NoticeCal. Super. - 6th Dist.March 24, 2021COBLENTZ PATCH DUFFY & BASS LLP ONE MONTGOMERY STREET, SUITE 3000, SAN FRANCISCO, CALIFORNIA 94lO4-5SOO FAX 4|5.989.|663 4|5.39|.4800 - \OWQQUIhMNH NNNNNNNNNHHHHHHHHHH WQQUIhMNHGQWQQUIhMNHG 21CV381 1 1O Santa Clara - Civil SCOTT C. HALL (State Bar N0. 232492) SKYE LANGS (State Bar N0. 287908) EMLYN MANDEL (State Bar N0. 3 10403) COBLENTZ PATCH DUFFY & BASS LLP One Montgomery Street, Suite 3000 San Francisco, California 94104-5500 Telephone: 415.391.4800 Facsimile: 415.989.1663 Email: ef-sch@cpdb.com ef-sdl@cpdb.com ef-erm@coblentzlaw.com Attorneys for Plaintiffs ANNE TING, JACK TING, and NICOLE TING-YAP SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA ANNE TING, an individual; JACK TING, an individual; and NICOLE TING-YAP, an individual, Plaintiffs, V. PANIDA CHINSUPAKUL, an individual; and DOES 1 through 10, Defendants. TO THE COURT, ALL PARTIES AND COUNSEL OF RECORD: PLEASE TAKE NOTICE that the following exhibits filed 0n May 20, 2021 in support 0f Plaintiffs’ EX Parte Notice and Application for Temporary Restraining Order and Order t0 Show Cause Why Preliminary Injunction Should Not Issue were accidentally reformatted during the filing process, causing portions 0f the exhibits t0 be omitted from the copy filed with the Court: 1. Exhibit A t0 the Declaration 0fAnne Ting; 1 Y. Chav Electronically Filed by Superior Court of CA, County of Santa Clara, on 7/9/2021 10:47 AM Reviewed By: Y. Chavez Case #21 CV381 1 1 0 Envelope: 6812539 Case N0. 21CV381 1 10 NOTICE OF ERRATA REGARDING DECLARATIONS FILED IN SUPPORT OF PLAINTIFFS’ EX PARTE APPLICATION FOR TEMPORARY RESTRAINING ORDER AND ORDER TO SHOW CAUSE WHY PRELIMINARY INJUNCTION SHOULD NOT ISSUE Date: July 15, 2021 Time: 1:30 pm. Place: Department 12 Action Filed: March 24, 2021 Trial Date: None Set Case No. 21CV381110 NOTICE OF ERRATA RE DECLARATIONS IN SUPPORT OF EX PARTE APPLICATION COBLENTZ PATCH DUFFY & BASS LLP ONE MONTGOMERY STREET, SUITE 3000, SAN FRANCISCO, CALIFORNIA 94lO4-5500 FAX 4|5.989.|663 4|5.39|.4800 - ©W\IO\UI&UJN# NNNNNNNNNr-tr-tr-tr-tr-tr-tr-tr-tr-tr-t WQGNUIhMNHGQWQO‘NUIhMNHG 2. Exhibit B to the Declaration of Jack Ting; 3. Exhibits C, D, E, and F to the Declaration ofNicole Ting-Yap; and 4. Exhibit J t0 the Declaration 0fWong Siew Ing. Plaintiffs apologize for the error, and for the belated discovery 0f the mistake, and attach t0 this Notice copies 0f the four declarations referenced above With properly formatted exhibits. The Declaration ofAnne Ting is attached as Exhibit 1, the Declaration 0f Jack Ting is attached as Exhibit 2, the Declaration 0f Nicole Ting-Yap is attached as Exhibit 3, and the Declaration of Wong Siew Ing is attached as Exhibit 4. Courtesy copies 0f the reformatted declarations will be submitted to Department 12 in advance of the July 15 hearing on the Order t0 Show Cause. DATED: July 9, 2021 COBLENTZ PATCH DUFFY & BASS LLP Attorneys for Plaintiffs ANNE TING, JACK TING, and NICOLE TING-YAP 2 Case No. 21CV381110 NOTICE OF ERRATA RE DECLARATIONS IN SUPPORT OF EX PARTE APPLICATION Exhibit 1 COBLENTZ PATCH DUFFY & BASS LLP ONE MONTGOMERY STREET, SUITE 3000, SAN FRANCISCO, CALIFORNIA 94lO4-5500 FAX 4|5.989.|663 4|5.39|.4800 - \OWQQUIhMNH NNNNNNNNNHHHHHHHHHH WQQUIhMNHGQWQQUIhMNHG SCOTT C. HALL (State Bar N0. 232492) SKYE LANGS (State Bar N0. 287908) EMLYN MANDEL (State Bar N0. 3 10403) COBLENTZ PATCH DUFFY & BASS LLP One Montgomery Street, Suite 3000 San Francisco, California 94104-5500 Telephone: 415.391.4800 Facsimile: 4 1 5.989. 1 663s Email: ef-sch@cpdb.com ef-sdl@cpdb.com ef-erm@cpdb.com Attorneys for Plaintiffs ANNE TING, JACK TING, and NICOLE TING-YAP SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA ANNE TING, an individual; JACK TING, Case N0. 21CV381 1 10 an individual; and NICOLE TING-YAP, an individual, DECLARATION OF ANNE TING IN Plaintiffs, SUPPORT 0F TEMPORARY RESTRAINING ORDER APPLICATION V. PANIDA CHINSUPAKUL, an individual; Trial Date; None Set and DOES 1 through 10, Defendant. DECLARATION OF ANNE TING I, ANNE TING, declare as follows: 1. I am a party in the above-entitled action. Ihave personal knowledge 0f the facts set forth herein, except as t0 those stated 0n information and belief and, as t0 those, I am informed and believe them t0 be true. If called as a witness, I could and would competently testify t0 the matters stated herein. 2. Ireside in Sydney, Australia. Julian Ting is my son, Plaintiff Jack Ting is my husband, and Plaintiff Nicole Ting-Yap is my daughter. 10621.002 4843-4776-9826.3 1 Case No. 21CV381 1 10 DECLARATION OF ANNE TING IN SUPPORT OF TEMPORARY RESTRAINING ORDER APPLICATION COBLENTZ PATCH DUFFY & BASS LLP ONE MONTGOMERY STREET, SUITE 3000, SAN FRANCISCO, CALIFORNIA 94lO4-5500 FAX 4|5.989.|663 4|5.39|.4800 \OWQQUIhMNH NNNNNNNNNHHHHHHHHHH WQQUIhMNHGQWQQUIhMNHG 3. On 0r about February 16, 2021, Julian informed me that Defendant Panida Chinsupakul had provided him with copies 0f some 0f documents, information, photographs, and screenshots that he believed she had illegally obtained. These documents included personal, financial, business, and tax information that belonged t0 me, my husband, and my daughter. 4. Some 0f the photographs Defendant took, which she later gave Julian copies 0f, were pictures 0fmy private information. Attached as Exhibit A is one 0f these documents. The original photograph shows all my personal information, which I have redacted in order t0 protect my privacy. 5. The information in Exhibit A belongs t0 me and concerns a matter I had before the Australian Tax Office (ATO). It includes attorney-client privileged and work product information, as well as detailed information about loans, real estate transactions, and my finances. Julian had this information 0n his iPad because I designated Julian as my agent in connection with the matter and authorized my attorneys t0 communicate with him t0 facilitate the provision 0f legal advice. He was helping me gather and organize information related t0 the dispute. 6. Defendant also took pictures 0f another document containing my private, attorney- client privileged information, which had Julian’s notes regarding communications with my attorney regarding the dispute. As with Exhibit A, Julian had this information because he was acting as my agent, and was authorized t0 communicate with my lawyers, in regards t0 the ATO dispute. 7. The information described in paragraphs 4, 5, and 6 belonged t0 me, and I had an immediate right t0 possess it. At my request, Julian would have immediately returned this information t0 me, 0r he would have permanently deleted it. Julian did not have my consent t0 share this information without my permission. 8. I trusted and believed that Julian would keep my confidential financial information private. I never expected that Defendant would be able t0 View, copy, 0r photograph the information I provided t0 Julian, 0r that she would be able t0 gain access t0 my private financial and tax information, 0r my attorney-client privileged information, without my knowledge 0r consent. I did not give Defendant permission t0 see my private information, and she did so 10621.002 4843-4776-9826.3 2 Case No. 21CV381 1 10 DECLARATION OF ANNE TING IN SUPPORT OF TEMPORARY RESTRAINING ORDER APPLICATION COBLENTZ PATCH DUFFY & BASS LLP ONE MONTGOMERY STREET, SUITE 3000, SAN FRANCISCO, CALIFORNIA 94lO4-5500 FAX 4|5.989.|663 4|5.39|.4800 \OWQQUIhMNH NNNNNNNNNHHHHHHHHHH WQQUIhMNHGQWQQUIhMNHG without my knowledge. Ibelieve that Defendant gained access t0 my information by spying 0n Julian t0 discovery his passwords, and then using them t0 access my private information without his or my knowledge. 9. Sometime around December 3, 2020, Julian informed me that the server in his home had been compromised. He later informed me that it had been shut down for an approximately 46-hour period without his consent, while he in Australia. At the time, I had n0 further information about why the server was shut down, 0r what might have happened during that time. 10. Since seeing the pictures Defendant took 0f Julian’s iPad, I have come t0 believe that Defendant most likely caused the server t0 be shut down, and that she probably had the contents 0f the server copied while it was shut down. 11. This worries me, because Julian maintains a lot 0fmy private and confidential information on his server, which I gave t0 him in connection with the help he provides me 0n my tax matters, real estate transactions, and stock market investments. The information of mine that is 0n his server belongs t0 me, and I have an immediate right t0 possess it. At my request, Julian would have immediately returned this information t0 me, 0r he would have permanently deleted it. Julian did not have my consent t0 share this information without my permission. I trusted Julian with this information because I knew the server was kept in a secure location, and that my information was protected by passwords known only t0 Julian. I never expected that Defendant would be able t0 View, copy, 0r access any 0fmy private information 0n the server. I did not give Defendant permission t0 View 0r access any 0fmy private information 0n the server. 12. I believe that Defendant took my personal information because she wants t0 use it against Julian in their divorce proceeding, and t0 frame, extort, harm, punish, or Vilify Julian because 0f the end 0f their marriage; t0 embarrass, harass, and annoy me; and t0 extort 0r otherwise obtain a financial advantage from me. I am afraid that if she is not stopped, she will publicly disclose all my private information. 