Preview
David M. Shaby 11, Esq. (97871) SUCPZERIOR. gFousgggFEmgggm
dshab @shabyandassociates.com 5A" BERNARD'NC’ D'STR'CT
R. Chrlstopher Harshman Esq. (248214)
charshman@shabyandass’ociatesxom MAY 2 6 2021
DAVID M. SHABY II 8c ASSOCIATES, APC
119149 Jecfferson Bfgulevard, Suite
Cu ver ity Cali omia 90230
104
BY ” my]
DEBRA PEDHOSA' DEPUTY
Telephonez) 310 827—7171
Facs1mile: 310 822-8529
Attomglsfor Defendant and Cross— Com lainant Sandy Acosta
and Defendants Marvin J. Guzman a Ulises A. Zepeda
SUPERIOR COURT 0F CALIFORNIA
COUNTY 0F SAN BERNARDINO
10 Jetcruzer International, LLC, Case no. CIVDSI930132
11 Plaintiff,
Assigned to the Hon. Tom Garza, Dept. 827
SUPPLEMENTAL DECLARATION 0F R.
12 vs'
CHRISTOPHER HARSHMAN IN SUPPORT OF
13 Sandy Acosta, et al,
MOTION T0 COMPEL FURTHER RESPONSES
Date: June 9, 2021
14 Defendants'
Time: 9:00 am.
1s And Related Cross—Complaint Department: 827
Complaint filed: October 8, 2019
16
Trial date: February 7, 2022
17
18 I, R. Christopher Harshman, declare as follows:
19 1. I am an attorney, duly licensed to practice law before all courts of the State of California,
20 and of counsel for David M. Shaby II 8: Associates, APC, attorneys of record for defendant and cross-
21 complainant Sandy Acosta (“Acosta”), and defendants Marvin J. Guzman and Ulises A. Zepeda in this
22 action. I have personal knowledge of the following facts. If called upon to testify, I could and would
23 testify competently to the facts set forth in this Declaration.
24 2. As the Court is aware, Ms. Acosta has pending a motion to compel further responses to
25 her Specially Prepared Interrogatories, Set One (the “Interrogatories”). Those Interrogatories include
26 numbers 1—6, which require plaintiff and cross—defendant JetCruzer International, LLC (“JetCruzer”)
27 to identify “all INTERESTED INVESTORS” (No. 1), “all INTERESTED PATRONS” (No. 3), and
28 “all POTENTIAL CUSTOMERS” (No. S).
1
SUPPLEMENTAL DECLARATION IN SUPPORT OF MOTION ’I‘O COMPEL FUR'I‘HER RESPON SES
3. In supplemental responses (see my April 5, 2021 Declaration in support of the instant
motion, Paragraph 11 and Exhibit K),JetCruzer made a variation of the following response:
The name of the INVESTOR is in a foreign language (Chinese). There are documents
containing the identity of the INVESTOR, and need to interpreted into English in order to
obtain the English-translated name, if there is such. Responding Party has not retained a
mVO‘Ul-bOJN
Chinese translator for such purpose, and thus the identities cannot be stated herein.
4. JetCruzer then referred us to their Exhibit AA (attached to my Exhibit K), a faded,
blurry, illegible document that appears to contain Chinese logograrns.
5. Subsequently, on May 7, 2021, my office received documents produced by East West
\O Bank in response to a subpoena for business records. One document in particularl found especially
10 notable, a check to JetCruzer with “Company Investment” in the memo field, from an individual with a
11 clearly Romanized name (“Tianyun Dong”). A true and correct copy 0f that produced check appears
12 inline after this paragraph (redacted as to all but the final four digits of the account number, and what
13 appears to be a residential address):
19115 UOCIMN' NA'» A Canl) Blcfifnfiogflfli AND mt‘MfH’MiHHNG I'M RFVFQM BM” INC! (IDES AK AR‘EBICIAL *‘ILMAIUI
14
15
I
ma "a35l’210
a
1°01
16
0m 7‘7 “3917
17 5%.?!“3 2‘6" r‘ .
’ona/ 46AM" Szaaaae;
18
m
ammefifiz/
4...:__.___.__. Mm
m'fiu
mu
19
i'WN'fi
20
21
22
L
WW
a 3 a 1.0003551:
6. Attached hereto
-q
is
aaor mo a.
a true and correct copy of a Declaration supplied by East
.J
West Bank
23
in connection with the documents produced.
24
7. Earlier this afternoon, I shared a copy of that check with attorney Grant Reader, counsel
25
forJetCruzer; I also, on May 14, 2021, sent Mr. Reader and Angelica Samaniego (also counsel for
26
JetCruzer) a courtesy copy of the hundreds of pages produced by East West Bank.
