Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 12/06/2022 02:10 PM Sherri R. Carter, Executive Officer/Clerk of Court, by A. Salcedo,Deputy Clerk
BENJAMIN DRAKE, ESQ. State Bar No. 243207
1 Benjamin@drakelawgroup.com
JEFF BONELLI, ESQ. State Bar No. 133616
2 Jeff@drakelawgroup.com
MEGAN VALLES, ESQ. State Bar No. 332730
3 Megan@drakelawgroup.com
IZABELLA STEPANYAN, ESQ. State Bar No. 270820
4 Izabella@drakelawgroup.com
DRAKE LAW FIRM
5 19935 Ventura Blvd., Suite 202
Woodland Hills, California 91364
6 Tel.: (888) 315-5721
Fax: (888) 340-6488
7 Service: litigation@drakelawgroup.com
8
Attorneys for Plaintiff, Drake Law Firm
9
10
Tel.: (888) 315 - 5721 | Fax: (888) 340 - 6488
11
SUPERIOR COURT OF THE STATE OF CALIFORNIA
19935 Ventura Blvd. Third Floor
COUNTY OF LOS ANGELES
Woodland Hills, CA 91364
DRAKE LAW FIRM
12
DRAKE LAW FIRM; CASE NO:
13
14 Plaintiff, COMPLAINT IN INTERPLEADER
vs. PURSUANT TO CODE OF CIVIL
15 PROCEDURE §386
TRACY MATHIS; SHERMAN WAY
16
SURGICAL CENTER, INC.; ABRAHAM
17 ISHAAYA, M.D.; BEVERLY
RADIOLOGY MEDICAL GROUP;
18 ARTHUR KREITENBURG, M.D.; DAVID
RAMIN, M.D.; DYNAMIC DIAGNOSTIC
19
IMAGING CENTER; POINT
20 ANESTHESIA; PROHEALTH
ADVANCED IMAGING; RAJAN PATEL,
21 M.D.; URGENT ORTHOPEDIC CARE;
WESTSTAR PHYSICAL THERAPY;
22
WILMORE PREMIER HEALTH GROUP;
23 DEPARTMENT OF HEALTH CARE
SERVICES and DOES 1 through 50
24 Inclusive.
25
Defendants.
26
27
28
- 1 -
___________________________________________________________________________________
COMPLAINT IN INTERPLEADER PURSUANT TO
CODE OF CIVIL PROCEDURE §386
1 Plaintiff DRAKE LAW FIRM, for its complaint in interpleader under Code of Civil
2 Procedure §386, alleges as follows:
3 1. At all times relevant herein, DRAKE LAW FIRM, hereinafter referred to as Plaintiff,
4 is a professional law corporation under the direction of Benjamin Drake, who is duly licensed
5 to practice law in the State of California.
6 2. Plaintiff believes and thereupon alleges that at all times relevant herein, TRACY
7 MATHIS, hereinafter referred to as Defendant MATHIS and/or MATHIS, was/is an
8 individual residing in city and county of Los Angeles, state of California.
9 3. Plaintiff believes and thereupon alleges that at all times relevant herein, SHERMAN
10 WAY SURGICAL CENTER, INC, hereinafter referred to as Defendant SWSC is a
Tel.: (888) 315 - 5721 | Fax: (888) 340 - 6488
11 corporation duly authorized to conduct business in the State of California, with its principal
19935 Ventura Blvd. Third Floor
Woodland Hills, CA 91364
DRAKE LAW FIRM
12 place of business in Reseda, California.
13 4. Plaintiff believes and thereupon alleges that at all times relevant herein, Dr.
14 ABRAHAM ISHAAYA, hereinafter referred to as Defendant ISHAAYA is a licensed
15 Medical Doctor by the State of California and was/is an individual residing in Los Angeles,
16 CA.
17 5. Plaintiff believes and thereupon alleges that at all times relevant herein, BEVERLY
18 RADIOLOGY MEDICAL GROUP, INC, hereinafter referred to as Defendant BRMG is a
19 California corporation duly authorized to conduct business in the State of California, with its
20 principal place of business in Beverly Hills, California.
21 6. Plaintiff believes and thereupon alleges that at all times relevant herein, Dr. ARTHUR
22 KREITENBURG, hereinafter referred to as Defendant KREITENBURG is a licensed Medical
23 Doctor by the State of California, was/is an individual residing in Los Angeles, CA.
24 7. Plaintiff believes and thereupon alleges that at all times relevant herein, DAVID
25 RAMIN M.D., hereinafter referred to as Defendant RAMIN, is a licensed Medical Doctor by
26 the State of California was/is an individual residing in Beverly Hills, CA.
