Preview
PLD-PI-001
[ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: FOR COURT USE ONLY
Name: Albert Masjedian
FIRM NAME:
STREET ADDRESS: 137 South Palm Drive #503
city: Beverly Hills STATE: CA, ZIP CODE: 90212
TELEPHONE NO.: 213-820-3010 FAX NO.
EMAIL ADDRESS:
ATTORNEY FOR (name): Albert Masiedian. Plaintiff Pro Se
FILED
Su rior Court of California
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES inty of Los Angeles
STREET ADDRESS: 1725 Main Street
MAILING ADDRESS: -—— JUN 1.1 2024
CITY AND ZIP CODE: Santa Monica. California 90401
BRANCH NAME: West David W. Slayton, Executive Oficer/Cterk of Cou
PLAINTIFF: Albert Masigdian By: M. Elder, Deputy
DEFENDANT: Samuel Ruben, and
DOES 1 TO 100, inclusive
COMPLAINT—Personal Injury, Property Damage, Wrongful Death CASE NUMBER:
[) AMENDED (Number):
Type (check all that apply):
[J MOTOR VEHICLE
(] Property Damage
[] OTHER (specify): Tort/Violation of Statute
[__] Wrongful Death 24 sMcv02790
Personal Injury _[__] Other Damages (specify):
Jurisdiction (check all that apply):
[[_] ACTION IS A LIMITED CIVIL CASE (does not exceed $35,000)
Amount demanded [__] does not exceed $10,000
exceeds $10,000
[5c] ACTION IS AN UNLIMITED CIVIL CASE (exceeds $35,000)
[__] ACTION IS RECLASSIFIED by this amended complaint
[1 from limited to unlimited
[] from unlimited to limited
Plaintiff (name or names): Albert Masjedian
alleges causes of action against defendant (name or names):
Samuel Ruben, and Doe Defendants 1 to 100, inclusive
This pleading, including attachments and exhibits, consists of the following number of pages: Ss
Each plaintiff named above is a competent adult
a. [_] except plaintiff (name):
(1) 1] a corporation qualified to do business in California.
(2) (J an unincorporated entity (describe):
(3) [_] a public entity (describe):
(4) [J a minor (J) an adult
(a) [] for whom a guardian or conservator of the estate or a guardian ad litem has been appointed.
(b) [J other (specify):
(5) _] other (specify):
b. [] except plaintiff (name):
(41) ] a corporation qualified to do business in California.
(2) (] an unincorporated entity (describe):
(3) [_] a public entity (describe):
(4) [J a minor (-) an adult
(a) [_] for whom a guardian or conservator of the estate or a guardian ad litem has been appointed.
(o) [J other (specify):
(5) [_] other (specify):
[] Information about additional plaintiffs who are not competent adults is shown in Attachment 3.
Page 1 of 3
Form Approved for Optional Use COMPLAINT—Personal Injury, Property Code of Civil Procedure, § 425.12
Judicial Council of California www courts.ca.gov
PLD-PI-O01 (Rev. January 1, 2026) Damage, Wrongful Death
PLD-PI-001
SHORT TITLE: CASE NUMBER:
Albert Masjedian vs. Samuel Ruben, et al. 24 swev02798
4. [_] Plaintiff (name):
is doing business under the fictitious name (specify):
and has complied with the fictitious business name laws.
5. Each defendant named above is a natural person
a. [__] except defendant (name): c. [__] except defendant (name):
(1) (] a business organization, form unknown. (1) [--] a business organization, form unknown.
(2) (7) a corporation. (2) [J a corporation.
(3) [J an unincorporated entity (describe): (3) [J an unincorporated entity (describe):
(4) [_] a public entity (describe): (4) [] a public entity (describe):
(5) [] other (specify): (5) [J other (specify):
b. [-_] except defendant (name): d. [__] except defendant (name):
(1) [) a business organization, form unknown. (1) [) a business organization, form unknown.
(2) [_] a corporation. (2) FJ a corporation.
(3) [J an unincorporated entity (describe): (3) [_] an unincorporated entity (describe):
(4) (] a public entity (describe): (4) [=] a public entity (describe):
(5) [_] other (specify): (5) [__] other (specify):
[1 Information about additional defendants who are not natural persons is contained in Attachment 5.
