Hothi v. Musk Document 12

California Court of Appeals
Case No. A162400
Filed June 10, 2021

Appellant's appendix filed.: Appellant's Appendix Volume 2 of 8 Pages 151 - 258

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Page 1 No. AIN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA
FIRST APPELLATE DISTRICT, DIVISION ONE
RANDEEP HOTHI,
Plaintiff-Respondent,
v.
ELON MUSK
On Appeal from the Superior Court for the County of Alameda
Hon. Julia Spain, Judge,
Case No. RGAPPELLANT’S APPENDIX
VOLUME II OF VIII, PAGES AA151 TO AA
ALEX SPIRO
(pro hac vice admission
pending)
QUINN EMANUEL URQUHART
& SULLIVAN, LLP
51 Madison Avenue, 22nd Floor
New York, NY Telephone: (212) 849-Facsimile: (212) 849-alexspiro@quinnemanuel.com
MICHAEL T. LIFRAK
(S.B. No. 210846)
JEANINE ZALDUENDO
(S.B. No. 243374)
QUINN EMANUEL URQUHART
& SULLIVAN, LLP
865 S. Figueroa Street, 10th Fl.
Los Angeles, CA Telephone: (213) 443-Facsimile: (212) 443-michaellifrak@quinnemanuel.com
Counsel for Defendant-Appellant Elon Musk
AA
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Defendant-Appellant.
Page 2 Randeep Hothi v. Elon Musk
First Appellate District Court of Appeal, Case No. A(Alameda County Superior Court Case No. RG20069852)
APPELLANT’S APPENDIX
CHRONOLOGICAL INDEX
Description
Date

Verified Complaint for Damages
and Demand for Jury Trial Filed
by Randeep Hothi
Defendant Elon Musk’s Answer
and Affirmative Defenses to the
Verified Complaint of Plaintiff
Randeep Hothi
Defendant Elon Musk’s Motion
to Strike the Complaint Pursuant
to Cal. Code. Civ. Proc. Section
425.16; Memorandum of Points
and Authorities in Support
Thereof
Declaration of Christine Leslie in
Support of Defendant Elon
Musk’s Motion to Strike the
Complaint Pursuant to Cal. Code.
Civ. Proc. Section 425.Declaration of Elon Musk in
Support of Defendant Elon
Musk’s Motion to Strike the
Complaint Pursuant to Cal. Code.
Civ. Proc. Section 425.Declaration of Tyler James in
Support of Defendant Elon
Musk’s Motion to Strike the



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Complaint Pursuant to Cal. Code.
Civ. Proc. Section 425.Declaration of Jeanine Zalduendo
in Support of Defendant Elon
Musk’s Motion to Strike the
Complaint Pursuant to Cal. Code.
Civ. Proc. Section 425.Defendant Elon Musk’s Request
for Judicial Notice in Support of
His Motion to Strike the
Complaint Pursuant to Cal. Code.
Civ. Proc. Section 425.16, and
Exhibits A-F thereto
Exhibit G (part 1) to Defendant
Elon Musk’s Request for Judicial
Notice in Support of His Motion
to Strike the Complaint Pursuant
to Cal. Code. Civ. Proc. Section
425.Exhibit G (part 2) to Defendant
Elon Musk’s Request for Judicial
Notice in Support of His Motion
to Strike the Complaint Pursuant
to Cal. Code. Civ. Proc. Section
425.Exhibits H-I to Defendant Elon
Musk’s Request for Judicial
Notice in Support of His Motion
to Strike the Complaint Pursuant
to Cal. Code. Civ. Proc. Section
425.Exhibits J-L to Defendant Elon
Musk’s Request for Judicial
Notice in Support of His Motion
to Strike the Complaint Pursuant
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to Cal. Code. Civ. Proc. Section
425.[Proposed] Order Granting
Defendant Elon Musk’s Motion
to Strike the Complaint Pursuant
to Cal. Code Civ. Proc. Section
425.Notice of Errata Regarding the
Signature Page to the Declaration
of Elon Musk’s Motion to Strike
the Complaint Pursuant to Cal.
Code Civ. Proc. Section 425.Plaintiff Randeep Hothi’s
Memorandum in Opposition to
Plaintiff Elon Musk’s Special
Motion to Strike
Declaration of Randeep Hothi in
Support of His Opposition to
Defendant’s Special Motion to
Strike
Plaintiff Randeep Hothi’s
Objections to Defendant’s
Evidence Submitted in Support of
Defendant’s Special Motion to
Strike
Reply in Support of Defendant
Elon Musk’s Motion to Strike the
Complaint Pursuant to Cal. Code
Civ. Proc. Section 425.Elon Musk’s Evidentiary
Objections to the Declaration of
Randeep Hothi
Defendant Elon Musk’s
Responses to Plaintiff Randeep
Hothi’s Evidentiary Objections
Page 5
Plaintiff Randeep Hothi’s
Response to Elon Musk’s
Evidentiary Objections to the
Declaration of Randeep Hothi
Order - Motion to Strike
Complaint Denied
Notice of Appeal
Appellant’s Notice Designating
Record on Appeal
Register of Actions and
Certificate
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Page 6 Randeep Hothi v. Elon Musk
First Appellate District Court of Appeal, Case No. A(Alameda County Superior Court Case No. RG20069852)
APPELLANT’S APPENDIX
ALPHABETICAL INDEX
Description
Date

Appellant’s Notice Designating
Record on Appeal
Declaration of Christine Leslie in
Support of Defendant Elon
Musk’s Motion to Strike the
Complaint Pursuant to Cal. Code.
Civ. Proc. Section 425.Declaration of Elon Musk in
Support of Defendant Elon
Musk’s Motion to Strike the
Complaint Pursuant to Cal. Code.
Civ. Proc. Section 425.Declaration of Jeanine Zalduendo
in Support of Defendant Elon
Musk’s Motion to Strike the
Complaint Pursuant to Cal. Code.
Civ. Proc. Section 425.Declaration of Randeep Hothi in
Support of His Opposition to
Defendant’s Special Motion to
Strike
Declaration of Tyler James in
Support of Defendant Elon
Musk’s Motion to Strike the
Complaint Pursuant to Cal. Code.
Civ. Proc. Section 425.


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Defendant Elon Musk’s Answer
and Affirmative Defenses to the
Verified Complaint of Plaintiff
Randeep Hothi
Defendant Elon Musk’s Motion
to Strike the Complaint Pursuant
to Cal. Code. Civ. Proc. Section
425.16; Memorandum of Points
and Authorities in Support
Thereof
Defendant Elon Musk’s Request
for Judicial Notice in Support of
His Motion to Strike the
Complaint Pursuant to Cal. Code.
Civ. Proc. Section 425.16, and
Exhibits A-F thereto
Defendant Elon Musk’s
Responses to Plaintiff Randeep
Hothi’s Evidentiary Objections
Elon Musk’s Evidentiary
Objections to the Declaration of
Randeep Hothi
Exhibit G (part 1) to Defendant
Elon Musk’s Request for Judicial
Notice in Support of His Motion
to Strike the Complaint Pursuant
to Cal. Code. Civ. Proc. Section
425.Exhibit G (part 2) to Defendant
Elon Musk’s Request for Judicial
Notice in Support of His Motion
to Strike the Complaint Pursuant
to Cal. Code. Civ. Proc. Section
425.Exhibits H-I to Defendant Elon
Musk’s Request for Judicial
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Notice in Support of His Motion
to Strike the Complaint Pursuant
to Cal. Code. Civ. Proc. Section
425.Exhibits J-L to Defendant Elon
Musk’s Request for Judicial
Notice in Support of His Motion
to Strike the Complaint Pursuant
to Cal. Code. Civ. Proc. Section
425.Notice of Appeal
Notice of Errata Regarding the
Signature Page to the Declaration
of Elon Musk’s Motion to Strike
the Complaint Pursuant to Cal.
Code Civ. Proc. Section 425.Order - Motion to Strike
Complaint Denied
Plaintiff Randeep Hothi’s
Memorandum in Opposition to
Plaintiff Elon Musk’s Special
Motion to Strike
Plaintiff Randeep Hothi’s
Objections to Defendant’s
Evidence Submitted in Support of
Defendant’s Special Motion to
Strike
Plaintiff Randeep Hothi’s
Response to Elon Musk’s
Evidentiary Objections to the
Declaration of Randeep Hothi
[Proposed] Order Granting
Defendant Elon Musk’s Motion
to Strike the Complaint Pursuant
to Cal. Code Civ. Proc. Section
425.16
Page 9
Register of Actions and
Certificate
Reply in Support of Defendant
Elon Musk’s Motion to Strike the
Complaint Pursuant to Cal. Code
Civ. Proc. Section 425.Verified Complaint for Damages
and Demand for Jury Trial Filed
by Randeep Hothi
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Page 10 Exhibit Number
ENDO'RSED
QUINN EMANUEL URQUHART & SULLIVAN, LLP
Alex Spiro (pro hac vice pending)
alexspiro@quinnemanuel.com
51 Madison Avenue, 22nd Floor
3 New York, New York Telephone: (212) 849-QUINN EMANUEL URQUHART & SULLNAN, LLP
5 Michael T. Lifrak (Bar No. 210846)
michaellifrak@quinnemanuel.com
6 Jeanine M. Zalduendo (Bar No. 243374)
jeaninezalduendo@quinnemanuel.com
7 Aubrey Jones (Bar No. 326793)
au breyjones@quinnemanuel.com
8 865 South Figueroa Street, 10th Floor
Los Angeles, California 90017-9 Telephone: (213) 443-
FILED
ALAMEDA COUN'J"Y
OCT 3 0
IO Attorneys for Defendant Elon Musk

SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF ALAMEDA
CASE NO. RG
RANDEEP HOTHI,

DEFENDANT ELON MUSK'S REQUEST
FOR JUDICIAL NOTICE IN SUPPORT
OF ms MOTION TO STRIKE THE
COMPLAINT PURSUANT TO CAL.
CODE CIV. PROC. SECTION 425.
Plaintiff,
VS.
17 ELON MUSK,
Assigned for all purposes to:
Judge Julia Spain
Department
Defendants.

Hearing Date: January 7,
Complaint Filed: August 4, Trial Date:
None Set

AA
Case No. RGREOUEST FOR JUDICIAL NOTICE
Page 11 1 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
Defendant Elon Musk, through his attorneys of record, requests that the Court take judicial
3 notice pursuant to Evidence Code sections 452 and 453 of the following in support of his Motion
4 to Strike the Complaint Pursuant to Cal. Code Civ. Proc. Section 425.16:
Exhibit A:
Declaration of Randeep Hothi in Support of Respondent’s Motion for
6 Reasonable Expenses Including Attorney’s Fees Pursuant to Code of Civil Procedure 128.5, dated
7 August 12, 2019, in case Tesla, Inc. v. Hothi (Case No. RG 19015770, Superior Court of the State
8 of California, County of Alameda).
Exhibit B:
Petition for Workplace Violence Restraining Order, including declarations,
10 dated April 19, 2019, in case Tesla, Inc. v. Hothi (Case No. RG 19015770, Superior Court of the
11 State of California, County of Alameda).
Exhibit C:
Temporary Restraining Order, dated April 19, 2019, in case Tesla, Inc. v.
13 Hothi (Case No. RG 19015770, Superior Court of the State of California, County of Alameda).
Exhibit D:
Order on Requests for Discovery, dated July 1, 2019, in case Tesla, Inc. v.
15 Hothi (Case No. RG 19015770, Superior Court of the State of California, County of Alameda).
Exhibit E:
Filed letter from Martha Boersch, counsel for Tesla, dated July 19, 2019, in
17 case Tesla, Inc. v. Hothi (Case No. RG 19015770, Superior Court of the State of California,
18 County of Alameda).
Exhibit F:
Order: Motion Dropped, dated August 1, 2019, in case Tesla, Inc. v. Hothi
20 (Case No. RG 19015770, Superior Court of the State of California, County of Alameda).
Exhibit G:
Document received by the CA 1st District Court of Appeal.

Respondent Randeep Hothi’s Notice of Motion and Motion for Reasonable
22 Expenses Including Attorney’s Fees Pursuant to Code of Civil Procedure 128.5, dated August 13,
23 2019 (excluding exhibits), in case Tesla, Inc. v. Hothi (Case No. RG 19015770, Superior Court of
24 the State of California, County of Alameda).
Exhibit H: Order on Motion for Attorney Fees, dated October 28, 2019, in case Tesla, Inc.
26 v. Hothi (Case No. RG 19015770, Superior Court of the State of California, County of Alameda).
AA
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Case No. RGREQUEST FOR JUDICIAL NOTICE
Page 12
Exhibit I: Request to Continue Hearing filed by Defendant Randeep Hothi, dated May 1,
2 2019, in case Tesla, Inc. v. Hothi (Case No. RG 19015770, Superior Court of the State of
3 California, County of Alameda).
Exhibit J: Definition of “Harass” from Merriam-Webster Online Dictionary (2020).

Exhibit K: Declaration of Randeep Hothi in Support of Response to Petition for
6 Workplace Violence Restraining Orders, dated May 17, 2019, in case Tesla, Inc. v. Hothi (Case
7 No. RG 19015770, Superior Court of the State of California, County of Alameda).
Exhibit L: Response to Petition for Workplace Violence Restraining Orders, including
9 declarations, dated May 17, 2019, in case Tesla, Inc. v. Hothi (Case No. RG 19015770, Superior

True and correct copies of the referenced documents are attached to this request.

The Court may take judicial notice of Exhibits A-I, as they are records of this Court.
13 Evid. Code. § 452(e). The Court may also take judicial notice of Exhibit J, the definition of
14 “harass,” per Evidence Code. § 451(e), allowing judicial notice of “[t]he true signification of all
Document received by the CA 1st District Court of Appeal.
10 Court of the State of California, County of Alameda).
15 English words and phrases.” The relevance of the documents requested to be noticed are set forth
16 in the memorandum accompanying the Motion.
18 DATED: October 30,
Respectfully submitted,

QUINN EMANUEL URQUHART & SULLIVAN, LLP
By:
Michael T. Lifrak
Attorneys for Elon Musk

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Case No. RGREQUEST FOR JUDICIAL NOTICE
Page 13 PROOF OF SERVICE

2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
At the time of service, I was over 18 years of age and not a party to this action. I am
employed in the County of Los Angeles, State of California. My business address is 865 South
4 Figueroa Street, 10th Floor, Los Angeles, CA 90017-2543.

On October 30, 2020, I served true copies of the following document(s) described as
DEFENDANT ELON MUSK’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT
OF HIS MOTION TO STRIKE THE COMPLAINT PURSUANT TO CAL. CODE
CIV. PROC. SECTION 425.on the interested parties in this action as follows:
10 Lawrence J. Fossi
25 Hawthorn Lane
11 Bozeman, MT Lawrence.fossi@outlook.com
Law Office of D. Gill Sperlein
345 Grove Street
San Franciso, CA gill@sperleinlaw.com

Document received by the CA 1st District Court of Appeal.

BY ELECTRONIC MAIL TRANSMISSION: By electronic mail transmission from
jeaninezalduendo@quinnemanuel.com
on October 30, 2020, by transmitting a PDF format copy of
such documents to each such person at the e-mail address listed above, per agreement between the
15 parties regarding electronic mail service. The documents were transmitted by electronic
transmission and such transmission was reported as complete and without error.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Executed on October 30, 2020, at Los Angeles, California
Jeanine Zalduendo

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Case No. RGPROOF OF SERVICE
Page 14 Document received by the CA 1st District Court of Appeal.
EXHIBIT A
AA164
Page 15
D. GILL SPERLEIN, SBN THE LAW OFFICE OF D. GILL SPERLEIN
345 Grove Street
San Francisco, CA Telephone: ( 415) 404-Facsimile: (415) 404-gill@sperleinlaw.com
Attorneys for Respondent

SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF ALAMEDA

Tesla, Inc. ,

c

Petitioner,
V.
Randeep Hothi,
Respondent.

)
)
)
)
)
)
)
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Case No. RGDECLARATION OF RANDEEP HOTHI
IN SUPPORT OF RESPONDENT'S
MOTION FOR REASONABLE
EXPENSES INCLUDING ATTORNEY'S
FEES PURSUANT TO CODE OF CIVIL
PROCEDURE 128.5;


I, Randeep Hothi, Declare:
1.
I am over eighteen years of age and have personal knowledge of the facts below. If
called upon, I could and would testify to the following.
2.
I am a member of the so-called $TSLAQ, a wide-ranging group of people who are
skeptical about the Tesla business enterprise and who regularly share infonnation on the social media
platform, Twitter.
3.
The $TSLAQ phenomenon has been featured in a documentary by Grant Williams (The

Electric Noise, at www.realvision.com) and described in various newspaper articles, including the Los

Angeles Times.

- 1DECL/\R/\TION OF R ANDEEP HOTHI IN SUPPORT OF RESPONDENT'S MOTION FOR FEES
AA
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9
Page 16
4.
I posted my findings under a pseudonym; my Twitter " handle" was @skabooshka.

Because Tesla, and specifically Elon Musk, has a history of trying to silence critics, I was

uncomfortable using my real name.

5.
I came to prominence during 2018 for my accurate observations about Tes la Model
production rates. I regularly reported those observations on Twitter, and my observations contradicted
Elon Musk's claim during a quarterly conference call in August of 2017 when he said:
What people should absolutely have zero concern about, and I mean 0, is that
Tesla will achieve a 10,000 unit production week by the end of next year .... I
think people should really not have any concerns that we won ' t reach that
outcome from a production rate.
6.
I consider that my research was vindicated. Tesla's actual production rate was much

D-
closer to my data-driven estimates than the "zero concern" Musk rate. My production insights earned
me more than l 0,000 followers on Twitter and became part of the media discussion about Tesla's

production problems. I have attached two June 22, 2018 articles which mention me and my research;

one article from the Verge titled "Tesla built a giant tent to expand production of the Model 3" attached

as Exhibit

; and one from Engadget titled "Tesla built Model 3 assembly 'tents' meet production
goals" attached as Exhibit B.
7.
The value of my data on Tesla production was recognized even by the Tesla owners and

fans who post regularly at the Tesla Motors Club site, as evidenced by this thread:

https ://teslamotorsclub.com/tmc/threads/skabooshkas-model-3-production-numbers. l 23 565/ I have

attached a printout of the first twenty entries as an example and attached those pages hereto as

Exhibit C.

