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George Sharp
3525 Del Mar Heights Road, #620
San Diego, CA 92130
(310) 498-4455
(619) 446-6717 fax

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In Propria Persona
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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COUNTY OF SAN DIEGO, CENTRAL DIVISION
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GEORGE A. SHARP,
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)
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Plaintiff,
)
)
v.
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STOCKTIPS.COM, AMERADA CORP.,
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LALUNA SERVICES, INC., TELUPAY
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INTERNATIONAL, INC., ECRYPT
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TECHNOLOGIES, INC., ALKAME
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)
HOLDINGS, INC., WELL POWER, INC.,
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TIGER OIL AND ENERGY, INC.,
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COASTAL INTEGRATED SERVICES, INC., )
EMPIRE STOCK TRANSFER, INC.,
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QUICKSILVER STOCK TRANSFER, INC., )
)
ROBERT BANDFIELD, AWEBER
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SYSTEMS, INC. ADRIAN HERMAN
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THOMAS, HAROLD GEWERTER and
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DOES 8 through 500, inclusive,
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)
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Defendants.
)
_____________________________________ )
)

Case No. 37-2015-0008210-CU-NP-CTL


(Assigned for all purposes to Hon. Timothy
Taylor)
PLAINTIFF GEORGE SHARPS
NOTICE OF MOTION AND MOTION
TO COMPEL RESPONSES TO
REQUEST FOR PRODUCTION OF
DOCUMENTS, SET ONE FROM
DEFENDANT COASTAL INTEGRATED
SERVICES; MEMORANDUM OF
POINTS AND AUTHORITIES;
DECLARATION OF GEORGE SHARP
IN SUPPORT THEREOF

Date: August 5, 2016


Time: 1:30 p.m.
Dept: C-72:

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TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:

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PLEASE TAKE NOTICE that, on August 5, 2016 at 1:30 p.m. or as soon thereafter as

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counsel may be heard in Department C-72 of the above-entitled court located at 330 W.

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Broadway, San Diego, California 92101, Plaintiff George Sharp (Plaintiff) will move the

-1MOTION TO COMPEL FURTHER RESPONSES, SET ONE

Court for an order compelling responses to Requests for Production, Set One, Propounded to

Defendant COASTAL INTEGRATED SERVICES, INC. (hereinafter RPDs), Request No. 1.

Plaintiff further moves the Court for an order that Defendant and its counsel, Robert Huston, pay

the sum of $60 as the reasonable costs incurred by Plaintiff in connection with the filing of this

motion to compel further responses.

This motion is made on the grounds that the discovery sought is relevant to the subject

matter of this action. Defendants refusal to respond to the discovery requests at issue herein is

without substantial justification and in bad faith. The motion is based on this notice, the

following memorandum of points and authorities and declaration of George Sharp and the

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attached exhibits, the papers and records on file with the court herein, and upon such further

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evidence and argument as may be presented at the time of hearing.

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Dated: May 24, 2016

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By.
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______________________________
George Sharp
In Propria Persona

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-2MOTION TO COMPEL FURTHER RESPONSES, SET ONE

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MEMORANDUM OF POINTS AND AUTHORITIES


1.

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INTRODUCTION
Plaintiff served a first round of document discovery requests on Defendant, to which

Defendant has not responded in any way.

Plaintiff has twice attempted to meet and confer to resolve this issue informally.

Defendant did not respond to either Meet and Confer effort. Defendants failure to properly

respond to discovery requests was done in bad faith and is sanctionable conduct. Defendant and

its counsels actions are flouting the discovery process and the integrity of the judicial system in

general. Defendant should be compelled to provide further responses (and documents) and

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sanctioned for the necessity of this motion.

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2.

SUMMARY OF RELEVANT FACTS

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This action arises out of Plaintiffs Complaint for violation of Business and Professions

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Code 17529.5 based on Defendants participation to defraud the public through a spam email

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pump and dump scheme. The Plaintiff contends that this Defendant participated in the scheme to

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defraud by providing cheap stock to all of the Defendants in exchange for little or no value and

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for the divesture by the Defendants at over inflated prices.

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On February 10, 2016, the Plaintiff served its first set of Requests for Production. Not a
single document was produced nor was an objection lodged in response.
On March 24, 2016, the Plaintiff emailed a request to Meet and Confer to Defendants

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counsel. (Decl. Sharp 4; Exhibit B March 24, 2016 Request to Meet and Confer) The

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courtesy of a response was not received.

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On March 29, 2016, the Plaintiff initiated a second attempt to Meet and Confer with

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Defendants Counsel. (Decl. Sharp 6; Exhibit C March 29, 2016 Request to Meet and

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Confer). Again, no response was proffered.

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Because defense counsel has failed to provide sufficient responses or to produce the

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requested documents, this motion to compel further responses was necessary.

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///

-3MOTION TO COMPEL FURTHER RESPONSES, SET ONE

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3.

LEGAL DISCUSSION
Because Defendant has failed to provide sufficient responses to Plaintiffs discovery

requests and is withholding documents, and instead provided baseless blanket objections, this

Motion should be granted.

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A.

Code of Civil Procedure section 2017.010 states, in part:

any party may obtain discovery regarding any matter, not privileged, that is relevant

to the subject matter involved in the pending action or to the determination of any motion made

Plaintiff Has a Right to Discovery from Defendant

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in that action, if the matter either is itself admissible in evidence or appears reasonably calculated

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to lead to the discovery of admissible evidence. (Emphasis added.)

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In Fuss v. Superior Court, the Court of Appeals stated, in part, as follows:

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The civil discovery statutes are intended to accomplish the following results (1) to give

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greater assistance to the parties in ascertaining the truth and in checking and preventing perjury;

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(2) to provide an effective means of detecting and exposing false, fraudulent and sham claims

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and defenses; (3) to make available, in a simple, convenient and inexpensive way, facts which

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otherwise could not be proved except with great difficulty; (4) to educate the parties in advance

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of trial as to the real value of their claims and defenses, thereby encouraging settlement; (5) to

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expedite litigation; (6) to safeguard against a surprise; (7) to prevent delay; (8) to simplify and

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narrow the issues; and (9) to expedite and facilitate both preparation and trial. 273 Cal.App.2d,

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807, 815-16 (1969) (citing Greyhound Corp. v. Super. Ct., 56 Cal. 2d 355, 376).

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Californias discovery procedures are designed to minimize the opportunities for

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fabrication and forgetfulness, and to eliminate the need for guesswork about the other sides

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evidence, with all doubts about discoverability resolved in favor of disclosure. Glenfed Dev.

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Corp. v. Super. Ct., 53 Cal.App.4th 1113, 1119 (1997). The purpose of pretrial discovery is to

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obtain all of the facts relative to a claim or defense. Hernandez v. Super. Ct., 112 Cal.App.4th

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285, 301 (2003). For discovery purposes, information sought is relevant to the subject matter

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-4MOTION TO COMPEL FURTHER RESPONSES, SET ONE

if it might reasonably assist a party in evaluating the case, preparing for trial or facilitating

settlement thereof. Stewart v. Colonial W. Agency Inc., 87 Cal.App.4th 1006 (2001).


Plaintiffs discovery efforts have been thwarted by Defendant as a result of its bad faith

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responses and refusal to provide further responses, despite Plaintiffs meet and confer effort. As

set forth below, Defendant has failed to make a good faith effort to respond to the requests, and

good cause exists to justify an order compelling the discovery sought.

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Defendant Has Failed to Sufficiently Respond to Plaintiffs RPDs

B.

The party to whom a demand for documents is directed must respond separately to each

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item in the demand by one of the following: (a) a statement that the party will comply by the date

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set for inspection with the particular demand for inspection; (b) a statement that the party lacks

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the ability to comply with the particular demand; or (c) an objection to all or part of the demand.

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Code Civ. Proc. 2031.210(a).

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An agreement to comply must state that the production and inspection demanded will be

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allowed (in whole or in part) and that the documents or things in the responding partys

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possession, custody, or control will be produced. Code Civ. Proc. 2031.220. In addition,

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compliance is satisfied by producing the documents either as they are kept in the usual course

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of business or sorted and labeled to correspond with the categories in the document demand. Id.

