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Lewis Pedigo
2 3222 Oak Knoll Drive
Rossmoor CA 90720
3 In Pro Per
562-650-6146
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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COUNTY OF LOS ANGELES, WHITTIER DISTRICT
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10 LEWIS PEDIGO ) CASE NO.: 18WHFL01382

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Petitioner ) REPLY DECLARATION OF
12 ) LEWIS PEDIGO
Vs )
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KARINA PEDIGO, )
)
15 ) Date: April 3, 2023
Respondent ) Time: 8:30 am
16 ____________________________________) Dept: 123
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19 DECLARATION OF LEWIS PEDIGO

20 I, LEWIS PEDIGO, hereby declare that the following declaration is true and correct,
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signed under the penalty of perjury as follows:
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I am the Petitioner in this instant case.
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This reply declaration is made in support of my Request for Order, at which time I am
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requesting the following:
26 1) Request for Funds held in trust for living and moving expenses
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 2) Respondent and I were married and a judgment for dissolution of marriage was entered on
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2 September 9,2021.

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a) Judgment was made September 2021.
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b) Reserved Issues Judgment was April 12, 2022.
5 c) Stipulation addressing the court order in the Judgment was entered November 29,2022
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(1) The Court shall reserve jurisdiction over the issue of the business known as 24/7
7 Concrete. entered July 29, 2022.
8 d) The Judgement on Reserved Issues was filed April 2022.
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3) The Respondents response declaration to my request for funds does not mention anything
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about my request or need to eat or have a home. It’s the same monologue.
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These are the specific reasons why I am requesting funds from the proceeds to live.
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13 a) I have no income, I am disabled. The Respondent eviscerated the community business.

14 b) I have no funds to secure a home, the lease where I live expired one month ago.
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c) I have no funds to make my truck payment or insure the vehicle.
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d) The Respondent removed me from her employer’s health plan in 2018. (attached hereto
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as exhibit ) I have had to private pay since then. I could not afford to pay for it
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19 anymore and I now have CalOptima and receiving Cal Fresh assistance.

20 4) I cannot pay my bills; I cannot afford to stay where I am, and I cannot afford to leave. I
21 have been evicted. (attached hereto as exhibit )
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5) Respondent fails to address the issues addressed in my Declaration which establish my
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change of circumstances. I have supplied the court with an fl-150 last month. It has not
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changed, but my living situation has declined while the Respondents Attorney ignored my

26 emails for a month. To this day the Respondents Attorney does not show me the respect an
27 attorney is supposed to show a self-represented litigant.
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 e) The respondent’s declaration in response to my request for funds is not a response to my
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2 request. It is another example of her deflecting a violated court order. Her Attorney does

3 nothing to encourage her to obey the court order. Once again all we hear from the
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Respondent is what she wants. Not a scintilla of accountability.
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f) Respondent in her Response sees it, however, as an opportunity to disparage me with
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untruths and false allegations and extortion.
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g) I responded to discovery on time. As the stipulation is written both parties were to

9 exchange all documents requested. I submitted several hundred documents. (attached

10 hereto as exhibit ) The Demand specifically stated that anything I did not submit, the
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respondent would use ‘any and all’ documents in her possession. If she has documents in
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her possession, why have we not had a valuation in 3 years?
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h) The Respondent has still not admitted to the court that she has had in her possession all

15 my documents that she subpoenaed in March 2021 and could have complied with this

16 court order 2 years ago. She has been using them in her trial briefs since 2021.
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i) Again, she keeps referring to the past. Using old bank statements. 2019 Pre-Pandemic
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accounts do not reflect today, 2023. Everyone was making money in 2019.
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j) Since then, the Petitioner’s health has taken an irreversible turn for the worse.
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21 k) By that action alone the Respondent should be held responsible for my attorney fees from

22 May 2021 through now ( that is the date she received the community chase bank
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statements from Tammy Weathersby. Respondent’s September 8 trial exhibits F – How
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can someone have that amount of information and conceal it. from the court for another
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year and a half. (attached hereto as exhibit )
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To this day the Respondent has not provided the ordered name. It is March 2023 this day
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 1 there is still NO valuation.
l) The Respondent continues to deflect in every way that she was ordered by this court to
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3 provide a Business Party name to perform a valuation in the judgment entered September

4 9,2021. Had she obeyed this order, a professional would have satisfied her demand for
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said valuation. We would not still be here talking up the court’s time and resources. She
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continues her meritless accusations to ignore the fact that she is once again the reason this
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divorce is being stalled out.
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10 6) The Respondents response to this Request for Order: Request for Funds:
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a) Her Procedural History is inaccurate. The ‘parcel’ of real estate she mentions casually,
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but how can anyone forget how she harangued this court to get her way. Her
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determination to control the sale of the Arizona property all make sense now. Those
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actions have been addressed in a hearing in Arizona when the Petitioner filed a complaint

16 against Ann Acevedo for her biased treatment against him and in favor of the
17 Respondent. Ann Acevedo refused to answer under oath when she was asked how long
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she has known the Respondent. Her ethics regarding the listing, the pricing and
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ultimately the sale of the community property were found in favor of the Petitioner.
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(attached hereto as exhibit )

22 b) Her statements are flippant and uninformed.

