DeclarationCal. Super. - 6th Dist.February 23, 202110 ll 12 l3 l4 l5 l6 l7 18 l9 20 21 22 23 24 25 26 27 28 Paul E. Rogers, Esq., SBN 288052 21 CH009879 Santa Clara - Civil M. Sorur Electronically Filed Advocas Law Group by Superior Court of CA, 255 N. Market St. #125 County of Santa Clara, San Jose, CA 951 10 on 6/28/2021 11:55 AM Phone: (408) 641-8803 Reviewed By: M. Scrum per@advocaslaw.com case #21 CH009879 Attorney for Pitchayapa Chaowalit EnveIOPG: 67371 39 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SANTA CLARA PITCHAYAPA CHAOWALIT, ) Case N0: 21CH009879 ) Protected Party, ) V. ) SUPPLEMENTAL DECLARATION OF ) PAUL ROGERS IN SUPPORT OF CANEISHA HOWELL, ) PETITIONER’S RESPONSE TO ) CANEISHA HOWELL’S NOTICE OF Restrained Party ) MOTION AND MOTION TO STRIKE ) PURSUANT TO C.CP. § 425.16 (ANTI- ) SLAPP) ) ) I, Paul E. Rogers, state that I am the attorney 0f record for Pitchayapa Chaowalit, protected party in Santa Clara County case numbers 20DV000265 and 21CH009879. 1. I am an attorney duly licensed t0 practice law in the State 0f California with my address located at 255 N. Market St. #125, San Jose, CA 951 10. On April 9. 2020, a restraining order was issued by the Hon. Carol Overton in the above case, naming Pitchayapa Chaowalit as the protected party and Menachem Hahn as the restrained party. Exhibit A. On June 3, 2020, Caneisha Howell sent a text message t0 Pitchayapa Chaowalit in which she states, “I’m a legal document assistant.” Exhibit B, Bates 000001. Publicly available records in Santa Clara County indicate Ms. Howell was not registered as a Legal Document Assistant in Santa Clara County prior t0 August 3, 2020. Exhibit C. On June 4, 2020, Caneisha Howell obtained from Ms. Chaowalit a service address 0f 234 E. Gish Rd., Suite 200, San Jose, CA 95 1 12. Exhibit B, Bates 000002. SUPPLEMENTAL DECLARATION OF PAUL ROGERS - 1 10 11 l2 13 l4 15 16 l7 l8 l9 20 21 22 23 24 25 26 27 28 6. In a letter dated June 24, 2020, Ms. Howell states to Ms. Chaowalit, “I recently have subpoenaed financial information to be able to see what your financial status is...” Exhibit Dzl 3|4. . From June 15, 2020 to June 22, 2020, Ms. Howell served subpoenas upon American Express (Exhibit E), Bank of America (Exhibit F) and Employment Development Department (Exhibit Q), on behalf of the restrained party (Menachem Hahn). Santa Clara County case 20DV000265 was the indicated case number used on the subpoenas. . The aforementioned subpoenas indicate the “last known address” of Ms. Chaowalit to be 234 E. Gish Rd., Suite 200, San Jose, CA 951 12, which is the address Ms. Chaowalit provided to Ms. Howell on June 4, 2020, and the address ofNext Door Solutions to Domestic Violence. Exhibit H. I declare under penalty of peljury under the laws of the State of California that the foregoing is true and correct. Executed at San Jose, California Dated: June 27, 2021 3 21/ Paul Rogers, Anon? for Pitchayapa Cha walit SUPPLEMENTAL DECLARATION OF PAUL ROGERS - 2 Exhibit A DV_1 10 Temporary Restraining order Clerk stamps date hem when brm Is filed. Person in (D must complete items®, Q), and @only. ,FqllperidI 9’ 2020 N o Protected Perso : o ’ fthe Court 6?: ORAQ UQ 0Q ahfio 1A9\\fl (Szlgle‘rioor Court of CA Your lawyer in t‘ffis cage (ifyou have one): County of Santa Clara Name: SeIf-Represented State BarNW 20DVOOOZGS Finn Name: Self-Represented By. . Address](Ifyou have a lauyerfor this case, give your Iawyer's I Ipaswn information. Ifyou do no! have a lawyer and want (o keep your home I _ _ _ _ _ Fill in court name and street addresa' address private, grve a dfferem mailing address Instead. You do nor have Superior Court of California, County of to giveyow- teIe hone fax, or e-mailg) Santa Clara AddreSSJ‘queé“FYQnC e5 Street: 201 N. First St, San Jose. CA 951 13 CltY-MW State: (Q5 Zip: 0\ AA V5 b Mail: 191 N. First 3L. San Jose. CA 95113Telephonesz ) 3bQ - qu Fax: Family Justice Center E-mail Address: ® Name of Restrained Per Ccourf Iii: r‘n czseInumberwhen form is filed.Menaohem fiopnnMe “Mm 35° “m e" Description of restrained person: Sex: M Mo F Height: b“ O Weight: QQ ‘5 Hair Color: BYOB y! Eye Co or: Race: WV“ e, Age: f2 $ Date ofBirth: OQ )0 ' Addressi[knowng 1 o A City: \ \ 0 \ n Relationship to protected person: Br) u, f Y‘ 6 V1 d C3) D Additional Protected Persons In addition to the person named m ®, the following persons are protected by temporary orders as indicated'm items © and ® aamily or household members). D Check here ifthere are additionalprotectedpersons. List them on an attached sheet ofpaper and write, "DV-l 10, Additional Protected Persons " as a title. The court will complete the res! 0fthisform. The temporary orders which are granted and attached remain in full ® court Hearing force and effect while you are in court until your hearing is finished This-order expires al'the end ofthe Itearing stated below: “"“ V" “"" ” ‘ """'“‘ "" " "‘""""""'" 7/1/2020 9:00Hearing Date: Time: This}Is a«Court Order. - ’ mac "Cam... . __ nmzmfifl'éasfk'fammxm?w - Temporary Restraining Order DY11° Page1°f6 :‘ . . . _ “":LL__‘.-9___ _-__1-63.”.- ingmé’fiw'm (CLETS TR0)_ in_ywfl (Domestic Violence Preventi'o‘fi) Jwri- 3‘ If. m ‘x'f" ." '4,“ w; - ' '.-. ~ - -3 ..~. , .,.~..,_- :.- lfase Number: l . . _. ... -g-..l-._.. \‘ ‘ ~' . .‘. - . rflot-hx ' ~ '- --‘.- é'--”-*-'=_’ .-.:.€;::;.. . z -.:. ....-...;-.-.-,.:».:.,-.,-.;- nnn\l 20DV000265_._._ - __..- hvgvfinvv ' I ® U Criminal Protective Order ""' '_" ’A cnmmal protectlve 6rder on form CR-160, Criminal Plotecfive Order-Domestic Violence, is in‘"effect I Cas_e_Number: " ' County. - Ex'piration' Date: bJD No mformatlon has beénprovided to thejudge about a criminal protective order. - , ‘l..':|"-|A_' ' ' :3 :--... _- L 3;. --.___._.__.-_.- ___ _,___- ‘ k To the personine :Pdu'x :1. n \ 'nuuua - -’ -'t The court has granted the temporary orders checked below. [f you do not obey these orders, you can be arrested and charged with a crime. You may be sent to jail for up to one year, pay a fine of up to $1,000, or both. ® PersonalConduct Orders D Notrequested D Denied untilthehearing m Gr‘anted as follows: a. You must not do the following things to the person in © and M persons in® : (if any listed) _ m Harass, attack, strike, threaten, assault (sexually or otherwise), hit, follow, stalk, molest, destroy personal property, disturb the peace, keep under surveillance, impersonate (on the Internet, electronically or otherwise), or block movements Contact, either directly or indirectly, in any way, including but not limited to, by telephone, mail, e-maiI or other electronic means Take any action, directly or through others, to obtain the addresses or locations of the persons in© and©. (chis item is not checked, the court hasjbzmdgood cause not to make this order.) b. Peaceful written contact through a lawyer or process server or another person for service ofEQmLDM-JZQ (Response toRequestfor Domestic Violence Restraining Order) or other legal papers related to a court case is allowed and does not violate this order. c. U Exceptions: Brief and peacefiJl contact with the person in ®, and peaceful contact with children in @, as required for court-ordered visitation of children, is allowed unless a crixgiigrgal 953838;“? Aorder says otherwise. Stay-Away Order D Not requested D Denied until the hearing wGranted as follows: a. Y must stay at least (speczfiz): £3O O yards away fiorn (check all that apply): dThe person in® School of person in CD Home ofperson in® D The persons in® ?The job or workplace of person in® D The child(ren)’s school or child care MVehicle of person in® D Other (speczfii). b. D Exceptions: Briefand peaceful contact with the person in®, and peaceful contact with children in ©, as required for court-ordered visitation of children, is allowed unless a criminal protective order says otherwise. Move-Out Order MNot requested D Denied until the hearing D Granted as follows: You must take only personal clothing and belongings needed until the hearing and move out immediately from (address): This is a Court Order. “WW? 1-2016 Temporary Restraining Order DV-"O: P899 2 016 (CLETS-TRO) -> (Domestic Violence Prevention) Esfzmfibb"DV000255 No Guns or Other Firearms oi' Ammunition a. You cannot own, possess, have, buy or try to buy, receive or try to receive, or in any other way get guns, other firearms, or ammunition. b. You must: - Sell to, or store with, a licensed gun dealer, or t'urn in to a law enforcemenf agency, any guns or other firearms within your immediate possession or control. Do so within 24 hours ofbeing served with this order. . Within 48 