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1 Parag L. Amin (SBN 281133) % 2 LAW OFFICE OF PARAG L. AMIN, P.C. A 8 of Los Anaabs

633 W. 5th St. Suite 26003 Los Angeles, CA 90071 1 O

T: (213)293-7881 gum-In, eolcedclark4 F: (213) 986-3563 3, _g‘r§"I,,_.:‘-.v1|' Dom

Email: parag@lawpla.com ~56 Attorney for Plaintiff, Craig Blair 1

7 .

SUPERIOR COURT OFJTHE STATE OF CALIFORNIA89 COUNTY LOS ANGELES

10 WEST DISTRICTI,1 Craig Blair 1 CASE NO: 3 C 1 2 8 1 9 3

Plaintiff,12 vs. COMPLAINT FOR: ~

13 Lauren Mathers White, an individual; Susan1 1. BREACH OF1 4 Hannaford, an individual; Nonna Hannafordl, CONTRACT;

an individual; Anastasia Lee, an individual,"15 Tyrone Jackson, an individual; Palazzo 1 2. BREACH OF COVENANT OF

Beverly Hills, LLC, a California limited 1 GOOD FAITH AND FAIR16 liability company; Zenith Entertainment, LLC, DEALING;

a California limited liability company, and 117 DOES 1 to 100, inclusive, 3. FRAUD;

18 Defendants. 4. VIOLATION OF PENAL CODE19 1 SECTION 496;

120 5. NEGLIGENT2 I MISREPRESENTATION;

22 6. NEGLIGENCE;23 7. UNFAIR BUSINESS PRACTICES

5' IN VIOLATION OF BUSINESS &24 PROFESSIONS CODE 17200 ET25 CASE MANAGEMENT CONFERENCE SEQ-3 I

26 8. MISLEADING ADVERTISING INDate 1 VIOLATION OF BUSINESS &

27 N E r 1) 1 PROFESSIONS CODE 17500 ETancy Newman by 1‘ 1 SEQ.

,i;;;g'; 28 1 [DEMAND FOR A JURY TRIAL]13:, 11;;:r3 1 ~ 1 -.:§;;. COMPLAINTI"JI"J 1

11 11

SWE>'0.”o¢1o7)3’ EH38’3607102017 ;4:;+SQALV 10.3

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1 ,2 Plaintiff Craig Blair DBA Capitan Eiiergy (“Plaintiff’ or “Blair”), a citizen of the State of

3 New Mexico, brings this action against Defejiiidants seekingjustice for Defendants numerous

4 misrepresentations to Blair in relation to hislrl ntal of a large mansion in Beverly Hills for an

5 upscale special event. Ultimately, Defendarjilifailed not only to deliver on their numerous

6 representations ofwhat services they would! lrovide for the money they solicited and accepted

7 from Blair, but also the rental was a “Fyre Flestival” style failure with accommodations that were

8 nothing near what they represented. Ultimate?y, Defendants left Blair and his guests stranded and

9 left Blair with damages totaling $295,784.57.

10 JURISDI(l'llION AND VENUE

ll 1. This Court has subject matter? jurisdiction over the matter pursuant to California

12 Civil Code sections 1780, 1781 along with tihfe California Constitution Article VI, Section 10.

13 2. This Court has personal jurisiction over Defendants pursuant to California Code

14 ofCivil Procedure section 410.10.

15 3. Venue is proper in the Superidr Court of the County of Los Angeles pursuant to

16 California Code of Civil Procedure sectionsl 395 and 395.5.

17 4. All actions relevant in this took place in Los Angeles County, CA.

18 5. The value of this case exceeds? $25,000.

