The Lawsuit Filed Against Thuy Huynh, Michael O'Young, and Early Hawkins

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MARK T. RISNER, ESQ.

Attorney at Law [CA SBN: 186942]
LAW OFFICE OF MARK T. RISNER
1 Park Plaza, Suite 600
Irvine, CA 92614
Telephone:
Facsimile:
(SPACE BELOW FOR FILING STAMP ONLY)
(949) 442-8302
(949) 442-8330
MATTHEW A. BERLINER, ESQ.

Attorney at Law [CA SBN: 224384]
BERLINER LEGAL GROUP
100 Spectrum Center Drive, Suite 870
Irvine, CA 92618
Telephone:
E-Mail:
(949) 698-2622
mberliner@berlinerlegal.net
Attorneys for Plaintiff, BRYAN CHRISTOPHER MOON
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IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA

IN AND FOR THE COUNTY OF ORANGE,
CENTRAL JUSTICE CENTER
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BRYAN CHRISTOPHER MOON,

an Individual,
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Plaintiff,
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v.
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THUY-DUYEN THI HUYNH,

a.k.a., THUY HUYNH, a.k.a.,
THUY LI, an Individual,
MICHAEL C. OYOUNG, an
Individual, LAW OFFICES OF
MICHAEL C. OYOUNG &
ASSOCIATES, a Business
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CASE NO. 30-2014-00713186-CUDF-CJC

CORRECTED FIRST AMENDED
COMPLAINT FOR DAMAGES:
1. MALICIOUS PROSECUTION
AGAINST ALL NAMED DEFENDANTS
AND ALL DOE DEFENDANTS;
2. DEFAMATION/SLANDER AGAINST
DEFENDANT THUY-DUYEN THI HUYNH
3. INTENTIONAL INFLICTION OF
EMOTIONAL DISTRESS AGAINST
DEFENDANT THUY-DUYEN THI HUYNH
__________________________________________________________________________________________________________________
CORRECTED FIRST AMENDED COMPLAINT FOR DAMAGES
Moon v. Thuy Huynh, et al.
CASE NO. 30-2014-00713186-CU-DF-CJC
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Entity Form Unknown,

EARLY M. HAWKINS, an
Individual, LAW OFFICES OF
EARLY M. HAWKINS, a Business
Entity Form Unknown,
and DOES 1 to 25, inclusive,
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Defendants.
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______________________________)
4. ASSAULT AGAINST DEFENDANT

MICHAEL C. OYOUNG AND ALL
DOE DEFENDANTS; and,
5. INTERFERENCE WITH
PROSPECTIVE ECONOMIC
ADVANTAGE AGAINST DEFENDANT
THUY-DUYEN THI HUYNH AND ALL
DOE DEFENDANTS
Assigned for All Purposes:
Hon. James Di Cesare
Dept. C-16
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Complaint Filed:
MSC Date:
ADR Review Hearing:
Trial Date:
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03/27/14
09/11/15
09/11/15
10/19/15
AN UNLIMITED CIVIL ACTION
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Here comes now Plaintiff Bryan Christopher Moon, an
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individual residing in the State of California (Plaintiff or
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Moon) and alleges as follows:
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1.
Moon is informed and believes and thereon alleges that
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Defendant Thuy-Duyen Thi Huynh is an individual and a resident
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of the State of Nevada, County of Clark.
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believes and thereon alleges that Huynh sometimes goes by the
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aliases Thuy Huynh and/or Thuy Li.
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2.
Moon is informed and
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Defendant Michael C. OYoung is an individual and a resident of
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the State of California, County of Orange.
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and believes and thereon alleges that OYoung is an attorney
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licensed to practice in the State of California.
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3.
Moon is informed
__________________________________________________________________________________________________________________
CASE NO. 30-2014-00713186-CU-DF-CJC
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Defendant, Law Offices of Michael C. OYoung & Associates is a
business entity of unknown capacity doing business in the State
of California and located in the County of Orange.
4.
Defendants the Law Offices of Michael C. OYoung &
Associates and OYoung initially represented Huynh in the
action that forms the basis for the Malicious Prosecution Claim
for Relief.
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5.
Defendant Early M. Hawkins is an individual and a resident of
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the State of California, County of Orange.
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and believes and thereon alleges that Hawkins is an attorney
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licensed to practice in the State of California.
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Moon is informed
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Defendant, Law Offices of Early M. Hawkins is a business entity
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of unknown capacity doing business in the State of California
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and located in the County of Orange.
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7.
Defendants the Law Offices of Early M. Hawkins, and
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Hawkins later represented Huynh in the action that forms
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the basis for this Malicious Prosecution Claim for Relief
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(collectively all Defendants in this matter shall be named
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Defendants).
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8.
Moon is not aware of the true names and capacities of
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defendants Does 1-25, inclusive, and therefore sues these
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defendants by such fictitious names.
Moon will amend this
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CASE NO. 30-2014-00713186-CU-DF-CJC
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Complaint to show the true names and capacities of such
fictitiously-named defendants when the same have been
ascertained.
alleges, that each of the Doe defendants are legally
responsible in some manner to Moon for the sums of damages
claimed herein.
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Moon is informed and believes, and based thereon
Moon is informed and believes, and thereon alleges,
that at all relevant times Defendants, and each of them, were
acting as agents, servants, employees, alter egos, successors
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or predecessors-in interest, or each of the other named
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defendants, and were acting within the course and scope of such
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relationship, with knowledge and consent, either express or
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implied, of the other named defendants.
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10.
Venue is proper in this venue as that the facts giving
rise to this action occurred in Orange County, California.
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Preliminary Matters/Allegations
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Moon has been analyzing investment opportunities for
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over a decade.
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arbitrage including spin-offs, mergers, bankruptcies and
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restructurings.
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situations involving high yield credit, warrants, and LEAPS.
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He also has experience in tracking and providing up-to-date
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commentary on activist investor campaigns.
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of an independent research service that focuses on providing
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His specialties are deep value and risk
Moon also has experience in analyzing special
Moon is the head
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CASE NO. 30-2014-00713186-CU-DF-CJC
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actionable investment ideas based on thorough fundamental
analysis of deep value, spin-offs, and other risk arbitrage
situations. Moon provides his clients with research profiles
representing his best ideas and provides ongoing commentary
and follow up. Over the last two years Moons stock picks have
outperformed the S&P 500 by a significant margin.
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Because of Moons skill and success in business and
investments, Moon has generated a well-regarded reputation in
the business and investment community at large.
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In the past Moon has assisted in raising capital from
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investors for large-scale residential real estate developments
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and commercial real estate in partnership with real estate
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developers.
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14.
During the last seven years, Moon has been attempting
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to generate investment leads, start businesses and seek capital
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and investors for prospective and on-going business ventures.
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15.
Moon originally met Huynh in or about the Summer of
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2004 at a night club in Los Angeles, California.
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in 2004, Moon and Huynh communicated with each other via e-mail
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and the social net-working website entitled Myspace.com.
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communicated in this manner until approximately 2007.
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Thereafter, the two began communicating again in or about
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August of 2010.
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After meeting
They
Throughout this period of time and upon
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CASE NO. 30-2014-00713186-CU-DF-CJC
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information and belief to this day, Huynh has/was attempting to
have a modeling career.
occasion promoted parties or events at local nightclubs.
promoted herself on social networking sites such as Myspace and
Facebook.
modeling career or promotional career.
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She was/is a bikini bartender and on