hours of receiving this order, file with the court a receipt that proves guns have been tumed in, stored, or sold. (You may pse Pgm DV-flflgz, ProofofFireanns Turned In, Sold or Stored, for the receipt.) Bring a court filed copy to the hearing. C D The court has received information that you own or possess a firearm. . Record Unlawful Communicationsfl Not requested D Denied until the hearingfl Granted as follows: The person in® can record communications made by you that violate the judge’s orders. ® Care of Animals M Not requested _ Denied until the hearing B Granted as follows: The person in Cl) is given the sole possession, care, and control of the animals listed below. The person in® must stay at least _ yards away fiom and not take, Isell, transfer, encumber, conceal, molest, attack, strike, threaten, harm, or otherwise dispose ofthe following anirnals: Child Custody and Visitation m Not requested D Denied until the hearing D Granted as follows: Child custody and visitation are ordéred bn the attached form DV- I40, Child Custoaji and Visitation Order or (spew)? otherform): . The barent with temporary custody of the child must not remove the child fi'om California unless the court allows it afier a noticed hearing (Pam. Code, § 3063). Child Support Not ordered now but may be ordered aficr a noticed hearing. Property Control M Not requested D Denied until the hearing DGranted as foIlows: Until the hearing, only the person in CD can use, control, and possess the following pr0perty: 6® ® Debt Payment d Not requested D Denied until the hearing D Granted as follows: The person in (2) must make these payments until this order ends: Pay to: For: Amount: S Due date: Pay to: For: Amount: $ Due date: PrOPerty ReStraim MNot requested D Denied until the hearing D Granted as follows: If the people in %and ®are married to each other or are registered donmctic partners,D the person in® D the person in must not transfer, borrow against, sell, hide, or get rid ofor destroy any property, including animals, except in the usual course of business or for necessities of life. In additiOn, each person must notify the other of any new or big expenses and explain them to the court. (Theperson in® cannot contact the persgn in© {l'th'e courl has_made a "no. contact’’Order.) © a Pea¢_efi11 written contact through a lawyer or a process server or other person for service of legal papers related to a codft case is alon'ved érjd doés not 'violate this order. - L H. . i I This is a Court Order. RWML?“ ” V - " ' ' Temporary Restraining Order Dv-110.Pagesofs - _. ' . , ' . '(CLETs-TRO) a I ' (Domestic Violence Preventlon) 1'?) ‘5 _ .... . - i '3 ES:EUEWODVOODZBi @QSpousal Support .u ,N" - ._ o't ordered now but may be onjdered after a noticed hearing. ' ‘ ' I , E. D V. Rights-to Mobile Devicé and Wireless Phone Account 1 3- Pr perty control of mobilé device‘ anfl wireless phone account , I I :3 ‘ “'= - " “ Not re‘quested D Denied u'ntiI the hearing D Granted as follows: ' ' " ' TUntil the Hearing“,‘onlythe person' in CD can use, control, and possess the following property: ' "‘5‘ Mobilé‘d'evic'e (d'e'scribe) ‘ "' “ " and account (phone n'umber). Mobile device (describe) and account (phone number): Mobile device (describe) and account @hone number): D Check here {fyou needmore space. Allach a sheet ofpaper and write ”DV-II 0 Righls to Mobile Device and Wireless Phone Account” as a title. b. Debt Payment E Not requested D Denied until the hearing D Granted as follows: The person in© must make these payments until this order ends: Pay to (Wireless service provider): Amount: $ Due date: c. Transfer of Wireless Phone Account Not ordered now but may be ordered afier a noticed hearing. Insurance Not requested D The person in ® U the person in ® is ordered NOT to cash, borrow against, cancel, transfer, dispose of, or change the beneficiaries ofany insurance or coverage held for the benefit ofthe parties, or their child(ren), if any, for whom support may be ordered, or both. Lawyer‘s Fees and Costs Not ordered now but may be ordered after a noticed hearing. Payments for Costs and Services Not ordered now but may be ordered afier a noticed hearing. Batterer Intervention Program Not ordercd now but may be ordered afier a noticed hearing. Other Orders D Not requested D Denied until the hearing D Granted as follows: 6 ®®®9 D Check here ifthere are additional orders. List them on an attached sheet ofpaper and write "DV-J1 0, Other Orders” as a title. . No Fee to Serve (Notify) Restrained Person Ifthe sheriffserves this order, he or she wiII do so for fi'ce. Signed: 4/9/2020 10:17 AM Date: Judge (or Judicial Oflicer) Carrie Zepeda This is a Court Order. ROVISIdJUI'y 1.2016 Temporary Restraining Order DV'110. P3934 Of6 (CLETs-TRO) -> (Domestic Violence Prevention) 'tiiS YI'L' ,a‘f v'P(II *5 Jan?” . f ' h Case Number: £20DVD00265 Warnings and Notices to the Restrained Person in 9 lf You Do Not Obey This Order, You Can Be Arrested And Charged With a Crime. - Ifyou do not obey this ordcr, you can go to jail or prison and/or pay a fine. - It is a felony to take or hide a child in violation of this order. . Ifyou travel to another state or to tribal lands or make the protected person do so, with the intention of disobeying this order, you can be charged with a federal crime. You Cannot Have Guns, Firearms, AndIOr Ammunition. You cannot own, have, possess, buy or try to buy, receive or try to receive, or otherwise get guns, other firearms, and/or ammunition while the order is in effect. Ifyou do, you can go -‘- to a law enforcement agency any guns or other firearms that you have or control. The judge ' will ask you for proof that you did so. Ifyou do not obey this order, you can be charged with a crime. Federal law says you cannot have guns or ammunition while the order is in effect. Service of Order by Mail If the judge makes a restraining order at the hearing, which has the same orders as in this form, you will get a copy ofthat order by mail at your last known address, which is written in ®. If this address is incorrect, or to find out if the orders were made permanent, contact the court. Child Custody, Visitation, and Support . Child custody and visitation: Ifyou do not go to the hearing, thejudge can make custody and visitation orders for your children without hearing from you. . Child support: Thejudge can order child support based on the income of both parents. The judge can also have that support taken directly from a parent's paycheck. Child support mn be a lot ofmoney, and usually you have to pay until the child is age 18. File and serve a Financial Statement ‘(Simpiified) (form FL-155) or an Income and Expense Declaration (form FL-lSO) ifyou want the judge to have information about your finances. Otherwise, the court may make support orders without hearing fiom you. - Spousal support: File and serve an Income and Expense Declaration (form FL-ISO) so the judge will have information about your finances. Otherwise, the court may make support orders without hearing from you. Instructions for Law Enforcement This order is effective when made. It is enforceable by any law enforcement agency that has received the order, is shown a copy ofthe order, or has verified its existence on the California Law Enforcement Telecommunications System (CLETS). If the law enforcement agency has not received proof ofservice on the restrained person, and the restrained person was not present at the court hearing, the agency shall advise the restrained person 0f the terms of the order and then shall enforce it. Violations of this order are subject to criminal penalties. Arrest Required if Order ls Violated Ifan officer has probable cause to believe that the restrained person had notice ofthe order and has disobeyed the order, the officer must arrest the restrained person. (Pen. Code, §§ 836(c)(1); l37OI(b) )A vxolatlon of thé.o'rder may be a "-'=' l "’3“ '-'»:.‘ ' ‘ violation ofPenal Code section l_66 'or 273.6. u ._.: ‘1 "3:...th 5 t- .2'57'. . '-".!!!! E.2‘::'.":I! .l;:‘. . . - . -.av. . ' ‘ ‘ (?zmr'j :12; Ema. '.':.".x.:a.s‘ 7-9;,- -.:--'-'3,fm.'_') vumm-xqj: I . '-‘ - - I ‘ .:.-u.-;.-" w" IJEE‘EN'E’ZFJ F" “VFW '3?“ :ii'? iii? WU'J‘) ???!""-""-"5§’= Th|s_ Is a Court Order. H “mm“?“vzflw w . 1 - - Temporary Restraining Order __ _ DV-1_1°-$99839” Z‘ _. .(CLETs-TRO) A - - -- - : (Domestic Violence Prevention) ;. , War- .-_-;-; ~ w- .-- - -._--u--. -- __ .-_-_:-=_.- __.. ..