Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
FOR COURT USE ONLY
Ronald P. Slates, SBN: 43712 / Kevin A Hoang, SBN:277 132
RONALD P. SLATES, P.C.
500 S. Grand Ave., Suite 201 O
Los Angeles, CA 90071
TELEPHONE NO. 213-624-1515 FAX NO. (Optional): 213-624-7 536
E-MAIL ADDREss rslates2@rslateslaw.com
ATTORNEY FOR (Name): Plaintiffs
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN MATEO
sTREET ADDRESS: 400 County Center
MAILING ADDRESS:
Redwood City, CA 94063
c1TY AND z1P coDE:
BRANCH NAME:Hall of Justice
PLAINTIFF/PETITIONER: AO WANG, an individual, et al
DEFENDANT/RESPONDENT: BETHANY SULAN LIOU, et al
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): UNLIMITED CASE
(Amount demanded
• LIMITED CASE
(Amount demanded is $25,000
23-CIV-02885
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: 3/14/2024 Time: 9:00 Dept.: 23 Div.: Room:
Address of court (if different from the address above):
D Notice of Intent to Appear by Telephone, by (name):
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. IZI This statement is submitted by party (name): See Attachment 1
b. D This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): 6/26/2023
b. DThe cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. D All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. IZI The following parties named in the complaint or cross-complaint
(1) D have not been served (specify names and explain why not):
(2) D have been served but have not appeared and have not been dismissed (specify names):
(3) IZI have had a default entered against them (specify names):Bethany Su/an Liou and Grande LLC
c. D The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
4. Description of case
a. Type of case in IZI complaint D cross-complaint (Describe, including causes of action): See attachment
2
Pa e1 ofS
Form Adopted for Mandatory Use Cal. Rules of Court,
Judicial Council of California CASE MANAGEMENT STATEMENT rules 3. 720-3.730
CM-110 [Rev. September 1, 2021] www.courts.ca.gov
CM-110
PLAINTIFF/PETITIONER: AO WANG, an individual, et al CASE NUMBER:
DEFENDANT/RESPONDENT: BETHANY SULAN LIOU, et al 23-CIV-02885
4. b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and
damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost
earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
Defendant Bethany Sulan Liou ("Liou") is indebted to Plaintiffs in the sum of at least $5,517,250.00 pursuant to
Judgments entered against her in the Santa Clara Superior Court Case #20CV37318. Prior to, during or shortly
after entry of the Judgments in the Santa Clara action, Defendant Liou transferred real property owned by her to
Defendant Grande without due consideration therefor thus necessitating the bringing of the within action
D(If more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parties request D a jury trial IZI a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. D The trial has been set for (date):
b. IZI No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if
not, explain):
Default as to all defendants was entered on February 5, 2024
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. D days (specify number):
b. D hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial IZI
by the attorney or party listed in the caption IZI by the following:
a. Attorney: Richard M. Williams/Kathryn T. Camerlengo
b. Firm: Gray Duffy LLP
c. Address: 555 Twin Dolphin Drive, Suite 300, Redwood City, California 94065
d. Telephone number: 650/365-7343 f. Fax number: 650/365-6225
D This case is entitled to preference (specify code section):
1O. Alternative dispute resolution (ADR)
a. ADR information package. Please note that different ADR processes are available in different courts and communities; read
the ADR information package provided by the court under rule 3.221 of the California Rules of Court for information about the
processes available through the court and community programs in this case.
(1) For parties represented by counsel: Counsel D
has D
has not provided the ADR information package
identified in rule 3.221 to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party D has D has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) D
This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141. 11 or to civil action
mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) D Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141. 11 .