Huynh
However, Huynh was not widely successful in her
on many occasions, Huynh has dated men she has met on social
networking sites and other venues in exchange for various gifts
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and money.
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Notwithstanding Moons prior success in business and
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investments, in or about 2010 he was in the midst of searching
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for new opportunities.
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they starting communicating again in 2010.
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A fact of which he informed Huynh when
On or about September 2010, Moon and Huynh begun a
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romantic relationship when she traveled from California to
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Dallas, Texas to meet Moon.
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had met in person since 2004.
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This was the first time the two
Moon and Huynh continued to have a romantic
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relationship thereafter and communicated with each often via
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email and social networking websites.
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and relished in hearing from him.
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Huynh often pursued Moon
On or about September 2010, Moon moved to Orange
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CASE NO. 30-2014-00713186-CU-DF-CJC
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County, California to reside with Huynh. The two then
cohabitated, sharing some expenses and costs; such as rent,
utilities, food and entertainment costs.
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After their brief courtship, Huynh repeatedly pressured
Moon to marry her and on or about May 18, 2011, they were
married in Orange County, California.
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Moon and Huynh lived together for approximately 8
months; Huynh having moved out of their common residence after
just a few weeks of marriage.
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24.
At no time, before, during or after their marital
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separation did Moon and Huynh enter into any monetary contracts
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whereby Moon agreed to pay Huynh for expenses the two incurred
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while married.
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or monies from Huynh.
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relationship, Moon gave Huynh significant amounts of cash.
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Moon also purchased Huynh various gifts such as high-end
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designer purses, wallets, sunglasses, clothes and other items.
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All exchanges of gifts and monies between Moon and Huynh were
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gratuitous in nature.
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25.
Moreover, at no time did Moon borrow any funds

In fact, during the course of their
The marriage between Moon and Huynh was nonetheless
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contentious and on or about January 29, 2012, Huynh filed for
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divorce from Moon in the Superior Court of the State of
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California, for the County of Orange.
The divorce action was
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CASE NO. 30-2014-00713186-CU-DF-CJC
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entitled [petitioner] Huynh v. Moon; Case No. 12D000915 (the
Divorce Proceeding).
26.
The grounds cited by Huynh for the Divorce Proceeding
was irreconcilable differences.
Proceeding did Huynh seek annulment of her marriage to Moon
based on fraud or allege fraud of any form.
27.
At no time during the Divorce
In Huynhs divorce petition, she listed the date of
marriage as May 18, 2011, and the date of separation as June 6,
2011.
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28.
On or about September, 2012, Moon and Huynh entered
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into a Stipulated Judgment of the Dissolution of Marriage;
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whereby the two agreed to the certain disposition of property,
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monies and debt.
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of Marriage the parties agreed that there was no community
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property, nor any unpaid community obligations of any kind.
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The parties also agreed that all assets before the marriage and
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after the date of separation are confirmed to be his or her
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separate property.
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29.
In the Stipulated Judgment of the Dissolution
The Stipulated Judgment of the Dissolution of Marriage
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does not reflect any claim or allegation that Moon owed Huynh
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any monies, or that she alleged that Moon defrauded her in any
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manner.
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matter are devoid of any allegations that Moon defrauded or
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owed money to Huynh.
The Divorce Proceeding and the documents filed in that
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CASE NO. 30-2014-00713186-CU-DF-CJC
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30.
In fact, at no time during the Divorce Proceeding did
Huynh allege, to the court or Moon, that Moon owed her any
monies via any agreement between them and/or obtained money
fraudulently.
The Underlying Action and Its Dismissal with Prejudice/Judgment

in Favor of Moon
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31.
On or about April 24, 2012, Huynh, represented by
OYoung and the Law Offices of Michael C. OYoung & Associates,

filed suit in the Superior Court of the State of California,
for the County of Orange naming Plaintiff Moon as the
defendant. The action was entitled Thuy Huynh v. Bryan
Christopher Moon, [and doe defendants], Case No. 30-201200564239-CU-BC-CJC; (the Underlying Action).
The Underlying
Action asserted three claims for relief against Moon for: (1)
Breach of Oral Contract; (2) Fraud; and (3) Intentional
Inflection of Emotional Distress.
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Moon subsequently was served with the complaint from
the Underlying Action and answered; denying all claims for

relief, allegations and asserting various affirmative defenses.
33.
In the Underlying Action, Huynh, represented by OYoung
and the Law Offices of Michael C. OYoung & Associates,

alleged, among other things, that Moon falsely asserted to
Huynh that he was a successful business man, and that Moon
faked/impersonated various online personalities and individuals
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CASE NO. 30-2014-00713186-CU-DF-CJC
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on the social networking site FACEBOOK in an effort to garner
sympathy from Huynh and/or to defraud Huynh.
34.
In the Underlying Action, Huynh, represented by
OYoung and Law Offices of Michael C. OYoung & Associates,
alleged, among other things, that Moon, while impersonating
various false on-line individuals, contacted Huynh to vouch
for Moon and his credentials.
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alleged, among other things, that Huynh lent money and funds to
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Moon in an amount of approximately $56,000 of which $21,000 was
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allegedly evidenced by cancelled checks.
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she, on one hand, and Moon on the other hand, agreed that Moon
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would repay her monies she provided him.
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36.
Huynh alleged that
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alleged, among other things, that Moon defrauded Huynh by:
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impersonating other online individuals; claiming to be a
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successful businessman;
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from Huynh;
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falsely requesting to borrow money
and falsely inducing Huynh into marrying Moon.
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alleged, among other things, that Moon inflicted intentional
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emotional distress upon Huynh, on his own behalf and through
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CASE NO. 30-2014-00713186-CU-DF-CJC
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his numerous fake aliases by sending malicious electronic
messages to Huynh.
emotional distress in the form of public humiliation, mental
anguish, anxiety, and emotional distress.
to have suffered from stress, anxiety, loss of sleep, loss of
appetite, and other severe emotional distress as a result of
Moon, in response to interrogatories propounded by Moon.
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Huynh alleged to have suffered severe
Huynh also alleged
In the Underlying Action, Huynh, represented by
OYoung, the Law Offices of Michael C. OYoung & Associates and

