Complaint,Petition: ALAMEDA SQUARE OWNER LLC VS TARTINE RESTAURANT GROUP, LLC, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 12/03/2019 03:26 PM Sherri R. Carter, Executive Officer/Clerk of Court, by R. Perez,Deputy Clerk
                                                                                       19STCV43248
                                        Assigned for all purposes to: Stanley Mosk Courthouse, Judicial Officer: Susan Bryant-Deason




                          1 Daniel L. Goodkin, Esq. (SBN 131347)
                            Email: dgoodkin@goodkinlaw.com
                          2 Gregory J. Maestri, Esq. (SBN 307332)
                            Email: gmaestri@goodkinlaw.com
                          3 GOODKIN LAW GROUP, APC
                            1800 Century Park East, 10th Floor
                          4 Los Angeles, California 90067
                            Telephone: (310) 552-3322
                          5 Facsimile: (310) 943-1589

                          6 Attorneys for Plaintiff,
                            ALAMEDA SQUARE OWNER LLC,
                          7 a Delaware limited liability company

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                          9                                SUPERIOR COURT OF THE STATE OF CALIFORNIA
                        10                                    FOR THE COUNTY OF LOS ANGELES - CENTRAL
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                        12 ALAMEDA     SQUARE OWNER LLC, a                                                    CASE NO.:
                           Delaware limited liability company,
                                                                                                              VERIFIED COMPLAINT FOR
                        13               Plaintiff,                                                           UNLAWFUL DETAINER
                        14                                                                                    [Unlimited Civil]
                                           vs.
                        15 TARTINE RESTAURANT GROUP, LLC, a

                        16 Delaware limited liability company,
                           MANUFACTORY LA, LLC, a California
                        17 limited liability company, and DOES 1 through
                           20, inclusive,
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                                            Defendants.
                        19

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                                           Plaintiff ALAMEDA SQUARE OWNER LLC, a Delaware limited liability company
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                               (“Plaintiff” or “Landlord”) hereby complains and alleges as follows:
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                                           A. The Parties
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                                           1.         At all times mentioned herein, Plaintiff was and is now a Delaware limited liability
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                               company, qualified to and lawfully doing business in the County of Los Angeles, State of
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                               California.
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                                           2.         Plaintiff alleges, on information and belief, that at all times mentioned herein,
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                               Defendant TARTINE RESTAURANT GROUP, LLC (“Tartine” or “Office Tenant”) was and is a
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                               10066.142                                                                  1
                                                                     VERIFIED COMPLAINT FOR UNLAWFUL DETAINER