Supplimental Reply in Opposition To Motion Compel Answers

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Dwight A. Bennett
P.O. Box 540
Susanville, CA 96130
In Pro Per
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IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LASSEN
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NORMAN W. ALLEN,
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Plaintiff,
vs.
SUMMIT FINANCIAL GROUP;
DANA CAPITOL CORP.; STEVE
WEICH; ROD HOSILK; DWIGHT A.
BENNETT; JUDITH A. ST. JOHN;
WILSHIRE CREDIT CORP.;
EVANS APPRAISAL SERVICES, INC.;
and DOES 1-10,
Defendants.
NORMAN W. ALLEN
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Plaintiff,
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vs.
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T.D. SERVICE COMPANY; WELLS

FARGO
BANK, N.A. as Trustee for the MLMI
Trust
Series 2005-HE3; and DOES 1-10,
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Defendants,
WELL FARGO BANK, N. A., as Trustee
for
MLMI Trust Series 2005-HE3; and BAC
HOME
LOANS SERVICING, LP, a Texas
limited partnership, successor by
merger to Wilshire
Credit Corporation,
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Cross-Complainants,
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Lead Case No.: 45679

(Consolidated with Case No. 50324)
(Related Cases Nos. 46190 &
DV49327
[Appellate Case No. C065379])
Assigned for All purposes to Hon.
Raymond J. Giordano. Judge
Department: 6
SUPPLIMENTAL REPLY OF
DWIGHT A. BENNETT,
DEFENDANT/CROSS-DEFENDANT
TO NOTICE OF ERRATA AND
DECLARATION OF TIMOTHY M.
RYAN; CONTINUED OPPOSITION
TO CROSS-COMPLAINANTS
WELLS FARGO BANK N.A. AND
BAC HOME LOAN SERVICING,
LPS MOTION TO COMPEL AND
REQUEST FOR SANCTIONS; AND
POINTS AND AUTHORITIES IN
SUPPORT OF OPPOSITION.
Date:
Time:
Department:
May 19, 2011

10:30 A.M.
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Trial date:
August 22, 2011
Declaration of Dwight A. Bennett - 1
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vs.
NORMAN W. ALLEN; DWIGHT A.
BENNETT;
JUDITH A. ST. JOHN; EVANS
APPRAISAL SERVICES INC.; and
ROES 1-10,
Cross-Defendants,
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AND ALL OTHER CROSS - ACTIONS
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DECLARATION of DWIGHT A. BENNETT
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I, Dwight A. Bennett, declare:
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1.
I am over the age of eighteen and I am competent to make this

declaration.
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I am a defendant/cross-defendant in pro per in the instant case before
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the court and in that capacity only practice law.
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2.
I have personal knowledge of the fact stated herein, and if called
to do so could competently testify thereto.
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3.
I am custodian of the records for my participation in the matter
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before the court.
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4.
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Ryan of the Ryan Firm, attorney of record for Wells Fargo Bank N.A.
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and BAC continues to serve motions and documents to Bennett at the
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street address and refuses to provide service to Bennetts P.O. Box 540
In utter disregard for the authority of this Court, Mr. Timothy
Susanville, CA 96130 as ordered by the Court on April 19, 2011. The
same is true of Mr. Craig Close of Close and Associates, attorney of
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record for Judith A. St. John, Mr. Close, was also present and received
the same instructions on April 19th. Mr. Close has also been admonished
by the Court of Appeals for not using this same incorrect address.
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but attended anyway. I offered to bring the requested documents if he
would provide me a copy of the notice of deposition or inform me what
I received no notice of the scheduled February 10, 2011 deposition
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was requested therein, he did not. Further he indicated we would not
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have time that day to conclude the deposition and that I could bring
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them to the continued deposition. This conversation occurred in the
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Lassen County Courthouse before witnesses.

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I answered all questions on the record, for which I was allowed
time, it is noteworthy that Mr. Ryan arrived at the deposition more
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than 50 minutes late and conducted other business that interrupted the
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time scheduled for my deposition.
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7.
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aggressive, unethical, and appeared to be determined to evoke
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confrontation and to intimidate.
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8.
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During the deposition Mr. Ryans demeanor was abusive,
I have requested the rough draft transcript of the sworn
deposition; Mr. Ryan refuses to provide it to myself or any other party

that I am aware of including the court. I still owe attorneys fees for
preparation and attendance to the deposition that Mr. Ryan scheduled
for March 28, 2011 and yet failed to attend
I received notice of postponement of the March 21, 2011 deposition
by mail on March 28, 2011 the containing envelope was dated Friday
March 18, 2011 by private postage machine as was the proof of service
within dated March 18, 2011. Attached to my previous Declaration in
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Opposition to Compel as Exhibit 7 it is true and correct copy thereof.