Hawkins, sought compensatory and exemplary damages from Moon.
39.
Prior to filing the complaint in the Underlying Action,
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OYoung and the Law Offices of Michael C. OYoung & Associates
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did not correspond with Moon or send him any form of demand
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letter or offer to compromise the Underlying Action.
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40.
The service of the complaint from the Underlying Action
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was the first instance that Moon was informed that Huynh
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alleged, and or claimed, that Moon had caused Huynh any legally
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cognizable damages, including but not limited to; (1) breach of
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oral contract; (2) fraud; and/or (3) intentional infliction of
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emotional distress.
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The complaint was filed just 6 weeks after Huynhs
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family attorney in the Divorce Proceeding, Damian Fragoso,
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learned that Moon was cooperating with the Internal Revenue
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Service under the innocent spousal rule due to his belief that
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CASE NO. 30-2014-00713186-CU-DF-CJC
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he could be liable for Huynh drastically underreporting her
income to the Internal Revenue Service. Moon believes the
Underlying Action was filed in retaliation for his cooperation
with the Internal Revenue Service.
42.
As early as May 2012, OYoung and his firm were
confronted by Moons counsel with a variety of factual
falsehoods/inconsistencies and/or exculpatory evidence
concerning the allegations alleged in the Underlying Action and
in Huynhs discovery responses.
Notwithstanding being
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confronted by these factual falsehoods/inconsistencies and/or
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exculpatory evidence, OYoung and his firm persisted in
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proceeding to prosecute the Underlying Action against Moon.
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Among the variety of factual falsehoods and
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inconsistencies concerning the allegations in the Underlying
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Action was the claim that Huynh lent Moon $56,000.
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claim was baseless and was not supported by any written
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documents or competent testimony.
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and expense declaration produced in the Divorce Proceeding,
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Huynh declared that her annual income was $24,000; meaning that
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it was unfeasible that she had the funds to loan anyone, much
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less Moon, $56,000.
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Dissolution of Marriage was devoid of any reference to Moon
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owing any monies to Huynh.
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This
Indeed, in Huynhs income
Moreover, the Stipulated Judgment of the
Huynhs claim that she lent Moon $56,000 was false
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CASE NO. 30-2014-00713186-CU-DF-CJC
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and not supported by any evidence.
the documents that do exist that any monies provided by Huynh
to Moon (and even from Moon to Huynh) were gifts either before
or after the two had married.
furtherance of their marriage and romantic relationship not a
loan. Indeed, Check No. 120 attached to the complaint in the
Underlying Action contained the following in the memo line I
You written by Huynh.
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Indeed, it is evident from
Or the money was spent in
In both written discovery and in deposition testimony,
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Huynh repeatedly failed to reconcile her income (as declared in
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the Divorce Proceeding) with the amount of funds she and
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OYoung (and his firm) alleged that Huynh had lent to Moon.
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When asked at deposition, Huynh could only testify that her
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cash loan totaling $35,000 to Moon had been made around the
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holidays of 2010.
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this allegation.
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46.
Huynh could provide no other support for
With respect to Huynhs allegation that Moon
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impersonated numerous individuals online in an attempt to
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garner her sympathies and support and/or to defraud her, Huynh
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did not (and cannot) provide any support for said allegations.
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During deposition, Huynh testified that she had proof via
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reports and her own forensic investigation that Moon had
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impersonated numerous people on line.
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her statements about her investigation and resulting reports,
However, notwithstanding
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CASE NO. 30-2014-00713186-CU-DF-CJC
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Huynh did not provide any evidence/documents for any allegation
that Moon had impersonated people on line. This is the case
notwithstanding that said information was requested by Moons
counsel and which Huynh agreed to provide to Moons counsel.
47.
Indeed, Huynh testified in deposition that she had
linked at least ten fake individuals/on-line personas to
Moon.
evidence to support these allegations.
48.
However, she did not produce any documents or other
Huynh also alleged that Moon defrauded her into
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marrying him in order to secure financial support from Huynh.
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However, in the Divorce Proceeding that was initiated to end
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the marriage between Moon and Huynh, Huynh did not seek or
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claim an annulment of the marriage based on fraud.
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Huynh allege any damages as a result of fraud by Moon in the
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Divorce Proceeding.
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49.
Nor did
Indeed, even after Huynh separated from Moon in June
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2011, and alleged that he had defrauded her, Huynh continued
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to have sexual relations with Moon up until late December 2011.
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50.
Shortly after Moon was served with the complaint from
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the Underlying Action, OYoung called Moon on behalf of Huynh
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and as her legal representative and agent and stated that Moon
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should write a check for $150,000 or else.
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is not privileged as it was not a legitimate or authenticate
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offer to compromise seeing as Huynhs complaint in the
This statement
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CASE NO. 30-2014-00713186-CU-DF-CJC
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Underlying Action only alleged $56,000 in damages.
OYoungs call and statements therein, were a form of
extortion. This further evidences the bad faith and malice by
Huynh, OYoung and his firm.
51.
Rather,
As part of the Underlying Action, and through counsel,
Moon served a Demand for Bill of Particulars on OYoung and
Huynh requesting an itemized accounting of charges. Defendants
failed to respond as is required, necessitating Moon to bring a
Motion to Preclude Evidence of Account.
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52.
After being ordered by the Court to produce a Bill of
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Particulars, OYoung and Huynh produced a defective Bill of
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Particulars with ever changing dates and no itemization.
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requests for Further Bill of Particulars, OYoung and Huynh
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produced a total of three inconsistent and hence defective
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Bill(s) of Particulars.
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53.
In May 2012, Moon, through counsel, served
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Huynh/OYoung with discovery requests and interrogatories.
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Huynh refused to comply with much of the requests on
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questionable grounds.
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54.
Upon
On or around July 2012, Huynh through counsel served
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Moon with discovery request that can only be characterized as
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overly broad. Requesting all emails from a relationship that
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ended two years prior to Moon dating Huynh. Such as requesting
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CASE NO. 30-2014-00713186-CU-DF-CJC
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records back to 2004, a full six years before they began
dating. All in an effort to harass and burden Moon.
55.
On January 4, 2013 Moon, traveled a total of 2,000
miles at the request of OYoung/Huynh for his deposition in
which OYoung asked questions of Moon for little more than 60
minutes and gathered little information.
deposition and questioning was more than an effort to harass
and burden Moon then seek legitimate discovery.
56.
Clearly the
Furthermore, during his deposition, Moon began
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presenting evidence and information that directly contradicted
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Huynhs allegations in the Underlying Action. After being
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presented with this information OYoung promptly ended the
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deposition, over the objections of Moon and counsel, to prevent
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the facts from getting on the record.
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57.
Further, throughout the litigation of the Underlying
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Action, OYoung represented to others that there was little
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evidence in the case to support Huynhs claims (i.e., a case of
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he said she said) and that the Underlying Action was brought
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for the purpose of exhausting Moons finances.
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58.
Through Moons counsel of record, OYoung was apprised
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of the many defects, improprieties, falsehoods, and
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inconsistencies in Huynhs complaint and allegations in the
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Underlying Action.
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evidence that contradicted the allegations and claims in the
OYoung was also presented with exculpatory
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CASE NO. 30-2014-00713186-CU-DF-CJC
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Underlying Action, for example the $56,000 Huynh loaned Moon
versus the contents of Huynhs Income and Expense Declaration
executed under penalty of perjury which stated she only had
annual income of $24,000.
his firm failed to recuse themselves from representing Huynh
and continued prosecuting the Underlying Action against Moon.
59.
Notwithstanding such, OYoung and
Moreover, during the litigation itself, OYoung
comported himself in a hostile and extremely unprofessional
manner.
During a break in Huynhs deposition on April 15,
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2013, unprovoked, OYoung threatened physical violence against
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Moon; calling him a Lunatic; and screaming Im going to kick
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[Moons] ass.
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purposefully threw his laptop at Moons head and left a 6-inch
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gash in the wall behind Moon.
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restrained by Moons counsel from harming Moon and the court
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reporters dove for cover underneath the conference table.
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behavior resulted in a 911-call and OYoung and Huynh fleeing
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the scene before the police could arrive.
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At that same time, unbelievably, OYoung
OYoung had to be physically
This
Before fleeing the conference room where the deposition
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was being held, OYoung yelled F*** You and made an obscene
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gesture at Moon.
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department was made.
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$2,437.56 discovery sanction against OYoung and Huynh.
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61.
A report to the Irvine, California police