19 i’lARTIES20 6. Plaintiff Craig Blair (“Plaintif:f” or “Blair”) is an individual who resides in New

21 Mexico but the subject property is located lthe County of Los Angeles.

22 7. Defendant Lauren Mathers Wliite (“White”) is an individual, who claimed to

23 represent the Beverly Hills Palazzo and engaged in business dealings in the County ofLos

24 Angeles regarding the subject property. §

25 8. Defendant Susan Hannaford=,(‘i"Hannaford”) is an individual, who, on information

26 and belief, is the recorded owner of the Bevl;ei‘ly Hills Palazzo and engaged in dealings with Blair

27 in the County of Los Angeles. l

28 9. Defendant Norma Hannaford i|(hereinafter, “Parry”) is an individual, who, on

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1 E1 information and belief, is the recorded ownerlof the Beverly Hills Palazzo and engaged in

2 dealings with Blair in the County ofLos Anlg‘eles. On information and belief, Norma Hannaford

3 may also go by the names Norma Parry andlNorma Perry. 6i I4 10. On information and belief, defendant Anastasia Lee (“Lee”) is an individual, who,

5 for all times relevant, helped operate the Beiv rly Hills Palazzo and engaged in dealings with Blair

6 in the County of Los Angeles.

7 11. On information and belief, dcte zendant Tyrone Jackson (“Jackson”) is an individual,

8 who, for all times relevant, helped operate thv Beverly Hills Palazzo and engaged in dealings with

9 Blair in the County of Los Angeles. ll

10 12. Beverly Hills Palazzo, LLC C‘ alazzo LLC”), is a California limited liability1

1 1 company that, on information and belief, claims to own and/or operates as Beverly Hills Palazzo

12 with the other Defendants. ll

13 l3. Zenith Entertainment, LLC (;“fenith”), is a California limited liability company

14 that, on information and belief, claims to own and/or operates as Beverly Hills Palazzo with the' l

15 other Defendants. E

16 14. The true names and capacitieslof the defendants named herein as DOES 1 to 100,

17 inclusive, are unknown to Plaintiff who, therefore, sues said defendants by such ctitious names.

18 Plaintiffwill amend this Complaint to allege :the true names and capacities of such DOES as they

19 are ascertained. Upon information and belie;f,£ each of the ctitiously named defendants herein isl 1

20 responsible in some manner for occurrences zllilleged in this Complaint and Plaintiffs injuries

21 were proximately caused by such defendants" acts.

22 15. Plaintiff is informed, believesl and on that basis alleges that all Defendants wereit l

23 co-conspirators, agents, alter-egos, licensee=s,land/or employees of each other. In committing the

24 acts described below, each Defendant was acling within the course and scope of such conspiracy,I E

25 agency, license, and/or employment, and the knowledge, consent, and in utherance of the

26 other Defendants. 3

27 16. The actions, representations,;a:nd other conduct alleged herein ofeach of the

3 28 named Defendants were and are the actionsl fepresentations, and conduct of the other named‘~5f:..’ l 2M .3..j;;. CR»/IPLAINTIL.'I.,J L J

aL l

— ‘ 1 1 1 0 0 1 Defendants, and each of them is bound therEelTy as having done, made, and/or committed the same

2 directly. At all times mentioned herein, Defendants’ conduct is and was the action, representation,

3 and conduct ofeach and all other such Defenidants, and each such Defendant is and was to be

4 obligated, responsible, held liable, and chargéd thereby.

5 17. On information and belief, eT<‘;h of the Defendants proted or benetted in some

6 manner from obtaining and using Plaintiffs %oods and services without compensating Plaintiff

7 for them. \

8 GENERAI1. ALLEGATIONS

9 18. Defendants regularly adverti:sé{ a rental property located at 13200 Mulholland Dr.

10 Beverly Hills, CA 90210, which they comm:o'nly refer to as “the Palazzo” on advertising materials

11 (hereafter, the “Property”), as a high-end margision that is “perfect for hosting large scale” parties.

12 19. Defendants advertise that their l’roperty has 10 bedrooms and 9 bathrooms and

13 falsely boast on an advertising website that New York Times said the Property was, “One of

14 the best houses in Beverly Hills with the behtlviews.”

