11. RULE OF LAW FOUNDATION III, INC. Plaintiff, -against- LI-Meng Yan Defendant. July 27, 2020.

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
RULE OF LAW FOUNDATION III, INC.
Plaintiff,
-against-
LI-Meng Yan
Defendant.
Index No.
To the above-named Defendant:
YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve
a copy of your answer, or, if the complaint is not served with this summons, to serve a notice of
appearance, on the plaintiff’s attorney(s) within 20 days after the service of this summons,
exclusive of the day of service (or within 30 days after the service is complete if this summons is
not personally delivered to you within the State of New York); and in case of your failure to appear
or answer, judgment will be taken against you by default for the relief demanded in the complaint.
Dated: New York, New York
July 27, 2021
LAWALL & MITCHELL, LLC
Attorneys for Plaintiff
BY: Aaron A. Mitchell
Aaron A. Mitchell, Esquire
99 Church Street, 4th Floor
White Plains, NY 10601
(973) 285-3280
aaron@lmesq.com
TO:
Defendant via Personal Service
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
RULE OF LAW FOUNDATION III, INC.
Plaintiff,
-against-
LI-MENG YAN.
Defendants,
Index No. /2021
COMPLAINT
Plaintiff Rule of Law III, Inc. (“ROL” or “Plaintiff”) for its complaint and action for money
damages against defendant Li-Meng Yan (“Yan” or “Defendant”), alleges as follows:
NATURE OF ACTION
1.
Plaintiff brings this action seeking redress for Defendant Yan’s fraudulent
misrepresentations, conversion, breach of contract, and breach of the covenant of good faith and
fair dealing.
PARTIES
2.
Plaintiff is a § 501 (c)(3) charitable not-for-profit domiciled at 162 E. 64th Street,
New York, New York.
3.
Defendant Yan is foreign citizen residing at, upon information and belief, 1 Broad
Street, Unit 17E, Stamford, Connecticut.
JURISDICTION & VENUE
4.
Jurisdiction is proper pursuant as the Agreement contains a provision identifying
New York State as the proper jurisdiction for any dispute between the parties.
5.
Further, ROL is domiciled in the State of New York.
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FACTUAL BACKGROUND
6.
On or about, July 31, 2020, ROL and Yan entered into a grant letter agreement (the
“Agreement”), whereby ROL was to pay $10,000.00 a month in order to help support Yan in
furtherance what was believed by ROL to be the shared mission of exposing corruption within the
Chinese Communist Party (“CCP”) and throughout the world.
7.
In addition to the $10,000.00 per month payment, ROL also paid the sum of
$8,800.00 to Yan’s landlord as a security deposit to make sure that Yan had housing.
8.
Pursuant to the Agreement, the security deposit was and remained the property of
ROL and was to be returned to ROL at the end of Yan’s lease on her Connecticut apartment.
9.
Prior to entering into the Agreement, Yan provided certain information to ROL in
order to induce ROL into entering into the Agreement.
10.
On or about July 12, 2021, Yan publicly turned on ROL, referring to the group, its
donors, and fellow supporters as a “Cult”.
11.
Yan’s statements against ROL were a clear breach of both the terms and spirit of
the Agreement.
12.
Immediately upon hearing of Yan’s denigrating statements, ROL terminated the
Agreement.
13.
Upon information, Yan has breached her lease by failing to pay rent and by
abandoning the apartment resulting in the likely forfeiture of the security deposit which is the
property of ROL.
14.
Since ROL became aware of Yan’s surprise turn, information has come out that
Yan had been conspiring with Wang Dinggang, since February to undermine the ROL and the
Whistleblower Movement which shares the ROL’s common goals of exposing corruption within
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the CCP and supporting the brave Whistleblowers who selflessly sacrifice to shine a light on
corruption in China and throughout the world.
15.
Wang Dinggang has publicly bragged on his internet broadcasts about this
conspiracy while attempting to undermine and divide the Whistleblower Movement.
AS AND FOR A FIRST CAUSE OF ACTION
Breach of Contract
16.
Plaintiff incorporates by reference paragraphs 1 through 14 as if fully set forth
herein.
17.
Yan had an obligation under the Agreement to act in accordance with the mission
statement and guiding principles of ROL
18.
In or about February 2021, Yan began to ignore her contractual obligations and act
in contravention of the terms of the Agreement, culminating in her public betrayal of ROL in mid-
July 2021.
19.
