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CARY W. GOLDSTEIN, Esq.
Calif. State Bar No. 85947
8383 Wilshire Blvd., Suite 830
Beverly Hills CA 90211-2407

Tel. [phone]
Fax. [phone]

Attorney for Plaintiff Ruth Tyrangiel

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF LOS ANGELES

RUTH TYRANGIEL,
          Plaintiff,

--vs.--

ROBERT ZIMMERMAN, aka
BOB DYLAN, et al.,
          Defendants.


Case No. BC115656

MOTION TO COMPEL FURTHER
RESPONSES TO NOTICE OF
PRODUCTION OF DOCUMENTS
AT DEPOSITION; DECLARATION OF
CARY W. GOLDSTEIN; REQUEST FOR
SANCTIONS; POINTS AND AUTHOR-
ITIES IN SUPPORT THEREOF.

HON. EDWARD ROSS

Date : May 24th, 1995
Time : 9:00 A.M.
Place: Department 39

 PLEASE TAKE NOTICE THAT: Ruth Tyrangiel, through her attorney of
record herein, will on May 24th, 1995, at 9:00 A.M., before this
Court in Department 39, located at 111 No. Hill St., Los
Angeles, California, move the Court for an Order compelling
Defendant Bob Dylan to produce further responses to Plaintiff's
Request for Production of Documents at Deposition, and an Order
for sanctions against Defendant's attorneys for wilfully
obstructing and delaying discovery. Said Motion will be made
upon the grounds that Defendant's Objections to the requested
discovery were wilfully calculated to obstruct discovery, and
delay Plaintiff's case, contrary to Code of Civil Procedure 2031
and it's applicable subsections. Said Motion will be based on
the attached Declaration of Cary W. Goldstein, the Memorandum of
Points and Authorities, and the complete files and records of
this action, as well as any oral testimony at the time of hearing

 Dated: May 3, 1995

 CARY W. GOLDSTEIN,
 Attorney for Plaintiff RUTH TYRANGIEL

 DECLARATION OF CARY W. GOLDSTEIN

 I, CARY W. GOLDSTEIN, declare:

 1. I am an attorney duly licensed to practice law before all of
the courts of this state. I represent the Plaintiff in the
within action, Ruth Tyrangiel. The following is within my
personal knowledge, and if called to so testify, I could and
would competently do so.

 2. The within lawsuit is what is generically known as an action
for "palimony". Plaintiff alleges a relationship with the
Defendant known as "Bob Dylan" of over 20 years, during the
course of which, the parties exchanged promises to always be
there for each other in most every respect, with Defendant
specifically promising to "always take care of" Plaintiff
financially.

 3. In December of 1994, Defendant caused to be served on
Plaintiff a Notice of Taking Deposition accompanied by a Notice
to Produce Documents at the Deposition. A copy of said Notice
served by Defendant is attached and incorporated herein by
reference as "Exhibit A". It will become clear to the Court why
Plaintiff is presenting this fact.

 4. At her deposition, Plaintiff complied with the document
request of Defendant. Plaintiff had many, many boxes of
documents and materials collected over the years in a storage
locker in New York City. She traveled to New York for the
specific purpose of searching the storage facility for materials
in response to Defendant's document request. She was able to
search most of the boxes, but due to time limitations, did not
complete her search at that time, had the remaining boxes
shipped to Los Angeles for the specific purposes of this
lawsuit, and completed her search here, albeit for a few
relevant but insignificant documents which she has produced
subsequent to her deposition.

 5. In addition to the actual documents, were answer machine tape
recordings of the Defendant Dylan, recorded with his knowledge.
The tapes were numerous, and were mixed in with totally
unrelated recordings. Hours of tapes had to be listened to, and
the relevant recordings had to be separated and recorded on
another tape, which Plaintiff has now done. Plaintiff will have
presented those tape recordings to Defendant well before the
hearing of this motion.

