11111111111111 11111111111111 MARY E. ALEXANDER, ESQ. (SBN: 104173) JENNIFER L. FIORE, ESQ. (SBN: 203618) SOPHIA M. ASLAMI, ESQ. (SBN: 262172) Fl Mary Alexander Associates, PC. ALAMEDA COUNTY 44 Montgomery Street, Suite 1303 San Francisco, CA 94104 0C1 2 7 2017 Phone: (415) 433-4440 CLE . Fax: (415) 433-5440 ?$333195 counr By Attorneys for Plaintiffs David Gregory, et a1. . DEPW SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ALAMEDA (UNLIMITED JURISDICTION) DAVID GREGORY, et al., Lead Case No. RG16843631 Plaintiffs, ASSIGNED FOR ALL PURPOSES TO - JUDGE BRAD SELIGMAN, DEPT. 23 v. JOINT STATEMENT BY PLAINTIFFS AND DEFENDANTS, CHOR NAR SIU NG, EVA NG AND KAI NG, SUBMITTED FOR INFORMAL DISCOVERY CONFERENCE REGARDING RESPONSES TO CASE MANAGEMENT ORDER NO. 3 CHOR NAR SIU NG, et al., Defendants. Date: October 30, 2017 Time: 3:00 pm. Dept.: 23 Judge: Hon. Brad Seligman 201 13th Street Oakland, CA And All Related Cases Plaintiffs? Liaison Counsel and counsel for Defendants, Chor Nar Siu Ng, individually and as Trustee of the Chor Nar Siu Ng Revocable Trust Dated Sept. 28, 2007, Eva Ng and Kai Ng (collectively ?Ng Defendants?), in this complex proceeding of related cases (?Proceeding?), hereby submit this joint statement of facts and issues with regard to the informal discovery conference on October 30, 2017. 1 JOINT STATEMENT BY PLAINTIFFS AND NG DEF ENDANTS REGARDING RESPONSES TO CASE MANAGEMENT ORDER NO. 3 Discovery at Issue The discovery dispute involves eight (8) form interrogatories that the Court ordered all defendants to respond to, including the Ng Defendants, by way of Case Management Order No. 3 The form interrogatories at issue are: 2.2, 2.5, 2.6, 2.7, 4.1, 12.1, 12.2 and 12.3. (See CMO 3, Exhibit B, attached hereto as Exhibit 1.) On October 10, 2017, Ng Defendants Chor Ng and Eva Ng provided incomplete responses to the form interrogatories. Responsive information to the eight interrogatories was withheld on basis of the information allegedly being ?highly con?dential for attorney?s eyes only.? (See Ng Defendants? responses to CMO 3, attached hereto as Exhibits 2-4.) 2. Meet and Confer Efforts Plaintiffs? Liaison Counsel and counsel for Ng Defendants have repeatedly attempted to informally resolve the dispute herein on numerous occasions via telephone meet and confers. The parties have reached an impasse, and therefore seek resolution from the Court via discovery conference. 3. Plaintiffs? Position Ng Defendants refuse to provide complete, substantive responses to the eight form interrogatories absent agreement from all Plaintiffs? counsel that the reSponses will not be provided to the Plaintiffs themselves. There is no factual or legal basis here for imposing such a severe restriction on the Plaintiffs? inherent right to access discovery. This dispute arose after Defendant Chor Ng allegedly received a death threat by mail to her home address sometime over the weekend of October 7th. (See Oct. 9, 2017 Letter of Stephen Dreher, attached as Exhibit 3.) Without any evidence connecting any Plaintiff to the threat,lNg Defendants unilaterally decided they did not want their form interrogatory responses containing their addresses, employment, or insurance policy information available to the Plaintiffs out of an irrational paranoia that the Plaintiffs would possibly use the information to locate the defendants and cause them physical harm. Ng Defendants? request for a protective order limiting form interrogatory responses from the Plaintiffs? view has no logical connection to 2 JOINT STATEMENT BY PLAINTIFFS AND NG DEFENDANTS REGARDING RESPONSES TO CASE MANAGEMENT ORDER NO. 3 the unfortunate threat to Chor Ng. Their position for withholding discovery from the Plaintiffs on this basis is insulting and offensive to all Plaintiffs. A protective order is simply not warranted in this case, especially not to protect basic background information such as addresses and employment, or insurance policy information, from the Plaintiffs? eyes. This type of material is routinely disclosed to parties in civil cases. There is no justi?cation in this Proceeding for departing from the usual practice of disclosure. The controlling legal principle at issue here is stated in C.C.P. 2017.010: party may obtain discovery regarding any matter, not privileged, that is relevant to the subject matter involved in the pending action or to the determination of any motion made in that action, if the matter either is itself admissible in evidence or appears reasonably calculated to lead to the discovery of admissible evidence. Discovery may relate to the claim or defense of the party seeking discovery or of any other party to the action. Discovery may be obtained of the identity and location of persons having knowledge of any discoverable matter, as well as of the existence, description, nature, custody, condition, and location of any document, electronically stored information, tangible thing, or land or other property. Courts have broadly construed the discovery statutes, so as to uphold the right to discovery wherever possible. Greyhound Corp. v. Sup. Ct. (1961) 56 Cal.2d 355, 377-378 (holding ?the several [discovery] statutes must be construed liberally in favor of disclosure unless the request is clearly imprOper by virtue of well-established causes for denial?) ?Even where the statutes require a showing of ?good cause? to obtain discovery for court-ordered mental examinations, this term is liberally construed to permit, rather than to prevent, discovery wherever possible.? (Weil Brown, Cal. Practice Guide: Civil Procedure Before Trial (The Rutter Group 2017) 11 8:36, p. 8B-3.) There are no grounds for the Court to limit the discovery at issue from the Plaintiffs. The information itself is not inherently privileged, nor have the Defendants established a suf?cient ground for a protective order. Pursuant to C.C.P. 2017.020, ?[t]he court shall limit the scope of discovery if it determines that the burden, expense, or intrusiveness of that discovery clearly outweighs the likelihood that the information sought will lead to the discovery of admissible evidence.? Ng Defendants have not and cannot demonstrate that the release of the form interrogatory responses to the Plaintiffs is so burdensome, costly or intrusive such that it 3 JOINT STATEMENT BY PLAINTIFF AND NO DEF ENDANTS REGARDING RESPONSES .TO CASE MANAGEMENT ORDER NO. 3 outweighs Plaintiffs? access to the information. Plaintiffs respectfully request that Ng Defendants? request for a protective order be denied. 4. ?g Defendants? Position Issue/ Facts: A document related to commercial insurance on the Ghost Ship building was leaked to the press by someone. This leak resulted in at least one newspaper article [September 27, 2017 article from San Jose Mercury News - attached]. The document was an internal insurance record showing loss runs and ?reserves? made by the insurance company with respect to the policy. Despite the fact that almost every conclusion drawn by the authors of the piece was totally incorrect with respect to the insurance situation and monies they fallaciously reported had been paid to defendant Chor Ng under this policy, the news media exploded with inaccurate coverage along the lines of: ?Chor Ng being paid millions, etc.? These stories, regardless of their inaccuracy, resulted in someone mailing a death threat to Chor Ng?s home address. Because the United States Mail was utilized to deliver this threat, it was a Federal crime. The Ng family?s counsel immediately noti?ed the FBI and David Lim, the Assistant District Attorney for the County of Alameda. Mr. Lim has opened an investigative ?le on this incident. The death threat letter has been turned over to the FBI, which has sent it to their crime lab, where ?ngerprint and DNA analyses are being conducted. copy of the threat letter will be provided to the Court for an in camera inspection at the time of this discovery hearing] The FBI and the District Attorney have requested that this letter not be made public at?this time. Concern: Emotions surrounding this case run high (understandably). Information by which the defendants can be physically located puts their life and safety of them and their families at risk. Relief Requested: An ?attorney eyes only? protective order for personally identifying information which would, in a less emotionally-charged matter, be exchanged during the normal course of discovery. Meet-and-Confer Efforts: Stephen Dreher, Ng defense counsel, contacted SOphia Aslami, plaintiffs? liaison counsel, explained the above situation and proposed a draft ?attomey-eyes-only? protective order attached. At the end of our conversation, Ms. Aslami stated that she personally 4 JOINT STATEMENT BY PLAINTIFFS AND NG DEF ENDANTS REGARDING RESPONSES TO CASE MANAGEMENT ORDER NO. 3 believed that, in principle, this was not an unreasonable request but that she would have to present it to the plaintiffs? counsel group as a whole before committing to anything. Ms. Aslami did so and informed that, as all of the plaintiffs? counsel would not agree to this approach, she could not agree to it either. This left the parties at an impasse and we both agreed that a presentation to the Court at an informal discovery conference would be appr0priate. Closing Comments: Counsel for the Ng defendants and the defendants themselves take this matter and the potential for further mischief very seriously. The defense is not proposing that personal identifying information (such as home addresses, addresses of places of employment, addresses of sensitive witnesses, etc.) be withheld, but rather that the dissemination of such sensitive information be limited to the attorneys and their necessary agents, such as experts, private investigators, etc. and that those agents be bound by the terms of the protective order as well. Given the circumstances, we do not believe this is an unreasonable request. The particular wording of the protective order is nowhere near as important as its effect. The attached is merely a suggestion as to how it might be stated. We are open to suggestions. ReSpectfully submitted, DATED: October 27, 2017 MARY ALEXANDE ASS IATES, P.C. By: Mary E. Alexander, Esq. Jennifer L. Fiore, Esq. SOphia M. Aslami, Esq. Plainti?s Liaison Counsel DATED: October 27,2017 BREMER WHYTE BROWN LLP By: Keith rem-r, Esqf Rayi iond Meyer, Jr., Esq. Stephen C. Dreher, Esq. Attorneys/Or Defendants Char Nar Stu Ng, er 5 .idiNT STATEMENT BY PLAINTIFFS AND NG DEFENDANTS REGARDING TO CASE MANAGEMENT ORDER NO. 3 EXHIBIT 1 1.1 2.l 2.2 2.5 2.6 2.7 2.9 EXHIBIT FORM INTERROGATORIES State the name, address, telephone number, and relationship to you of each person who prepared or assisted in the preparation of the responses to these interrogatories. State: your name; every name you have used in the past; and the dates you have used each name. State the date and place of your birth. State: your present residence address; your residence address for the past ?ve years; and the dates you lived at each address. State: the name, address, and telephone number of your present employer or place of self- employment; and the name, address, dates of employment, job title, and nature of work for each employer or self-employment you have had from ?ve years before the incident until today. State: the name and address of each school or other academic or vocational institution you have attended, beginning with high school; the dates you attended; the highest grade ievel you have completed; and the degrees received. Can you speak English with ease? If not, what language and dialect do you normally 14 STIPULATION AND CASE MANAGEMENT ORDER NO. 3 RE DISCOVERY PLAN 20 2l 22 23 24 2.10 2.11 3.1 3.2 3.3 use? Can you read and write English with ease? If not, what language and dialect do you normally use? At the time of the incident were you acting as an agent or employee for any person? If 50, state: the name, address, and telephone number of that person; and a description of your duties. Are you a corporation? If so, state: the name stated in the current articles of incorporation; all other names used by the corporation during the past 10 years and the dates each was used; the date and place of incorporation; the address of the principal place of business; and whether you are quali?ed to do business in California. Are you a partnership? If so, state: the current partnership name; all other names used by the partnership during the past 10 years and the dates each was used; whether you are a limited partnership and, if so, under the laws of what jurisdiction; (cl) the name and address of each general partner; and the address of the principal place of business. Are you a limited liability company? If so, state: the name stated in the current articles of organization; all other names used by the company during the past 10 years and the date each was used; the date and place of filing of the articies of organization; 15 STIPULATION AND CASE MANAGEMENT ORDER NO. 3 RE DISCOVERY PLAN the address of the principal place of business; and whether you are quali?ed to do business in Califomia. 3.4 Are you a joint venture? If 50, state; the current joint venture name; all other names used by the joint venture during the past 10 years and the dates each was used; the name and address of each joint venture; and the address of the principal place of business. 3.5 Are you an incorporated association? If so, state: the current unincorporated association name; all other names used by the unincorporated association during the past 10 years and the dates each was used; and the address of the principal place of business. 3.6 Have you done business under a fictitious name during the past 10 years? Ifso, for each fictitious name state: the name; the dates each was used; the state and county of each ?ctitious name filing; and the address of the principal place of business. 3.7 Within the past ?ve years has any public entity registered or licensed your business? If so, for each license or registration: identify the license or registration; state the name of the public entity; and (0) state the dates of issuance and expiration. At the time of the incident, was there in effect any policy of insurance through which you were or might be insured in any manner (for example, liability, primary, pro-rate, umbrella or excess liability coverage or medical eXpense coverage) for the damages, 16 STIPULATION AND CASE MANAGEMENT ORDER NO. 3 RE DISCOVERY PLAN 20 2 22 23 24 4.2 12.] 