Motion to Compel Production of Documents and Video Taped Depositions for Department of Motor Vehicles

ABDUL-JALIL al-HAKIM

4200 Park Blvd., Ste. #One16, Oakland CA  94602
Phone  (510) 394-4101

Aaron & Margaret Wallace Foundation
Aaron & Margaret Wallace Foundation-KPFA Promotional Video:
Aaron & Margaret Wallace Foundation Kids Celebrity Gift BackPacks
Aaron & Margaret Wallace Foundation Free Food Program Celebrity Giving Back
The Aaron & Margaret Wallace Foundation and ¿eX-whY AdVentures? Trader Joe’s Emeryville KPFA Interview Video
The Aaron & Margaret Wallace Foundation and ¿eX-whY AdVentures? Trader Joe’s Emeryville Customer Appreciation
The Aaron & Margaret Wallace Foundation and ¿eX-whY AdVentures? Trader Joe’s Alameda Customer Appreciation
The Aaron & Margaret Wallace Foundation and ¿eX-whY AdVentures? Entourage & Randy Holland in Trader Joe’s Pinole “Tribute to Legends of Jazz” Show
Santa Fe Elementary School’s Peace March with Aaron & Margaret Wallace Foundation, SemiFreddi’s, Trader Joe’s, Little Ceasar’s Pizza, Marshawn Lynch’s “Fam1ly F1rst” and Leon Powe’s “Fresh Start Oakland”
Aaron & Margaret Wallace Foundation and Santa Fe Elementary LilCaesars Pizza Part 1
Aaron & Margaret Wallace Foundation and Santa Fe Elementary LilCaesars Pizza Part 2
Abdul-Jalil Honored in Port Au-Prince, Haiti and Miami, Fla. for Relief Missions to Haiti
Linked In Profile on Abdul-Jalil
Thanks You from Arch Bishop Joel Jeune to Abdul-Jalil
Portrait of Abdul-Jalil by Artist Buford Delaney in Paris, France
Articles on Abdul-JalilABDUL-JALIL GENIUS- BOY WONDER!!MC Hammer Tribute to ABDUL-JALILKobe Supports AMWFEmanuel Steward on ABDUL-JALIL
ABDUL-JALIL’S BABE with Maze Featuring Frankie Beverly and Marvin Gaye
ABDUL-JALIL’S BABE with Khalid al-Mansour, President Barack Obama and Prince Al-Waleed
ABDUL-JALIL’S BABE with Destiny and Marvin Gaye
CALIFORNIA STATE ASSEMBLY HONORS ABDUL-JALIL Receives Certificate-of-Recognition for 2021-22 

Belal Salih Esa receives Posthumous Congressional Proclamation/Resolution for his work with the Aaron & Margaret Wallace Foundation (AMWF)
Belal Salih Esa received a Posthumous Legislative Proclamation/Resolution from California Governor Gavin Newsom and the State Legislature for his work with the Aaron & Margaret Wallace Foundation (AMWF)
Belal Salih Esa received a Posthumous Legislative Proclamation/Resolution from the Mayor, City Council and the Unified School District Board of Supervisors of the City of Albany for his work with the Aaron & Margaret Wallace Foundation (AMWF)

Humanitarian Civil and Human Rights Achievements
ABDUL-JALIL- the First _SUPER AGENT_ Legal Black History Page 1
ABDUL-JALIL-Sports and Entertainment Law Courses in All Major Law and MBA Programs Page 2
ABDUL-JALIL-Sports and Entertainment Law Courses in All Major Law and MBA Programs Page 3
ABDUL-JALIL-Sports and Entertainment Law, Lecturor, Presenter, Marketing, Branding Page 4

Rihanna SUPER BOWL Celebrity Promo
Dr. Dre SUPER BOWL Celebrity Promo
The Man Who Turn$ Hit$ Into Million$, One Special CaseESPN Bostock 5th & Jackson TV Special Part 1, and Part 2ESPN Bostock Magazine Special, ESPN Magazine- The History and Mystery of The High Five,
the “al-Hakim Tax Code Ruling”, Smart Agent, Busy Agent,
Abdul-Jalil in Harvard University Law School Federal Tax Course Outline
Abdul-Jalil in Yale University Law School Federal Tax Course 13th Ed., Prof. Eric Zolt
Abdul-Jalil in Wake Forest University Law School “Islamic and Jewish Perspective On Interest”
Abdul-Jalil in Washington University Law School Tax CodeAbdul-Jalil in Washington & Lee University Law School Tax Code,Abdul-Jalil in University of Virginia Law School Tax Course
Award for “Distinguished Marketing and Promotional Services” from NFL Super Bowl NFL Experience,


