Complaint,Petition: LINCOLN CENTER, LLC, A CALIFORNIA LIMITED LIABILITY COMPANY VS ALPHA BETA COMPANY, A CALIFORNIA CORPORATION, ET AL.

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                                19SMUD02528
                                 Assigned for all purposes to: Santa Monica Courthouse, Judicial Officer: Lisa Sepe-Wiesenfeld


Electronically FILED by Superior Court of California, County of Los Angeles on 12/13/2019 01:53 PM Sherri R. Carter, Executive Officer/Clerk of Court, by D. Fowler,Deputy Clerk


                         Dean P. Sperling
                         State Bar No. 82936
                         LAW OFFICE OF DEAN P. SPERLING
                         114 Pacifica, Suite 250
                         Irvine, California 92618
                         Telephone: (949) 333-6540

                         Attorneys for Plaintiff, Lincoln Center, LLC, a California limited liability company,
                         successor in interest to Earl H. Schafer and Sallie Jac Schafer
                                                    SUPERIOR COURT OF THE STATE OF CALIFORNIA
                                 FOR THE COUNTY OF LOS ANGELES, SANTA MONICA COURTHOUSE

                              LINCOLN CENTER, LLC, a California limited )                                         CASE NO.
                              liability company, successor in interest to Earl )
                 10           H. Schafer and Sallie Jac Schafer,               )                                  VERIFIED COMPLAINT FOR
                                                                                                            )     UNLA WFUL DETAINER
                                                                          Plaintiff,                        )
                                                   vs.                                                      )     [UNLIMITED JURISDICTION]
                 12                                                                                         )
                            ALPHA BETA COMPANY, a California
                 13         corporation, legal assignee of The I&roger
                            Company, a Ohio corporation; RALPHS
                 14         GROCERY COMPANY, a Ohio corporation;
                            and DOES 1 through 30, inclusive,
                 15
                                                                          Defendants.
                 16

                 17                 P 1ainti ff, LINCOLN CENTER, LLC, a California limited liability company, successor

                 18      in interest to Earl H. Schafer and Sallie Jac Schafer, do hereby allege as follows:

                 19                                                                           Parties
                 20      A.         Plaintiff
                 21                  1.         Plaintiff, LINCOLN CENTER, LLC, a California limited liability company,
                 22      successor in interest to Earl H. Schafer and Sallie Jac Schafer is, and was, a California
                 23      limited liability company and duly authorized and licensed to conduct business in the County
                 24      of Los Angeles State of California, with its principal place ofbusiness in the City of Venice,
                 25      County of Los Angeles State of California.
                 26      B.         Named Part Defendant
                 27                 2.          Plaintiff is informed and believes and upon such information and belief alleges
                 28      that Defendant ALPHA BETA COMPANY, a California corporation, legal assignee of The


                                                                   Verified Complaint for Unlawful Detainer