HomeMy WebLinkAboutSubpoena_Hsia Lee v Tenant PlanetRECEIVED
MAR 1 2 2025
rmWnq Th1n l9Tv (`I ERIC SUBP-010
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Slate Bar number, and address):
FOR COURT•USE ONLY
GARY W. ::SULLIVAN SBN: 103162
1565 THE ALAMEDA, SUITE 100
SAN JOSE, CA 95126
TELEPHONENO.: (408) 971-1340 FAXNO.: (408) 971-0478
31
E-MAIL ADDRESS: tgwSulllvanlaw@gmai1. Dorn
ATTORNEY FOR (Name): KELLY HSIA, JOANNE LEE
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA GLAPA
STREETADDRESS: 191 N. FIRST ST.
MAILING ADDRESS:
SAN JOSE, CA 95113
CITY AND ZIP CODE:
BRANCH NAME:
PLAINTIFF/ PETITIONER: KELLY L.LY HSIA, JOANNE LEE
DEFENDANT/ RESPONDENT: TENANT PLANET, INC., ET AL
DEPOSITION SUBPOENA
CASE NUMBER:
FOR PRODUCTION OF BUSINESS RECORDS 01!!2409440025
THE PEOPLE OF THE STATE OF CALIFORNIA, TO (name, address, and telephone number of deponent, if known):
CUSTODIAN OF REOORDS, OFFICE OFDE CITY OF CUPERTINO 10300 Torre Ave., Cupertino
1. YOU ARE ORDERED TO PRODUCE THE BUSINESS RECORDS described in item 3, as follows 95014 408 777-31
To (name of deposition officer): SAM POLVERINO
On (date): APRIL 16 , 2025 At (time): 10:00am
Location (address): 1565 THE ALAMEDA, SUITE 100, SAN JOSE, CA 95126
Do not release the requested records to the deposition officer prior to the date and time stated above.
a. U by delivering a true, legible, and durable copy of the business records described in item 3, enclosed in a sealed inner
wrapper with the title and number of the action, name of witness, and date of subpoena clearly written on it. The inner
wrapper shall then be enclosed in an outer envelope or wrapper, sealed, and mailed to the deposition officer at the
address In item 1.
b. ® by delivering a true, legible, and durable copy of the business records described in item 3 to the deposition officer at the
witness's address, on receipt of payment in cash or by check of the reasonable costs of preparing the copy, as
determined under Evidence Code section 1563(b).
c. = by making the original business records described in item 3 available for inspection at your business address by the
attorney's representative and permitting copying at your business address under reasonable conditions during normal
business hours.
2. The records are to be produced by the date and time shown in item 1 (but not sooner than 20 days after the issuance of the
deposition subpoena, or 15 days after service, whichever date is later). Reasonable costs of locating records, making them
available or copying them, and postage, if any, are recoverable as set forth in Evidence Code section 1563(b). The records shall be
accompanied by an affidavit of the custodian or other qualified witness pursuant to Evidence Code section 1561.
3. The records to be produced are described as follows (if electronically stored information is demanded, the form or
forms in which each type of information is to be produced maybe specified):
® Continued on Attachment 3.
4. IF YOU HAVE BEEN SERVED WITH THIS SUBPOENA AS A CUSTODIAN OF CONSUMER OR EMPLOYEE RECORDS UNDER
CODE OF CIVIL PROCEDURE SECTION 1985.3 OR 1985.6 AND A MOTION TO QUASH OR AN OBJECTION HAS BEEN
SERVED ON YOU, A COURT ORDER OR AGREEMENT OF THE PARTIES, WITNESSES, AND CONSUMER OR EMPLOYEE
AFFECTED MUST BE OBTAINED BEFORE YOU ARE REQUIRED TO PRODUCE CONSUMER OR EMPLOYEE RECORDS.
DISOBEDIENCE OF THIS SUBPOENA MAYBE PUNISHED AS CONTEMPT BY THIS COURT. YOU WILL ALSO BE LIABLE
FOR THE SUM OF FIVE HUNDRED DOLLARS AND ALL DAMAGES RESULTING FROM YOUR FAILURE TO OBEY.
Date issued: I1ARCII 12, 2025
GARY W. SULLIVAN
(TYPE OR PRINT NAME) (SI NATURE OF PERSON ISSUING SUBPOENA)
ATTORNEY AT LAN
(Proof of service on reverse) Page 1 of 2
Form Adopted for Mandatory Use DEPOSITION SUBPOENA FOR PRODUCTION Code of Civil Procedure, §§2020.410-2020.440;
Judicial Council of California Government Code, § 6a097.1
SUBP-010 (Rev. January 1, 2012) OF BUSINESS RECORDS www.courts.ca.gov
82
Mc -n2!
