Preview
FILER;a
JAMES M. BARRETT, ESQ. (SBN 190274)
SAN MATEO COUNTY
THE LAW OFFICE OF JAMES M. BARRETT, PLC
5150 EL CAMINO REAL, SUITE D-22
LOS ALTOS, CA 94022—1534
T: (650) 969-3687
F: (650) 969—3699
E: JB@JAMESBARRETTLAW.COM
Attorney for Defendants Bua Quach, Sovan Lien, Dong Vuong and Thank Lai
SUPERIOR COURT OF CALIFORNIA
FOR THE CITY AND COUNTY OF SAN MATEO
DBP INVESTMENTS, a California General )
10 Partnership, Case No.: CIV538897
;
11
Plaintiff, ) DEFENDANT’S NON-OPPOSITION TO
) PLAINTIFF’S MOTION TO COMPEL, AND
12
V. ) SANCTIONS, DECLARATION OF JAMES
13
M. BARRETT
KING PLAZA CENTER, LLC a Delaware i
)
14 Limited Liability Company, BUA QUACH, an) Date: March 27, 2017
individual, SOVAN LIEN, an individual, )
Time: 9:00 AM.
15 DONG VUONG, an individual, THANH LAI ,) Dept: Law and Motion
and DOES 1 through 10 ) Trial: Not Set "fl _- ________ ___ _.__
16 Defendants. ) 5,531,897
lEggiigjpposition to
17 i
3
)
18 AND RELATED CROSS-ACTION \ilii‘i‘il“ lllllllllllll\\\_
i
19
COMES NOW Defendant Bua Quach, and states as follows: Defendant’s Counsel files a Non-
20
Opposition to Defendant’s Request for Motions to Compel related to Production of Documents
21
through Discovery.
22
DATED: March 8, 2017 Law Office of James M. Barrett PLC
23
‘
24
'
fir»; M Awar—
ames M. Barrett
25 Attorney for Defendant
DBP v King Plaza et al — Case No.: CIV538897 1
’5:
0031.12:
Egg :2
d 5* w: 11:12
I James M. Barrett, declare as follows:
1. I am an attorney duly licensed to practice before all courts in the State of California.
2. This declaration is submitted in support of Defendant’s Non-opposition to
Plaintiffs Request for a Motion to Compel.
I have personal knowledge of the matters stated herein, except those matters stated on
information and belief, and to those matters, I believe them to be true. If called as a
witness I can testify meaningfully as to those matters.
With this Non-Opposition, Defendant includes the Amended Responses for the two
10 Requested Responses 9 and 10 which are the basis for this Motion; See Exhibit 1.
11 . Just to be clear with this Court, Plaintiff has gone to great lengths to make issues out of
12 Non issues, in that the requested responses (documents) were not in the custody or
13 control of Defendant Quach.
14
The Amended Responses make this quite clear. Plaintiff has been made quite aware
15
that Defendant Quach has produced all documents that were in the custody or control in
16
the first set of responses.
17
This entire Motion process was a waste of the Court’s time and energy. A proper use
18
of this process was for Moving Party to allow for the Amended Responses to be served
19 under the intent of the Discovery Act to avoid utilizing the Court’s time over this type
20 of Motion. There was no emergency that would lead Moving Party to believe that
waiting for the not in possession responses would have interfered with their case.
21
I declare under penalty of perjury under the laws of the State of California that the
22
foregoing is true and correct.
