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RE: LoadKarma Inc.
AI verdict
legal-george
urgent
· confidence: high
· by backfill-gmail
“George Burns: RE: LoadKarma Inc.”
OK, I was about to send you my draft, let me see if this influences it.
George S. Burns
Burns & Moss
620 Newport Center Drive
Suite 600
Newport Beach, CA 92660
Tel: (949) 263-6777
From: Kelvin Yan <[email protected]>
Sent: Wednesday, November 12, 2025 6:58 PM
To: George Burns <[email protected]>; Victoria Moss <[email protected]>
Subject: Re: LoadKarma Inc.
Text message from Vivek and we are still discussing between us 2 best exit options.
We have our partners weekly meetings tomorrow and I will be firm with my stands
I also spoke to SBA banker and he is looking for some options to remove Vivek personal guarantee.
[image]
Kelvin
On Nov 12, 2025, at 6:13 PM, George Burns <[email protected]<mailto:[email protected]>> wrote:
Pocket dial I have something cued up. Gimmie an hour.
George
On Nov 12, 2025, at 6:07 PM, Kelvin Yan <[email protected]<mailto:[email protected]>> wrote:
Were you suppose to add an attachment? It is empty email
Kelvin
On Nov 12, 2025, at 2:34 PM, George Burns <[email protected]<mailto:[email protected]>> wrote:
George S. Burns
Burns & Moss
620 Newport Center Drive
Suite 600
Newport Beach, CA 92660
Tel: (949) 263-6777
From: Kelvin Yan <[email protected]<mailto:[email protected]>>
Sent: Monday, November 10, 2025 6:32 PM
To: George Burns <[email protected]<mailto:[email protected]>>
Cc: Victoria Moss <[email protected]<mailto:[email protected]>>
Subject: Re: LoadKarma Inc.
I will be in your office 11am tomorrow thanks. Vivek will most likely join on video call
From: George Burns <[email protected]<mailto:[email protected]>>
Date: Monday, November 10, 2025 at 2:53 PM
To: Kelvin Yan <[email protected]<mailto:[email protected]>>
Cc: Victoria Moss <[email protected]<mailto:[email protected]>>
Subject: RE: LoadKarma Inc.
Great. A meeting here might be more effective than a call, but whatever works on your schedule. Let me know.
George S. Burns
Burns & Moss
620 Newport Center Drive
Suite 600
Newport Beach, CA 92660
Tel: (949) 263-6777
From: Kelvin Yan <[email protected]<mailto:[email protected]>>
Sent: Monday, November 10, 2025 2:00 PM
To: George Burns <[email protected]<mailto:[email protected]>>
Cc: Victoria Moss <[email protected]<mailto:[email protected]>>
Subject: Re: LoadKarma Inc.
No problem I’ll talk to Vivek for 11am time
Also Zams holds commission sheets and those kickback reports which I want
Kelvin
On Nov 10, 2025, at 1:54 PM, George Burns <[email protected]<mailto:[email protected]>> wrote:
My day is not slowing down, and I still need to finalize a big filing due today. Let’s talk tomorrow at 11 or some other time before 3 that you’ll suggest, and if we can do it with Vivek, that might help.
George S. Burns
Burns & Moss
620 Newport Center Drive
Suite 600
Newport Beach, CA 92660
Tel: (949) 263-6777
From: Kelvin Yan <[email protected]<mailto:[email protected]>>
Sent: Monday, November 10, 2025 1:33 PM
To: George Burns <[email protected]<mailto:[email protected]>>; Victoria Moss <[email protected]<mailto:[email protected]>>
Subject: Re: LoadKarma Inc.
George,
I think first is to remove Zams Financials as a vendor of probable cause of fraud. Please email Sapna of the complaint and official remove their services. Anthony and I can handle the bookkeeping for now. Make sure she knows her and her employees will have access restraint from quickbooks, TMS, Bank of America etc. All current data(AP/AR excel sheets etc) must be provided to Kelvin.
The brothers do not need to agree to this as they are a vendor and getting fired.
<image001.png>
Kelvin
From: George Burns <[email protected]<mailto:[email protected]>>
Date: Monday, November 10, 2025 at 7:28 AM
To: Kelvin Yan <[email protected]<mailto:[email protected]>>, Victoria Moss <[email protected]<mailto:[email protected]>>
Subject: RE: LoadKarma Inc.
Kelvin:
I read this and am available this afternoon to discuss if you like. I will of course make any demand you instruct, but my overall thoughts are that the Singhs will not agree to most or any of this, certainly not immediately. So, if these really are non-negotiable demands, then you should just file suit. But before doing so, we should have a clear eyed discussion to be sure that you understand and are prepared to fund the likely significant costs required to file and serve the lawsuit, seek an immediate injunction, etc. Note that, if the Singhs are in fact out of the country until November 25, as they claim, then they could not be personally served with a summons and complaint. Therefore, while I can file the complaint before then, the court would be unlikely to issue an injunction if they have not been served with process.
Also, to what extent can you immediately accomplish any of these demands by yourself? For instance, you list several items concerning freezing their access to the bank account, credit cards, etc. Have you determined whether you can just take unilateral action, including to open a new account(s) to which they do not have access, transfer all company funds into it, and make it the new auto-pay for bills as needed? As far as Zams reporting to you, etc., do you even need Zams financials, or could you just cause the company to hire new bookkeepers?
