Preview
20CV364020
Santa Clara — Civil
Y. Chavez
Electronically Filed
ANTHONY F. VENTURA, ESQ., SBN 191107 by Superior Court of CA,
aventura@venturahersey.com County of Santa Clara,
ALEXANDRIA C. KAVALARIS, ESQ., SBN 273522 on 7/24/2020 1:02 PM
akavalaris@venturahersey.com Reviewed By: Y. Chavez
VENTURA HERSEY & MULLER, LLP
1506 Hamilton Avenue Case #20CV364020
San Jose, CA 95125-4539 Envelope: 4656703
Telephone: 408.512.3022
Facsimile: 408.512.3023
Attorneys for
Defendant/Cross-Complainant Silva Management, Inc. and
Defendants Hao Chen and Xiaoyan Liu
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 FOR THE COUNTY OF SANTA CLARA
11
12 Zhaohua Meng, Case No. 20CV364020
13) Plaintiffs, DECLARATION OF ALEXANDRIA C.
KAVALARIS IN SUPPORT OF
14 vs. DEFENDANT’S MOTION TO COMPEL
RESPONSES TO INTERROGATORIES
15 Silva Management, Inc., Hao Chen; Xiaoyan AND DEMAND FOR PRODUCTION OF
Liu, Topcon Builder, Inc., Jiayu Lin, aka Jay DOCUMENTS AND FOR SANCTIONS
16 Lin, LEL Design, Inc., Leo Li, Wei Luo,
Asencion A.N. Ledesma, and DOES ONE Date:
17 through TEN, inclusive
Time: 9:00 AM
18 Defendants.
Dept.
19
Silva Management, Inc.,
20
Cross-Complainant,
21
VS.
22
Zhaohua Meng, Ran Tao, and Leilei Wang
23 and ROES 1-10, inclusive,
[Unlimited Civil Action — Amount Demanded
24 Cross-Defendants. Exceeds $25,000]
25
26 I, Alexandria C. Kavalaris, declare as follows:
27 1 Iam an attorney at law licensed to practice before all courts of the State of California.
28 Tam a partner of the law firm Ventura Hersey &Muller, LLP (“Ventura Hersey”) in San Jose,
DECLARATION OF ALEXANDRIA C. KAVALARIS IN SUPPORT OF MOTION TO COMPEL RESPONSES TO INTERROGATORIES AND.
DEMAND FOR PRODUCTION OF DOCUMENTS AND FOR SANCTIONS:
California, attorneys of record for Defendant/Cross-Complainant Silva Management, Inc. and
Defendants Hao Chen and Xiaoyan Liu.
2. I make this declaration in support of the Memorandum of Points and Authorities in
Support of Defendant’s Motion to Compel Responses to Interrogatories and Demand for Production
of Document and for Sanctions.
3 Attached hereto as Exhibit A is a true and correct copy of Defendant Silva
Management, Inc.'s Special Interrogatories to Plaintiff (Set One). The aforementioned
interrogatories were propounded via US Mail on April 6, 2020.
4. Attached hereto as Exhibit B is a true and correct copy of Defendant Silva
10 Management, Inc.’s Form Interrogatories to Plaintiff (Set One). The aforementioned interrogatories
11 were propounded via US Mail on April 6, 2020.
12 5 Attached hereto as Exhibit C is a true and correct copy of Defendant Silva
13) Management, Inc.’s Request for Production of Documents to Plaintiff (Set One). The
14 aforementioned request for production was propounded via US Mail on April 6, 2020.
15 6 Attached hereto as Exhibit D is a true and correct copy of the Proof of Service in
16 connection with the interrogatories and request for production of documents attached as Exhibits A
17 through C (collectively referred to as the “Discovery Requests”).
7
18 Plaintiff Zhaohua Meng’s responses were due on May 11, 2020.
19 8 No responses have been received from Plaintiff to date.
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DECLARATION OF ALEXANDRIA C. KAVALARIS IN SUPPORT OF MOTION TO COMPEL RESPONSES TO INTERROGATORIES AND.
DEMAND FOR PRODUCTION OF DOCUMENTS AND FOR SANCTIONS:
9 I spent 3.5 hours drafting the instant motion to compel and supporting documents. I
anticipate spending 2.5 hours to draft a reply to any opposition filed by Plaintiff. I further anticipate
billing 1.0 hour to attend the hearing on this motion. My hourly billing rate is $400.00. I am familiar
with the billing rates for attorneys practicing civil litigation in Santa Clara County, California, and
I believe my hourly rate to be consistent with a reasonable hourly rate charged by an attorney of my
background and experience.
I declare under penalty of perjury under the laws of the State of California that the foregoing
is true and correct. Executed at San Jose, California this 24"" day of July, 2020.
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ALEXANDRIA C. KAVALARIS
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DECLARATION OF ALEXANDRIA C. KAVALARIS IN SUPPORT OF MOTION TO COMPEL RESPONSES TO INTERROGATORIES AND.
DEMAND FOR PRODUCTION OF DOCUMENTS AND FOR SANCTIONS:
ANTHONY F. VENTURA, ESQ., SBN 191107
aventura@yventurahersey.com
MINGZI OUYANG, ESQ., SBN 314334
mouyang@venturahersey.com
VENTURA HERSEY & MULLER, LLP
1506 Hamilton Avenue
San Jose, California 95125
Telephone: (408) 512-3022
Facsimile: (408) 512-3023
Attorneys for Defendant/Cross-Complainant
Silva Management, Inc., Defendant Hao Chen
and Defendant Xiaoyan Liu
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SANTA CLARA.
10
ll ZHAOHUA MENG, Case No.: 20CV364020
12 Plaintiff, DEFENDANT SILVA MANAGEMENT,
INC.’S SPECIAL INTERROGATORIES TO
13 VS. PLAINTIFF ZHAOHUA MENG, SET ONE
14 Silva Management, Inc., Hao Chen, Xiaoyan
Liu, Topcon Builder, Inc., Jiayu Lin, Aka Jay
15 Lin, Lel Design, Inc., Leo Li, Wei Luo,
Asencion A. N. Ledesma, And Does One
16 Through Ten, Inclusive
[Unlimited Civil Action]
17 Defendants.
18
19 PROPOUNDING PARTY: Defendant SALVA MANAGEMENT, INC.
20 RESPONDING PARTY: Plaintiff ZHAOHUA MENG
21 SET NO.: ONE
22 Pursuant to Code of Civil Procedure sections 2030, et seg., Defendant Silva Management,
23 Inc. (“Propounding Party”) demands that Plaintiff Zhaohua Meng (“Responding Party”) answer
24 the following Special Interrogatories (Set One), fully and completely, in writing and under oath,
25 within 30 days of service.
26 INSTRUCTIONS
27 1 If it appears to YOU or YOUR attorney that a complete answer to any
28 Interrogatory calls for certain information YOU contend is protected from disclosure by the
_ Exhibit A
DEFENDANTS SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES, SET ONE TO PLAINTIFF
attorney-client privilege, the work product doctrine, or any other applicable privilege or
immunity, YOU are hereby directed to furnish sufficient information so as to PERSON any
COMMUNICATION which YOU believe to be protected from disclosure, including without
limitation:
a. the identity of the speaker or author,
b the identity of the PERSON(s) to whom the COMMUNICATION was
addressed or directed;
Cc. the identity of all other PERSON(s) present at the time of any oral
COMMUNICATION and/or who received the original or any copy of any WRITING or written
10 or electronic COMMUNICATION;
11 d the date of the COMMUNICATION;
12 ¢. the form of the COMMUNICATION (e.g. telephone call, facsimile, letter,
13 memorandum, handwritten notes, electronic mail or file, etc.); and
14 f. the subject matter of the COMMUNICATION.
15 DEFINITIONS
16 As used herein the following terms shall have the meanings set forth below:
17 Defendant “CHEN” shall mean the named defendant HAO CHEN.
18 3 Defendant “SILVA” shall mean the named defendant SILVA MANAGEMENT,
19 INC.
20 4 Defendant “LUO” shall mean the named defendant WEI LUO.
21 5 “PROPERTY” or “LOMITA” shall mean the real property located at 21871
22 Lomita Avenue in Cupertino, California, which is the subject property in this lawsuit.
23 6 The terms “COMMUNICATE?” or “COMMUNICATION” shall mean every
24 manner of disclosure, transfer, or exchange of information whether orally or by WRITING and
25 whether by face-to-face, telephone, computer, mail, e-mail, facsimile, video or audio
26 transmission, personal delivery, or otherwise.
27 7 The term “IDENTIFY” when used in reference to a COMMUNICATION means
28 to state the date of the COMMUNICATION, the manner in which the COMMUNICATION was
_ Exhibit A
DEFENDANT SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES, SET ONE TO PLAINTIFF
made, the PERSONS making and receiving the COMMUNICATION, the substance of the
COMMUNICATION, and the identity of any and all WRITINGS that set forth, summarize, or
refer to the COMMUNICATION.
8 The term “IDENTIFY” when used in reference to a WRITING means to state the
author of the WRITING, date of the WRITING, PERSONS the WRITING was addressed to,
subject matter or title of the WRITING and the type of WRITING.
9 The term “IDENTIFY” when used in reference to an INSURANCE POLICY
means to state the type of coverage, name of insurer, name of insured, policy number and policy
period.
10 10. The term “IDENTIFY” when used in reference to a PERSON or an entity means
11 to state the PERSON, entity or corporation’s full name, address, and telephone number, and in the
12 case of a PERSON, that PERSON’s present or last known title or business position and employer
13 or other business affiliation, and relationship to YOU, if any.