 6. Plaintiff has tendered to Defendant each and every item of
discoverable documentary evidence it has requested.

 7. On March 21, 1995, Plaintiff caused to be served on
Defendant a "Notice of Production of Documents at Deposition"
pursuant to C.C.P. 2025(d)(4). A copy of said notice is attached
and incorporated herein as "Exhibit B".

 8. The definitions, instructions and "Documents To Be Produced"
in Plaintiff's request were gleaned, almost word for word, from
Defendant's "Notice to Produce Documents at Deposition" served
on Plaintiff by the Defendant. I did this to insure that
Defendant would not complain of the requests being
objectionable.

 9. Nevertheless, on April 7th, 1995, I was served with
"Objections of Defendant Bob Dylan to Plaintiff Ruth Tyrangiel's
Notice of Production of Documents at Deposition", a copy of
which is attached and incorporated herein by reference as
"Exhibit C".

 10. Defendant sets forth a litany of "GENERAL OBJECTIONS" in
it's response, commencing at page 2, paragraph 4, through page
3, paragraph 12. Those objections are summarized as follows:

 a. Burdensome, overly broad, and not calculated to lead to the
discovery of admissible evidence.

 b. Attorney-Client privilege.

 c. An unspecified claimed privilege based on confidentiality
and/or proprietary information.

 d. Misuse of discovery pursuant to C.C.P. 2023(a).

 e. Burdensome, oppressing, harassing and annoying.

 f. Unreasonable time frame.

 g. Plaintiff's discovery incomplete.

 11. The objections of paragraph 10, (item "g", above), even
though inappropriate, can no longer apply, in that Plaintiff's
deposition has taken place, and Plaintiff has complied with
Defendant's document production requests.

 12. As to the objection lodged in paragraph 9, (item "f",
above), Defendant has had approximately six weeks to commence
the search for the requested material, as of the date of the
writing of this declaration, and has made no indication
whatsoever that it has done so. Defendant has not requested an
extension of time within which to respond, which Plaintiff would
have gladly granted. Defendant has not turned over any portion
of the material requested. This is a sham objection.

 13. The following constitutes the individual Requests by
plaintiff and Responses by Defendant

 Requested Item 1 - "All documents, including but not limited to
bank statements and canceled checks, which evidence YOUR banking
practices from January 1, 1974, through the present date."

 Response - "The Preliminary Statement and General
Objections are incorporated herein by reference.
Dylan objects to this request on the ground that
it is vague and ambiguous, overbroad and
propounded for pure harassment purposes. Dylan
further objects on the ground that it seeks
documents that are not relevant to this action or
reasonably calculated to lead to the discovery of
admissible evidence. Dylan further objects on the
ground that it seeks information protected by the
attorney- client privilege and/or work product
doctrine. Dylan further objects on the ground that
the request invades and violates Dylan's right to privacy."

 Argument re No. 1

 It should be first noted that this request is identical to
Defendant's request number 9 to Plaintiff, which it compelled
Plaintiff to respond to, and which Plaintiff did in fact respond
The time frame encompassed in this request focuses on the time
frame of the relationship as alleged by Plaintiff. I am informed
and believe and Plaintiff has testified that Defendant
consistently paid for, at least in part, during the majority of
the duration of the 20 year relationship, Plaintiff's living
expenses, and did so by check as well as cash. Defendant denies
this support. The requested documentation is as crucial to
Plaintiff's case as it's absence would be to Defendant's case.

 If these documents are no longer in existence, Defendant should
so state.

 Requested Item 2 - "All documents which evidence any joint
charge accounts or mutually assumed loan obligations entered
into between Ms. Tyrangiel and YOU from January 1, 1974 through
the present date."

