Fraud and Elder Abuse are not really a good DIY project. Many attorneys with years of experience struggle with the heightened clear and convincing evidence standard for fraud. This is something that you really should consider hiring counsel to tackle as once you respond and verify your responses, they are not going to go away and your case could be destroyed by a wrong answer.
The only way for an attorney to answer your question is to really get into your case enough to fully understand all of the facts and law. It is not easy. Sorry, I wish I could help more.
Kevin A. Spainhour, Esq.
Sometimes you can object to that question as an atty. Otherwise you may need to crack open the Calif Codes and start looking for statutes and regulations you believe the deft violated. You really should try to get a lawyer to represent you, as if you are having problems with 14.1, you are really going to have trouble putting on your case, with all the other rules involved.