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  • Sinco Technologies PTE LTD v. Soon, et al. Breach of Contract/Warranty Unlimited(06)  document preview
  • Sinco Technologies PTE LTD v. Soon, et al. Breach of Contract/Warranty Unlimited(06)  document preview
  • Sinco Technologies PTE LTD v. Soon, et al. Breach of Contract/Warranty Unlimited(06)  document preview
  • Sinco Technologies PTE LTD v. Soon, et al. Breach of Contract/Warranty Unlimited(06)  document preview
  • Sinco Technologies PTE LTD v. Soon, et al. Breach of Contract/Warranty Unlimited(06)  document preview
  • Sinco Technologies PTE LTD v. Soon, et al. Breach of Contract/Warranty Unlimited(06)  document preview
  • Sinco Technologies PTE LTD v. Soon, et al. Breach of Contract/Warranty Unlimited(06)  document preview
  • Sinco Technologies PTE LTD v. Soon, et al. Breach of Contract/Warranty Unlimited(06)  document preview
						
                                

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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 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA. 11 COUNTY OF SANTA CLARA 12 13 SINCO TECHNOLOGIES PTE LTD, Case No. 16CV301867 14 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 26 27 1 Per September 4, 2020 Order. 28 [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 10 attached to Daniel Gaitan’s declaration in support of the Amended Motion to Seal. 11 For the reasons set forth above, Plaintiff SinCo respectfully requests that the Court seal the 12 above-referenced documents and invite Mr. Eng’s Counsel to so stipulate. 13 14 Om i Dated: October 27, 2020 Respectfully submitted, Ob Lik 16 ROPERS MAJESKI PC om Ok 17 By: of Yhesd 18 Ob TODD A. ROBERTS LAEL D. ANDARA 9 JENNIFER E. ACHESON 20 DANIEL A. GAITAN Attorneys for Plaintiff and Cross-Defendant 21 SINCO TECHNOLOGIES PTE LTD 22 23 24 25 26 27 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 13 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 17 John Giust Michael York Jessica Crabbe 245 Fifth Street, Suite 103 San Francisco, California 94103 Email: edwin@pratherlawoffices.com 18 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 22 JessicaCrabbe@whgclaw.com 23 ElaineWu@WHGCLaw.com FrontDesk@WHGCLaw.com 24 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. 12 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 18 Ob 19 20 21 22 23 24 25 26 27 28 NG-V5401A9C:4852-4684-5375. 1 PROOF OF SERVICE