Document for ELMO PEREZ JR VS KHOA DINH NGUYEN ET AL

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 04/23/2019 03:18 PM Sherri R. Carter, Executive Officer/Clerk of Court, by D. Davis, Deputy Clerk




                                GRACE LEA CHANG, APC
                                GRACE LEA CHANG, SB #151564
                                SUSAN CARTER, SB#132201
                                301 E. COLORADO BLVD., SUITE 325
                                PASADENA, CA 91101
                                 626, 792-5888
                                 626 792-6886 FAX
                                Attorney for Plaintiff
                                ELMO PEREZ, JR.



                                                               SUPERIOR COURT OF THE STATE OF CALIFORNIA
                                                                           FOR THE COUNTY OF LOS ANGELES
                        10

                        11      ELMO PEREZ, JR.,                                                              Case No.: BC700475
                        12                                         Plaintiffs,                                SEPARATE STATEMENT IN SUPPORT
                                                                                                              OF MOTION TO COMPEL FURTHER
                        13                  VS.                                                               RESPONSES TO PLAINTIFF’S
                                                                                                              REQUESTS FOR IDENTIFICATION AND
                        14      KHOA DINH NGUYEN, et al.,                                                     PRODUCTION OF DOCUMENTS TO
                                                                                                              KHOA DINH NGUYEN [SET ONE]
                        15                                         Defendants.
                                                                                                              Date:      Mary 14, 2019
                        16                                                                                    Time:      8:30AM
                        17                                                                                    Dept.:62
                                                                                                              Judge: Hon. Michael Stem
                        18
                                                                                                              RES ID 861582388732
                        19

                        20

                        21                                                           SEPARATE STATEMENT
                        22                  This separate statement discusses the inadequacy of Defendant’s responses to Requests

                        23      for Identification and Production of Documents propounded by Plaintiff. As set forth in this
                        24      Separate Statement, Defendant provides identical objections to multiples of the questions, all
                        25      without basis, The Requests not cannot seek trade secrets as the original corporation was a
                        26      partnership between Plaintiff and Khoa Dinh Nguyen, and the new corporation identical in
                        27      function, the Requests are not overbroad, the information Surgical Endo LLC is not equally or
                        28      more accessible to Plaintiff, and Plaintiff has already discussed the right of privacy in some


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 GRACE LEA CHANG, APC
                                       SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER RESPOONSES TO PLAINTIFF'S
           Lawers                         REQUESTS FOR IDENTIFICATION AND PRODUCTION OF DOCUMENTS TO KHOA DINH NGUYEN