27
28
2
SUPPLEMENTAL DECLARATION IN SUPPORT 0F MOTION T0 COMPEL FURTHER RESPONSES
Preview
David M. Shaby 11, Esq. (97871) SUCPZERIOR. gFousgggFEmgggm dshab @shabyandassociates.com 5A" BERNARD'NC’ D'STR'CT R. Chrlstopher Harshman Esq. (248214) charshman@shabyandass’ociatesxom MAY 2 6 2021 DAVID M. SHABY II 8c ASSOCIATES, APC 119149 Jecfferson Bfgulevard, Suite Cu ver ity Cali omia 90230 104 BY ” my] DEBRA PEDHOSA' DEPUTY Telephonez) 310 827—7171 Facs1mile: 310 822-8529 Attomglsfor Defendant and Cross— Com lainant Sandy Acosta and Defendants Marvin J. Guzman a Ulises A. Zepeda SUPERIOR COURT 0F CALIFORNIA COUNTY 0F SAN BERNARDINO 10 Jetcruzer International, LLC, Case no. CIVDSI930132 11 Plaintiff, Assigned to the Hon. Tom Garza, Dept. 827 SUPPLEMENTAL DECLARATION 0F R. 12 vs' CHRISTOPHER HARSHMAN IN SUPPORT OF 13 Sandy Acosta, et al, MOTION T0 COMPEL FURTHER RESPONSES Date: June 9, 2021 14 Defendants' Time: 9:00 am. 1s And Related Cross—Complaint Department: 827 Complaint filed: October 8, 2019 16 Trial date: February 7, 2022 17 18 I, R. Christopher Harshman, declare as follows: 19 1. I am an attorney, duly licensed to practice law before all courts of the State of California, 20 and of counsel for David M. Shaby II 8: Associates, APC, attorneys of record for defendant and cross- 21 complainant Sandy Acosta (“Acosta”), and defendants Marvin J. Guzman and Ulises A. Zepeda in this 22 action. I have personal knowledge of the following facts. If called upon to testify, I could and would 23 testify competently to the facts set forth in this Declaration. 24 2. As the Court is aware, Ms. Acosta has pending a motion to compel further responses to 25 her Specially Prepared Interrogatories, Set One (the “Interrogatories”). Those Interrogatories include 26 numbers 1—6, which require plaintiff and cross—defendant JetCruzer International, LLC (“JetCruzer”) 27 to identify “all INTERESTED INVESTORS” (No. 1), “all INTERESTED PATRONS” (No. 3), and 28 “all POTENTIAL CUSTOMERS” (No. S). 1 SUPPLEMENTAL DECLARATION IN SUPPORT OF MOTION ’I‘O COMPEL FUR'I‘HER RESPON SES 3. In supplemental responses (see my April 5, 2021 Declaration in support of the instant motion, Paragraph 11 and Exhibit K),JetCruzer made a variation of the following response: The name of the INVESTOR is in a foreign language (Chinese). There are documents containing the identity of the INVESTOR, and need to interpreted into English in order to obtain the English-translated name, if there is such. Responding Party has not retained a mVO‘Ul-bOJN Chinese translator for such purpose, and thus the identities cannot be stated herein. 4. JetCruzer then referred us to their Exhibit AA (attached to my Exhibit K), a faded, blurry, illegible document that appears to contain Chinese logograrns. 5. Subsequently, on May 7, 2021, my office received documents produced by East West \O Bank in response to a subpoena for business records. One document in particularl found especially 10 notable, a check to JetCruzer with “Company Investment” in the memo field, from an individual with a 11 clearly Romanized name (“Tianyun Dong”). A true and correct copy 0f that produced check appears 12 inline after this paragraph (redacted as to all but the final four digits of the account number, and what 13 appears to be a residential address): 19115 UOCIMN' NA'» A Canl) Blcfifnfiogflfli AND mt‘MfH’MiHHNG I'M RFVFQM BM” INC! (IDES AK AR‘EBICIAL *‘ILMAIUI 14 15 I ma "a35l’210 a 1°01 16 0m 7‘7 “3917 17 5%.?!“3 2‘6" r‘ . ’ona/ 46AM" Szaaaae; 18 m ammefifiz/ 4...:__.___.__. Mm m'fiu mu 19 i'WN'fi 20 21 22 L WW a 3 a 1.0003551: 6. Attached hereto -q is aaor mo a. a true and correct copy of a Declaration supplied by East .J West Bank 23 in connection with the documents produced. 24 7. Earlier this afternoon, I shared a copy of that check with attorney Grant Reader, counsel 25 forJetCruzer; I also, on May 14, 2021, sent Mr. Reader and Angelica Samaniego (also counsel for 26 JetCruzer) a courtesy copy of the hundreds of pages produced by East West Bank. 27 28 2 SUPPLEMENTAL DECLARATION IN SUPPORT 0F MOTION T0 COMPEL FURTHER RESPONSES