Young

statement of facts contained in New Life’s opening brief. The following is a compilation of facts provided by New Life, together with certain allegations of fact gleaned from the balance of its brief. Plaintiff JBY International, Inc. (JBY) and New Life entered into a written “Finder’s Agreement” in 2010 pursuant to which JBY was to receive a finder’s fee if it produced “qualified investors as further described in the Finders Agreement.” At an earlier unstated time, JYB and plaintiffs Jennifer Young (JY) and William Young (WY) had negotiated the terms of a litigation settlement among themselves and Park Place EB5 (Park Place). That settlement included a provision that finder’s fees due to JBY would be paid by New Life to Park Place instead of to JBY. After plaintiffs had signed the writing settling that litigation and transmitted it to counsel for New Life and before any other party signed it, plaintiffs gave notice they were rescinding their consent to the agreement for reasons they stated (but which are not explained by New Life). The litigation which that agreement was supposed to settle was dismissed prior to all parties signing the settlement agreement. New Life does not…