1 Melody Gillespie 2 Porterville, California, 3 93258.

4 5 6 7 8 9 10 11 Melody Gillespie, 12 13 14
Et Al, Plaintiffs, -VSCASE #: 10-238961 SPECIAL WRITTEN INTERROGATORIES TO DEFENDANT NICKLAS HOFFMAN OF PLAINTIFF Melody Gillespie Set 2 SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF TULARE c/o P.O. Box 8323

15 Nicklas Hoffman; 16 17 Defendants 18 ___________________________ 19 Nicklas Hoffman, Et Al, 20 ___________________________

Cross Complainants,

21 PROPOUNDING PARTY: Plaintiff Melody Gillespie 22 SET 2 24 25 26 27 28

ANSWERING PARTY: Defendant Nicklas Hoffman

23 To: Defendant Nicklas Hoffman:

The following Special written interrogatories are being propounded to you pursuant to the Express Provisions of California Civil Discovery Act found in in the California Code of Civil Procedure ; You are required to deliver a written Response to Plaintiff Melody Gillespie within 35 days of date of mailing to you, or in the case of personal delivery 30 days of the date of such personal Service.
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If you fail or refuse to answer as Required Plaintiffs will move the Court for an Order Directing you to do so, & for Monetary & or Evidentiary Sanctions or a Dismissal Sanction against you. Interrogatory #: 1. Did you build a house located on the property in Terra Bella California described as: that portion of lot 379 of Terra Bella Lands Subdivision No. 9, as per map recorded in book 9 at page 27 of Official Maps, county of Tulare, Republic of California, described as follows: That certain parcel of land designed and delineated as Parcel 2, 5.06 Ac. Gross,on Tentative Parcel Map PPM 78143A, filed April 11, 1978, with the planning Commission of said county, and approved April 28, 1978 by Resolution No. 3612 of the Parcel Map Committee of said county.

13 2. Did you previously own the real property located at what is described as:
that portion of lot 379 of Terra Bella Lands Subdivision No. 9, as per map recorded in book 9 at page 27 of Official Maps, county of Tulare, Republic of California, described as follows: That certain parcel of land designed and delineated as Parcel 2, 5.06 Ac. Gross, on Tentative Parcel Map PPM 78143A, filed April 11, 1978, with the planning Commission of said county, and approved April 28, 1978 by Resolution No. 3612 of the Parcel Map Committee of said county. 3. Has the Title you claim to the Real Property at 1831 N. Lime Street, by Grant Deed, attached as Exhibit A to your Cross Complaint ever changed since Recording of said Grant Deed Document # 2004-0046807, on May 17, 2004 ? 4. If the Title to the Real Property at 1831 N. Lime Street has not changed since the Recording of the Grant Deed Document #: 2004-0046807 on May 17, 2004, what is the effect & meaning of Document #:2006-0002762, Recorded on January 11, 2006, titled DEED OF TRUST, Signed by Nickol D Gerritsma, Trustee of the H.M. Wysocki Irrevocable Trust, Notarized on June 8, 2004 by STEPHEN J. SLEEPER, CALIFORNIA NOTARY PUBLIC,COMMISSION NUMBER #: 1436722, SEE TRUE & ACCURATE COPY OF SAID DOCUMENT

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ATTACHED HERETO AS EXHIBIT # 1, WHICH IS HEREBY INCORPORATED HEREIN BY REFERENCE AS IF FULLY SET FORTH HEREIN, & WHICH IS HEREBY MADE A PART OF THIS DOCUMENT. WHEREIN THE DOCUMENT EXPRESSLY PURPORTS TO: IRREVOCABLY GRANT, TRANSFER AND ASSIGN TO TRUSTEE IN TRUST WITH POWER OF SALE, THE REAL PROPERTY AT 1831 N. LIME STREET, TO NEW PARADIGM HOLDING COMPANY, WHICH YOU NOW CLAIM IN YOUR CROSS COMPLAINT, IS OWNED BY H.M. Wysocki Irrevocable Trust.

10 5. Upon the Execution, Notarization, & Recording of the above said Document 11 #: 2006-0002762, did you ever comply with the Express Provisions set out in 12 13 14 15 16 17 18 19 20 21 22 23 24
SEE ATTACHED COPY OF SAID DOCUMENT ATTACHED HERETO AS EXHIBIT # 2, WITH SAID PORTION HIGHLIGHTED IN YELLOW , WHICH IS HEREBY INCORPORATED HEREIN BY REFERENCE AS IF FULLY SET FORTH, AND WHICH IS HEREBY MADE A PART OF THIS DOCUMENT. DEED OF TRUST WITH ASSIGNMENT OF RENTS AS ADDITIONAL SECURITY Document #: 2004-0046808, RECORDED IN TULARE COUNTY RECORDERS OFFICE ON MAY 17, 2004, STATING: In the event of a voluntary sale, alienation or conveyance of all or any portion of the real property described herein, any indebtedness or obligation under the promissory note secured hereby, at the option of the holder, shall immediately become due and payable.

25 On this day, the- -day-of-the-ninth-month-two-thousand-twelve, 26 27 28

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_______________________ Melody Gillespie

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all Rights Reserved.

EXHIBIT PAGE INDEX OF EXHIBITS #1: Grant Deed Document #: 2006-0002762, Recorded on January 11, 2006 in the
Tulare County Recorders Office purporting to IRREVOCABLY GRANT, TRANSFER AND ASSIGN TO TRUSTEE IN TRUST WITH POWER OF SALE, THE REAL PROPERTY AT 1831 N. LIME STREET, to NEW PARADIGM HOLDING COMPANY;

#2: DEED OF TRUST WITH ASSIGNMENT OF RENTS AS ADDITIONAL

SECURITY Document #: 2004-0046808, RECORDED IN TULARE COUNTY RECORDERS OFFICE ON MAY 17, 2004

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 SPECIAL WRITTEN INTERROGATORIES TO DEFENDANT NICKLAS 17 HOFFMAN OF PLAINTIFF Melody Gillespie Set 2 18 19 20 21 C/O: ATTORNEY OF RECORD ROBERT J. FLETCHER 22 P.O. BOX 824, Tulare, Ca. 93274. 23 24 Said Service was by First Class US Mail with said Document enclosed inside a sealed 25 envelope addressed as set forth above, with the postage fully prepaid by me. 26 27 28
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Proof of Service
I the undersigned hereby Declare under Penalty of Perjury under the Laws of the State of California that I served the here attached document Described as:

ON THE DAY OF: / / 2012, BY MAIL ON THE PERSONS OR PARTIES BELOW AT THE ADDRESSES TO FOLLOW: DEFENDANTS Nicklas Hoffman , ET AL,

I am not a party to this matter. I am over the age of eighteen years. My business address is 934 W. Henderson, PMB#: 132, Porterville, California, 93257.

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______________________ Alan David