You can click on any highlighted word to view or download that item

TO:  Steve Gordon, Joseph Chapman
        California Department of Motor Vehicles-DMV Legal Affairs Division
        Custodian of Records and Person Most Knowledgeable Does One through One Hundred
        2415 1st Avenue, MS C128
        PO Box 932382
        Sacramento, CA 95818-2606
        Fax: 916-657-6243


Sent via USPS mail and Emailed
Hearing Date: June 10, 2025, 9am, in Department 105 of the Alameda County Superior Court, Wiley W. Manuel Courthouse, 661 Washington Street, Oakland, CA 94607
FROM:     Abdul-Jalil al-Hakim
DATE:     June 2, 2025
NO PAGES:     2 pages
RE:        Motion to Compel Production of Documents and Video Taped Depositions for Patrick Dorais, Randall Phillips, the Custodian of Records, and Person Most Knowledgeable in Matter of East Bay Auto Center v. Aaron & Margaret Wallace Foundation, Case: #24SC067622; Hearing Date: June 10, 2025, 9am in Department 105 of the Alameda County Superior Court, Wiley W. Manuel Courthouse, 661 Washington Street, Oakland, CA 94607

Dear Steve Gordon, Joseph Chapman, Sonia Huestis, India Fayne, Marcela Sencion, Matthew Christy, the Custodian of Records, and Person Most Knowledgeable, et.al,;

    We are the defendant in the above case and have served you herewith attached this Defendant’s Motion to Compel compliance with the subpoena, the further Production of Documents and for Videotape Depositions to answer any question and to produce ALL documents, electronically stored information, and/or tangible things under your control that is specified in the subpoena that will be accompanied by this notice and meet and confer declaration. (Code Civ. Proc. § 2025.480(b).)   This Motion is for the Production of Documents and Videotape Depositions by Steve Gordon, Joseph Chapman, Sonia Huestis, India Fayne, Marcela Sencion, Matthew Christy, the Custodian of Records, and Person Most Knowledgeable PERSONALLY TESTIFYING AND BRINGING ALL REQUESTED DOCUMENTS TO THE COURT HEARING SCHEDULED ABOVE FOR IN CAMERA EXAMINATION/INSPECTION AND APPROVAL BY THE COURT. ALL THE REQUESTED DOCUMENTS MUST BE PROVIDED IN TRIPLICATE AS COPIES FOR THE COURT, PLAINTIFFS AND DEFENDANTS.     We had hoped to get the responses to the subpoena and we are now forced to file Defendant’s motion to Compel compliance with the subpoena, the further Production of Documents and for Videotape Depositions to answer any question and to produce ALL documents, electronically stored information, and/or tangible things under your control that is specified in the subpoena that will be accompanied by this notice and meet and confer declaration. (Code Civ. Proc. § 2025.480(b).)     Defendant is moving for an order compelling you as the subpoenaed party to provide a complete and accurate privilege log and for an in camera inspection of the documents you have withheld from production in response to defendant’s subpoena request for Production, based on any objections or claims of privilege, in order to determine whether you are entitled to withhold those documents based on any claims.
    The motion is made pursuant to Code of Civil Procedure Sections 2030 and 2031 on the ground that YOU, as the subpoenaed party, have failed to comply with your discovery obligations and on the further ground that good cause exists to compel the further responses and production of documents sought by DEFENDANTS’ MOTION TO COMPEL YOUR FURTHER RESPONSES AND PRODUCTION OF DOCUMENTS IN RESPONSE TO DEFENDANT’S REQUEST FOR PRODUCTION OF DOCUMENTS, AND FOR IN CAMERA INSPECTION OF DOCUMENTS WITHHELD BY YOU BASED ON ANY OBJECTIONS, CLAIMS OF PRIVILEGE, and REQUEST FOR PRODUCTION IN DISPUTE, YOUR FURTHER RESPONSES TO DISPUTED REQUEST FOR PRODUCTION AND REASONS FURTHER PRODUCTION AND RESPONSES SHOULD NOT BE COMPELLED.
    If you have any objection, response or reply it should be made in the form of a properly noticed, served, and filed motion to the court.
    We are demanding ALL related costs and all fees for the Meet and Confer and Motion to Compel Responses to the Subpoena and Video taped depositions, sanctions, and request a contempt order and order a bench warrant for the arrest of those responsible as provided by California Code of Civil Procedure § 2031.300 and others.


