On October 28, 2016 a
Motion,Ex Parte
was filed
involving a dispute between
Liew Yew Soon,
Ml Tjoa,
Ng Cher,
Xingke Electronics,
Sinco Technologies Pte Ltd,
and
Jinlong Machinery & Electronics Co., Ltd.,
Jin Shao Ping,
Liew Yew Soon,
Ml Tjoa,
Mui Liang Tjoa,
Ng Cher,
Ng Cher Yong,
Quek Seow Eng,
Sinco Electronics,
Sincoo Electronics Technology Co., Limited,
Xingke Electronics,
Xu Shugong,
for civil
in the District Court of Santa Clara County.
Preview
16CV301867
Santa Clara — Civil
TODD A. ROBERTS (SBN 129722) Electronically Filed
LAEL D. ANDARA (SBN 215416 by Superior Court of CA,
JENNIFER E. ACHESON (SBN 130833) County of Santa Clara,
DANIEL E. GAITAN (SBN 326413) on 10/27/2020 5:31 PM
ROPERS MAJESKI PC
1001 Marshall Street, Sth Floor
Reviewed By: R. Walker
Redwood City, CA 94063 Case #16CV301867
Telephone: 650.364.8200 Envelope: 5189736
Facsimile: 650.780.1701
Email: todd.roberts@ropers.com
lael.andara@ropers.com
jennifer.acheson@ropers.com
daniel.gaitan@ropers.com
Attorneys for Plainti
SINCO TECHNOLOGIES PTE LTD
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SUPERIOR COURT OF THE STATE OF CALIFORNIA.
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COUNTY OF SANTA CLARA
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SINCO TECHNOLOGIES PTE LTD, Case No. 16CV301867
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On Plaintiff, [AMENDED] NOTICE OF MOTION &
OC he i APPLICATION FOR ORDER TO SEAL
a EXHIBIT R SUPPORTING SINCO’S
Lik 16 SUPPLEMENTAL BRIEF
of
XINGKE ELECTRONICS (DONGGUAN) REGARDING QUEK SEOW ENG'S
17 CO., LTD.; XINGKE ELECTRONICS MOTION TO QUASH FOR LACK OF
OR 18
(HONG KONG) CO., LTD.; SINCOO
ELECTRONICS TECHNOLOGY CO.,
PERSONAL JURISDICTION
Oe LIMITED.; JINLONG MACHINERY & Date: October 28, 2020!
9 ELECTRONICS CO., LTD.; LIEW YEW Time: 1:30 P.M.
SOON aka MARK LIEW; SINCO Dept: 3
20 ELECTRONICS (DONGGUAN) CO., LTD.; Judge: Hon. Patricia M. Lucas
NG CHER YONG aka CY NG; MUI LIANG
21 TJOA; JIN SHAO PING; XU SHUGONG; Trial: May 17, 2021
QUEK SEOW ENG and DOES 5 through 20, Complaint Filed: 10/28/16
22 inclusive, Last CMC: 9/2/20
Next CMC: 1/6/21
23 Defendants. Original Cross-Complaint Filed: 7/18/19
FACC: 10/04/19
24 SACC: 01/17/20
25 AND RELATED CROSS-ACTION
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1 Per September 4, 2020 Order.
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[AMENDED] MOTION TO SEAL DOCUMENTS ISO OF SINCO'S SUPPLEMENTAL BRIEF RE ENG
MTQ
4823-7158-6512.1
TO ALL PARTIES AND THEIR RESPECTIVE ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that on October 28, 2020 at 1:30 P.M. or as soon thereafter as
the matter may be heard, in Department 6 of the above-entitled court, located at 191 North First
Street, San Jose, California, Plaintiff SINCO TECHNOLOGIES PTE LTD (“SinCo”) will move
the Court for an amended Order so as to incorporate the unredacted version of Exhibit R so as to
be included as part of the Motion to Seal, incorporated by reference, filed on October 12, 2020, but
stamped by the Court on October 13, 2020 [Envelope 5091699]. The redacted version of Exhibit R
was previously filed by Plaintiff on July 20, 2020. [Envelope 4627689] The unredacted version is
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attached to Daniel Gaitan’s declaration in support of the Amended Motion to Seal.
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For the reasons set forth above, Plaintiff SinCo respectfully requests that the Court seal the
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above-referenced documents and invite Mr. Eng’s Counsel to so stipulate.
