1 Jose Emiliano Gastelum Rivas

417 W. Maple St.,

2 Compton, CA 90220
213-910-6351
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SUPERIOR COURT OF CALIFORNIA
9 COUNTY OF LOS ANGELES

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) Case No.: 19-BL-10339-ER
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IDALIA VILLEGAS )
)
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Petitioner, ) OBJECTION OF ALTIS RYAN PEOPLES
) TO MOTION FOR RULE 2004 EXAM
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vs. )
Jose Emiliano Gastelum Rivas )
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Respondent )
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Altis Ryan Peoples objects to the Creditor Nicole M. Woods’s Motion for Rule 2004
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Examination. The Creditor Nicole M. Woods’s request to start yet another round of litigation and
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discovery with Mr. Hansen and Ms. Erdmann fails to disclose the discovery already taken from
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Mr. Hansen and third parties. While the Court has wide latitude to authorize examinations under
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Rule 2004, the right to conduct Rule 2004 examinations is not unlimited, particularly where, as
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here, the request appears to have as much to do with litigation tactics as anything else. The Court
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should deny the Trustee’s latest request.
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FACTS
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This case was filed on April 1, 2016. Mr. Calvert was appointed as Chapter 11 Trustee 24 on
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April 11, 2016. (ECF 45) On April 25, 2016, the Trustee filed ex parte motions for broad Rule 2004
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Examinations of Mr. Hansen, Ms. Erdmann, and Medallic Art Corporation. (ECF Nos. 109, 110,
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and 111) Orders granting the motions were entered by the Court. (ECF Nos. 132, 133, and 134) In
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May
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