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No action by the Ryan Firm has been effected to advise the Court
that he is requesting a ruling on an Amended Notice of Continued
Deposition. That Document is not a part of the Motion to Compel
submitted to this court by Wells Fargo/BAC yet it would necessarily
become included in that same motion. Rather than engage in purposeful
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discovery cross-complainants continue to prosecute a thinly veiled effort
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at subterfuge and abuse of process to the detriment of a fair trial on the
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merits under prevailing law.
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This is misuse of discovery exactly as is delineated by California

Statute. The contents thereof are significantly different from the unamended document submitted to this court for examination and ruling
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in the motion at bar. The amended demand, is attached to my
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previous Declaration in Opposition to Compel as Exhibit 8 and is a true
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and correct copy thereof.
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10. To my knowledge, Wells Fargo Bank N. A., BAC, nor their attorney
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of record has made any effort to request leave of this Court to seek
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discovery in matters under appeal, in compliance with Code of Civil
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Procedure 2036.030. Wells Fargo N.A. and BAC in the rush to

intimidate, embarrass, or eliminate Bennett from the matter at bar and
strike his answer; seek sanctions for fallacious allegations of discovery
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abuse. This is further display of an operative disregard for the wisdom
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and authority of the Bar and the equity of due process.
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I declare under penalty of perjury under the laws of the State of

California that the foregoing is true and correct, executed on May 13,
2011, at Susanville, CA
DwightA Bennett
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_________________________
Dwight A. Bennett
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In Pro Per
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POINTS AND AUTHORITIES IN SUPPORT OF
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OPPOSITION TO MOTION TO COMPEL AND SANCTIONS;
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REQUEST FOR SANCTIONS.
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Defendant/Cross-Defendant DWIGHT A. BENNETT, in Pro Per

respectfully submits the following memorandum of points and
authorities in opposition to the
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Motion to compel answers at deposition.
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Motion to produce documents requested at deposition
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Notice of Errata fails to cure any substantive issues.
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Sanctions for alleged reasonable costs in the amount of

$3,275.50 incurred by Defendant/Cross-plaintiff(s) as a result of
deponents alleged conduct at partial deposition conducted on
February 10, 2011.
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I.
INTRODUCTION
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Access to discovery is critical to all litigation and especially where

a controversy of complex actions involving multiple parties rests upon
limited documentation and may rely on witness testimony and third
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party evidence to bring a verdict on the merits. This is as it should be.
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Abuse of the discovery process cuts both ways with equal effect.
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Allegations of abuse of discovery and the resultant perfected
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appeal already bring controversy to the instant complex case. The
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earlier allegations of abuse of discovery leading to appeal were set into
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motion by obfuscation of facts on the record and orchestration of
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outrageous accusations during testimony by opposing counsel. In

truth the prima fascia evidence will present an alternative and opposite
basis of fact for judgment on the merits at trial. The litigants, the court
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and justice are best served where no controversies are manufactured
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during litigation.
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II.
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DEPOSING PARTIES HAVE FAILED TO CURE
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PROCEDURAL ERRORS BY
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NOTICE OF ERRATA
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A.
in matters under appeal, the very purpose of which is to allow the trial
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Attorney Ryan failed to seek leave of the Trial Judge for discovery
judge with firsthand knowledge of the matter to determine relevance or

potential harm of the discovery being requested.
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But "the moving party need only show, in addition to relevance (broadly construed), that
his reasons for seeking discovery are within the declared purposes of the Discovery Act
(that is, discovery will aid his case) and that discovery may be allowed without doing
violence to equity, justice, or the inherent rights of the adversary." (Emphasis added)
(Louisell & Wally, Modern Cal. Discovery (2d ed. 1972) 6.05, p. 420; cf.
also Beesley v. Superior Court (1962) 58 Cal.2d 205, 209 [23 Cal. Rptr. 390, 373
P.2d 454]; Suezaki v. Superior Court (1962) 58 Cal.2d 166, 172 [23 Cal. Rptr. 368, 373
P.2d 432, 95 A.L.R.2d 1073]; Greyhound Corp. v. Superior Court, supra, 56 Cal.2d 355, 388,
389)
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B.
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transcript of deposition in full it is sufficiently evident from the portions
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they dare show the court,that the inquiry was intended to antagonize,
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While the Wells Fargo still refuses to release the original
humiliate, instill fear and otherwise create an opening through the