It also resulted in an imposition of a
OYoungs behavior and physical actions directed at
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CASE NO. 30-2014-00713186-CU-DF-CJC
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Moon, caused Moon to incur emotional distress and mental
anguish.
was attempting to physically harm Moon.
62.
Moon reasonably and justifiably believed that OYoung
Further, OYoung ordered Huynh to leave the deposition
before she was properly excused in violation of the Code of
Civil Procedure.
63.
Following his violent outburst at Huynhs deposition,
and in what Moon believes is an attempt to avoid being
sanctioned for his behavior, OYoung withdrew from representing
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Huynh any further.

64.
After OYoungs withdrawal Huynh then retained attorney
Early M. Hawkins to represent her in the Underlying Action.

65.
After appearing as counsel for Huynh, Hawkins and his
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firm was similarly presented by Moons counsel with evidence of
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the factual inconsistencies/falsehood alleged by Huynh and/or
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exculpatory evidence that demonstrated that Huynhs claims
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against Moon lacked any merit and probable cause.
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ignored these communications and never responded.
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66.
Hawkins
Hawkins proceeded to prosecute Huynhs claims and
20
allegations against Moon, notwithstanding being presented by
21
evidence of the factual inconsistencies/falsehood alleged by
22
Huynh and/or exculpatory evidence that demonstrated that
23
Huynhs claims against Moon lacked any merit and probable
24
cause.
25
26
27
28
29
30
__________________________________________________________________________________________________________________
CASE NO. 30-2014-00713186-CU-DF-CJC
-18-
67.
Throughout the Underlying Action, Huynh, by and through
her counsel OYoung
to abide by her/their discovery obligations under the Code of
Civil Procedure.
respective firms) failed to produce (mainly because none
existed) checks totaling $21,000 for monies Huynh alleged was
lent to Moon.
produced, of the $35,000 in cash Huynh alleged she lent to
Moon. Huynh, by and through her counsel OYoung and Hawkins,
10
also failed to produce any evidence that Moon impersonated
11
people on line in an attempt to garner Huynhs support and/or
12
to defraud her.
13
deposition testimony that she had performed an investigation
14
and had reports of Moons illicit impersonations.
15
68.
and Hawkins and their firms, also failed
Huynh, OYoung and Hawkins (and their
Nor was there any evidence, or documents
This is the case notwithstanding her
Huynh also failed to produce any credible evidence of
16
the severe emotional distress in the form of public
17
humiliation, mental anguish, anxiety, and emotional distress,
18
anxiety, loss of sleep and/or loss of appetite that she alleged
19
to have suffered in the Underlying Action.
20
69.
Moreover, Huynhs claims of loss of appetite and
21
mental anguish, anxiety were contradicted by hundreds of
22
updates on social networking sites of her eating and enjoying
23
herself in many social settings and parties.
24
70.
That is because Huynh suffered from none of those
25
26
27
28
29
30
__________________________________________________________________________________________________________________
CASE NO. 30-2014-00713186-CU-DF-CJC
-19-
emotional and/or physical problems or maladies.
Indeed,
medical documents obtained by Moons counsel via subpoena
suggest that Huynhs emotional and/or psychological issues were
tied to her use of recreational drugs such as cocaine and
ecstasy.
Hawkins were aware that there was no medical evidence
supporting Huynhs allegations of emotional and/or physical
injury and also that he was aware of Huynhs recreational drug
use. Yet, even with this knowledge, OYoung and Hawkins pressed
Moon believes and thereon alleges that OYoung and
10
forward with Huynhs claims that she suffered these emotional
11
and/or physical ailments.
12
71.
On or around July 12, 2013, Moon filed a Motion to
13
Compel on discovery requests and a Motion to Compel Further
14
Bill of Particulars after repeated efforts to meet and confer
15
were ignored by Huynh and her then counsel of record Hawkins.
16
Huynh and Hawkins failed to file any opposition or response to
17
the Motion to Compel filed by Moon and his counsel.
18
72.
On or about August 14, 2013, in response to a motion to
19
compel filed by Moon, the Superior Court in the Underlying
20
Action ordered Huynh and Hawkins to produce various documents
21
relevant to her claims and allegations.
22
included, inter alia, documents evidencing Moon contacting
23
Huynh via various fake aliases; documents evidencing that Moon
24
agreed to reimburse Huynh for various living expenses in the
Such documents
25
26
27
28
29
30
__________________________________________________________________________________________________________________
CASE NO. 30-2014-00713186-CU-DF-CJC
-20-
sum of $21,000; and documents evidencing that Huynh received
treatment from health care providers for any injury resulting
from emotional distress allegedly caused by Moon.
Notwithstanding the Superior Courts order and various meet and
confer efforts by Moons counsel, Huynh and Hawkins (and his
firm) failed to produce the documents. These documents were
material and relevant to Huynhs claims in the Underlying
Action.
73.
On or about September 05, 2013, Hawkins filed a Motion
10
to Seal and Motion for Protective Order after failing to meet
11
the requirements to meet and confer. In both filings Hawkins
12
knowingly made false allegations against Moon.
13
were ultimately denied. This is just another example of Huynhs
14
and Hawkins malicious use of the judicial process to harm
15
Moon.
16
74.
The motions
On September 13, 2013, counsel for Moon filed and
17
served a Notice of Motion and Motion for Terminating Sanction to
18
be heard on October 9, 2013. The Motion for Terminating
19
Sanctions was based on Hunyhs failure to produce the documents
20
subject to the prior Order on Moons motion to compel. Huynh and
21
Hawkins did not file any Opposition or Response to Moons Motion
22
for Terminating Sanctions.
23
75.
On or about October 09, 2013, as a result of Huynhs,
24
25
26
27
28
29
30
__________________________________________________________________________________________________________________
CASE NO. 30-2014-00713186-CU-DF-CJC