27
28
- 2 -
___________________________________________________________________________________
COMPLAINT IN INTERPLEADER PURSUANT TO
CODE OF CIVIL PROCEDURE §386
1 8. Plaintiff believes and thereupon alleges that at all times relevant herein, POINT
2 ANESTHESIA, hereinafter referred to as Defendant PA is an unknown California business
3 entity, with its principal place of business in Irvine, California.
4 9. Plaintiff believes and thereupon alleges that at all times relevant herein, Dr. RAJAN
5 PATEL, hereinafter referred to as Defendant PATEL, is a licensed Medical Doctor by the
6 State of California was/is an individual residing in Los Angeles, CA.
7 10. Plaintiff believes and thereupon alleges at all times relevant herein, PROHEALTH
8 ADVANCED IMAGING, INC, hereinafter referred to as Defendant PAI, is an unknown
9 business entity with its principal place of business in North Hollywood, California.
10 11. Plaintiff believes and thereupon alleges at all times relevant herein, URGENT
Tel.: (888) 315 - 5721 | Fax: (888) 340 - 6488
11 ORTHOPEDIC CARE, hereinafter referred to as Defendant UOC, is an unknown business
19935 Ventura Blvd. Third Floor
Woodland Hills, CA 91364
DRAKE LAW FIRM
12 entity with its principal place of business in North Hollywood, California.
13 12. Plaintiff believes and thereupon alleges at all times relevant herein, WESTSTAR
14 PHYSICAL THERAPY, INC, hereinafter referred to as Defendant WPT is a California
15 corporation duly authorized to conduct business in the State of California, with its principal
16 place of business in Los Angeles, California.
17 13. Plaintiff believes and thereupon alleges at all times relevant herein, WILMORE
18 PREMIER HEALTH GROUP, INC, hereinafter referred to as Defendant WPHG is a
19 California corporation duly authorized to conduct business in the State of California, with its
20 principal place of business in Los Angeles, California.
21 14. Plaintiff believes and thereupon alleges at all times relevant herein, DEPARTMENT
22 OF HEALTH CARE SERVICES, hereinafter referred to as Defendant DHCS was/is a public
23 government entity.
24 15. Defendants SWSC, ISHAAYA, BRNG, KREITENBURG, RAMIN, PA, PATEL,
25 PAI, UOC, WPT, WPHG, and DHCS, hereinafter shall be collectively referred to as
26 Defendant Medical Providers.
27 16. Plaintiff lacks sufficient information or belief as to the true identities and capacities of
28 the fictitiously named Defendants and therefore sues said Defendants by such fictitious
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___________________________________________________________________________________
COMPLAINT IN INTERPLEADER PURSUANT TO
CODE OF CIVIL PROCEDURE §386
1 names. Plaintiff will amend this Complaint to set forth the true names and capacities of the
2 fictitiously named Defendants when ascertained.
3 17. On May 28, 2017, TRACY MATHIS incurred personal injuries as result of a slip and
4 fall incident at RALPHS Grocery Store located at 16123 Bellflower Blvd. City of Bellflower,
5 County of Los Angeles.
6 18. On or about May 31, 2017, TRACY MATHIS hired the Plaintiff to represent her with
7 regards to the injuries she sustained as result of the May 28, 2017 fall.
8 19. Subsequently, Plaintiff Drake Law Firm initiated a personal injury action on behalf of
9 TRACY MATHIS as to the responsible parties, titled Mathis v. Ralphs, Los Angeles Superior
10 Court Case No. 18STCV00036, and hereinafter referred to as Mathis v. Ralphs.
Tel.: (888) 315 - 5721 | Fax: (888) 340 - 6488
11 20. Thereafter, following significate litigation, parties in Mathis v. Ralphs settled the case
19935 Ventura Blvd. Third Floor
Woodland Hills, CA 91364
DRAKE LAW FIRM
12 via private mediation.
13 21. In the case of Mathis v. Ralphs, Defendant MATHIS obtained a settlement in the
14 amount of $150,000 for her injuries, medical expenses, pain and suffering, future medical
15 expenses and attorney’s fees.