8.
On April 16, 2019, I was driving on Interstate 880 near Fremont, when I noticed a Tesla
Model 3 with manufacturer plates enter the highway. The Model 3 had two roof-mounted cameras and
another camera mounted inside. Aware Tesla had announced an "Investor Autonomy Event" for April
-2DECLARATION OF RANDEEP H OTHI IN SUPPORT OF RESPONDENT'S MOTION FOR FEES
AA
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Page 17 22, at which it would tout its "autonomous driving" capabilities, I surmised the Model 3 was engaged

in public testing or videotaping for that event. I was headed to San Francisco for a meeting. The Model

3 test vehicle was also headed in the direction of San Francisco. I tracked the car's route for a half

hour or so, recording video and taking photos.

9.
To the best of my recollection, I did not swerve towards the Model 3. If l did so (and I

place a reasonable person in fear for his or her safety. I did not gesture toward or otherwise attempt to
engage with the Model 3's occupants in any way. I simply recorded what I observed.
10.

Shortly after making the recordings, and using the @skabooshka handle, l posted what

I observed on Twitter . One of the most historically pro-Tesla on-line publications, electrek.co,

evidently regarded my postings as important Tesla news. Within hours of my postings, electrek.co

published an article acknowledging that my Twitter posts appeared related to testing being conducted
in preparation for the Investor Autonomy Event. I have attached a true and correct copy of the article

u

as Exhibit D. The article included a photograph I had taken of the test car to which I added red arrows

pointing to the cameras. (I also redacted the faces of the car's occupants before posting the photo on

Twitter.) The lede in the electrek.co article read as follows:

Tesla has been spotted evidently filming a self-driving demo in a Model 3 ahead of its
planned ' Investor Autonomy Event' next week during which the automaker is expected
to release more details about 'Tesla Network', its autonomous ride-hailing network.

11.
The electrek.co a11icle reminded readers of past Tesla promises about autonomous
driving that had come to naught, and stated that readers should take Tesla's claims with a "grain of

salt":
Very little of all the capabilities Tesla demonstrated back in 2016 made it to customer vehicles
yet. Tesla did the demo route several times before it got it right for the video and while it was
an interesting look at future potential capabilities of Tesla's Autopilot, it wasn't really
representative of any type of feature making it to consumers any time soon.
-3DECLARATION OF RANDEEP HOTHI IN SUPPORT OF RESPONDENT' S MOTION !'OR FEES
AA
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8
Page 18 12.
I was not provided any notice of the April 19, 2019 hearing on the temporary restraining

order. I was never served with a copy of the Petition or the Court's Temporary Restraining Order, and

I am not aware of any attempts to serve me. I learned about the TRO online and I voluntarily appeared

in this Court to defend myself and my reputation.

13.
Tesla's TRO was widely reported in the media. On-line publications closely aligned
with Tesla published atticles that assumed the truth of Tesla's allegations of actual and threatened
violence, or assumed a judge had weighed the evidence, or both.

Electrek wrote,
"[I]t is not reasonable to attempt to cause car collisions because you have an apocalyptic vison
ofyourself winning a crusade against a businessman you don't like. " Attached as Exhibit E.



Clean Technica wrote,
"Hothi ... has been issued a temporary restra;ning order after allegedly trying to cause an
accident dur;ng a Model 3 test drive that demonstrated the Navigate on Autopilot feature. "
Attached as Exhibit F.
Engadget wrote,
"[Hoth;J reportedly injured a security guard at Tesla's Fremont factory with his car in
February after he was asked to leave the parking lot, and on April 16th stalked a Tesla-owned
Model 3 for 35 minutes on the freeway to the point where he forced the car into a automatic
emergency maneuver to avo;d a collision. " Attached as Exhibit G.
And Teslarati wrote,

"The noted TSLAQ member reportedly drove so recklessly that his vehicle ended up triggering
the Model 3 's crash emergency avoidance maneuver." Attached as Exhibit H.

14.

The mainstream media, including Bloomberg and the Los Angeles Times, also
published news stories about the TRO, repeating Tesla's allegations.
15.
I received a torrent of abuse on Twitter and other social media, accusing me of being a
terrorist, a criminal, and a homicidal maniac. I attached a compilation of examples at Exhibit I. While
I would have liked to defend myself on social media, I elected not to make any further posts on my

-4l)ECLARATION OF RANDEEP Honu IN SUPPORT OF RESPONDENT'S MOTION FOR FEES
AA
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Page 19 'l'wiacr feed,, l·ik 1·1~ liwsu:1 wns pending. ·1 he h~:,;t p.,s: 1 mad~\\ a:. un .\pril 22. 20 I9, h read: '"T:1~

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Document received by the CA 1st District Court of Appeal.
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Page 20 RESPONDENT RANDC:EiP HOTH! ' S MOTION FOR FEES
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Document received by the CA 1st District Court of Appeal.
Exhibit A
Page 21
Tesla built a giant tent to expand production of the
Model t

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https://www.theverge.com/2018/6/22/17488372/tesla-model-3-production-tent-expand
AA
Document received by the CA 1st District Court of Appeal.
r-::u,
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a, 1s.c M:,..f,1,.1-I 3 dual motor porlt;1rmanc-~ CC!ffl nr; 1:!h :r-:.o lino .
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https://www.theverge.com/2018/6/22/17 488372/tesla-model-3-prod uction-tent-expand
AA
Document received by the CA 1st District Court of Appeal.
Command lane
Page 23 lHEVERGE
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https://www.theverge.com/2018/6/22/17 488372/tesla-model-3-prod uction-tent-expa nd
AA
Document received by the CA 1st District Court of Appeal.
hru.t 1.. ,om lhe
Page 24 O'
v .. ,.
enl
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cc :(r)H;J:;J c,w,,c.r·,1:n!Y '<',-·~ ~-,;h)r.t n,A',.n ly ar:o '.<-:-r-pc:1.m:cr•> TJv;; ,-:, ,,.~,..~~:..\':;- :r-;r ~i}~
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IWC PILOT'S,
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NEW HORIZONS,
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t.rvl wa;h f'ltl(,1 ttle Ct-,:tng t;l'Cvt'litJ 1tntu!Tc1:""! asp~ts
i" tO-J1rn~ 1; c ti:,i~e P.Joos, ,'.::.cl~·~d~
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cwal-iY cr,r:;re;1 Yc.1u i https ://www, theve rge .com/2018/6/22/17488372/tes la-model-3-prod uction-tent-expa nd
AA
Document received by the CA 1st District Court of Appeal.
~'3C:/\fJ ~ ho noc.:Mi
Page 25 RESPONDENT RANDEF.P HOTT [I'S MOTTON l"OR Ferns
AA
Document received by the CA 1st District Court of Appeal.
Exhibit B
Page 26 -
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lnlotl0"'1td~
L.1Coll In Goa,
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Tesla built Model 3 assembly 'tents' to
meet production goals
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BUSINESS
nr~o,..-, 1 /1.'!>r
Document received by the CA 1st District Court of Appeal.
Sponsored Links
AA176
Page 27 r(1m1~.i, h~r h l)W Elon Mu~~k casu:tll y n1N 1tl• n C'd th :1 t l'c~la h~d !mill ..1 'ii..,·.
:1~•;f•:1;l 11y b:,· in jus rh ,ee w~eks to hitl p il meet its iony \-?~d !
prt:Lluction g,1tt\s? ii w~1.-; inor\! a l1d~c~l:us lh.1 11you
m;.tc-r$Z(l
rhr f1(•mvnt approval ~J. .-e Te-s!J )i.'< rmrnth..4; ,tlthu1.11.:;l11t could cxtt'nd th..;it
•k•• mil tu,ther if it w.:mu~u. ,\nJ lhl!-,c·s J rt•Jl (hante it imght beconu:
fi-t\fJJlil:'l~!U . MH~k
id.I; ·."•·!

chat [~H.\ rww lim• is ''way br:tf,:-r .. rhan another
il~~~mb:y linP th;H "cost hundrt•ds 0rm1lhons,· Jnd ·.
ure 1f his

cornp;-my "','.u·lu~lly nt.•t.•d(cJ ;1 hmldini;, Sprun5·s stTt!C tU!t:'.S ilffl
c:on'>iderab!y slurdwr than a.ctual L,mb, and the r:1.:in cha11cn~e ls c·nsunn~
th:n th,'. outdoors do~~n·t atfrct prodn(tion.
Wht")thNor n(lt thL~ aoually helps Tt'Sla .1,l•~t lB 5,000 pN WL'~l.: Modd rrodunum targ(•t Lsn·t renain. Mm,kwa!-to111,n~ [h~ tL'ntu1 mic.l •Junc, or
juM .1 couple of WN~k~ hefore the c-ml-of-)un(' tt1rg('t. At the tlmf•. Tr"iila 'Nil:-i
up to J.,5fJ0 (J1"S per w~~k ·- much t.Jettl!r lh•m tnd01~, bul thJl !efl .J 1nt of
·--· ..·····.... -· .......... .......-. -...... ·-·- ···rQQm
ro, impu>vement. It d~p1mJs 011 whlrn th~ rmtJ,,;i,or m.&nuf.:.c[UfHIS

---- ·-·--
-·••.-.
be-gan :md how rnui..:h lt''j conrnbutir.i to the~ ~rid re~11lt. If Jlmh1ng ~lsc-, H
~h1)ws Mu:;k's dt:ten:un:1tion Ill nw,J~ t;1r;;ers and gcr r~sf;\ ha< k j,1h'l
profuab,Jity.
aklJboa::tli k.a
h1qh tes ph¢los 01 lhe ll?n~l h c l !tla '.'lS1 A :ont asser.-bty
111;0 f;crn lne 1as1 24 hot,ts.
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~'lll--t Document received by the CA 1st District Court of Appeal.
JJ >'h![c.1 \:i.'\.~J ~?.dt•w: Ttw
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l:'remon~·s.ov.-n ;'ll)proval :H: ::<-;, h~1s in:1 J1~ d 1.• J1 that T,:-s1::r b111? t n~w
u1a11ur:h·ttning insidQ ,1 gro up or .Sl!H~rj l g!3n l ll!lll~ (ur rathl::'r, c~n\·11kt.•
..:,w1rn'.?-.. trm1u.h.s) to bnost ou lput uf ir~ hig.h·volurne EV. lfyc,.1u think t har
w 11nds ;;i.udacious. you\l b~ rjglll . r\ r~ ·n.,fh:riro ! '.HiiL'd lllat (!al·h ·1~11t' is
15(.) feet loug.i.nd 53 rr!et hit;h, an d thc1c·•, no knO\·.:n in~t~ncc o f vth.:-r CM
manufacturers doing t h.is bt?fore.
Page 28 -,.lt"-,, .,r• •••
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AA178
Page 29 RESPONDENT R,\NDEEP HOTHl 'S MOTION FOR FEES
AA
Document received by the CA 1st District Court of Appeal.
Exhibit C
Page 30 C!eanMyMac X is 50% Off
Skabooshka's Model 3 Production Numbers
Page1of14
l
As far as I can tell, this guy on Twitter has a Tesla employee source providing daily producllon numbers. He provides lhese dally
numbers for the rsLA shons Given the 1n1ense focus on the producllon ramp. I thought a would be helpful to have a thread fur
!racking these numbers If you believe he is a poor source for these numbers, I can understand tha l, and you can 19nore this lhreod.
bdvor.
M®el 3 Produc:tton
l::.O
11,
- - ~ Mr, 1-9 iil l $

q
······,
l ' I ll AOFtel,1n. 'i1t
6/2,1 Sd'I
6/25
6/27 6/28 6/29 6/7/1 7/7/3 7/4 7/S 7/ 6 7/7 7/H :l6U
7/9 7/7/7/13 7/14 7/15 7/ 7/17 ~7/19
7/20 7/21
https ://tes Ia motorsclub. com/tm c/th reads/ska boos h kas-mode 1-3-p rod uctio n-n um bers.12 3565/
AA
Document received by the CA 1st District Court of Appeal.
·'
Page 31 July Model 3 Daily Avetage.
bdyA:;(1'-V •~Cffit:1.tl
J M,t 19,201$
M.-"s~s
U
o
l.bl' ,l!lcn. Apf,lttOf\ WI
Da,ly Average Starting from JULY 5: 550 (lo eliminate the July 4th holiday period)
Jolne Mry 19, 2U1S
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ApplttOl'I, WI
Mu.1ag.e,,i
l,
Lor.ation:.~.WI
Today he posted numbers for July 22nd as being 3-40/S0/100 (3/S/X). Also repofling a serious Incident In the faciory that shut
down production today, possibly r11e. However, I can, r,nd any lndependel\1 conformation I really don1 know what to think about
their information On the one hand, lfd be great to have an accurate Inside source, on the other hand the.re is no way to know Ir that
sourc. is actually real at all, no, Is there is much reason to trust skabooshka themselvo beyond the trust youd place In any 01her
anonymDlls Twilter user (read: not much).
schonetooht
Joined:
MM 10. 201'
M~ssag~
4,
looalion:
Nodw'ld
Well, I've been expee1ing sabotage, and ·incidents which shut down production' are a pretty normal thing.
https ://teslamoto rsclub.com/tm cft hreads/ ska boos h kas-mode 1-3-prod uction-n um bers.1235 65/
AA
Document received by the CA 1st District Court of Appeal.
Dally Average Starting lrom JULY 1S (lael 7 days); 566
Page 32 .!,1111-t"J
Ap;' 2$. 201 I
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OK: 18. :Wt
The one good 1h111g lhese numbers show m• Is thal 5000/week was sustainable From July 11·15. they averaged over 5100/Week.
The problem. Of course, is that It hasnl been sustained. I don't know what happened on the 15th- I assume l~at wa$ the
switchover 10 dual motor ptoduction- but the daily overage droppe appeors 10 have dropped shorply again on the 22nd & 23rd.
All the FUO about demand & togist1cs & supply chain is nonsense P1od~c11on Is what mailers. So far. in July, it's a mixed bag.
.;
~ ~ 900d thir'K) \flf-Se nomb"5 d'lowi
bdy
rn, ts that 5000/WH:k w1, l'IUS1einlbll!'. nom Jc.At 1 1-15, · ~ .l!IYe'r.l!jli!'d CYf-r
5100/W..k
~ ~obt#m, of e:1;,urHj It 1h.:11t il ~:mi.'
°"'"" W!l1~1nP.d I dqrl, I knew ..t\.,t h~"'f'd on 1.-0 1.'lth~ 1 u.,..urnP ~:it wa•
lht KW1td1ffllU ID d\W,I ITI010( r,,OGUc::ictr- but lh• daily ti,Vf>(.,ot dropped by ~bout ioo1diy
n,p '1st kJoked pn;,mi-Sing.
https://teslamotorsclub.com/tmc/threads/skabooshkas-model-3-production-numbers.123565/
AA
Document received by the CA 1st District Court of Appeal.
to nir,t o U'ltNtl lot Uar:klng men numous. It ,ou L1tl11'\'¥' hit •s, poo, sourct IOr lnt-n nLJrntMHs, 1un ur:iue,a:101Kf
lhat, Jl'ld )'OU CM 1g~ lhlt thrHd
Page 33 Yeah, its been up and down. nearing the target or 700/day on 6 days on July w,th that noce 5 day s1retch on the moddie Maybe some
slo'!"downs for ttuo n•w c,on<,guraOnl\-s • p~forfll~nc~ ono AWP, ~ut not siire Mcnrdin9 to $k1Jbno•~•Q, th~re was rumor of tae1ory
shutdown due to a senous problem on 7/22 when p,oductlOn dropped dramaltcally Clad to see il Iumped up significantly
yesterday
I would think ch Z.. chSl>ahan
OK l. 201d
J..iir,td
M'-'S.sa9cs
1.lllB
Y•llh.,r~ bt-Mup and rlo---n,r\et•rtl',(J the tar~ of 700/day 006 da,a\nJllyW1U, lhlt n,r.,e Sday !.lf,tr.h lntrutm1ddl•
M31bt some slowdowns fM mt new oonfigurnuons- ~~rfo«nanco and AWD. but Ml !It.rt'. ACcordf\g 'lO Sboooshita,
theff' was rumor oJ fecto,y 1hutdorNndu! to a senou6 probltm on 7/22 when orodU<:ljon dtopt,Nt drwnaOc;,ly. OIJd to
SH 1t )limped up s1gn10c3nt"1 ye11.terda)'
l.ot:.011Qff
SMa1013. fl. / w,e>cta,ow,
flof.and
Seems ic wasn't a rumor He was Just guessing about the reason Apparently, ' fire· 1s one of che ~rst ,xplanaclons lhal came to h1S
mind.
ZachSh.:ahan
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~
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Yuh, rt'~ been \IP •nd dOwn, J'tt&{lnq 1h~ targ•t o1 'J00/day o,i G d,ays in Juty w1lh lhal nke S day suelcl\ In the mtddJe
Mo~bt t omt ~ow 1hefe wn rumor of 1M:IOl'f shutdown due to a .se,iou.s p,oblem on 7rn wtiein p,oduchon dfopP-td dramo11ealty. Glad to
SH it Jum,Pf'd "P ~rwfltantty ~"tSCffday
I ~Id 1h1nk 1hat Elon wo,nts som• good numbu11 going tmo 01 EA.
l' ·b t
Seems It wasn~ a tumor. He was just guessing about the reason Apparently, ·r,re· 1s one ol the first explanallons that came to hlS
mfnd.
t
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0,,
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Papafox
.ac·t ,,~V~;r,b•
.-11hXJt
MOdol 3:
1.1o0.. $ 1.10dotX
https ://tesl am otorscl ub.com/tm c/th reads/ska booshkas-mod el-3-p rod uctio n-n umbers.12 3565/
AA
Document received by the CA 1st District Court of Appeal.
skabooshk~ on rwitter
Page 34 J1,h~i:-d
J.in l:J,
Mc-"''ntjE"<;
,·un
4, IJ
Daily producrion upda1e
On July 24, 201 B TO$IQ produced appro>1marely
Model3· ModelS: ModelX.
G~rlands
Ut·~•••
Jointd;
A.pt 4.2CJ
Mi.:Sj;.t,;~s
l.~:1!16:l

