Free Declaration in Support - District Court of California - California

Case 3:07-cv-04946-JSW

Document 76

Filed 06/16/2008

Page 1 of 4

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

CHRISTOPHER COOKE, CA Bar #142342 STEPHEN S. WU, CA Bar # 205091 COOKE KOBRICK & WU LLP 177 Bovet Road, Suite 600 San Mateo, CA 94402 Email: [email protected] [email protected] Tel: (650) 638-2370 Fax: (650) 341-1395 Attorneys for Plaintiffs

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION MEI-FANG LISA ZHANG, BAY AREA AFFORDABLE HOUSING, LLC, XUEHUAN GAO, YANG-CHUN ZHANG, CAROL JIAN DENG, and HAO LIANG, Plaintiffs, vs. WEI-MAN RAYMOND TSE, RUN PING ZHOU a.k.a. FLORA ZHOU, THERESA WONG, JAMES YU, BILL SHU WAI MA, MOLLY LAU, VICTOR SO, JIAN XIAO, CHRIST INVESTMENT SERVICE INC., CIS SERVICE, INC., PACIFIC BEST GROUP LTD. a.k.a. PACIFIC BEST COMPANY LTD., and SOUTH CHINA INVESTMENT INC., Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No.: C-07-04946 JSW (Related to C-05-02641 JSW) DECLARATION OF CHRISTOPHER COOKE IN SUPPORT OF PLAINTIFFS' REQUEST FOR ENTRY OF DEFAULT AGAINST DEFENDANT MOLLY LAU UNDER FED. R. CIV. P. 55(a)

I, Stephen S. Wu, declare: 1. I am one of the attorneys for Plaintiffs in this action. I make this declaration in

support of Plaintiffs' Request for Entry of Default Against Defendant Molly Lau under Fed. R. Civ. P. 55(a). -1DECLARATION OF CHRISTOPHER COOKE IN SUPPORT OF PLAINTIFFS' REQUEST FOR ENTRY OF DEFAULT / Case No.: C-07-04946 JSW

Case 3:07-cv-04946-JSW

Document 76

Filed 06/16/2008

Page 2 of 4

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

2.

A copy of the Court's minute order of April 11, 2008, document no. 59, is

attached hereto as Exhibit "A." 3. On September 24, 2007, my firm caused Plaintiffs' Complaint in this case to be

filed with this Court. The Complaint and Summons were served on Defendant Molly Lau on October 9, 2007. See Return of Service (document no. 12). 4. On June 16, 2008 at 3:00 p.m., I checked the docket of this case through PACER,

and it reflects that no Answer or other response to the Complaint has been filed by Ms. Lau. 5. In addition, this is an e-filing case. I am registered in this district for e-filing and

have received electronic notices from the Court of filings in this case. As of June 16, 2008 at 3:00 p.m., I have received no electronic notices from the Court that an Answer or other response to the Complaint has been filed by Ms. Lau. Finally, as of June 16, 2008 at 3:00 p.m., I have not received from Ms. Lau an Answer or other response to the Complaint in the mail, by fax, by email, or in any other form. I declare under penalty of perjury under the laws of the United States and of the State of California that the foregoing is true and correct. Executed on June 16, 2008

/s/ CHRISTOPHER COOKE

-2DECLARATION OF CHRISTOPHER COOKE IN SUPPORT OF PLAINTIFFS' REQUEST FOR ENTRY OF DEFAULT / Case No.: C-07-04946 JSW

Case 3:07-cv-04946-JSW

Document 76

Filed 06/16/2008

Page 3 of 4

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

EXHIBIT A Minute Order of April 11, 2008

-1DECLARATION OF CHRISTOPHER COOKE IN SUPPORT OF PLAINTIFFS' REQUEST FOR ENTRY OF DEFAULT / Case No.: C-07-04946 JSW

Case 3:07-cv-04946-JSW

Document 59 76

Filed 04/11/2008 06/16/2008

Page 1 of 1 4 4

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA CIVIL MINUTE ORDER

JUDGE: JEFFREY S. WHITE DATE: April 11, 2008

COURTROOM DEPUTY: Jennifer Ottolini Court Reporter: Kathy Wyatt

CASE NO. C-074946 JSW TITLE: Mei-Fang Lisa Zhang, et al., v. Wei-Man Raymand Tse, et al.,

COUNSEL FOR PLAINTIFF: Christopher Cooke

COUNSEL FOR DEFENDANT: No appearance by or for any defendants

PROCEEDINGS: Initial Case Management Conference

RESULTS:

The Clerk is directed to enter default against all defendants except Run Ping Zhou. The Plaintiff re-filed it motion for subpoenas.