13. Defendant's actions have harmed me by invading my privacy. In addition, I have and will incur losses as a result 0f Defendant’s improper access t0, and use 0f, my private 10621.002 4843-4776-9826.3 3 Case No. 21CV381 1 10 DECLARATION OF ANNE TING IN SUPPORT OF TEMPORARY RESTRAINING ORDER APPLICATION COBLENTZ PATCH DUFFY & BASS LLP ONE MONTGOMERY STREET, SUITE 3000, SAN FRANCISCO, CALIFORNIA 94lO4-5500 FAX 4|5.989.|663 4|5.39|.4800 \OWQONUIhUJ 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 personal, financial, tax, and business information. Ihave expended time and money trying t0 get Defendant to return 0r destroy my private information, t0 secure the privacy 0fmy information, and t0 ensure that the disclosure 0f the information does not harm me in any future tax dispute before the ATO. I also expect t0 spend money investigating the damage she may have caused t0 the server. 14. The intrusion into my privacy has caused me emotional distress, such as embarrassment, anxiety, worry, nervousness, anger, shock, and humiliation. 1am very afraid that Defendant will disclose my private personal and financial information, and cause irreparable harm t0 me by causing the ATO t0 re-open my tax dispute, which is not active at the moment. Since learning of the breach 0fmy privacy and theft ofmy personal information, Ihave experienced insomnia, headaches, nausea, upset stomach, appetite changes, crying, depression, anxiety, and heart palpitations. I declare under penalty 0f perjury under the laws 0f the State 0f California that the foregoing is true and correct. Executed 0n this 29th day of March, 2021, at Sydney, Australia. DocuSigned by: deu, 1T _ 1§3955§21£|QQBJ 10621.002 4843-4776-9826.3 4 Case No. 21CV381 1 10 DECLARATION OF ANNE TING IN SUPPORT OF TEMPORARY RESTRAINING ORDER APPLICATION 8 : 3 9 A M S u n M a r 8 i i c l o u d . c o m ‘ 3 9 8 % @ I 1 0 0 % V A T O R e s p o n s e O r g a n i z e r J u l y 1 2 , 2 0 1 9 D e l i v e r a b l e N o . S c h e d u l e A ( 1 ) S c h e d u l e A ( 2 ) ( a ) S c h e d u l e A ( 2 ) ( b ) S c h e d u l e A ( 3 ) S c h e d u l e B 1 S c h e d u l e B 2 ( a ) S c h e d u l e B 2 ( b ) S c h e d u l e B 3 ( a ) S c h e d u l e B 3 ( b ) S c h e d u l e B 3 ( a ) S c h e d u l e B 3 ( d ) S c h e d u l e B 4 ( a ) S c h e d u l e B 4 ( b ) S c h e d u l e B 5 ( a ) S c h e d u l e B 5 ( b ) S c h e d u l e B 5 ( c ) S c h e d u l e B 6 ( a ) s a n k s m e m e m s s u p p o m n g i Calcula t i o n s h e e t o r w o r k i n g p a p e r s s h o w i n g t h e D o c u m e n t D e s c r i p t i o n S t a t u s A n s w e r s t o _ r e l a t i n g t o $ _ l o a n t o - P r o p e r t y D e t a i l s f o r R e f i n a n c i n g L o a n f o r _ L o a n f r o m W o r k i n g P a p e r s f o r W o r k i n g P a p e r s f o r W o r k i n g P a p e r s f o r W o r k i n g P a p e r s f o r W o r k i n g P a p e r s f o r W o r k i n g P a p e r s f o r L o a n a g r e e m e n t w i t h - f o r $ - G e n e r a l L e d g e r s f o r - B a n k S t a t e m e n t e v i d e n c i n g B a n k S t a t e m e n t e v i d e n c i n g G e n e r a l I e d g e r s f o r t h e l o a n B a n k s t a t e m e n t s e v i d e n c i n g - o n t h e _ | o a n P u r c h a s e c o n t r a c t f o r - S a l e c o n t r a c t f o r - D o w n l o a d C o l o r S c h e m e 1 N e e d t o a c q u i r e P a p e r d o c u m e n t P D F o n f i l e R e d a c t i o n s c o m p l e Exhibit 2 COBLENTZ PATCH DUFFY & BASS LLP ONE MONTGOMERY STREET, SUITE 3000, SAN FRANCISCO, CALIFORNIA 94lO4-5500 FAX 4|5.989.|663 4|5.39|.4800 - \OWQQUIhMNH NNNNNNNNNHHHHHHHHHH WQQUIhMNHGQWQQUIhMNHG SCOTT C. HALL (State Bar N0. 232492) SKYE LANGS (State Bar N0. 287908) EMLYN MANDEL (State Bar N0. 3 10403) COBLENTZ PATCH DUFFY & BASS LLP One Montgomery Street, Suite 3000 San Francisco, California 94104-5500 Telephone: 415.391.4800 Facsimile: 4 1 5.989. 1 663 Email: ef-sch@cpdb.com ef-sdl@cpdb.com ef-erm@cpdb.com Attorneys for Plaintiffs ANNE TING, JACK TING, and NICOLE TING-YAP SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA ANNE TING, an individual; JACK TING, Case N0. 21CV381 1 10 an individual; and NICOLE TING-YAP, an individual, DECLARATION OF JACK TING IN Plaintiffs, SUPPORT 0F TEMPORARY RESTRAINING ORDER APPLICATION V. PANIDA CHINSUPAKUL, an individual; Trial Date; None Set and DOES 1 through 10, Defendant. DECLARATION OF JACK TING I, JACK TING, declare as follows: 1. I am a party in the above-entitled action. Ihave personal knowledge 0f the facts set forth herein, except as t0 those stated 0n information and belief and, as t0 those, I am informed and believe them t0 be true. If called as a witness, I could and would competently testify t0 the matters stated herein. 2. Ireside in Sydney, Australia. Julian Ting is my son, PlaintiffAnne Ting is my wife, and PlaintiffNicole Ting-Yap is my daughter. 10621.002 4826481746904 1 Case No. 21CV381 1 10 DECLARATION OF JACK TING IN SUPPORT OF TEMPORARY RESTRAINING ORDER APPLICATION COBLENTZ PATCH DUFFY & BASS LLP ONE MONTGOMERY STREET, SUITE 3000, SAN FRANCISCO, CALIFORNIA 94lO4-5500 FAX 4|5.989.|663 4|5.39|.48OO \OWQQUIhMNH NNNNNNNNNHHHHHHHHHH WQQUIhMNHGQWQQUIhMNHG 3. On 0r about February 16, 2021, Julian informed me that Defendant Panida Chinsupakul had provided him with copies 0f some documents, information, photographs, and screenshots that he believed she had illegally obtained. These documents included personal, financial, business, and tax information that belonged t0 me, my wife, and my daughter. 4. Some 0f the photographs Defendant took, which she later gave Julian copies 0f, were pictures 0fmy private information. Attached as Exhibit B is one 0f these documents. The original photograph shows my confidential information, which I have redacted in order t0 protect my privacy. Exhibit B is a picture of an email from my accountant regarding tax and retirement planning, and concerning accounts and business entities belonging t0 me, which I forwarded t0 Julian t0 seek his advice 0n the proposed transactions. 5. Julian had this information 0n his iPad because he performs consulting work for me, and he also provides me with financial and business advice 0n occasion. Itrusted and believed that Julian would keep my information private, and that he would not share it with others, including Defendant, without my permission. This information belonged t0 me, and I had an immediate right t0 possess it. At my request, Julian would have immediately returned this information t0 me, 0r he would have permanently deleted it. Julian did not have my consent t0 share this information without my permission. 6. I never expected that that Defendant would be able t0 View, copy, photograph, use, 0r otherwise gain access t0 my private business, financial, and tax information without my consent. I did not give Defendant permission t0 see this information, which I believe is private and sensitive, because it reveals details about my personal finances and planned transactions involving commercial entities in which I have an ownership interest. Ibelieve that Defendant gained access t0 my information by spying 0n Julian t0 discovery his passwords, and then using them t0 access my private information without his knowledge. 7. Sometime around December 3, 2020, Julian had also informed me that the server in his home may have been compromised. He later informed me that it had been shut down for an approximately 46-hour period without his consent, while he was in Australia. At the time, I had 10621.002 4826481746904 2 Case No. 21CV381 1 10 DECLARATION OF JACK TING IN SUPPORT OF TEMPORARY RESTRAINING ORDER APPLICATION COBLENTZ PATCH DUFFY & BASS LLP ONE MONTGOMERY STREET, SUITE 3000, SAN FRANCISCO, CALIFORNIA 94lO4-5500 FAX 4|5.989.|663 4|5.39|.48OO \OWQQUIhMNH NNNNNNNNNHHHHHHHHHH WQQUIhMNHGQWQQUIhMNHG n0 further information about why the server was shut down, 0r what might have happened during that time. 8. Since seeing the picture Defendant took 0f Julian’s iPad, I have come t0 believe that Defendant most likely caused the server t0 be shut down, and that she probably had its entire contents copied while it was shut down. 9. This worries me, because Julian maintains a lot 0fmy private and confidential information, which I gave to him in connection with consulting work he performs for me, and he stores it 0n the server. Julian advises me 0n a broad range 0f business topics including strategies t0 commercialize the intellectual property I have developed in cosmetic surgery techniques over the course ofmy 50+ year career, the IT infrastructure and telecommunications systems I use t0 run my business, marketing strategies, finances, tax and investments, and sensitive matters involving my employees. The information 0f mine that is 0n his server belongs t0 me, and I have an immediate right t0 possess it. At my request, Julian would have immediately returned this information t0 me, 0r he would have permanently deleted it. Julian did not have my consent t0 share this information without my permission. I trusted Julian with this information because I knew the server was kept in a secure location. Additionally, I know that my information on the server is protected by a password which is known by only Julian, my daughter, and my daughter’s assistant. Inever expected that Defendant would be able t0 View, copy, 0r access any 0fmy private information 0n the server. 