H|||||||||||||||llllll||l|||lllllllllflllIlllilllIlllllllllllllllililli
`
`SUPERIOR COURT OF CALIFORNIA
`
`COUNTY OF SAN FRANCISCO
`
`DocUment Scanning Lead Sheet
`Oct-11-2018 8:55 am
`
`Case Number: CGC-18—570435
`
`Filing Date: Oct-11-2018 8:44
`
`COMPLAINT
`
`Filed by: NEYL WEBB
`
`Image: 06529612
`
`LANCE ECANDER ET AL VS; VERITAS INCESTMENTS, INC. ET AL
`
`001C06529612
`
`.
`.
`Instructions:
`Please place this sheet on top of the document to be scanned.
`
`

`

`
`
`
`‘ 3 '
`CM-0107
`
`FOR COURT USE ONLY
`
`
`ATTORNEY OR PARTY WITHOUT ATTORNEY game State Barnumber, and address
`lchael A. Schreiber (SBiN 271611)
`Ryan J. Vlasak (SBN 241581);
`BRACAMONTES & VLASAK, P C.
`
`
`220 Montgomery Street, Suite 870
`F I L E D
`
`
`San Francisco, CA 94104
`’
`,
`
`
`FAX NO: (415) 835~6780
`TELEPHONE NO.: {3415) 835-6777
`SanFrancisco County SuperiorCourt
`
`
`ATTORNEY FOR (Name):
`‘
`laintiffs
`
`
`
`SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Francisco
`ucr 1.12018
`
`
`
`
`STREET ADDRESS: 400. McAllister Street
`MAILING ADDRESS: Same
`
`
`CITY AND ZIP CODE: San. Francisco, CA 94102
`
`
`BRANCH NAME; C1V1c Center Courthouse
`
`
`.
`CASE NAME:
`.
`
`
`-
`Lance Evander, et a1. V. Veritas Investments, Inc., et a1.
`
`
`
`
`
`CIVIL CASE COVER SHEET
`Complex Case Designation
`Unlimited
`1: LImIted
`|:| Counter
`[:1 Joinder
`,
`
`
`
`(Amount
`(Amount
`
`.
`demanded
`demanded is
`Filed with first appearance by defendant
`
`
`
`exceeds $25,000)
`$25,000 or less)
`(Cal. Rules of Court, rule 3.402)
`
`Items 1—6 below must be completed (see instructions on page 2).
`. Check one box below for the case type that best describes this case:
`. Provisionally Complex Civil Litigation
`Auto Tort
`Contract
`_
`(Cal. Rules of Court, rules 3.400—3.403)
`U Auto (22)
`Breach of Contract/warranty (06)
`Antitrust/Trade regulation (03)
`[:I Uninsured motorist (46)
`Rule 3.740 collections (09)
`Construction defect (10)
`Other PIIPDNIID (Personal Injury/Property
`Other collections (09)
`Mass tort (40)
`DamageNllrongful Death) Tort
`Insurance coverage (18)
`Securities litigation (28)
`:1 Asbestos (04)
`Other contract (37)
`Environmental/Toxic tort (30)
`El Product liability (24)
`Property
`Insurance coverage claims arising from the
`:1 Medical malpractice (45)
`Eminent domain/Inverse
`above listed provisionally complex case
`:1 Other Pl/PD/WD (23)
`condemnation (14)
`'
`_ Wes (41),
`,
`Non-PIIPDIWD (Other) Tort
`Wrongful eviction (33)
`Enforcement of Judgment
`Business tort/unfair business practice (07)
`Other real property (26)
`[:1 Enforcement ofjudgment (20)
`Civil rights (08)
`nlawful Detainer
`Miscellaneous Civil Complaint
`Defamation (13)
`CommerCIal (31)
`|:l RICO (27)
`Fraud (16)
`Residential (32)
`El Other complaint (not specified above) (42)
`Intellectual property (19)
`DlUQS (38)
`Miscellaneous Civil Petition
`Professional negligence (25)
`J"dlC'al Rev'ew
`El Partnership and corporate governance (21)
`Other non-PI/PD/WD tort (35)
`El Asset forfeiture (05)
`Employment
`i:| Petition re: arbitration award (11) I: Other petition (not specified above) (43)
`Wrongful termination (36)
`El Writ of mandate (02)
`1 Other employment (15)
`D Other judicial review (39)
`2. This case - is n is not
`complex under rule 3.400 of the California Rules of Court. If the case is complex, mark the
`factors requiring exceptional judicial management:
`a. 1: Large number of separately represented parties
`b. |:| Extensive motion practice raising difficult or novel
`issues that will be time—consuming to resolve
`c. :1 Substantial amount of documentary evidence
`
`
`
`d. 1:] Large number of witnesses
`e. E Coordination with related actions pending in one or more courts
`In other counties, states, or countries, or in a federal court
`f. i: Substantial postjudgmentjudicial supervision
`
`91:59"
`
`6.
`
`Remedies sought (check all that apply): a.- monetary b.- nonmonetary; declaratory or injunctive relief
`Number of causes of action (specify): 11
`This case 1:] is
`is not
`a class action suit.
