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1 KIRSCHENBAUM LAW, PC
JEFFREY B. KIRSCHENBAUM (SBN: 152290)
2 RAYMONDE. LOUGHREY (SBN: 194363)
ELECTRONICALLY
328 15 th Street
3 Oakland, CA 94612 F I L E D
Superior Court of California,
Telephone (510) 740-9260 County of San Francisco
4 Email: jeff@kirschenbaumlaw.com
01/27/2020
5 Attorneys for Plaintiff and Cross-Defendant Clerk of the Court
BY: EDNALEEN ALEGRE
TON KIANG RESTAURANT, INC. Deputy Clerk
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9 SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 CITY AND COUNTY OF SAN FRANCISCO
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12 TON KIANG RESTAURANT, INC., CASE NO. CGC-19-574262
13 Plaintiff, (Consolidated with Case No. CUD-19-664262)
14 V.
15 WILLIAM WONG, WWJW FAMILY LLC, a DECLARATION OF RAYMONDE.
California Limited Liability Company, and LOUGHREY IN SUPPORT OF
16 DOESl-10, inclusive, PLAINTIFF TON KIANG RESTAURANT,
INC.'S OPPOSITION TO DEFENDANT
17 Defendants. WWJW FAMILY LLC'S MOTION TO
18 COMPEL RESPONSES TO REQEUST
WILLIAM WONG and WWJW FAMILY LLC, FOR PRODUCTION OF DOCUMENTS,
19 SET ONE
Cross-Complainants,
20 Hearing Date: February 7, 2020
v. Hearing Time: 9:30 a.m.
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TON KIANG RESTAURANT, INC., and ROES Place: Dept. 501
22 1-25,
23 Cross-Defendants. Action Filed: March 4, 2019
Trial Date: September 14, 2020
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AND CONSOLIDATED ACTION
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2811----------------------------------+
LOUGHREY DECLARATION IN OPPOSITION TO Printed on Recycled Paper
WWJW'S MOTION TO COMPEL RESPONSES TO
REQUEST FOR PRODUCTION OF DOCUMENTS
Case No. CGC-19-574262 I CUD-19-664262
1 I, RAYMONDE. LOUGHREY, declare as follows:
2 1. I am duly admitted to practice law in the State of California, including this Court. I
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am employed by the firm of Kirschenbaum Law, P.C., counsel for plaintiff and cross-defendant
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TON KIANG RESTAURANT, INC. ("Ton Kiang"). I have personal knowledge of the matters set
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forth herein and, if called as a witness, could and would competently testify thereto.
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7 2. On January 27, 2020, Ton Kiang served, without objection and without asserting
8 any privilege, full and complete responses to defendant and cross-complainant WWJW FAMILY
9 LLC's Request for Production of Documents, Set One. Ton Kiang agreed to produce all
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documents within its possession, custody, or control in response to requests numbers 1, 4, 6, 7, 8,
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9, 10, and 12, and will produce such documents as soon as possible. Ton Kiang, after making a
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diligent search and reasonable inquiry, is not aware of the existence to any documents in response
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to requests numbered 2, 3, 5, and 11. A true and correct copy of Ton Kiang's response is attached
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15 hereto as Exhibit A.
16 I declare under penalty of perjury under the laws of the State of California that the
17 foregoing is true and correct.
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Executed this 27 th day of January 2020, at Oakland, California.
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2811---------------------------------
LOUGHREY DECLARATION IN OPPOSITION TO 2 Printed on Recycled Paper
WWJW'S MOTION TO COMPEL RESPONSES TO
REQUEST FOR PRODUCTION OF DOCUMENTS
Case No. CGC-19-574262 / CUD-19-664262
EXHIBIT A
1 KIRSCHENBAUM LAW, PC
JEFFREY B. KIRSCHENBAUM (SBN: 152290)
2 RAYMONDE. LOUGHREY (SBN: 194363)
KRISTIN L. WILLIAMS (SBN: 312902)
