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  • CRYSTAL LEI VS. DEMAS YAN FRAUD document preview
  • CRYSTAL LEI VS. DEMAS YAN FRAUD document preview
  • CRYSTAL LEI VS. DEMAS YAN FRAUD document preview
  • CRYSTAL LEI VS. DEMAS YAN FRAUD document preview
  • CRYSTAL LEI VS. DEMAS YAN FRAUD document preview
  • CRYSTAL LEI VS. DEMAS YAN FRAUD document preview
  • CRYSTAL LEI VS. DEMAS YAN FRAUD document preview
  • CRYSTAL LEI VS. DEMAS YAN FRAUD document preview
						
                                

Preview

24 25 Crystal Lei & Bryant Fu San Pence CA 94121 F I L KB D Phone: (415) 221 — 0969 San Francisco County Suinerior Court Email: crystalleija@yahoo.com SEP 25 2019 Plaintiffs in Pro Per CLERK OF 1HE COURT BY: / Deputy Clerk SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Crystal Lei, an individual, Case No.: CGC-14-565831 Bryant Fu, an individual, Plainti aintifis, DECLARATION OF BRYANT FU IN SUPPORT OF PLAINTIFFS’ MOTION TO YS: TAX AND STRIKE COSTS Demas Yan aka Dennis Yan, an individual, DBA Epona Investment Realty, and DBA Yan Law Offices, Cheuk Tin Yan, an individual, Tina F. Yan, aka Tina Foon Yu Yan, an boys Date: October 24, 2019 individual, Time: 9:30 am 547 Investments LLC, a California limited Dept: 302 liability company, Place: 400 McAllister St. The Remodeling Company, Inc., a California San Francisco, CA 94102 corporation, Epona Investment Group LLC, a California limited liability company, Anew Law Corporation, a California corporation, Reservation No.: 009241024-05 Defendants. eee 565831 PLAINTIFFS’ MOTION TO TAX AND STRIKE COSTS 124 25 1, Bryant Fu, declare: 1. My name is Bryant Fu. I submit this declaration in support of Plaintiffs Motion to| Tax and Strike Costs. I am familiar with the matters stated in this declaration from my ows personal knowledge. If were called to testify about these matters, | would be competent to and would do so. 2. Attached hereto as Exhibit A is a true and correct copy of the Memorandum of Costs filed on September 10, 2019 by Mark Lapham for 547 Investments LLC. 3. Attached hereto as Exhibit B is a true and correct copy of the California Secretar of States’ business entity information for 547 Investments LLC showing that the business is, “SOS/FTB SUSPENDED”. The printout is current as of September 25, 2019. 4, Attached hereto as Exhibit C is a true and correct copy of the California State Ban profile for attorney Mark Lapham current as of September 25, 2019. 5. Attached hereto as Exhibit D is a true and correct copy of the Memorandum off Costs filed on September 10, 2019 by Mark Lapham for Cheuk Tin Yan. 6. Attached hereto as Exhibit E is a true and correct copy of the Memorandum o: Costs filed on September 10, 2019 by Mark Lapham for Tina Yan. 7. Attached hereto as Exhibit F is a true and correct copy of the Notice of Attend) Trial requiring Tina Yan to appear at trial. Tina Yan has failed to appear or otherwise compl with this subpoena. I declare under penalty of perjury under the law of the State of California the above is true and correct to the best of my personal knowledge, and that this declaration is executed atl San Francisco, California, this September 25, 2019. Bryant Fu 565831 PLAINTIFFS’ MOTION TO TAX AND STRIKE COSTS 2Exhibit AMC-010 [ATTORNEY OR PARTY WITHOUT ATTORNEY name: Mark Lapham FIRM NAME STREET ADDRESS: 751 Diablo Rd. city; Danville [TELEPHONE NO.; 925-837-9007 E-MAIL ADDRESS: STATE BAR NUMBER: 146352 state: CA FAX NO. ZIP CODE: 94526 ATTORNEY FOR (name): defendant 547 INVESTMENTS, LLC SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO STREET ADORESS. 400 MCALLISTER STREET MAILING ADDRESS city ano zip cope. SAN FRANCISCO, CA 94102 BRANCH NAME: PLAINTIFF: CRYSTAL LEI et al. DEFENDANT: DEMAS YAN et al. FOR COURT USE ONLY ELECTRONICALLY FILED ‘Superior Court of California, County of San Francisco 09/10/2019 Clerk of the Court BY: EDWARD SANTOS Deputy Clerk MEMORANDUM OF COSTS (SUMMARY) CASE NUMBER: CGC 14565831 The following costs are requested: 1. Filing and motion fees 2. Jury fees Jury food and lodging Deposition costs Service of process Surety bond premiums 3. 