---c 1-. . -- '2QDvoeoze suiazfigas; ,;-_16:5 [Cage Number: . - V "-'-llf the Protected Person Contacts the Restrained Person _'/ ......... be-enforced. The protected person cannot be arrested for Inviting or cons'enting to contact with the restrained person. The orders can be chanced only by another court order. (Pen. Code, §137 I O(b) )_mu ' a .’,' .; tics. "5:! 9:- .Conjicting_Orders-Priorities f9r Enforcement -If morethan one restraining order has been issued protecting the protected person from the restrained pe'rson, the orders-must-beenforced-according-to the following priorities (see Pen. Code, § 136.2, and Fam.~Code, §§ 6383(h), 6405(b)): I. EPO: 1f one of the orders is an Emergency Protective Order (form EPO-OO l), and it is more restrictive than other restraining or protective orders, it has precedence in enforcement over all other orders. 2. No-Contact Order: Ifthere is no EPO, a no-contact order that is included in a restraining or protective order has precedence in enforcement over any other restraining or protective order. .‘. 3. Criminal Order: Ifnone of the orders includes a no-contact order, a domestic violence protective order issued in a criminal case takes precedence in enforcement over any conflicting civil court order. Any nonconflicting terms of the civil restraining order remain in effect and enforceable. 4. Family, Juvenile, or Civil Order: Ifmore than one family, juvenile, or other civil restraining or protective order has been issued, the one that was issued last must be enforced. Child Custody and Visitation o The custody and visitation orders are on form DV-140, items© and® They are sometimes aIsq written on additional pages or referenced in DV- 140 or other orders that are not part of the mtraining order. - Forms DV-lOO and DV-l 05 are not orders. Do not en force them. Certificate of Compliance With VA‘WA This temporary protective order meets all “full faith and credit” requirements ofthe Violence Against Women Act, 18 U.S.C. § 2265 (1 994) (VAWA), upon notice of the restrained person. This court has jurisdiction over the parties and the subject matter; the restrained person has been or will be afforded notice and a timely opportunity to be heard as-provided by the laws of this jurisdiction. This order is valid and entitled to enforcement in each jurisdiction throughout the 50 states ofthe United States, the District of Columbia, all tribal lands, and all U.S. territories, commonwealths, and possessions and shall be enforced as if it were an order of that jurisdiction. (Clerk willflll out this part.) -Clerk's Certificate- Clerk 's Certificate I certify that this Temporary Restraining Order is a true and correct copy of the [seal] original on file in the court. Date: Clerk, by , Deputy This is a Court Order. R""°““" "2°” Temporary Restraining Order DV-“O: P39e5°f6 (CLETS'-TRO) ' ' (Domestic Violence Prevention) -q aIn? I‘J .0“- l n-I ‘. J - \- I' 5. a '5 . 6 Exhibit B Santa Clara County - Clerk-Reoorder Office State of California File Number: LDA228 LEGAL DOC ASSIST REG No. of Pages: 5 ' Total Fees: $182.00 County of Santa Clara File Date: 08/03/2020 Office of the Cou nty Clerk-Recorder Expires: 04/30/2021 Business Division County Government Center EEGRINA ALCOMENDRAS, Clerk-Recorder 70 West Hedding Street, E. Wlng, 1" Floor y' aymund A Reyes' Depmy Clerk'Reco'der San Jose. CA 95110 (408) 299-5688 32:3: above I'or County Clerk use only CORPORATION OR PARTNERSHIP APPLICATION FOR REGISTRATION AS A LEGAL DOCUMENT ASSISTANT COUNTY 0F SANTA CLARA N (CA Business and Professions CodJ6400 eLseq.) “been developedithe C0unty of Santa Clara G-lerk-Recoxder s _OffiCe developedithISfonn based Q‘n the -1ev151ons made to the apphcable séct’ions of-the Busilie'S's and Profession: Code‘ effective JanuaxLl, 2016 Please TYPE or PRINT legibly and firmly m BLACK ink. Neither the County Clerk nor his deputies me permitted by law Lo give legal advice and/or assistance. This filing will become a public record and there are ‘, no refunds. INSTRUCTIONS: Completely fill in all business and personal infomation requested in Part A. Check each applicable box in Parts B-F and provide infonnation as requested for each box that is checked. Attach legible copies of all documents requested for each box that is checked (attach certified copies and originals as specified). The completed application must be signed under penalty of perjury by a senior executive officer or a general partner. STATE OF CALIFORNIA COUNTY OF SANTA CLARA Primary Registration W m] l ,6‘gecondary Registration - Name of Primary County: ( Registration Number: Expiration Date: g If a renewal, a new # must be assigned if there is a Two‘ycars from date of filing or bond expiration. I lapse of three years or more in the period of Legislration A. Business and Personal Information Num:_qff‘-nwnnun nu l'mm- inip 44/113 0N 11MB Leann, menus Domwgm- Asmamce 1,1,0.- 15‘”“%o»c 2H3 “S‘anJose iCck MSW? 41 j Malone M One to four ($25,000 bond) D Five to nine ($50,000 bond) D Ten or more ($100,000 bond) x Rev. 01/01l2016 f List the name, address, telephone number and age ofEl; officer or general partner:WWW flowed, ”£731“po -:T358imramw “?S’onc2M §an sea S'éq ?%‘ibfi (2) Name r Dale of Binh Telephone Number (2) Address City Stale Zip Code (3) Name Dan: of Birth Telephone Numbcr (3) Address Cily Stale Zip Code (4) Namc Dale ol‘ Binh Telephone Number (4) Address City Smc Zip Code (5) Nam: Dale of Birth Telcpllonc Number (5) Address City Stale Zip Codc (6) Name Dmc of Birth Telephone Number (6) Address City State Zip Code B. Education and Experience (Note: This information must be provided for at ieast one corporate officer or general partner) Name of cor rate officer or gener l artner for whom education and experience information is provided: WIfiner 6/ 1.M Paralegal program/ABA School The above-named officer or partner has earned a certificate of completion from a paralegal program that is accredited by the American Bar Association (attach copy of certificate of completion). 2.- D Paralegal Program/Non-ABA School The above-named officer or partner has eamed a certificate of completion from a paralegal program that is institutionally accredited but that is not approved by the American Bar Association (attach copy of celtificate ofcompletion) AND the above-named officer or panner has Successfijily completed a minimum of 24 semester units (or the equivalent) in legal specialization courses (attach copy of transcript). Number of semester units (or the equivalent) 3. D College or University D The above-named officer or partner has a bachelor’s degree in AND (Lisl I'lcld and altucll copy ofdiplomu) Rev. 01/01/2016 4.0 D the abovc~named officer or partner has completed at least one year of law-related experience working under the supervision of a licensed attorney (must present original statement on the attorney’s letterhead signed by the attorney describing the scope and dates of your experience). 0R D The above-named officer or partner completed at least one year of experience providing seIf-help service as defined by Business and Professions Code §6400(d) before January 1, 1999 (attach original statement signed by the officer or partner describing the scope and dates of this experience). High School or General Equivalency Diploma D The above-named officer or partner has a high school diploma (attach copy of diploma). OR U The above-named officer or pafiner has a general equivalency diploma (attach copy of diploma) AND D The above-named officer or partner has completed at least two years of law-related experience working under the supervision of a licensed attorney (must present original statement on the attorney’s letterhead signed by the attorney describing the scope and dates of this experience). OR - D The above-named officer completed at least two years of experience providing self-help service as Defined by Business and Professions Code §6400(d) before January l, 1999 (attach original statement signed by the officer or partner describing the scope and dates of this experience). C. Disbarment/Suspension (Note: This infonnation must be provided for each corporate officer or general partner). Is any officer or general partner presently disbarred or suSpended from the practice of law pulsuant to Business and Professions Code §6100-6l l7? D Yes. Date of disbarment or suspension: ¢ No Name of corporate officer(s) or general partner(s)_ D. Civil Judgment (Note: This infonnation must be provided for each corporate officer or general partner) Rev. 01/01/2016 I. Has any officer or general partner been held liable in a final judgment or entxy of a stipulated judgment entered in a civil action that alleged fraud, use of an untrue or misleading representation, or use ofan unfair, unlawful or