RELEVANT BACKGROUND

On May 10, 2019, Perry filed a complaint against Till, asserting causes of action for breach of contract, common count, unjust enrichment, and declaratory relief.

On July 15, 2019, Till filed a cross-complaint against Perry and his son, Tye Perry (“Tye”), asserting causes of action for civil extortion – blackmail, aiding and abetting civil extortion, conspiracy to commit extortion, conversion, aiding and abetting conversion, conspiracy to commit conversion, civil claim for receipt of stolen property – Penal Code §496(c), unjust enrichment, common count: money had and received – quantum meruit, intentional infliction of emotional distress, violation of Usury Laws – loansharking, cancellation of written instruments – Civil Code §3412, rescission of written instruments, injunctive relief, and declaratory relief.

(1) DEMURRER TO COMPLAINT

INTRODUCTION

Till demurs to the first cause of action for breach of contract in Perry’s complaint. Till argues Perry failed to a