M:u•;Urtd
G,H .ind:, S.l rj :
Dady produC't,on 1.1pd"a\c
On July "24.2018 roa.:i orocuced approJ.1matcly.
bdy
Mod~l3•64Q
M~ 19, 2G
Me,$:t.t;~
ModtlS 1"MOdOIX
J,4n
toc:i.uon A&Jplirton. 'NI
These are good numbers again. Nice lo see. and espec,ally Nee to see 901119 inlo the 02 ER. Elon n..ds the firepower 11gh1 now
r'' C
bd)'1)~~!_.,,-. ~.r'tl'f'lt!•r
J;J\n.! ,•.
.._z
Tesla has averaged 540 model 3 per day since July Slh, y1eldmg a weekly rate of 3,782 I'd 11kt: to see lhem be able 10 bring that
average up above 580 over the next week, so 1hat 1he weekly average 1s over 4.000 per week since the July 4th Holiday If Elon
could state that and that the average over the last 7 days is over 5,000 per week would be great news. A statement that they are on
1raek 10 be at 6,000iWeek by the end of August would be nice too
May19,2n1!i
Okay. so throuQh the flrsl 24 days of July'
11,203 M3 produced,• rate IMt works out lo 42.Sk produC factoring oU1 the (1rs1 5 days (548 total In that lime), we get·
10,655 produC Esme Es Mejor
I think these numbers are rule so far. but we need them to
cont1nut ,1sing.
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ht tps ://tes la motorsclub. com/tm c/th reads/ ska booshkas-mod el-3" prod uction-n umbe r s.123565/
AA
Document received by the CA 1st District Court of Appeal.
Johitd
Page 35 Mrs,\•~t•<,:

l%," QayMea
ZachShahan
~tll-,t! Ytmt~
fhet-41 .are good n1,,1mbt-u :,,g.1&n Ntet to ,ec. aod l!Qp«:1alty nice to ~tt gQ,AQ Into tht-Q2 CR Elon nttds the firepow«
lqlf flOW
0t,c J, ;n\-
Jolnt!d
MP.stlc;es
1,
LO<:Ahon
SMH~U. Fl. I Wroctl'tollt,
PerhapS a result or whateve1 the slowdown a few days earlier was related to. You can see output dropped slowly and then rose
slowly
Pro!J1'(t
I lhlnk they slowed down or stopped the line lo:
Todd Burch
V.,."1.1'i,ttY'".l>CU11k"
1,:,tP.
J:)ir.~d·
New J. 200-;
M"!.Ui!).,..G
1 Make tweaks for AWD/P p,oducuon.
2. Adjust for white Interior (possibly)
3 Clear some bottlenecks so !hey can work loward 61 If they push herd J lhonk they may be ~hie to hold S,SOO/wk till• for th• rosl or \he n,onth, which would lpok r~;il good going into lhe
ER (especially rl hogh AWO/P mrx)
6,l(i
ZachShahan
°' u~
.....
'r,..,,11ct,t~fl 1W·,111h"
.,,.
1 M,eke lwok.1 lor A'liO/P ptoduc:::tion.
2 AdJUII fot wh•I• ,ntNiDt fpo.s,1bty).
3 Cte.,r some bonlcoo<:11.G GO they c.>n ,,..iork towa,d bkiwetll.
1r lhey push he,d I lhlnlt lhlll')' may be abtt to hold S,500/writ 1.&te fat \he rut of lhf: mond,. which 'NOutd look tnl good
going ln10 1ho liR (espodolly ,I h,gh AWO/P ,n;,J
Agreed .
... o, it could have been a fire "."'-1;
Given \hat they have opened up lot U.S orders, Tesla should have good 1ransparency ,nlo the expected performance and AWO
•ales mix for 03 and even Q4. That wrll be helpful for the 02 ER. I'm hopelul \hey actually n,iso !heir profit guidance for 03 and Q4,
11 even shghlly.
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(You mutt tog In or sign up lo pos1 htro.)
https ://tesla motorscl ub. co m/tm cfthreads/ska boosh kas-model-3-prod uctio n-nu mbers.12 3565/
AA
Document received by the CA 1st District Court of Appeal.
Loe:,1110;1
Page 36 RESPONDENT RANDEEP HOT!-ll'S M OTION FOR FEES
AA
Document received by the CA 1st District Court of Appeal.
Exhibit D
Page 37 APRIL
htt ps :// e lectre k. co/2019 /04/ 18/tes Ia-spotted-Se lf-d riving-demo-autono my-network-event/
AA
Document received by the CA 1st District Court of Appeal.
Tesla spotted filming self-driving demo ahead of
autonomy/Tesla Network event
Page 38 iUd•~ ,l t\tO,']tli;lld 1\1",.!W *f l~,1n t~u rei;la tw:;
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https://electrek.co/2019/04/18/tesla-spotted-self-driving-demo-autonomy-network-event/
AA
Document received by the CA 1st District Court of Appeal.
,,,_
Page 39 El~clr~k's Tnke
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https :// e Iect re k.co/2019/04/ 18/te sla-spotted-Se If-d rivi ng-d em o-a uto no my-network-event/
AA
Document received by the CA 1st District Court of Appeal.
t , · rl,-:;-
Page 40 RESPONDENT RANDEEP HOTHl'S MOTION FOR F!::ES
AA
Document received by the CA 1st District Court of Appeal.
Exhibit E
Page 41 , .,
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https://electrek.co/2019/04/20/tesla-shorts-threaten-accidents-restraining-order/
AA
Document received by the CA 1st District Court of Appeal.
Tesla shorts th reaten to cause car collision to
discredit Tesla; restrain ing order granted
Page 42 ~r; ft•,,l:1, ~~ tJOo':'fi,~''}f1~.
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J''nUf!O~lf WJlfl!I,~ :1 tfuSO~() a~1·n ~! ~l b:;.s:,'1:~~"'.:.1n
;:mi c,wl'I lik-1!
tor Qu;te 'i(;f:le til'T\C' th-)1 trer!J' ilr~ a b t ot j:).(1Q would ll( !!i to
It-5!,l foil lhta resistance :o i:"V6 '/;3$ t!JDt ctrhHt Md ll'IQSl
,, :i ~ ck:,3,
~
~ •.x-tfu! mt!1:r;uy m !!':e wa.!<1 J l~l-t'.:\ 10 Ir:~!' nut ~gr.1W.;tthtt-1 .f t•r...."<.:t uc t".iJJS :.:•+"i;t..l:-i! 9.·,;:;l'll1rw.:
p-owl".fl!'d C':il(1 n\13, 11.!'W s l O a~ ~f i~rt'IMQ1)nCJa r,(Jl111i:::.il po.;C'l!ln!) Md ;o.irn1 h-1-,.~-vr,v Wtl'vf:
a 1C)l •~I lh,s &tffiSJ".'el\'
t,(',¥{'!!-d
https://electrek.co/2019/04/20/tes la-shorts-threaten-accidents-restraining-order/
AA
Document received by the CA 1st District Court of Appeal.
t()l\1~·11110
Page 43 I
j

https ://e lectrek.co/2019 /04/20/tes Ia-shorts -th reaten-accide nts- restra i ni ng-orde r/
AA
Document received by the CA 1st District Court of Appeal.
fJ
Page 44 RESPONDENT RANDF.F.P HOTHl'S MOTION FOR FEES
AA
Document received by the CA 1st District Court of Appeal.
Exhibit F
Page 45 , I C ·" 10(11 I)(!.•,
f(j'J1e.~.~.
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What's Behind The Twisted
Tesla Short Seller Psyche?
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H•,~ 012:a,rc 04•t>,t, l)r' er, TSU\ :;t;)rl<; l~d lhC:J :..:1 re;;
https://cleantechnica.com/2019/05/16/whats-behind -the-twisted-tesla-short-seller-psyche/
AA
Document received by the CA 1st District Court of Appeal.
H'ltdo,t
Page 46 ~
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locmelly orga.ruzod (lh1J.s. it can't be caJlod a 'ccn.sp1racy"). bl.t ·Is
rner?"llbO~ d10 highl1/ moliYalfJet:ise.
dosiroyjng Tcsl~. ll 1:;n l
l"hid"l «hoy U!.o to gcnoratc crcd1b~0:-souri01!"'g ;m~•Tcsla oew5. ilefn!a
T!ic T~~:apllobes connt!'C:1 on Tw1ller l~rough a plarform cafod STSU.O [lhe O 15 s:ocf(
i:,:cha.l\ge nolahon lot .a company in bi;11n~r\.ptcy} kcordm9 10 tho fimes. -contribu:ors
t1,:.11do .1p rC!kll1t'.'h tlllN,s .tr.cO,\Wl!J lo pors.on.-J .n:o~mII And llbtilly wilh I;a om~ in ctu:ugo
Somo use e.:immoroal da1nb~So8S 10 t•M:k Tesla•lcaded $hips •tom San Fr~ncisco :o Europe
and China Some Im; exr.ert~ al aulomollvtt l"asrng or O.l!"l\.-erb:;le l>Ontl~ Som~ r@rx~sl
CI.JSklmrtr c,::;mp13,n1s .1bo Planel He 31Jd olhers 1:y over Tes:a lacil1ties ,r, small pJaoes. or ta~@ pldMtA'.'. 'tlili:h dmr.es,
looking ,o, ev1d&nc9 lha1 t.~e: c-cmpany·s oofi"-e1y figures don·1 add up Macnioe Prar.l:!t c14,rns
lhi.'lt 'l"csJa hlJS soma 52 pal1l1r,,g Jots all around tile US, f1tlod v-rith unsold voh,ctes This
modern-day b;un:.torml:!J ha5 1l\5PlrRd ii
leg,cm
ol 1rf11tr11ors, 1n11ep1d p1!ol.s who CiJll
ll'!arn!i!lvE!S IN Shorty A,r Fotce, or SAF lor sJitir1. ~nd proudly wear u shou!de, patch
cn,tJ
As IM Tirr,e.~ rePQr1s. STSLAQ may 0<.Nft 110 J'=acte,. bt.al ns ti~ro ,s Lawrance r-'oss1. t! mcroy
mao.i!]e! who poslod a :ste~c:ty Sltl!OrTI ct .anli-Tes\3 cmIc1es on S1!!ek1n9 .,-.ipha l,l'lder the
ha,,.cll& ~1m,1ana s~~p!ic t,nM l:lo,1 Mu~k t:ullo:ted him. Aftl:!t F'o!ii~•·s 1denhly -N""d5 revei:lled T1N1t:or 1ast JtJly_ Mush: pcrsooaPy callod lho invcslmonl compan~ he works for aM (so F0!ISI
c.:li11UT1S) 1h,eale11ed to .sue Fos51 lor delamtn on Mootalla S~epfic 1!1.sappe-'red trnm Saei(ing
l\.l~h.a ~r,Q Tw,tfcr M,,sW. ·..-,o,, lh,;. t,,s1 1ourld." Fos:,i loid lho ilmtis. but tl'lo 1ne>dC1nt
ger,e,aled more putJltcity ror STSLAO Th~ ar,li•Tesla narra\Ne '"'1s ge~Ing a 1o1 'TlCre
coverace lnon ii "'10uld have golle-11 ,f ~~k had kopt hts. big mou:h snut. whk:h is app.1re·itly
t~,on.:1 his capacity." .said F"0s.s.i
A tongue-Lrr-chi"!t:'k loo.if at some. of lhe !otces that could be out to cause trcublF? fr)r resl.l and
E!ct, Mi1sk ('rcu1u~: Amc1JCil11 AF)
https://cleantechnica.com/2019/05/16/whats-behind-the-twisted-tesla-short-seller-psyche/
AA
Document received by the CA 1st District Court of Appeal.
htilluring an SAF loijo ~ase<1 on a World War II ch,sign
lots. or !i'1mf! ol mem, do vx,:st
- Tosic ha:5 said lhill :noy a~o simply slagil'lg aroas lo, l111al aetivcry.)
Page 47 mal wofld, With po10011a.11y dangorci;s rosulls. A-s
rn~ Veomo
roportl:!d. c~"ilom;a res;dent
Flandeep Holh1, belre\"ec:J to be lhe human beh1C'd tr1e resl;1-bash1"g TWttfer account
-..::t51Ulbo05hko, has bOon is.sued a lemporary restrtlln,ng oraor a.her allogodly ttytng 10 causo
an ~CCJdenl during a Model 3 test dnve th81 dernonstmled ltie NaYiCJ.flte on Au:op lol tealure
Tes.Id says itil~ Wit.S:11'! tho 9iltHly's l1rst pn~ic.il c.o,~fruma~or, wilh cr,rn~ny om~loyoos hs
f~s~ wroto m •ls requo~t tor a returalnlng order
11'1 an lnad(trn m FMJrutt.ry 2019. R8Sp,Oltf1&nf hil Tes/;,~ 5ecuri!y empJoyH Tylet
James 'Nl'lh his- car as Mr. James ap~oac/lea Resportt!enl to aSk him ID Isa~ TQSII :s
pnvato ptoperty Mt. Tyler sutrert.'d m;ncr v~...,,,~~ ThB Re~~t dtd not stop and
!IL}o(J Jhe scc,1e, Tho hc()'kJnt Pc!iCA ~psrt,ncnt wo,o cd#od aod ttmvld on tl'le .1cm,u.
Tl'tB Dopaffmf11'11 lal8f ar.ef11pled ta 16.JUe RB5P,orrckmt .J Wilrnmg nollW of traspass. oot
was unYuCC6$.SIOI ~aun Rtt$p0/l(l(t(I/ Ila."> al/lOldml :mcf been ur1()()(;,:;1;1ralwe in
mooting M-1lh Fromc)(JI pottca off,co1s
Mare roccnrJ),'. an Apr,t 16. 2019, Respondent SliJlktld, hartJSSOO, and rodnngafD'd
/lhre• Tom smp/oy,,os} wll<> ""''' dtivmg on ll>e highway In • TftS/1KJwned Model WfflC:e Dea,1119 manufactumr ptlitBS ai:d ntowilBd with ca1n1ua equ:pmP.fl/. )l'l
pa,#a,lar. Jt,,jp,Jl!dcnl pursued ll>eso omp.'Oy..,. co lho ;;uMc highway lot abou/ m.iootes, vatio"sly drtving anond ul, beSl ct;,nge,ously Clo$O to th• •ct>JcJo ReSponcl6n/ swo"""1 so c/oso to lhe 5/do al the
T•sM 11111! 111-, vvh~•'s std•-colfision (t:tas/1) aw-,it1.V11.:a S1Jf11ty IBahJfd was tr,gge.1ild to
onga9e an emorgoncy- rnar.O'f.Jvor to avtM mo col/dlorl.
Eflf/M9•1 o,p,..,s. "Ralldeep a,.~ nos broll\er Gaga,, (who w<>t1ts tor VWJ aJloyocly also run
a Twitcer aa;.ounl 1'1ill trequenlty blasl.5 Musk aod Tes~. procla1m1ng lhe ccmpany·s Pte~otisly, use~ al~ Ink~ Iha Hom, C!Olh8f$ fo AQ\k11I aec:aunls thaf l'ltOdctrated 8 T6.',ls:ock subroddi1.· Tl\C Linl(odln Pf Ollie ol Aandccp's brolltor. Gag.1r, .:natu th.al ho works Jcr
ma nvol a1Jt01MkOt ilA a SYJ'Wot dAN(lO t~hnoklg1.~I. Ekm Mu:3k, i'lhl;!r di.,covering ln,51,
~~tQd, -"This iS o:icttomo,y trn)sstd up. @\/W. what's going onr
Sunon Al..,nroz:. wril1ng in To,J1raU, no:es thot tho reil.1-wortd act,vitios dosaibod
1n Tesla'!!
reMJa11..ng ordttr rtl'qur..• appear lo have been ir.l!ifH~ by ao eM~r d•S(:U:H,ion \n the
vehlctecras.tied
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https :// clea ntech nica .co m/2019 /05/ 16/whats-be hi nd-the-twi sted-te sla-short-seller-psyche/
AA
Document received by the CA 1st District Court of Appeal.
STSI.AO onr.ne community. When OC)Slll som& of oi.s ,o,.owerg sugge&led dit.rupttng me lest dnva by braJCJng in 1roru ol the vehicle
and intonbona11y S"Wotving ~tn Its lane - !.Otflfl also Jr,kt.d Iha.I it would bl;I t1..1nny it the
Page 48 RESPONDENT RAND EEP HOTHl'S MOTION FOR FEES
AA
Document received by the CA 1st District Court of Appeal.
Exhibit G
Page 49 r;ngadget-
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https://www.engadget.com/2019/04/22/tesla-short-seller-accused-of-threats/
AA
Document received by the CA 1st District Court of Appeal.
-=
Page 50 t'\Tns:r,I :mo1 1:1dnm;·e't,·, 1n1f'{'U-ro·1-1h• t h,m '•JJ;f'I YJt ti\;.'1.t u.,
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https ://www .engadget.com/2019/04/22/tesla-s hort-sel!er-accused-of-threats/
AA
Document received by the CA 1st District Court of Appeal.
1 ~ • l t;,i1
Page 51 RESPONDENTRANOEEPHOTHI 'S MOTION fORFEES
AA
Document received by the CA 1st District Court of Appeal.
Exhibit H
Page 52 ... >
T~c.- 11'1.ln til'hinJ or~ cf liu.~ rn::,~t pr.:iiri~nt J! ,:1•':t:sl;; (;c,..oi..:nl'< on T\v1UC'r, ·:-:·VJboc'ihic1l. 11.1~ Ucen
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rec:ldl~<.1y th.tl hil:i'V•.-1:it!c t•111trrJ ~;'I uiggr.ring 1h~ Mr;ct~I 2 ~. cr~1',h1•mf•1ge1u,v :wofdann.: m-,rn~tJ\."C'r.
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l11.)t C.-,liforni,l rt':"licJc-nl R,1:--d~·•p hc1hi, tt-e ir,;m ~llt~Rt~divnt:hhid lht~ TSLAQ
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·t 9ot cancer and
I didn't want to
smoke cigarettes.
Vaping changed
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• Jud9, 64. Sunnyside
.S PONSORED CONTENT
What is
endometriosis?
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https ://www.teslarati.com/tesla-tsla-restra ini ng-order-tslaq-mode 1-3-fsd-demo/
AA
Document received by the CA 1st District Court of Appeal.
Q
Page 53 II
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loan jncident in re~ua,y 2019 Respc,c,denr hi t T~kJ 's securi,v tmpfo~t TyfN James wirh his car tJS M,.
Janw:'ii appmar.hW Rtsocnth:ne roo1k him 10 ~uvt:, TI~.sk(s privutc 1>m1~rry. Mr. Tyl,;t STJ({t.ff!d 1r. lmu
lnjc.,ries. The Rz;;pondti,cd:rf r'lllf stnp.Jnd llcd r~ JCet.e. Th" Frerr.orit PQJlt:e Otpattmcnr wtrt i:olJtd and
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but was im~uc,;r;S)ftJI beai~.'iil!: Rec:1)01Jdtnt has rJ'Vl)irle-d t1nd been U'1Coop,tro:iveinmeetins with F~mont
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Mort rec•mtly. en AJJ(il .t6, 2019, R~p0ndet1l nalked. haros~cd, amll!ndt111llt.1e!1 (Hut, Tej!d emplcyt.:t!J
wh" WErf. .:1.-ivin,'t rm tlle hl,!hwarir1 r.i Teslo ":c1.m:cd "-"1rbcam~r4 eq1Ji~e11, J11 .w rt i high-HD)"' fnr :"Jbr.ut 35 m1r.uln • ...oriot.-sfy dti'fin,JOJ'w.od c( IH.' iiM. and t'..r.hi;ICJ lta.•tn. t1t1tl SY.'#.fVif\,'j
don9e,-0i1!i~• <.# f.il1t. cotri5ir:m (r.r.-r..-.h) i;:,.,01dor,n: Sfi[t.ty fl!fjtlir~wa_~ lr13Sr.red mtrsf!m;y mciof:~>t'Tr ! .} U'1>id
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BOOJ Thue emp/ov,ts ,-,,I ""P''°' Jaw,w/eda< ol R.,pondent s iottracticn< with r,s10. but 11 awearal :hot
.R~µo,n.d!'rt~ ~5 !1)''1tg to ;nctr:ctt: w,tt, lhei.r drwe. (Ind e{lt:hJeored tht;r RL-spc11drmt's rood i:ond1.,ct
Hertz
"'-'Cu,d cuus:t a coJlisfon und i!1j"tc them F1.:urin3 fot tHs scfccv aM for tht- ~o(ety of the Cf~r ~s~fls~n: ,n
the Model 3 fu Teslo ()mpt~c}co!ttd rh~ sun rru,:clS(O Pofiee OrpottroetH or rh4t timt. Howev-er. bii!a.,us:~
https://www.teslarati.com/tesla-tsla-restraining-order-tslaq-model-3-fsd-demo/
AA
Document received by the CA 1st District Court of Appeal.
1he-(nWYnt1
Page 54 rn,;, Q{(,t;t.-s wt"' i!I fht a,ea. flt::e T6kJ f:'rr.pkl~-rti) uJtimc;t~}ydid not rt-ij11t:st lhot on otf1r:t.r ~stnt M rh,-j f
'ocotiOfl
On April 12, 2019, Tc-slll wilt host lln evenr ot its htadqwrrc,s ~t 3500 Deer C:eck Rcod PaJoArto. durfn
wh,'ch T-?.SM t.'m~oyee~
wm lK: de:toothttfilfr:~ oH.hidt (un "l~l.lrbfrotlds. Re-spc,:denl hus eJ tncovtCJ$~d him ro t,)' to foif"w cJr.d i(ll tr(cre with r ~ drivt.t Reipondf'nl is a WK.t.l Ti:5-la derractor.
doim.s t£I l>t o Tc.do shc,t-~lit,, r1N1 li••~ts e ttchtM'Jlo,'fY] /t.lrl Tor.muro lht :soft.tr vf Te_o;lu £mpktycflcmd fhe p1,bfic. t~m,r,orory rxoie,lion h neclltd. r.1tApril 222019, (o, Ottr' Tr.!ila r.m,,loYHt drh,lr,$0 Tcsf.:, vc.'1idtwilhJM111,ifo(.tuflr pr~re.,-; wP!hin Sm:Jes of
T!'SM'-s.latQdqllt'lrtcrsnt 1500 Ottr Cit.ttk Ro.t:1d, f)f,.10Alto C{lJiforrtlu
Hey ~~eiof'tn.u~!<. • rust let1in~ you kriow lhal as we s.penk. short
Free Wi-Fi '
sellers aw d,scu~ing trymg !o deliburately cause an accident Ydh
one of y<;ur FSD vehlcfes tn order to mwcc TMla took Md
u ~:J,e 1~
•~ri, aMN'l\'i v'- il:J ~'\n.l m 1e! ~t'ii::::~~1;•

