BJS 22.12.28 DECLARATION OF ALEX M. WEINGARTEN IN SUPPORT OF JAMES P. SPEARS’S OPPOSITION TO MOTION TO COMPEL ANSWERS TO DEPOSITION QUESTIONS, REQUEST FOR LEAVE TO TAKE SECOND DEPOSITION, AND REQUEST FOR SANCTIONS

1 Alex M.
Weingarten (SBN 204410)

[email protected]
2 Eric J. Bakewell (SBN 241529)
[email protected]
3 WILLKIE FARR & GALLAGHER LLP
2029 Century Park East, Suite 3400
4 Los Angeles, CA 90067
Telephone: (310) 855-3000
5 Facsimile: (310) 855-3099
6 Attorneys for Former Conservator of the Estate
JAMES P. SPEARS
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8 SUPERIOR COURT OF CALIFORNIA

9 COUNTY OF LOS ANGELES - CENTRAL DISTRICT
10 In re the Conservatorship of the Person and CASE NO.: BP108870

Estate of
11 Hon. Brenda J. Penny
BRITNEY JEAN SPEARS, Dept.: 4
WILLKIE FARR & GALLAGHER LLP
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2029 CENTURY PARK EAST, SUITE 3 400
Conservatee. PUBLIC REDACTED VERSION

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LOS ANGELES, CA 90067
DECLARATION OF ALEX M.
310.855.3000
14 WEINGARTEN IN SUPPORT OF JAMES

P. SPEARS’S OPPOSITION TO MOTION
15 TO COMPEL ANSWERS TO
DEPOSITION QUESTIONS, REQUEST
16 FOR LEAVE TO TAKE SECOND
DEPOSITION, AND REQUEST FOR
17 SANCTIONS
18 [Filed Concurrently With Opposition To Motion
To Compel; Declaration Of Michael Arakelyan;
19 Response To Separate Statement; Evidentiary
Objections]
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Date: January 11, 2023
21 Time: 1:30 p.m.
22 Dept.: 4
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59858333
WEINGARTEN DECL. ISO OPP’N TO MOTION TO COMPEL SECOND DEPOSITION
1 DECLARATION OF ALEX M. WEINGARTEN
2 I, Alex M. Weingarten, declare as follows:
3 1. I am a member of the bar of the State of California and a Partner at Willkie Farr &
4 Gallagher LLP (“Willkie”), counsel of record for James P. Spears (“Jamie”) in this action. I
5 submit this declaration in support of Jamie’s Opposition To Britney Spears’s Motion To Compel
6 Answers To Deposition Questions, Request For Leave To Take Second Deposition, And Request
7 For Sanctions. I make this declaration of personal, firsthand knowledge, and if called and sworn
8 as a witness, I could and would testify as set forth below.
9 2. On October 14, 2021, Jamie retained Willkie to represent him in wrapping up his
10 duties in the Conservatorship proceedings of Britney Spears (“Britney”). Willkie substituted in
11 as counsel for Jamie on October 19, 2021 in the above-captioned case.

12 Jamie Makes An Extensive Record Production

13 3. Jamie was represented by lawyers at Freeman, Freeman & Smiley LLP (“FFS”)
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14 and Holland & Knight (“H&K”) prior to Willkie entering the case.
15 4. Willkie received several electronic productions of documents from FFS between
16 October 18 and November 17, 2021. These productions consisted of approximately 119,567
17 documents (totaling approximately 568,621 pages). These productions were concurrently made
18 available to Justin Gold (counsel for John Zabel who was the Temporary Conservator of
19 Britney’s Estate) in the same manner in which the productions were provided to Willkie.
20 5. Willkie received two electronic productions of documents from H&K between
21 October 29 and November 2, 2021. The production of documents Willkie received from H&K
22 consisted of approximately 5,069 documents (totaling approximately 23,993 pages). These two
23 productions were concurrently made available to Gold in the same manner in which the
24 productions were provided to Willkie.
25 6. FFS and H&K collectively produced approximately 124,636 electronic
26 documents (totaling approximately 592,614 pages).
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1 Britney’s Counsel Serves Discovery Requests On August 25 And December 17, 2021
2 7. Britney’s counsel served Jamie’s former counsel at H&K with a first set of
3 discovery (requests for production, requests for admission, special interrogatories, and form
4 interrogatories) on August 25, 2021 (the “August 25 Discovery”). The August 25 Discovery
5 contained 37 requests for production.
6 8. My understanding is that Jamie’s counsel at H&K negotiated a 21-day extension
7 to respond to the August 25 Discovery and Jamie timely responded to that discovery on October
8 15, 2021.
9 9. Britney’s counsel never served a motion to compel relating to the August 25
10 Discovery or otherwise attempted to meet and confer regarding a motion to compel further
11 responses to the August 25 Discovery.

12 10. Britney’s counsel then served a second set of discovery on December 17, 2021
13 (the “December 17 Discovery”). The December 17 Discovery also consisted of requests for
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14 production, requests for admission, special interrogatories, and form interrogatories. The
15 December 17 Discovery requests were materially identical to the August 25 Discovery requests.
16 11. Jamie timely responded to the December 17 Discovery on January 18, 2022.
17 Jamie objected to the December 17 Discovery on the grounds that a party cannot re-serve
18 materially identical discovery requests to cure a missed motion to compel deadline. Jamie’s
19 objections specifically cited to Pro. Colls., Magna Inst., Inc. v. Superior Court, 207 Cal. App. 3d
20 490 (1989).
21 12. Britney’s counsel never served a motion to compel further responses to the
22 December 17 Discovery.
23 Britney’s Counsel Serves A Revised Deposition Notice
24 13. Attached hereto as Exhibit 1 is a true and correct copy of the Second Amended
25 Notice Of Deposition Of James P. Spears served on March 2, 2022.
26 14. Attached hereto as Exhibit 2 is a true and correct copy of James P. Spears’s
27 Responses To The Second Amended Notice Of Deposition served on April 1, 2022.
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1 Jamie Produces Documents And Sits For A Deposition
2 15. Jamie made a production to Britney’s counsel consisting of 19,471 documents
3 spanning 43,385 pages when Jamie arrived at Greenberg Traurig, LLP’s offices for his
4 deposition on August 11, 2022 at 10:00 a.m. Britney’s counsel did not request the documents be
5 produced before the deposition or otherwise attempt to negotiate a schedule that would have
6 documents produced prior to the deposition.
7 16. Attached hereto as Exhibit 3 is a true and correct copy of select portions of the
8 Deposition Transcript of James P. Spears dated August 11, 2022. Exhibit 3 is filed under seal
9 because it was designated as “Highly Confidential” under the Protective Order entered by the
10 Court on September 14, 2022 (the “Protective Order”).
11 17. Attached hereto as Exhibit 4 is a true and correct copy of a text message
12 contained in Jamie’s document production bearing the Bates number JPS00045011. Exhibit 4 is
13 filed under seal because it was designated as “Confidential” under the Protective Order.
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14 18. Attached hereto as Exhibit 5 is a true and correct copy of a letter I received from
15 Kyle Freeny dated August 17, 2022.
16 19. Attached hereto as Exhibit 6 is a true and correct copy of the email releasing the
17 re-production of text messages per Britney’s counsel’s request on August 22, 2022 as a
18 professional courtesy.
19 20. I have not received any additional correspondence or otherwise received any
20 requests from Britney’s counsel since the August 17 letter that is Exhibit 5 seeking re-production
21 of other documents or further production of additional electronically stored information fields.
22 Jamie Responds To Meet And Confer Letters Regarding Britney’s Counsel’s
23 Motion To Compel
24 21. Attached hereto as Exhibit 7 is a true and correct copy of a letter I sent to
25 Britney’s counsel dated October 10, 2022. Portions of Exhibit 7 are filed under seal as Exhibit 7
26 references deposition testimony that was designated as “Highly Confidential” under the
27 Protective Order.
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1 22. Attached hereto as Exhibit 8 is a true and correct copy of a letter I sent to
2 Britney’s counsel dated November 3, 2022. Portions of Exhibit 8 are filed under seal as Exhibit
3 8 references deposition testimony that was designated as “Highly Confidential” under the
4 Protective Order.
5 Additional Exhibits
6 23. Attached hereto as Exhibit 9 is a true and correct copy of select portions of the
7 Deposition Transcript of Edan Yemini dated August 24, 2022. Exhibit 9 is filed under seal
8 because it was designated as “Highly Confidential” under the Protective Order.
9 I declare under penalty of perjury under the laws of the State of California that the
10 foregoing is true and correct.
11 Executed on December 28, 2022 at Los Angeles, California.

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Alex M. Weingarten
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EXHIBIT 1
1 PROOF OF SERVICE
2 STATE OF CALIFORNIA
3 COUNTY OF LOS ANGELES
4 I am employed in the aforesaid county, State of California; I am over the age of 18 years and not a
party to the within action; my business address is 1840 Century Park East, Suite 1900, Los Angeles,
5 CA 90067-2121.
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On March 2, 2022, I caused the document(s) described as SECOND MENDED NOTICE OF
7 DEPOSITION OF JAMES P. SPEARS AND REQUEST FOR PRODUCTION OF DOCUMENTS
to be transmitted to the addressee(s) listed on the attached Service List.
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(BY E-SERVICE) I caused the document(s) to be sent to the person(s) at the e-mail address(es)
9 indicated on the attached service list.
10 (STATE) I declare under penalty of perjury under the laws of the State of California that the
11 foregoing is true and correct.
12 Executed on March 2, 2022, at Los Angeles, California.