3 328 15th Street
Oakland, CA 94612
4 Telephone: (510) 740-9260
Email: Jeff@Kirschenbaumlaw.com
5
Attorneys for Plaintiff
6 TON KIANG RESTAURANT, INC.
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF SAN FRANCISCO
10 UNLIMITED CIVIL JURISDICTION
11 TON KIANG RESTAURANT, INC. CASE NO. CGC-19-574262
[Consolidated with CUD-19-664262]
12 Plaintiff,
13 v. PLAINTIFF'S RESPONSES TO WWJW
FAMILY LLC'S REQUEST FOR
14 WILLIAM WONG, WWJW FAMILY LLC, a PRODUCTION OF DOCUMENTS, SET
California Limited Liability Company, and ONE
15 DOES 1-10, inclusive
16 Defendants.
17
18
19 AND RELATED CROSS-ACTION AND
CONSOLIDATED ACTION.
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23 PROPOUNDING PARTY: Defendant and Cross-Complainant WWJW FAMILY LLC
24 RESPONDING PARTY: Plaintiff and Cross-Defendant TON KIANG RESTAURANT, INC.
25 SETNO.: One (1)
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PLAINTIFF'S RESPONSES TO WWJW FAMILY LLC'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE
1 Plaintiff and cross-defendant TON KIANG RESTAURANT (hereinafter referred to as
2 "Plaintiff'), pursuant to the provisions of sections 2031.10 et seq. of the California Code of Civil
3 Procedure, hereby responds to the Requests for Production of Documents, Set One, propounded by
4 defendant WWJW FAMILY LLC ("Defendant") as follows:
5 REQUEST FOR PRODUCTION NO. 1:
6 Any and all DOCUMENTS that support YOUR contention that you paid real PROPERTY
7 tax for 5821 Geary Boulevard to the City of San Francisco as alleged in your COMPLAINT.
8 RESPONSE TO REQUEST FOR PRODUCTION NO. 1:
9 Plaintiff will comply with this request and will produce all DOCUMENTS in its possession,
10 custody, or control.
11 REQUEST FOR PRODUCTION NO. 2:
12 Any and all DOCUMENTS to prove YOU made re~tal payments in the amount of $120,000
13 for 5821 Geary Boulevard in San Francisco, California for the calendar year 2018 as reflected on
14 YOUR 2018 tax returns.
15 RESPONSE TO REQUEST FOR PRODUCTION NO. 2:
16 A diligent search and reasonable inquiry for responsive DOCUMENTS has been made.
17 However, Plaintiff is unable to comply with this request. Plaintiff is unaware of the existence of
18 any documents responsive to this request.
19 REQUEST FOR PRODUCTION NO. 3:
20 Any and all cancelled checks to prove YOU made rental payments in the amount of
21 $120,000.00 for 5821 Geary Boulevard in San Francisco, California for the calendar year 2018 as
22 reflected in YOUR tax returns.
23 RESPONSE TO REQUEST FOR PRODUCTION NO. 3:
24 A diligent search and reasonable inquiry for responsive DOCUMENTS has been made.
25 However, Plaintiff is unable to comply with this request. Plaintiff is unaware of the existence of
26 any documents responsive to this request.
27 REQUEST FOR PRODUCTION NO. 4:
28 Any and all Schedule L's attached to YOUR tax returns for 2010-2018.
2
PLAINTIFF'S RESPONSES TO WWJW FAMILY LLC's REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE
1 RESPONSE TO REQUEST FOR PRODUCTION NO. 4:
2 Plaintiff will comply with this request and will produce all DOCUMENTS in its possession,
3 custody, or control.
4 REQUEST FOR PRODUCTION NO. 5:
5 Any and all Operating Agreements for Ton Kiang Restaurant Inc.
6 RESPONSE TO REQUEST FOR PRODUCTION NO. 5:
7 A diligent search and reasonable inquiry for responsive DOCUMENTS has been made.
8 However, Plaintiff is unable to comply with this request. Plaintiff is unaware of the existence of
9 any documents responsive to this request.
IO REQUEST FOR PRODUCTION NO. 6:
11 Any and all DOCUMENTS that reflect the names of the corporate officers and directors for
!2 Ton Kiang Restaurant, Inc. for each specific year from 2010 through the present.
