Opposition to Demurrer and Motion to Strike complaint alleging causes of action for Breach of Contract, Anticipatory Breach of Contract, Breach of the Covenant of Good Faith and Fair Dealing, Violation of Section 17200 of the California Business and Professions Code, Fraud, Conversion, Declaration of Constructive Trust, Negligent Misrepresentation, Conspiracy, an Accounting, Preliminary Injunction, Preliminary and Permanent Restraining Orders, and Declaratory Relief.

The opposition sets forth pleading standards to overcome demurrer, and argues the elements of the challenged causes of action. It concludes that "At this stage of pleading, the allegations must be taken as true, and the complaint is to be construed liberally. All of the facts are sufficient to state the associated causes of action, and the allegations of the Plaintiffs’ first complaint are ripe for adjudication at this time."