12.2 12.3 claims, or actions that have arisen out of the incident? If so, for each policy state: the kind of coverage; the name and address of the insurance company; the name, address, and telephone number of each named insured; the policy number; the limits of coverage for each type of coverage contained in the policy; (0 whether any reservation of rights or controversy or coverage dispute exists between you and the insurance company; and the name, address, and telephone number of the custodian of the policy, Are you self-insured under any statute for the damages, claims, or actions that have arisen out of the incident? If so, Specify the statute. State the name, address, and telephone number of each individual: who witnessed the incident or the events occurring immediately before or after the incident; who made any statement at the scene of the incident; who heard any statements made about the incident by any individual at the scene; and who you Or anyone acting on your behalf claim has knowledge of the incident. Have you or anyone acting on your behalf interviewed any individual concerning the incident? If so, for each individual state: the name, address, and telephone number of the individual interviewed; the date of the interview; and the name, address, and telephone number of the person who conducted the interview. Have you or anyone acting on your behalf obtained a written or recorded statement from any individual concerning the incident? If so, for each statement state: the name, address, and telephone number of the individual from whom the statement was obtained; 17 STIPULATION AND CASE MANAGEMENT ORDER NO. 3 RE DISCOVERY PLAN [2.4 12.5 12.6 the name, address, and telephone number of the individual who obtained the statement; the date the statement was obtained; and the name, address, and telephone number of each person who has the original statement or a copy. Do you or anyone acting on your behalf know of any photographs, ?lms, or videotapes depicting any place, object, or individual concerning the incident or plaintiff? injuries? If so, state: the number of photographs or feet of ?lm or videotape; the places, objects, or persons photographed, filmed or videotaped; the date of the photographs, ?lms, or videotapes were taken; the name, address, and telephone number of the individual taking the photographs, ?lms or videotapes; and the name, address, and telephone number of each person who has the original copy of the photographs, films or videotapes. Do you or anyone acting on your behalf know of any diagram, reproduction, or model of any place or thing concerning the incident? If so, for each item state: the type diagram, reproduction, or model); the subject matter; and the name, address, and telephone number of each person who has it. Was a report made by any person concerning the incident? If so, state: the name, title, identi?cation number, and employer of the person who made the report; the date and type of report made; the name, address, and telephone number of the person for whom the report was made; and the name, address, and telephone number of each person who has the original or a copy of the report. 18 STIPULATION AND CASE MANAGEMENT ORDER NO. 3 RE DISCOVERY PLAN 26 27 28 12.7 Have you or anyone acting on your behalf inspected the scene of the incident? If so, for each inspection state: the name, address, and telephone number of the individual making the inSpection; and the date of the inspection. 19 STIPULATION AND CASE MANAGEMENT ORDER NO. 3 RE DISCOVERY PLAN BREMER WHYTE BROWN d. LLP THE BUILDING 300 Frank 09m Plaza SUITE 355 Oakland. CA M012 BREM ER WI-JYTE BROWN LLP Raymond Meyer, 1112, State BarNo. 176235 Stephen C. Dreher, State Bar No. 129482 Carla Vasques dos Santos-Moore, State Bar No. 241883 The Rotunda Building 300 Frank H. Ogawa Plaza; Suite 355 Oakland, CA 94612 Telephone: (5 0) 540-488l Facsimile: (510) 540-4889 Attorneys for Defendants, NAR SIU NG, Individually and as Trustee of the NAR SIU NG REVOCABLE TRUST DATED September28; 2007; EVA and KAI NG SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ALAMEDA DAVID GREGORY, Individually, as Personal Case No. R016843631 Representative of the ESTATE OF MICI-IELA GREGORY and as Successor in Interest of MICHELA KIMBERLY GREGORY, Individually and as Successor in Interest of MICHELA GREGORY, DEFENDANT CHOR NAR SIU ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 INTERROGATORI ES Plaintiffs, VS. Trustee REVOCABLE TRUST DATED September 28, 2007; EVA DERICK ION OMAR JOHN 100% JOEL SHANAHAN, also known as GOLDEN and DOES 1 through 200, inclusive, NAR SIU NG, Individually and as 3 Defendants. PROPOUNDING PARTY: CASE MANAGEMENT ORDER NUMBER 3 RESPONDING PARTY: Defendant CHOR NAR STU NC SET NUMBER: ONE 1 DEFENDANT CH OR NAR SIU NO, as Tmstee ol' the REVOCABLE TRUST Dated September 28; 2007?s ADDITIONAL RESPONSES TO CASE ORDER NO. 3 FORM INTERROGATQRIES, SET In CMO No. 3 FonnRogsWamily Edits Final NU individual Additiouul Responses to BREMER WHYTE BROWN 11 LLP THE ROTUNDA SUILDING 300 Frank Ogawa Plaza SUITE 355 Oakland. CA 94612 FORM INTERROGATORY NO. 1.1: State the name, ADDRESS, telephone number, and relationship to you of each PERSON who prepared or assisted in the preparation of the responses to these interrogatories. (Do not identify anyone who simply typed or reproduced the responses.) ADDITIONAL RESPONSE TO FORM INTERROGATORY NO. 1.1: Legal counsel, Stephen C. Dreher, Bremer Whyte Brown O?Meara, 300 Frank H. Ogawa Plaza, Suite 355, Oakland, CA 94612; Telephone: (510) 540-4881. FORM INTERROGATORY NO. 2.1: State: your name; every name you have used in the past; and the dates you used each name. RESPONSE TO FORM INTERROGATORY NO. 2.1: Chor Nar Siu Ng Chor Nar Siu; and Chor Nar Siu from birth until move to the US. around January 1977, Chor Nar Siu Ng thereafter FORM INTERROGATORY NO. 2.2: State the date and place of your birth. ADDITIONAL RESPONSE TO FORM INTERROGATORY NO. 2.2: THE RESPONSE TO INTERROGATORY NO. 2.2 IS DESIGNATED AS CONFIDENTIAL EYES 2 lo CMO No.3 FonnRogs\anily Edits Final Versions\FlNAL NG individual Additional Responses to BREMER WHYTE BROWN 6 LLP THE ROTUNDA BUILDING 300 ank H. Ognwa Plazn SUITE 355 Oakland. CA. 94612 FORM INTERROGATORY NO. 2.5: State: your present residence your residence ADDRESSES for the past ?ve years; and the dates you lived at each ADDRESS. ADDITIONAL RESPONSE TO FORM INTERROGATORY NO. 2.5: THE RESPONSE TO INTERROGATORY NO. 2.5 IS DESIGNATED AS CONFIDENTIAL EYES (21) (C) FORM INTERROGATORY NO. 2.6: State: the name, ADDRESS, and telephone number of your present employer or place of self-employment; and the name, ADDRESS, dates of employment, job title, and nature of work for each employer or self-employment you have had from ?ve years before the INCIDENT until today. RESPONSE TO FORM INTERROGATORY NO. 2.6: I am not employed; None. FORM INTERROGATORY NO. 2.7: State: the name and ADDRESS of each school or other academic or vocational institution you have attended, beginning with high school; the dates you attended; (0) the highest grade level you have completed; and the degrees received. 3 DEFENDANT CHOR NAR NG, as Trustee of the REVOCABLE TRUST Dated September 28, 2007?s ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM INTERROGATORIES, SET to CMO N0. 3 FonnRogs\anily Edits Final Veisions\FlNAL NG individual Additional Responses to no .-.- . -. .. .M- An. r'BREMER WHYTE BROWN 5 LLP THE ROTUNDA BUILDING 800 rank H, Conwn P1010 SUITE 355 Oakland. CA 94612 . i I ADDITIONAL RESPONSE TO FORM INTERROGATORY NO. 2.7 a) None; None; None. FORM INTERROGATORY NO. 2.9: Can you speak English with ease? If not, what language and dialect do you normally use? RESPONSE TO FORM INTERROGATORY NO. 2.9: No. Cantonese. FORM INTERROGATORY NO. 2.10: Can you read and write English with ease? If not, what language and dialect do you normally use? RESPONSE TO FORM INTERROGATORY NO. 2.10: No. Simpli?ed Chinese. FORM INTERROGATORY NO. 2.11: At the time of the INCIDENT were you acting as an agent or employee for any If so, state: the name, ADDRESS, and telephone number of that PERSON: and a description of your duties. RESPONSE TO FORM INTERROGATORY NO. 2.11: Objection, calls for a legal conclusion. However, without waiving this objection, and in the Spirit of discovery, No. FORM INTERROGATORY NO. 3.1: Are you a corporation? If so, state: the name stated in the current aiticl es of incorporation; all other names used by the corporation during the past 10 years and the dates each was used; 4 DEFENDANT CHOR NAR SIU NG, as Trustee oftlie REVOCABLE TRUST Dated September 28, 2007?s ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM INTERROGATORIES, SET H:\l437\055\Discovcry\RESPONS ES to CMO No. 3 ForniRogs\FaInily Edits Final VemionlelNAL individual Addilional Responses In CMO.tlucx BREMER WHYTE BROWN 8 LLP THE HOTUNDA BUILDING 300 Frank H,Onawn Plozn SUITE 355 Oakland. CA. 911612 the date and place of incorporation; RESPONSE TO FORM INTERROGATORY NO. 3.1: the ADDRESS of the principal place of business; and whether you are quali?ed to do business in California. No. (0) and FORM INTERROGATORY NO. 3.2: Are you a partnership? If so, state: the current partnership name; all other names used by the partnership during the past 10 years and the dates each was used; (0) whether you are a limited partnership and, if so, under the laws of what jurisdiction; the name and ADDRESS of each general partner; and the ADDRESS of the principal place of business. RESPONSE TO FORM INTERROGATORY NO. 3.2: No. (0) and FORM INTERROGATORY NO. 3.3: Are you a limited liability company? If so, state: 5 DEFENDANT CHOR NAR SIU NG, as Trustee of the REVOCABLE TRUST Dated September 28, 2007?s ADDJTIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM INTERROGATORIES, SET ES to CMO No.3 FonnRogs\Family Edits Final VemiunsWINAL NG individual Additional Responses to CMO.docx an?. win. as" EREMER WHVTE BROWN 5 LLP THE ROTUNDA BUILDING 300 Frank H100m Plaza SUITE 355 Oakland. CA 0-1612 the name stated in the current articles of organization; all other names used by the company during the past 10 years and the date each was used; the date and place of ?ling of the articles of organization; the ADDRESS of the principal place of business; and (6) whether you are quali?ed to do business in California. RESPONSE TO FORM INTERROGATORY NO. 3.3: No. (0) and INTERROGATORY NO. 3.4: Are you a joint venture? If 50, state: the cunent joint venture name; all other names used by the joint venture during the past 10 years and the dates each was used; the name and ADDRESS of each joint venturer; and the ADDRESS of the principal place of business. RESPONSE TO FORM INTERROGATORY NO. 3.4: No. (0) and 6 DEFENDANT CI-IOR NAR SIU NO, as Trustee of the REVOCABLE TRUST Dated September 28, 2007's ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM INTERROGATORIES, SET lo CMO No. 3 FormRogs\anily Edits Final Vcrsions\FlNAL NG individual Additional Responses lo u, v? :m ..-. u- vi. 44., H. .. - .. HREMER WHYTE BROWN 1! LLP THE ROTUNDA BUILDING 300 Flank H. Plaza SUITE 355 Oakland. CA 946i? FORM NO. 3.5: Are you an unincorporated association? Ifso, state: the current unincorporated association. name; all other names used. by the unincorporated. association during the past '1 0 years and. the dates each was used; and the ADDRESS of the principal place of business. RESPONSE TO FORM NO. 3.5: No. and (0) FORM NO. 3.6: Have you clone business under a ?ctitious name during the past 10 years? If so, for each ?ctitious name state: the name; the dates each was used; the state and county of each ?ctitious name ?ling; and (cl) the ADDRESS of the principal place of business. RESPONSE TO FORM NO. 3.6: No. and FORM INTERROGATORY NO. 3.7: Within the past ?ve years has any public entity registered 01' licensed your business? If so, for each license or t'egistration: 7 ESPONSES 111CMO N11. 3 Edits Final NO individual Additional Response-t loCMO.dncx 1 identify the license or registration; 2 state the name of the public entity; and 3 (0) state the dates of issuance and expiration. 4 ADDITIONAL RESPONSE TO FORM INTERROGATORY NO. 3.7: 5 THE RESPONSE TO INTERROGATORY NO. 3.7 IS DESIGNATED AS 6 CONFIDENTIAL - EYES 0mm, animate No. 3 Edits Final Vmsinns\FINAL NG v. ran. m. u? ~m an?. 7.2 n3. u-p lel ?win-T u-x- u! ,n'r h. ..- .- BREMER WHYTE BROWN 5 LLP THE ROTUNDA BUILDING 300 Frank Ogawa Plnzo SUITE 355 Oakland. CA. 94512 (C) (C) FORM INTERROGATORY NO. 4.1: At the time of the INCIDENT, was there in effect any policy of insurance through which you were or might be insured in any manner (for example, primary, pro-rata, or excess liability coverage or medical expense coverage) for the damages, claims, or actions that have arisen out of the If so, for each policy state: the kind of coverage; the name and ADDRESS of the insurance company; the name, ADDRESS, and telephone number of each named insured; the policy number; the limits of coverage for each type of coverage contained in the policy; whether any reservation of rights or controversy or coverage dispute exists between you and the insurance company; and the name, ADDRESS, and telephone number of the custodian of the policy. ADDITIONAL RESPONSE TO FORM INTERROGATORY NO. 4.1: THE RESPONSE TO INTERROGATORY NO. 4.1 IS DESIGNATED AS CONFIDENTIAL EYES ON Information regarding insurance policies on other properties than the INCIDENT SITE is being compiled and will be provided under the terms of the ?Attorney?s Eyes Only" provision of the modified protective order. FORM INTERROGATORY NO. 4.2: Are you self-insured under any statute for the damages, claims, or actions that have arisen out of the If so, specify the statute. 9 CHOR NAR SIU as Trustee oi?thc REVOCABLE TRUST Dated September 23, 2007?s RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM INTERROGATORIES, SET Io CMO Nu. 3 Fomthigs\FatltIily Edits Final Individual Additional Responses to CMQxIncx GREMER WHYTE BROWN 5 LLP THE ROTUNDA BUILDING 300 Frank 09mm Plazn SUITE 355 Oakland. 94012 RESPONSE TO FORM INTERROGATORY NO. 4.2: No. FORM INTERROGATORY O. 12.1: State the name, ADDRESS, and telephone number of each individual: who witnessed the INCIDENT or the events occurring immediately before or after the who made any statement at the scene of the who heard any statements made about the INCIDENT by any individual at the scene; and who YOU OR ANYONE ACTING ON YOUR BEHALF claim has knowledge of the INCIDENT (except for expert witnesses covered by Code of Civil Procedure section 2034). ADDITIONAL RESPONSE TO FORM INTERROGATORY NO. 12.1: INFORMATION REGARDING WITNESS SHARON EVANS IS DESIGNATED CONFIDENTIAL EYES (3) (C) Darold Leite; Juan Davalo, and others as identi?ed in the press coverage of the INCIDENT. FORM INTERROGATORY O. 12.2: Have YOU OR ANYONE ACTING ON YOUR BEHALF interviewed any individual concerning the If so, for each individual state: the name, ADDRESS, and telephone number of the individual interviewed; the date of the interview; and . the name, ADDRESS, and telephone number of the PERSON who conducted the interview. 1 0 DEFENDANT CHOR NAR SIU NO, as Trustee ofthe REVOCABLE TRUST Dated September 28, 2007's ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM INTERROGATORIES, SET H:\I437\055\Discovcry\R ESPONS ES to CMO No.3 FonnRogs\anin Edits Finnl Velsinns\FlNAL NC individual Additional Responses to CMO.docx . . 34-? . .. . .u r! BREMER WHYTE BROWN 5 LLP THE ROTUNDA BUILDING 300 Frank H. Ogawn Plaza SUITE 355 Oakland. CA 94612 ADDITIONAL RESPONSE TO FORM INTERROGATORY NO. 12.2: INFORMATION REGARDING ONE OF THE WITNESSES IS DESIGNATED CONFIDENTIAL EYES (0) Stephen Dreher, counsel for Responding Party. Re: Darold Leite: Darold Leite, address unknown, telephone unknown; Various (two or three) in-person conversations in February 2017; Stephen Dreher, counsel for ReSponding Party Re: Juan Davalo Juan Davalo, address unknown; telephone unknown (former employee of Auto Shop next door to Ghost Ship) Late January 2017; Stephen Dreher, Counsel for Responding Party FORM INTERROGATORY N0. 12.3: Have YOU OR ANYONE ACTING ON YOUR BEHALF obtained a written or recorded statement from any individual concerning the If so, for each statement state: the name, ADDRESS, and telephone number of the individual from whom the statement was obtained; the name, ADDRESS, and telephone number of the individual who obtained the statement; the date the statement was obtained; and the name, ADDRESS, and telephone number of each PERSON who has the original statement or a copy. 1 1 DEFENDANT CHOR NAR SIU NO, as Trustee of the REVOCABLE TRUST Dated September 28, 2007?s ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM INTERROGATORIES, SET lo CMO N0. 3 FormRogs\Family Edits Final Vcrsinns\F NAL RESPONS NG individual Additional RcSponscs to CMO.d0cx a?r. v.1: .-. .-. n? in; un- {,g',nu .-.--. v-21'. nu. a BREMER WHYTE BROWN 6 LLP THE ROTUNDA BUILDING 300 Frank 09.1er Pinzn SUITE 355 Oakland. CA 06612 RESPONSE TO FORM INTERROGATORY N0. 