DEPO CASE BACKGROUND SUMMARY

(I gave to Attorney)

Upon the death of Paul Froemming on September 27. 2019, and subsequent review of his will, Paul’s dear friend, Donna Hamel, was given a real property:

3196 Serena Avenue, Carpinteria, California 93013.

Donna sold that property on February 12, 2021.

On August 5, 2025 Donna was served a Deposition Subpoena for personal appearance and production of documents and things.

The case is being brought against the buyers of the property and was filed 9/23/2024.

Description of case:

1.  Interference with easement

2.  Private Nuisance

3.  Quiet Title

4.  Declaratory Relief

5.  Temporary Restraining Order, Preliminary and Permanent Injunction

6.  Quiet Title – Prescriptive Easement

They consider Donna Hamel a witness and seeking ALL communications and documents regarding the property and adjoining property.

They are also seeking ALL documents and communications regarding a previous ALLEGED incident:

Los Angeles Superior Court case Macleod v. Dudrey

Case No. BC698675

Filed 3/19/2018

The case type: Premise Liability (e.g., dangerous conditions of property, slip/trip and fall, dog attack, etc.) (General Jurisdiction)

Ronald Macleod (Plaintiff), an incident allegedly occurred in 2018. During time of incident, property was under previous ownership by Froemming PF Trust (Cross-Defendant).

That case is of a neighbor or guest who allegedly trespassed onto the property and was allegedly injured while crossing a bridge that was clearly marked “Do Not Cross Bridge Dangerous” etc. and was blocked off.

That case was presumably settled in 2019.

Request for Dismissal with prejudice was filed by Plaintiff and Defendant.

Paul Froemming, passed away on or about 9/27/2019.

Mr. Froemming, gave the property to Donna Hamel via will.

SUMMARY

We have a non-party deposition subpoena (personal appearance + docs) tied to an easement/quiet title dispute involving a property my mother owned (2019–2021). The notice is set for Aug 25 (RESCHEDULE tentatively proposed for September 15, 17 or 18).

We may need:

(1) scope narrowing and protective order for settlement-related materials,

(2) a targeted ESI collection plan (texts/emails/photos), and

(3) deposition prep/defense.

Can you take a limited-scope engagement for this?

What would your budget range look like?