`If there are any known related cases, file and serve a notice of related case. (You may use form CM—015.)
`
`c. .punitive
`
`
`
`Date: October 10, 2018
`Ryan J. Vlasak, Esq.
`‘7. RNEY FOR PARTY)
`
`
`‘.
`(SIGNATURE OF 7‘ R
`(TYPE OR PRINT NAME)
`
`
`
`.
`NOTICE
`o Plaintiff must file this cover sheet with the first paper filed in the, action or proceeding (except small claims cases or cases filed
`
`under the Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.) Failure to file may result
`in sanctions.
`0 File this cover sheetIn addition to any cover sheet required by local court rule.
`
`0 If this case is complex under rule 3. 400 et seq. of the California Rules of Court, you must serve a copy of this cover sheet on all
`other parties to the action or proceeding.
`
`0 Unless this'Is a collections case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes onlly.1 f2
`ae 0
`
`
`JudICIal Council of California
`Cal. Standards of Judicial Administration, std. 3.10
`Form Adopted for Mandatory _Use
`CIVIL CASE COVER SHEET
`Cal. Rules of Court, rules 2.30, 3.220, 3.400—3.403, 3.740;
`CM-O10 [Rev.- July 1, 2007]
`www.courtinfo.ca.gov
`
`
`
`
`,
`
`

`

`CM-010
`
`
`
`INSTRUCTIONS ON HOW TO COMPLETE THE COVER SHEET
`To Plaintiffs and Others Filing First Papers.
`If you are filing a first paper (for example a complaint) in a civil case, you must
`complete and file, along with yourIfirst paper, the Civil Case Cover Sheet contained on page 1. This information will be used to compile
`statistics about the types and numbers of cases filed. You must complete items 1 through 6 on the sheet.
`In item 1, you must check
`one box, for the case type that best describes the case.
`If the case fits both a general and a more specific type of case listed in item 1,
`check the more specific one. If the case has multiple causes of action, check the box that best indicates the primary cause of action.
`To assist you in completing the sheet, examples of the cases that belong under each case type in item 1 are provided below. A cover
`sheet must be filed only with your initial paper Failure to file a cover sheet with the first paperIfled in a civil case may subject a party,
`its counsel, or both to sanctions under rules 2. 30 and 3220 of the California Rules of Court.
`To Parties in Rule 3.740 Collections Cases. A "collections case" under rule 3.740 is defined as an action for recovery of money
`owed in a sum stated to be certain that is not more than $25,000, exclusive of interest and attorney's fees, arising from a transaction in
`which property, services, or money was acquired on credit. A collections case does not include an action» seeking the following: (1) tort
`damages,
`(2) punitive damages,
`(3) recovery of real property,
`(4) recoVery of personal property, or (5), a prejudgment writ of
`attachment. The identification'of a case as a rule 3.740 collections case on this form means that it will be exempt from the general
`gtime-for-service requirements and case management rules, unless a defendant f les a responsive pleading. A rule 3.740 collections
`case will be subject to the requirements for service and obtaining a judgmentIn rule 3. 740.
`To Parties in Complex Cases.
`In complex cases only, parties must also use the Civil Case Cover Sheet to designate whether the
`case is complex. If a plaintiff believes the case is complex under rule 3.400 of the California Rules of Court, this must be indicated by
`~ completing the appropriate boxes in items 1 and 2. If a plaintiff designates a case as complex, the cover sheet must be served with the
`complaint on‘ all parties to the action. A defendant may file and serve no later than the time of its first appearance a joinder in‘the
`plaintiffs designation, a counter-designation that the case is not complex, or, if the plaintiff has made no designation, a designation that
`the case '5 complex
`CASE TYPES AND EXAMPLES
`Auto Tort
`Auto (22)—Personal‘ Injury/Property
`DamageNVrongful Death
`Uninsured Motorist (46) (if the
`case involves an uninsured
`motorist claim subject to
`arbitration, check this item
`instead ofAuto)
`Other Pl/PDIWD (Personal Injury]
`Property Damage/Wrongful Death)
`Tort
`
`
`
`Asbestos (04)
`Asbestos Property Damage
`Asbestos Personal Injury/
`Wrongful Death
`Product Liability (not asbestos or
`toxic/environmental) (24)
`Medical Malpractice (45)
`Medical Malpractice—
`Physicians & Surgeons
`Other Professional Health Care
`Malpractice
`Other PI/PDNVD (23)
`Premises Liability (e.g., slip
`and fall)
`Intentional Bodily Injury/PD/WD
`(e.g., assault, vandalism)
`Intentional Infiiction of
`'
`Emotional Distress
`Negligent lnfiiction of,
`Emotional Distress
`Other Pl/PD/WD
`Non-PIIPDIWD (Other) Tort
`Business Tort/Unfair Business
`Practice (07)
`Civil Rights (e.g., discrimination,
`false arrest) (not civil
`harassment) (08)
`Defamation (e.g., slander, libel)
`(13)
`Fraud (16)
`Intellectual Property (19)
`Professional Negligence (25)
`Legal Malpractice
`Other Professional Malpractice
`(not medical or legal)
`Other Non-Pl/PDNVD Tort (35)
`Employment
`Wrongful Termination (36)
`Other Employment (15)
`
`CM-O10 [Rev July 1, 2007]
`
`.