12.3: INFORMATION REGARDING ONE OF THE WITNESSES IS DESIGNATED AS CONFIDENTIAL EYES Yes. Stephen Dreher, counsel for Responding Party. (0) March 10, 2017 and a few phone calls setting up personal interview; Stephen Dreher, Esq. Bremer, Whyte, Brown O?Meara. Re: Darold Leite: No written or recorded statements were taken. Re: Juan Davalo: No written or recorded statements were taken. FORM INTERROGATORY NO. 12.4: Do YOU OR ANYONE ACTING ON YOUR BEHALF know of any photographs, ?lms, or videotapes depicting any place, object, or individual concerning the INCIDENT or plaintiffs injuries? If so, state: the number of photographs or feet of ?lm or videotape; the places, objects, or persons photographed, ?lmed, or videotaped; the date the photographs, ?lms, or videotapes were taken; the name, ADDRESS, and telephone number of the individual taking the photographs, ?lms, 0r videotapes; and the name, ADDRESS, and telephone number of each PERSON who has the original or a copy of the photographs, ?lms, or videotapes. ADDITIONAL RESPONSE TO FORM INTERROGATORY NO. 12.4: Three photographs (Bates N000002-4) Fire?ghting activities at the warehouse; (0) December 2, 2016; 12 DEFENDANT CHOR NAR SIU NO, as Trustee of the REVOCABLE TRUST Dated September 28, 2007?s ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM INTERROGATORIES, SET H:\l437\055\Diseovciy\RESPONS ES to CMO No.3 anangsianily Edits Final Versions\FlNAL NG individual Additional Responses to CMO.docx x? . um "yr? -..- bi": w-t- 4v?- run. w? nu:- yaw wt, um - u" 4.14. - 1 Kai Ng; 2 Kai Ng and Stephen Dreher, counsel for Responding Party. 3 7 photographs (Bates NG0000619) 4 Sidewalk and vacant lot near Ghost Ship warehouse; 5 November 19, 2016; 6 Unknown. Someone from the City of Oakland; 7 City of Oakland, Kai Ng, Stephen Dreher counsel for Responding Party 8 Thirty-four photographs (Bates 9 Various aspects of the exterior of the Ghost Ship warehouse and some shots of 10 electrical panels, etc. inside the warehouse and adjacent building; 11 (0) Unknown; 12 Believed to have been taken by Ben Cannon; 13 Ben Cannon, Kai Ng, Stephen Dreher, counsel for Responding Parties. 14 Three photographs (Bates 15 Fence bordering vacant lot adjacent to the Ghost Ship warehouse; 16 (0) September 13, 2014; 17 Eva Ng; 18 Eva Ng, Stephen Dreher, counsel for ReSponding Party. 19 Two photographs (Bates 20 Fence bordering vacant lot adjacent to the Ghost Ship warehouse and vacant lot; 21 September 20, 2014; 22 Eva Ng; 23 Eva Ng; Stephen Dreher counsel for ReSponding Party 24 Four photographs (Bates 25 Fence bordering vacant lot adjacent to the Ghost Ship warehouse and vacant lot; 26 October 4, 2014 94612 :11; No. 3 FonnRogsxramny Edits Final Vunsions\FlNAL NG ?412 171- M- wu- 0' Iu'" ..-: 1.3-: you arm .s'n aux .-- no? my}. run 0 I 4? BREMER WHYTE BROWN 6 LLP THE ROTUNDA BUILDING 300 Frank Ognwa Plaza SUITE 355 Oaklalw. CA. 94612 Eva Ng; Stephen Dreher counsel for Responding Party. (3) Eleven photographs (Bates Vacant lot adjacent to the Ghost Ship warehouse; June 22, 2014; Eva Ng; (6) Eva Ng; Stephen Dreher counsel for Responding Party. Five photographs (Bates Ghost Ship warehouse, exterior and interior; (0) Unknown exactly, but before lease to Derick Almeria; Eva Ng; (6) Eva Ng, Stephen Dreher counsel for ReSponding Party. Other photographs and videos as have appeared in press reports of the INCIDENT. Responding party is not in possession, custody or control of these and they are equally accessible to asking party. FORM INTERROGATORY N0. 12.5: Do YOU OR ANYONE ACTING ON YOUR BEHALF know of any diagram, reproduction, or model of any place or thing (except for items developed by expert witnesses covered by Code of Civil Procedure section 2034) concerning the If so, for each item state: the type diagram, reproduction, or model); the subject matter; and the name, ADDRESS, and telephone number of each PERSON who has it. RESPONSE TO FORM INTERROGATORY NO. 12.5: None other than diagrams that might have been produced during the investigation of the ?re by public agencies or which have been generated by expert consultants. FORM INTERROGATORY N0. 12.6: Was a report made by any PERSON concerning the If so, state: 14 DEFENDANT CHOR NAR NO, as Trustee of the REVOCABLE TRUST Dated September 28, 2007?s ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM INTERROGATORIES, SET lo CMO No. 3 FonnRogs\Falmily Edits Final Vcnsions\FlNAL NG individual Additional Responses to CMO.docx BREMER WHYTE BROWN 6 LLP THE ROTUNOA BUILDING 300 Frank H. Ognwu PI-zn SUITE 355 Oakland. CA 94512 the name, title, identi?cation number, and employer of the PERSON who made, the report; the date and type of repert made; the name, ADDRESS, and telephone number of the PERSON for whom the report was made; and the name, ADDRESS, and telephone number of each PERSON who has the original or a copy of the report. I RESPONSE TO FORM INTERROGATORY N0. 12.6: Other than "reports that might have been generated by public agencies investigating the ?re or those generated by experts by parties to the litigation, responding party knows of none such. FORM INTERROGATORY NO. 12.7: ?l-Iave YOU OR ANYONE ACTING ON YOUR BEHALF inspected the scene of the If so, for each inspection state: the name, ADDRESS, and telephone number of the individual making the inspection (except for expert witnesses covered by Code ofCivi! Procedure section 2034); and the date of the inspection. ESPONSE TO FORM N0. 12.7: Just the attorneys for responding party and experts retained on responding party?s behalf. Dated: October 10, 2017 BREMER WHYTE BROWN LLP J'r. Stephen C. .Dreher Carla Vasques dos Santos-Moore Attorneys for Defendants CI-IOR NAR SIU NO, Individually and as Trustee ofthe CHOR SIU NO REVOCABLE TRUST DATED September 28, 2007; EVA KAI l5 DEFENDANT CHOR NAR SIU NO, as Trustee of the TRUST Dated September 28, 2007?s ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM SET to CMO Na. 3 FumtRugs?inimily Etlils 'Finnl VersionlelNAL NO individual Additional Responses tn Document? VERIFICATION TO FOLLOW BREMER WHYTE BROWN 5 LLP THE ROTUNDA BUILDING 300 Frank H. Ogawa Plaza Stills 355 Oakland. CA 94812 PROOF OF SERVICE I am employed in the County of Alameda, State of California. I am over the age of 18 and not a party to the within action. My business address is The Rotunda Building, 300 Frank H. Ogawa Plaza, Suite 355, Oakland, CA 94612. On October 1 1, 2017, I served the within document(s) described as: DEFENDANT CHOR NAR SIU ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 on the interested parties in this action as stated below: Mary E. Alexander Jennifer L. Fiore jfiore@maryalexanderlaw.com; Sophia M. Aslami saslamifalmarvalexanderlawcom (BY ELECTRONIC MAIL SERVICE) Based upon CRC Rule 2.251 or an agreement of the parties to accept electronic service I caused such document(s) to be Electronically Mailed through Bremer, Whyte, Brown O'Meara electronic mail system for the above entitled case. Should your of?ce require a hard copy of said document, please contact our of?ce. Executed on October 11, 2017, at Oakland, California. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Natasha Y. Sullivan 2/ . (Type or print name) tunature) OF - 3 BREMER WHYTE BROWN 8 LLP THE ROTUNDA BUILDING 300 Frank Ottawa Plaza 355 BREMER WHYTE BROWN LLP Raymond Meyer, Jr., State Bar No. 176235 Stephen C. Dreher, State Bar No. 129482 Carla Vasques dos Santos-Moore, State Bar No. 241883 cmoore@bremetwhy?teeom The Rotunda Building 300 Frank H. Ogawa Plaza; Suite 355 Oakland, CA 94612 Telephone: (510) 540-4881 Facsimile: (510) 540-4889 Attorneys for Defendants, CHOR NAR SIU NG, Individually and as Trustee of the CHOR NAR SIU NG REVOCABLE TRUST DATED September 28, 2007; EVA and KAI NG SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ALAMEDA DAVID GREGORY, Individually, as Personal Case No. RG16843631 Representative of the ESTATE OF MICHELA GREGORY and as Successor in Interest of MICHELA KIMBERLY GREGORY, Individually and as Successor in Interest of MICHELA GREGORY, DEFENDANT CHOR NAR SIU NG, as Trustee of the CHOR NAR SIU NG REVOCABLE TRUST Dated September 28, 2007?s ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. Plaintiffs, 3 INTERROGATORIES VS. Trustee of the CHOR NAR SIU NG REVOCABLE TRUST DATED September 28, 2007; EVA DERICK ION MICAH DANIEL OMAR JOHN 100% JOEL SHANAHAN, also known as GOLDEN and DOES 1 through 200, inclusive, I CHOR NAR SIU NG, Individually and as 1 Defendants. I PROPOUNDING PARTY: CASE MANAGEMENT ORDER NUMBER 3 RESPONDING PARTY: Defendant CHOR NAR SIU NG, as Trustee of the CHOR NAR SIU NG REVOCABLE TRUST dated September 28, 2007 SET NUMBER: ONE 1 DEFENDANT CHOR NAR SIU NO, as Trustee ofthe REVOCABLE TRUST Dated September 28, 2007?s ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM INTERROGATORIES, SET to CMO No. 3 Foi?mRogs?1anily Edits Final VeisionszNAL RESPONSESICHOR NG Additional Responses to Form .a-u BREMER WHYTE BROWN 5 LLP THE ROTUNDA BUILDING 300 Frank Ouawn Plaza SUITE 355 Oakland. CA. 114612 FORM. INTER-ROGATORY NO. 1.1: State the name, ADDRESS, telephone number, and relationship to you of each PERSON who prepared or assisted in the preparation of the responses to these interrogatories. (Do not identify anyone who simply typed or reproduced the responses.) ADDITIONAL RESPONSE TO FORM INTERROGATORY NO. 1.1: Legal counsel, Stephen C. Dreher, Bremer Whyte Brown &-O?Meara, 300 Frank H. Ogawa Plaza, Suite 355, Oakland, CA 94612; Telephone: (510) 540-4881. FORM INTERROGATORY NO. 2.1: State: your name; every name you have used in thepast; and the dates you used each name. RESPONSE TO FORM INTERROGATORY NO. 2.1: Chor Nar Sin Ng Chor. Nar Sin; and Chor Nar Siu from birth until move to the US. around January 1977, C1101.- Nat Si?u Ng thereafter FORM INTERROGATORY NO. 2.2: State the date and place of your birth. ADDITIONAL RESPONSE TO FORM NO. 2.2: THE RESPONSE TO INTER ROGATORY NO. 2.218 DESIGNATED AS CONFIDENTIAL EYE-S ON FORM INTERROGATORY NO. 2.5: State: 2 DEFENDANT CHOR NAR NO, as Trustee of TRUST Dated September 28. 2007's ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM SET In CMO No. 3 Edits Final Vursinns?lFlNAL NC: Trustw Additional Responses In Form RogsleAL ONLdecx BREMER WHYTE BROWN 5 LLP THE ROTUNDA BUILDING 300 Frank H, Omiwa Plaza SUITE 355 Oakland. CA 01012 your present residence your residence ADDRESSES for the past ?ve years; and the dates you lived at each ADDRESS. ADDITIONAL RESPONSE TO FORM INTERROGATORY NO. 2.5: THE RESPONSE TO NO. 2.5 DESIGNATED AS CONFIDENTIAL EYES (8) FORM INTERROGATORY NO. 2.6: State: the name, ADDRESS, and telephone number of your present employer or place of self-employment; and the name? ADDRESS, dates of emplOyment, job title, and nature of work fer each employer or self4einployinent you have had. from ?ve years before the INCIDENT until today. RESPONSE TO FORM INTERROGATORY NO. 2.6: .1 am not employed; None. FORM INTERROGATORY NO. 2.7: State: the name and ADDRESS of each school or-other academic or vocational institution you have attended, beginning with high school; the dates you attended; (0) the highest grade level you have completed; and the degrees received. ADDITIONAL RESPONSE TO FORM INTERROGATORY NO. 2.7 a) None; 7 3 DEFENDANT CHOR NAR SIU NO, as Trustee of the TRUST Dated September 28, 2007?s ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM SET to CMO No. 3 thangs?tt-?mnily Edits Final VersionlelNAL NG Trustee Atlttiliunnt Responses In CMOH3 Fonn BREMER WHVTE BROWN 5 LLP THE ROTUNDA BUILDING 300 Frank H. Oguwa F'Iala SUITE 355 Oakland. CA 04612 None; None. FORM INTERROGATORY O. 2.9: Can you speak English with ease? If not, what language and dialect do you normally use? RESPONSE TO FORM INTERROGATORY NO. 2.9: No. Cantonese. FORM INTERROGATORY N0. 2.10: Can you read and write English with ease? If not, what language and dialect do you normally use? RESPONSE TO FORM INT ERROGATORY N0. 2.10: No. Simpli?ed Chinese. FORM INTERROGATORY NO. At the time of the INCIDENT were you acting as an agent or employee for any If so, state: the name, ADDRESS, and telephone number of that PERSON: and a description of your duties. RESPONSE TO FORM INTERROGATORY N0. 2.11: Objection, calls for a legal conclusion. However, without waiving this objection, and in the spirit of discovery, No. FORM INTERROGATORY NO. 3.1: Are you a corporation? If so, state: the name stated in the current articles of incorporation; all other names used by the corporation during the past 10 years and the dates each was used; the date and place of incorporation; the ADDRESS of the principal place of business; and 4 DEFENDANT CHOR NAR SIU NO, as Trustee of the REVOCABLE TRUST Dated September 28, 2007?s ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM INTERROGATORIES, SET to CMO No. 3 FonnRogs\anily Edits Final Versions\FlNAL NO Additional Responses to Form ONLY.docx BREMER WHYTE BROWN I LLP THE ROTUNDA BUILDING 300 Frank H-09nwa Plnzu SUITE 355 CA 04912 whether you are quali?ed to do business in California. RESPONSE TO FORM INTERROGATORY NO. 3.1: No. (0) and FORM INTERROGATORY NO. 3.2: Are you a partnership? If so, state: the current partnership name; all other names ?used by the partnership during the past 10 years and the dates each wwuwm whether you are a limited partnership and, if so, under the laws of what jurisdiction; the name and ADDRESS of each general partner; and the ADDRESS of the principal place of business. RESPONSE TO FORM INTERROGATORY NO. 3.2: No. and (6) FORM INTERROGATORY NO. 3.3: Are you a limited liability company? If so, state: the name stated in the current articles of organization; 5 DEFENDANT CHOR NAR NO, as Trustee ofthe REVOCABLE TRUST Dated September 28, 2007?s ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM INTERROGATORIES, SET to CMO N0. 3 FonnRogs?anmily Edits Final VemionszNAL NO Trustee Additional! Responses Form 0NLY.docx I um 14% .29. n? h-vlBREMER WHYTE BROWN 5 LLP THE ROTUNDA BUILDING 300 Frank Ounwa Plaza SUITE 355 Oakland. CA 04612 all other names used by the company during the past ?1 0 years and the_,cl_ate each was used; the date and place of ?ling of the articles oforganization; the ADDRESS of the principal place of business; and whether you are quali?ed to do business in California. RESPONSE TO FORM NO. 3.3: No. (8.) and FORM NO. 3.4: Are you a joint venture? If so, state: the current joint venture name; all other names used by the joint venture during the past 10 years and the dates each wmuw? the. name and ADDRESS of each joint venturer; and the ADDRESS of the principal place of business. RESPONSE TO FORM INTERROGATORY NO. 3.4: No. and (cl) 6 CHOR NA SIU NO, as Trustee oi?Ihe TRUST Dated Seplembcr 28, 2007's ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM SET In CMO No. 3 FormRogs?IanIily Edits Final Veminn??lFlNAL DDITIONAL NO ?l?nistcc Additional Responses In ann Rogs_FlN1\L ONLY.1lncx BREMER WHYTE BROWN 4. LLP THE ROTUNDA BUILDING 300 Flank Ogawa Plaza SUITE 355 Daklmd. CA. MGIZ FORM. INTERROGATORY NO. 3.5: Are you an unincorporated association? 