-21-
OYoungs, and Hawkins failure to produce the documents
subject to Moons motion to compel, the Superior Court in the
Underlying Action granted Moons motion for Terminating
Sanctions against Huynh; and dismissed her complaint with
prejudice.
76.
The judgment in favor of Moon and against Huynh,
emananting from Moons Motion for Terminating Sanctions,
reflected on the merits of the Underlying Action and Moons
innocence of the wrongful conduct alleged against him as well as
10
Huynhs failure to prosecute her case. This ruling was a
11
determination on the merits of the Underlying Action in favor of
12
Moon. As noted above, Huynh failed to produce and evidence to
13
support her claims despite being ordered by the Court to do so.
14
Huynh also failed to file any Opposition or Response to numerous
15
Motions (including the terminating sanction motion) and totally
16
ignored several Court Orders which is further evidence that
17
she was failing to prosecute the Underlying Action. This all
18
concluded in a ruling in favor of Moon on hi Motion for
19
Terminating Sanctions which reflects a failure to prosecute the
20
Underlying Action on behalf of Huynh and her counsel. Such a
21
result has been held by California Courts to constitute a
22
favorable termination for purposes of a Malicious Prosecution
23
Action. Finally, Huynhs failure to appeal the dismissal of her
24
25
26
27
28
29
30
__________________________________________________________________________________________________________________
CASE NO. 30-2014-00713186-CU-DF-CJC
-22-
case reflects the obvious conclusion that her case was meritless
and filed with malice.
77.
Additionally, the Court dismissed Moons cross-
complaint for declaratory relief (which had incorporated
the contents of Huynhs complaint by reference) as moot.
Specifically, the Court in the Underlying Action determined that
the ruling terminating Huyhns affirmative complaint in the
Underlying Action was res judicata as to Moons counterclaim
for declaratory relief hence further demonstrating that the
10
terminating sanction/order was a determination on the merits on
11
Huynhs affirmative claims in the Underlying action.
12
13
78.
On or about November 7, 2013, the Superior Court in the
Underlying Action entered judgment in favor of Moon and against
14
Huynh based on the prior order on Moons motion for terminating
15
sanctions. Moon was declared the prevailing party and was
16
awarded his costs for the Underlying Action. Neither Huynh or
17
her counsel brought any motion to tax costs, but rather
18
willingly paid them yet another admission Huynhs case lacked
19
merit and was brought without probable cause.
20
79.
Defendants, all of them, acted without probable cause
21
in the Underlying Action in that there were no contracts between
22
Moon and Huynh, Moon did not defraud Huynh and he did not
23
inflict emotional distress upon her. Nor did Huynh suffer from
24
any of the emotional and/or physical distress she alleged in the
25
26
27
28
29
30
__________________________________________________________________________________________________________________
CASE NO. 30-2014-00713186-CU-DF-CJC
-23-
Underlying Action. In fact, Defendants produced no credible
evidence in the Underlying Action to support Huynhs claims for
relief as alleged in the Underlying Action or in subsequent
responses to discovery and deposition questioning. As such,
Defendants, all of them, did not, and could not have honestly
believed that there were grounds for the Underlying Action or
its continued prosecution. Moreover, Huynhs failure to allege
any contract for monies or fraud in the Divorce Proceeding
further supports Moons allegations that Defendants lacked
10
probable cause to raise the claims in the Underlying Action and
11
thereafter to continue to prosecute its claims for relief.
12
80.
Finally, OYoungs personal conduct itself, and his
13
physical assault on Moon, demonstrates that he lacked any
14
probable cause to assert the Underlying Action and that the
15
Underlying Action was being prosecuted solely out of malice to
16
harm and injure Moon.
17
81.
Defendants, all of them, acted maliciously in bringing
18
the Underlying Action against Moon in that they had improper
19
motives and purpose, prejudice and a desire to harm and wrong
20
Moon.
21
failure of Defendants to produce credible evidence supporting
22
Huynhs claims and allegations in the Underlying Action;
23
Defendants failure to abide by their discovery obligations in
24
the Underlying Action, the exculpatory evidence that was
This malice is evidenced, in part, by the complete
25
26
27
28
29
30
__________________________________________________________________________________________________________________
CASE NO. 30-2014-00713186-CU-DF-CJC
-24-
provided to Defendants, the factual inconsistencies presented
to Defendants regarding the Underlying Action, Defendants
failure to dismiss the Underlying Action after being presented
with the aforementioned exculpatory evidence and factual
inconsistencies, OYoungs statements to Moons counsel and
others, and OYoungs personal conduct, such as the assault and
threats to Moon.
8
9
82.
As a result of Defendants conduct and malicious
prosecution, Moon suffered damages such as attorneys fees and
10
costs in the amount of $52,413.76 (not including interest);
11
emotional and mental distress and anxiety; loss of business
12
reputation, character and good will; and loss of business
13
opportunities.
14
by Defendants caused key backers to withdraw funding and/or
15
abandon business and investment ventures with Moon. The
16
Underlying Action also caused Moon to suffer emotional
17
distress, anxiety and depression.
18
83.
By way of example, the baseless claims asserted
Huynh, OYoung (and his firm), and Hawkins (and his
19
firm) were well aware that the Underlying Action would harm
20
Moons business interests.
21
investor, Moon informed Huynh that a fraud action could be the
22
death knell to his career.
23
thereon alleges that OYoung and Hawkins (and their respective
24
firms) were aware of this fact, and asserted, and continued to
As a Wall Street professional and
Moon is informed and believes and
25
26
27
28
29
30
__________________________________________________________________________________________________________________
CASE NO. 30-2014-00713186-CU-DF-CJC
-25-
prosecute, the baseless fraud claim in the Underlying Action
solely to improperly harm Moon and his business prospects.
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
Huynhs Defamatory Statements