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at 2031.280(a). An inability to comply shall state that a diligent search and reasonable inquiry

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has been made in an effort to locate the item demanded, as well as the reason the party is unable

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to comply (e.g., the document never existed, has been lost or stolen, was inadvertently destroyed,

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or is not in the possession, custody, or control of the responding party). Id. at 2031.230. With

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respect to objections, the objection must identify with particularity the specific document or

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evidence to which the objection is made. Code Civ. Proc. 2031.240(b). Objections constitute

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implicit refusals to produce documents. Standon Co., Inc. v. Super. Ct., 225 Cal.App.3d 898, 901

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(1990). By refusing to respond, Defendant did not adhere to any of the proper actions dictated by

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Code Civ. Proc. 2031.

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///

-5MOTION TO COMPEL FURTHER RESPONSES, SET ONE

C.

Warranted

Code of Civil Procedure section 2023.010 defines discovery misuse as follows:

The Imposition of Sanctions against Defendant and Its Counsel Is

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Misuses of the discovery processes include, but are not limited to the
following: . . .
(c) Employing a discovery method in a manner or to an extent that causes

unwarranted annoyance, embarrassment, or oppression, or undue burden

expense.

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(d) Failing to respond or to submit to an authorized method of discovery.

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(e) Making, without substantial justification, an unmeritorious objection to

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discovery.
(f) Making an evasive response to discovery.

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Code of Civil Procedure section 2023.030 states, in pertinent part:

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To the extent authorized by the chapter governing any particular

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discovery method or any other provision of this title, the Court, after notice to any

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affected party, person or attorney, and after opportunity for hearing, may impose

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the following sanctions against any one engaging in conduct that is a misuse of

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the discovery process:

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(a) The Court may impose a monetary sanction ordering that (1)

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engaging in the misuse of the discovery process, or any attorney advising that

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conduct, or both, pay the reasonable expenses, including attorneys fees, incurred

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by anyone as a result of that conduct. (Emphasis added.)

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Moreover, Code Civ. Proc. 2030.300(d) requires a court to impose a monetary sanction

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against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel

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further response to a discovery request unless it finds that the one subject to the sanction acted

-6MOTION TO COMPEL FURTHER RESPONSES, SET ONE

with substantial justification or that other circumstances make the imposition of the sanction

unjust.

In this case, Defendants patently refused to respond to the discovery requests.

The discovery propounded on Defendant were authorized methods of discovery, and its

and its counsels actions in failing to provide proper responses constitute a misuse of the

discovery process, as do the failures to substantively meet and confer. As a result of

Defendants action, Plaintiff has been forced to file the instant motion. Based on Defendants

bad faith actions, sanctions in the amount of $60 should be imposed against Defendant and its

counsel.

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4.

CONCLUSION
For the foregoing reasons, Plaintiff George Sharp respectfully requests that the Court

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order Defendant Coastal Integrated Services, Inc. to provide complete substantive responses to

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the RPD 1 at issue in this Motion. Plaintiff further requests that the Court impose sanctions

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against Defendant and its counsel, Robert Huston, in the amount of $60.

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Dated: May 24, 2016

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By.

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______________________________
George Sharp
In Propria Persona

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-7MOTION TO COMPEL FURTHER RESPONSES, SET ONE

DECLARATION OF GEORGE SHARP

I, George Sharp, declare as follows:

1.

I am over 18 years of age and am the Plaintiff in this case. I have personal

knowledge of the facts stated herein, and if called as a witness would truthfully and competently

testify to the following.

2.

On February 10, 2016, I served Request for Production of Documents, Set One on

the Defendant Coastal Integrated Services, Inc. Attached as Exhibit A is a true and correct

copy of this discovery request.

3.

On March 24, 2016, I sent a Meet and Confer request to Defendants Counsel,

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Robert Huston, regarding responses to the document requests. Attached as Exhibit B is a true

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copy of this Meet and Confer letter.

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4.

On March 29, 2016, I sent a second Meet and Confer request to Defendants

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Counsel, Robert Huston, regarding responses to the document requests. Attached as Exhibit C

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is a true copy of this Meet and Confer letter.