4 5. 6. Attachment expenses 7. 8. Witness fees 9. Court-ordered transcripts 10. Attorney fees (enter here if contractual or statutory fees are fixed without necessity of a court determination; otherwise a noticed motion is required) 11. Court reporter fees as established by statute 12. Models, enlargements, and photocopies of exhibits 13. Interpreter fees 14. Fees for electronic filing or service 15. Fees for hosting electronic documents 16. Other TOTALS 960 ee HHH HH HH 60 CR HH 8 & TOTAL COSTS $ 1020 lam the attorney, agent, or party who claims these costs. To the best of my knowledge and belief this memorandum of costs is correct and these costs were necessarily incurred in this case. Date: Sep 10, 2019 MARK LAPHAM (TYPE OR PRINT NAME) (Proof of service on reverse) Lb (SIGNATURE OF DECLARANT) Page 1 of 2 Form Approved for Optional Use Judicial Council of Califomia MC-010 (Rev. September 1, 2017] MEMORANDUM OF COSTS (SUMMARY) Code of Civil Procedure, §§ 1032, 1033.5Exhibit B9/25/2019 Busin... —earch - Business Entities - Business Programs | California Secretary of State Alex Padilla California Secretary of State OQ. Business Search - Entity Detail The California Business Search is updated daily and reflects work processed through Tuesday, September 24, 2019. Please refer to document Processing Times for the received dates of filings currently being processed, The data provided is not a complete or certified record of an entity. Not all images are available online. 201322010264 547 INVESTMENTS LLC Registration Date: 08/05/2013 Jurisdiction: CALIFORNIA DOMESTIC SOS/FTB SUSPENDED Agent for Service of Process: JOHN NGUYEN 426 S MAIN ST MILPITAS CA 95035 Entity Address: 426 S MAIN ST MILPITAS CA 95035 Entity Mailing Address: 426 S MAIN ST MILPITAS CA 95035 LLC Management One Manager Document Type Ut File Date PDF SI-COMPLETE 12/16/2013 REGISTRATION 08/05/2013 * Indicates the information is not contained in the California Secretary of State's database. Note: If the agent for service of process is a corporation, the address of the agent may be requested by ordering a status report. For information on checking or reserving a name, refer to Name Availability. « If the image is not available online, for information on ordering a copy refer to Information Requests. « For information on ordering certificates, status reports, certified copies of documents and copies of documents not currently available in the Business Search or to request a more extensive search for records, refer to Information Requests. . « For help with searching an entity name, refer to Search Tips. ° For descriptions of the various fields and status types, refer to Frequently Asked Questions. Modify Search New Search Back to Search Results hitps://businesssearch.sos.ca.gov/CBS/DetailExhibit C9/25/2019 Mark Whitney Lapham #146362 - Attorney Licensee Search The State Bar of California Mark Whitney Lapham #146352 License Status: Active Address: Law Offices of Mark Lapham, 751 Diablo Rd, Danville, CA 94526 County: Contra Costa County Phone Number: (925) 837-9007 Fax Number: Not Available Email: Not Available Law School: Gonzaga Univ SOL; Spokane WA Below you will find all changes of license status due to both non-disciplinary administrative matters and disciplinary actions. Date License Status Discipline Administrative Action Present Active 7/4/2015 Active 6/4/2015 Not Eligidle To Practice Law in California Discipline w/actual suspension 13-0-17332 2/17/2011 Active 9/14/2006 Inactive 9/3/2002 Active 3/1/2002 Inactive 6/11/1994 Not Eligible To Practice Law in California Discipline w/actual suspension 91-C-02826 11/28/1991 Not Eligible To Practice Law in California _ Interim suspension after conviction 91-C-02826 1/1/1991 Inactive 6/12/1990 Admitted to The State Bar of California State Bar Court Cases The listing below is partial, as the State Bar Court is transitioning to online dockets. Please refer to the License Status, Disciplinary