Respondent Response to Interrogatories

1 CAROLE D. BALDWIN, CFLS, SBN 213310•BALDWIN & BALDWIN2 9171 Towne Centre Drive, Suite 440San Diego, CA 921223 Telephone: (858) 452-2898456Attorney for Respondent,MICHAEL CALDWELL7 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN DIEGO891011In re the Marriage of: Case No. ED 48912Petitioner: GINNY CALDWELLRESPONDENT'S RESPONSE TOPETITIONER'S SPECIALINTERROGATORIES12 and13Respondent: MICHAEL CALDWELL14(SET ONE)1516171819202122232425•262728PROPOUNDING PARTY: Petitioner, GINNY CALDWELLRESPONDING PARTY: Respondent, MICHAEL CALDWELLSET NUMBER:ONERespondent, MICHAEL CALDWELL, responds to the Special Interrogatories(Set One) propounded by Petitioner, GINNY CALDWELL, as follows:PRELIMINARY STATEMENTRespondent objects to these Interrogatories as they have not been properlydrafted pursuant to California Code of Civil Procedure section 2030.060.These responses to special interrogatories are made solely for the purpose of,and in relation to, this action. Each response is given subject to all appropriateobjections (including, but not limited to, objections concerning competency, relevancy,materiality, propriety and admissibility) which would require the exclusion of anystatement contained herein were made by, a witness present and testifying in court. AllRESPONDENT'S RESPONSE TO PETITIONER'S SPECIAL INTERROGATORIES (SET ONE) 1

•12345678910111213141516171819202122232425such objections and grounds thereof are reserved and may be interposed at the time oftrial.The party on whose behalf the responses to special interrogatories are given hasnot yet completed investigation of the facts relating to this action, has not yet completeddiscovery in this action, and has not yet completed preparation for trial. Consequently,the following responses are given without prejudice to the answering party's right toproduce, at the time of trial, subsequently discovered material. Except for factsexplicitly admitted herein, no admission of any nature whatsoever is to be implied orinferred.The following interrogatory responses are given without prejudice toRespondent's right to produce evidence of any subsequently discovered fact or factswhich Respondent may later recall. Respondent accordingly reserves the right tochange any and all answers as additional facts are ascertained, analyses are made,research is completed, and contentions are made. The answers contained are made ina good faith effort to supply as much factual information and as much specification oflegal contentions as is presently known, but should in no way be to the prejudice ofRespondent in relation to further, discovery, research or analysis.All answers must be construed as given on the basis of present recollection.Any interrogatory deemed as continuing is objected to as oppressive, burdensome,improper, and not in compliance with California Code of Civil Procedure Sections 2016,2030 et seq., and will not be regarded as continuing in nature. Without waiving theforegoing, this responding party answers Petitioner's special interrogatories as follows:SPECIAL INTERROGATORY NO. 1:On January 1, 2008, what was your ownership of CSldentity?RESPONSE TO SPECIAL INTERROGATORY NO. 1:26Ido not know. Petitioner has submitted a subpoena to CSldentity, and the•2728information requested may be available through that subpoena. The address forCSldentity is: 7500 Rialto Blvd., #260, Austin Texas 78735.RESPONDENT'S RESPONSE TO PETITIONER'S SPECIAL INTERROGATORIES (SET ONE) 2

•2345678910111213• 14151617181920212223242526• 2728iSPECIAL INTERROGATORY NO. 2:What date did you acquire an interest in Internet Megameeting?RESPONSE TO SPECIAL INTERROGATORY NO. 2:I do not recall the exact date but I believe it was early in 2004. This informationshould be available from Internet Megameeting. The address is: 14900 Ventura Blvd.,#310, Sherman Oaks, California 91403.SPECIAL INTERROGATORY NO. 3:What years did you get 1099 income during the period of 2006 -2008?RESPONSE TO SPECIAL INTERROGATORY NO. 3:Objection: Irrelevant to current proceedings; not likely to lead to admissibleevidence. Without waiving stated objections, I respond to this interrogatory as follows:I received 1099 income the first half of 2006.Discovery is ongoing and continuous and therefore Respondent reserves theright to amend this interrogatory.SPECIAL INTERROGATORY NO. 4:What was the source of 1099 income in 2007?RESPONSE TO SPECIAL INTERROGATORY NO. 4:Objection: Irrelevant to current proceedings; not likely to lead to admissibleevidence.SPECIAL INTERROGATORY NO. 5:What was source of 1099 income in 2006?RESPONSE TO SPECIAL INTERROGATORY NO. 5:Objection: Irrelevant to current proceedings; not likely to lead to admissibleevidence.SPECIAL INTERROGATORY NO. 6:What was source of the brokerage income you cashed out in July 2009?RESPONSE TO SPECIAL INTERROGATORY NO. 6:The funds cashed out in July 2009 came from investments I made with myRESPONDENT'S RESPONSE TO PETITIONER'S SPECIAL INTERROGATORIES (SET ONE)3

