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PLEASE TAKE NOTICE that on August 27, 2026, at 9:30 a.m. in Department 9 of the above-referenced court located at 111 N. Hill Street, Los Angeles, California 90012, respondent Matthew Barkohanai, Trustee of The Second Amended and Restated George Saadian Revocable Living Trust (“Trustee”) will move the Court for an order compelling Bobby B. Saadian (“Bobby” or “Deponent”) to comply with the subpoena for deposition, order attend Bobby to attend a deposition and testify and produce all documents requested in Demand No. 1 on a date to be determined by this Court or by counsel for movant.1 Bobby has refused, and continues to refuse, to comply with a deposition subpoena, appear for deposition and produce the requested documents as demonstrated in the Declarations of Brian C. Lysaght and Natasha Riggs and the accompanying exhibits.
The Trustee also moves for an order that Bobby pay the moving party the sum of $500 in contempt sanctions under Code of Civ. Proc. Section 1992 and reasonable costs and attorney’s fees incurred by the moving party in connection with this proceeding in the amount of $4,410.00 under Code of Civ. Proc. Sections 2020.240; 2023.020; 2023.030; 2025.480, for a total sanctions amount of $4,910.00
This Motion is made on the grounds that the deposition is relevant to the subject matter of this action, and that Bobby’s refusal to be deposed and produce documents is without sufficient justification. (Code of Civ. Proc. §§ 2017.010; 2019.010(a); 2020.310; 2020.510; 2025.480; Probate Code § 1000.) The Trustee has made good faith attempts at informal resolution of the issues presented by this motion as set forth in the attached meet and confer declarations pursuant to Section 2016.040. The witness is an experienced attorney who is knowledgeable about the consequences of failure to comply with a subpoena. An order of contempt, award of sanctions, attorneys’ fees and costs against the Due to the commonality of Bobby Saadian’s last name with his cousin Petitioner Jonah Saadian, the settlor and others, those persons are referred to by their first name. No disrespect is intended.
witness for his refusal to be deposed is justified. (Code Civ. Proc. §§ 2023.020; 2025.430, 2025. 440, 2020.240; 2023.020.)
This Motion is based on this notice, the points and authorities set forth below, the attached Declarations of Brian C. Lysaght, Natasha Riggs, and Matthew Barkohanai, Exhibits A-I, the accompanying Separate Statement, oral argument, and the files and records of this action.
By this motion, Matthew Barkohanai, trustee of The Second Amended and Restated George Saadian Revocable Living Trust seeks an order compelling nonparty witness Bobby B. Saadian to appear and testify at a deposition and produce the requested documents in compliance with a valid and properly served subpoena.
This motion is necessary because the witness Bobby refused to appear for his properly noticed deposition on November 7, 2025. (See Exhibits A, B, E.) The subpoena was issued on October 9 and personally served on the witness a few days later, on October 12, 2025. (Exhibit A, C.)
On October 31, 2025, the witness served written objections stating that “Responding Party is unavailable on that date.” (Exhibit D.) The witness further justified his failure to appear by stating he has “no knowledge relevant to the dispute”. That is not valid basis for refusing to testify and produce. He also objected on the grounds that the Trustee has access to information from Petitioner Jonah and the Trustee, rendering Bobby’s deposition unnecessary. That is not an excuse recognized in California law either. A witness cannot refuse to comply with a subpoena by stating he has no information.
Beneficiary Jonah has filed a petition to remove and surcharge the Trustee Matthew Barkohanai for alleged transgressions in the administration of the trust. The other two beneficiaries are the estate of the settlor’s mother and the settlor’s surviving girlfriend/partner, neither of whom has joined in the petition.
The Trustee is entitled to the discovery at issue because of written and verbal threats the witness has made against the Trustee, including financing litigation by Jonah, as well as by Jonah’s brother, against the Trustee. (Exhibits H, I.) Barkohanai is also the
trustee of separate trusts in which Jonah and Brandon are the sole beneficiaries (the related cases.)
Jonah and his brother Brandon are unhappy with the terms of the trust. They are represented by the same attorneys. Jonah is unhappy that he was not selected as trustee and was not given a larger beneficiary percentage of the trust. Brandon is upset that his father disinherited him and did not name him as a successor trustee.
The Trustee’s administration of this complex trust has been exemplary. The trust held multiple real properties located in California, Nevada and Israel, as well as numerous entities and valuable personal property which Jonah and Brandon refuse to turn over. The Trustee has now sold five of the multi-million real properties resulting in net income to the trust and large cash distributions to the beneficiaries. Jonah’s Petition demonstrates an intent to harass the Trustee as well as a fundamental misunderstanding of tax rules and misrepresents tax consequences of the sale of trust assets.
The Trustee has successfully resolved at least ten lawsuits by third parties involving the trust and its assets. Jonah has filed several petitions causing unnecessary fees and expenses for the trust. For example, he objected to the profitable sale of one of the real properties tying up the property in litigation and leading to the failure of escrow. Jonah desires to use trust assets to purchase that property but has for years failed to come up with a proposal acceptable to the other beneficiaries.
Bobby Saadian is another of the parties’ cousins. He is a trial attorney and real estate investor. In writing, he has demonstrated knowledge of Jonah and Brandon’s personal disputes with the Trustee. (Exhibit H.) He has threatened to pursue and finance litigation brought by himself, Jonah and Brandon against the Trustee. (Exhibit I.) His threats demonstrate animosity towards the Trustee apparently arising out of an unrelated real estate dispute. Given those threats, the existence and extent of Bobby’s involvement in efforts to remove and surcharge the Trustee and the reasons behind doing so are relevant to the motives behind the petition and the Trustee’s defense.
A valid subpoena for the deposition testimony and production of business records of third party witness Bobby Saadian was issued on October 9, 2025. (Exhibit A.) The subpoena and notice of deposition was personally served on the witness on October 12, 2025. (Exhibit C.) The date and time for the deposition was November 7, 2025. The location was 8 miles from Bobby’s residence. (Riggs Declaration, ¶ 2.)
