On April 02, 2018 a
Separate Statement
was filed
involving a dispute between
Kenp Inc.,
Nguyen Khoa Dinh,
Perez Elmo Jr.,
and
Hoang Mike,
Huynh Tuyet,
Kenp Inc.,
Madrid Anthony A.,
Magnolia World Holding Llc,
Nguyen Calvin T.,
Nguyen Khoa Dinh,
Surgical Endo Llc,
Twenty Seven Trucking,
Www.Surgical-Endo.Com,
for Contractual Fraud (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
Efectromically FICED by SuperiorCourt of California, County of Los ANgEles OM 04/22/2019 04:08 PMS Hert R- Carter,EXECUNVE OMICETICTERK OF OUI, By E> Gregg Deputy Clerk
GRACE LEA CHANG, APC
GRACE LEA CHANG, SB #151564
301 E. COLORADO BLVD., SUITE 325
PASADENA, CA 914
626) 792-5888
626, 792-6886 Fax
Attomey for Plaintiff ELMO PEREZ, JR.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
10
il ELMO PEREZ, JR., Case No.: BC700475
12 Plaintiffs, SEPARATE STATEMENT IN SUPPORT
OF MOTION TO COMPEL FURTHER
13 VS. RESPONSES TO PLAINTIFF’S FORM
INTERROGATORIES TO SURGICAL
“4 KHOA DINH NGUYEN, et al., ENDO LLC [SET ONE]
15 Defendants. Date: May 16, 2019
Time: 8:30AM
16
Dept.: 62
7 Judge: Hon, Michael Stern
18 RES ID 134336611658
19
20 SEPARATE STATEMENT
21 This separate statement discusses the inadequacy of Defendant's responses to Form
22 Interrogatories propounded by Plaintiff. As set forth in this Separate Statement, Defendant
23 provides identical objections to multiples of the questions, all without basis. The interrogatories
24 are not vague, the information is not equally available to Plaintiff, and Plaintiff has already
25 discussed the right of privacy in some detail in the Motion to Compel. Moreover, these
26 responses are virtually identical to the responses provided by Khoa Dinh Nguyen. It is highly
a7 unlikely that the responses provided by two different law firms would be identical as to each and
28 every questioned From Interrogatory unless the firms are sharing information.
-l-
SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER RESPOONSES TO PLAINTIFF'S
GRACE Lea CHANG, APC.
Lawyers FORM INTERROGATORIES PROPOUNDED ON SURGICAL ENDO LLC
Document Filed Date
April 22, 2019
Case Filing Date
April 02, 2018
Category
Contractual Fraud (General Jurisdiction)
Status
Request for Dismissal - Before Trial not following ADR or more than 60 days since ADR 01/27/2020
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Efectromically FICED by SuperiorCourt of California, County of Los ANgEles OM 04/22/2019 04:08 PMS Hert R- Carter,EXECUNVE OMICETICTERK OF OUI, By E> Gregg Deputy Clerk GRACE LEA CHANG, APC GRACE LEA CHANG, SB #151564 301 E. COLORADO BLVD., SUITE 325 PASADENA, CA 914 626) 792-5888 626, 792-6886 Fax Attomey for Plaintiff ELMO PEREZ, JR. SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES 10 il ELMO PEREZ, JR., Case No.: BC700475 12 Plaintiffs, SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER 13 VS. RESPONSES TO PLAINTIFF’S FORM INTERROGATORIES TO SURGICAL “4 KHOA DINH NGUYEN, et al., ENDO LLC [SET ONE] 15 Defendants. Date: May 16, 2019 Time: 8:30AM 16 Dept.: 62 7 Judge: Hon, Michael Stern 18 RES ID 134336611658 19 20 SEPARATE STATEMENT 21 This separate statement discusses the inadequacy of Defendant's responses to Form 22 Interrogatories propounded by Plaintiff. As set forth in this Separate Statement, Defendant 23 provides identical objections to multiples of the questions, all without basis. The interrogatories 24 are not vague, the information is not equally available to Plaintiff, and Plaintiff has already 25 discussed the right of privacy in some detail in the Motion to Compel. Moreover, these 26 responses are virtually identical to the responses provided by Khoa Dinh Nguyen. It is highly a7 unlikely that the responses provided by two different law firms would be identical as to each and 28 every questioned From Interrogatory unless the firms are sharing information. -l- SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER RESPOONSES TO PLAINTIFF'S GRACE Lea CHANG, APC. Lawyers FORM INTERROGATORIES PROPOUNDED ON SURGICAL ENDO LLC