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WEST\285762686.4
CTC GLOBAL CORPORATION’S REPLY TO DEFENDANTS OPPOSITION
TO PLAINTIFF’S MOTION FOR DEFAULT JUDGMENT
TAMANY J. VINSON BENTZ (SBN 258600)
tamany.bentz@dlapiper.com
AARON T. GOODMAN (Pro Hac Vice)
aaron.goodman@dlapiper.com
HECTOR E. COREA (SBN 318971)
hector.corea@dlapiper.com
DLA PIPER LLP (US)
2000 Avenue of the Stars
Suite 400 North Tower
Los Angeles, California 90067-4704
Tel: 310.595.3000
Fax: 310.595.3300
Richard J. Frey (SBN 174120)
EPSTEIN BECKER GREEN
1925 Century Park East
Suite 500
Los Angeles, California 90067
Attorneys for Plaintiff and Counterdefendant
CTC GLOBAL CORPORATION
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
CTC GLOBAL CORPORATION, a
Delaware corporation,
Plaintiff,
v.
JASON HUANG, an individual,
RULONG CHENG, an individual;
and JIANPING HUANG a/k/a
JAMES HUANG, an individual,
Defendant.
CASE NO. 8:17-cv-02202-AG-KES
CTC GLOBAL CORPORATION’S
REPLY TO DEFENDANTS’
OPPOSITION TO PLAINTIFF’S
MOTION FOR DEFAULT
JUDGMENT OR, IN THE
ALTERNATIVE, FOR SANCTIONS
[DKT. NO. 168]
JASON HUANG, an individual,
Counterclaimant,
v.
CTC GLOBAL CORPORATION, a
Delaware Corporation,
Counterdefendant.
Date: April 1, 2019
Time: 10:00 a.m.
Courtroom: 10D
Complaint Filed: December 18, 2017
Trial Date: May 7, 2019
Case 8:17-cv-02202-AG-KES Document 193 Filed 03/25/19 Page 1 of 14 Page ID #:17950
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CTC GLOBAL CORPORATION’S REPLY TO DEFENDANTS OPPOSITION
TO PLAINTIFF’S MOTION FOR DEFAULT JUDGMENT
TABLE OF CONTENTS
Page
THE CRAIN REPORT AND KUNKEL DECLARATIONS ARE ADMISSIBLE
EVIDENCE THE COURT CAN RELY ON........................................................ 1
RELEVANT EVIDENCE WAS DESTROYED .................................................. 3
A. Relevant WeChat Messages Have Been Destroyed .............................. 3
B. Relevant Evidence Was Deleted From the iPad ........ .................... 5
C. Relevant Evidence Was Destroyed When JASONPC was Donated ..... 7
D. Relevant Evidence Was Destroyed On USB Drives ............................. 8
E. There is Relevant Evidence In the DropBox Account ....... .................. 9
DEFAULT IS THE APPROPRIATE SANCTION .............................................. 9
CONCLUSION ........................................................................................... 10 Case 8:17-cv-02202-AG-KES Document 193 Filed 03/25/19 Page 2 of 14 Page ID #:17951
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CTC GLOBAL CORPORATION’S REPLY TO DEFENDANTS OPPOSITION
TO PLAINTIFF’S MOTION FOR DEFAULT JUDGMENT
TABLE OF AUTHORITIES
Page(s)
Cases
Apple Inc. v. Samsung Elecs. Co.,
888 F. Supp. 2d 976 (N.D. Cal. 2012) ................................................................. 3
Kelly v. Echols,
Case No. CIV-F-05-118 AWI DLB, 2008 WL 4163221 (Sept. 4,
2008) ........................................................................................................ 2
Leon v. IDX Systems Corp.,
464 F.3d 951 (9th Cir. 2006) ................................................................ passim
Smith v. City of Oakland,
Case No. C-05-4045 EMC, 2007 WL 2288328 (N.D. Cal. Aug. 9,
2007) ........................................................................................................ 2
Travelers Casualty and Surety Co. v. Telstar Construction Co., Inc.,
252 F.Supp.2d 917 (D. Ariz. 2003) .............................................................. 2
Other Authorities
Fed. R. Civ. P. 55 ................................ .......................................................... 2
Rule 26(a) ........................................................................................................... 1
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CTC GLOBAL CORPORATION’S REPLY TO DEFENDANTS OPPOSITION
TO PLAINTIFF’S MOTION FOR DEFAULT JUDGMENT
It is undisputed that every device that CTC did not take immediate possession
of was destroyed—JASONPC was donated, USB drives were thrown in the trash,
and the iPad was set back to factory settings. Even what CTC could immediately
take possession of was not complete because the WeChat application was erased from
the CTC iPhone.