14 11. “PERSON?” and its derivatives shall mean an individual, trust, firm, joint stock
15 company, corporation (including an active, suspended, dissolved or government corporation),
16 joint venture, partnership, association, State, municipality, commission, political subdivision of a
17 State, or any interstate body and shall include each and every department, agency, and
18 instrumentality of the United States. Whenever a reference to a business entity appears, the
19 reference shall mean the business, its affiliated companies, partnerships, divisions, directors,
20 officers, employees, agents, or other representatives.
21 12. “RELATES TO” and its derivatives shall mean without limitation, either directly
22 or indirectly, in whole or in part, in any way, evidencing, describing, referring to, supporting,
23 mentioning, discussing, commenting, constituting, concerning, comprising, containing, reflecting,
24 identifying, stating, or referring to the given subject.
25 13. “WRITING?” as defined by California Evidence Code section 250 shall mean
26 handwriting, typewriting, printing, photostating, photographing, photocopying, transmitting by
27 electronic mail or facsimile, and every other means of recording upon any tangible thing, any
28 form of communication or representation, including letters, words, pictures, sounds, or symbols,
_ Exhibit A
DEFENDANT SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES, SET ONE TO PLAINTIFF
or combinations thereof, and any record thereby created, regardless of the manner in which the
record has been stored and shall include the “original” and “duplicate” (as those terms are defined
by California Evidence Code sections 255 and 260, respectively) and all non-duplicate copies and
all drafts thereof which presently are or have been in YOUR actual or constructive possession,
custody or control or which are or have been otherwise available to, or which are or have ever
been known to YOU including, but not limited to: contracts, leases, renewals, supplements and
amendments to leases, correspondence, letters, memoranda, telephone messages, logs, notes,
reports, files, books, records, agreements, applications, manuals, guidelines, telegrams, telexes,
wires and other COMMUNICATIONS sent or received, printouts, diary entries, calendars, tables,
10 computer tapes, calculations, purchase orders, invoices, shipping documents, manifests, bills of
11 lading, maps, charts, graphs, plot plans, surveys, blueprints, diagrams, recommendations, work
12 papers, summaries, minutes, digests, and other records or recordings of any conferences,
13 meetings, visits, interviews, telephone conversations, and financial or statistical data, analyses,
14 surveys, transcripts of testimony or written statements, affidavits, or printed matter. The term
15 “WRITING?” shall also include every other means by which information is recorded, stored, or
16 transmitted, including but not limited to tape recordings, microfilms, microfiches, data
17 compilations, chromatographs, hard disks, floppy disks, data processing and computer records,
18 however produced or reproduced, and the written information necessary to understand and use
19 such material. The term “WRITING” shall also include all photographs, films, slides, audio
20 recordings, video recordings, and tapes, however produced or reproduced. In addition, the term
21 shall include handwriting, typewriting, printing, photostating, photographing, and every other
22 means of recording upon any tangible thing any form of communication or representation,
23 including letters, words, pictures, sounds, or symbols, or combination thereof.
24 14. “YOU”, “YOUR” and “Responding Party” means: Plaintiff ZHAOHUA MENG
25 including: (a) any PERSON or entities acting in his interest or on his behalf; or (b) any PERSON
26 or entities which he has custody or control, including without limitation, his past or present
27 investigators, consultations, accountants, bankers, brokers, representatives, agents, officers,
28 directors, employees, advisors, and any representative of the foregoing; and (c) and where
_ Exhibit A
DEFENDANT SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES, SET ONE TO PLAINTIFF
applicable in context, its parent, subsidiary or other related or affiliated organizations, and its
officers, directors, employees, consultants, representatives, agents and all other individuals acting
or purporting to act on such entity(ies)’s behalf.
15. “COMPLAINT” shall mean the complaint YOU filed with the Court on or about
February 24, 2020 for the instant matter with the case number of 20CV364020.
16. “LUO LOAN” shall mean the loan agreement to finance the LOMITA project as
alleged in paragraph 16 of YOUR COMPLAINT.
17. All terms which are in the singular form shall include the plural; and all terms
which are in the plural form shall include the singular.
10 SPECIAL INTERROGATORIES
11 SPECIAL INTERROGATORIES NO. 1
12 State all facts that support YOUR contention in Paragraph 17 of YOUR COMPLAINT that
13 “In January 2017, Defendant CHEN represented to the other partners that he had real estate
14 management and development experience.”
15 SPECIAL INTERROGATORIES NO. 2
16 IDENTIFY each PERSON with information that supports YOUR contention in Paragraph
17 17 of YOUR COMPLAINT that “In January 2017, Defendant CHEN represented to the other
18 partners that he had real estate management and development experience.”
19 SPECIAL INTERROGATORIES NO. 3
20 IDENTIFY all DOCUMENTS that RELATE TO YOUR contention in Paragraph 17 of
21 YOUR COMPLAINT that “In January 2017, Defendant CHEN represented to the other partners
22 that he had real estate management and development experience.”
23 SPECIAL INTERROGATORIES NO. 4
24 State all facts that support YOUR contention in Paragraph 17 of YOUR COMPLAINT that
25 Defendant CHEN persuaded the other partners to retain his company, Defendant SILVA, to manage
26 and develop the Property.
27 SPECIAL INTERROGATORIES NO. 5
28 IDENTIFY each PERSON with information that supports YOUR contention in Paragraph
-5- Exhibit A
DEFENDANT SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES, SET ONE TO PLAINTIFF
17 of YOUR COMPLAINT that Defendant CHEN persuaded the other partners to retain his
company, Defendant SILVA, to manage and develop the Property.
SPECIAL INTERROGATORIES NO. 6
IDENTIFY all DOCUMENTS that RELATE TO YOUR contention in Paragraph 17 of
YOUR COMPLAINT that Defendant CHEN persuaded the other partners to retain his company,
Defendant SILVA, to manage and develop the Property.
SPECIAL INTERROGATORIES NO. 7
State all facts that support YOUR contention in Paragraph 18 of YOUR COMPLAINT that
Defendant CHEN and Defendant SILVA failed to disclose to other partners that they did not have
10 areal estate license as required by Business and Professions Code §10130.
11 SPECIAL INTERROGATORIES NO. 8
12 IDENTIFY all PERSONS with information that supports YOUR contention in Paragraph
13 18 of YOUR COMPLAINT that Defendant CHEN and Defendant SILVA failed to disclose to other
14 partners that they did not have a real estate license as required by Business and Professions Code
15 §10130.
16 SPECIAL INTERROGATORIES NO. 9
17 IDENTIFY all DOCUMENTS that RELATE TO YOUR contention in Paragraph 18 of
18 YOUR COMPLAINT that Defendant CHEN and Defendant SILVA failed to disclose to other
19 partners that they did not have a real estate license as required by Business and Professions Code
20 §10130.
21 SPECIAL INTERROGATORIES NO. 10
22 State all facts that support YOUR contention in Paragraph 19 of YOUR COMPLAINT that
23 Defendants CHEN and LIU were the actual persons managing and developing the property on
24 behalf of Defendant SILVA.
25 SPECIAL INTERROGATORIES NO. 11
26 IDENTIFY all PERSONS with the information that supports YOUR contention in
27 Paragraph 19 of YOUR COMPLAINT that Defendants CHEN and LIU were the actual persons
28 managing and developing the property on behalf of Defendant SILVA.
_ Exhibit A
DEFENDANT SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES, SET ONE TO PLAINTIFF
SPECIAL INTERROGATORIES NO. 12
IDENTIFY all DOCUMENTS that RELATE TO YOUR contention in Paragraph 19 of
YOUR COMPLAINT that Defendants CHEN and LIU were the actual persons managing and
developing the property on behalf of Defendant SILVA.
SPECIAL INTERROGATORIES NO. 13
State all facts that support YOUR contention in Paragraph 20 of YOUR COMPLAINT that
“all the defendants, except Defendant LEDESMA, and Huan Li directly or indirectly owned interest
in LUSSO.”
SPECIAL INTERROGATORIES NO. 14
10 IDENTIFY all PERSONS with the information that supports YOUR contention in
11 Paragraph 20 of YOUR COMPLAINT that “all the defendants, except Defendant LEDESMA, and
12 Huan Li directly or indirectly owned interest in LUSSO.”
13 SPECIAL INTERROGATORIES NO. 15
14 IDENTIFY all DOCUMENTS that RELATE TO YOUR contention in Paragraph 20 of
15 YOUR COMPLAINT that “all the defendants, except Defendant LEDESMA, and Huan Li directly
16 or indirectly owned interest in LUSSO.”
17 SPECIAL INTERROGATORIES NO. 16
18 State all facts that support YOUR contention in Paragraph 21 that “Defendant LEL’s initial
19 design was defective and was denied for building permit.”
20 SPECIAL INTERROGATORIES NO. 17
21 IDENTIFY all PERSONS with information that supports YOUR contention in Paragraph
22 21 that “Defendant LEL’s initial design was defective and was denied for building permit.”
23 SPECIAL INTERROGATORIES NO. 18
24 IDENTIFY all DOCUMENTS that RELATE TO YOUR contention in Paragraph 21 that
25 “Defendant LEL’s initial design was defective and was denied for building permit.”