 Response - "The Preliminary Statement and General Objections are
incorporated herein by reference. Dylan objects to this request
on the ground that it is vague and ambiguous, overbroad and
propounded for pure harassment purposes. Dylan further objects
on the ground that it seeks documents that are not relevant to
this action or reasonably calculated to lead to the discovery of
admissible evidence. Dylan further objects on the ground that it
seeks information protected by the attorney- client privilege
and/or work product doctrine. Dylan further objects on the
ground that the request invades and violates Dylan's right to
privacy."

 Argument re No.2

 This too, was gleaned from Defendant's Request to Plaintiff.
(See Defendant's item number 10.) The same arguments set forth
in Argument to Item No. 1 applies equally herein.

 Requested Item 3 - "All documents which support or tend to
support an agreement between YOU and Ms. Tyrangiel to share any
profits and losses accumulated as a result of Mr. Dylan's
personal talents."

 Response - "The Preliminary Statement and General Objections are
incorporated herein by reference. Dylan objects to this request
on the ground that it is vague and ambiguous, overbroad and
propounded for pure harassment purposes. Dylan further objects
on the ground that it seeks documents that are not relevant to
this action or reasonably calculated to lead to the discovery of
admissible evidence. Dylan further objects on the ground that it
seeks information protected by the attorney- client privilege
and/or work product doctrine. Dylan further objects on the
ground that the request invades and violates Dylan's right to
privacy."

 Argument re No. 3

 Plaintiff alleges business relationships with Defendant relating
to their music and Mr. Dylan's art work and investments. Rather
than evade discovery, Defendant should have either stated that
none exist, or if they do, he should have produced them, as
their relevance to this lawsuit is abundantly clear. Rather,
Defendant seeks to obstruct discovery and harass Plaintiff,
delay her case, and force her attorney to bring this within
motion. This too, was copied from Defendant's request to
Plaintiff. Defendant found it relevant to his case, but not
worthy of Plaintiff's case.

 Requested Item 4 - "All documents which support or tend to
support any alleged agreement entered into between YOU and Ms.
Tyrangiel providing for the distribution of Your assets"

 Response "The Preliminary Statement and General
Objections are incorporated herein by
reference. Dylan objects to this request on the
ground that it is vague and ambiguous,
overbroad and propounded for pure harassment
purposes. Dylan further objects on the ground
that it seeks documents that are not relevant
to this action or reasonably calculated to lead
to the discovery of admissible evidence. Dylan
further objects on the ground that it seeks
information protected by the attorney- client
privilege and/or work product doctrine. Dylan
further objects on the ground that the request
invades and violates Dylan's right to privacy."

 Argument re No.4

 This was item number 18 in Defendant's request to Plaintiff.
Plaintiff did not object to this request. The argument set forth
in item number 3 applies equally to item number 4. Why not
respond "No" if that is their response, or produce the obviously
relevant documents? Because Defendant is wilfully seeking to
obstruct and delay discovery by Plaintiff, and the progress of
this case.

 Requested Item 5 - "All documents which evidence payment by YOU
of Ms. Tyrangiel's business and living expenses."

 Response - "The Preliminary Statement and General
Objections are incorporated herein by
reference. Dylan objects to this request on the
ground that it is vague and ambiguous,
overbroad and propounded for pure harassment
purposes. Dylan further objects on the ground
that it seeks documents that are not relevant
to this action or reasonably calculated to lead
to the discovery of admissible evidence. Dylan
further objects on the ground that it seeks
information protected by the attorney- client
privilege and/or work product doctrine. Dylan
further objects on the ground that the request
invades and violates Dylan's right to privacy."

 Argument re No.5

 This too, goes to the heart of Plaintiff's case, and Defendant's
defense. That is apparent, in that it was copied from Item
Number 19 in Defendant's Request to Plaintiff. arguments as set
forth above apply herein.

 Requested Item 6 - "All documents which evidence each different
residential address YOU maintained between January 1, 1974 and
the present date and the period of time YOU spent at each
address."

