On August 03, 2022 a
Motion-Secondary
was filed
involving a dispute between
Rosena Ranch Community Association,
Rosen Ranch Community Association,
Zhang, Yan,
and
Does 1 To 20,
Zhang, Yan,
for Breach of Contract/Warranty Unlimited
in the District Court of San Bernardino County.
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Yan Zhang,
3665
,
Bilberry
San Bernardino,
MD
Telephone: 909-270-1 830
Road
CA 92407
WahraD
mm.‘VEHOFSANmmm W
SCAN ED AUG 2 9
V
2023
Fax: 888-523-5237
Email:
Plaintiff
yanmdphd@yahoo.com
BYMg V
Mm .DEPuw
SUPERIOR COURT OF CALIFORNIA. COUNTY OF SAN BERNADINO
Rosena Ranch Community Association V Case Number: CIVSB 2216707
Plaintiff(s)
VS. CROSS-COMPLAINER & DEFENDANT YAN
ZHANG’S OPPOSITION TO PLAINTIFF’S MOTION
lO Yan Zhang; and TO DEMURRER TO YAN ZHANG’S CROSS COM-
PLAINT; MEMORANDUM OF POINTS &
vvvvvvvv
Does 1 through 20, inclusive
11 AUTHORITIES; DECLARATION OF YAN ZHANG
Defendants
l2
13 Yan Zhang, )
Cross-Complainant, )
l4
Vs. )
Rosena Ranch Community Association) DEPT 24
15
)
DATE: 09/1 1/2023
16 Roes 1 through 20, inclusive )
TIME: 8:30AM.
Cross—Defendant V
Cross-complaint and answer to plaintiffs’ complaint
l7 filed on 05/02/2023 concurrently
v
18
TO THE CLERK OF THE SUPERIOR COURT, COUNTY OF SAN BERNADINO, STATE OF
19
CALIFORNiA, TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD HEREIN:
20 a motion to demurrer to cross-complainers and
The plaintiff and cross defendant has filed
defendant’s cross—complaint. This motion wiII be heard at the time and location stated above. The
21
plaintiff opposes this motion for the following reasons:
22
The and cross defendant’s motion to demurrer
plaintiff is based on the argument that the cross-
23 complaint did not plea enough facts for those cause of actions. The plaintiff disagree based on the
followings:
24
1.This cross-complaint and the answer (EXHIBIT A) to the plaintiff's complaint were filed and served
25 at the same time around 05/02/2023. All the details of cross-complaint’s causes actions were
adequately laid out in my 7 pages of answer to the plaintiff‘s complaint. This was discussed with the
26
attorneys of the plaintiff multiple times, and yet they refused to see what is in front of them, and
27
made this unnecessary motion to demurrer.
28
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Document Filed Date
August 29, 2023
Case Filing Date
August 03, 2022
Category
Breach of Contract/Warranty Unlimited
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Yan Zhang, 3665 , Bilberry San Bernardino, MD Telephone: 909-270-1 830 Road CA 92407 WahraD mm.‘VEHOFSANmmm W SCAN ED AUG 2 9 V 2023 Fax: 888-523-5237 Email: Plaintiff yanmdphd@yahoo.com BYMg V Mm .DEPuw SUPERIOR COURT OF CALIFORNIA. COUNTY OF SAN BERNADINO Rosena Ranch Community Association V Case Number: CIVSB 2216707 Plaintiff(s) VS. CROSS-COMPLAINER & DEFENDANT YAN ZHANG’S OPPOSITION TO PLAINTIFF’S MOTION lO Yan Zhang; and TO DEMURRER TO YAN ZHANG’S CROSS COM- PLAINT; MEMORANDUM OF POINTS & vvvvvvvv Does 1 through 20, inclusive 11 AUTHORITIES; DECLARATION OF YAN ZHANG Defendants l2 13 Yan Zhang, ) Cross-Complainant, ) l4 Vs. ) Rosena Ranch Community Association) DEPT 24 15 ) DATE: 09/1 1/2023 16 Roes 1 through 20, inclusive ) TIME: 8:30AM. Cross—Defendant V Cross-complaint and answer to plaintiffs’ complaint l7 filed on 05/02/2023 concurrently v 18 TO THE CLERK OF THE SUPERIOR COURT, COUNTY OF SAN BERNADINO, STATE OF 19 CALIFORNiA, TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD HEREIN: 20 a motion to demurrer to cross-complainers and The plaintiff and cross defendant has filed defendant’s cross—complaint. This motion wiII be heard at the time and location stated above. The 21 plaintiff opposes this motion for the following reasons: 22 The and cross defendant’s motion to demurrer plaintiff is based on the argument that the cross- 23 complaint did not plea enough facts for those cause of actions. The plaintiff disagree based on the followings: 24 1.This cross-complaint and the answer (EXHIBIT A) to the plaintiff's complaint were filed and served 25 at the same time around 05/02/2023. All the details of cross-complaint’s causes actions were adequately laid out in my 7 pages of answer to the plaintiff‘s complaint. This was discussed with the 26 attorneys of the plaintiff multiple times, and yet they refused to see what is in front of them, and 27 made this unnecessary motion to demurrer. 28 . ' , VI .. ‘ .. _ I ' . ‘ ' “y .b..5'. I L . . ~v‘ .-