The true names of defendants sued as Does are unknown to plaintiff.
a. [3] Doe defendants (specify Doe numbers): 1 to 50 were the agents or employees of other
named defendants and acted within the scope of that agency or employment.
b. [5c] Doe defendants (specify Doe numbers): 51 to 100 are persons whose capacities are unknown to
plaintiff.
[—_)Defendants who are joined under Code of Civil Procedure section 382 are (names):
This court is the proper court because
a. . [] atleast one defendant now resides in its jurisdictional area.
b. . [-_] the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area.
c. - [<7 injury to person or damage to personal property occurred in its jurisdictional area.
d. |. [_] other (specify):
. [_] Plaintiff is required to comply with a claims statute, and
a. [__] has complied with applicable claims statutes, or
b. [__] is excused from complying because (specify):
PLD-PI-001 [Rev. January 1, 2024] COMPLAINT—Personal Injury, Property Page
2 of 3
Damage, Wrongful Death
PLD-PI-001
SHORT TITLE: MBER:
DI\GEAT WASTED
AN V5 SAmvel Roesn 24 a\- 4 Mev 0279 9
10. The following causes of action are attached and the statements above apply to each (each complaint must have one or more
causes of action attached):
a. [__] Motor Vehicle
b. [__] General Negligence
©. » [_] Intentional Tort
d. [__] Products Liability
e. [__] Premises Liability
f. [Ec] Other (specify):
Statutory Liability
11 Plaintiff has suffered (check all that apply)
a [-) wage loss.
. [€] loss of use of property.
. [_] hospital and medical expenses.
[Ec general damage.
- [] property damage.
[] loss of earning capacity.
. [3c] other damage (specify):
Statutory Penalties
12.["_] The damages claimed for wrongful death and the relationships of plaintiff to the deceased are
a. [__] listed in Attachment 12.
b. [_] as follows:
13. The relief sought in this complaint is within the jurisdiction of this court.
14, Plaintiff prays for judgment for costs of suit; for such relief as is fair, just, and equitable; and for
a. (1) [3¢] compensatory damages.
(2) [3<] punitive damages.
The amount of damages is (in cases for personal injury or wrongful death, you must check (1)):
(1) [52] according to proof.
(2) [_] in the amount of: $
15. [__] The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers):
Date: June 10, 2024
Albert Masjedian
(TYPE OR PRINT NAME)
a Mee
(SIGNA PORE OF PLAINTIFF OR ATTORNEY)
PLD-PI-001 [Rev. January 1, 2024] COMPLAINT—Personal Injury, Property Page
3 of 3
Damage, Wrongful Death
For your protection and privacy, please press the Clear
This Form button after you have printed the form. [Print this form | [ Save this form | [eee oie)
PLD-PI-001 (3)
SHORT TITLE:
Masjedian vs. Ruben
CASE
egucy 0279 0
First CAUSE OF ACTION—Intentional Tort Page 4
(number)
ATTACHMENT TO = [X_] Complaint [) Cross - Complaint
(Use a separate cause of action form for each cause of action.)
IT-1. Plaintiff (name): Albert Masjedian ("Plaintiff") incorporates pages 1-3 of this complaint herein, and
alleges that defendant (name): Samuel Ruben ("Defendant') engaged in intentional wrongdoing, along with
x] Does 1 to 100
was the legal (proximate) cause of damages to plaintiff. By the following acts or omissions to act, defendant intentionally
caused the damage to plaintiff
on (date): or about May 3, 2024
at (place): 137 S. Palm Drive #503, Beverly Hills, California 90212
(description of reasons for liability):
that after the Plaintiff, in early March 2024, entered into a lease with the Defendant as to the above indicated address, the
Defendant began to harass the Plaintiff in retaliation, including an attempted wrongful retaliatory eviction, for the Plaintiff
having complained about breaches occurring which violated the implied warranty of habitability, including no working clothes
washer, no drainage of the kitchen sink, the air conditioner does not work, lo window covers, and a non-functioning intercom,
as to the subject address in violation of every governing and relevant Civil Code Section.
