`
`Ryan J. Vlasak (SBN 241581)
`BRACAMONTES & VLASAK, P.C.
`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, Suite 621
`San Francisco, CA 94104
`Telephone: (415) 773-1240
`Facsimile: (415) 773-1240
`
`Attorneys for All Plaintiffs
`
`ELECTRONICALLY
`F I L E D
`
`Superior Court of California,
`County of San Francisco
`01/31/2020
`Clerk of the Court
`BY: ERNALYN BURA
`Deputy Clerk
`
`
`SUPERIOR COURT OF THE STATE OF CALIFORNIA
`IN AND FOR THE COUNTY OF SAN FRANCISCO
`UNLIMITED JURISDICTION
`
`
`CASE NO.: CGC-18-570435
`THIRD AMENDED COMPLAINT FOR
`DAMAGES, INJUNCTIVE RELIEF, AND
`EQUITABLE RELIEF
`
`DEMAND EXCEEDS $25,000.00
`
`
`
`
`
`
`
`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 "JJ"
`CATANZARITA, JOSEPH DOWLER, MAHELA
`SHAW, CHRISTINE SANDHU, LETICIA
`CORTEZ, RAQUEL DOMINGUEZ, RAYMOND
`SULLIVAN, SHIRROD RICHARDSON, SARA
`GIESSINGER, FABIAN HERD, SELINA
`KEENE, GWEN PORTER, MARY WILSON,
`STEPHEN WILSON, MATTHEW POWELL,
`
`
`________________________________________ - 1 -
`Evander, et al. v. Veritas Investments, Inc., et al. – Third Amended Complaint for Damages, Injunctive Relief, and
`Equitable Relief
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`A Professional Law Corporation
`Bracamontes & Vlasak
`
`www.bvlawsf.com
`
`
`

`

`
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`ELIZABETH MENON, MIGUEL GONGORA,
`JENNIFER GALARZA, CHIA TAM, THOMAS
`BULGER, SANDRA DENUTO, MEREDITH
`SPOTO, JAY WILSON FISHER, ELLEN
`SHEELEY, 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
`SULLON, MADELYN MCMILLIAN, GERMAIN
`GONGORA, 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, ALEX
`WILSON, JAMES HUTCHINSON, JAMES
`SHUMATE, REUBEN PEREZ, SHEHAN
`JAYATILAKA, ADIL AHSAN, JON KESSLER,
`EVAN MEAGHER, REBECCA FRAZZANO,
`ANTONIO GODOY, ELIZABETH MATICELLO,
`, MENTA SRIKANTH SUNDARA, DALE
`SPEER, NEIL W. HARVEY, TARUN MEHTA,
`GAIL CLARK, SOOK FUNG, PAULA
`GINSBURG, CYNTHIA SPEARS, JOHN
`
`
`________________________________________ - 2 -
`Evander, et al. v. Veritas Investments, Inc., et al. – Third Amended Complaint for Damages, Injunctive Relief, and
`Equitable Relief
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`A Professional Law Corporation
`Bracamontes & Vlasak
`
`www.bvlawsf.com
`
`

`

`
`
`HUGHES, DOLLY TALAGA, FLORENCE
`NORMAN, DEBRA NUNEZ, JOSE NAJERA,
`CESAR SERRANO, VICTOR PECH, MARIA
`PECH UC, JEFFREY GILMORE, SOFIA UC,
`DANIEL CORIN, SILMARIE TORRES,
`CHARLOTTE HUNT, ROSA ACUNA,
`WENCESLAO “ROLY” MUNOZ, VALEDI
`KACUPI, YUKA KANPURI, MICHAEL
`RUTLEDGE, SILVANA M. SOUZA, RICHARD
`KOCH, LINDA KOCH, MARIO DZUL,
`VICENTE DZUL, ABDEL ELGAWADY,
`GLORIA FORTIER, PAMELA JOHNSON,
`NICOLE DIACONOFF, JEFF STOFAN,
`TAYLOR KHOV, ANA ESCANDON, ALVARO
`FORTIZ, JIANYING ZENG, ROSARIO
`GARCIA, MANUEL ALVARADO, ALICIA
`JENISH-MCCARRON, ADRIAN MCCARRON,
`MARIANNA GRAHAM, ALIX MYRTHIL, MAN
`FAT LUI, SHUN MEI ZHU, LI KUANG, MEI
`YING CHEN, JIAN LIANG ZHEN,
`
`
`Plaintiffs,
`
`
`vs.
`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 JOSEPHS A2,
`
`
`________________________________________ - 3 -
`Evander, et al. v. Veritas Investments, Inc., et al. – Third Amended Complaint for Damages, Injunctive Relief, and
`Equitable Relief
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`A Professional Law Corporation
`Bracamontes & Vlasak
`
`www.bvlawsf.com
`
`

