On October 28, 2015 a
Motion-Secondary
was filed
involving a dispute between
Chi-Kan Liu,
Li-Yuan Liu,
Patrick Lin,
Sherry Hsieh,
Yeao-Nan Hsieh,
and
Jemmy Lin,
May Lin,
Min Chou,
Patrick Lin,
Rosa Wang,
Sherry Hsieh,
for Other Petition (Not Spec) Unlimited (43)
in the District Court of Santa Clara County.
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SHERRY HSIEH
YEAO-NAN HSIEH "
52 Dunbarton Court
San Ramon, CA 94583
F I LE
Tel: (408)981-6201
AUG '
1 0 2013
Email: shinchyi@comcast.net
‘
WE”. '“hml'b
.
Pro Se Plamtzffi
.
BY
Wwdmcww n“
sqn;0hn
oapuw
H.
\DOONQ
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10
COUNTY OF SANTA CLARA
11
UNLIMITED JURISDICTION
12
13
SHERRY HSIEH, YEAO-NAN HSIEH, Case No. 115CV287361
Plaintiffs,
14
15 VS. Memorandum of points and authorities in
opposition 0f defendants’ exparte to shorten
PATRICK time to hearing and motion to compel
16 LIN, PATRICK LIN, JEMMY LIN,
deposition
MAY LIN, and DOES 1 THROUGH 10,
Vvvvvvvvvvvvv
17
Defendants.
Date: August 10, 2018
18
Time: 8:15AM
Dept: 9
Judge: Honorable Mary E. Arand
19
20
Trial Date: October 22, 201 8
21
Opposition to shorten time to hearing and motion to compel degosition
22
Sherry Hsieh & Min Chou oppose the defendant’s exparte to shonen time to hearing and motion to
23
compel deposition.
24
Memorandum of points and authorities
25
Sherry Hsieh & Min Chou oppose the exparte to shorten time to hearing and motion to compel
26
deposition. The reasons are as following:
27
28
Memorandum of points and authorities in opposition of motion for compel deposition
Page 1 of2
l. Oral deposition was scheduled to be held around Jul! 3 for Min Chou and July 5 for
Sherry Hsieh and Attornev Jon Robb cancelled both depositions.
Attorney Jon Robb cancelled the oral deposition just one day before the scheduled deposition date
because the translator was sick. Sherry Hsieh scheduled a vacation on July 3 and July 5 in order
to take Min Chou to the Oral deposition.
Sherry Hsieh cannot afford to take two day vacation anymore to go attorney Jon Robb’s office for
\OOO\10\
oral deposition. Once Jon Robb cancelled the deposition, there can be no more deposition.
10 2. The complaints of this case are several emails distributed to Patrick Lin’s college
11 classmates written bv Min Chou.
12
13 Attorney Jon Robb needs to study the emails and nothing else he needs to study for defamation
14 case. No deposition can be taken to court because the deposition has nothing to do with this case.
15
16 3. Patrick Lin refused to have deposition taken. How can he demand Sherfl Hsieh to be
17 called to deposition.
18
19 Patrick Lin refused to have the deposition taken by Sherry Hsieh’s attorney Peter Chao, he has no
20 right to demand a deposition from Sherry Hsieh.
21
I declare under penalty of perjury under the laws of State of California that the foregoing is true and
22
correct.
23
24
Date: August 9, 201 8
25
26
27
28 SHERRY HSIEH & MIN CHOU
Memorandum of points and authorities in opposition of motion for compel deposition
Page 2 of 2
Document Filed Date
August 10, 2018
Case Filing Date
October 28, 2015
Category
Other Petition (Not Spec) Unlimited (43)
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SHERRY HSIEH YEAO-NAN HSIEH " 52 Dunbarton Court San Ramon, CA 94583 F I LE Tel: (408)981-6201 AUG ' 1 0 2013 Email: shinchyi@comcast.net ‘ WE”. '“hml'b . Pro Se Plamtzffi . BY Wwdmcww n“ sqn;0hn oapuw H. \DOONQ SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF SANTA CLARA 11 UNLIMITED JURISDICTION 12 13 SHERRY HSIEH, YEAO-NAN HSIEH, Case No. 115CV287361 Plaintiffs, 14 15 VS. Memorandum of points and authorities in opposition 0f defendants’ exparte to shorten PATRICK time to hearing and motion to compel 16 LIN, PATRICK LIN, JEMMY LIN, deposition MAY LIN, and DOES 1 THROUGH 10, Vvvvvvvvvvvvv 17 Defendants. Date: August 10, 2018 18 Time: 8:15AM Dept: 9 Judge: Honorable Mary E. Arand 19 20 Trial Date: October 22, 201 8 21 Opposition to shorten time to hearing and motion to compel degosition 22 Sherry Hsieh & Min Chou oppose the defendant’s exparte to shonen time to hearing and motion to 23 compel deposition. 24 Memorandum of points and authorities 25 Sherry Hsieh & Min Chou oppose the exparte to shorten time to hearing and motion to compel 26 deposition. The reasons are as following: 27 28 Memorandum of points and authorities in opposition of motion for compel deposition Page 1 of2 l. Oral deposition was scheduled to be held around Jul! 3 for Min Chou and July 5 for Sherry Hsieh and Attornev Jon Robb cancelled both depositions. Attorney Jon Robb cancelled the oral deposition just one day before the scheduled deposition date because the translator was sick. Sherry Hsieh scheduled a vacation on July 3 and July 5 in order to take Min Chou to the Oral deposition. Sherry Hsieh cannot afford to take two day vacation anymore to go attorney Jon Robb’s office for \OOO\10\ oral deposition. Once Jon Robb cancelled the deposition, there can be no more deposition. 10 2. The complaints of this case are several emails distributed to Patrick Lin’s college 11 classmates written bv Min Chou. 12 13 Attorney Jon Robb needs to study the emails and nothing else he needs to study for defamation 14 case. No deposition can be taken to court because the deposition has nothing to do with this case. 15 16 3. Patrick Lin refused to have deposition taken. How can he demand Sherfl Hsieh to be 17 called to deposition. 18 19 Patrick Lin refused to have the deposition taken by Sherry Hsieh’s attorney Peter Chao, he has no 20 right to demand a deposition from Sherry Hsieh. 21 I declare under penalty of perjury under the laws of State of California that the foregoing is true and 22 correct. 23 24 Date: August 9, 201 8 25 26 27 28 SHERRY HSIEH & MIN CHOU Memorandum of points and authorities in opposition of motion for compel deposition Page 2 of 2