Park Capital Management, LLC v. Satya Chillara, et al.

Under Code of Civil Procedure Section 2025.230:

If the deponent named is not a natural person, the deposition notice shall describe with reasonable particularity the matters on which examination is requested. In that event, the deponent shall designate and produce at the deposition those of its officers, directors, managing agents, employees, or agents who are most qualified to testify on its behalf as to those matters to the extent of any information known or reasonably available to the deponent.

C.C.P. § 2025.230. The Notice of Deposition lists 25 Matters for Examination for the person most qualified (“PMQ”) designated by RAJS to testify about on RAJS’s behalf at

1 While Park Capital’s Motion refers to “person most knowledgeable (‘PMK’),” the precise

term under our Code of Civil Procedure Section 2025.230 is person “most qualified” (“PMQ”). C.C.P. § 2025.230.

the January 15, 2016 deposition. Martins Decl. Ex.

1.

RAJS designated Satya Chillara as its PMQ for all 25 deposition topics to testify at the January 15, 2026 deposition. Martins Decl. at ¶ 4.

Unsatisfied with Satya Chillara’s answers as PMQ to questions to Matters for Examination Nos. 4, 5, 6, 7, 9, 14, 15, 16, 17, 18, 19, 21, 22, and 24 at the January 15, 2026 deposition, Park Capital now moves the Court to compel Jyothi Chillara, who Satya Chillara testified is his wife and the only other agent of RAJS,2 to testify at deposition as the PMQ for RAJS for Matters for Examination Nos. 4, 5, 6, 7, 9, 14, 15, 16, 17, 18, 19, 21, 22, and 24.

Park Capital argues that he Motion should be granted as to Matters of Examination Nos. 5 and 18 because Satya Chillara testified at the January 15, 2026 PMQ deposition that he did not know information about these two topics but that Jyothi Chillara would know. Pl. Memo. of Points and Authorities in Support of Motion (“Pl. Memo.”) at 3:17-4-27.

Regarding Matters of Examination Nos. 5 and 18—and only Nos. 5 and 18—Park Capital’s position is well founded.

When asked about topic No. 5 (“RAJS’s procedures for corporate recordkeeping, documentation of decisions, and maintenance of corporate governance”), Satya Chillara testified that he did not know but that Jyothi Chillara, who is a CPA who handles taxation and compliance matters for RAJS would have such knowledge.3

Likewise, when asked about topic No. 18 (“RAJS’s involvement in preparing reviewing, or providing Schedule K-1 forms to the limited partners of OYF LP”), Satya Chillara testified that he did not know but that Jyothi Chillara would have such knowledge because she prepared the K-1 forms submitted to OYF LP’s limited partners.4

As under Code of Civil Procedure Section 2025.230 RAJS was required to designate and produce to testify at the January 15, 2026 deposition the person “most qualified” to testify on behalf of topics Nos. 5 and 18, and because by his own testimony

2 Jan. 15, 2026 Dep. Transcript at 73:12-15 (Martins Decl. Ex. 3) (Q. “How many agents

has RAJS had since 2018 to present on each year?” A. “Well, from the exhibits that we watched, either it’s me or my wife.”) 3 Jan. 15, 2026 Dep. Transcript at 130:13-20 (Martins Decl. Ex. 3) (Q. “Who files

[RAJS’s] taxes?” A. “My wife. She does taxes for us.” Q. “So she is the one who receives any taxable documents and puts together the file and file on [RAJS’s] behalf”? A. “That’s a reasonable assumption.” Q. “Do you know if she does that?” A. “Obviously.”) 4 Jan. 15, 2026 Dep. Transcript at 126:8-16 (Martins Decl. Ex. 3) (Q. “Do you know who

sends that on behalf of OYF I LP? And by that I mean the K-1s.” A. “I don’t know.” Q. “Who would know?” A. “. . . My wife is a CPA she would probably know it is coming and is paying attention to it.”).

at this deposition Satya Chillara admitted that had no knowledge of these topics but that Jyothi Chillara, the only other agent of RAJS besides Satya Chillara, would have such knowledge, the Court agrees with Park Capital that Jyothi Chillara must be produced to testify on behalf of RAJS under Section 2025.230 for topics Nos. 5 and 18.

Accordingly, the Court GRANTS In Part the Motion as follows. Specifically, the Court ORDERS that within 30 days from today RAJS produce its agent Jyothi Chillara to testify at deposition on RAJS’s behalf under Code of Civil Procedure Section 2025.230 for the following two Matters of Examination listed in the Notice of Deposition:

• Matter of Examination No. 5: RAJS’s procedures for corporate recordkeeping, documentation of decisions, and maintenance of corporate governance.

• Matter of Examination No. 18: RAJS’s involvement in preparing reviewing, or providing Schedule K-1 forms to the limited partners of OYF LP.

