Motion-Secondary: DO WOO KIM, ET AL. VS HYUN JONG HAN, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 09/06/2019 12:52 PM Sherri R. Carter, Executive Officer/Clerk of Court, by L. Perez,Deputy Clerk



                    1 Brian F. Buchanan, SBN 086017
                      Jeremy Friedman, SBN 249706
                    2 BUCHANAN & PATTERSON, LLP
                      1000 Wilshire Boulevard, Suite 570
                    3 Los Angeles, California 90017
                      Telephone: (213) 457-7350
                    4 Facsimile: (213) 457-7355
                      E-mail: bbuchanan@bplawllp.com
                    5
                      Attorneys for Defendants in Case No. 19STCV16827
                    6 and for Plaintiff in related Case No. 19STCP02628

                    7                                   SUPERIOR COURT OF THE STATE OF CALIFORNIA

                    8                                              FOR THE COUNTY OF LOS ANGELES

                    9                                                 UNLIMITED CIVIL JURISDICTION

                  10       THE WILTON KOREAN PRESBYTERIAN                                                 Case No. 19STCV16827
                           CHURCH IN LOS ANGELES, a Non-Profit                                                     19STCP02628 (Related Cases)
                  11       Religious Corporation; DO WOO KIM, an
                           individual; DO RIM KIM, an individual;                                         OPPOSITION TO THE KIM
                  12                                                                                      BROTHERS' PRELIMINARY
                                                             Plaintiffs,                                  INJUNCTION MOTION;
                  13                                                                                      MEMORANDUM OF POINTS
                           vs.                                                                            AND AUTHORITIES
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                           HYUN JONG HAN, an individual; YONG
                  15       CHUL CHO, an individual; FRANCIS KIM,                                         Date: September 19, 2019
                           an individual; NEE DON CHU, an individual;                                    Time: 8:30 a.m.
                  16       DAE WON PARK, an individual; & DOES 1                                         Dept.: 17
                           through 50, inclusive                                                         Hearing Judge: Richard Rico
                  17                                                                                     Action Filed: May 16, 2019
                                          Defendants.                                                    Trial Date: None Set
                  18       AND RELATED CASE
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                         TO THE COURT AND ALL PARTIES AND THEIR RESPECTIVE ATTORNEYS OF
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                         RECORD:
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                                    The five named Defendants in Case Number 19STCV16827 (i.e., HYUN JONG HAN,
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                         YONG CHUL CHO, FRANCIS KIM, NEE DON CHU, and DAE WON PARK) (herein,
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                         collectively, the "First Case Defendants")) hereby oppose the pending motion for a preliminary
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                         injunction (the "Motion") that was brought by DO WOO KIM and DO RIM KIM (collectively, the
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                         "Kim Brothers"), who are plaintiffs in Case Number 19STCV16827 and are defendants in Case
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                         Number 19STCP02628.
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                                    This opposition is based upon the following concurrently-filed materials:
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                                  MEMORANDUM OF POINTS AND AUTHORITIES IOT PRELIMIINARY INJUNCTION MOTION