Yan Zhou v. Hung Ern Toh

I. INTRODUCTION AND BACKGROUND

This case involves an alleged scheme by defendants to fraudulently induce plaintiff Yan Zhou into investing in a home healthcare business, represented to have been located in Los Angeles County. Zhou is a foreign national based in Shenzen, China. On October 4, 2018, Zhou filed this action against Hung Ern Toh, two entities Toh controls, Barr Consulting and Holdings, Inc., and Barr Holdings, LLC (the “Barr Defendants”), as well as John B. Flecke, and Beverly Hills Escrow. ECF No. (“Compl.”). Zhou alleges that Toh induced her to transfer $322,129 to Toh and the Barr Defendants by misrepresenting an intention to invest those funds in a home healthcare business that Toh and the Barr Defendants stated they would operate. Compl. {| 23-24, 35, 57-58, 60, 62-69. Zhou alleges that neither Toh nor any of the Barr Defendants intended to actually invest Zhou’s funds at the time they induced Zhou’s investment. Id. 9] 51, 61. Zhou further claims that she would not have transferred any funds to Toh or the Barr Defendants but for their misrepresentations, and that she has lost all of her investment as a result. Id. 59, 68-69.…