SHORT TITLE: CASE NUMBER:
HSIA V. TENANT PLANET 24CV440025
ATTACHMENT (Number):
(This Attachment may be used with any Judicial Council form.)
THE FOLLOWING RECORDS IN REGARDS TO REAL PROPERTY COMMONLY KNOWN AS 19461
GREENWOOD DR., APT 1, CUPERTINO, CA 95014, -APN 375 04 033
ANY AND ALL DOCUMENTS FOR THE PERIOD FROM JANUARY 1, 2021 TO THE PRESENT TIME
RELATING TO CORRESPONDENCE WITH THE OWNERS AND PROPERTY MANAGERS OF THE
PROPERTY, INCLUDING BUT NOT LIMITED TO, MADHU RAYABHARI, GOURI RAYABHARI,
TENANT PLANET, INC., RELATING TO CODE COMPLIANCE WARNING LETTERS/INSPECTION
NOTICES, CODE COMPLIANCE INSPECTIONS, CODE COMPLIANCE ORDERS, DOCUMENTS
RELATING TO COMPLIANCE WITH CODE COMPLIANCE ORDERS, PERMIT APPLICATIONS,
PERMITS, CORRESPONDENCE WITH THE AFOREMENTIONED OWNERS, PROPERTY MANAGERS,
FINES
(If the item that this Attachment concerns is made under penalty of perjury, all statements in this
Attachment are made under penalty of perjury.)
Page of
(Add pages as required)
Form Approved for Optional Use ATTACHMENT www.courinfo.ca.gov
Judicial Council of CaliforniaCaf
MC-025 [Rev. July 1, 20091 to Judicial Council Form
SUBP-010
PLAINTIFF/PETITIONER: CASE NUMBER:
DEFENDANT/RESPONDENT:
PROOF OF SERVICE OF DEPOSITION SUBPOENA FOR
PRODUCTION OF BUSINESS RECORDS
1. I served this Deposition Subpoena for Production of Business Records by personally delivering a copy to the person served
as follows:
a. Person served (name):
b. Address where served:
C. Date of delivery:
d. Time of delivery:
e. (1) 0 Witness fees were paid.
Amount: .............. $
(2) Copying fees were paid.
Amount:.............. $
f. Fee for service:................ $
2. I received this subpoena for service on (date):
3. Person serving:
a. Not a registered California process server.
b. California sheriff or marshal.
c. 0 Registered California process server.
d. Employee or independent contractor of a registered California process server.
e. Exempt from registration under Business and Professions Code section 22350(b).
f. 0 Registered professional photocopier.
g. Exempt from registration under Business and Professions Code section 22451.
h. Name, address, telephone number, and, if applicable, county of registration and number:
I declare under penalty of perjury under the laws of the State of (For California sheriff or marshal use only)
California that the foregoing is true and correct. I certify that the foregoing is true and correct.
Date: Date:
(SIGNATURE) (SIGNATURE)
SUBP-010 [Rev. January 1, 20121 DEPOSITION SUBPOENA FOR PRODUCTION Page 2 of 2
OF BUSINESS RECORDS
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SUBP-025
ATTORNEY OR PARTY WITHOUT ATtORNEY (Na a SNfe Belnrgjbb(�r,g�d address):
1
FOR COURT USE ONLY
1565 THE -ALAMEDA, SUITE 100
SAN JOSE, CA 95126
TELEPHONE NO.: (40 8) 971-1340 FAX NO. (Optional):
E-MAIL ADDRESS (Optional): gwsullivanlaw@gmai 1. com
ATTORNEY FOR (Name): KELLY HSIA, JOANNE LEE
SUPERIOR COURT OF CALIFORNIA, COUNTY OF
STREET ADDRESS: 191 N. FIRST STREET
MAILING ADDRESS:
SAN JOSE, CA 95126
CITY AND ZIP CODE:
BRANCH NAME:
PLAINTIFF/ PETITIONER: KELLY HSIA, JOANNE LEE
CASE NUMBER:
DEFENDANT/ RESPONDENTTEL4ANT PLANET, INC. , ET AL
2401440025
NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION
(Code Civ. Proc., §§ 1985.3,1985.6)
NOTICE TO CONSUMER OR EMPLOYEE
TO (name): TENANT PLANET, INC., MADHU RAYABHARI, GOURI RAYABHARI
1. PLEASE TAKE NOTICE THAT REQUESTING PARTY (name�Y HSIA, O'OANNE LEE
SEEKS YOUR RECORDS FOR EXAMINATION
by the parties to this action on (specify date). ApRIL16 , 2025
The records are described in the subpoena directed to witness (specify name and address of person or entity frd7Prwhom records
are sought): OFFICE OF CODE ENFORCEMENT, CITY OF CUPERTINO 10300 Torre Ave. , Cupertino, CA
A copy of the subpoena is attached. 95014 (408) 777-3182
2. IF YOU OBJECT to the production of these records, YOU MUST DO ONE OF THE FOLLOWING BEFORE THE DATE SPECIFIED.
IN ITEM a. OR b. BELOW:
a. If you are a party to the above -entitled action, you must file a motion pursuant to Code of Civil Procedure section 1987.1 to
quash or modify the subpoena and give notice of that motion to the witness and the deposition officer named in the subpoena
at least five days before the date set for production of the records.
