Frank Recruitment Group, Inc vs. Loko AI, Inc

modifications, or other alterations or repairs” were not in compliance with applicable building codes, that “notices of abatement or citations against the property” had been issued, that they had hired unlicensed workers to perform the Renovations, that architectural and engineering plans and specifications were not prepared, that structural, electrical, mechanical, and Title 24 engineering calculations were not performed, that required permits were not obtained, and that required building inspections were not performed all in furtherance of their mutual business purpose of maximizing profits on the “fix & flip” of the Property.

(Compl. ¶¶ 16-17.)

The above is sufficient to meet the heightened pleading requirements for a fraud cause of action. To the extent that additional fraudulent statements are alleged that have not been pled with sufficient specificity, additional information can be obtained through discovery. This is because a general demurrer does not lie to only part of a cause of action. If there are sufficient allegations to entitle plaintiff to relief, other allegations cannot be challenged by general demurrer. (Daniels v. Select Portfolio Servicing, Inc. (2016) 246 Cal.App.4th 1150, 1167, (disapproved on other grounds by Sheen v. Wells Fargo Bank, N.A. (2022) 12 Cal.5th 905, 948 & fn. 12).)

Accordingly, the demurrer to the first cause of action is OVERRULED.

Plaintiff’s objections to the Slome Declaration are SUSTAINED.

Defendant Hopkins shall file his Answer within 20 days.

Plaintiff to give notice.

6. 30-2024-01382035 1. Motion to Appear Pro Hac Vice

Frank Recruitment Plaintiff/Cross-Defendant, Frank Recruitment Group Inc.’s Application for Admission Pro Hac Group, Inc vs. Loko AI, Vice of Michael J. Burns is GRANTED. Inc The verified application contains the information required by California Rules of Court, rule 9.40, and demonstrates compliance with the service and fee requirements. (See Declaration of Michael J. Burns; Declaration of Patrick A. Hormillosa, ¶ 4.)