1ANDDOES 1?5-05, MASASHI TAKAHASHI, i STEAM LABS, ma; SEAN Bradford. Fieyd-(SBN 136459} Email: bc?gvm?mdlaw?mm LY Cariten D. Playd (SEN 275958)- E-mail cd?a?vd?l?wdlaw?rm.net Fleyd Law Firm, A Califwmia Partnership Superior Court of Carffornfa, County of San Francisco 819=Sevenih?tr?et Eureka, California 95501 avmummnnes T?fl?ph?n?i Deputy Clerk Facsimil?; (767) 445 6915 Aftomeys far Dafendants, Takahashi, Masashi Takahashi; Margaret Takahashi; and D033 1?50. SUPERIOR THE STATE OF CALIFORNIA IN AND THE COUNTY OF SAN FRANCISCO STEAM 3 Case Plaintiff; V. TAKAHASHLMASASHI MARGARET Defendant. CroSs-CnmpiainanL v. EDI-IN FRANCIS PATRICIA R. KILLEEN and DOES 2?50 CROSS 1 3,.28 Parties. Cross-Camplainant Masaahi Ta'leahaehi was; and is a resident 0f San and the owner ef the praperty- at 3183-3185 Misaiaa Street, San Francisco,'CA 94'} :30. CroaswCemplaiaant Takahashi is over 65 years 0f age. Crass?efeadant Steam Labs? Inc. is. an entity registered as a Califemia menupre?t corp-oration. Crees~DafEndant Sean Killer; is and was a resident of San Franciseag and is. ihe CEO of Cress~Defbndaat Steam Labs}, Inc. CressuD'eferrdant Jeseph Nobie is arid was a. resident San Frameisee, and is an agenr of. Steam.;Laba. CresamDefEHd-ant 011:} Francis Kilian is an investor-anti partner in Steam Labs? and a resident of Califamia Cross-Defendant Patricia R. Kilien is anjinveSth and. part?er in Steam Labs, and a resident 0f Califemia. Croas?Cemplainant is ignorant ef the true names and capacities of Rees-1. through 100-, reclusive, and th-erefere see these Cress?Ebefendanta by each fietitieus names. will amen-d this complaint to aliege the true names afauch Crass? Defendanfe whentheir true names and capacities are ascertained. is informed-arid behaves and an that basis; alleges; that a1 all times mentioned in: this mmplaint, Crossn?efendanta were the agent-s aadempioyeea ef-their ca?- Cresa?Defendants, and in de-irig?the things alleged in this: camplaiat Were 'aetinjg within the mama and scape 0f that ageney and emplaymenh JCRQESWCOMFLAINT: Case 2 10 1.1 12 13 14 13ll. 12. 1.4. . 17,. 38. 19. 20. Steam Labs" did rim; and does not, camera?ie fOTlTl-?llii?s. Staam Labs shares and funds with multiple ether entities-1, and private individuals. Steam Labs: mi'sed and mmptecl iiWe-Stment 111011535 despite being a nampm?t. Sic-arr]; Labsgf?wrs/dimctors usad. Cqui?atr: funds. fmitlwir personal despita the cargoratim?i?s lack of per-er capitalizatiun. Elwin-Labs was usacl as a criminal liability shield while Cf?SS-D?f??da?tS operatecl an illegal cannabis delivery sawice, SteamLaljs has he: asset's. Steam Labs is being used HEW solely as a .ciVil liability shield to protect againgl: Wilmer- claims- arising C'ifOSS?Defanclants? frivalws sui? .-Based; on. the ab?ve? CrassQDefendants are jointly and severally liable far Steam Lam? aats because if; wauld be unjust it} allow this: camara?ce veil t0 protect 'Cross?Def?n'dants'. Ba??d 201.}. the allow, Cress-Defwdantsare jointly and SeVerally liable far Steam. Labs? acts 1336211156 Crass?Dcfendants are a partnership. Cross?Dngiidalits, 321011 and every 01516 (if then; poolad tlieirrcsources togathar, fanning a partnership", far the purpose of making a from tha sale of cannabis. In 2015, Steam Labs was Greatacl pmvide a criminal. liability shiald whim Cross:- Defehclanlis delivered medical ea?nab'is. In December 2015., Steam Labssigned a 133% farfll Street. . Caae 10 11 3.2 13 1-41 15 16 2121. 22. 23.. 24. 25. 26.. .27. 