Party Discovery: Corona -v- Zhong et al Print

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                                ELECTRONICALLY FILED
     LIU LAW& INC.                              SUPERIOR COURT OF CALIFORNIA
                                                COUNTY OF SAN BERNARDINO
     Long Z. Liu, Esq. (SBN 236815)             SAN BERNARDINO DISTRICT
     David Lopez, Esq. (SBN 122477)
                                                12/28/2023 7:23 PM
 8   1163 Fairway Drive, Suite 105
     City of Industry, CA 91789                 By: Paola Iniguez Solorio, DEPUTY
     Telephone: (909) 468-2165
 s   Facsimile: (815) 331-0657
     Email: o fficetutheliulawfirm.corn
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     Attorneys for Defendant Jiang Kai Zhong dba NEW HAPPY DAY SPA
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                  SUPERIOR COURT OF THK STATE OF CALIFORNIA
 9                COUNTY OF SAN BERNADINO — CENTRAL DISTRICT
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     SARAH CORONA,                              Court Case No.: CIVSB2301961
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                  Plaintiff,
13                                     NOTICE OF MOTION AND
                   vs.
'4                                     MOTION BY DEFENDANT llANG
     JIANG KAI ZHONG dba NEW HAPPY DAY
                                       KAI ZHONG TO QUASH
     SPA; JANINA UNGUREANU; DOES I
     through 50, inclusive,            SUBPOENA; MEMORANDUM OF
16                                     POINTS AND AUTHORITIKS IN
17                De fendants.                  SUPPORT THEREOF;
                                                DECLARATION OF LONG Z. LIU
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20                                              Date: March 21, 2024
                                                Time: 8:30 a.m.
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                                                Dept; S-30
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      NOTICE OF MOTION AND MOTION BY DEFENDANT JIANG ICAI ZHONG TO QUASH SUBPOENA -   I
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     TO PLAINTIFF ANII HER COUNSEL OF RECORD:
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             PI.FASE TAKE NOTICE that on March 21, 2024 at 8:30 a.m., or as soon thereafter as
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     the matter may be heard in Department S-30 of the above-entitled court, Defendant Jiang Kai

     Zhong dba New Happy Day Spa (" Defendant" ) will and hereby does move this court to quash or
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     alternatively impose a protective order regarding the Deposition Subpoena For Production of
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     Business Records (" Subpoena") dated December 7, 2023 directed to SB County DA's Officc—
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     Appellate Services — 303 w. Third Streel., 6'" Floor, San Bernardino ("SB County DA's Oflice")
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     on the following grounds: (1) the Subpoena invade the rights of privacy of third parties; and (2)

13   the Subpoenas are overbroad and seek inl'ormation that is neither rclcvant nor reasonably
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     calculated to lead to the discovery of admissible evidence. This subpoena was served in bad faith
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     and therefore moves to quash the Subpoena.
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            This Motion is based upon this Notice, the attached Memorandum of Points and
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     Authorities and Declaration liled and served concurrently herewith, the records, papers and files

19   in the above-entitled action, and upon such documentary and oral evidence as may be introduced
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     at or prior to hearing on this Motion.
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     Dated: December 28, 2023                         Liu Law,

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                                                          Long
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                                                          dba N
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      NOTICE   OI'OTION AND MO'I'ION BY DEFENDANT JIANG KAI ZI lONG TO QUASH SUBPOENA - 2