Gang Yang v. Anne Chui, et al.

| William A. Crowfoot Judge of the Superior Court | Parties who intend to submit on this tentative must send an email to the Court at [email protected] indicating intention to submit on the tentative as directed by the instructions provided on the court website at www.lacourt.org. Please be advised that if you submit on the tentative and elect not to appear at the hearing, the opposing party may nevertheless appear at the hearing and argue the matter. Unless you receive a submission from all other parties in the matter, you should assume that others might appear at the hearing to argue. If the Court does not receive emails from the parties indicating submission on this tentative ruling and there are no appearances at the hearing, the Court may, at its discretion, adopt the tentative as the final order or place the motion off calendar.

OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES - NORTHEAST DISTRICT GANG YANG, Plaintiff(s), vs. ANNE CHUI, et al., Defendant(s). |))))))))))) | CASE NO.: 25NNCV06903 [TENTATIVE] ORDER RE: PLAINTIFF GANG YANG'S MOTIONS TO DEEM ADMITTED; REQUEST FOR MONETARY SANCTIONS

Dept. 3 8:30 a.m. August 26, 2026 | On September 30, 2025, plaintiff Gang Yang ("Plaintiff") filed this action against defendants Anne Chui, Rogers Chui, A&R Trust, and A1 Meat, Inc.. Plaintiff moved for orders deeming admitted the truth of the matters specified in requests for admission propounded on Anne Chui and Rogers Chui (collectively, "Defendants"). The underlying written discovery was served on April 16, 2026. On August 5, 2026, the Court held a hearing on Plaintiff's motions and continued the hearing to August 26, 2026, for further briefing.

Defendants filed opposition briefs on August 18, 2026, averring that responses to Plaintiff's Requests for Admission were served. On August 19, 2026, Plaintiff filed reply briefs reiterating a request for mandatory sanctions in connection with the motions to deem admitted. Where a party fails to timely respond to a request for admission, the propounding party may move for an order that the genuineness of any documents and the truth of any matters specified in the requests be deemed admitted. (Code Civ.

Proc., Sec. 2033.280, subd. (b).) Where a party fails to provide a timely response to requests for admission, "[i]t is mandatory that the court impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) on the party or attorney, or both, whose failure to serve a timely response to requests for admission necessitated this motion." (Code of Civ. Proc., Sec. 2033.280, subd. (c).) Since Defendants' failure to timely serve responses necessitated motion practice, Plaintiff's request for monetary sanctions is GRANTED.

Sanctions are imposed as follows: (1) On Anne Chui and counsel of record, jointly and severally, in the reduced amount of $487.20 consisting of 1 hour at a reasonable hourly rate of $415 and $72.20 in filing fees, payable within 20 days of the date of this Order. (2) Rogers Chui and counsel of record, jointly and severally, in the reduced amount of $487.20 consisting of 1 hour at a reasonable hourly rate of $415 and $72.20 in filing fees, payable within 20 days of the date of this Order. Plaintiff to give notice.

Dated this 26th day of August 2026 | | | William A. Crowfoot

Judge of the Superior Court | Parties who intend to submit on this tentative must send an email to the Court at [email protected] indicating intention to submit on the tentative as directed by the instructions provided on the court website at www.lacourt.org. Please be advised that if you submit on the tentative and elect not to appear at the hearing, the opposing party may nevertheless appear at the hearing and argue the matter. Unless you receive a submission from all other parties in the matter, you should assume that others might appear at the hearing to argue.

If the Court does not receive emails from the parties indicating submission on this tentative ruling and there are no appearances at the hearing, the Court may, at its discretion, adopt the tentative as the final order or place the motion off calendar. SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES - NORTHEAST DISTRICT GANG YANG, Plaintiff(s), vs. ANNE CHUI, et al., Defendant(s). |))))))))))) | CASE NO.: 25NNCV06903 [TENTATIVE] ORDER RE: PLAINTIFF'S APPLICATIONS FOR WRIT OF ATTACHMENT Dept. 3 8:30 a.m.

August

26, 2026 | Plaintiff Gang Yang ("Plaintiff") seeks writs of attachment against Defendants Anne Chui, Rogers Chui, A&R Trust and A1 Meat Inc. ("A1 Meat") (collectively, "Defendants") in the amount of $500,000. On August 3, 2026, Defendants filed notices of opposition and claims of exemption, as well as a memorandum of point and authorities and joint declaration of Anne Chui and Rogers Chui. Plaintiff filed reply briefs on August 18, 2026. Plaintiff alleges claims for breach of contract arising from a written settlement agreement entered into on February 22, 2024 ("2024 Agreement").

The 2024 Agreement required Defendants to provide "application materials and supplementary materials for the application of removing conditions" on Plaintiff's conditional green card following Plaintiff's $500,000 investment in A1 Meat as part of a visa application. Plaintiff alleges he cannot remove the conditions on his green card due to Defendants' actions and, as a result, he has suffered damages "in the sum of $500,000 plus consequential damages according to proof." (Compl., P. 33.) "Upon the filing of the complaint or at any time thereafter, the plaintiff may apply pursuant to this article for a right to attach order and a writ of attachment by filing an application for the order and writ with the court in which the action is brought." (CCP Sec. 484.010.)

