Claim for Damages

City of Reedley
Name of Claimant
(lnjured or damaged party)

Universal Meditech Inc

Business Address and

Telephone Number 850 I Skeet
Number and Street Address
Reedley CA 93654
city state zip code
TelephoneNumber (559)653-8885

AttorneyAddress and
Telephone Number Thomas Business Law Grou ,
P.C. 17800 Castleton Street, Suite 600
Number and Street Address
city of Industry CA 91748
city state Zip code

TelephoneNumber (626) 771-1005

Where would you Iike

Z Business IX Morney
notices sent?

When did the injury or EEI AM

damage occur? >/12 / 2023 : EEI PM
Month/DayWear Day of Week Time of Day

Where did the injury or

damage occur? 50
I
Street, Reedley CA 93654
Street address, intersedion or other Iocation
How did the injury or
damage occur? Unlawful seizure b ci officials

see Attached Exhibit A

1
Names and telephone (SS9)318-61 13
1yn Hamer
eSa
numbers of witnesses
(

( )

esalyn Harper
Names of City employees
involved

PoliceAgencyand Police
Report Number Agency Report Number
Name of Poli

What action or inaction of

the City or its employeets) Wron 11 Seizure
caused your injury or
damages? Destructions of over 1000 Plzre Bred Mice without cause

Destructions of over 100 tons assets

See Attached Exhibit A

What injuries or damages

Hu Financial loss of assets
did you suffer? e

Irre arable harm in excess of $30,000,000

See attached Exhibit B

Total amount claimed $30,000,000

 Signature: Date (month/day/year) 10/11 1023
Stephen J. 'rhomas

(rype or Print name)

homas Business Law Grou ,

P.C., 17800 Castleton Street, Suite 600, Ci of lndust , CA 91748
IW
um er an treet ress tate Ip o e

Relationshipto Claimant Attorney Felephone Number: (626)771-1005

3
EXHIBIT A
 case Summary

UMI has been legally and compliantly operating and producing in Central California for 7

years from 2015 to 2022. Three years in Tulare City and more than four years in Fresno

City.

In 2021, in keeping with future requirements of regulation and development for the

manufacture of medical in vitro diagnostic devices, UMI designed a brand new factory

building of nearly 20,000 square feet near Yosemite lnternational Airport and signed a

contract with the Iocal builder for construction in April 2022. It planned to move in in

May 2023.

As to UMI's s-year Iease (2018-2023) conflids with the Iandlord during 2021 and 2022

in Fresno city, provoked court proceedings. In order to avoid further intensification of

Iegal fight, agreement was finally reached, UMl moved 8 months advance, and
the an in

the two parties would not pursue the responsibility for breach of contract. Otherwise,

the Iandlord will have to apply to the court for eviction proceedings.

Accordingly, UMI was forced to rent a temporary warehouse. Aer an urgent search, UM1

finally rented 850 Reedley for half a year, completed the

I

St in and move between

and 20th, 2022.

1
November 5th
Almost immediately, the Reedley municipal management department and the urban

management personnel continued to check and harass. From March onwards, the

Temporarywarehouse was completely sealed up. At the same time, Local officers

reported to the federal FDA, CDC, state public health and medical device management

departments, and county public health management departments.As a result, these

departments have repeatedly carried out onerous inspections and investigations on the

temporary warehouse.

Between April 15th and 20th, the Reedley urban management department wrongfully

destroyed more than 1,000 precious purebred experimental mice without any notice or

cause. After the destruction, they officially notified UMI on April 21. This destrudion

went beyond the authority granted by the warrant

The Fresno County Public Health Department applied to the court for a warrant on June

26 on the grounds that the fabricated 850 temporary warehouse contained a Iarge

number of viruses and baderia that seriously endangered public health. This was a Iie.

On one day's notice, on July 3, aII biological assets stored in refrigerators and freezers

were destroyed from July 5th to 8th, and company representatives were not allowed to

observe and collect evidence on site. Prior to this, the UMI company had sent emails to

inform aII executivesof the department many times, and filed an appeal with the Iocal

municipal government, trying its best to inform them that the value of these assets

planned to be destroyed is extremely huge, and not only have no lnfection agents that
endangers public health, but also many of these biological assets are non-reproducible

biological assets for the detection of numerous infectious diseases. There is no reason

or basis for the local government to action. The seizure and destrudion went beyond the

authority granted by the warrants.

lt appears that the relevant departments of the Iocal city government and county

government will further destroy other biochemical assets stored at room temperature,

and up to now, company personnel have not been allowed to enter.

Although the new factory building expeded to be moved in May has been built, the Iocal

municipal inspection department has delayed the approval because UMI/PBI will be the

tenant. The improper seizure and unauthorized Iaw enforcement activities, as well as the

resulting Iocal public media, which published many false and distorted reports and

information, Ied to the inability to carry out the relocation of the new factory building.

The Iandlord gave formal notice of unilateral cancellation of the Iease agreement in mid-

August.

The economic Ioss to the company appears to exceed $50,000,000.00.

