Zhou

facts from plaintiff’s complaint, the allegations of which are deemed true for the limited purpose of determining whether [the] plaintiff has stated a viable cause of action. [Citation.]” (Stevenson v. Superior Court (1997) 16 Cal.4th 880, 885.) 2 Zhou dismissed Stewart Title Guaranty Company with prejudice on April 9, 2019.

2 Discovery The parties then apparently participated in some discovery. Again, as is relevant to the issues raised in this appeal, SJO asked Zhou in a special interrogatory to “[i]dentify, with specificity, the content of each and every verbal statement any representative of SJO . . . made to [you] that [you] contend was false.” Zhou responded: “Mr. Chris Sumners [an SJO representative] informed me that this is a normal sale with distressed property. He never informed me that this property could not be sold or inhabited.” Similarly, in response to a form interrogatory, Zhou stated that SJO “represented to [him] that the property being sold was capable of being conveyed and was conveyed with marketable title.” Furthermore, Zhou stated that “[t]he property was not capable of being conveyed and was not conveyed with a marketable title.” When asked if “any…