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Williams v. Wells Fargo Bank CA2/7
The Williams plaintiffs filed this action on April 27, 2020. After the trial court sustained the Wells Fargo defendants’ demurrer to the first amended complaint with leave to amend, the Williams plaintiffs filed the operative second amended complaint, alleging causes of action for (1) breach of contract, (2) declaratory relief, (3) conspiracy to convert and embezzle funds, (4) negligence, (5) breach of the covenant of good faith and fair dealing, (6) financial elder abuse, and (7) violation of the UCL. The second amended complaint omitted several material factual allegations from the first amended complaint; we consider these allegations under the sham pleading doctrine.
The second amended complaint relies on the same allegations for all counts. Williams was an 84-year-old physician who operated a medical practice in California through the Corporation, which he wholly owned. As of April 12, 2014 the Corporation operated two medical clinics in Los Angeles County.

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