10. I believe that Defendant took my personal information because she wants t0 use it against Julian in their divorce proceeding, and t0 frame, extort, harm, punish, or Vilify Julian because 0f the end 0f their marriage; 0r because she wants t0 use it t0 harm my business interest, t0 embarrass, harass, and annoy me; and t0 extort 0r otherwise obtain a financial advantage from me. I am afraid that if she is not stopped, she will publicly disclose all my private information. 11. Defendant's actions have harmed me by invading my privacy. In addition, I have and will incur losses as a result 0f Defendant’s improper access t0, and use 0f, my private personal, financial, tax, and business information. Ihave expended time and money trying t0 get Defendant t0 return 0r destroy my private information, and t0 secure the privacy 0fmy 10621.002 4826481746904 3 Case No. 21CV381 1 10 DECLARATION OF JACK TING IN SUPPORT OF TEMPORARY RESTRAINING ORDER APPLICATION COBLENTZ PATCH DUFFY & BASS LLP ONE MONTGOMERY STREET, SUITE 3000, SAN FRANCISCO, CALIFORNIA 94lO4-5500 FAX 4|5.989.|663 4|5.39|.4800 \OWQONUIhUJ 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 information. Ialso expect t0 spend money investigating the damage she may have caused t0 the server. Additionally, Defendant now has access t0 the details 0f proposed commercial transactions I was considering undertaking, and I am concerned she may try t0 use that information t0 compromise my ability to enter those transactions on favorable terms. It is also possible that the disclosure ofmy private information could adversely affect the price at which I could potentially sell my business t0 an interested buyer. 12. The intrusion into my privacy has caused me emotional distress, such as embarrassment, anxiety, worry, nervousness, anger, shock, and humiliation. 1am very afraid that Defendant will disclose my private personal and financial information, and cause irreparable harm t0 my business interest. Since learning 0f the breach 0fmy privacy and theft ofmy personal information, Ihave experienced insomnia, headaches, nausea, upset stomach, appetite changes, depression, anxiety, and heart palpitations. I declare under penalty 0f perjury under the laws 0f the State 0f California that the foregoing is true and correct. Executed 0n this 29th day of March, 2021, at Sydney, Australia. DocuSigned by: jack 1T ,QCE§EEB%€%-- 10621.002 4826-7817-4690.4 4 Case No. 21CV381 1 10 DECLARATION OF JACK TING IN SUPPORT OF TEMPORARY RESTRAINING ORDER APPLICATION 9 : 1 7 P M M o n M 8 1 6 < M a i l b o x e s A l l h b o n e s E d i t v « y a m , r u n a n n n ¢ s t Q ; [ B C S m t s ] B a y A r e a W l d e ' s h e l t e r . . . I m p o r t a n t p o i n t f r o m t h e s a m e a r t i c l e : P e o p l e i n t h e s i x c o u n t i e s w i l l s t i l l b . . . a d d i n g 2 : 0 7 P M F w d : . . é H i J u l i a n , C a n y o u p l e a s e r e a d t h i s d o c u m e n t f r o m K e n a n d l e t r n e k n o w w . . . o K r i s M i h a i c 1 : 1 8 P M [ B C S _ p a r e n t s ] S o c i a l d i s t a n c i n g s i m u l . . . h t t p s : / / w w w . w a s h i n g t o n p o s t . c o m / g r a p h i c s / 2 O Z O / w o r l d / c o r o n a - s i m u | a t o r . . . 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D e a r P i n e w o o d C o m m u n i t y , T o d a y m a r k s t h e f i r s t d a y o f o u r c a m p u s c l o s . . . o M a n s i B h a t i a T r i p a t h i 9 : 0 4 A M [ B C S p a r e n t s ] G e t a r t v : r e s o u r c e s ® W J u s t N o w - 2 9 , 5 5 0 U n r e a d A c c o u n t E r r o r s D e t a i l s . ” 9 8 9 % . - H i r a m J a c k T i n g 2 : 0 7 P M T o : J u l i a n T i n g > F w d : f u n d c r e a t i o n H i J u l i a n , C a n y o u p l e a s e r e a d t h i s d o c u m e n t f r o m K e n a n d l e t m e k n o w w h a t y o u t h i n k . T h a n k s . C h e e r s , D r . J a c k T i n g . M B B S . F A C C S . B e g ' n f o r w a r d e d m e s s a g e : F r o m : K e n n e t h L e o < > D a t e : 1 6 M a r c h 2 0 2 0 a t 1 1 : 0 5 : 1 3 A E D T T o : J a c k < > , " J a c k T i n g ( ) " < > S u b j e c t : f u n d c r e a t i o n G o o d m o r n i n g D r T i n g a n d A n n e , I t w a s g r e a t t o c a t c h u p w i t h y o u b o t h y e s i e r d a y , i t w a s g r e a t . W e s h o u l d d o t h e M a l a y s i a n p l a c e t h e n e x t t i m e . F o r C A ' a “ . l v @ 1 5 8 9 : 1 7 P M M o n M a r 1 6 ( M a i l b o x e s A l l i n b o m s E d i t v R y a n , n n n a n n n 5 . 5 m m Q ) [ B C S _ p a n n t s ] B a y A r e a W i d e “ s h e l t e r . . . I m p o r t a n t p o i n t f r o m t h e s a m e a r t i c l e : “ . . . P e o p l e i n t h e s i x c o u n t i e s w i l l s t i l l b . . . J o c k T i n g 2 : 0 7 P M F w d : . . é H i J u l i a n , C a n y o u p l e a s e r e a d t h i s d o c u m e n t f r o m K e n a n d l e t m e k n o w w . . . K r i s M i h a l i c 1 : 1 8 P M [ B C S _ p a r e n t s ] S o c i a l d i s t a n c i n g s i m u l . . . h t t p s : / / w w w . w a s h i n g t o n p o s t . c o m / g r a p h i c s / 2 0 2 0 / w o r l d / c o r o n a - s i m u l a t o r . . . V i n c e F e l i o e t t a 1 2 : 2 0 p M I n v o i c e 6 / H o l l i e , ' L a w r e n c e & ' Y i . . . 1 1 : 2 0 A M ® [ B C S _ p a r e n t s ] R e m i n d e r : O n - L i n e I . . . / / R e g a r d i n g t h e o n l i n e l i b r a r y f o r m i d d l e s c h o o I , t h e y d o n ' t n e e d t h e i r i P a d t o u . . . m _ n p l y @ l o s a l t o s c a . g o v 1 0 : 2 6 A M O n l i n e I n s p e c t i o n R e q u e s t S c o t t R i c h e s 1 0 : 1 5 A M P i n e w o o d S c h o o l D a i l y U p d a t e I M o n d . . . D e a r P i n e w o o d C o m m u n i t y , T o d a y m a r k s t h e f i r s t d a y o f o u r c a m p u s c l o s . . . o M a n s i S h a u n T t i p a t h i 9 : 0 4 A M [ B C S p a r e n t s ] G o t a n v : r e s o u r c e s W J u s t N o w - 2 9 , 5 5 0 U n r e a d A c c o u n t E r r o r s D e t a i l s “ . F o r t h e t h e e v e n t o f a s a l e o f y o u r b u s i n e s s . W e w i l l n o w k i l l t w o b i r d s w i ‘ h o n e s t o n e . B a s i c i d e a Y o u w i l l s e | l c a p i t a l g a i n o f m o r e t h a n A n a d d e d b e n e f i t t o t h i s p l a n i s t h a t i n t h e f u t u r e S _ t e _ p _ 1 _ ( l w i l l b e d o i n g t h i § ) _ 1 . T r a n s f e r ( ‘ s e l | ’ ) t o 2 . S e t u p ( I w i l l s e n d y o u t h e d o c u m e n t s f o r y o u t o s i g n ) 3 . S e t u p a § L e _ F g _ ( Y o u w i l l n e e d t o d o t h i s ) _ _ _ _ _ ’ _ - - - 1 . S i g n r e l e v a n t : ( l ) b a n k a c c o u n t ( i i ) S h a r e t r a d i n g a c c o u n t I 2 . T r a n s f e r $ f r o m b a n k a c o c u n t s t o b a n k a c c o u n t a n d s t a r t C A 9 : 1 8 P M M o n M a r 1 6 9 8 9 % U ' < M a i l b o x e s A n I n b o x e s E d i t f u n d 0 m m " E [ Z J ‘ I R y a n , M u l t a n A n n J . J I H M Q ; ‘ ' v ‘ I [ B c s _ p . r e n t s ] B a y A r e a W i d e " s h e l t e r " . 2 - g r a D S f e r : b a n k a c o c u n t s t o b a n k a c c o u n t a n d s t a r t I m p o r t a n t p o i n t f r o m t h e s a m e a r t i c l e : 3 8 : ) ; n g S a r e s b k t d f “ . . . P e o p l e i n t h e s i x c o u n t i e s w i l l s t i l l b . . . ‘ p a n a c c o u n s a n t r a n s e r m u n g 2 : 0 7 p M 4 . W h e n ( 3 ) I s s e t u p , c e a s e t r a d i n g a n d s t a r t t r a d i n g F w d : é H i J u l i a n , C a n y o u p l e a s e r e a d t h i s d o c u m e n t f r o m K e n a n d l e t m e k n o w w . . . S t e p 3 ( T 0 b e d i s c u s s e d ) o K r i s M i h a l i c 1 : 1 8 P M ' 1 . p u t i n u p m s [ B C S _ p a r e n t s ] S o c i a l d i s t a n c i n g s i m u l . . . h t t p s : / / w w w . w a s h i n g t o n p o s t . c o m / g r a p h i c 5 / 2 0 2 0 / w o r I d / c o r o n a - s i m u l a t o r . . . V i n c e F e l i c e t t a 1 2 : 2 0 P M L o t m o l m o w l f y o u w o u d l l k o t o d o m m I n v o i c e g o H o l l i e , ' L a w r e n c e & ' Y i . . . 1 1 : 2 0 A M Q ) [ B C S _ p a r e n t s ] R e m i n d e r : O n - L i n e l . . . é R e g a r d i n g t h e o n l i n e l i b r a r y f o r m i d d l e s c h o o l , t h e y d o n ' t n e e d t h e i r i P a d t o u . . . : y m t r e u o n - s a l t o s c a g o v 1 o 2 6 A M S u i t e 9 5 , L e v e l 5 , 3 3 0 W a t t l e S t r e e t . U l t i m o N S W g 0 _ 0 _ 7 O n l m e I n s p e c t i o n R e q u e s t T e l : 1 3 0 0 0 0 0 5 2 E m a i l : W m W e b : m L m L m B fi a k m O S c o t t R i c h e s 1 0 : 1 5 A M C o n n e c t w i t h u s : P i n e w o o d S c h o o l D a i l y U p d a t e | M o n d . . . : 2 : w a D e a r P i n e w o o d C o m m u n i t y , T o d a y L i n k e d i n : ‘ W M W m a r k s t h e f i r s t d a y o f o u r c a m p u s c l o s . . . ' ' ' h i 9 : 0 4 A M l _ m _ p o r t a n g g i g c l a i m g r a n g w a r n i n g ' . fi g s g a m ? g g p : n t v . r e s o u r c e s L L B A c c o u n t a n t s d o n o t r e p r e s e n t o r w a r r a n t t h a t e a c h a t t a c h m e n t i s f r e e f r o m c o m p u t e r w r u s e s o r o t h e r d e f e c t s . U p d a t e d 2 m i n u t e s a g o - 2 9 , 5 5 0 U n r e a d ® A c c o u n t E r r o r s D e t a i l s , < A Exhibit 3 COBLENTZ PATCH DUFFY & BASS LLP ONE MONTGOMERY STREET, SUITE 3000, SAN FRANCISCO, CALIFORNIA 94lO4-5500 FAX 4|5.989.