The application shall be executed under oath and must include: - a statement showing that the attachment is sought to secure the recovery on a claim upon which an attachment may be issued; - a statement of the amount to be secured by the attachment; - a statement that the attachment is not sought for a purpose other than the recovery on the claim upon which the attachment is based; - a statement that the applicant has no information or belief that the claim is discharged or that the prosecution of the action is stayed in a proceeding under the Bankruptcy Act (11 U.S.C. section 101 et seq.); and - a description of the property to be attached under the writ of attachment and a statement that the plaintiff is informed and believes that such property is subject to attachment. (CCP Sec. 484.020.)

Plaintiff argues that his breach of contract claim entitles him to a writ of attachment as his damages of $500,000 are fixed and readily ascertainable from Defendants' refusal to cooperate with his EB-5 visa application. Defendants oppose Plaintiff's applications on the grounds that the claimed damages of $500,000 is incorrect and that damages are uncertain due to the parties' agreement in 2024,

which allocated responsibility for payroll taxes, labor insurance premiums, and management fees to Plaintiff, depending on the requirements of Plaintiff's visa application. However, the 2024 Agreement accounts for different scenarios in which Plaintiff would be responsible for certain expenses depending on when his visa application was approved; since Plaintiff alleges that his green card has not been approved, those scenarios are irrelevant and damages are not uncertain. Next, Defendants argue that Plaintiff cannot prove a breach of contract.

Defendants claim they complied with their obligations under the 2024 Agreement because Plaintiff has not been in communication with them and that it is unknown why the conditions on his green card were not removed. Defendants point to another party to the 2024 Agreement, Junhui Li, who, like Plaintiff, invested in A1 Meat and was successfully able to remove the conditions on his green card. Defendants emphasize that Li and Plaintiff used the same immigration attorney. (Opp., p. 2.) Defendants assert that Plaintiff likely abandoned his petition for a visa because of issues proving that his funds were legitimate and that their conduct is not to blame for the Plaintiff's unsuccessful visa application. (Opp., pp. 2-3; Chui Joint Decl., P. 16.)

On August 18, 2026, Plaintiff filed a reply brief that merely reiterated the arguments made in his moving papers. Plaintiff contends that damages are easily ascertainable but does not address Defendants' claim that their actions did not cause Plaintiff's inability to remove the conditions on his green card. Thus, Plaintiff fails to demonstrate that his claims have probable validity and the applications for writs of attachment are DENIED. Plaintiff to give notice. Dated this 26th day of August 2026 | | | William A.

Crowfoot Judge of the Superior Court | Parties who intend to submit on this tentative must send an email to the Court at [email protected] indicating intention to submit on the tentative as directed by the instructions provided on the court website at www.lacourt.org. Please be advised that if you submit on the tentative and elect not to appear at the hearing, the opposing party may nevertheless appear at the hearing and argue the matter. Unless you receive a submission from all other parties in the matter, you should assume that others might appear at the hearing to argue.

If the Court does not receive emails from the parties indicating submission on this tentative ruling and there are no appearances at the hearing, the Court may, at its discretion, adopt the tentative as the final order or place the motion off calendar. SUPERIOR COURT OF THE STATE OF

CALIFORNIA FOR THE COUNTY OF LOS ANGELES - NORTHEAST DISTRICT GANG YANG, Plaintiff(s), vs. ANNE CHUI, et al., Defendant(s). |))))))))))) | CASE NO.: 25NNCV06903 [TENTATIVE] ORDER RE: MOTIONS TO BE RELIEVED Dept. 3 8:30 a.m. August 26, 2026 | |) | | Henry Ng seeks to be relieved as counsel of record for defendants Anne Chui, Rogers Chui, A1 Meat Inc., and A&R Trust (collectively, "Defendants") on grounds that his health has been deteriorating. Absent a showing of resulting prejudice, an attorney's request for withdrawal should be granted. (People v. Prince (1968) 268 Cal.App.2d 398, 406.) The Court notes that trial in this

matter is set for July 19, 2027, and no prejudice will result from granting this motion. However, the proposed orders submitted are incomplete and do not contain all future hearing dates, Defendants' addresses and telephone numbers, or the correct trial date. Accordingly, the hearing on these four motions to be relieved is CONTINUED to _____ at 8:30 a.m. in Department 3 of the Alhambra Courthouse so that defense counsel can submit revised proposed orders for the Court's signature. The proposed orders must be filed no later than 5 court days before the date of the hearing.

Defense counsel to give notice. Dated this 26th day of August 2026 | | | William A. Crowfoot Judge of the Superior Court | Parties who intend to submit on this tentative must send an email to the Court at [email protected] indicating intention to submit on the tentative as directed by the instructions provided on the court website at www.lacourt.org. Please be advised that if you submit on the tentative and elect not to appear at the hearing, the opposing party may nevertheless appear at the hearing and argue the matter.

Unless you receive a submission from all other parties in the matter, you should assume that others might appear at the hearing to argue. If the Court does not receive emails from the parties indicating submission on this tentative ruling and there are no appearances at the hearing, the Court may, at its discretion, adopt the tentative as the final order or place the motion off calendar. Case Number: 26NNCV00002 Hearing Date: August 26, 2026 Dept: 3 SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES - NORTHEAST DISTRICT EMEKA V.

PETER, Plaintiff(s), vs. SAROYAN AVETIK, et al., Defendant(s). |)))