Party Discovery: CATHAY BANK, A CALIFORNIA BANKING CORPORATION VS. RAYMOND XIANG ZHANG et al

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                                SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO

Document Scanning Lead Sheet
Oct-03-2012 2:54 pm

Case Number: CGC-10-500934
Filing Date: Oct-03-2012 2:53
Filed by: ROSSALY DELAVEGA
Juke Box: 001 Image: 03790071
DECLARATION OF

CATHAY BANK, A CALIFORNIA BANKING CORPORATION VS. RAYMOND
XIANG ZHANG et al

001003790071

Instructions:
Please place this sheet on top of the document to be scanned.Michael Gerard Fletcher (State Bar No. 070849)
mfletcher@frandzel.com

Kenneth N. Russak (State Bar No. 107283)
krussak@franzel.com

Hanna B. Raanan (State Bar No. 261014)
hraanan@frandzel.com

FRANDZEL ROBINS BLOOM & CSATO, L.C.

6500 Wilshire Boulevard
Seventeenth Floor

Los Angeles, California 90048-4920
Telephone: (323) 852-1000
Facsimile: (323) 651-2577

Attorneys for Plaintiff and Cross-Defendant
CATHAY BANK

SUPERIOR COURT OF CALIFORNIA

COUNTY OF SAN FRANCISCO

CATHAY BANK, a California banking
corporation,

Plaintiff,
Vv.

RAYMOND XIANG KAI ZHANG, aka
RAYMOND KAI ZHANG, aka RAYMOND
ZHANG, aka XIANG KAI ZHANG, aka
XIANG ZHANG, aka ZHANG XIANG, an
individual; CINDY ZHANG, an individual;
DONG YING QUI, an individual; XIANG
KAI, LLC; a California limited liability
company; RAY KAI, LLC , a California
limited liability company; ZHANGS, LLC, a
California limited liability company; and
DOES 1 through 200, inclusive,

Defendants.

AND RELATED CROSS-ACTIONS

1087999.1 | 023000-0790

CASE NO. CGC-10-500934

DECLARATION OF HANNA B. RAANAN
IN SUPPORT OF PLAINTIFF AND
CROSS-DEFENDANT CATHAY BANK'S
OPPOSITION TO DEFENDANTS'
MOTION TO COMPEL FURTHER
RESPONSES TO FORM
INTERROGATORIES AND FOR
SANCTIONS

[Filed concurrently with Opposition to Motion
to Compel Further Responses, and Separate
Statement of Disputed Discovery]

Date: October 17, 2012
Time: 9:00 a.m.
Dept.: 302

400 McAllister Street

San Francisco, CA 94102

1 .
DECLARATION OF HANNA B. RAANAN IN SUPPORT OF PLAINTIFF AND CROSS-DEFENDANT CATHAY
BANK'S OPPOSITION TO DEFENDANTS' MOTION TO COMPEL FURTHER RESPONSES TO FORM
INTERROGATORIES AND FOR SANCTIONSI, Hanna B. Raanan, hereby state and declare as follows:

1 Tam an attorney licensed to practice law in California. I am an associate of
Frandzel Robins Bloom & Csato, L.C. attorneys for Plaintiff and Cross-defendant Cathay Bank
("Cathay"). I am submitting this declaration in support of the Bank's Opposition to Defendants!
Motion to Compel Further Responses to Form Interrogatories, Set One and For Sanctions
("Motion"). I have personal knowledge of the matters set forth in this declaration and I could and
would testify competently thereto if called upon to do so

2. On or about June 15, 2012, I received form interrogatories propounded by.
Defendant Raymond Zhang to Cathay Bank. On or about July 27, 2012, pursuant to stipulation,
the Bank responded to the form interrogatories. Attached hereto as Exhibit 1 is a true and correct
copy of the Bank's Responses and Objections to Form Interrogatories served on July 27, 2012.

3. I was the attorney principally responsible for preparing Cathay's Responses and all
of the responses and objections were properly asserted based on information available to Cathay at
the time the Response was prepared. Kenneth N. Russak is the partner in my firm responsible for
supervising me on this case. He reviewed the responses and the Opposition to the Motion to
Compel.

4. On August 20, 2012, I received a letter from counsel for the Defendant regarding
Cathay's responses to all discovery, including the form interrogatories. I responded to the August
20, 2012 letter on August 29, 2012.

5. Following my response, I did not receive an phone calls or follow-up letters to
discuss the Bank's responses to the form interrogatories.

6. I bill my time to Cathay at a rate of $221.00 per hour. Mr. Russak bills his time to
Cathay at a rate of $382.50 per hour. I have spent a total of ten (10) hours preparing the Response
to Separate Statement and the Opposition to the Motion. I anticipate spending two (2) hours to
review the Defendant's reply to the Opposition and two (2) hours to prepare for the hearing on the
Motion. Kenneth N. Russak spent four hours and six minutes (4.1) hours reviewing and revising

the Response to Separate Statement and the Opposition to the Motion. I anticipate eight (8) hours
1087999.1 | 023000-0790 1
DECLARATION OF HANNA B. RAANAN IN SUPPORT OF PLAINTIFF AND CROSS-DEFENDANT CATHAY
BANK'S OPPOSITION TO DEFENDANTS' MOTION TO COMPEL FURTHER RESPONSES TO FORM
INTERROGATORIES AND FOR SANCTIONSFRANOZEL ROBINS BLOOM & CsaTo, L.C.

