On February 08, 2021 a
Complaint,Petition
was filed
involving a dispute between
Arditi Scott Albert,
Expert Car Washes Inc.,
National Car Washes Inc.,
Shouhed Shahriar,
and
Arditi Scott Albert,
Auto Care California Inc. A California Corporation As A Nominal Defendant As To Derivative Claims,
Expert Car Washes Inc.,
for Other Commercial/Business Tort (not fraud/ breach of contract) (General Jurisdiction)
in the District Court of Los Angeles County.
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1 MICHAEL W . VIVOLI (Bar No. 184366)
JASON P . SACCUZZO (Bar No. 221837)
2 jsaccuzzo(a),vivolilaw.com
VIVOLI SACCUZZO, LLP
3 3104 Fomih Avenue
San Diego, California 92 103
4 (619) 744-9992 (Tel)
(619) 744-9994 (Fax)
5
Attorneys for Plaintiffs,
6 NATIONAL CAR WASHES , INC.,
7 and SHAHRlAR SHOUHED
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 IN AND FOR THE LOS ANGELES - CENTRAL DISTRICT
10
11
NATIONAL CAR WASHES, INC., a California ) CASE NO.: 21STCV05032
12 corporation; and SHAHRlAR SHOUHED, an ) [Assigned for All Purposes to Hon. Kristin S.
individual , ) Escalante, Dept. 24]
13 )
Plaintiffs, ) FIRST AMENDED COMPLAINT FOR
14
) DAMAGES, REMOVAL OF DIRECTOR
15 V. ) AND DECLARATORY AND
) INJUNCTIVE RELIEF
Electronically Received 09/13/2021 10:55 AM
16 SCOTT ALBERT ARDITI, an individual; )
EXPERT CAR WASHES, INC., a California )
17
corporation, as a nominal defendant as to )
18 derivative claims, and DOES 1 through 50, )
)
19 Defendants. )
20
_____ ___ _________ )
21 Plaintiffs, NATIONAL CAR WASHES , INC. ("National") and SHAHRlAR SHOUHED
22 ("Shouhed") (collectively, "P laintiffs") allege as fo llows:
23 PARTIES AND VENUE
24 1. National is a California corporation that maintains its primary place of business
25 within the County of Los Angeles.
26 2. Shouhed is an individual domiciled within the County of Los Angeles and is the
27 owner of 260 of the 1,000 issued and outstanding shares of Expert Car Washes, Inc. ("Expert")
28 and is a 50% voting principal of Expert. Shouhed also owns 13 5 of the 1000 issued and
COMPLA INT FOR DAMAGES AND EQUITABLE RELIEF
Document Filed Date
September 13, 2021
Case Filing Date
February 08, 2021
Category
Other Commercial/Business Tort (not fraud/ breach of contract) (General Jurisdiction)
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1 MICHAEL W . VIVOLI (Bar No. 184366) JASON P . SACCUZZO (Bar No. 221837) 2 jsaccuzzo(a),vivolilaw.com VIVOLI SACCUZZO, LLP 3 3104 Fomih Avenue San Diego, California 92 103 4 (619) 744-9992 (Tel) (619) 744-9994 (Fax) 5 Attorneys for Plaintiffs, 6 NATIONAL CAR WASHES , INC., 7 and SHAHRlAR SHOUHED 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE LOS ANGELES - CENTRAL DISTRICT 10 11 NATIONAL CAR WASHES, INC., a California ) CASE NO.: 21STCV05032 12 corporation; and SHAHRlAR SHOUHED, an ) [Assigned for All Purposes to Hon. Kristin S. individual , ) Escalante, Dept. 24] 13 ) Plaintiffs, ) FIRST AMENDED COMPLAINT FOR 14 ) DAMAGES, REMOVAL OF DIRECTOR 15 V. ) AND DECLARATORY AND ) INJUNCTIVE RELIEF Electronically Received 09/13/2021 10:55 AM 16 SCOTT ALBERT ARDITI, an individual; ) EXPERT CAR WASHES, INC., a California ) 17 corporation, as a nominal defendant as to ) 18 derivative claims, and DOES 1 through 50, ) ) 19 Defendants. ) 20 _____ ___ _________ ) 21 Plaintiffs, NATIONAL CAR WASHES , INC. ("National") and SHAHRlAR SHOUHED 22 ("Shouhed") (collectively, "P laintiffs") allege as fo llows: 23 PARTIES AND VENUE 24 1. National is a California corporation that maintains its primary place of business 25 within the County of Los Angeles. 26 2. Shouhed is an individual domiciled within the County of Los Angeles and is the 27 owner of 260 of the 1,000 issued and outstanding shares of Expert Car Washes, Inc. ("Expert") 28 and is a 50% voting principal of Expert. Shouhed also owns 13 5 of the 1000 issued and COMPLA INT FOR DAMAGES AND EQUITABLE RELIEF