26 SPECIAL INTERROGATORIES NO. 19
27 State all facts that support YOUR contention in Paragraph 21 of YOUR COMPLAINT that
28 “Due to Defendant LEL’s mistake and extensive delay, the building permit was not approved until
a7e Exhibit A
DEFENDANT SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES, SET ONE TO PLAINTIFF
March 31, 2018.”
SPECIAL INTERROGATORIES NO. 20
IDENTIFY all PERSONS with information that supports YOUR contention in Paragraph
21 of YOUR COMPLAINT that “Due to Defendant LEL’s mistake and extensive delay, the
building permit was not approved until March 31, 2018.”
SPECIAL INTERROGATORIES NO. 21
IDENTIFY all DOCUMENTS that RELATE TO YOUR contention in Paragraph 21 of
YOUR COMPLAINT that “Due to Defendant LEL’s mistake and extensive delay, the building
permit was not approved until March 31, 2018.”
10 SPECIAL INTERROGATORIES NO. 22
11 State all facts that support YOUR contention in Paragraph 22 of YOUR COMPLAINT that
12 Defendant TOPCON falsely charged the partners approximately $770,000 instead of $561,700 for
13 the construction work performed.
14 SPECIAL INTERROGATORIES NO. 23
15 IDENTIFY all PERSONS with information that supports YOUR contention in Paragraph
16 22 of YOUR COMPLAINT that Defendant TOPCON falsely charged the partners approximately
17 $770,000 instead of $561,700 for the construction work performed.
18 SPECIAL INTERROGATORIES NO. 24
19 IDENTIFY all DOCUMENTS that RELATE TO YOUR contention in Paragraph 22 of
20 YOUR COMPLAINT that Defendant TOPCON falsely charged the partners approximately
21 $770,000 instead of $561,700 for the construction work performed.
22 SPECIAL INTERROGATORIES NO. 25
23 State all facts that support YOUR contention in Paragraph 22 of YOUR COMPLAINT that
24 Defendant TOPCON threatened “not to carry out warranty on its work.”
25 SPECIAL INTERROGATORIES NO. 26
26 IDENTIFY all PERSONS with information that supports YOUR contention in Paragraph
27 22 of YOUR COMPLAINT that Defendant TOPCON threatened “not to carry out warranty on its
28 work.”
_ Exhibit A
DEFENDANT SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES, SET ONE TO PLAINTIFF
SPECIAL INTERROGATORIES NO. 27
IDENTIFY all DOCUMENTS that RELATE TO YOUR contention in Paragraph 22 of
YOUR COMPLAINT that Defendant TOPCON threatened “not to carry out warranty on its work.”
SPECIAL INTERROGATORIES NO. 28
State all facts that support YOUR contention in Paragraph 23 of YOUR COMPLAINT that
Defendant TOPCON’s allegedly defective work “decreased the value of LOMITA.”
SPECIAL INTERROGATORIES NO. 29
IDENTIFY all PERSONS with information that supports YOUR contention in Paragraph
23 of YOUR COMPLAINT that Defendant TOPCON’s allegedly defective work “decreased the
10 value of LOMITA.”
11 SPECIAL INTERROGATORIES NO. 30
12 IDENTIFY all DOCUMENTS that RELATE TO YOUR contention in Paragraph 23 of
13 YOUR COMPLAINT that Defendant TOPCON’s allegedly defective work “decreased the value
14 of LOMITA.”
15 SPECIAL INTERROGATORIES NO. 31
16 State all facts that support YOUR contention in Paragraph 23 of YOUR COMPLAINT that
17 Defendant TOPCON’s allegedly defective work “increased the possibility of disputes between
18 Plaintiff and buyer of the property.”
19 SPECIAL INTERROGATORIES NO. 32
20 IDENTIFY all PERSONS with information that supports YOUR contention in Paragraph
21 23 of YOUR COMPLAINT that Defendant TOPCON’s allegedly defective work “increased the
22 possibility of disputes between Plaintiff and buyer of the property.”
23 SPECIAL INTERROGATORIES NO. 33
24 IDENTIFY all DOCUMENTS that RELATE TO YOUR contention in Paragraph 23 of
25 YOUR COMPLAINT that Defendant TOPCON’s allegedly defective work “increased the
26 possibility of disputes between Plaintiff and buyer of the property.”
27 SPECIAL INTERROGATORIES NO. 34
28 Based on YOUR allegations in Paragraph 23 of YOUR COMPLAINT, do YOU contend
_ Exhibit A
DEFENDANT SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES, SET ONE TO PLAINTIFF
that Defendant TOPCON should have followed a certain “construction plan” but failed to do so?
SPECIAL INTERROGATORIES NO. 35
If YOUR answer to the previous Interrogatory is yes, please state all facts that support
YOUR contention that Defendant TOPCON should have followed a certain “construction plan” but
failed to do so.
SPECIAL INTERROGATORIES NO. 36
If YOUR answer to the previous Interrogatory No. 34 is yes, please IDENTIFY all
PERSONS with information that supports YOUR contention that Defendant TOPCON should have
followed a certain “construction plan” but failed to do so.
10 SPECIAL INTERROGATORIES NO. 37
11 If YOUR answer to Interrogatory No. 34 is yes, please IDENTIFY all DOCUMENTS that
12 support YOUR contention that that Defendant TOPCON should have followed a certain
13 “construction plan” but failed to do so.
14 SPECIAL INTERROGATORIES NO. 38
15 State all facts that support YOUR contention that YOU and other partners “clearly
16 instructed Defendant SILVA not to borrow money for the project unless all the partners agreed.”
17 SPECIAL INTERROGATORIES NO. 39
18 IDENTIFY all PERSONS with information that supports YOUR contention that YOU and
19 other partners “clearly instructed Defendant SILVA not to borrow money for the project unless all
20 the partners agreed.”
21 SPECIAL INTERROGATORIES NO. 40
22 IDENTIFY all DOCUMENTS that RELATE TO YOUR contention that YOU and other
23 partners “clearly instructed Defendant SILVA not to borrow money for the project unless all the
24 partners agreed.”
25 SPECIAL INTERROGATORIES NO. 41
26 Based on YOUR allegations in Paragraph 24 of YOUR COMPLAINT, do YOU contend
27 that YOU did not receive any advanced notice regarding Defendant SILVA borrowing money from
28 Defendant LUO?
-10-
Exhibit A
DEFENDANT SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES, SET ONE TO PLAINTIFF
SPECIAL INTERROGATORIES NO. 42
If YOUR answer to the previous Interrogatory is yes, state all facts that support YOUR
contention that YOU did not receive any advanced notice regarding Defendant SILVA borrowing
money from Defendant LUO.
SPECIAL INTERROGATORIES NO. 43
If YOUR answer to Interrogatory No. 41 is yes, IDENTIFY all PERSONS with information
that supports YOUR contention that YOU did not receive any notice regarding Defendant SILVA
borrowing money from Defendant LUO.
SPECIAL INTERROGATORIES NO. 44
10 If YOUR answer to Interrogatory No. 41 is yes, IDENTIFY all DOCUMENTS that
11 RELATE TO YOUR contention that YOU did not receive any notice regarding Defendant SILVA
12 borrowing money from Defendant LUO.
13 SPECIAL INTERROGATORIES NO. 45
14 Based on YOUR allegations in Paragraph 25 of YOUR COMPLAINT, do YOU contend
15 that Defendant LEDESMA should have followed a certain plan but failed to do so?
16 SPECIAL INTERROGATORIES NO. 46
17 If YOUR answer to the previous Interrogatory is yes, state all facts that support YOUR
18 contention that Defendant LEDESMA should have followed a certain plan but failed to do so.
19 SPECIAL INTERROGATORIES NO. 47
20 If YOUR answer to Interrogatory No. 45 is yes, IDENTIFY all PERSONS with information
21 that supports YOUR contention that Defendant LEDESMA should have followed a certain plan but
22 failed to do so.
23 SPECIAL INTERROGATORIES NO. 48
24 If YOUR answer to Interrogatory No. 45 is yes, IDENTIFY all DOCUMENTS that
25 RELATE TO YOUR contention that Defendant LEDESMA should have followed a certain plan
26 but failed to do so.
27 SPECIAL INTERROGATORIES NO. 49
28 IDENTIFY all PERSONS who have witnessed the buyer complaining about the quality of
-ll-
Exhibit A
DEFENDANT SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES, SET ONE TO PLAINTIFF
LOMITA as YOU allege in Paragraph 26 of YOUR COMPLAINT.
SPECIAL INTERROGATORIES NO. 50
IDENTIFY all PERSONS who have witnessed the buyer complaining about the quality of
LOMITA as YOU allege in Paragraph 26 of YOUR COMPLAINT.
SPECIAL INTERROGATORIES NO. 51
IDENTIFY all PERSONS who have knowledge regarding the allegation in Paragraph 26 of
YOUR COMPLAINT that the buyer complained about the quality of LOMITA.
SPECIAL INTERROGATORIES NO. 52
IDENTIFY all DOCUMENTS that RELATE TO the allegation in Paragraph 26 of YOUR
10 COMPLAINT that the buyer complained about the quality of LOMITA.
11 SPECIAL INTERROGATORIES NO. 53
12 State all facts RELATED TO the allegation in Paragraph 26 of YOUR COMPLAINT that
13 the buyer requested repairs of LOMITA.
14 SPECIAL INTERROGATORIES NO. 54
15 IDENTIFY all PERSONS who have witnessed that the buyer requested repairs of LOMITA
16 as YOU allege in Paragraph 26 of YOUR COMPLAINT.
