Douglas G. Gray v. Kristine Ben

I. BACKGROUND

On March 11, 2022, the Grays filed their first amended complaint in Los Angeles Superior Court, bringing claims against Ben and Chase for negligence under California law and elder financial abuse pursuant to Cal. Welf. & Inst. Code §§ 15610.30 and 15657.5. Dkt. 1, Ex. A, CM/ECF page ID 26 et seq.1 (FAC) ¶¶ 30-38. The Grays allege they were victims of a wire fraud scam. Id. ¶¶ 11-23. On November 30, 2020, an individual who identified himself as Jonathan from Amazon contacted Mrs. Gray by telephone informing her that a fraudulent charge of $349.99 had been made to her Amazon

1 In future, exhibits to notices of removal should be separately linked. Case 2:22-cv-03090-DSF-PVC Document Filed 08/31/ Page 2 of Page ID #:172

account and that Amazon intended to refund that amount. Id. ¶ 11. The individual gained remote access to Mrs. Gray’s computer so she could observe him filling out a refund form. Id. ¶ 12. The individual stated that he erroneously processed a refund of $35,000 to her Chase checking account. Id. ¶¶ 12-13. Mrs. Gray then received instructions to wire funds to the Bangkok Bank in Thailand in order to “correct the mistake.” Id. ¶¶…