Motion QuashCal. Super. - 6th Dist.February 1, 2021wooqmml-POONH wwwwmwmer-II-tr-Iv-II-tr-Iv-tr-Ir-Iv-t OOQGDO‘lv-POOND-‘OCDOONGDOTr-PCJONHO Dmitry Stadlin, SBN 302361 STADLIN MARINHO LLP ElectronIFally FIled 111 N. Market Street. Suite 300 by suPer'or court 0f CA, San Jose, California 95113 county 0f santa Clara: Tel: (408) 645-7801 on 1/28/2022 4:49 PM FaXI (408) 645-7802 Reviewed By: K. Nguyen Email: ds@stadlinmarinh0.com case #21CH009337 Attorneys for Petitioner EnveloPe: 8169095 ALEXIS DACOSTA SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SANTA CLARA ALEXIS DACOSTA Case N0.: 21CH009837 Petitioner, NOTICE OF MOTION AND MOTION TO QUASH DEPOSITION SUBPOENA And, FOR PRODUCTION OF BUSINESS RECORDS KRZYSZTOF SYWULA, DATE: 03/21/2022 Respondent. TIME: 93003m DEPT: 4 11 TO RESPONDENT AND TO HIS ATTORNEY(S) OF RECORD: NOTICE IS HEREBY GIVEN that on the date and time specified above, 0r as soon thereafter as the matter may be heard, in the above-named department of the above-entitled court, Petitioner, ALEXIS DACOSTA (“Petitioner”), by and through his attorney 0f record, Will move to quash the Deposition Subpoena for Production of Business Records t0 Google LLC served by Respondent KRZYSZTOF SYWULA (“Respondent”) in the above-entitled matter. This motion will be based on the grounds that California Code of Civil Procedure (“CCP”) §527.6 does not permit discovery under civil harassment. This motion is further based 0n CCP §§1985.3, 1987.1, 2019.030, and 2020.410 in that the production 0f the records in its entirety were overbroad in scope, time, and subject matter, harassing, and seeks information that is neither relevant nor reasonably calculated to lead t0 the discovery of admissible evidence. 1 NOTICE OF MOTION AND MOTION TO QUASH DEPOSITION SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS wmflmmfiwNI-l NNNNNNNNNr-II-tr-Ir-II-tr-Ir-Ir-tr-II-t mflmmfiwNI-‘OCDOONGDmb-PCDNHO Petitioner further gives notice to Respondent that they are seeking reasonable attorneys’ fees and costs and/or sanctions in relation to this Motion. Said fees and costs and/or sanctions are sought against both Respondent and his counsel 0f record jointly. This motion is based 0n this Notice of motion, the memorandum 0f points and authorities in support hereof, 0n the papers and records 0n file herein, the declaration of Dmitry Stadlin in support hereof, and on such oral and documentary evidence as may be presented at the hearing of this motion. Dated: January 28, 2022 Respectfully submitted, Dmitry Stadlin Attorney for Petitioner 2 NOTICE OF MOTION AND MOTION TO QUASH DEPOSITION SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS