OrderCal. Super. - 6th Dist.March 24, 202121 CV381 1 10 Santa Clara - Civil EFfimiaga ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NO.: FOR COURT USE ONLY NAME; Scott Hall (232492) Skye Langs (287908) Emlyn Mandel (310403) FIRM NAME: Coblentz Patch Duffy & Bass LLP STREET ADDRESS: One Montgomery Street, Suite 3000 CITY: san FranCiSCO STATE: CA z|P CODE: 94104 TELEPHONENOJ (415) 391-4800 FAXNO; (415) 989-1663 on 1/10/2022 11:24 AM E-MAILADDRESS;ef-sch@cpdb.com; ef-sdl@cpdb.com; ef-erm@cpdb.com Reviewed By: R. Burciaga ATTORNEY Fomname): Plaintiffs Anne Ting, Jack Ting, and Nicole Ting-Yap case #21 cv381 1 1 o SUPERIOR COURT 0F CALIFORNIA, COUNTY 0F Santa Clara Env l : 21 1 STREETADDREss: 191 North First Street e ope 80 03 MAILING ADDRESS: CITY AND ZIP CODE: San Jose 951 13 BRANCH NAME; Downtown Superior Court CASE NUMBER; . - - - - 21 CV381 1 1 0 PLAINTIFF/PETITIONER. Anne Ting, Jack Tlng and Nicole TIng-Yap . ' ' JUDICIAL OFFICER: DEFENDANT/RESPONDENT. Panlda Chlnsupakul Hon. Christopher Rudy OTHER: DEPT: PROPOSED ORDER (COVER SHEET) 7 NOTE: This cover sheet is to be used to electronically file and submit to the court a proposed order. The proposed order sent electronically to the court must be in PDF format and must be attached to this cover sheet. In addition, a version ofthe proposed order in an editable word-processing format must be sent to the court at the same time as this cover sheet and the attached proposed order in PDF format are filed. 1. Name of the party submitting the proposed order: Plaintiffs Anne Ting, Jack Ting and Nicole Ting-Yap 2. Title ofthe proposed order: [Proposed] Order After Hearing Granting Motion for Protective Order Regarding the Deposition of Nicole Ting-Yap 3. The proceeding to which the proposed order relates is: Hearing for Protective Order Regarding the Deposition of Nicole Ting-Yap a. Description of proceeding: Granting protective order regarding the deposition of Nicole Ting-Yap b. Date and time: January 6, 2022, 9:00 a.m. c. Place: Santa Clara County Superior Court, Dept. 7 4. The proposed order was served on the other parties in the case. Michael G. Ackerman, Attorney for Defendant Panida Chinsupakul. NOTE: Defendant objects to the last line of the Proposed Order, which reads "This Order is without prejudice regarding the scope or relevance of written discovery that was not the subject of the Motion for Protective Order Regarding the Deposition of Nicole Ting-Yap." Defendant proposed alternative language which would read "This is order pertains or relates to discovery that is relevant to the family law matter (Chinsupakul v. Ting, Case number 20-FL- 003262) and does not affect or limit Defendant’s right to conduct discovery in defense of the claims pled against her in this matter." Emlyn Mandel V Farm WY“MW (TYPE OR PRINT NAME) (SleATURE OF PARTY OR ATTORNEY) Page 1 of 2 Form Adopted for Mandatory Use PROPOSED ORDER (COVER SH EET) Cal. Rules of Court, Judicial Council of California . . . rules 2.252, 3.1312 EFS-020 [Rev. February 1, 2017] (EleCtronlc Flllng) www.courts.ca.gov American LegalNet, Inc. www‘FomlsWorkl-‘lowxom _ EFS-020 CASE NAME: CASE NUMBER: Anne Ting, et al. v. Panida Chinsupakul 21CV381 110 PROOF OF ELECTRONIC SERVICE PROPOSED ORDER 1. | am at least 18 years old and not a party to this action. a. My residence or business address is (specify): Coblentz Patch Duffy & Bass LLP One Montgomery Street, Suite 3000 San Francisco, CA 94104 b. My electronic service address is (specify): dcampos@coblentzlaw.com 2. | electronically served the Proposed Order (Cover Sheet) with a proposed order in PDF format attached, and a proposed order in an editable word-processing format as follows: a. On (name ofperson served) (If the person served is an attorney, the party orpariies represented should also be stated): Michael G. Ackerman, Attorney for Defendant Panida Chinsupakul b. To (electronic service address ofperson served): mga@mgackermanlaw.com; sls@mgackerman|aw.com c. On (date): January 10, 2022 DElectronic service of the Proposed Order (Cover Sheet) with the attached proposed order in PDF format and service of the proposed order in an editable word-processing format on additional persons are described in an attachment. | declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Date: January 10, 2022 Diana Campos P [(24% flM/® (TYPE OR PRINT NAME OF DECLARANT) (SIGNATURE OF DECLARANT) EFS-020 [Rev. February 1, 2017] PROPOSED ORDER (COVER SHEET) Pagezofz (Electronic Filing) American LegalNet, Inc. www,FormsWorkF10w.com COBLENTZ PATCH DUFFY & BASS LLP ONE MONTGOMERY STREET, SUITE 3000, SAN FRANCISCO, CALIFORNIA 94lO4-5500 FAX 4|5.989.