84.
In addition to falsely accusing (without any probable
cause) Moon of breaching any contract, defrauding her, or

causing her emotional distress; Huynh also published many
unprivileged defamatory comments about Moon on webpages, social
net-working sites and via emails/or communiqus
to third
parties.
85.
From approximately February 2012 to August 2013, Huynh
made the following defamatory comments and web-posts regarding

Moon:
a. On or about February 12, 2012, Huynh created a
Facebook page entitled Chris Moon FB Scam Alert.
b. On that same Facebook page Huynh accused Moon of
impersonating various other individuals online.
c. On that same Facebook page Huynh accused Moon of
raising and generating money from investors for
projects and investments that did not exist.
19
20
21
22
23
d. On that same Facebook page Huynh referred to Moon as

a psycho-stalker.
e. On or about February 12, 2012, Huynh created a post
on the website RipOffReport.com accusing Moon of
being a scam artist and a fraud.
24
25
26
27
28
29
30
__________________________________________________________________________________________________________________
CASE NO. 30-2014-00713186-CU-DF-CJC
-26-
1
2
3
4
5
6
7
f. On that same posting of RipOffReport.com Huynh

accused Moon of impersonating various individuals
online.
g. On that same posting(s) on RipOffReport.com Huynh
accused Moon of raising and generating money from
investors for projects and investments that did not
exist.
h. On that same posting(s) on RipOffReport.com Huynh
accused Moon of having restraining orders issued
against him.
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
i. Huynh posted a link on the RipOffReport.com

website to her personal Facebook page. Huynhs
personal Facebook page therein stated that Moon
scammed me, dont let him scam you and
Christopher Moon scams Asian models.
j. On May 25, 2012, Huynh posted on her Facebook page
that Moon was hacking her email accounts. She also
called Moon a sociopath and a super obsessed
stalker.
k. On or about May 25, 2012, on Huynhs personal
Facebook page she stated that an ex-boyfriend of
Huynhs hired a cyber-detective and that they had
linked Moon to all these phony accounts of fake
individuals.
l. On or about June 22, 2012, Huynh posted on her
Facebook page that Moon was impersonating her then
roommate Jen Lee Tran online.
m. On or about November 15, 2013, Huynh created a
second post on RipOffReport.com accusing Moon of
the crime of running and operating investment scams.
n. On or about April 19, 2013, Huynh emailed Moons
business partner David L. White in an attempt to get
__________________________________________________________________________________________________________________
CASE NO. 30-2014-00713186-CU-DF-CJC
-27-
him to sever business ties with Moon. In the email

she wrote:
1
2
3
4
5
o. On or about June 4, 2013, Huynh again posted on her

personal Facebook page a statement calling Moon a
psycho-stalker and accusing Moon of posting
information about her tax problems with the IRS
online.
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
That Moon had scammed Huynh.

That Moon impersonated people online; and
That Moon had scammed other individuals online.
86.
The above publications and words made and published by
Huynh were heard by White and various other third parties whose
names are not currently known to Moon.
87.
At the time Huynh made the defamatory statements and
publications Moon was not a public figure nor making public

statements.
88.
The above publications and words made by Huynh were
false or made without the reasonable belief that they were

true.
89.
The above described publications and words by Huynh
were not privileged because Huynh published these with personal

animosity, actual malice, hatred and ill will toward Moon and
with either knowledge that they were false or without any
reasonable grounds for believing that they were true in that it
was false that Moon: (a) was operating any fraudulent schemes
to scam money from investors; (b) was impersonating
individuals online; (c) had a restraining order issued against
__________________________________________________________________________________________________________________
CASE NO. 30-2014-00713186-CU-DF-CJC
-28-
him; (c)
scammed Huynh or other Asian models;
and/or a fraud; and (f) was raising and generating money from
investors for projects and investments that did not exist.
90.
was a sociopath and a super obsessed stalker; (d)

(e) was a scam artist
Moreover, the above described publications and words by
Huynh, are not afforded any privilege of the California Civil
Code because she is not an officer of the government; because
they were not published or spoken in connection with a
legislative, judicial or other official proceeding or
10
proceeding reviewable by mandate; because they were not spoken
11
or written by Huynh to a person who was interested in the
12
communication, because they were not published to a person
13
related to Huynh, or to a person who requested the information
14
from Huynh; were not published in a public journal concerning
15
an official proceeding or a verified complaint; and were not
16
written or published in a report of a public meeting or of a
17
matter for the public benefit.
18
applies to the defamatory words and comments made by Huynh to
19
third parties.
20
91.
Simply put, no privilege
The above described publications and words by Huynh
21
were, and are, defamatory per se because they accused Moon of
22
committing various state and federal crimes, of being a
23
criminal, of perpetrating frauds and fraudulent schemes and/or
24
other morally repugnant conduct (such as, but not limited to,
25
26
27
28
29
30
__________________________________________________________________________________________________________________
CASE NO. 30-2014-00713186-CU-DF-CJC
-29-
being a stalker), and tarnishing Moons
business and general community at large.
92.
good reputation in the
Indeed, Huynh was well aware that the false and
defamatory statement she made to third parties would harm
Moons reputation in the business community and the community
at-large and cause him to suffer grave reputational harm.
made these statements with the intent and purpose to harm Moon.
8
9
93.
And as a result of Huynhs defamatory statements,
Moons reputation in the business community and the community
10
at-large was harmed and he incurred financial losses as a
11
result thereof.
12
distress and anxiety as a result of Huynhs defamatory
13
statements and the effect these had on his reputation and
14
goodwill.
15
17
19
20
21
22
23
24
Moon also incurred emotional and mental
FIRST CAUSE OF ACTION FOR RELIEF

Malicious Prosecution
(Against All Defendants and DOES 1 to 25)
16
18
She
94.
Moon realleges and incorporates paragraphs 1 through 91
fully herein.
95.
Defendants initiated the Underlying Action in Orange
County Superior Court.
At the time Defendants initiated the
Underlying Action they lacked and acted without probable cause

to bring each and every claim for relief contained therein.
96.
Moreover Defendants continued to prosecute the
25
26
27
28
29
30
__________________________________________________________________________________________________________________
CASE NO. 30-2014-00713186-CU-DF-CJC
-30-
Underlying Action without probable cause even after being
presented with exculpatory evidence and facts and/or
inconsistencies in the allegations and claims brought in the
Underlying Action.
5
6
7
97.
Defendants acted maliciously in bringing and continuing
to prosecute the Underlying Action against Moon.