b. If you are not a party to this action, you must serve on the requesting party and on the witness, before the date set for
production of the records, a written objection that states the specific grounds on which production of such records should be
prohibited. You may use the form below to object and state the grounds for your objection. You must complete the Proof of
Service on the reverse side indicating whether you personally served or mailed the objection. The objection should not be filed
with the court. WARNING: IF YOUR OBJECTION IS NOT RECEIVED BEFORE THE DATE SPECIFIED IN ITEM 1, YOUR
RECORDS MAY BE PRODUCED AND MAY BE AVAILABLE TO ALL PARTIES.
3. YOU OR YOUR ATTORNEY MAY CONTACT THE UNDERSIGNED to determine whether an agreement can be reached in writing
to cancel or limit the scope of the subpoena. If no such agreement is reached, and if you are not otherwise represented by an
attorney in this action, YOU SHOULD CONSULT AN ATTORNEY TO ADVISE YOU OF YOUR RIGHTS OF PRIVACY.
Date: MARCH 12y 2025
GARY W. SULLIVAN
(TYPE OR PRINT NAME)
(SIGNATURE OF REQUESTING PARTY ATTORNEY)
OBJECTION BY NON-PARTY TO PRODUCTION OF RECORDS
1. 0 I object to the production of all of my records specified In the subpoena.
2. I object only to the production of the following specified records:
3. The specific grounds for my objection are as follows:
Date:
(TYPE OR PRINT NAME)
(SIGNATURE)
(Proof of service on reverse) Page 1 of 2
Form Adopted for Mandatory Use Code of Civil Procedure,
JudlcialCouncilofCalifomia NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION §§ 1985.3.1985.8,
SUBP-025 [Rev. January 1, 2008) 2020.010-2020.510
www.courfs.ca.gov
5UBP-025
PLAINTIFF/ PETITIONER: HSIA CASE NUMBER:
DEFENDANT/ RESPONDENT: TEN rr 24CV440025
rkUU1" Ur a1 kVIGt Uf- NU I IGt I U CUUN5UMtR OR EMPLOYEE AND OBJECTION
(Code Civ. Proc., §§ 1985.3,1985.6)
LIII Personal Service x0 Mail
1. At the time of service I was at least 18 years of age and not a party to this legal action.
2. I served a copy of the Notice to Consumer or Employee and Objection as follows (check either a orb):
a. = Personal service. I personally delivered the Notice to Consumer or Employee and Objection as follows:
(1) Name of person served: (3) Date served:
(2) Address where served: (4) Time served:
b. Ox Mail. I deposited the Notice to Consumer or Employee and Objection in the United States mail, in a sealed envelope
with postage fully prepaid. The envelope was addressed as follows:
(1) Name of person served: JAMES I-KEUEKIC COX, ESU (3) Date of mailing: MARCH J..2,,2U2b
(2) Address: (4) Place of mailing (city and state):
241 KINGS VILLAGE KU., #Ub2ti3, SUU I IS VALLEY, CA SAN JOSE, CA
(5) I am a resident of or employed in the county where the Notice %Consumer or Employee and Objection was mailed.
c. My residence or business address is (specify): 1555 I HE ALAMEUA, SUI lb 1UU„ SAN JOSE, CA 95125
d. My phone number is (specify): (405) 9/1-1340
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Date: MARCH 12, 2025
GARY W. SULLIVAN
(TYPE OR PRINT NAME OF PERSON WHO SERVED) ( GNATURE OF PERSON WHO SERVED)
PROOF OF SERVICE OF OBJECTION TO PRODUCTION OF RECORDS
(Code Civ. Proc., §§ 1985.3,1985.6)
0 Personal Service [] Mail
1. At the time of service I was at least 18 years of age and not a party to this legal action.
2. I served a copy of the Objection to Production of Records as follows (complete either a orb):
a. ON THE REQUESTING PARTY
(1) 0 Personal service. I personally delivered the Objection to Production of Records as follows:
(I) Name of person served: (iii) Date served:
(ii) Address where served: (iv) Time served:
(2) 0 Mail. I deposited the Objection to Production of Records in the United States mail, in a sealed envelope with
postage fully prepaid. The envelope was addressed as follows:
(i) Name of person served: (iii) Date of mailing:
(ii) Address: (iv) Place of mailing (city and state):
(v) I am a resident of or employed in the county where the Objection to Production of Records was mailed.