`

`
`
`LP, Delaware Limited Partnership, 318 TURK
`I7, LP, a Delaware limited partnership,1440
`SUTTER STREET, LLC, a Delaware limited
`liability company, 57 TAYLOR I7, LP, a
`Delaware Limited Partnership, 655 POWELL I5
`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 I5, LLC, a Delaware Limited
`Liability Company,
`1075 O’FARRELL STREET LLC, a California
`Limited Liability Company, 920
`LEAVENWORTH I5 LLC, a Delaware Limited
`Liability Company, 990 FULTON
` I2 LLC, a Delaware Limited Liability Company,
`337 10TH I5 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 I1 LLC, a
`
`
`________________________________________ - 4 -
`Evander, et al. v. Veritas Investments, Inc., et al. – Third Amended Complaint for Damages, Injunctive Relief, and
`Equitable Relief
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`A Professional Law Corporation
`Bracamontes & Vlasak
`
`www.bvlawsf.com
`
`

`

`
`
`Delaware Limited Liability Company,
`270 TURK, LLC, a Delaware Limited Liability
`Company, 610-660 CLIPPER I1, LLC, a
`Delaware Limited Liability Company, 721
`GEARY I5, LLC, a Delaware Limited Liability
`Company, 720 BAKER I1, LLC, a Delaware
`Limited Liability Company, SF 685 GEARY
`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
`BUSH STREET LLC, a Delaware Limited
`Liability Company, 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, 1260 BROADWAY STREET, LLC, a
`Delaware Limited Liability Company, and 1025
`STEINER I2 LLC, a Delaware Limited Liability
`Company, 655 STOCKTON STREET, LLC, a
`Delaware Limited Liability Company dba
`VERITAS-B SENIOR MEZZ, LLC, 665 PINE
`I7, LP, a Delaware Limited Liability Partnership,
`SF 3809 20th STREET, LLC, a Delaware Limited
`Liability Company, 1035 SUTTER I3, LP, a
`Delaware Limited Liability Partnership, 516
`ELLIS I7, LP, a Delaware Limited Liability
`
`
`________________________________________ - 5 -
`Evander, et al. v. Veritas Investments, Inc., et al. – Third Amended Complaint for Damages, Injunctive Relief, and
`Equitable Relief
`
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`A Professional Law Corporation
`Bracamontes & Vlasak
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`www.bvlawsf.com
`
`