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5.

I have not received any response to my efforts to Meet and Confer.

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6.

I have not received any responses to the Request for Production of Documents,

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Set One.
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I have advanced $60 as a filing fee for this motion.

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

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foregoing is true and correct. This declaration was executed on May 24, 2016 in San Diego,

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California.

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____________________________
George Sharp

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-8MOTION TO COMPEL FURTHER RESPONSES, SET ONE

PROOF OF SERVICE - CCP. 1013A, CG 002015.5

STATE OF CALIFORNIA, COUNTY OF SAN DIEGO

I, the undersigned, reside in the County of San Diego, State of California. I am over the

age of eighteen (18) years and not a party to the within action. My business address is 3525 Del

Mar Heights Road, Suite 620, San Diego, California 92130. My email address is

George@George-Sharp.com.

On May 24, 2016, at approximately 8:30 p.m., I served true copies of the foregoing

documents described as PLAINTIFF GEORGE SHARPS NOTICE OF MOTION AND

MOTION TO COMPEL RESPONSES TO REQUEST FOR PRODUCTION OF

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DOCUMENTS, SET ONE FROM DEFENDANT COASTAL INTEGRATED SERVICES;

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MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF GEORGE

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SHARP IN SUPPORT THEREOF on the interested parties in this action, addressed as

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follows:

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Kenneth Stone

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THE STONE LAW GROUP

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Karl@KRInternetLaw.com

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Robert Huston

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Bob_Huston@Yahoo.com

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BY EMAIL: The documents were scanned and uploaded to the One Legal internet

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website with the instruction to forward the documents to the interested parties. I am "readily

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familiar" with the practice of uploading to One Legal for email forwarding.

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I certify under penalty of perjury that the foregoing is true and correct and that this
declaration was executed May 24, 2016.

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____________________

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George Sharp

-9MOTION TO COMPEL FURTHER RESPONSES, SET ONE

EXHIBIT A

George Sharp
3525 Del Mar Heights Road, #620
San Diego, CA 92130
(310) 498-4455
(619) 446-6717 fax

In Propria Persona

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SUPERIOR COURT OF THE STATE OF CALIFORNIA


COUNTY OF SAN DIEGO, CENTRAL DIVISION

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GEORGE SHARP,

)
)
)
Plaintiff,
)
)
v.
)
)
)
STOCKTIPS.COM, AMERADA CORP.,
)
LALUNA SERVICES, INC., TELUPAY
)
INTERNATIONAL, INC., ECRYPT
)
TECHNOLOGIES, INC., ALKAME
)
)
HOLDINGS, INC., WELL POWER, INC.,
COASTAL INTEGRATED SERVICES, INC., )
)
and DOES 1 through 500, inclusive,
)
)
)
Defendants.
)
___________________________________ )
)

Case No.: 37-2015-00008210-CU-NP-CTL


(Assigned for all purposes to Hon. Timothy
Taylor)
REQUEST FOR PRODUCTION OF
DOCUMENTS BY DEFENDANT
COASTAL INTEGRATED SERVICES,
INC., SET ONE
Trial Date:

none

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PROPOUNDING PARTY:

Plaintiff George Sharp

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RESPONDING PARTY:

Defendant Coastal Integrated Services, Inc.

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SET NUMBER:

One

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TO DEFENDANT COASTAL INTEGRATED SERVICES, INC. AND ITS

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ATTORNEY OF RECORD:

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Pursuant to California Code of Civil Procedure Section 2031, plaintiff George Sharp

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hereby requests that defendant Coastal Integrated Services, Inc., hereinafter COASTAL,
-1_____________________________________________________________________________
REQUEST FOR PRODUCTION OF DOCUMENTS BY DEFENDANT COASTAL INTEGRATED SERVICES, INC., SET ONE

produce the following documents for copying and inspection at 3525 Del Mar Heights Road,

Suite 620, at 10:00 a.m. on March 21, 2016

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DEFINITIONS
1.

