Roberta McGregor v. Victoria Yeager

Category No. 22: Defendants are ordered to produce copies of any financial statements (profitand-loss statements, balance sheets) most recently prepared by or for Corporate Defendant, or a supplemental declaration explaining why they cannot be produced.

Bank and Financial Accounts of Corporate Defendant Daniel Fraiman Construction, a California Corporation Category No. 23: Defendants are ordered to produce copies of complete account statements for all corporate checking, savings, payroll, money market, and brokerage accounts held in the name of Corporate Defendants, for the period July 1, 2024, through the present, or a supplemental declaration explaining why they cannot be produced.

Category No. 24: Defendants are ordered to produce copies of all records of any certificates of deposit, treasury instruments, or other investment accounts held by Corporate Defendants, or a supplemental declaration explaining why they cannot be produced.

Category No. 25: Defendants are ordered to produce copies of all records of any merchant accounts, payment processing accounts (e.g., PayPal, Square, Stripe), or construction draw accounts maintained by Corporate Defendants, for the period July 1, 2024, through the present, or a supplemental declaration explaining why they cannot be produced.

Corporate Records and Ownership of Corporate Defendant Daniel Fraiman Construction, a California Corporation Category No. 26: Defendants are ordered to fully comply with this category by immediately providing Plaintiffs the corporate stock ledge and records of all shares issued and outstanding, identifying all current shareholders, or a supplemental declaration explaining why Defendants are unable to produce documents responsive to this category.

Corporate Assets of Corporate Defendant Daniel Fraiman Construction, a California Corporation Category No. 30: Defendants are ordered to fully comply with this category by immediately providing Plaintiffs a current schedule of all equipment owned or leased by Corporate Defendants, identifying each item, its approximate fair market value, and whether it is owned free and clear or subject to a lien or financing agreement, or a supplemental declaration explaining why Defendants are unable to produce the schedule and documents responsive to this category.

Liabilities and Obligations of Corporate Defendant Daniel Fraiman Construction, a California Corporation Category No. 34: Defendants are ordered to immediately produce all lines of credit agreements and the most recent statements of the outstanding balance for each, or a supplemental declaration explaining why Defendants are unable to produce copies of all lines of credit agreements and the most recent statements of the outstanding balance for each.

Contracts, Revenue, and Receivables of Corporate Defendant Daniel Fraiman Construction, a California Corporation Category No. 38: Defendants are ordered to fully comply with this category by immediately providing Plaintiffs a current list of all active construction contracts or agreements to which 8

Corporate Defendant is a party, identifying the project name, location, contract value, and amount remaining to be paid, or a supplemental declaration explaining why Defendants are unable to produce that list.

Category No. 39: Defendants are ordered to fully comply with this category by immediately providing Plaintiffs a current accounts receivable aging report, or a supplemental declaration explaining why there is no current accounts receivable aging report and why Defendants are unable to produce one.

Category No. 40: Defendants are ordered to fully comply with this category by immediately providing Plaintiffs all of DFC’s accounting records evidencing all amounts owed to Corporate Defendant under contracts currently in dispute or in litigation, including the courts in which those actions are pending, or a supplemental declaration under oath stating that DFC is not owed any money and is not currently in dispute or in litigation over any amounts DFC claims it is due, other than this litigation.

Distributions, Transfers, and Related-Party Transactions Category No. 42: Defendants are ordered to immediately produce all records of any transfer of assets out of Corporate Defendant to any individual or entity within the past two (2) years, including the nature of the asset transferred, the transferee, the date, and the consideration received, or a supplemental declaration under oath stating that no transfer of assets out of Corporate Defendant to any individual or entity has been made within the past two (2) years.

Insurance Category No. 44: Defendants are ordered to immediately produce copies of all declarations pages for all current commercial general liability and contractors’ professional liability, insurance policies maintained by Corporate Defendant.

5. CU0002738 Roberta McGregor v. Victoria Yeager

No appearances are required.

Defendant/Cross-Complainant Victoria S. Yeager’s (“Defendant”) motion regarding discovery is continued on the Court’s motion until December 11, 2026 at 10:00 a.m. for consideration of an amended motion and associated briefing.

In her August 3, 2026, motion, Defendant moved to/for: 1) an order to deem requests for admission (sets one and two) admitted; 2) compel initial responses to special interrogatories (set one); 3) compel further responses to form interrogatories (sets one, two, and three), special interrogatories (set two) and requests for production of documents (sets one and two); 4) leave to propound additional discovery; and 5) sanctions.

As part of the motion at issue, Plaintiff reports that she served various amended discovery responses upon Defendant apparently to address potential deficiencies in connection with previous responses. Defendant appears to suggest she has not received all of the discovery responses. Both parties, without authorization from the Court, have filed numerous pleadings 9

outside the scope of normal motion practice attempting to address the discovery issues. At this juncture, the record presented by the parties is wholly unclear as to what discovery responses are currently the operative responses, whether Defendant believes they are sufficient or otherwise, and the position of Plaintiff to the extent there are any purported deficiencies. The Court lacks the ability to thoughtfully adjudicate any dispute that potentially exists between the parties.

The parties are directed to meet and confer in person with respect to all of the discovery requests at issue to establish definitively what the operative responses are and that Defendant has received the same no later than September 11, 2026. As part of the meet and confer, Plaintiff shall personally deliver all the operative responses to Defendant. No later than September 14, 2026, the parties shall jointly submit each of the operative responses to the Court in a single filing which clearly identifies each separate operative response.

Afterwards, should Defendant believe any of the responses are inadequate, she is granted leave to file an amended motion by no later than October 16, 2026. If an amended motion is not required, Defendant shall file a withdrawal of her original motion by the same date. Solely the amended motion will be adjudicated and solely the operative responses filed by September 14, 2026 will be considered as part of that amended motion. Should a motion be filed, any opposition shall be filed and served by November 13, 2026; and any reply shall be noticed and served by November 25, 2026.

No other filings are permitted other than those noted herein.

The parties are admonished as follows: Under the Civil Rules of Procedure and Rules of Court, a moving party is allowed to file a motion with a memorandum of points and authorities (15 pages maximum) and supporting documents, an opposing party is allowed to file a single opposition with memorandum (15 pages maximum) and supporting documents, and the moving party is permitted to file a single reply (10 pages maximum). See Code Civ. Proc. 1005(b), Rules of Court, Rules 3.112-3.113. All briefing shall comply with the requirements of the Rules of Procedure and Rules of Court, without exception. The Court, as necessary, will exercise its authority to strike and disregard future filings that do not comply with these rules and/or impose monetary sanctions for failure to abide by applicable rules.

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