Page 1 of 1
‘Form Approved for Optional Use Code of Givi Procedure, § 425.12
Judicial Councd of California CAUSE OF ACTION—Intentional Tort wwrw.courts.ca.gov
PLD-PI-001(3) [Rev. January 1, 2007]
For your protection and privacy, please press the Clear
This Form button after you have printed the form. [Print
this form | [ Save this form |
PLD-PI-001(3)
SHORT TITLE: CASE WiC Q?2 79
Masjedian vs. Ruben
Second CAUSE OF ACTION—Intentional Tort Page 5
(number)
ATTACHMENT TO [X_] Complaint [] Cross - Complaint
(Use a separate cause of action form for each cause of action.)
IT-1. Plaintiff (name): Albert Masjedian ("Plaintiff") incorporates pages 1-3 of this complaint herein, and
alleges that defendant (name): Samuel Ruben ("Defendant’) engaged in intentional wrongdoing, along with
x] Does 4 to 100
was the legal (proximate) cause of damages to plaintiff. By the following acts or omissions to act, defendant intentionally
caused the damage to plaintiff
on (date): or about May 3, 2024
at (place): 137 S. Palm Drive #503, Beverly Hills, California 90212
(description of reasons for liability):
The Plaintiff is suing the Defendant and the Doe Defendants for Intentional Infliction of Emotional Distress as, after the
Plaintiff, in early March 2024, entered into a lease with the Defendant as to the above indicated address, the Defendant
began to harass the Plaintiff in retaliation, including an attempted wrongful retaliatory eviction, for the Plaintiff having
complained about breaches occurring which violated the implied warranty of habitability, including no working clothes
washer, no drainage of the kitchen sink, the air conditioner does not work, lo window covers, and a non-functioning intercom,
as to the subject address in violation of every governing and relevant Civil Code Section.
Page 1 of 1
Form Approved for Optional Use Codeof Civil Procedure, § 425.12
Judicial Counct of California CAUSE OF ACTION—Intentional Tort www courts.ca.gov
PLD-PI-001(3) [Rev. January 1, 2007}
For your protection and privacy, please press the Clear
This Form button after you have printed the form. [Print
this form | | Save this form |
Preview
PLD-PI-001 [ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: FOR COURT USE ONLY Name: Albert Masjedian FIRM NAME: STREET ADDRESS: 137 South Palm Drive #503 city: Beverly Hills STATE: CA, ZIP CODE: 90212 TELEPHONE NO.: 213-820-3010 FAX NO. EMAIL ADDRESS: ATTORNEY FOR (name): Albert Masiedian. Plaintiff Pro Se FILED Su rior Court of California SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES inty of Los Angeles STREET ADDRESS: 1725 Main Street MAILING ADDRESS: -—— JUN 1.1 2024 CITY AND ZIP CODE: Santa Monica. California 90401 BRANCH NAME: West David W. Slayton, Executive Oficer/Cterk of Cou PLAINTIFF: Albert Masigdian By: M. Elder, Deputy DEFENDANT: Samuel Ruben, and DOES 1 TO 100, inclusive COMPLAINT—Personal Injury, Property Damage, Wrongful Death CASE NUMBER: [) AMENDED (Number): Type (check all that apply): [J MOTOR VEHICLE (] Property Damage [] OTHER (specify): Tort/Violation of Statute [__] Wrongful Death 24 sMcv02790 Personal Injury _[__] Other Damages (specify): Jurisdiction (check all that apply): [[_] ACTION IS A LIMITED CIVIL CASE (does not exceed $35,000) Amount demanded [__] does not exceed $10,000 exceeds $10,000 [5c] ACTION IS AN UNLIMITED CIVIL CASE (exceeds $35,000) [__] ACTION IS RECLASSIFIED by this amended complaint [1 from limited to unlimited [] from unlimited to limited Plaintiff (name or names): Albert Masjedian alleges causes of action against defendant (name or names): Samuel Ruben, and Doe Defendants 1 to 100, inclusive This pleading, including attachments and exhibits, consists of the following number of pages: Ss Each plaintiff named above is a competent adult a. [_] except plaintiff (name): (1) 1] a corporation qualified to do business in California. (2) (J an unincorporated entity (describe): (3) [_] a public entity (describe): (4) [J a minor (J) an adult (a) [] for whom a guardian or conservator of the estate or a guardian ad litem