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BOOK NOW
It should be nQted th.ii: @'skabooihk;l'.s .Kt1om men~loned by resl.a in iti restr.11riirig 0 disrnrbh1gly mirrot some of the suggesrions prop~sc- bec>t '1Q5-1ed im;:,ges of the ccmpatry's: Model 3 test Cilron Twitter. Among these suggestions ioduCc
bt.lklng l.n froi,l ,of resli:l's test vehicles, as well .n lr.tcnlionilliy swervln.i into the t:lectric (',:irs· hme
lo ensure thi'lt the company's demonstratfons Me .authentic. Other Tesla bears also jok~d that it
would be ,1Ml.!S(ng if :h~ Mod~I 3 Ct:tsh~d.
Due to his actions. the noted Tc5JJ bc.1rw II now be required to St.ly Pt lc~:ist \OOyard~ t>'N r,~,.
thefremool factory or the employees n.ltned :n
..-,re~tr.>inin.g orditr. He is al,o requi,ed to stav
Y'J'Yard~ May trom <>nY resl.'.l v~~i~le YJ"lth manutuC.turer pl31les within hvc miles of the tauory. The.
t~str3,nffil;o,der ,s effect Ne unU\ M;w 7 when a he.1nng is set
Free Wi-Fi'

the Tiest,1,rihi: \ n~ddc'5s ~,dion'5 st,cmed tu l..wr. ~ternm~d from a par-tkul,1r fou.1..\ en Tl"\ll~
uotoming A~tonomv lnve-.tor O.l'I on April 22. wt'lert thf ele inve5tors J dl";'pdive mlo ih ,ull self dri\ling in1riatiY@'1, intluding it,;, c,1<,Wm H.>tdit1.irt J n ~rr;:nJkr
leit rides on-..,ehides equipped with ur,re.l~Jsed fe,uur6 of Autopilot and the Full St-lt•Ori..-ing
suite Jre al!o ~,cpKled' to oe held inthe~nt
Neither Tesl1 nat f-l0Lhi have· t@ipond~1d hi rP.qUe~h far c,,rnrntnt to medi~ pulllic,it1cm: ~u \/C?1Jr":. though the @'ikah~k-it l'wjtter at. •1will r.or
re,t T~i'i is my promi~fl' Tl'.!'!'iln
,;
tero. ie,r.lonrnusk willxoto pr;son.' El<.m Musk, /or hi\ p~rt noted
oo fwilter lhaf Lhe ..\ctlons of the not~ Tc~li! be.Jr was o;omethlng that he h\lS never seen before
Avoilablc at over 64 million
hotspots worldwide.
BOOK NOW
Hertz
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a fesi df.fTIO YIIJ~[IIJ! 1$111.Q mus, bu Ot".-0 ;.>I the ~ l =n~al'JU m,t1g11 it tu,poe:MO :o ., r.omr,any, itil .i1r)nn MIC llltir rnnko~, Lnc .....,,rlrl bolftt'.
No1..-er se~n a1,ything liX& iL Tesla is just uying 10 moi..e elaccric co,s
6 solar power tor a bette, fulvte to, al.I. T)\Jll, we might f'-01 succeed,
bul why do lhey want us to fa11?
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https ://www. tes la rati .com/tesl a-tsla-restra ini ng-o rder-tslaq-mode 1-3-fsd-demo/
AA
_j _J
Document received by the CA 1st District Court of Appeal.
Hertz
Page 55 RESPONDENT RANDEEP HOTHT'S MOTION FOR FEES
AA
Document received by the CA 1st District Court of Appeal.
Exhibit I
Page 56 EXAMPLES FROM TWITTER
Clarence W orley
- .:'~::••,:~'-:': ·. -;_-Q;;r,.:r: l"J,'·r9,: :-=~=,.~ ·t•1:;•·: 1:d.:lp.,:·1::::·
_ ,~,.1~-".;::::._ n~~· .=•:;c1·:h:-r ·:e :L ....
= li:.abeth Soechting -'} ' 1,iG'i-:=:f-':eal t.3 • /•.r,:r

v
t hope the case @skabooshka shows joumos ,.-,hat kind of people hey have bei=:n
rt?lying e n, ~tslaq a1tracts crir:1 :nal mindse s a c people ful l of ha:red. ~ o~ vali d
o r reliable sources

_:;n
i
;:;o tant top ic Ii e ft EVRevolution, #Tes la.
-#Teslalmpact.
Pas:.ionPlanet '..!-'P.:issionP:an<2i 1 · Apr
V
You're a fraud :and you 're a v12ry 5ick person, Wl> ile I und er~tand you five with your
fa ther and don·t understan d the rea l economics of what t his is doi119 to try to hurt
emp!cyees is <1 whOle nother t ~·ng I r,ope you get wha 's com ing o yot now th at
you 've been doxed. Fraud,
)
Kim Paquette 3. k r1pdOt:e::'.lo::: •
~.!,


Arc l'OW S s_;.Q is ercc.1·ag ng others to take wp sabot:agi.,g the event in
Skabooshka 's st~ac. SICK. '(12~1 people
.ue S CK. Le-t Skabooshka be a lesson -
7esla sr t putting u;: w,th this crap. Po ice will be c.; 'ed. STSLA
Daniel : ..... Scott ;;; Cr-:rBby • ' pr ;::o
Repl/11',g to @Matt MillecrCubed @tesla_tr 1th
Amazing how many of these assholes turns out to be working for a, ICE
auto1m ker. Pipperger. skabooshka 's brother, Preaching about 1ntegri •y and
moral character all day. Turns cu they're the rea l frauds, Sad.
"j
AA
Document received by the CA 1st District Court of Appeal.
E2ply•1 SJ to @skabooshka @elo, musk
Page 57 Starlin k & flocks of Cars :~.ii!•,.•., :· c•:••)eni'.~o;a • ;..;:, .: ,
F ~1~1y:1,] 1.c: @:skabooshka ~.:for.musk and ;J ,)~: 21.:
@SEC_Enrorcemer-t ancl @Fel This is ,•:b3t you "leed to investigate. i; Comrr.on tlwg racketeering against competitive i ni~ovaticn
t heverge.com,1201 '? .:'../20/1850.. .. @tesl:a tol"'.1plai n he-re about these two. 3 ~hort
selie r & V'.·V employee sec.gov/c iea/Complaint.... & @fbi r.ere ~bi.gov/t1ps
V
From the Berkley Bio ;t i s clear R,3ndE-ep is associated w 1t11 :he separatist Khalistan
n,~..1er.1en!. I-'e could b e ,,io fe,,t
hir
cl dangerous - as ,,..,e ha-.·e see!\. Tesla should t~eat
as a credible v iolent threat,
Lady Tesla '::' v
H1 @·\ JewcombeWW @wwfour.dat ion are you aware of ;t11Ran deepHothi's .aka
@skabooshka crir 1inal acti 1:ity? You g.=ve him a S2.5K gra,· t . He si:;ent that money
0n: Trespassing,
ass.3ult placing video canier.ls on private pro,::erty, 1·,.:1rassr-,ent
#lnvestin\N'h' STSU~. #\/\N
MrManderly t:JM1M;i11do::dy '1 1•
R•~ply:•19 to ~;;1/,lfi;,•.i\r,.,iy,,: 1 C,.StE-.,,,vl;·ro
What's a few rnurder.s when racketeering.
n
Q
v
B
Johnny Franklin
(
Follow
}
But after you thought right?? Stupid fucking
middle easterner
... u.
AA
Document received by the CA 1st District Court of Appeal.
stalking. documentcloud.adobe.corn/ li1ck/ tra::!<.?uri...
Page 58 MrManderly '''.1- '.r\i.Hh.ied,: 1 :,,
v
Trying to crash a vehicle with occupants in it Js very definitely atternpiecl -nurder.
!ts especially eg,egious when all youi tv.ritter friend are encouraging you to do it
before hand. tha, makes it premeditated.

;..::J
EXAMPLES FROM ELECTREK.CO
l
0.-.11id Gilmore ""' . ,
My comment was rcnmve:CI for nam,ng the terrorist Hwolved. But ,t'n .ill public record Tl·,cre's no ncco to cle:etc
comments that have public inforrnation that was onutted by the article for no reason. The W/ connection is really
ihe crux of this whole story. We have to name names. Tris is REAL news for a change. Not idle clickba,t.
S i1,u1,
- - - Change ..,. ,
~
I ,(
t;
I 11 ,,
I'

;
Yes by not naming them peoole are already wrongly thinking these are some poorly educated idiots. Both of
them are in fact highly educated and these are very deliberate and planned attacks on Tesla and Tesla
employees. T>ie truths needs :o be told and these people need to be held accountable for the,r terror. ll VW is
TlmRowledge \ :,• -n1h1i
,· t,)
,.:,:=t:::I
So a grcup cf ~cple commun,cat1ng to plan actions that will plausibly ci1use ar.;tuaUy comrnit aclions as discus~:aid ; how 1s this 1101 a text t.:cok case of conspiracy tc comrnn murder?
Ch, y&s, and since lhere appears to bF. intent to force changes In 90.,erno;nit policy by violent means. r ow is li1is n ot 1errorisrn?
·q '
~l{U'O
marcusmaximus04 ...+ Etchy McEtchy 4 mu11ths a~io
Sure, but more importantly, FBI should investigate for terrorism.
A
Share,
/
Hopefully they're not born and raised here, otherNisa it'll never be labeled terrorism. Mental issues if we get really really
lucky.
Nawnp MCPE I <11•,11•·
-~
'ilO
1,.,,,: .,J
'Nl1.11 logic ,s d,scredillng a sell dri1>1ng car by inlsnt,onally wrecking ,t'I Ai the best !he stc,y:•ne \•,ould be · ,J,01 wrecks imo resla wMa
obvious demo ~quip"'ent 15 set ,ioAJ!.io is l hcrc not ln...•JS ,1qa1nst Sclbot~g1119 a coin~any 1hat you ht-1vo a tmnnc1nl inc.?ntwe to do so·,' su,~lv th..,t iS n J'41I .Jbfo otfense
S I ru
., •
,...._~
deJ,e,knis :~ rn:.i,11h·.~ ,"~I'•
l SLAO seems to becomirg or,creas,ngly radicalized. I hope the FBI is invesligatlng - I could see 011e of 1he mere radical memt:ers
rJ~cKJing that a bomb at Fr~mont would t:" good tor u,e c~use.
AA
Document received by the CA 1st District Court of Appeal.
actively involved 111 orchestrating physical attacks on Tesla employP-es and property this 1s a very big story.
Page 59 Brv-1n B3kctr
ti
m.,-1,!th •'.\;!,}
It's tlma for everyone lo cool oft a htlle bit here.· No. ,t G lima tor \11is wack lob to crawl back inlo his hole. and for Teslu to oontir.ua to
mmp up protec11ons aga.nsl him and his ilk. Never give anything lo n buily--all they'll want is a little more.
IH,,...
Sh.-"";
I think the Tasia Secu111y depa1 tmen1 snould keep the FBI lnform&d about these ,wents. I am immediately reminded of Ted Kaczynski
who ended up ln .i Superm(lx Facility. From 1/./ik,pedia ·some neo·Luddites use v~ndalism and or vrotenco to nch,eve social change
and promote their cause • Tho carispi,a~,- angle a!so wmra,ns rurth~r research.
9 , . ._
Shat"',
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How ,s lhal not crnninal?
Openly discussing attempted murder to make money sho1,ld be charged as such. As well as losing any access 10 sleek markels.
Wah Cheung 3 ;lY.wUB •lHi,
The guy 1nterlered Tes 1a employees M d their demonstration work nearly ca~sing ,m nccidenl 1s 3 dcgeflerated hl1man worm.
2 -~
..,
SNuo
farllcustheelder 4 mo"'hs ct,;n
Someone needs to take his meds. Bizarre to think that a few random acts will have existential import. Not rational,