(3) D This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 2 of 5
CM-110
PLAINTIFF/PETITIONER: AO WANG, an individual, et al CASE NUMBER:
DEFENDANT/RESPONDENT: BETHANY SULAN LIOU, et al 23-CIV-02885
10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or
have already participated in (check all that apply and provide the specified information):
The party or parties completing If the party or parties completing this form in the case have agreed to
this form are willing to participate in or have already completed an ADR process or processes,
participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR
processes (check all that apply): stipulation):
• Mediation session not yet scheduled
(1) Mediation
• • Mediation session scheduled for (date):
• Agreed to complete mediation by (date):
• Mediation completed on (date):
• Settlement conference not yet scheduled
(2) Settlement
• • Settlement conference scheduled for (date):
conference
• Agreed to complete settlement conference by (date):
• Settlement conference completed on (date):
• Neutral evaluation not yet scheduled
(3) Neutral evaluation
• • Neutral evaluation scheduled for (date):
• Agreed to complete neutral evaluation by (date):
• Neutral evaluation completed on (date) :
• Judicial arbitration not yet scheduled
(4) Nonbinding judicial
• • Judicial arbitration scheduled for (date):
arbitration
• Agreed to complete judicial arbitration by (date):
• Judicial arbitration completed on (date):
• Private arbitration not yet scheduled
(5) Binding private
• • Private arbitration scheduled for (date):
arbitration
• Agreed to complete private arbitration by (date) :
• Private arbitration completed on (date):
• ADR session not yet scheduled
(6) Other (specify):
• • ADR session scheduled for (date):
• Agreed to complete ADR session by (date):
• ADR completed on (date):
CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 3 of 5
CM-110
PLAINTIFF/PETITIONER: AO WANG, an individual, et al CASE NUMBER:
DEFENDANT/RESPONDENT: BETHANY SULAN LIOU , et al 23-CIV-02885
11. Insurance
a. D Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: D Yes D No
c. D Coverage issues will significantly affect resolution of this case (explain):
12. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
D Bankruptcy D Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. D There are companion, underlying, or related cases.
(1) Name of case: Ao Wang et al v Bethany Liou, et al
(2) Name of court: Santa Clara Superior Court
(3) Case number: 20CV373181
(4) Status: Judgments Entered
D Additional cases are described in Attachment 13a.
b. D A motion to D consolidate D coordinate will be filed by (name party):
14. Bifurcation
D The party or parties intend to file a motion for an order bifurcating , severing , or coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons):
15. Other motions
D The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
16. Discovery
a. D The party or parties have completed all discovery.
b. D The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
N/A- default entered 2/5/2024 as to all Defendants
c. D The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-11 0 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 4 of 5
CM-110
PLAINTIFF/PETITIONER: AO WANG, an individual, et al CASE NUMBER:
DEFENDANT/RESPONDENT: BETHANY SULAN LIOU, et al 23-CIV-02885
17. Economic litigation
a. D This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code
of Civil Procedure sections 90-98 will apply to this case.
b. D This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional
discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial
should not apply to this case):
18. Other issues
D The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
19. Meet and confer
a. [gl The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules
of Court (if not, explain):
N/A - Default as to all Defendants entered on 2/5/2024
b. D After meeting and conferring as required by rule 3. 724 of the California Rules of Court, the parties agree on the following
(specify):
20. Total number of pages attached (if any): 6
I am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution ,
as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of
the case management conference, including the written authority of the party where required .
Date: 3/1/2024
Ronald P. Slates, SBN: 43712 / /s/ RONALD P. SLATES
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME)
• (SIGNATURE OF PARTY OR ATTORNEY)
D Additional signatures are attached.
CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 5 of 5
CASE NUMBER:
SHORT TITLE: Ao Wang, et al v. Bethany Liou, et al
23-CIV-02885
1 ATTACHMENT 1
2
3 1.a. AO WANG, an individual; LING YANG, an individual; MEIFANG LI, an individual; JUNJIE ZHANG, an individua;
4 KINGPING YIM, an individual; XUELING OUYANG, an individual; CHANGJIN LU, an individual; GUANGMING
5 ZHANG, an individual; JING ZHANG, an individual; XINZE YU, an individual and CHENQIU LI, an individual
6
7
8
9
10
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15
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26 (Required for verified pleading) The items on this page stated on information and belief are (specify item numbers, not line
numbers):
27 This page may be used with any Judicial Council form or any other paper filed with the court. Page§
Form Approved by the ADDITIONAL PAGE CRC 201 , 501
Judicial Council of California
MC-020 (New January 1, 1987] Attach to Judicial Council Form or Other Court Paper
SHORT TITLE: Ao Wang, et al v. Bethany Liou, et al CASE NUMBER:
23-CIV-02885
1 ATTACHMENT 2
2 4.a.
3 COMPLAINT FOR (1) AVOIDANCE OF TRANSFER OF REAL PROPERTY [CAL. CIV. CODE §3439.04(a)(1)]; (2)
4 VOIDABLE TRANSACTION [CAL. CIV. CODE §3439.04(a)(2)]; (3) VOIDABLE TRANSACTION [CAL. CIV. CODE
5 §3439.05]; (4) FRAUD & DECEIT - CONCEALMENT; and (5) FRAUD & DECEIT - PROMISE MADE WITHOUT
6 INTENT TO PERFORM
7
8
9
10
11
12
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19
20
21
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23
24
25
26 (Required for verified pleading) The items on this page stated on information and belief are (specify item numbers, not line
numbers):
27 This page may be used with any Judicial Council form or any other paper filed with the court. Pagel
Form Approved by the
Judicial Council of California
ADDITIONAL PAGE CRC 201 , 501
MC-020 [New January 1, 1987] Attach to Judicial Council Form or Other Court Paper
1 PROOF OF SERVICE
2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
3 I am employed in the County of Los Angeles, State of California. I am over the age of 18
and not a party to the within action. My business address is 500 South Grand A venue, Biltmore
4 Tower Suite 2010, Los Angeles, California 90071.
5 On March 1, 2024, I served the foregoing document described as PLAINTIFFS' CASE
MANAGEMENT STATEMENT on all interested parties in this action as stated below and on the
6 attached Service List.
7
[BY MAIL] I enclosed the document(s) in a sealed envelope or package addressed to the
8
person(s) at the address(es) listed on the attached Service List and placed the envelope for
9
t/ collection and mailing, following our ordinary business practices. I am readily familiar with the
practice of this business for collecting and processing correspondence for mailing. On the same
day that correspondence is placed for collection and mailing, it is deposited in the ordinary course
of business with the United States Postal Services, in a seal envelope with postage fully prepaid.
[BY PERSONAL SERVICE] I personally delivered the document(s) to the persons at the
address(es) listed on the attached Service List. For a party represented by an attorney, delivery
was made to the attorney or at the attorney's office by leaving the document(s), in an envelope or
package clearly labeled to identify the attorney being served, with a receptionist or an individual in
charge of the office, between the hours of nine in the morning and five in the evening.
[BY OVERNIGHT DELIVERY] I enclosed the document(s) in an envelope or package
provided by an overnight delivery carrier and addressed to the person(s) at the address(es) listed on
the attached Service List. I placed the envelope or package for collection and overnight delivery at
an office or a regularly utilized drop box of the overnight delivery carrier.
[BY ELECTRONIC SERVICE] My electronic address is khoang@rslateslaw.com. On the date
set forth herein, I electronically served the above-listed document(s) to the person(s) at the
electronic address( es) listed.
19 Executed on March 1, 2024, at Los Angeles, California.
20 181 (State) I declare under penalty of perjury under the laws of the State of California that the
above is true and correct.
