Motion AmendedCal. Super. - 6th Dist.March 24, 2021Electronically Filed by Superior Court of CA, County of Santa Clara, on 7/13/2021 10:10 AM Reviewed By: A. Rodriguez Case #21CV381110 Envelope: 6833693 21CV381110 Santa Clara - Civil \OOGQQ‘JIAUJN 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Michael G. Ackerman, Esq. (SBN 64997) LAW OFFICES OF MICHAEL G. ACKERMAN 2391 The Alameda, Suite 100 Santa Clara, CA 95050 Telephone: (408) 261-5800 Facsimile: (408) 261-5900 Email: mga@mgackermanlaw.com Attorneys for Defendant, PANIDA CHINSUPAKUL SUPERIOR COURT FOR THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA ANNE TING, an individual; JACK TING, ) Case No.2 21CV381 1 10 an individual; and NICOLE TING-YAP, an ) individual; ) DEFENDANT PANIDA ) CHINSUPAKUL’S NOTICE OF MOTION Plaintiffs, g TO STRIKE PLAIN'I'IFFS’ COMPLAINT vs. ) Date: 9/28/2021 ) Time: 9:00 am. ) Dept: 7 PANIDA CHINSUPAKUL, an individual; g Judge: Hon. Christopher G. Rudy ) ) ) ) and DOES 1 through 10; Defendants. TO THE COURT AND TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that on 9/28/2021, in Department 7 ofthe above entitled Court, Defendant, PANIDA CHINSUPAKUL, will move the Court for an Order to stn'ke portions of Plaintiffs’ Complaint pursuant to C.C. P. §§ 435 and 436 on the ground that the material is irrelevant, improper, and not in conformity with the law of this state. The motion will be based on the Notice of Motion, the Memorandum ofPoints and Authorities, the Declaration of Michael G. Ackerman, and the pleadings and other records filed with the Court in this action, and upon such other fithher evidence and argument as may be presented at or before the hearing of the Motion. _ 1 _ DEFENDANT PANIDA CHINSUPAKUL’S NOTICE OF MOTION T0 STRIKE PLAINTIFFS’ COMPLAINT CASE NO.: 21CV381110 £11th \OOONQ 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DATED: July AZ , 2021 LAW OFFICES OF Attorneys or Defendant, PANIDA ICHAEéLf/GfACKERMAN, ESQ. CHINSU AKUL _ 2 - DEFENDANT PANIDA CHINSUPAKUL’S NOTICE 0F MOTION T0 STRIKE PLAINTIFFS’ COMPLAINT CASE No.: 21CV381110 ©00NOLII$UJN~ NNNNNNNNn-ah-In-HHv-Iu-t-tt-Ir-A gflathN-‘OWOOVQMAWN-‘O PROOF OF SERVICE The undersigned declares: I am a citizen of the United States and a resident of Santa Clara County, State of California. I am over the age of eighteen (1 8) years and not a party to the within above-entitled action. My business address is 2391 The Alameda, Suite 100, Santa Clara, CA 95050. On July 13, 2021, I served a copy of the following document(s) described as: - DEFENDANT PANIDA CHINSUPAKUL’S NOTICE OF MOTION TO STRIKE PLAINTIFFS’ COMPLAINT on the interested parties in this action by placing true copies thereof to the person(s) listed below: Ms. Skye Langs, Esq. COBLENTZ PATCH DUFFY & BASS LLP One Montgomery St., Suite 3000 San Francisco, CA 94104 Telephone: (415) 391-4800 Facsimile: (415) 989-1663 email: ef-sdl c db.com slangs@coblentzlaw.com (Attorneyfor Plaintiffs, Anne Ting, Jack Ting, and Nicole Ting- Yap) (>0 (By U.S. Mail) I am readily familiar with my employer’s business practice for collection and processing of correspondence for mailing with the United States Postal Service. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date 0r postage meter is more than one day after dated of deposit for mailing in affidavit. I caused to be deposited such envelope(s) with postage thereon fully paid to be placed in the United States Mail at Santa Clara, California. (2Q (By E-Mail) I caused a true copy of the foregoing document to be served on Skye Langs, of Coblentz Patch Duffy & Bass LLP, at slangs@coblentzlaw.com. The e-mails were complete and no reports of error were received on July 13, 2021. ( ) (By Facsimile) I caused to be served by facsimile a true and correct copy pursuant to C.C.P. §1013(e), calling for agreement and written confirmation of that agreement on court order, to the - 3 _ DEFENDANT PANIDA CHINSUPAKUL’S NOTICE 0F MOTION To STRIKE PLAINTIFFS’ COMPLAINT CASE No.: 21CV381110 \OOOQQU‘&WN 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 number(s) listed above or on an attached sheet. Said transmission was reported complete and without error. ( ) (By Federal Express) I caused to be served a true and correct copy enclosed in a sealed package, for California Overnight collection and for overnight delivery. I had said envelope marked for collection and overnight delivery to the addressed and to the office of the addressee(s) as above indicated. In the ordinary course of business and including said overnight envelopes, will be deposited with Federal Express at Santa Clara, California. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that this declaration was executed in the City of Santa Clara, State of California on July 13, 2021. - 4 _ DEFENDANT PANIDA CHINSUPAKUL’S NOTICE 0F MOTION T0 STRIKE PLAINTIFFS’ COMPLAINT CASE N0.: 21CV381110
