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ELECTRONICALLY FILED
N. Stephen Vokshori (SBN 245570) SUPERIOR COURT OF CALIFOR NIA
COUNTY OF SAN BERNARDINO
VOKSHORI LAW GROUP, APC SAN BERNARDINO DISTRICT
1010 Wilshire B1Vd., Ste. 1404
Los Angeles, California 90017 10/20/2023 2:26 PM
Telephone: (213) 986-4323
Facsimile: (3 10) 881-6996
By: Leanne Landeros, DEPUTY
Email: stephen@vok1aw.com
Attorneys for Plaintiff JOHN MAJIDI, as Trustee 0f the JZMM
FAMILY TRUST
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO
10
UNLIMITED CIVIL JURISDICTION
11
CIVSBZ326678
12 JOHN MAJIDI, as Trustee 0f the JZMM CASE NOO:
FAMILY TRUST,
13 VERIFIED COMPLAINT FOR:
Plaintiff,
14 1. QUIET TITLE; AND
V. 2. DECLARATORY RELIEF
15
STATE OF CALIFORNIA, a DEMAND FOR JURY TRIAL
16 entity; PORTFOLIO
governmental
RECOVERY ASSOCIATES, LLC, a [Code Civ. Proc. §§ 701.630 and 726]
17 limited liability company; AMERICAN
LEGAL INVESTIGATION SERVICES,
18 INC., a corporation; and DOES 1-100,
inclusive,
19
Defendants.
20
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22 COMES NOW Plaintiff JOHN MAJIDI, as Trustee 0f the JZMM FAMILY TRUST
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(hereinafter, “Plaintiff”), Who hereby complains and alleges in this Complaint against Defendants
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STATE OF CALIFORNIA, a governmental entity; PORTFOLIO RECOVERY ASSOCIATES,
25
LLC, a limited liability company; AMERICAN LEGAL INVESTIGATION SERVICES, INC., a
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corporation; and DOES 1-100 (collectively, “Defendants”), inclusive as follows:
27
28
1.
VERIFIED COMPLAINT
PARTIES
1. Plaintiff, JOHN MAJIDI, at all times mentioned herein, is and was an individual
acting as trustee of the JZMM FAMILY TRUST, residing in the State 0f California, County 0f
Contra Costa.
2. Plaintiff alleges upon information and belief that Defendant STATE OF
CALIFORNIA, at all relevant times, is and was a governmental entity with its principal seat of
government in California, regularly conducting business Within the state.
3. Plaintiff alleges upon information and belief that Defendant PORTFOLIO
RECOVERY ASSOCIATES, LLC, at all relevant times, is and was a limited liability company
10
registered t0 conduct business in California.
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4. Defendant AMERICAN LEGAL INVESTIGATION SERVICES, INC., at all
12
times mentioned herein, is and was a corporation With its principal place 0f business in
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Sacramento County, California, regularly conducting business within the state.
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5. The true identities 0f Defendants named as Doe 1 through Doe 100 are currently
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unknown to Plaintiff, Who sues them by these fictitious names. Plaintiff Will seek to amend this
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complaint When their true identities and capacities are discovered. Plaintiff alleges on information
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and belief that each fictitiously named defendant is in some way responsible for the actions
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alleged herein and that Plaintiffs damages were proximately caused by them.
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6. Plaintiff alleges on information and belief that at all times mentioned, Defendants,
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and each 0f them, acted 0n their own behalf and/or as the agents, employees, partners, joint
21
venturers, or representatives of the other Defendants. The acts of each Defendant, as alleged
22
herein, were authorized, ratified, or directed by the other Defendants.
23
JURISDICTION AND VENUE
24 7. This action affects title and possession of certain real property located in San
25 Bernardino County, California, commonly known as 14365 Pleasant Hill Drive, Chino Hills, CA
26 91709 (the "Property") and more specifically described as:
27 Lot 101 0f Tract N0. 1365 1-12, in the City 0f Chino, County 0f San
28 Bernardino, State 0f California, as per plat recorded in Book 227, Page(s)
2.
