items document as hers were not.
DEFICIENCIES. Defendant’s statement is untruthful as Defendant’s mother stated to Colebrook when she took in a consignment of cache pots that she was going to buy the items herself and she proceeded to put them aside for herself. The record of sale or transfer of Colebrook’s art needs to be produced.
REQUEST NUMBER 18. Provide the name, address, and phone number of the person(s) who purportedly purchased the rare stained-glass window of a runner including the amount that it was sold for. Specifically, to include the following pieces
- Sunrise (framed) -BLS private collection) 47″x49″ 1983.
- Sunset (framed) – BLS private collection 47″x49″ 1983
- XXX Landscape -BLS private collection) 52″x46 1986.
- XXX Seascape (framed) 48″x39 1986; and
- a rare and original stained framed window of a runner (not by Brett Livingstone Strong)
DEFENDANTS RESPONSE TO REQUEST #18 No Such documents exist. Plaintiffs’ consignment account does not reflect a “rare” stained glass window of a runner. Nor was there any record of correspondence of one missing from her account. The first TTHC hear of this stained glass was after the store closed. And Plaintiff stopped by the store one a week for almost two years to visit shop and drop flowers and never once mentioned a missing rare stained glass.
DEFICENCIES: Plaintiff Colebrook asserts that Defendants are being less than candid with the court in this respect. Defendants clearly did not add all Colebrook’s consignment pieces to the ConsignPro account. Defendants own email of June 14th that Defendant filed into this court states in response to Colebrook question about if it had sold QUOTE “that sold a long time ago, XXX (sic) 2018. I will find out.” Plaintiff Colebrook asked about it multiple times on those weekly visits, including talking with Andrea about it possibly going to an athlete as it depicted a female runner. Andrea said she knew XXX (a locally famous runner) family and would contact them to see if would interest them. Plaintiff told Andrea that she did not want it sold for less than $400 as one tiny piece of glass cost $135 to repair. Colebrook asked why it was not on display and was told that it was a delicate item and would be shown to those she though would be interested. Plaintiff never saw it on display at the store. The other 4 art pieces from Brett Livingston Strong were never entered into the computer.
REQUEST NUMBER 26. Provide documentary proof that Defendants contacted by email, letter, or phone to inform her of the auction of the contents of the store.
DEFENDANTS RESPONSE TO REQUEST #26 No Documents exist. TTHC spoke to Plaintiff for months about picking up her items. This was not via email or phone. Pursuant to the contract TTHC did not call consignors after an item had expired. It was the consignor’s responsibility o follow the dates listed on the www.myresaleweb.com. It was in person. It was regular practice at the time for TTHC to ask all consignors who stopped by or called the store to pick up any items that they could, so they did not have to be moved. At that time, it was believed that the new location would be much smaller. Plaintiff repeatedly stated she would pick up the items, but she did not.
DEFICENCIES. Plaintiff Colebrook strongly denies she was told to pick up her items and asserts that Defendant is again speaking with less than candor to the court. In fact, in Colebrook’s sworn complaint to the District Attorney signed on XXX she stated that Colebrook visited the store in late XXX before she visited her sick mother and asked Andrea if her art had sold. She gave me some prints that I had consigned and the appraisal that were in an envelope because she did not want them to be damaged in the move. I asked about the framed art and window and she stated they would be safe as they would be moved with all the other framed art. If she had not stated, they would be safe I would have taken them right then along with the unframed prints. Andrea stated that she would see me in May at the new store. Andrea did not inform plaintiff Craig that she could pick up her art despite Craig asking multiple times. Andrea encouraged Plaintiff Viar and his wife to bring their bookcases in knowing that she was being evicted shortly. Earlier Defendant stated that those consigners that answered her calls were able to come in and pick up their items. Proof of emails or calls to consignors is critical to knowing how many consigners were actually notified of this sale.