16 22. Following the settlement, Defendant MATHIS, has demanded in writing that the entire
17 $150,000 settlement funds be paid to her, and that the Plaintiff cover the medical expenses out
18 of its own pocket with no funds going to the Plaintiff.
19 23. Plaintiff is informed and believes, and based upon such information and belief alleges,
20 that each of the Defendants will claim some right, benefit or entitlement in the personal injury
21 settlement received by Defendant MATHIS which is being held in Plaintiff’s trust.
22 24. Defendants, and each of them, are claiming damages from Defendant MATHIS’
23 settlement amount.
24 25. The Defendant Medical Providers that furnished services to Defendant MATHIS have
25 not yet had an opportunity to negotiate their contractual and statutory liens as against the
26 above referenced settlement amount.
27 26. Defendant MATHIS is demanding that the settlement amount in its entirety or close to
28 its entirety to be paid to her.
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___________________________________________________________________________________
COMPLAINT IN INTERPLEADER PURSUANT TO
CODE OF CIVIL PROCEDURE §386
1 27. Thereupon, Plaintiff is unable to ascertain itself the validity of the conflicting demands
2 noted herein and cannot determine how the settlement received in Mathis v. Ralphs should be
3 distributed.
4 28. Plaintiff intends to deposit into the Court, or such other depository as may be directed,
5 the sum of $150,000.00, said sum being the whole of the funds from the settlement of the
6 claim pursuant to Code of Civil Procedure §386 and to thereafter have the Court determine the
7 respective rights of the Defendants, and each of them, as well as ordering attorney’s fees and
8 costs incurred by the Plaintiff for the prosecution of the underlying Claim (Mathis v. Ralphs).
9 29. Plaintiff is entitled to attorneys’ fees and costs pursuant to California Code of Civil
10 Procedure § 386.6(a):
Tel.: (888) 315 - 5721 | Fax: (888) 340 - 6488
A party to an action who follows the procedure set forth in Section 386 or 386.5
11
19935 Ventura Blvd. Third Floor
may insert in his motion, petition, complaint, or cross complaint a request for
Woodland Hills, CA 91364
DRAKE LAW FIRM
12 allowance of his costs and reasonable attorney fees incurred in such action. In
ordering the discharge of such party, the court may, in its discretion, award such
13 party his costs and reasonable attorney fees from the amount in dispute which has
been deposited with the court. At the time of final judgment in the action the court
14
may make such further provision for assumption of such costs and attorney fees
15 by one or more of the adverse claimants as may appear proper.
16
17 WHEREFORE, Plaintiff prays for judgment against Defendants in interpleader as
18 follows:
19 1. That Defendants, and each of them, be ordered to interplead and litigate their claims to
20 the money described herein;
21 2. The attorney’s fees equivalent to 40% of the settlement amount of $150,000 in amount
22 of $60,000 pursuant to the retainer agreement signed by Defendant TRACY MATHIS
23 and DRAKE LAW FIRM to be awarded to the plaintiff; a true and correct copy of the
24 retainer agreement is attached herein as Exhibit “A”
25 3. Costs of $12,418.20 incurred by the plaintiff for prosecuting the Mathis v. Ralph Case
26 to be reimbursed to the Plaintiff;
27 4. That Plaintiff be discharged from any further liability and dismissed from this action.
28
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___________________________________________________________________________________
COMPLAINT IN INTERPLEADER PURSUANT TO
CODE OF CIVIL PROCEDURE §386
1 5. That Defendants, and each of them be restrained until further order of this court from
2 instituting or further prosecuting any other proceeding against Plaintiff in any court in
3 the State of California affecting the rights and obligations between the parties to this
4 action;
5 6. For the costs and reasonable attorney’s fees to be awarded to the Plaintiff pursuant
6 CCP §836.6 to be determined by the Court; and,
7 7. That Plaintiff be granted such other and further relief as the Court deems just.
8
9 Dated: December 6, 2022
10
Tel.: (888) 315 - 5721 | Fax: (888) 340 - 6488
By: ____________________________
11
19935 Ventura Blvd. Third Floor
Izabella Stepanyan, Esq.
Woodland Hills, CA 91364
DRAKE LAW FIRM
12 Megan Valles, Esq.
Benjamin Drake, Esq.