 Response - "The Preliminary Statement and General Objections are
incorporated herein by reference. Dylan objects to this request
on the ground that it is vague and ambiguous, overbroad and
propounded for pure harassment purposes. Dylan further objects
on the ground that it seeks documents that are not relevant to
this action or reasonably calculated to lead to the discovery of
admissible evidence. Dylan further objects on the ground that it
seeks information protected by the attorney- client privilege
and/or work product doctrine. Dylan further objects on the
ground that the request invades and violates Dylan's right to
privacy."

 Argument re No.6 - Plaintiff has presented evidence pursuant to
Defendant's request at deposition regarding Plaintiff's address
for the past twenty years. This goes to an essential allegation
of the complaint. The parties cohabited during the
relationship, a fact which Defendant denies. The location of his
residences is as essential to Plaintiff's case as it is to
Defendant's. Plaintiff has been requested to and has given this
information relating to herself to Defendant. Equal treatment
commands that Defendant do the same

 Requested Item 7 - "All documents that relate to YOUR banking
relationships and accounts YOU maintained from January 1, 1974
to the present date."

 Response - "The Preliminary Statement and General Objections are
incorporated herein by reference. Dylan objects to this request
on the ground that it is vague and ambiguous, overbroad and
propounded for pure harassment purposes. Dylan further objects
on the ground that it seeks documents that are not relevant to
this action or reasonably calculated to lead to the discovery of
admissible evidence. Dylan further objects on the ground that it
seeks information protected by the attorney- client privilege
and/or work product doctrine. Dylan further objects on the
ground that the request invades and violates Dylan's right to
privacy."

 Argument re No.7 - This too, was a specific question asked of
Plaintiff by Defendant. (See Defendant's Request No.39.) The
bank records would demonstrate payments to Plaintiff, of which
at the present time, Plaintiff has only partial proof of; that
is copies of some, but not all checks given to her by Mr. Dylan.

 Request Item 8 - "All documents that identify all credit cards
that listed YOU as an authorized signatory from
January 1, 1974 to the present date."-

 Response - "The Preliminary Statement and General Objections are
incorporated herein by reference. Dylan objects to this request
on the ground that it is vague and ambiguous, overbroad and
propounded for pure harassment purposes. Dylan further objects
on the ground that it seeks documents that are not relevant to
this action or reasonably calculated to lead to the discovery of
admissible evidence. Dylan further objects on the ground that it
seeks information protected by the attorney- client privilege
and/or work product doctrine. Dylan further objects on the
ground that the request invades and violates Dylan's right to
privacy."

 Argument re No.8 - This is a copy of Defendant's Item Number 40
to Plaintiff. Certainly it was of value to Defendant, otherwise
they would not have requested it. Why would this information not
be of value to Plaintiff?

 Requested Item 9 - "Any and all documents which refer, relate or
pertain to any communications between Defendant and Plaintiff
from January 1, 1974 to the present date."

 Response - "The Preliminary Statement and General Objections are
incorporated herein by reference. Dylan objects to this request
on the ground that it is vague and ambiguous, overbroad and
propounded for pure harassment purposes. Dylan further objects
on the ground that it seeks documents that are not relevant to
this action or reasonably calculated to lead to the discovery of
admissible evidence. Dylan further objects on the ground that it
seeks information protected by the attorney- client privilege
and/or work product doctrine. Dylan further objects on the
ground that the request invades and violates Dylan's right to
privacy."

 Argument re No. 9

 This was Defendant's Request No. 43 to Plaintiff, to which
Plaintiff responded with documents and tape recordings. The
requested documents go to evidence of the existence and nature
of the relationship, both which are facts placed in dispute by
Defendant.

 Requested Item 10 - "Any and all documents that refer, relate or
pertain to any travel within or outside the State of California
by Defendant from January 1, 1974 to the present date."