`

`
`
`Partnership, 990 GEARY I3, LP, a Delaware
`Limited Liability Partnership, VIC C16, LLC, a
`Delaware Limited Liability Company, 1 SAN
`ANTONIO I5, LLC, a Delaware Limited Liability
`Company, 2619 MISSION I2, LLC, a Delaware
`Limited Liability Company, 1025 SUTTER I5,
`LLC, a Delaware Limited Liability Company, 735
`O’FARRELL I7, LP, a Delaware Limited
`Partnership, 737 PINE I1, LLC, a Delaware
`Limited Liability Company, VIC STRATEGIC
`MULTIFAMILY PARTNERS, LP, a Delaware
`Limited Partnership, 430 BAKER I5, LLC, a
`Delaware Limited Liability Company, 430
`BAKER I5 LP, a Delaware Limited Partnership,
`2824-2828 GEARY, LLC, a California Limited
`Liability Company, 781 O’FARRELL I7, LP, a
`Delaware Limited Partnership, and DOES 1 to 20,
`inclusive,
`Defendants.
`
`
`Plaintiffs 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 "JJ" CATANZARITA, JOSEPH DOWLER, MAHELA SHAW,
`CHRISTINE SANDHU, LETICIA CORTEZ, RAQUEL DOMINGUEZ, RAYMOND SULLIVAN,
`SHIRROD RICHARDSON, SARA GIESSINGER, FABIAN HERD, SELINA KEENE, GWEN
`PORTER, MARY WILSON, STEPHEN WILSON, MATTHEW POWELL, ELIZABETH MENON,
`MIGUEL GONGORA, JENNIFER GALARZA, CHIA TAM, THOMAS BULGER, SANDRA
`DENUTO, MEREDITH SPOTO, JAY WILSON FISHER, ELLEN SHEELEY, KAREN MCMILLAN,
`
`
`________________________________________ - 6 -
`Evander, et al. v. Veritas Investments, Inc., et al. – Third Amended Complaint for Damages, Injunctive Relief, and
`Equitable Relief
`
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`Bracamontes & Vlasak
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`www.bvlawsf.com
`
`

`

`
`
`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 SULLON, MADELYN
`MCMILLIAN, GERMAIN
` GONGORA, 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, ALEX WILSON, JAMES HUTCHINSON,
`JAMES SHUMATE, REUBEN PEREZ, SHEHAN JAYATILAKA, ADIL AHSAN, JON KESSLER,
`EVAN MEAGHER, REBECCA FRAZZANO, ANTONIO GODOY, ELIZABETH MATICELLO,
`MENTA SRIKANTH SUNDARA, DALE SPEER, NEIL W. HARVEY, TARUN MEHTA, GAIL
`CLARK, SOOK FUNG, PAULA GINSBURG, CYNTHIA SPEARS, JOHN HUGHES, DOLLY
`TALAGA, FLORENCE NORMAN, DEBRA NUNEZ, JOSE NAJERA, CESAR SERRANO, VICTOR
`PECH, MARIA PECH, JEFFREY GILMORE, SOFIA UC, DANIEL CORIN, SILMARIE TORRES,
`CHARLOTTE HUNT, ROSA ACUNA, WENCESLAO “ROLY” MUNOZ, VALEDI KACUPI, YUKA
`KANPURI, MICHAEL RUTLEDGE, SILVANA M. SOUZA, RICHARD KOCH, LINDA KOCH,
`MARIO DZUL, VICENTE DZUL, ABDEL ELGAWADY, GLORIA FORTIER, PAMELA
`JOHNSON, NICOLE DIACONOFF, JEFF STOFAN, TAYLOR KHOV, ANA ESCANDON,
`ALVARO FORTIZ, JIANYING ZENG, ROSARIO GARCIA, MANUEL ALVARADO, ALICIA
`JENISH-MCCARRON, ADRIAN MCCARRON, MARIANNA GRAHAM, ALIX MYRTHIL, MAN
`FAT LUI, SHUN MEI ZHU, LI KUANG, MEI YING CHEN, JIAN LIANG ZHEN, (collectively,
`Plaintiffs”) sue Defendants VERITAS INVESTMENTS, INC., a California Corporation, GREENTREE
`PROPERTY MANAGEMENT, INC., a California Corporation, YAT-PANG AU, an individual
`(collectively “CORPORATE DEFENDANTS”), 240 SAINT JOSEPHS, LLC, a Delaware Limited
`Liability Company, 240 SAINT JOSEPHS A2, LP, Delaware Limited Partnership, 318 TURK I7, LP, a
`Delaware limited partnership, 1440 SUTTER STREET, LLC, a Delaware limited liability company, 57
`TAYLOR I7, LP, a Delaware Limited Partnership, 655 POWELL I5 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
`
`
`________________________________________ - 7 -
`Evander, et al. v. Veritas Investments, Inc., et al. – Third Amended Complaint for Damages, Injunctive Relief, and
`Equitable Relief
`
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`Bracamontes & Vlasak
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`www.bvlawsf.com
`
`