George
George S. Burns
Burns & Moss
620 Newport Center Drive
Suite 600
Newport Beach, CA 92660
Tel: (949) 263-6777
From: Kelvin Yan <[email protected]<mailto:[email protected]>>
Sent: Sunday, November 9, 2025 11:22 PM
To: George Burns <[email protected]<mailto:[email protected]>>; Victoria Moss <[email protected]<mailto:[email protected]>>
Subject: Re: LoadKarma Inc.
George,
I would like to demand the following immediate operation actions for them to agree within 24hr to accept and provide info on some demand items. These critical operation daily tasks need to be address asap.
Rest of the demands will work with you till end of the week.
-Agree to remove Sapna Bank of America cash pro online admin access and approval access for outgoing payments. All approvals of outgoing payments must be approved by Kelvin with details supplied by Zams financials people to me or assignee(Anthony) for checks and balance.
-Zams financials people including Sapna to report directly to Kelvin or assignee.
-Kelvin has full discretion to make decisions on payments and accounts receivable collections, credit cards access, quickbooks access, bank of American online access, payroll or any other areas that Kelvin think is best for Load Karma.
-Karam to disclose to Kelvin kickbacks excel sheet including MSI and all companies involved. (Need to know what other liabilities are out there)
-Jaspreet, Karam, Zams to fully disclose and cooperate with Kelvin or assignee any request made including sales, operations, financials
-Full admin access to Load Karma Innovations LTD bank account(s) in India and fully cooperate/disclose request from Kelvin on India operation
-Disclose their nature of business in India for Load Karma. (Some language to reframe them from recruiting Load Karma India staff to their suspected new companies. They will probably use someone else names not theirs).
- Provide detail travel report with outcomes and expense receipts after any trips to Kelvin.
-Freeze Jaspreet salary until further notice (this was discuss among the partners and agree but they wanted to freeze mine too)
-non negligible terms
These immediate demands does not remove my option from filing the suit or agree to their BS extension.
Kelvin
From: Jaspreet Singh <[email protected]<mailto:[email protected]>>
Date: Sunday, November 9, 2025 at 7:53 PM
To: George Burns <[email protected]<mailto:[email protected]>>
Cc: Karam Singh <[email protected]<mailto:[email protected]>>, Kelvin Yan <[email protected]<mailto:[email protected]>>, Victoria Moss <[email protected]<mailto:[email protected]>>
Subject: Re: LoadKarma Inc.
Hi Mr Burns,
We have received your letter dated November 8, 2025. I and Karam are travelling out of country and will not be back until November 25th, 2025. However, we are committed to resolving all issues without litigation.
we respectfully request that no lawsuit is filed until after January 15th, 2026, to allow sufficient time to resolve all issues and or retain a counsel.
This communication is made solely for scheduling and discussion purposes and does not constitute an admission of liability or wrongdoing, nor does it waive any rights, objections or defenses.
We look forward to working with Kelvin to negotiate a resolution. Please confirm the requested extension.
We will look forward to your response and thank you for your understanding.
Regards,
Jaspreet Singh
Get Outlook for Mac<https://aka.ms/GetOutlookForMac>
From: George Burns <[email protected]<mailto:[email protected]>>
Date: Saturday, November 8, 2025 at 3:55 AM
To: [email protected]<mailto:[email protected]> <[email protected]<mailto:[email protected]>>
Cc: Jaspreet Singh <[email protected]<mailto:[email protected]>>, Karam Singh <[email protected]<mailto:[email protected]>>, Kelvin Yan <[email protected]<mailto:[email protected]>>, Victoria Moss <[email protected]<mailto:[email protected]>>
Subject: LoadKarma Inc.
Mr. Singh and Mr. Singh:
I represent Kelvin Yan. On his behalf, I intend to file a lawsuit, a draft of which is attached. It describes how you both have violated your obligations to Load Karma, Inc., including by operating a competing business, Load Konnect, Inc., which skimmed profits from clients due to Load Karma, by taking a secret interest in Abacus Transport, LLC, which overcharged Load Karma, and by bribing a representative of a key client of Load Karma to look the other way while you overcharged the client, causing that client to threaten to sue the Company for over $500,000. The lawsuit will also name Karamjeet Singh’s wife, who rigged the books of Load Karma, to prevent Mr. Yan from discovering your fraud.
The lawsuit demands an injunction preventing you from funneling Load Karma clients to Load Konnect, and related relief. You are on notice that this relief will be sought in the immediately future, and demand is made that you cease and desist from any such activities immediately.
Lawsuits are exceedingly unpleasant, and I write now to offer an opportunity to avoid litigation, as follows. There does not appear to be any scenario in which my client and you work together in the future, and your liabilities to the company cannot seriously be disputed. At the same time, Load Karma and Haven have assets, including Load Karma receivables that should be closed out, and it has debts that must be paid. Therefore, the parties should work together to collect anything that Load Karma is owed, resolve claims against it that could reach the shareholders, compensate Kelvin for monies that you have wrongfully taken, and then shut down the business and file a final tax return. So, if you are interested in cutting out your nonsense, now, and instead working together with Kelvin towards a negotiated resolution, please so advise. If not, I will file this lawsuit next week and seek appropriate interim relief against both of you.
Finally, while I have copied Ms. Kapoor based on her statements to me that she represents you, my client will and does object to her being involved in this dispute, due to her actual conflict of interest as counsel for Load Karma. Ms. Kapoor, please respond with your confirmation that you will not be involved in any way, including that you will not seek to advise your clients, and will not disclose to them any information or documents you may have obtained in your engagement with Load Karma.
George
George S. Burns
Burns & Moss
620 Newport Center Drive
Suite 600
Newport Beach, CA 92660
Tel: (949) 263-6777