Defendants do not contest that beginning in August 2016, they had a duty to
preserve evidence relevant to this dispute. Defendants do not dispute that Jason
Huang and Rulong Chen destroyed electronic data on these multiple devices after
August 2016. Since Defendants cannot contest their duty or the destruction of data,
they simply downplay the importance of the evidence that was destroyed.
Defendants’ position ignores the evidence in the record that there would have
been relevant evidence in what was destroyed. Defendants also conveniently ignore
that in the Ninth Circuit there is a presumption that the destroyed evidence goes to
the merits of the case and is adverse to the party tha destroyed it. Defendants have
failed to rebut this presumption with evidence. Rather, the evidence of record
indicates that the WeChats, iPad, USB drives, and JASONPC were sources of
relevant information. CTC was denied any chance to r view the relevant information
on these devices because Defendants knowingly and intentionally destroyed the data
after August 2016.
Defendants destruction of multiple devices has hampered CTC’s claims and
this Court’s ability to determine this case. Defenda ts have engaged in the deliberate
destruction of evidence and must be sanctioned. For the reasons set forth herein and
in CTC’s Motion, default judgment is the appropriate sanction.
THE CRAIN REPORT AND KUNKEL DECLARATIONS ARE
ADMISSIBLE EVIDENCE THE COURT CAN RELY ON
Defendants contend that the Court cannot rely on the Declaration of Michael
Kunkel because he was not identified on a Rule 26(a) disclosure. Defendants are
mistaken. Mr. Kunkel was identified on CTC’s Amendd Rule 26(a) disclosures on
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CTC GLOBAL CORPORATION’S REPLY TO DEFENDANTS OPPOSITION
TO PLAINTIFF’S MOTION FOR DEFAULT JUDGMENT
February 1, 2019. (See Declaration of Tamany Vinson Bentz at ¶ 2, Ex. A.)
However, this was not the first time Mr. Kunkel was di closed as a witness. In
November 2018, CTC provided Defendants with Mr. Kunkel’s “highly detailed”
declaration—the very same “highly detailed” declaration that was filed with CTC’s
motion. (See Doc. 97-1, Defendants’ Br. at 2:24-6 (“CTC’s new Motion is now
accompanied by a highly detailed 6-page, 15-paragraph Declaration dated November
21, 2018 from an individual named Michael Kunkel.”)) To argue that this Court
should not consider Mr. Kunkel’s declaration when Defendants have been in
possession of that declaration for months strains Defendants’ credibility.
Defendants also argue that this Court should disregard the expert report and
supplemental expert report from Andrew Crain. Defendants’ objection to Mr.
Crain’s report is purely procedural as they do not contest his ability to testify as an
expert or discuss the evidence in his report. Defendants also fail to cite a single case
refusing to consider an expert report in this context. See Travelers Casualty and
Surety Co. v. Telstar Construction Co., Inc., 252 F.Supp.2d 917 (D. Ariz. 2003)
(finding a declaration insufficient for lack of foundation, but not discussing expert
reports); Kelly v. Echols, Case No. CIV-F-05-118 AWI DLB, 2008 WL 4163221
(Sept. 4, 2008) (considering motion for summary judgment and not sanctions); Smith
v. City of Oakland, Case No. C-05-4045 EMC, 2007 WL 2288328 (N.D. Cal. Aug.
9, 2007) (considering motion for summary judgment and not sanctions). The issue
at hand is not an issue of summary judgment, as requests for default are governed by
Fed. R. Civ. P. 55, not 56. Furthermore, Mr. Crain’s report should not be considered
hearsay because Defendants have deposed Mr. Crain and had the chance to cross
examine him on the report.1 Mr. Crain, moreover, adopted and affirmed his repo t
during that deposition.
Even if the Court were to disregard Mr. Crain’s exprt report, there is still
1 CTC was unable to cite to the deposition in their brief because the transcript was
not received until two days after the brief was due. (Bentz Decl. at ¶ 5.)
