DeclarationCal. Super. - 6th Dist.February 11, 2021GCA LAW PARTNERS LLP Mountain View California \OOOQQUI-PUJNr-A N N NNNHy-Ar-IHWt-iwr-twr-I JAMES L. JACOBS (SBN 158277) Electronically Filed KATHRYN C. CURRY (SBN 157099) by Superior Court of CA, GCA LAW PARTNERS LLP County of Santa Clara, 2570 W. E1 Camino Real, Suite 400 on 4/28/2021 6:07 PM Mountain View, CA 94040 Reviewed By: K. Nguyen Telephone: (65o) 428-3900 Case #21 CH009861 Facsimile: (650) 428-3901 Envelope: 6338577 Email: jjacobs@gca1aw.com kcurry@gcalaw.com Attorneys for Respondent MICHAEL HAN SUPERIOR COURT OF THE STATE OF CALIFORNIA INAND FORTHE COUNTY OF SANTA CLARA UNLIMITED JURISDICTION BRIAN TRAN, CASE NO. 21CH009861 Petitioner, DECLARATION 0F KATHRYN C. CURRY IN OPPOSITION TO V- PETITIONER BRIAN TRAN’S MOTION TO QUASH DEPOSITIONMICHAEL HAN> NOTICEAND REQUEST FOR Respondent. DOCUMENTS ' Date: May 11, 2021 Time: 9:00 a.m. Dept. 4 Judge: Comm. Erik Johnson DECL. 0F KATHRYN C. CURRY ISO MICHAEL HAN’S OPP. TO MOTION TO QUASI-I - CASE NO 2 1 CH009861 GCA LAW PARTNERS LLP Mountain View, California OONON \O 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I, Kathryn C. Curry, am an attorney licensed to practice before all the courts in the State of California. I am a partner at GCA Law Partners, LLP, and am lead counsel for Plaintiff Bell Investment Partners, LLC in this action. I make this declaration ofmy own knowledge, except Where indicated otherwise, and as to those I believe them to be true. 1. Brian Tran filed an application for a civil harassment restraining order against Michael Han on February 11, 2021. 2. Mr. Tran and Mr. Han are former business partners. It is my information and belief that this civil harassment action is part of a continuing effort by Mr. Tran to harass Mr. Han and to punish him for leaving the business. Mr. Han has not interacted with or spoken to Mr. Tran in over a year. The petition is without merit. 3. The matter was initially set for hearing on April 6, 2021, but has been continued to June 2, 2021 at 1:30 p.m. in Department 4. 4. On April 1, 2021, Michael Han served a deposition notice (via zoom) and request for production of documents to Brian Tran. The deposition was set for April 15, 2021. 5. On April 12, 2021, Mr. Tran filed a motion to quash the deposition notice and request for documents. 6. Although Mr. Stadlin met and conferred with me regarding the propriety of conducting discovery in a civil harassment proceeding, he did not assert any objections to the document requests in the deposition notice and did not initiate any meet and confer discussions relating to the document requests. 7. Petitioner did not serve any written objections to the deposition notice or requests for documents. I declare under penalty of perjury under the laws of the State of California that the foregoing is true ofmy own knowledge, executed in Mountain View, California on April 28, 2021. H : C .C Kathryn C. Curry -1- DECL. 0F KATHRYN C. CURRY ISO MICHAEL HAN’s OPP. To MOTION To QUASH- CASE No. 21CH009861