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14 ___/s/ Jane Davidson ______________________

Jane Davidson
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PROOF OF SERVICE
1
SERVICE LIST
2 CASE BP108870
3
Alex Weingarten Attorneys for James P. Spears
4 Willkie Farr & Gallagher, LLP Suspended Conservator of the Estate
Email; [email protected]
6 [email protected]
7 Tel: 310-855-3000/Fax: 310-855-3099
8 Vivian L. Thoreen Former Attorneys for James P. Spears,

Jonathan H. Park Suspended Conservator of the Estate
9 HOLLAND & KNIGHT, LLP
400 S. Hope Street, 8th Floor
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Los Angeles, CA 90071
11 Tel: 213-896-2400/ Fax: 213-896-2450
Email: [email protected]
12 [email protected]
13
Geraldine A. Wyle Former Attorneys for James P. Spears,
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Jeryll S. Cohen Suspended Conservator of the Estate
15 FREEMAN FREEMAN & SMILEY, LLP
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19 Yasha Bronshteyn Attorneys for Lynne Spears, Mother of Former

GINZBURG & BRONSHTEYN, LLP Conservatee
20 11111 Santa Monica Blvd., Suite. 1840
Los Angeles CA 90025
21 Tel: 310-914-3222
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Gladstone N. Jones, III Attorneys for Lynne Spears, Mother of Former
24 Lynn E. Swanson Conservatee
JONES SWANSON HUDDELL & GARRISON, LLC
25 Pan-American Life Center
601 Pyodras Street, Suite 2655
26 New Orleans, LA 70130
27 Tel: 504-523-2500
Email: [email protected];
PROOF OF SERVICE
1 Lauriann C. Wright Attorneys for Jodi Montgomery
Marie Mondia
2 WRIGHT KIM DOUGLAS, ALC
3 130 S. Jackson Street
Glendale, CA 91205-1123
4 Tel: 626-356-3900
5 [email protected]
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7 Eric Adler Attorneys for Non-Party, Tri-Star Sports &

MAGEE & ADLER, APC Entertainment
8 400 Oceangate, Suite 1030
Long Beach, CA 90802
9 Tel: 562-432-1001
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PROOF OF SERVICE
EXHIBIT 2
1 Alex M. Weingarten (SBN 204410)
[email protected]
2 Eric J. Bakewell (SBN 241529)
[email protected]
3 WILLKIE FARR & GALLAGHER LLP
Telephone: (310) 855-3000
5 Facsimile: (310) 855-3099
6 Attorneys for Former Conservator of the Estate

JAMES P. SPEARS
7
8 SUPERIOR COURT OF CALIFORNIA

9 COUNTY OF LOS ANGELES - CENTRAL DISTRICT
10
In re the Conservatorship of the Person and CASE NO.: BP108870

Estate of
11 Hon. Brenda J. Penny
BRITNEY JEAN SPEARS, Dept.: 4
2029 CENTURY PARK EAST, SUITE 3400
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Conservatee. OBJECTIONS TO SECOND AMENDED
13 NOTICE OF DEPOSITION OF JAMES P.

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SPEARS AND REQUESTS FOR

14 PRODUCTION OF DOCUMENTS
15 Date: April 6, 2022
Time: 10:00 a.m.
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Place: Greenberg Traurig, LLP
17 1840 Century Park East, Suite 1900
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51511276
OBJECTIONS TO SECOND AMENDED NOTICE OF DEPOSITION OF JAMES P. SPEARS
1 Pursuant to California Civil Procedure Code Section 2025.210 et seq., James P. Spears
2 (“Jamie”), former Conservator of the Estate of Britney Jean Spears (“Britney”), hereby responds
3 and objects to Britney’s Second Amended Notice of Deposition of James P. Spears (“Deposition
4 Notice”) and Request for Production Of Documents (“Document Requests”) as follows:
5 GENERAL OBJECTIONS
6 The following general objections apply to the Deposition Notice generally and to each
7 and every Document Request therein:
8 1. Jamie is presently pursuing his investigation of the facts and law relating to
9 Britney’s Deposition Notice, Document Requests, and definitions. Jamie’s objections and
10 responses are based on the knowledge, information, and belief of Jamie at this time, as well as
11 the documents in Jamie’s possession, custody, or control. Therefore, these objections and
12 responses are given without prejudice to Jamie’s right to produce evidence of subsequently
13 discovered facts or to add, modify, or otherwise change or amend the objections and responses or
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14 to rely on additional evidence at trial or in connection with any pretrial proceedings. Jamie
15 expressly reserves the right to amend or supplement these objections and responses.
16 2. Jamie’s response to any part of the Deposition Notice, Document Requests, or
17 definitions shall not be deemed as an admission or acknowledgement that such portion of the
18 demand calls for information that is relevant to the subject matter of the instant action and is
19 without prejudice to Jamie’s right to contend at any stage of the case that the requested
20 information is irrelevant, inadmissible, immaterial, or otherwise objectionable.
21 3. The Deposition Notice, Document Requests, and definitions set the place for
22 deposition outside the geographic limitations established by the California Civil Procedure Code.
23 California Civil Procedure Code Section 2025.250(a) requires the deposition to be taken within
24 either: (a) 75 miles of the deponent’s residence, or (b) the county where the action is pending and
25 within 150 miles of the deponent’s residence. The Deposition Notice, Document Requests, and
26 definitions set the place for deposition at Greenberg Traurig, LLP’s office in Century City,
27 California. But, Jamie resides in Kentwood, Louisiana. Kentwood, Louisiana is nowhere close
28 to 75 miles from Century City, California or 150 miles from Los Angeles County (where the
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1 case is pending). The Deposition Notice, Document Requests, and definitions are improper
2 because the place for deposition is not set within 75 or 150 miles of Jamie’s residence.
3 4. The Deposition Notice, Document Requests, and definitions unilaterally set April
4 6, 2022 as the date for deposition on which neither Jamie nor his counsel are available to sit for
5 deposition. Counsel for Jamie attempted to meet and confer with Britney’s counsel to agree and
6 stipulate to mutually agreeable deposition dates for Jamie and Britney. Britney’s counsel refused
7 to agree to any deposition of Britney, offer any dates for Britney’s deposition, or participate in
8 any constructive meet and confer discussion regarding deposition dates for Jamie and Britney.
9 Instead, Britney’s counsel unilaterally noticed a deposition for Jamie on April 6, 2022 without
10 inquiring about Jamie’s or his counsel’s availability. Neither Jamie nor Jamie’s counsel are
11 available to attend what is presumably intended to be an all-day deposition on April 6, 2022.

12 Additionally, there is a hearing set for this matter on April 6, 2022 at 1:30 p.m. which further
13 makes the date for the deposition untenable for all parties.
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14 5. Jamie objects to the Deposition Notice, Document Requests, and definitions to the
15 extent that they are duplicative of the requests and information sought by Britney’s August 25,
16 2021 first set of requests for production and Britney’s December 17, 2021 second set of requests
17 for production. Britney’s August 25, 2021 first set of requests for production contained thirty-
18 seven requests. Britney’s December 17, 2021 second set of requests for production contained
19 fifty-eight requests. The second set served on December 17 is nearly identical to the first set
20 served on August 25. Jamie timely objected to the first set of requests in their entirety on
21 October 15, 2021 pursuant to the response deadline agreed to by the parties. Jamie timely
22 objected to the second set of requests for production in their entirety on January 18, 2022.
23 Britney did not move to compel further responses to either the first or second sets of requests for
24 production. The Deposition Notice, Document Requests, and definitions again serve nearly
25 identical Requests a third time and are, therefore, unduly burdensome and unreasonably
26 cumulative and duplicative.
28 extent they extend beyond the proper scope of discovery and improperly attempt to re-litigate the
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1 entire thirteen-year Conservatorship and innumerable final court orders. California Civil
2 Procedure Code Section 2017.010 limits the scope of discovery to matters relevant to the subject
3 matter involved in the pending action. California Probate Code Section 2103 releases a
4 conservator and sureties from all the conservatee’s claims when the court authorizes, approves,
5 or confirms the conservator’s action in an order. Accordingly, Jamie objects: (a) to the extent the
6 Deposition Notice, Document Requests, and definitions are overbroad, unduly burdensome, and
7 beyond the scope of discovery; (b) to the extent the Deposition Notice, Document Requests, and
8 definitions are not relevant to the limited matters remaining before the Court; and (c) to the
9 extent the Court already approved any action in an order or judgment. Filing belated objections
10 to Court orders from over a decade ago or attempting to re-litigate settled issues does not expand
11 the scope of discovery.

12 7. Jamie objects to the Deposition Notice, Document Requests, and definitions as

13 duplicative, unduly burdensome, oppressive, and harassing to the extent the Deposition Notice,
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14 Document Requests, and definitions seek some or all of the same documents and information
15 that Jamie already voluntarily produced. Since October 2021, Jamie’s counsel has arranged for
16 nearly 600,000 pages of documents (consisting of more than 58 boxes of hard copy documents
17 and more than 22 drives of electronic documents and spanning over 13 years of documents).
18 Britney’s own counsel admitted at the January 19, 2022 hearing that Jamie “produced
19 voluminous information.” See Jan. 19, 2022 Hr’g Tr. 17:3-4 (“Jan. 19 Tr.”). The nearly 600,000
20 pages of documents represent more than 124,500 electronic documents. Britney already is in
21 possession of the documents responsive to her the Deposition Notice, Document Requests, and
22 definitions and there are no further documents Jamie could provide to respond to the Deposition
23 Notice, Document Requests, and definitions. Apparently, Britney and her counsel are more
24 interested in making inflammatory and/or incendiary Requests (without any good faith factual
25 basis) instead of reviewing the documents and information that are already in their possession,
26 custody, or control (as Jamie already produced all of the documents that could be responsive to
27 the requests). In any event, any responsive documents that are in Jamie’s possession, custody, or
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1 control already are in Britney’s possession, custody, or control or are otherwise equally available
2 to her given Jamie’s prior voluminous production of documents and information.
3 8. Jamie objects to the Deposition Notice, Document Requests, and definitions and
4 the accompanying Requests to the extent they are not relevant and not reasonably calculated to
5 lead to the discovery of admissible evidence.
7 extent that they are vague, ambiguous, overly broad, unduly burdensome, oppressive, and seek
8 information that is not within Jamie’s possession, custody, or control.
10 extent that they seek information protected from disclosure by the attorney-client privilege, work
11 product doctrine, third-party privacy rights, and/or any other available privilege or immunity.
12 Any inadvertent production of privileged documents or things shall not constitute a waiver of: (a)
13 any such privilege or immunity; (b) any grounds for objection to discovery with respect to such
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14 information or document; or (c) Jamie’s right to demand the return of inadvertently disclosed
15 materials or to object to the use of any such information or document during any subsequent
16 proceeding in this action or elsewhere.
18 extent it fails to define “YOU” or “YOURS” and is therefore ambiguous.
20 extent they do not limit the scope of the requests to relevant dates and are accordingly overly
21 broad, unduly burdensome, and oppressive.
23 extent they are speculative, lack foundation, or improperly assume the existence of hypothetical
24 facts that are incorrect or unknown to Jamie.
26 extent they call for a legal conclusion. Any response by Jamie should not be construed as
27 providing a legal conclusion regarding the meaning or application of any terms or phrases used
28 in Britney’s instructions, definitions, or requests.
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2 extent they are duplicative, cumulative, and/or seek information that may be obtained from other
3 sources or through other means of discovery that are more convenient, more efficient, more
4 practical, less burdensome, or less expensive.
5 16. Jamie objects to the discovery of electronically stored information on the grounds
6 and to the extent that the Deposition Notice, Document Requests, and definitions seek the
7 production of documents or information from a source (including, but not limited to, servers,
8 hard drives, cell phones, tape backups, storage media, cloud based storage) that is not reasonably
9 accessible because of undue burden or expense and that Jamie will not search those sources
10 which it determines, after a reasonable search and investigation, would result in undue burden or
11 expense in the absence of an agreement with Britney or court order.

13 extent they seek or require the review of documents to the extent that the volume of documents,
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14 coupled with the burden and expense of searching for, recovering, and/or reviewing such
15 materials for responsiveness and privilege purposes, would outweigh the likely benefit of this
16 discovery, taking into account the needs of this cases and other factors.
17 18. The following responses constitute Jamie’s best information and belief at this
18 time, based upon reasonable inquiry and the facts presently available and, except for explicit
19 facts admitted herein, no incidental or implied admissions are intended hereby. The fact that
20 Jamie has answered or objected to any request or part thereof should not be taken as an
21 admission that Jamie accepts or admits the existence of any facts set forth or assumed by such
22 requests, or that such answer or objection constitutes admissible evidence. The fact that Jamie
23 has responded to part or all of any request is not intended and shall not be construed to be a
24 waiver by Jamie of all or any part of any objection to any request.
26 extent that they attempt to expand the nature and/or scope of Jamie’s obligations to respond
27 beyond that required by law. Accordingly, without limiting the generality of the foregoing, in
28 response to Britney’s requests, Jamie will use reasonable diligence to locate responsive
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1 information, based upon an examination of documents, if any, in his custody, possession or
2 control that may reasonably be expected to yield responsive information. To the extent Britney
3 seeks to require Jamie to do more than the foregoing, Jamie objects to each and every demand on
4 the grounds that it is vague and ambiguous, overbroad, seeks information that is neither relevant
5 to Britney’s claims and/or defenses in this action nor reasonably calculated to lead to the
6 discovery of admissible evidence, and would subject Jamie to oppression, harassment, and undue
7 burden and expense.
9 extent they attempt to impose any burdens inconsistent with or in addition to the obligations
10 under the California Civil Code, California Probate Code, California Civil Procedure Code,
11 California Evidence Code, this Court’s Order(s) or local rules, or any other applicable law.
12 21. Each of the foregoing general objections is incorporated by reference into each
13 and every specific objection set forth below.

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14 OBJECTIONS TO REQUESTS FOR PRODUCTION
15 REQUEST FOR PRODUCTION NO. 1:
16 All DOCUMENTS and COMMUNICATIONS RELATING TO the electronic
17 surveillance, monitoring, cloning, or recording of the activity of any phones or other devices
18 used by Britney Jean Spears, including but not limited to the surveillance, monitoring, cloning,
19 iCloud mirroring, or recording of calls, e-mails, text messages, internet browser use or history,
20 and social media use or direct messages on social media.
21 RESPONSE TO REQUEST FOR PRODUCTION NO. 1:
22 Jamie incorporates by reference his General Objections. Jamie further objects to the
23 Document Request to the extent it is vague, ambiguous, overly broad, unduly burdensome, and
24 oppressive especially as it does not contain any temporal limitations. Jamie further objects to the
25 Document Request to the extent it impermissibly seeks material protected by the attorney-client
26 privilege, the attorney work-product doctrine, and/or the common interest doctrine. Jamie
27 further objects to the Document Request to the extent that it seeks information that is already in
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1 Britney’s possession or equally available to her. Jamie objects on the grounds that this
2 Document Request presents an incomplete hypothetical and assumes facts.
3 Jamie further objects to the Document Request as follows:
4  Jamie objects on the grounds that the Document Request is unduly burdensome
5 and unreasonably duplicative and cumulative because it seeks the same information that was
6 requested by Britney from Jamie in her December 17, 2021 Second Set of Requests for
7 Production (see, e.g., Request for Production Nos. 12-21).
8  The Document Request extends beyond the proper scope of discovery and
9 improperly attempts to re-litigate the thirteen-year Conservatorship and innumerable final court
10 orders. California Civil Procedure Code Section 2017.010 limits the scope of discovery to
11 matters relevant to the subject matter involved in the pending action. California Probate Code
12 Section 2103 releases a conservator and the sureties from all the conservatee’s claims when the
13 court authorizes, approves, or confirms the action in an order. This Document Request is
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14 therefore overbroad, unduly burdensome, and beyond the scope of discovery to the extent it is
15 not relevant to the limited matters remaining before the Court and to the extent the Court already
16 approved any action in an order or judgment.
17  There is no legitimate reason for requiring Jamie to undertake the burden of
18 sifting through documents he already produced and reproducing those documents that are
19 responsive to this Document Request. Jamie objects to these Document Requests as duplicative,
20 unduly burdensome, oppressive, and harassing to the extent the Document Requests seek some
21 or all of the same documents and information that Jamie already voluntarily produced. Since
22 October 2021, Jamie’s counsel has arranged for nearly 600,000 pages of documents (consisting
23 of more than 58 boxes of hard copy documents and more than 22 drives of electronic documents
24 and spanning over 13 years of documents). Britney’s own counsel admitted at the January 19,
25 2022 hearing that Jamie “produced voluminous information.” See Jan. 19 Tr. 17:3-4. The nearly
26 600,000 pages of documents represent more than 124,500 electronic documents. Any responsive
27 documents that are in Jamie’s possession, custody, or control already are in Britney’s possession,
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1 custody, or control or are otherwise equally available to her given Jamie’s prior voluminous
2 production of documents and information.
4 All DOCUMENTS and COMMUNICATIONS RELATING TO any recording or
5 listening device in the home or bedroom of Britney Jean Spears, including all DOCUMENTS
6 and COMMUNICATIONS relating to the decision to place any such recording or listening
7 device and the records of any such audio recordings.
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21 Production (see, e.g., Request for Production Nos. 10-11).
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17 All DOCUMENTS and COMMUNICATIONS RELATING TO any and all loans you
18 received from Tri Star Sports & Entertainment or Lou Taylor.
24 privilege, the attorney work-product doctrine, and/or the common interest doctrine. Jamie also
25 objects to the Document Request to the extent it seeks documents or information not relevant or
26 related to Britney or the Conservatorship.
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3 requested by Britney from Jamie in her August 25, 2021 First Set of Requests for Production
4 (see, e.g., Request for Production No. 9) and in her December 17, 2021 Second Set of Requests
5 for Production (see, e.g., Request for Production No. 5).
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2 All agreements contracting for personal services of Britney Jean Spears.
10 Britney’s possession or equally available to her.

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16 for Production (see, e.g., Request for Production No. 3). This is now the third time Britney
17 served the exact same request.
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13 All DOCUMENTS that refer, reflect, or RELATE TO any communications between

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14 YOU and any representative of Tri Star Sports & Entertainment Group, including Lou Taylor
15 and Robin Greenhill.
19 oppressive especially as it does not contain any temporal limitations. Jamie objects on the
20 grounds that this Document Request seeks confidential or private financial information,
21 confidential business or commercial information, trade secrets, proprietary information, or
22 otherwise calls for information protected by the right of privacy. Jamie further objects to the
25 objects to this Document Request to the extent it calls for documents and information irrelevant
26 and unrelated to Britney or the Conservatorship. Jamie further objects to the Document Request
27 to the extent that it seeks information that is already in Britney’s possession or equally available
28 to her.
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4 All communications, including agreements, with Tri Star Sports & Entertainment Group
5 or any of its principals or employees.
9 oppressive especially as it does not contain any temporal limitations. Jamie objects on the
10 grounds that this Document Request seeks confidential or private financial information,
11 confidential business or commercial information, trade secrets, proprietary information, or

12 otherwise calls for information protected by the right of privacy. Jamie further objects to the
310-855-3000
15 objects to this Document Request to the extent it calls for documents and information irrelevant
18 to her.
51511276 14
310-855-3000
21 All DOCUMENTS RELATING TO any agreements with Tri Star Sports &
22 Entertainment Group.
26 oppressive especially as it does not contain any temporal limitations. Jamie objects to this
27 Document Request to the extent it calls for documents and information irrelevant and unrelated
28 to Britney or the Conservatorship. Jamie further objects to the Document Request to the extent it
51511276 15
1 impermissibly seeks material protected by the attorney-client privilege, the attorney work-
2 product doctrine, and/or the common interest doctrine. Jamie further objects to the Document
3 Request to the extent that it seeks information that is already in Britney’s possession or equally
4 available to her.

310-855-3000
51511276 16
7 All correspondence (whether on paper, electronically, or by text or instant message) with
8 Tri Star Sports & Entertainment Group RELATING TO Tri Star Sports & Entertainment
9 Group’s compensation.
310-855-3000
51511276 17
310-855-3000
20 All DOCUMENTS RELATING TO a listening or recording device placed in Britney
21 Jean Spears’s home or bedroom.
51511276 18
7 Production (see, e.g., Request for Production No. 10). This is now the second time Britney
310-855-3000
51511276 19
4 All correspondence (whether on paper, electronically, or by text or instant message)
5 RELATING TO a listening or recording device placed in Britney Jean Spears’s home or
6 bedroom.
310-855-3000
51511276 20
310-855-3000
17 All DOCUMENTS RELATING TO mirroring of Britney Jean Spears’s mobile telephone
18 on another device or mirroring any telephone or device utilized by Ms. Spears.
51511276 21
310-855-3000
28
51511276 22
2 All DOCUMENTS RELATING TO monitoring of Britney Jean Spears’s personal
3 computer, iPad or a computer used by Ms. Spears.


310-855-3000
17 Production (see, e.g., Request for Production No. 17).
51511276 23


13 All DOCUMENTS RELATING TO monitoring of Britney Jean Spears’s iCloud account

310-855-3000
14 or an iCloud account used by Britney Spears.
28 Production (see, e.g., Request for Production No. 20).
51511276 24

310-855-3000
25 RELATING TO monitoring of Britney Jean Spears’s iCloud account.
51511276 25

310-855-3000
51511276 26
8 All DOCUMENTS RELATING TO payments or approvals for payments made for legal
9 representation of Lou Taylor or Robin Greenhill.

310-855-3000
51511276 27
310-855-3000
20 All DOCUMENTS RELATING TO tax or “accounting services” rendered by Tri Star
21 Sports & Entertainment Group.
28
51511276 28

310-855-3000
51511276 29
5 All correspondence (whether on paper, electronically, or by text or instant message) with
6 security services and/or guards at Black Box Security, Inc. or otherwise, who have worked at the
7 residence of Britney Jean Spears concerning electronic surveillance.
310-855-3000
51511276 30

12 All lease or other rental agreements paid for out of the Conservatorship Estate of Britney
13 Jean Spears.
310-855-3000
51511276 31

310-855-3000
25 RELATING TO the monthly allowance that you allowed to Britney Jean Spears out of her
26 Conservatorship Estate.
27
28
51511276 32

310-855-3000
51511276 33

11 All DOCUMENTS evidencing any analysis performed RELATING TO the monthly

12 allowance that you permitted to Britney Jean Spears out of her Conservatorship Estate.

310-855-3000
28
51511276 34

310-855-3000
24 All DOCUMENTS evidencing your ascertainment, if any, of the goals, needs and
25 preferences of Britney Jean Spears while you were the Conservator of the Person.
51511276 35

310-855-3000
51511276 36
8 All DOCUMENTS RELATING TO any discussion or negotiation for your resignation
9 from the position of Conservator.

310-855-3000
14 Document Request to the extent that it seeks information that is already in Britney’s possession
15 or equally available to her. Jamie further objects to the Document Request to the extent it
17 product doctrine, and/or the common interest doctrine.
51511276 37
310-855-3000
20 All DOCUMENTS RELATING TO any payments to third parties that you sought as part
21 of any discussion or negotiation for your resignation from the position of Conservator.
28
51511276 38

310-855-3000
51511276 39
6 RELATING TO any payments to third parties that you sought as part of any discussion or
7 negotiation for your resignation from the position of Conservator.
310-855-3000
51511276 40
310-855-3000
18 All DOCUMENTS evidencing any training, schooling, or education you received
19 RELATING TO how to be a fiduciary or manage the financial affairs of a third party.
51511276 41
310-855-3000
51511276 42
2 All organizational and corporate formation documents for all entities that have received
3 or held Conservatorship Estate assets and in which you held or hold an officer, director,
4 managing member, general partner, or managing agent position.
10 or equally available to her. Jamie objects on the grounds that this Document Request seeks
11 confidential or private financial information, confidential business or commercial information,

12 trade secrets, proprietary information, or otherwise calls for information protected by the right of
13 privacy. Jamie further objects to the Document Request to the extent it impermissibly seeks
310-855-3000
14 material protected by the attorney-client privilege, the attorney work-product doctrine, and/or the
15 common interest doctrine.
51511276 43
310-855-3000
19 RELATING TO whether Britney Jean Spears wanted or did not wish to work a second residency
20 in Las Vegas.
51511276 44
310-855-3000
28
51511276 45
5 RELATING TO whether Britney Jean Spears wanted to work again for so long as you were her
6 Conservator.
310-855-3000
51511276 46
310-855-3000
17 If you contend that your Twelfth Accounting should be approved, all DOCUMENTS
18 supporting that contention.
28
51511276 47
310-855-3000
28
51511276 48
2 If you contend that your Petition for Order Allowing and Approving Payment of
3 Compensation to Conservator and Attorneys for Conservator and for Reimbursement of Costs
4 should be granted, all DOCUMENTS supporting that contention.


310-855-3000
28
51511276 49

310-855-3000
15 All DOCUMENTS RELATING TO monies you, or any entity with whom you are
16 affiliated as an officer, director, employee, or in any capacity are affiliated, received between
17 2008 and the termination of the Conservatorship.
51511276 50

310-855-3000
27
28
51511276 51
2 All DOCUMENTS RELATING TO the media work invoiced by law firms for which you
3 seek approval to pay their invoiced fees out of the Conservatorship Estate.


310-855-3000
51511276 52



310-855-3000
14 RELATING TO the media work invoiced by law firms for which you seek approval to pay their
15 invoiced fees out of the Conservatorship Estate.
28
51511276 53


310-855-3000
26 All DOCUMENTS RELATING TO the business manager matters invoiced by law firms
27 for which you seek approval to pay their invoiced fees out of the Conservatorship Estate.
28
51511276 54
8 Britney’s possession or equally available to her. Jamie further objects to the Document Request
9 as follows:
310-855-3000
51511276 55

11 RELATING TO the business manager matters invoiced by law firms for which you seek
12 approval to pay their invoiced fees out of the Conservatorship Estate.


310-855-3000
51511276 56
310-855-3000
22 All DOCUMENTS RELATING TO the travel planning invoiced by law firms for which
23 you seek approval to pay their invoiced fees out of the Conservatorship Estate.
51511276 57

310-855-3000
51511276 58
5 All DOCUMENTS RELATING TO the invoiced legal fees incurred by Atlanta law firms
6 in connection with the Bryan Kuchar litigation (Northern District of Georgia Case No. 1:19-cv-
7 03028).
310-855-3000
51511276 59

12 All DOCUMENTS RELATING TO the invoiced legal fees relating to litigation pursued
13 against one of the leaders of the “#FreeBritney” movement or any participants in that movement.
310-855-3000
28
51511276 60

310-855-3000
25 RELATING TO the invoiced legal fees relating to litigation pursued against one of the leaders of
26 the “#FreeBritney” movement or any members of that movement.
27
28
51511276 61

310-855-3000
51511276 62

10 All DOCUMENTS RELATING TO the stipulated judgment and settlement in the
11 litigation pursued by the Conservatorship Estate - regardless of which entity initiated the action -
12 against one of the leaders of the “#FreeBritney” movement or any members of the movement.