A
Drucifer 4 months ago
Lock Them Up!
2A V
Share
Martin Bartek 4 months ago
l hope those stalkers will go to prison soon .
2 A
Nicholas Pye
~
V
Share>
,.
;noutm, 1~w
Great news. You cannot behave like a psyct>opath and think its ok.
A.
Sh.a.re i
B..try AharMml• Fae.I Covtaf•
~ n·~l!'lf!'I,-, :-.go
r,.cJ,11}d
These are extremely disturbed individuals {tacepetmJ
,
~
Shnro
AA
Document received by the CA 1st District Court of Appeal.
..,.;::
Page 60 Th q11y ,.n:i1h11,11 11 t 111a!ely cr,0zy. ,~ 11' crazy. q,, lly trnp,~- rn I
~ 11 ,t ~n catrS<-:? , t •:i cnl Gh -n
Iii:, lho hr, 1 ln. H (lp(d to cne f I on 1 "/
At any rnte. there are plen!y of crazy people oul Ihere but them is also a ll~avy dosa of r:eurotic people on here. author inc:udoo, •:,ho
me convinced of a non· eKistent consI>irncy by the o,I companies. I 91!t th(ll many of you ha1e them , hut seriously thmo jvs1 ,sn I
.,~,dence 10 maki, :lie leap that th""' i» some giant oil company conspiracy Jgai11s1Tesla. If the <>lltl companies ~ated Te<,;la hey would
1ust t>11y up ~II Ihe stock which for lhern would he cheap .
«•~t,.
~i.l lll '\1!-
A crazy r,erson usually
spouts nonsen5e. rh15 guy is ma!icious , if you ,;,.itch his tweets you WJil ooser;e c.:ilculated
mIs1ntcrma1Ion, not cont~slon.
Randeep H01ru
soundt like il Pok1 n~me
sel'l(I lhe Tesla hating loi,er back 11nMe LOL
;.
,
quallturv
Q • •28 ~orms
, ·
•·
r ,
Original filing at https://www.plainsite.org/clockets/3xt7clv6u8/superior-court·of· california-county-ohilameda/tesla inc v-hothi/
If that stupid fuck is on this sub, can we please have him broken both leg,; removed from here?
l ·l /...,,
,_,,
A.nil Tryhtlrdr:;69 O points ~ •,: 11\t--
.. ll"
Absolute piece of fucking SHIT. Sue the tuck out of the sumbitch and prosecute him criminally if circumsta nces allow.
Make an example out of him. Fucking neck beard trash.
Elon
should go after ihis motherfucker with all of his lawyers, bankrupt him and put in Jail.
AA
Document received by the CA 1st District Court of Appeal.
EXAMPLES FROM REDDIT.COM
Page 61 s1cgc3:t2 MOCEL ::: Li? A!canlro
,.·
6 J.?<:ints
Looking through some of the Twitter posts, they flat out give 1he locatlon of employees and incite assauit with a
deadly l",eapon. How has Twitter and gofundme not banded them?
Dt.•a1mtll~t12()2:~ .'31 l)(HltS .
V
·: '
!I
I his is dearly racketeering
There is a group, organising and colluding online, that is committing illegal acts fer the purpose of harming or
destroying a rnultibilllon dollar company w,th rnembers of the group linanciaily bene1iting.
This guy posied hrs plans and was encouraged by other members of the group.
The motivation Is not important. The means of communication ''Twitter" ·snot releva11t. Wh,ither the group h2s a
formalised str1Jcture or leader ship does not mailer 1his is a clear mcketeenng case with a billion dolla1 company i'.lt
stake.
SEC has been profouncJ\y silent (not even acknowledging the problem or issuing a public warning)
This was the only f.ictor that created the pressures to consider taking TESLA private. I hope that the agreement the
SEC is currently negotiating specifically acknowledges this point and commits to future eniorcement against all forms
of intentionally misleading milrket moving in for mation .:ind those that fraudulently benefit from it.
I also hope that FBI RICO resources are allocated to investigating anc.l prosecut ing ,hese events
a cunt
w1,y is this guy doing all this to harass these people? Sorry if it's a stupid question, l;m just a random from the front
page lo\. I read th,i first 4ish pages of the document, ancl the stuff this guy has done is really tucked up. I just can·t
seern to see why he would do all of that lo!.
oli'-'ersl 4 points
~
,: )c
~•
.- • ; '
Have you read the restraining order? He was attacking the Tesla car with his !:ex\!~ Acura TL. PuHing driver life and
propert y in danger.
These people have reached a new level or pathetic. Spreadir,g lies on ttle internet i~ annoying and stupid, but
trespassing, hit and runs, and actively trying to cause car accidents is a whole new level
Wow. fhe sheer amount of crazy that this guy is. He hit someone and he was driving erratically. Lock this lunatic up .
.,,. Batshit crazy. Running over employees just to see what's going on i11side What the actua1fuck.
fI
'\
',

Thani< vou tesla for doxxino @skabooshka. Hooefullv Mr. Randeep can now tuck off
AA
Document received by the CA 1st District Court of Appeal.
Wow, what
Page 62 , "\.
momyp(rrt 6 OC•ng '
That guy has serious mental Illness.
~
',~••
ll
,~~
,;,•;
Is this Hie skabooshka scumbag who tails Tesla test cars and that Fred Electrek gloriously used for one of his blog
"articlcs 1' ?
,
OeeSnow97 Trying
w decide ,f ii'$ still woo ti• getting a driv 13 points
· ec :',,,,
,,.
Borderline? He assaulted a security guard with a car and fled tile scene. That's a felony.
'I./
Loi what a scumbag i...
cp19!l6 F
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6 ncints ·:: ··,
,·i.r.~:
~n•:hOr Pcorl Whiltt LRM3 107 .POonts
-l f ,
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So so11nds like the dipshit tried to sabotage it, but ended ltP giving Testa good footage of accident avoidance and
·.,
how well their system works. Dumbass.
( ·) C,'UD
i.O col:":-." t,,,1,,;:1 Should they be labeled merely a short seller at this point? I would label them a trespasser, hari:lsser, hit and runner,
and saboteur. Saying It's "against a short seller" is a framing that implies they are innocent and merely being targeted
because they are shorting the stock.
These fucking bears need lo get their heads checked. You cannot run over police officers to get your pictures of Tesla showrooms that
you post on HSLAO. You cannot stalk people and doxx people and pay for FUD. When TSLA gets to 5008 market cap they are going
to remember who tried to fuck over the planet ancl you will get yours, and then some.
[IA
V
He's fucking insane and that's the most dangerous part Someone please tell me Elon is surrounded by
bodyguards at all times
AA
Document received by the CA 1st District Court of Appeal.
Randeep tried to commit vehicular manslaughter and you're relating It to Musk simply asking a contact for more
information? Wow. Just wow. All t ime low For you.
Page 63
·. ,,
! •"
• ,,

'eirCCC
JJ ,,
0 :Jr"••t
!
Hot Pink Unicorn 3 points ..
Vehicular Assault is a thing ....
xnaas TM3 LR AWD
,
24 coinls , ·, ·• •·.
I imagine ·attempted vehicular homicide'' would not be out of the question, considering there's clearly
intent.
Edit: manslaughter -> homicide
A
koosllipuh '/ po,n.ts
'.-
lsn·t vehicular manslaughter tor accidental death, t hough? Tha1 might be why the pen;ilty is light2r
··v,: I'·, ,..: ,
than you expect.
l"i /'•
"'- ·
xnaas TM3 LR AWO
5 co;rll$ l • ~"''" ·.c~o
Sorry, thai's right. Fixed to homicide!
Idiots like !his should be dragged behind an alley and be neutered w~h a hammer.
Trying to hit someone w i!h your cor just because you don't like the complll1y??I! WTF i3 wrong wi!h you .
n
Michael Wakin ..+ macrodoodle 3 months ago
I suggest reviewing the posts of that moron. You will see what
everyone here already knows. lshkaidiot is deranged and acting on
that sick impulse.
You may not realize it so I will point it out for you, by defending him
you are seriously lowering any credibility your opinions carry.
Share,
A
Jame 3 monlhs ngo
In any group of persons, you will always find 2-3% of reactionary sociopathic
psychopaths
2 .,,
"'
Share•
Wallace_.. J.rn1c 3 mon1t1s ago
Ar,d a few batshit crazy folks as well ....
2 "'
.,.
Sham•
AA
Document received by the CA 1st District Court of Appeal.
i
..
Assault with a deadly weapon, maybe attempted murder
Page 64 Document received by the CA 1st District Court of Appeal.
EXHIBIT B
AA214
Page 65 ...
,,
'"Petitioh"',,ft'>r Workplace Violence
Restraijning Orders
wv-I
I
II
I.
Read How Do I Get an Order to Prbhibit Workplace Violence (form
WV-I00~INFO)before completing t:his fonn, NOTE: Petitioner must
be an employer with standing to b:ring this action under Code of
Civil Pro.cedure section 527.8. Alsp fill out Confidential CLETS
Information (fonn CLETS-001) with as much information as you know,
Clerk slam s date here when form is r;J;d,
.
ALAMEDA COUNTY .
.~PR 1-f20\9 ·
ERK OF T H E ~ T
Tesla. Inc, _ _ _ _ _ _ _ _ _ _ _ _ _ __
a. Name: .,;;;.;;.;=..;;;;;;.;;.;.._

[ 1111111/il l fl!~~!J~l110~~
.FILED
(D Petitioner (Employer)
is a'
-
D sole proprietorship
[8J corporation

YS:: · "#
Dtipuly
Fill in court name and street address:
(specify):
Superior C.ourt of California, County of
and is fi~i~g this sui~ ~n behalfofthe employee identified in item@.
b. Lawyer for Petitioner (if ariy for this case)
Name: Zachary J. Alirider
Fi~~ Name: Sideman & Bancroft LLP.
State Bar No.:
Alameda
Rene C. Davidson. Courthouse
1225 Fallon Street
Oakland, California
!

Employee in N,eed of Prntection
.
Full Name: Matt Cross
Sex:
l:8J M
•F
Age:
0 Respondent (~erson Friom Whom Protection Is Sought)
Age:
J Address (if known):·

State:
City:
_ __
Zip:
Additional Protected P(~rsons ·
a. Are you asking for protect/on for any family or household members of the employee or for any other
employees at the employees workplace or at other workplaces of the petitioner?
l:8J Yes D No (Ifyes, /istthem):
Age Household Member'> Rclationshi12 to Emplo~ee.
Sex
Full Name
M
M
Robert Temmerman
James McDonald

• Yes
l:8J No
0Yes l:8J No
. Colleague
Colleague
0Yes 0No-
D Additional protected persons are listed in Attachment 4a.
This is not a Court/ Ord~r.
Petii:ion for Workplace Violence Restraining Orders
JudlclelCouncllorca11rornia www.courls,ca.gov
• "
Revised January 1, 2018. Mandatory Fmm
Code of Civil Procedure,§§ 527.B and 527.
t' )

I
(
Workp ace 1olence Preven ton
AA
Document received by the CA 1st District Court of Appeal.
Court fills in case number when form is filed.
Petitioner's Address (If the petitioner has a lawyer, give the lawyer's
Case Number:
information.)
c. Address: One Embarcadero Center, 22nd Floor
Zip: State: CA
San Francisco
City:
----Fax: 415-392-Telephone:415-392-1960 :
E-Mail A,ddress: zalinder@.sideman.com
WV-100, Page 1 of

FILED BY FAX
Page 66
·
I
Case Number:
b. Why ·do these people n~ed protection? (Explain):
D Response is stated in Attachment 4b.
These employees have suffered actual and threatened violence from Respondent through a course of conduct as
more fully described in the accompanying Declarations of Tyler James, Matt Cross, Robert Temmerman, James
McDonald, and Christine Leslie.
Respondent hau history of trespassing at Tesla's facilities, unlawfully taking photographs and video to post to
his Twitter account, and o~her misconduct, as explained in the Leslie Declaration. However, in recent months,
Respondent's conduct has .escalated and has resulted in violent and intimidating confrontations with Tesla
employees. ·
in

More recently, on April 1,6, 2019, Respondent stalked, harassed, and endangered Matt Cross, Robert
Temmerman, and James McDonald, who were driving on the highway in a Tesla-owned Model 3 vehicle
bearing manufacturer plates and mounted with camera'equipmcnt. In particular, Respondent pursued these
employees on the public highway for about 35 minutes, variously driving ahead of, beside, and behind them,
and swerving dangerously close to the vehicle. Respondent swerved so close to the side of the Tesla that the
vehicle's side~collision (srash) avoidance safety feature was triggered to engage an emergency maneuver to
avoid the collision. These employees had no prior knowledge of Respondent's interactions with Tesla, but it
app~ared that Respondent was trying to interfere with their drive, and each feared that Respondent's road
conduct would cause a collision and injure them. Fearing for his safety and for the safety of the other passengers
in the Model 3, Mr. Cros:s called the San Francisco Police Department at that time. However, because no
officers were in the area/ Mr. Cross ultimately did not request that an officer be sent to their location.
Relationship of Employee and Respondent
a. How does the employee 1,mow the respondent? (Describe):
.These employees do not know the Respondent.
D Response is stated in 'Attachment Sa.
b. Respondent D is 1:8] is not a current employee of petitioner. (Explain any decision to retain, terminate,
D Response is stated in Attachment Sb.·
otherwise discipline the respondent):
or
Venue
. W~ are you filing in this county? (Check all that apply):
a. 12:5:1 The respondent live/; in this county.
b. 12s) The respondent has caused physical or emoti~nal injury to the petitioner's employee in this county .
· _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
. c. D Other (@c[fy): _ _ _ _
Revlsod January 1, 201B
Petition for Workplace Viol.ence Restraining Orders
(Workplace Violence Prevention)
AA
WV-100, Pag82 of

Document received by the CA 1st District Court of Appeal.

In an incident February, 2019, Respondent hit Tesla's security employee Tyler James with his car as Mr.
James approached Respondent to ask him to leave Tesla's private property (the factory at 45500 Fremont Blvd.,
Fremont). Mr, Tyler suffered minor injuries. The Respondent did not stop and fled the scene. The Fremont ·
Police Department were called and arrived on the scene. The Department later attempted to issue Respondent a
warning notice of trespass, but was unsuccessful because Respondent has avoided and been uncooperative in
meeting with Fremont poiice officers: · ·
Page 67 -

I
Other Court Cases
a. Has the employee or any of the persons named in
[8J No
been involved in another court case with the respondent?
D Yes Ifyes, c,heck each kind of case and indicate where and when each was filed:
Kind of Case
(I) 0 Workplace Viole~ce
(2) D Civil Harassment
(3) D Domestic Violence
(4) D Divorce, Nullity, Legal Separation
(5) D Paternity, Parentage, Child Support
(6) D Eviction
(7) D Guardianship
(8) D Small Claims
(9) D Postsecondary Sc,hool Violence
(I 0) D Criminal
(11) D Other (specify):
Filed in (Countv!State.J
Year Filed Case Nwnbet (i(knownl
Document received by the CA 1st District Court of Appeal.
b. Are any restraining orders or criminal protective orders now in effect relating to the employee or any of the
D No D Yes (If yes, attach a copy ifyou have one.)
and the respbndent?
persons in
This is not a Court :order.
Revised January 1,
Petition for Workplace Violence Restraining Orders
(Workplace Violence Prevention)
AA
WV-100, Page 3 of
Page 68
I
I

Case Number: ---
© Description of Respondent's Conduct
a. Respondent has (check one or more):
(1) 1:81 Assaulted, battered, or stalked the employee
(2) IZ! Made a credible threat of violence against the employee by making knowing or willful statemerts or
engaging iii a cm:1rse of conduct that would place a reasonable person in fear for his or her safety or the
·
safety of his or her immediate family.
b; One or more of these acts (check either or both):
·(I) [8] Took place at the employee's workplace
(2) 1:81 Can reasonably be construed_ to be carried out in the future at the employee's workplace
c. Describe what happened. (Provide details,· include the dates of all incidents beginning with the mo.fr recent; tell
who did what to whom; identify any witnesses):
D Response is stated in Attachment 8e.
See paragraph 4.
d. Was the employee harmect or injured?
D Response is stated in Attachment Sd.
[8] Yes
D No (Jfyes, describe harm or injuries):
When Respondent hit Mr. James with his car, Mr. James suffered injury to his knee.
e. Did the respondent use ur threaten to use a gun or any other weapon?
D Response is stated in Attachment Se.
D
Yes t8J No
(ljyes, describe):
This is not a Court Order.
I
Revisti I
Petition for Workplace Violence Restraining Orders
(Workplace Violence Prevention)
WV,100, Page 4 of

Amerlr:rn l.egalNrl, In(', ~ '
,www, frn:.msWJ>Lkflow co1,1 ~Q
AA
Document received by the CA 1st District Court of Appeal.
Address of workplace: See Attachment 8b(2) for a list of workplace addresses.
Page 69

I._c_a_s_e_N_u_m_b-er_:___ _ _ _ _ _ ___,!"
®f.
For any of the incidents dt_:scribed above, did the police come? ~ Yes D No
I don't know
If yes, did the employee 01r the respondent receive an Emergency Protective Order?
0 Yes ~ No O I do_n't know
If yes, the order protects (9heck all that apply):
0 the employee · [] the respondent
0 one or more of the persons in@.
(Attach a copy ofthe order ifyou have one.)
Check the orders you want lil'
(;\ ~ Personal Conduct O~ders
I ask the court to order the respondent not to do any of the following things to the employee or lo any person to
be protected listed in@ : ·
a. [8J Harass, intimidate, molest, attack, strike, stalk, threaten, assault (sexually or otherwise), hit, abuse, destroy
personal property of, or disturb the peace of the person.
·
b. [81 Commit acts of unlawful violence on or make threats of violence to the person.
c. [gl Follow or stalk the person during work hours or to or from the place of work.
d. ~ Contact the person, eit,her directly or indirectly, by any means, including, but not limited to, in person, by
telephone, in writing, by public or private mail, by interoffice mail, by e-mail, by text message, by fax, or by
other electronic meami.
e. [gl Enter the person's woi"kplace.
F. 0 Other (specify):
0 As stated in Attac~ment 9f.
The respondent will be order,ed not to take any action to get the addresses or locations ofany protected person
unless the court finds good cause not to make the order.
,@ Stay-Away Order
a. I ask the court to order the respondent to stay at least_S0_0_ _ ___,yards away from (check all that app(y):
(1) ~ The employee.
(8) ~ The employee's vehicle.
(2) ~ The other persons listed in@.
(9) l;8j Other (specify):
All places that Petitioner conducts its business, as
described in Attachment 8b(2).
(3) r?.SJ The employee's workplace.
(4) D The employee's home.
(S) 0 The employee's school.
(6) D The school of the employee's
children.
(7) D The place of child care of the employee's
children.
This is not a Courrt Order.
Revised Jnnunry 1,
I
Pet_ition for Workplace Violence Restraining Orders
(Workplace Violence Prevention)
AA
WV-100, Page 5 of

Document received by the CA 1st District Court of Appeal.
V
Page 70
fl
I
I Case Number:
If the court orders the respo:ndent to stay away from all the places listed above, will he or she still be abl~ to get
IZJ Yes D No (If no, explain):
to his or her home, school, or job?
0 Response is stated on Attachment IOb.
@ Guns or Other Firearms. and Ammunition
Does the respondent own or possess any guns or other firearms? 0 Yes D No IZJ I don't know
If the judge grants a protective order, the respondent will be prohibited from owning, possessing, purchasing,
receiving, or attempting to purchase or receive a gun, other firearm, and ammunition while the protective order is
in effect. The respondent will dlso be ordered to turn in Jo law enforcement, or sell to or store with a licensed gun
dealer, any guns or firearms w/thin his or her immediate possession or control.
@ r8J Temporary Restraini:ng Order
·
.
Has the Respondent been told,that you were going to go to court to seek a TRO against him/her?
(.lfy_ou answered no, explain why below):
0 Yes IZ! No

Reasons are stated in Attachment 12.
Respondent's course of conduct and behavior in stalking, harassing, and assaulting Petitioner's employees are such
~hat great or irreparable hanniis likely to occur if immediate orders without notice are not issued.
@) D Request for Less Than Five Days' Notice of Hearing
You must have your papers personally served on the respondent at least five days before the hearing, unless the·
court orders a shorter time for service. (Form WV-200-JNFO explains what is proof ofpersonal service. Form
WV~200, Proof of Personal Service, may be used to show the court that the papers have been served.)
lf you want there to be fewer than five days between service and the hearing, explain why:

Reasons are stated in At1,.1chment I 3.
Revised January 1,
Pet:ition for Workplace Violence Restraining Orders
(Workplace Violence Prevention)
AA
WV-100, Page 6 of

Document received by the CA 1st District Court of Appeal.
I request that a Temporary Re~training Order (TRO) be issued against the Respondent to last until the hearing. I am
presenting form WV- I I0, Temporary Restraining Order, for the court's signature together with this Petition,
Page 71

.
.
@ D No Fee to Serve Orders
_
I ask the court to order the she,riff or marshal to serve the respondent with the others for free because this request
for orders is based on a credible threat of violence or stalking.
@ D Court Costs
I ask the court to order the respondent to pay my court costs.
@ [g] Additional Orders REiquested
I ask the court to make the fol)owing additional orders (.~pecify):
On April 22, 2019, Tesla will host an event at its headquarters at 3500 Deer Creek Road, Palo Alto, during which
Tesla employees will be demonstrating vehicle functionality in manufacturer-plated vehicles on nearby roads.
Respondent has expressed int6rest in this event on Twitter, and his Twitter followers have encouraged him to try to
follow and interfere with these drives. Respondent is a vocal Tesla detractor, claims to be a Tesla short-seller, and
tweets extensively about.his d!esfre to see Tesla (and its Autopilot technology) fail. To ensure the safety of Tesla
employees and the public, te01porary protection is needed, on April 22, 2019 only, for any Tesla employee driving a
Tesla vehicle with manufacturer plates within 5 miles of Tesla's headquarters at 3500 Deer Creek Road, Palo Alto,
California. Respondent is well aware of what Tesla manufacturing license plates look like, as he has previously
posted a picture of one, and noted that it was a "company vehicle." See Declaration of Christine Leslie, Attachment
A.
stay away order from any Tesl
@ Tesla therefore respectfully requests that the Court issue an additional SO-yard
at 3500 Deer Creek Road, Palo Alto,
vehicle with manufacturer plates within 5 miles of Tesla's headquarters
California on April 22, 2019 only.
Number of pages attached to this form, if any:
A
Date: April 19, Zachary J. Alinder
Lcrwyer 's name (if any)
I declare under penalty of pc~jury under the laws of the State of California that the information above and on
all attachments is true and comet.
Date: Ae_ril 19,
b. f)n
. ~t

, ,
___·_ _ _ _ _ __
! ' ~ vW_ct_O,<}\..Nl_~
· Christine Leslie '
· Name ofpetitioner

Signature
..
Staff Global Security Investigator, Security
Title
novlsod ,l~rioo,y 1. 20 i o
Petition for Workplace Violence Restraining Orders
(Workplace Violence Prevention)
AA
WV-100, Page 7 of
Document received by the CA 1st District Court of Appeal.
D Additional orders requested are stated in Attachment 17.
Page 72

I,
~-
ATTACHMENT 8b(2)
to P,~tition for Workpla~e Violence Restraining Order
Addresses of workplace:
(1) 45500 Fremont Boulevard
Fremont, CA
Document received by the CA 1st District Court of Appeal.
(2) 3500 Deer Creek Road
Palo Alto, CA
AA222
Page 73

I
PLAINTIFF/PETITIONER:
DEFENDANT/RESPONDENT:
Tesla, Inc.
MC-
CASE NUMBER:
Randeep Hothi
DECLARATION
(This form must be attached to another form or court paper before it can be filed in court.)
I, Christine Leslie, am the Staff Glbbal Security Investigator, Security, for Tesla, Inc.
All information stated in this declaration is based upon my own personal knowledge, my review and oversight of work
done by others who report to me, and information obtained from other Tesla team members in the course of my
investigation as outlined below.
I declare under penalty of perjury under the laws of the Stale of California that the foregoing Is true and correct.
Date: April 19,
('[)
Christine Leslie
(TYPE OR PRINT NAME)
'
(SIGNATURE OF DECLARANT)
D
·D
Fann Approved for Optional Use
Judicial Council of Callfomla
'~ /}
,_.J)_.
l.)4\0~\'~ (];Jz.)j\A)
Attorney for
Respondent
ATTACHED DECLARATION
D
D
Plaintiff ~ Petitioner
other (Specify):
Amorlcan LogalNol, Inc.
www.USCour1Forms.com
MC•031 [Rev, July 1, 2005]
AA
D
Defendant
Page 1 of
Document received by the CA 1st District Court of Appeal.
I have personally conducted an investigation into the threats made by the driver of a white Acura TL against Tesla
employees Matt Cross, Robert Te'mmerman, and James McDonald while they were attempting to film the Navigate on
Autopilot feature while driving a T~sla Model 3 on April 16, 2019. The summary attached hereto as Attachment A ·
explains how Tesla was able to id~ntify the individual stalking and harassing the above Tesla employees as Respondent
Randeep Hothi.
Page 74

Attachment A to Christine Leslie Declaration





On Twitter, the user with the @skabooshka handle identifies as part of a community of
Tesla short-sellers and frequently tweets with the hashtag "$TSLAQ," which is used
on line to indicate1the poster's hope or purported belief that Tesla will fail as a company._
As reported in the L.A. Times, the goal of the $TSLAQ movement is to see Tesla fail
•https ://www. lati1T,1 es.com/business/au tos/la-fi-h y-tesl a-sh ort-se Ilers-m usk-20 J90408story. htm I.
In spring 2018, th.e @skabooshka handle began regularly posting photos and video of the
Tesla Fremont factory employee parking lots and logistics lots. These locations are not
·
open to the public.
Tesla discovered that the Twitter account was used by one of two Fremont-based
brothers, Gagan and Randeep Singh Hothi, based on internet research and public record
searches and Tes/a security infrastructure, including security cameras on the premises.
o Gagan and Ran deep 's last address of record is Fremont with their father,
Kalvinde1: Singh Hothi. Public records indicate the three men live within less than
3 miles of the Tesla Fremont factory.
In August 2018 an Ario portable camera was found by Tesla Security Personnel mounted
on a utility pole at the private property of the Tesla Fremont factory, pointed at Tesla
private property. An Ario customer service representative provided the registered name,
Skabooshka, and email skabooshka@protonmail.com, for the camera in question.
Jn January 2019, a Cam Pak Hunting Trail portable camera was discovered inside autility
. box at a private parking lot at the Tesla Fremont factory, pointing in the same general
direction as the aforementioned Ario camera. The camera was examined, photographed,
. and left in place, and Tesla security cameras were adjusted to observe the location.
o At l 0:37 pm on January 3, 2019, a white Acura entered the Tesla factory parking
lot, CA license plate-• parking with headlights illuminating the utility box
containing the camera. A tall, bearded male with long hair exited the vehicle,
removed .the known device as well as another, moved them both several times, .
finally co'llccting them both and departing.
o California OMV records indicate the registered owner of the Acura is Kalvinder
Singh of Fremont, father and co-habitant of Gagan and Randeep Hothi.
o As described in a subsequent police report, Kalvinder identified his son Randeeµ
as the primary user of the identified vehicle.
2. Ran deep Hothi 1hits a Tesla employee with his car after he is caught trespassing.

On Thursday, February 21, 2019 at approximately 2: 11 pm, the aforementioned white
Acura was again seen at Tesla's Fremont. factory, and two Tesla security officers,
including Tyler James, were dispatched to .deliver a verbal notice of trespass.
88888-8\
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Document received by the CA 1st District Court of Appeal.
1. · Randeep Hothi's history of trespassing on Tesla's property and Tweeting about it.
Page 75

I
Document received by the CA 1st District Court of Appeal.
• At 2:22 pm, Mr. James, in uniform, approached the vehicle in the employee parking lot
·and tapped on the:driver side window.
,
• The driver, later i:-Jentified as Randcep Hothi by Fremont police, made eye contact with
the Tesla security officer, refused to roll down the window, and drove his car quickly and
recklessly out of t,he parking spot, striking Mr. James as he sped out of the parking lot.
• The Tesla employees followed him out of the lot and delivered the verbal notice of
trespass while the Acura was stopped al a stop sign in traffic on the private access road
_adjacent to the Tesla Fremont factory. Randeep did not roll down his window and did
not-cooperate with security personnel, and drove off as soon as traffic cleared.
88888-8\
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Page 76
Tesla reported the matter to the police. On 2/27/2019, the Fremont Police Department
con finned that R~ndeep Hothi was the driver of the vehicle involved in the 2/21 incident
Following their ipvestigation, the Fremont Police Department has prepared a formal No
Trespassing order to Randeep Hothi and has attempted to deliver it to him. The police
have informed T<,!sla that effo1is to deliver the' No Trespassing order have been
unsuccessful bec.ause Randeep has either ignored or refused the request of Fremont police
officers to meet.
3. · Ran deep Hothi ;endangers a crew of Tesla employees driving on public roads.


On 4/16/2019, a crew of Tesla employees was driving on Highway 880 in a Model vehicle with ma~ufacturers' license plates and externally mounted camera equipment,
The crew-comprised of Matt Cross, Robert Temmerman, and James McDonald-was
taking video to demonstrate the capabilities of Tesla's Autopilot and Navigate on
Autopilot features, which can semi-autonomously drive the vehicle on the highway (with
human supervision) by steering, braking and accelerating, and changing lanes, among
other things.
During the drive, the crew observed a white Acura TL driving unsafely and erratically,
following them c)nd approaching the vehicle from all sides, and taking photos. While on
the freeway operating at speed, the vehicle would move very close to the Tesla .vehicle
and at times swe,rve toward the Tesla's lane, at one point triggering the vehicle's sidecollision (crash) avoidance system, At another point, the Tesla vehicle had slowed down
88888·8\
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Page 77

I
• The @skabooshka Twitter account corroborates the team's account of events, and
reinforces the connection between the @skabooshka account, the Acura TL, and Randeep
Hothi.
.
• In particular, on Ap1'i1 I6 and April 18, the @Skabooshka account began tweeting photos
of a Tesla photography crew driving on 880 in a Tesla vehicle with manufacturer plates.
The tweets included pictures and detailed the entire route of the car and crew .
88888-8\
. 4.
AA
Document received by the CA 1st District Court of Appeal.
in preparation of the toll booth ahead. The white Acura TL was in the left lane behind the
Tesla.vehicle, but was approaching very fast. When the white Acura TL realized that the
Tesla vehicle was slowing down, the driver attempted to merge right behinq the Tesla
vehicle but had to then rapidly brake, otherwise it would have driven past the Tesla
vehic!e" at his spe1~d. The Tesla crew felt this was a very dangerous and threatening
maneuver.
• The video crew had no previous knowledge of the @skabooshka/Randeep Hothi case, but
were so concerned with the behavior that they decided to call the police.
• The crew was able to take a photo of the car, which was the same white Acura TL
described above that is known to be driven by Randeep Hothi. At1er being shown a
photo ofRandeep Hothi, two of the crew members confirmed they believed that Randeep
Hothi was the driver of the white Acura TL on the day they were followed und harassed.
Page 78
• As shown by the below screenshots, the @skabooshka account began tweeting about the
drive at 1:29 PM PDT, and the team raised their concerns at about 11 :30 AM PDT. He
then followed up yvith additional tweets on April 18, 2019:
skabooshka
@:;,kabumi1ka
Tesla tis currently conducting its
autop ilot / FSD demo recording
northpound on 1-880, using a red dual
motor Model 3, w/ two backseat ·
came:ramen and trunk-mounted gopro.
Vehicle entered 1-880 near Fremont at
.',
I '. ,.•\.,
1PM ,;v .:(:i

\l)
! '\
f:]
()
()
1'
'l\'loot your reply
skabooshka @skaboo,;hk,1 · 1Oh
The vehicle traveled ap:~roxlmately 35 miles from 1:00PM 10 1:40PM, entered I·
880N in FremonVUnion City, conducted trivial lane changes (merging from
lcftmost-lano into right jano and back), and concludod Its "automous" drivo at
the Treasure Island c~lt on the Bay Bridge.
' ·~_M0Xl.t,'
... ·OJablO
·,, Sil)to
. P£<1ii
Danville
Son FJomor
e:i
il. }5)\t;.fYi._,"_·, .... •·: ·.., :;.
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() !i
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!5-L-W!Jtl' Pit:J~
1)
·
5-
AA
Document received by the CA 1st District Court of Appeal.
1:2\l l'M • ,Ill Apr 2019
Page 79

skabooshka @i,kabooshko · 1Oh
v
The demo conv:eniently bypassed the toll booth, by using lanes compatible with
the "FasTrak" tr:ansponder.
Note that the vehicle did not (and most assuredly does not have the capability
to) follow tralfic;laws, Bay Bridge entrance speed limit is 25 MPH, The vehicle
drove at 45 MPH
()
skabooshka
Q
;''ii;,,,
!
V
®skubooshka
Photogr:aphs: .ri '.'L<\ recording the
"autonomous driving" demo for its socalled "Autonomy Investor Day" (Apr
22).
Mounted, two cameras: one rear~facing
on the trunk, one inside directed
towards the steering and center .
console·.
Note th\3 license plate: MFG632779S. a
i
u,:, AM·
I
10 Apr
~o 1:
o The behavior of the Acura driver, as recounted by the crew, is also consistent with ·
@skabooshka's appa,:ent obsession, as documented on Twitter, with testing - and
disputing - the capabilities of Autopilot.
88888-8\
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Document received by the CA 1st District Court of Appeal.
aV
tl s
Page 80 ~-

I
4. Randeep Hothi Should Be Restrained from Interfering With Tesla's Upcoming
Autonomy Investor Day on April 22 nd in Palo Alto

skabooshka @;skai,r1Jsht.c1 · Apr J.....................,.-,,~--··-1~~1.a is curriently c011c1t,.1<:t'ing itt a1.1topilot / ~SI) d~mo re.cording northbot1r,d en
1-680, using a red du~! n1otor Model 3. w/ two back~eat carne-r;1m1;-n and tnmkrnounted gopro. Vehicli! ente-ri:~ C·8S0 near rremcrit -at 1PM. ) !\i !\
1J ,,
n
r.n
('.) .rm
EJ
follow
You sure it isn't a Model Y? It's hard to tell
them apart.
You should help with the testing. Brake in
front of the car, swerve into its lane, etc. Just
to make sure it's a realist FSD test
$TSLA $TSLAQ
2:24 PM,, lt\ hp,
Q)
88888-8\
n
I]
-7-
AA
Document received by the CA 1st District Court of Appeal.
From the @skabooshka Twitter account, it appears that Randeep Hothi has a particular
interest in Tesla's, ,upcoming Autonomy Investor Day, which will take place this coming
Monday, April 22 at Tesla's headquarters at 3500 Deer Creek Road, Palo Alto,
California. See https://twitter.com/skabooshka/status/l l l 8938028385263617. For this
event, Tesla will l1ost investors for presentations about its self-driving technology and
roadmap, and investors will be able to take test-drives to experience Autopilot firsthand,
including features and functionality that are under active development (and which are not
publicly known or available). These vehicles will be on the roads near and around
Tesla's headquarters, and will bear manufacturers' license plates,just like the vehicle that
Randeep Hothi fqllowed on 4/17/19.
• After his posts about the 4/17/19 drive, Randeep's followers applauded him and sent him
tweets both encm;iraging him to follow Tesla's cars at the investor event, and to try to
sabotage Tesla's vehicles on the road. Examples are below:
Page 81
I
~kabooshka @skaboo5hk~ • .'l.lh
Q
,.;t,~,
-lifl/lf
f
I]
1.l
(J ll
El
Main Line Dad @lviLDD,,d. · 21h
Bravo sir.
()
v
As with JII things Tesla. particularly with regard to its apparent technological
prowess. the 'Autonomy Investor Day" will be saturated with false p1omi;e1,
misleading suggestions. ancl lures to credulity.
c
n
V
.
; Thinking Turtle
~ !@th1nkingxtwtle
,,.f{•·,•·
Replying' to ·
It wi.I1 be funny if it crashed.
11:20 M;I · 1B 1\pr
tl
B

skabooshka @skabooshka • Apr Hi
v
Tesla is currently conducting its autopilot/ FSD demo recording northbound on
1-880. using a red dual motor Model .3, w/ two backseat cameramen ancl trunk•
mounted gopro. Vehicle entered 1-880 near Fremont st 1PM. STSLA
()
:n
B
6a
.
·,
(\ .. Follow / )
' Corey
(~1rraderS
V
Driv,e along with it and create random events
for it to react to
2:02 PM 16 Apr
Q -~
n.
Morten Lund 1,£>rncrtenh.1ndB9 • ;\pr -i Replying to (~:trnder5l @sk;;b0r1shkJ
Worth having in mind.
•~£>Tesla
88888-8\
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AA
V
Document received by the CA 1st District Court of Appeal.
0
Page 82

MC-PLAINTIFF/PETITIONER:
DEFENDANT/RESPONDENT:
CASE NUMBER:
Tesla, Inc.
Randeep Hothi
DECLARATION
(This form must be attached to another form or court paper before ii can be filed in court)
I, Tyler James, am a Senior Priitection Specialist for Tesla, Inc.
All information stated in this declaration is based upon my own personal knowledge, unless stated on information and
·
belief, and if stated on information and belief, I believe those things to be true..
I declare under penalty of perjury 1,nder the laws of the State of California that the foregoing is true and correct.
Date: April 19,
Tyler James
. (TYPE OR PRINT NAME)
D
Form ~pprovcd for Opllonal u,o
Attorney for
Respondent
ATTACHED DECLARATION
'J1Jdici1Jl Cwncil of California
MC•0J I (Rev, July 1, 2005)
AAI
aintiff
D
Petitioner
D
Defendant
Other (Specify): Witness
American LegalNet, Inc,
www.USCourtFonm:.com
Page1 of
Document received by the CA 1st District Court of Appeal.
On Thursday, February 21st 2q19 at approximately 2: 11 pm, I was asked to respond to a BOLO hit near the South
parking lot of the Tesla factory ,located at 45500 Fremont Blvd. I identified the vehicle in question as a White Acura TL
and noted its license plate number. I followed the Acura In my company patrol vehicle at a reasonable distance.
Eventually I parked two parking spots to the West of the White Acura. My colleague who was with me at the time
directed that we would approach the White Acura and make contact. Because I was wearing a uniform that identified me
as a Tesla security officer, I wd,uld be the contact officer and he would be the cover officer to obtain photographs . We
approached the Vehicle at 2:22 pm. The driver made eye contact with me and would not roll down his windows to
communicate. He then at a fa~t rate of speed exited the parking stall and the drivers' side of his vehicle made contact
with my left knee as he drove out of the stall.
Page 83