manufacture of controversy to yield unfounded sanctions and
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termination and avoid resolution on the merits. Judicial review is
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requested of the AMENDED notice of deposition and demand for
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production of documents.
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C.
Wells Fargo/BACs Amended notice of deposition and demand for
production.. utterly violates California statute and case law regarding;
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attorney-client privilege, attorney work product and demands business
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records for over 9 years, far beyond the necessary scope of consideration
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to conclude the matter at bar.
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"[T]he [attorney-client] privilege is absolute and disclosure may not be ordered, without
regard to relevance, necessity or any particular circumstances peculiar to the case."
(Gordon v. Superior Court (1997) 55 Cal.App.4th 1546, 1557, 65 Cal.Rptr.2d 53.)
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D.
Bennett in propria persona under prevailing law is an; attorney-
in-fact and is accorded privilege of attorney work product.
The work product doctrine was recognized in (Hickman v. Taylor (1947)

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329 206*206 U.S. 495, 67 S.Ct. 385, 91 L.Ed. 451), which established a qualified
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privilege for certain materials prepared by an attorney acting for his client in anticipation
of litigation: "Historically, a lawyer is an officer of the court and is bound to work for the
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advancement of justice while faithfully protecting the rightful interests of his clients. In
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performing his various duties, however, it is essential that a lawyer work with a certain
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degree of privacy, free from unnecessary intrusion by opposing parties and their
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counsel. Proper preparation of a client's case demands that he assemble information,
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sift what he considers to be the relevant from the irrelevant facts, prepare his legal
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theories and plan his strategy without undue and needless interference. That is the
historical and the necessary way in which lawyers act within the framework of our
system of jurisprudence to promote justice and to protect their clients' interests. This
work is reflected, of course, in interviews, statements, memoranda, correspondence,
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briefs, mental impressions, personal beliefs, and countless other tangible and intangible
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ways aptly though roughly termed by the Circuit Court of Appeals in this case as the
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`work product of the lawyer.' Were such materials open to opposing counsel on mere
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demand, much of what is now put down in writing would remain unwritten. An attorney's
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thoughts, heretofore inviolate, would not be his own. Inefficiency, unfairness and sharp
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practices would inevitably develop in the giving of legal advice and in the preparation of
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cases for trial. The effect on the legal profession would be demoralizing. And the
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interests of the clients and the cause of justice would be poorly served." (Ibid. at pp.
510-511, 67 S.Ct. 385.)
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E.
that prima fascia evidentiary documents are missing or were stolen;
that Bennett has already delivered demanded production of documents
regarding business records and proof of domestic violence beyond
requirement of the law and statute to Mr. Closes office. Yet the
amended demand requires production of more than 9 years of
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Cross-complainants know fully well that it is a matter of record
business records and any and all evidence of Domestic Violence and or
attacks on horses by St. John as alleged by Bennett, (emphasis added).
Any honest desire for discovery by W.F.B. N.A./BAC requires only that
portion afforded them under the law.
Not the least of which, clearly there is direct attack on personal or
class economic hardships and an effort to bypass standing injunctions
against alleged Trespass to Chattel & Spoliation of Evidence as is
evidenced in the transcript of deposition now submitted to this court.
When the interest of a civil litigant in discovering potentially relevant information
intrudes on another person's claim to privacy, the court must engage in a careful
balancing of each interest. (Valley Bank of Nevada v. Superior Court, supra, 15 Cal.3d
657.)
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As the foregoing cases illustrate, when a litigant's request for discovery touches
another person's privacy interest, a litigant is not as free to obtain information as he
might otherwise be. (See Greyhound Corp. v. Superior Court, supra, 56 Cal.2d at pp.
384-386.) A particularized need for the information must be established. How
compelling this need must be will depend on the importance of the privacy interest
involved.
(Davies v. Superior Court [1984] supra, 36 Cal.3d 291 (1984) 682 P.2d 349
204 Cal. Rptr. 154)
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F.
Attorney Ryan, asserts nothing new in his Notice of Errata.
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The same questions are presented for the Courts decision, although
these questions were previously claimed to be submitted in errata.
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The Notice of Errata made no substantive changes; it merely increased