28. In January 2016., articies were ?led with iha Califmnia Secretary 0f State, creating-T113 New Bernal Heights, Ina. The-y are Sigma-d by Crass?Defendant Sean Killer]. In January 2016., a leitey W215 Sigma by 1:15:19 quicgt of Crass? Defendant Sean Kilian, stating that they were tbs: for Bernal Heights.? In February 2016, Steam Labs assigned all its. rights 133.1116 lease. fin? 3.185 1341331011 Street to: nonwparty New Banal Heights. The assignment was done so that an application 1:0 operate a maadic-al cannabis dispensary could be far New Bernal Heights with the City {if San Francisco Department (3f Haaltl}. Ih.F613rLlary 2016; an application fer New Emmi Heights. to 0133272116. an MCD 9.13185 Missicm Street was filed with. the: SF "13131-1. Th6. application 1110111de the: lease,. the asSignm.ent,, and a check with Crosstefendan? Sean Killen?s signature, drawn his account, and with the manic} reading, ?New Bernal.? In June 2016, CmssuDefm?an?tS Sean Kilian and Jaseph Neble burned several of their them off ciom'pletaly, and taking Everythingfm themgelws. 111111118 .2016, Cregs?efendant Sean Kilian mmdi?ad the: MCD application withrha DPH lay-ramming his ex~partnezrs names. and changing entity from Naw 13611131 Heights, 1:0 Being]. Haights 'CGlleative. Natab'ly, Crass-Defmdant {litlil?t_put Steam Labs the Ammded MCD Application. In. July 20.113, .Cr?ss-Defen?atits: Sean-Kiilan and Noble began the unlicensed sale 0f cannabis from-3185 Missien Street. They ware issued a cease and desigt {rem the SF 13131-1 themafter. 21311 7. in response 10 a lawsuit by the 8114121311116ng Cis??Defeizciants mare tinder penalty Case 4 29.. i 30. 31, 32. 33.- 34. 3-5, 361 '31. 0f peljury that they are no: i?I?m?bm?S! 61? dimmers Qf New Berna] 'H?i'ghts. 011 August ?16, 12017, New Bamal Heights ?led-a mmplaimfm ihii? eviction 0mes3- Defendants, (131:1 NWembcr 8-, 2017 the Wfi?t of 133886531011 Was enfm?cw by the Sheriff?s Department a?d Cross-Eefan?ants were: locked out of the Subject prupenfy. FIRST CAUSE OF ACTION INTENTIONAL- INTERFERENCE WITH CONTRACT (Against All Cres?s?COmplaina?t aiieges and incumorates herein by refere?ce all allegatians; mntained in paragraphs 21. {ha-rough 30' with the same: force a11deffect as; though. ?lliy. 5111.: fart}: herein! Takahashi enteredinto a 00-11mm: sell his pmpertyto a'third party. Cross~Def?ndants knew that CIQSSwaQIan-aiamm Takahashzi into a contract to sell his property 1:61 a third party. ?led the instant $1.111:th prevmt.thejp?1r?hasc Gamma-t; {110_Si_11g, 1:31" at 183311 make it mere dif?cuit and expansive?to (31986. Crass?Defendants? suit did preventTakahashi?S-pmchasa contract {mm chasing, am has made. it more expensive. is banned in thatthe purchase contract cannot 0198:: until this suit is is ?lrther h'a?ned in that he is. i?mculTing Iegai fees 351:1 casts 3:0 navigate the situatien that Cross-Defendants? suit has mused. SECONB CAUSE OF ACTION IICROSSQCOMPLAINT Case .5 'ELDER. FINANCIAL ABUSE {Against All Cram-Defendants). 38. alleges and here-in by refemmce all allegatim?ia CQ'ntained in paragraphs 1 ilirmgh 37 with the same farm and effect as though-fully set'faiih hermi?n. 3:9. CroS?s-Defendahta took Ci?assm?mnpi?ainant?s property in that CmSSeCmI-iplainant was. fumed :9 Spend nmney todefend agaihst a baseless. lawsuit filed by Cress?Defendants. 4.0. Crass?Defendants knew. sir-should have: known, that ?ling a- baaeless lawsuit wag likely to harm. 431. harmed by Cross?Dafendams ?ling of a hass?flags suit in that he: was fhrced?te Spend: his 112102113th mount a def?nse. 42.. Crass?'?efendants? suit was the: primary cause of Cross?Complainan? harm. THIRD CAUSE 0F ACTION INTENTIONAL (Against All Cross?Defandants) 43. zillegais andfinmrporates herain by reference all allegatimis containe? in paragraphs; 1 thmugh 42 with the same-farce and Effect as thaugh hilly get forth herein. -- 44L. Crass?Defendantsrepresented that they were-the parties in central of New Bernal Heights, 11:10., and that they had unfettered authority it) makedccisions ?jr the entity. 4S. Hawaiian Cross-Defendants did nothave. any authm?iiy to make; decisions far The New Bemai Ina, and ?act Being sued by awry, lei-3i, ?f their partners far the {if the entity?s agsets. Gaga 45 47. 48. 49? 50.. 52 . 