23 c) Her needs and desires and wants from this court have proven to be endless, they are
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based upon fraud and misrepresentations of facts, and they are not a response to my
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request for funds.
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7. RESERVED ISSUES:
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BUSINESS KNOWN AS 24/7 Concrete Pumping
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 The Court shall reserve jurisdiction over the issue of the business known as 24/7
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Concrete.
2 d) The parties shall cooperate and participate in the valuation of said business as of the
date of separation and present value.
3 e) Respondent shall provide Petitioner’ counsel with the name of the business party which
shall perform said valuation by 9-17-21. Appraisal shall be from date of separation of
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1/1/2018 through and including the current value.
5 f) The costs are to be evenly split between the parties and may be paid out of the trust
account from proceeds of sale of property in Arizona.
6 g) The parties agree that in said valuation, the 2018 Chevy Silverado, License No.:
14608J2 and is considered to be business assets.
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8. RESPONDENT’S ACTION AGAINST THE COMMUNITY

9 h) Respondent was aware of the fact that a civil lawsuit was filed against the Petitioner
10 related to the community business and failed to advise the Petitioner of the lawsuit. The
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case is entitled ASSOCIATED Ready Mixed Concrete, Inc vs Pedigo doing Business as
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24/7 Concrete Pumping, Orange County Superior Court Case Number: 30-2020-
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01138082-CU-BC-CJC.

15 i) Petitioner was required to investigate the civil lawsuit and it was apparent that the

16 Respondent was served with the Summons and failed to advise the Petitioner, which she
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concealed since March 2020 and now the Petitioner is defending himself in this Civil
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action. The Petitioner has filed a Cross-Complaint against the Respondent for a breach
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of fiduciary, fraud, and mail theft. It is concurrently filed under the same case number
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21 m) That trial is April 17, 2023. The Respondent is doing everything she can to avoid being

22 financially accountable for damaging the community. (attached hereto as exhibit )

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n) The Petitioners former attorney Dennis Sanchez and Mr. Shahon did not begin to perform
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any valuation of the business, the Respondent again is misleading the court. The
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stipulation was followed by the Petitioner, albeit a personal family concern took Mr.
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27 Sanchez out of town and that’s when Mr. Shahon became aggressive and since then has

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 been nothing but intimidating and insulting. He has arrived on this scene at the end of the
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2 road and is causing unnecessary delays not responding to discovery and allowing his

3 client to continue this reprehensible behavior. The Petitioner is not comfortable at all with
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Mr. Shahon being involved with any part of this case let alone funds he put no work into.
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He has made NO effort to obey the stipulation and his “demand” for documents was not
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for a valuation is was a hunt for spousal support. (attached hereto as exhibit )
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9. On January 26 when the Petitioner gave notice to Mr. Shahon by phone, he was smart

9 enough to protect himself by recording his own voice. At the hearing the Petitioner plans to
10 play this for the court to prove his own truth in reference to Mr. Shahon opposition of the Ex-
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Parte and his client’s statement in paragraph 8 line 22.
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10. The Respondent’s inaccurate references as she tries to mislead the court with a 2018 bank
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statement, she tries to convince a court there was over 50,000 in the account, she neglects to

15 acknowledge the huge amount of check and withdrawals made in the lines directly below-

16 amounts that are similar if not greater than any amount/costs of goods the petitioner had
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since
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11. Additionally, the Respondent has remained consistent with her pattern of ignoring the
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21 process of service and this morning, March 14,2023 had her response personally served to

22 the law offices of Dennis Sanchez knowing that he withdrew in January 2023. There is
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signed service of mailing by her attorney dated today as well.
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Conclusion
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 The Petitioner responds to the Respondents Response to his Request for Order: The Respondent
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2 has failed to declare an opposition or any facts supporting his specific request. The Petitioner

3 also submits to the court additional requests, documents and exhibits in support of every request
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he has prayed to this court for. The most important request being the end of this marriage and a
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fair equalization of proceeds from the sale of the community home, he prays the court allow him
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funds to live at this and relocate. He has suffered at the unkind hands of the Respondent long
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enough. The community has suffered because of the Respondent. The Petitioner is almost 60

9 years old with nothing left to the show for 25 years of carrying 200lbs of concrete on his neck so
10 that the Respondent could live a very good life. A life she decided to destroy for everyone.
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The foregoing declaration is true and correct, signed under the penalty of perjury this 14th day of
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March 2023, in Los Angeles, California.

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19 LEWIS PEDIGO, Petitioner
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