11?50, state: the current unincomoratcd association name; all other names used by the unincorporated association during the past '1 0 years and the dates each was used; and the ADDRESS of the principal place of business. RESPONSE TO FORM INTERROGATORY NO. 3.5: No. (21) and (0) FORM INTERROGATORY NO. 3.6: Have you done business under a ?ctitious name during the past 10 years? If so, for each ?ctitious name state: the name; the dates each was used; the state and county of each fictitious name filing; and the ADDRESS of the principal place of business. RESPONSE TO FORM NO. 3.6: No. (0) and FORM INTERROGATORY NO. 3.7: Within the past ?ve years has any public entity registered or licensed your business? If so, for each license or registrationFonnRugleumily Edits Final Vursinns\FlNAL DDITIONAL NG Additional Responses to CMOM Form RogsleAL SC ONLYalocx BREMER WHYTE BROWN 6 LLP THE ROTUNDA BUILDING 300 ank H, Onawn SUITE 355 Oakland. CA, 04612 identify the license or registration; state the name of the public entity; and state the dates of issuance and expiration. ADDITIONAL RESPONSE TO FORM 1N TERRO GATORY O. THE RESPONSE TO NO. 3.7 DESIGNATED CONFIDENTIAL - EYES (21). (0) (C) (0), 8 DEFENDANT NO, as Trusgcc oflh'c REVOCABLE TRUST Dated Scpl?embcr28, 2007's- RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM INTERROGATORIES, SET lb '3 Edils Fin?l NG Tmstuc Addilinnul 'Ruepunsus Farm RegkleAL 0N BREMER WHYTE BROWN 5 LLP THE ROTUNOA BUILDING 800 ank Ognvm Plaza SUETE 355 Oakland. CA 04612 (C) FORM INTERROGATORY NO. 4.1: At the time of the INCIDENT, was there in effect any policy of insurance through which you were or might be insured in any manner (for example, primary, pro-rate, or excess liability coverage or medical expense coverage) for the damages, claims, or actions that .have arisen out of the If so, for each policy state: the kind. of coverage; the name and ADDRESS of the insurance company; the name, ADDRESS, and telephone number of each named insured; the policy number; (3) the limits of coverage for each type of coverage contained in the policy; whether any reservation. of rights or controversy 0r coverage dispute exists between you and the insurance company; and the name, ADDRESS, and telephone number of the custodian of the policy. ADDITIONAL RESPONSE TO FORM INTERROGATORY O. 4.1: THE RESPONSE TO INTERROGATORY NO. IS DESIGNATED AS CONFIDENTIAL EYES Information regarding insurance policies on other prepertics than the INCIDENT SITE is being compiled and will be provided under the terms of the ?Attorney?s Eyes Only? provision of the modi?ed protective order. FORM INTERROGATORY NO. 4.2: Are you self-insured under any statute for the damages, claims, or actions that have arisen out of the It?so, specify the statute. 9 DEFENDANT NAR SIU NO, as Trustee ol" the TRUST Dated September 28, 2007?s ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER 73 FORM SET Io CMO No.3 Edits Final SCDVIDDITIONAL N0 Trustee Additional Rcslitmses In MOM Form ON BREMER WHYTE BROWN A LLP THE ROTUNDA BUILDING 300 Frank Ogewa Ptaza SUITE 355 Oakland. CA 04812 RESPONSE TO FORM .INTERROGATORY O. 4.2: No. FORM INTERROGATORY N0. 12.1: State the name, ADDRESS, and telephone number of each individual: who witnessed the INCIDENT or the events.occurringimmediately before 01' after the who made any statement at the scene of the (0) who heard any statements made about the INCIDENT by any individual at the scene; and who YOU OR ANYONE ACTING ON YOUR BEHALF claim has knowledge of the INCIDENT (except for expert witnesses covered by Code o/?Civil Procedure section 2034). ADDITIONAL RESPONSE TO FORM INTERROGATORY NO. 12.1: INFORMATION REGARDING WITNESS SHARON EVANS IS DESIGNATED CONFIDENTIAL - EYES (21) (0) Darold L'eite; Juan Davalo, and others as Identi?ed in the press coverage or? the INCIDENT. FORM NO. 12.2: I-lave YOU OR ANYONE ACTING ON YOUR interviewed any individual concerning the for each individual state: the name, ADDRESS, and telephone number of'the individual interviewed; the date of the interview; and . the name, ADDRESS, and telephone number of the PERSON who conducted the interview. 10 DEFENDANT NAR SIU NU, as Trustee Ol" the REVOCABLE TRUST Dated September 28, 2007?s ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM SET to CMO N0. 3 annltognl?mniIyEdils Finai Vetsinns?iFlNAL NO "l?nisloe Atltlilimml Responses in Fumi Rogtt?FlNAL BREMER WHYTE BROWN 5 LLP THE ROTUNDA EUILDING 100 Frank H.00m Plaza SUITE 355 Oakland. CA 06812 ADDITIONAL RESPONSE TO FORM, NO. INFORMATION REGARDING ONE OF THE WITNESSES lS DESIGNATED ".l-llGl-lLY CONFIDENTIAL EYES Stephen Dreher, counsel for Responding Party. Re: Darold Leite?: Dar-old Leite, address Unknown, telephone unknown; Various (two or three). in-person conversations in February 2017; Stephen Dreher, counsel for Responding Party Re: Juan Davalo (21) Juan Davalo, address unknown; telephone unknown (former employee of Auto Shop next door to Ghost Ship) Late January 2017; Stephen Dreher, Counsel for Responding Party FORM INTERROGATORY NO. 12.3: Have YOU OR ANYONE ACTING ON YOUR BEHALF obtained a written or recorded statement from any individual concerning the If so, for each statement state: the name, ADDRESS, and telephone number of the individual from whom the statement was obtained; the name, ADDRESS, and telephone number ot?the individual who obtained the statement; the date the statement was obtained; and the name, ADDRESS, and telephone number of each PERSON who has the original statement or a copy. 1 DEFENDANT CHOR NAR NO, as Trustee of the REVOCABLE TRUST Dated September 28, 2007's ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM SET Hmtl37\055\Diseuvcry\R ESPO NSES to CMO No. 3 Edits innl VersiunszN/ll. RESPONSESKZHOR NC Trustee Additional Responses In Form SCDJEYES ONLValncs BREMER WHYTE BROWN 3 LLP THE ROTUNDA GUILDING 100 Frank Ognwa SUITE 355 Oakland. CA RESPONSE TO FORM INTERROGATORY N0. 12.3: INFORMATIONREGARDING ONE OF THE WITNESSES IS DESIGNATED AS CONFIDENTIAL EYES Yes. Stephen .Dreher, counsel for Responding Party. March IO, 2017 and a few phone calls setting up personal interview; Stephen Dreher, Esq. Bremer, Whyte, Brown O?Meara. Re: Darold Leite: No written 01' recorded statements were taken. Re: Juan Davalo: No written or recorded statements were taken. FORM N0. 12.4: Do YOU OR ANYONE ACTING ON YOUR BEHALF know of any photographs, ?lms, or videotapes depicting any place, object, or individual conceming the INCIDENT or plaintiffs injuries? ilt'so, state: the number of photographs or feet of film or videotape; the places, objects, or persons photographed, ?lmed, or videotaped; . the date the photographs, ?lms, or videotapes were taken; the name, ADDRESS, and telephone number of the individual taking the photographs, ?lms, or videotapes; and the name, ADDRESS, and telephone number of each PERSON who has the original or a cepy ot' the photographs, ?lms, or videotapes. ADDITIONAL RESPONSE FORM. INTERROGATORY NO. 12.4: Three photographs (Bates Fire?ghting activities at. the warehouse; December FetnliRogsWumily Edits Final IOR NC Trustee Additional Responses In Form ONl.Y.tlocs (DO-BREMER WHYTE BROWN LL THE ROTUNDA BUILDING 300 Frank Ogawa Plaza SUITE 355 Oakland. CA 94512 (C) (C) (C) (cland Stephen Dreher, counsel for Restionding Party. 7 photographs (Bates Sidewalk and vacant lot near Ghost Ship warehouse; November '19, 2016; Unknown. Someone from the City of Oakland; City of Oakland, Kai g, Stephen Dre'her counsel for Responding Fatty Thirty~four photographs (Bates Various aSpects of the exterior of the Ghost Ship warehouse and some shots of electrical panels, etc. inside the warehouse and adjacent building; Unknown; Believed to have been taken by Ben Cannon; Ben Cannon, Kai g, Stephen 'Dreher, counsel for Responding Parties. Three photographs (Bates Fence bordering vacant lot adjacent to the Ghost Ship warehouse; September 13, 2014; Eva g; Eva g, Stephen Dreher, Counsel for Responding Party. Two photographs (Bates Fence bordering vacant lot adjacent to the Ghost Ship warehouse and vacant lot; September 20, 2014; Eva g; Eva Ng; Stephen Dreher counsel for Responding Party Four photographs (Bates Fence bordering vacant lot adjacent to the Ghost Ship warehouse and vacant lot; October 4, 2014 Eva g; 13 NAR SIU NO, as Trustee ol'tlte REVOCABLE TRUST Dated September 28-, 2007?s ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM INTERROGATOIRIES, SET CMO No. .3 Edits Final VersionszNAL NC Additional Responses to CMOM Form BREMER 8ROWN 6 LLP THE HOTUNOA BUILDING 300 Frank 090m: Plaza SUITE 355 Oakland. CA. 94612 Eva Ng; Stephen Dreher counsel for Responding Party. Eleven photographs (Bates Vacant lot adjacent to the Ghost Ship warehouse; June 22, 2014; Eva Ng; (6) Eva Ng; Stephen Dreher counsel for Responding Party. Five photographs (Bates Ghost Ship warehouse, exterior and interior; (0) Unknown exactly, but before lease to Derick Almeria; Eva Ng; Eva Ng, Stephen Dreher counsel for Responding Party. Other photographs and videos as have appeared in press reports of the INCIDENT. Responding party is not in possession, custody or control of these and they are equally accessible to asking party. FORM INTERROGATORY NO. 12.5,: Do YOU OR ANYONE ACTING ON YOUR BEHALF know of any diagram, reproduction, or model of any place or thing (except for items deveIOped by expert witnesses covered by Code ofCivil Procedure section 2034) concerning the If so, for each item state: the type diagram, reproduction, or model); the subject matter; and the name, ADDRESS, and telephone number of each PERSON who has it. RESPONSE TO FORM INTERROGATORY NO. 12.5: None other than diagrams that might have been produced during the investigation of the ?re by public agencies or which have been generated by expert consultants. l4 DEFENDANT CHOR NAR SIU NO, as Trustee of the REVOCABLE- TRUST Dated September 28, 2007?s ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM INTERROGATORIES, SET lo CMO No. 3 Form Rogs\Family Edits Finn! Vcrsions\FlNAL NG Addilional Responses to Fonn ONLY.docx . ..-. ?v ?4 . BREMER BROWN A LLP THE ROTUNDA BUILDING 300 Frank Ogawn Plaza SUITE 355 Oakland. CA 94612 FORM NO. 12.6: Was a report made by any PERSON concerning the If so, state: 1(a) the name, title, identi?cation, number, and; employer of the PERSON who made the report; I the date and type of report made; the name, ADDRESS, and telephone number of the PERSON for whom the report was made; and (cl) the name, ADDRESS, and telephone?n?nmber of each PERSON who has the original or a copy of the report. RESPONSE TO FORM N0. 12.6: Other than reports that might have been generated by public agencies investigatzing'the ?re or those generated by experts by parties to the litigation, responding party knows of none such. FORM N0. 12.7: Have YOU OR ANYONE ACTING ON YOUR BEHALF inspected the sceneof the It?so, for each inSpection state: the name, ADDRESS, and telephone number of the individual making the inSpeCtion (except for expert witnesses covered by Code q/?Ciw?l Procedure section 2034); and the date of the inspection. ~15 DEFENDANT HOR NAR NO, as Trustee ol'lhc REVOCABLE TRUST Dated September 28, 2007?s ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM INTERROGATORIES. SET In CMO No. 3 Etlils Final Vuu?siunlelNAL SCDXADDITIONAL NG Trustee Additional Responses to CMOHJ Funn Rngs_l"lNAL SC ES ON Unless BREMER WHYTE BROWN 6 LLP THE ROTUNDA BUILDING 300 Frank Ognwn Plnzu SUITE 355 Oakland. CA 94812 RESPONSE TO FORM INTERROGATORY N0. 12.7: Just the attorneys for responding party and experts retained on responding pany?s behalf. Dated: October 10, 2017 BREMER WHYTE BROWN LLP ?Raym'on' . -- - Stephen C. Dreher Carla Vasques dos Santos-Moore Attorneys for Defendants CHOR NAR SIU NG, Individually and as Trustee of the CHOR NAR SIU NG REVOCABLE TRUST DATED September 28, 2007; EVA KAI NG L6 DEFENDANT CHOR NAR SIU NG, as Trustee of the REVOCABLE TRUST Dated September 28, 2007?s ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM INTERROGATORIES, SET to CMO No. 3 FonnRogs\Family Edits Finnl Vusions\F1NAL NG Trustee Additional Responses to Fonn ONLY.docx VERIFICATION TO FOLLOW Document? nu. 1.1? aw .. - ?11ng \BREMER WHYTE BROWN 5 LLP THE ROTUNDA BUILDING :00 ank H. Ogawa Plaza Suite 355 Oakland. CA 94012 PROOF OF SERVICE I am employed in the County of Alameda, State of California. I am over the age of 18 and not a party to the within action. My business address is The Rotunda Building, 300 Frank H. Ogawa Plaza, Suite 355, Oakland, CA 94612. On October 11, 2017, I served the within document(s) described as: DEFENDANT CHOR NAR SIU NO, as Trustee of teh CHOR NAR SIU NG REVOCABLE TRUST Dated September 28, 2007?s ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 on the interested parties in this action as stated below: Mary E. Alexander Jennifer L. Fiore Sophia M. Aslami saslami@marvalexanderlaw.com (BY ELECTRONIC MAIL SERVICE) Based upon CRC Rule 2.251 or an agreement of the parties to accept electronic service I caused such document(s) to be Electronically Mailed through Bremer, Whyte, Brown O'Meara electronic mail system for the above entitled case. Should your of?ce require a hard 00py of said document, please contact our of?ce. Executed on October 11,2017, at Oakland, California. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Natasha Y. Sullivan (Type or print name) (Signature) OF SERVICE - - BREMER WHYTE BROWN A LLP THE ROTUNDA 300 Frank Ogawa Plaza SUITE 355 Oakland, (194612 BR EMER WI-IYTE BROWN Raymond Meyer, State Bar No. 176235 Stephen C. Dreher, State .Bar No. 129482 Carla Vasques dos Santos-Moore, State Bar No. 241883 cmoore@bremerwlutecom The Rotunda Building . 300 Frank H. Ogawa Plaza; Suite 355 Oakland, CA 94612 Telephone: (510) 540-4881 Facsimile: (510) 540-4889 Attorneys for Defendants, NG, Individually and as Trustee of the CHOR NAR SIU NG REVOCABLE TRUST DATED September 28, 2007; EVA and KAI NG SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OFALAMEDA DAVID GREGORY, Individually, as Personal. Case NO. Representative of the ESTATE OF MICI-IELA GREGORY and as Successor in Interest of MICHELA GREGORY, Individually and as Successor in Interest of MICHELA GREGORY, Plaintiffs, vs. CHOR NAR, SIU NG, Individually and as Trustee of the CHOR NAR SIU NG REVOCABLE TRUST DATED September 28, 2007; EVA DERICK ION MICAH ALLISON, DANIEL OMAR JOHN JOEL also known as GOLDEN and DOES I through 200, inclusive, Defendants. DEFENDANT EVA ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 INTERROGAT ORIES I PROPOUNDING PARTY: CASE MANAGEMENT ORDER NUMBER 3 RESPONDINC PARTY: Defendant, EVA SET NUMBER: ONE DEFENDANT EVA NG ADDITIONAL RESPONSES 0 CASE MANAGEMEN ORDER NO 3 I ORM TNTERROGA .l ORIES, SET ONE II: SPONSES to CMO No 3 Fi?innRoylFamily Edits in: II SCDTADDI I IONAL NC Addition: il Responses Iu CMOM Fm Regs; FINAL 5CD EYES ONLY dues 1 FORM INTERROGATORY NO. 1.1: 2 State the name, ADDRESS, telephone number, and relationship to you of each PERSON 3 who prepared or assisted in the preparation of the responses to these interrogatories. (Do not 4 identify anyone who simply typed or reproduced the responses.) 5 ADDITIONAL RESPONSE TO FORM INTERROGATORY NO. 1.1: 6 Legal counsel, Stephen C. Dreher, Bremer Whyte Brown O?Meara, 300 Frank H. Ogawa 7 Plaza, Suite 355, Oakland, CA 94612; Telephone: (510) 540-4881. 8 FORM INTERROGATORY NO. 2.1: 9 State: 10 your name; 1 1 every name you have used in the past; and 12 the dates you used each name. 13 RESPONSE TO FORM INTERROGATORY NO. 2.1: 14 Eva Ng 15 None other; 16 From birth to present. 17 FORM INTERROGATORY NO. 2.2: 18 State the date and place of your birth. 19 ADDITIONAL RESPONSE TO FORM. INTERROGATORY NO..2.2: 20 THE RESPONSE TO INTERROGATORY NO. 22 IS DESIGNAGED AS 21 CONFIDENTIAL EYES 22 23 FORM INTERROGATORY NO. 2.5: 24 State: 25 your present residence 26 your residence ADDRESSES for the past ?ve years; and 27 the dates you lived at each ADDRESS. 28 BREMERI WHYTE BROWNS 2 I we SWEATER DEFENDANT EVA ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM i INTERROGATORIES, SET ONE Oai'andaCAlm?z ES to CMO No. 3 FonuRogs\Family Edits Final Versious\FlNAL RESPONSESVEVA NG Additional Responses to Form ONLY.docx mEN, BREMER WHYTE BROWN LLP THE ROTUNDA BUILDING 300 Frank H, Ogawa Plaza SUITE 355 Oakland. CA. 04612 -m ww \m ?to Idf? 11'" :17: m. nu.- way "an ..-: ,wq mm 17-? ..