310-855-3000
51511276 63
310-855-3000
23 RELATING TO the stipulated judgment and settlement in the litigation pursued by the
24 Conservatorship Estate - regardless of which entity initiated the action- against one of the leaders
25 of the “#FreeBritney” movement or any members of the movement.
51511276 64

310-855-3000
51511276 65
7 A copy of your bond posted for the Conservatorship and all DOCUMENTS RELATING
8 TO the bond.

310-855-3000
51511276 66
310-855-3000
19 All DOCUMENTS RELATING TO “Cookin’ Cruzin’ and Chaos with Jamie Spears”
20 Motor Home or putative pilot television show.
27 objects to the Document Request to the extent it calls for documents and information irrelevant
51511276 67
2 to her. Jamie objects on the grounds that this Document Request seeks confidential or private
3 financial information, confidential business or commercial information, trade secrets, proprietary
4 information, or otherwise calls for information protected by the right of privacy.
310-855-3000
28
51511276 68
2 All DOCUMENTS RELATING TO Marc Delcore.
9 objects to the Document Request to the extent it calls for documents and information irrelevant
12 to her.

310-855-3000
51511276 69
9 All DOCUMENTS RELATING TO the Domestic Violence Restraining order entered

10 against you in 2019.

310-855-3000
14 oppressive especially as it does not contain any temporal limitations. Jamie objects to the
15 Document Request to the extent it calls for documents and information irrelevant and unrelated
16 to Britney or the Conservatorship. Jamie further objects to the Document Request to the extent it
18 product doctrine, and/or the common interest doctrine. Jamie also objects to this Document
19 Request to the extent it seeks documents or information about Britney’s minor children. Jamie
51511276 70
310-855-3000
18 All DOCUMENTS RELATING TO payments made to Advanced Multimedia Partners
19 from Britney Spears or her Estate including but not limited to all payments made to that entity or
20 James P. Watson, III.
51511276 71

310-855-3000
24 Dated: April 1, 2022 WILLKIE FARR & GALLAGHER LLP
25
By:
26 Alex M. Weingarten
Eric J. Bakewell
27
Attorneys for James P. Spears
28
51511276 72
1 PROOF OF SERVICE
4 I am employed in the County of Los Angeles, State of California. I am over the age of 18
and not a party to the within action; my business address is Willkie Farr & Gallagher LLP, 2029
5 Century Park East, Suite 3400, Los Angeles, California.
6 On April 1, 2022, I served a copy  / original  of the foregoing document described as
OBJECTIONS TO SECOND AMENDED NOTICE OF DEPOSITION OF JAMES P.
7 SPEARS AND REQUESTS FOR PRODUCTION OF DOCUMENTS on the interested
parties in this action addressed as follows:
8
9 SEE ATTACHED SERVICE LIST
10  BY PERSONAL SERVICE (CCP §1011): I caused to be delivered such

envelope(s) by hand to the addressee(s) as stated above.

11
 BY ELECTRONIC SERVICE (CCP § 1010.6; CRC Rule 2.251(g)): I
12 transmitted the above-stated document(s) and a copy of this declaration from my

13 computer (electronic notification address [email protected]) located at

Willkie Farr & Gallagher LLP, 2029 Century Park East, Suite 3400, Los Angeles,
310-855-3000
14 California 90067, to the interested parties in this action whose names and e-mail
addresses are listed above. I did not receive, within a reasonable time after the
15 transmission, any electronic message or other indication that the transmission was
unsuccessful. Service by e-mail or electronic transmission was agreed upon based
16 on a court order or an agreement of the parties to accept service.
17
above is true and correct.
19
Executed on April 1, 2022, at Los Angeles, California.
20
21
22 America Garcia
23
24
25
26
27
28
1
PROOF OF SERVICE
1 SERVICE LIST
Conservatorship of Britney Jean Spears
2 Case No. BP108870
3
BY PERSONAL AND ELECTRONIC Attorney for Conservatee Britney Jean
4 SERVICE: Spears
Mathew S. Rosengart
5 Greenberg Traurig LLP
[email protected]
7
8 BY PERSONAL SERVICE ONLY: Conservatee

Britney J. Spears
9 c/o Mathew S. Rosengart
Greenberg Traurig LLP
10

[email protected]
12
BY ELECTRONIC SERVICE ONLY: Temporary Conservator of the Person
13 Jodi Montgomery
310-855-3000
1443 East Washington Blvd., Suite 644

14 Pasadena, CA 91104
16 BY ELECTRONIC SERVICE ONLY: Attorney for Jodi Montgomery

Lauriann C. Wright Request for Special Notice
17 Wright Kim Douglas, ALC
130 S. Jackson Street
18
20 BY ELECTRONIC SERVICE ONLY: Attorney for Lynne Spears

Yasha Bronshteyn
21 Ginzburg & Bronshteyn, APC
22 11755 Wilshire Blvd., Suite 1250
24
25
26
27
28
2
PROOF OF SERVICE
1 BY ELECTRONIC SERVICE ONLY: Attorney for Lynne Spears
Gladstone N. Jones, III
2 Lynn E. Swanson
Jones Swanson Huddell & Garrison, LLC
3
Pan-American Life Center
4 601 Pyodras Street, Suite 2655
New Orleans, LA 70130
5 [email protected]
6 BY ELECTRONIC SERVICE ONLY: Counsel for Temporary Conservator of
Justin B. Gold Estate John Zabel
7 Oldman, Cooley, Sallus, Birnberg,
8 Coleman & Gold, LLP
16133 Ventura Boulevard, #PHA
9 Encino, CA 91436
[email protected]
10
BY ELECTRONIC SERVICE ONLY: Former Counsel for James P. Spears

11
Vivian L. Thoreen
12 Jonathan Park
Holland & Knight LLP
13 400 South Hope Street, 8th Floor

310-855-3000

[email protected]
15
16 BY ELECTRONIC SERVICE ONLY: Former Counsel for James P. Spears

Geraldine A. Wyle Request for Special Notice
17 Jeryll S. Cohen
Freeman, Freeman & Smiley, LLP
Los Angeles, California 90067
19
[email protected]
21 BY ELECTRONIC SERVICE ONLY: Request for Special Notice

Eric Adler
22 Magee & Adler, APC
400 Oceangate, Suite 1030
23
Long Beach, CA 90802
25
26
27
28
3
PROOF OF SERVICE
EXHIBIT 3
Filed under seal pursuant to Cal. R. Ct. 2.550(a)(3)
EXHIBIT 4
EXHIBIT 5
Kyle R. Freeny
Tel 202.331.3118
Fax 202.331.3101
[email protected]
August 17, 2022
Alex Weingarten
Willkie Farr & Gallagher LLP
2029 Century Park East ALBANY
AMSTERDAM
ATLANTA
AUSTIN
Re: Production of Text Messages by James P. Spears
BOSTON
CHICAGO
Dear Mr. Weingarten: DALLAS
DELAWARE
As you know, on July 13, 2022 your client was ordered to produce all documents DENVER
responsive to the Document Requests attached to the Second Amended Notice of FORT LAUDERDALE
Deposition on the date of your client James Spears’s deposition. As part of that production HOUSTON
on August 11, 2022, Mr. Spears produced approximately 2,900 text messages, instant LAS VEGAS
messages, and/or Whatsapp messages or equivalent (hereinafter, collectively referred to as LONDON*
text messages). They were produced in a disjointed, improper manner. (See Kayne v. LOS ANGELES
Grande Holdings Ltd. (2011) 198 Cal.App.4th 1470, 1475-76 [sanctions appropriate where MEXICO CITY+
party refused to produce documents in an organized and labelled manner].) Specifically, MIAMI
despite our best efforts to make sense of this portion of the production, we have been unable MILAN**
to do so because the text messages were produced in an unworkable manner, out of NEW JERSEY
NEW YORK
chronological order and without sufficient metadata to group them by conversation. In
ORANGE COUNTY
addition, individual text messages within a single conversation are not Bates numbered
ORLANDO
consecutively. Indeed, after extensive work, we have been advised by our litigation support
PALM BEACH COUNTY
staff that the text messages appear to have been produced in an intentionally disjointed
PHILADELPHIA
fashion that would make our review as difficult and complicated as possible causing us to PHOENIX
be unable to process them. ROME**
SACRAMENTO
Consistent with best practices as instructed by Kayne and other authorities, (see SAN FRANCISCO
Moore, et al., Cal. Civ. Prac. Procedure (2021) § 13:224), please immediately reproduce all SEOUL∞
text messages with associated Conversation IDs (which may also be referred to as text SHANGHAI
thread ID or similar), and then Bates-numbered chronologically within each conversation SILICON VALLEY
(i.e., each set of text messages sharing a Conversation ID). This conversation ID is a TALLAHASSEE
number assigned to all text messages within a given conversation and is necessary to allow TAMPA
meaningful review of the conversations. Please note that it is not the same as the so-called TEL AVIV^
“chat number” that was provided in the production, as each individual text message appears TYSONS CORNER
to have been assigned a unique chat number, and the chat numbers were not assigned to the WARSAW~
texts in chronological or other meaningful order. WASHINGTON, D.C.