deceptive business practice? D Yes (attach certified copy of each judgment). % No Name of corpomte officer(s) or general pa11ner(s) for whom judgment information is provided: ._4 2. Has any officer or general partner had a civil judgment entered against him or her in an action arising out of negligent, reckless or willful failure to properly perform the obligation of a legal document assistant or an unlawful detainer assistant? D Yes (attach certified copy of each judgment). fl No Name of corporate officcfls) or general partner(s) for whom judgment information is provided: E. Criminal ConViction (Note: This information must be provided for each corporate officer or general partner. Conviction means a plea or verdict of guilty or a conviction following a plea of nolo contendere. Any conviction dismissed under Penal Code §1203.4 must be included). I. Has any officer or general partner been convicted of‘ a felony? D Yes (attach‘certified copies of each conviction and disposition) Name of corporate officer(s) or general partner(s) for whom conviction information is provided: __-r 2. Has any officer or general partner been convicted of a misdemeanor unlawful practice of law or the contempt of the authority of a court under Business and Professions Code §6126 or §6 | 27, or found liable under Section §6126.5? D Yes (attach certified copies of each conviction and disposition) X No Name of corporate officer(s) or general partner(s) for whom conviction information is provided' 3. Has any officer or general partner been convicted of a misdemeanor violation of the provisions on legal document assistants and unlawful detainer assistants under Business and Professions Code §6400- 6416‘? U Yes (attach cenified copies of each conviction and disposition) M No Name ot‘corporatc officer(s) or general panner(s) for whom conviction infonmation is provided: - -- - - F. Revocation 0f Registration (NOTE: This information must be provided for each corporate officer or general partner) Has any officer or general partner had a registration as a legal document assistant or an unlawful dctainer assistant revoked by a county clerk pursuant to Business and Professions Code §64 13? Rev. 01/01/2016 D Yes (attach certified copy of each revocation) V No Name of corporate officefls) or general partner(s) for whom revocation information is provided: RENEWAL 0F REGISTRATION To be eligible to renew registration, registrant shall complete 15 hours of continuing legal education courses during the two-year period preceding renewal. D I have completed the legal education courses required by Business and Professions Code Section 6402.2 l clarecfi‘nder penahy of perjuly under the laws of the State of California that all information on this N32, _J 06042416?“ a; pp ca i and on all Acoaanying documents is true and correct. ISig . W 7W/2090 I MEZ’SMTOSP, (b\- 'Sisnarurc / / Title V I Dale Place of Execution *Corporate applicant: Application must be signed by: The chairman of the board or the president; or by any vice president AND the secretary, any assistant secretary, the chief financial officer or any assistant treasurer. *Partnership applicant: Application must be signed by at least one general partner. *Other entity applicant: Application must be signed by at least one officer, partner, or managing member. . r r ’* 9 n 2M1 v . r 2* u , . am! ; H ‘ .10 Rev. OllOl/ZUIG This is t'o certify that-fh‘i’s is a true copy of the document . fl ' ' .- fiyggfifh's °ffi°e JUN 2 1 2&2!XW COUNTY CLERK-RECORDER SANTA CLARA COUNTY, CALIFORNIA Exhibit C iMessage Wed, Jun 3, 8200 PM Pitchayapa Chaowalit This is caneisha and I'm a legal document assistant. | would like to arrange service of Mr Menachem Hahns response to you for the TRO from the family court. Are you available Friday? Thu, Jun 4, 11:15 AM Only to serve you personally with documents in response to the restraining order Additionally you are being sued in civil court those documents need to be personally served as well I can do the restraining order by mail 000001 notlce by mall I can do the restraining order by mail The civil law suit | can send you something to sign and send back authorizing mail service otherwise it’s not legal Are you still at the sunnyvale address? The Sunnyvale address is on the restraining order documents that’s where I got it yes | can send to you at that one on Gish 000002 Exhibit D 6/24/2020 Re: Menachem Hahn 200V000265 20CV366941 Dear Pnchayapa, l am not an attorney however I am approaching you as a mediator In an attempt to possibly create some son of workable settlement between you and Mr, Hahn to avoid additional expenses attributed to him. As you can read from ms temporary res1raimng order response Mr Hahn has suffered great injury as well as upset over being wrongly arrested, losing his weapons during the shelter in place covid-1 9 quarantine, now having nerve damage in his hand, losing income and mounting medical expenses as well as my legal expenses. Mr. Hahn is asking the coun to order a 3 year restraining order against you as well as an order to cover all of his related expenses and emotional distress. As of now the district attorney has rejected prosecuting Mr. Hahn 1or any alleged abuse against you. The Milpitas Police Department has changed his arrest to a detention for failure to find evidence against him that he committed domestic violence against you. This does not change that Mr Hahn had to bail out of jail and the costs that he experienced. Mr. Hahn is pushing the police department to investigate you for domestic violence and theft of his property which you used to assault him with and was not recovered by police when they investigated. A family court andlor criminal restraining order against you will make it very diflicuIt if not impossible to obtain cit‘cenship. l am not an aflomey in this area however I do have experience in helping people obtain citizenship and (here is an Investigation into moral character as part of the process of applying for citizenship. There would more than likely be an investigation into the restraining orders against you and they would Interview Mr. Hahn regarding his claims that you committed domestic violence against him. However in an attempt to settle this case and allow both parties to close this chapter of their lives and move on I would like to know if you are open to a mutual “no contact order' and paying Mr. Hahn back regarding monies he states you owe him and which I am more than available to create a document that outlines it if you have interest. He is agreeable to substanljal monthly payments if this is easier {or you. I recently have subpoenaed financial Information to be able to see what your financial status is and how much you could contribute monthly so that the court can make an order if a settlement is not reached prior to the July 1st hearing. Mr. Hahn does not feel that he should continue to lose income by attending a court hearing 0' multiple court hearings {f the parties can agree on a somement because f0! him he IS 90"‘9 ‘0 attribute lost income to part of his damages and will be seeldng that you repay him ‘0' them- If you have any questions please feel free to reach out to me if you would like the documents outlining all oi the expenses and damages that Mr. Hahn is going to be requeStiDQ fmm “1° court I would be more than happy provide that for you. Exhibit E 3UBP-002ammmmnmmwhmmm ”Mug", I Menachem M. Hahn 765 Montague Expressway Apt 478 Milpifls, Ca. 95035 TELEPHOOIE HO; 4934714033 FAX N0-MID: immat'ma-WW AWPORM): In prop“ SUPERIOR COURTOFCAIJFORMA, COUWOFMm “HAW: 201 N. First Steelmm 201 N. FirstStmetmmmm San Jose.Cam ‘ WW2 FanilthstiOeCemer PLAINTIFF, PEWONER:mM DEFENDANT] RESPONDENT: ileuadnm M. l'hhn CML SUBPOENA {DUCES TECUM) for Personal Appearance and mm Production of Documents, Electronically Stored Information. and Things atl 200v000265 Trial or Hearinland DECLARATION THE PEOPLE 0F THE STATE OF CALIFORNIA, TO (name, addm and telephone numberofdeponent, iflmown):mam Custodiaflome mm. 818 w:Sevanfl1Wmfi m ca-nm‘l? 1. YOU ARE ORDEREDTOAPPEARASAWITNESS in tbs amen attire date,time, and place shown inthe box below UNLESS your appearance is exclsed as indlwted in box 3b below oryou make an agreement with the person named in item4below. a. Date: 071010020 Tune: 900m m Dept: 66 D Div: GROW: b. Address: mam 2. IF YOU HAVE BEEN SERVED WITH THIS SUBPOENAASA CUSTODIAN OF CONSUMEROR MPLOYEE RECORDS UNDER CODE OF CIVIL PROCEURE SECTION 1985.3 OR 1935.6ANDA MOTION T0 QUASH 0R AN OBJECTION HAS BEEN SERVED ON YOU. A COURT ORDER ORAGREEMENT 0F THE PARTIES, WITNESSES, ANDCONSUMER OR EMPLOYEE AFFECTED MUST BE OBTAINED EFORE YOU ARE REQUIRED TO PRODUCE CONSUMER 0R EMPLOYEE RECORDS. 