-- nu,- -- gv; a 4 1 ADDITIONAL RESPONSE TO FORM INTERROGATORY NO. 2.5: THE RESPONSE TO INTERROGATORY NO. 2.5 IS DESIGNAGED AS CONFIDENTIAL EYES (3) (C) FORM INTERROGATORY NO. 2.6: State: the name, ADDRESS, and telephone number of your present employer or place of self-employment; and the name, ADDRESS, dates of employment, job title, and nature of work for each employer or self-employment you have had from ?ve years before the INCIDENT until today. ADDITIONAL RESPONSE TO FORM INTERROGATORY NO. 2.6: . THE RESPONSE TO INTERROGATORY NO. 2.6 IS DESIGNAGED AS CONFIDENTIAL EYES (8) FORM INTERROGATORY NO. 2.7: State: the name and ADDRESS of each school or other academic or vocational institution you have attended, beginning with high school; the dates you attended; the highest grade level you have completed; and the degrees received. ADDITIONAL RESPONSE TO FORM INTERROGATORY NO. 2.7 3 DEFENDANT EVA ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM INTERROGATORIESFonnRogs\anily Edits Final Vcrsions\FlNAL RESPONSESIEVA NG Additional Responses to Fonn ON LY.docx BREMER WHYTE BROWN 11 LLP THE ROTUNDA BUILDING 300 Frank H: Onuwn Plaza SUITE 355 Oakland. CA. 941612 THE RESPONSE TO INTERROGATORY NO. 2.2 IS DESIGNAGED AS CONFIDENTIAL EYES (31) (C) (C) (C) FORM INTERROGATORY NO. 2.9: Can you speak English with ease? If not, what language and dialect do you normally use? RESPONSE TO FORM INTERROGATORY NO. 2.9: Yes. FORM INTERROGATORY NO. 2.10: Can you read and write English with case? If not, what language and dialect do you normally use? RESPONSE TO FORM INTERROGATORY NO. 2.10: FORM INTERROGATORY NO. 2.11: 4 DEFENDANT EVA ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM INTERROGATORIES, SET ONE 437\055\Discovcry\RESPONS ES to CMO No.3 FonnRogs\Fm11iiy Edits Final Velsions?iFlNAL NO Additional Responses to Fonn ONLY.docx I UH: awn ..-- ?a .71 11?" ..- ma .714 aw. wu Mu 24-. - SREMER WHYTE BROWN 5 LLP THE ROTUNDA BUILDING 300 ank 09am Plazn SUITE 355 Oakland. CA Dam: At the time of the INCIDENT were you acting as an agent or employee for any If so, state: the name, ADDRESS, and telephone number of that PERSON: and a description of your duties. RESPONSE TO FORM INTERROGATORY NO. 2.11: Objection, calls for a legal conclusion. However, without waiving this objection, and in the Spirit of discovery, I assisted my mother with collection of rent and contacts with the tenant at the warehouse property. FORM INTERROGATORY NO. 3.1: Are you a corporation? If so, state: the name stated in the current articles of incorporation; all other names used by the corporation during the past 10 years and the dates each was used; the date and place of incorporation; the ADDRESS of the principal place of business; and (6) whether you are quali?ed to do business in California. RESPONSE TO FORM INTERROGATORY NO. 3.1: No. (0) and FORM INTERROGATORY NO. 3.2: Are you a partnership? If so, state: the current partnership name; 5 DEFENDANT EVA ADDITIONAL RESPONSES TO CASE MANAGEMENT ORDER NO. 3 FORM INTERROGATORIESFonnRogs\anily Edits Final Versions\FlNAL RESPONSESVEVA NG Additional Responses ann ONLY. Kennedy, Kate (kkennedy@omm.com) Subject: RE: Gregory v. Ng, et al. 1437055 All: A circumstance arose over the weekend that will necessitate our proposing modifications to the existing protective order regarding discovery disclosures. A death threat was sent to Chor Ng, via the United States Mail at her home address. The FBI has been notified, as has the Alameda County District Attorney?s office. Both the FBI and the DA are actively investigating. We take these matters very seriously. Accordingly, we are working on a modification of the protective order as it relates to any information which could be used to by anyone to determine the physical location of our clients or the one sensitive witness. The proposed order will contain an ?Attorneys' Eyes-Only? provision regarding such personal contact information. We will provide the proposed protective order as soon as it is ready, hopefully sometime later this afternoon. This should not impact the disclosure of other, non-personal contact information contained in the interrogatory and document production responses. Regards, Steve Dreher Stephen C. Dreher Bremer Whyte Brown O'Meara, LLP 300 Frank Ogawa Plaza, Suite 355 Oakland, CA 94612 e: t: 510.540.4881 f: 510.540.4889 BWBremer Whyte Brown O'Meoro Arizona i Caiifornia 1 Coiorado 1 Nevada Washington Europe 1 South Africa brcirrieriirh life. com From: Janet Williams Sent: Monday, October 09, 2017 11:47 AM To: Abbie Chin; Adam Shearer, Esq.; Aimee Kirby; Alison Cordova, Esq.; Amrita Prasad; Amy Chau Andrea Bolnick; Anne Hunt; Ashkahn Mohamadi, Esq.; Bee Speer; Brian J. Malloy, Esq.; Bronwyn Kay Galloway; Carey Groom; Carla Jimenez; Carla Moore; Casey Gee; Chris Dolan; Christina Ayala; Christopher T. Aumais, Esq. Claire Hauso; Craig M. Peters, Esq.; D. Mark Jackson, Esq. Dan Siegel, Esq. David Cannon, Esq.; Debra M. Rose; Diane Marger Moore, Esq.; Do Kim, Esq. Elisa Miller; Frank M. Pitre, Esq. Gregory Vanni, Esq. Hanna Mohr, Esq.; Heather Maxey; Iberie M. Seck, Esq. Isabelle Tan; J. Gary Gwilliam, Esq.; Janet Ospina; Janet Williams; Jashoda Kashyap, Esq.; Jennifer Fiore; John M. Feder, 1 Esq.; John R. Browne, Esq. John Thyken, Esq.; Jonathan E. Davis, Esq.; Joshua Cohen Slatkin, Esq.; Kate Dyer, Esq.; Keith G. Bremer; Kelly Winter, Esq. Kevin M. Osborne, Esq.; Kimberly Miller, Esq. Bowen, Esq.; Kymberly Speer, Esq.; LaTanya Wyatt; Laurie Edelstein, Esq.; Law Of?ces of Paula Canny; Lorrie Orchard; Lucia Rodriguez; Madison Miller; Mallory Soto; Marcelis Morris, Esq.; Marta Carreno; Mary Alexander; Mary Mazzola; Maybelle Dominguez; Michael Wenzel, Esq.; Mike Cornwell; Monika Yamuremye; Oresetes Cross, Esq.; Paul A. Matiasic, Esq.; Paula Canny, Esq.; Raf? H. Ohanian, Esq. Raymond Marshall, Esq.; Ray Meyer; Rita Juarez; Robert Arns, Esq.; Robert Bale, Esq.; Robert C. Foss, Esq.; Robert Thompson; Ronald L.M. Goldman, Esq.; Ryan J. Vlasak, Esq. S. Dean Ruiz, Esq. Sandra Ribera Speed, Esq.; Seth Sias, Esq.; Sophia Aslami; Stephen C. Dreher; Thomas Brandi, Esq. Timothy A. Loranger, Esq.; Toni Stevens; William G. Kaupp, Esq.; Winston Moody, Esq. Subject: Gregory v. Ng, et al. Counsel, Attached is the executed Stipulation Regarding Ng Defendants' Production of Documents Pursuant to Case Management Order No. 3. Thank you, Janet Williams, Paralegal Mary Alexander Associates, RC. 44 Montgomery Street, Suite 1303 San Francisco, CA 94104 (415) 433-4440 (415) 433-5440 - facsimile iwilliams@marvalexanderlaw.com This e?mail message contains confidential, privileged information intended solely for the addressee. Please do not read, copy, or disseminate it unless you are the addressee. If you have received it in error, please call (415) 433-4440 and ask to speak with the message sender. Also, we would appreciate your forwarding the message back to us and deleting it from your system. Thank you. CONFIDENTIAL ATTORNEY WORK PRODUCT. No criminal charges for G. Ship owner Chor Ng, but she could co.t more than $3 Page 1 of 4 NEWS CRIME 8: COURTS criminal charges for Ghost Ship owner Chor g, but she could collect more than $3 million in insurance Ghost Ship warehouse owner Chor Ng could get more than $3.1 i million in insurance payments following the Dec. 2 ?re that killed i 36 people. (Photo by Darin Marshall) By GAFNI and DAVID DEBOLT The San Jose Mercury News September 27, 2017 at 4:31 pm 5 denverpo st.com/201 7/ 09/2 7/ 1 0/27/2017 No criminal charges for Gl. Ship owner Chor Ng, but she could co. more than $3 Page 2 of 4 OAKLAND The landlord of the Ghost Ship warehouse where 36 people died in a ?re on Dec. 2 has avoided prosecution, but she?s set to collect at least $3.1 million in insurance payments, according to an insurance document obtained exclusively by this news agency. Claims Adjusting Group has reserved $3.1 million to pay Chor Ng, who owns the Fruitvale District warehouse and adjacent properties, to cover her property and liability policy. The document indicates she has received more than $670,000 so far, likely to cover her attorney?s fees and facility security costs. However, Ng?s $6 million liability insurance maximum will likely never make its way to the dozens of victims suing her and other agencies for the deadly ?re, one insurance expert says. ?Everything will likely be exhausted long before they go to trial,? said Karl Susman. owner of Susman Insurance Agency and expert insurance witness, who reviewed the Ng document. ?And then she personally might declare bankruptcy I {?53 60.0wNL- N?l Harm Fro-w Sm tau}! Mam-n . ?we" mum urn-murauinwmm 1mmVinnie-n um) We. In mm Mm mum: Ive-u matron. IMI mm Witt! new? um HA In minim urn-mun! an steam ma um minim" in?. summation" Huh I tun lute "Iv-ht alumnus .as until use: lam murmur mi mweethm-Iumm A nun?: m- tum emu-m one.? In mu. autumn-i Inm- am am In? mam weir.? ?mu Ill ?u Imam run- ?131:? serum)!" mean? um? am an inch: (M. e. mehHIMr-Mumu?ih-uehg?aew-u 0mm!" tidal-warm mam me ha suns-ear ?p An insurance document exclusively obtained by the Bay Area News Group shows that Chor Ng, owner of the Ghost Ship warehouse, is set to receive at least million in insurance payments from the ?re. 10/27/2017 No criminal charges for G1. Ship owner Chor Ng, but she could co. more than $3 Page 3 of 4 The insurance document was obtained Tuesday, and on Wednesday Derick Ahnena, master tenant at the former unpetmitted ans collective, and his second-in-command Max Harris pleaded not guilty to 36 counts of involuntary manslaughter. Ng and her family have not been criminally charged in the case, however they are defendants in dozens of civil claims. The insurance claim document shows two Ghost Ship related claims resulting ?'om the Dec. 2 ?re. Ng?s policy covers a block of properties she owns there, from 1305 to 1313 3 Street and 3065 to 3073 International Boulevard. Ng paid $2,265 this year for $1.6 million of property coverage on the warehouse, according to the record. Her policy included $1 million of basic liability coverage and she also received an extra $5 million. Such a low premium is not unusual for commercial warehouse insurance, Susman said. ?When you think about it what?s going to happen at a warehouse?? he said. ?The only real exposure is in the event of something like this happening which is unusual.? According to the document, the insurer has estimated it will have to pay Ng more than $2.1 million, citing as a description of the claim: ?Building intended for warehouse use may have facilitated a Rave or other unintended/unauthorized activity by the tenant." Susman said he was ?puzzled" why the insurance company was willing to pay out $2.1 million for the building when the total insurance value was only $1.6 million. The insurance company has already activated Ng's basic liability coverage of $1 million, according to the record, and has paid more than $670,000 to her already. Susrnan said that money has likely been spent on attomeys, public relations consultants, warehouse security and other costs. A judge ordered Ng to hire round-the-clock security at the burned out warehouse and at a debris dump site to secure possible evidence. Her attorneys have been working with public relations consultant Sam Singer since the ?re. Singer said he would check with Ng?s attorneys on Wednesday to see if they had a comment on the insurance revelations. Cb eck back for updates. 7/ 09/27/ 1 0/27/2017 No criminal charges for G}.Ship owner Chor Ng, but she could co]. more than $3 Page 4 of 4 TAGS: OAKLAND WAREHOUSE FIRE Matthias Gafni David DeBolt SPONSORED CONTENT This Couple Trusts Their Local Caf? Ambassador With Money and New Parent Tips By Capital One? Baby advice and ?nancial advice in one place. CLICK FOR DIGITAL HOME DELIVERY 60% OFF 7/09/ 27/ 1 0/2 7/20 1 7 7 28 BREMER WHYTE BROWN 5 LLP 300 FRANK H: OGAWA PL. SUITE 355 OAKLAND, CA 94312 (510) 540-4881 BREMER WHYTE BROWN LLP Raymond Meyer, Jr., State Bar No. 176235 Stephen C. Dreher, State Bar No. 129482 Carla Vasques dos Santos-Moore, State Bar No. 214883 The Rotunda Building 300 Frank H. Ogawa Plaza; Suite 355 Oakland, CA 94612 Telephone: (510) 540-4881 Facsimile: (510) 540-4889 Attorneys for Defendants, CHOR NAR SIU NG, Individually and as Trustee of the CHOR NAR SIU NG REVOCABLE TRUST DATED September 28, 2007; EVA NG and KAI NG SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ALAMEDA DAVID GREGORY, Individually, as Personal Representative of the ESTATE OF MICHELA GREGORY and as Successor in Interest of MICHELA KIMBERLY GREGORY, Individually and as Successor in Interest of MICHELA GREGORY, Plaintiffs, vs. CHOR NAR SIU NG, Individually and as Trustee of the CHOR NAR SIU NG REVOCABLE TRUST DATED September 28, 2007; EVA DERICK ION MICAH DANIEL OMAR JOHN 100% JOEL SHANAHAN, also known as GOLDEN RUSSELL E.L. BUTLER, aka BLACK OPAL BENJAMIN MAX PACIFIC GAS ELECTRIC DOES 1 through 500, inclusive, Defendants. AND ALL RELATED CASES Case No. RG16843631 (And Related Cases: RG17871131) Judge: Brad Seligman Dept: 30 I MODIFICATION TO PROTECTIVE ORDER REGARDING INFORMATION PRODUCED IN DISCOVERY Next CMC: November 7, 2017 Time: 3:00 pm. Department: 23 MODIFICATION OF PROTECTIVE ORDER RE: INFORMATION PRODUCED IN DISCOVERY ORDER STIPULATION RE Eyes Only\Proposed Protective Order_Shost Ship.docx BREMER WHYTE BROWN A ONE RA LLP 300 FRANK H. OGAWA PL, SUITE 355 000le OAKLAND. CA 94512 (510) 540-4681 1. PURPOSES AND LIMITATIONS Disclosure and discovery activity in this action are likely to involve production of con?dential, proprietary, or private information for which Special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly, the parties hereby stipulate to and petition the court to enter the following Stipulated Protective Order. The parties acknowledge that this Order does not confer blanket protections on all disclosures or reSponses to discovery and that the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to con?dential treatment under the applicable legal principles. The parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order does not entitle them to file con?dential information under seal; California Rule of Court 2.55.1 sets forth the procedures that must be followed and the standards that will be applied when a party seeks permission from the court to ?le material under seal. 2. DEFINITIONS 2.1 Challenging Par_ty: a Party or Non-Party that challenges the designation of documents, information, or items under this Order. 2.2 Information or Items: documents, information (regardless of how it is generated, stored or maintained), or tangible things that qualify for protection under the provisions of the California Code of Civil Procedure that provide for the application for and issuance of protective orders covering information sought in discovery or by the parties stipulation. 2.3 Counsel or Outside Counsel: Attorneys_of Record for a Party in this litigation, as well as other attorneys and support staff in their respective law ?rms paralegals, case clerks, assistants, and secretaries). This does not include In-House counsel, as de?ned in Section 2.8. 2.4 Designating Pam: a Party or Non-Party that designates information or items thatit produces in disclosures or in responses to discovery as CONFIDENTIAL EYES 2 MODIFICATION OF PROTECTIVE ORDER RE: INFORMATION PRODUCED IN DISCOVERY ORDER STIPULATION RE Eyes OnIy\Proposcd Protective Order_Shost Ship.docx BREMER WHYTE BROWN a LLP 300 FRANK H. oenwa PL. SUITE 355 OAKLAND. CA 94312 (510) 540.4115! 2.5 Disclosure or Discovery Material: all documents, items, or information, regardless of the medium or manner in which it is generated, stored, or maintained (including, among other things, testimony, transcripts, and tangible things), that are produced or generated in disclosures or responses to discovery in this matter. 