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Om
i Dated: October 27, 2020 Respectfully submitted,
Ob
Lik 16 ROPERS MAJESKI PC
om
Ok
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By:
of Yhesd
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Ob TODD A. ROBERTS
LAEL D. ANDARA
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JENNIFER E. ACHESON
20 DANIEL A. GAITAN
Attorneys for Plaintiff and Cross-Defendant
21 SINCO TECHNOLOGIES PTE LTD
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28 -1-
[AMENDED] MOTION TO SEAL DOCUMENTS ISO OF SINCO'S SUPPLEMENTAL BRIEF RE ENG
MTQ
4823-7158-6512.1
CASE NAME: SINCO TECHNOLOGIES PTE LTD V. XINGKE ELECTRONICS
(DONGGUAN) CO., LTD., ET AL.
ACTION NO.: 16CV301867
PROOF OF SERVICE
METHOD OF SERVICE
O First Class Mail DO Facsimile Oo Messenger Service
O1 Overni ight Delivery I] E-Mail/Electronic Delivery
1. At the time of service I was over 18 years of age and not a party to this action.
2. My business address is 1001 Marshall Street, 5th Floor, Redwood City, California 94063,
County of San Mateo.
10 3. On October 27, 2020 I served the following documents:
11 [AMENDED] NOTICE OF MOTION & APPLICATION FOR ORDER TO SEAL
EXHIBIT R SUPPORTING SINCO’S SUPPLEMENTAL BRIEF REGARDING QUEK
12 SEOW ENG'S MOTION TO QUASH FOR LACK OF PERSONAL JURISDICTION
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4. I served the documents on the persons at the address below (along with their fax numbers
14 and/or email addresses if service was by fax or email):
NB
Ob i
Jeffrey C.P. Wang Edwin K. Prather
Li 16 Kathleen E. Alparce Prather Law Offices
of
Ok
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John Giust
Michael York
Jessica Crabbe
245 Fifth Street, Suite 103
San Francisco, California 94103
Email: edwin@pratherlawoffices.com
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WHGC, P.L.C.
Ye
19 1301 Dove Street, Suite 1050
Newport Beach, CA 92660
20 Email: Jef rey Wang@whgclaw.com
KathleenAlparce@whgclaw.com
21 JohnGiust@whgclaw.com
MichaelY ork@whgclaw.com
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JessicaCrabbe@whgclaw.com
23 ElaineWu@WHGCLaw.com
FrontDesk@WHGCLaw.com
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25 5. I served the documents by the following means:
26 a. O By United States mail: I enclosed the documents in a sealed envelope or package
addressed to the persons at the addresses specified in item 4 and placed the envelope for
27 collection and mailing, following our ordinary business practices. I am readily familiar with this
business’s practice for collecting and processing correspondence for mailing. On the same day
28 that correspondence is placed for collection and mailing, it is deposited in the ordinary course of
NG-V5401A9C:4852-4684-5375. 1
PROOF OF SERVICE
business with the United States Postal Service, in a sealed envelope with postage fully prepaid at
the address listed in Paragraph 2 above.
b. O By overnight delivery: I enclosed the documents in an envelope or package
provided by an overnight delivery carrier and addressed to the persons at the addresses in item 4.
I placed the envelope or package for collection and overnight delivery at an office or a regularly
utilized drop box of the overnight delivery carrier.
Cc O By messenger: I served the documents by placing them in an envelope or
package addressed to the persons at the addresses listed in item 4 and providing them to a
messenger for service.
d. O By fax transmission: Based on an agreement between the parties and in
conformance with Rule 2.306, and/or as a courtesy, I faxed the documents to the persons at the
fax numbers listed in item 4. No error was reported by the fax machine that I used. A copy of
the record of the fax transmission is attached.
e O By email or electronic transmission: Based on an agreement between the parties
10 and/or as a courtesy, I sent the documents via my electronic service address
(morgan.macnerland@ropers.com) to the persons at the email addresses listed in item 4. I did
11 not receive, within a reasonable time after the transmission, any electronic message or other
indication that the transmission was unsuccessful.
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f f By email or electronic transmission: In compliance with Code of Civil Procedure
13 §1010.6, via my electronic business address (morgan.macnerland@ropers.com), I caused the
document(s) listed above to be electronically served through One Legal for the above-entitled
14 case upon the parties listed in item 4. The file transmission was reported as complete and a copy
NB of the One Legal Receipt will be maintained in our case file.
Ol 15
I declare under penalty of perjury under the laws of the State of California that the above
Lik 16 is true and correct.
of
Ok
17 Date: October 27, 2020
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Ob
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NG-V5401A9C:4852-4684-5375. 1
PROOF OF SERVICE