3. YOU ARE (item aorb mustbe dvecked): a. E Orderedtoappearinpersonmmmmmmmmmmmmmmumem declamtion oraffidavit. The personal attendanceofflvewstodianoromerquaflfiedufimwand thepmducfion oflhe original records are required by this subpoena. The procedure aulhoriZed by Evidence Code sections 1560(b), 1561, and 1562 wili not be deemed suficient compliance vw’th this subpoena. b. m Notrequiredtoappearinperson ifyou produw (inherecords dasaibed infiredeciaration on pagetwo ormeaflached dedarafion or affidavit and (fi) a completed declaration of custodian of records in compliance with Evidence Code sections 1560. 1561. 1562, and 1271. (1) Place a copy of the records in an envelope (or other mapper)- Endose the original declaration of the wstodian wim me records. Seal u» envelope. (2) Attach a copy of this subpoena to the envelope or write on the envelope [he cam name and number: your name; and the date. time, and place from item 1 in the box above. (3) Place th's first envempe in an outer emeiope. m! it. and rnafl itm the clerk ofthe court at the address in item 1. (4) Mai! a copy of your decimation to the attorney or party listed at the top of this form. 4. IFYOU HAVE ANY QUESTIONS ABOUT THETHE OR DATE YOU ARE TOAPPEAR, 0R IF YOU WANTTO BE CERTAIN :HATPIOUR PRESENCE IS REQUIRED. CONTACT THE FOIJ.OWING PERSON BEFORE THE DATE ON WHICH YOU ARE O A EAR: a. Name ofsubpoenaing partyoratbmey: Mmachem MJ-iahn b.Te!ephone number: 408.771.3033 5- WitnessFeeszYouareenfifledtommfexandn-meageauuanyhaveledbomwayaaprovidedbylawjfywlequestmem atthetimeofservice.Ywmayrequstmanbefomyourscheduiedappearameflunmepasonmmedhm¢ ‘ "T "FEW ‘T-‘IYBEPU ' ‘ FDRTHE SUM OFFNEHUNDREDDQLARSAND Date issued: J. N30mmmm x SUBP-002 PLAINHFFIPEHHONER: Pitchayapa Chaowalit mum DEFENDANTIRESPONDENT: Menachem M. Hahn 200V000265 The production of the dowments, electmnimfly stored information. or otherthings sought by the subpoena on page one is supported by (check one): - E the attached affidavit or m the following decimation: DecLARAnou IN SUPPORT 0F CML SUBPOENA (Duels TECUM) FOR PERSONALAPPEARANCE AND PRooucnON 0F DOCUMENTS, ELECTRONICALLY STORED INFORMATION. AND THINGS AT TRIAL 0R HEARING (Code cw. Proc., §§ 1985,1987.5) 1. l, the undersigned, dedate I am the D plaintiff D defendant E petitioner m respondentE attorney for (specify): E other (specify): in the above-entifled action. z The wimas hasmien or comm! of the documents. electroniwlly stored information. or other things fisted below. and shalI produce them at the time and place spedfied in the Civil Subpoena for Personal Appearance and Produw'on of Records at Trial or Haring on page one of this form (specify the exact documents or other things to be produce; if electrmfmlly gored information is demanded, the form or fonns in which each type of information is to be producedmay be specified): Amerimn Exptm may have records of the Peh'tioner Pitchayapa Chaowalit. January 2019 to current monthly statements. D Continued on AttachmentZ 3. Good muse exists for the producfion ofme dowmem. electroniwlly stored information. or other things descn'bed in paragraph 2 for the following reasons: Petitioner Pitchayapa Chaowalit may have a Ameriwn Exprws credit card flat will assist the ooun to determine her financial ability to pay the Respondent back for medical and add'm'onal costs. E Continued on Attachment 3. 4. The comments. electoninlly stored information, or other things desofibed in paragraph 2 are material to the issues involved in this case for the following rusons: There ale signifiwnt medio-I and additional costs that the Respondent seeks reimbursement for. If the Petitioner has financial ability it is vital for the ooun to have this information. E Continued onAmGhment 4. ldedareunderpemltyofpefiurymderthelawsofmeStateofCallunfiammeforegohgishuea curred.WM' . A/mmmm (mmwgmpm D Am'fgip Request for Accommodaflons Assistive listeni systems. computer-assisted ml-time capfioni , or sign language interpreter servim are available if you ask at least days before the rooeeding. Contad the clerk s officeflor go to www- .couns.ca.govfionns for Request for Accommodations by Persons IM Disabilmes and Response (form_rw:L,-41 O). (Clv. Code, § 54. .) (Pmoforsewioa on page3) Pitchayapa Chaowalit Date of Birth August 25th, 1989 Last known address 234 E. Gish Rd Suite 200 San Jose. Ca. 951 12 765 Montague Expressway Apt 478 Milpitas.Ca. 95035 5560 Lexington Ave. Apt 248 San Jose, Ca. 95123 Phone number 323-369-7093 SUBP-OZSAWMPARTYWMTORflEmewmmm Menachem M. Hahn 765 Montague Expressway Apt 478 Milpitas, Ca. 95035 MMMMY TELEPHONE ”0-3 408-771-3033 FAX NovW: E-MAI.MSS(W mmhathZanhoonom ATTORNEYma (Nanny In pro per SUPERlOR COURT OF CALIFORNIA. COUNTY OF s“ ch. STREET ADDRESS: 201 N. First StreetWW3 201 N. First Sheetmmmm San Jose, Ca.95113 BRANCHM Familly Justice Cenbr PLAINTIFF! PETTI‘IONER: Pimyapa craowalit cAse NUMBER- DEFENDANTI RESPONDENT:Mm M Hahn 200V000265 "once To CONSUMER 0R EMPLOYEE AND OBJEC'non (Code cw. Prue" §§ 1985.3,19355) NOTICE TO CONSUMER 0R EMPLOYEE T0 (name): Pimapa cnaowaaz 1. PLEASE TAKE NOTICE THAT REQUESTING PARTY (name): Menachem M. Hahn SEEKS YOUR RECORDS FOR EXAMINATION by the parties to this action on (specify date): W I I20 The records am described in the subpoena direded to wltness (specify name and address ofperson entity {mm whom recortls are sought): American Express Custodian of Records CT Corporation System 818 W. Seventh Street. 2nd Floor Los Angeles, CA A copy of themama Is attached. 2. IF YOU OBJECT to the production ofthese teoords, YOU MUST DO ONE OF THE FOLLOWING BEFORE 11-IE DATE SPECIFIED IN ITEM a. OR b. BELOW: a. If you are a party to the above-entifled action. you must file a motion pursuant to Code of Civil Procedure section 1987.1 to quash or modify the subpoena and give nofioe of that motion to the witness and the deposifion officer named in the subpoena at least five days before the date set for pmducfion ofme records. b. If you are not a party to this action. you must serve on me requesting party and on the witness, before the date set for pmduction of the records, a wn‘lten objection that states the specific grounds on which production of such records should be prohibited. You may use the form below to object and state the grounds for your objection. You must complete the Proof of Service on the reverse side indicating whether you personally served or mailed the objection. The objection should not be filed with the court. WARNING: IF YOUR OBJECTION IS NOT RECENED BEFORE THE DATE SPECIFIED IN ITEM 1 , YOUR RECORDS MAY BE PRODUCED AND MAY BE AVAILABLE TO ALL PARTIES. 3. YOU OR YOUR A'I'I'ORNEY MAY CONTACT THE UNDERSIGNED to determine whether an agreement can be reached in wrih'ng to wnoel or limit the scope of me subpoena. if no such agreement is reached. and if you ate not otherwise represented by an attorney in this action, YOU SHOULD CONSULT AN ATTORNEY T0 ADVISE YOU OF YOUR RIGHTS OF PRIVACY. flfi'lmm- >Wmmmm (5mm mun? Elam OBJECTION BY NON-PARTY TO PRODUCTION OF RECORDS . E lobiectto the production of all ofmy records specified in the subpoena. 2. D I objed only to the production of the bilowing specified records: 3. The specific grounds for my objeclion ale as follows: Date: mmmm mm SUBP-025 PLAIN'nFFI PETmONER; Pitchayapa Chaowalit cassuuuam DEFENDANT! Respounemuenachem n Hahn 200V000265 PROOF OF SERVICE OF NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION (Code Civ. Prom. §§ 19853.19855)E Personal Service m Mall 1. Atthetimeofservioe lwasat least 18years ofage and not a partytothis legal action. 2. lsarved a copy ofthe Nofioe m ConsumerorEmponee andObjecfion asfollows (check eilhera orb): a. E Personal service. I personally delivered the Notice to ConwmerorEmployee and Objeclvbn as follows: (1) Name of person sewed: (3) Date sewed: (2) Address whom sewed: (4) Time sewed: b. m Mall. I deposited the Notice to ConsumerorEmployee and Objecb'on in the United States mall, in a seaied envelope with postage fulIy prepaid. The envelope was addressed as follows: (1) Name of person sewed: Pitdmyapa Chaowdit (3) Date of maifing: Jug-Q’I90 (2) Address where sewed: (4) Place of mailing ( state). 234 E. Gish Rd. #200 San Jose. Ca. 95112 San Jose. Ca. (5) I am a resident of or employed in me county where the Nodes a - nsumar orEmployee and Objecfion was mailed. c. Myresidenceorbusinessaddmssisbpedfy): P080X2113$anJose. n.