98.
The Underlying Action was terminated in Moons favor,
and judgment entered on his behalf.
prevailing party and awarded his costs from the Underlying
10
11
Moon was declared the
Action.
99.
As a proximate result of Defendants bringing and
12
prosecuting the Underlying Action, Moon has been damaged in the
13
sum of $52,413.73 (excluding interest) for fees and costs
14
defending the Underlying Action.
15
damages including emotional and mental distress, loss of
16
business opportunities, and harm to his reputation in an amount
17
to be proven at trial.
Moon has also incurred
18
100. Defendants acts, as alleged above, were willful,
19
wanton, malicious and oppressive, were undertaken with the
20
intent to harm and prejudice Moon and justify the awarding of
21
exemplary and punitive damages.
22
23
24
/ / /
25
26
27
28
29
30
__________________________________________________________________________________________________________________
CASE NO. 30-2014-00713186-CU-DF-CJC
-31-
SECOND CAUSE OF ACTION FOR RELIEF

Defamation/Slander
(Against Huynh and DOES 1 to 25)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
101. Moon realleges and incorporates paragraphs 1 through 98

fully herein.
102. As alleged above, Huynh spoke and published false and
defamatory words concerning Moon.
103. These words and publications were read and/or heard by
White and various other third parties whose names are not
currently known to Moon.
104. The above described publications and words by Huynh
were and are defamatory per se because they accused Moon of
committing various state and federal crimes, of being a
criminal, of perpetrating frauds and fraudulent schemes and/or
other morally repugnant conduct (such as, but not limited to,
being a stalker);
and tarnishing Moons good reputation in the

105. The words also carried a defamatory meaning because
they falsely claimed that Moon committed frauds and fraudulent
schemes, committing various state and federal crimes, other
morally repugnant conduct (such as, but not limited to, being a
stalker); and/or tarnishing Moons good reputation in the
were false.
__________________________________________________________________________________________________________________
CASE NO. 30-2014-00713186-CU-DF-CJC
-32-
were nor privileged pursuant to the California Civil Code.
could Huynhs statements and publications be privileged because
Huynh published these words and statements with personal
animosity, actual malice, hatred and ill will toward Moon and
with either knowledge that they were false or without any
reasonable grounds for believing that they were true.
108. As a result of the above described words and
8
9
Nor
statements, Moon has suffered general damage to his reputation.

109. As a further and proximate result of the above
10
described words and statements, Moon has suffered the following
11
special damages, including but not limited to, injury to his
12
trade and profession, lost business opportunities and emotional
13
and mental distress in an amount to be proven at trial.
14
110. Huynhs conduct, as alleged above, was willful,
15
wanton, malicious and oppressive, was undertaken with the
16
17
18
19
20
21
22
23
THIRD CAUSE OF ACTION FOR RELIEF

Intentional Infliction of Emotional Distress
111. Moon realleges and incorporates paragraphs 1 through
108 fully herein.
112. Huynh, through both her on-line activities and
24
25
26
27
28
29
30
__________________________________________________________________________________________________________________
CASE NO. 30-2014-00713186-CU-DF-CJC
-33-
statements and words published to third parties made false
statements regarding Moon, his character, his (non-existent)
criminal activities, and his conduct.
4
5
6
113. Huynh acted with malice and the intent to damage Moon
and to cause him severe emotional and mental distress.
114. As a proximate result of Huynhs acts and conduct, Moon
did in fact incur severe emotional and mental distress, in the
form of mental anguish, depression, anxiety, and humiliation.
9
10
11
115. As a proximate result of Huynhs acts and conduct, Moon

suffered damages in an amount to be proven at trial.
116. Huynhs conduct, as alleged above, were willful,
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
FOURTH CAUSE OF ACTION FOR RELIEF

Assault
(Against OYoung and DOES 1 to 25)
114 fully herein.
118. On or about April 15, 2013, OYoung acted, intending to
cause harm and physical damage/contact to Moon.
This conduct
was demonstrated by OYoungs verbal and physical actions

towards Moon, including but limiting to, throwing his laptop
computer at Moon.
OYoung had to be restrained and in that
process - assaulted Moons counsel resulting in injury.

__________________________________________________________________________________________________________________
CASE NO. 30-2014-00713186-CU-DF-CJC
-34-
1
2
3
4
119. Moon reasonably believed that he was about to be

touched in a harmful and offensive manner by OYoung.
120. It also reasonably appeared to Moon that OYoung was
about to carry out his threats.
121. Moon did not consent to OYoungs conduct.
122. Moon was harmed by OYoungs conduct.
7
8
9
And OYoungs
conduct was a substantial factor in causing Moons harm.

123. OYoungs conduct, as alleged above, was willful,
wanton, malicious and oppressive, was undertaken with the
10
11
12
FIFTH CAUSE OF ACTION FOR RELIEF
Interference with Prospective Economic Advantage
13
14
15
16
17

121 fully herein.
125. Moon and various third parties were in economic
18
relationship(s) that probably would have resulted in an
19
economic benefit to Moon.
20
126. Huynh knew of these relationships.
21
127. Huynh intended to disrupt these relationships and harm
22
23
Moon.
128. Huynh engaged in wrongful conduct through unfounded
24
25
26
27
28
29
30
__________________________________________________________________________________________________________________
CASE NO. 30-2014-00713186-CU-DF-CJC
-35-
litigation and slander and defamation to intentionally disrupt
these economic relationships between Moon and various third
parties.
129. Huynh is not, and was not, a competitor of Moons and
her conduct did not fall within the confines of fair
competition.
130. These economic relationships between Moon and various
third parties were in fact disrupted by Huynhs improper and
illegal conduct.
10
11
12
13
14
131. Moon was harmed by Huynhs improper and illegal conduct

and disruption of his economic relationships.
132. Huynhs wrongful conduct was substantial facto in
causing Moons harm.
133. Huynhs conduct, as alleged above, were willful,
15
16
17
18
19
20
21
22
/ / /
23
/ / /
24
25
26
27
28
29
30
__________________________________________________________________________________________________________________
CASE NO. 30-2014-00713186-CU-DF-CJC
-36-
1
2
WHEREFORE, Moon prays for Judgment as to all Causes of

Action for Relief as against all Defendants, as follows:
3
4
5
a. For actual damages according to proof and for interest

thereon at the legal rate;
b. For presumed damages according to the trier of fact;
6
7
8
9
c. For exemplary and punitive in an amount the trier of

fact deems proper;
d. For costs of suit;
10
e. For attorneys fees according to proof;
11
f. For interest at the legal rate; and
12
g. For all other relief as the Court may seem just and
proper.
13
14
LAW OFFICE OF MARK T. RISNER
15
16
Dated: June 3, 2015
17
18
/s/_________________________
MARK T. RISNER
Attorney for Plaintiff,
BRYAN CHRISTOPHER MOON
19
BERLINER LEGAL GROUP
20
21
22
Dated: June 3, 2014
23
/s/_________________________
MATTHEW A. BERLINER
Attorney for Plaintiff,
BRYAN CHRISTOPHER MOON
24
25
26
27
28
29
30
/ / /
__________________________________________________________________________________________________________________
CASE NO. 30-2014-00713186-CU-DF-CJC
-37-
PROOF OF SERVICE
STATE OF CALIFORNIA )
) ss.
COUNTY OF ORANGE
)
2
3
4
5
6
I am employed in the County of Orange, State of California. I