13 RESPONSE TO REQUEST FOR PRODUCTION NO. 6:
14 Plaintiff will comply with this request and will produce all DOCUMENTS in its possession,
15 custody, or control.
16 REQUEST FOR PRODUCTION NO. 7:
17 Any and all DOCUMENTS that reflect the names of the shareholders for Ton Kiang
18 Restaurant, Inc. for each specific year from 2010 through the present.
19 RESPONSE TO REQUEST FOR PRODUCTION NO. 7:
20 Plaintiff will comply with this request and will produce all DOCUMENTS in its possession,
21 custody, or control.
22 REQUEST FOR PRODUCTION NO. 8:
23 Any and all DOCUMENTS that reflect the percentage shares held by any shareholders for
24 Ton Kiang Restaurant Inc. for each specific year from 2010 through the present.
25 RESPONSE TO REQUEST FOR PRODUCTION NO. 8:
26 Plaintiff will comply with this request and will produce all DOCUMENTS in its possession,
27 custody, or control.
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PLAJNTIFF'S RESPONSES TOWWJW FAMILY LLC's REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE
1 REQUEST FOR PRODUCTION NO. 9:
2 Any and all DOCUMENTS that support YOUR contention that someone other than WWJW
3 Family LLC or William Wong paid the REAL PROPERTY TAXES on the PROPERTY at any
4 time during the period October 2010 through the present as alleged in YOUR COMPLAINT.
5 RESPONSE TO REQUEST FOR PRODUCTION NO. 9:
6 Plaintiff will comply with this request and will produce all DOCUMENTS in its possession,
7 custody, or control.
8 REQUEST FOR PRODUCTION NO. 10:
9 Any and all DOCUMENTS that support YOUR contention that YOU paid the REAL
10 PROPERTY TAXES on the PROPERTY at any time during the period of October 2010 through
11 the present as alleged in YOUR COMPLAINT.
12 RESPONSE TO REQUEST FOR PRODUCTION NO. 10:
13 Plaintiff will comply with this request and will produce all DOCUMENTS in its possession,
14 custody, or control.
15 REQUEST FOR PRODUCTION NO. 11:
16 Any and all DOCUMENTS that support YOUR contention that William Wong received
17 $400,000 from his father's Charles Schwab account, alleged in YOUR COMPLAINT.
18 RESPONSE TO REQUEST FOR PRODUCTION NO. 11:
19 A diligent search and reasonable inquiry for responsive DOCUMENTS has been made.
20 However, Plaintiff is unable to comply with this request. Plaintiff is unaware of the existence of
21 any documents responsive to this request.
22 REQUEST FOR PRODUCTION NO. 12:
23 Any and all DOCUMENTS that reflect the dates and amounts of each and every payment
24 YOU made to date that allegedly covers the carrying costs for the PROPERTY after William took
25 title as alleged in YOUR COMPLAINT.
26 RESPONSE TO REQUEST FOR PRODUCTION NO. 12:
27 Plaintiff will comply with this request and will produce all DOCUMENTS in its possession,
28 custody, or control.
4
PLAINTIFF'S RESPONSES TO \VWJW FAMILY LLC'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE
1 DATED: January 27, 2020 KIRSCHENBAUM LAW, PC
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5 Attorneys for Plaintiff
TON KIANG RESTAURANT, INC.
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PLAINTWF'SR.ESPONSESTO\\'WJWFAMILYLLC'sREQUESTFORPRODUCTIONOFDOCUMENTS,SET0NE
VERIFlCATtON
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i, RICHARD WONG, declare:
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I am President and Chief Executive Officer of plaintiff Ton Kiang Restaurant, lnc., and
am authorized to execute this verification on the company" s behalf. I have read the foregoing
Responses to WWJW FAMILY, LLC's Requests for Production of Documents (Set One) and
know the contents thereof. The same is true of my own knowledge, except as to those matters
that are therein stated upon my information and beficf, and as to those matters 1 believe it to be
true.
l declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Dated: January 2 ') . 2020
/_
,I-[.,,
-------1_. _,, .,I .-·
.