YOU or YOUR means Defendant COASTAL INTEGRATED

SERVICES, INC., its employees, agents, attorneys, accountants, transfer agents, officers,

directors, affiliates, successors, assigns, partners, representatives, any person or entity acting on

its behalf, at his request or with his authorization.

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PERSON or PERSONS mean any natural person, association,

partnership, corporation, organization, business, trust, joint venture, receiver, estate, syndicate or

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any other entity or combination acting as a unit or acting as a form of legal entity, including the

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parties to this suit and their members, officers, directors, partners, agents, contractors,

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subcontractors, employees, representatives and affiliates.

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REGARDING, RELATING TO or RELATE TO means

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mentioning, discussing, summarizing, describing, regarding, referring to, relating to, evidencing,

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depicting, embodying, constituting or reporting.

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6.

COMMUNICATION means any meeting, conversation, discussion,

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correspondence, message or other occurrence where thoughts, opinions or data are transmitted

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between two or more PERSONS.

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7.

The terms DOCUMENT and DOCUMENTS are used in their

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broadest possible sense and mean, without limitation, any kind of written, printed, typed,

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photostatic, photographed, recorded or otherwise reproduced communication or representation,

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whether comprised of letters, words, numbers, pictures, sounds, syllables or any combination

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thereof, regardless of whether the same is an original, a copy, a reproduction, a facsimile or draft,

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and regardless of the source or author thereof. This definition includes copies or duplicates of

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DOCUMENTS contemporaneously or subsequently created that have any non-conforming notes

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or other markings. Without limiting the generality of the foregoing, the terms DOCUMENT

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and DOCUMENTS include, but are not limited to, correspondence, memoranda, notes,

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records, letters, envelopes, telegrams, messages, studies, analyses, contracts, agreements,


-2_____________________________________________________________________________
REQUEST FOR PRODUCTION OF DOCUMENTS BY DEFENDANT COASTAL INTEGRATED SERVICES, INC., SET ONE

working papers, summaries, statistical statements, financial statements or work papers, accounts,

invoices, receipts, payment records, analytical records, reports and/or summaries of

investigations, trade letters, press releases, comparisons, books, calendars, diaries, articles,

magazines, newspapers, booklets, brochures, pamphlets, circulars, bulletins, notices, drawings,

diagrams, instructions, notes or minutes of meetings or other communications of any type,

including inter- and intra-office communications, faxed materials (including fax cover sheets),

questionnaires, surveys, charts, graphs, photographs, phonograph recordings, electronic mail,

film, tapes, disks, diskettes, data cells, tape back-ups, drums, print-outs, all other data

compilations from which information can be obtained (translated, if necessary, by YOU into

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usable form), and any preliminary versions, drafts or revisions of any of the foregoing, whether

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used or not, and any writings as defined by Rule 1001 of the Federal Rules of Evidence.

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8.

If any DOCUMENT is withheld under a claim of privilege, to assist the

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Court and the parties hereto in determining the validity of the claim of privilege, you are asked to

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furnish a list (Privilege Log) signed by the person supervising the response to this request for

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production of DOCUMENTS, which identifies each DOCUMENT for which the privilege is

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claimed, together with the following information regarding said document:

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a)

the date of the DOCUMENT;

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b)

the identity of the PERSON who signed said DOCUMENT or on whose

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behalf it was sent or issued, including said PERSONS last known

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business and home addresses and telephone numbers;

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c)

the identity of the PERSON to whom said DOCUMENT was directed,

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including said PERSONS last known business and home addresses and

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telephone numbers;

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d)

the nature and substance of said DOCUMENT set forth with sufficient

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particularity to enable the Court and the parties hereto to identify the

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DOCUMENT;

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e)

the identity of each PERSON who has custody, control or possession of


the original DOCUMENT and/or copy thereof;

-3_____________________________________________________________________________
REQUEST FOR PRODUCTION OF DOCUMENTS BY DEFENDANT COASTAL INTEGRATED SERVICES, INC., SET ONE

f)

the number of pages in the DOCUMENT;

g)

the basis upon which any privilege is claimed;

h)

whether or not any non-privileged matter is included within the document;

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and
i)

the number of the document request to which such DOCUMENT relates


or corresponds.

