Qi

BACKGROUND

In August 2023, Qi filed a partition action against his former wife, real party in

interest Lang Mao, in the Superior Court of San Bernardino County. Qi sought partition

and sale of certain real property in Chino Hills, California. Mao filed a cross-complaint

seeking similar relief.

Nearly two years later, in April 2025, Mao filed a motion under section 2025.260

to compel Qi to appear in person for a deposition in Los Angeles, California. Mao

argued that it was “unclear what city and country [Qi] actually resides in,” so the court

should apply the balancing test in section 2025.260(b) and compel Qi to attend his

deposition at a place beyond the distance limits prescribed by section 2025.250.

The motion was supported by a declaration from Mao’s attorney, Jessica Do,

along with several accompanying exhibits. Do described the information that she had

received about Qi’s place of residence from Qi and his attorney, Kenneth Gross. In

November 2024, Qi filed a verified response to interrogatories in which he stated that he

had “resided overseas in various locations since 2021.” In January 2025, Gross emailed

Do that Qi’s deposition would have to be taken…