Robert Hurford Hale, Sui Juris

3243 Congressional Circle

Fairfield 94534

CALIFORNIA, USA

tel: 707-426-1841

In Propria Persona

Superior Court of California

Solano County

REDWOOD PLAZA INVESTMENTS, L.P., ) Case No. FCS025327

)

v. ) NOTICE OF MOTION AND

) MOTION TO COMPEL

PGM, INC., ) PRODUCTION OF DOCUMENTS:

PETER G. MOZSARY, ) Evidence Code, section 453;

ROBERT H. HALE, and ) California Business and

DOES 1 through 10. ) Professions Code, secs. 6067-6128;

_________________________________) 18 U.S.C. 1341, 1964 (Civil RICO).

COMES NOW Robert H. Hale, Sui Juris, a named Defendant in the above entitled case, without waiving or conferring any jurisdiction, formally to move this honorable Court for an ORDER compelling Mr. Kirk E. Giberson either to produce the documents required by the SUBPOENA previously issued and served upon him, or to admit that he does not have a license to practice law in California, with a certificate of his oath indorsed by him upon said license, that conforms to section 6067 of the California Business and Professions Code.

Defendant Hale hereby reminds the Court that Kirk E. Giberson has already received and acknowledged a court-issued SUBPOENA to produce a proper license to practice law in California, with certificate of oath indorsed upon said license, that conforms to section 6067 supra.

Mr. Giberson’s failure to produce the physical documents required by section 6067 occurred without any substantial justifications.

Defendant Hale also requests monetary sanctions against Mr. Giberson, and also against the Plaintiff, for reasonable counsel’s fees and all related costs incurred by Defendant Hale in bringing this MOTION.

Such sanctions are sought on the ground that there is no substantial justification for Mr. Giberson’s failure to produce a proper answer to the SUBPOENA in question.

Good cause exists to compel the production of such documents in that the documents being sought are relevant to the issue of whether the Plaintiff, a registered Limited Partnership, may proceed in the first instance against Defendant without proper legal representation.

As a fictitious legal entity, Plaintiff is required by existing California State laws, and numerous court cases holding that a Limited Partnership must be properly represented before it can even appear in this honorable Court by means of written motions, pleadings or otherwise.

Defendant Hale hereby incorporates by reference all documents previously certified by him and previously filed in the Court record, as if all were set forth fully here in support of the instant MOTION.

Defendant Hale respectfully requests that this Court pay particular attention to Hale’s previously filed MEMORANDUM OF LAW.

That MEMORANDUM discusses this Court’s specific powers with respect to timely objections to an attorney’s missing credentials and/or certified allegations of attorney malpractice, malfeasance, willful misrepresentation, and/or any other violations of State and federal laws for which the Plaintiff is now legally responsible under a theory of respondeat superior (in Latin) also known as vicarious liability (in English). See 18 U.S.C. 1964, in chief.

Defendant Hale’s objections and certified allegations to date have been entirely timely and proper in this regard.

Dated: May 16, 2005

Signed: /s/ Robert H. Hale

___________________________________________

Printed: Robert H. Hale, Sui Juris

PROOF OF SERVICE

I, Robert H. Hale, Sui Juris, hereby certify, under penalty of perjury, under the laws of the United States of America, without the “United States” (federal government), that I am at least 18 years of age, a Citizen of ONE OF the United States of America, and that I personally served the following document(s):

NOTICE OF MOTION

AND MOTION TO COMPEL

PRODUCTION OF DOCUMENTS:

Evidence Code, section 453;

California Business and

Professions Code, secs. 6067-6128;

18 U.S.C. 1341, 1964 (Civil RICO)

by placing one true and correct copy of said document(s) in first class United States Mail, with postage prepaid and properly addressed to the following:

[PLAINTIFF’S ATTORNEY]

Mr. Kirk E. Giberson

Hefner Stark & Marios

2150 River Plaza Dr. #450

Sacramento 95833

CALIFORNIA, USA

[CLERK OF COURT (2x)]

600 Union Avenue

Fairfield 94533

CALIFORNIA, USA

Dated: May 16, 2005

Signed: /s/ Robert H. Hale

___________________________________________

Printed: Robert H. Hale, Sui Juris