12345678910111213• 14151617181920212223242526• 2728earnings from CSldentity.SPECIAL INTERROGATORY NO. 7:What dates did you do any type of work for Digital Infrastructure?RESPONSE TO SPECIAL INTERROGATORY NO. 7:Objection: Irrelevant to current proceedings; not likely to lead to admissibleevidence. Without waiving stated objections, I respond to this interrogatory as follows:I do not recall the exact dates. I stopped performing any work for that companyin 2003. This information should be available from Digital Infrastructure located at14852 Ventura Blvd., #207, Sherman Oaks, California 91403.SPECIAL INTERROGATORY NO. 8:How were you paid by Digital Infrastructure? Cash, Check, Other.RESPONSE TO SPECIAL INTERROGATORY NO. 8:Objection: Irrelevant to current proceedings; not likely to lead to admissibleevidence. Without waiving stated objections, I respond to this interrogatory as follows:I was paid by check.SPECIAL INTERROGATORY NO. 9:How was income from Internet Megameeting reported on your taxes in 2008,and 2009?RESPONSE TO SPECIAL INTERROGATORY NO. 9:Objection: Irrelevant to current proceedings; not likely to lead to admissibleevidence; vague and ambiguous as to the term "income." Without waiving statedobjections, I respond to this interrogatory as follows:I received K-1 income in 2008 and it was reported on my tax return on theSchedule E and 1040 forms. I did not receive K-1 income or any other type of incomefrom Internet Megameeting in 2009. It should be noted that the K-1s were for taxreporting purposes only. I never actually received money from Internet Megameeting.Discovery is ongoing and continuous and therefore Respondent reserves theright to amend this interrogatory.RESPONDENT'S RESPONSE TO PETITIONER'S SPECIAL INTERROGATORIES (SET ONE)4

1•23456789101112130141516171819202122232425262728SPECIAL INTERROGATORY NO. 10:What date did you begin doing any work with Internet Megameeting?RESPONSE TO SPECIAL INTERROGATORY NO. 10:Objection: Irrelevant to current proceedings; not likely to lead to admissibleevidence; assumes facts not in evidence; vague and ambiguous. Without waivingstated objections, I respond to this interrogatory as follows:I have never done any work with Internet Megameeting.SPECIAL INTERROGATORY NO. 11:What were the terms of you acquiring your partnership with InternetMegameeting?RESPONSE TO SPECIAL INTERROGATORY NO. 11:Objection: Irrelevant to current proceedings; not likely to lead to admissibleevidence; assumes facts not in evidence. Without waiving stated objections, I respondto this interrogatory as follows:I am unable to answer this interrogatory. I do not have the documentation thatoutlines the terms of my partnership with Internet Megameeting. This informationshould be available from Internet Megameeting located at 14900 Ventura Blvd., #310,Sherman Oaks, California 91403.SPECIAL INTERROGATORY NO. 12:Are you a trustee of any trust?RESPONSE TO SPECIAL INTERROGATORY NO. 12:Objection: Irrelevant to current proceedings; not likely to lead to admissibleevidence. Without waiving stated objections, I respond to this interrogatory as follows:No.SPECIAL INTERROGATORY NO. 13:What is the amount of rent you pay to your mother?RESPONSE TO SPECIAL INTERROGATORY NO. 13:I pay my mother $1,000 a month for rent.RESPONDENT'S RESPONSE TO PETITIONER'S SPECIAL INTERROGATORIES (SET ONE)5