53' Cress-?efendants made their Statements regarding the authority to act fer The New Bernal Heights; Inc. with reeklees disregard for the truth 0f the matter-by failing to explain the ongoing disputes with their err?partners. CresewDefender?tte itrteeded fer CreesLCer?rrpleinents?te their StatEmente. Cress?emplairraets did rely on Crees~Defendarrt3? they acted} in that they weuid netlreve requested that. CresewDetendents reveke an assignment that they had. 110 authority te revoke. CresanOmpIeinants were damaged by Cress-Defendante? false stetemente in: that Cress: Cempleieantsineurred attorney?s fees and are now faced with this meter-1t seitmpremised .301er (311 legally void. decrement they were "trick-ed. inte requesting freer Cresew?efendents. CresshDetEndarrts damages were Substantially caused by Crees?Defendente false assertions. FOURTH CAUSE OF ACTION NEGLIGENT MISREPQRESENTATIGN (Against All Cress-Defmdants) 5.1Cresewcemplainantalleges andineerperetes herein by reference alluallegetiens centeined. in paragraphs .1 through 50 Wit-11th:: same force and effect as though-fell}; set ferth herein.- . Cress?Defendants represented that the-y'were the parties in centre} efNew Bernal Heights? and that they had ttrr~fetteretl"autherity te meke decisions fer the entity. . Hewever, =Cress~Defer1dentjs ritd'rret haveaey' eutherity to make for The New Bemel Heights, 1210,, and were in feet-being sued by every, test, ene .01? their partners for the theft at" the eetity?s esset3.. Case NO . 1 8 5 7? .56 57.. 58, '60 61 made than Statements: regarding fh?: authority to act fanhn New Bamal Heights, {110. with HG reasonable basin for believing that to be: true given their swam Statement? in nthet (3215628. 'C?tossJDefandants for to rcty on their statements. did rat}; nn Crass?Detentiants" what} they ant-eds, in that they wnuid not have: requested that CI?Oss-Defandants revnkn an that they had-110 authnrity t0 revnke. were damagedby Cress~D=efendants? false statements in" that (Irons-? incurred fee-S and am new facctt with thin instant sotely 011a. lega?y mid wens triaknd into requesting from Ctn.SS?Defnndants.. d-aznagen were caused by false FIFTH CAUSE 0F ACTIQN CONCEALMENT (Against Ail Cr?ss~?ef?ndant? 596,. aliegas herein-by I?Bf?i??ll?? all contained in paragraphs i through 58 with thesatne force: and effect 3-3 thangh-tully-set forth herein.- . Cross?Defandants raptesentcd that theyWet?e the parties" in annual at New Bamai Heights, 1110., and that theyhad un??attered authority to make decisions to; the antiiy. . HDWEVEF, did nnt- hayeany authority in. make decisions for. Th6 New Bernat Heights, 1210., and Were in fast being ?ned by awry1 last} {3116: at their partners fer the inf-the entity?s assets. Casa . 85: 62. 63. 64. 65. '66. 2.67. 68. 69. 70 7t Crossw?efandants made their staten?lents I'Bgardihg the authmrity to act far The NEW 13:3in Heights, while concealing the Did-gaing disputes: with their ex?pm?tl?ters. C'mssufjefandantg cancealad the infon?atian intentimaily and in bad faith. intended for Cress?"Camplaina?ts ?ta rely 011 their statements. (Ir-msownpiainants did r933; ?lmy acted, in that they would 1101; have requested that rcvake an assignmrant that they had 110 authmity-t? revake. 'CmsS~Complainants (lid mt know about the ongoing diSpulGS. were damagadby false Stat?mmts in that Crass; .incurrsd attomey?s and are DGW fast-Lid with this. imit?ant 30131)! m1 a-legally weld clueument-they were tricked inta requesting Cmss~Defendant3 Cross-Defendants damages were substantially caused-by Crass?Defendants false assertims. SIXTH CAUSE XNFLICTICN 0F EMGTIONAL- (Against All Emss?--C-0mplai11ant allege-s ami incerpomtes herein by reference all allegations CD'BEai?ed in paragraphs '1 thraugh 67 with the sauna- force and eff?ct as though fully set" farm lie-r8111. Cmsseljafe?dants hell to Cress?Campla?ina?ts abuut their to act for the entity in wutml Df the ISBSE: for 3185-.Mi33i29n Sarn- anc-lsm? CA 941.10. ?led a law-Suit t0 extent a settlement paymant from Crass-? Complainants. I Case No.0Gcwl7w561785 .9. 173. Lying,_ to faiariCate documents, to manufam'ure-ra 133361-635 legal in. ?74. As a. regult'of Crossw?efendantg? actg, Sufferad 611195011211 distresg; such acts. playing a substantial. 