`

`
`
`PACIFIC I5, LLC, a Delaware Limited Liability Company, 1075 O’FARRELL STREET LLC, a
`California Limited Liability Company, 920 LEAVENWORTH I5 LLC, a Delaware Limited Liability
`Company, 990 FULTON I2 LLC, a Delaware Limited Liability Company, 337 10TH I5 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 I1 LLC, a Delaware Limited Liability
`Company, 270 TURK, LLC, a Delaware Limited Liability Company, 610-660 CLIPPER I1, LLC, a
`Delaware Limited Liability Company, 721 GEARY I5, LLC, a Delaware Limited Liability Company,
`720 BAKER I1, LLC, a Delaware Limited Liability Company, SF 685 GEARY 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 BUSH STREET LLC, a
`Delaware Limited Liability Company, 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, 1260 BROADWAY STREET, LLC,
`a Delaware Limited Liability Company, 1025 STEINER I2 LLC, a Delaware Limited Liability
`Company, 655 STOCKTON STREET, LLC, a Delaware Limited Liability Company dba VERITAS-B
`SENIOR MEZZ, LLC, 665 PINE I7, LP, a Delaware Limited Liability Partnership, SF 3809 20th
`STREET, LLC, a Delaware Limited Liability Company, 1035 SUTTER I3, LP, a Delaware Limited
`Liability Partnership, 516 ELLIS I7, LP, a Delaware Limited Liability Partnership, 990 GEARY I3, LP,
`a Delaware Limited Liability Partnership, VIC C16, LLC, a Delaware Limited Liability Company, 1
`SAN ANTONIO I5, LLC, a Delaware Limited Liability Company, 2619 MISSION I2, LLC, a Delaware
`Limited Liability Company, 1025 SUTTER I5, LLC, a Delaware Limited Liability Company, 735
`O’FARRELL I7, LP, a Delaware Limited Partnership, 737 PINE I1, LLC, a Delaware Limited Liability
`Company, VIC STRATEGIC MULTIFAMILY PARTNERS, LP, a Delaware Limited Partnership, 430
`BAKER I5, LLC, a Delaware Limited Liability Company, 430 BAKER I5 LP, a Delaware Limited
`Partnership, 2824-2828 GEARY, LLC, a California Limited Liability Company, 781 O’FARRELL I7,
`
`
`________________________________________ - 8 -
`Evander, et al. v. Veritas Investments, Inc., et al. – Third Amended Complaint for Damages, Injunctive Relief, and
`Equitable Relief
`
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`Bracamontes & Vlasak
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`www.bvlawsf.com
`
`

`

`
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`LP, a Delaware Limited Partnership and DOES 1 to 20, inclusive (collectively, “Defendants”), as
`further specified herein, and demand a trial by jury of all issues and for causes of action, allege:
`GENERAL ALLEGATIONS
`1. Plaintiffs are ignorant of the true names and capacities of the Defendants sued herein under the
`fictitious names DOE ONE through DOE TWENTY, inclusive. Plaintiffs will amend this complaint
`to allege their true names and capacities when ascertained. Plaintiffs are informed and believe and
`thereon allege that each of the DOE defendants is responsible in some manner for the occurrences
`and injuries alleged in this complaint.
`2. At all times mentioned in the causes of action to which this paragraph is incorporated by reference,
`each and every Defendant was the agent or employee of each and every other Defendant. In doing
`the things alleged in the causes of action into which this paragraph is incorporated by reference, each
`and every Defendant was acting within the course and scope of his/its agency or employment and
`was acting with the consent, permission, and authorization of each of the remaining Defendants. All
`actions of each of the Defendants alleged in the causes of action into which this paragraph is
`incorporated by reference were ratified and approved by the officers or managing agents of every
`other Defendant.
`3. The acts and/or failures to act complained of herein occurred in San Francisco County, State of
`California.
`4. Plaintiffs at all times relevant herein, have been competent adults and residents of the City and County
`of San Francisco, California. Each of them at all relevant times are or were tenants residing at the
`real property owned and managed by Defendants. Plaintiffs reside or resided at the following
`properties (collectively, “Subject Properties”) owned on Title by the following respective
`Defendants (collectively, “OWNER DEFENDANTS”):
`A)
`240 SAINT JOSEPHS, LLC and 240 SAINT JOSEPHS A2, LP owns and/or owned the real
`property located at 240 Saint Joseph’s Avenue, San Francisco, CA during all relevant times
`alleged herein (the entities were created by CORPORATE DEFENDANTS and Yat Pang
`Au as a holding shell for this property, as part of their single business enterprise; the
`operating
`addresses
`of
`these
`two
`entities
`is
`268 Bush St.,
`#1688,
`
`
`________________________________________ - 9 -
`Evander, et al. v. Veritas Investments, Inc., et al. – Third Amended Complaint for Damages, Injunctive Relief, and
`Equitable Relief
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`Bracamontes & Vlasak
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`www.bvlawsf.com
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`