am over the age of 18 and not a party to the within action; my
business address is 1 Park Plaza, Suite 600, Irvine, CA 92614.
On this date, June 3, 2015, I served the foregoing documents
described as:
CORRECTED FIRST AMENDED COMPLAINT
Upon all interested parties in this action by placing true

copies thereof enclosed in a sealed envelope with postage fully
prepaid in the United States mail at Irvine, California
addressed as follows:
9
10
SEE ATTACHED SERVICE LIST
11
12
(BY MAIL)
I caused such envelope with postage thereon
fully prepaid, as First Class Mail, to be placed in the
United States Mail at Irvine, California. I am "readily
familiar" with the firm's practice of collection and
processing correspondence for mailing.
Under that
practice it would be deposited with U.S. postal service on
that same day with postage thereon fully prepaid at
Irvine, California in the ordinary course of business. I
am aware that on motion of the party served, service is
presumed invalid if postal cancellation date or postage
meter date is more than one day after the date of deposit
for mailing in affidavit.
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( X )
(BY ELECTRONIC SERVICE, CRC Rule 2.261) My electronic

service
address
is
Barrister33@myexcel.com
and
I
electronically served the aforementioned parties or their
counsel
at
their
respective
service
address(es):
askearly@aol.com,
abrown@daydayandbrown.com,
tmazura@euslaw.com, ges@shoffnerlawfirm.com on the date
mentioned herein at approximately ____5:00_AM/PM.
(BY PERSONAL SERVICE) I caused such envelope

delivered by hand to the office of the addressee.
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( X )
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be
(STATE) I declare under penalty of perjury under the laws

of the State of California that the above is true and
correct.
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to

Case No. 30-2014-00713186-CU-DF-CJC
PROOF OF SERVICE
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) (FEDERAL) I declare that I am employed in the office of a

member of the bar of this court at whose direction the
service was made.
Executed this date, June 3, 2015, at Irvine, California.
4
/s/
Mark T. Risner
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Case No. 30-2014-00713186-CU-DF-CJC
PROOF OF SERVICE
-2-
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SERVICE LIST
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Early M. Hawkins, In Pro Per

17011 Beach Blvd, Ste. 900
Huntington Beach, CA 92647
Phone: (949) 842-9394
FAX (949) 269-6377
E-Mail: askearly@aol.com
LAW OFFICES OF EARLY M. HAWKINS
17011 Beach Blvd, Ste. 900
Huntington Beach, CA 92647
Phone: (949) 842-9394
FAX (949) 269-6377
E-Mail: askearly@aol.com
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Alan C. Brown, Esq.

DAY, DAY & BROWN
301 W. First Street,
Tustin, CA 92780
Phone: (714)832-4811
FAX: (714) 832-4815
E-Mail: abrown@daydayandbrown.com
Terrence A. Mazura, Esq.
MAZURA LAW FIRM
414 West 4th Street, Ste. A
Santa Ana, CA 92701
Phone: (714) 550-5011
Attorneys for Defendant(s): Thuy-Duyen Thi Huynh
E-Mail: tmazura@euslaw.com
Gary E. Shoffner, Esq.
414 West 4th Street, Ste. A
Santa Ana, CA 92701
Phone: (714) 550-5011
Attorneys for Defendant(s): Thuy-Duyen Thi Huynh
E-Mail: ges@shoffnerlawfirm.com
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Case No. 30-2014-00713186-CU-DF-CJC
PROOF OF SERVICE
-3-

The Lawsuit Filed Against Thuy Huynh, Michael O&#39;Young, and Early Hawkins

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1

MARK T. RISNER, ESQ.

(SPACE BELOW FOR FILING STAMP ONLY)

MATTHEW A. BERLINER, ESQ.

Attorneys for Plaintiff, BRYAN CHRISTOPHER MOON

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA

BRYAN CHRISTOPHER MOON,

THUY-DUYEN THI HUYNH,

CASE NO. 30-2014-00713186-CUDF-CJC

Entity Form Unknown,

4. ASSAULT AGAINST DEFENDANT

AN UNLIMITED CIVIL ACTION

Here comes now Plaintiff Bryan Christopher Moon, an

individual residing in the State of California (Plaintiff or

Moon) and alleges as follows:

Moon is informed and believes and thereon alleges that

Defendant Thuy-Duyen Thi Huynh is an individual and a resident

of the State of Nevada, County of Clark.

believes and thereon alleges that Huynh sometimes goes by the

aliases Thuy Huynh and/or Thuy Li.

Moon is informed and

Moon is informed and believes and thereon alleges that

Defendant Michael C. OYoung is an individual and a resident of

the State of California, County of Orange.

and believes and thereon alleges that OYoung is an attorney

licensed to practice in the State of California.

Moon is informed and believes and thereon alleges that

Defendant, Law Offices of Michael C. OYoung & Associates is a

business entity of unknown capacity doing business in the State

of California and located in the County of Orange.

Defendants the Law Offices of Michael C. OYoung &

Associates and OYoung initially represented Huynh in the

Moon is informed and believes and thereon alleges that

Defendant Early M. Hawkins is an individual and a resident of

the State of California, County of Orange.

and believes and thereon alleges that Hawkins is an attorney

licensed to practice in the State of California.

Moon is informed and believes and thereon alleges that

Defendant, Law Offices of Early M. Hawkins is a business entity

of unknown capacity doing business in the State of California

and located in the County of Orange.

Defendants the Law Offices of Early M. Hawkins, and

Hawkins later represented Huynh in the action that forms

the basis for this Malicious Prosecution Claim for Relief

(collectively all Defendants in this matter shall be named

Moon is not aware of the true names and capacities of

defendants Does 1-25, inclusive, and therefore sues these

defendants by such fictitious names.

Moon will amend this

Complaint to show the true names and capacities of such

fictitiously-named defendants when the same have been

alleges, that each of the Doe defendants are legally

responsible in some manner to Moon for the sums of damages

Moon is informed and believes, and based thereon

Moon is informed and believes, and thereon alleges,

that at all relevant times Defendants, and each of them, were

acting as agents, servants, employees, alter egos, successors

or predecessors-in interest, or each of the other named

relationship, with knowledge and consent, either express or

implied, of the other named defendants.

Venue is proper in this venue as that the facts giving

rise to this action occurred in Orange County, California.

Moon has been analyzing investment opportunities for

arbitrage including spin-offs, mergers, bankruptcies and

The Lawsuit Filed Against Thuy Huynh, Michael O'Young, and Early Hawkins

The Lawsuit Filed Against Thuy Huynh, Michael O'Young, and Early Hawkins