Richard Anderson, Esq



Exhibit A to Motion for Protective Order

GERIATRIC MEDICAL GROUP

123 MIDDLEFIELD ROAD

SEASIDE, CA 95555

March 17, 2004

MEMO TO: Richard Anderson

FROM: YEE HONG, M.D.

RE: RUTH MARTIN

Ruth Martin has been my patient for the past 4 years. She is 92 years old, and currently suffering from diabetes and heart disease, chronic emphysema and anxiety.

She is not in any condition to be deposed, and I do not see that she ever will be. As I understand it, she could be required to answer written questions instead, which she should be able to do within a month or so if her condition continues to improve.

EXHIBIT A

Exhibit B to Motion for Protective Order

Richard Anderson, Esq.

Counselor at Law

THE LAW OFFICES OF RICHARD ANDERSON

999 The Heights, 35th Floor

Vista Del Mar, CA 95555

Tel:(555) 555-5555

Fax: (555) 555-5558

March 14, 2004

By Facsimile: 555-6789

Miller Simons, Esq.

The Simons Law Group

999 the Heights, Suite 301

Vista Del Mar, CA 95555

Re: Smart v. Martin

Dear Mr. Simons,

The purpose of this letter is to attempt to persuade you again to take the deposition of Ruth Martin off calendar until her health returns, and then to reschedule it as a deposition on written questions.

As you know, Ms. Martin is 92, and in poor health. Even as I write this letter my legal assistant is working with her doctor to obtain a declaration regarding her condition. It is Dr. Hong’s adamant position that she cannot be deposed at this time. Once her health returns, which may be in a few weeks, she could be deposed on written questions. Since even your pleadings show that you do not believe that she had any first hand knowledge about the premises, and that any source of fraud would be based on written documents she was given upon inheriting the property, I do not see how a deposition written questions would deprive you of any meaningful discovery.

If you agree to take the deposition on written questions, and later determine that it did not provide you with adequate discovery, we could address the issue again.

If you are not willing to take the deposing off calendar, and consider taking it on written questions, I will have no choice but to seek a protective order, and ask for sanctions against you.

Please contact me at your earliest opportunity to resolve this matter.

Sincerely,

Richard Anderson, Esq.

Counselor at Law

RA/llp\

EXHIBIT B

Exhibit C to Motion for Protective Order

Richard Anderson, Esq.

Counselor at Law

THE LAW OFFICES OF RICHARD ANDERSON

999 The Heights, 35th Floor

Vista Del Mar, CA 95555

Tel:(555) 555-5555

Fax: (555) 555-5558

March 15, 2004

By Facsimile: 555-6789

Miller Simons, Esq.

The Simons Law Group

999 the Heights, Suite 301

Vista Del Mar, CA 95555

Re: Smart v. Martin

Dear Mr. Simons,

This letter will confirm our telephone conversation of today. I had written you March 12, 2004 to ask that you take the deposition of Ruth Martin off calendar until her health returns, and then to reschedule it as a deposition on written questions.

You responded to my letter by telephone call today, and refused to take the deposition off calendar, or to consider taking it on written questions.

You leave me no choice but to seek a protective order, and ask for sanctions against you.

Please let me know if you change your mind.

Sincerely,

Richard Anderson, Esq.

Counselor at Law

RA/llp\

EXHIBIT C

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