 Response - "The Preliminary Statement and General Objections are
incorporated herein by reference. Dylan objects to this request
on the ground that it is vague and ambiguous, overbroad and
propounded for pure harassment purposes. Dylan further objects
on the ground that it seeks documents that are not relevant to
this action or reasonably calculated to lead to the discovery of
admissible evidence. Dylan further objects on the ground that it
seeks information protected by the attorney- client privilege
and/or work product doctrine. Dylan further objects on the
ground that the request invades and violates Dylan's right to
privacy."

 Argument re No. 10 - Plaintiff has alleged that she has traveled
with Defendant on tour many times over the course of the 20 year
relationship. Defendant's counsel extensively grilled Plaintiff
on this particular question in her deposition. This was also
Defendant's specific request number 44. We must now corroborate
her responses with those of Defendants. Why should Defendant be
prepared at the time of trial to attempt to impeach Plaintiff,
and Plaintiff not be afforded the reciprocal right to impeach
Defendant?

 Requested Item 11 - "any and all documents that refer, relate or
pertain to any rental agreements respecting Defendant's place of
residence from January 1, 1974 to the present."

 Response - "The Preliminary Statement and General Objections are
incorporated herein by reference. Dylan objects to this request
on the ground that it is vague and ambiguous, overbroad and
propounded for pure harassment purposes. Dylan further objects
on the ground that it seeks documents that are not relevant to
this action or reasonably calculated to lead to the discovery of
admissible evidence. Dylan further objects on the ground that it
seeks information protected by the attorney- client privilege
and/or work product doctrine. Dylan further objects on the
ground that the request invades and violates Dylan's right to
privacy. "

 Argument re No.11

 In this area too, Plaintiff was extensively interrogated in her
deposition. This was correlative to Defendant's request number
46 of Plaintiff. Plaintiff is entitled to oppose Defendant's
arguments regarding Plaintiff's residences during the term of
the relationship.

 Requested Item 12 - "Any and all documents that refer, relate or
pertain to the ownership of any real property by YOU from
January 1, 1974 to the present."

 Response - "The Preliminary Statement and General Objections are
incorporated herein by reference. Dylan objects to this request
on the ground that it is vague and ambiguous, overbroad and
propounded for pure harassment purposes. Dylan further objects
on the ground that it seeks documents that are not relevant to
this action or reasonably calculated to lead to the discovery of
admissible evidence. Dylan further objects on the ground that it
seeks information protected by the attorney- client privilege
and/or work product doctrine. Dylan further objects on the
ground that the request invades and violates Dylan's right to
privacy .

 Argument re No. 12

 This was copied from Defendant's request number 47. Plaintiff
responded to this inquiry. Plaintiff alleges in her complaint
that Defendant breached his promise to share with Plaintiff, and
that he would always take care of Plaintiff financially.
Defendant's property holdings, which Plaintiff contends Mr.
Dylan is holding title to in Constructive Trust for Plaintiff,
are an essential elements of proof to Plaintiff's case. Besides,
Defendant believed this to be proper inquiry of Plaintiff; Is
Mr. Dylan different than the rest of us? Is he privileged? Does
he not have to respond as Plaintiff must, and did, in response
to his request that she do so?

 Requested Item 13 - "Any and all diaries, calendars, or daily
logs kept by YOU from the period January 1, 1974 to the
present."

 Response - "The Preliminary Statement and General Objections are
incorporated herein by reference. Dylan objects to this request
on the ground that it is vague and ambiguous, overbroad and
propounded for pure harassment purposes. Dylan further objects
on the ground that it seeks documents that are not relevant to
this action or reasonably calculated to lead to the discovery of
admissible evidence. Dylan further objects on the ground that it
seeks information protected by the attorney- client privilege
and/or work product doctrine. Dylan further objects on the
ground that the request invades and violates Dylan's right to
privacy."

 Argument re No. 13

 Plaintiff claims a twenty year relationship with defendant, the
substance of which Defendant denies. Defendant's counsel
extensively questioned Plaintiff regarding diaries at her
deposition, and demanded that she produce what he believed were
diaries. Plaintiff contends that the reasons given by Defendant
for production of Plaintiff's non-existent diaries are valid
reasons for defendant to produce any he may have. This was
Defendant's requested item number 48. Again, is Defendant Dylan
privileged?