`
`Contract
`Breach of Contract/Warranty (06)
`Breach of Rental/Lease
`Contract (not unlawful detainer
`or wrongful eviction)
`Contract/Warranty Breach—Seller
`Plaintiff (not fraud or negligence)
`Negligent Breach of Contract/‘
`Warranty
`Other Breach of Contract/Warranty
`Collections (e.g., money owed, open
`book accounts) (09)
`Collection Case—Seller Plaintiff
`Other Promissory Note/Collections
`Case
`Insurance Coverage (not provisionally
`complex) (1 8)
`Auto Subrogation
`Other Coverage
`Other Contract (37)
`Contractual Fraud
`Other Contract Dispute
`Real Property
`Eminent Domain/Inverse
`Condemnation (14)
`Wrongful Eviction (33)
`Other Real Property (e.g., quiet title) (26)
`Writ of Possession of Real Property
`Mortgage Foreclosure
`Quiet Title
`Other Real Property (not eminent
`domain, landlord/tenant, or
`foreclosure)
`Unlawful Detainer
`Commercial (31)
`Residential (32)
`Drugs (38) (if the case involves illegal
`drugs, check this item; othenII/ise,
`report as Commercial or Residential)
`Judicial Review
`Asset Forfeiture (05)
`Petition Re: Arbitration Award (11)
`Writ ‘of Mandate (02)
`Writ—Administrative Mandamus
`Writ—Mandamus on Limited Court
`Case Matter
`Writ—Other Limited Court Case
`Review
`Other Judicial Review (39)
`Review of Health Officer Order
`Notice of Appeal—Labor
`Commissioner Appeals
`CIVIL CASE COVER SHEET
`
`Provisionally Complex Civil Litigation (Cal.
`Rules of Court Rules 3.400—3.403)
`Antitrust/Trade Regulation (03)
`Construction Defect (10)
`Claims Involving Mass Tort (40) »
`Securities Litigation (28)
`Environmental/Toxic Tort (30)
`Insurance Coverage Claims
`(arising from provisionally comp/ex
`case type listed above) (41)
`Enforcement of Judgment
`Enforcement of Judgment (20)
`Abstract of Judgment (Out of
`County)
`Confession of Judgment (non-
`domestic relations)
`Sister State Judgment
`Administrative Agency Award
`(not unpaid taxes)
`Petition/Certification of Entry of
`Judgment on Unpaid Taxes
`Other Enforcement of Judgment
`Case
`Miscellaneous Civil Complaint
`RICO (27)
`Other Complaint (not specified-
`above) (42)
`Declaratory Relief Only
`Injunctive Relief Only (non-
`harassment)
`Mechanics Lien
`Other Commercial Complaint
`Case (non-tort/non—complex)
`Other Civil Complaint
`(non-tort/non-complex)
`MiScellaneous Civil Petition
`Partnership and Corporate
`Governance (21)
`Other Petition (not specified
`above) (43)
`Civil Harassment
`Workplace Violence
`Elder/Dependent Adult
`Abuse
`Election Contest
`Petition for Name Change
`Petition for Relief From Late
`Claim
`Other Civil Petition
`
`Page 2 of 2_
`
`

`

`
`
`Bracamontes&VlasakI
`
`,AProfessionalLawCorporationwww.bvlawsf.corn
`
`)_I
`
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`
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`
`
`,
`Ryan J. Vlasak (SBN 241581)
`Michael A. Schreiber (SBN 27161 1)
`BRACAMONTES & VLASAK, RC.
`220 Montgomery Street, Suite 870
`San Francisco, CA-94104
`Phone: (415)835-6777.
`Fax:
`, (415) 835-6780 '
`
`Kenneth M. Greenstein (SBN 201224)
`Ariel M. Gershon (SBN 242326)
`GREENSTEIN &MCDONALD
`
`300 Montgomery Street, Suite621
`San Francisco, CA 94104
`Telephone: (415) 773-1240
`Facsimile:
`(415) 773-1240
`
`
`
`Attorneys for All, Plaintiffs
`SUPERIOR COURT OF THE STATE OF CALIFORNIA
`
`IN AND FOR THE COUNTY OF SAN FRANCISCO
`
`UNLIMITED JURISDICTION
`
`LANCE EVANDER, MIRIAM PALM, JOHN
`
`DESSING, JOHN JAY PARRISH, LANDRA
`
`TANKHA, JON E. CHRISTENSON, ANNE
`
`LUKANC, GUNVANT SHAH, JASON
`
`SANDERS, REBECCA HALAS, KENDRA
`
`WEINISCH, DAVID L. CUNNINGHAM,
`
`JACQUES MICHAELS, JOSEPH JAMES "H"
`
`CATAZARITA, JOSEPH DOWLER,,MAHELA
`
`SHAW, CHRISTINE SANDHU’, LETICIA
`
`CORTEZ, JOHN SIMMONS, RAQUEL
`
`
`
`
`
`
`
`
`
`
`MATTHEW POWELL, ELIZABETH MENON,
`
`CASENOGGC'18v57C435
`COMPLAINT FOR DAMAGES,
`INJUNCTIVE RELIEF, AND EQUITABLE
`RELIEF
`
`DEMAND EXCEEDS $25, 000. 00
`
`DOMINGUEZ, RAYMOND SULLIVAN,
`
`I SHIRROD RICHARDSON, SARA GIESSINGER,
`
`' FABIAN HERD, SELINA KEENE’, GWEN
`
`PORTER, MARY WILSON, STEVEN WILSON,
`
`
`
`Evander, et al. v. Veritas Investments, Inc, et al. — Complaintfor Damages, Injunctive Relief and Equitable Relief
`
`_ 1 _
`
`

`

`Bracamontes&VlasakAProfessionalLawCorporation
`
`www.bvlawsf.com
`
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`
`
`MIGUEL GONGORA, JENNIFER GALARZA,
`CHIA TAM, THOMAS BULGER, SANDRA
`DENUTO, MEREDITH SPOTO, JAY WILSON
`
`’
`FISHER, ELLEN SHEELEY, OSCAR
`CORONADO, KAREN MCMILLAN, MARCELO
`
`FARIAS, GEOFF HECHT, KIMBERLY HECHT,
`ELIZABETH STAUB, RANDY SAWYER,
`
`KATHERINE SHANNON, PATRICK
`
`
`SHANNON, JACK BEST, ANDREAS
`
`PEDERSEN, BRITTANY SHOOT, ADAM
`
`OUDERKIRK, LIDIA SULLON, YOLANDA
`
`GONGORA, SAAD ALSORIHI, RAYMOND
`LEVY, ANGEL TENORIO, DORIS JOHNSON,
`
`GREGORY LAWLER, CHRISTOPHER KANG,
`
`PENNY SCHONER, EMANUEL WAKTOLA,
`
`‘ MARGARET SMITH, ADRIAN ANZALDUA,
`MIRRA SCHWARTZ, ROBERT MCCRADY,
`
`,
`
`BRENDA ELLIS, BRYAN BUTLER,
`
`Plaintiffs,
`
`VS.
`
`L
`
`
`
`
`
`SULLON, MADELYN MCMILLIAN, GERMAIN
`
`
`
`
`
`
`
`
`
`
`
`
`VERITAS INVESTMENTS, INC. is a California
`
`Corporation, GREENTREE PROPERTY
`
`MANAGEMENT, INC, a California
`
`'
`
`Corporation, YAT-PANG AU, an individual, 240
`
`SAINT JOSEPHS, LLC, a Delaware Limited
`
`Liability Company, 240 SAINT IOSEPHSAZ,
`
`
`
`
`LP, Delaware Limited Partnership, 318 TURK
`
`Evander, et a]. v. Veritas Investments, Inc., et al. — Complaintfor Damages, Injunctive Relief, and Equitable Relief
`
`-2-
`
`

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`e
`
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`
`17, LP, a Delaware limited partnership,1440
`SUTTER STREET, LLC, a Delaware limited
`
`liability company, 57 TAYLOR I7, LP, a
`
`L Delaware Limited Partnership, 655 POWELL 15
`LLC, a Delaware Limited Liability Company,
`2730 SACRAMENTO I4, LLC, a Delaware
`‘,
`Limited Liability Company, 3659 20TH
`STREET, LLC, a California Limited Liability ..
`
`company dba TELEGRAPH HILL VISTAS,
`
`LLC, 916 PACIFIC 15, LLC, a Delaware Limited
`
`, Liability Company,
`
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`
`
`
`
`1075 O’FARRELL STREET LLC, a California
`Limited Liability Company, 920
`
`LEAVENWORTH I5 LLC, a Delaware Limited
`Liability Company, 990 FULTON 12 LLC, a
`
`Delaware Limited Liability Company, 337 10TH
`
`15 LLC, a Delaware Limited Liability Company,
`
`845 CALIFORNIA STREET LLC, a Delaware
`
`Limited Liability Company, 709 GEARY
`STREET LLC, a Delaware Company, 621
`
`
`
`STOCKTON PROPERTY, LLC, a Delaware
`
`Limited Liability Company dba TIMESHARE
`
`TRADE INS LLC, 336-350 JUDAH I3, LP, a
`Delaware Limited Partnership; 698 BUSH C1,
`
`LP, a Delaware Limited Partnership, 915 PIERCE
`
`STREET, LLC, a Delaware Limited Liability
`
`Company, 1819 GOLDEN GATE Il LLC, a A
`
`Delaware Limited Liability Company,
`
`
`
`,
`_ 3 _
`Evander, et al. v. Veritas Investments, Inc, et a]. —— Complaintfor Damages, Injunctive Relief and Equitable Relief
`
`

`

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`
`
`
`
`
`www.bvlawsf.com
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`270 TURK, LLC, a Delaware Limited Liability
`Company, 610-660 CLIPPER Il, LLC, a
`Delaware Limited Liability Company, 721'”
`GEARY 15, LLC, a Delaware Limited Liability '
`Company, 720 BAKER I1, LLC, a Delaware y‘
`Limited Liability Company, SF 685 GEARY A
`STREET, LLC, a Delaware Limited Liability
`
`Company, 3201 23RD I7 LP, a Delaware Limited
`Partnership, 520 BUCHANAN. STREET LLC, a
`Delaware Limited Liability Company, 1126
`I
`BUSH STREET LLC, a Delaware Limited ,
`Liability Cempany, 20 SAN ANTONIO I6 LP, a
`Delaware Limited Partnership, 16-50 LAGUNA
`I2 LLC, a Delaware Limited Liability Company,
`
`1064 DOLORES I1 LLC, a Delaware Limited
`
`Liability Company dba VERITAS PROPERTIES
`
`'S-I LLC, and DOES 1 to 20, inclusive,
`Defendants.
`
`Plaintiffs LANCE EVANDER, MIRIAM PALM, JOHN IDESSING, JOHN JAY PARRISH,
`
`LANDRA TANKHA, JON E. CHRISTENSON, ANNE LUKANC, GUNVANT SHAH, JASON
`
`SANDERS, REBECCA HALAS, KENDRA WEINISCH, DAVID L. CUNNINGHAM, JACQUES
`MICHAELS, JOSEPH JAMES "JJ" CATAZARITA, JOSEPH DOWLER, MAHELA SHAW,
`
`'
`
`'_CHRISTINE SANDHU, LETICIA CORTEZ,
`
`JOHN SIMMONS, RAQUEL DOMINGUEZ,
`
`RAYMOND SULLIVAN, SHIRROD RICHARDSON, SARA GIESSINGER, FABIAN‘ HERD,
`
`SELINA KEENE, GWEN PORTER, MARY WILSON, STEVEN W'ILSON, MATTHEW POWELL,
`
`ELIZABETH MENON, MIGUEL GONGORA, JENNIFER GALARZA, CHIA TAM, THOMAS
`BULGER, SANDRA DENUTO, MEREDITH SPOTO, JAY WILSON FISHER, ELLEN SHEELEY,
`
`OSCAR CORONADO, KAREN MCMILLAN, MARCELO FARIAS, GEOFF HECHT, KIMBERLY
`
`Evander, et al! v. Veritas Investments, Inc, et al. — Complaintfor Damages, Injunetive Relief and Equitable Relief
`
`_ 4 -
`
`

`

`
`
`
`
`
`
`www.bvlawsf.com'
`
`Bracamontes&VlasakAProfessionalLawCorporation
`
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`HECHT, ELIZABETH STAUB, RANDY SAWYER, KATHERINE. SHANNON, PATRICK,
`SHANNON, JACK BEST, ANDREAS PEDERSEN, BRITTANY SHOOT,ADAM OUDERKIRK,
`LIDIA SULLON, YOLANDA SULLON, MADELYN MCMILLIAN, GERMAIN‘ GONGORA,
`SAAD ALSORIHI, RAYMOND LEVY, ANGEL TENORIO, DORIS JOHNSON,” GREGORY
`‘ LAWLER, CHRISTOPHER KANG, PENNY SCHONER, EMANUEL WAKTOLA, MARGARET
`SMITH, ADRIAN ANZALDUA, MIRRA SCHWARTZ, ROBERT MCCRADY, BRENDA ELLIS,
`BRYAN BUTLER (collectively, Plaintiffs”) sue Defendants VERITAS INVESTMENTS, INC., a
`
`California Corporation, GREENTREE PROPERTY MANAGEMENT, INC., a California Corporation,
`
`YAT—PANG AU, an individual, 240 SAINT JOSEPHS, LLC, a Delaware Limited Liability Company,
`240 SAINT JOSEPHS A2, LP, Delaware Limited Partnership, 318 TURK 17, LP, a Delaware limited
`partnership, 1440 SUTTER STREET, LLC, aDelaware limited liability company, 57 TAYLOR 17, LP,
`a Delaware Limited Partnership, 655 POWELL 15 LLC, a Delaware Limited Liability Company, 2730
`
`SACRAMENTO 14, LLC, a Delaware Limited Liability Company, 3659 20TH STREET, LLC, a
`
`California Limited Liability Company dba TELEGRAPH HILL VISTAS, LLC, 916 PACIFIC 15,
`
`LLC, a Delaware Limited Liability Company, 1075 O’FARRELL STREET LLC, a California Limited
`
`Liability Company, 920 LEAVENWORTH 15 LLC, a Delaware Limited Liability Company, 990
`
`FULTON 12 LLC, a Delaware Limited Liability Company, 337 10TH 15 LLC, a Delaware Limited
`
`Liability Company, 845 CALIFORNIA STREET LLC, a Delaware Limited Liability Company, 709
`GEARY STREET LLC, a Delaware Company, 621 STOCKTON PROPERTY, LLC, a Delaware
`
`‘ Limited Liability Company dba TIMESHARE TRADE INS LLC, 336-3 50 JUDAH 13, LP, a Delaware
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`Limited Partnership, 698 BUSH C1, LP, a Delaware Limited Partnership, 915 PIERCE STREET,
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`_
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`LLC, a Delaware Limited Liability Company, 1819 GOLDEN GATE Il- LLC, a Delaware Limited
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`Liability Company, 270 TURK, LLC, a Delaware Limited Liability Company, 610-660 CLIPPER 11,
`LLC, a Delaware Limited Liability Company, 721 GEARY 15, LLC, a Delaware Limited Liability
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`Company, 720 BAKER 11, LLC, a Delaware Limited Liability Company, SF 685 GEARY STREET,
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`LLC, a Delaware Limited Liability Company, 3201 23RD 17 LP, a Delaware Limited Partnership, 520
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`BUCHANAN STREET LLC, a Delaware Limited Liability Company, 1126 BUSH STREET LLC, a
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`Delaware Limited Liability Company, 20 SAN ANTONIO 16 LP, a Delaware Limited Partnership, 16-
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`Evander, et al. v. Veritas Investments, Inc, et al. — Complaintfor Damages, Injunctive Relief and Equitable Relief
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`www.bvlawsf.com<
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`Bracamontes&VlasakAProfessionalLawCorporation
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`50 LAGUNA I2 LLC, a Delaware Limited Liability Company, 1064 DOLORES Il LLC, a Delaware
`Limited Liability Company dba VERITAS PROPERTIES S-I LLC, and DOES 1
`to 20, inclusive
`(collectively, ‘fDefendants”), and each of them, and demand a trial by jury of all issues and forcauses
`of action, allege:
`L
`L
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`GENERAL ALLEGATIONS
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`'l. Plaintiffs are ignorant of the true names and capacities of the Defendants sued herein under the
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`fictitious names DOE ONE through DOE TWENTY, inclusive7 Plaintiffs will amend this complaint
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`to allege their true names and capacities when ascertained. Plaintiffs are informed and believe and
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`thereon allege that each of the DOE defendants is responsible in some manner for the occurrenCes
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`and injuries alleged in this complaint.
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`. At all times mentioned in the causes of action to which this paragraph is incorporated by reference,
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`each and every Defendant was the agent or employee of each and every other Defendant. In doing '
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`the things alleged in the Causes of action into which this paragraph is incorporated by reference,
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`each and every Defendant was acting within the course and scope of his/its agency or employment
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`and was acting with the consent, permission, and authorization of each of the remaining
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`Defendants. All actions of each of the Defendants alleged in the causes of action into which this
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`paragraph is incorporated by reference were ratified and approved by the officers or managing
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`agents of every other Defendant.
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`. The acts and/or failures to act complained of herein occurred in San Francisco County, State of
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`California.
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`. Plaintiffs at all times relevant herein, have been competent adults and residents of the City and
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`County of San Francisco, California. Each of them were, at all relevant times are or were tenants
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`residing at the real property owned and managed by Defendants. Plaintiffs reside or resided at the
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`following properties (collectively, “Subject Properties”)owned by the following Defendants
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`(collectively, “OWNER DEFENDANTS”):
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`A)
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`240 SAINT JOSEPHS, LLC and .240 SAINT JOSEPHS A2, LP owns and/or owned the real
`property located at 2407 Saint Joseph’s Avenue, San Francisco, CA during all relevant times
`
`alleged herein;
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`‘ Evander, et al. v. Veritas Investments, Inc.,‘ et al. — Complaintfor Damages, Injunctive Relief and Equitable Relief
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`-6-
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`B)
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`C)
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`D)
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`E)
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`318 TURK 17, LP owns and/or owned the real. property located at 320 Turk Street, San
`Francisco, CA during all relevant times alleged herein;
`1440 SUTTER STREET, LLC owns and/or owned 1440 Sutter Street, San Francisco, CA ,«
`during all relevant times alleged herein;
`’7
`I
`I
`57 TAYLOR 17, LP owns and/or owned 57 Taylor Street, San Francisco,CA during all
`relevant times alleged herein;
`655 POWELL I5 LLC holds and/or held title 655 Powell Street, San Francisco, CA during
`all relevant times alleged herein;
`1
`L
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`I
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`F)
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`2730 SACRAMENTO I4, LLC owns and/or owned 2730 Sacramento Street,.San Francisco,
`
`'
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`CA during all relevant times alleged herein;
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`Bracamontes&Vlasak.AProfessionalLawCorporation
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`www.bvlawsf.com
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`G)
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`3659 20TH STREET, LLC dba' Telegraph Hill Vistas, LLC owns and/or owned 3663 20th
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`, Street, San Francisco, CA during all relevant times alleged herein;
`
`H)
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`9‘16 PACIFIC 15, LLC owns and/or owned 916 Pacific Avenue, San Francisco CA during
`
`all relevant times alleged herein;
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`1075 O’FARRELL STREET LLC owns and/or owned 1075 O’Farrell Street, San Francisco,
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`CA during all relevant times alleged herein;
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`920 LEAVENWORTH 15 LLC owns and/or owned 920 Leavenworth Street, San Francisco,
`
`CA during all relevant times alleged herein;
`990 FULTON l2 LLC owns and/or owned 990 Fulton Street, San Francisco, CA during all
`
`I)
`
`J)‘
`
`K)
`
`relevant times alleged herein;
`
`L)
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`337 10TH 15 LLC owns and/or owned 337 10th Avenue, San Francisco, CA during all
`
`relevant times alleged herein;