Response for XXX
REQUEST NUMBER ONE
Plaintiff has requested the name, address and telephone number of the person who purchased the listed art of Robert McKee, valued at $1500, which was never put into ConsignPro.
DEFENDANT’S RESPONSE TO REQUEST NUMBER ONE
The defendant claims that “there was not time for a one person cashier (sic) to enter a name, telephone number, address.” The defendant then
states she can “provide a credit card receipt or documentation that would match that item, day, or time.”
DEFICIENCIES
This transaction information, which was promised in an email from Bowen-Gardner to Craig fully two years ago, and dated February 28, 2019, has never been provided. See below:
“As for your accusation that we pocketed your money, we will be happy to make a copy of every credit card transaction for the purchases of your items. We will do this tomorrow and will send with tracking. We also have receipts for every donation. We will include that to. (sic)”
Neither has she provided transaction information for the wrought iron chandelier (REQUEST NUMBER 2), the wrought iron table (REQUEST NUMBER 3), the hand painted Parisian screen (REQUEST NUMBER 4) or the antique Chinese saddle bench (REQUEST NUMBER 5.)
All these items, it should be noted, were discussed at length and had agreed upon prices. If not sold at the price desired, consignor Craig would pick them up. On one of many occasions when Craig and her husband went to the store, they inquired after the Chinese saddle bench. Bowen Gardner had no recollection of it. Craig’s husband drew a picture of the bench (the picture is in our possession), and reminded Bowen Gardner. She then remembered, it, and called somebody on the phone to ask after the price. We don’t know who she spoke with. She had no record of the sale. We were told it sold for a few hundred dollars (way below what we had wanted), given a check, and promised a copy of the transaction, which never arrived.
REQUEST NUMBER 16
Plaintiff requested copies of donations made of her items, so she could see that they were, in fact, donated – specifically against her wishes, as she was considering giving her items to friends who’d lost their belongings in the Santa Rosa fires. But at the very least, she could use the tax write off.
DEFENDANT’S RESPONSE TO REQUEST NUMBER 16
TTHC does not have or ever had donation slips filled out by the charity. There was never any written request to save any abandoned items for Sonoma County Fire victims.
DEFICIENCIES
Bowen Gardner often exceeded the 90 day contract – by months – on items consigned to her, claiming there was not enough room on the showroom floor, and that they were in the warehouse. Given that not all her items were listed in ConsignPro, plaintiff had no idea of knowing when her items appeared, if ever. Hence, the word ‘abandoned’ is used inappropriately. A consignor and her husband regularly checking on their items, in person and by phone, are not abandoning anything, but rather showing dedicated stewardship of their expensive belongings. Further, on at least two occasions, Bowen Gardner assured Craig that they never donated anything in the value range of her items. She would be contacted to come pick them up if they didn’t sell. She was never contacted. Nor was it ever suggested that she put her request to ‘save her abandoned items’ in writing. Instead, Craig relied on the verbal assurances of the defendant, which she had no reason to disbelieve, given that she did not enter into the relationship expecting to be deceived and defrauded.
Further, as in the abovementioned Deficiencies with regard to Request Number 1, Bowen Gardner sent an email to Craig dated February 28, 2019, promising to send copies of all the donation slips.
“As for your accusation that we pocketed your money, we will be happy to make a copy of every credit card transaction for the purchases of your items. We will do this tomorrow and will send with tracking. We also have receipts for every donation. We will include that to. (sic)”.
All requests for TTHC are running 7 business days. I think two years was a reasonable amount of time for you to be interested in your items or your accounting questions.
The consign pro is an inventory accounting program that updates itself daily. I do not add anything, it does everything , so I seriously doubt there is an error. So what supsificly are you asking about?
We would be happy to forward a tax deduction for you. Again, two years was prently of time for you to request this information.
Finally, Plaintiff Teena Colebrook has an email from Bowen-Gardner offering to generate a donation slip for one of Colebrook’s donated items. Bowen Gardner has three different responses to a single question regarding donation slips.