|663 4|5.39|.48OO \OWQQUIhM 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 SCOTT C. HALL (State Bar N0. 232492) SKYE LANGS (State Bar N0. 287908) EMLYN MANDEL (State Bar N0. 3 10403) COBLENTZ PATCH DUFFY & BASS LLP One Montgomery Street, Suite 3000 San Francisco, California 94104-5500 Telephone: 415.391.4800 Facsimile: 4 1 5.989. 1 663 Email: ef-sch@cpdb.com ef-sdl@cpdb.com ef-erm@cpdb.com Attorneys for Plaintiffs ANNE TING, JACK TING, and NICOLE TING-YAP SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA ANNE TING, an individual; JACK TING, Case N0. 21CV381 1 10 an individual; and NICOLE TING-YAP, an individual, DECLARATION OF NICOLE TING-YAP Plaintiffs, IN SUPPORT 0F TEMPORARY RESTRAINING ORDER APPLICATION V. PANIDA CHINSUPAKUL, an individual; Trial Date; None Set and DOES 1 through 10, Defendant. DECLARATION OF NICOLE TING-YAP I, NICOLE TING-YAP, declare as follows: 1. I am a party in the above-entitled action. Ihave personal knowledge 0f the facts set forth herein, except as t0 those stated 0n information and belief and, as t0 those, I am informed and believe them t0 be true. If called as a witness, I could and would competently testify t0 the matters stated herein. 2. I reside in Kuala Lumpur, Malaysia. Julian Ting is my brother, and Plaintiffs Anne Ting and Jack Ting are my parents. 18786.001 4814-7860-4002.6 1 Case N0. 21CV381 1 10 DECLARATION OF NICOLE TING-YAP IN SUPPORT OF TEMPORARY RESTRAINING ORDER APPLICATION COBLENTZ PATCH DUFFY & BASS LLP ONE MONTGOMERY STREET, SUITE 3000, SAN FRANCISCO, CALIFORNIA 94lO4-5500 FAX 4|5.989.|663 4|5.39|.48OO \OWQQUIhM 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3. I am a Director and/or custodian 0f records for approximately 15 business entities, including JCT Holdings Sdn. Bhd. (“JCT Holdings”), Setima Sdn. Bhd. (“Setima”), and Chelsea Capital Limited. I stored confidential information related t0 these entities, as well as confidential information related t0 my own business interests, 0n my brother Julian’s server, and I also occasionally, when Ineeded his assistance, sent him copies 0f some 0f this confidential information. 4. My brother, Julian, has n0 ownership interest in any 0fmy personal business ventures, 0r any 0f the 15 entities for which I am a Director and/or the custodian 0f records, and I have records t0 prove this. Additionally, I can provide the names 0f all the entities at issue, butI would prefer not t0 disclose this information publicly. For now, I will focus 0n just two 0f the entities, JCT Holdings and Setima, because Defendant has been using the documents that she took from me without my permission, and that concern these entities, in her marital dissolution proceedings against my brother. Ibelieve that she has been using documents about JCT Holdings and Setima based 0n her mistaken belief that Julian has an ownership interest in them, and that the documents concern his finances. They d0 not. Julian has had n0 ownership interest in JCT Holdings 0r Setima since November 30, 2000. 5. Julian and I are both Directors 0f Setima Sdn. Bhd. (“Setima”), and I am its custodian 0f records. Setima is owned by myself and others, excluding Julian. JCT Holdings is wholly owned by Setima, and has been since 1984. Julian and I are both Directors 0f JCT Holdings, and I am its custodian 0f records. In his role as a Director, Julian is provided with confidential information about both JCT Holdings and Setima. 6. On 0r about February 16, 2021, Julian informed me that Defendant had provided him with copies 0f some documents, information, photographs, and screenshots that he believed she had illegally obtained. Julian provided me with copies 0f these documents shortly thereafter. These documents included personal, financial, business, and tax information that belonged t0 me, my father, and my mother. 18786.001 4814-7860-4002.6 2 Case N0. 21CV381 1 10 DECLARATION OF NICOLE TING-YAP IN SUPPORT OF TEMPORARY RESTRAINING ORDER APPLICATION COBLENTZ PATCH DUFFY & BASS LLP ONE MONTGOMERY STREET, SUITE 3000, SAN FRANCISCO, CALIFORNIA 94lO4-5500 FAX 4|5.989.|663 4|5.39|.48OO \OWQQUIhM 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 7. Some 0f the photographs Defendant took, which she later gave Julian copies 0f, were pictures 0fmy private business and financial information which Julian had on his MacBook Pro, iPhone, and iPad. 8. Attached as Exhibit C is a one 0f these documents. It is a picture Defendant took 0f a check deposit receipt and account statement for JCT Holdings. The original photograph shows confidential financial information, which I have redacted in order t0 protect my privacy. 9. Attached as Exhibit D is another picture Defendant took 0fmy private financial information without my permission. It is a picture 0f an account statement for Chelsea Capital Limited, an entity belonging t0 my husband and others, and for which I am a Director and the custodian 0f records. The original photograph shows confidential financial information, which I have redacted in order t0 protect the confidentiality 0f the information it contains. 10. Attached as Exhibit E is a picture Defendant took 0f an encrypted text message, addressed t0 me, 0n Julian’s phone, which concerns rental payments 0n real property owned by Setima. The original photograph shows confidential financial information, which I have redacted in order t0 protect the confidentiality 0f the information it contains. 11. In addition t0 the documents Ihave described above, Defendant took photographs of the following private information on Julian’s MacBook Pro, iPad, and iPhone: a. tax vouchers, corporate governance documents, and account information for JCT Holdings; b. title documents for property in London owned by an entity belonging t0 me, and for which I am the Director and the custodian 0f records; c. private emails between me, my assistant, and Julian concerning real property I own, and several entities for which JCT Holdings is a shareholder; and d. encrypted text messages address t0 me, and concerning an entity for which JCT Holdings is a shareholder. 12. The information described above is private and confidential, and concerns my private financial affairs, and the private financial affairs 0f numerous business entities which I manage, act as a Director and/or custodian 0f records, and have an ownership interest in. I did not 18786.001 4814-7860-4002.6 3 Case N0. 21CV381 1 10 DECLARATION OF NICOLE TING-YAP IN SUPPORT OF TEMPORARY RESTRAINING ORDER APPLICATION COBLENTZ PATCH DUFFY & BASS LLP ONE MONTGOMERY STREET, SUITE 3000, SAN FRANCISCO, CALIFORNIA 94lO4-5500 FAX 4|5.989.|663 4|5.39|.48OO \OWQQUIhM 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 give Defendant permission t0 View 0r copy this information, and she did so without my consent. This information is not publicly available, and I would not voluntarily share it with any individual, including Defendant, unless there was a business need t0 d0 so. This information belongs t0 me, 0r was in my lawful possession, and I have an immediate right t0 possess it. While the information was in Julian’s possession, Julian did not own it, and if I asked him t0, he would have immediately returned this information t0 me, 0r he would have permanently deleted it. Julian did not have my consent t0 share this information without my permission. 13. Julian had possession 0f the documents described above, concerning JCT Holdings and Setima, because he is a Director 0f those entities and is consulted 0n transactions that concern them, even though he does not have an ownership interest in them. He is expected t0 review, and be aware 0f, confidential issues concerning these entities. His duties as a Director also entitle him t0 vote 0n resolutions that the company will act 0n, for example whether a particular transaction moves forward 0r not. The other private business and financial information described in paragraphs 7 through 11 was provided t0 Julian because he performs consulting work for me, such as the negotiation 0f commercial contracts, exercise 0f shareholder rights, optimization 0f cost 0f funds through the use 0f interest rate swaps and other financial derivative instruments and energy efficient building methods and systems. He also provides me with financial and business advice 0n occasion. 14. I trusted and believed that Julian would keep my information private, and that he would not allow others, including Defendant, t0 View it without my permission. Inever expected that Defendant, 0r anyone other than Julian, would be able t0 View, copy, photograph, use, 0r otherwise gain access t0 the private business and financial information 0n Julian’s MacBook, iPad, and iPhone without my consent. Ibelieve that Defendant gained access t0 my information by spying 0n Julian t0 discover his passwords, and then used them t0 access my private information without his knowledge. 15. Sometime around December 3, 2020, Julian informed me that the server in his home had been compromised. He later informed me that the server had been shut down for an approximately 46-hour period without his consent, while he was out 0f the country. At the time, I 18786.001 4814-7860-4002.6 4 Case N0. 