23
24
DATE: March 8, 2017 L Office f Janos M. Barrett PLC
25
J es M. Barrett
2
DBP v King Plaza et al — Case No.: CIV538897
© LEGAL DIMENSIONS 1979
800-535-7753 - 949-582-3484
www.lega|d|mensions.com
I mus.“ —
JAMES M. BARRETT, ESQ. (SBN 190274)
THE LAW OFFICE OF JAMES M. BARRETT, PLC
5150 EL CAMINO REAL, SUITE D-22 .
LOS ALTOS, CA 94022-1534
T: (650) 969-3687
F: (650) 969-3699
E: JB@JAMESBARRETTLAW.COM
\ooouoxmhwwp-
Attorney for Defendants Bua Quach, Sovan Lien, Dong Vuong and Thanh Lai
SUPERIOR COURT OF CALIFORNIA
FOR THE CITY AND COUNTY OF SAN MATEO
DBP INVESTMENTS, a California General )
Partnership, ) Case N0.: CIV538897
)
Plaintiff, ) AMENDED RESPONSES TO
PLAINTIFF’S REQUEST FOR
v. g PRODUCTION OF DOCUMENTS
)
)
KING PLAZA CENTER, LLC a Deleware
)
Limited Liability Company, BUA QUACH, an)
individual, SOVAN LIEN, an individual,
DONG VUONG, an individual, THANH LAI, )
NNNNNNNNNI—‘r—‘h—‘r—‘D—‘v—‘i—II—‘Hh—fi
and DOES 1through 10 )
Defendants. )
)
WQQMAWNHOKOOONQMAUJNv—‘O
)
)
AND RELATED CROSS-ACTION )
PROPOUNDIN PARTY : DBP Investments
RESPONDING PARTY : Bua Quach
SET NUMBER : One
Comes Now Defendant Bua Quach, and Hereby Responds To Plaintiff DBP Investments
Request for Production of Documents, Set One, As Follows:
Case No CIV538897
RESPONSE TO REQUEST FOR PRODUCTION NO. 1.
After a diligent search and reasonable inquiry has been made in an effort to locate the item
demanded there are no documents in the custody or control of Responding Party that answer this
request. It is Responding Party’s belief that no documents requested exist. Defendant has no
\OOO\]O\U‘-AWNt—-
knowledge of who would be in possession of the requested documents should they exist other
than Plaintiff DBP Investments should such document exist. Should any documents come into
the possession of Responding Party they will be produced to asking party.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2.
After a diligent search and reasonable inquiry has been made in an effort to locate the item
demanded there are no documents in the custody or control of Responding Party that answer this
request. It is Responding Party’s belief that no documents requested exist. Defendant has no
knowledge of who would be in possession of the requested documents should they exist other
than Plaintiff DBP Investments should such document exist. Should any documents come into
the possession of Responding Party they will be produced to asking party.
NNNNNNNNNHHF—‘I—‘HD—lt—‘b—Db—‘p—I
RESPONSE TO REQUEST FOR PRODUCTION NO. 3.
After a diligent search and reasonable inquiry has been made in an effort to locate the item
WQGMAWNHOOOOVQM-hwwflo
demanded there are no documents in the custody or control of Responding Party that answer this
request. It is Responding Party’s belief that no documents requested exist. Defendant has no
knowledge of who would be in possession of the requested documents should they exist other
than Plaintiff DBP Investments should such document exist. Should any documents come into
the possession of Responding Party they will be produced to asking party.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4.
After a diligent search and reasonable inquiry has been made in an effort to locate the item
demanded there are no documents in the custody or control of Responding Party that answer this
request. It is Responding Party’s belief that no documents requested exist. Defendant has no
Case No CIV538897
knowledge of who would be in possession of the requested documents should they exist other
than Jeffrey Litke should such document exist. Should any documents come into the possession
of Responding Party they will be produced to asking party.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5.
\OOONONLIIADJNv—a
After a diligent search and reasonable inquiry has been made in an effort to locate the item
demanded there are no documents in the custody or control of Responding Party other than
Exhibit A contained herein, (Previously marked KING00171) that answer this request. It is
Responding Party’s belief that no documents requested exist other than identified. Defendant
has no knowledge of who would be in possession of the requested documents should they exist
other than Jeffrey Litke should such document exist. Should any documents come into the
possession of Responding Party they will be produced to asking party.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6.