 Requested Item 14 - "Any and all documents that refer, relate or
pertain to communications between Defendant and third parties
wherein Plaintiff is referred to or mentioned, including, but
not limited to, copies or correspondence, notes and recordings."

 Response - "The Preliminary Statement and General Objections are
incorporated herein by reference. Dylan objects to this request
on the ground that it is vague and ambiguous, overbroad and
propounded for pure harassment purposes. Dylan further objects
on the ground that it seeks documents that are not relevant to
this action or reasonably calculated to lead to the discovery of
admissible evidence. Dylan further objects on the ground that it
seeks information protected by the attorney- client privilege
and/or work product doctrine. Dylan further objects on the
ground that the request invades and violates Dylan's right to
privacy .

 Argument re No. 14

 Plaintiff requests this to prove essential elements of it's
case; that is the nature of the relationship in dispute. This
was Defendant's request number 49 to Plaintiff.

 Requested Item 15 - "Any and all of YOUR bank statements,
including checking and savings from 1974 to the present."

 Response - "The Preliminary Statement and General Objections are
incorporated herein by reference. Dylan objects to this request
on the ground that it is vague and ambiguous, overbroad and
propounded for pure harassment purposes. Dylan further objects
on the ground that it seeks documents that are not relevant to
this action or reasonably calculated to lead to the discovery of
admissible evidence. Dylan further objects on the ground that it
seeks information protected by the attorney- client privilege
and/or work product doctrine. Dylan further objects on the
ground that the request invades and violates Dylan's right to
privacy."

 Argument re Item 15

 This was identical to Defendant's requested item number 51. this
information would serve to prove the allegations of support of
Plaintiff by Defendant.

 Requested Item 16 - "Any and all of YOUR investment account
statements from 1974 to the present "

 Response - "The Preliminary Statement and General
Objections are incorporated herein bY reference.
Dylan objects to this request on the ground that
it is vague and ambiguous, overbroad and
propounded for pure harassment purposes. Dylan
further objects on the ground that it seeks documents that are
not relevant to this action or reasonably calculated to lead to
the discovery of admissible evidence. Dylan further objects on
the ground that it seeks information protected by the attorney-
client privilege and/or work product doctrine. Dylan further
objects on the ground that the request invades and violates
Dylan's right to privacy."

 Argument re Item 16

 Previous arguments regarding the broken promises of Defendant
apply here as well. Plaintiff requires this information in order
to prove her involvement in defendant's financial affairs, and
what is being held in constructive trust by Mr. Dylan for her.

 Requested Item 17 "Any and all documents that reflect payments
made by YOU on Plaintiff's behalf."

 Response - "The Preliminary Statement and General Objections are
incorporated herein by reference. Dylan objects to this request
on the ground that it is vague and ambiguous, overbroad and
propounded for pure harassment purposes. Dylan further objects
on the ground that it seeks documents that are not relevant to
this action or reasonably calculated to lead to the discovery of
admissible evidence. Dylan further objects on the ground that it
seeks information protected by the attorney- client privilege
and/or work product doctrine. Dylan further objects on the
ground that the request invades and violates Dylan's right to
privacy."

 Argument re Item 17

 Plaintiff has produced documentation in response to Defendant's
requested item number 54, which is identical to Plaintiff's
within request. This is crucial, essential to Plaintiff's case.
Plaintiff alleges support by Defendant during the course of the
20 year relationship. Plaintiff has presented partial proof of
that fact. Defendant possesses the balance of the documentation,
and should be compelled to produce it.

 Requested Item 18 - "Any and all documents that refer, relate,
pertain or reflect any social functions at which YOU accompanied
Ms. Tyrangiel from January 1, 1974 to the present date."

