On January 26, 2016 a
Motion-Secondary
was filed
involving a dispute between
Moda Kevin,
and
Brivanlou Pacoima Llc,
Hakak Mahin,
Harold Igdaloff Trustee Of The Igdaloff,
for Other Real Property (not eminent domain, landlord/tenant, foreclosure) (General Jurisdiction)
in the District Court of Los Angeles County.
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®
Shari Rosenthal, Esq. (State Bar No. 123083)
Sharon S. Jeffrey, Esq. (State Bar No, 228149)
Manning & Kass, Ellrod, Ramirez Trester LLP Super
FI LED
Court of Ca
801 South Figueroa Street, 15" Floor ounty of Los Annela
s
Los Angeles, CA 90017
Tel: (213) 624-6900 AUG 07 2017
Fax: (213) 624-6999
opel
Sherri i oe Exe utive Oiticer/Cierk
By
Attorneys for Defendants BRIVANLOU PACOIMA, LC, MAHIN HA! Raul Sanchez Deputy
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES, CENTRAL DISTRICT
10
KEVIN MODA, Case No. BC608383
(Hon. Maureen Duffy Lewis; Dept. 38]
11
Plaintiff,
REPLY TO OPPOSITION TO AMENDED
12
MOTION FOR JUDGMENT ON THE
Ba Vv.
PLEADINGS
13
se
ne
BRIVANLOU PACOIMA, LC, MAHIN
Be HAKAK, and DOES 1 -10, Inclusive, Date: August 14, 2017
me 14
ge Time: 9:30 AM
Defendants Dept: 38
15 Reservation #: 161111173426
16
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Defendant Brivanlou Pacoima and Mahin Hakak reply to Plaintiff's Opposition to the
18
Motion for Judgment on the Pleadings as follows:
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Plaintiff claims that the First Cause of Action for breach of contract against Brivanlou
20
Pacoima, LLC, is because "its managing member, co-defendant Hakak was/is a fraudster. She
21
would take the checks of the Plaintiff and alter the checks notations to reflect a month for which
22
rent was already paid and then demand rents again." This claim was already litigated in the
23
unlawful detainer trial adversely to Plaintiff. To the contrary, the Court determined that
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Defendant (Kevin Moda) "did not tender a sufficient number of good checks to Plaintiff by which
25
he paid all rent due through February 2016. There was at least a month shortfall which appears
26
oa attributable to a rent check for July 2015 which was returned unpaid." No fraud on the part of Ms.
27
Hakak or Brivanlou was found.
28
4852-2564-4876.1 1
REPLY TO OPPOSITION TO AMENDED MOTION FOR JUDGMENT ON THE PLEADINGS
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® Shari Rosenthal, Esq. (State Bar No. 123083) Sharon S. Jeffrey, Esq. (State Bar No, 228149) Manning & Kass, Ellrod, Ramirez Trester LLP Super FI LED Court of Ca 801 South Figueroa Street, 15" Floor ounty of Los Annela s Los Angeles, CA 90017 Tel: (213) 624-6900 AUG 07 2017 Fax: (213) 624-6999 opel Sherri i oe Exe utive Oiticer/Cierk By Attorneys for Defendants BRIVANLOU PACOIMA, LC, MAHIN HA! Raul Sanchez Deputy SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES, CENTRAL DISTRICT 10 KEVIN MODA, Case No. BC608383 (Hon. Maureen Duffy Lewis; Dept. 38] 11 Plaintiff, REPLY TO OPPOSITION TO AMENDED 12 MOTION FOR JUDGMENT ON THE Ba Vv. PLEADINGS 13 se ne BRIVANLOU PACOIMA, LC, MAHIN Be HAKAK, and DOES 1 -10, Inclusive, Date: August 14, 2017 me 14 ge Time: 9:30 AM Defendants Dept: 38 15 Reservation #: 161111173426 16 17 Defendant Brivanlou Pacoima and Mahin Hakak reply to Plaintiff's Opposition to the 18 Motion for Judgment on the Pleadings as follows: 19 Plaintiff claims that the First Cause of Action for breach of contract against Brivanlou 20 Pacoima, LLC, is because "its managing member, co-defendant Hakak was/is a fraudster. She 21 would take the checks of the Plaintiff and alter the checks notations to reflect a month for which 22 rent was already paid and then demand rents again." This claim was already litigated in the 23 unlawful detainer trial adversely to Plaintiff. To the contrary, the Court determined that 24 Defendant (Kevin Moda) "did not tender a sufficient number of good checks to Plaintiff by which 25 he paid all rent due through February 2016. There was at least a month shortfall which appears 26 oa attributable to a rent check for July 2015 which was returned unpaid." No fraud on the part of Ms. 27 Hakak or Brivanlou was found. 28 4852-2564-4876.1 1 REPLY TO OPPOSITION TO AMENDED MOTION FOR JUDGMENT ON THE PLEADINGS