21
• (Federal) I declare that I am employed in the office of a member of the bar of this
22 Court at whose direction the service was made.
23
24
/s/ KEVIN HOANG
25 KEVIN HOANG
26
27
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Page 1
Plaintiffs' Case Management Statement
1 SERVICE LIST
2 Bethany Liou
21701 Stevens Creek Blvd, #2610
3 Cupertino, CA 95014
4 Bethany Liou
68 Almendral A venue
5 Atherton, CA 94027
6 Grande LLC, a California limited liability company
21701 Stevens Creek Blvd, #2610
7 Cupertino, CA 95014
8 Grande LLC, a California limited liability company
21701 Stevens Creek Blvd, #2610
9 Cupertino, CA 95014
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Plaintiffs' Case Management Statement
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Ronald P. Slates, SBN: 43712 / Kevin A Hoang, SBN:277 132 RONALD P. SLATES, P.C. 500 S. Grand Ave., Suite 201 O Los Angeles, CA 90071 TELEPHONE NO. 213-624-1515 FAX NO. (Optional): 213-624-7 536 E-MAIL ADDREss rslates2@rslateslaw.com ATTORNEY FOR (Name): Plaintiffs SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN MATEO sTREET ADDRESS: 400 County Center MAILING ADDRESS: Redwood City, CA 94063 c1TY AND z1P coDE: BRANCH NAME:Hall of Justice PLAINTIFF/PETITIONER: AO WANG, an individual, et al DEFENDANT/RESPONDENT: BETHANY SULAN LIOU, et al CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): UNLIMITED CASE (Amount demanded • LIMITED CASE (Amount demanded is $25,000 23-CIV-02885 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: 3/14/2024 Time: 9:00 Dept.: 23 Div.: Room: Address of court (if different from the address above): D Notice of Intent to Appear by Telephone, by (name): INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. IZI This statement is submitted by party (name): See Attachment 1 b. D This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): 6/26/2023 b. DThe cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. D All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. IZI The following parties named in the complaint or cross-complaint (1) D have not been served (specify names and explain why not): (2) D have been served but have not appeared and have not been dismissed (specify names): (3) IZI have had a default entered against them (specify names):Bethany Su/an Liou and Grande LLC c. D The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): 4. Description of case a. Type of case in IZI complaint D cross-complaint (Describe, including causes of action): See attachment 2 Pa e1 ofS Form Adopted for Mandatory Use Cal. Rules of Court, Judicial Council of California CASE MANAGEMENT STATEMENT rules 3. 720-3.730 CM-110 [Rev. September 1, 2021] www.courts.ca.gov CM-110 PLAINTIFF/PETITIONER: AO WANG, an individual, et al CASE NUMBER: DEFENDANT/RESPONDENT: BETHANY SULAN LIOU, et al 23-CIV-02885 4. b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) Defendant Bethany Sulan Liou ("Liou") is indebted to Plaintiffs in the sum of at least $5,517,250.00 pursuant to Judgments entered against her in the Santa Clara Superior Court Case #20CV37318. Prior to, during or shortly after entry of the Judgments in the Santa Clara action, Defendant Liou transferred real property owned by her to Defendant Grande without due consideration therefor thus necessitating the bringing of the within action D(If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request D a jury trial IZI a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. D The trial has been set for (date): b. IZI No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if not, explain): Default as to all defendants was entered on February 5, 2024 c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. D days (specify number): b. D hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial IZI by the attorney or party listed in the caption IZI by the following: a. Attorney: Richard M. Williams/Kathryn T. Camerlengo b. Firm: Gray Duffy LLP c. Address: 555 Twin Dolphin Drive, Suite 300, Redwood City, California 94065 d. Telephone number: 650/365-7343 f. Fax number: 650/365-6225 D This case is entitled to preference (specify code section): 1O. Alternative dispute resolution (ADR) a. ADR information package. Please note that different ADR processes are available in different courts and communities; read the ADR information package provided by the court under rule 3.221 of the California Rules of Court for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel D has D has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. (2) For self-represented parties: Party D has D has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) D This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141. 