•12345678910111213• 14151617181920212223242526SPECIAL INTERROGATORY NO. 14:How is the rent paid to your mother?RESPONSE TO SPECIAL INTERROGATORY NO. 14:I pay my mother by check.SPECIAL INTERROGATORY NO. 15:What was the amount of rent you pay to your mother from March, 2011 throughSeptember 2011?RESPONSE TO SPECIAL INTERROGATORY NO. 15:Objection: assumes facts not in evidence. Without waiving stated objections, Irespond to this interrogatory as follows:None.SPECIAL INTERROGATORY NO. 16:What was the source of the 110,000 (approximate) deposited into your checkingaccount at HSBC in 2010 and 2011?RESPONSE TO SPECIAL INTERROGATORY NO. 16:Objection: assumes facts not in evidence. Without waiving stated objections, Irespond to this interrogatory as follows:The source of the funds deposited into the HSBC account in 2010 and 2011 wasloans from my mother.SPECIAL INTERROGATORY NO. 17:What was the source of miscellaneous deposits in 2008?RESPONSE TO SPECIAL INTERROGATORY NO. 17:Objection: Irrelevant to current proceedings; not likely to lead to admissibleevidence; vague as to account; overly-burdensome. Without waiving stated objections, Irespond to this interrogatory as follows:I am unable to answer this interrogatory because I do not know which account•2728Petitioner is referring to, and this interrogatory is overly-burdensome.///RESPONDENT'S RESPONSE TO PETITIONER'S SPECIAL INTERROGATORIES (SET ONE) 6

12345678910111213• 14151617181920212223SPECIAL INTERROGATORY NO. 18:What items did you sell via paypal in 2009?RESPONSE TO SPECIAL INTERROGATORY NO. 18:Objection: Not relevant to the proceedings before the court; overly-burdensome.Without waiving stated objections, I respond to this interrogatory as follows:I am unable to recall the exact nature of the items I sold on PayPal in 2009.Pursuant to C.C.P. section 2030.230, I refer Petitioner to the PayPal TransactionHistory provided in my response to her Request for Production and Inspection ofDocuments — Set Six.Discovery is ongoing and continuous and therefore Respondent reserves theright to amend this interrogatory.SPECIAL INTERROGATORY NO. 19:Who is owner of the plane in your airplane hangar?RESPONSE TO SPECIAL INTERROGATORY NO. 19:Objection: Not relevant to the proceedings before the court; not likely to lead toadmissible evidence. Without waiving stated objections, I respond to this interrogatoryas follows:Lea Caldwell is the owner of the incomplete airplane built from a kit stored in theairplane hangar.Discovery is ongoing and continuous and therefore Respondent reserves theright to amend this interrogatory.SPECIAL INTERROGATORY NO. 20:What is your ownership of CSIdentity?•2624252728RESPONSE TO SPECIAL INTERROGATORY NO. 20:Objection: assumes facts not in evidence. Without waiving stated objections, Irespond to this interrogatory as follows:I do not have sufficient information to be able to answer this interrogatory. Theinformation should be available from CSIdentity located at 7500 Rialto Blvd., #260,RESPONDENT'S RESPONSE TO PETITIONER'S SPECIAL INTERROGATORIES (SET ONE) 7

•1 Austin Texas 78735.2 SPECIAL INTERROGATORY NO. 21:•143456789101112131516171819202122232425262728What is your ownership of Internet Megameeting?RESPONSE TO SPECIAL INTERROGATORY NO. 21:At one point in time I had a 2% ownership interest. I do not have sufficientinformation to determine what, if any, ownership interest I have at this time. Theinformation should be available from Internet Megameeting located at 14900 VenturaBlvd., #310, Sherman Oaks, California 91403.SPECIAL INTERROGATORY NO. 22:What is your ownership of Digital Infrastructure?RESPONSE TO SPECIAL INTERROGATORY NO. 22:None.Respectfully Submitted,Date: 1! (60,Lcie,4761.-CAROLE D. BALDWIN,Attorney for RespondentRESPONDENT'S RESPONSE TO PETITIONER'S SPECIAL INTERROGATORIES (SET ONE) 8

1234567VERIFICATIONI, MICHAEL CALDWELL, am the Respondent in the above-entitled action, I haveread the foregoing Respondent's Response to Petitioner's Special Interrogatories (SetOne), and I know the contents thereof. The same is true to the best of my ownknowledge and belief.I declare under penalty of perjury under the laws of the State of California that theforegoing is true and correct.891011121314• 15161718192021222324252627• 28Date: 11 3/1 (ICHAEL CALDWELL,RespondentRESPONDENT'S RESPONSE TO PETITIONER'S SPECIAL INTERROGATORIES (SET ONE) 9