On June 18, 2018 a
Motion-Secondary
was filed
involving a dispute between
Sha, Solomon,
Sweet Production, Inc., A California Corporation,
and
Does 1 To 10, Inclusive,
Sha, Solomon,
for (07) Unlimited Business Tort/Unfair Business Practice
in the District Court of San Mateo County.
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DAVID MICLEAN (SBN
FILEE
MATEO COUNTY
J. 115098) SAN
dmiclean@micleangleason.corn AUG 2 1 2019
DANIELLE M. MIHALKANIN (SBN 271442)
dmihalkanin@micleangleason.com
MICLEAN GLEASON LLP
411 Borel Avenue, Suite 3 1 0
San Mateo, CA 94402
Telephone: (650) 684-1 181
Facsimile: (650) 684-1 1 82
Attorneys for Defendant and Cross—Complainant
Solomon Sha
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN MATEO
SWEET PRODUCTION, INC., a California Case No. 18-CIV—03 1 10
Corporation,
Plaintiff, DECLARATION 0F DANIELLE M.
MJHALKANIN 1N SUPPORT 0F SOLOMON,
SHA’s REPLY 1N SUPPORT 0F MOTION
v.
FOR LEAVE 0F COURT T0 FILE AND
HAVE HEARD SHA’s MOTION FOR
SOLOMON SHA, an individual; and DOES 1 to TERMINATING SANCTIONS 0R
10, inclusive, ALTERNATIVELY To REOPEN AND
COMPEL DISCOVERY
(C.C.P. §§ 2023.010, 2023.030, 2024.050)
Defendants.
Date: August 28, 2019
SOLOMON SHA, Time: 9:00 am.
Department: Law & Motion
Cross-Complainant,
v.
Trial Date: January 6, 2020
SWEET PRODUCTION, INC., a California
corporation; SWEET EXPRESS; MING CHIN;
DOREEN CHM; and ROES 1 through 10,
inclusive,
Cross—Defendants.
MIHALKANIN DECL. ISO SHA REPLY ISO MOTION FOR LEAVE CASE NO. 18-C1V-03 1 10
K"\
J
I, Danielle M. Mihalkanin, declare as follows:
1. I am an attorney at the law firm of Miclean Gleason LLP located at 411 Borel Avenue,
Suite 3 10, San Mateo, California 94402. I submit this Declaration in support of Solomon Sha’s Reply
in Support of Motion for Leave of Court to File and Have Heard Sha’s Motion for Terminating
Sanctions or Alternatively to Reopen and Compel Discovery.
2. I am a member in good standing of the State Bar of California.
3. I make this declaration based upon facts within my own personal knowledge, except as to
\OOOQON
those matters stated upon information and belief, and as to those matters Ibelieve them to be true. If
called upon to testify to the matters stated herein, I could testify competently and truthfully.
-
10 4. Pursuant t0 the stipulation entered on June 5, 2019, SPI was obligated to produce
11 documents within 45 days so that the parties could “meaningfully participate in settlemen .” As of
12 August 21, 2019, and the filing of this Reply, our office has received no document production from SPI
13 or its counsel.
14 Ideclare under the penalty of peljury of the laws of the United States of America and the State of .
15 California that the foregoing istrue and correct, and that this declaration was executed this let day of i
16 August, ‘2019, in San Mateo, California.
17
18
19
20
By: M Danielle
i‘%‘; W
M. Mihalkanin
21
22
23
24
25
26
27
28
1
MIHALKANIN DECL. ISO SHA REPLY ISO MOHON FOR LEAVE CASE N0. 18-CIV-03 1 10
Document Filed Date
August 21, 2019
Case Filing Date
June 18, 2018
Category
(07) Unlimited Business Tort/Unfair Business Practice
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DAVID MICLEAN (SBN FILEE MATEO COUNTY J. 115098) SAN dmiclean@micleangleason.corn AUG 2 1 2019 DANIELLE M. MIHALKANIN (SBN 271442) dmihalkanin@micleangleason.com MICLEAN GLEASON LLP 411 Borel Avenue, Suite 3 1 0 San Mateo, CA 94402 Telephone: (650) 684-1 181 Facsimile: (650) 684-1 1 82 Attorneys for Defendant and Cross—Complainant Solomon Sha SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN MATEO SWEET PRODUCTION, INC., a California Case No. 18-CIV—03 1 10 Corporation, Plaintiff, DECLARATION 0F DANIELLE M. MJHALKANIN 1N SUPPORT 0F SOLOMON, SHA’s REPLY 1N SUPPORT 0F MOTION v. FOR LEAVE 0F COURT T0 FILE AND HAVE HEARD SHA’s MOTION FOR SOLOMON SHA, an individual; and DOES 1 to TERMINATING SANCTIONS 0R 10, inclusive, ALTERNATIVELY To REOPEN AND COMPEL DISCOVERY (C.C.P. §§ 2023.010, 2023.030, 2024.050) Defendants. Date: August 28, 2019 SOLOMON SHA, Time: 9:00 am. Department: Law & Motion Cross-Complainant, v. Trial Date: January 6, 2020 SWEET PRODUCTION, INC., a California corporation; SWEET EXPRESS; MING CHIN; DOREEN CHM; and ROES 1 through 10, inclusive, Cross—Defendants. MIHALKANIN DECL. ISO SHA REPLY ISO MOTION FOR LEAVE CASE NO. 18-C1V-03 1 10 K"\ J I, Danielle M. Mihalkanin, declare as follows: 1. I am an attorney at the law firm of Miclean Gleason LLP located at 411 Borel Avenue, Suite 3 10, San Mateo, California 94402. I submit this Declaration in support of Solomon Sha’s Reply in Support of Motion for Leave of Court to File and Have Heard Sha’s Motion for Terminating Sanctions or Alternatively to Reopen and Compel Discovery. 2. I am a member in good standing of the State Bar of California. 3. I make this declaration based upon facts within my own personal knowledge, except as to \OOOQON those matters stated upon information and belief, and as to those matters Ibelieve them to be true. If called upon to testify to the matters stated herein, I could testify competently and truthfully. - 10 4. Pursuant t0 the stipulation entered on June 5, 2019, SPI was obligated to produce 11 documents within 45 days so that the parties could “meaningfully participate in settlemen .” As of 12 August 21, 2019, and the filing of this Reply, our office has received no document production from SPI 13 or its counsel. 14 Ideclare under the penalty of peljury of the laws of the United States of America and the State of . 15 California that the foregoing istrue and correct, and that this declaration was executed this let day of i 16 August, ‘2019, in San Mateo, California. 17 18 19 20 By: M Danielle i‘%‘; W M. Mihalkanin 21 22 23 24 25 26 27 28 1 MIHALKANIN DECL. ISO SHA REPLY ISO MOHON FOR LEAVE CASE N0. 18-CIV-03 1 10