WHITE PLAINS
* OPERATES AS GREENBERG
Based on the metadata that was provided, we anticipate that this re-production can TRAURIG MAHER LLP
be made easily and quickly by the vendor you informed us was hired to collect and
+ OPERATES AS
GREENBERG TRAURIG, S.C.
^ A BRANCH OF
GREENBERG TRAURIG, P.A.
FLORIDA, USA
~ OPERATES AS
GREENBERG TRAURIG, LLP  ATTORNEYS AT LAW  WWW.GTLAW.COM GREENBERG TRAURIG GRZESIAK sp.k.
1840 Century Park East, Suite 1900  Los Angeles, California 90067-2121  Tel 310.586.7700  Fax 310.586.7800 ∞ OPERATES AS
ACTIVE 681432261 GREENBERG TRAURIG LLP
FOREIGN LEGAL CONSULTANT
OFFICE
** STRATEGIC ALLIANCE
EXHIBIT 6
Horak, Emily
From: [email protected]
Sent: Monday, August 22, 2022 10:20 AM
To: [email protected]; [email protected]; [email protected]
Cc: Weingarten, Alex; Bakewell, Eric; Hanle, Sean; Horak, Emily
Subject: In re Spears – Jamie Spears Document Production
[email protected] sent you a secure message
Access message
Counsel,
As requested, enclosed are the re-ordered and re-stamped text messages originally
produced on August 11. The production also includes the metadata field X-ThreadID,
which is the equivalent to the “Conversation ID” you requested.
To download the zip file, please click on the link below and create an account (unless you
have previously created an account).
Once the account is created, log in and download the zip file.
The zip file is password protected. The password is the same one previously provided.
Thanks
Attachments expire on Sep 05, 2022
This message requires that you sign in to access the message and any file attachments.
1
Important Notice: This email message is intended to be received only by persons entitled to receive the confidential
information it may contain. Email messages to clients of Willkie Farr & Gallagher LLP presumptively contain information
that is confidential and legally privileged; email messages to non-clients are normally confidential and may also be legally
privileged. Please do not read, copy, forward or store this message unless you are an intended recipient of it. If you have
received this message in error, please forward it back. Willkie Farr & Gallagher LLP is a limited liability partnership
organized in the United States under the laws of the State of Delaware, which laws limit the personal liability of partners.
2
EXHIBIT 7
Los Angeles, CA 90067-2905
Tel: 310 855 3000
Fax: 310 855 3099
October 10, 2022 Alex M. Weingarten
VIA EMAIL Tel: 310 855 3020

[email protected]
Mathew S. Rosengart
[email protected]
Re: Response To September 30, 2022 Letter

In re the Conservatorship of the Person and Estate of Britney Jean Spears
Los Angeles Superior Court Case Number BP108870
Dear Matt:
We write on behalf of James P. Spears (“Jamie”) in response to your September 30, 2022 letter
requesting a second deposition of Jamie. Your letter is riddled with more of your alternative “facts”
and provides no factual or legal basis to demand an additional deposition of Jamie. To wit:
• Questions About : Your letter states that Jamie failed

to respond to questions about . See Ltr. ¶ 3. Not so. Jamie asked for a break,
returned from the break, and answered all the questions you asked on this subject. See James P. Spears
Depo. Tr. 316:8-319:23, Aug. 11, 2022 (“Spears Depo. Tr.”). You then moved on to a new topic after
asking your questions and receiving answers. Id. at 321:18-322:7. The only unanswered questions are
the ones you failed to ask. This presents no basis for a second deposition.
• Objections On The Basis Of Relevance: Your letter claims that Jamie’s counsel
improperly objected on the basis of relevance. See Ltr. ¶ 5. What you fail to mention, however, is: (1)
counsel objected on relevance to preserve the record as is proper and appropriate given your fishing
expedition untethered to any live issues pending in this case; (2) counsel’s relevance objections were
always accompanied by other objections; and (3) there were no instructions not to answer based only
on a relevance objection. See Spears Depo. Tr. 72:4-9, 283:24-284:4, 302:9-11, 307:21-24, 311:16-18,
314:17-19. In fact, your letter cites Weil, Brown et al., California Practice Guide, Civil Procedure
Before Trial (The Rutter Group) ¶ 8:734.2 with a parenthetical stating that it is “improper for counsel
to instruct a witness not to answer on grounds other than privilege, privacy, trade secrets or other
matters statutorily or constitutionally exempt from discovery.” Ltr. ¶ 5. These were Jamie’s exact
objections. See, e.g., Spears Depo. Tr. 302:9-11 (“It’s irrelevant, it’s privileged, and it’s an invasion of
privacy.”). The only questions Jamie was instructed not to answer were protected by a privilege or
other proper non-relevance ground. See id. at 72:4-9, 283:24-284:4, 302:9-11, 307:21-24, 311:16-18,
314:17-19.
B RUSSE LS C H ICA GO FRAN KFURT H O UST ON L ON DON L OS A N GE LES M ILAN

N EW YO RK P A LO A LTO PA RIS R O ME S AN F RAN CISCO WASH IN GT ON
57853834
Mathew S. Rosengart
October 10, 2022
Page 2
• Production Of Documents The Day Of The Deposition: Your letter complains that
Jamie did not produce documents until the day of his deposition. See Ltr. ¶ 6. But, you fail to provide
the rest of the facts showing how and why Jamie produced documents the day of his deposition and
how you repeatedly failed to organize the schedule to require Jamie’s production of documents prior to
the deposition. Britney Spears (“Britney”) served Jamie with improper document requests on August
25, 2021. Jamie provided objections by the parties’ agreed-upon October 15, 2021 deadline. You
missed the motion to compel deadline (and never even met and conferred about a motion to compel).
Next, you served identical discovery requests on December 17, 2021 – a tactic that is flatly prohibited
by California law. See Pro. Colls., Magna Inst., Inc. v. Superior Court, 207 Cal. App. 3d 490, 493-94
(1989) (“[I]t would be an absurdity to say that a party who fails to meet the time limits . . . may avoid
the consequences of [her] delay and lack of diligence by propounding the same question again.”).
Jamie timely objected on January 18, 2022. You missed the deadline to move to compel a second time
(and never again never met and conferred about any motion to compel). Next, you served a deposition
notice on Jamie requesting the same documents a third time and setting the deadline for the production
the same day as the deposition. You also convinced the Court to set a deadline for Jamie’s deposition.
But, what you never did in the deposition notice, any discussions among counsel, in Britney’s motion
to compel, or at the hearing is get an agreement or court order to have documents be produced before
the deposition. There is no reasonable basis to ask Jamie to incur the expenses and undue burden to sit
for a second deposition because of your neglect. We produced documents on the deadline you set for
their production – at Jamie’s actual deposition.
• Order Of Production Of Documents: Your letter claims the documents were

produced in a disjointed order. See Ltr. ¶ 6. Nonsense. Any insinuation that the documents were
purposely produced in a disjointed manner is false, absurd, and simply represents your desperation to
invent wrongdoing where none exists. The documents were produced in the order in which the
documents were loaded into the document review and production platform. That database has the
documents in the same order in which you received the documents. And, your deposition notice did
not request the documents in any particular order. We re-produced the text messages in the order you
later requested. 1 You did not subsequently request re-productions of any other documents. Again,
there is no reasonable basis to ask Jamie to sit for a second deposition because you did not ask for
documents before his deposition or specify the order in which you wanted documents produced.
• Production Of Password Protected Documents: Your letter makes claims about the
password-protected documents produced. See Ltr. ¶ 8. This issue already was addressed on the record
1 Your letter makes a point that the text messages were reproduced “eleven days after Mr. Spears sat
for the first installment of his deposition.” Ltr. ¶ 7 (emphasis original). As with nearly every other
point in your letter, you leave out numerous material facts including that: (1) you apparently botched
the timing of the production by not setting up a schedule where the documents were produced before
the deposition; (2) you reached out after 5:00 pm on Wednesday, August 17 (six days after Jamie’s
deposition) with an accusatory letter; (3) my colleagues promptly advised you that relevant team
members were not immediately available; and (4) the messages (which you had) were re-produced as
soon as practicable after your request (on the morning of Monday, August 22).
Mathew S. Rosengart
October 10, 2022
Page 3
at Jamie’s deposition. See Spears Depo. Tr. 87:5-88:19, 334:5-8. The passwords for documents sent
after October 2019 were produced through Jamie’s text messages. Black Box produced unlocked
versions of the PDFs for which it obtained the passwords, and you have access to those PDFs. But,
there are a group of password-protected documents for which Jamie does not have the password and
for which Black Box was unable to obtain the password. The flippant comments of your colleagues at
deposition aside, we cannot and have not accessed these documents (because we do not have the
password) but produced the password-protected documents to ensure a complete production. If you
cannot access the document, we cannot and have not either. There is nothing a second deposition will
change about that simple and basic fact.
• Questions About : Your letter also discusses questions

about “ .” Ltr. ¶ 5.
Jamie answered your questions
See Spears Depo. Tr. 228:10-236:23. But, Jamie
objected
That line of questioning is undoubtedly improper.
• Questions About Your letter seeks

answers to two questions asked at Jamie’s deposition
See Ltr. ¶ 5.
If you doubt counsel’s representations on

