Motion-Secondary: WATER FLOWER APPAREL, INC. VS ONEWORLD APPAREL, LLC

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 12/16/2022 04:42 PM Sherri R. Carter, Executive Officer/Clerk of Court, by R. Perez,Deputy Clerk




                      Grant J. Hallstrom (SBN 203830)
                 1 Betty J. Levine (SBN 105961)
                 2
                   HALLSTROM, KLEIN & WARD, LLP
                   15615 Alton Pkwy., Suite 175
                 3 Irvine, CA 92618
                   Telephone: (949) 450-8500
                 4 Facsimile: (949) 450-1588
                 5 Attorneys for Plaintiff
                      Water Flower Apparel, Inc.
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                 7
                                                   SUPERIOR COURT OF THE STATE OF CALIFORNIA
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                                FOR THE COUNTY OF LOS ANGELES, STANLEY MOSK COURTHOUSE
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               10
                        WATER FLOWER APPAREL, INC., a                                                   CASE NO.: 22STCV38063
               11       California corporation,
                                                                                                        UNLIMITED CIVIL
               12                              Plaintiff,
                                                                                                        DECLARATION OF WILLIAM ZHOU IN
               13       vs.                                                                             SUPPORT OF PLAINTIFF’S EX PARTE
               14       ONEWORLD APPAREL, LLC, a California                                             APPLICATION FOR RIGHT TO
                        limited liability company; and DOES 1                                           ATTACH ORDER AND WRIT OF
               15       through 50, inclusive,                                                          ATTACHMENT AGAINST DEFENDANT
               16                                                                                       ONEWORLD APPAREL, LLC
                                               Defendants.
               17                                                                                       Date: December 20, 2022
                                                                                                        Time: 8:30 a.m.
               18
                                                                                                        Dept.: 85
               19
                                                                                                        Action Filed: December 6, 2022
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               21                                                   DECLARATION OF WILLIAM ZHOU
               22                I, Yonglian Zhou also known as William Zhou declare as follows:
               23                1.          I am the owner and Chief Executive Officer of Plaintiff Water Flower Apparel,
               24 Inc. (“Water”). I make this Declaration in support of Water’s Ex Parte Application for Right to
               25 Attach Order and Writ of Attachment against Defendant OneWorld Apparel, LLC
               26 (“OneWorld”). I have first hand personal knowledge of the matters stated herein and, if called
               27 upon to testify thereto, I would and could competently do so.
               28                2.          Waters is in the wholesale trade business of procuring and/or manufacturing
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                                                                            DECLARATION OF WILLIAM ZHOU