Nice Wave International Limited v. Michael Tzu-Wen Wang, et al

5/21/26 - Law and Motion Calendar Judge Mark A. McCannon – Department 2 Page 8 of 13

2:00 PM LINE: 3 23-CIV-05934 NICE WAVE INTERNATIONAL LIMITED, A HONG KONG CORPORATION VS. MICHAEL TZU- WEN WANG, ET AL

NICE WAVE INTERNATIONAL LIMITED, A HONG KONG CORPORATION CHRISTOPHER D BEATTY MICHAEL TZU-WEN WANG OLIVER M. GOLD

CROSS DEFENDANT NICE WAIVE INTERNATIONAL LIMITED’S MOTION TO COMPEL WITH DEPOSITION SUBPOENA FOR PERSONAL APPEARANCE AND PRODUCTION OF DOCUMENTS AND THINGS TO CECILIA LAU AND REQUEST FOR MONETARY SANCTIONS

TENTATIVE RULING:

For the reasons stated below, Plaintiff/Cross-Defendant Nice Wave International Limited’s (“Nice Wave”) unopposed Motion to Compel Compliance with Deposition Subpoena for Personal Appearance and Production of Documents to third party Cecilia Lau, which includes a request for monetary sanctions is GRANTED IN PART.

The motion to compel Cecilia Lau to appear and testify at deposition is GRANTED. (Code Civ. Proc., §§ 2025.450, 2025.480). Nice Wave establishes good cause to compel Ms. Lau’s deposition. Based on the moving papers, Ms. Lau may have relevant knowledge regarding Defendant/Cross-Complainant Michael Tzu-Wen Wang’s management of the Market Street Property, relevant banking information, and other discoverable information relevant to the asserted claims and defenses. Nice Wave’s request to depose Ms. Lau therefore constitutes permissible discovery. Further, Ms. Lau has already agreed to be deposed.

Based on the evidence presented, the amended subpoena to Ms. Lau was properly served through the Perkins Coie firm. Perkins Coie previously stated that it represented Ms. Lau and accepted service of both the original subpoena and the amended subpoena on her behalf. Perkins Coie also served objections to both subpoenas. That conduct supports a finding that service and representation were accepted. The fact that Perkins Coie has filed a motion seeking to withdraw as counsel for Defendant Wang, which has not yet been heard, does not change the result.

Ms. Lau and/or her counsel, whether Perkins Coie or otherwise, shall contact Plaintiff’s counsel within ten (10) days of this order to meet and confer regarding a deposition date. The deposition shall take place within twenty (20) days of notice of entry of this order, unless Nice Wave agrees to a later date.

The Perkins Coie firm shall serve Ms. Lau with notice of this order.

The Motion to Compel Ms. Lau to produce documents responsive to the amended subpoena is GRANTED IN PART. (Code Civ. Proc., §§ 2025.450, 2025.480). The amended subpoena requested production of 29 categories of documents. (Nov. 21, 2025 Separate Statement.)

5/21/26 - Law and Motion Calendar Judge Mark A. McCannon – Department 2 Page 9 of 13

Although the Court does not find that Ms. Lau waived her objections, the objections to the requests for production of documents are OVERRULED. Ms. Lau has not responded to the arguments raised in Nice Wave’s Separate Statement. With respect to objections regarding temporal scope, the Court finds that a time period dating back to 2015 is not overbroad in light of the 2015 sale underlying the alleged claims and defenses in this action. The remaining objections are unsupported, lack sufficient detail, and do not justify withholding responsive documents.

Ms. Lau shall conduct a diligent search and produce all responsive documents.

Nice Wave’s request for monetary sanctions is GRANTED IN PART, jointly and severally against Ms. Lau and the Perkins Coie firm, in the reduced amount of $500. (Code Civ. Proc., §§ 2025.450, subd. (g)(1), 2025.480, subd. (j).) The Court finds sanctions appropriate because Ms. Lau’s deposition was improperly cancelled after service of the amended subpoena had been accepted and the September 25, 2025 deposition date had been agreed upon. The sanctions shall be paid within thirty (30) days of notice of entry of this order.

If the tentative ruling is uncontested, it shall become the order of the Court. Thereafter, counsel for the prevailing party shall prepare a written order consistent with this ruling for the Court’s signature, pursuant to California Rules of Court, rule 3.1312, and provide notice of the ruling to all appearing parties as required by law. The Court further directs the parties’ attention to revised Local Rule 3.403(b)(iv) (eff. Jan. 1, 2024) regarding the form of proposed orders.

5/21/26 - Law and Motion Calendar Judge Mark A. McCannon – Department 2 Page 10 of 13

02:00 PM LINE: 4 23-CIV-05934 NICE WAVE INTERNATIONAL LIMITED, A HONG KONG CORPORATION VS. MICHAEL TZU- WEN WANG, ET AL

NICE WAVE INTERNATIONAL LIMITED, A HONG KONG CORPORATION CHRISTOPHER D BEATTY MICHAEL TZU-WEN WANG OLIVER M. GOLD

CROSS DEFENDANT NICE WAIVE INTERNATIONAL LIMITED’S MOTION TO COMPEL COMPEL WITH DEPOSITION SUBPOENA FORPERSONAL APPEARANCE AND PRODUCTION OF DOCUMENTS AND THINGS TO ROSE DICKSON AND REQUEST FOR MONETARY SANCTIONS IN THE AMOUNT OF $3,753.75

TENTATIVE RULING:

For the reasons stated below, Plaintiff/Cross-Defendant Nice Wave International Limited’s (“Nice Wave”) unopposed Motion to Compel Compliance with Deposition Subpoena for Personal Appearance and Production of Documents to third party Rose Dickson, which includes a request for monetary sanctions, is GRANTED IN PART.

The motion to compel Rose Dickson to appear, testify, and produce documents at deposition is GRANTED. (Code Civ. Proc., §§ 2025.450, 2025.480.) Nice Wave establishes good cause to compel Ms. Dickson’s deposition and production of responsive documents. Based on the moving papers, Ms. Dickson may have relevant knowledge regarding Defendant/Cross-Complainant Michael Tzu-Wen Wang’s management of the Market Street Property, the purported General Service Agreement, Wang’s claimed right to fees, and other discoverable information relevant to the asserted claims and defenses. Nice Wave’s request to depose Ms. Dickson therefore constitutes permissible discovery. Further, Ms. Dickson has already agreed to be deposed.

Based on the evidence presented, the amended subpoena to Ms. Dickson was properly served through the Perkins Coie firm. Perkins Coie previously stated that it represented Ms. Dickson and accepted service of both the original subpoena and the amended subpoena on her behalf. Perkins Coie also served objections to both subpoenas. That conduct supports a finding that service and representation were accepted. Perkins Coie also agreed, on Ms. Dickson’s behalf, to the revised September 23, 2025 deposition date. The fact that Perkins Coie has filed a motion seeking to withdraw as counsel for Defendant Wang, which has not yet been heard, does not change the result.

Ms. Dickson and/or her counsel, whether Perkins Coie or otherwise, shall contact Plaintiff’s counsel within ten (10) days of this order to meet and confer regarding a deposition date. The deposition shall take place within twenty (20) days of notice of entry of this order, unless Nice Wave agrees to a later date.

The Perkins Coie firm shall serve Ms. Dickson with notice of this order.