Eun Jung Lim
17192 Murphy Avenue #17723
Irvine, California [92623]
September 19, 2022
JO LYNN VALOFF (SBN:177081)
CARROLL, KELLY, TROTTER & FRANZEN
111 WEST OCEAN BOULEVARD
14TH FLOOR, P.O. BOX 22636
LONG BEACH, CA 90801
TELEPHONE NO.: (562) 432-5855
FAX NO.: (562) 432-8785
Attorney for Defendant, Hoag Memorial Hospital Presbyterian
Re: OBJECTION TO DEPOSITION SUBPOENA
Respectfully,
I refer to Case No. 30-2022-01242187 (Eun Jung Lim v. Hoag Memorial Hospital
Presbyterian, et. al.)
This letter serves as my formal objection of the Deposition Subpeona in the afore-referenced
case.
I am the Plaintiff in the referenced case. On or about August 29, 2022, I was served with a
“Notice to Consumer or Employee and Objection”. In the document, you sought my records
from Irvine Police Department. You also filed a Proof of Service thereof.
You also filed a Deposition Subpoena, which requested information as follows: “Records
from 04/01/2015 to present for the following types of records: any and all photographs
relating to the incident and police reports relating to an altercation on 01/25/2020 involving
Ms. Lim and Hoag Security. Incident Report: 20-01167.”
I hereby raise my objections to the requests therein as follows:
1. You have failed to follow CCP § 1985.3 and CCP § 1985.6 that requires the obtaining
of a court order or agreement of the parties affected before one is required to produce
the records. I have not provided any authorization to the production of your requested
information. I have also not instructed any attorney to provide any authorization on
my behalf.
2. The Subpoena seeks the production of irrelevant information. You request for
information dating as far back as 2015. The subject incidence occurred on January 25,
2020. Therefore, your request is irrelevant and overboard. You request therefore
appears to have ulterior intent to frustrate me.
3. Defendant Herbert Conrad’s name is missing in the record. You should understand
that there is a need to obtain information on Defendant Herbert, who perpetrated the
assault against me on the January 25 th incidence. Such information would help paint a
picture on the real events of the incidence, and how Defendant Herbert Conrad gave
false information on what happened.
4. There is pertinent evidence that must be included therein. Your request has omitted
important evidence, without which justice would not be served. These include: All
Audio recordings of all Irvine police officers at the scene, names of the police
officers, and their badge numbers, the police officers’ supervisor’s names, and their
badge numbers, Michele Hinig declaration of arrest and her audio recordings, audio
recording of Plaintiff’s communication with the officer at the hospital on January 26,
2020, and all email correspondences during the months of January-April 2020
regarding the incident.
I have filed a Notice of Motion and a Motion to Quash the Defendant’s Deposition Subpoena
for Production of Business Records at the Court. I seek a quashing of your Deposition
Subpoena for the aforesaid reasons.
Sincerely,
_________________
EUN JUNG LIM
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