13 Attorneys for Plaintiff,
Drake Law Firm
14
15
16
17
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20
21
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23
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25
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___________________________________________________________________________________
COMPLAINT IN INTERPLEADER PURSUANT TO
CODE OF CIVIL PROCEDURE §386
EXHIBIT "A"
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 12/06/2022 02:10 PM Sherri R. Carter, Executive Officer/Clerk of Court, by A. Salcedo,Deputy Clerk BENJAMIN DRAKE, ESQ. State Bar No. 243207 1 Benjamin@drakelawgroup.com JEFF BONELLI, ESQ. State Bar No. 133616 2 Jeff@drakelawgroup.com MEGAN VALLES, ESQ. State Bar No. 332730 3 Megan@drakelawgroup.com IZABELLA STEPANYAN, ESQ. State Bar No. 270820 4 Izabella@drakelawgroup.com DRAKE LAW FIRM 5 19935 Ventura Blvd., Suite 202 Woodland Hills, California 91364 6 Tel.: (888) 315-5721 Fax: (888) 340-6488 7 Service: litigation@drakelawgroup.com 8 Attorneys for Plaintiff, Drake Law Firm 9 10 Tel.: (888) 315 - 5721 | Fax: (888) 340 - 6488 11 SUPERIOR COURT OF THE STATE OF CALIFORNIA 19935 Ventura Blvd. Third Floor COUNTY OF LOS ANGELES Woodland Hills, CA 91364 DRAKE LAW FIRM 12 DRAKE LAW FIRM; CASE NO: 13 14 Plaintiff, COMPLAINT IN INTERPLEADER vs. PURSUANT TO CODE OF CIVIL 15 PROCEDURE §386 TRACY MATHIS; SHERMAN WAY 16 SURGICAL CENTER, INC.; ABRAHAM 17 ISHAAYA, M.D.; BEVERLY RADIOLOGY MEDICAL GROUP; 18 ARTHUR KREITENBURG, M.D.; DAVID RAMIN, M.D.; DYNAMIC DIAGNOSTIC 19 IMAGING CENTER; POINT 20 ANESTHESIA; PROHEALTH ADVANCED IMAGING; RAJAN PATEL, 21 M.D.; URGENT ORTHOPEDIC CARE; WESTSTAR PHYSICAL THERAPY; 22 WILMORE PREMIER HEALTH GROUP; 23 DEPARTMENT OF HEALTH CARE SERVICES and DOES 1 through 50 24 Inclusive. 25 Defendants. 26 27 28 - 1 - ___________________________________________________________________________________ COMPLAINT IN INTERPLEADER PURSUANT TO CODE OF CIVIL PROCEDURE §386 1 Plaintiff DRAKE LAW FIRM, for its complaint in interpleader under Code of Civil 2 Procedure §386, alleges as follows: 3 1. At all times relevant herein, DRAKE LAW FIRM, hereinafter referred to as Plaintiff, 4 is a professional law corporation under the direction of Benjamin Drake, who is duly licensed 5 to practice law in the State of California. 6 2. Plaintiff believes and thereupon alleges that at all times relevant herein, TRACY 7 MATHIS, hereinafter referred to as Defendant MATHIS and/or MATHIS, was/is an 8 individual residing in city and county of Los Angeles, state of California. 9 3. Plaintiff believes and thereupon alleges that at all times relevant herein, SHERMAN 10 WAY SURGICAL CENTER, INC, hereinafter referred to as Defendant SWSC is a Tel.: (888) 315 - 5721 | Fax: (888) 340 - 6488 11 corporation duly authorized to conduct business in the State of California, with its principal 19935 Ventura Blvd. Third Floor Woodland Hills, CA 91364 DRAKE LAW FIRM 12 place of business in Reseda, California. 13 4. Plaintiff believes and thereupon alleges that at all times relevant herein, Dr. 14 ABRAHAM ISHAAYA, hereinafter referred to as Defendant ISHAAYA is a licensed 15 Medical Doctor by the State of California and was/is an individual residing in Los Angeles, 16 CA. 17 5. Plaintiff believes and thereupon alleges that at all times relevant herein, BEVERLY 18 RADIOLOGY MEDICAL GROUP, INC, hereinafter referred to as Defendant BRMG is a 19 California corporation duly authorized to conduct business in the State of California, with its 20 principal place of business in Beverly Hills, California. 21 6. Plaintiff believes and thereupon alleges that at all times relevant herein, Dr. ARTHUR 22 KREITENBURG, hereinafter referred to as Defendant KREITENBURG is a licensed Medical 23 Doctor by the State of California, was/is an individual residing in Los Angeles, CA. 24 7. Plaintiff believes and thereupon alleges that at all times relevant herein, DAVID 25 RAMIN M.D., hereinafter referred to as Defendant RAMIN, is a licensed Medical Doctor by 26 the State of California was/is an individual residing in Beverly Hills, CA. 27 28 - 2 - ___________________________________________________________________________________ COMPLAINT IN INTERPLEADER PURSUANT TO CODE OF CIVIL PROCEDURE §386 1 8. Plaintiff believes and thereupon alleges that at all times relevant herein, POINT 2 ANESTHESIA, hereinafter referred to as Defendant PA is an unknown California business 3 entity, with its principal place of business in Irvine, California. 