After Bobby was served, counsel for Bobby contacted the Trustee’s counsel. (Lysaght Declaration, ¶ 2.) Bobby’s counsel did not state Bobby was unavailable on the noticed date. (Id.) Instead, he stated that he would try to convince Bobby to appear. (Id.) He asked if Bobby could be appear on that date remotely. (Id.) The Trustee’s counsel confirmed that the Bobby had to appear in person because the deposition was going to be videotaped. (Id., Exhibit G.)
Ten days later, Bobby served written objections to the subpoena. (Exhibit D.) He did not show up on the scheduled date, has not produced any documents, and has failed to respond to requests to reschedule the deposition.
The rules and procedures relating to discovery in civil actions, including those set forth in the Civil Discovery Act, are equally applicable to probate actions. (See Probate Code § 1000.) The basic purpose of all discovery is to take the “game” element out of case preparation by enabling parties to obtain the evidence necessary to evaluate and resolve their dispute beforehand. (Emerson Electric Co. v. Superior Court (1997) 16 Cal.4th 1101, 1107.) Each party has a presumptive right to inquire about any matter which – based on reason, logic and common sense – might (1) be admissible, (2) lead to admissible evidence, or (3) reasonably assist that party in evaluating the case, preparing for trial and/or facilitating resolution. (See Code Civ. Proc. § 2017.010; Williams v.
Superior Court (2017) 3 Cal.5th 531, 557.) Courts construe the right to discovery liberally to permit discovery whenever possible. (Williams, id at 541.)
In this case, Bobby has information regarding the Petition, including the motives for bringing it, a valid and proper subject matter of discovery by the Trustee. He has already demonstrated knowledge of the disputes in written and verbal threats to the Trustee. (Exhibits H, I.) He has threatened to finance the petition and disrupt the orderly administration of the trust. The witness has an incentive to do so because of disputes he has with the Trustee in an unrelated real estate matter.
“[D]iscovery from a nonparty may be obtained only by ‘deposition subpoena.’” (Unzipped Apparel, LLC v. Bader (2007) 156 Cal.App.4th 123, 130; Code Civ. Proc. § 2025.010 (b).) Personal service of a deposition subpoena obligates the witness to appear in any proceedings to enforce discovery and is effective to require personal attendance and testimony of the witness. (Code Civ. Proc. § 2020.220(c).) If a nonparty disobeys a deposition subpoena, the subpoenaing party may seek a court order pursuant to Code of Civ. Proc. Section 1987.1 compelling the nonparty to comply with the subpoena within 60 days after completion of the deposition record. (Code Civ. Proc. § 2025.480(b); Unzipped Apparel, id. at 127.)
Here, a subpoena which complied with California law was properly issued and personally served. (Exhibit A.) (See Code Civ. Proc. §§ 2020.210(b); 2020.220(b).) The subpoena was served well before the date of the deposition. (See Code Civ. Proc. § 2020.220(a).) The place of the deposition was about a 15-20 minute drive from the witness’ residence. (Riggs Declaration, ¶ 2.) The start time was 1:00 p.m.
The witness served objections to the subpoena served on October 31, 2025. (Exhibit D.) His objections included the statement that the date and time of the deposition was unilaterally selected and he was “unavailable”. (Exhibit D.) Bobby did not file a
motion to quash the subpoena. He did not seek a protective order. The objection that he was not available was not raised by his counsel during a pre-deposition call. (Lysaght Declaration, ¶ 2.) The witness refuses to appear and testify. He refuses to produce any of the requested documents.
The court may award monetary and contempt sanctions against nonparties and their attorneys who flout the discovery process by ignoring subpoenas. Sanctions are appropriate where a nonparty witness fails to appear. If a deponent on whom a deposition subpoena has been served fails to attend a deposition, the court may impose on the deponent sanctions described in Code of Civil Procedure Section 2020.240. (Code Civ. Proc. §2025.440(b).) Those sanctions include contempt, as well as a civil action for damages, with a minimum forfeiture of $500.00. (Code Civ. Proc. §§ 1992; 2020.240.)
The Code provides for contempt sanctions against nonparties who have been personally served with deposition subpoenas. Section 2025.440 states that if a deponent “fails to attend a deposition,” the Court may hold that witness in contempt. These sanctions are available even absent “a prior order of court directing compliance by the witness.” (C.C.P. § 2020.240.) Code of Civil Procedure Section 2020.240 provides:
A deponent who disobeys a deposition subpoena in any manner described in
subdivision (c) of Section 2020.220 may be punished for contempt under
Chapter 7 (commencing with Section 2023.010) without the necessity of a
prior order of court directing compliance by the witness. The deponent is
also subject to the forfeiture and the payment of damages set forth in
Section 1992.
Here the witness is an experienced attorney who understands the consequences of failure to comply with subpoena for deposition testimony. Yet he persists in misusing the discovery process. (See Code of Civ. Proc. § 2023.010 (d), (f).) The Trustee requests an award of sanctions in the amount of $500 under Section 1992 against Bobby Saadian for his unjustified refusal to comply with the subpoena and $4,410 in fees and costs for having to bring this motion.
The Trustee respectfully requests that the Court order Bobby Saadian to appear and testify at a deposition on a date set by this Court or by counsel for the Trustee and to produce all documents responsive to Demand No. 1.
The witness, the founder of a large law firm, knows that inconvenience or not wanting to be bothered with a deposition is not an excuse for a not appearing after a valid subpoena was properly and timely served. Contempt sanctions in the amount of $500 and attorneys’ fees and costs in having to bring this motion in the amount of $4,410 should also be awarded against the witness.
I, Natasha Riggs, declare and state as follows.
1. I am an attorney licensed to practice law in the state of California and other jurisdictions. I am one of the attorneys for respondent Matthew Barkohanai, Trustee of The Second Amended and Restated George Saadian Revocable Living Trust in this case. I make this declaration on personal knowledge in support of the Trustee’s Motion seeking an order compelling third party Bobby B. Saadian to comply with a subpoena and appear at a deposition and for an award of $4,910 in sanctions for his failure to comply and for having to bring this motion.