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CTC GLOBAL CORPORATION’S REPLY TO DEFENDANTS OPPOSITION
TO PLAINTIFF’S MOTION FOR DEFAULT JUDGMENT
sufficient evidence to find willful spoliation, including Defendants sworn
declarations, Defendants’ testimony, Mr. Kunkel’s declaration, and Mr. Crain’s
deposition in which he gave sworn testimony regarding his report.
RELEVANT EVIDENCE WAS DESTROYED
It is undisputed that Defendants had a duty to preserve evidence by at least
August 2016. It is also undisputed that Defendants destroyed data after August 2016.
For instance, it is undisputed that Rulong threw away USB drives after August 2016;
Jason donated JASONPC after August 2016 (thereby rende ing it unavailable to
anyone for analysis); Rulong set an iPad back to factory settings after August 2016
(thereby deleting all the data on the iPad); and Jason’s WeChat application was
deleted from his iPhone around August 2016, during the time period CTC was
investigating his involvement with James’s patent.
Under these circumstances, there is a presumption that relevant evidence was
destroyed. “In the Ninth Circuit, spoliation of evidence raises a presumption that the
destroyed evidence goes to the merits of the case, and further, that such evidence was
adverse to the party that destroyed it.” Apple Inc. v. Samsung Elecs. Co., 888 F. Supp.
2d 976, 993 (N.D. Cal. 2012). Moreover, “because ‘th relevance of … [destroyed]
documents cannot be clearly ascertained because the documents no longer exist,’ a
party ‘can hardly assert any presumption of irrelevance as to the destroyed
documents.’” Leon v. IDX Systems Corp., 464 F.3d 951, 959 (9th Cir. 2006). Here,
there is no way to know what was on the devices that Defendants destroyed and,
accordingly, Defendants are not entitled to a the benefit of the doubt in this case.
A. Relevant WeChat Messages Have Been Destroyed
Defendants try to overcome the presumption that relevant WeChats were
destroyed by arguing that the evidence is available from other sources, but
Defendants’ position is not supported by the evidence.
Defendants contend that WeChat is a cloud-based applic tion and the deletion
of the application from one device does not destroy the messages. (Doc. 178 at 13.)
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CTC GLOBAL CORPORATION’S REPLY TO DEFENDANTS OPPOSITION
TO PLAINTIFF’S MOTION FOR DEFAULT JUDGMENT
Defendants’ own testimony contradicts this argument. Jason stated, in a sworn
declaration, that “WeChat messages can only be accessed on the devices through
which such messages were originally sent.” (Doc. 73, Jason Huang Declaration at ¶
4 (November 16, 2018)). Jason also testified that he cannot access the WeChat
account that was on the CTC phone anymore. (Bentz Decl. at ¶ 3, Ex. B, Jason Depo
Tr. at 84:2-84:11.) If WeChat was indeed a cloud based program that users could
access from any device, then Jason would still be al to access the program.
Importantly, very few WeChats were produced by Defendants and no WeChats were
produced by Defendants dated prior to December 2016. (Bentz Decl. at ¶ 4). The
testimony of Mr. Crain that Defendants rely on for their proposition does not
contradict Jason’s testimony or support their argument. Mr. Crain testified that there
was some synchronization in the WeChat system, but he did not know, for instance,
how long messages were kept by the system. (Bentz Dec. at ¶ 5, Ex. C, Crain Depo
at 78:9-79:7.)
Defendants also contend, without evidence or any citation, that the messages
could have been made available by WeChat. There is no evidence of record that
messages could be obtained from WeChat, nor do Defendants contend they made any
effort to collect messages from WeChat, or try to gain access to the account they
suddenly claim is based in the cloud. If Defendants are not willing to take these steps
to collect their own information, they cannot minimize their own spoliation by
contending CTC should have taken these steps.