Mathew S. Rosengart
October 10, 2022
Page 4
these points, we can discuss the issue. But, a second deposition obviously is not needed for either of
these questions given that the questions have been answered.
* * *
We told you Jamie has nothing to hide so will hide nothing. Jamie testified candidly and
truthfully for all six hours and four minutes on the record. We explicitly told you that we would stay
as late as needed for you to use the full seven hours and that Jamie would not be returning from
Louisiana for any further depositions. See Spears Depo. Tr. 333:7-15 (
”). California law prohibits a second deposition of the same

individual. See Cal. Civ. Proc. Code § 2025.610 (“Once any party has taken the deposition of any
natural person, including that of a party to the action, neither the party who gave, nor any other party
who has been served with a deposition notice pursuant to Section 2025.240 may take a subsequent
deposition of that deponent.”). You could have taken hours of breaks to review documents or get
prepared and then resumed questioning. You could have been more mindful of the civil procedure
rules and taken steps to get permissible steps to ensure you had documents before the deposition. You
did not and instead wasted everyone’s time with more of your grandstanding and posturing for effect
by seeking Jamie’s deposition by August 12, 2022. Jamie complied with the Court’s order and
appeared for deposition on August 11, 2022. You (and not Jamie or his counsel) chose to end the
deposition you insisted on taking at that time. You do not get a do-over because you now decided you
are unhappy with the deposition and did not establish anything of consequence at the deposition.
There is nothing in your letter that provides a legitimate basis for you to have a second
opportunity for a deposition. Indeed, you have not identified a single legitimate question for Jamie to
answer at a second deposition. Accordingly, there is no need to provide dates for a second deposition.
If you disagree with the facts stated in this letter, please advise when you are available to convene a
conference of counsel to discuss and attempt to resolve the matter without the need for judicial
intervention.
Kindest Professional Regards,
Alex M. Weingarten
EXHIBIT 8
Los Angeles, CA 90067-2905
Tel: 310 855 3000
Fax: 310 855 3099
November 3, 2022 Alex M. Weingarten
VIA EMAIL Tel: 310 855 3020

[email protected]
Mathew S. Rosengart
[email protected]
Re: November 2, 2022 Meet and Confer

In re the Conservatorship of the Person and Estate of Britney Jean Spears
Los Angeles Superior Court Case Number BP108870
Dear Matt:
I write on behalf of James P. Spears (“Jamie”) regarding our November 2, 2022 meet and
confer relating to your request for a second deposition of Jamie. As discussed during our call and in
our prior correspondence: (1) you have not identified a single legal basis to request a second deposition
or a single proper topic for a second deposition; and (2) you have offered no legitimate explanation as
to why you apparently chose not to complete Jamie’s deposition at his August 11, 2022 deposition
when substantial planning and arrangements were made (at significant cost to all involved) for that
deposition. Accordingly, additional deposition dates will not be offered for Jamie absent additional
information that justifies a second deposition.
First, Jamie (and I as counsel appearing for and defending Jamie at deposition) offered to stay
as late as necessary for you to complete Jamie’s deposition on August 11, 2022. See James P. Spears
Depo. Tr. 333:8-12, Aug. 11, 2022 (“Spears Depo. Tr.”) (“
”). But, you declined and chose to end the deposition. That was your choice, but you are
not entitled to a second opportunity to depose Jamie based on your voluntary decision not to finish
your questions on August 11, 2022. See Cal. Civ. Proc. Code § 2025.610 (“Once any party has taken
the deposition of any natural person, including that of a party to the action, neither the party who gave,
nor any other party who has been served with a deposition notice pursuant to Section 2025.240 may
take a subsequent deposition of that deponent.”).
Second, Jamie answered questions on every topic at his August 11 deposition despite the Court
ruling that discovery is limited to the objections to the Twelfth Accounting and your questions going
well beyond any issue with the Twelfth Accounting. See Spears Depo. Tr. 65:25-66:5, 67:18-24; see
also Minute Order 6, Oct. 10, 2022 (“[T]he Court finds that discovery requests outside the scope of the
B RUSS ELS C HICAGO F RANKFURT H OUSTON L ONDON L OS A NGELES M ILAN

N EW Y ORK P ALO A LTO P ARIS R OME S AN F RANCISCO W ASHINGTON
58564854
Mathew S. Rosengart
November 3, 2022
Page 2
pending petitions and objections are presently improper and irrelevant as the outstanding petitions
concern the 12th Accounting and the petition for fees.”). The Court expressly held that topics related
to previously-approved accountings and the formation of the Conservatorship are irrelevant and
beyond the scope of discovery. See Minute Order at 6, Oct. 10, 2022 (“Oct. 10 Minute Order”)
(granting protective order for irrelevant requests “outside the pending petition such as Mr. Spears’s
alleged misconduct in his capacity as conservator and the establishment of the conservatorship”). 1
Third, your claim that a second deposition of Jamie is somehow proper based on Jamie’s
document production is belied by the fact that you have not identified any legitimate issue with Jamie’s
August 11 document production. As discussed in the meet and confer and in our October 10 letter: (1)
your notice of deposition did not specify a preferred order for production; (2) the documents were
produced to you as the documents were ordered based on how the documents were forensically
collected from Jamie’s devices; (3) you have not asked us to re-produce the documents in any
particular order (like you asked for the text messages and which we re-produced days later); and (4)
your notice of deposition requested the documents at the time of the deposition. You again took issue
with password-protected documents contained in Jamie’s production, but this is an issue invented out
of whole cloth which has been explained to you numerous times at this point as you already know.
This issue was already addressed in our October 10 letter and on the record at Jamie’s deposition. See
Spears Depo. Tr. 87:5-88:19, 334:5-8. And, a second deposition will not solve the fact that we cannot
open the documents either. In any event, you have not provided any legal authority for a second
deposition even if any of your baseless accusations about Jamie’s document production were true (they
are not). See, e.g., Kayne v. The Grande Holdings Ltd., 198 Cal. App. 4th 1470, 1477 (2011) (granting
fees for time spent to organize intentionally jumbled production in response to request for production
under California Civil Procedure Code Section 2031 (not Section 2025) but not granting second
opportunity for deposition).
Fourth, were there legitimate grounds for a second deposition that deposition would be limited
to objections to the Twelfth Accounting and could not last any longer than 56 minutes. As noted, the
Court already limited discovery to issues relating to the objections to the Twelfth Accounting. See Cal.
Civ. Proc. Code § 2017.010 (limiting discovery to issues “relevant to the subject matter involved in the
pending action or to the determination of any motion made in that action”); Oct. 10 Minute Order; see
also Forthmann v. Boyer, 97 Cal. App. 4th 977, 988 (2002) (“We therefore are satisfied, and do
expressly hold, that the filing of a formal objection or response is a necessary predicate to the conduct
of any discovery with respect to the trustee’s interim accounting. Absent an objection or response,
even if made only on information and belief, there is no issue joined by which the relevancy of any
proposed discovery may be judged.”). Additionally, Jamie’s prior deposition lasted six hours and four
minutes on the record, and you have provided no legitimate justification for why Jamie should be
forced to incur the undue burden and expense of traveling from Louisiana for a do-over deposition or
1
Further, our previous October 10, 2022 letter answered your questions about
. See
Letter from Alex M. Weingarten (Oct. 10, 2022).
Mathew S. Rosengart
November 3, 2022
Page 3
why you should get more than the default seven hours of deposition time for Jamie. See Cal. Civ.
Proc. Code § 2025.420(b) (allowing Court to award protective order to protect against unwarranted
annoyance, oppression, or undue burden and expense); see Cal. Civ. Proc. Code § 2025.290(a)
(limiting deposition to seven hours); see also Spears Depo. Tr. 315:13 (acknowledging you have seven
hours to complete Jamie’s deposition). Moreover, you have not identified any unanswered questions
from the August 11 deposition transcript on which you intend to move to compel, and a second
deposition cannot be related to new topics. See Cal. Civ. Proc. Code § 2025.480(a) (“If a deponent
fails to answer any question . . ., the party seeking discovery may move the court for an order
compelling that answer[.]”). Not liking Jamie’s answer to a question is not grounds to move to compel
especially when you had the full seven hours to ask follow-up questions and secure the testimony you
desired. See id. (allowing only motion for failure to answer). The fact that you cannot list the specific
questions that remain unanswered despite sending your meet and confer letter over one month ago
underscores that there is no proper purpose for a second deposition (obviously, harassing Jamie is not a
proper purpose).
Lastly, even if a second deposition was warranted (and it is not), you also acknowledged during
our call that you will not seek answers to your clearly harassing “questions” and topics like:
Harassing “questions” about would