|883 4|5.39|.4800 \OWQQUIhMNH NNNNNNNNNHHHHHHHHHH WQONUIhbJNH©©WQONUIhMNHG SCOTT C. HALL (State Bar N0. 232492) SKYE LANGS (State Bar No. 287908) EMLYN MANDEL (State Bar No. 310403) Filed COBLENTZ PATCH DUFFY & BASS LLP January 1 1, 2022 One Montgomery Street, Suite 3000 Clerk Of the Court San Francisco, California 94104-5500 Superior Court Of CA gelephfifinei jigflggé‘ggg County of Santa Clara acs1m1 e: . . Email: ef-sch@cpdb.com 21 CV381 1 10 ef-sdl@cpdb.com By: raragon 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, Case No. 2 1 CV381 1 10 an individual; and NICOLE TING-YAP, an individual, fPRGPO‘S-EBTORDER AFTER HEARING GRANTING MOTION FOR Plaintiffs, PROTECTIVE ORDER REGARDING THE DEPOSITION OF NICOLE TING- V. YAP PANIDA CHINSUPAKUL, an individual; Action Filed: March 24, 2021 and DOES 1 through 10, Trial Date: None Set Defendants. Plaintiff s Motion for Protective Order Regarding the Deposition 0fNicole Ting-Yap came 0n for hearing before this Court on January 6, 2022 at 9:00 am. After full consideration of the matter, this Court finds as follows: No opposition was filed. A failure t0 oppose a motion may be deemed a consent t0 the granting 0f the motion. Cal. R. Ct. 8.54(c). The relief requested is consistent with the Court’s ruling of 12/16/2021 denying Defendant’s motion t0 compel. Good cause appearing, Plaintiffs Motion for a Protective Order Regarding the Deposition 0fNicole Ting-Yap is GRANTED. IT IS THEREFORE ORDERED that a protective order is issued prohibiting deposition questioning ofNicole Ting-Yap on the following topics: 18786.001 4863-2365-00563 1 Case No. 21CV381 1 10 -[-PR9PO-SEB-]- ORDER AFTER HEARING GRANTING MOTION FOR PROTECTIVE ORDER REGARDING THE DEPOSITION OF NICOLE TING-YAP COBLENTZ PATCH DUFFY & BASS LLP ONE MONTGOMERY STREET, SUITE 3000, SAN FRANCISCO, CALIFORNIA 94lO4-5500 FAX 4|5.989.|883 4|5.39|.4800 \OWQQUIhMNH NNNNNNNNNHHHHHHHHHH WQONUIhbJNH©©WQONUIhMNHG (1) the finances, financial statements, records 0r reports, shareholder reports, tax returns or tax payments, minutes, resolutions, agreements, contracts, assets, loans, cash distributions or transfers, asset distributions or transfers, identity of shareholders 0r trustees, share transfers, or payments made by or received by the entities for Which any Plaintiff was a shareholder, director, 0r custodian 0f records, including, but not limited to, J.C.T. Holdings Sdn Bhd and Setima Sdn Bhd, and/or the Ting Family Trust; (2) loans, transfers, 0r gifts purportedly made t0 Julian Ting by Plaintiffs, J.C.T. Holdings, Setima, the Ting Family Trust, or any entity for which Plaintiffs are shareholders, directors, and/or custodians 0f record; (3) Plaintiffs' personal financial affairs, including financial accounts, assets, ownership interests in various entities, investments and real estate holdings, and other information divulging details of personal wealth and net worth, including Which financial institutions, advisers, consultants, auditors, accountants, lawyers, and/or other agents help manage her personal finances and financial affairs; (4) The ownership, structure, assets, or identity of shareholders, trustees, directors, and/or beneficiaries 0f J.C.T. Holdings, Setima, and/or the Ting Family Trust; (6) Plaintiffs' personal information, including but not limited to regarding family members, counseling sessions, and photographs; (7) Third-parties' private information, including information concerning Plaintiff Ting- Yap's children and employees, and the identity of any third-party business or government contacts; and (8) Third-parties' private financial information, including information concerning Plaintiff Ting-Yap's in-laws, and other members of her family, including Julian Ting. This Order is Without prejudice regarding the scope 0r relevance 0f written discovery that was not the subj ect 0f the Motion for Protective Order Regarding the Deposition of Nicole Ting- Yap. / / / / / / 18786.001 4863-2365-00563 2 Case No. 21CV381 1 10 'fPRGPG'SEB-fORDER AFTER HEARING GRANTING MOTION FOR PROTECTIVE ORDER REGARDING THE DEPOSITION OF NICOLE TING-YAP COBLENTZ PATCH DUFFY & BASS LLP ONE MONTGOMERY STREET, SUITE 3000, SAN FRANCISCO, CALIFORNIA 94lO4-5500 FAX 4|5.989.|883 4|5.39|.4800 \OWQQUIhMNH NNNNNNNNNHHHHHHHHHH WQONUIhbJNH©©WQONUIhMNHG IT IS SO ORDERED. Dated; January 10, 2022 18786.001 4863-2365-0056.3 3 fl 1/10/2022 04:2 Hon. ChristopherW Judge of the Superior Court Case N0. 21CV381110 'fPROPOSEB'] ORDER AFTER HEARING GRANTING MOTION FOR PROTECTIVE ORDER REGARDING THE DEPOSITION OF NICOLE TING-YAP