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`
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`B)
`
`C)
`
`D)
`
`E)
`
`SAN FRANCISCO CA 94104, which address is a mailbox only, and which address until
`recently was the shared mailing address for OWNERSHIP DEFENDANTS and also for
`the CORPORATE DEFENDANTS);
`318 TURK I7, LP owns and/or owned the real property located at 320 Turk Street, San
`Francisco, CA during all relevant times alleged herein (the entity was created by
`CORPORATE DEFENDANTS and Yat Pang Au as a holding shell for this property, as
`part of their single business enterprise; the operating address of this entity is 268 Bush
`St., #1688, SAN FRANCISCO, CA 94104, which address is a mailbox only, and which
`address until recently was
`the shared mailing address
`for OWNERSHIP
`DEFENDANTS and also for CORPORATE DEFENDANTS);
`1440 SUTTER STREET, LLC owns and/or owned 1440 Sutter Street, San Francisco, CA
`during all relevant times alleged herein (the entity was created by CORPORATE
`DEFENDANTS and Yat Pang Au as a holding shell for this property, as part of their
`single business enterprise; the operating address of this entity is 268 Bush St., #1688,
`SAN FRANCISCO CA 94104, which address is a mailbox only, and which address until
`recently was the shared mailing address for OWNERSHIP DEFENDANTS and also for
`CORPORATE DEFENDANTS);
`57 TAYLOR I7, LP owns and/or owned 57 Taylor Street, San Francisco, CA during all
`relevant times alleged herein (the entity was created by CORPORATE DEFENDANTS
`and Yat Pang Au as a holding shell for this property, as part of their single business
`enterprise;
`the operating address of
`this entity
`is 268 Bush St., #1688,
`SAN FRANCISCO CA 94104, which address is a mailbox only, and which address until
`recently was the shared mailing address for OWNERSHIP DEFENDANTS and also for
`CORPORATE DEFENDANTS);
`655 POWELL I5 LLC holds and/or held title 655 Powell Street, San Francisco, CA during
` (the entity was created by CORPORATE
`all relevant
`times alleged herein
`DEFENDANTS and Yat Pang Au as a holding shell for this property, as part of their
`single business enterprise; the operating address of this entity is 268 Bush St., #1688,
`
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`________________________________________ - 10 -
`Evander, et al. v. Veritas Investments, Inc., et al. – Third Amended Complaint for Damages, Injunctive Relief, and
`Equitable Relief
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`A Professional Law Corporation
`Bracamontes & Vlasak
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`www.bvlawsf.com
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`SAN FRANCISCO CA 94104, which address is a mailbox only, and which address until
`recently was the shared mailing address for OWNERSHIP DEFENDANTS and also for
`CORPORATE DEFENDANTS);
`2730 SACRAMENTO I4, LLC owns and/or owned 2730 Sacramento Street, San Francisco,
`CA during all relevant times alleged herein (the entity was created by CORPORATE
`DEFENDANTS and Yat Pang Au as a holding shell for this property, as part of their
`single business enterprise; the operating address of this entity is 268 Bush St., #1688,
`SAN FRANCISCO CA 94104, which address is a mailbox only, and which address until
`recently was the shared mailing address for OWNERSHIP DEFENDANTS and also for
`CORPORATE DEFENDANTS);
`3659 20TH STREET, LLC dba Telegraph Hill Vistas, LLC owns and/or owned 3663 20th
`Street, San Francisco, CA during all relevant times alleged herein (the entity was created by
`CORPORATE DEFENDANTS and Yat Pang Au as a holding shell for this property, as
`part of their single business enterprise; the operating address of this entity is 268 Bush
`St., #1688, SAN FRANCISCO CA 94104, which address is a mailbox only, and which
`address until recently was
`the shared mailing address
`for OWNERSHIP
`DEFENDANTS and also for CORPORATE DEFENDANTS);
`916 PACIFIC I5, LLC owns and/or owned 916 Pacific Avenue, San Francisco CA during all
`relevant times alleged herein (the entity was created by CORPORATE DEFENDANTS
`and Yat Pang Au as a holding shell for this property, as part of their single business
`enterprise;
`the operating address of
`this entity
`is 268 Bush St., #1688,
`SAN FRANCISCO CA 94104, which address is a mailbox only, and which address until
`recently was the shared mailing address for OWNERSHIP DEFENDANTS and also for
`CORPORATE DEFENDANTS);
`1075 O’FARREL STREET LLC owns and/or owned 1075 O’Farrell Street, San Francisco,
`CA during all relevant times alleged herein (the entity was created by CORPORATE
`DEFENDANTS and Yat Pang Au as a holding shell for this property, as part of their
`single business enterprise; the operating address of this entity is 600 Montgomery Street,
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`________________________________________ - 11 -
`Evander, et al. v. Veritas Investments, Inc., et al. – Third Amended Complaint for Damages, Injunctive Relief, and
`Equitable Relief
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`A Professional Law Corporation
`Bracamontes & Vlasak
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`www.bvlawsf.com
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`14th Floor, SAN FRANCISCO CA 94111, which address is the office of CORPORATE
`DEFENDANTS’ attorneys: Lubin Olson & Niewiadomski LLP);
`920 LEAVENWORTH I5 LLC owns and/or owned 920 Leavenworth Street, San Francisco,
`CA during all relevant times alleged herein (the entity was created by CORPORATE
`DEFENDANTS and Yat Pang Au as a holding shell for this property, as part of their
`single business enterprise; the operating address of this entity is 268 Bush St., #1688,
`SAN FRANCISCO CA 94104, which address is a mailbox only, and which address until
`recently was the shared mailing address for OWNERSHIP DEFENDANTS and also for
`CORPORATE DEFENDANTS);
`990 FULTON I2 LLC owns and/or owned 990 Fulton Street, San Francisco, CA during all
`relevant times alleged herein (the entity was created by CORPORATE DEFENDANTS
`and Yat Pang Au as a holding shell for this property, as part of their single business
`enterprise;
`the operating address of
`this entity
`is 268 Bush St., #1688,
`SAN FRANCISCO CA 94104, which address is a mailbox only, and which address until
`recently was the shared mailing address for OWNERSHIP DEFENDANTS and also for
`CORPORATE DEFENDANTS);
`337 10TH I5 LLC owns and/or owned 337 10th Avenue, San Francisco, CA during all
`relevant times alleged herein (the entity was created by CORPORATE DEFENDANTS
`and Yat Pang Au as a holding shell for this property, as part of their single business
`enterprise;
`the operating address of
`this entity
`is 268 Bush St., #1688,
`SAN FRANCISCO CA 94104, which address is a mailbox only, and which address until
`recently was the shared mailing address for OWNERSHIP DEFENDANTS and also for
`CORPORATE DEFENDANTS);
`845 CALIFORNIA STREET LLC owns and/or owned 845 California Street, San Francisco,
`CA during all relevant times alleged herein (the entity was created by CORPORATE
`DEFENDANTS and Yat Pang Au as a holding shell for this property, as part of their
`single business enterprise; the operating address of this entity is 268 Bush St., #1688,
`SAN FRANCISCO CA 94104, which address is a mailbox only, and which address until
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`________________________________________ - 12 -
`Evander, et al. v. Veritas Investments, Inc., et al. – Third Amended Complaint for Damages, Injunctive Relief, and
`Equitable Relief
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`A Professional Law Corporation
`Bracamontes & Vlasak
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`www.bvlawsf.com
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`recently was the shared mailing address for OWNERSHIP DEFENDANTS and also for