.
RI Cl-JAR J.Y\¥oNG
I am employed in the County of Alameda, State of California. I am over the age of 18 years
2 and not a party to this action. My business address is 328 15 th Street, Oakland, California 94612.
3 On the date below, I served the attached document described as:
4 PLAINTIFF'S RESPONSES TO WWJW FAMILY LLC'S REQUEST FOR
PRODUCTION OF DOCUMENTS, SET ONE
5
on the interested parties in this action:
6
Counsel for Defendants
7 Ryan K. J. Mau, Esq.
LAW OFFICE OF RYAN MAU, PC
8 333 Bush Street, 2151 Floor
San Francisco, CA 94104
9
Email: ryan@rmaulaw.com
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(/\) BY MAIL: I enclosed the document in a sealed envelope addressed to the party(ies)
11 listed above, with postage thereon fully prepaid and placed the envelope for collection
and mailing, following our ordinary business practices. I am readily familiar with this
12 business's practice for collecting and processing correspondence for mailing. On the
same day that correspondence is placed for collection and mailing, it is deposited in the
13 ordinary course ofbusiness with the United States Postal Service.
14 ( ) BY OVERNIGHT SERVICE: I enclosed the document in a sealed envelope(s)
addressed to the person(s) listed above. Then, I placed the envelope for collection arid
15 overnight delivery by Federal Express, with receipts affixed thereto promising delivery
to the addressee(s) on the following business day.
16
( ) BY HAND DELIVERY: I enclosed true and correct copies of the documents in a
17 sealed envelope addressed to the party(ies) listed above. I caused said envelope(s) to be
18 delivered by a professional messenger or courier service, on the date below.
19 (X) BY EMAIL: I caused a true and correct copy(ies) of the above documents to be sent via
electronic service to the email address(es) listed above. I did not receive a notice
20 indicating delivery failure.
21 I declare under penalty of perjury under the laws of the state of California that the
22 foregoing is true and correct. Executed on January 27, 2020, at Oakland, California.
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Sandra Peralta-Bernal
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PROOF OF SERVICE
1 I am employed in the County of Alameda, State of California. I am over the age of 18 years
2 and not a party to this action. My business address is 328 15 thStreet, Oakland, California 94612.
3 On the date below, I served the attached document·described as,
4 DECLARATION OF RAYMONDE. LOUGHREY IN SUPPORT OF
PLAINTIFF TON KIANG RESTAURANT, INC.'S OPPOSITION TO
5 DEFENDANT WWJW FAMILY LLC'S MOTION TO COMPEL
RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS,
6 SET ONE
7 on the interested parties in this action:
8 Ryan K. J. Mau, Esq.
9 LAW OFFICE OF RY AN MAU, PC
333 Bush Street, 21 st Floor
10 San Francisco, CA 94104
Email: ryan@rmaulaw.com
11
(X) BY MAIL: I enclosed the document in a sealed envelope addressed to the party(ies)
12 listed above, with postage thereon fully prepaid and placed the envelope for collection
and mailing, following our ordinary business practices. I am readily familiar with this
13 business's practice for collecting and processing correspondence for mailing. On the
same day that correspondence is placed for collection and mailing, it is deposited in the
14 ordinary course of business with the United States Postal Service.
15 ( ) BY OVERNIGHT SERVICE: I enclosed the document in a sealed envelope(s)
addressed to the person( s) listed above. Then, I placed the envelope for collection and
16
overnight delivery by Federal Express, with receipts affixed thereto promising delivery
17 to the addressee( s) on the following business day.
18 ( ) BY HAND DELIVERY: I enclosed true and correct copies of the documents in a
sealed envelope addressed to the party(ies) listed above. I caused said envelope(s) to be
19 delivered by a professional messenger or courier service, on the date below.
20 (X) BY EMAIL: I caused a true and correct copy(ies) of the above documents to be sent via
electronic service to the email address( es) listed above. I did not receive a notice
21 indicating delivery failure.
