Document for 12-CV-0645 - CLASSIC IMPORTS, INC vs. HUR, EUNNIE

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IN THE WAYNE COUNTY COURT OF COMMON PLEAS ‘ gay
WAYNE COUNTY, OHIO ere Gb. Ty, gma

MS IUEAY ALS 22
Classic Imports, Inc. ) CASE NO. 12-CV-0645 ,
) JUDGE WIEST .
Plaintiff ) wee >
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vs. y Plaintiff's Response to Motion
) to Dismiss
)
Eunnie Hur y
)
Defendant )

 

Now comes the Plaintiff and hereby opposes Defendant’s motion to dismiss complaint.
L INTRODUCTION

The within matter was filed with this Court on September 18, 2012, seeking monetary and
declaratory relref—with claims for interference with business, declaratory judgment, and seeking an
accounting. Attached to that complaint were certain draft proposed consulting agreements. Please
note that none of these were executed by either of the parties Certain correspondence with Ms. Hur’s
California counsel was also attached. Her California counsel had referenced a certain “executed oral
agreement.” Seeing that it is impossible to execute an oral agreement, and seeing that Ms. Hur’s
California attorney was attempting to “cherry…