Re: Mike Lin v. Joe Chang, et al. (KC067752)

MOTION TO BE RELIEVED AS COUNSEL

Moving Party: William L. Niu, Counsel for Cross-Defendant/Cross-Complainant Chin Hao Tsui

POS: Moving OK

This is an LLC members dispute and ownership determination. The complaint, filed 6/30/16, asserts causes of action for:

1. Breach of Fiduciary Duty
2. Breach of Duty of Loyalty
3. Breach of Contract
4. Fraud
5. Claim and Delivery
6. Misappropriation (California Common Law)
7. Injunctive Relief
8. Conversion
9. Unjust Enrichment
10. Imposition of Constructive Trust
11. Accounting

On 9/8/15, Maggie C. Hsu (“Hsu”) filed her cross-complaint against Stacy Lin, Chin Hao Tsui aka Jack Tsui (“Tsui”), Smelly Pot, LLC and ROES 1-100 for:

1. Fraud
2. Negligent Misrepresentation
3. Intentional Misrepresentation
4. Unjust Enrichment
5. Rescission
6. Declaratory Relief
7. Constructive Trust

On 2/22/16, Tsui filed his cross-complaint against Hsu and POES 1-100 for Declaratory Relief.

The Final Status Conference