Preview
12/24/2014 12:55
oR ew YN ADH Re DN =
11
5188362900
Omar Krashna (SBN 214567)
KRASHNA LAW FIRM
7700 Edgewater Drive, Suite 710
Oakland, CA, 94621
510.836.2999(ph)
510.836.2900(fax)
Attorneys for Plaintiffs
KRASHNA LAW FIRM PAGE
ELECTRONICALLY
FILED
Superior Court of California,
County of San Francisco
12/24/2014
Clerk of the Court
BY:WILLIAM TRUPEK
Deputy Clerk
IN THE SUPERIOR COURT FOR THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
(Unlimited Jurisdiction)
CINDY YU, an individual, and
TOSHIYUKI MUSHA, an individual,
Plaintiffs,
vs.
SHAWN SHAO DAN YU, an individual,
JUN YANG YU, an individual, and
LI ZI CHEN, an individual, and all persons
unknown, claiming any legal or equitable right,
title, estate, lien, or interest in the property
described in the complaint adverse to Plaintiffs’
title, or any cloud on Plaintiffs’ title thereto; and
Does 1 through 20, inclusive.
Defendants.
Case No.: CGC-13-533308
5
d
{
j
4
4
‘
4
| REPLY TO OPPOSITION TO MOTION
2 FOR LEAVE TO FILE FAC AND IN THE
« ALTERNATIVE TO CONSOLIDATE
‘MATTERS
Date: December 29, 2014
Time: 9:30 am
Dept: 501
a2/14
REPL Y-—-——-~- Page}
KRASHNA LAW FIRM.
7100 Edgewater Idrive, Suite 71.0
Oakland, CA 94621
510.836.2999(tel)/5 10.836.2900(fax)
AOSMG25758094 tif - 12/24/2044 12:05:15 PM12/24/2014 12:55 51898362908
co PY Dw BW KH
Rb NY NY RP NY NR KN VY Se SB Be ew Se me Be ea
ant DY FY NH F§ SD Oe a RH B WN BS
NOW COME Plaintiffs, CINDY YU and TOSHTYUKI MUSHA, who reply to Defendants’
opposition to Plaintiffs’ motion for an order granting leave to file a first amended complaint, and in the
alternative to consolidate matters.
Respectfully submitted.
Dated: December 23, 2014
KRASHNA LAW FIRM PAGE 3/14
REPLY
KRASHNA LAW FIRM
Omar Krashna
Attorney for Plaintiffs
REPL Yonunnnaawn Page 2
KRASHNA 1L.AW FIRM.
7700 Edgewater !rive, Suite 710
Oakland, CA 94621
510,836,2999(tel/510,836,2900( fax)
AOSMBI5758004 lif - 12/24/2044 12:08:15 PM12/24/2014 12:55 5108362908 KRASHNA LAW FIRM PAGE 4/14
wo em YI Dh BW NHN =
BN YN YN NY NY YN Ye |= He ee Se Se we eB ke
CWA MED NH |= SO BAIA DWH Ew DP =A S
PROOF OF SERVICE
I, the undersigned, declare that I am employed in the City of Oakland, County of Alameda, California. 1
am over 18 years of age and am not a party to the within entitled cause; my business address is 7700 Edgewater
Drive, Suite 710, Oakland CA 94621. On the date indicated below, I caused to be served the attached documents:
REPLY TO OPPOSITION TO MOTION FOR LEAVE TO FILE FAC AND IN THE
ALTERNATIVE TO CONSOLIDATE MATTERS
on the party/parties in said cause, by placing a true copy thereof in a sealed envelope, each cnvelope addressed as follows:
Stanley C. Shen, Esq.
2037 Irving St Ste 206
San Francisco, CA 94122
XX_ (BY US POSTAL MAIL) placing true and correct copies thereof enclosed in a sealed envelope(s), with
first class postage fully prepaid, for collection and mailing at Krashna Law Firm, 7700 Edgewater Drive,
Suite 710, Oakland CA 94621 addressed as set forth above. J am readily familiar with the business
practice for collection and processing of correspondence for mailing with the United States Postal Service.
Correspondence so placed would be deposited with the United States Postal Service that same day in the
ordinary course of business.
(BY PERSONAL SERVICE) I caused cach such envelope to be delivered by hand to the office of each
addressee set forth above.
(BY OVERNIGHT DELIVERY) placing true and correct copies thereof enclosed in a sealed envelope(s),
for overnight delivery, in a box or other facility regularly maintained by an express service carrier, or
delivered to an authorized courier or driver authorized by that express service carrier with delivery fees
paid or provided for, addressed to the person(s) on whom it is to be served, at the office address as last
given by that person(s) on any document filed in the cause and served on the party making service or at
that party’s/parties’ place of residence.
XX_ (BY FACSIMILE) transmission to a facsimile machine maintained by the person(s) on whom it is served
at the facsimile machine telephone number as last given by that person(s) on any document filed in the
cause and served on the party making service (i.e. 415.373.3707).
I declare under penalty of perjury under the laws of California that the foregoing is true and correct and
that this declaration was executed on December 24, 2014, in Oakland, California.