22
I declare under penalty of perjury under the laws of the state of California that the
23
foregoing is true and correct. Executed on January 27, 2020, at Oakland, California.
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26 Sandra Peralta-Bernal
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l
PROOF OF SERVICE
Preview
1 KIRSCHENBAUM LAW, PC JEFFREY B. KIRSCHENBAUM (SBN: 152290) 2 RAYMONDE. LOUGHREY (SBN: 194363) ELECTRONICALLY 328 15 th Street 3 Oakland, CA 94612 F I L E D Superior Court of California, Telephone (510) 740-9260 County of San Francisco 4 Email: jeff@kirschenbaumlaw.com 01/27/2020 5 Attorneys for Plaintiff and Cross-Defendant Clerk of the Court BY: EDNALEEN ALEGRE TON KIANG RESTAURANT, INC. Deputy Clerk 6 7 8 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 CITY AND COUNTY OF SAN FRANCISCO 11 12 TON KIANG RESTAURANT, INC., CASE NO. CGC-19-574262 13 Plaintiff, (Consolidated with Case No. CUD-19-664262) 14 V. 15 WILLIAM WONG, WWJW FAMILY LLC, a DECLARATION OF RAYMONDE. California Limited Liability Company, and LOUGHREY IN SUPPORT OF 16 DOESl-10, inclusive, PLAINTIFF TON KIANG RESTAURANT, INC.'S OPPOSITION TO DEFENDANT 17 Defendants. WWJW FAMILY LLC'S MOTION TO 18 COMPEL RESPONSES TO REQEUST WILLIAM WONG and WWJW FAMILY LLC, FOR PRODUCTION OF DOCUMENTS, 19 SET ONE Cross-Complainants, 20 Hearing Date: February 7, 2020 v. Hearing Time: 9:30 a.m. 21 TON KIANG RESTAURANT, INC., and ROES Place: Dept. 501 22 1-25, 23 Cross-Defendants. Action Filed: March 4, 2019 Trial Date: September 14, 2020 24 AND CONSOLIDATED ACTION 25 26 27 2811----------------------------------+ LOUGHREY DECLARATION IN OPPOSITION TO Printed on Recycled Paper WWJW'S MOTION TO COMPEL RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS Case No. CGC-19-574262 I CUD-19-664262 1 I, RAYMONDE. LOUGHREY, declare as follows: 2 1. I am duly admitted to practice law in the State of California, including this Court. I 3 am employed by the firm of Kirschenbaum Law, P.C., counsel for plaintiff and cross-defendant 4 TON KIANG RESTAURANT, INC. ("Ton Kiang"). I have personal knowledge of the matters set 5 forth herein and, if called as a witness, could and would competently testify thereto. 6 7 2. On January 27, 2020, Ton Kiang served, without objection and without asserting 8 any privilege, full and complete responses to defendant and cross-complainant WWJW FAMILY 9 LLC's Request for Production of Documents, Set One. Ton Kiang agreed to produce all 10 documents within its possession, custody, or control in response to requests numbers 1, 4, 6, 7, 8, 11 9, 10, and 12, and will produce such documents as soon as possible. Ton Kiang, after making a 12 diligent search and reasonable inquiry, is not aware of the existence to any documents in response 13 to requests numbered 2, 3, 5, and 11. A true and correct copy of Ton Kiang's response is attached 14 15 hereto as Exhibit A. 16 I declare under penalty of perjury under the laws of the State of California that the 17 foregoing is true and correct. 18 Executed this 27 th day of January 2020, at Oakland, California. 19 20 21 22 23 24 25 26 27 2811--------------------------------- LOUGHREY DECLARATION IN OPPOSITION TO 2 Printed on Recycled Paper WWJW'S MOTION TO COMPEL RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS Case No. CGC-19-574262 / CUD-19-664262 EXHIBIT A 1 KIRSCHENBAUM LAW, PC JEFFREY B. KIRSCHENBAUM (SBN: 152290) 2 RAYMONDE. LOUGHREY (SBN: 194363) KRISTIN L. WILLIAMS (SBN: 312902) 3 328 15th Street Oakland, CA 94612 4 Telephone: (510) 740-9260 Email: Jeff@Kirschenbaumlaw.com 5 Attorneys for Plaintiff 6 TON KIANG RESTAURANT, INC. 