VERIFIED COMPLAINT
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ELECTRONICALLY FILED N. Stephen Vokshori (SBN 245570) SUPERIOR COURT OF CALIFOR NIA COUNTY OF SAN BERNARDINO VOKSHORI LAW GROUP, APC SAN BERNARDINO DISTRICT 1010 Wilshire B1Vd., Ste. 1404 Los Angeles, California 90017 10/20/2023 2:26 PM Telephone: (213) 986-4323 Facsimile: (3 10) 881-6996 By: Leanne Landeros, DEPUTY Email: stephen@vok1aw.com Attorneys for Plaintiff JOHN MAJIDI, as Trustee 0f the JZMM FAMILY TRUST SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO 10 UNLIMITED CIVIL JURISDICTION 11 CIVSBZ326678 12 JOHN MAJIDI, as Trustee 0f the JZMM CASE NOO: FAMILY TRUST, 13 VERIFIED COMPLAINT FOR: Plaintiff, 14 1. QUIET TITLE; AND V. 2. DECLARATORY RELIEF 15 STATE OF CALIFORNIA, a DEMAND FOR JURY TRIAL 16 entity; PORTFOLIO governmental RECOVERY ASSOCIATES, LLC, a [Code Civ. Proc. §§ 701.630 and 726] 17 limited liability company; AMERICAN LEGAL INVESTIGATION SERVICES, 18 INC., a corporation; and DOES 1-100, inclusive, 19 Defendants. 20 21 22 COMES NOW Plaintiff JOHN MAJIDI, as Trustee 0f the JZMM FAMILY TRUST 23 (hereinafter, “Plaintiff”), Who hereby complains and alleges in this Complaint against Defendants 24 STATE OF CALIFORNIA, a governmental entity; PORTFOLIO RECOVERY ASSOCIATES, 25 LLC, a limited liability company; AMERICAN LEGAL INVESTIGATION SERVICES, INC., a 26 corporation; and DOES 1-100 (collectively, “Defendants”), inclusive as follows: 27 28 1. VERIFIED COMPLAINT PARTIES 1. Plaintiff, JOHN MAJIDI, at all times mentioned herein, is and was an individual acting as trustee of the JZMM FAMILY TRUST, residing in the State 0f California, County 0f Contra Costa. 2. Plaintiff alleges upon information and belief that Defendant STATE OF CALIFORNIA, at all relevant times, is and was a governmental entity with its principal seat of government in California, regularly conducting business Within the state. 3. Plaintiff alleges upon information and belief that Defendant PORTFOLIO RECOVERY ASSOCIATES, LLC, at all relevant times, is and was a limited liability company 10 registered t0 conduct business in California. 11 4. Defendant AMERICAN LEGAL INVESTIGATION SERVICES, INC., at all 12 times mentioned herein, is and was a corporation With its principal place 0f business in 13 Sacramento County, California, regularly conducting business within the state. 14 5. The true identities 0f Defendants named as Doe 1 through Doe 100 are currently 15 unknown to Plaintiff, Who sues them by these fictitious names. Plaintiff Will seek to amend this 16 complaint When their true identities and capacities are discovered. Plaintiff alleges on information 17 and belief that each fictitiously named defendant is in some way responsible for the actions 18 alleged herein and that Plaintiffs damages were proximately caused by them. 19 6. Plaintiff alleges on information and belief that at all times mentioned, Defendants, 20 and each 0f them, acted 0n their own behalf and/or as the agents, employees, partners, joint 21 venturers, or representatives of the other Defendants. The acts of each Defendant, as alleged 22 herein, were authorized, ratified, or directed by the other Defendants. 23 JURISDICTION AND VENUE 24 7. This action affects title and possession of certain real property located in San 25 Bernardino County, California, commonly known as 14365 Pleasant Hill Drive, Chino Hills, CA 26 91709 (the "Property") and more specifically described as: 27 Lot 101 0f Tract N0. 1365 1-12, in the City 0f Chino, County 0f San 28 Bernardino, State 0f California, as per plat recorded in Book 227, Page(s) 2. VERIFIED COMPLAINT