1016 in causing this: distress. WHEREFOR-E, Cross-Cmupiainant prays- far judgment against defendant/s as sat fez-rib below. I As {he FIRST through SIXTH CAUSES OF ACTEQN: I 1. damages to be determin?d by the wurt; 2. GEnemuikgnagasasson?ngtopnoo? 3. Oasis of suit; Rraasam?i?e attame'y?s fees; and, SECOND- CAUSE OF ACTION: 1. Triple punitive damages; General damages. according: tq pram?; 4m 5.: Coats 0f suit; 10 Case I Reamnabie: attorney?s. feas; and, 7. Any- (Ether mficf that. the Court .{it?zems pr?per. THIN) CAUSE OF ACTION: 1. C-ompmsamry damag?s ti) be dmmined by the. court; 2. awarding t0 pmof; 3 Spaaial damagas accmdingto proof; 4. Costs 0f wit; Reasomble- attemey?s fees; and, 6. Any other relief that the; Causit dgems proper. FGURTH CAUSE OF ACTION: 1. Compensatory damages to be. determined by tha 2. General damages- acmrding t0 mod; Special damages awarding to proof; Casts bf wit; 5. Reasmxable atmmey?sfees; and, Any other-relief fhat-the Cams: deems proper, FIFTH CAUSE OF ACTION: 1.. 'Punitivedamagcs; 2. Generaldamages according t0 pmaf; Special damages according 1m p'me; Case IE 13. Casts of Suit; 5. Reasanable atmm?y?s few; and, 6. Any ether re'iief {hat the Court d?ems pmper; 7. Camp?nsatmy 'damagag to be detei'mined by the court. CAUSE 0F ACTEUN: damages; 2.. Compensatory damages to he determincd by the mutt; 3-. Gemral damages; accoi?ding t0 pmaf; 4. Special damages awarding to proof; 5. Costs (3f suit; 6? Raasonable atmmey?s feas;.andj Any rather reiief that thus deems proper. .r ?if; FLOYD LAW FIRM Dated: January 24, 2018 83" MM ?f gCarEitQ?m?f?yF'layd; Atfbfixey for CROSS Cage 12 PROOF OF SERWCE 'l?ho undersigned declares; lam over iho ago. of 8 wars and mot a party to this. action. My addreog is;- 8 l, .9 Sawmill Smog Eureka, California, which is loomed it: l-lumboldt Coumty the SSW-lei?? dos-orib-ed loo-low ?09k plow. (311 January 243 2018, I. sowed all parties; in mid action with the following documents: CROSS mi LES. Mail: byplaomg a true copy thereof encloacd in a sealed oovclope, addressad as below and placing tho Envelope: ?for oollootion and mailing on the date am? at the place Shown below, following our ofclinary businesg practices. I am readily familiar bis-smoss? practice for collecting and procosoing co?espondencofor mailing. On the game: clay that-{borrogpondenoe is [3!an for oollootion and mailing, it is depositod in the ordinary course ol?busioosg with the United States Postal. Sowioe in a sealed envelope with postage fully prepaid. Personal Servicfe: by placing a. true copy theroof enclosed in a sealed onvolopog addressed as-shown below and causing samo to be: dolivcm? to the individual nan-13d boiow or'to that indivitiual in care of a mambo? of'herfhis of?c?'prior to 5:09 pm. ()vemight Mail: by placing-a. true copy thereof in a sealed omelopo addressed its; shoWn below and causing said envelop-e to be ?epogitod in a box or other faoil?ty rogularly mainmimod by the expross service, or delivefed to an Hailmrizod courier or Eiriver autho?zed by the oxpross Sowing? came]? to receive- documenig, in an envelope or package by the Express sowice carrier with delivery fooa paid or provided for. Faosimile Traosmi?sion: by transmitting a true copy thereof from fax telephone number- 7074455915 to the porsor?s) at the fax Humbo?s) indioatod bolow. The transmiSSion Was reported. as complete and Without and such report: was proporly issued by the transmitting fax maol?no. Email or Electronic Transmission: Basal on aoourt order or an agreement of the parties to sowiot: by email or oloctronio cam-3d. tho documentg to be son: to tho persons; at; tho o-mail Moms-36$ or at tho famimilo numbers listed below. ABBRESSEHS): Na?il Benjamin, Esq. Momma Poppor, Esq. BENJAMIN LAW GROUP, RC. 1290 Street: Sui?e 314 Hayward, CA 94541 ldoclare undo-1' penalty ofporjory undor the laws; of the State of Califomia that the foregoing i3 two and oorfoot. Exooutod Januaiy 245 2.018 at Eurega, li?fomi H?athor L. Kamila}?