`
`_
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`M)
`
`845 CALIFORNIA STREET LLC owns and/or owned 845 California Street, San Francisco,
`
`CA during all relevant times alleged herein;
`
`709 GEARY STREET LLC owns and/or owned 709 Geary Street, San Francisco, CA
`
`during all relevant times alleged herein
`
`0)
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`621 STOCKTON PROPERTY, LLC, dba Timeshare Trade Ins, LLC owns and/or owned
`
`621 Stockton Street, San Francisco, CA during all relevant times alleged herein;
`
`-7-
`Evander, et a]. v. Veritas Investments, Inc, et al. —— Complaintfor Damages, Injunctive Relief and Equitable Relief
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`

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`Bracamontes&VlasakAProfessionalLawCorporation
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`P)
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`336-350 JUDAH I3, LP owns and/or owned 350 Judah Street, San Francisco, CA during all
`
`relevant times alleged herein;
`
`I
`
`,
`
`,
`
`Q)’
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`698 BUSH C1, LP owns and/or owned 698 Bush Street San Francisco, CA during all
`
`,R)‘
`
`S) '
`
`T)
`
`U),
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`V)
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`relevant times alleged herein;
`915 PIERCE STREET, LLC owns and/or owned 915 Pierce Street, San Francisco, CA
`V during all relevant times alleged herein;
`1819 GOLDEN GATE Il LLC owns and/or owned 1819 Golden Gate Avenue, San
`Francisco, CA during all relevant times alleged herein,
`270 TURK, LLC owns and/or owned 270 Turk Street, San Francisco, CA during all relevant
`
`times alleged herein;
`
`- 610—660 CLIPPER Il, LLC owns and/or owned 610 Clipper Street, San Francisco, CA
`
`during all relevant times alleged herein;
`
`721 GEARY 15, LLC owns and/or owned 721 Geary Street, San Francisco, CA during all
`relevant times alleged herein;
`I
`I
`
`W)
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`720 BAKER Il, LLC owns and/or owned 720 Baker, San Francisco, CA during all relevant
`
`times alleged herein;
`‘
`,
`SF 685 GEARY STREET, LLC owns and/or owned 685 Geary Street, San Francisco, CA
`during all relevant times alleged herein;
`2
`3201 23RD 17 LP owns and/or owned 3201 23rd Street, San Francisco, CA during all
`
`X)
`
`Y)
`
`relevant times alleged herein;
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`Z)
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`520 BUCHANAN STREET'LLC owns and/or owned 520 Buchanan Street, San Francisco,
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`CA during all relevant times alleged herein;
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`AA)
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`1126 BUSH STREET LLC owns and/or owned 1126 Bush Street, San Francisco, CA during
`
`all relevant times alleged herein;
`
`I
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`BB)
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`20 SAN ANTONIO 16 LP holds title to 20 San Antonio Place, San Francisco, CA during all
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`relevant times alleged herein;
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`CC)
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`16-50 LAGUNA I2 LLC owns and/or owned 50 Laguna Street, San Francisco, CA during
`all relevant times alleged herein;
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`
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`-8-
`Evander, et al. v. Veritas Investments, Inc., et al. — Complaintfor Damages, Injunctive Relief and Equitable Relief
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`Bracamontes&V|asakAProfessionalLawCorporation
`
`www.bvlawsf.com
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`DD),
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`1064 DOLORES Il LLC dba Veritas- Properties ‘S-I LLC owns and/or owned 1064 Dolores
`
`Street, San Francisco, CA during all relevant times alleged herein;
`. Defendant VERITAS INVESTMENTS, INC.is a California Corporation authorized to do business
`in the State of California. At all relevant times, Defendant VERITAS INVESTMENTS, INC. Was
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`landlord and managed the Subject Properties owned by Defendants.
`
`»
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`'
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`. On infOrmation and belief, Plaintiffs allege as follows: Defendant VERITAS INVESTMENTS,
`INC. owns and controls OWNER DEFENDANTS. OWNER DEFENDANTS are owners of
`
`VERITAS INVESTMENTS,
`
`INC.
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`for holding the above-referenced real property. OWNER
`
`DEFENDANTS are alter egos of VERITAS INVESTMENTS, INC.
`
`».
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`L VERITAS INVESTMENTS, INC. has actually owned and controlled the Subject Properties during
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`relevant times.
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`is a California Corporation
`. Defendant GREENTREE PROPERTY MANAGEMENT, INC.