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF SAN FRANCISCO 10 UNLIMITED CIVIL JURISDICTION 11 TON KIANG RESTAURANT, INC. CASE NO. CGC-19-574262 [Consolidated with CUD-19-664262] 12 Plaintiff, 13 v. PLAINTIFF'S RESPONSES TO WWJW FAMILY LLC'S REQUEST FOR 14 WILLIAM WONG, WWJW FAMILY LLC, a PRODUCTION OF DOCUMENTS, SET California Limited Liability Company, and ONE 15 DOES 1-10, inclusive 16 Defendants. 17 18 19 AND RELATED CROSS-ACTION AND CONSOLIDATED ACTION. 20 21 22 23 PROPOUNDING PARTY: Defendant and Cross-Complainant WWJW FAMILY LLC 24 RESPONDING PARTY: Plaintiff and Cross-Defendant TON KIANG RESTAURANT, INC. 25 SETNO.: One (1) 26 27 28 PLAINTIFF'S RESPONSES TO WWJW FAMILY LLC'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE 1 Plaintiff and cross-defendant TON KIANG RESTAURANT (hereinafter referred to as 2 "Plaintiff'), pursuant to the provisions of sections 2031.10 et seq. of the California Code of Civil 3 Procedure, hereby responds to the Requests for Production of Documents, Set One, propounded by 4 defendant WWJW FAMILY LLC ("Defendant") as follows: 5 REQUEST FOR PRODUCTION NO. 1: 6 Any and all DOCUMENTS that support YOUR contention that you paid real PROPERTY 7 tax for 5821 Geary Boulevard to the City of San Francisco as alleged in your COMPLAINT. 8 RESPONSE TO REQUEST FOR PRODUCTION NO. 1: 9 Plaintiff will comply with this request and will produce all DOCUMENTS in its possession, 10 custody, or control. 11 REQUEST FOR PRODUCTION NO. 2: 12 Any and all DOCUMENTS to prove YOU made re~tal payments in the amount of $120,000 13 for 5821 Geary Boulevard in San Francisco, California for the calendar year 2018 as reflected on 14 YOUR 2018 tax returns. 15 RESPONSE TO REQUEST FOR PRODUCTION NO. 2: 16 A diligent search and reasonable inquiry for responsive DOCUMENTS has been made. 17 However, Plaintiff is unable to comply with this request. Plaintiff is unaware of the existence of 18 any documents responsive to this request. 19 REQUEST FOR PRODUCTION NO. 3: 20 Any and all cancelled checks to prove YOU made rental payments in the amount of 21 $120,000.00 for 5821 Geary Boulevard in San Francisco, California for the calendar year 2018 as 22 reflected in YOUR tax returns. 23 RESPONSE TO REQUEST FOR PRODUCTION NO. 3: 24 A diligent search and reasonable inquiry for responsive DOCUMENTS has been made. 25 However, Plaintiff is unable to comply with this request. Plaintiff is unaware of the existence of 26 any documents responsive to this request. 27 REQUEST FOR PRODUCTION NO. 4: 28 Any and all Schedule L's attached to YOUR tax returns for 2010-2018. 2 PLAINTIFF'S RESPONSES TO WWJW FAMILY LLC's REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE 1 RESPONSE TO REQUEST FOR PRODUCTION NO. 4: 2 Plaintiff will comply with this request and will produce all DOCUMENTS in its possession, 3 custody, or control. 4 REQUEST FOR PRODUCTION NO. 5: 5 Any and all Operating Agreements for Ton Kiang Restaurant Inc. 6 RESPONSE TO REQUEST FOR PRODUCTION NO. 5: 7 A diligent search and reasonable inquiry for responsive DOCUMENTS has been made. 8 However, Plaintiff is unable to comply with this request. Plaintiff is unaware of the existence of 9 any documents responsive to this request. IO REQUEST FOR PRODUCTION NO. 6: 11 Any and all DOCUMENTS that reflect the names of the corporate officers and directors for !2 Ton Kiang Restaurant, Inc. for each specific year from 2010 through the present. 13 RESPONSE TO REQUEST FOR PRODUCTION NO. 6: 14 Plaintiff will comply with this request and will produce all DOCUMENTS in its possession, 15 custody, or control. 16 REQUEST FOR PRODUCTION NO. 7: 17 Any and all DOCUMENTS that reflect the names of the shareholders for Ton Kiang 18 Restaurant, Inc. for each specific year from 2010 through the present. 