17 SPECIAL INTERROGATORIES NO. 55
18 IDENTIFY all PERSONS who have knowledge regarding the allegation in Paragraph 26 of
19 YOUR COMPLAINT that the buyer requested repairs of LOMITA.
20 SPECIAL INTERROGATORIES NO. 56
21 IDENTIFY all DOCUMENTS that RELATE TO the allegation in Paragraph 26 of YOUR
22 COMPLAINT that the buyer requested repairs of LOMITA.
23 SPECIAL INTERROGATORIES NO. 57
24 State all facts that support YOUR contention in Paragraph 27 of YOUR COMPLAINT that
25 “the defendants used design of LOMITA and materials purchased for LOMITA on 4358 Silva
26 Court.”
27 /
28 MI
-12-
Exhibit A
DEFENDANT SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES, SET ONE TO PLAINTIFF
SPECIAL INTERROGATORIES NO. 58
IDENTIFY all PERSONS with knowledge supporting YOUR contention in Paragraph 27
of YOUR COMPLAINT that “the defendants used design of LOMITA and materials purchased for
LOMITA on 4358 Silva Court.”
SPECIAL INTERROGATORIES NO. 59
IDENTIFY all DOCUMENTS that RELATE TO YOUR contention in Paragraph 27 of
YOUR COMPLAINT that “the defendants used design of LOMITA and materials purchased for
LOMITA on 4358 Silva Court.”
Dated: April 6, 2020 VENTURA HERSEY & MULLER, LLP
10
11
12 By:
ng OC.
ANTHONY F. NNTURA
13 MINGZI OUYANG
Attorneys for Defendants
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SILVA MANAGEMENT INC. and HAO
15 CHEN and XIAOYAN LIU
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27
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-13-
Exhibit A
DEFENDANT SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES, SET ONE TO PLAINTIFF
DISC-001
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Stafe Bar number, and address).
Anthony F. Ventura, Esq., (SBN 191107)/ Mingzi Ouyang, Esq. (SBN 314334)
|_ Ventura Hersey & Muller LLP
1506 Hamilton Avenue,
San Jose, CA 05125
‘TELEPHONE NO. (408) 512-3022
FAXNO. (Optional: (408) 512-3023
E-MAIL ADDRESS (Optiona): aventua@venturahersey.com
ATTORNEY FOR (Name) Defendants Silva Management, Inc., Hao Chen and Xiaoyan Liu
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Santa Clara
191 N. First Street,
San Jose, CA 95125
SHORT TITLE OF CASE:
Zhaohua Meng vs. Silva Management, Inc., et al.
FORM INTERROGATORIES—GENERAL CASE NUMBER:
Asking Party: Silva Managment, Inc. 19CV360440
Answering Party: Zhaohua Meng
Set No.: One
Sec. 1. Instructions to All Parties (c) Each answer must be as complete and straightforward
(a) Interrogatories are written questions prepared by a party as the information reasonably available to you, including the
to an action that are sent to any other party in the action to be information possessed by your attorneys or agents, permits. If
answered under oath. The interrogatories below are form an interrogatory cannot be answered completely, answer it to
interrogatories approved for use in civil cases. the extent possible.
(b) For time limitations, requirements for service on other (d) Ifyou do not have enough personal knowledge to fully
parties, and other details, see Code of Civil Procedure answer an interrogatory, say so, but make a reasonable and
sections 2030.010-2030.410 and the cases construing those good faith effort to get the information by asking other persons
sections. or organizations, unless the information is equally available to
(c) These form interrogatories do not change existing law the asking party.
relating to interrogatories nor do they affect an answering (e) Whenever an interrogatory may be answered by
party's right to assert any privilege or make any objection. referring to a document, the document may be attached as an
exhibit to the response and referred to in the response. If the
Sec. 2. Instructions to the Asking Party document has more than one page, refer to the page and
(a) These interrogatories are designed for optional use by section where the answer to the interrogatory can be found.
parties in unlimited civil cases where the amount demanded (f) Whenever an address and telephone number for the
exceeds $25,000. Separate interrogatories, Form
same person are requested in more than one interrogatory,
Interrogatories—Limited Civil Cases (Economic Litigation) you are required to furnish them in answering only the first
(form DISC-004), which have no subparts, are designed for
interrogatory asking for that information.
use in limited civil cases where the amount demanded is
(g) If you are asserting a privilege or making an objection to
$25,000 or less; however, those interrogatories may also be
used in unlimited civil cases. an interrogatory, you must specifically assert the privilege or
‘state the objection in your written response.
(b) Check the box next to each interrogatory that you want
the answering party to answer. Use care in choosing those (h) Your answers to these interrogatories must be verified,
interrogatories that are applicable to the case. dated, and signed. You may wish to use the following form at
(c) You may insert your own definition of INCIDENT in the end of your answers:
Section 4, but only where the action arises from a course of | declare under penalty of perjury under the laws of the
conduct or a series of events occurring over a period of time. State of California that the foregoing answers are true and
(d) The interrogatories in section 16.0, Defendant's correct.
Contentions—Personal Injury, should not be used until the
defendant has had a reasonable opportunity to conduct an (DATE) (SIGNATURE)
investigation or discovery of plaintiff's injuries and damages.
(e) Additional interrogatories may be attached. Sec. 4. Definitions
Sec. 3. Instructions to the Answering Party Words in BOLDFACE CAPITALS in these interrogatories
(a) An answer or other appropriate response must be are defined as follows:
given to each interrogatory checked by the asking party. (a) (Check one of the following):
(b) As a general rule, within 30 days after you are served [J (4) INCIDENT includes
the circumstances and
with these interrogatories, you must serve your responses on events surrounding the alleged accident, injury, or
the asking party and serve copies of your responses on all other occurrence or breach of contract giving rise to
other parties to the action who have appeared. See Code of this action or proceeding.
Civil Procedure sections 2030.260-2030.270 for details.
Page 1 of 8
Form Approved for Optional Use ‘ode of Civil Procedure,
Judicial Council of California FORM INTERROGATORIES—GENERAL ‘98 2030.010-2030.410, 2033.710
DISC-001 Rev. January1, 2008] ww.courtinfo.ca.gov
Exhibit B
DISC-001
(2) INCIDENT means (insert your definition here or 1.0 Identity of Persons Answering These Interrogatories
on a separate, attached sheet labeled “Sec. {_] 1.1 State the name, ADDRESS, telephone number, and
4(a)(2)’): relationship to you of each PERSON who prepared or
assisted in the preparation of the responses to these
interrogatories. (Do not identify anyone who simply typed or
reproduced the responses.)
2.0 General Background Information—individual
(b) YOU OR ANYONE ACTING ON YOUR BEHALF LJ 2.1 state:
includes you, your agents, your employees, your insurance (a) your name;
companies, their agents, their employees, your attorneys, your (b) every name you have used in the past; and
accountants, your investigators, and anyone else acting on (c) the dates you used each name.
your behalf.
(c) PERSON includes a natural person, firm, association, [_] 2.2 State the date and place of your birth.
organization, partnership, business, trust, limited liability
company, corporation, or public entity.
(JJ 2.3 At the time of the INCIDENT, did you have a driver's
license? If so state:
(d) DOCUMENT means a writing, as defined in Evidence (a) the state or other issuing entity;
Code section 250, and includes the original or a copy of (b) the license number and type;
handwriting, typewriting, printing, photostats, photographs, (c) the date of issuance; and
electronically stored information, and every other means of (d) all restrictions.
recording upon any tangible thing and form of communicating (J 2.4 Atthe time of the INCIDENT, did you have any other
or representation, including letters, words, pictures, sounds, or
permit or license for the operation of a motor vehicle? If so,
symbols, or combinations of them.
state:
(e) HEALTH CARE PROVIDER includes any PERSON (a) the state or other issuing entity;
referred to in Code of Civil Procedure section 667.7(e)(3). (b) the license number and type;
(c) the date of issuance; and
(f) ADDRESS means the street address, including the city, (d) all restrictions.
state, and zip code.
Sec. 5. Interrogatories
LC 25 state:
(a) your present residence ADDRESS;
The following interrogatories have been approved by the (b) your residence ADDRESSES for the past five years; and
Judicial Council under Code of Civil Procedure section 2033.710: (c) the dates you lived at each ADDRESS.
CONTENTS
1.0 Identity of Persons Answering These Interrogatories
LC 26 state:
(a) the name, ADDRESS, and telephone number of your
2.0 General Background Information—Individual present employer or place of self-employment; and
3.0 General Background Information—Business Entity
(b) the name, ADDRESS, dates of employment, job title,
4.0 Insurance
and nature of work for each employer or
5.0 [Reserved]
self-employment you have had from five years before
6.0 Physical, Mental, or Emotional Injuries
the INCIDENT until today.
7.0 Property Damage
8.0 Loss of Income or Earning Capacity LC 27 state:
9.0 Other Damages (a) the name and ADDRESS of each school or other
10.0 Medical History academic or vocational institution you have attended,
11.0 Other Claims and Previous Claims beginning with high school;
12.0 Investigation—General (b) the dates you attended;
13.0 Investigation—Surveillance (c) the highest grade level you have completed; and
14.0 Statutory or Regulatory Violations (d) the degrees received.
15.0 Denials and Special or Affirmative Defenses
16.0 Defendant's Contentions Personal Injury O 2.8 Have you ever been convicted of a felony? If so, for
17.0 Responses to Request for Admissions each conviction state:
18.0 [Reserved] (a) the city and state where you were convicted;
19.0 [Reserved] (b) the date of conviction;
20.0 How the Incident Occurred—Motor Vehicle (c) the offense; and
25.0 [Reserved] (d) the court and case number.
