Re: Yapu Bambooo Flooring, Inc., etc. v. Ying Li, et al. (KC066080)

MOTION TO FILE FIRST SUPPLEMENTAL AND AMENDED COMPLAINT

Moving Party: Plaintiff Ampy Bamboo Flooring Inc., fka Yapu Bamboo Flooring, Inc., fka Ampu (USA), Inc.

Respondent: Defendant, FloorUS, LLC

POS: Moving OK; Opposing OK; Reply OK

Plaintiff is the judgment creditor of Greenwood Flooring Co. Ltd. (“Greenwood”) in the action styled Ampu Flooring, et al. v. Lu, et al., Case No. BC393733 for a total judgment of $1,580,637.71 from Defendants FloorUS.com, Greenwood and Musong Yuang. Greenwood filed for bankruptcy on or about 12/4/12. Prior to the bankruptcy filing, Greenwood, by and through the individual defendants, allegedly transferred all of its assets to in violation of the California Uniform Fraudulent Transfer Act, CC §§ 3439-3439.12. On 6/7/13, plaintiff filed its complaint. Plaintiff’s First Amended Complaint, filed on 1/21/16, asserts causes of action for:

1. Fraudulent Transfer
2. Declaratory Relief

A