and Administrative History section above for a record of discipline cases. Case dockets and documents may be available using the State Bar Court Search for a Case feature. Effective Date Case Number Description 6/4/2015 13-0-17332 Stipulation [PDF] Additional Information: e Explanation of licensee status * Explanation of disciplinary system ¢ Explanation of disciplinary actions * Copies of official licensee discipline records are available upon request The State Bar Court began posting public discipline documents online in 2005. The format and pagination of documents posted on this site may vary from the originals in the case file as a result of their translation from the original format into Word and PDF Copies of additional related documents in a case are available upon request. On May 31, 2019, the State Bar Court launched online case dockets. If a case was open or filed on or after Feb 7, 2019, documents are being added online as events occur, and can be accessed with the new Search for a Case feature. Older case records are available on request. members.calbar,ca.gov/fal/Licensee/Detail/146352 AExhibit DMC-010 JATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: 146352 NAME: Mark Lapham FIRM NAME: STREET ADORESS: 751 Diablo Rd. jerry. Danville state. CA zi cone: 94526 TELEPHONE NO: 925-837-9007 FAX NO: ELECTRONICALLY E-MAIL ADDRESS FILED ATTORNEY FOR (name. defendant YAN, CHEUK TIN ‘Superior Court of California, County of San Francisco JSUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO STREET ADDRESS: 400 MCALLISTER STREET 09/10/2019 MAILING ADDRESS: Clerk of the Court icity ano zi cove: SAN FRANCISCO, CA 94102 BY: EDWARD SANTOS Deputy Clerk BRANCH NAME: PLAINTIFF: CRYSTAL LEI et al. DEFENDANT: DEMAS YAN et al. FOR COURT USE ONLY ‘CASE NUMBER: MEMORANDUM OF COSTS (SUMMARY) CGC 14565831 The following costs are requested: TOTALS 1. Filing and motion fees 1280 2. Jury fees Jury food and lodging Deposition costs 3. 4 5. Service of process 6. Attachment expenses 7. Surety bond premiums 8. Witness fees 9. Court-ordered transcripts enenneeen wa 10. Attorney fees (enter here if contractual or statutory fees are fixed without necessity of a court determination; otherwise a noticed motion is required) 41. Court reporter fees as established by statute 60 42. Models, enlargements, and photocopies of exhibits 13. Interpreter fees 14. Fees for electronic filing or service 15. Fees for hosting electronic documents Pee eH 16. Other TOTAL COSTS $ 1340 1 am the attorney, agent, or party who claims these costs. To the best of my knowledge and belief this memorandum of costs is correct and these costs were necessarily incurred in this case. Date: Sep 10, 2019 MARK LAPHAM PEQWAA (TYPE OR PRINT NAME) (SIGNATURE OF DECLARANT) (Proof of service on reverse) Page 1 of 2 Form Approved for Optional Use. Code of Civil Procedure, Juda Counel of Califomia MC-010 MEMORANDUM OF COSTS (SUMMARY) 98 1032, 1033.5 {Rev. September 1, 2017),Exhibit EMC-010 ATTORNEY OR PARTY WITHOUT ATTORNEY Name. Mark Lapham FIRM NAME: STREET ADDRESS: 751 Diablo Rd. city: Danville TELEPHONE NO.: 925-837-9007 E-MAIL ADDRESS: ATTORNEY FOR (name): defendant YAN, TINA STATE BAR NUMBER: 146352 state: CA ZIP. CobE: 94526 FAX NO, SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO street ADoRESS: 400 MCALLISTER STREET MAILING ADDRESS. city ano zip cove: SAN FRANCISCO, CA 94102 BRANCH NAME: PLAINTIFF: CRYSTAL LE] et al. DEFENDANT: DEMAS YAN et al. FOR COURT USE ONLY ELECTRONICALLY FILED ‘Superior Court of California, County of San Francisco 09/10/2019 Clerk of the Court BY: EDWARD SANTOS Deputy Clerk MEMORANDUM OF COSTS (SUMMARY) CASE NUMBER: CGC14565831 The following costs are requested: 1. Filing and motion fees 2. Jury fees 3. Jury food and lodging 4. Deposition costs 5. Service of process 6. Attachment expenses 7. Surety bond premiums 8. Witness fees 9. Court-ordered transcripts 10. Attorney fees (enter here if contractual or statutory fees are fixed without necessity of a court determination; otherwise