30.0 [Reserved]
40.0 [Reserved]
Preview
20CV364020 Santa Clara — Civil Y. Chavez Electronically Filed ANTHONY F. VENTURA, ESQ., SBN 191107 by Superior Court of CA, aventura@venturahersey.com County of Santa Clara, ALEXANDRIA C. KAVALARIS, ESQ., SBN 273522 on 7/24/2020 1:02 PM akavalaris@venturahersey.com Reviewed By: Y. Chavez VENTURA HERSEY & MULLER, LLP 1506 Hamilton Avenue Case #20CV364020 San Jose, CA 95125-4539 Envelope: 4656703 Telephone: 408.512.3022 Facsimile: 408.512.3023 Attorneys for Defendant/Cross-Complainant Silva Management, Inc. and Defendants Hao Chen and Xiaoyan Liu SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 FOR THE COUNTY OF SANTA CLARA 11 12 Zhaohua Meng, Case No. 20CV364020 13) Plaintiffs, DECLARATION OF ALEXANDRIA C. KAVALARIS IN SUPPORT OF 14 vs. DEFENDANT’S MOTION TO COMPEL RESPONSES TO INTERROGATORIES 15 Silva Management, Inc., Hao Chen; Xiaoyan AND DEMAND FOR PRODUCTION OF Liu, Topcon Builder, Inc., Jiayu Lin, aka Jay DOCUMENTS AND FOR SANCTIONS 16 Lin, LEL Design, Inc., Leo Li, Wei Luo, Asencion A.N. Ledesma, and DOES ONE Date: 17 through TEN, inclusive Time: 9:00 AM 18 Defendants. Dept. 19 Silva Management, Inc., 20 Cross-Complainant, 21 VS. 22 Zhaohua Meng, Ran Tao, and Leilei Wang 23 and ROES 1-10, inclusive, [Unlimited Civil Action — Amount Demanded 24 Cross-Defendants. Exceeds $25,000] 25 26 I, Alexandria C. Kavalaris, declare as follows: 27 1 Iam an attorney at law licensed to practice before all courts of the State of California. 28 Tam a partner of the law firm Ventura Hersey &Muller, LLP (“Ventura Hersey”) in San Jose, DECLARATION OF ALEXANDRIA C. KAVALARIS IN SUPPORT OF MOTION TO COMPEL RESPONSES TO INTERROGATORIES AND. DEMAND FOR PRODUCTION OF DOCUMENTS AND FOR SANCTIONS: California, attorneys of record for Defendant/Cross-Complainant Silva Management, Inc. and Defendants Hao Chen and Xiaoyan Liu. 2. I make this declaration in support of the Memorandum of Points and Authorities in Support of Defendant’s Motion to Compel Responses to Interrogatories and Demand for Production of Document and for Sanctions. 3 Attached hereto as Exhibit A is a true and correct copy of Defendant Silva Management, Inc.'s Special Interrogatories to Plaintiff (Set One). The aforementioned interrogatories were propounded via US Mail on April 6, 2020. 4. Attached hereto as Exhibit B is a true and correct copy of Defendant Silva 10 Management, Inc.’s Form Interrogatories to Plaintiff (Set One). The aforementioned interrogatories 11 were propounded via US Mail on April 6, 2020. 12 5 Attached hereto as Exhibit C is a true and correct copy of Defendant Silva 13) Management, Inc.’s Request for Production of Documents to Plaintiff (Set One). The 14 aforementioned request for production was propounded via US Mail on April 6, 2020. 15 6 Attached hereto as Exhibit D is a true and correct copy of the Proof of Service in 16 connection with the interrogatories and request for production of documents attached as Exhibits A 17 through C (collectively referred to as the “Discovery Requests”). 7 18 Plaintiff Zhaohua Meng’s responses were due on May 11, 2020. 19 8 No responses have been received from Plaintiff to date. 20 i 21 // 22 // 23 i 24 i 25 // 26 i 27 i 28 MH 2 DECLARATION OF ALEXANDRIA C. KAVALARIS IN SUPPORT OF MOTION TO COMPEL RESPONSES TO INTERROGATORIES AND. DEMAND FOR PRODUCTION OF DOCUMENTS AND FOR SANCTIONS: 9 I spent 3.5 hours drafting the instant motion to compel and supporting documents. I anticipate spending 2.5 hours to draft a reply to any opposition filed by Plaintiff. I further anticipate billing 1.0 hour to attend the hearing on this motion. My hourly billing rate is $400.00. I am familiar with the billing rates for attorneys practicing civil litigation in Santa Clara County, California, and I believe my hourly rate to be consistent with a reasonable hourly rate charged by an attorney of my background and experience. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed at San Jose, California this 24"" day of July, 2020. 10 11 ph nl (A2—>— 12 ALEXANDRIA C. KAVALARIS 13) 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 DECLARATION OF ALEXANDRIA C. KAVALARIS IN SUPPORT OF MOTION TO COMPEL RESPONSES TO INTERROGATORIES AND. DEMAND FOR PRODUCTION OF DOCUMENTS AND FOR SANCTIONS: ANTHONY F. VENTURA, ESQ., SBN 191107 aventura@yventurahersey.com MINGZI OUYANG, ESQ., SBN 314334 mouyang@venturahersey.com VENTURA HERSEY & MULLER, LLP 1506 Hamilton Avenue San Jose, California 95125 Telephone: (408) 512-3022 Facsimile: (408) 512-3023 Attorneys for Defendant/Cross-Complainant Silva Management, Inc., Defendant Hao Chen and Defendant Xiaoyan Liu SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SANTA CLARA. 10 ll ZHAOHUA MENG, Case No.: 20CV364020 12 Plaintiff, DEFENDANT SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES TO 13 VS. PLAINTIFF ZHAOHUA MENG, SET ONE 14 Silva Management, Inc., Hao Chen, Xiaoyan Liu, Topcon Builder, Inc., Jiayu Lin, Aka Jay 15 Lin, Lel Design, Inc., Leo Li, Wei Luo, Asencion A. N. Ledesma, And Does One 16 Through Ten, Inclusive [Unlimited Civil Action] 17 Defendants. 18 19 PROPOUNDING PARTY: Defendant SALVA MANAGEMENT, INC. 20 RESPONDING PARTY: Plaintiff ZHAOHUA MENG 21 SET NO.: ONE 22 Pursuant to Code of Civil Procedure sections 2030, et seg., Defendant Silva Management, 23 Inc. (“Propounding Party”) demands that Plaintiff Zhaohua Meng (“Responding Party”) answer 24 the following Special Interrogatories (Set One), fully and completely, in writing and under oath, 25 within 30 days of service. 26 INSTRUCTIONS 27 1 If it appears to YOU or YOUR attorney that a complete answer to any 28 Interrogatory calls for certain information YOU contend is protected from disclosure by the _ Exhibit A DEFENDANTS SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES, SET ONE TO PLAINTIFF attorney-client privilege, the work product doctrine, or any other applicable privilege or immunity, YOU are hereby directed to furnish sufficient information so as to PERSON any COMMUNICATION which YOU believe to be protected from disclosure, including without limitation: a. the identity of the speaker or author, b the identity of the PERSON(s) to whom the COMMUNICATION was addressed or directed; Cc. the identity of all other PERSON(s) present at the time of any oral COMMUNICATION and/or who received the original or any copy of any WRITING or written 10 or electronic COMMUNICATION; 11 d the date of the COMMUNICATION; 12 ¢. the form of the COMMUNICATION (e.g. telephone call, facsimile, letter, 13 memorandum, handwritten notes, electronic mail or file, etc.); and 14 f. the subject matter of the COMMUNICATION. 15 DEFINITIONS 16 As used herein the following terms shall have the meanings set forth below: 17 Defendant “CHEN” shall mean the named defendant HAO CHEN. 18 3 Defendant “SILVA” shall mean the named defendant SILVA MANAGEMENT, 19 INC. 20 4 Defendant “LUO” shall mean the named defendant WEI LUO. 21 5 “PROPERTY” or “LOMITA” shall mean the real property located at 21871 22 Lomita Avenue in Cupertino, California, which is the subject property in this lawsuit. 23 6 The terms “COMMUNICATE?” or “COMMUNICATION” shall mean every 24 manner of disclosure, transfer, or exchange of information whether orally or by WRITING and 25 whether by face-to-face, telephone, computer, mail, e-mail, facsimile, video or audio 26 transmission, personal delivery, or otherwise. 27 7 The term “IDENTIFY” when used in reference to a COMMUNICATION means 28 to state the date of the COMMUNICATION, the manner in which the COMMUNICATION was _ Exhibit A DEFENDANT SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES, SET ONE TO PLAINTIFF made, the PERSONS making and receiving the COMMUNICATION, the substance of the COMMUNICATION, and the identity of any and all WRITINGS that set forth, summarize, or refer to the COMMUNICATION. 8 The term “IDENTIFY” when used in reference to a WRITING means to state the author of the WRITING, date of the WRITING, PERSONS the WRITING was addressed to, subject matter or title of the WRITING and the type of WRITING. 9 The term “IDENTIFY” when used in reference to an INSURANCE POLICY means to state the type of coverage, name of insurer, name of insured, policy number and policy period. 10 10. The term “IDENTIFY” when used in reference to a PERSON or an entity means 11 to state the PERSON, entity or corporation’s full name, address, and telephone number, and in the 12 case of a PERSON, that PERSON’s present or last known title or business position and employer 13 or other business affiliation, and relationship to YOU, if any. 14 11. “PERSON?” and its derivatives shall mean an individual, trust, firm, joint stock 15 company, corporation (including an active, suspended, dissolved or government corporation), 16 joint venture, partnership, association, State, municipality, commission, political subdivision of a 17 State, or any interstate body and shall include each and every department, agency, and 18 instrumentality of the United States. Whenever a reference to a business entity appears, the 19 reference shall mean the business, its affiliated companies, partnerships, divisions, directors, 20 officers, employees, agents, or other representatives. 