Subpoena and Meet and Confer Attempt
2. Attached hereto as Exhibit A is a true and correct copy of the Deposition Subpoena for Personal Appearance and production of Things which I issued on October 9, 2025. The deposition was set for November 7, 2025 at 1:00 p.m. at my office address in Santa Monica, approximately 8 miles from Bobby Saadian’s residence in Pacific Palisades which is about a 15-20 minute drive from the deposition location.
3. Attached hereto as Exhibit B is a true and correct copy of the Notice of Bobby Saadian’s deposition dated October 9, 2025.
4. Attached hereto as Exhibit C is a true and correct copy of the proof of service of the subpoena on Bobby Saadian. Bobby was served on October 12, 2025.
5. Attached hereto as Exhibit D is a true and correct copy Bobby Saadian’s Objections to Subpoena, Notice of Deposition and Request to Produce at Deposition dated October 31, 2025.
6. Attached here as Exhibit E is a true and correct copy of pages 1-8 from the court reporter’s November 7, 2025 Certificate of Non Appearance of Bobby Saadian.
7. Attached hereto as Exhibit F is a true and correct copy of my email sent to John Lucas, general counsel of Bobby Saadian’s law firm on December 1, 2025. In that email, I again requesting a meet and confer about Bobby Saadian’s refusal to appear at a deposition. As of the filing of this motion, I have not heard back. In Exhibit F, below my
I, Brian C. Lysaght, declare and state as follows.
1. I am an attorney licensed to practice law in the state of California and other jurisdictions. I am chief counsel for respondent Matthew Barkohanai, Trustee of The Second Amended and Restated George Saadian Revocable Living Trust in this case. I make this declaration on personal knowledge in support of the Trustee’s Motion seeking an order compelling third party Bobby B. Saadian to comply with a subpoena and appear at a deposition and for an award of $4,910.00 in sanctions for his failure to comply and for having to bring this motion.
2. On October 21, 2025, I spoke with John Lucas, general counsel for the Wilshire Law Firm of which Bobby Saadian is a partner. Mr. Lucas stated that he was acting as the legal representative of Saadian. Mr. Lucas did not advise me that Saadian was unavailable on the scheduled date. He stated that Saadian wanted his deposition after the party depositions. I responded that due to scheduling issues that was not possible. Mr. Lucas stated that Saadian had nothing to say about the trust litigation although we briefly discussed Saadian’s text messages to the Trustee about the subject. I advised him that a deposition cannot be avoided based on the witness’ unsworn denials of relevant information. Mr. Lucas stated he would “try” to get Saadian to appear for his deposition. He inquired about Mr. Saadian appearing remotely and remarked that it may be easier to get Saadian to appear remotely. Shortly after the phone call, I sent Mr. Lucas an email informing him that Saadian would have to appear in person because his deposition was going to be videotaped. A true and correct copy of that email dated October 21, 2025 is appended as Exhibit G.
3. Saadian did not appear on the scheduled date for his deposition. I phoned Mr. Lucas’ cell phone and left a message asking about the non-appearance. I also phoned the Wilshire Law firm and was told Mr. Lucas was not available so I left another message on his firm voicemail. Later that afternoon, Mr. Lucas sent me an email stating that he “assumed” we “will be able to obtain seek whatever it is we are seeking from the parties”.
That is not a valid basis for refusing to appear. A true and correct copy of that email is on page 2 of Exhibit F hereto and a true and correct copy of my response is on page 1.
4. My rate of $700 per hour in this case is reasonable in light of my seniority and experience. The Laffee Index of rates in the Southern California region justifies an hourly rate of over $1,000 for me.
5. After graduating from Johns Hopkins University with an MLA I received my J.D. from the University of California at Davis in 1974. After law school I clerked for Justice Stanley Mosk for the California Supreme Court’s 1974-1975 term after which I became a litigation associate at O’Melveny and Myers in Los Angeles. Thereafter I was a federal prosecutor with the Antitrust Division of the United States Department of Justice. In 1985 I formed O’Neill, Lysaght & Sun LLP. In 2003 I accepted a position as a partner and head of Southern California Litigation at the international firm of DLA Piper. I formed my present firm Lysaght Law Group LLP in 2011.
6. I have been qualified, deposed and testified as an expert witness on the subject of federal jury trial practice and procedure. I have had extensive jury and court trial and appellate experience in state and federal courts in various jurisdictions including New York, Washington, California, Colorado, Nevada and New Mexico. In 2011 I became licensed as a solicitor with a practicing certificate in England and Wales.
7. I have served two terms on the Board of Directors of the Association of Business Trial Lawyers and two terms as an appointed member of the Judicial Nomination and Evaluation Commission (“JNE Commission”). I am currently serving a three-year term as an appointed member of the federal Magistrate Merit Selection Panel, which vets candidates and issues recommendations regarding potential United States Magistrate Judges to the Chief Judge of the Central District of California.
8. I believe that my experience justifies my fee rate of &4and that of my partner Natasha Riggs in this case. The Laffee Index of rates in the Southern California region justifies an hourly rate of over $1,000 for me.
9. I have spent over 1.00 hours in connection with the drafting and preparation
I, Matthew Barkohanai, declare and state as follows.
1. I am the Trustee of The Second Amended and Restated George Saadian Revocable Living Trust. I make this declaration on personal knowledge in support of the Motion seeking an order compelling third party Bobby B. Saadian to comply with a subpoena and appear at a deposition and for an award of $4,410.00 in attorneys’ fees and costs and contempt sanctions in the amount of $500.
2. Attached hereto as Exhibit H are true and correct copies of text messages from Bobby Saadian to me sent on November 11, 2024. Bobby states in part:
“ I am aware of how you are abusing Jonah and Brandon
The Last thing you want is for me to join them in a lawsuit against you.”
3. Attached here as Exhibit I is are true and correct copies of text messages from Bobby Saadian to me sent on November 14, 2024. Saadian states in part that he “is going to fund Brandon and Jonah’s lawsuit against you as well”.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true incorrect, and that this declaration was executed on December 13, 2025 at Los Angeles, California.
