– 8

(1) Cross-Complainant Ron Merom’s Motion for Order that Matters in Request for Admissions be Deemed Admitted and Imposing Monetary Sanctions [against cross- defendant Hoang Nguyen]

(2) Cross-Complainant Ron Merom’s Motion for Order that Matters in Request for Admissions be Deemed Admitted and Imposing Monetary Sanctions [against cross- defendant Patrick Long]

(3) Cross-Complainant Ron Merom’s Motion for Order that Matters in Request for Admissions be Deemed Admitted and Imposing Monetary Sanctions [against cross- defendant George Li]

Factual and Procedural Background

First Amended Complaint

Founded in January 2017, plaintiff Finclusion Labs, Inc. dba WeTrust (“Finclusion”) creates decentralized, peer-to-peer financial solutions that promote financial inclusion. (First Amended Complaint (“FAC”), ¶1.) In conjunction with formation of Finclusion, each co- founder, including defendant Ron Merom (“Merom”), was granted 25% of the company’s outstanding stock, subject to a vesting ag