the number of exhibit pages, while presenting the Court a clearer view
of the tone and tenor of aggression by Ryan without viable purpose,
except to; humiliate, intimidate, strike a sense fear for the safety of and
helplessness to protect the animals under the Bennetts care.
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"One of the principal purposes of the Discovery Act (Code Civ. Proc., 2016-2035) is to
enable a party to obtain evidence in the control of his adversary in order to further the
efficient, economical disposition of cases according to right and justice on the merits.
(41 Mich. L.Rev. 205; 50 Yale Law Journal 711; Pettie v. Superior Court, 178
Cal.App.2d 680, 689 [3 Cal.Rptr. 267].) Its purpose is not 'to provide a weapon for
punishment, forfeiture and the avoidance of a trial on the merits. (Crummer v. Beeler,
185 Cal.App.2d 851, 858 [8 Cal.Rptr. 698]; Mitchell v. Johnson, 274 F.2d 394.)"
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G.
Mr. Ryan far exceeded the rules of professional conduct.
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The partially released transcripts indicate as much, his questions,
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demeanor, and interactions with cross-defendant St. John were
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designed to intimidate, induce fear and inflame Bennetts passions
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regarding the deaths of horses that are subject matters of cases; Lassen
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#46190 and DV49327 the primary and companion case under appeal,
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this violates the injunctive order currently in effect in DV49327.
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III.
DILATORY DEFENSE
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Definition of DILATORY DEFENSE: a defense or plea which is intended to
defeat the pending action or proceeding without involving any decision on

the merits of the case
(24 Cal.Rptr.3d 474 [2005]
126 Cal.App.4th 993)
Five.
Review Denied April 27, 2005.
February 14, 2005.
No. B170904.
Court of Appeal, Second District, Division
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Bennetts Verified Answer to Cross-Complaint asserted

allegations of Corporate Successor Liability and Capacity or Standing
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to Sue. Wells Fargo and BACs knee jerk response has been to isolate
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and eradicate Bennett, now alleging abuse of discovery and requesting
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sanctions for the same. The allegations are wholly without merit and
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cannot even be prosecuted without the wholesale abandonment of the
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Code of Civil Procedures 2036.010-2036.040. That being, in

paraphrase; the requirement of a motion requesting leave of the trial
court appealed from, to conduct discovery regarding matters under
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appeal. The trial court may then set the depth, scope and breadth of the
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discovery to be allowed as to; persons deposed, specific questions
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allowed or restricted, and documents to be produced. These as set forth
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in CHAPTER 20 of the C.C.P. 2036.040 subsections (a),(b),&(c). There
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is simply no available end run to avoid this requirement for discovery,
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no matter how disconcerting a partys verified answer may be.
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A litigant's standing to sue is a threshold issue to be resolved before the

matter can be reached on the merits. (Hernandez v. Atlantic Finance Co.
(1980) 105 Cal.App.3d 65, 71, 164 Cal.Rptr. 279.) "If we were to conclude
that plaintiff did not have standing to maintain the action, not having been
personally damaged by the defendants' conduct, then there would be no
need to address the merits of her cause. Equally wasteful of judicial
resources would be a resolution on the merits without reaching the standing
issue." (Ibid.) We will not address the merits of litigation when the plaintiff
lacks standing, because "`California courts have no power ... to render
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advisory opinions or give declaratory relief.'" (Municipal Court v. Superior

Court (Gonzalez) (1993) 5 Cal.4th 1126, 1132, 22 Cal.Rptr.2d 504, 857
P.2d 325.) [Blumhorst v. Jewish Family Services of LA, 24 Cal. Rptr. 3d 474]
"Standing"`goes to the existence of a cause of action.' (5 Witkin, Cal.