EXHIBIT B
Evaluation of biological assets at 850 I

st temporary warehouse

The core biotechnology materials and valuable reagents stored in the 850 ST temporary
warehouse are divided into the following 10 categories. The specific description and valuation are
as follows:

1,
Estimate of more than 1,000 purebred Balb/c mice.
On the website provided by American Laboratory Animals, the price of a mouse about three
months oId is about $50 plus shipping, and should be at Ieast about $60.
According to our statistics at the time, there should be about 1,200 mice. So the total value should
be 1200*60=72000 USO.

2. Estimation of dozens of purebred experimental mice that are particularly resistant to tumor cells.
Such pure-line mice with anti-tumor propedies are simply not available on the market. lt is a
precious mouse obtained after several years of screening and breeding in the Iaboratory, and it
plays a very important role in anti-tumor research. You should find a professional evaluation
agency to demonstrate its value. Here, tentatively based on the potential price of this project, the
entire group is valued at $600,000.

3,An estimate of more than 3,000 monoclonal antibody frozen cell Iines.
ln addition to the development of UMI, many of these precious monoclonal antibody cells are the
crystallization of more than ten years of research and development results from six companies
including NIM, IDI, Guangdi, Amity, Betray Bio, and Cybers Bio.. Cell Iines must be stored in a Iow-
temperature refrigerator below -80 degrees Celsius. Each strain of cells is stored in a sealed
cryopreservation tube, and 100 cryopreservation tubes are stored in a cryopreservation box.
According to the storage list provided by UMI, there should be about 80 boxes of frozen storage
boxes in the seed cells, that is, 8,000 cell Iines. Each cell Iine should have 2-3 copies, so it is
conservatively estimated that there should be 2000-3000 cell Iines. ln addition, there are 500-600
cell Iines for production, which have much more cells than the seed cell Iines, and are placed in
Iarger closed test tubes for the production of mouse ascites.
The aforementioned seed cell Iines and production cell Iines are hardly available in the public market.
Even if it is bought and transferred, it will be a sky-high price. At least it should be more than
100,000 US dollars per cell Iine. Therefore, how to evaluate the value really needs to find a
professional evaluation company to provide a template acceptable to the coud. Even if we give the
most conservative valuation here, the seed cell Iine is calculated at 10,000 US dollars, and the
production cell Iine is calculated at 50,000 US dollars, the overall value will exceed 30 million US
dollars.
4, Valuation of more than 300 recombinant genetically engineered strains.
The storage conditions of the recombinant genetically engineered strains are similar to those of
the above monoclonal antibody cell strains. It must be stored at ultra-low temperature.
They are the core technical materials for the expression and production of various
immunodiagnostic antigens (HIV HCV HBV Syphilis Malaria etc) and genetic engineering
pharmaceuticals (recombinant insulin, recombinant EPO, recombinant reteplase, recombinant
interferon etc).
The valuation of this pad of the core technical materials of engineering bacteria. It is also more
difficult to make, because there is no public market price, and it is the core technical secret for
related medical testing and pharmaceutical companies. However, professional appraisal
companies must have more practical appraisal plans.
We are making the most conservative estimate here. Even if a class of engineered strains costs
US$100,000, the overall value should be more than US$10 million.

5,Hundreds of kinds of monoclonal antibody ascites and purified antibodies, about 500MIx600
bottIes=300000ML. Based on an average of 3 mg per mI, the overall estimate is 900,000 mg.
Based on the minimum market price of 10 US dollars per mg, the total value should be more than 9
million US dollars.

6,Goat and cattle anti-mouse antibody serum and purified anti-antibody 1000MLx1 50 bottles =
150000ML, calculated on the basis of 2 mg effective anti-antibody per mI, there should be 300,000
mg. The market price per mg is calculated at a minimum of 3 US dollars, and the total value should
be 900,000 US dollars.

7, lnclusion bodies expressed by recombinant genetically engineered bacteria and purified antigen
500MLx800 bottIes=500000ML The market price of this part varies greatly. Among them, the
effective antigen content also varies greatly according to the situation of each production
expression. Even according to the minimum zmg/ml, there are million mg. The market value per
1

mg is at least US$10, so the total value must exceed US$10 million.

8, Hundreds of gold-labeled monoclonal antibody antigens and enzyme-labeled monoclonal

antibody antigens. The quantity and type of this pad are still being checked. An estimate is due
Iater this week. The estimated valuation is around US$1 million.

9, Due to the Iarge variety of various expensive biochemical and immunological reagents, it will
take several weeks to re-evaluate according to the specific quantity and current price. For the time
being, it will be calculated at 2 million US dollars. What needs to be pointed out is that these
reagents are not just stored in the refrigerator, there are quite a few at room temperature, and we
don't know if aII of them have been destroyed.

10, Various detection standards. Including international standards and standards of various
countries. This part of the data is also being reorganized. Although the quantity is not as many as
the first nine categories, as Iegal standard products, the market price is extremely expensive. The
valuation is tentatively set at US$5O0,000.

The extent of the actual damage cannot be ascertained accurately at this time because UMI has
been Iocked out of the warehouse.