`authorized to, do business in the State of California. At all relevant times, Defendant GREENTREE
`
`PROPERTY MANAGEMENT, INC. was landlord and managed the Subject Properties owned by
`
`defendants. During relevant times, Defendant GREENTREE PROPERTY MANAGEMENT, INC.
`performed management functions at the Subject Properties owned by Defendants, and the actions
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`hereafteralleged undertaken by Defendants were done so within the scope of their authority to
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`manage said property. Plaintiffs are informed and believe and thereon allege that Defendant
`
`GREENTREE PROPERTY MANAGEMENT, INC. was established by and is Wholly affiliated
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`with and controlled by defendant VERITAS INVESTMENTS, INC. for the San Francisco rental
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`property management business for properties owned by the Defendants. Defendants — including but
`
`not limited to VERITAS INVESTMENTS, INC.; OWNERDEFENDANTS; and YAT-PANG AU —
`
`have actually controlled the management of the Subject Properties during all relevant times.
`
`. Defendant YAT-PANG AU is a competent adult who has been doing business in the City and
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`County of San Francisco, California. Plaintiffs are informed and believe and thereon allege that,
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`during the relevant times herein Defendant YAT-PANG AU actually owned, managed and/or
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`controlled the Subject Properties.
`
`
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`-9-
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`Evander, et al. v. Veritas Investments, Inc., et al. — Complaintfor Damages, Injunctive Relief and Equitable Relief
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`10. On information and belief, Plaintiffs allege as follows: Defendant YAT-PANG AU owns and
`controls ‘ defendants VERITAS
`INVESTMENTS,
`INC; GREENTREE
`PROPERTY
`MANAGEMENT,
`INC; and OWNER" DEFENDANTS. VERITAS INVESTMENTS, INC;
`
`GREENTREE PROPERTY MANAGEMENT, INC; and OWNER DEFENDANTS are alter egos
`of defendant YAT-PANGAU.“
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`. Defendant YAT-PANG AU at all times relevant herein, actually owned, dominated, and Controlled
`
`the Subject Properties, and orchestrated and ratified and was otherwise involved in theunlawful
`schemes hereinafter described. Plaintiffs are informed and believe, and thereon allege that
`Defendant YAT-PANG AU has committed acts establishing alter ego liability in that he'has been
`
`the alter-ego of OWNER DEFENDANTS and/or in’that he has been the alter-ego of GREENTREE
`PROPERTY MANAGEMENT, INC. and/or in that he has been the alter-ego of VERITAS
`
`INVESTMENTS,
`
`INC. As Such,;adherence to the fiction of the separate existence of each
`
`Defendant as an entity distinct from each other would permit an abuse of the corporate and LLC ,
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`privileges and would promote injustice. Therefore it would be inequitable for any Defendant to
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`escape liability for an act undertaken as much for that Defendant’s benefit as for the other
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`Defendants.
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`‘17
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`12.
`
`Defendant VERITAS INVESTMENTS,
`
`INC. at all
`
`times relevant herein, actually owned,
`
`18
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`19
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`20
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`21
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`22
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`23
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`2'4
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`,
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`25
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`26
`
`27
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`13.
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`28
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`dominated, and controlled the Subject Properties, and orchestrated and, ratified and was otherwise
`
`involved, in the unlawful schemes hereinafter described. Plaintiffs are informed and believe, and
`thereon allege that Defendant VERITAS INVESTMENTS, INC. has committed acts establishing
`
`alter ego liability in that it has been the alter-ego of OWNER DEFENDANTS and/or in that it has
`
`been the alter-ego of GREENTREE PROPERTY MANAGEIVIENT, INC. As such, adherence to the
`
`fiction of the separate existence of each defendant as an entity distinct from each other would
`
`permit an abuse of the corporate and LLC privileges and would promote injustice. Therefore it
`would be inequitable for any Defendant to escape liability for an act undertaken as much for that
`
`Defendant’s benefit as for the other Defendants.
`
`limited to VERITAS INVESTMENTS, INC; GREENTREE
`Defendants — including but not
`PROPERTY MANAGEMENT, INC; and OWNER DEFENDANTS ¥ are essentially front I
`
`Evander, et al. v. Veritas Investments, Inc, et al. — Complaintfor Damages, Injunctive Relief, and Equitable Relief
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`-10-
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`Bracamontes&VlasakAProfessionalLawCorporation
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`www.bv|awsf.com
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`organizations for YAT-PANG AU. Defendant YAT-PANG AU purchases, oWns, and manages real
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`‘ property throughout San Francisco. He owns the properties via OWNERDEFENDANTS under his
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`‘
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`control, and he controls the properties together as one business. Most of these properties are multi-
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`14.
`
`15.
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`unit buildings, many containing scores of units.
`The true names and capacities of Defendants sued herein as DOES 1 through 20, inclusive, are at V
`this time unknown to Plaintiffs, whotherefore sue these Defendants by such fictitious names.
`Plaintiffs will request leave to amend this complaint to allege their true names and capacities if and
`
`when same have been ascertained.
`At all times relevant herein, the above Defendants, and