Judy/Saclee
REPL Yomnammnen Page 3 KRASHNA LAW TIRM
7100 Edgewater Drive, Suite 710
Oakland, CA 94621
510.836.2999(tel)/510,836,2900(fax)
AOSMBI5758004 lif - 12/24/2044 12:08:15 PM
Preview
12/24/2014 12:55 oR ew YN ADH Re DN = 11 5188362900 Omar Krashna (SBN 214567) KRASHNA LAW FIRM 7700 Edgewater Drive, Suite 710 Oakland, CA, 94621 510.836.2999(ph) 510.836.2900(fax) Attorneys for Plaintiffs KRASHNA LAW FIRM PAGE ELECTRONICALLY FILED Superior Court of California, County of San Francisco 12/24/2014 Clerk of the Court BY:WILLIAM TRUPEK Deputy Clerk IN THE SUPERIOR COURT FOR THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO (Unlimited Jurisdiction) CINDY YU, an individual, and TOSHIYUKI MUSHA, an individual, Plaintiffs, vs. SHAWN SHAO DAN YU, an individual, JUN YANG YU, an individual, and LI ZI CHEN, an individual, and all persons unknown, claiming any legal or equitable right, title, estate, lien, or interest in the property described in the complaint adverse to Plaintiffs’ title, or any cloud on Plaintiffs’ title thereto; and Does 1 through 20, inclusive. Defendants. Case No.: CGC-13-533308 5 d { j 4 4 ‘ 4 | REPLY TO OPPOSITION TO MOTION 2 FOR LEAVE TO FILE FAC AND IN THE « ALTERNATIVE TO CONSOLIDATE ‘MATTERS Date: December 29, 2014 Time: 9:30 am Dept: 501 a2/14 REPL Y-—-——-~- Page} KRASHNA LAW FIRM. 7100 Edgewater Idrive, Suite 71.0 Oakland, CA 94621 510.836.2999(tel)/5 10.836.2900(fax) AOSMG25758094 tif - 12/24/2044 12:05:15 PM12/24/2014 12:55 51898362908 co PY Dw BW KH Rb NY NY RP NY NR KN VY Se SB Be ew Se me Be ea ant DY FY NH F§ SD Oe a RH B WN BS NOW COME Plaintiffs, CINDY YU and TOSHTYUKI MUSHA, who reply to Defendants’ opposition to Plaintiffs’ motion for an order granting leave to file a first amended complaint, and in the alternative to consolidate matters. Respectfully submitted. Dated: December 23, 2014 KRASHNA LAW FIRM PAGE 3/14 REPLY KRASHNA LAW FIRM Omar Krashna Attorney for Plaintiffs REPL Yonunnnaawn Page 2 KRASHNA 1L.AW FIRM. 7700 Edgewater !rive, Suite 710 Oakland, CA 94621 510,836,2999(tel/510,836,2900( fax) AOSMBI5758004 lif - 12/24/2044 12:08:15 PM12/24/2014 12:55 5108362908 KRASHNA LAW FIRM PAGE 4/14 wo em YI Dh BW NHN = BN YN YN NY NY YN Ye |= He ee Se Se we eB ke CWA MED NH |= SO BAIA DWH Ew DP =A S PROOF OF SERVICE I, the undersigned, declare that I am employed in the City of Oakland, County of Alameda, California. 1 am over 18 years of age and am not a party to the within entitled cause; my business address is 7700 Edgewater Drive, Suite 710, Oakland CA 94621. On the date indicated below, I caused to be served the attached documents: REPLY TO OPPOSITION TO MOTION FOR LEAVE TO FILE FAC AND IN THE ALTERNATIVE TO CONSOLIDATE MATTERS on the party/parties in said cause, by placing a true copy thereof in a sealed envelope, each cnvelope addressed as follows: Stanley C. Shen, Esq. 2037 Irving St Ste 206 San Francisco, CA 94122 XX_ (BY US POSTAL MAIL) placing true and correct copies thereof enclosed in a sealed envelope(s), with first class postage fully prepaid, for collection and mailing at Krashna Law Firm, 7700 Edgewater Drive, Suite 710, Oakland CA 94621 addressed as set forth above. J am readily familiar with the business practice for collection and processing of correspondence for mailing with the United States Postal Service. Correspondence so placed would be deposited with the United States Postal Service that same day in the ordinary course of business. (BY PERSONAL SERVICE) I caused cach such envelope to be delivered by hand to the office of each addressee set forth above. (BY OVERNIGHT DELIVERY) placing true and correct copies thereof enclosed in a sealed envelope(s), for overnight delivery, in a box or other facility regularly maintained by an express service carrier, or delivered to an authorized courier or driver authorized by that express service carrier with delivery fees paid or provided for, addressed to the person(s) on whom it is to be served, at the office address as last given by that person(s) on any document filed in the cause and served on the party making service or at that party’s/parties’ place of residence. XX_ (BY FACSIMILE) transmission to a facsimile machine maintained by the person(s) on whom it is served at the facsimile machine telephone number as last given by that person(s) on any document filed in the cause and served on the party making service (i.e. 415.373.3707). I declare under penalty of perjury under the laws of California that the foregoing is true and correct and that this declaration was executed on December 24, 2014, in Oakland, California. Judy/Saclee REPL Yomnammnen Page 3 KRASHNA LAW TIRM 7100 Edgewater Drive, Suite 710 Oakland, CA 94621 510.836.2999(tel)/510,836,2900(fax) AOSMBI5758004 lif - 12/24/2044 12:08:15 PM