21CV381 1 10 DECLARATION OF NICOLE TING-YAP IN SUPPORT OF TEMPORARY RESTRAINING ORDER APPLICATION COBLENTZ PATCH DUFFY & BASS LLP ONE MONTGOMERY STREET, SUITE 3000, SAN FRANCISCO, CALIFORNIA 94lO4-5500 FAX 4|5.989.|663 4|5.39|.48OO \OWQQUIhM 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 had n0 further information about why the server was shut down, 0r what might have happened during that time. Recently, Ihave come t0 believe that Defendant caused the server t0 be shut down so that its contents could be copied. Idid not give Defendant permission t0 access any 0f my information 0n the server. 16. Ihave since learned that Defendant has admitted t0 making copies 0f all the information contained 0n the server, including my private personal information and confidential business information. Prior t0 learning that fact, one 0f the reasons Ibelieved that Defendant copied the contents 0f the server is because some 0f the pictures Defendant took 0f Julian’s MacBook screen are 0f file directories and pathways showing the location 0f information I store 0n Julian’s server, including files containing tax returns, share statements, banking records, loan documents, and interest statements. Attached as Exhibit F are a sample 0f some 0f these pictures, which I have redacted in order t0 protect the confidential information in these directories. Not only are these directories themselves private, because they reveal details about my private information which I would not otherwise publicly disclose, such as the names 0f accounts Ihold and businesses Ihave an interest in, but I also believe that Defendant took this information in order t0 determine what information was contained 0n the server, t0 decide which portions 0f the server t0 image, and t0 understand and organize the information she was taking. 17. The information I store 0n Julian’s server is password protected. Ihave only given three people permission t0 View and access the information 0n my partition: me, my assistant, and Julian. Given these password protections, and the fact the server is located in a safe place in Julian’s home, I believed that my information was secure and would remain private. I never expected that Defendant, 0r any other person, would be able t0 View, copy, photograph, use, 0r otherwise gain access t0 the information I stored 0n the server. I did not give Defendant permission t0 see my personal 0r private information 0n Julian’s server. 18. Iused my partition 0n the server store back-up copies 0fmy personal, financial, business, and tax information for safekeeping. As Julian is the executor 0fmy last will and testament, Ikept a copy 0f these records with him t0 feel safe as Ihave n0 other relatives in Malaysia where I live and d0 not trust anyone else t0 handle my business in case anything happens 18786.001 4814-7860-4002.6 5 Case N0. 21CV381 1 10 DECLARATION OF NICOLE TING-YAP IN SUPPORT OF TEMPORARY RESTRAINING ORDER APPLICATION COBLENTZ PATCH DUFFY & BASS LLP ONE MONTGOMERY STREET, SUITE 3000, SAN FRANCISCO, CALIFORNIA 94lO4-5500 FAX 4|5.989.|663 4|5.39|.48OO \OWQQUIhM 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 t0 me. Although I placed my data 0n Julian’s server for safekeeping, at all times I owned the information and had an immediate right t0 possess it. I could access my information 0n the server whenever I wanted by using my password. Julian did not own the information 0r have my consent t0 share this information without my permission. 19. The private personal information I store 0n the server includes Videos 0f private counseling sessions involving me, my children, and my husband; sensitive photographs 0f me; passport information; identity information for my children; attorney-client privileged information relating to pending litigation I am involved in; and information concerning current and former household employees. Much 0f this information is incredibly sensitive. I am especially concerned about the potential disclosure 0f the pictures 0f me, as well as the Videos 0fmy family’s counseling sessions, which are deeply personal and involve very intimate and confidential family discussions that I reasonably expected t0 remain private. Knowing this information could be disclosed t0 third parties, I feel constantly unsafe and fearful, and worry, almost constantly, about what will happen to me and my family if this information is made public. As a result, I am now taking anti-anxiety medications and anti-depressants t0 help manage my distress. 20. I also used the server t0 store my personal business records, as well as the records for fifteen different entities for which I am 0r was the custodian 0f records. These records are confidential, and include financial records, privileged communications regarding commercial transactions, and trade secrets and competitively sensitive business information. 21. I am the owner, lawful possessor, and/or licensee 0f trade secret information which is stored 0n Julian’s server. This trade secret information includes information about product designs, marketing plans, business strategies, future commercial transactions, pricing information, and profit margins for some or all of the fifteen different entities for which I am 0r was the custodian 0f records, as well as for my own personal business enterprises. 22. This trade secret information is not generally known t0 the public 0r business competitors, and reasonable efforts have been taken t0 maintain the secrecy 0f this information. For instance, I stored the information in a secure manner, limited its disclosure t0 a small number 0f employees, and instructed employees t0 keep the information private. In the event that I 18786.001 4814-7860-4002.6 6 Case N0. 21CV381 1 10 DECLARATION OF NICOLE TING-YAP IN SUPPORT OF TEMPORARY RESTRAINING ORDER APPLICATION COBLENTZ PATCH DUFFY & BASS LLP ONE MONTGOMERY STREET, SUITE 3000, SAN FRANCISCO, CALIFORNIA 94lO4-5500 FAX 4|5.989.|663 4|5.39|.48OO \OWQQUIhM 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 determine that some portion 0f the confidential information needs t0 be disclosed outside 0f the organization (for instance, t0 a business partner), Itake steps t0 ensure that it is disclosed subject t0 certain protections, including non-disclosure agreements, and only t0 the extent necessary t0 accomplish the specific purpose. 23. The trade secret information has independent economic value, which, if publicly disclosed, would allow business competitors t0 copy product concepts and business strategies, and compromise my ability t0 enter into favorable commercial transactions and t0 compete in the marketplace. For example, I am in the process 0f developing intellectual property around energy efficient building techniques and have constructed a prototype. Ihave a fiduciary obligation t0 my partners in this enterprise t0 maintain the privacy 0f this intellectual property. The learnings that we obtain specific t0 the environment/climate in Malaysia are currently being reviewed and give me a competitive advantage when bidding for government construction contracts in Malaysia. I am nervous about this information being leaked t0 my competitors who did not make the investments Imade t0 learn t0 achieve the energy efficient performance levels I am seeing. The current value 0f the bid that could be jeopardized by the disclosure 0f this information is around USD 75 million. In addition t0 this trade secret information, Ihold other trade secrets that belong t0 me personally, as well as some that belong t0 the fifteen different entities I am involved in. 24. Ihave been authorized by both JCT Holdings and Setima t0 “commence 0r defend . . . any action 0r other proceeding in any court . . .for the recovery 0f any property 0f the Company whether tangible 0r intangible . . . by any means 0r 0n any account whatsoever.” True and correct copies 0f the Directors’ Resolutions providing this authorization are attached as Exhibits G and Exhibit H. I can obtain additional resolutions 0f this nature, if necessary, for the other entities whose data was stolen from me. 25. I also used a partition 0n the server t0 create a full Apple Time Machine back-up of my Macbook Pro. It contains attorney client privileged emails and other communications between me and my lawyers around the world in addition t0 other personal and business information that the defendant now has access t0. 18786.001 4814-7860-4002.6 7 Case N0. 21CV381 1 10 DECLARATION OF NICOLE TING-YAP IN SUPPORT OF TEMPORARY RESTRAINING ORDER APPLICATION COBLENTZ PATCH DUFFY & BASS LLP ONE MONTGOMERY STREET, SUITE 3000, SAN FRANCISCO, CALIFORNIA 94lO4-5500 FAX 4|5.989.|663 4|5.39|.48OO \OWQQUIhM 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 26. In addition t0 the copying 0fmy private information, 0n 0r about March 8, 2021, Julian told me that Defendant was asking questions about companies, real property, and assets that are owned and/or managed by me, my husband, and/or my in-laws. Julian has n0 ownership interest in the entities Defendant was asking about, and these entities are unrelated t0 his finances 0r any marital property. Defendant had n0 reason t0 be asking about these companies, real property, and assets unless she had illegally Viewed 0r accessed my private information contained 0n Julian’s server, MacBook Pro, iPad, and iPhone, and mistakenly believed it belonged t0 Julian. Ihave also been told that Defendant has filed some documents concerning business entities I own, and which Julian has no ownership interest in, in her marital dissolution proceedings. 