Separate Statements in Support of Motion To Compel COLV's Production of Documents, Set Two

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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,
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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., )
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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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Defendants.
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_____________________________________ )
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Case No. 37-2015-0008210-CU-NP-CTL

(Assigned for all purposes to Hon. Timothy
Taylor)
SEPARATE STATEMENT OF ITEMS IN
DISPUTE RE REQUESTS FOR
PRODUCTION OF DOCUMENTS, SET
TWO, PROPOUNDED TO
DEFENDANT COASTAL INTEGRATED
SERVICES, INC.
[Filed Concurrently with Motion to Compel
Further Responses to Requests for Production
of Documents]
Date: August 5, 2016
Time: 1:30 p.m.
Dept: C-72:
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Plaintiff George Sharp (Sharp or Plaintiff) hereby respectfully submits this Separate
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Statement of Items in Dispute pursuant to California Rules of Court Rule 3.1345 in support of its
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Motion to Compel Further responses to Requests for Production of Documents, Set Two, to
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Coastal Integrated Services, Inc. (COASTAL or Defendant):

-1Separate Statement of Items in Dispute Re Requests for Production of Documents, Set Two
REQUESTS FOR PRODUCTION OF DOCUMENTS
AND RESPONSES IN DISPUTE
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Request for Production No. 2:

All documents relating to the formation of the corporation currently known as Coastal
Integrated Services, Inc, its predecessors, affiliates and subsidiaries.
Response to Request for Production No. 2:
Responding Party objects to this request on the basis that this request for
production of documents seeks the discovery of information which is beyond the scope and
issues of this lawsuit in that the documents sought are unrelated to the transmission of
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unsolicited commercial emails, and therefore irrelevant, immaterial, and not reasonably
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calculated to lead to the discovery of admissible evidence.
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Responding Party further objects to this request on the basis that this request for
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production of documents is unduly burdensome to the extent that it seeks documents that
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are publicly available on the Internet. Responding to this request would be oppressive,
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unduly burdensome, and unnecessarily expensive, and the burden of responding to such
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requests is substantially the same or less for the Plaintiff as for the Responding Party.
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Responding Party declines the request.
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Reasons Why a Supplemental Response Should Be Ordered:
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Scope and issues of lawsuit, i.e. relevancy, is not a valid objection. Discovery is relevant
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to the subject matter of the litigation if it might reasonably assist a party in evaluating the case,
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preparing for trial, or facilitating settlement thereof. Gonzalez v. Sup. Ct. (1995) 33 Cal.App.4th
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1599, 1611; Stewart v. Colonial Western Agency, Inc. (2001) 87 Cal.App.4th 1006, 1013.
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Further, the relevancy to the subject matter is applied liberally. Any doubt is resolved in favor of
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permitting discovery. Colonial Life & Acc. Ins. Co. v. Sup. Ct. (1982) 31 Cal.3d 785, 790.
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Further, this is never a proper objection for the refusal to provide discovery responses. See Coy
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v. Superior Court of Contra Costa County (1962) 58 Cal 2d 210 (Objection interposed as reason
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for not answering written interrogatories that they were irrelevant and immaterial to issues of
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case could not be used to deny discovery). Further, the requested documents are directly
relevant to this litigation.
Documents obtained from the internet may not be admissible as they are not certified and
receiving certified copies would be an undue burden and expense on the Plaintiff. Instead of
providing a straightforward response to this interrogatory as required by the Code. Pursuant to
Cal. Code of Civ. Proc. 2030.220; See also Deyo v. Kilbourne, 84 Cal.App.3d 771, 783-784
(1978) (it is not proper to answer by stating, See my deposition, See my pleading, or See
the financial statement.). A corporation is bound to keep corporate documents and should have
access to authentic documents.
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As for the assertion that the requests is burdensome, the true test of burdensome and
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harassing is whether the amount of work required to respond to the request is so great, and the
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utility of the information sought so minimal, that it defeats the ends of justice to require
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responses. See Columbia Broadcasting Systems, Inc. v. Sup. Ct. (Rolfe), 263 Cal. App. 2d 12, 21
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(1968) (As the court said in Greyhound Corp. v. Superior Court, 56 Cal.2d 355, 383-384, . . . a
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trial court In the exercise of its discretion the court should weigh the relative importance of the
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information sought against the hardship which its production might entail.). All discovery
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imposes some burden, but [t]he objection of burden is valid only when that burden is
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demonstrated to result in injustice. West Pico Furniture, Co. v. Superior Court (Pacific Finance
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Loans), 56 Cal. 2d 407, 418 (1961). The party objecting must present evidence showing the
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quantum of work required to respond to the discovery request. West Pico, 56 Cal. 2d at 417.
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The Responding Party does not even attempt to make such a showing. The mere fact that the
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response may be expensive and burdensome did not justify a refusal to responds to the discovery.
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See Alpine Mut. Water Co. v. Superior Court of Ventura County (1968) 259 Cal App 2d 45.
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Further, an objection on the grounds of burden was not valid unless the burden results in
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injustice. See Pantzalas v. Superior Court of Los Angeles County (1969) 272 Cal App 2d 499.
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Good cause exists to order the production of these documents as they are necessary to
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this case in that it establishes who were the potential beneficiaries of the spam email pump and
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dump scheme, as well as those in control of the company when it willingly participated in the
scheme, including potential alter-egos. The discovery will also aid in establishing potential
witnesses.
All documents relating to the assignments and resignations of any officers and directors
of Coastal Integrated Services, Inc. or its predecessor company(s) since May 2, 2009.
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calculated to lead to the discovery of admissible evidence.
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As for the assertion that certain requests are burdensome, the true test of burdensome and
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witnesses.
All documents relating to general meetings of the shareholders of Coastal Integrated
Services, Inc. and its predecessors, including minutes of those meetings, since May 2, 2009.
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calculated to lead to the discovery of admissible evidence. Responding Party declines the
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request.
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witnesses. Furthermore, the minutes of the meetings would establish whether the purported
officers and directors had the actual right to execute the contracts, corporate actions and other
events that lead to the pleaded Cause of Action.
All minutes of meetings of the directors of Coastal Integrated Services, Inc. and its
predecessors since May 2, 2009.
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request.
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this case in that it establishes the role the Defendant played in the spam email pump and dump
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scheme, it establishes who were the potential beneficiaries of the spam email pump and dump
scheme, as well as those in control of the company when it willingly participated in the scheme,
including potential alter-egos. The discovery will also aid in establishing potential witnesses.
Furthermore, the minutes of these meetings could establish whether the contracts, corporate
actions and other events which lead to the alleged Cause of Action were properly approved by
the officers and directors of the Defendant.
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All documentation referencing the transfer of ownership of common stock, preferred
stock, stock options, and warrants in Coastal Integrated Services, Inc.
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request.
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Furthermore, the documents will establish whether stock was properly issued, what value (if any)
was received, timing of divestiture and which shareholders benefited from the spam email pump
and dump campaign.
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All documentation referencing the issuance of common stock, preferred stock, stock
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options, and warrants in Coastal Integrated Services, Inc.
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request.
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was received and which significant shareholders divested their stock during the spam email
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pump and dump campaign.
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All written communications, including letters, emails and contracts between Coastal
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Integrated Services, Inc. or its predecessors and its transfer agents.
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request.
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was received, and which shareholders benefited from the spam email pump and dump campaign.
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All documentation referring to contracts or letters of intent or business agreements
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between Coastal Integrated Services, Inc., or its predecessors and any other entity.
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request.
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Responding Party further objects to this request on the basis that it is overly broad
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and thus places an undue burden on this Defendant to respond.
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As for the assertion that request is burdensome, the true test of burdensome and harassing
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is whether the amount of work required to respond to the request is so great, and the utility of the
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information sought so minimal, that it defeats the ends of justice to require responses. See
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Columbia Broadcasting Systems, Inc. v. Sup. Ct. (Rolfe), 263 Cal. App. 2d 12, 21 (1968) (As
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the court said in Greyhound Corp. v. Superior Court, 56 Cal.2d 355, 383-384, . . . a trial court In
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the exercise of its discretion the court should weigh the relative importance of the information
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sought against the hardship which its production might entail.). All discovery imposes some
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burden, but [t]he objection of burden is valid only when that burden is demonstrated to result in
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injustice. West Pico Furniture, Co. v. Superior Court (Pacific Finance Loans), 56 Cal. 2d 407,
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418 (1961). The party objecting must present evidence showing the quantum of work required
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to respond to the discovery request. West Pico, 56 Cal. 2d at 417. The Responding Party does
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not even attempt to make such a showing. The mere fact that the response may be expensive and
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burdensome did not justify a refusal to responds to the discovery. See Alpine Mut. Water Co. v.
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Superior Court of Ventura County (1968) 259 Cal App 2d 45. Further, an objection on the
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grounds of burden was not valid unless the burden results in injustice. See Pantzalas v. Superior
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Court of Los Angeles County (1969) 272 Cal App 2d 499.

