On January 31, 2017 a
Hearing
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 05/20/2022
Clerk of the Court
5 BY: EDNALEEN ALEGRE
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
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Plaintiffs,
DEFENDANTS’ TINA YAN, THAI MING
12 vs. CHIU, and KAMAN LIU’S NOTICE OF
TINA YAN et al.,
13 DEMURRER AND DEMURRER TO
Defendants. PLAINTIFFS’ FIRST AMENDED
14 COMPLAINT
_____________________________________
15
And RELATED CROSS-COMPLAINT.
16 PROOF OF SERVICE
17 Date: June 16, 2022
Time: 9:30 am
18 Dept: 501
19 NOTICE IS HEREBY GIVEN that DEFENDANTS’ TINA YAN, THAI MING CHIU, and
20 KAMAN LIU’S DEMURRER TO PLAINTIFFS’ FIRST AMENDED COMPLAINT has been
21 set for hearing on the date, time, and location as captioned above, or as soon thereafter as the
22 matter may be heard.
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Demurrer is taken to the First Cause of Action for FRAUDULENT TRANSFERS and Second
Causes of Action for CONSPIRACY TO ENGAGE IN FRAUDULENT TRANSFER on the
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grounds that they are barred by statute of limitation CCP section 338 and do not state facts
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sufficient to constitute a cause of action (CCP § 430.10 (e)). In addition as to defendant Tina
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Yan, the action is subject to abatement for another action pending between the same parties on
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the same cause of action (CCP § 430.10 (c)). Demurrer is based on this notice, the
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memorandum of points and authorities, the records and file herein, and such further evidence as
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may be presented at the hearing.
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3 Dated: 5/19/2022
/s/Leeds Disston, Esq.
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PROOF OF SERVICE
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I declare that I am a resident of the State of California, over the age of 18 years, and not a party
3 to this action.
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On this date, I served the following document(s):
6 DEFENDANTS’ TINA YAN, THAI MING CHIU, and KAMAN LIU’S NOTICE OF
DEMURRER AND DEMURRER TO PLAINTIFFS’ FIRST AMENDED COMPLAINT
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8 MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANTS’
TINA YAN, THAI MING CHIU, and KAMAN LIU’S DEMURRER TO PLAINTIFFS’ FIRST
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AMENDED COMPLAINT
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CIV-140 Declaration re. Meet and Confer
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on the following parties by eserve:
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Charlie Yu
14 Attorney for Cross-Defendant CHEN
15 Gary Kaplan
Attorney for Plaintiffs
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I declare under penalty of perjury under the laws of the State of California that the foregoing is
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true and correct.
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20 Dated: 5/20/22
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_____________
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William Mora
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Document Filed Date
May 20, 2022
Case Filing Date
January 31, 2017
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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 05/20/2022 Clerk of the Court 5 BY: EDNALEEN ALEGRE 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’ TINA YAN, THAI MING 12 vs. CHIU, and KAMAN LIU’S NOTICE OF TINA YAN et al., 13 DEMURRER AND DEMURRER TO Defendants. PLAINTIFFS’ FIRST AMENDED 14 COMPLAINT _____________________________________ 15 And RELATED CROSS-COMPLAINT. 16 PROOF OF SERVICE 17 Date: June 16, 2022 Time: 9:30 am 18 Dept: 501 19 NOTICE IS HEREBY GIVEN that DEFENDANTS’ TINA YAN, THAI MING CHIU, and 20 KAMAN LIU’S DEMURRER TO PLAINTIFFS’ FIRST AMENDED COMPLAINT has been 21 set for hearing on the date, time, and location as captioned above, or as soon thereafter as the 22 matter may be heard. 23 24 Demurrer is taken to the First Cause of Action for FRAUDULENT TRANSFERS and Second Causes of Action for CONSPIRACY TO ENGAGE IN FRAUDULENT TRANSFER on the 25 grounds that they are barred by statute of limitation CCP section 338 and do not state facts 26 sufficient to constitute a cause of action (CCP § 430.10 (e)). In addition as to defendant Tina 27 Yan, the action is subject to abatement for another action pending between the same parties on 28 the same cause of action (CCP § 430.10 (c)). Demurrer is based on this notice, the - 1 memorandum of points and authorities, the records and file herein, and such further evidence as 1 may be presented at the hearing. 2 3 Dated: 5/19/2022 /s/Leeds Disston, Esq. 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 - 2 1 PROOF OF SERVICE 2 I declare that I am a resident of the State of California, over the age of 18 years, and not a party 3 to this action. 4 5 On this date, I served the following document(s): 6 DEFENDANTS’ TINA YAN, THAI MING CHIU, and KAMAN LIU’S NOTICE OF DEMURRER AND DEMURRER TO PLAINTIFFS’ FIRST AMENDED COMPLAINT 7 8 MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANTS’ TINA YAN, THAI MING CHIU, and KAMAN LIU’S DEMURRER TO PLAINTIFFS’ FIRST 9 AMENDED COMPLAINT 10 11 CIV-140 Declaration re. Meet and Confer 12 on the following parties by eserve: 13 Charlie Yu 14 Attorney for Cross-Defendant CHEN 15 Gary Kaplan Attorney for Plaintiffs 16 17 I declare under penalty of perjury under the laws of the State of California that the foregoing is 18 true and correct. 19 20 Dated: 5/20/22 21 22 _____________ 23 William Mora 24 25 26 27 28 - 3