21 12. “RELATES TO” and its derivatives shall mean without limitation, either directly 22 or indirectly, in whole or in part, in any way, evidencing, describing, referring to, supporting, 23 mentioning, discussing, commenting, constituting, concerning, comprising, containing, reflecting, 24 identifying, stating, or referring to the given subject. 25 13. “WRITING?” as defined by California Evidence Code section 250 shall mean 26 handwriting, typewriting, printing, photostating, photographing, photocopying, transmitting by 27 electronic mail or facsimile, and every other means of recording upon any tangible thing, any 28 form of communication or representation, including letters, words, pictures, sounds, or symbols, _ Exhibit A DEFENDANT SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES, SET ONE TO PLAINTIFF or combinations thereof, and any record thereby created, regardless of the manner in which the record has been stored and shall include the “original” and “duplicate” (as those terms are defined by California Evidence Code sections 255 and 260, respectively) and all non-duplicate copies and all drafts thereof which presently are or have been in YOUR actual or constructive possession, custody or control or which are or have been otherwise available to, or which are or have ever been known to YOU including, but not limited to: contracts, leases, renewals, supplements and amendments to leases, correspondence, letters, memoranda, telephone messages, logs, notes, reports, files, books, records, agreements, applications, manuals, guidelines, telegrams, telexes, wires and other COMMUNICATIONS sent or received, printouts, diary entries, calendars, tables, 10 computer tapes, calculations, purchase orders, invoices, shipping documents, manifests, bills of 11 lading, maps, charts, graphs, plot plans, surveys, blueprints, diagrams, recommendations, work 12 papers, summaries, minutes, digests, and other records or recordings of any conferences, 13 meetings, visits, interviews, telephone conversations, and financial or statistical data, analyses, 14 surveys, transcripts of testimony or written statements, affidavits, or printed matter. The term 15 “WRITING?” shall also include every other means by which information is recorded, stored, or 16 transmitted, including but not limited to tape recordings, microfilms, microfiches, data 17 compilations, chromatographs, hard disks, floppy disks, data processing and computer records, 18 however produced or reproduced, and the written information necessary to understand and use 19 such material. The term “WRITING” shall also include all photographs, films, slides, audio 20 recordings, video recordings, and tapes, however produced or reproduced. In addition, the term 21 shall include handwriting, typewriting, printing, photostating, photographing, and every other 22 means of recording upon any tangible thing any form of communication or representation, 23 including letters, words, pictures, sounds, or symbols, or combination thereof. 24 14. “YOU”, “YOUR” and “Responding Party” means: Plaintiff ZHAOHUA MENG 25 including: (a) any PERSON or entities acting in his interest or on his behalf; or (b) any PERSON 26 or entities which he has custody or control, including without limitation, his past or present 27 investigators, consultations, accountants, bankers, brokers, representatives, agents, officers, 28 directors, employees, advisors, and any representative of the foregoing; and (c) and where _ Exhibit A DEFENDANT SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES, SET ONE TO PLAINTIFF applicable in context, its parent, subsidiary or other related or affiliated organizations, and its officers, directors, employees, consultants, representatives, agents and all other individuals acting or purporting to act on such entity(ies)’s behalf. 15. “COMPLAINT” shall mean the complaint YOU filed with the Court on or about February 24, 2020 for the instant matter with the case number of 20CV364020. 16. “LUO LOAN” shall mean the loan agreement to finance the LOMITA project as alleged in paragraph 16 of YOUR COMPLAINT. 17. All terms which are in the singular form shall include the plural; and all terms which are in the plural form shall include the singular. 10 SPECIAL INTERROGATORIES 11 SPECIAL INTERROGATORIES NO. 1 12 State all facts that support YOUR contention in Paragraph 17 of YOUR COMPLAINT that 13 “In January 2017, Defendant CHEN represented to the other partners that he had real estate 14 management and development experience.” 15 SPECIAL INTERROGATORIES NO. 2 16 IDENTIFY each PERSON with information that supports YOUR contention in Paragraph 17 17 of YOUR COMPLAINT that “In January 2017, Defendant CHEN represented to the other 18 partners that he had real estate management and development experience.” 19 SPECIAL INTERROGATORIES NO. 3 20 IDENTIFY all DOCUMENTS that RELATE TO YOUR contention in Paragraph 17 of 21 YOUR COMPLAINT that “In January 2017, Defendant CHEN represented to the other partners 22 that he had real estate management and development experience.” 23 SPECIAL INTERROGATORIES NO. 4 24 State all facts that support YOUR contention in Paragraph 17 of YOUR COMPLAINT that 25 Defendant CHEN persuaded the other partners to retain his company, Defendant SILVA, to manage 26 and develop the Property. 27 SPECIAL INTERROGATORIES NO. 5 28 IDENTIFY each PERSON with information that supports YOUR contention in Paragraph -5- Exhibit A DEFENDANT SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES, SET ONE TO PLAINTIFF 17 of YOUR COMPLAINT that Defendant CHEN persuaded the other partners to retain his company, Defendant SILVA, to manage and develop the Property. SPECIAL INTERROGATORIES NO. 6 IDENTIFY all DOCUMENTS that RELATE TO YOUR contention in Paragraph 17 of YOUR COMPLAINT that Defendant CHEN persuaded the other partners to retain his company, Defendant SILVA, to manage and develop the Property. SPECIAL INTERROGATORIES NO. 7 State all facts that support YOUR contention in Paragraph 18 of YOUR COMPLAINT that Defendant CHEN and Defendant SILVA failed to disclose to other partners that they did not have 10 areal estate license as required by Business and Professions Code §10130. 11 SPECIAL INTERROGATORIES NO. 8 12 IDENTIFY all PERSONS with information that supports YOUR contention in Paragraph 13 18 of YOUR COMPLAINT that Defendant CHEN and Defendant SILVA failed to disclose to other 14 partners that they did not have a real estate license as required by Business and Professions Code 15 §10130. 16 SPECIAL INTERROGATORIES NO. 9 17 IDENTIFY all DOCUMENTS that RELATE TO YOUR contention in Paragraph 18 of 18 YOUR COMPLAINT that Defendant CHEN and Defendant SILVA failed to disclose to other 19 partners that they did not have a real estate license as required by Business and Professions Code 20 §10130. 21 SPECIAL INTERROGATORIES NO. 10 22 State all facts that support YOUR contention in Paragraph 19 of YOUR COMPLAINT that 23 Defendants CHEN and LIU were the actual persons managing and developing the property on 24 behalf of Defendant SILVA. 25 SPECIAL INTERROGATORIES NO. 11 26 IDENTIFY all PERSONS with the information that supports YOUR contention in 27 Paragraph 19 of YOUR COMPLAINT that Defendants CHEN and LIU were the actual persons 28 managing and developing the property on behalf of Defendant SILVA. _ Exhibit A DEFENDANT SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES, SET ONE TO PLAINTIFF SPECIAL INTERROGATORIES NO. 12 IDENTIFY all DOCUMENTS that RELATE TO YOUR contention in Paragraph 19 of YOUR COMPLAINT that Defendants CHEN and LIU were the actual persons managing and developing the property on behalf of Defendant SILVA. SPECIAL INTERROGATORIES NO. 13 State all facts that support YOUR contention in Paragraph 20 of YOUR COMPLAINT that “all the defendants, except Defendant LEDESMA, and Huan Li directly or indirectly owned interest in LUSSO.” SPECIAL INTERROGATORIES NO. 14 10 IDENTIFY all PERSONS with the information that supports YOUR contention in 11 Paragraph 20 of YOUR COMPLAINT that “all the defendants, except Defendant LEDESMA, and 12 Huan Li directly or indirectly owned interest in LUSSO.” 13 SPECIAL INTERROGATORIES NO. 15 14 IDENTIFY all DOCUMENTS that RELATE TO YOUR contention in Paragraph 20 of 15 YOUR COMPLAINT that “all the defendants, except Defendant LEDESMA, and Huan Li directly 16 or indirectly owned interest in LUSSO.” 17 SPECIAL INTERROGATORIES NO. 16 18 State all facts that support YOUR contention in Paragraph 21 that “Defendant LEL’s initial 19 design was defective and was denied for building permit.” 20 SPECIAL INTERROGATORIES NO. 17 21 IDENTIFY all PERSONS with information that supports YOUR contention in Paragraph 22 21 that “Defendant LEL’s initial design was defective and was denied for building permit.” 23 SPECIAL INTERROGATORIES NO. 18 24 IDENTIFY all DOCUMENTS that RELATE TO YOUR contention in Paragraph 21 that 25 “Defendant LEL’s initial design was defective and was denied for building permit.” 