After a diligent search and reasonable inquiry has been made in an effort to locate the item
demanded there are no documents in the custody or control of Responding Party other than
Exhibit B contained herein, (Previously marked KINGOOI91) that answer this request. It is
NNNNNNNNNHI—‘D—DD—‘P—lfll—ii—lv—‘H
Responding Party’s belief that no documents requested exist other than identified. Defendant
WNQMAMNb—‘ONDOOQQM-P-WNI—‘O
has no knowledge of who would be in possession of the requested documents should they exist
other than Tammy Ho, Sabrina Ho, Edmund H0, Ronald Rossi, or Madolyn Orr should such
document exist. Should any documents come into the possession of Responding Party they will
be produced to asking party.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7.
After a diligent search and reasonable inquiry has been made in an effort to locate the item
demanded there are no documents in the custody or control of Responding Party that answer this
request. Defendant has no knowledge of who would be in possession of the requested
Case No CIV538897
documents. Should any documents come into the possession of Responding Party they will be
produced to asking party.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8.
After a diligent search and reasonable inquiry has been made in an effort to locate the item
\OOOflam-tn—a
demanded there are no documents in the custody or control of Responding Party that answer this
request. Defendant has no knowledge of who would be in possession of the requested
documents. Should any documents come into the possession of RespondingParty they will be
produced to asking party.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9
After a diligent search and reasonable inquiry has been made in an effort to locate the item
demanded there are no documents in the custody or control of Responding Party that answer this
request. Defendant has no knowledge of who would be in possession of the requested documents
other than the City of Daly City Code Enforcement located at City Hall, 333 90‘h Street, Planning
Division Daly City 94015, 650-991-8000,. Should any documents come into the possession of
NMNNNNNNNb—dt—v—t—nr—r—tr—‘r—ti—a—a
Responding Party they will be produced to asking party.
RESPONSE TO REQUEST FOR PRODUCTION NO. 10
WQQMAWNH‘OWWNOMAWND—‘O
After a diligent search and reasonable inquiry has been made in an effort to locate the item
demanded there are no documents in the custody or control of Responding Party that answer this
request. Defendant has no knowledge of who would be in possession of the requested documents
Iother than the City of Daly City Code Enforcement located at City Hall, 333 90‘h Street, Planning
{Division Daly City 94015, 650-991-8000,. Should any documents come into the possession of
Responding Party they will be produced to asking party.
iRESPONSE TO REQUEST FOR PRODUCTION NO. 11
After a diligent search and reasonable inquiry has been made in an effort to locate the item
demanded there are no documents in the custody or control of Responding Party that answer this
Case No CIV538897
request. Defendant has no knowledge of who would be in possession of the requested
documents. Should any documents come into the possession of Responding Party they will be
produced to asking party.
RESPONSE TO REQUEST FOR PRODUCTION NO. 12
\OOOVONUI-PWNH
After a diligent search and reasonable inquiry has been made in an effort to locate the item
demanded there are no documents in the custody or control of Responding Party that answer this.
request. Defendant has no knowledge of who would be in possession of the requested
documents. Should any documents come into the possession of Responding Party they will be
produced to asking party.
RESPONSE TO REQUEST FOR PRODUCTION NO. 13
After a diligent search and reasonable inquiry has been made in an effort to locate the item
demanded there are no documents in the custody or control of Responding Party that answer this
request. Defendant has no knowledge of who would be in possession of the requested
documents. Should any documents come into the possession of Responding Party they will be
NNNNNNNNNHD—Ib—II—ID—lj—Ih—II—fil—Ir—t
produced to asking party.
WNQMAWNHOKOOOQONMAWNv—‘O
Respectfully Submitted: March 9, 2017
Wu“;
LAW OFFICE OF JAMES M BARRETT PLC
es M. Barrett, Esq
ttorney for Defendants Quack et al. from Manila
riental Market
Case No C1V538897
Ud/U‘d/Zbl'l 16:42 K552195513 LAw L‘JFFICE PAGE 82/62
\ .
~ .
I
.
.