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DOCUMENT REQUESTS
REQUEST FOR PRODUCTION NO. 1
Copies of all Opinion Letters and other documents which recommended directed or

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enabled the removal of legends on previously restricted stock certificates for the period January

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1, 2014 to the present.

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Dated: February 10, 2016

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By.

______________________________
George Sharp

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-4_____________________________________________________________________________
REQUEST FOR PRODUCTION OF DOCUMENTS BY DEFENDANT COASTAL INTEGRATED SERVICES, INC., SET ONE

PROOF OF SERVICE - CCP. 1013A, CG 002015.5


STATE OF CALIFORNIA, COUNTY OF SAN DIEGO

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I, the undersigned, reside in the County of San Diego, State of California. I am over the
age of eighteen (18) years and not a party to the within action. My business address is 3525 Del
Mar Heights Road, Suite 620, San Diego, California 92130. My email address is
George@George-Sharp.com.
On February 10, 2016, at approximately 12:30 p.m., I served true copies of the foregoing
documents described as REQUEST FOR PRODUCTION OF DOCUMENTS BY
DEFENDANT COASTAL INTEGRATED SERVICES, INC., SET ONE on the interested
parties in this action, addressed as follows:

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Kenneth Stone
THE STONE LAW GROUP
Karl@KRInternetLaw.com

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Robert Huston
Bob_Huston@Yahoo.com

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BY EMAIL: The documents were scanned and uploaded to the One Legal internet
website with the instruction to forward the documents to the interested parties. I am "readily
familiar" with the practice of uploading to One Legal for email forwarding.
I certify under penalty of perjury that the foregoing is true and correct and that this
declaration was executed February 10, 2016.

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____________________
George Sharp

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-5_____________________________________________________________________________
REQUEST FOR PRODUCTION OF DOCUMENTS BY DEFENDANT COASTAL INTEGRATED SERVICES, INC., SET ONE

EXHIBIT B

George Sharp
From:
Sent:
To:
Cc:
Subject:

George Sharp <george@george-sharp.com>


Thursday, March 24, 2016 8:08 PM
bob_huston@yahoo.com
Kenneth Stone (khstone@hotmail.com)
Sharp v StockTips.com - Your client: Coastal Integrated Services, Inc.

Dear. Mr. Huston:


This letter shall be considered an attempt to Meet and Confer with respect to a Request For Production of Documents, Set One propounded on your client on
February 10, 2016. To date, I have not received any responses to these requests and as the allowed by code has lapsed, your client has waived all objections and
must produce the responsive documents.
Kindly let me know when I may expect these documents so that I may avoid having to file a Motion to Compel. I am prepared to delay such a filing until April 8,
2016.
Regards,

George Sharp
310-498-4455

EXHIBIT C

George Sharp
From:
Sent:
To:
Cc:
Subject:

George Sharp <george@george-sharp.com>


Tuesday, March 29, 2016 4:46 PM
bob_huston@yahoo.com
Kenneth Stone (khstone@hotmail.com)
RE: Sharp v StockTips.com - Your client: Coastal Integrated Services, Inc.

Mr. Huston:
I have now not only not received the documents, but I have not received a response to my Meet and Confer email. Please let me know by the end of business
tomorrow whether you will be producing the documents by April 8, 2016 or not.
George Sharp
310-498-4455
From: George Sharp [mailto:george@george-sharp.com]
Sent: Thursday, March 24, 2016 8:08 PM
To: bob_huston@yahoo.com
Cc: Kenneth Stone (khstone@hotmail.com)
Subject: Sharp v StockTips.com - Your client: Coastal Integrated Services, Inc.

Dear. Mr. Huston:


This letter shall be considered an attempt to Meet and Confer with respect to a Request For Production of Documents, Set One propounded on your client on
February 10, 2016. To date, I have not received any responses to these requests and as the allowed by code has lapsed, your client has waived all objections and
must produce the responsive documents.
Kindly let me know when I may expect these documents so that I may avoid having to file a Motion to Compel. I am prepared to delay such a filing until April 8,
2016.
Regards,

George Sharp
310-498-4455
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