On January 31, 2017 a
Conference
was filed
involving a dispute between
Chiu, Thai Ming,
Liu, Kaman,
Fu, Bryant,
Lei, Crystal,
and
Chiu, Thai Min,
Chiu, Thai Ming,
Does 1-20, Inclusive,
Liu, Kaman,
Yan, Tina,
for civil
in the District Court of San Francisco County.
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CHARLIE W. YU (SBN 268233)
1 ESSENTIAL LAW GROUP
548 Market Street, PMB 48752
2 San Francisco, CA 94104-5401 ELECTRONICALLY
Telephone: (415) 349-5180 F I L E D
3 Facsimile: (415) 349-5180 Superior Court of California,
County of San Francisco
4 Attorneys for Cross-Defendant 04/29/2022
STELLA CHEN aka HONG XING FU aka HONG XING CHEN Clerk of the Court
5 BY: SANDRA SCHIRO
Deputy Clerk
6
7 SUPERIOR COURT OF THE STATE OF CALIFORNIA
8 COUNTY OF SAN FRANCISCO
9 UNLIMITED CIVIL JURISDICTION
10
11 BRYANT FU et al., CASE NO. CGC-17-556769
12 Plaintiffs, DECLARATION RE: COMPLIANCE WITH
MEET AND CONFER REQUIREMENT
13 vs.
14 TINA YAN et al., Date: June 1, 2022
Time: 9:30 am
15 Defendants. Dept.: 501
Judge: Hon. Charles F. Haines
16
And RELATED CROSS-COMPLAINT
17
18 I, Charlie W. Yu, declare as follows:
19 1. I am one of the attorneys for Cross-Defendant STELLA CHEN. I have personal
20 knowledge of the facts stated in this declaration and would testify to them if called to do so.
21 2. On March 16, 2022, I conferred by e-mail with Mr. Leeds Disston, Esq., counsel
22 for Cross-Complainant THAI MING CHIU. In the e-mail, I explained to Mr. Chao the grounds
23 for my client’s position that the cross-complaint is legally insufficient, and provided him with
24 legal support for that position. Those grounds are the same as those set forth in the demurrer.
25 3. On March 16, 2022, Mr. Disston replied to my email stating that he will check
26 with his client “who will probably talk with his Brother in Law” and get back to me. Mr.
27 Disston never got back to me.
28 4. On March 28, 2022, I followed up with an email to Mr. Disston but did not
29 1
DECLARATION RE: COMPLIANCE WITH MEET AND CONFER REQUIREMENT
30 CASE NO. GC-17-556769
31
1 receive a response.
2 5. On April 5, 2022, I followed up with another email to Mr. Disston but did not
3 receive a response.
4 6. On April 26, 2022, I followed up with both a phone call to Mr. Disston, no one
5 picked up, and I left a voicemail, and I followed up with another email to Mr. Disston but did
6 not receive a response.
7 7. On April 28, 2022, I followed up with another phone call to Mr. Disston, no one
8 picked up, and I left another voicemail.
9 8. I have not received a response from Mr. Disston, and he did not offer to amend
10 the pleading to cure the legal insufficiency I described. Because no amendment was proposed,
11 the parties were unable to resolve the objections raised in the demurrer filed herewith.
12 I declare under penalty of perjury under the laws of the state of California that the
13 foregoing is true and correct.
14 Executed on April 29, 2022 at San Francisco, California
15
16 Charlie Yu
17 CHARLIE W. YU
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DECLARATION RE: COMPLIANCE WITH MEET AND CONFER REQUIREMENT
30 CASE NO. GC-17-556769
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Document Filed Date
April 29, 2022
Case Filing Date
January 31, 2017
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CHARLIE W. YU (SBN 268233) 1 ESSENTIAL LAW GROUP 548 Market Street, PMB 48752 2 San Francisco, CA 94104-5401 ELECTRONICALLY Telephone: (415) 349-5180 F I L E D 3 Facsimile: (415) 349-5180 Superior Court of California, County of San Francisco 4 Attorneys for Cross-Defendant 04/29/2022 STELLA CHEN aka HONG XING FU aka HONG XING CHEN Clerk of the Court 5 BY: SANDRA SCHIRO Deputy Clerk 6 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 COUNTY OF SAN FRANCISCO 9 UNLIMITED CIVIL JURISDICTION 10 11 BRYANT FU et al., CASE NO. CGC-17-556769 12 Plaintiffs, DECLARATION RE: COMPLIANCE WITH MEET AND CONFER REQUIREMENT 13 vs. 14 TINA YAN et al., Date: June 1, 2022 Time: 9:30 am 15 Defendants. Dept.: 501 Judge: Hon. Charles F. Haines 16 And RELATED CROSS-COMPLAINT 17 18 I, Charlie W. Yu, declare as follows: 19 1. I am one of the attorneys for Cross-Defendant STELLA CHEN. I have personal 20 knowledge of the facts stated in this declaration and would testify to them if called to do so. 21 2. On March 16, 2022, I conferred by e-mail with Mr. Leeds Disston, Esq., counsel 22 for Cross-Complainant THAI MING CHIU. In the e-mail, I explained to Mr. Chao the grounds 23 for my client’s position that the cross-complaint is legally insufficient, and provided him with 24 legal support for that position. Those grounds are the same as those set forth in the demurrer. 25 3. On March 16, 2022, Mr. Disston replied to my email stating that he will check 26 with his client “who will probably talk with his Brother in Law” and get back to me. Mr. 27 Disston never got back to me. 28 4. On March 28, 2022, I followed up with an email to Mr. Disston but did not 29 1 DECLARATION RE: COMPLIANCE WITH MEET AND CONFER REQUIREMENT 30 CASE NO. GC-17-556769 31 1 receive a response. 2 5. On April 5, 2022, I followed up with another email to Mr. Disston but did not 3 receive a response. 4 6. On April 26, 2022, I followed up with both a phone call to Mr. Disston, no one 5 picked up, and I left a voicemail, and I followed up with another email to Mr. Disston but did 6 not receive a response. 7 7. On April 28, 2022, I followed up with another phone call to Mr. Disston, no one 8 picked up, and I left another voicemail. 9 8. I have not received a response from Mr. Disston, and he did not offer to amend 10 the pleading to cure the legal insufficiency I described. Because no amendment was proposed, 11 the parties were unable to resolve the objections raised in the demurrer filed herewith. 12 I declare under penalty of perjury under the laws of the state of California that the 13 foregoing is true and correct. 14 Executed on April 29, 2022 at San Francisco, California 15 16 Charlie Yu 17 CHARLIE W. YU 18 19 20 21 22 23 24 25 26 27 28 29 2 DECLARATION RE: COMPLIANCE WITH MEET AND CONFER REQUIREMENT 30 CASE NO. GC-17-556769 31