VERIFICATION
I, Bua Quach declare:
I am the person in the above entitled action; I have mad the foregoing Amended Resmnses to the
Request for Request Production of Documents and know the contents thereof; the same is true of
my own knowiedge, except as to those matters which are therein. stated upon my information or
belief, and as to those matters I ’belieVe it to be true.
I declare under penalty of perjury under the laws of the State of California that the foregoing
reSponses are )and correct and this Verification was executed in Los Angeles California.
OKs—f
//-"“ Date : March 9, 2017
Bua Quach/
DBP Investments v. King Plaza Et Al. CIV 538897
PROOF OF SERVICE
(1013a(3) CCP Revised 1/1/88)
STATE OF CALIFORNIA, COUNTY OF SANTA CLARA
I am employed in the county of Santa Clara, State of California. I am over the age of 18 and not
within action; my business address is: The Law Office of James M. Barrett, PLC, 5150 El
a party to the
Camino Real, Suite D-22, Los Altos, California 94022-1534.
On March 9, 2017 1 served the foregoing documents described as:
Defendant Quach’s Notice of Non Opposition to Motion to Compel, Exhibit 1 Amended Responses to
Request for Production of Documents, Verification
in the interested party(ies) in this action by placing a true copy thereof enclosed in sealed envelopes
and/or packages addressed as follows:
Steven B. Piser
1300 Clay Street Suite 1050
Oakland, CA 94612
John Fitzgerald
101 California Street Suite 2300
San Francisco, CA 94111
(X) BY MAIL: I am readily familiar with the firm's practice of collection and processing
correspondence for mailing. Under that practice it would deposited with US. Postal Service on
that same day with postage thereon fully prepaid at Mountain View, California in the ordinary
course of business. I am aware that on motion of party served, service is presumed invalid if
postal cancellation date or postage meter date is more than 1 day afier date of deposit for
mailing in affidavit.
I declare under penalty of perjury under the laws of the State of California that the above is true and
correct.
Executed on March 9, 2017 at Los Altos, California.
WW
Susie’ Maggio
y/
PROOF OF QFRVV‘F . 1
Preview
FILER;a JAMES M. BARRETT, ESQ. (SBN 190274) SAN MATEO COUNTY THE LAW OFFICE OF JAMES M. BARRETT, PLC 5150 EL CAMINO REAL, SUITE D-22 LOS ALTOS, CA 94022—1534 T: (650) 969-3687 F: (650) 969—3699 E: JB@JAMESBARRETTLAW.COM Attorney for Defendants Bua Quach, Sovan Lien, Dong Vuong and Thank Lai SUPERIOR COURT OF CALIFORNIA FOR THE CITY AND COUNTY OF SAN MATEO DBP INVESTMENTS, a California General ) 10 Partnership, Case No.: CIV538897 ; 11 Plaintiff, ) DEFENDANT’S NON-OPPOSITION TO ) PLAINTIFF’S MOTION TO COMPEL, AND 12 V. ) SANCTIONS, DECLARATION OF JAMES 13 M. BARRETT KING PLAZA CENTER, LLC a Delaware i ) 14 Limited Liability Company, BUA QUACH, an) Date: March 27, 2017 individual, SOVAN LIEN, an individual, ) Time: 9:00 AM. 15 DONG VUONG, an individual, THANH LAI ,) Dept: Law and Motion and DOES 1 through 10 ) Trial: Not Set "fl _- ________ ___ _.__ 16 Defendants. ) 5,531,897 lEggiigjpposition to 17 i 3 ) 18 AND RELATED CROSS-ACTION \ilii‘i‘il“ lllllllllllll\\\_ i 19 COMES NOW Defendant Bua Quach, and states as follows: Defendant’s Counsel files a Non- 20 Opposition to Defendant’s Request for Motions to Compel related to Production of Documents 21 through Discovery. 22 DATED: March 8, 2017 Law Office of James M. Barrett PLC 23 ‘ 24 ' fir»; M Awar— ames M. Barrett 25 Attorney for Defendant DBP v King Plaza et al — Case No.: CIV538897 1 ’5: 0031.12: Egg :2 d 5* w: 11:12 I James M. Barrett, declare as follows: 1. I am an attorney duly licensed to practice before all courts in the State of California. 2. This declaration is submitted in support of Defendant’s Non-opposition to Plaintiffs Request for a Motion to Compel. I have personal knowledge of the matters stated herein, except those matters stated on information and belief, and to those matters, I believe them to be true. If called as a witness I can testify meaningfully as to those matters. With this Non-Opposition, Defendant includes the Amended Responses for the two 10 Requested Responses 9 and 10 which are the basis for this Motion; See Exhibit 1. 