Defendants next contend that CTC’s expert admitted that no WeChats were
deleted from the phone. This is false and contradicte by all of the evidence of
record. CTC’s expert in his deposition and in his report acknowledges that the entire
WeChat application was deleted. (Bentz Decl. at ¶ 5, Ex. C, Crain Depo. at 18:5-12;
Doc. 169-1 at 16.) Therefore, any messages between June 2016,2 when the phone
2 Defendants refer to a September 2016 back-up. There is no September 2016
back-up. (Bentz Dec. at ¶ 5, Ex. C, Crain Depo. at 19:5-12.) Defendants’
statement relies on a single question CTC’s counsel asked during Jason’s
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CTC GLOBAL CORPORATION’S REPLY TO DEFENDANTS OPPOSITION
TO PLAINTIFF’S MOTION FOR DEFAULT JUDGMENT
was backed-up on the laptop, and December 2016, when CTC confiscated the phone,
are gone. The testimony Defendants rely on for this statement does not contradict
CTC’s position, as Mr. Crain unequivocally said “we obviously have a gap in
available messages and the removal of the app from the phone.” (Bentz Dec. at ¶ 5,
Ex. C, Crain Depo. at 79:13-15.) Mr. Kunkel moreov r stated this fact in his
declaration that “[a]n examination of the iPhone revealed it no longer contained the
WeChat application, and additional messages were not rec verable.” (Doc. 111 at ¶
8.) Thus, the evidence that there are missing WeChat messages comes from two
independent experts and Defendant Jason Huang himself.
B. Relevant Evidence Was Deleted From the iPad
Defendants contend there is no evidence that the iPad contained relevant
information. Defendants do not address the WeChats t would have been available
on the iPad. Initially, Jason Huang stated under oath that he “never used WeChat on
my iPad.” (See Doc. 127-1, Jason Huang Dec. at ¶ 6 (December 2, 2018).) Then
CTC discovered a 2013 back-up of the iPad, which showed that Jason Huang used
the WeChat application on his iPad. (Bentz Dec. at ¶ 5, Ex. C, Crain Depo. at 20:13-
21:1; Doc. 169-1 at 16:11-16.) When faced with Jason Huang’s misrepresentation,
Defendants take the position that the iPad is irrelevant. Defendants make the bold
statement that the only relevant time period is 2014 and 2015, but this ignores CTC’s
claims and evidence concerning Jason’s work with James that started as early as 2012
(Doc. 169-1 at 4-5). It also ignores the fact that J son contends he raised concerns
relating to CTC’s ACCC™ in 2016, for which he was terminated (Doc. 179-2 at
15:4-5). Accordingly, the relevant time period in this case is 2012 to today, during
which it is undisputed that Jason used the iPad.
It is undisputed that Jason used the WeChat application to correspond with his
brother during this time period. It is the mode of c rrespondence Jason used to tell
deposition wherein the transcript is either incorrect or counsel misspoke and said
“September” instead of “June”.
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CTC GLOBAL CORPORATION’S REPLY TO DEFENDANTS OPPOSITION
TO PLAINTIFF’S MOTION FOR DEFAULT JUDGMENT
James when to file the provisional patent application; what to add to the patent
application and to procure and provide legal advice from CTC’s attorney for his
brother. (Doc. 169-1 at 5-6) Accordingly, WeChats in the 2012-2014 time frame,
when Jason was indisputably working with his brother, would be on the iPad and are
relevant to this dispute. Again, Defendants’ contention that CTC could access those
WeChats from another device, including the iPhone, is contradicted by Jason’s own
testimony that the WeChat’s could not be accessed by another device. (Doc. 73,
Jason Huang Declaration at ¶ 4 (November 16, 2018).)
Defendants also state that the iPad was reset and given to Rulong’s parents
prior to 2015, but there is no corroborating evidence that Rulong’s parents ever used
the iPad. For instance, there is no declaration frm her parents stating that they used
the iPad. Rulong’s parents have never even been idntified in this case. Furthermore,
Rulong testified she was not aware of anyone else using the iPad:
Q Do you recall anybody other than Mr. Huang who would have used
his iPad?
A You asked me if anyone could use his iPad?
Q No. I asked if you recall anyone using it.
A I don't recall he let other people use his iPad. I on't see it. I didn't
see it.
Q When was the last time you saw Mr. Wang's[sic] iPad?
A When was the last time I saw Mr. Wang's[sic] iPad? The day when
I returned that iPad to CTC.
(Bentz Dec. at ¶ 6, Ex. D, Rulong Depo. at 94:5-14.) Notably, there is no
corroborating evidence on the device itself because any data on the device was
completely destroyed.
Defendants further argue that resetting the iPad back to factory settings does
not matter because it was a personal device. Whether the device was owned by
Defendants or not is irrelevant—the question at hand is whether the Defendants can
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CTC GLOBAL CORPORATION’S REPLY TO DEFENDANTS OPPOSITION
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rebut the presumption that the iPad had relevant evidence on it when it was set back
to factory settings by Rulong. The evidence of reco d indicates that it would have
contained Jason’s communications during a relevant time period and relating to his
work for CTC.