a noticed motion is required) 11. Court reporter fees as established by statute 12. Models, enlargements, and photocopies of exhibits 13. Interpreter fees 14. Fees for electronic filing or service 15. Fees for hosting electronic documents 16. Other TOTALS CR FHF HH HH HF & Cee 8 & 1020 90 [TOTAL COSTS a 1110 lam the attorney, agent, or party who claims these costs. To the best of my knowledge and belief this memorandum of costs is correct and these costs were necessarily incurred in this case, Date: Sep 11, 2019 MARK LAPHAM (TYPE OR PRINT NAME) (Proof of service on reverse) DL iQ 4 (SIGNATURE OF DECLARANT) Page 1 of 2 Form Approved for Optional Use Judicial Council of Califomia MC-010 (Rev. September 1, 2017] MEMORANDUM OF COSTS (SUMMARY) Code of Civit Procedure, §§ 1032, 1033.8Exhibit FCo em IN DA NW FF WN | A pn OHK 2S 16 CHERYL C. ROUSE (State Bar No. 118313) NORMAN P. BAHLERT (State Bar No. 135693) LAW OFFICES OF ROUSE & BAHLERT 1246 18th Street San Francisco, CA 94107 Mailing Address: 1459 18th Street, #104 San Francisco, CA 94107 Tel No. (415) 575-9444 Fax No. (415) 575-9440 rblaw@ix.netcom.com Attorneys for Plaintiffs Crystal Lei and Bryant Fu SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO UNLIMITED CIVIL JURISDICTION CRYSTAL LEI AND BRYANT FU, CASE NO. CGC 14-565831 Plaintiffs, v. DEMAS YAN aka DENNIS YAN, an individual, DBA EPONA NOTICE TO ATTEND TRIAL INVESTMENT REALTY and DBA YAN LAW OFFICES, CHEUK TIN YAN, an individual, TINA F. YAN, aka TINA FOON YU YAN, an individual, 547 INVESTMENTS LLC, a California limited liability company, THE REMODELING COMPANY, INC., a California corporation, ERONA INVESTMENT Trial Date: June 24, 2019 GROUP, LLC, a California limited Time: 9:30 a.m. liability company, ANEW LAW Dept: 206 CORPORATION, a California corporation, and DOES 1-50, inclusive Defendants. TO TINA YAN aka TINA F. YAN aka TINA FOON YU YAN AND TO HER! ATTORNEY OF RECORD: Pursuant to Code of Civil Procedure §1987(b) Plaintiffs Crystal Lei and Bryant Ful hereby request that TINA YAN aka TINA F. YAN aka TINA FOON YU YAN attend and Notice to Attend Trial 1appear at the trial in this matter commencing on June 24, 2019. at 9:30 a.m. in Department 206 of the Supcrior Court located at 400 McAllister St., San Francisco, CA 94102. Dated: June 14, 2019 LAW OFFICES OF ROUSE & BAHLERT Attorneys for Plaintifls CRYSTAL LEI and BRYANT FU. w Notice to Attend TrialCERTIFICATE OF SERVICE STATE OF CALIFORNIA ) ) ss COUNTY OF SAN FRANCISCO — ) [, the undersigned, declare: lam acitizen of the United States and a resident of the County of SAN FRANCISCO, 1am over the age of eighteen (18) years and not a party to the within action. My business address is: LAW OFFICES OF ROUSE & BAHLERT, 1246 18th Street. San Francisco. California 94107, On June 14. 2019.1 served the within documents: NOTICE TO ATTEND TRIAL (TINA YAN aka TINA F. YAN aka TINA FOON YU YAN) X__ by U.S. First Class Mail on the parties so designated by placing a true copy thereo enclosed in a sealed envelope with postage therein fully prepaid in the United States mail at San Francisco, California, addressed as follows: Demas Yan aka Dennis Yan Defendant Tina Yan Aka Tina F. Yan Aka Defendant in pro per Jina Foon Yu Yan and 547 Investments, 100 Pine Street. #1250 LLC San Francisco, CA 94111 Mark Lapham, Esq. and 751 Diablo Road 1433 7" Avenue Danville, CA 94526 San Francisco, CA 94122 Niceforo Luceno Avila, Jr.. Esq. 478 Ic, Santa Clara Street. Suite 234 San Jose. CA 95112 by transmitting via the document(s) listed above via fascimile at the fax number set forth below on this date prior to 6:00 p.m. X__ by transmitting via the document(s) listed above via e-mail at the e-mail address set forth below on this date prior to 5:00 p.m. Demas Yan aka Dennis Yan - anewlaw@gmail.com Mark Lapham, Esq. - marklaphamoffice@gmail.com EXECUTED ON June 14, 2019 at SAN FRANCISCO, California. X__ (State) I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. \ CU Olen. CHERYL C. ROUSE Proof of Service of Notice to Attend Trial 1