has been appointed. (b) [J other (specify): (5) _] other (specify): b. [] except plaintiff (name): (41) ] a corporation qualified to do business in California. (2) (] an unincorporated entity (describe): (3) [_] a public entity (describe): (4) [J a minor (-) an adult (a) [_] for whom a guardian or conservator of the estate or a guardian ad litem has been appointed. (o) [J other (specify): (5) [_] other (specify): [] Information about additional plaintiffs who are not competent adults is shown in Attachment 3. Page 1 of 3 Form Approved for Optional Use COMPLAINT—Personal Injury, Property Code of Civil Procedure, § 425.12 Judicial Council of California www courts.ca.gov PLD-PI-O01 (Rev. January 1, 2026) Damage, Wrongful Death PLD-PI-001 SHORT TITLE: CASE NUMBER: Albert Masjedian vs. Samuel Ruben, et al. 24 swev02798 4. [_] Plaintiff (name): is doing business under the fictitious name (specify): and has complied with the fictitious business name laws. 5. Each defendant named above is a natural person a. [__] except defendant (name): c. [__] except defendant (name): (1) (] a business organization, form unknown. (1) [--] a business organization, form unknown. (2) (7) a corporation. (2) [J a corporation. (3) [J an unincorporated entity (describe): (3) [J an unincorporated entity (describe): (4) [_] a public entity (describe): (4) [] a public entity (describe): (5) [] other (specify): (5) [J other (specify): b. [-_] except defendant (name): d. [__] except defendant (name): (1) [) a business organization, form unknown. (1) [) a business organization, form unknown. (2) [_] a corporation. (2) FJ a corporation. (3) [J an unincorporated entity (describe): (3) [_] an unincorporated entity (describe): (4) (] a public entity (describe): (4) [=] a public entity (describe): (5) [_] other (specify): (5) [__] other (specify): [1 Information about additional defendants who are not natural persons is contained in Attachment 5. The true names of defendants sued as Does are unknown to plaintiff. a. [3] Doe defendants (specify Doe numbers): 1 to 50 were the agents or employees of other named defendants and acted within the scope of that agency or employment. b. [5c] Doe defendants (specify Doe numbers): 51 to 100 are persons whose capacities are unknown to plaintiff. [—_)Defendants who are joined under Code of Civil Procedure section 382 are (names): This court is the proper court because a. . [] atleast one defendant now resides in its jurisdictional area. b. . [-_] the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area. c. - [<7 injury to person or damage to personal property occurred in its jurisdictional area. d. |. [_] other (specify): . [_] Plaintiff is required to comply with a claims statute, and a. [__] has complied with applicable claims statutes, or b. [__] is excused from complying because (specify): PLD-PI-001 [Rev. January 1, 2024] COMPLAINT—Personal Injury, Property Page 2 of 3 Damage, Wrongful Death PLD-PI-001 SHORT TITLE: MBER: DI\GEAT WASTED AN V5 SAmvel Roesn 24 a\- 4 Mev 0279 9 10. The following causes of action are attached and the statements above apply to each (each complaint must have one or more causes of action attached): a. [__] Motor Vehicle b. [__] General Negligence ©. » [_] Intentional Tort d. [__] Products Liability e. [__] Premises Liability f. [Ec] Other (specify): Statutory Liability 11 Plaintiff has suffered (check all that apply) a [-) wage loss. . [€] loss of use of property. . [_] hospital and medical expenses. [Ec general damage. - [] property damage. [] loss of earning capacity. . [3c] other damage (specify): Statutory Penalties 12.["_] The damages claimed for wrongful death and the relationships of plaintiff to the deceased are a. [__] listed in Attachment 12. b. [_] as follows: 13. The relief sought in this complaint is within the jurisdiction of this court. 