Respondent OSC Companion Matter - Fixfamilycourtnow.org

1 when I responded to the request propounded by Mr. Mason on Ginny's behalf the2 summer before. I referred them to my previous response provided to Mr. Mason.3 Ginny did not file a motion to compel after I responded to this second set of document4 requests.5 Redacted Information:6 In my most recent response to Ginny's request for production of documents, my7 attorney blacked out a few transactions on my checking account statements and credit8 card statements. The attorney/client privilege was asserted on my behalf because9 these transactions were payments made to professionals advising me in my legal case.10 The dates and the amounts of the transactions were not blacked out. Only the11 names of the recipients were redacted. When I received the meet and confer letter12 from Mr. Klueck, I once again reiterated my response that this was privileged13 information and they were informed that these payments were made to the14 professionals assisting me with my case. Lodged as Exhibit D is a copy of my15 response to their meet and confer letter. I went into significant detail to provide them16 with answers to their questions about various documents and transactions. I have been17 cooperative and forthcoming in all of my responses to Ginny's requests for discovery.18 The redacted portions of my bank and credit card statements do not interfere with her19 ability to ascertain how much money I maintain in my accounts and how much I spent20 during the period in question.21 Sanctions:22 This motion was completely unwarranted and is just an attempt to disparage me23 in the eyes of the court. I am requesting that the court order sanctions against Ginny24 for at least $1,000. My attorney's hourly rate is $300, and she spent approximately one25 hour of her time preparing this response plus her staff's time which is billed at $110 an26 hour. i anticipate that I will be billed another two hours of my attorney's time to appear27 in court and argue against this motion.28 IEND OF DECLARATIONI2