Matthew Barkohanai
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
STREET ADDRESS: 111 N. Hill Street MAILING ADDRESS: 111 N. Hill Street CITY AND ZIP CODE: Los Angeles 90012 BRANCH NAME: Stanley Mosk Courthouse
DEFENDANT/ RESPONDENT: Matt Barkohanai, as Trustee of the Second Amended and Restated
THE PEOPLE OF THE STATE OF CALIFORNIA, TO (name, address, and telephone number of deponent, if known): Bobby Babak Saadian, Wilshire Law Firm, PLC, 3055 Wilshire Blvd Fl 12, Los Angeles, CA 90010; Tel: 213-381-9988 1. YOU ARE ORDERED TO APPEAR IN PERSON TO TESTIFY AS A WITNESS in this action at the following date, time, and place: Date: November 7, 2025 Time: 1:00 p.m. Address: 401 Wilshire Blvd., 12th Floor, Santa Monica CA 90401 a. As a deponent who is not a natural person, you are ordered to designate one or more persons to testify on your behalf as
to the matters described in item 4. (Code Civ. Proc., § 2025.230.) b. You are ordered to produce the documents and things described in item 3. c. This deposition will be recorded stenographically through the instant visual display of testimony
and by audiotape videotape. d. This videotape deposition is intended for possible use at trial under Code of Civil Procedure section 2025.620(d). 2. The personal attendance of the custodian or other qualified witness and the production of the original records are required by this subpoena. The procedure authorized by Evidence Code sections 1560(b), 1561, and 1562 will not be deemed sufficient compliance with this subpoena. 3. The documents and things to be produced and any testing or sampling being sought are described as follows:
See Attachment 3.
Continued on Attachment 3. 4. If the witness is a representative of a business or other entity, the matters upon which the witness is to be examined are described as follows:
Continued on Attachment 4. 5. IF YOU HAVE BEEN SERVED WITH THIS SUBPOENA AS A CUSTODIAN OF CONSUMER OR EMPLOYEE RECORDS UNDER CODE OF CIVIL PROCEDURE SECTION 1985.3 OR 1985.6 AND A MOTION TO QUASH OR AN OBJECTION HAS BEEN SERVED ON YOU, A COURT ORDER OR AGREEMENT OF THE PARTIES, WITNESSES, AND CONSUMER OR EMPLOYEE
6. At the deposition, you will be asked questions under oath. Questions and answers are recorded stenographically at the deposition; later they are transcribed for possible use at trial. You may read the written record and change any incorrect answers before you sign the deposition. You are entitled to receive witness fees and mileage actually traveled both ways. The money must be paid, at the option of the party giving notice of the deposition, either with service of this subpoena or at the time of the deposition. Unless the court orders or you agree otherwise, if you are being deposed as an individual, the deposition must take place within 75 miles of your residence or within 150 miles of your residence if the deposition will be taken within the county of the court where the action is pending. The location of the deposition for all deponents is governed by Code of Civil Procedure section 2025.250. DISOBEDIENCE OF THIS SUBPOENA MAY BE PUNISHED AS CONTEMPT BY THIS COURT. YOU WILL ALSO BE LIABLE
Date issued: October 9, 2025
(Proof of service on reverse) Page 1 of 2 Form Adopted for Mandatory Use Code of Civil Procedure §§ 2020.510, Judicial Council of California DEPOSITION SUBPOENA FOR PERSONAL APPEARANCE 2025.220, 2025.230, 2025.250, 2025.620; SUBP-020 [Rev. January 1, 2009] Government Code, § 68097.1
AND PRODUCTION OF DOCUMENTS AND THINGS www.courts.ca.gov
DEFENDANT/RESPONDENT: Matt Barkohanai, as Trustee of the Second Amended 2STPB12471
1. I served this Deposition Subpoena for Personal Appearance and Production of Documents and Things by personally delivering a copy to the person served as follows: a. Person served (name): b. Address where served: c. Date of delivery: d. Time of delivery: e. Witness fees and mileage both ways (check one):
(1) were paid. Amount: . . . . . . . . . . . $
(2) were not paid.
(3) were tendered to the witness's
public entity employer as
required by Government Code
section 68097.2. The amount
tendered was (specify): . . . . . . . $ f. Fee for service: . . . . . . . . . . . . . . . . . . . . $ 2. I received this subpoena for service on (date): 3. Person serving: a. Not a registered California process server b. California sheriff or marshal c. Registered California process server. d. Employee or independent contractor of a registered California process server e. Exempt from registration under Business and Professions Code section 22350(b) f. Registered professional photocopier g. Exempt from registration under Business and Professions Code section 22451 h. Name, address, telephone number, and, if applicable, county of registration and number: I declare under penalty of perjury under the laws of the State of (For California sheriff or marshal use only) California that the foregoing is true and correct. I certify that the foregoing is true and correct. Date: Date:
SUBP-020 [Rev. January 1, 2009] PROOF OF SERVICE Page 2 of 2
In the matter of The Second Amended and Restated George Saadian Revocable Living Trust, as
amended and restated, L.A.S.C. Case No. 26TPB12471
1. Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian, relating to Jonah Saadian’s Petition to Remove or Suspend Matthew Barkohanai as trustee of The Second Amended and Restated George Saadian Revocable Living Trust, as amended and restated (“GS TRUST”).
2. Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian, regarding Matthew Barkohanai, from February 1, 2025 to the present.
3. Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian, relating to Matthew Barkohanai’s administration of the GS TRUST.
3 Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian, relating to the GS TRUST.
4. Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian, relating to the real property located at 12235 Beach Blvd in Stanton California 90680 (the “Beach Property”), from February 1, 2021 to the present.
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5. Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian, relating to the real property located at 405 Evelyn Place, Beverly Hills, California 90210 (the “Evelyn Property”), from February 1, 2025 to the present.
6. Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian, relating to sale of the real property located at 660-670 Monterey Pass Road in Monterey Park, California 91754 (“Monterey Park Property”), from February 1, 2021 to the present.
7. Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian, relating to GS TRUST accountings from February 1, 2025 to the present.
8. Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian, relating to rents paid to Branmark Group for the residential use of the Evelyn Property, from February 1, 2021 to the present.
9. Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to the Jonah Saadian, relating to Jonah Saadian’s efforts to name Brandon A. Saadian a beneficiary of the GS TRUST.
10. Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian relating to distributions from the GS TRUST, from February 1, 2021 to the present.