27. Defendant’s conduct makes me believe that she has not made any attempt t0 identify what information she has that belongs t0 me and must remain private, and I am afraid that Defendant will publicly disclose more 0fmy private information, which would be extremely harmful t0 me, both personally and professionally. Defendant also claims that she cannot “selectively delete” the private and confidential information I stored 0n my partition 0f the server. Given Defendant’s use 0fmy information so far, Ibelieve the only way t0 keep my data safe and private is t0 require Defendant t0 delete every copy she has made 0f any and all data she took from the server. 28. I believe that Defendant took my private information because she wants t0 use it against Julian in their divorce proceeding, and t0 frame, extort, harm, punish, or Vilify Julian because 0f the end 0f their marriage; 0r because she wants t0 use it t0 harm my business interest, t0 embarrass, harass, and annoy me; and t0 extort 0r otherwise obtain a financial advantage from me. 29. Defendant’s actions have harmed me by invading my privacy. In addition, Ihave and will incur losses as a result 0f Defendant’s improper access t0, and use 0f, my private personal, financial, tax, and business information. Ihave expended time and money trying t0 get Defendant t0 return 0r destroy my private information, and t0 secure the privacy 0fmy information. Ialso expect t0 spend money investigating the damage she may have caused t0 the S€I'V€I‘. 18786.001 4814-7860-4002.6 8 Case N0. 21CV381 1 10 DECLARATION OF NICOLE TING-YAP IN SUPPORT OF TEMPORARY RESTRAINING ORDER APPLICATION COBLENTZ PATCH DUFFY & BASS LLP ONE MONTGOMERY STREET, SUITE 3000, SAN FRANCISCO, CALIFORNIA 94lO4-5500 FAX 4|5.989.|663 4|5.39|.4800 ©W\IO\UIhUJ 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 30. The intrusion into my privacy has caused me emotional distress. In addition t0 the severe distress surrounding my fears that my personal information will be disclosed, I feel embarrassment, anxiety, worry, nervousness, anger, shock, and humiliation, as a result 0f the intrusion into my privacy, and I fear that Defendant will disclose my private personal and financial information, and cause irreparable harm t0 my business interests, including by disclosure 0fmy trade secret information. I declare under penalty 0f perjury under the laws 0f the State 0f California that the foregoing is true and correct. Executed 0n this 18th day 0f May, 2021, at Kuala Lumpur, Malaysia. DocuSigned by: 035FEF18§8851§---. _ -YAP 18786.001 4814-7860-4002.6 9 Case NO. 21CV381 1 10 DECLARATION OF NICOLE TING-YAP IN SUPPORT OF TEMPORARY RESTRAINING ORDER APPLICATION .4... Prewev. v 4 vmam-o_. I :i 1 _ We hereby cemfy (hal nu lax rs deduchmu from mu 5m in the hands o! the shareholders pursuant (o [mama B'fwx Cheque Deposit Receipt - Acwcam No _ J.c.T. HOLDINGS son BHD Datemme osomzon 12-27:“!-d Branch/Termlnal 1‘ Cheque No - ‘ 1 Flam Day - H Bank _ ICreme Amount _ I Canm » r Net Amount - ‘ 913;" MALAYSAN TAX VOUCHER VOUCHER N0. Impamnt Notes: We encoungc you Io op! for pawn! o! dividends through MaybInk ODMdond fot added convonhneu. Please updah your bank account deans through your stockbroker If you wlsh loRcazuo enjoy this service‘ J C T HOLDINGS SDN BH DIVIDEND NO TYPE OF C‘ . [4' W " ZORV OF DIWDEND FOR YEAR ENDED ENTITLEMENT DATE DATE OF PAYMENT NO OF SHARES DIVIDEND RATE GROSS DIVIDEND [RM] INCOME TAX (RM) NEY DIVIDEND (RM) glu hcv dmdend under Secuon 108 ollhe In ph 128 cl Schedule a otlhe sax: Acl. m: pan is w be rammed by sharonommsm am requested la gwa ummucmm noncn muuuin mm: cos Account AMums 30 Indus». o1 6% GsT w.“ be mmgea «o, um, um come Tax Ac! 1967 The smg‘u Ix ~ vs n3: ramble m wumq n' Am W w- l. wm w A . m.m ‘ .. Re \slmrn E d i t I n s e n F o r m a t A r r a n g e V i e w W i n d a w O E r C h e f s e a ' - a fi j v u n v a v u ] V u . l u L y ‘ T a v F M V I E W Z o o m | , v - ‘ I . " = ' I I n s e r t T a m e C h a r ! M e d i a ' " : e i ' v i i z u ' fl f u ‘ P J M w E m S o n o s H e l p T e x t S h a p e P u g t a C H E L S E A C A P I T A L L I M I T ‘ 1 3 D e c e m b e r 2 U 1 2 P a g e N u m h m , ' F a r m a t N u m b e r i n g ' l ' . w i m g fl l 5 r . i ; ” w n T ! D e a r S i r s ‘ C r e a t e a n e w m m a m s m m w m m m u m i v A c c o u n t N a m e : C h e l s e a C fl a l L i m i t e d I S e c u r i t i e s a c c o u n t n u m b e r : - S T O C K N A M E S T D C H Q U A N T I T Y F R I C E l M Y R } C O D E 10:31 o ’ -’ <0 . Nicole > Today 8:27 PM Subject: Dear Datin Nicole l hope you and your family are doing well. lam writing to follow up on our conversation regarding the tenancy agreement pertaining to As discussed on the telephone, this particular stretch on solely relies on the Middle Eastern tourist trade; and as you know, there have been no tourists or visitors arriving in the country since the beginning of the Movement Control Order on Mammal]. That is four months without the usual footfall and clientele that (Subject mg) Vicsficfi w p.06 © o .6 .v v- usual footfall and clientele that we rely on. To make matters worse, this period also included the complete closure of the restaurant for two months when the restrictions were in place. Due to this, our operations have slowed down dramatically for the majority of 2020 and our revenue has been close to zero for the past four months. Please find attached our sale figures for the period, with the comparison of last year’s sales for the same period. In light of the devastating slowdown this pandemic has caused, we now need to amend the terms of our agreement in order to reflect the change in climate and enable us to survive long term. Subject Q 6) 10:32 <. . NicoIe > Please see below an outline of the proposal. Year 2020 rental at Year 2021 rental at Year 2022 rental at On acceptance of these new terms, we will be able to continue operating during this challenging time and then hope to pick up in sales and revenue as soon as border open and life normalises. We are confident in the future success of our business. Thank you in advance for your sunnnrt Subject a!» 36>-‘A-.. C ® / k ) A - fl I v u x u w g ( 6 7 ) ) A i r D r o p i C I o u d ( 3 i C l o u d D r i v e L o c a t i o n s D J u l i a n ' s M a . . . D i s k S t a . . . @ N e t w o r k I } T a g s C ? G r e e n ® O r a n g e H o m e C P u r p l e 5 " ; W o r k O G r a y D O OO D U E U § l § l < fl < N a m e T r u s t - . p d f V V V V V V V V L " J C T - c o m p a n y p r o f i l e . d o c V V V V V V V V , . , J C T H o l d i n g s S d n B h d A D a t e M o d i f i e d V S i z e B a n k i n g - B a n k i n g - - B a n k i n g - - B a r m i n s k - J C T - b a n k i n g _ J C T - a u d i t e d a c c o u n t s J C T - b a n k i n g J C T - l a n d t i t l e J C T - - B a n k - J C T - _ B a n k - _ J e v J C T - s h a r e & s e c u r i t i e s - J C T - s h a r e s & s e c u r i t i e s J C T - t a x a t i o n T r a n s f e r I n s t r u c t i o n s - K i n d P D F D o c F o l d e r F o l d e r F o l d e r F o l d e r F o l d e r F o l d e r F o l d e r F o l d e r W o r d d o F o l d e r F o l d e r F o l d e r F o l d e r F o l d e r F o l d e r F o l d e r F o l d e r v 1 . _ V . _ . ‘ _ . . u u a u v u u U l l T o : T i n g F a m i l y _ H o l d i n g s L t d m m ] F a m i n - J e f f Y a p D i 0 1 ~ C o r r e s p o n d e n c e O O r a n g e . r e a d i n g 7 W T i m e C a p s u l e H o m e v i d e o r I O m F a m i n - J o h n Y a p b i 0 2 - R e m i t t a n c e s > I E M o v ' e s . h m F a m i n - n i c o l e y a p D 0 3 - C l i e n t S t a t e m e n t s b a P i e t u r e s k D i s k S t a t i o n m F a m i n - T a n S r i Y a p D i 0 4 - - A g r e e m e n t b I @ A i r D r o p 1 C o n n e c t e d a s : J u l i a n T i n g m F e n g S h U i ' i 0 5 ‘ - A 9 r e e m e m ’ m G o o g l e S h e e t s - d o c s b i 0 6 - S e c r e t a n a l v i C E - E E ‘ E m H a m p e r s D i 0 7 - L o a n D o c u m e n t s D ' C I O U d m _ D a l y C i t y , m H o u s e h o l d b Q 0 8 - I n t e r e s t S t a t e m e n t > G i C I o u d D r i v e W - O r a n g e I n t e r i o r D e s i g n v m H u m a n R e s o u r c e b u 0 8 - I n t e r e s t S t a t e m e n t s b f . [ m F a m i l y , @ 3 9 3 I N B O X b - _ T a x R e t u r n - D L O C B U O H S m h o m e é , J C T H o l d i n g s S d n B h d D k I D J u n a n l s M a " 3 1 ; ) h o m e s I ’ fl D i s k S t a fl ‘ f 1 1 % g B E ‘ g ' : { fi g m u s i c " . @ N e t w o r k m N e t B a c k u p : L - S d n B h d . T a g s L i - , m 3 L e t t e r h e a d ’ _ ‘ , . , . G r e e n m i p h o t o : E t g b g j z ‘ , p D - 4 “ ‘ W J C T - s h a r e s & s e c u r i t i e s i < > 3 3 3 i ‘ m J ‘ r ' j i ‘ m g fl m v g l fi v i f o w E E G ? Q S e a r c h 3 ‘ l [ 1 9 1 0 1 1 ; ‘ 3 ‘ - ~ - ' - * ' r ‘ A ‘ E M ? “ W “ ‘ N a m e A . . “ “ ‘ W - r r - © A i r D r o p fl D a t e M o d l f l e d s l z e K i n d } 5 2 0 1 0 - - F o l d e r i C l o u d ’ $ 2 0 1 2 - - F o l d e r Q i C l o u d D r i v e ’ f a 2 ° 1 3 - - F o l d e r D @ 2 0 1 4 - - F o l d e r L o c a t i o n s > Q 2 0 1 5 _ _ F o l d e r D J u l i a n ' s M a . . . ’ m 2 0 1 6 - - F o l d e r . P E 2 0 1 7 - - F o l d e r . D a s k S t a . . . - , @ 2 0 1 8 - - F o l d e r ® N e t w o r k > m 2 0 1 9 - - F o l