11 or to civil action mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) D Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of Civil Procedure section 1141. 11 . (3) D This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 2 of 5 CM-110 PLAINTIFF/PETITIONER: AO WANG, an individual, et al CASE NUMBER: DEFENDANT/RESPONDENT: BETHANY SULAN LIOU, et al 23-CIV-02885 10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or have already participated in (check all that apply and provide the specified information): The party or parties completing If the party or parties completing this form in the case have agreed to this form are willing to participate in or have already completed an ADR process or processes, participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR processes (check all that apply): stipulation): • Mediation session not yet scheduled (1) Mediation • • Mediation session scheduled for (date): • Agreed to complete mediation by (date): • Mediation completed on (date): • Settlement conference not yet scheduled (2) Settlement • • Settlement conference scheduled for (date): conference • Agreed to complete settlement conference by (date): • Settlement conference completed on (date): • Neutral evaluation not yet scheduled (3) Neutral evaluation • • Neutral evaluation scheduled for (date): • Agreed to complete neutral evaluation by (date): • Neutral evaluation completed on (date) : • Judicial arbitration not yet scheduled (4) Nonbinding judicial • • Judicial arbitration scheduled for (date): arbitration • Agreed to complete judicial arbitration by (date): • Judicial arbitration completed on (date): • Private arbitration not yet scheduled (5) Binding private • • Private arbitration scheduled for (date): arbitration • Agreed to complete private arbitration by (date) : • Private arbitration completed on (date): • ADR session not yet scheduled (6) Other (specify): • • ADR session scheduled for (date): • Agreed to complete ADR session by (date): • ADR completed on (date): CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 3 of 5 CM-110 PLAINTIFF/PETITIONER: AO WANG, an individual, et al CASE NUMBER: DEFENDANT/RESPONDENT: BETHANY SULAN LIOU , et al 23-CIV-02885 11. Insurance a. D Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: D Yes D No c. D Coverage issues will significantly affect resolution of this case (explain): 12. Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. D Bankruptcy D Other (specify): Status: 13. Related cases, consolidation, and coordination a. D There are companion, underlying, or related cases. (1) Name of case: Ao Wang et al v Bethany Liou, et al (2) Name of court: Santa Clara Superior Court (3) Case number: 20CV373181 (4) Status: Judgments Entered D Additional cases are described in Attachment 13a. b. D A motion to D consolidate D coordinate will be filed by (name party): 14. Bifurcation D The party or parties intend to file a motion for an order bifurcating , severing , or coordinating the following issues or causes of action (specify moving party, type of motion, and reasons): 15. Other motions D The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16. Discovery a. D The party or parties have completed all discovery. b. D The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date N/A- default entered 2/5/2024 as to all Defendants c. D The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-11 0 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 4 of 5 CM-110 PLAINTIFF/PETITIONER: AO WANG, an individual, et al CASE NUMBER: DEFENDANT/RESPONDENT: BETHANY SULAN LIOU, et al 23-CIV-02885 17. Economic litigation a. D This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code of Civil Procedure sections 90-98 will apply to this case. b. D This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial should not apply to this case): 18. Other issues D The party or parties request that the following additional matters be considered or determined at the case management conference (specify): 19. Meet and confer a. [gl The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of Court (if not, explain): N/A - Default as to all Defendants entered on 2/5/2024 b. D After meeting and conferring as required by rule 3. 