`CORPORATE DEFENDANTS);
`709 GEARY STREET LLC owns and/or owned 709 Geary Street, San Francisco, CA during
`all relevant times alleged herein (the entity was created by CORPORATE DEFENDANTS
`and Yat Pang Au as a holding shell for this property, as part of their single business
`enterprise;
`the operating address of
`this entity
`is 268 Bush St., #1688,
`SAN FRANCISCO CA 94104, which address is a mailbox only, and which address until
`recently was the shared mailing address for OWNERSHIP DEFENDANTS and also for
`CORPORATE DEFENDANTS);
`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 (the entity was
`created by CORPORATE DEFENDANTS and Yat Pang Au as a holding shell for this
`property, as part of their single business enterprise; the operating address of this entity
`is 268 Bush St., #1688, SAN FRANCISCO CA 94104, which address is a mailbox only,
`and which address until recently was the shared mailing address for OWNERSHIP
`DEFENDANTS and also for CORPORATE DEFENDANTS);
`336-350 JUDAH I3, LP owns and/or owned 350 Judah Street, San Francisco, CA during all
`relevant times alleged herein (the entity was created by CORPORATE DEFENDANTS
`and Yat Pang Au as a holding shell for this property, as part of their single business
`enterprise; the operating address of this entity is 600 California St., 20th Floor, SAN
`FRANCISCO CA 94108, which address until recently was the shared office address for
`CORPORATE DEFENDANTS);
`698 BUSH C1, LP owns and/or owned 698 Bush Street, San Francisco, CA during all relevant
`times alleged herein (the entity was created by CORPORATE DEFENDANTS and Yat
`Pang Au as a holding shell for this property, as part of their single business enterprise;
`the in-state address of this entity, which is a mailing address, is 500 Washington St.,
`Suite 488, SAN FRANCISCO CA 94111, which address was previously the shared office
`address for CORPORATE DEFENDANTS);
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`________________________________________ - 13 -
`Evander, et al. v. Veritas Investments, Inc., et al. – Third Amended Complaint for Damages, Injunctive Relief, and
`Equitable Relief
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`A Professional Law Corporation
`Bracamontes & Vlasak
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`www.bvlawsf.com
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`915 PIERCE STREET, LLC owns and/or owned 915 Pierce Street, San Francisco, CA during
`all relevant times alleged herein (the entity was created by CORPORATE DEFENDANTS
`and Yat Pang Au as a holding shell for this property, as part of their single business
`enterprise; the operating address of this entity is 268 Bush St., #1688, SAN
`FRANCISCO CA 94104, which address is a mailbox only, and which address until
`recently was the shared mailing address for OWNERSHIP DEFENDANTS and also for
`CORPORATE DEFENDANTS);
`1819 GOLDEN GATE I1 LLC owns and/or owned 1819 Golden Gate Avenue, San
`Francisco, CA during all relevant times alleged herein (the entity was created by
`CORPORATE DEFENDANTS and Yat Pang Au as a holding shell for this property, as
`part of their single business enterprise; the operating address of this entity is 268 Bush
`St., #1688, SAN FRANCISCO CA 94104, which address is a mailbox only, and which
`address until recently was
`the shared mailing address
`for OWNERSHIP
`DEFENDANTS and also for CORPORATE DEFENDANTS);
`270 TURK, LLC owns and/or owned 270 Turk Street, San Francisco, CA during all relevant
`times alleged herein (the entity was created by CORPORATE DEFENDANTS and Yat
`Pang Au as a holding shell for this property, as part of their single business enterprise;
`the operating address of this entity is 268 Bush St., #1688, SAN FRANCISCO CA 94104,
`which address is a mailbox only, and which address until recently was the shared
