eee 10 oT R 13 4 15 16 7 18 19 20 2 2 2B 24 25 26 2 28 Lisa Bloom (SBN: 158458) Jivaka Candappa (SBN: 225919) FILED, sf California THE BLOOM FIRM superior CO our tel 20700 Ventura Blvd., Suite 301 18 ‘Woodland Hills, CA 91364 JAN 30 10 Telephone: (818) 914-7320 sui ret Ok 1H Attomeys for Plaintiff, LIANNA SHAKHNAZARIAN » Depaly a Robinson SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES BY| FAX BC6 91527 LIANNA SHAKHNAZARIAN, an individual, CASE NO.: Plaintiff, COMPLAINT FOR DAMAGES: v. PROFESSIONAL NEGLIGENCE; FRAUD - CONCEALMENT; 3. FRAUD ~ INTENTIONAL MISREPRESENTATION; 4, BREACH OF CONTRACT; BREACH OF FIDUCIARY DUTY; 2 ) ) 2 ) FREEDMAN + TAITELMAN, LLP, an ona) } } 6 BEACH OF THE IMPLIED COVENANT } ) ) ) ) ) ) ) BRYAN FREEDMAN, an individual; PATRICIA ARIAS MUSITANO, an inéividual; and DOES 1-10, inclusive, Defendants. OF GOOD FAITH AND FAIR DEALING Plaintiff LANNA SHAKHNAZARIAN hereby complains, alleges and brings suit against DEFENDANTS FREEDMAN + TAITELMAN, LLP, BRYAN FREEDMAN, PATRICIA ARIAS MUSITANO, and DOES 1-10, inclusive, on the causes of action enumerated above as follows: > COMPLAINT FOR DAMAGES ‘LIANNA SHAKHNAZARIAN v. FREEDMAN + TAITELMAN, LLP, et al,#60 BOTPELSOSHIS ezstes9aul 12 13 4 15 16 W7 18 19 20 2 22 23 24 25 26 21 28 PARTIES 1, Plaintiff is an individual residing in Tarzana, California. 2. On information and belief Defendant FREEDMAN + TAITELMAN, LLP ("Freedman and Taitelman") is a California limited liability partnership duly organized and existing under the laws of the State of California with its principal place of business in the County of Los Angeles. 3. On information and belief Defendant BRYAN FREEDMAN ("Freedman") is an individual residing in California, and an attomey at law licensed to practice in California with ‘an office in Los Angeles County, California. 4, On information and belief Defendant PATRICIA ARIAS MUSITANO ("Musitano") is an individual residing in California, and an attomey at law licensed to practice in California with an office in Los Angeles County, California. 5. Atall times set forth herein, Defendant Freedman was a partner and agent of Defendant Freedman and Taitelman, and was acting within the scope of such employment and agency in connection with all matters set forth in this pleading, 6. Atall times set forth herein, Defendant Musitano was an employee and agent of Defendant Freedman and Taitelman, and was acting within the scope of such employment and agency in connection with all matters set forth in this pleading. 7. The true names of Defendants named as Doe 1 through Doe 10 are presently unknown to Plaintiff. Plaintiff will amend this Complaint setting forth the true names of these Doe Defendants when they are ascertained. Plaintiff is informed and believes, and that basis, alleges that each of the Doe Defendants participated in the acts, as alleged in this Complaint. 8. Atall times set forth herein, Defendant Freedman and Taitelman and Does 1 through 10, and each of them, were and now are, attorneys at law, duly admitted and licensed to practice law in the State of California, and doing business in Los Angeles County, California, JURISDICTION AND VENU 9. The Court has personal jurisdiction over Defendant, Freedman and Taitelman because it is a California entity with its principal place of business in Los Angeles County, COMPLAINT FOR DAMAGES LIANNA SHAKHNAZARIAN v. FREEDMAN + TAITELMAN, LLP, et al. 2