ON THE WITNESS
(1) = Personal service. I personally delivered the Objection to Production of Records as follows:
(i) Name of person served:
(ii) Address where served:
(iii) Date served:
(iv) Time served:
(2) = Mail. I deposited the Objection to Production of Records in the United States mail, in a sealed envelope with
postage fully prepaid. The envelope was addressed as follows:
(I) Name of person served: (iii) Date of mailing:
(ii) Address: (iv) Place of mailing (city and state):
(v) I am a resident of or employed in the county where the Objection to Production of Records was mailed.
3. My residence or business address is (specify):
4. My phone number is (specify):
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Date:
(TYPE OR PRINT NAME OF PERSON WHO SERVED) (SIGNATURE OF PERSON WHO SERVED)
SUBP-025 (Rev. January1, 20081 NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION Page 2 of 2
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SUBP-025
PLAINTIFF/ PETITIONER: BEIA CASE NUMBER:
DEFENDANT/ RESPONDENT: TENANfI1 24CV440025
rtcuut- UI- StI. VIL;t ut- NO I IGt I U LUNSUMEK OR EMPLOYEE AND OBJECTION
(Code Civ. Proc., §§ 1985.3,1985.6)
Personal Service x0 Mail
At the time of service I was at least 18 years of age and not a party to this legal action.
I served a copy of the Notice to Consumer or Employee and Objection as follows (check either a or b):
a. 0 Personal service. I personally delivered the Notice to Consumer or Employee and Objection as follows:
(1) Name of person served: (3) Date served:
(2) Address where served: (4) Time served:
b. Mail. I deposited the Notice to Consumer or Employee and Objection In the United States mail, in a sealed envelope
with postage fully prepaid. The envelope was addressed as follows:
(1) Name of person served: KIRK HUI-FMAN, ESU. (3) Date of mailing: MARCH J2 2025
(2) Address: (4) Place of mailing (city and state):
2021 I HE ALAMEDA, S 1 E 215, SAN JOSE, CA 9512b SAN JOSE, CA
(5) I am a resident of or employed in the county where the Notice to Consumer or Employee and Objection was mailed.
c. My residence or business address is (specify): 15ti5 I HE ALAMEDA, SUI I E 100„ SAN JOSE, CA 9512(
d. My phone number Is (specify): (4Ud) 9f1 -134U
I declare under penalty of perjury under the laws of the State of California that the foregoing Is true and correct.
Date: MARCH 12, 2025
GARY W. SULLIVAN
(TYPE OR PRINT NAME OF PERSON WHO SERVED) (SIGNATURE OF PERSON WHO SERVED)
PROOF OF SERVICE OF OBJECTION TO PRODUCTION OF RECORDS
(Code Civ. Proc., §§ 1985.3,1985.6)
Personal Service 0 Mail
At the time of service I was at least 18 years of age and not a party to this legal action.
I served a copy of the Objection to Production of Records as follows (complete either a orb):
a. ON THE REQUESTING PARTY
(1) 0 Personal service. I personally delivered the Objection to Production of Records as follows:
(i) Name of person served: (iii) Date served:
(ii) Address where served: (iv) Time served:
(2) = Mail. I deposited the Objection to Production of Records in the United States mail, in a sealed envelope with
postage fully prepaid. The envelope was addressed as follows:
(I) Name of person served: (iii) Date of mailing:
(ii) Address: (iv) Place of mailing (city and state):
(v) I am a resident of or employed in the county where the Objection to Production of Records was mailed.
b. ON THE WITNESS
(1) = Personal service. I personally delivered the Objection to Production of Records as follows:
(I) Name of person served:
(ii) Address where served:
(iii) Date served:
(iv) Time served:
(2) L Mail. I deposited the Objection to Production of Records in the United States mail, in a sealed envelope with
postage fully prepaid. The envelope was addressed as follows:
(I) Name of person served: (iii) Date of mailing:
(ii) Address: (iv) Place of mailing (city and state):
(v) I am a resident of or employed in the county where the Objection to Production of Records was mailed.
3. My residence or business address is (specify):
4. My phone number is (specify):
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Date:
(TYPE OR PRINT NAME OF PERSON WHO SERVED)
(SIGNATURE OF PERSON WHO SERVED)
SUBP-025 [Rev. January 1, 2008] NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION
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