11. All documents relating to Jonah Saadian’s legal costs, including attorney’s fees in
the Los Angeles Superior Court probate case In the matter of The Second Amended and Restated
George Saadian Revocable Living Trust, as amended and restated, L.A.S.C. Case No.
25STPB12471, including but not limited to emails, text messages, copies of confirmations of
payments whether by check, draft, Zelle, wire, ACH or Venmo.
Dated: October 9, 2025 LYSAGHT LAW GROUP LLP
Case No. 2STPB12471 In the matter of:
(Assigned to Hon. Ruben Garcia, Dept. 9) The Second Amended and Restated George Saadian Revocable Living Trust, as TRUSTEE AND RESPONDENT amended and restated. MATTHEW BARKOHANAI’S NOTICE OF
Date: November 7, 2025
Time: 1:00 p.m.
Place: 401 Wilshire Blvd., 12th Floor
Santa Monica, CA 90401
Tel: 424-252-4747
which an objection is made; and (ii) specifically set forth any and all grounds for the objection. Said objection must be served on counsel for the TRUSTEE at least three days prior to the deposition. (C.C.P. § 2025.410(a).) If any objection is made three calendar days before the deposition date, the objecting party shall personally serve counsel for the TRUSTEE with said objection. (C.C.P. § 2025.410(b).)
1. Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian, relating to Jonah Saadian’s Petition to Remove or Suspend Matthew Barkohanai as trustee of The Second Amended and Restated George Saadian Revocable Living Trust, as amended and restated (“GS TRUST”).
2. Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian, regarding Matthew Barkohanai, from February 1, 2025 to the present.
3. Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian, relating to Matthew Barkohanai’s administration of the GS TRUST.
3 Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian, relating to the GS TRUST.
4. Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian, relating to the real property located at 12235 Beach Blvd in Stanton California 90680 (the “Beach Property”), from February 1, 2021 to the present.
5. Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian, relating to the real property located at 405 Evelyn Place, Beverly Hills, California 90210 (the “Evelyn Property”), from February 1, 2025 to the present.
6. Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian, relating to sale of the real property located at 660-670 Monterey Pass Road in Monterey Park, California 91754 (“Monterey Park Property”), from February 1, 2021 to the present.
7. Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian, relating to GS TRUST accountings from February 1, 2025 to the present.
8. Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian, relating to rents paid to Branmark Group for the residential use of the Evelyn Property, from February 1, 2021 to the present.
9. Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to the Jonah Saadian, relating to Jonah Saadian’s efforts to name Brandon A. Saadian a beneficiary of the GS TRUST.
10. Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian relating to distributions from the GS TRUST, from February 1, 2021 to the present.
11. All documents relating to Jonah Saadian’s legal costs, including attorney’s fees in
the Los Angeles Superior Court probate case In the matter of The Second Amended and Restated
George Saadian Revocable Living Trust, as amended and restated, L.A.S.C. Case No.
2STPB12471, including but not limited to emails, text messages, copies of confirmations of
payments whether by check, draft, Zelle, wire, ACH or Venmo.
Dated: October 9, 2025
In the matter of: CASE NO.: 23STPB12471
[Assigned for all purposes to the Hon. Ruben The Second Amended and Restated George Garcia, Dept. 9] Saadian Revocable Living Trust, as amended and restated. THIRD PARTY BOBBY SAADIAN’S
OBJECTIONS TO SUBPOENA,
Defendant. DEPOSITION NOTICE, AND DOCUMENT
Date: November 7, 2025
Time: 1:00 p.m.
Place: 401 Wilshire Blvd.12th Floor
Santa Monica, CA 90401
Third Party Bobby Saadian’s Objections to Deposition Notice and Document Requests
Third Party Bobby Saadian (“Responding Party”) hereby responds and objects to the Subpoena, Deposition Notice, and accompanying document requests (sometimes collectively referred to as the “Notice”) of Trustee and Respondent Matthew Barkohanai (“Trustee”), as follows:
1. Responding Party objects to the Deposition Notice and Subpoena on the grounds that Responding Party has no knowledge relevant to the dispute, is neither a trustee or beneficiary of the subject trust, and has no documents responsive to the attached requests that could be relevant to this dispute. Responding Party’s counsel informed Trustee’s counsel of these facts, but Trustee’s counsel plans to proceed with seeking the deposition and documents anyway, simply to harass Responding Party.
2. Responding Party further objects to the Deposition Notice and Subpoena on the grounds that Trustee has access to any information it needs from Petitioners and Trustee, rendering Responding Party’s deposition unnecessary and duplicative. Indeed, Trustee conceded that he has not received documents or testimony from Petitioners, but is seeking this information from Responding Party first, again making clear that the only purpose of this is to harass Responding Party.
3. Responding Party further objects to the Deposition Notice and Subpoena on the grounds that Trustee unilaterally selected the date and time of the deposition and Responding Party is unavailable on that date.
Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian, relating to Jonah Saadian’s Petition to Remove or Suspend Matthew Barkohanai as trustee of The Second Amended and Restated George Saadian Revocable Living Trust, as amended and restated (“GS TRUST”).
Responding Party objects to this request on the grounds that it is vague and ambiguous, overly broad, vague and ambiguous as to time, not related to the matters in controversy, and not sufficiently specific. Responding Party further objects to this request on the grounds that it is burdensome and harassing. Responding Party further objects to this request on the grounds
Third Party Bobby Saadian’s Objections to Deposition Notice and Document Requests that it is not reasonably calculated to lead to the discovery of admissible evidence. Responding Party further objects to this request on the grounds that it lacks foundation and assumes facts not in evidence. Responding Party further objects to this request on the grounds that it purports to seek information that is already in Defendant’s possession or that is equally available to Trustee. Responding Party further objects to this request on the grounds that it seeks the disclosure of confidential, proprietary, or sensitive business information or trade secrets of Responding Party and/or third parties. Responding Party further objects to this request on the grounds that it seeks information that is protected by the right of privacy of Responding Party or other persons or entities as guaranteed by the California and United States Constitutions.
Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian, regarding Matthew Barkohanai, from February 1, 2025 to the present.