724 of the California Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any): 6 I am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution , as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of the case management conference, including the written authority of the party where required . Date: 3/1/2024 Ronald P. Slates, SBN: 43712 / /s/ RONALD P. SLATES (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) • (SIGNATURE OF PARTY OR ATTORNEY) D Additional signatures are attached. CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 5 of 5 CASE NUMBER: SHORT TITLE: Ao Wang, et al v. Bethany Liou, et al 23-CIV-02885 1 ATTACHMENT 1 2 3 1.a. AO WANG, an individual; LING YANG, an individual; MEIFANG LI, an individual; JUNJIE ZHANG, an individua; 4 KINGPING YIM, an individual; XUELING OUYANG, an individual; CHANGJIN LU, an individual; GUANGMING 5 ZHANG, an individual; JING ZHANG, an individual; XINZE YU, an individual and CHENQIU LI, an individual 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 (Required for verified pleading) The items on this page stated on information and belief are (specify item numbers, not line numbers): 27 This page may be used with any Judicial Council form or any other paper filed with the court. Page§ Form Approved by the ADDITIONAL PAGE CRC 201 , 501 Judicial Council of California MC-020 (New January 1, 1987] Attach to Judicial Council Form or Other Court Paper SHORT TITLE: Ao Wang, et al v. Bethany Liou, et al CASE NUMBER: 23-CIV-02885 1 ATTACHMENT 2 2 4.a. 3 COMPLAINT FOR (1) AVOIDANCE OF TRANSFER OF REAL PROPERTY [CAL. CIV. CODE §3439.04(a)(1)]; (2) 4 VOIDABLE TRANSACTION [CAL. CIV. CODE §3439.04(a)(2)]; (3) VOIDABLE TRANSACTION [CAL. CIV. CODE 5 §3439.05]; (4) FRAUD & DECEIT - CONCEALMENT; and (5) FRAUD & DECEIT - PROMISE MADE WITHOUT 6 INTENT TO PERFORM 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 (Required for verified pleading) The items on this page stated on information and belief are (specify item numbers, not line numbers): 27 This page may be used with any Judicial Council form or any other paper filed with the court. Pagel Form Approved by the Judicial Council of California ADDITIONAL PAGE CRC 201 , 501 MC-020 [New January 1, 1987] Attach to Judicial Council Form or Other Court Paper 1 PROOF OF SERVICE 2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES 3 I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action. My business address is 500 South Grand A venue, Biltmore 4 Tower Suite 2010, Los Angeles, California 90071. 5 On March 1, 2024, I served the foregoing document described as PLAINTIFFS' CASE MANAGEMENT STATEMENT on all interested parties in this action as stated below and on the 6 attached Service List. 7 [BY MAIL] I enclosed the document(s) in a sealed envelope or package addressed to the 8 person(s) at the address(es) listed on the attached Service List and placed the envelope for 9 t/ collection and mailing, following our ordinary business practices. I am readily familiar with the practice of this business for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Services, in a seal envelope with postage fully prepaid. [BY PERSONAL SERVICE] I personally delivered the document(s) to the persons at the address(es) listed on the attached Service List. For a party represented by an attorney, delivery was made to the attorney or at the attorney's office by leaving the document(s), in an envelope or package clearly labeled to identify the attorney being served, with a receptionist or an individual in charge of the office, between the hours of nine in the morning and five in the evening. [BY OVERNIGHT DELIVERY] I enclosed the document(s) in an envelope or package provided by an overnight delivery carrier and addressed to the person(s) at the address(es) listed on the attached Service List. I placed the envelope or package for collection and overnight delivery at an office or a regularly utilized drop box of the overnight delivery carrier. [BY ELECTRONIC SERVICE] My electronic address is khoang@rslateslaw.com. On the date set forth herein, I electronically served the above-listed document(s) to the person(s) at the electronic address( es) listed. 19 Executed on March 1, 2024, at Los Angeles, California. 20 181 (State) I declare under penalty of perjury under the laws of the State of California that the above is true and correct. 21 • (Federal) I declare that I am employed in the office of a member of the bar of this 22 Court at whose direction the service was made. 23 24 /s/ KEVIN HOANG 25 KEVIN HOANG 26 27 28 Page 1 Plaintiffs' Case Management Statement 1 SERVICE LIST 2 Bethany Liou 21701 Stevens Creek Blvd, #2610 3 Cupertino, CA 95014 4 Bethany Liou 68 Almendral A venue 5 Atherton, CA 94027 6 Grande LLC, a California limited liability company 21701 Stevens Creek Blvd, #2610 7 Cupertino, CA 95014 8 Grande LLC, a California limited liability company 21701 Stevens Creek Blvd, #2610 9 Cupertino, CA 95014 la! 10 c:,, 0 ~ ~ 0 N 11 c:,, ~ ,m::, Ql LO ~ <( Cl~ C ' ~ ~ "O <( ' .... ;;, ~ .c ~ ~ - 5 N ~ 17 <:: en la! 0 18 ~ 0 LO 19 20 21 22 23 24 25 26 27 28 Pa e 2 Plaintiffs' Case Management Statement