Request #8831

DEMAND FOR PRODUCTION NO. 1:
Any and all DOCUMENTS (The term “DOCUMENT” or “DOCUMENTS” shall include, but is not limited to, writings as defined by California Evidence Code section 250, and includes the original or a copy of handwriting, typewriting, printing, photostats, photographs, electronically stored information, and every other means of recording upon any tangible thing and form of communicating or representation, including letters, words, pictures, sounds, or symbols, or combinations of them from which information can be obtained. Without limiting the generality of the foregoing, the term "DOCUMENT" shall specifically include all contracts, subcontracts, agreements, forms, correspondence, letters, facsimile transmissions, e-mail, telegram messages, telephone messages, telephone statements or bills, notices, notes or reports, diaries, minutes, recitals, statements, work sheets, abstracts, resumes, summaries, notes, jottings, books, journals, ledgers, audits, maps, charts, diagrams, exhibits, drafts, newspapers, employment books, desk calendars, memorandums, or expense reports. The term "DOCUMENT" shall also include all copies and all draft copies of documents whether completed or not, by whatever means made.) which relate to the current status of PROJECT at SITE C.
DEMAND FOR PRODUCTION NO. 1:
Any and contracts between Investel Garden Resorts, LLC and any hotels partners in the PROJECT during the time period January 1, 2015 until date of deposition.
DEMAND FOR PRODUCTION NO. 2:
Any all DOCUMENTS which relate to electricity or utilities being brought to SITE C for the purpose of the PROJECT during the time period January 1, 2015 until date of deposition.
DEMAND FOR PRODUCTION NO. 3:
Any all contracts between Investel Garden Resorts, LLC and the City of Garden Grove related to SITE C during the time period January 1, 2015 until date of deposition.
DEMAND FOR PRODUCTION NO. 5:
Any all contracts between SCG America Group, Inc. and the City of Garden Grove related to SITE C during the time period January 1, 2015 until date of deposition.

DEMAND FOR PRODUCTION NO. 4:
Any and all DOCUMENTS which evidence pro formas and/or projections of Transient Occupancy Tax rebates from the City of Garden Grove to be received in connection with the PROJECT during the time period January 1, 2015 until date of deposition.
DEMAND FOR PRODUCTION NO. 5:
Any and all DOCUMENTS which evidence pro formas and/or projections of Sales Tax rebates from the City of Garden Grove to be received by in connection with the PROJECT during the time period January 1, 2015 until date of deposition.
DEMAND FOR PRODUCTION NO. 6:
Any and all appraisals for SITE C and/or the adjacent acquired parcels during the time period January 1, 2015 until date of deposition.
DEMAND FOR PRODUCTION NO. 7:
Any and all DOCUMENTS that evidence all monetary funds deposited with the City of Garden Grove in anyway related to SITE C and/or the PROJECT.
DEMAND FOR PRODUCTION NO. 8:
Any and all DOCUMENTS that evidence all monetary funds deposited in any escrow in anyway related to SITE C and/or the PROJECT.
DEMAND FOR PRODUCTION NO. 10:
Any and all DOCUMENTS that evidence all loans or other encumbrances placed on are in anyway related to SITE C and/or the PROJECT.
DEMAND FOR PRODUCTION NO. 11:
Any and all DOCUMENTS that evidence all loans or other encumbrances placed on or which are in anyway related to the real properties