On June 01, 2016 a
Motion-Secondary
was filed
involving a dispute between
Dbp Investments,
King Plaza Center, Llc,
and
Does 1 - 10, Inclusive,
King Plaza Center,Llc,
Lai, Thanh,
Lien, Sovan,
Quach, Bua,
Voung, Dong,
for (26) Unlimited Other Real Property
in the District Court of San Mateo County.
Preview
STEVEN B. PISER, SBN 62414
LAW OFFICES OF STEVEN B. PISER ETEEE
SAN MATEO QQUMTY
A Professional Corporation
1300 Clay Street, Suite 1050
Oakland, California 94612 _
APR 2 I 2017
Telephone: (510) 83 5-55 82
Facsimile: 832-1717 Clerk give Su ,. ’OrCourR
(510)
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JOHN L. FITZGERALD, SBN 126613
LAW OFFICES OF JOHN -L. FITZGERALD
101 California Street, Suite 2300
San Francisco, California 941 11
Telephone: (415) 689-1209
Attorneys for
DBP INVESTMENTS, -
a California General Partnership
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN MATEO
DBP INVESTMENTS, a California General ) CASE NO. CIV538897
Partnership, )
)
Plaintiff ) SUPPLEMENTAL DECLARATION OF STEVEN
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) B. PISER IN SUPPORT OF MOTION To
v. ) COMPEL ANSWER To SPECIAL
ooqoxm-boomHooooqoxwLoowI—to ) INTERROGATORY AND FOR SANCTIONS
KING PLAZA, CENTER, LLC, a Delaware ) FROM KING PLAZA CENTER, LLC
Limited Liability Company, BUA-QUACH, )
an individual, SOVAN LIEN, an individual, ) DATE APRIL 28, 2017
DONG VUONG, an individual, THANH ) TIME 9: 00 AM
LAT, and DOES 1 through 10 ) DEPT. LAW & MOT-ION
) TRIAL NOVEMBER 13, 2017
_
Defendants. )
)
KING PLAZA CENTER, LLC, a Delaware )
Limited Liability Company, )
BY FAX
)
Cross-Complainant, )
V. CIVS33397‘TT
H __ ‘ ' T" ‘
)
SUP
)‘ Supplemental
DBP INVESTMENTS, a California General )
Partnership and ROES 1through 10,
3
‘
Cross-Defendants. ) [tillmmmummmmunu
)
Law Oflices of l
Steven B. Piser B.
SUPPLEMENTAL DECLARATION OF STEVEN MOIION To COMPEL ANSWER To SPECIAL INTERROGATORY 'AND FOR
PISER IN SUPPORT OF
,
LLC
SANCTIONS FROM KING PLAZA CENTER,
i
1 I, Steven B. Piser, declare:
2 I am an attorney at law duly admitted to practice before all the courts of the State of
3 California and am an attorney for plaintifi‘ herein. I make this declaration based upon my. own
I
4 knowledge.
5 In any document intensive case, an initial review of all documents is crucial. This is
6 especially true in this era, where email has become a substitute for oral communication. Careful
7 evaluation and analysis of email is important; in the end it can save a lot of money, vitiating the
8 need for oral depositions. This case is no different.
.
9 I prepared a discovery plan only after having been assured all documents were produced.
.1 O This assurance came by way of a court order compelling production and King’s many direct
1 1 statements saying no additional documents existed. I spent at least eight hours preparing for the
12 PMK deposition. And this was after having spent many hours reviewing, analyzing and charting
13 King’s document production. A production I learned three days ago was not complete.
14 On April 12,I spent the entire day at King’s attomey’s office for a deposition of a partner
15 of DBP. Not one word was said about the three thousand documents Mr. Rossi learned of the
16 day before. And nothing was said on the 13‘“, when I was at Mr. Rossi’s office for the continued
‘
17 deposition.
18 Mailing the documents, with a disc, on the 14th assured they would not arrive until the
19 middle of this week.
i
20 I have not reviewed the documents. I do not know what discovery DBP undertook that
21 will have to be re-done or would have been conducted in a different way. Nor do I know how
22 much more my client will have to spend to put it in the position it would have been (and should
23 have been) and there been compliance.
24 I spent two hours reviewing the opposition and assisting in the preparation of this reply.
25 My rate is $515 per hour for an additional $1,030. John Fitzgerald assisted me. His rate is $420
26 per hour. He has submitted a supplemental declaration. DBP should recover the entire cost of
27 this motion.
28 I declare under penalty of perjury under the laws of the State of California that the
‘
Law 0mm of 2
Steven 3- Piser SUPPLEMENTAL DECLARmoN OF STEVEN B. Sorrow OF MOTION To COMPEL ANSWER To SPECIAL INTERROGATORY AND FOR
PISER IN
SANCTIONS FROM KING PLAZA CENTER, LLC
foregoing is true and con‘ect.
Executed this 21Stday of April 2017 at Boston, Massachusetts.
