On June 22, 2010 a
Party Discovery
was filed
involving a dispute between
Cathay Bank, A California Banking Corporation,
Qui, Dong Ying,
Ray Kai, Llc, A California Limited Liability,
Xiang Kai, Llc.; A California Limited Liability,
Zhang, Cindy,
Zhang, Raymond,
Zhangs, Llc, A California Limited Liability,
and
Does 1 Through 200, Inclusive,
Qui, Dong Ying,
Ray Kai, Llc, A California Limited Liability,
Xiang Kai, Llc.; A California Limited Liability,
Zhang, Cindy,
Zhang, Raymond,
Zhangs, Llc, A California Limited Liability,
for civil
in the District Court of San Francisco County.
Preview
ICME
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
Sep-10-2012 2:55 pm
Case Number: CGC-10-500934
Filing Date: Sep-10-2012 2:53
Filed by: RONNIE OTERO
Juke Box: 001 Image: 03757103
MOTION (CIVIL GENERIC)
CATHAY BANK, A CALIFORNIA BANKING CORPORATION VS. RAYMOND
XIANG ZHANG et al
001003757103
Instructions:
Please place this sheet on top of the document to be scanned.An Bw NH =
o Oo ND
Chijeh Hu (SBN 241271)
CJH & ASSOCIATES, P.C.
1440 Broadway, Suite 1000
Oakland, CA 94612
Telephone: (510) 832-1686
Fax: (510) 251-1155
Attorney for Defendants/Cross
Complainants,
RAYMOND ZHANG, et al.
yererep COURT
yey OF CAN FRANTSCE
a7 sep 10, AMUSO
out i C
BY —s
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN FRANCISCO
CATHAY BANK, a California banking
Corporation,
Plaintiff,
v.
RAYMOND XIANG KAI ZHANG, et al.,
Defendants.
CASE NO: CGC- 10 - 500934
NOTICE OF MOTION AND MOTION TO
QUASH DEPOSITION SUBPOENAS FOR
CONSUMER RECORDS OF DEFENDANTS;
SEPARATE STATEMENT OF DISPUTED
DISCOVERY REQUESTS UNDER CRC
3.1345; DECLARATION OF MAUREEN
MCCUAIG; MEMORANDUM OF POINTS
AND AUTHORITIES
REQUEST FOR MONETARY SANCTIONS
AGAINST PLAINTIFF AND ITS ATTORNEY,
FRANDZEL ROBINS BLOOM & CSATO,
L.C. IN THE SUM OF $3,500
C.C.P. § 1987.1 — 1987.2, §2023.030
Date: October 12, 2012
Time: 9:30am
Dept.: 302
-1-
NOTICE OF MOTION AND MOTION TO QUASH DEPOSITION SUBPOENAS FOR CONSUMER RECORDS OF
DEFENDANTS
|| PLEASE TAKE NOTICE that Defendants Raymond Zhang, Cindy Zhang and Dong
Ying Qui will move the Court at the above date and time for an order to quash the deposition
subpoenas for production of business records now scheduled for September 14, 2012, and for
monetary sanctions in the amount of $3,500 under Cal. Code Civ. Pro. §1987.2 and §2023.030
against Plaintiff Cathay Bank and its attorney Frandzel Robins Bloom & Csato, L.C. This
motion is made under Cal. Code Civ. Pro. §1987.1 on the grounds that the deposition
subpoenas, notice of which was served on Defendants on August 23, 2012, seeks privileged or
otherwise inadmissible documents and fails to adequately identify documents to be produced.
This motion is based on this notice, the attached supporting memorandum, the attached
separate statement of disputed discovery requests, the attached declaration of Maureen
McCuaig, the attached notice of deposition, all pleadings, records and files in this action and
| further oral and documentary evidence as may be presented at the time of the hearing on this
motion.
| Date: September » 2012 By. heey
ijeh Hu
Attorney for Defendants,
Raymond Zhang, et al.
-l-
NOTICE OF MOTION AND MOTION TO QUASH DEPOSITION SUBPOENAS FOR CONSUMER RECORDS OF
NEFENDANTS
Document Filed Date
September 10, 2012
Case Filing Date
June 22, 2010
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ICME SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Document Scanning Lead Sheet Sep-10-2012 2:55 pm Case Number: CGC-10-500934 Filing Date: Sep-10-2012 2:53 Filed by: RONNIE OTERO Juke Box: 001 Image: 03757103 MOTION (CIVIL GENERIC) CATHAY BANK, A CALIFORNIA BANKING CORPORATION VS. RAYMOND XIANG ZHANG et al 001003757103 Instructions: Please place this sheet on top of the document to be scanned.An Bw NH = o Oo ND Chijeh Hu (SBN 241271) CJH & ASSOCIATES, P.C. 1440 Broadway, Suite 1000 Oakland, CA 94612 Telephone: (510) 832-1686 Fax: (510) 251-1155 Attorney for Defendants/Cross Complainants, RAYMOND ZHANG, et al. yererep COURT yey OF CAN FRANTSCE a7 sep 10, AMUSO out i C BY —s SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO CATHAY BANK, a California banking Corporation, Plaintiff, v. RAYMOND XIANG KAI ZHANG, et al., Defendants. CASE NO: CGC- 10 - 500934 NOTICE OF MOTION AND MOTION TO QUASH DEPOSITION SUBPOENAS FOR CONSUMER RECORDS OF DEFENDANTS; SEPARATE STATEMENT OF DISPUTED DISCOVERY REQUESTS UNDER CRC 3.1345; DECLARATION OF MAUREEN MCCUAIG; MEMORANDUM OF POINTS AND AUTHORITIES REQUEST FOR MONETARY SANCTIONS AGAINST PLAINTIFF AND ITS ATTORNEY, FRANDZEL ROBINS BLOOM & CSATO, L.C. IN THE SUM OF $3,500 C.C.P. § 1987.1 — 1987.2, §2023.030 Date: October 12, 2012 Time: 9:30am Dept.: 302 -1- NOTICE OF MOTION AND MOTION TO QUASH DEPOSITION SUBPOENAS FOR CONSUMER RECORDS OF DEFENDANTS || PLEASE TAKE NOTICE that Defendants Raymond Zhang, Cindy Zhang and Dong Ying Qui will move the Court at the above date and time for an order to quash the deposition subpoenas for production of business records now scheduled for September 14, 2012, and for monetary sanctions in the amount of $3,500 under Cal. Code Civ. Pro. §1987.2 and §2023.030 against Plaintiff Cathay Bank and its attorney Frandzel Robins Bloom & Csato, L.C. This motion is made under Cal. Code Civ. Pro. §1987.1 on the grounds that the deposition subpoenas, notice of which was served on Defendants on August 23, 2012, seeks privileged or otherwise inadmissible documents and fails to adequately identify documents to be produced. This motion is based on this notice, the attached supporting memorandum, the attached separate statement of disputed discovery requests, the attached declaration of Maureen McCuaig, the attached notice of deposition, all pleadings, records and files in this action and | further oral and documentary evidence as may be presented at the time of the hearing on this motion. | Date: September » 2012 By. heey ijeh Hu Attorney for Defendants, Raymond Zhang, et al. -l- NOTICE OF MOTION AND MOTION TO QUASH DEPOSITION SUBPOENAS FOR CONSUMER RECORDS OF NEFENDANTS