11 . Just to be clear with this Court, Plaintiff has gone to great lengths to make issues out of 12 Non issues, in that the requested responses (documents) were not in the custody or 13 control of Defendant Quach. 14 The Amended Responses make this quite clear. Plaintiff has been made quite aware 15 that Defendant Quach has produced all documents that were in the custody or control in 16 the first set of responses. 17 This entire Motion process was a waste of the Court’s time and energy. A proper use 18 of this process was for Moving Party to allow for the Amended Responses to be served 19 under the intent of the Discovery Act to avoid utilizing the Court’s time over this type 20 of Motion. There was no emergency that would lead Moving Party to believe that waiting for the not in possession responses would have interfered with their case. 21 I declare under penalty of perjury under the laws of the State of California that the 22 foregoing is true and correct. 23 24 DATE: March 8, 2017 L Office f Janos M. Barrett PLC 25 J es M. Barrett 2 DBP v King Plaza et al — Case No.: CIV538897 © LEGAL DIMENSIONS 1979 800-535-7753 - 949-582-3484 www.lega|d|mensions.com I mus.“ — JAMES M. BARRETT, ESQ. (SBN 190274) THE LAW OFFICE OF JAMES M. BARRETT, PLC 5150 EL CAMINO REAL, SUITE D-22 . LOS ALTOS, CA 94022-1534 T: (650) 969-3687 F: (650) 969-3699 E: JB@JAMESBARRETTLAW.COM \ooouoxmhwwp- Attorney for Defendants Bua Quach, Sovan Lien, Dong Vuong and Thanh Lai SUPERIOR COURT OF CALIFORNIA FOR THE CITY AND COUNTY OF SAN MATEO DBP INVESTMENTS, a California General ) Partnership, ) Case N0.: CIV538897 ) Plaintiff, ) AMENDED RESPONSES TO PLAINTIFF’S REQUEST FOR v. g PRODUCTION OF DOCUMENTS ) ) KING PLAZA CENTER, LLC a Deleware ) Limited Liability Company, BUA QUACH, an) individual, SOVAN LIEN, an individual, DONG VUONG, an individual, THANH LAI, ) NNNNNNNNNI—‘r—‘h—‘r—‘D—‘v—‘i—II—‘Hh—fi and DOES 1through 10 ) Defendants. ) ) WQQMAWNHOKOOONQMAUJNv—‘O ) ) AND RELATED CROSS-ACTION ) PROPOUNDIN PARTY : DBP Investments RESPONDING PARTY : Bua Quach SET NUMBER : One Comes Now Defendant Bua Quach, and Hereby Responds To Plaintiff DBP Investments Request for Production of Documents, Set One, As Follows: Case No CIV538897 RESPONSE TO REQUEST FOR PRODUCTION NO. 1. After a diligent search and reasonable inquiry has been made in an effort to locate the item demanded there are no documents in the custody or control of Responding Party that answer this request. It is Responding Party’s belief that no documents requested exist. Defendant has no \OOO\]O\U‘-AWNt—- knowledge of who would be in possession of the requested documents should they exist other than Plaintiff DBP Investments should such document exist. Should any documents come into the possession of Responding Party they will be produced to asking party. RESPONSE TO REQUEST FOR PRODUCTION NO. 2. After a diligent search and reasonable inquiry has been made in an effort to locate the item demanded there are no documents in the custody or control of Responding Party that answer this request. It is Responding Party’s belief that no documents requested exist. Defendant has no knowledge of who would be in possession of the requested documents should they exist other than Plaintiff DBP Investments should such document exist. Should any documents come into the possession of Responding Party they will be produced to asking party. NNNNNNNNNHHF—‘I—‘HD—lt—‘b—Db—‘p—I RESPONSE TO REQUEST FOR PRODUCTION NO. 3. After a diligent search and reasonable inquiry has been made in an effort to locate the item WQGMAWNHOOOOVQM-hwwflo demanded there are no documents in the custody or control of Responding Party that answer this request. It is Responding Party’s belief that no documents requested exist. Defendant has no knowledge of who would be in possession of the