6500 WILSHIRE BOULEVARD, | 7TH FLOOR

LOS ANGELES, CALIFORNIA 90048-4920

(323) 852-1000

Cem aI DA nH PB WwW NY

BN NY NY KY NY NRK HN SB Be Be Be Se Be me Se
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for Mr. Russak to travel to San Francisco for the hearing. In spite of the time it will take to travel
to the hearing, Cathay expects to spend two hours actually appearing at the hearing on the Motion.
In total, my firm anticipates billing thirty 35.1 hours and total fees in the amount of $9,712.25 as a
result of responding to the Motion. Cathay requests monetary sanctions in the full amount of the
fees incurred, $9.712.25, or a lesser amount deemed by the Court to be reasonable in light of the
circumstances. Cathay requests that sanctions awarded be payable by the Defendant within thirty
(30) days of the order on this Motion.

7. The monetary sanctions requested by Cathay are reasonable because the Defendant
had no justification for bringing the Motion, as shown by the Plaintiff's Response to Separate
Statement of Disputed Discovery, and Cathay had to spend substantial time opposing the Motion
and anticipates spending substantial time appearing for the hearing on the Motion to Compel.

I declare under penalty of perjury under the laws of the State of California that the

foregoing is true and correct and that this declaration was executed this 3rd day of October, 2012,

at Los Angeles, California. f j J; ,
JANNA

B. RAANAN

1087999.1 | 023000-0790 2

DECLARATION OF HANNA B. RAANAN IN SUPPORT OF PLAINTIFF AND CROSS-DEFENDANT CATHAY
BANK'S OPPOSITION TO DEFENDANTS’ MOTION TO COMPEL FURTHER RESPONSES TO FORM

INTERROGATORIES AND FOR SANCTIONSLOS ANGELES, CAUFORNIA 90048-4920
(323) 852-1000

FRANDZEL ROBINS BLOoMm & Csato, L.C.
6500 WILSHIRE BOULEVARD, 1 7TH FLOOR

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YN NYY YN NR NY KY SE Be Be eB Be we Be Be eB
eo IY AA FF YN |= DOD MA DA BF wYwNH S&S SD

PROOF OF SERVICE
I, the undersigned, declare and certify as follows:

I am over the age of eighteen years, not a party to the within action and employed in the
County of Los Angeles State of California. I am employed in the office of Frandzel Robins
Bloom & Csato, L.C., members of the Bar of the above-entitled Court, and I made the service
referred to below at their direction. My business address is 6500 Wilshire Boulevard, Seventeenth
Floor, Los Angeles, California 90048-4920

On October 3, 2012, I served true copy(ies) of the DECLARATION OF HANNA B.
RAANAN IN SUPPORT OF PLAINTIFF AND CROSS-DEFENDANT CATHAY BANK'S
OPPOSITION TO DEFENDANTS' MOTION TO COMPEL FURTHER RESPONSES TO
FORM INTERROGATORIES AND FOR SANCTIONS, the original(s) of which is(are) affixed
hereto. to the party(ies) on the attached service list.

& BY OVERNIGHT DELIVERY: I deposited such document(s) in a box or other facility
regularly maintained by the overnight service carrier, or delivered such document(s) to a
courier or driver authorized by the overnight service carrier to receive documents, in an
envelope or package designated by the overnight service carrier with delivery fees paid or
provided for, addressed to the person(s) served hereunder.

I certify under penalty of perjury under the laws of the State of California and the United
States of America that the foregoing is true and correct.

Executed on October 3, 2012, at Los Angeles, California.

1087999.1 | 023000-0790

3
DECLARATION OF HANNA B. RAANAN IN SUPPORT OF PLAINTIFF AND CROSS-DEFENDANT CATHAY
BANK'S OPPOSITION TO DEFENDANTS' MOTION TO COMPEL FURTHER RESPONSES TO FORM

INTERROGATORIES AND FOR SANCTIONSFRANDZEL ROBINS BLOOM & CSATO, L.C.
‘6500 WILSHIRE BOULEVARD, | 7TH FLOOR
LOS ANGELES, CALIFORNIA 90048-4920

(323) 852-1000

Chijeh Hu

CJH & Associates, P.C.
1440 Broadway, Suite 1000
Oakland, CA 94612

Telephone: 510-832-1686

Facsimile: 510-251-1155

Email: ch@cjhulaw.com;
bhofer@cjhulaw.com

1087999.1 | 02300-0790

SERVICE LIST

Attorney for Defendants and Cross-
Complainants:

RAYMOND ZIANG KAI ZHANG, aka
RAYMOND KAI ZHANG, aka RAYMOND
ZHANG, aka XIANG KAI ZHANG, aka
XIANG ZHANG, aka ZHANG XIANG, an
individual; CINDY ZHANG, an individual;
DONG YING QUI, an individual; XIANG KAI,
LLC, a California limited liability company ;
RAY KAI, LLC, a California limited liability
company; ZHANGS, LLC, California limited
liability company

DECLARATION OF HANNA B. RAANAN IN SUPPORT OF PLAINTIFF AND CROSS-DEFENDANT CATHAY
BANK'S OPPOSITION TO DEFENDANTS' MOTION TO COMPEL FURTHER RESPONSES TO FORM
INTERROGATORIES AND FOR SANCTIONS