Responding Party objects to this request on the grounds that it is vague and ambiguous, overly broad, not related to the matters in controversy, and not sufficiently specific. Responding Party further objects to this request on the grounds that it is burdensome and harassing. Responding Party further objects to this request on the grounds that it is not reasonably calculated to lead to the discovery of admissible evidence. Responding Party further objects to this request on the grounds that it seeks the disclosure of confidential, proprietary, or sensitive business information or trade secrets of Responding Party and/or third parties. Responding Party further objects to this request on the grounds that it seeks information that is protected by the right of privacy of Responding Party or other persons or entities as guaranteed by the California and United States Constitutions.
Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian, relating to the GS TRUST.
Responding Party objects to this request on the grounds that it is vague and ambiguous, overly broad, vague and ambiguous as to time, not related to the matters in controversy, and
Third Party Bobby Saadian’s Objections to Deposition Notice and Document Requests not sufficiently specific. Responding Party further objects to this request on the grounds that it is burdensome and harassing. Responding Party further objects to this request on the grounds that it is not reasonably calculated to lead to the discovery of admissible evidence. Responding Party further objects to this request on the grounds that it lacks foundation and assumes facts not in evidence. Responding Party further objects to this request on the grounds that it purports to seek information that is already in Defendant’s possession or that is equally available to Trustee. Responding Party further objects to this request on the grounds that it seeks the disclosure of confidential, proprietary, or sensitive business information or trade secrets of Responding Party and/or third parties. Responding Party further objects to this request on the grounds that it seeks information that is protected by the right of privacy of Responding Party or other persons or entities as guaranteed by the California and United States Constitutions.
Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian, relating to the real property located at 12235 Beach Blvd in Stanton California 90680 (the "Beach Property"), from February 1, 2021 to the present.
Responding Party objects to this request on the grounds that it is vague and ambiguous, overly broad, vague and ambiguous as to time, not related to the matters in controversy, and not sufficiently specific. Responding Party further objects to this request on the grounds that it is burdensome and harassing. Responding Party further objects to this request on the grounds that it is not reasonably calculated to lead to the discovery of admissible evidence. Responding Party further objects to this request on the grounds that it lacks foundation and assumes facts not in evidence.
Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian, relating to the real property located at 405 Evelyn Place, Beverly Hills, California 90210 (the “Evelyn Property”), from February 1, 2021 to the present.
Third Party Bobby Saadian’s Objections to Deposition Notice and Document Requests
Responding Party objects to this request on the grounds that it is vague and ambiguous, overly broad, vague and ambiguous as to time, not related to the matters in controversy, and not sufficiently specific. Responding Party further objects to this request on the grounds that it is burdensome and harassing. Responding Party further objects to this request on the grounds that it is not reasonably calculated to lead to the discovery of admissible evidence. Responding Party further objects to this request on the grounds that it lacks foundation and assumes facts not in evidence.
Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian, relating to sale of the real property located at 660-670 Monterey Pass Road in Monterey Park, California 91754 ("Monterey Park Property"), from February 1, 2021 to the present.
Responding Party objects to this request on the grounds that it is vague and ambiguous, overly broad, vague and ambiguous as to time, not related to the matters in controversy, and not sufficiently specific. Responding Party further objects to this request on the grounds that it is burdensome and harassing. Responding Party further objects to this request on the grounds that it is not reasonably calculated to lead to the discovery of admissible evidence. Responding Party further objects to this request on the grounds that it lacks foundation and assumes facts not in evidence.
Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian, relating to GS TRUST accountings from February 1, 2025 to the present.
Responding Party objects to this request on the grounds that it is vague and ambiguous, overly broad, vague and ambiguous as to time, not related to the matters in controversy, and not sufficiently specific. Responding Party further objects to this request on the grounds that it is burdensome and harassing. Responding Party further objects to this request on the grounds
Third Party Bobby Saadian’s Objections to Deposition Notice and Document Requests that it is not reasonably calculated to lead to the discovery of admissible evidence. Responding Party further objects to this request on the grounds that it lacks foundation and assumes facts not in evidence.
Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian, relating to rents paid to Branmark Group for the residential use of the Evelyn Property, from February 1, 2021 to the present.
Responding Party objects to this request on the grounds that it is vague and ambiguous, overly broad, vague and ambiguous as to time, not related to the matters in controversy, and not sufficiently specific. Responding Party further objects to this request on the grounds that it is burdensome and harassing. Responding Party further objects to this request on the grounds that it is not reasonably calculated to lead to the discovery of admissible evidence. Responding Party further objects to this request on the grounds that it lacks foundation and assumes facts not in evidence.
Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to the Jonah Saadian, relating to Jonah Saadian's efforts to name Brandon A. Saadian a beneficiary of the GS TRUST.
Responding Party objects to this request on the grounds that it is vague and ambiguous, overly broad, vague and ambiguous as to time, not related to the matters in controversy, and not sufficiently specific. Responding Party further objects to this request on the grounds that it is burdensome and harassing. Responding Party further objects to this request on the grounds that it is not reasonably calculated to lead to the discovery of admissible evidence. Responding Party further objects to this request on the grounds that it lacks foundation and assumes facts not in evidence. Responding Party further objects to this request on the grounds that it purports to seek information that is already in Defendant’s possession or that is equally available to Trustee. Responding Party further objects to this request on the grounds that it seeks the disclosure of confidential, proprietary, or sensitive business information or trade secrets of
Third Party Bobby Saadian’s Objections to Deposition Notice and Document Requests
Responding Party and/or third parties. Responding Party further objects to this request on the grounds that it seeks information that is protected by the right of privacy of Responding Party or other persons or entities as guaranteed by the California and United States Constitutions.
Printed copies of all communications, including but not limited to text messages, emails, and postings on any social media sites such as Instagram and WhatsApp, between you and any person, including but not limited to Jonah Saadian relating to distributions from the GS TRUST, from February 1, 2021 to the present.
Responding Party objects to this request on the grounds that it is vague and ambiguous, overly broad, vague and ambiguous as to time, not related to the matters in controversy, and not sufficiently specific. Responding Party further objects to this request on the grounds that it is burdensome and harassing. Responding Party further objects to this request on the grounds that it is not reasonably calculated to lead to the discovery of admissible evidence. Responding Party further objects to this request on the grounds that it lacks foundation and assumes facts not in evidence. Responding Party further objects to this request on the grounds that it purports to seek information that is already in Defendant’s possession or that is equally available to Trustee. Responding Party further objects to this request on the grounds that it seeks the disclosure of confidential, proprietary, or sensitive business information or trade secrets of Responding Party and/or third parties. Responding Party further objects to this request on the grounds that it seeks information that is protected by the right of privacy of Responding Party or other persons or entities as guaranteed by the California and United States Constitutions.
All documents relating to Jonah Saadian’s legal costs, including attorney’s fees in the Los Angeles Superior Court probate case In the matter of The Second Amended and Restated George Saadian Revocable Living Trust, as amended and restated, L.A.S.C. Case No . 23STPB12471, including but not limited to emails, text messages, copies of confirmations of payments whether by check, draft, Zelle, wire, ACH or Venmo.
Responding Party objects to this request on the grounds that it is vague and ambiguous, overly broad, vague and ambiguous as to time, not related to the matters in controversy, and not sufficiently specific. Responding Party further objects to this request on the grounds that it
Third Party Bobby Saadian’s Objections to Deposition Notice and Document Requests is burdensome and harassing. Responding Party further objects to this request on the grounds that it is not reasonably calculated to lead to the discovery of admissible evidence. Responding Party further objects to this request on the grounds that it lacks foundation and assumes facts not in evidence. Responding Party further objects to this request on the grounds that it purports to seek information that is already in Defendant’s possession or that is equally available to Trustee. Responding Party further objects to this request on the grounds that it seeks the disclosure of confidential, proprietary, or sensitive business information or trade secrets of Responding Party and/or third parties. Responding Party further objects to this request on the grounds that it seeks information that is protected by the right of privacy of Responding Party or other persons or entities as guaranteed by the California and United States Constitutions.
In the Los Angeles, CA Superior Court Matter of
Case No.
Certificate of Nonappearance for
Taken on
Reported By:
In the matter of: ) Case No. 23STPB12471
) The Second Amended and Restated ) George Saadian Revocable Living ) Trust, as amended and restated. )
)
)
)
)
)
)
) _________________________________) Certificate of Nonappearance and Statement on the Record for the Deposition of BOBBY BABAK SAADIAN by Respondent, at 401 Wilshire Boulevard, 12th Floor, Santa Monica, California, commencing at 1:30 p.m., Friday, November 7, 2025, before Melissa Wali, CSR No. 13514.
FOR THE PETITIONER (Not Present):
Attorney at Law 3055 Wilshire Boulevard Floor 12 Los Angeles, California 90010 (213) 381-9988 bobby@wilshirelawfirm.com
Attorneys at Law
401 Wilshire Boulevard
12th Floor
Santa Monica, California 90401
(424) 252-4747
blysaght@lysaghtlegal.com
MATT BARKOHANAI, Respondent BARRETT REPORTING, INC. (888) 740-1100 www.barrettreporting.com
By Mr. Lysaght 5
Exhibit 1 Respondent's Deposition Subpoena 6
for Personal Appearance and
Exhibit 2 Proof of Service of Deposition 6
Subpoena for Personal Appearance
and Production of Documents and
Things Exhibit 3 Trustee and Respondent 6
Matthew Barkohanai's Notice of
Deposition of Bobby Babak Saadian
and Request for Production of
Documents at Deposition BARRETT REPORTING, INC. (888) 740-1100 www.barrettreporting.com
1:30 P.M.
-o0o-
THE REPORTER: My name is Melissa Wali, California certified shorthand reporter No. 13514.
I, Melissa Wali, California certified shorthand Reporter, No. 13514, hereby certify that I am the certified shorthand reporter who appeared at 401 Wilshire Boulevard, 12th Floor, Santa Monica, California, on FRIDAY, NOVEMBER 7, 2025, at 12:45 p.m., for attorney BRIAN C. LYSAGHT for the purpose of taking the deposition of BOBBY BABAK SAADIAN on behalf of the Respondent; that the Respondent's attorney, Ms. Riggs, Matt Barkohanai, and myself waited until the hour of 1:30 p.m., and the deponent did not appear.
Respondent's attorney, BRIAN C. LYSAGHT, made the following statement:
MR. LYSAGHT: My name is Brian Lysaght, and I am the party who caused the subpoena to be served on Mr. Bobby Babak Saadian and request for production of documents.
I'd like to mark, as exhibit next in order, the deposition subpoena for personal appearance and production of documents and things that was directed to the deponent to appear, and I'd like that marked as next in order. BARRETT REPORTING, INC. (888) 740-1100 www.barrettreporting.com
(Exhibit 1 was marked for identification by the court reporter and is attached hereto.)
MR. LYSAGHT: All right. And I'd like the reporter, please, to mark, as next in order, a proof of service of the deposition subpoena for personal appearance and production of documents and things that was served on Bobby Babak Saadian on October 12, 2025 by a registered California process server, and I'd like the reporter to mark that as next in order. It could be 1 and 2 if you wish.
(Exhibit 2 was marked for identification by the court reporter and is attached hereto.)
MR. LYSAGHT: And I'd like to mark, as exhibit next in order, a notice of deposition of Bobby Babak Saadian and request for production of documents at deposition which was served on the witness and all parties that were necessarily interested in the deposition. And that will be Exhibit 3, I suppose.
(Exhibit 3 was marked for identification by the court reporter and is attached hereto.)
MR. LYSAGHT: Now, let the record reflect that it is now -- what time is it now?
MR. LYSAGHT: It is now 1:35 p.m. The deposition was scheduled for 1:00 p.m. I have received a call from BARRETT REPORTING, INC. (888) 740-1100 www.barrettreporting.com
the general counsel of the firm where the witness is employed who inquired why we were taking the deposition and that it should not be taken because Mr. Saadian knows nothing.
And I responded, "That's why we're taking the deposition, to find out."
I told him that we expected him to be here at 1:00 o'clock. It is now 1:35 p.m. There has been no appearance by the witness. There has been no documents produced by the witness or his counsel.