`mailing address for OWNERSHIP DEFENDANTS and also for CORPORATE
`DEFENDANTS);
`610-660 CLIPPER I1, LLC owns and/or owned 610 Clipper Street, San Francisco, CA during
`all relevant times alleged herein (the entity was created by CORPORATE DEFENDANTS
`and Yat Pang Au as a holding shell for this property, as part of their single business
`enterprise; the operating address of this entity is 268 Bush St., #1688, SAN
`FRANCISCO CA 94104, which address is a mailbox only, and which address until
`recently was the shared mailing address for OWNERSHIP DEFENDANTS and also for
`CORPORATE DEFENDANTS);
`
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`________________________________________ - 14 -
`Evander, et al. v. Veritas Investments, Inc., et al. – Third Amended Complaint for Damages, Injunctive Relief, and
`Equitable Relief
`
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`A Professional Law Corporation
`Bracamontes & Vlasak
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`www.bvlawsf.com
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`721 GEARY I5, LLC owns and/or owned 721 Geary Street, San Francisco, CA during all
`relevant times alleged herein (the entity was created by CORPORATE DEFENDANTS
`and Yat Pang Au as a holding shell for this property, as part of their single business
`enterprise; the operating address of this entity is 268 Bush St., #1688, SAN
`FRANCISCO CA 94104, which address is a mailbox only, and which address until
`recently was the shared mailing address for OWNERSHIP DEFENDANTS and also for
`CORPORATE DEFENDANTS);
`720 BAKER I1, LLC owns and/or owned 720 Baker, San Francisco, CA during all relevant
`times alleged herein (the entity was created by CORPORATE DEFENDANTS and Yat
`Pang Au as a holding shell for this property, as part of their single business enterprise;
`the operating address of this entity is 268 Bush St., #1688, SAN FRANCISCO CA 94104,
`which address is a mailbox only, and which address until recently was the shared
`mailing address for OWNERSHIP DEFENDANTS and also for CORPORATE
`DEFENDANTS);
`SF 685 GEARY STREET, LLC owns and/or owned 685 Geary Street, San Francisco, CA
`during all relevant times alleged herein (the entity was created by CORPORATE
`DEFENDANTS and Yat Pang Au as a holding shell for this property, as part of their
`single business enterprise; the operating address of this entity is 268 Bush St., #1688,
`SAN FRANCISCO CA 94104, which address is a mailbox only, and which address until
`recently was the shared mailing address for OWNERSHIP DEFENDANTS and also for
`CORPORATE DEFENDANTS);
`3201 23RD I7 LP owns and/or owned 3201 23rd Street, San Francisco, CA during all relevant
`times alleged herein (the entity was created by CORPORATE DEFENDANTS and Yat
`Pang Au as a holding shell for this property, as part of their single business enterprise;
`the operating address of this entity is 268 Bush St., #1688, SAN FRANCISCO CA 94104,
`which address is a mailbox only, and which address until recently was the shared
`mailing address for OWNERSHIP DEFENDANTS and also for CORPORATE
`DEFENDANTS);
`
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`________________________________________ - 15 -
`Evander, et al. v. Veritas Investments, Inc., et al. – Third Amended Complaint for Damages, Injunctive Relief, and
`Equitable Relief
`
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`A Professional Law Corporation
`Bracamontes & Vlasak
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`www.bvlawsf.com
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`520 BUCHANAN STREET LLC owns and/or owned 520 Buchanan Street, San Francisco,
`CA during all relevant times alleged herein (the entity was created by CORPORATE
`DEFENDANTS and Yat Pang Au as a holding shell for this property, as part of their
`single business enterprise; the operating address of this entity is 268 Bush St., #1688,
`SAN FRANCISCO CA 94104, which address i