19 RESPONSE TO REQUEST FOR PRODUCTION NO. 7: 20 Plaintiff will comply with this request and will produce all DOCUMENTS in its possession, 21 custody, or control. 22 REQUEST FOR PRODUCTION NO. 8: 23 Any and all DOCUMENTS that reflect the percentage shares held by any shareholders for 24 Ton Kiang Restaurant Inc. for each specific year from 2010 through the present. 25 RESPONSE TO REQUEST FOR PRODUCTION NO. 8: 26 Plaintiff will comply with this request and will produce all DOCUMENTS in its possession, 27 custody, or control. 28 3 PLAJNTIFF'S RESPONSES TOWWJW FAMILY LLC's REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE 1 REQUEST FOR PRODUCTION NO. 9: 2 Any and all DOCUMENTS that support YOUR contention that someone other than WWJW 3 Family LLC or William Wong paid the REAL PROPERTY TAXES on the PROPERTY at any 4 time during the period October 2010 through the present as alleged in YOUR COMPLAINT. 5 RESPONSE TO REQUEST FOR PRODUCTION NO. 9: 6 Plaintiff will comply with this request and will produce all DOCUMENTS in its possession, 7 custody, or control. 8 REQUEST FOR PRODUCTION NO. 10: 9 Any and all DOCUMENTS that support YOUR contention that YOU paid the REAL 10 PROPERTY TAXES on the PROPERTY at any time during the period of October 2010 through 11 the present as alleged in YOUR COMPLAINT. 12 RESPONSE TO REQUEST FOR PRODUCTION NO. 10: 13 Plaintiff will comply with this request and will produce all DOCUMENTS in its possession, 14 custody, or control. 15 REQUEST FOR PRODUCTION NO. 11: 16 Any and all DOCUMENTS that support YOUR contention that William Wong received 17 $400,000 from his father's Charles Schwab account, alleged in YOUR COMPLAINT. 18 RESPONSE TO REQUEST FOR PRODUCTION NO. 11: 19 A diligent search and reasonable inquiry for responsive DOCUMENTS has been made. 20 However, Plaintiff is unable to comply with this request. Plaintiff is unaware of the existence of 21 any documents responsive to this request. 22 REQUEST FOR PRODUCTION NO. 12: 23 Any and all DOCUMENTS that reflect the dates and amounts of each and every payment 24 YOU made to date that allegedly covers the carrying costs for the PROPERTY after William took 25 title as alleged in YOUR COMPLAINT. 26 RESPONSE TO REQUEST FOR PRODUCTION NO. 12: 27 Plaintiff will comply with this request and will produce all DOCUMENTS in its possession, 28 custody, or control. 4 PLAINTIFF'S RESPONSES TO \VWJW FAMILY LLC'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE 1 DATED: January 27, 2020 KIRSCHENBAUM LAW, PC 2 3 4 5 Attorneys for Plaintiff TON KIANG RESTAURANT, INC. 6 7 8 9 10 11 !2 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 5 PLAINTWF'SR.ESPONSESTO\\'WJWFAMILYLLC'sREQUESTFORPRODUCTIONOFDOCUMENTS,SET0NE VERIFlCATtON 2 3 i, RICHARD WONG, declare: 4 I am President and Chief Executive Officer of plaintiff Ton Kiang Restaurant, lnc., and am authorized to execute this verification on the company" s behalf. I have read the foregoing Responses to WWJW FAMILY, LLC's Requests for Production of Documents (Set One) and know the contents thereof. The same is true of my own knowledge, except as to those matters that are therein stated upon my information and beficf, and as to those matters 1 believe it to be true. l declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Dated: January 2 ') . 2020 /_ ,I-[.,, -------1_. _,, .,I .-· . . RI Cl-JAR J.Y\¥oNG I am employed in the County of Alameda, State of California. I am over the age of 18 years 2 and not a party to this action. My business address is 328 15 th Street, Oakland, California 94612. 