DeclarationCal. Super. - 6th Dist.November 23, 2020\OOOQONUl-RUJNH NNNNNNNNNr-tr-tr-tr-tr-tr-tr-tr-tr-tr-t OOQONUl-bUJNt-‘OKDOOQQUl-bUJNP-‘O 200V37394O Santa Clara - Civil Electronically Filed Howard L. Magee (State Bar N0. 185199) by Superior Court of CA, Larry W. Lee (State Bar No. 228175) county of Santa Clara, MaX W. GaVI'OIl (State Bar NO. 291697) on 4/22/2021 3.32 PM DIVERSITY LAW GROUP, A Professional Corporation Reviewed By: R_ Nguyen 515 South Figueroa Street, Suite 1250 case #Zocv373940 Los Angeles, California 90071 Envelope: 6298270 (213) 488-6555 (213) 488-6554 facsimile Robert Starr (State Bar No. 183052) Theodore Tang (State Bar No. 313294) Manny Starr (State Bar No. 3 19778) FRONTIER LAW CENTER 23901 Calabasas Road, Suite 2074 Calabasas, California 91302 T: (818) 914-3433 F: (818) 914-3433 Attorneys for Plaintiff J DOE SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SANTA CLARA J DOE, as an individual, Case N0. 20CV373940 Plaintiff, DECLARATION OF THEODORE R. TANG IN SUPPORT OF PLAINTIFF’S MOTION VS. TO CONTINUE ACTION AS “J DOE” ROKU, INC., a Delaware corporation; LONG-JI Date: April 29, 2021 LIN, an individual, and DOES 1 through 50, Time: 10:00 am. inclusive, Dept: 02 Defendants. Complaint Filed: November 23, 2020 Trial Date: None Set I, Theodore R. Tang, Declare as follows: 1. I am an attorney duly licensed to practice law before all courts 0f the State of California. My law firm, Frontier Law Center, is counsel for Plaintiff J Doe in this action along With Diversity Law Group. This declaration is submitted in support 0f Plaintiff J Doe’s motion t0 continue this 1 DECLARATION OF THEODORE R. TANG IN SUPPORT OF PLAINTIFF’S MOTION TO CONTINUE ACTION AS “J DOE’ R. Nguyen \OOOQONUl-RUJNH NNNNNNNNNr-tr-tr-tr-tr-tr-tr-tr-tr-tr-t OOQONUl-bUJNt-‘OKDOOQQUl-bUJNP-‘O action as “J Doe.” The following facts are within my personal knowledge and, if called as a witness herein, I can and Will competently testify thereto. 2. On or about January 4, 2021 our office was served With form interrogatories, special interrogatories, and requests for production 0f documents. 3. On or about February 5, 2021, our co-counsel’s office, Diversity Law Group, served responses to this discovery. 4. Since then, our offices have met and conferred regarding the discovery. Plaintiff has served supplemental responses, and the parties continue to meet and confer about those responses. 5. On February 10, 2021 our co-counsel, Diversity Law Group, served discovery requests to Defendant Roku, Inc. 6. On March 19, 2021, Defendant Roku Inc. served responses t0 Plaintiff’s discovery requests. 7. The parties are in the process 0f meeting and conferring regarding Roku, Inc’s discovery responses. 8. On April 22, 2021 Defendant Roku, Inc. served a second set 0f discovery. 9. During the discovery exchange and meet and confer process t0 date, Defendants have not raised, nor am I aware 0f, any issues 0r obj ections t0 the discovery based 0n Plaintiff’s name. Executed on this 22nd day of April, 2021 in Vista, California. I declare under penalty 0f perjury under the laws of the State of California that the foregoing is true and correct. WL7/ Theodore R. Tang 2 DECLARATION OF THEODORE R. TANG IN SUPPORT OF PLAINTIFF’S MOTION TO CONTINUE ACTION AS “J DOE’