requested documents should they exist other than Plaintiff DBP Investments should such document exist. Should any documents come into the possession of Responding Party they will be produced to asking party. RESPONSE TO REQUEST FOR PRODUCTION NO. 4. After a diligent search and reasonable inquiry has been made in an effort to locate the item demanded there are no documents in the custody or control of Responding Party that answer this request. It is Responding Party’s belief that no documents requested exist. Defendant has no Case No CIV538897 knowledge of who would be in possession of the requested documents should they exist other than Jeffrey Litke should such document exist. Should any documents come into the possession of Responding Party they will be produced to asking party. RESPONSE TO REQUEST FOR PRODUCTION NO. 5. \OOONONLIIADJNv—a After a diligent search and reasonable inquiry has been made in an effort to locate the item demanded there are no documents in the custody or control of Responding Party other than Exhibit A contained herein, (Previously marked KING00171) that answer this request. It is Responding Party’s belief that no documents requested exist other than identified. Defendant has no knowledge of who would be in possession of the requested documents should they exist other than Jeffrey Litke should such document exist. Should any documents come into the possession of Responding Party they will be produced to asking party. RESPONSE TO REQUEST FOR PRODUCTION NO. 6. After a diligent search and reasonable inquiry has been made in an effort to locate the item demanded there are no documents in the custody or control of Responding Party other than Exhibit B contained herein, (Previously marked KINGOOI91) that answer this request. It is NNNNNNNNNHI—‘D—DD—‘P—lfll—ii—lv—‘H Responding Party’s belief that no documents requested exist other than identified. Defendant WNQMAMNb—‘ONDOOQQM-P-WNI—‘O has no knowledge of who would be in possession of the requested documents should they exist other than Tammy Ho, Sabrina Ho, Edmund H0, Ronald Rossi, or Madolyn Orr should such document exist. Should any documents come into the possession of Responding Party they will be produced to asking party. RESPONSE TO REQUEST FOR PRODUCTION NO. 7. After a diligent search and reasonable inquiry has been made in an effort to locate the item demanded there are no documents in the custody or control of Responding Party that answer this request. Defendant has no knowledge of who would be in possession of the requested Case No CIV538897 documents. Should any documents come into the possession of Responding Party they will be produced to asking party. RESPONSE TO REQUEST FOR PRODUCTION NO. 8. After a diligent search and reasonable inquiry has been made in an effort to locate the item \OOOflam-tn—a demanded there are no documents in the custody or control of Responding Party that answer this request. Defendant has no knowledge of who would be in possession of the requested documents. Should any documents come into the possession of RespondingParty they will be produced to asking party. RESPONSE TO REQUEST FOR PRODUCTION NO. 9 After a diligent search and reasonable inquiry has been made in an effort to locate the item demanded there are no documents in the custody or control of Responding Party that answer this request. Defendant has no knowledge of who would be in possession of the requested documents other than the City of Daly City Code Enforcement located at City Hall, 333 90‘h Street, Planning Division Daly City 94015, 650-991-8000,. Should any documents come into the possession of NMNNNNNNNb—dt—v—t—nr—r—tr—‘r—ti—a—a Responding Party they will be produced to asking party. RESPONSE TO REQUEST FOR PRODUCTION NO. 10 WQQMAWNH‘OWWNOMAWND—‘O After a diligent search and reasonable inquiry has been made in an effort to locate the item demanded there are no documents in the custody or control of Responding Party that answer this request. Defendant has no knowledge of who would be