3 On the date below, I served the attached document described as: 4 PLAINTIFF'S RESPONSES TO WWJW FAMILY LLC'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE 5 on the interested parties in this action: 6 Counsel for Defendants 7 Ryan K. J. Mau, Esq. LAW OFFICE OF RYAN MAU, PC 8 333 Bush Street, 2151 Floor San Francisco, CA 94104 9 Email: ryan@rmaulaw.com 10 (/\) BY MAIL: I enclosed the document in a sealed envelope addressed to the party(ies) 11 listed above, with postage thereon fully prepaid and placed the envelope for collection and mailing, following our ordinary business practices. I am readily familiar with this 12 business's practice for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the 13 ordinary course ofbusiness with the United States Postal Service. 14 ( ) BY OVERNIGHT SERVICE: I enclosed the document in a sealed envelope(s) addressed to the person(s) listed above. Then, I placed the envelope for collection arid 15 overnight delivery by Federal Express, with receipts affixed thereto promising delivery to the addressee(s) on the following business day. 16 ( ) BY HAND DELIVERY: I enclosed true and correct copies of the documents in a 17 sealed envelope addressed to the party(ies) listed above. I caused said envelope(s) to be 18 delivered by a professional messenger or courier service, on the date below. 19 (X) BY EMAIL: I caused a true and correct copy(ies) of the above documents to be sent via electronic service to the email address(es) listed above. I did not receive a notice 20 indicating delivery failure. 21 I declare under penalty of perjury under the laws of the state of California that the 22 foregoing is true and correct. Executed on January 27, 2020, at Oakland, California. 23 24 Sandra Peralta-Bernal 25 26 27 28 1 PROOF OF SERVICE 1 I am employed in the County of Alameda, State of California. I am over the age of 18 years 2 and not a party to this action. My business address is 328 15 thStreet, Oakland, California 94612. 3 On the date below, I served the attached document·described as, 4 DECLARATION OF RAYMONDE. LOUGHREY IN SUPPORT OF PLAINTIFF TON KIANG RESTAURANT, INC.'S OPPOSITION TO 5 DEFENDANT WWJW FAMILY LLC'S MOTION TO COMPEL RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, 6 SET ONE 7 on the interested parties in this action: 8 Ryan K. J. Mau, Esq. 9 LAW OFFICE OF RY AN MAU, PC 333 Bush Street, 21 st Floor 10 San Francisco, CA 94104 Email: ryan@rmaulaw.com 11 (X) BY MAIL: I enclosed the document in a sealed envelope addressed to the party(ies) 12 listed above, with postage thereon fully prepaid and placed the envelope for collection and mailing, following our ordinary business practices. I am readily familiar with this 13 business's practice for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the 14 ordinary course of business with the United States Postal Service. 15 ( ) BY OVERNIGHT SERVICE: I enclosed the document in a sealed envelope(s) addressed to the person( s) listed above. Then, I placed the envelope for collection and 16 overnight delivery by Federal Express, with receipts affixed thereto promising delivery 17 to the addressee( s) on the following business day. 18 ( ) BY HAND DELIVERY: I enclosed true and correct copies of the documents in a sealed envelope addressed to the party(ies) listed above. I caused said envelope(s) to be 19 delivered by a professional messenger or courier service, on the date below. 20 (X) BY EMAIL: I caused a true and correct copy(ies) of the above documents to be sent via electronic service to the email address( es) listed above. I did not receive a notice 21 indicating delivery failure. 22 I declare under penalty of perjury under the laws of the state of California that the 23 foregoing is true and correct. Executed on January 27, 2020, at Oakland, California. 24 25 26 Sandra Peralta-Bernal 27 28 l PROOF OF SERVICE