d e r > i C o r r e s p o n d e n c e - - F o l d e r T a g s ‘ f 3 G r e e n ' 9 O r a n g e f ) H o m e O P u r p l e W o r k Q G r a y r u m : H a c e w e d d e m a n d f o r p a y m e n t f r o m - - - * - O 1 " " ' ( D A T E ) - Y O U S C fl n n e d t h e l e t t e r . P l e a s e p r o v d ‘ e d a t a i j < > m a ~ m m C E ] : 3 3 3 - 3 v . n V k - 1 Q " ~ L e r ' a r ‘ r i y r ' 1 [ j D E S k t O p N a m e D H ' " " " " " " " " " - ° - ~ - ~ H 7 - , _ _ r E t a M D d l fi E d S i i _ 7 - . V z e ® D o c u m e n t s F P r u n e r t y - _ K i n d ° “ ° ‘ “ “ ' ° a d 5 ~ W a r w " * P r u n e r t v - - * ‘ W a r F ~ P r o p e r w - - “ d ” - - F o l d e r " W W W - P i c t u r e s p R j « ~ ' u F D i d e r e G L a t l o n - _ u F e w e r ( 6 : 3 ) ) A i r D r O p r - S d n B h d ~ - F n l d e r I v S e t i m a S d n B h d F o l d e r i C I o u - d P S h a r e C e r t i f i c a t e s k - - F o l d e r ( 1 : 5 i C I o u d D r i v e 9 ’ S t o r a g e _ , F o l d e r . b S t o r a g e - p e r s o n a l e f f e c t s - - F o l d e r . - F o l d e r D J u l i a n ' s M a . . . " ' n g J a C k C h a n g x F o l d e r E fi D i s k S t a * p T ' t ' e s m e . » h T 0 d o l i s t _ P o i t i e r N B t W O f k I v T r a v e l R e w a r d P o i n t s r ‘ ' _ F u l d e r I r u n t i t l e d f o l d e r u P a i d “ P V i s a A p p l i c a t i o n s , , , _ _ A . , F _ " " ' “ H ’ - - = - - - t u l l fl u E u r T h u r s d a y R e n t e d a c m , f r 0 m _ R a p o r t e d t o m y i n s u r a n c a m _ i P G a E R e c e i v e d d e m a n d f o r p a y m e n t v f r a i fi . Q i ( D A T E ) . Y o u s c a n n e d t h e f e t t e r . P h a s e - a w - S d n 8 h d " ‘ ‘ ~ - 3 } E S E E E E D E J 3 E » . fi v Q I : 5 T : { . I $ = 7 L r 2 , D e s k t o n N a m e D a t e M o d i f i e d fl D o c u m e n t s " ‘ _ b a n k s t a t e m e n t s o D o w n l o a d s ' 1 _ 3 C C r e o p e n i n g c h e c k l i s t x l s 1 B K B ‘ - - u d i t m a n s 2 3 K B g n M u s i c h » - a n k s t a t e m e n t s H ‘ H M o v i e s D - ~ _ C o r r e s p o n d e n c e - - ‘ _ F _ Q u i t r e n t 8 : a s s e s s m e n t - - i m p l u m e s b - e c r e t a r i a l d o c u m e n t s ~ * - ® A i r D r o p i C i o u d a i C I o u d D r i v e ‘ a n a t i n n s fl J u l i a n ' s M a . . . - D . i s k 8 t a . . = . ‘ o N e t w o r k . l 4 V ® T h u r s d a y R e n t e d n c a r f r o m - P G fi E . : 3 : < s a g g i n g ! : v fi v . D e s k t o p N a m e fl D o c u m e n t s u ' ° D o w n 1 o a d s n M u s i c H M o v i e s l ‘ P i c t u r e s i ( 6 3 ) ) A i r D r o p B i s t r o R e s t a u r a n t C o m p a n y i C l o u d Q i C I a u d D r i v e H o l d i n g s v a v r v r T Y ‘ F ' v v ‘ r " 4 7 > D e v e l o p m e n t L o c a t i o n s J u l i a n ' s M a . . . E D i s k S t a . . . 2 [ O ‘ N a t w o r k ‘ l ‘ ‘ i ; 1 3 9 ‘ . . - 1 - - M a r k e t i n g a S h a r e h o l d i n g - s u m m a r y . p d f u h : S h a r e C e r t i f i c a t e s _ . . ' - w - w u u H I u a l u w E p e e a o n t h e s a m e d a y - R e p o r t e d t o m y i n s u r a n c e c o m p a n y o n - R e c e i v e d d e m a n d f o r p a y m e n t f r o m E ( D A T E ) . Y o u s c a n n e d t h e l e t t e r ‘ P l e a s e p r O V I E d a t a j . 7 Q D a t e M o d i f i e d S i z e I n d - - F o l d e r - - F o l d e r - - F o l d e r - - F o l d e r - - F o l d e r u F o i d e r n F o l d e r - - F o l d e r - - F o l d e r ‘ _ _ F o l d e r - - F o l d e r , s - - F a i d e r _ . F a l d g t 1 t F o l d e r r “ JCT HOLDINGS SDN. BHD. (Registration No 197401002525 (19984-A)) (Incorporated in Malaysia) DIRECTORS’ RESOLUTIONS IN WRITING MADE PURSUANT TO ARTICLE 91(A) 0F THE COMPANY’S ARTICLES OF ASSOCIATION RESOLVED : 1. THAT NICOLE BlN-SHUN TING (aka NICOLE TlNG-YAP) be and is hereby authorised to for and in the name of the Company to - 1.1. 1.2. commence or defend or conduct any action or other proceeding in any court ofjustice and to accept service of any writ, summons or other legal process and to appear and to represent the Company in any court and before all magistrates or judicial or other officers whatsoever for the recovery of any property of the Company whether tangible or intangible, any debt, sum of money, right, title, interest, property, matter or thing whatsoever belonging to the Company and whether now due or payable or to become due or payable or in anywise belonging to the Company by any means or on any account whatsoever and the same action or proceeding to prosecute, discontinue, compromise, stay, terminate or abandon if NICOLE BlN-SHUN TING (aka NICOLE TlNG-YAP) shall see cause; and to take such other lawful ways and means for the recovering or getting in any such property, sum of money or other thing whatsoever which shall by NICOLE BlN-SHUN TING (aka NICOLE TING-YAP) be conceived to be due, owing, belonging or payable to the Company by any person whomsoever. THAT NICOLE BlN-SHUN TING (aka NICOLE TlNG-YAP) be and is hereby authorised to sign, verify and submit applications, affidavits, petitions, plaints, written statements, counterclaims, objection petition, complaints, memorandum of appeal and any other documents as may be required to be submitted to the court in connection with any court case or legal proceedings involving the Company. 3. THAT NICOLE BlN-SHUN TING (aka NICOLE TlNG-YAP) be and is hereby authorised to engage and appoint any solicitor, attorney and/or counsel to prosecute or defend in the proceedings aforesaid or any of them as occasion may require and give instructions to solicitors, attorneys and/or counsels or to execute power of attorney in favour of any person in relation to any court case or to swear affidavits on behalf of the Company in connection with any court case or legal proceedings involving the Company. JCT Holdings Sdn. Bhd. Directors' Resolution Pursuant to Article 91 (A) Page 2 of 2 4. THAT any actions taken by NICOLE BIN~SHUN TING (aka NICOLE TlNG-YAP) plior to the date hereof is within the authority conferred thereby and are hereby tatified. confirmed and approved as the acts and deeds of the Company./ BOARD 0F DIRECTORs DRJACK CHANG TING NICOLE BIN-SHUN Date : 15m Match. 2021 G JULIAN BlN-LIN TING SETIMA SDN. BHD. (Registration No 198301015055 (110448-M)) (Incorporated in Malaysia) DIRECTORS’ RESOLUTIONS IN WRITING MADE PURSUANT TO ARTICLE 91(A) 0F THE COMPANY’S ARTICLES OF ASSOCIATION RESOLVED : 1. THAT NICOLE BlN-SHUN TING (aka NICOLE TlNG-YAP) be and is hereby authorised to for and in the name of the Company to - 1.1. 1.2. commence or defend or conduct any action or other proceeding in any court ofjustice and to accept service of any writ, summons or other legal process and to appear and to represent the Company in any court and before all magistrates or judicial or other officers whatsoever for the recovery of any property of the Company whether tangible or intangible, any debt, sum of money, right, title, interest, property, matter or thing whatsoever belonging to the Company and whether now due or payable or to become due or payable or in anywise belonging to the Company by any means or on any account whatsoever and the same action or proceeding to prosecute, discontinue, compromise, stay, terminate or abandon if NICOLE BlN-SHUN TING (aka NICOLE TlNG-YAP) shall see cause; and to take such other lawful ways and means for the recovering or getting in any such property, sum of money or other thing whatsoever which shall by NICOLE BlN-SHUN TING (aka NICOLE TING-YAP) be conceived to be due, owing, belonging or payable to the Company by any person whomsoever. THAT NICOLE BlN-SHUN TING (aka NICOLE TlNG-YAP) be and is hereby authorised to sign, verify and submit applications, affidavits, petitions, plaints, written statements, counterclaims, objection petition, complaints, memorandum of appeal and any other documents as may be required to be submitted to the court in connection with any court case or legal proceedings involving the Company. 3. THAT NICOLE BlN-SHUN TING (aka NICOLE TlNG-YAP) be and is hereby authorised to engage and appoint any solicitor, attorney and/or counsel to prosecute or defend in the proceedings aforesaid or any of them as occasion may require and give instructions to solicitors, attorneys and/or counsels or to execute power of attorney in favour of any person in relation to any court case or to swear affidavits on behalf of the Company in connection with any court case or legal proceedings involving the Company. Setima Sdn. Bhd. Directors' Resolution Pursuant to Article 91 (A) Page 2 of 2 4. THAT any actions taken by NICOLE BIN-SHUN TING (aka NICOLE TlNG-YAP) pfior to the date hereof is within the authority oonfemd thereby and are hereby ratified. continued and approved as the acts and deeds of the Company. / BOARD OF DIRECTORS DRJACK CHANG TING NICOLE BIN-SI-IUN G JULIAN BIN-LIN TING Date : 15th March. 2021 Exhibit 4 COBLENTZ PATCH DUFFY & BASS LLP ONE MONTGOMERY STREET, SUITE 3000, SAN FRANCISCO, CALIFORNIA 94lO4-5500 FAX 4|5.989.|663 4|5.39|.48OO \OWQQUIhM 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 SCOTT C. HALL (State Bar N0. 232492) SKYE LANGS (State Bar N0. 287908) EMLYN MANDEL (State Bar N0. 3 10403) COBLENTZ PATCH DUFFY & BASS LLP One Montgomery Street, Suite 3000 San Francisco, California 94104-5500 Telephone: 415.391.4800 Facsimile: 4 1 5.989. 