similarly continue to be improper. See, e.g., Spears Depo. Tr. 285:15-285:1, 286:5-14. These
questions are well beyond issues related to the Twelfth Accounting, protected by the financial privacy
privilege, and serve no purpose other than to harass Jamie. See Cal. Civ. Proc. Code § 2017.010
(limiting scope of discovery to matters relevant to pending issues); Cal. Civ. Proc. Code § 2025.420(b)
(allowing Court to award protective order to protect against unwarranted annoyance, oppression, or
undue burden and expense); Oct. 10 Minute Order at 6 (limiting discovery to objections to the Twelfth
Accounting); see also City of Carmel-By-The-Sea v. Young, 2 Cal. 3d 259, 267-68 (1970) (
).
* * *
Simply put, there is no legal basis for a second deposition nor have you identified any legal or
legitimate basis for a second deposition. Any “need” for a second deposition is because of your own
lack of preparation (which of course is not Jamie’s fault), and we will not produce Jamie for a do-over
deposition only for you to harass and bully him again. See, e.g., Spears Depo. Tr. 307:17-20.
Mathew S. Rosengart
November 3, 2022
Page 4
Please identify (with citations to the August 11 deposition transcript) the questions asked and
unanswered on which you intend to move to compel, or please identify what specific topics or
questions form the basis for your request for a second deposition.
Kindest Professional Regards,
Alex M. Weingarten
EXHIBIT 9
1 PROOF OF SERVICE
4 I am employed in the County of Los Angeles, State of California. I am over the age of 18
and not a party to the within action; my business address is Willkie Farr & Gallagher LLP, 2029
5 Century Park East, Suite 3400, Los Angeles, California.
6 On December 28, 2022, I served a copy  / original  of the foregoing document
described as PUBLIC REDACTED VERSION DECLARATION OF ALEX M.
7 WEINGARTEN IN SUPPORT OF JAMES P. SPEARS’S OPPOSITION TO MOTION
TO COMPEL ANSWERS TO DEPOSITION QUESTIONS, REQUEST FOR LEAVE TO
8 TAKE SECOND DEPOSITION, AND REQUEST FOR SANCTIONS on the interested
parties in this action addressed as follows:
9
10 SEE ATTACHED SERVICE LIST
11  BY ELECTRONIC SUBMISSION AND E-SERVICE VIA GREEN FILING:

I caused the above-entitled document(s) to be electronically dated and e-served
12 through Green Filing to those parties on the service list maintained by Green
Filing. Upon completion of transmission of said document(s), a filing receipt is

issued acknowledging receipt, filing, and service by Green Filing’s system. A
13 copy of Green Filing’s receipt will be maintained with the original document(s) in
our office.
310.855.3000
14
above is true and correct.
16
Executed on December 28, 2022, at Los Angeles, California.
17
18 _____
America Garcia
19
20
21
22
23
24
25
26
27
28
1
PROOF OF SERVICE
1 SERVICE LIST
Conservatorship of Britney Jean Spears
2 Case No. BP108870
3 Mathew S. Rosengart Attorney for Conservatee Britney Jean
Lisa McCurdy Spears
4
Kyle Freeny
5 Kelsey Sherman
7 [email protected]
[email protected]
8 [email protected]
[email protected]
9
Britney J. Spears Conservatee
10 c/o Mathew S. Rosengart
12
[email protected]
13 David C. Nelson Associated Litigation Counsel for
Ronald C. Pearson Conservatee

310.855.3000
14 Loeb & Loeb

10100 Santa Monica Blvd., Suite 2200
[email protected]
17 Jodi Montgomery Temporary Conservator of the Person
1443 East Washington Blvd., Suite 644
18 Pasadena, CA 91104
[email protected]
19
20 Lauriann C. Wright Attorney for Jodi Montgomery

Wright Kim Douglas, ALC Request for Special Notice
21 130 S. Jackson Street
23 Yasha Bronshteyn Attorney for Lynne Spears

Ginzburg & Bronshteyn, APC
24 11755 Wilshire Blvd., Suite 1250
26
27
28
2
PROOF OF SERVICE
1 Gladstone N. Jones, III Attorney for Lynne Spears
Lynn E. Swanson
2 Jones Swanson Huddell & Garrison, LLC
Pan-American Life Center
3 601 Pyodras Street, Suite 2655
New Orleans, LA 70130
4 [email protected]
5 Lisa MacCarley, Executive Director Counsel for amici curiae

Betty’s Hope, A 501(c)(3) Charity
6 700 North Brand Boulevard, Suite 240
Glendale, CA 91203
7 [email protected]
8 Justin B. Gold Counsel for Temporary Conservator of

Oldman, Cooley, Sallus, Birnberg, Estate John Zabel
9 Coleman & Gold, LLP
16133 Ventura Boulevard, #PHA
10 Encino, CA 91436
[email protected]
11
Samuel D. Ingham, III Former Court-Appointed Counsel for
12 Law Offices of Samuel D. Ingham III Britney J. Spears

111 West Topa Street, Suite 8

13 Ojai, California 93023
[email protected]
310.855.3000
14
Vivian L. Thoreen Former Counsel for James P. Spears
15 Jonathan Park
Holland & Knight LLP
16 400 South Hope Street, 8th Floor
[email protected]
18
Geraldine A. Wyle Former Counsel for James P. Spears
19 Jeryll S. Cohen Request for Special Notice
Freeman, Freeman & Smiley, LLP
Los Angeles, California 90067
[email protected]
22
Eric Adler Request for Special Notice
23 Magee & Adler, APC
400 Oceangate, Suite 1030
24 Long Beach, CA 90802
[email protected]
25
26
27
28
3
PROOF OF SERVICE

BJS 22.12.28 DECLARATION OF ALEX M. WEINGARTEN IN SUPPORT OF JAMES P. SPEARS’S OPPOSITION TO MOTION TO COMPEL ANSWERS TO DEPOSITION QUESTIONS, REQUEST FOR LEAVE TO TAKE SECOND DEPOSITION, AND REQUEST FOR SANCTIONS

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BJS 22.12.28 DECLARATION OF ALEX M. WEINGARTEN IN SUPPORT OF JAMES P. SPEARS’S OPPOSITION TO MOTION TO COMPEL ANSWERS TO DEPOSITION QUESTIONS, REQUEST FOR LEAVE TO TAKE SECOND DEPOSITION, AND REQUEST FOR SANCTIONS

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1 Alex M.

Weingarten (SBN 204410)

8 SUPERIOR COURT OF CALIFORNIA

10 In re the Conservatorship of the Person and CASE NO.: BP108870

Conservatee. PUBLIC REDACTED VERSION

14 WEINGARTEN IN SUPPORT OF JAMES

2 I, Alex M. Weingarten, declare as follows:

8 as a witness, I could and would testify as set forth below.

10 duties in the Conservatorship proceedings of Britney Spears (“Britney”). Willkie substituted in

11 as counsel for Jamie on October 19, 2021 in the above-captioned case.

12 Jamie Makes An Extensive Record Production

15 4. Willkie received several electronic productions of documents from FFS between

20 5. Willkie received two electronic productions of documents from H&K between

24 productions were provided to Willkie.

25 6. FFS and H&K collectively produced approximately 124,636 electronic

26 documents (totaling approximately 592,614 pages).

5 contained 37 requests for production.

6 8. My understanding is that Jamie’s counsel at H&K negotiated a 21-day extension

9 9. Britney’s counsel never served a motion to compel relating to the August 25

11 responses to the August 25 Discovery.

23 Britney’s Counsel Serves A Revised Deposition Notice

25 Notice Of Deposition Of James P. Spears served on March 2, 2022.

27 Responses To The Second Amended Notice Of Deposition served on April 1, 2022.

2 15. Jamie made a production to Britney’s counsel consisting of 19,471 documents

6 documents produced prior to the deposition.

10 Court on September 14, 2022 (the “Protective Order”).

15 Kyle Freeny dated August 17, 2022.

21 of other documents or further production of additional electronically stored information fields.

22 Jamie Responds To Meet And Confer Letters Regarding Britney’s Counsel’s

8 because it was designated as “Highly Confidential” under the Protective Order.

10 foregoing is true and correct.

11 Executed on December 28, 2022 at Los Angeles, California.

3 COUNTY OF LOS ANGELES

12 Executed on March 2, 2022, at Los Angeles, California.

14 ___/s/ Jane Davidson ______________________

8 Vivian L. Thoreen Former Attorneys for James P. Spears,

19 Yasha Bronshteyn Attorneys for Lynne Spears, Mother of Former

7 Eric Adler Attorneys for Non-Party, Tri-Star Sports &

6 Attorneys for Former Conservator of the Estate

8 SUPERIOR COURT OF CALIFORNIA

In re the Conservatorship of the Person and CASE NO.: BP108870

13 NOTICE OF DEPOSITION OF JAMES P.

SPEARS AND REQUESTS FOR

4 Notice”) and Request for Production Of Documents (“Document Requests”) as follows:

7 and every Document Request therein:

16 2. Jamie’s response to any part of the Deposition Notice, Document Requests, or

20 information is irrelevant, inadmissible, immaterial, or otherwise objectionable.

11 available to attend what is presumably intended to be an all-day deposition on April 6, 2022.

26 cumulative and duplicative.

11 the scope of discovery.

12 7. Jamie objects to the Deposition Notice, Document Requests, and definitions as

2 to her given Jamie’s prior voluminous production of documents and information.

5 lead to the discovery of admissible evidence.

8 information that is not within Jamie’s possession, custody, or control.

16 proceeding in this action or elsewhere.

18 extent it fails to define “YOU” or “YOURS” and is therefore ambiguous.

21 broad, unduly burdensome, and oppressive.

24 facts that are incorrect or unknown to Jamie.

28 in Britney’s instructions, definitions, or requests.

14 _/s/ Jane Davidson ____________________