14, Plaintiff prays for judgment for costs of suit; for such relief as is fair, just, and equitable; and for a. (1) [3¢] compensatory damages. (2) [3<] punitive damages. The amount of damages is (in cases for personal injury or wrongful death, you must check (1)): (1) [52] according to proof. (2) [_] in the amount of: $ 15. [__] The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers): Date: June 10, 2024 Albert Masjedian (TYPE OR PRINT NAME) a Mee (SIGNA PORE OF PLAINTIFF OR ATTORNEY) PLD-PI-001 [Rev. January 1, 2024] COMPLAINT—Personal Injury, Property Page 3 of 3 Damage, Wrongful Death For your protection and privacy, please press the Clear This Form button after you have printed the form. [Print this form | [ Save this form | [eee oie) PLD-PI-001 (3) SHORT TITLE: Masjedian vs. Ruben CASE egucy 0279 0 First CAUSE OF ACTION—Intentional Tort Page 4 (number) ATTACHMENT TO = [X_] Complaint [) Cross - Complaint (Use a separate cause of action form for each cause of action.) IT-1. Plaintiff (name): Albert Masjedian ("Plaintiff") incorporates pages 1-3 of this complaint herein, and alleges that defendant (name): Samuel Ruben ("Defendant') engaged in intentional wrongdoing, along with x] Does 1 to 100 was the legal (proximate) cause of damages to plaintiff. By the following acts or omissions to act, defendant intentionally caused the damage to plaintiff on (date): or about May 3, 2024 at (place): 137 S. Palm Drive #503, Beverly Hills, California 90212 (description of reasons for liability): that after the Plaintiff, in early March 2024, entered into a lease with the Defendant as to the above indicated address, the Defendant began to harass the Plaintiff in retaliation, including an attempted wrongful retaliatory eviction, for the Plaintiff having complained about breaches occurring which violated the implied warranty of habitability, including no working clothes washer, no drainage of the kitchen sink, the air conditioner does not work, lo window covers, and a non-functioning intercom, as to the subject address in violation of every governing and relevant Civil Code Section. Page 1 of 1 ‘Form Approved for Optional Use Code of Givi Procedure, § 425.12 Judicial Councd of California CAUSE OF ACTION—Intentional Tort wwrw.courts.ca.gov PLD-PI-001(3) [Rev. January 1, 2007] For your protection and privacy, please press the Clear This Form button after you have printed the form. [Print this form | [ Save this form | PLD-PI-001(3) SHORT TITLE: CASE WiC Q?2 79 Masjedian vs. Ruben Second CAUSE OF ACTION—Intentional Tort Page 5 (number) ATTACHMENT TO [X_] Complaint [] Cross - Complaint (Use a separate cause of action form for each cause of action.) IT-1. Plaintiff (name): Albert Masjedian ("Plaintiff") incorporates pages 1-3 of this complaint herein, and alleges that defendant (name): Samuel Ruben ("Defendant’) engaged in intentional wrongdoing, along with x] Does 4 to 100 was the legal (proximate) cause of damages to plaintiff. By the following acts or omissions to act, defendant intentionally caused the damage to plaintiff on (date): or about May 3, 2024 at (place): 137 S. Palm Drive #503, Beverly Hills, California 90212 (description of reasons for liability): The Plaintiff is suing the Defendant and the Doe Defendants for Intentional Infliction of Emotional Distress as, after the Plaintiff, in early March 2024, entered into a lease with the Defendant as to the above indicated address, the Defendant began to harass the Plaintiff in retaliation, including an attempted wrongful retaliatory eviction, for the Plaintiff having complained about breaches occurring which violated the implied warranty of habitability, including no working clothes washer, no drainage of the kitchen sink, the air conditioner does not work, lo window covers, and a non-functioning intercom, as to the subject address in violation of every governing and relevant Civil Code Section. Page 1 of 1 Form Approved for Optional Use Codeof Civil Procedure, § 425.12 Judicial Counct of California CAUSE OF ACTION—Intentional Tort www courts.ca.gov PLD-PI-001(3) [Rev. January 1, 2007} For your protection and privacy, please press the Clear This Form button after you have printed the form. [Print this form | | Save this form |