 Response - "The Preliminary Statement and General
Objections are incorporated herein by
reference. Dylan objects to this request on the
ground that it is vague and ambiguous,
overbroad and propounded for pure harassment purposes. Dylan
further objects on the ground that it seeks documents that are
not relevant to this action or reasonably calculated to lead to
the discovery of admissible evidence. Dylan further objects on
the ground that it seeks information protected by the attorney-
client privilege and/or work product doctrine. Dylan further
objects on the ground that the request invades and violates
Dylan's right to privacy."

 Argument re Item 18

 This is essential to Plaintiff's proving the extent and nature
of her relationship with Defendant. Defendant obviously found it
to be a pertinent inquiry, as it was his requested item number
55.

 General Argument re Defendant's Repeated Objections

 It is clear that not one question is vague or ambiguous. Each
request is clear as to it's meaning. Defendant's counsel should
understand that...they drafted them. That the same logic
applies to Defendant's claims-of the requests being "overbroad
and propounded for pure harassment purposes." Certainly
Defendant is not claiming it demanded production of those
documents from Plaintiff to harass her. Plaintiff has
demonstrated in each argument above that it's requests are
relevant to the within action, and are reasonably calculated to
lead to the discovery of admissible evidence. None of the
material requested is attorney-client privileged, or is attorney
work product. We regret that Mr. Dylan believes his privacy is
being invaded, but firstly, he is the one who broke the promises
made to Plaintiff, and secondly, he had no concern for
Plaintiff's privacy when he had his counsel interrogate
Plaintiff about the most intimate details of her life.

 14. Defendant's responses to Plaintiff's requests are
nothing but a wilful, intentional ruse to delay discovery. Mr.
Dylan does not like the idea that he must produce detailed
information about his private life, but Ms. Tyrangiel is
likewise not pleased to have to expose the most intimate details
of her life in public to enforce the promises made and broken by
Mr. Dylan. Let him do what is right and not utilize the Court as
his muse. Pay or produce and defend. Mr. Dylan was not dragged
into this battle by Ms. Tyrangiel...she is the disenfranchised
woman left homeless by Mr. Dylan, after 20 years, when he pulled
the plug on her at his whim. She was compelled to fight for what
is rightfully hers after being denied it by the self-important
Defendant.

 15. I declare to the Court that on or about April 16th, I left a
telephone message for defense counsel Gatti on his voice mail
specifically stating that I was calling to discuss his clients
responses to Plaintiff's discovery requests. I then called
again, before preparing this motion, wanting to meet and confer
regarding his client's responses. At that time Mr. Gatti made a
significant step towards resolution of this case by offering to
meet with me to discuss the possibility of settlement. After
three telephone calls between us and Mr. Gatti's partner, "Skip"
Miller, on that day, the proposal for a meeting fell apart, and
it did not take place. Nevertheless, 15 day extensions were
granted mutually to bring any discovery motions which may be
delayed by the meeting.

 16. By correspondence and fax of April 24th, 1995, a copy of
which is attached and incorporated herein as "Exhibit D", I
again attempted to meet and confer with Mr. Gatti. My request
was not responded to.

 17. On May 2, 1995, Mr. Gatti and I met at the Courthouse when
appearing together on the status conference in this matter.
cornered Mr. Gatti and inquired as to how he wishes to proceed
on the discovery issues, particularly further responses to
Plaintiff's document request. He stated that he did not believe
Ms. Tyrangiel was entitled to that documentation, and stood by
his objections. then prepared this motion.

 18. I have spent approximately 6 hours in the preparation of
this Motion, and anticipate that I will spend an additional 2.5
hours in traveling to and from the courthouse and in the actual
hearing of this motion. My usual hourly rate for work of this
sort is $300.00. It is requested that the Court award sanctions
against Defendant and his counsel in the amount of $2,550.00 for
it's wilful obstruction of discovery, in addition to the $14.00
filing fee attendant to this motion.