4 9. Plaintiff believes and thereupon alleges that at all times relevant herein, Dr. RAJAN 5 PATEL, hereinafter referred to as Defendant PATEL, is a licensed Medical Doctor by the 6 State of California was/is an individual residing in Los Angeles, CA. 7 10. Plaintiff believes and thereupon alleges at all times relevant herein, PROHEALTH 8 ADVANCED IMAGING, INC, hereinafter referred to as Defendant PAI, is an unknown 9 business entity with its principal place of business in North Hollywood, California. 10 11. Plaintiff believes and thereupon alleges at all times relevant herein, URGENT Tel.: (888) 315 - 5721 | Fax: (888) 340 - 6488 11 ORTHOPEDIC CARE, hereinafter referred to as Defendant UOC, is an unknown business 19935 Ventura Blvd. Third Floor Woodland Hills, CA 91364 DRAKE LAW FIRM 12 entity with its principal place of business in North Hollywood, California. 13 12. Plaintiff believes and thereupon alleges at all times relevant herein, WESTSTAR 14 PHYSICAL THERAPY, INC, hereinafter referred to as Defendant WPT is a California 15 corporation duly authorized to conduct business in the State of California, with its principal 16 place of business in Los Angeles, California. 17 13. Plaintiff believes and thereupon alleges at all times relevant herein, WILMORE 18 PREMIER HEALTH GROUP, INC, hereinafter referred to as Defendant WPHG is a 19 California corporation duly authorized to conduct business in the State of California, with its 20 principal place of business in Los Angeles, California. 21 14. Plaintiff believes and thereupon alleges at all times relevant herein, DEPARTMENT 22 OF HEALTH CARE SERVICES, hereinafter referred to as Defendant DHCS was/is a public 23 government entity. 24 15. Defendants SWSC, ISHAAYA, BRNG, KREITENBURG, RAMIN, PA, PATEL, 25 PAI, UOC, WPT, WPHG, and DHCS, hereinafter shall be collectively referred to as 26 Defendant Medical Providers. 27 16. Plaintiff lacks sufficient information or belief as to the true identities and capacities of 28 the fictitiously named Defendants and therefore sues said Defendants by such fictitious - 3 - ___________________________________________________________________________________ COMPLAINT IN INTERPLEADER PURSUANT TO CODE OF CIVIL PROCEDURE §386 1 names. Plaintiff will amend this Complaint to set forth the true names and capacities of the 2 fictitiously named Defendants when ascertained. 3 17. On May 28, 2017, TRACY MATHIS incurred personal injuries as result of a slip and 4 fall incident at RALPHS Grocery Store located at 16123 Bellflower Blvd. City of Bellflower, 5 County of Los Angeles. 6 18. On or about May 31, 2017, TRACY MATHIS hired the Plaintiff to represent her with 7 regards to the injuries she sustained as result of the May 28, 2017 fall. 8 19. Subsequently, Plaintiff Drake Law Firm initiated a personal injury action on behalf of 9 TRACY MATHIS as to the responsible parties, titled Mathis v. Ralphs, Los Angeles Superior 10 Court Case No. 18STCV00036, and hereinafter referred to as Mathis v. Ralphs. Tel.: (888) 315 - 5721 | Fax: (888) 340 - 6488 11 20. Thereafter, following significate litigation, parties in Mathis v. Ralphs settled the case 19935 Ventura Blvd. Third Floor Woodland Hills, CA 91364 DRAKE LAW FIRM 12 via private mediation. 13 21. In the case of Mathis v. Ralphs, Defendant MATHIS obtained a settlement in the 14 amount of $150,000 for her injuries, medical expenses, pain and suffering, future medical 15 expenses and attorney’s fees. 16 22. Following the settlement, Defendant MATHIS, has demanded in writing that the entire 17 $150,000 settlement funds be paid to her, and that the Plaintiff cover the medical expenses out 18 of its own pocket with no funds going to the Plaintiff. 19 23. Plaintiff is informed and believes, and based upon such information and belief alleges, 20 that each of the Defendants will claim some right, benefit or entitlement in the personal injury 21 settlement received by Defendant MATHIS which is being held in Plaintiff’s trust. 