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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