 SWORN, this 3 day of May, 1995, at Beverly Hills, California,
under the penalty of perjury, that the foregoing is true and
accurate to the best of my knowledge.

 CARY W. GOLDSTEIN, declarant.

 POINTS AND AUTHORITIES

 I.

 PRELIMINARY STATEMENT

 This is an eight count action commonly referred to as a lawsuit
for "palimony". Plaintiff maintained a relationship with the
Defendant known as Bob Dylan for over twenty years. Mr. Dylan
and Plaintiff Tyrangiel exchanged promises as set forth in the
Complaint. Ms. Tyrangiel kept those promises, Mr. Dylan broke
them. Ms. Tyrangiel was disenfranchised by the Defendant,
destitute, and left no alternative but to compel Defendant to
keep his promises regarding sharing and taking care of Plaintiff
by bringing this lawsuit.

 CODE OF CIVIL PROCEDURE PROHIBITS DISCOVERY ABUSES

 "Code of Civil Procedure 2023. Abuses of Discovery; sanctions

 (a) Misuses of the discovery process include, but are not
limited to, the following: ...

 (5) Making, without substantial justification, an unmeritorious
objection to discovery.

 (6) Making an evasive response to discovery.

 (9) Failing to confer in person, by telephone, or by letter with
an opposing party or attorney in a reasonable and good faith
attempt to resolve informally any dispute concerning discovery,
if the section governing a particular discovery motion requires
the filing of a declaration stating facts showing that such an
attempt has been made. Notwithstanding the outcome of the
particular discovery motion, the court shall impose a monetary
sanction ordering that any party or attorney who fails to confer
as required pay the reasonable expenses, including attorney's
fees, incurred by anyone as a result of that conduct.

 (b) To the extent authorized by the section governing any
particular discovery method or any other provision of this
article, the court, after notice to any affected party, person
or attorney, and after opportunity for hearing, may impose the
following sanctions against anyone engaging in conduct that is a
misuse of the discovery process.

 (1)The court may impose a monetary sanction ordering that one
engaging in the misuse of the discovery process, or any attorney
advising that conduct, or both pay the reasonable expenses,
including attorney's fees, incurred by anyone as a result of
that conduct. The court may also impose this sanction on one
unsuccessfully asserting that another has engaged in the misuse
of the discovery process, or on any attorney who advised that
assertion, or on both. If a monetary sanction is authorized by
any provision of this article, the court shall impose the
sanction unless it finds that the one subject to the sanction
acted with substantial justification or that other circumstances
make the imposition of the sanction unjust.

 III.

 CONCLUSION

 As set forth in the attached Declaration of Cary W. Goldstein,
each and every item requested by Plaintiff is clearly within the
reasonable boundaries of discovery. The Court is reminded that
each of Plaintiff's eighteen requests were taken specifically
from Defendant's sixty five requests for production to
Plaintiff.

 Defendant demanded that Plaintiff respond to that discovery,
claiming it was essential to the preparation of it's case for
trial. We agree, it was. In an effort to not hide any facts,
Plaintiff capitulated to Defendant's inquiries into the most
personal aspects of Plaintiff's life.

 Plaintiff now requires the same information. It is essential to
her preparation for trial. Defendant's objections are merely a
sham to obstruct discovery and delay this case from moving
forward. It is unfortunate that Mr. Dylan is not happy about
this case, but neither is Ms. Tyrangiel. Certainly, as between
the parties, Mr. Dylan presently is placed in a far more
comfortable position than Plaintiff, the woman left with nothing
at the whim of Mr. Dylan.

 The information requested by Plaintiff is essential to her
preparing this case for trial. Defendant has requested and
received this information from Plaintiff. Plaintiff should not
be denied the opportunity to litigate her case on equal ground
with Defendant.

 Dated: MaY 3. 1995

 Respectfully submitted,

 CARY W. GOLDSTIEN
 Attorney for Plaintiff Ruth Tyrangiel.