22 24. Defendants, and each of them, are claiming damages from Defendant MATHIS’ 23 settlement amount. 24 25. The Defendant Medical Providers that furnished services to Defendant MATHIS have 25 not yet had an opportunity to negotiate their contractual and statutory liens as against the 26 above referenced settlement amount. 27 26. Defendant MATHIS is demanding that the settlement amount in its entirety or close to 28 its entirety to be paid to her. - 4 - ___________________________________________________________________________________ COMPLAINT IN INTERPLEADER PURSUANT TO CODE OF CIVIL PROCEDURE §386 1 27. Thereupon, Plaintiff is unable to ascertain itself the validity of the conflicting demands 2 noted herein and cannot determine how the settlement received in Mathis v. Ralphs should be 3 distributed. 4 28. Plaintiff intends to deposit into the Court, or such other depository as may be directed, 5 the sum of $150,000.00, said sum being the whole of the funds from the settlement of the 6 claim pursuant to Code of Civil Procedure §386 and to thereafter have the Court determine the 7 respective rights of the Defendants, and each of them, as well as ordering attorney’s fees and 8 costs incurred by the Plaintiff for the prosecution of the underlying Claim (Mathis v. Ralphs). 9 29. Plaintiff is entitled to attorneys’ fees and costs pursuant to California Code of Civil 10 Procedure § 386.6(a): Tel.: (888) 315 - 5721 | Fax: (888) 340 - 6488 A party to an action who follows the procedure set forth in Section 386 or 386.5 11 19935 Ventura Blvd. Third Floor may insert in his motion, petition, complaint, or cross complaint a request for Woodland Hills, CA 91364 DRAKE LAW FIRM 12 allowance of his costs and reasonable attorney fees incurred in such action. In ordering the discharge of such party, the court may, in its discretion, award such 13 party his costs and reasonable attorney fees from the amount in dispute which has been deposited with the court. At the time of final judgment in the action the court 14 may make such further provision for assumption of such costs and attorney fees 15 by one or more of the adverse claimants as may appear proper. 16 17 WHEREFORE, Plaintiff prays for judgment against Defendants in interpleader as 18 follows: 19 1. That Defendants, and each of them, be ordered to interplead and litigate their claims to 20 the money described herein; 21 2. The attorney’s fees equivalent to 40% of the settlement amount of $150,000 in amount 22 of $60,000 pursuant to the retainer agreement signed by Defendant TRACY MATHIS 23 and DRAKE LAW FIRM to be awarded to the plaintiff; a true and correct copy of the 24 retainer agreement is attached herein as Exhibit “A” 25 3. Costs of $12,418.20 incurred by the plaintiff for prosecuting the Mathis v. Ralph Case 26 to be reimbursed to the Plaintiff; 27 4. That Plaintiff be discharged from any further liability and dismissed from this action. 28 - 5 - ___________________________________________________________________________________ COMPLAINT IN INTERPLEADER PURSUANT TO CODE OF CIVIL PROCEDURE §386 1 5. That Defendants, and each of them be restrained until further order of this court from 2 instituting or further prosecuting any other proceeding against Plaintiff in any court in 3 the State of California affecting the rights and obligations between the parties to this 4 action; 5 6. For the costs and reasonable attorney’s fees to be awarded to the Plaintiff pursuant 6 CCP §836.6 to be determined by the Court; and, 7 7. That Plaintiff be granted such other and further relief as the Court deems just. 8 9 Dated: December 6, 2022 10 Tel.: (888) 315 - 5721 | Fax: (888) 340 - 6488 By: ____________________________ 11 19935 Ventura Blvd. Third Floor Izabella Stepanyan, Esq. Woodland Hills, CA 91364 DRAKE LAW FIRM 12 Megan Valles, Esq. Benjamin Drake, Esq. 13 Attorneys for Plaintiff, Drake Law Firm 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 - 6 - ___________________________________________________________________________________ COMPLAINT IN INTERPLEADER PURSUANT TO CODE OF CIVIL PROCEDURE §386 EXHIBIT "A"