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Procedure (4th ed. 1997) Pleading, 862, p. 320.)
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In the instant case Wells Fargo N.A. and BAC through
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their legal counsel Tim Ryan submitted documents to this court on
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February 2, 2010 to wit; a letter to Judge Darlington submitted as their

Settlement Conference Statement for the February 9th hearing. It
reads on page one:
Wells Fargo and Wilshire Credit Corporation each has filed a declaration of nonmonetary status pursuant to Civil Code section 29241, stating that they believe:
(a) That they have been named as defendants in the lawsuit solely in
their respective capacities as agents of the beneficiary under the Deed
of Trust in issue in the case. (underscore added)
Following the assertion of res judicata by these same

defendants/cross-complainants they have engaged in filing a series of
conflicting and contradictory claims as to their alleged status and their
relationship to the Deed of Trust in question, creating reasonable doubt
about their legal capacity to proceed.
Code of Civil Procedure section 367 provides: "Every action must

be prosecuted in the name of the real party in interest, except as otherwise
provided by statute." (Accord, 5 Witkin, Cal. Procedure, supra, Pleading,
862, p. 320.) "The issue of whether a party has standing focuses on the
plaintiff, not the issues he or she seeks to have determined." (Torres v. City
of Yorba Linda (1993) 13 Cal. App.4th 1035, 1040, 17 Cal.Rptr.2d 400.)
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Submitted to this court in the motion to compel at bar, Wells Fargo
Bank N.A. asserts sua sponte through Counsel Ryan in his
Memorandum of Points and Authorities at bar here; on pg. 1 at footnote
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1 Defendant/Cross-Complainant Wells Fargo Bank N.A. (Wells

Fargo) is the current beneficiary under the Option One loan to Allen,
and BAC Home Loans Servicing, LP (BAC) (collectively Defendants)
is the servicing entity for the loan.
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"A person who invokes the judicial process lacks standing if he, or
those whom he properly represents, `does not have a real interest in the
ultimate adjudication because [he] has neither suffered nor is about to suffer
any injury of sufficient magnitude reasonably to assure that all of the relevant
facts and issues will be adequately presented.' [Citation.]" (Schmier v.
Supreme Court (2000) 78 Cal.App.4th 703, 707, 93 Cal.Rptr.2d 580; see
also Common Cause v. Board of Supervisors, supra, 49 Cal.3d at pp. 439440, 261 Cal. Rptr. 574, 777 P.2d 610["[t]he purpose of a *480 standing
requirement is to ensure that the courts will decide only actual controversies
between parties with a sufficient interest in the subject matter of the dispute
to press their case with vigor"]; (Residents of Beverly Glen, Inc. v. City of Los
Angeles (1973) 34 Cal.App.3d 117, 129, 109 Cal. Rptr. 724)
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This being said, Wells Fargo Bank N.A. nor BAC have
done anything to contradict the allegations of lack of capacity
or standing except re-submitting to the court; copies of an
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unendorsed Deed of Trust, an invalid assignment of deed, a
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forged substitution of trustee and a partial pooling and service
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agreement. Ergo until Wells Fargo and BAC establish
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capacity in fact they may have no standing to enter the court
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room, to prosecute causes of action or to pursue sanctions at
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all.
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IV
DEPOSING PARTY FAILED TO APPEAR AT

SCHEDULED CONTINUANCE OF DEPOSITION AND
PROVIDED NO NOTICE OF FURTHER POSTPONEMENT
TO DEPONENT BENNETT UNTIL MARCH 29, 2011
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As stated, unaware of any postponement and unwilling to be

subjected to further abuses I spent two hours with attorney Robert
Terry in preparation on March 20, 2011 and retained him as co-counsel
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for the full day of March 21, 2011.
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At approximately 10:45 A.M. I called Ryan and Associates Law Firm
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from the deposition site to find out why the scheduled deposition was
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delayed and when Mr. Ryan would arrive. To my surprise, Mr. Ryan
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came on the line still in southern California and I explained that I was
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waiting with co-counsel; after learning this he informed me that as I
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had retained co-counsel he could no longer speak with me and refused
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to since that day.

Under the Civil Code of Procedures 2025.430 If the Party giving
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notice of a deposition fails to attend or proceed with it the court shall
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impose a monetary sanction under Chapter 7 (commencing with Section
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2023.010) against that party, or the attorney of that party or both, in
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favor of the party attending..
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CONCLUSION
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Under C.C.P. 2025.440.(a) failure to serve adequate notice of

deposition to deponent allows the imposition of sanctions by the court
on the offending party.
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Under C.C.P. 2025.540. subsection (b) Use of Rough Draft

Transcript Is Not Permitted.
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Sanctions against Ryan and Associates Law Firm and Wells