- THAT Plaintiffs aver that the said response was insufficient for the following reasons:
- Copies of inventory of 3c trains
According to ex-partner Kevin Rock there were 3c trains full of items that did not fit in the showroom and there should be an inventory if all items were tagged with consignment numbers as Defendants state. We would like to see that inventory and if there is not one then it shows that Defendants did not honor the contracts with Consignors. Plaintiffs respectfully ask Judge to order discovery on these items.
- Copies of Donated Items XXX
If Copies of donated Inventory were given to Attorney XXX as Defendants state, XXX did not forward them to Plaintiffs. Plaintiffs do not believe It is not an invasion of privacy to request where the items were donated to and for the donation receipts. Plaintiffs wish to ascertain when these items were donated and if the contract was adhered to. Defendants in prior emails contradicted this statement when they emailed plaintiff Craig l XXX Defendants stated “As for your accusation that we pocketed your money, we will be happy to make a copy of every credit card transaction for the purchases of your items. We will do this tomorrow and will send with
tracking. We also have receipts for every donation. We will include that to”. NOTE: NEVER SENT
Please see that in her response to our request for production of documents (No.#1), she indicates that she never had copies of these transactions. Not that she had misplaced them, or they were with the sheriff’s office, or had been lost. She never had them. Evidently, she was not telling the truth. Same with the donation receipts. (N0#16) She claims that she does not now, and never had any.
However, above, she claims to have receipts for every donation. Which is it? Further,
Teena Colebrook has an email from Bowen Gardner where she offers to generate donation receipts. So, here we have a case of
1.) TT never had them
2.) TT has them and will send
3.) TT will generate them as needed. Three different scenarios.
Plaintiffs respectfully ask Judge to order discovery on these items.
- Copies of W2 or 1099
Defendants state that these documents cannot be provided for defendant’s mother Linda Bowen and Nick Brooks due to EDD laws and Plaintiffs respectfully request that the Judge intervene and authorize production of these forms. Plaintiffs wish to ascertain if Defendant’s mother and Nick were being paid under the table to avoid taxes. No such documents for Defendants themselves have been sent despite their assertions to the contrary if they have them they should provide them. Plaintiffs respectfully ask Judge to order discovery on these items.
- Copies of records or sales taxes impounded by state board.
Defendant’s state these are not relevant to the case and Plaintiffs disagree, they are TTHC documents and Plaintiffs believe that they will show that Defendants have deliberately defrauded the state board as they have other consigners, and it will show a pattern of fraud Plaintiffs respectfully ask Judge to order discovery on these items.
- Copies of Sales Tax to the State Board of Equalization.
Defendants’ response is Asked and Answered? Plaintiffs state that these documents have not been proffered. Plaintiffs respectfully ask Judge to order discovery on these items. Plaintiffs respectfully ask Judge to order discovery on these items.
- Copies of all credit card transactions XXX.
Defendants state they are not in possession of documents, and they could not give them out due to privacy reasons? Plaintiffs disagree and assert that Defendants can request Credit card statements from their credit card companies and that they are not private. Plaintiffs are asking for sales and receivable information from their business and personal credit cards to show what their were spending on and/or receiving. Plaintiffs respectfully ask Judge to order discovery on these items. Plaintiffs respectfully ask Judge to order discovery on these items.
- Copies of all accounting documents from XXX
Plaintiffs have not received accounting documents as Defendants state and aver that Defendants are avoiding providing relevant documents because they are hiding information that is relevant to Plaintiffs case. Plaintiffs respectfully ask Judge to order discovery on these items.
- Copies of al bounced checks from both Defendants XXX.
