lawsuit versus 1 and 1 electric and sami khosravi

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Complaint

4. Plaintiff is unaware of the true identity, nature and capacity of each of the

Defendants designated herein as a DOES. Plaintiff is informed and believes and thereon alleges

that each of the Defendants designated herein as a DOE is in some manner responsible for the

damages and injuries as are alleged in this complaint. Upon learning the true identity, nature and

capacity of the DOE Defendants, Plaintiff will amend this complaint to allege their true names and

capacities.

5. Plaintiff is informed and believes and thereon alleges that all material times herein

alleged that the Defendants, and each of them, were the agents, servants and employees of the

other Defendants, and each of them.

6. Plaintiff is informed and believes, and on that basis alleges that each of the

Defendants, including the fictitiously named Defendants, are the authorized agent of the other,

acted in concert with the other Defendants, and are responsible in some manner for the

occurrences alleged herein, and that Plaintiff's damages as herein alleged were proximately caused

by their conduct.

Jurisdiction and Venue

7. This Court has jurisdiction over the causes of action asserted herein pursuant to the

California Constitution, Article VI, Sec. 10, because this case is not a cause given by statute to

other trial courts.

8. This Court has jurisdiction over the Defendants because all contracts and

agreements between the parties were entered into, and all work performed by the Defendants (such

as it was) was performed, in the County of Los Angeles, California. This action is not removable.

9. Venue is proper in this Court, as Plaintiff resides in this County near this

Courthouse, the Defendant does business in this county and near this Courthouse, and the alleged

damages to Plaintiff arose in this County and near this Courthouse.

Summary of Facts

10. On or about May of 2016, Plaintiff MOGHADAM entered into written and verbal

agreements with Defendants 1 AND 1 and KHOSRAVI for certain repairs and improvements on

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Complaint

MOGHADAM’s home located at 16729 Alginet Place, Encino, CA 91436 (the “House”). True

and correct copies of the written contracts are attached hereto as Exhibit "A."

11. To induce MOGHADAM to enter the contracts, KHOSRAVI made representations

regarding his high skill and ability to perform on time, as well promises to take perform the duties

himself and with the utmost care. He and 1 AND 1 warranted to Plaintiff that the materials and

equipment furnished under the contracts would be of good quality and that the work would be

performed free from defects.

12. MOGHADAM was also induced to make certain expenditures for materials and

supplies, which KHOSRAVI insisted, were required and proper for the requested House projects

contracted for.

13. MOGHADAM also paid KHOSRAVI and 1 AND 1 for their services under the

contracts.

14. However throughout the process, KHOSRAVI and 1 AND 1 failed to live up to

their representations, promises and contracts.

15. These failures include not performing the services up to code or applicable

standards, the improper destruction of the House’s existing structures and fixtures as well as those

purchase for the improvements, unauthorized outsourcing of work to unqualified individuals who

caused more damage and unprofessional results (including theft of property in the House), and

ultimately complete abandonment of the ongoing projects in breach of the contracts, leaving

MOGHADAM living in a difficult to inhabit home.

16. Walls have been left partially and badly painted. New flooring purchased by

MOGHADAM for the project has been sanded and re-sanded to an inch of its life by KHOSRAVI

and 1 AND 1 leaving them barely useful and yet still not installed correctly. The floors have been

left uneven and with large gaps between planks. The bathrooms were stripped of new, quality

material out in by MOGHADAM and replaced with inferior material and abandoned partially

finished. Walls are uneven and their supports compromised by KHOSRAVI and 1 AND 1. A

security gate was never properly fixed.

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Complaint

17. Not a single project contracted for has been completed, and those that KHOSRAVI

and 1 AND 1 began, were so poorly done that they must be done anew.

18. All of this was as a result of improper design, installation, construction, and

planning by the Defendants.

19. MOGHADAM expressed concern and dissatisfaction throughout. KHOSRAVI

admitted to the problems in writing and orally and made written and oral promises regarding

rectifying the damages to MOGHADAM and the House. The promises were made in order to

continue to flow of payments to them from MOGHADAM and otherwise delay action on

MOGHADAM’s part.

20. KHOSRAVI went so far as to ask her to find bids that he would cover the cost for

to repair his and 1 AND 1’s mistakes and finish the work. KHOSRAVI and 1 AND 1 had no

intention of honoring this and rejected all bids out of hand. MOGHADAM has also made several

written and oral demands to restart work and to pay for repairs, all of which have gone

unanswered.

21. KHOSRAVI and 1 AND 1 also demanded payment for services not authorized or

performed. For example, representations were made regarding installation of new lighting,

whereas inspections indicate no new lighting was installed. MOGHADAM received invoices for

heating and cooling system repairs that were never authorized and about which 1 AND 1 is

seeking payment through suit in a related small claims action. This related suit and associated

invoice are attached hereto as Exhibit B.

22. Due to the continued state of disrepair the use and enjoyment of the House has been

denied Plaintiff and the House has diminished in value in amount be proven at trial. The House

continues to suffer resulting property damage, including, but not limited to mold and mildew.

Plaintiff is still investigating latent defects and deficiencies and will seek leave to amend the

complaint as needed to address any so discovered.

23. According to filings with State of California, KHOSRAVI is the “President” and

agent for service of 1 AND 1. Despite promises by KHOSRAVI to MOGHADAM that 1 AND 1

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Complaint

was insured for the work they were to perform, it now clear that they maintain only a small bond

($15,000.00) that does not cover anything other than statutory violations.

24. This is part of a plan by KHOSRAVI to undercapitalize the entity for liability while

still attempting to enjoy the corporate shield for personal liability. This plan includes creating no

meaningful separation between KHOSRAVI and 1 AND 1, asking that payments be made

occasionally to KHOSRAVI and occasionally to 1 AND 1, and otherwise using the 1 AND 1

entity to effect frauds and damage on the public. FIRST CAUSE OF ACTION

(BREACH OF CONTRACT)

25. Plaintiff incorporates by this reference each and every allegation of Paragraphs 1

through 24, above, as though fully set forth at length.

26. Despite entering and being paid under the contracts Defendants have failed to

perform the contemplated services therein and have abandoned them completely.

27. Defendants breached the terms of the contract by failing to and still refusing to

perform the services, or pay for replacement services and material.

28. Plaintiff is informed and believes and thereon alleges that the Defendants, and each

of them, breached their obligations under the contracts.

29. Plaintiff has fully performed her respective obligations as set forth in the contracts.

30. Plaintiff is informed and believes and thereon alleges that to the extent that the

Plaintiff was unable to perform any portion of the obligations under the contracts, it was because

she was prevented from doing so by the Defendants through their material breach and/or

anticipatory breach of the contracts.

31. Plaintiff is informed and believes and thereon alleges that, as a direct and

proximate result of the material breach of the contracts by Defendants, Plaintiff has sustained

general, special, consequential and incidental damages in an amount presently unknown, but in

excess of the minimal jurisdictional limit of this Court in that Plaintiff will be required to perform

works of repair, restoration, and construction to portions of the House to prevent further property

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Complaint

damage and to restore portions thereof to their proper condition. Plaintiff will establish the precise

amount of damages at trial, according to proof.

SECOND CAUSE OF ACTION

(NEGLIGENCE)



33. Plaintiff is informed and believes and thereon alleges that Defendants performed

work, labor and/or services at the House and each knew, or should have known, that if the House

and services contemplated were not properly or adequately designed, supervised and/or

constructed, that Plaintiff would be substantially damaged thereby and that the services would be

defective and not of merchantable quality.

34. Defendants were under a duty to exercise ordinary and reasonable care as

contractors, subcontractors, materialmen, suppliers, architects, inspectors, engineers and/or

builders, or otherwise to avoid reasonably foreseeable injury to Plaintiff and knew or should have

known, with reasonable certainty, that Plaintiff would suffer the monetary damages set forth

herein if said Defendants failed to perform their duty to cause the Project to be completed in a

proper and workmanlike manner and fashion and without defects.

35. Defendants, and each of them, failed and neglected to perform the work, labor

and/or services properly or adequately in that each of said Defendants negligently, carelessly and

in an unworkmanlike manner performed the aforesaid work, labor and/or services such that the

work, as described herein, was constructed improperly, negligently, carelessly, and in an

unworkmanlike manner.


proximate result of the foregoing negligence, carelessness, unworkmanlike conduct, and the

actions and/or omissions of Defendants, and each of them, Plaintiff has sustained general, special,

consequential and incidental damages in an amount presently unknown, but in excess of the

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Complaint

minimal jurisdictional limit of this Court in that Plaintiff will be required to perform works of

repair, restoration, and construction to portions of the House to prevent further property damage

and to restore portions thereof to their proper condition. Plaintiff will establish the precise amount

of damages at trial, according to proof.

THIRD CAUSE OF ACTION

(BREACH OF EXPRESS WARRANTY)



38. Defendants warranted that the materials and equipment furnished under the contract

would be of good quality and new and that the work would be free from defects and would

conform with the requirements of all contract documents.

39. Plaintiff is informed and believes and thereon alleges that the services on the house

were inadequately performed, manufactured, developed, designed, supervised or otherwise

improved, as more fully alleged hereinabove, so that the above-described defective conditions

exist and the services are not of merchantable quality or performed in a reasonably workmanlike

manner.

40. Plaintiff is informed and believes and thereon alleges that the House may be

additionally defective in ways and to extents not precisely known, but which will be asserted

herein by way of amendment or will be established at the time of trial, according to proof.

41. Plaintiff has performed everything on its part to be performed pursuant to the

express warranties and have timely notified Defendants that the services or portions thereof was

not of merchantable quality or erected in a reasonably workmanlike manner and from time to time,

gave further notice of the particulars of such defective conditions. Notwithstanding such notices,

the Defendants have declined and failed to acknowledge responsibility for these defects or

otherwise cause the appropriate restoration and/or repairs to be made to the House at their expense

or to otherwise contribute to the costs of these repairs.

42. Plaintiff is informed and believes and thereon alleges that the defects described

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Complaint

herein arose out of, or were attributable to and were directly and proximately caused by the above-

described latent deficiencies in the design, specifications, planning, supervision, observation of

construction, selection of building materials, construction, development and/or improvement of

the House and that prior to the time when it was discovered by Plaintiff, could not have been

discovered by the exercise of reasonable diligence.


proximate result of the foregoing breach of express warranty and the actions and/or omissions of

Defendants, and each of them, Plaintiff has sustained general, special, consequential and incidental

damages in an amount presently unknown, but in excess of the minimal jurisdictional limit of this

Court in that Plaintiff will be required to perform works of repair, restoration, and construction to

portions of the House to prevent further property damage and to restore portions thereof to their

proper condition. Plaintiff will establish the precise amount of damages at trial, according to

proof.

44. Plaintiff is informed and believes and thereon alleges that, as a further direct and

proximate result of the foregoing breach of express warranty of Defendants, and each of them, the

use and enjoyment of Plaintiff in the House and the value thereof has been reduced and

diminished in an amount presently unknown but will be established at the time of trial, according

to proof. FOURTH CAUSE OF ACTION

(RECOVERY OF CONTRACTOR’S LICENSE BOND)

45. Plaintiff re-alleges and incorporates herein by reference each and every allegation

contained in Paragraphs 1 through 24, inclusive, as though fully set forth at length.

46. Plaintiff is informed and believes and thereon alleges that Defendants executed and

delivered to the State of California their bonds and obligations in writing pursuant to Division 3,

Section 9 of the California Business and Professions Code. Pursuant to such, such bonds are for

the benefit of any person damaged as a result of a violation of relevant portions of the Business

and Profession Code.

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Complaint

47. As alleged hereinabove, Defendants have willfully failed to perform work at the

House with reasonable diligence and further failed in material respects to complete contracted

services and those performed were done deficiently and defectively. The acts and omissions of

Defendants constitute violations of Business and Professions Code Sections 7000-7173.

48. Plaintiff is unaware of the true identity of the surety who issued license bonds on

behalf of Defendants and will amend this complaint when the true names of the surety has been

identified

49. For the reasons set forth hereinabove, each surety issuing a Contractor State

License Bond is indebted to Plaintiff in the full amount of the penal sum of the license bonds

issued to all Defendants as will be established according to proof at the time of trial.

FIFTH CAUSE OF ACTION

(BREACH OF THIRD PARTY BENEFICIARY CONTRACT)



51. Plaintiff is informed and believes and thereon alleges that certain Defendants

entered into written contracts with KHOSRAVI and 1 AND 1 pursuant to which they were

subcontractors or otherwise agreed to perform work of improvement at the

House (the “Subcontractors”). These contracts were made for the benefit of Plaintiff.

52. Plaintiff is informed and believes and based thereon alleges that Subcontractors

breached said contracts in that they failed to perform their scopes of work in a workmanlike

manner and in accordance with the plans and specifications and applicable building codes.


proximate result of the foregoing breach of the third party beneficiary contracts, and the actions

and/or omissions of Defendants, and each of them, Plaintiff has sustained general, special,

consequential and incidental damages in an amount presently unknown, but in excess of the

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10 Complaint

minimal jurisdictional limit of this Court in that Plaintiff will be required to perform works of

repair, restoration, and construction to portions of the House to prevent further property damage

and to restore portions thereof to their proper condition. Plaintiff will establish the precise amount

of damages at trial, according to proof.


proximate result of the breach of third party beneficiary contracts by Defendants, and each of

them, the use and enjoyment of Plaintiff in the House and the value thereof has been reduced and

diminished in an amount presently unknown but will be established at the time of trial, according

to proof. FIFTH CAUSE OF ACTION

(FRAUD)



56. Defendants intentionally and/or negligently misrepresented the need for certain

work in the House with the intention of inflating the cost to Plaintiff.

57. This included removing newly installed material in the bath and shower fit for

purpose, and replacing it with material of lesser quality not fit for purpose.

58. Defendants also claimed to have performed work which they did not actually

perform, including the claim of installation of new lighting whereas a reuse of existing lighting

was performed.

59. Also, rather than perform fully and professionally work actually agreed to,

Defendants performed or claimed to perform unauthorized work on the House and presented

invoiced for their payment. This included work claimed to have been performed on the heating

and cooling system, which 1 AND 1 is fraudulently seeking recovery for through a related small

claims action.

60. The foregoing were the result of false representations by the Defendants that they

knew were false or had no reasonable grounds for believing were true, and with the intent to

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11 Complaint

defraud and induce Plaintiff to contract or pay for services and material.

61. At the time, Plaintiff did not know the representations were false and believed they

were true and acted justifiably in reliance on their truth.

62. Further, Defendants concealed or suppressed the false representations by, among

other things, overlaying construction material to conceal what was improperly done underneath,

and by telling Plaintiff that work was performed or performed in a certain manner in order to

mislead Plaintiff.

63. Defendants concealed or suppressed these facts with the intent to defraud and

induce Plaintiff to act as described above. At the time, Plaintiff was unaware of the concealment or

suppression of facts and would have taken action if she had known the facts.


proximate result of the foregoing fraud and the actions and/or omissions of Defendants, and each

of them, Plaintiff has sustained general, special, consequential and incidental damages in an

amount presently unknown, but in excess of the minimal jurisdictional limit of this Court in that

Plaintiff will be required to perform works of repair, restoration, and construction to portions of

the House to prevent further property damage and to restore portions thereof to their proper

condition. Plaintiff will establish the precise amount of damages at trial, according to proof.


proximate result of the foregoing fraud of Defendants, and each of them, the use and enjoyment

of Plaintiff in the House and the value thereof has been reduced and diminished in an amount

presently unknown but will be established at the time of trial, according to proof.

WHEREFORE Plaintiff respectively requests entry of a judgment and order on all causes

of action providing as follows:

1. For general, special, consequential and incidental damages, according to proof;

2. For costs of suit incurred herein;

3. For interest on all amounts paid Defendants by Plaintiff;

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12 Complaint

4. For reasonable attorney’s fees which are due and payable to the prevailing party in

any dispute concerning the contracts.

5. For such other and further relief as the Court deems necessary and proper.

DATED: February 4, 2017

By: Daryoush Niknejad Attorney for MARCI MOGHADAM

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13 Complaint

EXHIBIT A

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14 Complaint

EXHIBIT B

ÎTrialDate

You are the Defendant if your name is listed in on page 2 of this form. The person suing you is the Plaintiff, listed in on page 2.

Plaintiff’s Claim and ORDERto Go to Small Claims Court

Clerk stamps date here when form is filed.

Fill in court name and street address:Superior Court of California, County of

Clerk fills in case number and case name:Case Number:

SC-100, Page 1 of 5Plaintiff’s Claim and ORDERto Go to Small Claims Court

Date Time Department Name and address of court if different from above1.

2.

3.

Date: Clerk, by , Deputy

The people in and must go to court: (Clerk fills out section below.)

Judicial Council of California, www.courts.ca.govRevised July 1, 2015, Mandatory FormCode of Civil Procedure, §§ 116.110 et seq.,116.220(c), 116.340(g)

Notice to the person being sued:

Read this form and all pages attached to understand the claim against you and to protect your rights.

Bring witnesses, receipts, and any evidence you need to prove your case.

If you lose, the court can order that your wages, money, or property be taken to pay this claim.

You and the Plaintiff must go to court on the trial date listed below. If you do not go to court, you may lose the case.

Aviso al Demandado:

Lea este formulario y todas las páginas adjuntas para entender la demanda en su contra y para proteger sus derechos.Lleve testigos, recibos y cualquier otra prueba que necesite para probar su caso.

Si pierde el caso la corte podría ordenar que le quiten de su sueldo, dinero u otros bienes para pagar este reclamo.

Usted y el Demandante tienen que presentarse en la corte en la fecha del juicio indicada a continuación. Si no se presenta, puede perder el caso.

Order to Go to Court

Instructions for the person suing:You are the Plaintiff. The person you are suing is the Defendant.

You must have someone at least 18—not you or anyone else listed in this case—give each Defendant a court-stamped copy of all pages of this form and any pages this form tells you to attach. There are special rules for “serving,” or delivering, this form to public entities, associations, and some businesses. See Forms SC-104, SC-104B, and SC-104C.

Fill out pages 2 and 3 of this form. Then make copies of all pages of this form. (Make copy for each party named in this case and an extra copy for yourself.) Take or mail the original and these copies to the court clerk’s office and pay the filing fee. The clerk will write the date of your trial in the box above.

Before you fill out this form, read Form SC-100-INFO, Information for the Plaintiff , to know your rights. Get SC-100-INFO at any courthouse or county law library, or go to: www.courtinfo.ca.gov/ forms

Go to court on your trial date listed above. Bring witnesses, receipts, and any evidence you need to prove your case.

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(Small Claims)

SC-100

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Usted es el Demandado si su nombre figura en de la página 2 de este formulario. La persona que lo demanda es el Demandante, la que figura en de la página 2.

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Case Name:

E-FILING ID: 170101000250

E-FILING ID: 170101000250

1AND1 ELECTRIC INC, VS. MARCIMOGHADAM

VAN NUYS COURTHOUSE EAST6230 SYLMAR AVE., ROOM340VAN NUYS, CA 91401

17VESC00048

03/09/2017 8:30 AM Z

1/3/2017 SHERRI R. CARTER TAKESHA WHITE

ELECTRONICALLY FILED BY SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES. (Receipt #1170104E6182)

FILEDElectronically

By Superior Court of California,County of Los Angeles on

JAN 3 2017SHERRI R. CARTER ,CLERKBY TAKESHA WHITE, Deputy

The Defendant (the person, business, or public entity being sued) is:

Revised July 1, 2015 SC-100, Page 2 of 5

The Plaintiff (the person, business, or public entity that is suing) is:

The Plaintiff claims the Defendant owes $ . (Explain below):a. Why does the Defendant owe the Plaintiff money? b. When did this happen? (Date):

c. How did you calculate the money owed to you? (Do not include court costs or fees for service.)If no specific date, give the time period: Date started: Through:

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2Check here if either Plaintiff listed above is doing business under a fictitious name. If so, attach Form SC-103. Check here if more than 2 Plaintiffs and attach Form SC-100A.

Plaintiff (list names):

Case Number:

Check here if more than 2 Defendants and attach Form SC-100A.Check here if any Defendant is on active military duty, and write his or her name here:


(Small Claims)

If more than one Plaintiff, list next Plaintiff here:

If more than one Defendant, list next Defendant here:

E-FILING ID: 170101000250

1AND1 ELECTRIC INC,

3220.00

WE FINISHED SOME JOB IN HER HOUSE

07/22/2016 11/01/2016

THAT IS THE AMOUNT OF ONE UNPAID INVOICE

NAME: 1AND1 ELECTRIC INC,HOME ADDRESS: 8448 SAMRA DR WEST HILLS, CA 91304PHONE: (818) 401-3734

NAME: MARCI MOGHADAMHOME ADDRESS: 16729 ALGINET PL ENCINO, CA 91436PHONE: (310) 514-7999

17VESC00048

You must ask the Defendant (in person, in writing, or by phone) to pay you before you sue. Have you done this? Yes NoIf no, explain why not:

Plaintiff types or prints name here Plaintiff signs here

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Revised July 1, 2015 SC-100, Page 3 of 5

Plaintiff (list names):

Why are you filing your claim at this courthouse? This courthouse covers the area (check the one that applies):

b. Where the buyer or lessee signed the contract, lives now, or lived when the contract was made, if this claim is about an offer or contract for personal, family, or household goods, services, or loans. (Code Civ. Proc., § 395(b).) c. Where the buyer signed the contract, lives now, or lived when the contract was made, if this claim is about a retail installment contract (like a credit card). (Civil Code, § 1812.10.) d. Where the buyer signed the contract, lives now, or lived when the contract was made, or where the vehicle is permanently garaged, if this claim is about a vehicle finance sale. (Civil Code, § 2984.4.)e. Other (specify):

List the zip code of the place checked in above (if you know):

Is your claim about an attorney-client fee dispute? Yes NoIf yes, and if you have had arbitration, fill out Form SC-101, attach it to this form, and check here:

Are you suing a public entity? Yes NoIf yes, you must file a written claim with the entity first. A claim was filed on (date): If the public entity denies your claim or does not answer within the time allowed by law, you can file this form. Have you filed more than 12 other small claims within the last 12 months in California? Yes No If yes, the filing fee for this case will be higher.

I understand that by filing a claim in small claims court, I have no right to appeal this claim.

Requests for AccommodationsAssistive listening systems, computer-assisted, real-time captioning, or sign language interpreter services are available if you ask at least 5 days before the trial. Contact the clerk’s office for Form MC-410, Request for Accommodations by Persons With Disabilities and Response. (Civil Code, § 54.8.)

Date:

Case Number:

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(1) Where the Defendant lives or does business.(2) Where the Plaintiff’s property was damaged. (3) Where the Plaintiff was injured.

a. (4) Where a contract (written or spoken) was made, signed, performed, or broken by the Defendant or where the Defendant lived or did business when the Defendant made the contract.

Date: Second Plaintiff types or prints name here Second Plaintiff signs here


(Small Claims)

I have not filed, and understand that I cannot file, more than two small claims cases for more than $2,500 in

I declare, under penalty of perjury under California State law, that the information above and on any attachments to

California during this calendar year.

this form is true and correct.

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E-FILING ID: 170101000250

1AND1 ELECTRIC INC,

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91436

✔

1/1/2017 SAMI KHOSRAVI

17VESC00048