Fargo/BAC are appropriate here and should be imposed by the court.
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1. In the placement of a protective order preventing any and all
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further discovery by the offending parties regarding subject
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matters related to Lassen Case No. DV 49327, seeking attorney
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work product, and seeking information protected by attorney
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client privilege.
2. In an Order by the Court requiring all further discovery requested
of Bennett by Wells Fargo/BAC be first approved by leave of the
court to avoid future abuses of discovery.
3. That attorneys for Wells Fargo/BAC and Judith A. St. John be
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again ordered by the court to serve all future documents to
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Bennetts correct address, cease sending facsimiles intended for
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Bennett to the Law Office of Peter Talia and to cease placing
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phone calls intended for Bennett to Mr. Talias Office.
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4. For monetary sanctions for Bennetts cost of $2,500.00 for

attorneys fees incurred through their actions in misuse of
discovery and failure of deposing to attend or notify of
postponement.
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5. For monetary sanctions as determined appropriate by the court to

discourage future abuse of discovery & abuse of process tactics by
Ryan and Associates and Wells Fargo Bank/BAC.
6. That the full transcripts of the deposition be provided to Bennett.
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As a litigant in propria persona I am not afforded special or
exceptional treatment under the law, nor do I desire any. I do
request equal treatment under the law and equal due process to
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that afforded any other natural citizen of California and the
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United States of America.
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Respectfully Submitted,
May 13, 2011
DwightA Bennett
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____________________
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Dwight A. Bennett
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in pro per
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Supplimental Reply in Opposition To Motion Compel Answers

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Supplimental Reply in Opposition To Motion Compel Answers

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1

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LASSEN

T.D. SERVICE COMPANY; WELLS

Lead Case No.: 45679

May 19, 2011

August 22, 2011

Declaration of Dwight A. Bennett - 1

AND ALL OTHER CROSS - ACTIONS

DECLARATION of DWIGHT A. BENNETT

I, Dwight A. Bennett, declare:

I am over the age of eighteen and I am competent to make this

I am a defendant/cross-defendant in pro per in the instant case before

the court and in that capacity only practice law.

I have personal knowledge of the fact stated herein, and if called

to do so could competently testify thereto.

I am custodian of the records for my participation in the matter

before the court.

and BAC continues to serve motions and documents to Bennett at the

In utter disregard for the authority of this Court, Mr. Timothy

Declaration of Dwight A. Bennett - 2

Susanville, CA 96130 as ordered by the Court on April 19, 2011. The

same is true of Mr. Craig Close of Close and Associates, attorney of

but attended anyway. I offered to bring the requested documents if he

would provide me a copy of the notice of deposition or inform me what

I received no notice of the scheduled February 10, 2011 deposition

was requested therein, he did not. Further he indicated we would not

them to the continued deposition. This conversation occurred in the

Lassen County Courthouse before witnesses.

I answered all questions on the record, for which I was allowed

time, it is noteworthy that Mr. Ryan arrived at the deposition more

time scheduled for my deposition.

aggressive, unethical, and appeared to be determined to evoke

confrontation and to intimidate.

During the deposition Mr. Ryans demeanor was abusive,

I have requested the rough draft transcript of the sworn

deposition; Mr. Ryan refuses to provide it to myself or any other party

within dated March 18, 2011. Attached to my previous Declaration in

Opposition to Compel as Exhibit 7 it is true and correct copy thereof.

that he is requesting a ruling on an Amended Notice of Continued

Deposition. That Document is not a part of the Motion to Compel

submitted to this court by Wells Fargo/BAC yet it would necessarily

become included in that same motion. Rather than engage in purposeful

discovery cross-complainants continue to prosecute a thinly veiled effort

at subterfuge and abuse of process to the detriment of a fair trial on the

merits under prevailing law.

This is misuse of discovery exactly as is delineated by California

in the motion at bar. The amended demand, is attached to my

previous Declaration in Opposition to Compel as Exhibit 8 and is a true

and correct copy thereof.

discovery in matters under appeal, in compliance with Code of Civil

Procedure 2036.030. Wells Fargo N.A. and BAC in the rush to

abuse. This is further display of an operative disregard for the wisdom

and authority of the Bar and the equity of due process.

Declaration of Dwight A. Bennett - 4

I declare under penalty of perjury under the laws of the State of

POINTS AND AUTHORITIES IN SUPPORT OF

OPPOSITION TO MOTION TO COMPEL AND SANCTIONS;

REQUEST FOR SANCTIONS.

Defendant/Cross-Defendant DWIGHT A. BENNETT, in Pro Per

Motion to compel answers at deposition.

Motion to produce documents requested at deposition

Notice of Errata fails to cure any substantive issues.