C. Relevant Evidence Was Destroyed When JASONPC was Donated
Defendants contend that the destruction of JASONPC does not matter because
it was used only for personal reasons and never synced with his work iPhone.
Information can be relevant even if it is personal, especially in employment disputes
like this one. See Leon v. IDX Sys. Corp., 464 F.3d 951, 959 (9th Cir. 2006).
Defendants nonetheless ignore all of the evidence idicating that JASONPC was a
significantly important piece of this puzzle. It is undisputed it was in use during the
critical time periods. (Bentz Decl. at ¶ 7, Ex. E, Jason Huang Decl. at ¶ 3.e. (January
25, 2019).) Forensic evidence shows it had relevant information because it was
synced with Jason’s iPhone. (Dkt. No. 111, Kunkel Dcl. ¶¶ 8, 14-15.) Defendants
repeatedly deny that it was synced but they have no evidence to support their position
(and any evidence was destroyed when JASONPC was donated). Additionally, Jason
testified that he corresponded with his brother via an email account he accessed from
JASONPC. (Doc. 168-2 at ¶ 5, Huang Depo., 154:24-156:18.) What Jason
transferred to his personal computer and his communications with his brother are
highly relevant to the disputes in this case.
All of the data on JASONPC was destroyed when the computer was
purportedly donated to Goodwill in January 2017. (Dkt. No. 127-1, Huang Decl. ¶
8.) Defendants’ contention that there was no spoliati n because the computer was
overheating is legally incorrect, and their story lacks any corroborating evidence.
(Doc. 169-1 at 17-18.)
The evidence Defendants rely on to support their contentions that there were
problems with JASONPC is specious. Initially, Defendants refused to produce
JASONPC for inspection. (Dkt. No 109, Joint Stipulation and Motion to Compel at
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CTC GLOBAL CORPORATION’S REPLY TO DEFENDANTS OPPOSITION
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12-13.) Defendants never mentioned that JASONPC had been donated and was no
longer available. (Dkt. No. 125-1, Declaration of Tamany Bentz in support of CTC’s
Supplemental Memorandum to CTC’s Motion to Compel, ¶ 9.) Defendants waited
until after CTC moved to compel the inspection of JASONPC to disclose that Jason
no longer had JASONPC because he donated it to charity. (Dkt. No. 127-1, Huang
Decl., ¶ 8.) Initially Jason claimed it was donated because it was “routinely
overheating”. Id. Later, Jason took the position that the computer was “overheating
and locking up.” (Bentz Decl. at ¶ 7, Huang Decl. at ¶3.e.) There is no verifiable
evidence of the disposal of JASONPC. Defendants rely on an unauthenticated
encryption recovery key for BitLocker, which says nothing about JASONPC,
overheating, or locking up. (Bentz Decl. at ¶ 5, Ex. C, Crain Depo. at 16:1-16; Doc.
168-2 at ¶ 3, Ex. B, Supplemental Report of Andrew Crain (“Crain Supp. Report”),
¶¶ 7-10.) The document does not even mention Microsoft. Id. Defendants also rely
on a Goodwill receipt, which indicates that not 1 but 2 computers were purportedly
donated to Goodwill by Defendants. (Id. ¶ 11, Ex. K.) There has been no disclosure
of the second computer, even though Jason was ordered to identify all the devices he
used during the relevant time, and no evidence to corroborate the Goodwill receipt.
(Id.)
D. Relevant Evidence Was Destroyed On USB Drives
Defendants admit that Jason used USB drives during the critical time period.
Defendants also admit that Rulong threw out the USB drives after August 2016.
Since Defendants cannot deny the destruction, they assert the unsubstantiated
position that the USB drives only contain promotional materials. Defendants would
have the Court presume that the USB drives do not have relevant information on
them, which is inappropriate as a matter of the law. See Leon, 464 F.3d at 959
(“because ‘the relevance of … [destroyed] documents cannot be clearly ascertained
because the documents no longer exist,’ a party ‘can hardly assert any presumption
of irrelevance as to the destroyed documents’”). There is zero evidence that the USB
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CTC GLOBAL CORPORATION’S REPLY TO DEFENDANTS OPPOSITION
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drives contain only promotional materials. Defendants cite to Rulong, but she
testified she did not look at the USB drives before disposing of them. (Doc. 168-2 at
¶ 4, Chen Depo. at 75:21-76:19 (“After I and Jason were terminated, we [threw] away
all those USB drives.”). The evidence destroyed when the USB drives were thrown
out is laid out in CTC’s brief and remains uncontested. (Doc. 169-1 at 18-19.)
