Contract analysis

I. Description of the Document Produced to Date In connection with the filing of Contestants' initial objection, your office produced a single photocopy of a two-page document purporting to be a premarital agreement dated May 30, 2008 (the "Photocopy"). We acknowledge receipt of that Photocopy and have reviewed it carefully. We note the following with respect to the document as produced: The Photocopy bears what appe

II. Deficiencies in the Photocopy The Photocopy produced by your office suffers from numerous and fatal deficiencies that render it wholly inadequate as a basis for Contestants' claims. We identify these deficiencies as follows: A. The Document Is Only a Photocopy. The Photocopy is not an original instrument. It is a reproduction of unknown provenance, and its authenticity cannot be verified through physical examinat

III. Legal Basis for This Demand The demand set forth in this letter is grounded in well-established principles of California statutory and evidentiary law. We summarize the applicable authorities as follows: A. California Family Code § 1611 — Writing and Signature Requirement. Under California Family Code Section 1611, a premarital agreement must be in writing and signed by both parties in order to be enforceable. T

IV. Specific Demand In light of the foregoing, Calderwood & Harkness LLP, on behalf of Marguerite D. Fonseca, hereby demands that Brennan, Ortega & Saldívar LLP produce the following documents and information within twenty-one (21) calendar days of the date of this letter — that is, by no later than December 22, 2022:

1. The Original Premarital Agreement. The original premarital agreement allegedly dated May 30, 2008, including all pages, signature pages, exhibits, schedules, attachments, and any addenda or amendments thereto, in whatever form they exist.

2. All Drafts and Prior Versions. All drafts, revisions, redlined versions, markups, and prior versions of the alleged agreement, whether in hard copy or electronic form, reflecting the negotiation and development of the document from its inception through any purported final execution.

3. All Related Correspondence and Communications. All correspondence, communications, memoranda, transmittal letters, emails, text messages, or other records relating to the preparation, negotiation, review, execution, delivery, or storage of the alleged agreement, including communications between or among the parties, their respective counsel (if any), and any other person or entity involved in the process.

4. Identification of Counsel. Identification of the attorney or attorneys, if any, who prepared, drafted, reviewed, or provided legal advice with respect to the alleged agreement on behalf of either Teodoro R. Fonseca or Marguerite D. Fonseca, including the name, firm affiliation (if applicable), and contact information of each such attorney, and a description of the scope and nature of the legal services provided.

5. Chain-of-Custody Statement. A complete and detailed chain-of-custody statement establishing who has possessed the original of the alleged agreement and/or any copies thereof from the date of its purported execution on or about May 30, 2008, through the present, including the dates and circumstances of each transfer of possession, the identity of each custodian, and the location(s) at which the original and/or copi

6. Financial Disclosure Documentation. Any and all financial disclosure statements, schedules of assets and liabilities, income summaries, property valuations, or other documents exchanged between the parties in connection with the alleged agreement, as contemplated by California Family Code Section 1615(c). This demand includes any written acknowledgment or waiver of such disclosure by either party. This demand is m

V. Consequences of Non-Production In the event that the original premarital agreement cannot be produced, we demand that your office provide a detailed written explanation of the circumstances of its unavailability. That explanation must address, at a minimum, the following: when the original was last seen and by whom; who last possessed the original; where the original was stored; what efforts have been undertaken t

VI. Client's Position So that there is no ambiguity regarding Ms. Fonseca's position, we state it plainly here for the record: Ms. Fonseca categorically denies that she ever executed any premarital agreement with Teodoro R. Fonseca. Ms. Fonseca denies that she was ever presented with a final version of any such agreement for her signature, that she ever agreed to the terms reflected in the Photocopy, or that she ever

VII. Reservation of Rights This letter is written and transmitted without prejudice to any and all rights, claims, remedies, and defenses available to Ms. Fonseca in the above-referenced proceeding or in any other forum. Nothing contained in this letter shall be construed as a waiver, limitation, or relinquishment of any right to seek additional discovery, to propound formal interrogatories or requests for production

VIII. Closing We respectfully request that you confirm receipt of this letter at your earliest convenience and advise us of your clients' position with respect to the demands set forth herein. We are prepared to discuss the logistics of document production or, if your clients prefer, to arrange for an in-person inspection of any original documents at a mutually convenient time and location. We trust that this matter