Moreover, RAJS’s objections to Jyothi Chillara answering questions as to Matters of Examination Nos. 5 and 18 on the ground of marital privilege are OVERRULED. The Court finds and rules that her knowledge of these topics Nos. 5 and 18 arises from her involvement as RAJS’s agent in RAJS’s business operations regarding these two specific topics—and not from confidential marital communications. As such, marital privilege does not apply. So at the upcoming PMQ deposition that the Court has now ORDERED, Jyothi Chillara on behalf of RAJS under Section 2025.230 is to give full and forthright testimony on topics Nos. 5 and 18, and while defense counsel may make and preserve objections for the record, defense counsel is ORDERED not to instruct Jyothi Chillara not to answer depositions questions on topics Nos. 5 and 18 based on marital privilege.

She must answer the questions asked on these two topics.

As for Park Capital’s accompanying request in the Motion that the Court compel RAJS “to search and produce all responsive documents to the deposition notice” (Pl. Memo. at 10:2-21), that request is DENIED. The Court has carefully reviewed the Requests for Production of Documents (“RFPs”) attached to the Notice of Deposition, and closely compared these RFPs to Matters for Examination Nos. 5 and 18, and the Court finds and rules that none of these RFPs are narrowly-tailored to Matters for Examination Nos. 5 and 18. As such, this document production request in the specific context of this PMQ deposition on these two topics is DENIED.

As for all the other Matters of Examination at issue in this Motion— Nos. 4, 6, 7, 9, 14, 15, 16, 17, 19, 21, 22, and 24, the Motion is DENIED. Park Capital’s ground for asking this Court to Order Jyothi Chillara to testify as RAJS’s PMQ witness at deposition on these topics—that “it is reasonable to assume that . . . Jyothi would be the other individual with potential knowledge” about these topics (Pl Memo. at 6:18-21)—is sheer speculation. The Court has spent considerable time reviewing and comparing each of these Matters of Examination with every line of the transcript of the January 15, 2026 PMQ Deposition submitted by the parties, and the Court finds and rules that there is no basis whatever to believe that Jyothi Chillara has any knowledge of Matters of

Examination Nos. 4, 6, 7, 9, 14, 15, 16, 17, 19, 21, 22, and 24. So there is no basis in law or logic to compel her to testify on behalf of RAJS as to these topics.

Regarding the competing requests for monetary sanctions in this Motion—Park Capital requests “$5,000.00” for attorneys’ fees incurred for the Motion (Pl. Memo. at 10-13-17), and RAJS in turn seeks “$3,241.00” for its attorneys’ incurred for this Motion (Opp. at 14:10-12), the Court DENIES the competing requests for sanctions because the Court finds that the “circumstances make the imposition of the sanction unjust” against either party. While this Motion by Park Capital was justified to the extent that RAJS should have swiftly agreed after the January 15, 2026 deposition to produce Jyothi Chillara as RAJS’s PMQ on topics Nos. 5 through 18, Park Capital also badly overreached in this Motion by insisting that Jyothi Chillara be compelled to testify as RAJS’s PMQ on topics Nos. 4, 6, 7, 9, 14, 15, 16, 17, 19, 21, 22, and 24 without having any basis beyond sheer speculation to assert that she knows anything about these topics.

So under these circumstances, awarding either side sanctions for this Motion would be unjust and is DENIED.

Conclusion & Order

Accordingly, Park Capital’s Motion is GRANTED In Part and DENIED in Part as follows.

1. Regarding Matters for Examination Nos. 5 and 18 in the Notice of Examination, the Motion is GRANTED and the Court ORDERS RAJS within 30 days from today to produce its agent Jyothi Chillara to testify on only those two topics on RAJS’s behalf under Code of Civil Procedure Section 2025.230.

2. Regarding Matters for Examination Nos. 5 and 18 in the Notice of Examination, Jyothi Chillara is to provide full and forthright answers as RAJS’s PMQ on these two topics at this deposition that will happen within 30 days of today, and defense counsel is ORDERED not to instruct her not to answer based on the objection of marital privilege that the Court has OVERRULED.

3. Regarding Matters of Examination Nos. 4, 6, 7, 9, 14, 15, 16, 17, 19, 21, 22, and 24, the Motion is DENIED and RAJS need not produce Jyothi Chillara to testify on its behalf of these topics.

4. Regarding Park Capital’s request that RAJS search and produce all responsive documents to Requests for Production of Documents in the Notice of Deposition, that request is DENIED.

5. Regarding the parties’ competing requests for monetary sanctions, those requests are DENIED.

Nota Bene: Defendant RAJS Funds, LLC and its defense counsel are put on NOTICE that if they fail to comply with this ORDER within 30 days from today then then Defendant RAJS Funds, LLC and its defense counsel will be subject to escalating

sanctions, including monetary and non-monetary sanctions such as evidentiary, issue, and terminating sanctions.

SO ORDERED.

Date: May 15, 2026 Hon. Vincent I. Parrett Superior Court of the State of California, County of Santa Clara

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