On March 04, 2022 a
Motion-Secondary
was filed
involving a dispute between
Dl Trucking Inc.,
Zou Xueyun,
Gosdom Inc,
and
Gosdom Inc,
Guo Trustee Of The Guo Protection Trust Yao,
Guo Yao Aka Vanessa Yao Guo Aka Vanessa Guo Aka Guo Baozhi Aka Yuki Guo,
for Contractual Fraud (General Jurisdiction)
in the District Court of Los Angeles County.
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Electronically FILED by Superior Court of California, County of Los Angeles on 08/09/2022 03:41 PM Sherri R. Carter, Executive Officer/Clerk of Court, by N. Le,Deputy Clerk
Jom S. Rossi, Esq. (State Bar No. 86721)
Law Office of Jom Rossi
2 31600 Railroad Canyon Road, Suite B
Canyon Lake, CA 92587
3 Telephone: 951-409-3499
Email: rossilaw@yahoo.com
4
Attorney for Plaintiffs, Xueyun Zou, and DL
5 Trucking Inc.
6
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF LOS ANGELES, ALHAMBRA COURTHOUSE
10
11 XUEYUN ZOU and DL TRUCKING, INC. Case No. : 22AHCV00123
12 Plaintiffs, Assigned for all purposes to:
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Judge Colin P. Leis, Dept. 3
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13 vs.
z -u'~"' OPPOSITION TO DEMURRER TO
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YAO GUO, aka VANESSA YAO GUO, aka
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o fU GUO; GOSDOM, INC ; YAO GUO, TRUSTEE OF
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-:l-"' 16 GUO PROTECTION TRUST; and DOES 1-20, COMPLAINT FILED: 03/04/2022
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20 MEMORANDUM OF POINTS & AUTHORITIES
21 I.
22 INTRODUCTION
23 Sufficient facts are stated to state the causes of action alleged. Particularly coupled
24 with the case record of defendant, Yao Guo's, ("Guo") declaration in opposition to
25 Plaintiffs' Application for preliminary injunction under the Uniform Fraudulent Transfer
26 Act which admits the material, false representations made by Guo to 83 year old plaintiff
27 Zou namely, that none of the named defendants were "THE PRODUCER" of the movies,
28
-1
Opposition To Demurrer To Complaint
Document Filed Date
August 09, 2022
Case Filing Date
March 04, 2022
Category
Contractual Fraud (General Jurisdiction)
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Electronically FILED by Superior Court of California, County of Los Angeles on 08/09/2022 03:41 PM Sherri R. Carter, Executive Officer/Clerk of Court, by N. Le,Deputy Clerk Jom S. Rossi, Esq. (State Bar No. 86721) Law Office of Jom Rossi 2 31600 Railroad Canyon Road, Suite B Canyon Lake, CA 92587 3 Telephone: 951-409-3499 Email: rossilaw@yahoo.com 4 Attorney for Plaintiffs, Xueyun Zou, and DL 5 Trucking Inc. 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF LOS ANGELES, ALHAMBRA COURTHOUSE 10 11 XUEYUN ZOU and DL TRUCKING, INC. Case No. : 22AHCV00123 12 Plaintiffs, Assigned for all purposes to: ~ :c U] 0 .::: ~ r- Judge Colin P. Leis, Dept. 3 ~ " ""' :/)"' 13 vs. z -u'~"' OPPOSITION TO DEMURRER TO p::; g .:: 14 COMPLAINT v,...., "' - c I---) c 2 ~ YAO GUO, aka VANESSA YAO GUO, aka ~ ? :..= 15 VANESSA GUO , aka GUO BAOZHI, aka YUKI o fU GUO; GOSDOM, INC ; YAO GUO, TRUSTEE OF wv u " -:l-"' 16 GUO PROTECTION TRUST; and DOES 1-20, COMPLAINT FILED: 03/04/2022 ~ ~ ;: --,<: ~ LI., ::; c 0 ~ c>- 17 Defendants. §3: ov 0 " ~ :: 18 >--1 "' 19 20 MEMORANDUM OF POINTS & AUTHORITIES 21 I. 22 INTRODUCTION 23 Sufficient facts are stated to state the causes of action alleged. Particularly coupled 24 with the case record of defendant, Yao Guo's, ("Guo") declaration in opposition to 25 Plaintiffs' Application for preliminary injunction under the Uniform Fraudulent Transfer 26 Act which admits the material, false representations made by Guo to 83 year old plaintiff 27 Zou namely, that none of the named defendants were "THE PRODUCER" of the movies, 28 -1 Opposition To Demurrer To Complaint