On January 31, 2017 a
Motion-Secondary
was filed
involving a dispute between
Chiu, Thai Ming,
Liu, Kaman,
Fu, Bryant,
Lei, Crystal,
and
Chiu, Thai Min,
Chiu, Thai Ming,
Does 1-20, Inclusive,
Liu, Kaman,
Yan, Tina,
for civil
in the District Court of San Francisco County.
Preview
Leeds Disston, Esq. SBN 045016
1
CASALINA & DISSTON
2 409 13th Street, 9th Floor ELECTRONICALLY
Oakland, CA 94612 F I L E D
3 (510) 835-8110 Telephone Superior Court of California,
County of San Francisco
(510) 835-8113 Facsimile
4
casdiss@yahoo.com 07/14/2022
Clerk of the Court
5 BY: RONNIE OTERO
Attorney for defendants Deputy Clerk
6 TINA YAN, THAI MING CHIU, and KAMAN LIU
7
SUPERIOR COURT OF THE STATE OF CALIFORNIA
8 COUNTY OF SAN FRANCISCO
UNLIMITED CIVIL JURISDICTION
9
10 BRYANT FU and CRYSTAL LEI, Case No.: CGC-17-556769
11
Plaintiffs,
DEFENDANTS’ SEPARATE STATEMENT
12 vs. OF UNDISPUTED MATERIAL FACTS IN
TINA YAN et al.,
13 SUPPORT OF OPPOSITION TO
Defendants. PLAINTIFFS' MOTION FOR SUMMARY
14 ADJUDICATION ON FIRST CAUSE OF
_____________________________________ ACTION
15
and RELATED CROSS-COMPLAINT.
16 Date: July 29, 2022
17
Time: 9:30 am
Dept.: 501
18 The Hon. Charles F. Haines
19 Defendants’ TINA YAN, THAI MING CHIU, and KAMAN LIU (Defendants) hereby submit
20 this separate statement of UNDISPUTED MATERIAL FACTS in opposition to PLAINTIFFS'
21 MOTION FOR SUMMARY ADJUDICATION ON FIRST CAUSE OF ACTION.
22
23 Issue 1 – Transferee Defendants Are Liable For Yan’s Fraudulent Transfer Of The Subject
24 Property To Them With The Intent To Hinder, Delay Or Defraud Yan’s Creditors
25
26
27
28
- 1
1
Opposing Party’s (Defendants) Material Facts Moving Party’s (Plaintiffs) Response in
and Supporting Evidence Opposition and Supporting Evidence
2
1. The transfer of the Subject Property to 547
3 23rd Avenue, LLC was set aside on 2016-06-
24.
4
Evidence:
5
Judgment Setting Aside Fraudulent Transfers
6 (CGC14537574, LI v. CHIU et al.)
[Defendants RJN, Ex. 1, RJN-2 at par. E.]
7
2. The transfers of 547 23rd Avenue, LLC
8 membership interests to Defendants were set
aside on 2016-06-24.
9
10
Evidence:
Judgment Setting Aside Fraudulent Transfers
11 (CGC14537574, LI v. CHIU et al.)
[Defendants RJN, Ex. 1, RJN-3 at par. F.]
12
3. The transfer of the Subject Property from
13 547 23rd Avenue, LLC to 547 Investments,
LLC was set aside on 2016-06-24.
14
15 Evidence:
Judgment Setting Aside Fraudulent Transfers
16 (CGC14537574, LI v. CHIU et al.)
[Defendants RJN, Ex. 1, RJN-3 at par. G.]
17
4. Yan was the sole owner of the Subject
18 Property at the time of commencement of this
19
action by plaintiffs’ complaint filed on
January 31, 2017.
20
Evidence:
21 Judgment Setting Aside Fraudulent Transfers
22
(CGC14537574, LI v. CHIU et al.)
[Defendants RJN, Ex. 1, at pars. E-H.]
23
24
25 Dated: 7/14/2022
26 /s/Leeds Disston, Esq.
27
28
- 2
Document Filed Date
July 14, 2022
Case Filing Date
January 31, 2017
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