-_ - d. My phone number is (specifir): 408-228-2626 Ideclargundar naltyofpeajuryunderflielawsofmsmteofCalifomia : om. magi: Caneisha HowellMMWNAIEOFWWSM) PROOF 0F semncE 0F 03.150110“ To PRODU‘GfiON 0F RECORDS (Code Civ. Proc., §§ 1935.3,19855)D Personal Service E Mail 1. Atthetime ofservioe I msetleast 18 yeats of age and not a partyto this legal action. 2. I served a copy of the Objection to Production of Records as follows (complete either a or b): a. ON THE REQUESTING PARTY (1 ) E Personal soMco. I pemnafly delivered the Objecfion to Pmducfion o_fRecords as follows: (i) Name of person served: (iii) Date sewed: (ii) Address where sewed: (iv) Time sewed: (2) E Mall. l deposited the Objection to Production ofReoords in the United States mail. In a sealed envelope with postage fully prepaid. 1119 envelope was addrmsed as follows: (i) Name of person served: (Iii) Date of mailing: (II) Address: (iv) Place of mailing (dty and date): (v) | am a resident of or employed in the county where the Objecfion to Production ofRecords was mailed. b. ON THE WITNESS (1) D Personal senioe. 1 personafly delivemd he Objeofion tn Production ofRecords as follows: G) Name of person served: (iii) Date served: (ll) Address where sewed: (Iv) Tums served: (2) E Mall. I deposited the Object'on to Production ofRecords in the United 8mm mail. in a sealed envelope with postage fully prepaid. The envelope was addmed as follows: (i) Name of person served: (iii) Date of mailing: (ii) Address: (iv) Mace of mailing (city and state): (v) I am a resident of or empioyed in the county where the Objecfion to Production ofRecords was mailed. c. My residence or business address is (specify): d. My phone number is (specify): l declare under penalty of perjury under the laws of the State of Califom' that the foregoing is true and correct. Exhibit F SUBP-ODZnmmmmmwammhhhmum mmumv -| Menachem M. Hahn 765 Montague Expressway Apt 478 Milpitas. Ca. 95035W ND.- 4os.771.3033 FAX N0. (Omani):mmW.-Wm Amman (Name): In Pro Per SUPERIORCOUR'I’OFCALIFORNIACOUNTYOFmm STREET”ms: 201 N. Fast Street MAMNGADDRER 201 N. First Street cnvmm cove San Jose. Ca. 95035mm Famfly Jcsfioe Center PLAINTIFF! PETD'JONER:Wcm DEFENDANT] RESPONDENT:m u. Hahn CML SUBPOENA (DUCES TECUM) for Personal Appearance aI'_Id CASEm Production of Documents. Elecu'onioully Stored Information, and Thmgsaj zoovooozss Trial or Hearigland DECLARATION THE PEOPLE OF THE STATE OF CALIFORNIA, T0 (name, address, and telephone number ofdepganeglg, Ifknown): Bankofm CUStodianofRecom acdm. 318W;s¢venfl1$heetzndfl Ln - a 017 1. YOU AREORDEREDTOAPPEARASAWITNESS in th'sacuonatthedate,time, andplaceshowp inflleboxbelow - UNLESS your appearance isexam as indiated in box 3b bdow oryou make an agreement with file person named m - item 4 below. a. Date: 07/01/2020 Tume: 9:00AM m Dept: 66 D Div: E3 Room= b. Address: 8am. as above 2. IF YOU HAVE BEEN SERVED WITH THiS SUBPOENA ASA CUSTODIAN OFCONSUMH OR EMPLOYE RECORDS UNDER CODE OF CML PROCEDURE SECTION 1985.3 OR 1985.6 ANDA MOTION TO QUASH 0R AN OBJECTION HAS BEEN SERVED ON YOU, A COURTORDER ORAGREEMENT OF THE PARTIES, WITNESSES, ANDCONSUHER OR EMPLOYEE AFFECTE MUST BE OBTAINED BEFORE YOU ARE REQUIRED TO PRODUCE CONSUMER 0R EMPLOYEE RECORDS. 3. YOU AREfitemaorbmustbechedred): a. D Orderedtoappearin personandtopmduosmereoordsdesuibed infiedechaflononpagehuoarmeattached decimation or affidavit. The personal attendance of the custodian orother qualified witness and the production of the original records are required by this subpoena. The procedure authorized by Evidence Code sections 1560(b), 1561. and 1562 wi1| not be deemed sufficient compliance with this subpoena. b- m Natrequiredtoappearin person ifyou produceaflhereoordsdesu'ibed inthededaiafionou pagelwoortheahched dadalafion or afidavit and (fi) a completed dedalation of custodian of reouds in compliance with Evidence Code sections 1560. 1561. 1562. and 1271. (1) Phce a copy ofthe rewrds in an envelope (or other wrapper). Enclose the original declaraflon 01‘ me custodlanmm the recorus. Seal the envelope. (2) Attach a copy ofthis subpoena to the envelope or write on the envelope me case name and number; your name; and me date. fime, and place from item 1 in the box above. (3) Place th's first enveiope in an outer envelope, seal it. and mail it to the dark ofthe oourtat the addms in item 1. (4) Mail a copy of your declaration to the attorney orparty listed at the top of this fonn. 4. IF YOU HAVE ANY QUES‘HONS ABOUT THE 11MB 0R DATEYOU ARETO APPEAR, 0R IF YOU WANT TO BE CERTAIN THATYOUR PRESENCE IS REQUIRED, CONTACT THE FOLLOWING PERSON BEFORE 11-IE DATE ONWHICH YOU ARE T0 APPEAR: a. Name of subpoenaing party orattorney: Mm M Hahn b. Telephone number. 403.771.3033 5. WFees:You amenfifledtowitnessfemandnfileageactuallyuaveledboflIways.asptovidedbylaw.ifyourequestmem atthehmeofsewioe. You mayrequestthembeforeyoursd‘reduled appearanoefromtheperson namedinitem4. C F B SU PUNISH AS C B . FOR THE SUI OF FIVE HUNDRED DOLLARSAND _ _ RESULTING FROM YOUR F URETO OBEY. Data bsued: J. Ngommmm alt SUBP-002 PLAINTIFF/PETITIONER: Pitchayapa Chaowalit mse NUMBER; DEFENDANTIRESPONDENT: Menachem M. Hahn 2°DV°°°255 The production of the documents, electronicalty stored information, or other things sought by the subpoena on page one is supported by (check one):E the attached affidavit or m the following deciaration: DECLARATION IN SUPPORT OF CIVIL SUBPOENA (DUCES TECUM) FOR PERSONAL APPEARANCE AND PRODUCTION OF DOCUMENTS. ELECTRONICALLY STORED INFORMATION, AND THINGS AT TRIAL OR HEARING (Code Civ. Proc., §§ 1985,1987.5) 1. I. the undersigned, declarelam the E plaintiff D defendant E petitioner m respondentm attorney for (specify): E other (specify): in the above-entitied action. 2. The witness has possession or control of the documents, electronically stored information, or other things listed below, and shall produce them at the time and place specified in the Civil Subpoena for Personal Appearance and Production of Records at Trial or Hean‘ng on page one of this form (specify the exact documents or other things to be produce; if electronically stored information is demanded, the form or forms in which each type of information is lo be produced may be specified): Bank of America may have records of the Petitioner Pitohayapa Chaowalit. January 2019 to current monthly statements. E Continued on Attachment 2. 3. Good cause exists for the production of the documents. electronically stored information, or other things described in paragraph 2 for the following reasons: Peu'tioner Pitchayapa Chaowalit may have a Bank of America savings, checking and credit card that will assist the court to determine her financial ability to pay the Respondent back for medical and additional costs. E Continued on Attachment 3. 4. The documents, electronically stored information, or other things described in paragraph 2 are material to the issues involved in this case for the following reasons: There are significant medical and additional costs that the Respondent seeks reimbursement for. If the Petitioner has financial abiIity it is vital for the court to have this information. E Continued on Attachment 4. I declare under penal of perjury under the laws of the State of California that the foregoing is hue Date: Menachem M. Hahn ’ //WRW (wm‘EWWW“ E gaaazmmm Requests for Accommodations Assistive listenin systems, computer-assisted reaI-time captionin , or sign language interpreter services are available if you ask at least we days before the proceeding. Contact the clerk s office or go to www.courts.ca.gov/fonns for Request for Accommodations by Persons lMth Disabilities andResponse (form “I 3-41 CI). (Civ. Code, § 54.8.) (Proof of service on page 3) suapmmwW11 2012; CIVIL SUBPOENA (DUCES TECUM) for Personal Appearance and mum Production of Documents, Electronically Stored Information, and Things at Trial or Hearing and DECLARATION Pitchayapa Chaowalit Date of Birth August 25th. 1989 Last known address 234 E. Gish Rd Suite 200 San Jose. Ca. 951 12 765 Montague Expressway Apt 478 Milpitas.Ca. 95035 5560 Lexington Ave. Apt 248 San Jose. Ca. 95123 Phone number 323-369-7093 SUBP-025 ATTORhEYORPARTYMfl-{OUTATTORNEYMM&malum: Menachem M. Hahn 765 Monmgue Expressway Apt 478 Milpitas, Ca. 95035 MMNMLY TELEPHONE N0; 403.771.3033 FAX N0. (Opium: E-MM-ADDRESSW: mthnSZanhoonom ATTORNEY Fon (Name)- .n pm per SUPERIOR COURT OF CALIFORNIA. COUNTY OF sumcmmm: 201 N. Hts! Street WWWmm: 201 N. First Streetmmmm San Jose. Ca. 95113 BRANCHNM Famifly Justice Center PLAINTIFF] PETI'HONER:WWcmm CASE NUMBER DEFENDANT! RESPONDENT! Menodm M. Hahn 20DV000265 N011CE To CONSUMER 0R EMPLOYEE AND OBJECHON (Code Civ. Pmc., §§ 1985319855) N0110E TO CONSUMER 0R EMPLOYEE To (name): Wm Chaowalit 1. PLEASE TAKE NOTICE THAT REOUES'nNG PARTY (name): Menachem M. Hahn SEEKS YOUR RECORDS FOR EXAMINATION by the panics to this action on (speciw date): 1 d | IThe records are described in the subpoena directed to witness (Specify name and address ofperso o entfiy from whom records are sought): Bank of America Custodian of Records CT Corporation System 818 W. Seventh Street. 