My Opposition to FTB’s Motion for Sanctions Dated 09-01-2021 and My Request for Sanctions

On September 1, 2021, FTB filed a Motion for Sanctions against me in a blatant attack of retaliation, harassment and obstruction of justice.

On March 7, 2021, I filed my Opposition to their Motion for Sanctions and my own request for sanctions against FTB for:

• Violation of Code Civ. Proc., §128.5 and §128.7(b): Motion is Frivolous (page 30)
• Violation of CA Rules of the Court 1.201: Failure to Redact Personal Information (page 32)
• Violation of CRC 3.1348: Failure to Provide Discovery (page 39)
• Chelsea Hubbard: Perjury, Withholding Evidence and Improper Redactions (page 40) 
• Keith Swank: Perjury and Failure to Furnish Information (page 53)
• Grace LeBleu: False Statements and Improper Redactions (page 59) 

Here are pages 1 – 19, 20 – 39, 40 – 55, 56 – 69, and pages 70 – 71 are the the list of laws cited.

Below is the list of exhibits for my SDSC court case. The items that were submitted as a part of the Motion for Sanctions are 61 – 92. I have a lot to redact and upload. I will update the charts with the links to the documents as I can. It will take a while.

Exhibit #	Description	Pages
39	Deposition Request (Demand) for Documents	3
40	Response to Requests for Production of Documents	16
41	Documents Set One (1)	33
42	Meet and Confer Letter	10
43	2009 accounting ledger	1
44	Emails between Grab and Barsegyan dated 12/1 and 12/2, 2020	6
45	Meet and Confer Response Letter	4
46	Emails between Grab and Barsegyan dated 12/9/2020	4
47	Notice of Proposed Assessments 2011, 2013 and 2014	5

SDSC Ex. #	Description	# of pages	FCC Ex. #
61	Overview of FTB’s 8 Unlawful Schemes	5	1
62	Information on FTB Employees	5	43
63	Emails With and Complaint letter About Barsegyan	2	49
64	SDPD Police Report	1	50
65	FCC Against Bear, Burton-Beilby, Barsegyan	15	n/a
66	FCC Against Hubbar, Swank, Barsegyan	70	n/a
67	Oral Arguments Motion to Compel Hearing May 2021	5	48
68	Video of June 2021 FTB Board of Directors Meeting	USB	55
69	Agenda and Budget Requests from June FTB Meeting	3	57
70	Emails Between Smith and Grab Dated 11-06-2018	2	58
71	Correspondence Between Calhoun and Grab	8	59
72	Letter to Governor Brown dated 02-07-2018	3	6
73	2019 Annual Taxpayer Bill of Rights Speech	USB	60
74	Letter from Taxpayer Advocate dated 01-31-2020	4	61
75	Plaintiff’s Response to Defendant’s Meet and Confer	12	46
76	Proof Records Exist of Dates Payments Applied	5	28
77	2021 Taxpayer Bill of Rights Requests and Response	12	29
78	Plaintiff’s Demand for Documents, set #002	2	30
79	Defendant’s Response to Demand for Documents, set 2	7	31
80	Meet and Confer for Plaintiff’s Demand for Documents 2	9	32
81	Amended Response to Demand for Documents, set 2	7	33
82	FTB Response to Meet and Confer for Interrogatories 1	6	36
83	Proof of Improper Redactions	12	37
84	Privilege Log	3	38
85	Proof of Improper Redactions	7	39
86	Letter to Governor Brown dated 02-23-2018	5	15
87	Redactions Which Appear to be Improper	26	40
88	Eric Yadao Income History	1	42
89	Emails Between Grab and Barsegyan from May 2021	2	45
90	Emails Between Grab and Barsegyan January 2022	5	62
91	Improperly redacted documents submiited by LeBleu	4	n/a
92	FTB Litigation Budget for fiscal year 2021 – 2022	1	n/a

Unfortunately, the judge rejected My Opposition to FTB’s Motion for Sanctions Dated 09-01-2021 and My Request for Sanctions because it was over the limit of page numbers.