2.6 lime?rt: a person with specialized knowledge or experience in a matter pertinent to the litigation who (1) has been retained by a Party or its counsel to serve as an expert witness or as a consultant in this action, (2) is not a past or current employee of a Party or of a Party?s competitor, and (3) at the time of retention, is not anticipated to become an employee of a Party or of a Party?s competitor. 2.7 EYES Information or Rem sensitive Disclosure or Discovery Material that constitute or contain in whole or in part, information of which the Producing Party reasonably believes disclosure to another Party or Non- Party would create a substantial risk of serious harm that could not be avoided by less restrictive means and/or will harm its competitive position if the information becomes known to a party other than the Producing Party. Such information or items may constitute or contain, but are not limited to: past, current, and prospective revenue, pro?t, pricing and cost ?gures; audience or customer information of the Producing Party?s products or services; highly sensitive technical information relating to research for an development of current or future products or services; highly sensitive marketing plans; 6 highly sensitive forecasts; customer-related data; customer orders, contracts, and quotations, and information by which a party?s or a sensitive witnesses? residence or employment location might be known. 2.8 In-I-Iouse Counsel: attorneys who are employees of a party to this action. In-House Counsel is not and does not include Outside Counsel of Record or any other outside counsel. 2.9 Non?Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 2.10 Outside Counsel of Record: attorneys (and their support staff) who are not employees of a party to this action but are retained to represent or advise a party to this action and 3 MODIFICATION OF PROTECTIVE ORDER RE: INFORMATION PRODUCED IN DISCOVERY ORDER STIPULATION RE DlSCOVERY\Atlorney?s Eyes Only\Proposed Protective Ordcr_Shost Ship.docx BREMER WHYTE BROWN 5 LLP 300 FRANK H. OGAWA FL. SUITE 355 OAKLAND. CA 84812 (510) 5404851 have appeared in this action on behalf of that party or are af?liated with a law ?rm which has appeared on behalf of that party. I 2.11 Part5 any party to this action, including all of its of?cers, directors, employees, consultants, retained experts, and Outside Counsel of Record) and their support staffs). 2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this action. 2.13 Professional Vendors: persons or entities that provide litigation support services photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, storing, or retrieving data in any form or medium) and their employees and subcontractors. 2.14 Protected Material: any Disclosure or Discovery Material that is designated as or as CONFIDENTIAL EYES 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing Party. 3- The protections conferred by this Stipulation and Order cover not only Protected Material (as de?ned above), but also (1) any information c0pied or extracted from Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, conversations, or presentations by Parties or their Counsel that might reveal Protected Material. However, the protections conferred by this Stipulation and Order do not cover the following information: any information that is in the public domain at the time of disclosure to a Receiving Party or becomes part of the public domain after its disclosure to a Receiving Party as a result of publication not involving a violation of this Order, including becoming part of the public record through trial or otherwise; and any information known to the Receiving Party prior to the disclosure or obtained by the Receiving Party after the disclosure from a source who obtained the information lawfully and under no obligation of con?dentiality to the Designating Party. Any use of Protected Material at trial shall be governed by a separate agreement or order. 4 MODIFICATION OF PROTECTIVE ORDER RE: INFORMATION PRODUCED IN DISCOVERY ORDER RE DlSCOVERY?tAttorney's Eyes Only\Proposed Protective Ordcr__Shost Ship.docx BREMEFI wr-me BROWN 5 LLP 300 FRANK H. OGAWA PL. SUITE 355 OAKLAND, CA 94512 (510; 540-4531 4. DURATION Even after ?nal disposition of this litigation, the con?dentiality obligations imposed by this Order shall remain in effect until a Designating Party agrees otherwise in writing or acourt order otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all claims and defenses in this action, with or without prejudice; and (2) ?nal judgment herein after the completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, including the time limits for ?ling any motions or applications for extension of time pursuant to applicable law. 5. DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party or Non-Party that designates information or items for protection under this Order must take care to limit any such designation to speci?c material that quali?es under the appropriate standards. To the extent it is practical to do so, the Designating Party must designate for protectiononly those parts of material, documents, items, or oral or written communications that qualify so that other portions of the material, documents, items, or communications for which protection is not warranted are not swept unjustifiably within the ambit of this Order. Mass, indiscriminate, or routinized designations are prohibited. If it comes to a Designating Party?s attention that information or items that it designated for protection do not qualify for protection at all or do not qualify for the level of protection initially asserted, that Designating Party must notify all other parties that it is withdrawing the mistaken designation. 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order (see, e. second paragraph of Section 5.2(a) below), or as otherwise stipulated orordered, Disclosure or Discovery Material that quali?es for protection under this Order must be clearly so designated before the material is disclosed or produced. Designation in conformity with this Order requires: for information in. dacumentar?y form paper or electronic documents, but including transcripts of depositions or other pretrial or trial proceedings), that the Producing Party 5 MODIFICATION OF PROTECTIVE ORDER RE: INFORMATION PRODUCED 1N DISCOVERY ORDER STIPULATION RE Eyes Only\Proposcd Protective Order_Shost Ship.docx BREMER WHYTE BROWN d1 300 FRANK H. OGAWA PLOAKLAND. CA 84612 (510) 540?48? af?x the legend or CONFIDENTIAL to each page that contains protected material. A Party or Non-Party that makes original documents or materials available for inspection need not designate them for protection until after the inSpecting Party has indicated which material it would like copied and produced. During the inspection and before the designation, all of the material made available for inspection shall be deemed EYES After the inspecting Party has identi?ed the documents it wants copied and produced, the Producing Party must determine which documents, or portions thereof, qualify for protection under this Order. Then, before producing the speci?ed documents,the Producing Party must af?x the appropriate legend I CONFIDENTIAL EYES to each page that contains Protected Material. for testimony given in deposition or in other pretrial or trial proceedings, that the Designating Party identify on the record, before the close of the deposition, hearing, or other proceeding, all protected testimony and specify the level of protection being asserted. When it is impractical to identify separately each portion of testimony that is entitled to protection and it appears that substantial portions of the testimony may qualify for protection, the Designating Party may invoke on the record (before the deposition, hearing, or other proceeding is concluded) a right to have up to 21 days to identify the Speci?c portions of the testimony as to which protection is sought and to specify the level of protection being asserted. Only those portions of the testimony that are appropriately designated for protection within the 21 days shall be covered by the provisions of this Stipulated Protective Order. Alternatively, a Designating Party may specify, at the deposition or up to 21 days afterwards if that period is properly invoked, that the entire transcript shall be treated as or EYES While Protected Material is being used at a deposition, no person to whom the Protected Material may not be disclosed under this Order shall be present. The use of a document as an exhibit at a deposition shall not in any way affect its designation as or CONFIDENTIAL EYES 6 MODIFICATION OF PROTECTIVE ORDER RE: INFORMATION PRODUCED IN DISCOVERY ORDER STIPULATION RE Eyes Only/\Proposed Protective Order_Shost Ship.docx 1 Transcripts containing Protected Material shall have an obvious legend on the title page that 2 the transcript contains Protected Material, and the title page shall be followed by a list of all pages 3 (including line numbers as appropriate) that have been designated as Protected Material and the 4 level of protection being asserted by the Designating Party. The Designating Party shall inform the 5 court reporter of these requirements. Any transcript that is prepared before the expiration of a 21- 6 day period for designation shall be treated during that period as if it had been designated 7 CONFIDENTIAL EYES in its entirety unless otherwise agreed. After 8 the expiration of that period, the transcript shall be treated only as actually designated. 9 for information produced in some form other than documentary and for any other . 10 tangible items, that the Producing Party af?x in a prominent place on the exterior of the container 11 or containers in which the information or item is stored the legend 12 CONFIDENTIAL EYES 13 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to 14 designate quali?ed information or items does not, standing alone, waive the Designating Patty?s 15 right to secure protection under this Order for such material. Upon timely correction of a 16 designation, the Receiving Party must make reasonable efforts to assure that the material is treated 17 in accordance with the provisions of this Order. 18 6. CHALLENGING CONFIDENTIALITY 19 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of 20 con?dentiality at any time. Unless a prompt challenge to a Designating Party?s con?dentiality 21 designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic 22 burdens, or a signi?cant disruption or delay of the litigation, a Party does not waive its right to 23 challenge a con?dentiality designation by electing not to mount a challenge after the 24 original designation is disclosed. 25 6.2 Meetand Confer. The Challenging Party shall initiate the dispute resolution process 26 by providing written notice of each designation it is challenging and describing the basis for each 27 challenge. To avoid ambiguity as to whether a challenge has been made, the written notice must 28 BREMER WHYTE BROWN 7 LLP MODIFICATION OF PROTECTIVE ORDER RE: INFORMATION PRODUCED IN DISCOVERY nun FRAEGEE TESAWA PL. ?tagging?? ORDER STIPU LATION RE Eyes Only\Proposcd Protective Order?Shost Ship.docx BREMER WHYTE BROWN 5 LLP 300 FRANK H. OGAWA PL. SUITE 355 OAKLAND. CA 94812 540-4581 recite that the challenge to con?dentiality is being made in accordance with this speci?c paragraph of the Protective Order. The parties shall attempt to resolve each challenge in good faith and must begin the process by conferring directly (in voice to voice dialogue; other forms of communication are not suf?cient) within 14 days of the date of service of notice. In conferring, the Challenging Party must explain the basis for its belief that the con?dentiality designation was not proper and must give the Designating Party an opportunity to review the designated material, to reconsider the circumstances, and, if no change in designation is offered, to explain the basis for the chosen designation. A Challenging Party may proceed to the next stage of the challenge process only if it has engaged in this meet and confer process ?rst or establishes that the Designating Party is unwilling to participate in the meet and confer process in a timely manner. 6.3 Judicial Intervention. If the Parties cannot resolve a challenge withoutcourt intervention, the Challenging Party may ?le and serve a motion challenging the designation (and in compliance with California Rule of Court 255.1, if applicable). Each such motion must be accompanied by a competent declaration affirming that the movant has complied with the meet and confer requirements imposed in the preceding paragraph. The burden of persuasion in any such challenge proceeding shall be on the Designating Party. Frivolous challenges and those made for an imprOper purpose to harass or impose unnecessary expenses and burdens on other parties) may expose the Challenging Party to sanctions. All parties shall continue to afford the material in question the level of protection to which it is entitled under the Producing Party?s designation until the court rules on the challenge. No Party shall object to the ?ling of the challenged material with the Court under seal in order for the Court to resolve the matter or otherwise rule on the challenge. 7. ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or produced by another Party or by a Non-Party in connection with this case only for prosecuting, defending, or attempting to settle this litigation. Such Protected Material may be disclosed only to 8 OF PROTECTIVE ORDER RE: PRODUCED lN DISCOVERY ORDER STIPULATION RE DlSCOVERY\Attorney's Eyes Only\Proposed Protcctivc OrdcruShost Ship.docx BREMER BROWN a. LLP 100 FRANK H. OGAWA PL, SUITE 355 OAKLAND. CA 94612 (510) 5404881 the categories of persons and under the conditions described in this Order. When the litigation has been terminated, a Receiving Party must comply with the provisions of Section 13 below(FINAL DISPOSITION). Protected Material must be stored and maintained by a Receiving Party at a location and in a secure manner that ensures that access is limited to the persons authorized under this Order. 7.2 Disclosure of Information or Items. Unless otherwise ordered by the court or permitted in writing by the Designating Party, a Receiving Party may disclose any information or item designated only to: the Receiving Party?s Outside Counsel of Record in this action, as well as employees or staff of said Outside Counsel of Record to whom it is reasonably necessary to disclose the information for this litigation; the of?cers, directors, and employees (including In-House Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this litigation; Experts (as defined in this Order) of the Receiving Party to whom disclosure is reasonably necessary for this litigation and who have signed the ?Acknowledgment and Agreement to Be Bound? (Exhibit the court and its personnel; court reporters and their staff; (6) professional jury or trial consultants or mock jurors, and Professional Vendors to whom disclosure is reasonably necessary for this litigation and who have signed the ?Acknowledgment and Agreement to Be Bound? (Exhibit (1) during their depositions, witnesses in the action to whom disclosure is reasonably necessary and who have signed the ?Acknowledgment and Agreement to Be Bound? (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the court. Pages of transcribed deposition testimony or exhibits to depositions that reveal Protected Material must be separately bound by the court reporter and may not be disclosed to anyone except as permitted under this Stipulated Protective Order. the author or recipient of a document containing the information or a custodian. 