1 663 Email: ef-sch@cpdb.com ef-sdl@cpdb.com ef-erm@cpdb.com Attorneys for Plaintiffs ANNE TING, JACK TING, and NICOLE TING-YAP SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA ANNE TING, an individual; JACK TING, an individual; and NICOLE TING-YAP, an individual, Plaintiffs, V. PANIDA CHINSUPAKUL, an individual; and DOES 1 through 10, Defendant. Case N0. 21CV381 1 10 DECLARATION OF WONG SIEW ING IN SUPPORT OF TEMPORARY RESTRAINING ORDER APPLICATION Trial Date: None Set DECLARATION OF WONG SIEW ING I, Wong Siew Ing, declare as follows: 1. I am the Company Secretary for Setima Sdn. Bhd. (“Setima”) and JCT Holdings Sdn. Bhd. (“JCT Holdings”). Ihave held this position since June 16, 2005. As Company Secretary, I am responsible for maintaining records about ownership 0f Setima and JCT Holdings, including information about the transfer 0f shares and the identity 0f the current shareholders. I have personal knowledge 0f the facts set forth herein, except as t0 those stated 0n information and 18786.001 4846-3929-0344.1 Case N0. 21CV381 1 10 DECLARATION OF WONG SIEW ING IN SUPPORT OF TEMPORARY RESTRAINING ORDER APPLICATION COBLENTZ PATCH DUFFY & BASS LLP ONE MONTGOMERY STREET, SUITE 3000, SAN FRANCISCO, CALIFORNIA 94lO4-5500 FAX 4|5.989.|663 4|5.39|.48OO \OWQQUIhM 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 belief and, as t0 those, I am informed and believe them t0 be true. If called as a witness, I could and would competently testify t0 the matters stated herein. 2. Setima was formed in 1983. At that time, Setima acquired all the outstanding shares 0f JCT Holdings. JCT Holdings is wholly owned by Setima, and has been since 1984. 3. In 1996, Julian Ting owned 600,000 shares in Setima. On November 30, 2000, he transferred all 0f these shares t0 his sister, Nicole Bin-Shun Ting (also known as Nicole Ting- Yap). Attached hereto as Exhibit J is a true and correct copy 0f documentation showing this transfer. Since November 30, 2000, Julian Ting has not owned any shares 0f Setima 0r JCT Holdings. Executed 0n this 19th day 0f May, 2021, at Sibu, Sarawak, Malaysia. Cw/ WONG SIEW ING 123786.001 4846-3929-0344.1 2 Case No. 21CV381 1 10 DECLARATION OF WONG SIEW ING IN SUPPORT OF TEMPORARY RESTRAINING ORDER APPLICATION F O R M 3 2 A C o m p a n i e s A c t 1 9 6 5 , S e c t i o n 1 0 3 ( 1 ) W M O F T R A N S F E R 0 F S E C U R I T I F ‘ . ‘ E ‘ W F ‘ W J ‘ U ’ é ‘ u ’ fi J ‘ J ‘ l - i j M m « w a i f : 1 1 . N A M E 0 F C O M P A N Y : S E T I ( I N B L O C K L E T T E R S ) M A S D N B H D ' v m m m a h t s ‘ j f s é m s v a n o m s a z ; S i g n e d , s e a i e d e l i v e r I n t h e p r e s e n c e o f E . I . w . . . 2 . N U M B E R 0 F U N I T S : C E R T I F I C A T E ‘ j r " “ N F I G U R E S & W O R D S , D E S C R I P T I O N 0 F S E C U R I T I E S N U M B E R S , S i g n m u r e > > w , ) 3 o [ l l i c ' S I X H U N D R E D l o i V l " a T H O U S A N D O R D I N A R Y S H R A E s _ _ § & 7 N W W I O ‘ G w a m w m . J ' T x fi e q fi b fi A N l r s ( 6 0 0 , 0 0 0 ) ” ‘ A d d r e s s Q C ” m , 3 . N A M E 0 F T R A N S F E R O R I S ) : u N B L o c h E T T E H S ) T I N G J U L I A N B I N w L I N . ( H E R E I N A F r E R C A L L E D ' T R A M S F E H O R ‘ ) O c c u p a n o n J 4 R D I P A S S P O R T , T R U E S i g n e d . s e a l l d a n d d e l i v e r e d i n t h e p r e s e n c e o f . m m u e n G a m m a : _ ) C O P Y . ‘ S i g n a t u r e 5 . N A M E & A D D R E S S O F T H A N S F E R E E I S ) : ( 1 N m o c x L E ' I - r E R S I [ H E R E I N A F T E R C A L L E D " T R A N S F E R E E U . . . ‘ N a m e T I N G N I C O L E B I N _ S H U N W O N G S I E V V ‘ N G L S O O O A G Z O ‘ A d d r e s s P _ fl u " ” m m " V ‘ . c o m p a n y S e c r e t a r y z G x o i u n r j F l o o r , N a . 3 L o r o n g P a h l a w a n 7 A 2 , ‘ ’ 3 ‘ 3 “ P a h l a w m a n 9 6 0 0 0 S i b u . S a r a w a k 0 . J 5 0 2 0 0 K L U M P U R c c u p a u o n S i g n e d , s e a l e d a n d d e l i v e r e d i n t h e p r e s e n c e o f 6 . P A R T I C U L A R S 0 F T R A N S F E R E E { S e n c o l u m n s b e l o w ) : S i g n a t u r e ‘ V ( I F T R A N S F E R E E I S A P E R S O N ) ( I F T H A N S F E H E E I S A B O D Y C O R P O R A T E ) . T I N G N C O r B I ‘ . l W / P n s s p o n N o . _ > N a m e C H A N Y o L ( A l s o s m l e c o l o u r 6 < I y p e m m s o s l a m c o u n t r y ) C o m p a n y N o l fl a g m m l m n N o , A d d r e s s L O L Y M P I A y . . l l I a a A m m / . A . _ N a t i o n a l i t y P l a c e o f I n c o r p o r a t i o n _ 5 0 2 0 0 K U M P U R x I A U S T R A L I A N J I o c c u p m ' m E X E C . S E C . ‘ R A C E ( u M a l a y s i a n ) ; T Y P E O F B O D Y C O R P O R A T E S ' g n e d ' s e a l ” a n d d e l ' v e ' e d m m w fi fi n i : 8 5 w } : 5 3 k . 4 8 , 2 f r _ a M a l a y D G o v e r n m e n t A g e n t : i e s fl n s t i t u l i o n s l s m u m r y E a d i e : S i g n a t u r e 8 ' 5 v y L m m ' 9 4 E Q § } W ' m C h i n e s e D C o m r o l l a d b y M a l a y s i a n s l M a l a v / N u l i v e s ) P g n z i m c I 5 F a : l g ' g a f b x 4 7 A ( 1 ) ‘ r r fi J ) ‘ 1 x m I n d i a n D C o n l r o l l a d b y M a l a y s i a n s [ N o n v M a l a v s / N o n - N a t i v e s ) I S t ” ‘ ” k ” - . . E - i 2 N , 2 , m D l h e l s l S p c c i i y ) D C o n l r u l l c d b y N o n - M a l a y s i a n a N a m e ' V ‘ ‘ “ ' { f ‘ , 7 - E ; f , A d d r e s s H I : “ 2 . ) “ a n ' - i “ g i x . “ 3 > q I a r m M e a r e * n o m i n e e ( s ) o f a p e r s o n r e s i d e n t i n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ( c o u n t r y ) . H _ é ; ‘ L P : 3 4 v - f , ‘ _ ' C 7 . O N S I D E H A T I O N O F T H E S U M H E R E I N M E N T I O N E D . ' I I W E ' , T H E T R A N S F E R O R , H E R E B Y - ' ' u A 7 ' g ‘ f ‘ a ‘ c f [ # e r v a T o T H E T R A N S F E R E E T H E S E C U R I T I E S R E F E R R E D T o I N P A R A G R A P H S 1 A N D 2 H E R E O F o c c u p a ' m " J H D N ’ W - 5 0 / 9 9 0 2 1 0 ” R ’ ' 9 % k ’ J A N D ‘ U W E ‘ , T H E T R A N S F E R E E , H E R E B Y A C C E P T T H E T R A N S F E R O F T H E S A I D S E C U R I T I E S . C o n s i d e r a t i o n S u m ( i n W o r d s ) : R i n g g i t C o n s i d e r a t i o n S u m ( i n R i n g g i t M a l a y s i a ) 4 T h e c o n s i d e r a t i o n s u m s a t f o r t h i n a T v a n s f a r m a y d i f f e r l r o m I h a l w h i c h l h a l i r s l S e l l e r w i l l r a c a i v a i r m é M U M S b y l h e o r i g i n a l b u y e r ; t h e S t a m p O r d i n a n c e r e q u i r e s m a t i n s u c h c a s e s t h e c o n s i d e r a t i o n m o n e y p a i d b y t h e o n e I n s e r t e d i n t h e f o r m , a s r a g u l a l i n g a d v a l a r c m d u t y ( S t a m p O r d i n a n c e 1 9 4 5 ) P l e a s e r e f e r l o i t e r n 3 2 t h ) . F i r s t S c h e d u l e o i t h e S l u m p O r d i n a n c e 1 9 4 9 f u r t h e s t u m p d u x y c h a r g e a b l e o n s a l e o f a n y s m c k . s h a r e s o r m a r k m a b l e s s c u r i u ' e s S I X H U N D R E D T H O U S A N D O N L Y I f t h e t r a n s f o r m o r t r a n s f e r e e i s a b o d y c o y p o r a t e . t h e e x e c u t i o n o f t h i s i n s t r u m e n t m u s t b e d u n e i n a c c o r d a n c e w i t h t h e R M 6 0 O I O 0 O - 0 0 p r o v i s i o n o f l l m c o n s m u l i o n o f i t s i n c o r p o r a t i o n . 8 _ D a t e d t h i s 3 0 T H d a y o f N O V E M B E R , 2 o o O B ’ S t r i k e O u t w h i c h e v e r i s i n a p p l i c a b l e . E A h u s b a n d m u s t n o t w i t n e s s t h e s i g n a t u r e o f h i s w i f e o r v i c e v e r s a COBLENTZ PATCH DUFFY & BASS LLP ONE MONTGOMERY STREET, SUITE 3000, SAN FRANCISCO, CALIFORNIA 94lO4-5500 FAX 4|5.989.|663 4|5.39|.4800 - ©W\IONUI&UJN# NNNNNNNNNr-tr-tr-tr-tr-tr-tr-tr-tr-tr-t WQGNUIhMNHG©WQONUIhMNHO PROOF OF SERVICE Anne Ting, Jack Ting, and Nicole Ting-Yap vs. Panida Chinsupakul Santa Clara County Superior Court Case N0. 21CV381 1 10 STATE OF CALIFORNIA, COUNTY OF SAN FRANCISCO At the time 0f service, I was over eighteen years 0f age and not a party t0 this action. I am employed in the County 0f San Francisco, State 0f California. My business address is One Montgomery Street, Suite 3000, San Francisco, California 94104-5500. On July 9, 2021, I served true copies 0f the foregoing document described as NOTICE OF ERRATA REGARDING DECLARATIONS FILED IN SUPPORT OF PLAINTIFFS’ EX PARTE APPLICATION FOR TEMPORARY RESTRAINING ORDER AND ORDER TO SHOW CAUSE WHY PRELIMINARY INJUNCTION SHOULD NOT ISSUE 0n the interested parties in this action as follows: Attorney for Defendant Panida Chinsupakul: Michael G. Ackerman, Esq. The Law Offices 0f Michael G. Ackerman 2391 The Alameda, Suite 100 Santa Clara, California 95050 Telephone: 408.261.5800 Facsimile: 408.261.5900 E-Mail: mga@mgackermanlaw.com sls@mgackermanlaw.com BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy 0f the document t0 be sent from e-mail address rbrown@coblentzlaw.com t0 the persons at the e-mail addresses listed above. I did not receive, within a reasonable time after the transmission, any electronic message 0r other indication that the transmission was unsuccessful. I declare under penalty 0f perjury under the laws 0f the State 0f California that the foregoing is true and correct. Executed 0n July 9, 2021, at San Francisco, California. @Wfi/MWV Robert Brown 18786.001 4810-4941 -3 873.1 Case No. 21CV381 1 10 NOTICE OF ERRATA RE DECLARATIONS IN SUPPORT OF EX PARTE APPLICATION