Complaint,Petition: ERICA MARIE ANDERSSON VS KIOMARS NAGHDI, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 06/26/2019 05:48 PM Sherri R. Carter, Executive Officer/Clerk of Court, by R. Clifton,Deputy Clerk
                                                                                       19STCV22427
                                         Assigned for all purposes to: Stanley Mosk Courthouse, Judicial Officer: Holly Fujie



               1      THE MARGARIAN LAW FIRM
                      HOVANES MARGARIAN, SBN 246359
               2      SHUSHANIK MARGARIAN, SBN 318617
                      801 N. Brand Boulevard, Suite 210
               3      Glendale, California 91203
                      Telephone Number:       (818) 553-1000
               4      Facsimile Number:       (818) 553-1005
               5      Attorneys for Plaintiff,
                      ERICA MARIE ANDERSSON
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               8                                       SUPERIOR COURT OF THE STATE OF CALIFORNIA
               9                                FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT
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             11        ERICA MARIE ANDERSSON, an                  ) Case No.:
                       individual,                                )
             12                                                   )
                             Plaintiff,                           ) PLAINTIFF’S COMPLAINT FOR DAMAGES
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                       vs.                                        )
             14                                                   )
                       KIOMARS NAGHDI, an individual; AUTO )
             15        WHOLESALE OUTLET, form of entity           )
                       unknown; and DOES 1 through 30, inclusive, )
             16                                                   )
                             Defendants.                          )
             17                                                   )
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                                                                               NATURE OF THE ACTION
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                                NOW COMES the Plaintiff ERICA MARIE ANDERSSON, an individual, by and through
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                      Plaintiff’s attorneys The Margarian Law Firm with Plaintiff’s Complaint for Damages against
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                      Defendants, KIOMARS NAGHDI, an individual; AUTO WHOLESALE OUTLET, form of entity
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                      unknown; and DOES 1 through 30, inclusive.
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                                Plaintiff is informed and believes, and based thereon alleges, that Defendants sold Plaintiff a 2003
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                      Ford F250 bearing VIN 1FTNW20P73ED19156 (“Subject Vehicle”), that Defendants were fully aware
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                      of having been previously exhibited nonconformities which rendered it unmerchantable. Plaintiff was
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                      sold the Subject Vehicle without any reference to its unmerchantable condition. Instead, Defendants
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                      verbally assured Plaintiff that the vehicle was in excellent mechanical condition. Furthermore,
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                      Defendants failed to smog check the vehicle and embezzled Plaintiff’s payment towards the vehicle’s

                                                                        PLAINTIFF’S COMPLAINT FOR DAMAGES