including potential alter-egos or those who received stock in exchange for Letters of Intent or
other business agreements. The discovery will also aid in establishing potential witnesses.
was received, and which shareholders benefited from the spam email pump and dump campaign.
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All press releases issued on behalf of Coastal Integrated Services, Inc and its
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predecessors.
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request.
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scheme, as press releases were issued concurrently with the scheme. The discovery will also aid
in establishing potential witnesses.
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All SEC filings on behalf of Coastal Integrated Services, Inc and its predecessors.
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request.
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scheme, as SEC documents were filed concurrently with the scheme. The discovery will also aid
in establishing potential witnesses.
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All disclosures and/or filings to the Financial Industry Regulatory Authority (FINRA),
OTC Markets or other market facilitators or regulators.
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request.
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To the extent that this request requires production of Responding Partys filings with
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OTC Markets or the Securities and Exchange Commission, Responding Party further objects to
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this request on the basis that this request for production of documents is unduly burdensome to
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the extent that it seeks documents that are publicly available on the Internet. Responding to this
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request would be oppressive, unduly burdensome, and unnecessarily expensive, and the burden
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of responding to such requests is substantially the same or less for the Plaintiff as for the
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Responding Party. Responding Party declines the request.
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scheme, by discovering what disclosures were made concurrent with the scheme. The discovery
will also aid in establishing potential witnesses.
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All documentation referencing financing of Coastal Integrated Services, Inc., or its
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predecessors, including but not limited to equity financing, notes and debentures (convertible or
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not).
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request.
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As for the assertion that request is burdensome, the true test of burdensome and harassing
is whether the amount of work required to respond to the request is so great, and the utility of the
information sought so minimal, that it defeats the ends of justice to require responses. See
Columbia Broadcasting Systems, Inc. v. Sup. Ct. (Rolfe), 263 Cal. App. 2d 12, 21 (1968) (As
the court said in Greyhound Corp. v. Superior Court, 56 Cal.2d 355, 383-384, . . . a trial court In
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the exercise of its discretion the court should weigh the relative importance of the information
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sought against the hardship which its production might entail.). All discovery imposes some
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burden, but [t]he objection of burden is valid only when that burden is demonstrated to result in
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injustice. West Pico Furniture, Co. v. Superior Court (Pacific Finance Loans), 56 Cal. 2d 407,
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418 (1961). The party objecting must present evidence showing the quantum of work required
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to respond to the discovery request. West Pico, 56 Cal. 2d at 417. The Responding Party does
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not even attempt to make such a showing. The mere fact that the response may be expensive and
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burdensome did not justify a refusal to responds to the discovery. See Alpine Mut. Water Co. v.
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Superior Court of Ventura County (1968) 259 Cal App 2d 45. Further, an objection on the
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grounds of burden was not valid unless the burden results in injustice. See Pantzalas v. Superior
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Court of Los Angeles County (1969) 272 Cal App 2d 499.
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including potential alter-egos or those who received stock in exchange for Letters of Intent or
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other business agreements. The discovery will also aid in establishing potential witnesses.
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was received, and which significant shareholders divested their stock during the spam email
pump and dump campaign.
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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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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 5:30 p.m., I served true copies of the foregoing
documents described as SEPARATE STATEMENT OF ITEMS IN DISPUTE RE
REQUESTS FOR PRODUCTION OF DOCUMENTS, SET TWO, PROPOUNDED TO
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DEFENDANT COASTAL INTEGRATED SERVICES, INC. on the interested parties in this
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action, addressed as 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
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Separate Statements in Support of Motion To Compel COLV's Production of Documents, Set Two

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Separate Statements in Support of Motion To Compel COLV's Production of Documents, Set Two

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1

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

Coastal Integrated Services, Inc. (COASTAL or Defendant):

REQUESTS FOR PRODUCTION OF DOCUMENTS

AND RESPONSES IN DISPUTE

Request for Production No. 2:

Integrated Services, Inc, its predecessors, affiliates and subsidiaries.

Response to Request for Production No. 2:

calculated to lead to the discovery of admissible evidence.

Responding Party declines the request.

Reasons Why a Supplemental Response Should Be Ordered:

relevant to this litigation.

providing a straightforward response to this interrogatory as required by the Code. Pursuant to

access to authentic documents.

Request for Production No. 3:

Response to Request for Production No. 3:

calculated to lead to the discovery of admissible evidence.

Responding Party declines the request.

Reasons Why a Supplemental Response Should Be Ordered:

relevant to this litigation.

providing a straightforward response to this interrogatory as required by the Code. Pursuant to

access to authentic documents.

Request for Production No. 4:

All documents relating to general meetings of the shareholders of Coastal Integrated

Response to Request for Production No. 4:

Reasons Why a Supplemental Response Should Be Ordered:

relevant to this litigation.

events that lead to the pleaded Cause of Action.

Request for Production No. 5:

predecessors since May 2, 2009.

Response to Request for Production No. 5:

Reasons Why a Supplemental Response Should Be Ordered:

relevant to this litigation.

the officers and directors of the Defendant.

Request for Production No. 8:

Reasons Why a Supplemental Response Should Be Ordered:

relevant to this litigation.

and dump campaign.

Request for Production No. 9:

options, and warrants in Coastal Integrated Services, Inc.

Response to Request for Production No. 9:

Reasons Why a Supplemental Response Should Be Ordered:

relevant to this litigation.

pump and dump campaign.

Request for Production No. 10:

Integrated Services, Inc. or its predecessors and its transfer agents.

Response to Request for Production No. 10:

Reasons Why a Supplemental Response Should Be Ordered:

relevant to this litigation.

Request for Production No. 11:

All documentation referring to contracts or letters of intent or business agreements

Response to Request for Production No. 11:

and thus places an undue burden on this Defendant to respond.

Reasons Why a Supplemental Response Should Be Ordered:

relevant to this litigation.

Court of Los Angeles County (1969) 272 Cal App 2d 499.

Request for Production No. 12:

Response to Request for Production No. 12:

and thus places an undue burden on this Defendant to respond.

Reasons Why a Supplemental Response Should Be Ordered:

relevant to this litigation.

providing a straightforward response to this interrogatory as required by the Code. Pursuant to

access to authentic documents.