Dotzenroth

I. FACTUAL BACKGROUND

23 The facts as asserted in Plaintiff’s Complaint include the following: 24 25 26 1 Defendants mistakenly identify Count Four as the Unfair Competition Law (“UCL”) claim, and Count Five as the breach of fiduciary duty claim, however Count Five alleges violation of the UCL, and Count 28 Plaintiff Mammoth Freighters LLC (“Mammoth” or “Mammoth Freighters”) is developing a passenger aircraft conversion program, designed in part by Plaintiff Wagner Aeronautical, Inc. (“Wagner Aeronautical”), that takes passenger aircraft and modifies them to carry cargo for the world’s leading air freight companies. The co-CEOs of Mammoth are Plaintiffs William Wagner (“Wagner”) and William Tarpley (“Tarpley”). Wagner, is the founder and president of Wagner Aeronautical and Tarpley is the business lead for Mammoth’s conversion program. 8 When Wagner and Tarpley began work on the conversion program, they asked 9 Defendant David Dotzenroth (“Dotzenroth”), a long-time friend with connections in the 10 financial industry, if he would be interested in exploring the possibility of a collaboration 11 whereby Wagner and Wagner Aeronautical would…