Unlike Defendants answers. These are absolutely relevant to the case as it shows that Defendants consistently refused to pay people and intended to defraud. Plaintiffs disagree that these will have personal information that cannot be disclosed. Plaintiffs respectfully ask Judge to order discovery on these items. Plaintiffs respectfully ask Judge to order discovery on these items
- Copies of documents request by the trustee in Defendants Bankruptcy,
These are absolutely relevant to the case. If trustee wants them it shows that they are relevant to the case. Plaintiffs aver that all the documents requested by the Trustee XXX at the 341 hearings have not been provided as requested. (eg. Tax returns, contracts of purchase and sale of vehicles) Plaintiffs respectfully ask Judge to order discovery on these items. Plaintiffs respectfully ask Judge to order discovery on these items
- Copies of receipts of items taken by the DA.
This has not been answered and is relevant to the case, Defendants stated that the DA and Sheriff’s confiscated items so she could not provide them. The District Attorney informed Plaintiffs that a full receipt and accounting of all items confiscated was provided to Defendants. Plaintiffs are requesting that receipt which is relevant to our case as it will show what documents were in Defendant’s possession. Plaintiffs respectfully ask Judge to order discovery on these items
- Copies of cleared checks for Colleen Craig and Teena Colebrook.
Defendants have previously stated on XXX that these copies were ordered from the bank; now they say that documents were provided which is blatantly untrue Plaintiffs cannot and should not have to attempt to ascertain what defendants claim to have paid them and are unable to ask for confirmation from their bank. This is information that Defendants have to provide; they must prove that they paid plaintiffs what they claim to have paid them. Plaintiffs respectfully ask Judge to order discovery on these items.
- Copies of personal and business tax returns.
Documents have not been provided as claimed and if tax returns had been filed they were available for defendants to request from the IRS. There should be no reason for a forensic tax service in Burbank to provide what should be available from the IRS? Defendants previously stated that plaintiffs would receive them on September 24th so their story changes all the time and plaintiffs aver that defendants have had more than enough time to provide the documents requested. Bankruptcy Trustee Jeremy Faith stated to Defendants in XXX that they had to refile because they could not have a negative income. Plaintiffs respectfully ask Judge to order discovery on these items. Re: Tax returns: Answer to RFP: “To the extent available Defendant will produce these documents”. Defendants state that they have filed taxes they should easily be able to provide a copy of filed taxes, they should not need to now manufacture them.
- On or about XXX, Defendant Andrea Bowen emailed Plaintiff Teena that XXX the accountant would email the taxes to the Plaintiff in the morning. However, the said Defendant did not send the promised information.
- Copies of missing bank statements.
Defendants have not provided all bank statements Plaintiffs have asked for specific missing statements many times. Defendant have promised them, but they have not been provided, if defendants had them, they can easily be provided within a matter of days but have not. Plaintiffs aver those defendants are trying to hide relevant information. Plaintiffs respectfully ask Judge to order discovery on these items.
- On or about Wednesday XXX, Defendant Andrea Bowen emailed Plaintiff XXX that he had ordered a new set of bank statements from the Bank, and that he would forward them the next day. However, the said Defendant did not send the statements.
- Re #5 Copies accounting documents:
Copies of cleared checks for XXX and XXX.
Defendants have previously stated that these copies were ordered from the bank; now they say that documents were provided which is untrue Plaintiffs cannot and should not have to attempt to ascertain what defendants claim to have paid them and are unable to ask for confirmation from their bank. This is information that Defendants have to provide, they must prove that they paid plaintiffs what they claim to have paid them.
- In Defendants XXX RFP They stated “With that said I am able to provide copies of the cleared checks. I ordered them from Wells Fargo” 10 months later Plaintiff Colebrook is still waiting for them and cannot ask her own bank as they do not have copies of them.
- THAT Plaintiffs pray that the court compel defendants to comply with Plaintiff(s)’ requests in full.
- THAT Plaintiffs also pray this Court orders Defendants pay costs in the amount of $1,600 for their failure to provide responses to the requests for production of documents.
- THAT Plaintiffs declare under penalty of perjury that everything that stated herein is true and correct.
Sincerely; Dated this Day of [ENTER DATE].
XXX: …………………
(Plaintiffs In Pro Per)
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