Yan’s conduct has damaged ROL in the sum of $40,000.00.
20.
Additionally, pursuant to the Agreement, Yan was to pay rent at her apartment and
comply with the terms of her lease in order ensure that the security deposit in the sum of $8,800.00
was returned to ROL
21.
Yan’s failure to comply with the terms of her lease has resulted in ROL suffering
damages in the sum of $8,800.00.
22.
Yan’s conduct constitutes a breach of the Agreement.
23.
As a direct and proximate cause of Yan’s breaches of the Agreement, ROL has been
damaged in the sum of $48,800.00.
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AS AND FOR A SECOND CAUSE OF ACTION
Breach of the Covenant of Good Faith and Fair Dealing
24.
Plaintiff incorporates by reference paragraphs 1 through 23 as if fully set forth
herein
25.
Every agreement contains an implied covenant of good faith and fair dealing,
including the Agreement at issue in this matter.
26.
Yan’s co-conspirator, Wang Dinggang has openly acknowledged that he and Yan
had been in league since February 2021 in their scheme to cause ROL and its brothers and sisters
in the Whistleblower Movement to suffer derision and embarrassment.
27.
Upon information and belief, Yan waited several months in order to continue to
obtain her monthly payment from ROL, all while plotting to destroy its reputation.
28.
As a result of Yan’s conduct, ROL has suffered damages, including $40,000.00 in
payments to Yan after she violated the covenant of good faith and fair dealing.
AS AND FOR A THIRD CAUSE OF ACTION
Fraud
29.
Plaintiff incorporates by reference paragraphs 1 through 28 as if fully set forth
herein.
30.
Upon information and belief, in or about February 2021, Yan began to conspire
against ROL and the Whistleblower Movement.
31.
However, in February through May of 2021, Yan eagerly accepted the ROL
monthly payment while also plotting to destroy it from the inside.
32.
ROL diligently made the monthly payments to Yan, not knowing that she was
working against the ROL and its core values.
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33.
Had ROL been aware of Yan’s plans, ROL would have ceased to make the
payments to Yan, as her conduct was a clear violation of the Agreement.
34.
In order to deceive ROL in order to continue to receive her monthly payment, Yan
pretended to support the ROL while conspiring against it.
35.
As direct and proximate result of Yan’s fraudulent conduct, Plaintiff has been
damaged in an amount to be determined at trial, but not less than $40,000.00.
AS AND FOR A FOURTH CAUSE OF ACTION
Conversion
36.
Plaintiff incorporates by reference paragraphs 1 through 35 as if fully set forth
herein.
37.
Yan, by failing to make her rent payments caused the forfeiture of her security
deposit which had been paid by ROL.
38.
Pursuant to the Agreement, the security deposit was the property of ROL and was
to be returned to ROL at the end of the lease.
39.
By causing the forfeiture of the security deposit in order to cover the cost of her
own unpaid rent, Yan has permanently deprived ROL of the security deposit funds in the sum of
$8,800.00.
40.
As direct and proximate result of Yan’s fraudulent conduct, Plaintiff has been
damaged in an amount to be determined at trial, but not less than $8,800.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff requests entry of Judgment in its favor and against Defendant
Li-Meng Yan as follows:
A. That judgment be issued in favor of Plaintiff and against Defendant Yan in the sum of
$48,800.00 on Plaintiff’s first cause of action for breach of contract;
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B. That judgment be issued in favor of Plaintiff and against Defendant Yan in the sum of
$48,800.00 on Plaintiff’s second cause of action for breach of the covenant of good
faith and fair dealing;
C. That judgment be issued in favor of Plaintiff and against Defendant Yan in the sum of
$48,800.00 on Plaintiff’s third cause of action for fraud;
D. That judgment be entered in favor of Plaintiff and against Defendant Yan in the sum
$8,800.00 Plaintiff’s fourth cause of action for conversion of ROL’s funds.
E. Such other relief as the Court deems necessary and proper.
Dated: July 27, 2021
New York, New York
LAWALL & MITCHELL, LLC
Attorneys for Plaintiff
Aaron A. Mitchell
_
By: Aaron A. Mitchell, Esq.
99 Church Street, 4th Floor
White Plains, NY 10601
(973) 285-3280
aaron@lmesq.com
FILED: NEW YORK COUNTY CLERK 07/27/2021 12:50 AM
INDEX NO. 654602/2021
NYSCEF DOC. NO. 1
RECEIVED NYSCEF: 07/27/2021
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