Pham

FACTS

I.

THE NEVADA RECEIVERSHIP PROCEEDINGS

In 2018, a Nevada court appointed Williams as a receiver in pending litigation between Pham and a third party. Williams was tasked with managing several Nevada properties owned by Pham. In 2020, the Nevada court approved Williams’s final report and accounting and discharged him as receiver.

II.

THE CALIFORNIA ACTION AND RELATED NEVADA PROCEEDINGS

In 2021, Pham filed the California action in propria persona against Williams, alleging fraud and embezzlement, among other things.

3 Pham later hired attorneys to represent him and filed an amended complaint, asserting causes of action for fraud and conversion, among other claims. The amended complaint alleged, inter alia, that Williams had embezzled receivership funds and defrauded the Nevada court in various ways. According to the amended complaint, venue was proper in the Superior Court of Orange County because Williams resided in the county. After filing the amended complaint, Pham petitioned the Nevada court for leave to sue Williams.1 The Nevada court denied Pham permission to sue Williams, concluding, inter alia, that it had already considered and rejected his asserted grounds…