26 SPECIAL INTERROGATORIES NO. 19 27 State all facts that support YOUR contention in Paragraph 21 of YOUR COMPLAINT that 28 “Due to Defendant LEL’s mistake and extensive delay, the building permit was not approved until a7e Exhibit A DEFENDANT SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES, SET ONE TO PLAINTIFF March 31, 2018.” SPECIAL INTERROGATORIES NO. 20 IDENTIFY all PERSONS with information that supports YOUR contention in Paragraph 21 of YOUR COMPLAINT that “Due to Defendant LEL’s mistake and extensive delay, the building permit was not approved until March 31, 2018.” SPECIAL INTERROGATORIES NO. 21 IDENTIFY all DOCUMENTS that RELATE TO YOUR contention in Paragraph 21 of YOUR COMPLAINT that “Due to Defendant LEL’s mistake and extensive delay, the building permit was not approved until March 31, 2018.” 10 SPECIAL INTERROGATORIES NO. 22 11 State all facts that support YOUR contention in Paragraph 22 of YOUR COMPLAINT that 12 Defendant TOPCON falsely charged the partners approximately $770,000 instead of $561,700 for 13 the construction work performed. 14 SPECIAL INTERROGATORIES NO. 23 15 IDENTIFY all PERSONS with information that supports YOUR contention in Paragraph 16 22 of YOUR COMPLAINT that Defendant TOPCON falsely charged the partners approximately 17 $770,000 instead of $561,700 for the construction work performed. 18 SPECIAL INTERROGATORIES NO. 24 19 IDENTIFY all DOCUMENTS that RELATE TO YOUR contention in Paragraph 22 of 20 YOUR COMPLAINT that Defendant TOPCON falsely charged the partners approximately 21 $770,000 instead of $561,700 for the construction work performed. 22 SPECIAL INTERROGATORIES NO. 25 23 State all facts that support YOUR contention in Paragraph 22 of YOUR COMPLAINT that 24 Defendant TOPCON threatened “not to carry out warranty on its work.” 25 SPECIAL INTERROGATORIES NO. 26 26 IDENTIFY all PERSONS with information that supports YOUR contention in Paragraph 27 22 of YOUR COMPLAINT that Defendant TOPCON threatened “not to carry out warranty on its 28 work.” _ Exhibit A DEFENDANT SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES, SET ONE TO PLAINTIFF SPECIAL INTERROGATORIES NO. 27 IDENTIFY all DOCUMENTS that RELATE TO YOUR contention in Paragraph 22 of YOUR COMPLAINT that Defendant TOPCON threatened “not to carry out warranty on its work.” SPECIAL INTERROGATORIES NO. 28 State all facts that support YOUR contention in Paragraph 23 of YOUR COMPLAINT that Defendant TOPCON’s allegedly defective work “decreased the value of LOMITA.” SPECIAL INTERROGATORIES NO. 29 IDENTIFY all PERSONS with information that supports YOUR contention in Paragraph 23 of YOUR COMPLAINT that Defendant TOPCON’s allegedly defective work “decreased the 10 value of LOMITA.” 11 SPECIAL INTERROGATORIES NO. 30 12 IDENTIFY all DOCUMENTS that RELATE TO YOUR contention in Paragraph 23 of 13 YOUR COMPLAINT that Defendant TOPCON’s allegedly defective work “decreased the value 14 of LOMITA.” 15 SPECIAL INTERROGATORIES NO. 31 16 State all facts that support YOUR contention in Paragraph 23 of YOUR COMPLAINT that 17 Defendant TOPCON’s allegedly defective work “increased the possibility of disputes between 18 Plaintiff and buyer of the property.” 19 SPECIAL INTERROGATORIES NO. 32 20 IDENTIFY all PERSONS with information that supports YOUR contention in Paragraph 21 23 of YOUR COMPLAINT that Defendant TOPCON’s allegedly defective work “increased the 22 possibility of disputes between Plaintiff and buyer of the property.” 23 SPECIAL INTERROGATORIES NO. 33 24 IDENTIFY all DOCUMENTS that RELATE TO YOUR contention in Paragraph 23 of 25 YOUR COMPLAINT that Defendant TOPCON’s allegedly defective work “increased the 26 possibility of disputes between Plaintiff and buyer of the property.” 27 SPECIAL INTERROGATORIES NO. 34 28 Based on YOUR allegations in Paragraph 23 of YOUR COMPLAINT, do YOU contend _ Exhibit A DEFENDANT SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES, SET ONE TO PLAINTIFF that Defendant TOPCON should have followed a certain “construction plan” but failed to do so? SPECIAL INTERROGATORIES NO. 35 If YOUR answer to the previous Interrogatory is yes, please state all facts that support YOUR contention that Defendant TOPCON should have followed a certain “construction plan” but failed to do so. SPECIAL INTERROGATORIES NO. 36 If YOUR answer to the previous Interrogatory No. 34 is yes, please IDENTIFY all PERSONS with information that supports YOUR contention that Defendant TOPCON should have followed a certain “construction plan” but failed to do so. 10 SPECIAL INTERROGATORIES NO. 37 11 If YOUR answer to Interrogatory No. 34 is yes, please IDENTIFY all DOCUMENTS that 12 support YOUR contention that that Defendant TOPCON should have followed a certain 13 “construction plan” but failed to do so. 14 SPECIAL INTERROGATORIES NO. 38 15 State all facts that support YOUR contention that YOU and other partners “clearly 16 instructed Defendant SILVA not to borrow money for the project unless all the partners agreed.” 17 SPECIAL INTERROGATORIES NO. 39 18 IDENTIFY all PERSONS with information that supports YOUR contention that YOU and 19 other partners “clearly instructed Defendant SILVA not to borrow money for the project unless all 20 the partners agreed.” 21 SPECIAL INTERROGATORIES NO. 40 22 IDENTIFY all DOCUMENTS that RELATE TO YOUR contention that YOU and other 23 partners “clearly instructed Defendant SILVA not to borrow money for the project unless all the 24 partners agreed.” 25 SPECIAL INTERROGATORIES NO. 41 26 Based on YOUR allegations in Paragraph 24 of YOUR COMPLAINT, do YOU contend 27 that YOU did not receive any advanced notice regarding Defendant SILVA borrowing money from 28 Defendant LUO? -10- Exhibit A DEFENDANT SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES, SET ONE TO PLAINTIFF SPECIAL INTERROGATORIES NO. 42 If YOUR answer to the previous Interrogatory is yes, state all facts that support YOUR contention that YOU did not receive any advanced notice regarding Defendant SILVA borrowing money from Defendant LUO. SPECIAL INTERROGATORIES NO. 43 If YOUR answer to Interrogatory No. 41 is yes, IDENTIFY all PERSONS with information that supports YOUR contention that YOU did not receive any notice regarding Defendant SILVA borrowing money from Defendant LUO. SPECIAL INTERROGATORIES NO. 44 10 If YOUR answer to Interrogatory No. 41 is yes, IDENTIFY all DOCUMENTS that 11 RELATE TO YOUR contention that YOU did not receive any notice regarding Defendant SILVA 12 borrowing money from Defendant LUO. 13 SPECIAL INTERROGATORIES NO. 45 14 Based on YOUR allegations in Paragraph 25 of YOUR COMPLAINT, do YOU contend 15 that Defendant LEDESMA should have followed a certain plan but failed to do so? 16 SPECIAL INTERROGATORIES NO. 46 17 If YOUR answer to the previous Interrogatory is yes, state all facts that support YOUR 18 contention that Defendant LEDESMA should have followed a certain plan but failed to do so. 19 SPECIAL INTERROGATORIES NO. 47 20 If YOUR answer to Interrogatory No. 45 is yes, IDENTIFY all PERSONS with information 21 that supports YOUR contention that Defendant LEDESMA should have followed a certain plan but 22 failed to do so. 23 SPECIAL INTERROGATORIES NO. 48 24 If YOUR answer to Interrogatory No. 45 is yes, IDENTIFY all DOCUMENTS that 25 RELATE TO YOUR contention that Defendant LEDESMA should have followed a certain plan 26 but failed to do so. 27 SPECIAL INTERROGATORIES NO. 49 28 IDENTIFY all PERSONS who have witnessed the buyer complaining about the quality of -ll- Exhibit A DEFENDANT SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES, SET ONE TO PLAINTIFF LOMITA as YOU allege in Paragraph 26 of YOUR COMPLAINT. SPECIAL INTERROGATORIES NO. 50 IDENTIFY all PERSONS who have witnessed the buyer complaining about the quality of LOMITA as YOU allege in Paragraph 26 of YOUR COMPLAINT. SPECIAL INTERROGATORIES NO. 51 IDENTIFY all PERSONS who have knowledge regarding the allegation in Paragraph 26 of YOUR COMPLAINT that the buyer complained about the quality of LOMITA. SPECIAL INTERROGATORIES NO. 52 IDENTIFY all DOCUMENTS that RELATE TO the allegation in Paragraph 26 of YOUR 10 COMPLAINT that the buyer complained about the quality of LOMITA. 11 SPECIAL INTERROGATORIES NO. 53 12 State all facts RELATED TO the allegation in Paragraph 26 of YOUR COMPLAINT that 13 the buyer requested repairs of LOMITA. 14 SPECIAL INTERROGATORIES NO. 54 15 IDENTIFY all PERSONS who have witnessed that the buyer requested repairs of LOMITA 16 as YOU allege in Paragraph 26 of YOUR COMPLAINT. 17 SPECIAL INTERROGATORIES NO. 55 18 IDENTIFY all PERSONS who have knowledge regarding the allegation in Paragraph 26 of 19 YOUR COMPLAINT that the buyer requested repairs of LOMITA. 20 SPECIAL INTERROGATORIES NO. 56 21 IDENTIFY all DOCUMENTS that RELATE TO the allegation in Paragraph 26 of YOUR 22 COMPLAINT that the buyer requested repairs of LOMITA. 23 SPECIAL INTERROGATORIES NO. 57 24 State all facts that support YOUR contention in Paragraph 27 of YOUR COMPLAINT that 25 “the defendants used design of LOMITA and materials purchased for LOMITA on 4358 Silva 26 Court.” 