2nd Floor Los Angeles, CA AoopyoftheWm Isatvached. 2. IF YOU OBJECT to the production ofthese mcords. YOU MUST DO ONE OF THE FOLLOWING BEFORE THE DATE SPECIFIED IN ITEM a. OR b. BELOW: a. If you are a party to the above-entifled adion. you must file a motion pursuant to Code of Civil Procedure section 1987.1 to quash or modify the subpoena and give notice of that motion to the witness and the deposition officer named in the subpoena at least five days before the date set for production of the records. b. If you are not a party to this action, you must serve on the requesting party and on the moss, before the date set for production of the records. a written objecfion that statfi the specific grounds on which production of such records should be prohibited. You may use me form below to object and state the grounds for your objection. You must complete the Proof of Service on the reversa side indiwting whether you personafly sewed or mailed the objection. The objection should not be filed with the coun. WARNING: lF YOUR OBJECTION IS NOT RECEIVED BEFORE THE DATE SPECIFIED IN ITEM 1, YOUR RECORDS MAY BE PRODUCED AND MAY BE AVAILABLE TO ALL PARTIES. 3. YOU 0R YOUR ATI'ORNEY MAY CONTACT THE UNDERSIGNED to determine whether an agreement an be readied in writing tounwlorlimitthesoopeoflhesubpoena.lfnosud1agreementisreached,andifyouamnotofl19mlsa byan attorney in this aclion. YOU SHOULD CONSULTAN ATTORNEY TO ADVISE YOU OF YOUR RIGHTS NACY. Date: Menachem M. Hahn ’ ___ MORPHNTNAME) (shamWm“: m-Am OBJECTION BY NON-PARTY TO PRODUCTION OF RECORDS 1. D lobjecttalheproducfion ofall ofmyreoords specified inthesubpoena. 2. E lobject only to me production ofthe following specified records: 3. The spedfic grounds for my objection are as foflcws: Dam: mmmm (5mm WM PLAINnFF/ PErmONER- Pltchayapa Chaowalit use "mask DEFENDANT/ ResmNDEm:Menachem M_ Hahn ZODV000265 PROOF OF SERVICE OF NOTICE T0 CONSUMER OR EMPLOYEE AND OBJECTION (Code Civ. Pmc.. §§ 1985.3,1985.6)D Personal Service m Mail 1. Atthefimeofservicelwasatleast 18 yearsofage and nota partytothis legal action. 2. Iserveda oopyofthe Noticeto ConsumerorEmployoe andObjecfionasfollows (checkeilhera orb): a. D Personal service. I personalty delivered the Notice to Consumer orEmponee and Objection as follows: (1) Name of person sewed: (3) Date sewed: (2) Address where sewed: (4) Time served: $UBP-025 b. E Mall. I deposited the Notice to ConsumerorEmponee and Objection in the United Stem mail, in a sealed envelope with postage fully prepaid. The envetope was addmsed as foflows: ‘ (1) Name ofpetsonserved:warm (3) Daheofmailing: La} @0 (2) Address where sewed: (4) Place of mailing (city and state : 234 E. Gish Rd. #200 San Jose, Ca. 95112 San Jose. Ca. (5) lamatasidentoforemployedinlheoountywheremeNofios r playmandObjectionwasmalled. c. Myresidenoeorbusiness addressisfioea'fy): POBox211asanJose ' ' d. My phone number is (spedfy): 408-228-2626 ldedare undarpenaltyofpetjury underlhetaws oftheSiateofCalifomia Date: _ Lg r v- Caneisha H mpg onmmMme orpmwno sewer» PROOF 0F SERVICE 0F OBJECTIoN To PRooucnoN 0F RECORDS (Code Civ. Proc, §§ 1985.3,1985.6) E] Personal Service E Mail 1. Atthe fimeofservioe l was at least 18 years ofage and not a party to thls legal actlon. 2. I sewed a copy of the Objection to Production of Records as follows (complete either a or b): a. 0N THE REQUESHNG PARTY (1) E Personal service. I personally delivered the Objecfion to Production ofRecords as follows: (i) Name of person served: (m) Date sewed: (ii) Address where served: (iv) Turne served: (2) E Mall. I deposfled me Objecflon to Hoductfon of Records in the United States mail, In a sealed envelope with postage fully prepaid. The envelope was addressed as follows: (i) Name of person sewed: (ifi) Date of mailing: (It) Addrm: ‘ (iv) Place of malflng (altyand state): (v) l am a resident of or employed in me county where the Objech'on to Huduwon ofReoords was mailed. b. ON THE WITNESS (1) a Personal service. l personafly delivered the Objection lo Produofion ofRecords as follows: (i) Name of person served: (iii) Date served: (ll) Addms where sewed: (Iv) Tune sewed: (2) E Mall. I deposited me Objection to Pmduca'on of Records in the United States mail, in a sealed envelope with posbge fully prepaid. The envelopems addrassed as follows: (i) Name of person sewed: (iii) Date of mailing: (ii) Address: (iv) Piece of mailing (city and state).- (v) lam a residentoforemployed in the oountywheve the Ob'pction to Producfion ofRecoIds was mailed. c. My residence or business addm is (specify): d. My phone number is (specify): I declare under penalty of perjury under the laws ofme sate of California that the fategolng is true and correct. Date: Exhibit G SUBP-002mm“”hummus“ mmumv Menadiem M. Hahn 765 MonmUe Expressway Apt 478 Milpima. Ca. 95035 mm; 105771.333 mmmwWWWWmAmmlm InPfoW SUPERIORCOURTOFWWWMm STEAM:201 N_Fimsuaetmmzmurmsm GTYNODMESanJm.Ca.95035WWEFMWW PLANHFF/PETmONER:mm WIRESPONDENT:Mum CML SUBPOENA (DUCES TECUM) for Penonal Appeu'anco and “SEm Production of Documents, Electronicalty Stored Information, and Things zoovooozes Trial or Hearing and DECLARA'HON THE PEOPLE 0F THE STATE 0F CAUFORMA, To (name, addns. and Mophone number ofdeponent, iflmown):EWW MM museum mclpflnllm Samoan,“ 95.14 Mics: 1. YOUAREORDERED TOAPPHR ASAWITNESS In lhisaeoonatflse dmtimemndplaceshmlnfluboxbdw UNLESS your appearance is excised as inflated in box 3b hdow oryou make an agreement vim me person named In item4below. a. Date: 0710112020 Time: 9.00m m Dept: as D Div-I [BROWN b- Address= m a5; We) 7 2. IF YOU HAVE BEENmm THE SUBPOENAAS AWM CONSUIERDR“PLOWm UNDER CODE OF CML PROCEDURE SECTION 1985.3 OR 1935.5 ANDA MOTION T0 QUASH OR AN OBJECTION HAS BEEN SERVED ON YOU. A COURT ORDER ORAGREEMENT OF THE PARTIES, WITNESES, ANDCONSUMER OR EMPLOYEE AFFECTED DUST BE OBTNNED EFORE YOU ARE REQUIRED TO PRODUCE CONSUMER 0R EMPLOYEE RECORDS. 3. YOUAREfilemaorbnuMb’edwedred): a. D mmmmrmmaMbmmememmmpaQeMmmm dedarafionoraffidavitThepersomlathendaneeafhecustodianoromerqmlifiedwimmmeproducfionofm odginalmcotflsarerequiredbymiswbpoena.Theprooedure authorized by EvidenoeCodesecfims1560(b).1561.and 1562 wil not be deemed sufficiem mplianoewifl-n this subpoena. b. m NottequhedtoappearinpetsonifyoupmducefiWnereootdsdmmdinmededmfionmpagetwoortheattacheddeohmfionmafidmfiammnwnmmmmdamdmmmmmmmmmm 1560. 1561, 1562,and 127i. (1) Place a copy ofthe records in an envelope (oromerwrapper). Endosethe original dedarahonofmemmdlanwmmemcoruammeenvebpo.(2)Auadnacopyofflfisstnbpoemtomeenvelopeor wfiteonheemdopememmandnumbenywrname;arldmedate.u‘me.arwplacefromitem1inheboxabove. (3)Placeth‘sfistemdopeinmomerenvelope.sealit,andmilntomederkofmeoourtalmeaddmsinitemt (4)Maflacopyofyourdedamflmtoflieanomeyormnylistedatmetopofmisfom 4. IFYouHAVEANYOUES‘HONSABOUTTHETMEORDATEYOUARETOAPPEARORIFYOUWANTTOBECERI’AIN wgggg PRESENCE Is REQUIRED. CONTACTme FOLLOWING pensou BEFORE THE DATE ON WHICH YOU ARE a. Namedwhpoem’mgpaflyoraibmey: MammHam b.Telephonemmben 4033713033 5. WMflguamenfifledmwmmeeameflyh-ambomwaysaspmvldedbylawmyouroqmswwnmmde.YwmymmflmbWemWWmmehm¢ FORTl-IESUIOFHVEHUNDREDMAND Dds issued: J.$0mmmm SUBP-Ooz PLNN'HFFIPEflflONER: Pitchayapa Chaowalit casewm DEFENDANTIRESPONDENT: Menachem M. Hahn 2°DV°°°265 The produdion of the documents. eledronimfly stored inforrnafion, or other things sought by the subpoena on page one is supported by {check one):B the attached afidavit or m me following dedaration: DECLARATION IN SUPPORI' OF CIVIL SUBPOENA (DUCES TECUM) FOR PERSONAL APPEARANCE AND PRODUCTION 0F DOCUMENTS, ELECTRONICALLY STORED INFORMATION, AND THINGS AT TRIAL OR HEARING (Code Civ. Proc“ §§ 1985,1987.5) 1. I, the undersigned, declare I amthe D piainfiff B defendant E] petitioner m respondent E] aflomeyfor (specify): E other (specr‘fy): in the above-enfiued action. 2. The witness has possession or oonb'oi ofthe documents. electronimfly stored infotmation. or other things listed below. and shalt produce them at the time and place specified in the Civil Subpoena for Personal Appeararm and Production of Records at Trial or Hearing on page pne of this form (specify the exact documents or other things to be produce; if electronically stored information is demanded. the form or forms in which each type of information is (o be produced may be specified): mmwmmumm D Continued on Attachment2 3. Good muse exists for the production of the documents. eledmnimfly stored information, or other things dam'bed in paragraph 2 for the following reasons: mmMmmm-mmm D Confinued on Attadwment 3. 