Complaint,Petition: IRIS SANGIOVANNI, AN INDIVIDUAL, ET AL. VS SILVER HORIZONS LLC, A CALIFORNIA LIMITED LIABILITY COMPANY

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 11/02/2021 01:57 PM Sherri R. Carter, Executive Officer/Clerk of Court, by N. Alvarez,Deputy Clerk
                                                                                       21STCV40251
                                        Assigned for all purposes to: Stanley Mosk Courthouse, Judicial Officer: Kristin Escalante




                     1      Christofer R. Chapman, Esq. Bar # 153186
                     2      Jason B. Friedman, Esq. Bar # 216178
                            FRIEDMAN & CHAPMAN, LLP
                     3      1342 Coronado Ave.,
                            Long Beach, CA 90804
                     4
                            562-888-4151 Telephone; 562-436-9415 Facsimile
                     5      chris@fc-lawfirm.com jason@fc-lawfirm.com

                     6      Attorneys for all Plaintiffs,
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                                                                         SUPERIOR COURT OF CALIFORNIA
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                                                            COUNTY OF LOS ANGELES, CENTRAL DISTRICT
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                   10       IRIS SANGIOVANNI, an individual; IDMAN                                             No.
                            ABDULKADIR, an individual;
                   11                                                                                          Judge:
                                                                          Plaintiffs,
                   12                                                                                          Dept.:
                                       v.
                   13                                                                                          COMPLAINT FOR:
                            SILVER HORIZONS LLC, a California
                   14       limited liability company; and DOES 1 through                                            1) BREACH OF IMPLIED
                            50, inclusive;                                                                              WARRANTY OF HABITABILITY
                   15                                                                                                2) BRE ACH OF STATUTORY
                                                                          Defendants.                                   WARRANTY OF HABITABILITY
                   16                                                                                                3) BREACH OF THE COVENANT OF
                                                                                                                        QUIET ENJOYMENT
                   17                                                                                                4) NEGLIGENCE
                                                                                                                     5) VIOLATION OF CIVIL CODE
                   18                                                                                                   SECTION 1942.4
                                                                                                                     6) PRIVATE NUISANCE
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                                                                                                               DEMAND FOR JURY TRIAL
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                                       Plaintiffs individually and collectively allege against the Defendant as follows:
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                                       1.          Defendant SILVER HORIZONS LLC, a California limited liability company,
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                            since on or about September 18, 2003, and to the present, was the owner and manager of an
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                            apartment building with APN 2654-036-016 located at 8116 Langdon Ave. Van Nuys, CA 91406
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                            herein after “apartment building.”
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                                       2.          Plaintiffs, IRIS SANGIOVANNI, an individual; IDMAN ABDULKADIR, an
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                            individual; hereinafter “Plaintiffs”, are individuals who are now or have been tenants subject to a
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                            lease in the apartment building at various relevant times as alleged herein during the last four years.
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                            At all times relevant herein, Plaintiffs resided in Unit 309 of the apartment building. Plaintiffs may

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                                                                                              COMPLAINT