E. There is Relevant Evidence In the DropBox Account
Defendants contend there can be no spoliation with respect to the Dropbox
account because there is a log that shows whether any file uploaded to the Dropbox
account was removed from the laptop. (Doc. 178 at 13:13-15). Defendants do not
cite any evidence to support their contention that ere is a log. Defendants cannot
cite any evidence of such a log because such logs d not exist in a Dropbox account.
(See Declaration of Andy Crain at ¶ 7.) Moreover, without access to the Dropbox
account, CTC cannot tell what other devices were synched to the Dropbox—for all
CTC can tell, it was synched to JASONPC or a computer owned by Jason Huang.
(Bentz Decl. at ¶ 5, Ex. C, Crain Depo. at 69:1-23.)
DEFAULT IS THE APPROPRIATE SANCTION
CTC’s brief sets forth, in detail, the elements necessary to establish that default
judgment is an appropriate sanction under Ninth Circuit precedent. Defendants
contend that CTC must show the missing evidence is “cr tical” to show prejudice.
Defendants misstate the legal standard. “The prejudice inquiry ‘looks to whether the
[spoiling party’s] actions impaired [the non-spoiling party’s] ability to go to trial or
threatened to interfere with the rightful decision n this case.’” Leon, 464 F.3d 959
(citations omitted). It cannot be disputed that the destruction of whole devices that
were in use during the critical time periods threatens to interfere with the rightful
decision in this case. Moreover, there is evidence that the destroyed devices would
have contained relevant information because they were used for important
communications between Defendants and with third parties, or because they were
linked to CTC’s devices and CTC cannot tell how much and what information was
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CTC GLOBAL CORPORATION’S REPLY TO DEFENDANTS OPPOSITION
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transported by Defendants from CTC’s system. Indeed, these issues and this
evidence are referenced repeatedly through CTC’s Opposition to Defendants’ Motion
for Summary Judgment.
Defendants next argue there is no showing of bad faith or willful spoliation.
Defendants misunderstand the standard for bad faith. “A party’s destruction of
evidence qualifies as willful spoliation if the party has ‘some notice that the
documents were potentially relevant to the litigation before they were destroyed.’”
Leon, 464 F.3d at 959 (emphasis in original). Here, Defendants not only failed to take
proper steps to preserve evidence – they actively dstroyed it. (Doc. 169-1 at 21.)
Every source of evidence from Defendants that CTC did not take immediate
possession of was destroyed. Tellingly, almost all of the documents produced by
Defendants came from Rulong’s .pst file of CTC emails, which she was asked to
return in December 2016—Defendants produced almost n documents from any
other sources. (Bentz Dec. at ¶¶ 8-10). Defendants conduct occurred after they had
a duty to preserve evidence. (Doc. 169-1 at 12-15.) CTC requested that Jason and
Rulong return CTC’s information on December 6, 2016. Defendants made no effort
to return any information. (Doc. 169-1 at 14.) Instead, they systematically destroyed
evidence.
Defendants next contend that this issue has not consumed Court resources until
this motion. This is untrue. The parties have been litigating discovery disputes
involving Defendants’ data and failure to produce throughout the discovery period
of this case. The Magistrate Judge previously heldthree hearings concerning the loss
of JASONPC and evidence of spoliation. (Docs. 133, 137, 159)
CONCLUSION
Defendants had a pattern and practice of destroying evidence at critical time
periods in this case. Defendants must be sanctioned for this conduct, and given the
scope of deleted evidence, the only sanction appropriate is default judgment.
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CTC GLOBAL CORPORATION’S REPLY TO DEFENDANTS OPPOSITION
TO PLAINTIFF’S MOTION FOR DEFAULT JUDGMENT
Dated: March 25, 2019 DLA PIPER LLP (US)
By:/s/ TAMANY J. VINSON BENTZ
TAMANY J. VINSON BENTZ
AARON T. GOODMAN
HECTOR E. COREA
Attorneys for Plaintiff
CTC GLOBAL CORPORATION
Case 8:17-cv-02202-AG-KES Document 193 Filed 03/25/19 Page 14 of 14 Page ID
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