I
MC-PLAINTIFF/PETITIONER:
DEFENDANT/RESPONDENT:
CASE NUMBER:
Tesla, Inc.
Randeep Hothi
DECLARATION
(This form must be attached to another form or court paper before it can be filed in court.) ·
I, Matt Cross, am a Senior Content Producer for Tesla, Inc.
All information stated in this declaration is based upon my own personal knowledge, unless stated on information and
belief, and if stated on information and belief, I believe those things to be true.
On April 16, 2019, my colleagues i~obert Temmerman, James McDonald and I were in a Tesla Model 3 to film its
Navigate on Autopilot feature.
We were driving northbound on l-~80 around 11 :30 a.m. and had been driving for approximately 5 minutes near the Auto
Mall Parkway when Rob noticed a!white Acura TL on our right side approaching us from behind.
We saw that the male driver was observing us and our car, and he started taking photos and videos on his phone. He
·
stayed near us for about 10 minut(is, maneuvering around our car.
The driver stayed within visual contact with our car for the rest of our drive to Treasure Island.
As we approached the toll plaza to the Bay Bridge, the Model 3 slowed down to 35mph. The Acura TL had been 100 ft
behini:J us on the left, and the driver swerved into our lane, braked abruptly, and came up very close behind us as we
slowed down.
We proceeded to Treasure Island, but the driver continued to follow us off the freeway, at which point I called the San
Francisco Police Department. We then drove around making random turns to see if he was still goin.g to follow us. He
did. As we circled around Treasure Island talking to the police, he turned off on a different road. I was told that there
were no officers on Treasure Island, and therefore no officers would be able to arrive within the next 30 minutes. Since
the driver was no longer following us, we decided to start drivi_ng back and told the police officer not to send anybody.
The driver had been following us fiJr at least 35 minutes. His erratic and dangerous conduct cause me to fear for my
~ersonal safety and for the person:al safety of Rob and James, which is why I called the police .
.
,
I declare under penalty of perjury under the laws of the Stale of California that the foregoing is true and correct.
/4@.
Date: April 19,
Matt Cross
(TYPE OR PRINT NAM~)
c~
D
D
Form Approved lor Optional use
Judicial Cmmcil ol California
MC-031 \Rov, July 1, 2005]
-·----.,
(SIGNATURE OF DECLARANT)
Attorney for D Plaintiff D Petitioner D Defendant
Respondent C8J Other (Specify): Witness
ATTACHED DECLARATION
Amorlcan LegalNet, Inc.
www.USCourtForms.com
AA
Page 1 of
Document received by the CA 1st District Court of Appeal.
We were in the far left lane, and he was in the lane next to us on the right. He then started swerving out of his lane
towards us. This happened twice, and he swerved close enough to trigger the Model 3's side-collision avoidance feature.
Page 84
MC-CASE NUMBER:
PLAINTIFF/PETITIONER: Tesla, lhc.
DEFENDANT/RESPONDENT: Randeep Hoth
DECLARATION
(This fonn must be attached to another form or court paper before it can be filed in court.)
I, Robert Temmerman, am an Associate Content Producer, Design & Styling, for Tesla, Inc.
All information stated in this declaration is based upon my own personal knowledge, unless stated on information and
belief, and if stated on information and belief, I believe those things to be true.
On April 16, 2019, I was driving a .Tesla Model 3 with my colleagues Matt Cross and James McDonald in the backseat to
film the Navigate on Autopilot feat:ure.
When we came into contact with the white Acura TL referenced in Matt's declaration, I was able to tell that the driver
imme:diately recognized that we were filming. The driver pulled out his phone to record us, and when doing so, began to
merge into our lane directly parallE,31 to our car. Because the Acura TL continued to come within 12 to 18 inches of our
vehicle, the car's Autopilot feature, repeatedly caused the car to move over in the lane to avoid a side collision: The
driver eventually drove around all four sides of the car, presumably to test the car's various features.
Towards the end of the drive, we lost sight of the Acura TL for a few minutes. However, as we drove onto the on-ramp
leading to the Bay Bridge and wer e rounding a slighly curved corner, I saw the driver reappear at a high speed. He
switched lanes from the right lane-adjacent to ours into our lane. Because the car's Autopilot had slowed us down to mph i,n about 4 seconds, the only Y"ay I was able to avoid a cdlision was to disengage Autopilot and accelarate rapidly.
This is when Matt decided to call the police, as we were all fearful for our personal safety and the driver of the Acura TL
appeared to be either stalking or ~arassing us.
I declare under penalty of perjury undeir the laws of the State of California that the foregoing is true and correct.
Date: April 19,
Robert Temmerman
(SIGNATURE() ~ARANT)
!TYPE OR PRINT NAME)
D
D
form Approved far Optional use
Judicial Council of California
MC-031 IRov July 1, 2005)
Attorney for
Respondent
ATTACHED DECLARATION
AA
D
r8I
Plaintiff D Petitioner D Defendant
Other (Specify): Witness
American LegafNot, Inc.
www.USCourtForms.com
Page 1 or
Document received by the CA 1st District Court of Appeal.
1
Page 85
1•
.,,..--
MC-PLAINTIFF/PETITIONER:
DEFENDANT/RESPONDENT:
Tesla, Irle.
CASE NUMBER:
Randeej:> Hothi
DECLARATION
(This form must be attached to another form or court paper before it can be filed in court.)
I, James McDonald, am a video e~itor for Tesla, Inc.
All information stated in this declai·ation is based upon my own personal knowledge, unless stated on information and
belief, and if stated on information:and belief, I believe those things to be true.
I declare under penalty of perjury undiir the laws of the State of California that the foregoing is true and correct.
Date: April 19,
James McDonald
(TYPE OR PRINT NAME)
D
D
rorm Approved for Oplionsl Use
Judicial Council of California
MC-031 [Rov July 1, 2005)
Attorney for
Respondent
ATTACHED DECLARATION
AA
D
Plaintiff D Petitioner O Defendant
Other (Specify): Witness
American LogolNct, Inc.
www.USCour1Formo.com
Page 1 of
Document received by the CA 1st District Court of Appeal.
I have reviewed the Declarations 6f Matt Cross and Robert Temmerman and agree with their accounts of the events on ·
April 16, 2019. The erratic and da'.ngerous actions of the driver of the white Acura TL caused me to fear for my personal
safety and for the safety of my coUeagues.
Page 86 Document received by the CA 1st District Court of Appeal.
EXHIBIT C
AA236
Page 87 WV-
Clerk stamps date here when form is filed.
Temporary Restraining Order
Petitioner (Employer)
a. Name: Tesla, Inc.
Lawyer for Petitioner (if any, for this case):
Name: Zachary J. Alinder
State Bar No.: Firm Name: Sideman & Bancroft LLP
b. Your Address (If you have a lawyer, give your lawyer’s information.):
Address: One Embarcadero Center, 22nd Floor
Fill in court name and street address:
City: San Francisco
State: CA
Zip:
Telephone: 415-392-
Fax: 415-392-
Superior Court of California, County of
Alameda
Rene C. Davidson Alameda County
Courthouse
1225 Fallon Street
Oakland, CA
E-Mail Address: zalinder@sideman.com
Employee (Protected Person)
Full Name: Matt Cross
Court fills in case number when form is filed.
Respondent (Restrained Person)
Full Name: Randeep Hothi
Case Number:
RG
Description:
Sex:

M
F Height: 6'0"
Hair Color: BLK
Weight:
Eye Color: BRO
Date of Birth:
Age:
Race: Z
Home Address (if known):
State:
City:
Relationship to Employee:

Zip:
None
Additional Protected Persons
In addition to the employee, the following family or household members or other employees are protected by the
temporary orders indicated below:
Full Name
Sex Age Household Member?
Relation to Employee
Yes ✔ No
Colleague
Robert Temmerman
M
James McDonald
M
Other Tesla employees as noted belo

Yes
Yes

Colleague
No
No
Additional protected persons are listed at the end of this Order on Attachment 4.
Expiration Date
This Order expires at the end of the hearing scheduled for the date and time below:
Date:
05/07/
Time:
1:30pm
a.m.

p.m.
Document received by the CA 1st District Court of Appeal.

This is a Court Order.
Judicial Council of California, www.courts.ca.gov
Revised January 1, 2017, Mandatory Form
Code of Civil Procedure, §§ 527.8 and 527.Approved by DOJ
Temporary Restraining Order (CLETS-TWH)
(Workplace Violence Prevention)
AA
WV-110, Page 1 of 5
Page 88 Case Number:
RGTo the Respondent:
The court has issued the temporary orders checked as granted below. If you do not obey these orders, you can be
arrested and charged with a crime. You may have to go to jail for up to one year, pay a fine of up to $1,000, or
both.
6 Personal Conduct Orders
Not Requested
Denied Until the Hearing

Granted as Follows:
(1)

(2)
(3)
(4)

(5)
(6)


(7)



Harass, molest, strike, assault (sexually or otherwise), batter, abuse, destroy personal property of, or
disturb the peace of the person.
Commit acts of violence or make threats of violence against the person.
Follow or stalk the person during work hours or to or from the place of work.
Contact the person, either directly or indirectly, in any way, including, but not limited to, in person, by
telephone, in writing, by public or private mail, by e-mail, by fax, or by other electronic means.
Enter the workplace of the person.
Take any action to obtain the person’s address or locations. If this item is not checked, the court has
found good cause not to make this order.
Other (specify):
Other personal conduct orders are attached at the end of this Order on Attachment 6a(7).
Personal conduct order extends to all Tesla employees at 45500 Fremont Boulevard,
Fremont, CA 94538 or 3500 Deer Creek Road, Palo Alto, CA b. Peaceful written contact through a lawyer or a process server or other person for service of legal papers related
to a court case is allowed and does not violate this order. However, you may have your papers served by mail
on the petitioner.
Stay-Away Order
Not Requested
a. You must stay at least
Denied Until the Hearing

Granted as Follows:
yards away from (check all that apply):
(1)

The employee
(7)
(2)

Each other protected person listed in
(8) ✔ The employee’s vehicle
(3)

The employee’s workplace
(9)
The employee’s children’s place of child care

Other (specify):
45500 Fremont Boulevard, Fremont, CA
94538 and 3500 Deer Creek Road, Palo
Alto, CA
(4)
The employee’s home
(5)
The employee’s school
(6)
The employee’s children’s school
b. This stay-away order does not prevent you from going to or from your home or place of employment.
Document received by the CA 1st District Court of Appeal.
a. You are ordered not do the following things to the employee
and to the other protected persons listed in 4 :

This is a Court Order.
Revised January 1,
Temporary Restraining Order (CLETS-TWH)
(Workplace Violence Prevention)
AA
WV-110, Page 2 of 5
Page 89 Case Number:
RG
No Guns or Other Firearms and Ammunition
a. You cannot own, possess, have, buy or try to buy, receive or try to receive, or in any other way get guns, other
firearms, or ammunition.
b. You must:
(1) Sell to or store with a licensed gun dealer or turn in to a law enforcement agency any guns or other firearms
in your immediate possession or control. This must be done within 24 hours of being served with this
Order.
(2) File a receipt with the court within 48 hours of receiving this Order that proves that your guns or firearms
have been turned in, sold, or stored. (You may use Form WV-800, Proof of Firearms Turned In, Sold, or
Stored for the receipt.)
c.
Other Orders
✔ Granted as Follows (specify):
Not Requested
Denied Until the Hearing
10-yard stay away order as to any Tesla vehicle with manufacturer plates within 5 miles of
Tesla's headquarters at 3500 Dear Park Rd., Palo Alto, CA on April 22,
Additional orders are attached at the end of this Order on Attachment 9.
To the Petitioner:
10 Mandatory Entry of Order Into CARPOS Through CLETS
This Order must be entered into the California Restraining and Protective Order System (CARPOS) through the
California Law Enforcement Telecommunications System (CLETS). (Check one):
a.

The clerk will enter this Order and its proof-of-service form into CARPOS.
b.
The clerk will transmit this Order and its proof-of-service form to a law enforcement agency to be entered
into CARPOS.
c.
By the close of business on the date that this Order is made, the employer or the employer’s lawyer should
deliver a copy of the Order and its proof-of-service form to the law enforcement agencies listed below to
enter into CARPOS:
Name of Law Enforcement Agency
Address (City, State, Zip)
Additional law enforcement agencies are listed at the end of this Order on Attachment 10.
✔ Ordered
11 No Fee to Serve (Notify) Restrained Person
The sheriff or marshal will serve this Order without charge because:
a.
b.

Not Ordered
The Order is based on a credible threat of violence or stalking.
The petitioner is entitled to a fee waiver.
Document received by the CA 1st District Court of Appeal.

The court has received information that you own or possess a firearm.
This is a Court Order.
Revised January 1,
Temporary Restraining Order (CLETS-TWH)
(Workplace Violence Prevention)
AA
WV-110, Page 3 of 5
Page 90 Case Number:
RG
Number of pages attached to this Order, if any:
Date:
04/19/Judicial Officer
Warnings and Notices to the Restrained Person in You Cannot Have Guns or Firearms
You cannot own, have, possess, buy or try to buy, receive or try to receive, or otherwise get guns, other firearms, or
ammunition while this Order is in effect. If you do, you can go to jail and pay a $1,000 fine. You must sell to or store with
a licensed gun dealer or turn in to a law enforcement agency any guns or other firearms that you have or control as stated
in item 8 above. The court will require you to prove that you did so.
Notice Regarding Nonappearance at Hearing and Service of Order
If this address is not correct or you wish to verify that the Temporary Restraining Order was converted into a restraining
order at the hearing without substantive change, or to find out the duration of the order, contact the clerk of the court.
After You Have Been Served With a Restraining Order
• Obey all the orders.
• Read Form WV-120-INFO, How Can I Respond to a Petition for Orders to Stop Workplace Violence?, to learn
how to respond to this Order.
• If you want to respond, fill out Form WV-120, Response to Petition for Workplace Violence Restraining Orders,
and file it with the court clerk. You do not have to pay any fee to file your response if the petition claims that you
threatened violence against or stalked the employee, or placed the employee in reasonable fear of violence.
Document received by the CA 1st District Court of Appeal.
If you have been personally served with this Temporary Restraining Order and Form WV-109, Notice of Court Hearing,
but you do not appear at the hearing either in person or by a lawyer, and a restraining order that is the same as this
Temporary Restraining Order except for the expiration date is issued at the hearing, a copy of the order will be served on
you by mail at the address in item 3 .
• You must have Form WV-120 served on the petitioner or the petitioner’s attorney by mail. You cannot do this yourself.
The person who does the service should complete and sign Form WV-250, Proof of Service of Response by Mail. File
the completed proof of service with the court clerk before the hearing date or bring it with you to the hearing.
• In addition to the response, you may file and have declarations served, signed by you and other persons who have
personal knowledge of the facts. You may use Form MC-030, Declaration, for this purpose. It is available from the
clerk’s office at the court shown on page 1 of this form or at www.courts.ca.gov/forms. If you do not know how to
prepare a declaration, you should see a lawyer.
• Whether or not you file a response, you should attend the hearing. If you have any witnesses, they must also go to the
hearing.
• At the hearing, the judge can make restraining orders against you that last for up to three years. Tell the judge why you
disagree with the orders requested.
This is a Court Order.
Revised January 1,
Temporary Restraining Order (CLETS-TWH)
(Workplace Violence Prevention)
AA
WV-110, Page 4 of 5
Page 91 Case Number:
RG
Instructions for Law Enforcement
Enforcing the Restraining Order
This order is enforceable by any law enforcement agency that has received the order, is shown a copy of the order, or has
verified its existence on the California Restraining and Protective Orders System (CARPOS). Agencies are encouraged to
enter violation messages into CARPOS. If the law enforcement agency has not received proof of service on the restrained
person, the agency must advise the restrained person of the terms of the order and then must enforce it. Violations of this
order are subject to criminal penalties.
Start Date and End Date of Orders
This order starts on the date next to the judge’s signature on page 4. The order ends on the expiration date in item 5 on
page 1.
If the Protected Person Contacts the Restrained Person
Document received by the CA 1st District Court of Appeal.
Even if the protected person invites or consents to contact with the restrained person, this order remains in effect and must
be enforced. The protected person cannot be arrested for inviting or consenting to contact with the restrained person. The
order can be changed only by another court order. (Pen. Code, § 13710(b).)
Conflicting Orders—Priorities for Enforcement
If more than one restraining order has been issued, the orders must be enforced according to
the following priorities: (See Pen. Code, § 136.2, Fam. Code, §§ 6383(h)(2), 6405(b).)
1. EPO: If one of the orders is an Emergency Protective Order (form EPO-001) and is more restrictive than other
restraining or protective orders, it has precedence in enforcement over all other orders.
2. No Contact Order: If there is no EPO, a no-contact order that is included in a restraining or protective order has
precedence over any other restraining or protective order.
3. Criminal Order: If none of the orders includes a no contact order, a domestic violence protective order issued in a
criminal case takes precedence in enforcement over any conflicting civil court order. Any nonconflicting terms
of the civil restraining order remain in effect and enforceable.
4. Family, Juvenile, or Civil Order: If more than one family, juvenile, or other civil restraining or protective order
has been issued, the one that was issued last must be enforced.
(Clerk will fill out this part.)
—Clerk's Certificate—
Clerk’s Certificate
[seal]
I certify that this Temporary Restraining Order is a true and correct copy of the
original on file in the court.
Date:
Clerk, by
, Deputy
This is a Court Order.
Revised January 1,
Temporary Restraining Order (CLETS—TWH)
(Workplace Violence Prevention)
AA
WV-110, Page 5 of 5
Page 92 WV-
Clerk stamps date here when form is filed.
Notice of Court Hearing
1 Petitioner (Employer)
a. Name: Tesla, Inc.
Lawyer for Petitioner (if any for this case):
Name: Zachary J. Alinder
State Bar No.: Firm Name: Sideman & Bancroft LLP
b.
Address (If you have a lawyer, give your lawyer’s information.):
Address: One Embarcadero Center, 22nd Floor
Fill in court name and street address:
Superior Court of California, County of
State: CA
Zip: City: San Francisco
Telephone: 415-392-Fax: 415-392-E-Mail Address: zalinder@sideman.com
2 Employee in Need of Protection
Alameda
Rene C. Davidson Alameda County
Courthouse
1225 Fallon Street
Oakland, CA Fill in case number:
Full Name: Matt Cross
Case Number:
3 Respondent (Person From Whom Protection Is Sought)
Full Name: Randeep Hothi
The court will complete the rest of this form.
4 Notice of Hearing
A court hearing is scheduled on the request for restraining orders against the respondent:
Name and address of court if different from above:
Hearing
Date
Date: 05/07/Dept.:

Time: 1:30pm
Room:
Hayward Hall of Justice
24405 Amador Street
Haywrd, CA
5 Temporary Restraining Orders (Any orders granted are on Form WV-110, served with this notice.)
a.
Temporary Restraining Orders for personal conduct and stay away orders as requested in Form WV-100,
Request for Workplace Violence Restraining Orders, are (check only one box below):
(1) ✔ All GRANTED until the court hearing.
(2)
All DENIED until the court hearing. (Specify reasons for denial in b, below.)
(3)
Partly GRANTED and partly DENIED until the court hearing. (Specify reasons for denial in
b, below.)
Judicial Council of California, www.courts.ca.gov
Revised January 1, 2012, Mandatory Form
Code of Civil Procedure, § 527.Approved by DOJ
Notice of Court Hearing
(Workplace Violence Prevention)
AA
Document received by the CA 1st District Court of Appeal.
RG
WV-109, Page 1 of 3
Page 93 Case Number:
RGb. Reasons that Temporary Restraining Orders as requested in Form WV-100, Petition for Workplace
Violence Restraining Orders, for personal conduct or stay away are denied are:

(1)
The facts as stated in Form WV-100 do not sufficiently show reasonable proof that the employee
has suffered unlawful violence or a credible threat of violence by the respondent, and that great or
irreparable harm to the employee would result if a temporary restraining order is not issued.
(2)
Other (specify):
As stated on Attachment 5b.
Service of Documents by the Petitioner
a. WV-100, Petition for Workplace Violence Restraining Orders (file-stamped)
b. ✔ WV-110, Temporary Restraining Order (file-stamped) IF GRANTED
c. WV-120, Response to Petition for Workplace Violence Restraining Orders (blank form)
d. WV-120-INFO, How Can I Respond to a Petition for Workplace Violence Restraining Orders?.
e. WV-250, Proof of Service of Response by Mail (blank form)
f.
Other (specify):
Date: 04/19/Judicial Officer
To the Petitioner:
• The court cannot make the restraining orders after the court hearing unless the respondent has been personally
given (served) a copy of your request and any temporary orders. To show that the respondent has been served,
the person who served the forms must fill out a proof of service form. Form WV-200, Proof of Personal
Service, may be used.
• For information about service, read Form WV-200-INFO, What Is “Proof of Personal Service”?
• If you are unable to serve the respondent in time, you may ask for more time to serve the documents. Use
Form WV-115, Request to Continue Court Hearing and to Reissue Temporary Restraining Order.
Revised January 1,
Notice of Court Hearing
(Workplace Violence Prevention)
AA
Document received by the CA 1st District Court of Appeal.
At least ✔ five
days before the hearing, someone age 18 or older—not you or anyone to be
protected—must personally give (serve) a court file-stamped copy of this Form WV-109, Notice of Court Hearing,
to the respondent along with a copy of all the forms indicated below:
WV-109, Page 2 of 3
Page 94 Case Number:
RGTo the Respondent
• If you want to respond to the request for orders in writing, file Form WV-120, Response to Request for
Workplace Violence Restraining Orders, and have someone age 18 or older—not you or anyone to be
protected—mail it to the petitioner.
• The person who mailed the form must fill out a proof of service form. Form WV-250, Proof of Service of
Response by Mail, may be used. File the completed form with the court before the hearing and bring a copy with
you to the court hearing.
• Whether or not you respond in writing, go to the hearing if you want the judge to hear from you before making
an order. You may tell the judge why you agree or disagree with the orders requested.
• You may bring witnesses and other evidence.
• At the hearing, the judge may make restraining orders against you that could last up to three years and
Request for Accommodations
Assistive listening systems, computer-assisted real-time captioning, or sign language
interpreter services are available if you ask at least five days before the hearing. Contact the
clerk’s office or go to www.courts.ca.gov/forms for Request for Accommodations by Persons
with Disabilities and Response (Form MC-410). (Civ. Code, § 54.8.)
(Clerk will fill out this part.)
—Clerk’s Certificate—
I certify that this Notice of Court Hearing is a true and correct copy of the original on file in the court.
Clerk’s Certificate
[seal]
Date:
Clerk, by
Revised January 1,
, Deputy
Notice of Court Hearing
(Workplace Violence Prevention)
AA
Document received by the CA 1st District Court of Appeal.
may order you to sell or turn in any firearms that you own or possess.
WV-109, Page 3 of 3
Page 95 Document received by the CA 1st District Court of Appeal.
EXHIBIT D
AA245
Page 96 Illllll lllll lllll lllll lllll lllll
FILED

ALAMEDA COUNTY

SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF ALAMEDA
ESLA, et al,

Plaintiffs,

v.
No. RG 19-ORDER ON REQUESTS FOR DISCOVERY

OTHI, et al,
Defendants.

Petitioner Tesla and Respondent Hothi have filed letter briefs with the court on the issue

of whether pre-hearing discovery should be permitted in this case. After consideration of the

letters, IT IS ORDERED: The requests for pre-hearing discovery are GRANTED IN PART and

DENIED IN PART. The motions for discovery are GRANTED to the extent they request the

production of photographic, audio, or video recordings of the alleged incidents on February
and April 6, 2019. Each party shall produce to the other any such evidence on or before Tuesday
July 16, which is 10 days of the hearing scheduled for Friday July 26, 2019. The motions are

otherwise DENIED.
Ill
AA
Document received by the CA 1st District Court of Appeal.
9
Page 97
BACKGROUND
This case is an action under CCP 527.6 and CCP 527.8 for civil harassment action and
workplace harassment.
Petitioner Tesla alleges that respondent Randeep Hothi engaged in violence, threats of

violence or a course of conduct warranting the issuance of a pennanent order. Tesla's petition is
based on two incidents: (1) an incident on February 21, 2019 in the parking lot of Tesla's

Fremont facility wherein respondent "hit Tesla's security employee ... with his car" and then
"fled the scene" in a "reckless manner" as he left the parking lot and (2) an incident on April 6,

2019 on public roads wherein respondent "stalked harassed and endangered" a Tesla Model
automobile engaged in autonomous driving testing.

On April 19, 2019, Tesla filed the action. On April 19, 2019, the court entered a
temporary restraining order and set a hearing for May 7, 2019. Hothi requested a continuance of
the hearing to pennit time for discovery. The court granted the request and re-set the hearing to

May 21, 2019. On May 21, 2019, the court requested briefing on whether the court can pennit
discovery and also continued the matter to July 26, 2019. The length of the continuance was to
accommodate counsels' schedules and was not to permit time for discovery.
Hothi's letter to the court dated May 23, 2019, states that Hothi seeks discovery,

including video, photographic and audio recordings, incident and investigation reports, "non-

privileged statements," correspondence, and police reports relating to both incidents. Hothi

makes 11 requests in all.

ORDER ON DISCOVERY
CCP section 527.6 does not provide for discovery in harassment cases, including actions

alleging workplace violence. Hothi 's letter brief of 5/23/19 at page 4 acknowledges "there is

AA
Document received by the CA 1st District Court of Appeal.
8
Page 98
nonnally no opportunity for discovery" in summary proceedings seeking harassment-related

restraining orders. Tesla and Hothi both cite Thomas v. Quintero (2005) 126 Cal.App.4th 635,

650 fn 11, which states:

There is no provision under section 527.6 allowing for discovery, and in any case,
under the civil harassment scheme there is insufficient time in which to conduct
discovery. (See generally Byers v. Cathcart, supra, 57 Cal.App.4th at p. 811, Cal.Rptr.2d 398; Diamond View Limitedv. Herz, supra, 180 Cal.App.3d 612, 619620, fn. 8,225 Cal.Rptr. 651.) Section 527.6, subdivision (d) requires the trial court
to "receive any testimony that is relevant" at the hearing.


Byers v. Cathcart, 57 Cal.App.4 th at 811, states that CCP 527.6 "provides a quick and truncated
procedure." Diamond View Limited v. Herz (1986) 180 Cal.App.3d 512, 519 fn 8, states,

"section 527.6 is a special statute which significantly changed the ordinary procedures and

requirements in actions for injunctive relief by altering the provisions relating to pleading,
temporary restraining orders, undertakings, attorney's fees, discovery and trial."
The court holds as a matter of law that there is no right to discovery in petitions for

harassment under CCP 527.6 and 527.8. The law provides for a short and truncated procedure

and a quick resolution of the dispute. A right to discovery would run counter to the legislative

goals.

The dangers envisioned by the courts in Thomas, Byers, and Diamond View are evident in

this case. At the court's May 21 hearing, Hothi requested time to seek discovery, citing at that
time primarily video evidence that might be available to negate Tesla's claims. The court
invited letter briefs to outline the parties' positions with regard to their right to discovery in this

type of action. That invitation has now spawned 26 single-spaced page~ of "letter briefs," along

with tens of pages of attachments, in support of and in opposition to Hothi' s broad-based

requests for discovery described above, which, in tum, have drawn predictable objections from

AA
Document received by the CA 1st District Court of Appeal.
9
Page 99 Tesla and claims of confidentiality, privacy, burdensome, overbreadth and proprietary rights
along with requests for protective orders. It has also spawned requests by both parties for

reciprocal discovery should any discovery be allowed. Such a full-blown fight over discovery is

neither authorized nor intended by the statutory scheme in harassment restraining order actions.

The court holds as a matter of law that the court has the discretion to permit discovery in
petitions for harassment under CCP 527.6 and 527.8. The court may adopt "any suitable process

Although there is no right to discovery in harassment proceedings, the court may, on good cause

shown and after considering the possibility of prejudice, order the parties to exchange discovery

before the hearing on the merits.

The court finds that limited discovery is appropriate on the facts of this case. The parties

must produce any photographic, audio, or video recordings of the alleged incidents on February
21 and April 6, 2019. Any such recordings would be directly relevant to the claims and defenses
in this case. Production of any such recordings would impose a minimal burden on the parties.
If any party were in possession of any such recordings and decided to not present them at trial,

then the court might be inclined to draw an adverse inference. (Evid Code 412; CACI 203.) If

any party produced recordings at the trial that were not previously available to the other party,

then due process concerns with notice might suggest that the court continue the trial to permit the

.
·
other party an adequate opportunity to respond. The court emphasizes that the grant of discovery
herein is limited and focused: Photographic, audio or video records of conduct that forms the
basis of Petitioner's request - the parking lot incident of February 21, 2019 and the driving-

related incident of April 6, 2019.

AA
Document received by the CA 1st District Court of Appeal.
or mode of proceeding" ... "which may appear most conformable to the spirit of this code."
8
Page 100 In contrast, the court does not require the parties to produce incident and investigation
reports, witness statements, correspondence, and police reports relating to the incidents.

Although these are certainly relevant to the case, they are not directly relevant in the same way

that the recordings of the incidents are relevant. Although reports, statements, and

correspondence might be contemporaneous with the incidents, they are not real-time recordings
of the incidents. The reports, statements, and correspondence also might raise issues with

confidentiality and that the recordings to not present those issues. The court is cautious about
requiring discovery beyond the recordings of the incidents because it might lead to burden,

expense, and delay that is contrary to the quick and truncated procedure envisioned by the

statutory scheme.


CONCLUSION
The motion is GRANTED to the extent it requests the production of photographic, audio,

or video recordings of the alleged incidents on February 21 and April 6, 2019. Each party shall
produce to the other any such evidence on or before Tuesday July 16, which is 10 days of the
hearing scheduled for Friday July 26, 2019. The motion is otherwise DENIED.

Dated: July!_,


AA
Document received by the CA 1st District Court of Appeal.
8
Page 101 SUPERIOR COURT OF CALIFORNIA
COUNTY OF ALAMEDA
Case Number: RGCase Name: Tesla vs. Hothi
1.
Order On Requests for Discovery
DECLARATION OF SERVICE BY MAIL
I declare .under penalty of perjury that the foregoing is true and correct. Executed on
,/4/~
7,/
Executive Officer/Clerk of the Superior Court
By M. Scott Sanchez, Deputy Clerk
j
under, Zachary J '
-
"i
. Sperlein, D Gill
Law Office of D Gill Sperlein
345 Grove Street
.San Francisco, CA
· Sideman & Bancroft LLP
One Embarcadero Center
Tvyenty-Second Floor
Sa n Francisco, GA 941113711_____ __,
.. ,
'
AA
Document received by the CA 1st District Court of Appeal.
.I certify that I am not a party to this cause and that a true and correct copy of the Order On Requests
'by placing it for collection, stamping or metering with prepaid postage, and mailing on the date stated
below, in the United States mail at Alameda County, California, following standard court practices.
Page 102 Document received by the CA 1st District Court of Appeal.
EXHIBIT E
AA252
Page 103 RECEIVED
7/22/2019 9:33:53 AM
Fax Server
07/19/
15:
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July 19, Honorable Jeffrey S. Brand
Ala:tneda County Superior Court
Hayward Hall of Justice
Department 24405 Amador Stl'eet
Hayward, CA Re: Tesla, Inc. v. Randeep Hothi
Dear Judge Brand:
We are in receipt of the Court's July 18, 2019 Order (the "Order''). That Order clarifies
that the Court's July 1 discovery order requires Tesla to produce both video and audio
,:ecQrdmg-s related to two incidents involving Respondent Hothi's conduct on February
21 and .A.pt·il 16, 2019.
Tesla very much. appl'eointes the Court's con.sidGJ.·ati011 of i:ts motim). 1t respectfully
disagref'!s, however, with J.ht> Comt's o.i:de · requi mg production of tbe m,1di recording,
pa,rticula,:Jy wbere othet evidence amply demonstrates Hothi's c.onduct. Wh.i1e 'J,'e!;la j,.'j
confident tha:tthe evidence supports the l;,iirt\.5 made in this case, TesL.'\ has endeavored
to make foar thattbe audio recording contains its em1>loyees _
private and per.sunal
convei·sations. As described iJ:J, Tc.sin's bcie:fing, those couvc.rsations include _personal
informatio11 and private disc.ussious tl,at these individuals oe\!Elr intended forpub]ic
consumption. Tesla's employees have already been subjected to both the conduct
described 1ll T~la's p~titl. n and -the ®Wanted publicity and online harassment that
followed the 15Hng of that petition. Prc,dnnl.foo o( llie.lr w ·i,Wt.l • on,ve.r.saticm lo Mr
Hothi would, m Tesla's vi,ew, ~mhct more damage by sul')jecting them to an wiwarriu~tecl
invasion of their pt'ivacy and furt.h r harassment. A.nd once the audio is produced, as
the Cov.1;t1s Ordet' Jt5elfsuggests, little doubt l'emains that it will make its way into the
public dotnA.it publiclytt,posiog every detail of an infonJ)a1 conversation among
cnwnr'k,e rs wlio did nothing wrong.
Tesla hact hoperl n.Qt to have to ch ose in this Instance between pl'otecti.\,g rts employees'
safety and exposing them to iava.,;fon of their privacy. The Companys -.it'.eessary
course of action is now clear after the Court's Order. While Tesla believes that a
AA
Document received by the CA 1st District Court of Appeal.
Case No. RG19015770
Page 104 Hon. Jeffrey Brand
July 19, Page
restraining order against Mr. Hothi is necessary and appropriate to protect its
employees at their workplace, Tesla will redouble its efforts to protect its employees
through other means. Tesla believes it has given Mr. Hothi clear notice not to enter its
property and that Tesla will take appropriate action in the future to protect its
employees.
Tesla hereby withdraws the petition and will file the appropriate papers with the Clerk
of the Court.
Respectfully submitted,
cc: D. Gill Sperlein, Esq. (counsel for Respondent)
AA
Document received by the CA 1st District Court of Appeal.
Martha Boersch
Eugene Illovsky
Page 105 Document received by the CA 1st District Court of Appeal.
EXHIBIT F
AA255
Page 106 ~ Boersch & Illovsky LLP
Law Office of D Gill Sperlein
Attn: Sperlein, D Gill
345 Grove Street
San Francisco, CA
Attn: Illovsky, Eugene
1611 Telegraph Avenue
Suite Oakland, CA
Superior Court of California, County of Alameda
Hayward Hall of Justice
Tesla, Inc.
No. RGPlaintiff/Petitioner( s)
Order
vs.
Motion
Dropped
Hothi
Defendant/Respondent( s)
(Abbreviated Tille)
IT IS HEREBY ORDERED THAT:
The tentative ruling is affirmed as follows: The motion is dropped. Petitioner filed a request for
dismissal and dismissal was entered on 7/26/19.
Dated: 08/01/Judge Karin S Schwartz
Order
AA
Document received by the CA 1st District Court of Appeal.
The Motion was set for hearing on 08/01/2019 at 09:00 AM in Department 512 before the Honorable
Karin S Schwartz. The Tentative Ruling was published and has not been contested.
Page 107 SHORT TITLE:
CASE NUMBER:
Tesla, Inc. VS Hothi
RG
ADDITIONAL ADDRESSEES
Document received by the CA 1st District Court of Appeal.
Sideman & Bancroft LLP
Attn: Alinder, Zachary J
One Embarcadero Center
Twenty-Second Floor
San Francisco, CA 94111-
Order
AA257
Page 108 Superior Court of California, County of Alameda
Hayward Hall of Justice
Case Number: RGOrder After Hearing Re: of 08/01/
DECLARATION OF SERVICE BY MAIL
I certify that I am not a party to this cause and that a true and correct copy of the
foregoing document was mailed first class, postage prepaid, in a sealed envelope,
addressed as shown on the foregoing document or on the attached, and that the
mailing of the foregoing and execution of this certificate occurred at
24405 Amador Street, Hayward, California.
Executed on 08/02/2019.
Chad Finke Executive Officer / Clerk of the Superior Court
~ ,.,:_ ~=-Deputy Clerk
AA
Document received by the CA 1st District Court of Appeal.
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