Respectfully,


Abdul-Jalil al-Hakim
ajalil1234@gmail.com
510 394-4501


——– Message ——–

Subject:CORRECTED CIVIL SUBPOENA (DUCES TECUM)
Date:Tue, 26 Nov 2024 11:42:09 -0800
From:A. J. <ajalil1234@gmail.com>
Reply-To:ajalil1234@gmail.com
To:Joseph.Chapman@dmv.ca.gov, PRArequest@dmv.ca.gov, Steve.Gordon@dmv.ca.gov, Sonia.Huestis@dmv.ca.gov, Matthew.Christy@dmv.ca.gov

TO:     Steve Gordon- Director
           Department of Motor Vehicles
           2415 1st Ave., Mail Station F101
           Sacramento, CA 95818-2606
cc: Mr. Chapman, Mr. Christy
sent via: U. S. Mail, and email                                  
FROM:     Abdul-Jalil al-Hakim, Aaron & Margaret Wallace Foundation
DATE:     November 25, 2024
RE:        CIVIL SUBPOENA (DUCES TECUM) in East Bay Auto Center, Shah Sons LLC, Muhammad Khan, Sani Khan, Tariq Khan, Numi Khan, Asian investors, and Does One through One Hundred, Plaintiffs, vs. Aaron & Margaret Wallace Foundation, Defendant,

Dear Director Gordon, Mr. Chapman, and Mr. Christy,
    Attached hereto please find aCORRECTED CIVIL SUBPOENA (DUCES TECUM) Evidence Code sections 1560, 1561, 1562, and 1271 governing this SUBPOENA (DUCES TECUM) AND Code of Civil Procedure Section 2031 (CCP 2031) for Personal Appearance and Production of Documents, Electronically Stored Information, and Things in response to the court order (attached) for production of documents in the above referenced matter.    We CORRECTED the Motion section of the first page pleading from BAR to DMV. The rest of the document is the same.
    Mr. Gordon and Joseph Chapman-Legal Counsel, as the Custodian of Records you are NOT required to appear in person if within ten (10) days from the date of the serving of this request upon you, you produce (i) the Bates-stamped or otherwise numbered sequentially records described in the “DEFINITIONS” Section as part of this attached affidavit and (ii) a completed declaration of custodian of records in compliance with Evidence Code sections 1560, 1561, 1562, and 1271. (1) Place a copy of the records in an envelope (or other wrapper) where Documents produced shall be Bates-stamped or otherwise numbered sequentially. Enclose the original declaration of the custodian with the records. Seal the envelope. (2) Attach a copy of this subpoena to the envelope or write on the envelope the case name and number; your name; and the date, time, and place. (3) Place this first envelope in an outer envelope, seal it, and mail it to me at the address or email address (ajalil1234@gmail.com ) above. (4) The written response shall be served within ten (10) days of the service of this request.
SUBPOENA REQUESTS FOR PRODUCTION OF DOCUMENTS
Pursuant to Evidence Code sections 1560, 1561, 1562, and 1271 governing this SUBPOENA (DUCES TECUM) AND Code of Civil Procedure Section 2031 (CCP 2031) on Responding Party: Custodian of Records and Person Most Knowledgeable is used herein to refer to, and includes Bureau of Automotive Repair (BAR), Patrick Dorais- Chief AND YOU are NOT required to appear in person if you produce (i) the Bates-stamped or otherwise numbered sequentially records described in the declaration on page two or the attached declaration or affidavit and (ii) a completed declaration of custodian of records in compliance with.As might be YOUR custom, you may provide responsive records in electronic format (i.e., text files that can be opened with any word processing software such as Word or TextEdit) or a searchable portable document file (PDF).
If any DOCUMENT requested herein was, but no longer is, in YOUR possession, custody, or control, please state whether such DOCUMENT was lost, destroyed or otherwise disposed of, and describe the circumstances and date(s) of such disposition.    These requests are deemed to be continuing insofar as if any of the above is secured subsequent to the date herein for the production of same, said documents are to be provided to Defendant’s consistent within the applicable Rule of Civil Procedure.
     This subpoena is not intended as a full or complete statement of all relevant demands, claims, facts or applicable law, and nothing herein is intended as, nor should it be deemed to constitute, a waiver or relinquishment of any of my rights, remedies, claims or causes of action, all of which are hereby expressly reserved.
     Please provide the records in an electronic format to: ajalil1234@gmail.com. Documents not in electronic format should be forwarded Abdul-Jalil al-Hakim below on or before the return date of this subpoena if you wish to comply voluntarily rather than appearing before the court.
     Should you have any questions regarding this matter, please contact Abdul-Jalil al-Hakim at:
Aaron & Margaret Wallace Foundation 
4200 Park Blvd., Suite 116 
Oakland, CA 94602 
Tel: 510-394-4501
Respectfully,
Abdul-Jalil