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Zhang Ziyi v. China Free Press Inc et al

REPLY In Support MOTION for Bond Security Under CCP 1030 43

10 Cited authorities

  1. Zamani v. Carnes

    491 F.3d 990 (9th Cir. 2007)   Cited 1,184 times
    Holding that a district court "need not consider arguments raised for the first time in a reply brief"

  2. Batzel v. Smith

    333 F.3d 1018 (9th Cir. 2003)   Cited 367 times   17 Legal Analyses
    Holding that the denial of an anti-SLAPP motion is appealable under § 1291

  3. Simulnet East Assoc. v. Ramada Hotel Operating

    37 F.3d 573 (9th Cir. 1994)   Cited 106 times   1 Legal Analyses
    Discussing factors district courts should balance before imposing a security bond

  4. Baltayan v. Estate of Getemyan

    90 Cal.App.4th 1427 (Cal. Ct. App. 2001)   Cited 61 times
    Noting that a defendant is "not required to show that there [is] no possibility that [the plaintiff] could win at trial, but only that it [is] reasonably possible that [the defendant will] win"

  5. Aggarwal v. Ponce School of Medicine

    745 F.2d 723 (1st Cir. 1984)   Cited 80 times
    Observing that "[m]odern litigation practices being what they are, the monetary demand which caps a plaintiff's complaint is likely to be sanguine at best"

  6. Gabriel Technologies Corp. v. Qualcomm Inc.

    CASE NO. 08 CV 1992 MMA (POR) (S.D. Cal. Sep. 20, 2010)   Cited 4 times
    In Gabriel Technologies Corp. v. Qualcomm Inc., 2010 WL 3718848, at *2 (S.D.Cal. Sept. 20, 2010), at issue was “over $1 billion in damages.

  7. Rule 12 - Defenses and Objections: When and How Presented; Motion for Judgment on the Pleadings; Consolidating Motions; Waiving Defenses; Pretrial Hearing

    Fed. R. Civ. P. 12   Cited 362,910 times   962 Legal Analyses
    Granting the court discretion to exclude matters outside the pleadings presented to the court in defense of a motion to dismiss

  8. Rule 5 - Serving and Filing Pleadings and Other Papers

    Fed. R. Civ. P. 5   Cited 23,556 times   16 Legal Analyses
    Providing for service via CM/ECF Systems

  9. Section 425.16 - [Effective 1/1/2025] California anti-SLAPP law

    Cal. Code Civ. Proc. § 425.16   Cited 3,008 times   110 Legal Analyses
    Reversing district court's denial of anti-SLAPP motion as moot and remanding for consideration of the motion, including attorney's fees

  10. Section 1030 - Motion for plaintiff residing out of state or foreign corporation to file undertaking securing costs in special proceeding

    Cal. Code Civ. Proc. § 1030   Cited 121 times   1 Legal Analyses

    (a) When the plaintiff in an action or special proceeding resides out of the state, or is a foreign corporation, the defendant may at any time apply to the court by noticed motion for an order requiring the plaintiff to file an undertaking to secure an award of costs and attorney's fees which may be awarded in the action or special proceeding. For the purposes of this section, "attorney's fees" means reasonable attorney's fees a party may be authorized to recover by a statute apart from this section