\QOO\]O\U1-I>-OOLOH
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STEVEN B. 'PISER
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Slave" B. Plser To COMPELANSWER To SPECIAL INTERROOATORY AND FOR
SUPPLEMENTAL DECLARATION OF STEVEN B. PISER IN SUPPORT OF MOTION
SANcrIONs FROM KING PLAZA CENTER, LLC
Preview
STEVEN B. PISER, SBN 62414 LAW OFFICES OF STEVEN B. PISER ETEEE SAN MATEO QQUMTY A Professional Corporation 1300 Clay Street, Suite 1050 Oakland, California 94612 _ APR 2 I 2017 Telephone: (510) 83 5-55 82 Facsimile: 832-1717 Clerk give Su ,. ’OrCourR (510) kOOO\'lO‘\Ul-l‘-‘-OJI\)I—t 533} 4 U ’ 'nwuava'mm ”LAW”... JOHN L. FITZGERALD, SBN 126613 LAW OFFICES OF JOHN -L. FITZGERALD 101 California Street, Suite 2300 San Francisco, California 941 11 Telephone: (415) 689-1209 Attorneys for DBP INVESTMENTS, - a California General Partnership IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN MATEO DBP INVESTMENTS, a California General ) CASE NO. CIV538897 Partnership, ) ) Plaintiff ) SUPPLEMENTAL DECLARATION OF STEVEN wwwwwwwml—‘l—‘l—‘l—IHHl—‘HH ) B. PISER IN SUPPORT OF MOTION To v. ) COMPEL ANSWER To SPECIAL ooqoxm-boomHooooqoxwLoowI—to ) INTERROGATORY AND FOR SANCTIONS KING PLAZA, CENTER, LLC, a Delaware ) FROM KING PLAZA CENTER, LLC Limited Liability Company, BUA-QUACH, ) an individual, SOVAN LIEN, an individual, ) DATE APRIL 28, 2017 DONG VUONG, an individual, THANH ) TIME 9: 00 AM LAT, and DOES 1 through 10 ) DEPT. LAW & MOT-ION ) TRIAL NOVEMBER 13, 2017 _ Defendants. ) ) KING PLAZA CENTER, LLC, a Delaware ) Limited Liability Company, ) BY FAX ) Cross-Complainant, ) V. CIVS33397‘TT H __ ‘ ' T" ‘ ) SUP )‘ Supplemental DBP INVESTMENTS, a California General ) Partnership and ROES 1through 10, 3 ‘ Cross-Defendants. ) [tillmmmummmmunu ) Law Oflices of l Steven B. Piser B. SUPPLEMENTAL DECLARATION OF STEVEN MOIION To COMPEL ANSWER To SPECIAL INTERROGATORY 'AND FOR PISER IN SUPPORT OF , LLC SANCTIONS FROM KING PLAZA CENTER, i 1 I, Steven B. Piser, declare: 2 I am an attorney at law duly admitted to practice before all the courts of the State of 3 California and am an attorney for plaintifi‘ herein. I make this declaration based upon my. own I 4 knowledge. 5 In any document intensive case, an initial review of all documents is crucial. This is 6 especially true in this era, where email has become a substitute for oral communication. Careful 7 evaluation and analysis of email is important; in the end it can save a lot of money, vitiating the 8 need for oral depositions. This case is no different. . 9 I prepared a discovery plan only after having been assured all documents were produced. .1 O This assurance came by way of a court order compelling production and King’s many direct 1 1 statements saying no additional documents existed. I spent at least eight hours preparing for the 12 PMK deposition. And this was after having spent many hours reviewing, analyzing and charting 13 King’s document production. A production I learned three days ago was not complete. 14 On April 12,I spent the entire day at King’s attomey’s office for a deposition of a partner 15 of DBP. Not one word was said about the three thousand documents Mr. Rossi learned of the 16 day before. And nothing was said on the 13‘“, when I was at Mr. Rossi’s office for the continued ‘ 17 deposition. 18 Mailing the documents, with a disc, on the 14th assured they would not arrive until the 19 middle of this week. i 20 I have not reviewed the documents. I do not know what discovery DBP undertook that 21 will have to be re-done or would have been conducted in a different way. Nor do I know how 22 much more my client will have to spend to put it in the position it would have been (and should 23 have been) and there been compliance. 24 I spent two hours reviewing the opposition and assisting in the preparation of this reply. 25 My rate is $515 per hour for an additional $1,030. John Fitzgerald assisted me. His rate is $420 26 per hour. He has submitted a supplemental declaration. DBP should recover the entire cost of 27 this motion. 28 I declare under penalty of perjury under the laws of the State of California that the ‘ Law 0mm of 2 Steven 3- Piser SUPPLEMENTAL DECLARmoN OF STEVEN B. Sorrow OF MOTION To COMPEL ANSWER To SPECIAL INTERROGATORY AND FOR PISER IN SANCTIONS FROM KING PLAZA CENTER, LLC foregoing is true and con‘ect. Executed this 21Stday of April 2017 at Boston, Massachusetts. \QOO\]O\U1-I>-OOLOH Ar STEVEN B. 'PISER OUT-PXOJKOI—LO I—‘i—‘I—‘l—JHI—‘H OOflmm-b-(Dtor—IOKOCDNI NNMNNNNMNHHH Law Office: of 3 Slave" B. Plser To COMPELANSWER To SPECIAL INTERROOATORY AND FOR SUPPLEMENTAL DECLARATION OF STEVEN B. PISER IN SUPPORT OF MOTION SANcrIONs FROM KING PLAZA CENTER, LLC