27 / 28 MI -12- Exhibit A DEFENDANT SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES, SET ONE TO PLAINTIFF SPECIAL INTERROGATORIES NO. 58 IDENTIFY all PERSONS with knowledge supporting YOUR contention in Paragraph 27 of YOUR COMPLAINT that “the defendants used design of LOMITA and materials purchased for LOMITA on 4358 Silva Court.” SPECIAL INTERROGATORIES NO. 59 IDENTIFY all DOCUMENTS that RELATE TO YOUR contention in Paragraph 27 of YOUR COMPLAINT that “the defendants used design of LOMITA and materials purchased for LOMITA on 4358 Silva Court.” Dated: April 6, 2020 VENTURA HERSEY & MULLER, LLP 10 11 12 By: ng OC. ANTHONY F. NNTURA 13 MINGZI OUYANG Attorneys for Defendants 14 SILVA MANAGEMENT INC. and HAO 15 CHEN and XIAOYAN LIU 16 17 18 19 20 21 22 23 24 25 26 27 28 -13- Exhibit A DEFENDANT SILVA MANAGEMENT, INC.’S SPECIAL INTERROGATORIES, SET ONE TO PLAINTIFF DISC-001 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Stafe Bar number, and address). Anthony F. Ventura, Esq., (SBN 191107)/ Mingzi Ouyang, Esq. (SBN 314334) |_ Ventura Hersey & Muller LLP 1506 Hamilton Avenue, San Jose, CA 05125 ‘TELEPHONE NO. (408) 512-3022 FAXNO. (Optional: (408) 512-3023 E-MAIL ADDRESS (Optiona): aventua@venturahersey.com ATTORNEY FOR (Name) Defendants Silva Management, Inc., Hao Chen and Xiaoyan Liu SUPERIOR COURT OF CALIFORNIA, COUNTY OF Santa Clara 191 N. First Street, San Jose, CA 95125 SHORT TITLE OF CASE: Zhaohua Meng vs. Silva Management, Inc., et al. FORM INTERROGATORIES—GENERAL CASE NUMBER: Asking Party: Silva Managment, Inc. 19CV360440 Answering Party: Zhaohua Meng Set No.: One Sec. 1. Instructions to All Parties (c) Each answer must be as complete and straightforward (a) Interrogatories are written questions prepared by a party as the information reasonably available to you, including the to an action that are sent to any other party in the action to be information possessed by your attorneys or agents, permits. If answered under oath. The interrogatories below are form an interrogatory cannot be answered completely, answer it to interrogatories approved for use in civil cases. the extent possible. (b) For time limitations, requirements for service on other (d) Ifyou do not have enough personal knowledge to fully parties, and other details, see Code of Civil Procedure answer an interrogatory, say so, but make a reasonable and sections 2030.010-2030.410 and the cases construing those good faith effort to get the information by asking other persons sections. or organizations, unless the information is equally available to (c) These form interrogatories do not change existing law the asking party. relating to interrogatories nor do they affect an answering (e) Whenever an interrogatory may be answered by party's right to assert any privilege or make any objection. referring to a document, the document may be attached as an exhibit to the response and referred to in the response. If the Sec. 2. Instructions to the Asking Party document has more than one page, refer to the page and (a) These interrogatories are designed for optional use by section where the answer to the interrogatory can be found. parties in unlimited civil cases where the amount demanded (f) Whenever an address and telephone number for the exceeds $25,000. Separate interrogatories, Form same person are requested in more than one interrogatory, Interrogatories—Limited Civil Cases (Economic Litigation) you are required to furnish them in answering only the first (form DISC-004), which have no subparts, are designed for interrogatory asking for that information. use in limited civil cases where the amount demanded is (g) If you are asserting a privilege or making an objection to $25,000 or less; however, those interrogatories may also be used in unlimited civil cases. an interrogatory, you must specifically assert the privilege or ‘state the objection in your written response. (b) Check the box next to each interrogatory that you want the answering party to answer. Use care in choosing those (h) Your answers to these interrogatories must be verified, interrogatories that are applicable to the case. dated, and signed. You may wish to use the following form at (c) You may insert your own definition of INCIDENT in the end of your answers: Section 4, but only where the action arises from a course of | declare under penalty of perjury under the laws of the conduct or a series of events occurring over a period of time. State of California that the foregoing answers are true and (d) The interrogatories in section 16.0, Defendant's correct. Contentions—Personal Injury, should not be used until the defendant has had a reasonable opportunity to conduct an (DATE) (SIGNATURE) investigation or discovery of plaintiff's injuries and damages. (e) Additional interrogatories may be attached. Sec. 4. Definitions Sec. 3. Instructions to the Answering Party Words in BOLDFACE CAPITALS in these interrogatories (a) An answer or other appropriate response must be are defined as follows: given to each interrogatory checked by the asking party. (a) (Check one of the following): (b) As a general rule, within 30 days after you are served [J (4) INCIDENT includes the circumstances and with these interrogatories, you must serve your responses on events surrounding the alleged accident, injury, or the asking party and serve copies of your responses on all other occurrence or breach of contract giving rise to other parties to the action who have appeared. See Code of this action or proceeding. Civil Procedure sections 2030.260-2030.270 for details. Page 1 of 8 Form Approved for Optional Use ‘ode of Civil Procedure, Judicial Council of California FORM INTERROGATORIES—GENERAL ‘98 2030.010-2030.410, 2033.710 DISC-001 Rev. January1, 2008] ww.courtinfo.ca.gov Exhibit B DISC-001 (2) INCIDENT means (insert your definition here or 1.0 Identity of Persons Answering These Interrogatories on a separate, attached sheet labeled “Sec. {_] 1.1 State the name, ADDRESS, telephone number, and 4(a)(2)’): relationship to you of each PERSON who prepared or assisted in the preparation of the responses to these interrogatories. (Do not identify anyone who simply typed or reproduced the responses.) 2.0 General Background Information—individual (b) YOU OR ANYONE ACTING ON YOUR BEHALF LJ 2.1 state: includes you, your agents, your employees, your insurance (a) your name; companies, their agents, their employees, your attorneys, your (b) every name you have used in the past; and accountants, your investigators, and anyone else acting on (c) the dates you used each name. your behalf. (c) PERSON includes a natural person, firm, association, [_] 2.2 State the date and place of your birth. organization, partnership, business, trust, limited liability company, corporation, or public entity. (JJ 2.3 At the time of the INCIDENT, did you have a driver's license? If so state: (d) DOCUMENT means a writing, as defined in Evidence (a) the state or other issuing entity; Code section 250, and includes the original or a copy of (b) the license number and type; handwriting, typewriting, printing, photostats, photographs, (c) the date of issuance; and electronically stored information, and every other means of (d) all restrictions. recording upon any tangible thing and form of communicating (J 2.4 Atthe time of the INCIDENT, did you have any other or representation, including letters, words, pictures, sounds, or permit or license for the operation of a motor vehicle? If so, symbols, or combinations of them. state: (e) HEALTH CARE PROVIDER includes any PERSON (a) the state or other issuing entity; referred to in Code of Civil Procedure section 667.7(e)(3). (b) the license number and type; (c) the date of issuance; and (f) ADDRESS means the street address, including the city, (d) all restrictions. state, and zip code. Sec. 5. Interrogatories LC 25 state: (a) your present residence ADDRESS; The following interrogatories have been approved by the (b) your residence ADDRESSES for the past five years; and Judicial Council under Code of Civil Procedure section 2033.710: (c) the dates you lived at each ADDRESS. CONTENTS 1.0 Identity of Persons Answering These Interrogatories LC 26 state: (a) the name, ADDRESS, and telephone number of your 2.0 General Background Information—Individual present employer or place of self-employment; and 3.0 General Background Information—Business Entity (b) the name, ADDRESS, dates of employment, job title, 4.0 Insurance and nature of work for each employer or 5.0 [Reserved] self-employment you have had from five years before 6.0 Physical, Mental, or Emotional Injuries the INCIDENT until today. 7.0 Property Damage 8.0 Loss of Income or Earning Capacity LC 27 state: 9.0 Other Damages (a) the name and ADDRESS of each school or other 10.0 Medical History academic or vocational institution you have attended, 11.0 Other Claims and Previous Claims beginning with high school; 12.0 Investigation—General (b) the dates you attended; 13.0 Investigation—Surveillance (c) the highest grade level you have completed; and 14.0 Statutory or Regulatory Violations (d) the degrees received. 15.0 Denials and Special or Affirmative Defenses 16.0 Defendant's Contentions Personal Injury O 2.8 Have you ever been convicted of a felony? If so, for 17.0 Responses to Request for Admissions each conviction state: 18.0 [Reserved] (a) the city and state where you were convicted; 19.0 [Reserved] (b) the date of conviction; 20.0 How the Incident Occurred—Motor Vehicle (c) the offense; and 25.0 [Reserved] (d) the court and case number. 30.0 [Reserved] 40.0 [Reserved]