There were objections filed by the general counsel who appears to be representing the witness and we have those, but that did not excuse the witness' appearance. He has not appeared here, and we will proceed to take such steps as to compel his appearance and to compel a production of documents.
And I guess we're off the record. I apologize Mr. Videographer and Ms. Reporter.
-o0o-
BARRETT REPORTING, INC. (888) 740-1100 www.barrettreporting.com
I, MELISSA WALI, CSR No. 13514, Certified Shorthand Reporter, certify:
That the foregoing proceedings were taken at the location, date, and time therein set forth, at which time, the statements made were recorded stenographically by me and were thereafter transcribed;
That the foregoing is a true and correct transcript of my shorthand notes so taken.
I further certify that I am not a relative or employee of any attorney of the parties, nor financially interested in the action.
I declare under penalty of perjury under the laws of California that the foregoing is true and correct.
Dated this 13th day of November, 2025.
___________________________________
MELISSA WALI, CSR No. 13514 BARRETT REPORTING, INC. (888) 740-1100 www.barrettreporting.com
Bobby Saadian Deposition/Meet & Confer
Natasha Riggs <nriggs@lysaghtlegal.com>
Mon, Dec 1, 2025 at
To: John Lucas <john.lucas@wilshirelawfirm.com>
Cc: BLysaght <blysaght@lysaghtlegal.com>
Good Morning Mr. Lucas, We received no response to our email of November 10 regarding Bobby Saadian’s failure to appear.
We are writing again to give you the opportunity to schedule the deposition and produced the requested documents before we file m seeking compliance with the subpoena.
We are available this week on Tuesday, Thursday or Friday 11:30 a.m.- 1:30 pm.
Regards , Natasha Riggs, Esq.
Lysaght Law Group LLP
401 Wilshire Blvd., 12th Flr.
Santa Monica, CA 90401
Tel: 424.252.4747
On Nov 10, 2025, at 9:57 PM, Brian Lysaght <blysaght@lysaghtlegal.com> wrote:
You and I discussed the deposition and Saadian’s appearance before the depo. We agreed on the date (Nov 7) and that it would have to be live because of videographers. You did not advise at that time any problem with the date or time
Instead, on October 31 you served objections to every category of documents. Included in the objections was a one sentence statement stating that he would not appear for the long scheduled deposition without further explanation.
Your email below says that the deponent will not produce documents because in his opinion he does not possess documents relevant to the trust dispute, a case where he is not a party.
A subpoena is a court order. Your client cannot simply decide for himself whether the subpoenaed documents are relevant to the subject matter or may lead to discovery of admissible evidence. Your client’s high handed disregard of that subpoena is contemptuous of the lawful orders of
From the objections and your client’s refusal to appear it appears evidence that yourposition is firm that he will not comply.
The same thing is true of the document demands which we also discussed and I told you there were interesting texts directly relevant to the Petition case.
I will thus file a declaration that we have conferred in good faith as required. Said declaration will be appended to our Application for OSC re Contempt or similar coercive relief to compel obedience to the court order.
Let me know if you disagree with any of the foregoing
Brian C. Lysaght
Lysaght Law Group LLP
401 Wilshire Blvd., 12th Flr., #1004
Santa Monica, CA 90401
Tel: 424.252.4747
[Mail-client signature block and confidentiality notice omitted]
On Fri, Nov 7, 2025 at 13:59 John Lucas, Esq. <john.lucas@wilshirelawfirm.com> wrote:
Brian,
I was surprised to get your voicemail. We made clear in our timely, valid objections to (1) the subpoena; (2) the deposition notice; and (3) the document requests that Mr. Saadian would not be appearing, and that he would not be producing documents because he does not possess responsive documents relevant to the trust dispute. We assume that you will be able to obtain whatever it is that you are seeking from discovery among the parties.
John
John Lucas, Esq.
delete it.
[Mail-client signature block and confidentiality notice omitted]
George Saadian Trust matter
Brian Lysaght <blysaght@lysaghtlegal.com>
Tue, Oct 21, 2025 at 12:38 PM
To: John.lucas@wilshirelawfirn.com
Cc: Natasha Riggs <nriggs@lysaghtlegal.com>
John, On further reflection, the deposition will need to be in person. We arranged for it to be videotaped. Our office is located near to Bobby Saadian’s residence.
Best, Brian Lysaght
On Monday, October 20, 2025, John Lucas, Esq. <john.lucas@wilshirelawfirm.com> wrote:
Natasha, thanks for getting back to me. Late morning tomorrow should work for me. As for the phone issue, I dialed three times and it happened all three. Glad it's working for you all.
John Lucas, Esq.
From: Natasha Riggs <nriggs@lysaghtlegal.com>
Sent: Monday, October 20, 2025 2:00 PM
To: John Lucas, Esq. <john.lucas@wilshirelawfirm.com>
Cc: BLysaght <blysaght@lysaghtlegal.com>
Subject: Re: George Saadian Trust matter
Good Afternoon John, I’d be happy to speak with you. I can call tomorrow late morning.
Thank you for the information about our telephone number. However, we do not seem to be having any problems on our end.
Natasha Riggs, Esq.
Lysaght Law Group LLP
401 Wilshire Blvd., 12th Flr.
Santa Monica, CA 90401
Tel: 424.252.4747
On Oct 20, 2025, at 12:44 PM, John Lucas, Esq. <john.lucas@wilshirelawfirm.com> wrote:
Hi, Natasha. I'm the GC at Wilshire Law Firm and I have the depo notice and subpoena for Bobby Saadian. I was hoping to speak with you about that for a couple minutes. I tried the firm's number several times and was immediately kicked to "sorry, can't be completed as dialed." So I'd appreciate it if you could give me a ring. My cell is fine. [cell number omitted]. Thanks.
[Mail-client signature block and confidentiality notice omitted]
John Lucas, Esq.
--
Brian C. Lysaght
Lysaght Law Group LLP
401 Wilshire Blvd., 12th Flr., #1004
Santa Monica, CA 90401
Tel: 424.252.4747
[Mail-client signature block and confidentiality notice omitted]