Excerpt: ...to the Shadafni Action, defendants Sharon Ajlouni and Karen Ajlouni (collectively, “Ajlounis”) filed a lawsuit against Hawari, Searles and SCI in Santa Clara County Superior Court, case number 1‐13‐CV‐242018 (“Ajlouni Action”). (Complaint, ¶¶6 – 8.) Defendant Michael Prozan (“Prozan”), a California licensed attorney, represented Shadafni and the Ajlounis in their respective actions against Hawari and others. (Complaint, ¶¶...

Excerpt: ...entered into an agreement with after the merger with Aemetis was terminated. As alleged in the third amended complaint (“TAC”), Edeniq was formed in 2008 and is the inventor and exclusive licensor of valuable technology that converts corn fiber into cellulosic ethanol. (TAC, ¶ 8.) This technology would be worth hundreds of millions of dollars if approved by the U.S. Environmental Protection Agency (“EPA”) but Edeniq was consistently unab...

Excerpt: ... ¶9.) At the time of said breach, defendant Chea owed the sum of $9,996.55 demand for which was made on September 10, 2015 and remains unpaid. (Complaint, ¶10.) Plaintiff Retirement Security Investment Group LLC (“RSIG”) acquired a debt portfolio from Cherrywood Enterprises, LLC consisting of personal loan debt. (Complaint, ¶6.) Plaintiff RSIG is a third party debt buyer and the holder of that certain debt portfolio defined as the Cash Cal...

Excerpt: ...Plaintiff's summons and complaint is DENIED. “A defendant is under no duty to respond in any way to a defectively served summons. It makes no difference that defendant had actual knowledge of the action. Such knowledge does not dispense with statutory requirements for service of summons.” (Weil & Brown et al., CAL. PRAC. GUIDE: CIV. PROC. BEFORE TRIAL (The Rutter Group 2018) ¶4:414, p. 4‐69 citing Kappel v. Bartlett (1988) 200 Cal.App.3d 1...

Excerpt: ... Shulmans are the current owners of 95 Mount Vernon Lane in Atherton (“Replacement Residence”). (Id.) Defendant RFBPO LLC (“LLC”) purchased the Original Residence on October 8, 2013 for $14 million dollars. (FAC, ¶¶4 and 9.) Defendant Santa Clara County Assessor's Office assessed the Original Residence value at $4.86 million dollars. (FAC, ¶4.) LLC is controlled and/or owned by Mark Zuckerberg (“Zuckerberg”), founder of Facebook. (...

Excerpt: ...ted on Mr. Usher's hand using a “MANOS device” “for a carpal tunnel repair.” (Second Amended Complaint (“SAC”) at pp. 4, 6.) Plaintiffs allege Dr. Yeh did not adequately disclose information about the MANOS device or his experience and skill using it. (SAC at pp. 6‐7.) Additionally, during the surgery, Dr. Yeh severed Mr. Usher's median nerve. (SAC at p. 4.) Subsequently, Mr. Usher told Dr. Yeh he had been experiencing “more pain ...

Excerpt: ...to assist plaintiff Yum in applying for and obtaining a modification of the first and second deeds of trust recorded against plaintiff Yum's property. (SAC, ¶8.) Defendant Yum verbally represented that he and/or defendants Nexus Line Inc. and Nexus Homes Inc. (collectively, “Nexus”) could obtain or provide plaintiff with a loan modification and prevent or stop any foreclosure of plaintiff's property, and that he had performed the same servic...

Excerpt: ...riage on September 15, 1996. (FAC, ¶12.) After marriage, Plaintiff and Defendant continued to reside together as husband and wife until March 6, 2016. (FAC, ¶13.) On or about February 1, 1992, Plaintiff and Defendant entered into an oral agreement by which they agreed to treat as joint property the earnings, income and all property acquired therewith, which resulted from all personal service, skill, effort, work, monetary contribution and non�...