4. The documents. elmnimlly stored information, or oiher things described in paragraph 2 are material to the issues involved in this mse for the following reasons: There are signifiwnt medial and add'm‘onal cosm that the Respondent seeks reimbursement for. If the Petitioner has financial ability it is vital for the coun to have this information. E Confinued on Athchment 4. IdeclareunderpenaflyofpeqmyuMermeIawsofmsmeofCaifmniammforegoingishue correct.mm Date: ‘ Menachem M. Hahn ’Mmmm omomma: mum | I A‘I'I'OMEYFORmpm Requests forAccommodaflom Assisfive listeni systems computet-assismd mI-time captioning, or sign language interpreter sewices are available if you ask at least ve days before the proceeding. Corned the clerk's otfioe or go to www.couns.ca.gav/rbnns for Request for Accommodations by Persons With Disabilities and Response (form MC-410). (Cw. Code. § 54.8.) (Proof of seeviee on page 3) minus", 1. 2m] CML SUBPOENA (DUCES TECUM) for Personal Appearance and p... 2.. 3 Production of Documenb, Electronically Stored Information, and Things at Trial or Hearing and DECLARATION Pitchayapa Chaowalit Date of Birth August 25th, 1989 Last known address 234 E. Gish Rd Suite 200 San Jose. Ca. 95112 765 Montague Expressway Apt 478 Milpitas.Ca. 95035 5560 Lexington Ave. Apt 248 San Jose. Ca. 95123 Phone number 323-369-7093 SUBP-025 ATrORNEY 0R PARTY WITHOUTATrORNEv (Name. Stale Bummer, and amass): Menachem M. Hahn 765 Montague Expressway Apt 478 Milpitas. Ca. 95035 m COUR' USEONLY TELEPHONE no; 403.771.3033 FAX N0. (Opaonw; E-MAIL ADDRESS (quad).- mmhahn92@yahoo.oom ATTORNEY FOR (Namey In pro per SUPERIOR COURT OF CALIFORNIA. COUNTY OF Sam Clara STREETADDRESS” 201 N. Flrsi Street MNUNGADDRESS= 201 N. First Sheet CITY ANDZ’P CODE San Jose. Ca. 951 13 BRANCH NAME Familly Justice Canter PLA'NT'FFI PEnTlONERI Pflchayapa Chaowalit CASE NUMBER; DEFENDANT] RESPONDENT: Menachem M. Hahn 20DV000265 NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION (Code Civ. Proc., §§ 1985.3.1985.6) NOTICE TO CONSUMER OR EMPLOYEE TO (name): pitanyapa Chaowam 1. PLEASE TAKE NOTICE THAT REQUESflNG PARTY (name): Menachem M. Hahn SEEKS YOUR RECORDS FOR EXAMINATION by the parties to this action on (specify date): "“2”" The records are described in the subpoena direded to witness (specify name and address ofperson or entity fmm whom records are sought): 5'"me Deve'opmem Department 722 Capitol Mall mc 53 Sacramento. CA. 95314 A copy of the Gwpuena is attached. 2. IF YOU OBJECT t0 the production of these records. YOU MUST DO ONE OF THE FOLLOWING BEFORE THE DATE SPECIFIED IN ITEM a- OR b. BELOW: a. If you are a party to the above-entitled action. you must file a motion pursuant to Code of Civil Procedure section 1987.1 to quash or modify the suprena and give notice of that motion to the witness and the deposition officer named in the subpoena at least five days before the date set for production of the records. b. If you are not a party to this action, you must serve on the mquesfing party and on the witness, before the date set for production of the records, a written objection that states the specific grounds on which production of such records should be prohibited. You may use the form below to object and state the grounds for your objection. You must complete the Proof of Service on the reverse side indicating whether you personally served or mailed the objection. The objection should not be filed with the court. WARNING: IF YOUR OBJECTION IS NOT RECEIVED BEFORE THE DATE SPECIFIED IN ITEM 1, YOUR RECORDS MAY BE PRODUCED AND MAY BE AVAILABLE TO ALL PARTIES. 3. YOU OR YOUR ATTORNEY MAY CONTACT THE UNDERSIGNED to determine whether an agreement un be reached in writing to mneel or limit the scope of the subpoena. If no sum agreement is reached. and ifyou ate mi chemise re 611 orzo Date: Menachem M. Hahn , (WPE 0R PRINT NAME) OBJEC'ITON BY NON-PARTY TO PRODUCTION 0F RECORDS 1. D I object to me production of all of my records specified in the subpoena. 2. E l object only to the production of the following specified records: 3. The specific grounds for my objection are as follows: Date: (TYPEmPW NAME) (SIGNATLRE) {Pmnf nfm onml M 1 d 2 FumWad fatWV U33 Code ol Civl Prnawuru,WOwns 0‘WM NOflCE TO CONSUMER OR EMPLOYEE AND OBJECTION gs 1935.3. mass. SUBP-(lfi [Ram .hmary 1.2M 2020.010-m20510 www.maaaov SUBP-025 PLAINTIFF/ PETITIONER: Pitchayapa Chaowalit use NUMBER: DEFENDANT; RESPONDENT: Menachem M. Hahn 2°DV°°°265 PROOF 0F SERVICE OF NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION (Code Civ. Proc., §§ 1985.3,1985.6)E Personal Service m Mail 1. At the time of service I was at 1east 18 years of age and not a patty to this legal action. 2. l served a copy of the Notice to Consumer or Employee and Objection as follows (check either a or b): a. E Personal service. l personally del'wered the Notice to Consumer or Employee and Objection as folIows: (1) Name of person sewed: (3) Date served: (2) Address where served: (4) Time sewed: b. E Mail. I deposited the Notice to Consumer or Employee and Objection in the United States mail, in a sealed envelope with postage fully prepaid. The envelope was addressed as follows: (1) Name of person served: Pitchayapa Chaowam (3) Date of mailing: LP la;‘90 (2) Address where sewed: (4) Place of mailing (city and state): 234 E. Gish Rd. #200 San Jose. Ca. 951 12 San Jose. Ca. (5) l am a resident of or employed in the county where the Notice to Consumer or Employee and Objection was mailed. c. My residence or business address is (specify): Po Box 2113 San Jose, Ca. 95109 d. My phone number is (speciM: 408-22&2626 l declare under nalty of perjury under the laws of the State of California that t = Date: Lfl ‘ Caneisha Howell (TYPE OR PRINT NAME 0F PERSON WHO SERVED) PROOF OF SERVICE OF OBJECTION TO PRODUCTION OF RECORDS (Code Civ. Proc.. §§ 1985.3,1 985.6)E Personal Service E Mail 1. At the time of service I was at least 18 years of age and not a party to this legal action. 2. I served a copy of the Objection to Production of Records as follows (complete either a or b): a. ON THE REQUESTING PARTY (1) E Personal service. I personally delivered the Objection to Production ofRecords as follows: (i) Name of person served: (iii) Date sewed: (ii) Address where served: (iv) Time served: (2) [j Mail. I deposited the Objection to Production of Records in the United States mail, in a sealed envelope with postage fully prepaid. The envelope was addressed as follows: (i) Name of person served: (iii) Date of mailing: (ii) Address: (iv) Place of mailing (city and state): (v) I am a resident of or employed in the county where the Objection to Production of Records was mailed. b. ON THE WITNESS (1) E Personal service. l personally delivered the Objection to Production of Records as follows: (i) Name of person served: (iii) Date sewed: (ii) Address where served: (iv) Trme sewed: (2) E Mail. ldeposited the Objection to Production of Records in the United States mail. in a sealed envelope with postage fully prepaid. The envelope was addressed as follows: (i) Name of person sewed: (iii) Date of mailing: (ii) Address: (iv) Place of mailing (city and stale): (v) l am a resident of or employed in the county where the Objection to Production of Records was mailed. c. My residence or business address is (specify): d. My phone number is (specify): l declare under penalty of perjury under the laws of the State of California that the foregoing is tme and correct. Date: > OR PRINT NAME 0F PERSON WHO SERVED) (SIGNATURE OF PERSON WHO SERVED) suav-ozsmsv..vanuary 1.20081 NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION Pas-zon For your protection and privacy. please press the Clear This Form button after vou have printed the form. l Save this fnnn I I Clam- fhis fnrrn ''W'fifl;73%;: Exhibit H 6 9 C' fl nextdoorsolutions.org/services/ gunman. I fi :3. “3‘ ; *I“ In “- I " i “Ra R H'r'flflcflfl' Learn More » NEED IMMEDIATE HELP? GET‘ Call: 24/7 HOTLINE: (408) 279-2962 n I Chat: A” safechatsv.org 234 E. Gish Road, Suite 200 JOin O San Jose, CA 95112 Main Office Phone: (408) 501-7550 f _ Information: info@nextdoor.org Emma“ Contact Us First Nam: Find Domestic Violence Help, Shelter Near You Address, zip, city... a Last Nam .‘ merfiti by; 4- '3“gm '2: 2i: -: r:r5W
