Kaplan, Inc. and MG Prep, Inc. d/b/a Manhattan Prep and Manhattan GMAT, Plaintiffs.
Tracy Yun and Manhattan Enterprise Group LLC d/b/a Manhattan Elite Prep, Defendants.
Plaintiffs Kaplan, Inc. and MG Prep, Inc. d/b/a Manhattan Prep and Manhattan GMAT (collectively,
"Manhattan Prep" or "Plaintiffs"), for thie First Amended and Supplemental Complaint against
Defendants Tracy Yun ("Yun") and Manhattan Enterprise Group d/b/a Manhattan Elite Prep ("MEP"),
allege as follows, with knowledge of their own actions and upon information and belief as to the
activities of others:
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