9 MODIFICATION OF PROTECTIVE ORDER RE: INFORMATION PRODUCED IN DISCOVERY ORDER STIPULATION RE Eyes OnlyIProposed Protective Order_Shost Ship,docx BREMER WHYTE BROWN MEARA LLP 300 FRANK H. OGAWA PL. SUITE 355 ~OAKLAND, CA 94612 (510) 540-4661 7.3 Disclosure of CONFIDENTIAL EYES Information or Items. Unless otherwise ordered by the court or permitted in writing by the Designating Party, a Receiving Party may disclose any information or item designated CONFIDENTIAL EYES only to: the Receiving Party?s Outside Counsel of Record in this action, as well as employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose the information for this litigation and who have signed the ?Acknowledgment and Agreement to Be Bound? that is attached hereto as Exhibit Experts of the Receiving Party to whom disclosure is reasonably necessary for this litigation, (2) who have signed the ?Acknowledgment and Agreement to Be Bound? (Exhibit A), and (3) as to whom the procedures set forth in paragraph below, have been followed; (0) the court and its personnel; court reporters and their'staff, professional jury or trial consultants and mock jurors, and Professional Vendors to whom disclosure is reasonably necessary for this litigation and who have signed the ?Acknowledgment and Agreement to Be Bound? (Exhibit and the author or recipient of a document containing the information or a custodian. 7.4.Pi'ocedures for Approving or Obi?ectinu to Disclosure of CONFIDENTIAL - ATTORNEYS EYES Information or Items toExperts. Unless otherwise ordered by the court or agreed to in writing by the Designating Party, a Party that seeks to disclose to an Expert (as de?ned in this Order) any information or item that has been designated CONFIDENTIAL EYES pursuantto paragraph 7.3(b) ?rst must make a written request to the Designating Party that (1) sets forth the full name of the Expert, (2) attaches a copy of the Expert?s current resume, (3) identi?es the Expert?s current employer(s), (4) identi?es each person or entity from whom the Expert has received compensation or funding for work in his or her areas of expertise or to whom the expert has provided professional services, including in connection with a litigation, at any time during the preceding five years, and (5) identi?es (by name and number of the case, ?ling date, and location 10 MODIFICATION OF PROTECTIVE ORDER RE: INFORMATION PRODUCED IN DISCOVERY ORDER STIPULATION RE Eyes OnlyiProposed Protective Order_Shost Ship.docx BREMER WHYTE BROWN 5 LLP 300 FRANK H. OGAWA PL. SUITE 355 OAKLAND. CA 94012 (510) 54041331 of court) any litigation in connection with which the Expert has offered expert testimony, including through a declaration, report, or testimony at a deposition or trial, during the preceding ?ve years. A Party that makes a request and provides the information Specified in the preceding paragraphs may disclose the subject Protected Material to the identi?ed Expert unless, within 5 days of delivering the request, the Party receives a written objection from the DesignatingParty. Any such objection must set forth in detail the grounds on which it is based. (0) A Party that receives a timely written objection must meet and confer with the Designating Party (through direct voice to voice dialogue) to try to resolve the matterby agreement within 4 days of the written objection. If no agreement is reached, the Party seekingto make the disclosure to the Expert may ?le a motion with the Court (and in compliance with Civil Local Rule 79-5, if applicable) seeking permission from the court to do so. Any such motion must describe the circumstances with speci?city, set forth in detail the reasons why the disclosure to the Expert is reasonably necessary, assess the risk of harm that the disclosure would entail, and suggest any additional means that could be used to reduce that risk. In addition, any such motion must be accompanied by a competent declaration describing the parties? efforts to resolve the matter by agreement the extent and the content of the meet and confer discussions) and setting forth the reasons advanced by the Designating Party for its refusal to approve the disclosure. In any such proceeding, the Party opposing disclosure to the Expert shall bear the burden of proving that the risk of harm that the disclosure would entail (under the safeguards proposed) outweighs the Receiving Party?s need to disclose the Protected Material to its Expert. 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION If a Party is served with a subpoena or a court order issued in other litigation that compels disclosure of any information or items designated in this action as or CONFIDENTIAL EYES that Party must: notify in writing the Designating Party. Such noti?cation shall includea copy of the subpoena or court order; 1 1 MODIFICATION OF PROTECTIVE ORDER RE: INFORMATION PRODUCED IN DISCOVERY ORDER STIPU LATION RE DlSCOVERY\Attorney?s Eyes Only\PropOSEd Protective Order_Shost Ship.docx BREMER WHYTE BROWN 6 LLP 300 FRANK H. OGAWA PL. OAKLAND. CA 91612 (510) SID-4851 notify in writing the party who caused the subpoena or order to issue in the other litigation that some or all of the material covered by the subpoena or order is subject to this copy of the subpoena or court order; (0) cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material may be affected. If the Designating Party timely seeks a protective order, the Party served with the subpoena or court order shall not produce any information designated in this action as or CONFIDENTIAL EYES before a determination by the court from which the subpoena or order issued, unless the Party has obtained the Designating Party?s permission. The Designating Party shall bear the burden and expense of seeking protection in that court of its confidential material and nothing in these provisions should be construed as authorizing or encouraging a Receiving Party in this action to disobey a lawful directive from another court. 9. A PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS LITIGATION The terms of this Order are applicable to information produced by a Non-Party in this action and designated as or CONFIDENTIAL - EYES Such information produced by Non-Parties in connection with this litigation is protected by the remedies and relief provided by this Order. Nothing in these provisions should be construed as prohibiting a Non-Party from seeking additional protections. In the event that a Party is required, by a valid discovery request, to produce a Non- Party?s con?dential information in its possession, and the Party is subject to an agreement with the Non-Party not to produce the Non-Party?s con?dential information, then the Party shall: 1. notify in writing the Requesting Party and the Non-Party that some or all of the information requested is subject to a con?dentiality agreement with a Non-Party; 2. provide the Non-Party with a mm of the Stipulated Protective Order in 12 MODIFICATION OF PROTECTIVE ORDER RE: INFORMATION PRODUCED lN DISCOVERY ORDER STIPULATION RE DlSCOVERYlAttorney's Eyes Only\Proposcd Protective Ordcr_Shost Ship.docx BHEMER WHYTE BROWN 5 CM EARA LLP 300 FRANK H, OGAWA PL. SUITE 355 25 26 27 28 OAKLAND. CA 94612 (510) 540.4391 this litigation, the relevant discovery request(s), and a reasonably speci?c description of the information requested; and 3. make the information requested available for inspection by the Non?Party. If the Non-Party fails to object or seek a protective order from this court within 4days of receiving the notice and accompanying information, the Receiving Party may produce the Non- Party?s con?dential information responsive to the discovery request. If the Non-Party timely seeks a protective order, the Receiving Party shall not produce any information in its possession or control that is subject to the con?dentiality agreement with the Non-Party before a determination by the court. Absent a court order to the contrary, the Non-Party shall bear the burden and expense of seeking protection in this court of its Protected Material. 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected Material to any person or in any circumstance not authorized under this Stipulated Protective Order, the Receiving Party must immediately notify in writing the Designating Party of the unauthorized disclosures, use its best efforts to retrieve all unauthorized copies of the Protected Material, inform the person or persons to whom unauthorized disclosures were made Of all the terms of this Order, and request such person or persons to execute the ?Acknowledgment and Agreement to Be Bound? that is attached hereto as Exhibit A. ll. PRIVILEGE LOG A Producing Party may withhold production of a document or portions of a document based on the assertion that the otherwise responsive document is privileged attorney-client privilege, work-product doctrine, and/or other applicable privilege). Within a reasonable time after production of any documents from which any materials have been withheld as privileged, the party asserting a claim of privilege will describe the nature of the documents or other material withheld in a manner that complies with Federal Rule of Civil Procedure Unless otherwise agreed to by the parties or ordered by the court, the parties are not required to log or otherwise provide information about privileged documents dated on or after July 10,2017. 1 3 MODIFICATION OF PROTECTIVE ORDER RE: INFORMATION PRODUCED IN DISCOVERY ORDER STIPULATION RE Eyes Only\Proposed Protective Ordcr_Shost Ship.docx BREMER WHYTE BROWN .3. 300 FRANK H. OGAWA PL. SUITE 355 OAKLAND. CA 94812 (510) 540-4351 12. MISCELLANEOUS 12.] Right to Further Relief. Nothing in this Order abridges the right of any person to seek its modi?cation by the court in the future. 12.2 Eight to Assert Other Obiecti'on?s. By stipulating to the entry of this Protective Order no Party waives any right it otherwise would have to object to disclosing or producing any information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no Party waives any right to object on any ground to use in evidence of any of the material covered by this Protective Order. 12.3 Filing Protected Material. Without written permission from the Designating Party or a court order secured after appropriate notice to all interested persons, a Party may not ?le in the public record in this action any Protected Material. A Party that seeks to ?le under seal any Protected Material must comply with California Rule of Court 255.1. Protected Material may only be ?led under seal pursuant to a court order authorizing the sealing of the speci?c Protected Material at issue. If a Receiving Party's request to ?le Protected Material under seal pursuant to is California Rule of Court 255.1 by the court, then the Receiving Party may ?le the Protected Material in the public record pursuant to California Rule of Court 255.1unless otherwise instructed by the court. 13. FINAL DISPOSITION Within 60 days after the ?nal disposition of this action, as de?ned in Section 4, each Receiving Party must return all Protected Material to the Producing Party or destroy such material. As used in this subdivision, ?all Protected Material? includes all copies, abstracts, compilations, summaries, and any other format reproducing or capturing any of the Protected Material. Whether the Protected Material is returned or destroyed, the Receiving Partymust submit a written certi?cation to the Producing Party (and, if not the same person or entity, to the Designating Party) by the 60-day deadline that af?rms that the Receiving Party has not retained any copies, abstracts, compilations, summaries or any other format reproducing or capturing any of the Protected Material. Notwithstanding this provision, Counsel are entitled to retain an archival copy of all 14 MODIFICATION or PROTECTIVE ORDER RE: INFORMATION PRODUCED IN DISCOVERY ORDER STIPULATION RE DlSCOVER??Attorney's Eyes Only\Proposed Protective Order_Shost Ship.docx BREMER WHYTE BROWN A LLP 300 FRANK H. OGAWA PL. SUITE 355 OAKLAND. CA (510) 5404881 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work product, and consultant and expert work product, even if such materials contain Protected Material. Any such archival COpies that contain or constitute Protected Material remain subject to this Protective Order as set forth in Section 4 above. IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. Dated: October 10, 2017 BREMER WHYTE BROWN LLP By; 0? Raymond Meyer Jr. Stephen C. Dreher Carla Moore Attorneys for Defendants, CHOR NAR SIU NG, Individually and as Trustee of the CHOR NAR SIU NG REVOCABLE TRUST DATED September 28, 2007; EVA and KAI NG Dated: October 10, 2017 MARY ALEXANDER ASSOCIATES By: Mary E. Alexander, Esq. Jennifer L. Fiore, Esq. SOphia M. Aslami, Esq Liaison Counsel on behalf of Attorneys for Plaintiffs [Liaison Counsel] ATTESTATION I hereby attest that concurrence in the ?ling of this document has been obtained from all participating counsel for plaintiffs. Mary E. Alexander 15 OF PROTECTIVE ORDER RE: INFORMATION PRODUCED IN DISCOVERY H:\l43 ORDER STIPULATION RE Eyes Protective Order_Shost Ship.docx BREMER WHYTE BROWN 6 LLP 300 FRANK H. OGAWA PL. SUITEOAKLAND. CA 9-1612 (510) 5404591 EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT IO BE BOUND I, [print or type full name], of [print or type full address], declare under penalty of perjury that I have read in its entirety and understand the Stipulated Protective Order that was issued by the Alameda County Superior Court on in the case of The Ghost Ship ?re Litigation, lead case Gregory, et al. v. Chor Nar Siu Ng, et a1. Case No. R616843631 and all cases deemed related. I agree to comply with and to be bound by all the terms of this stipulated Protective Order and I understand and acknowledge that failure to so comply could expose me to sanctions and punishment in the nature of contempt. I solemnly promise that I will not disclose in any manner any information or item that is subject to this Stipulated Protective Order to any person or entity except in strict compliance with the provisions of this Order. I further agree to submit to the jurisdiction of the Superior Court for the County of Alameda, State of California for the purpose of enforcing the terms of this Stipulated Protective Order, even if such enforcement proceedings occur after termination of this action. I hereby appoint [print or type full name] of [print or type full address and telephone number] as my California agent for service of process in connection with this action or any proceedings related to enforcement of this Stipulated Protective Order. Date: City and State where worn and signed: Printed name: [printed name] Signature: 16 MODIFICATION, OF PROTECTIVE ORDER RE: INFORMATION PRODUCED IN DISCOVERY H:\l43 ORDER STIPULATION RE Eyes Protective 0rder_Shost Ship.docx BROWN a. LLP THE ROTUNDA BUILDING 300 Frank H. Ooawa Plaza suite 355 Oakland. CA 94612 PROOF OF SERVICE I am employed in the County of Alameda, State of California. I am over the age of 18 and not a party to the within action. My business address is The Rotunda Building, 300 Frank H. Ogawa Plaza, Suite 355, Oakland, CA 94612. On October 11, 2017, I served the within document(s) described as: MODIFICATION TO PROTECTIVE ORDER REGARDING INFORMATION PRODUCED IN DISCOVERY on the interested parties in this action as stated below: Mary E. Alexander Jennifer L. Fiore j?ore@maryalexanderlawcom; Sophia M. Aslami saslami@marvalexanderlaw.com (BY ELECTRONIC MAIL SERVICE) Based upon CRC Rule 2.251 or an agreement of the parties to accept electronic service I caused such document(s) to be Electronically Mailed through Bremer, Whyte, Brown O'Meara electronic mail system for the above ergftitled case. Should your office require a hard copy of said document, please contact our 0 ice. Executed on October 11, 2017, at Oakland, California. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Natasha Y. Sullivan (Type or print name) . (Signature) OF SERVICE - CERTIFICATE OF SERVICE I am over the age of 18 years and not a party to the within entitled action. I am employed at Mary Alexander Associates, PC, 44 Montgomery Street, Suite 1303, San Francisco, California 94104. I served the documents(s) listed below as follows: Date Served: October 27, 2017 Documents Served: JOINT STATEMENT BY PLAINTIFFS AND DEFENDANTS, CHOR NAR SIU NG, EVA NG AND KAI NG, SUBMITTED FOR INFORMAL DISCOVERY CONFERENCE REGARDING RESPONSES TO CASE MANAGEMENT ORDER NO. 3 Parties Served: See attached list. BY MAIL: I placed a true and correct copy of the documents(s) in a sealed envelope with ?rst class postage fully prepaid in the United States Mail at San Francisco, California, addressed as shown on the attached list. As to Defendants Omar Vega and Max Harris only. BY PERSONAL SERVICE: I served a true and correct copy of the above document(s) by delivering them to the persons shown on the attached list. BY FEDERAL EXPRESS: I sent a true and correct copy of the document(s) for delivery to the persons shown on the attached list in accordance with standard Federal Express Overnight delivery procedures. BY FACSIMILE: I transmitted by facsimile a true and correct copy of the document(s) to the persons shown on the attached list. BY EMAIL OR ELECTRONIC TRANSMISSION: I e-mailed a true and correct copy of the document(s) addressed to the persons shown on the attached list. All parties except Defendants Omar Vega and Max Harris. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that this declaration was executed on October 27, 2017, at San Francisco, California. (I /4 CARLA nix/191132 PROOF OF SERVICE SERVICE LIST GHOST SHIP LITIGATION updated 10/23/2017 Mary E. Alexander, Esq. Jennifer L. Fiore, Esq. Sophia M. Aslami, Esq. Casey A. Gee, Esq. Mary Alexander Associates, PC. 44 Montgomery Street, Suite 1303 San Francisco, CA 94104 Phone: (415) 433-4440 Facsimile: (415) 433-5440 saslami@maryalexanderlaw.com cgee@maryalexanderlaw.com Plaintiffs? Liaison Counsel for all related actions and Attorneys for Plaintiffs in: Avalos v. Ng, et al. Alameda County Superior Court Case No. Barmby, et al. v. Ng, et al. Alameda County Superior Court Case No. Brito v. Ng, et al. Alameda County Superior Court Case No. Calvera v. Ng, et al. Alameda County Superior Court Case No. Chavarria v. Ng, et al. Alameda County Superior Case No. Fritz, et al. v. Ng, et al. Alameda County Superior Court Case No. Ghassart, et al. v. Ng, et al. Alameda County Superior Court Case No. Gregory, et al. v. Ng, et al. Alameda County Superior Court Case No. Jahanbani v. Ng, et al. Alameda County Superior Court Case No. Kelber v. Ng, et al. Alameda County Superior Court Case No. Kermorz v. Ng, et al. Alameda County Superior Court Case No. RG17866657 Kershaw, et al. v. Ng, et al. Alameda County Superior Court Case No. Madden, et al. v. Ng, et al. Alameda County Superior Court Case No. Morris, et al. Ng, et al. Alameda County Superior Court Case No. Morton v. Ng, et al. Alameda County Superior Court Case No. Porter, et al. v. Ng, et al. Alameda County Superior Court Case No. Ruiz, et al. v. Ng, et al. Alameda County Superior Court Case No. RG17877854 Russell v. Ng Alameda County Superior Court Case No. Slocum. v. Ng, etal., Alameda County Superior Court Case No. SERVICE LIST GHOST SHIP LITIGATION Vega v. Ng, et al. Alameda County Superior Court Case No. Wadsworth, et al. v. Ng, et al. Alameda County Superior Court Case No. RG16843856 Bobby Thompson, Esq. Thompson Law Of?ces, PC 700 Airport Blvd, Suite 160 Burlingame, CA 94010 Phone: (650) 513-6111 Facsimile: 650-513-6071 bobby@tlopc.com Attorneys for Plaintiffs in: Avalos v. Ng, et al. Alameda County Superior Court Case No. Barmby, et al. v. Ng, et al. Alameda County Superior Court Case No. Brita v. Ng, et al. Alameda County Superior Court Case No. Calvera v. Ng, et al. Alameda County Superior Court Case No. Chavarrz'a v. Ng, et al. Alameda County Superior Case No. Fritz, et al. v. Ng, et a1. Alameda County Superior Court Case No. Ghassan, et al. v. Ng, et al. Alameda County 3 Superior Court Case No. 1 Gregory, et al. v. Ng, et al. Alameda County 3 Superior Court Case No. Jahanbani v. Ng, et al. Alameda County i Superior Court Case No. Kelber v. Ng, et a1. Alameda County Superior Court Case No. Kennon v. Ng, et al. Alameda County Superior Court Case No. 7866657 Kershaw, etal. v. Ng, et al. Alameda County Superior Court Case No. Madden, et al. v. Ng, et al. Alameda County Superior Court Case No. Morris, et al. Ng, et al. Alameda County Superior Court Case No. Morton v. Ng, et al. Alameda County Superior Court Case No. Porter, et al. v. Ng, et al. Alameda County Superior Court Case No. Ruiz, et al. v. Ng, etal. Alameda County Superior Court Case No. RG17877854 2 SERVICE LIST GHOST SHIP LITIGATION Russell v. Ng Alameda County Superior Court Case No. Slocum. v. Ng, et al., Alameda County Superior Court Case No. Vega v. Ng, et al. Alameda County Superior Court Case No. Wadsworth, et al. v. Ng, er al. Alameda County Superior Court Case No. RG1 6843 856 Joshua Cohen Slatkin, Esq. Law Of?ce of Joshua Cohen Slatkin 2001 Wilshire Blvd, Suite 320 Santa Monica, CA 90403 Phone: (310) 627-2699 Facsimile: (310) 943-2757 jcohenslatkin@jcslaw4you.com Attorneys for Plaintiff in: Jack Bohlka v. Ng, et al. Alameda County Superior Court Case No. RG17846748 Gregory Vanni, Esq. Raf? H. Ohanian, Esq. Thon Beck Vanni Callahan Powell 1100 East Green Street Pasadena, CA 91 106-2513 Phone: (626) 795-8333 Facsimile: (626)449-9933 gvanni@thonbeck.com rohanian@thonbeck.com Attorneys for Plaintiff in: Margaret Bohlka v. Ng. et a1. Alameda County Superior Court Case No. RG17851011 Thomas Brandi, Esq. Brian Malloy, Esq. The Brandi Law Firm 354 Pine Street, 3rd ?oor San Francisco, CA 94104 Phone: (415) 989-1800 Facsimile: (415) 989-1801 tjb@brandilaw.com bjm@brandilaw.com Attorneys for Plaintiff Clark v. Ng, et a1. Alameda County Superior Court Case No. RG17854628 Dolan v. Ng, et al. Alameda County Superior Court Case No. RG17860682 Christopher T. Aumais, Esq. Ashkahn Mohamadi, Esq. Kelly Winter, Esq. Girardi Keese 1126 Wilshire Blvd. Los Angeles, CA 90017 Phone: (213) 977-0211 Facsimile: (213) 481?1554 Attorneys for Plaintiffs in: Dennis v. Ng, et al. Alameda County Superior Court Case No. RG17863866 Grandchamps, et al. v. Ng, et Alameda County Superior Court Case No. 3 SERVICE LIST GHOST SHIP LITIGATION caumais@girardikeese.com amohamadi@girardikeese.com kwinter@girardikeese.com Jacobitz v. Ng, et al. Alameda County Superior Court Case No. RG17863858 Marin v. Ng, et al. Alameda County Superior Court Case No. McCarty, et al. v. Ng, et al. Alameda County Superior Court Case No. RG17856893 imonen, et al. v. Ng, et al. Alameda County Superior Court Case No. RG17851540 Ibiere N. Seek, Esq. Marcelis Morris, Esq. The Cochran Firm 4929 Wilshire Blvd., Suite 1010 Los Angeles, CA 90010 Phone: (323) 435-8205 Facsimile: (323) 282?5280 iseck@CochranFirm.com MMorris@CochranFirm.com Attorneys for Plaintiffs in: Grandchamps, etal. v. Ng, et a1. Alameda County Superior Court Case No. McCarty, et al. v. Ng, er al. Alameda County Superior Court Case No. RG17856893 imonen, et al. v. Ng., etal. Alameda County Superior Court Case No. RG17851540 Robert S. Arns, Esq. Jonathan E. Davis, Esq. Kevin M. Osborne, Esq. Robert C. Foss, Esq. The Arms Law Firm 515 Folsom St., 3rd Floor San Francisco, CA 94105 Phone: (415) 495?7800 Facsimile: (415) 495-7888 rsa@arnslaw.com jed@arnslaw.com kmo@arnslaw.com rcf@arnslaw.com Attorneys for Plaintiffs in: Plotkin, et al. ng, et al. Alameda County Superior Court Case No. RG17850334 Frank M. Pitre, Esq. Alison E. Cordova, Esq. John Thyken, Esq. Cotchett, Pitre McCarthy, LLP San Francisco Airport Of?ce Center 840 Malcolm Road, Suite 200 Burlingame, CA 94010 Phone: (650) 697-6000 Facsimile: (650) 697-0577 fpitre@cpmlegal.com acordova@cpmlegal.com Attorneys for Plaintiffs in: Cline, et al. v. Ng, et al. Alameda County Superior Court Case No. RG17862635 Vega, et al. Ng, er a1. Alameda County Superior Court Case No. Walrath, er al. v. Ng, et a1. Alameda County Superior Court Case No. RG17854654 4 SERVICE LIST GHOST SHIP LITIGATION Paula K. Canny, Esq. Law Of?ces of Paula Canny 840 Hinckley Road, Suite 101 Burlingame, CA 94010 Phone (650) 652-7862 Facsimile (650) 652-7835 defensedog@aol.com Attorneys for Plaintiffs in: Cline, et al. v. Ng, et al. Alameda County Superior Court Case No. RG17862635 Vega, er al. Ng, etal. Alameda County Superior Court Case No. Walrath, et al. v. Ng, et al. Alameda County Superior Court Case No. RG17854654 W. Gordon Kaupp, Esq. Kaupp Feinberg LLP One Sansome Street, 35th Floor San Francisco, CA 94104 Phone: (415) 896-4588 Facsimile: (415) 294-9127 gordon@kauppfeinberg.com Attorneys for Plaintiff in: Samuel Maxwell v. Ng, et al. Alameda County Superior Court Case No. RG17853077 Ryan J. Vlasak, Esq. Bracamontes Vlasak, PC. 220 Montgomery Street, Suite 870 San Francisco, CA 94104 Phone: (415) 835-6777 Facsimile: (415) 835-6780 Attorneys for Plaintiff in: Samuel Maxwell v. Ng, et al. Alameda County Superior Court Case No. RG17853077 rvlasak@bvlawsf.com Ronald Goldman, Esq. Attorneys for Plaintiff in: Timothy Loranger, Esq. Diane Moore, Esq. Robert Lapine v. Ng, er al. Alameda County Baum Hedlund Aristei Goldman, PC 12100 Wilshire Blvd., Ste. 950 Los Angeles, CA 90025 Phone: (310) 207-3233 RGoldman@baumhedlundlaw.com tloranger@baumhedlundlaw.corn Superior Court Case No. RG17854328 Paul A. Matiasic, Esq. Hannah E. Mohr, Esq. Matiasic Johnson LLP 44 Montgomery Street, Suite 3850 San Francisco, CA 94104 Phone: (415) 675-1089 Facsimile: (415) 675-1103 matiasic@mjlawoff1ce.com Attorneys for Plaintiff in: Yraz?na L. Kopelman v. Ng, et al. Alameda County Superior Court Case No. RG17854105 Matlock, et al. v. Ng, et al. Alameda County Superior Court Case No. RG17864342 Wittenauer. v. Ng, et al. Alameda County Superior Court Case No. RG17864346 John R. Browne, Esq. Law Of?ces of John R. Browne, 50 California Street, Suite 3500 Attorneys for Plaintiff in: 5 SERVICE LIST GHOST SHIP LITIGATION San Francisco, CA 94111 Phone: (415) 421-6700 Facsimile: (415) 398-2438 Kellogg v. Ng, et al. Alameda County Superior Court Case No. RG17857948 Christopher Dolan, Esq. Isabelle Tan, Esq. Aimee Kirby, Esq. Dolan Law Firm PC 1438 Market Street San Francisco, CA 94102 Phone: (415) 636-8160 Facsimile: (415) 421-2830 chris@cbdlaw.com Attorneys for Plaintiff in: Cidlik v. Ng, er al. Alameda County Superior Court Case No. RG17860699 Hough v. Ng, et al. Alameda County Superior Court Case No. RG17860697 Igaz v. Ng, et al. Alameda County Superior- Court Case No. RG17863541 Runnels v. Ng, et al. Alameda County Superior Court Case No. RG17860700 John M. Feder, Esq. Rouda Feder Tietj en McGuinn 44 Montgomery Street, Suite 750 San Francisco, CA 94104 Phone: (415) 398-5398 Facsimile: (415) 398-8169 Attorneys for Plaintiff in: Danemayer, et al. v. Ng, et al. Alameda County Superior Court Case No. RG17861609 Robert B. Bale, Esq. Dreyer Babich Buccola Wood Campora, LLP 20 Bicentennial Circle Sacramento, CA 95826 Phone: (916) 379-3500 Facsimile: (916) 379-3599 Attorneys for Plaintiffs in: McGill, et al. v. Ng, eta]. Alameda County Superior Court Case No. RG17869439 Do Kim, Esq. Law Of?ces of Do Kim APLC 3435 Wilshire Ste 2700 Los Angeles, CA 90010-2013 Phone: (213) 251-5440 Facsimile: (213) 232-4919 dkim@dokimlaw.com Attorneys for Plaintiffs in: J0, etal. v. Ng, et al. Alameda County Superior Court Case No. RG17871131 J. Gary Gwilliam, Esq. Winston W. Moody, Esq. Gwilliam, Ivary, Chiosso, Cavalli Brewer 1999 Harrison Street, Suite 1600 Oakland, CA 94612 Phone: (510) 832-5411 Facsimile: (510) 832-1918 Attorneys for Plaintiff in: Farsoudi-Hoda. v. Ng, et al. Alameda County Superior Court Case No. RG17871774 SERVICE LIST GHOST SHIP LITIGATION ggwilliam@giccb.com wmoody@giccb.com Dan Siegel, Esq. Siegel Yee 499 14?h Street, Suite 300 Oakland, CA 94612 Phone: (510) 839-1200 Facsimile: (510) 444-6698 dansiegel@siegelyee.com Attorneys for Plaintiff in: Farsoudi-Hoda. v. Ng, et al. Alameda County Superior Court Case No. RG17871774 Sandra Ribera Speed, Esq. Ribera Law Firm 157 West Portal Avenue, Suite 2 San Francisco, CA 94127 Phone: (415) 576-1600 Facsimile: (415) 842-0321 sribera@riberalaw.com Attorneys for Plaintiff in: Christopher Askew v. Ng, et Alameda County Superior Court Case No. RG17873709 Craig M. Peters, Esq. David L. Winnett, Esq. The Veen Firm, PC. 711 Van Ness Avenue, Suite 220 San Francisco, CA 94102 PO. Box 7296 San Francisco, CA 94120 Phone: (415) 673-4800 Facsimile: (415) 771-5845 C.P.Team@VeenFirm.com Attorneys for Plaintiff in: Leisa Askew v. Ng, et al. Alameda County Superior Court Case No. RG1783957 Raymond Meyer, Jr., Esq. Stephen C. Dreher, Esq. Keith G. Bremer, Esq. Bremer Whyte Brown O?Meara LLP 300 Frank H. Ogawa Plaza The Rotunda Building, Suite 355 Oakland, CA 94612 Phone: (510) 540-4881 Facsimile: (510) 540-4889 Attorneys for Defendants Chor Nar Siu Ng, Individually and as Trustee of the Chor Nar Siu Ng Revocable Trust Dated September 28, 2007 and Eva Ng Raymond Marshall, Esq. Bowen, Esq, Sheppard Mullin Richter Hampton LLP Four Embarcadero Center, 17th Floor San Francisco, CA 94111-4109 Attorneys for City of Oakland SERVICE LIST GHOST SHIP LITIGATION Phone: (415) 774-3167 Facsimile: (415) 403-6230 RMarshall@sheppardmullin.com KBowen@sheppardmullin.com Orestes Alexander Cross, Esq. Valor Legal, P.C. 2600 Tenth Street, Ste. 435 Berkeley, CA 94710 Phone: (415) 545-8394 Facsimile: (415) 520-9695 E-mail: ocross@valorlegal.com Attorneys for Defendant Jonathan Hrabko Kimberly Miller, Esq. Bird Marella Boxer Wolpert 1875 Century Park #23 Los Angeles, CA 90067 Phone: (310) 201-2100 Facsimile: (310) 201-2110 Attorneys for Defendants 100% Silk, Amanda Beth Brown, individually and dba 100% Silk; Britt Brown, individually and dba 100% Silk; and Not Not Fun Records km@birdmarella.com S. Dean Ruiz, Esq. Attorneys for Defendants Daniel Lopez and Harris, Perisho Ruiz 510 Custom Audio Brookside Corporate Center 3439 Brookside Road, Suite 210 Stockton, CA 95129 Phone: (209) 957-4254 Facsimile: (209) 957-5338 E-mail: dean@hprlaw.net Kate Dyer, Esq. Clarence Dyer Cohen LLP 899 Ellis Street San Francisco, CA 94109 Phone: (415) 749-1800 Facsimile: (415) 749-1694 E-mail: kdyer@clarencedyer.com Attorneys for Defendants Paci?c Gas Electric Company and Corporation Laurie Edelstein, Esq. Seth Sias, Esq. Steptoe Johnson LLP One Market Street Steuart Tower, Suite 1800 San Francisco, CA 94105 Phone: (415) 365-6700 Facsimile: (415) 365-6699 E-mail: ledelstein@steptoe.com ssias@steptoe.com Attorneys for Defendants Paci?c Gas Electric Company and Corporation 8 SERVICE LIST GHOST SHIP LITIGATION Michael Wenzel, Esq. ashoda Kashyap, Esq. Bertrand, Fox, Elliot, Osman Wenzel 2749 Hyde Street San Francisco, CA 94107 Phone: (415) 353-0999 Facsimile: (415) 353-0990 E-mail: mwenzel@bfesf.com Attorneys for Defendant County of Alameda jkashyap@bfesf.com D. Mark Jackson, Esq. Attorneys for Defendant Russell E.L. Butler Bassi Edlin Huie Blum aka Black Jeans 500 Washington Street, Suite 700 San Francisco, CA 94111 Phone: (415) 397-9006 Facsimile: (415) 397-1339 E-mailz mjackson@behblaw.com Omar Vega 2641 Crestmore Circle Stockton, CA 95206 Defendant Max Harris, BLM855 Santa Rita Jail 5325 Broder Blvd. Dublin, CA 94568 Defendant, In Pro Per 9 SERVICE LIST GHOST SHIP LITIGATION