in possession of the requested documents Iother than the City of Daly City Code Enforcement located at City Hall, 333 90‘h Street, Planning {Division Daly City 94015, 650-991-8000,. Should any documents come into the possession of Responding Party they will be produced to asking party. iRESPONSE TO REQUEST FOR PRODUCTION NO. 11 After a diligent search and reasonable inquiry has been made in an effort to locate the item demanded there are no documents in the custody or control of Responding Party that answer this Case No CIV538897 request. Defendant has no knowledge of who would be in possession of the requested documents. Should any documents come into the possession of Responding Party they will be produced to asking party. RESPONSE TO REQUEST FOR PRODUCTION NO. 12 \OOOVONUI-PWNH After a diligent search and reasonable inquiry has been made in an effort to locate the item demanded there are no documents in the custody or control of Responding Party that answer this. request. Defendant has no knowledge of who would be in possession of the requested documents. Should any documents come into the possession of Responding Party they will be produced to asking party. RESPONSE TO REQUEST FOR PRODUCTION NO. 13 After a diligent search and reasonable inquiry has been made in an effort to locate the item demanded there are no documents in the custody or control of Responding Party that answer this request. Defendant has no knowledge of who would be in possession of the requested documents. Should any documents come into the possession of Responding Party they will be NNNNNNNNNHD—Ib—II—ID—lj—Ih—II—fil—Ir—t produced to asking party. WNQMAWNHOKOOOQONMAWNv—‘O Respectfully Submitted: March 9, 2017 Wu“; LAW OFFICE OF JAMES M BARRETT PLC es M. Barrett, Esq ttorney for Defendants Quack et al. from Manila riental Market Case No C1V538897 Ud/U‘d/Zbl'l 16:42 K552195513 LAw L‘JFFICE PAGE 82/62 \ . ~ . I . . VERIFICATION I, Bua Quach declare: I am the person in the above entitled action; I have mad the foregoing Amended Resmnses to the Request for Request Production of Documents and know the contents thereof; the same is true of my own knowiedge, except as to those matters which are therein. stated upon my information or belief, and as to those matters I ’belieVe it to be true. I declare under penalty of perjury under the laws of the State of California that the foregoing reSponses are )and correct and this Verification was executed in Los Angeles California. OKs—f //-"“ Date : March 9, 2017 Bua Quach/ DBP Investments v. King Plaza Et Al. CIV 538897 PROOF OF SERVICE (1013a(3) CCP Revised 1/1/88) STATE OF CALIFORNIA, COUNTY OF SANTA CLARA I am employed in the county of Santa Clara, State of California. I am over the age of 18 and not within action; my business address is: The Law Office of James M. Barrett, PLC, 5150 El a party to the Camino Real, Suite D-22, Los Altos, California 94022-1534. On March 9, 2017 1 served the foregoing documents described as: Defendant Quach’s Notice of Non Opposition to Motion to Compel, Exhibit 1 Amended Responses to Request for Production of Documents, Verification in the interested party(ies) in this action by placing a true copy thereof enclosed in sealed envelopes and/or packages addressed as follows: Steven B. Piser 1300 Clay Street Suite 1050 Oakland, CA 94612 John Fitzgerald 101 California Street Suite 2300 San Francisco, CA 94111 (X) BY MAIL: I am readily familiar with the firm's practice of collection and processing correspondence for mailing. Under that practice it would deposited with US. Postal Service on that same day with postage thereon fully prepaid at Mountain View, California in the ordinary course of business. I am aware that on motion of party served, service is presumed invalid if postal cancellation date or postage meter date is more than 1 day afier date of deposit for mailing in affidavit. I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on March 9, 2017 at Los Altos, California. WW Susie’ Maggio y/ PROOF OF QFRVV‘F . 1