15 20. In or around May 2016, Blai%r’1is assistant located the Palazzo through an intemet

16 search as a potential venue because Blair warlted to rent a property in or around Los Angeles for

17 Califomia’s world-famous Breeder’s Cup, which is an annual horse race of thoroughbred race

18 horses. ;

19 21. Blair was looking for a properity that had approximately 10 bedrooms and 10

20 bathrooms for himself and his numerous gupsts and business associates who were going to be

21 traveling from around the United States for hl+e event.

22 22. Blair, through his assistant, rlegotiated the accommodations with White, who was

23 informed that the event was to be no-expensel-spared type event.

24 23. White arranged the accommhdations for the 8-day stay by Blair and his guests.

25 Blair made it clear to White that he wanted exceptional event with no expense spared. The

26 event was to include a concierge, butler, eshly stocked kitchen with snacks and high-end

27 alcohol, and catered gourmet meals. White hzitppily obliged every request with additional fees to

28 extract tens of thousands of additional dolla from Blair.

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1 11 24. For example, Defendants charged Blair $60,000 to cater food for 10 people for 8

2 ) days from November 2, 2016 to November 0, 2016. That was in addition to the $87,600 to stay

3 ‘ at the Property for 8 nights. }

4 25. However, when Blair and his guests arrived on November 2, 2016, Defendants

5 refused their early check-in time of 12 p.m.ErIrl1stead, Defendants forced Blair and his out-of-town

6 ; guests to wait for over 8 hours while Defendants claimed they were preparing the Property for

7 Blair and his guests’ arrival. ‘ a

8 ‘ 26. When Blair and his guests were nally allowed into the Property 8.5 hours later at_ . . .1" .9 around 8.30 p.m., Blair realized the Property as not what the Defendants had advertised or what

10 1 he had paid for. : ‘

ll 27. The Property had only 5 bedrooms and 5.5 bathrooms.

12 28. For the high-end catered meals that White had solicited and accepted $60,000 to

13 ! provide, the only meal Defendants provided \|L'as pizzas from California Pizza Kitchen (“CPK”).

14 29. There were dirty brown rags in the showers.

15 30. The beds were stained and had: no bed sheets or pillow cases.

16 E 31. There was trash stuffed into alfmost every drawer, cabinet, or open closet that was

17 ! available in the Property. The Property lookgecii more like a scene from the television show

18 “Hoarders” than the beautiful estate that Defeindants had advertised.

19 32. Defendants failed to stock the kitchen with the $30,000 of alcohol and snacks for

20 I which White had solicited and charged Blair!‘

21 1 33. Thereafter, Blair asked White to provide the home that she and the Defendants had

22 1 advertised and that Blair had paid to receive}. :1-Iowever, White and the other Defendants reised.

23 So, Plaintiff had to relocate his guests and apcifzommodate them at the Peninsula Beverly Hills

24 1 Hotel, which cost Blair $148,184.57. 3 125 l FIRST OF ACTION26 ‘ (Breach of Contralft Against All Defendants)

27 34. Blair re-alleges and incorporaties all allegations in the paragraphs 1 through 33 as if

28 I fully set forth herein.

. Cjoilx/IPLAINT

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1 1 35. The contract for property lease is attached hereto as Exhibit 1 (the “Rental

2 i Agreement”). 1 ‘, I

3 36. Blair and Defendants also entered into agreements for Defendants to provide a

4 butler, a maid, a concierge, gourmet meals, d a kitchen stocked with the items provided in a list

5 by Blair’s assistant to Defendants, as well a.%Eigh-end food catering for $60,000.

6 i 37. The contract for the Property! ~ as entered into with “Zenith Entertainment, LLC,”

7 i which, on information and belief, is an altergo for the Defendants.

8 38. Blair performed all of his obEli1 ations under the contracts by paying the sums due

9 i on time and in full. 2

10 i 39. Defendants failed to perforrri tgiieir obligations under the agreements, including, but

1 l E not limited to, delivering the premises at the tiime agreed upon or in the manner in which it was

12 i agreed; failing to provide the agreed-upon riuimber ofbedrooms and bathrooms; failing to provide

13 ; catering services; failing to provide a maid, butler, gourmet meals, or a kitchen stocked with the

14 items provided by Blair’s assistant in exchani|ge for $60,000.

15 40. Defendants failed to deliver the premises in a “professionally cleaned” manner as

16 required by paragraphs 10 and 31 of the Rentiial Agreement.

17 1 41. As a result of Defendants’ numerous breaches of the contract, Plaintiff and his

18 guests were forced to seek comparable acconlvmodations elsewhere and incurred additional

19 expenses ofapproximately $148,184.57 in addition to the $87,600 for the Property rental and the

20 l $60,000 for the catering which Defendants never provided.

21 42. Therefore, Blair seeks dama‘ge,[s according to proof, but in an amount not less than

22 1 $295,784.57. '23 SECOND CEAUSE OF ACTION

24 (Breach of Covenant of Good Faithiand Fair Dealing - Against All Defendants)

25 43. Plaintiff re-alleges and incorpiorates all allegations in the paragraphs 1 through 42

26 i as if fully set forth herein.

27 44. As explained above, Plaintiff entered into multiple agreements with Defendants,

28 including the Event Rental Agreement and thie catering agreement.

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l ‘ 45. Blair did all of the things the‘ ciontract required him to do.

2 l 46. Defendants unfairly interfered’; with Blair’s right to receive the benets under his

3 z contract with them by refusing to abide by agreements, including by assaulting Blair’s

_ 4 assistant, which made none of Blair’s guesti feel safe at the Property.

5 g 47. Blair was damaged as a result !of the false representations.

6 i 48. As a direct and proximate restilt of Blair’s reasonable reliance on Defendants’

7 representations, Blair was damaged in an amciaunt totaling approximately $295,784.57. The full

8 amount shall be proven at trial. E

9 THIRD CjA§UsE or ACTION10 (Fraud Against All Defendants)

ll 49. Blair re-alleges and incorporaips all allegations in the paragraphs 1 through 48 as if

12 fully set forth herein.

13 50. As explained above, Defendarits made numerous false representations and: l

14 promises to Blair regarding the condition of‘ T16 premises, the number of rooms and bathrooms at

15 the premises, the quality of the catering servifes, the existence of catering, and the very nature of

16 the Property in addition to various services that they would provide in exchange for Blair’s

17 payments. 1

18 _ 51. As explained above, the Proptiny had about halfof the number of bedrooms and

19 bathrooms that Defendants represented on their advertisements that it had. The Property had

20 I garbage strewn everywhere and looked likemi was being used as a storage facility for old items

21 1 such as bags of clothes, old appliances, etc. ftunhennore, the only meal Defendants provided for

22 5 the $60,000 they solicited and accepted from iBlair for catering was a few boxes of CPK pizza.

23 52. On information and belief, Dyeifendants did not have the right to even rent the

24 ‘ Property to Blair.

25 53. On information and belief, Degfendants did not intend to perform their promises

26 ” when they made them to Blair and knew theii representations were false when they made them.

27 ‘ 54. On information and belief, Die‘ endants’ representations about the size and quality

E3 28 of the home, the number of bedrooms and baiihrooms, and the quality of catering were intended to

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l induce Blair into renting the Property from Dicafendants and ordering catering services through

2 Defendants. l

3 55. On information and belief, Déefendants never intended to perform on their

4 representations and instead intended to defraud Blair out of as much money as possible.

5 56. On infonnation and belief, Dilelfendants’ representations relating to the advance

6 payment for catering and the Property rental fem intended to induce Defendant into leasing the

7 Property. 3

8 57. On information and belief, Derendants intended for Blair to rely on their false

9 promises. I

10 58. Blair reasonably relied on Detlfndarits’ promises, as Defendants represented their

11 owned and managed the Property, which ori irformation and belief, is false.

12 59. Blair’s reliance was reasonablle since Defendants created a legitimate and

13 professional looking website for the Propertjiyl and advertised that it had certain features.

14 60. On information and belief, Dzelfendants also falsied reviews about the Property on

1.5 home rental websites such as VRBO. 1 l

1_6 61. On information and belief, Dgeifendants’ failure to perform their promised acts was

I 7 intentional. l

18 62. Blair was damaged as a result Eof the false representations, because he has paid

19 over $140,000 in costs both to Defendants towards renting a new property to stay at, and

20 Defendants have refused to return any part of? the funds fraudulently obtained from Blair.

21 63. Blair’s reliance on Defendants’ promises was a substantial factor in causing Blair’s

22 harm.

23 64. As a direct and proximate restlllt of Blair’s reasonable reliance on Defendants’

24 representations, Blair was damaged in an arimpunt totaling approximately $295,784.57. The full

25 amount shall be proven at trial.

26 65. On information and belief, Dleifendants’ actions were willful, malicious,

27 oppressive, and fraudulent. Therefore, Blair; decks punitive and exemplary damages.

28

OOIMPLAINT

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l 1 FOURTH CALUSE OF ACTION. " " ‘ g

2 3 (Violation of Penal Code Sedtion 496 Against All Defendants) }1 1 1

3 66. Blair re-alleges and incorporate”? all allegations in the paragraphs 1 through 65 and

4 1 as if illy set forth herein. 7 i

5 67. Penal Code section 496 allowsl?1n injured party to sue for treble damages and

6 i attomey’s fees against anyone who obtains or receives or aids in obtaining or receiving any

7 ‘ property that has been stolen or that has beenlbtained in any manner constituting the. (Penal

8 E Code § 496(a), (c).) I r| .

9 1 68. The denition of “theft” includ%s knowingly and designedly obtaining credit,

10 I labor, or property through fraudulent represedtftions or pretenses. (See Penal Code § 484(a).)

ll 69. As explained above, Defendants obtained Blair’s money through fraudulent

l2 misrepresentations about the Property and ab€)l;;lt the services Defendants would purportedly

13 ; provide for the duration of Blair’s rental of the|Property.‘ !

14 1 70. However, Defendants’ actions: following the event have made it clear that4 1' 1

15 | Defendants knew their representations were false and they never intended to perform them.\ 3 =

16 l 71. As explained above, Blair’s reliiance was reasonable.» 1

l7 72. Blair’s reliance on Defendants’ [representations was a substantial factor in causing

18 ‘ Blair’s harm. *

19 > 73. As a direct and proximate reslilti of Blair’s reasonable reliance on Defendants’. ‘ 1

20 misrepresentations, Blair was damaged in an ainount totaling approximately $295,784.57. The: I

21 1 full amount shall be proven at trial. 1i l

22 74. On information and belief, the.IE)efendants’ actions were willful, malicious,

23 1 oppressive, and fraudulent. Therefore, Blair seeks punitive, exemplary, and treble damages.

24 FIFTH CAUSE OF ACTION‘ E

25 5 (Negligent Misrepresention Against All Defendants)

26 75. Blair re-alleges and incorporate:s all allegations in the paragraphs 1 through 74 as if

27 ¥ ll] t f rth here‘ Z3 y se 0 in. . »; n

{-53, 28 l 76. Defendants represented and adylertised to Blair that the Property contained 10

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l ‘ bedrooms and 9 bathrooms even though thb tproperty contains only 5 bedrooms and 5.5

2 bathrooms.

3 ‘ 77. Defendants represented that they could provide catering and gounnet meals to

4 « Blair for his event. ‘5 78. Defendants represented that. tghe Property would be professionally cleaned.

6 79. These representations were ifalilse.

7 80. On information and belief, Diefendants knew these representations were false when

8 ‘ they made them, but if Defendants did not lcirow those representations were false, then they

9 ' should have known they would not be able‘ tf provide the services they represented, and agreed to

10 provide, to Blair. '1

11 81. On information and belief, Dzefendants intended for Blair to rely on their

12 1‘ representations. 3

13 82. Blair’s reliance on Defendanés’ representations was reasonable.

14 83. Blair was harmed in an amoiuint to be proven at trial but in an amount not less than

15 $295,784.57.l6 84. Blair’s reliance on Defendanfls’ representations was a substantial factor in causing

17 ‘ his harm.

18 SIXTH OF ACTION

19 I (Negligence lkifainst All Defendants)

20 l 85. Blair re-alleges and incorporates all allegations in the paragraphs 1 through 84 as if

21 T 1lly set forth herein.

22 86. Defendants had a duty to maltie accurate representations about the Property and

23 what services they could and would provide :to Blair.

24 87. Defendants also had a duty toi publish accurate advertisements about the Property 8

25 ‘ so as not to be misleading.

26 6 88. As discussed above, Defendariits breached those duties by making false

27 1 representations about the Property and by publishing false advertising about the Property and its

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1 , 89. As a direct and proximate resllult of Defendants’ false representations about the

2 , Property, Blair was harmed in an amount acicording to proofbut in an amount not less than

3 l $295,784.57. l4 90. Each and every one of Deferrldants’ misrepresentations was a substantial factor in

5 causing Blair’s harm. I

6 , SEVENTH lCAUSE OF ACTION

7 (Violation of Business & Professions Clpltle Section 17200 et seq. — Against All Defendants)

8 1 91. Blair re-alleges and incorporateislall allegations in the paragraphs 1 through 90 as if

9 fully set forth herein. 1

10 l 92. Defendants engaged in unfair cprlripetition within the meaning ofCalifornia Business

1 l & Professions Code section 17200 et seq. misrepresenting the quality and nature of the

12 Property, their services, and their ability or ilight to lease the Property to members of the public

13 l like Blair. '

14 93. As a direct and proximate result bfDefendants’ unfair and fraudulent business acts

15 and practices, Blair was injured in an amounit to be proven at trial but in an amount not less than

16 $295,784.57. § §

17 l EIGHTH AAUSE OF ACTION

18 l (Misleading Advertising In Violation of gliliusiness & Professions Code Section 17500 et seq. -

19 l Againbtl All Defendants)

20 94. Blair re-alleges and incorpoldtes all allegations in the paragraphs 1 through 93 as if

21 i fully set forth herein. 3 l

22 95. Defendants engaged in misleading advertising within the meaning ofCalifornia

23 Business & Professions Code sections 1750(1) set seq. by misrepresenting the quality and nature of

24 l the Property, Defendants’ services, and Defelzndants’ ability or right to lease the Property to

25 members of the public like Blair. l

26 l 96. Defendants misrepresented advertised to Blair that the Property contained 10

27 bedrooms and 9 bathrooms even though the property contains only 5 bedrooms and 5.5

28 2 bathrooms. ‘

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i1 97. Defendants misrepresented their ability and quality ofcatering services to Blair.

2 1 98. As a direct and proximate result ofDefendants’ unfair and fraudulent business acts

3 and practices, Blair was injured in an mnoyiiit to be proven at trial but in an amount not less than3 l 14 $295,784.57. 1 1

5 l6 ’ DATED: October 6, 2017 1 1

" 1 1 LAW OFFICE OF PARAG L. AMIN, P.C.7 i

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8 K 1 1 W

Parag L. Amm, Esq.,l l 1 Attorney for Craig Blair

12 QI !

13 PRAYER FOR RELIEF""""""'1 T"

14 ON THE FIRST CAUSE OF ACTION BREACH OF CONTRACT:

15 1. For an award of actual damatiges according to proof but in an amount not less than

15 $295,734.57; ?I 1

17 2. For prejudgment interest; I 1E 1

13 3. For costs of suit; and, 1 1

19 4. For any and all relief this C1I<1)urt deems appropriate or necessary.

20 ON THE SECOND CAUSE OF ACTION FOR BREACH OF THE COVENANT OFI 3 1

21 GOOD FAITH AND FAIR DEALING‘: I1 1

22 1. For an award of actual damages according to proof but in an amount not less than

23 1 $295,734.57;24 1 2. For prejudgment interest;

25 3. For an award of punitive damages pursuant to Civil Code section 3294;

26 4. For costs of suit; and,

27 5. For any and all relief this :C§ourt deems appropriate or necessary.

11:1 23 ON THE THIRD CAUSE OF ACTIO11‘I1 FOR FRAUD:

1. For an award ofactual dairiages_ grding to proofbut in an amount not less than':;{-J I 1 1 31%

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1 $295,784.57;2 2. For prejudgment interest;

3 3. For an award ofpunitive dairiages pursuant to Civil Code section 3294;

4 4. For costs of suit; and,

5 5. For any and all relief this deems appropriate or necessary.

6 ON THE FOURTH CAUSE OF ACTIOEN FOR VIOLATION OF PENAL CODE

7 SECTION 496:8 E 1. For an award ofactual damages according to proof but in an amount not less than

9 1 $295,784.57;

10 1 2. For prejudgment interest;

l 1 3. For an award of punitive daages pursuant to Civil Code section 3294;

12 4. For an award of treble damajgies pursuant to Civil Code section 496(c);

13 5. For attomey’s fees pursuantgttl) Civil Code section 496(c);

14 I 6. For costs of suit; and,

15 E 7. For any and all relief this C(E)1l:[I‘t deems appropriate or necessary.

16 ON THE FIFTH CAUSE OF ACTION NEGLIGENT MISREPRESENTATION:

17 1. For an award ofactual damages according to proof but in an amount not less than

18 $295,784.57;

19 2. For prejudgment interest; E

20 3. For costs of suit; and,

21 4. For any and all relief this deems appropriate or necessary.

22 ON THE SIXTH CAUSE OF ACTION NEGLIGENCE:

23 1. For an award ofactual damaigps according to proof but in an amount not less than

24 1 $295,784.57;25 2. For prejudgment interest;

26 ‘ 3. For costs of suit; and, 1

27 4. For any and all relief this Copr deems appropriate or necessary.

28 * ON THE SEVENTH CAUSE OF ACTIQN FOR VIOLATION OF BUSINESS AND

COMPLAINTu::.x::2 ; ‘

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l1 PROFESSIONS CODE SECTION 17200 ETSEQ.:

2 1. For restitution of all sums paid; '

3 2. For prejudgment interest; 2l .

4 3. For costs of suit; and, j

5 4. For any and all relief this Court deems appropriate or necessary.

6 ON THE EIGHTH CAUSE OF ACTION FOR VIOLATION OF BUSINESS AND

7 1 PROFESSIONS CODE SECTION 1750(I ETSEQ.:

8 1. For restitution ofall sums paid;‘ ‘ .

9 l 2. For prejudgment interest; *5

10 3. For an injunction from publishing false advertisements about the Property in the

1 1 } future;

12 4. For costs of suit; and,

13 . 5. For any and all relief this Court deems appropriate or necessary.

14 l15 DATED: October 6, 2017 LAW OFFICE OF PARAG L. AMIN, P.C.

16 !17 %

l18 By:19 Parag L. Amin

Attorney for PlaintiffCraig Blair20

21 REUEST FOR A JURY TRIALl

22 § Blair requests a trial byjury for all claims.23

1‘ DATED: October 6, 2017 LAW OFFICE OF PARAG L. AMIN, P.C.24 4

25 %26 l

27 l BYITI Parag L. Amin

28 Attorney for Craig Blair

l - 14 -l COMPLAINT