This document is a complaint filed in the Superior Court of California, County of Los Angeles by plaintiffs Abdullah Abed and Diana Abed against defendant Michael Stevenson and Doe defendants 1-4 for breach of a residential lease agreement. The complaint alleges that Stevenson failed to pay rent beginning in October 2010 and abandoned the leased property without permission, in violation of the terms of the one-year lease agreement. The plaintiffs are seeking unpaid rent, damages for repairs, replacement of removed property, attorneys' fees, costs, and other relief from the court.

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MOTAZ M. GERGES, SBN 202175
LAW OFFICES OF MOTAZ M. GERGES
21550 OXNARD STREET, SUITE 300
WOODLAND HILLS CA 91367
PHONE: 818-279-2749
FAX: 818-401-0711
EMAIL: mgerges@aol.com
Attorneys for Plaintiffs
Abdullah Abed and Diana Abed
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES, NORTHWEST JUDICIAL DISTRICT
VAN NUYS COURTHOUSE

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ABDULLAH ABED AND DIANA ABED
PLAINTIFFS,
V.
MICHAEL STEVENSON, and DOES 1
TO 4, inclusive,
DEFENDANT.
)
) Case No.
)
) COMPLAINT FOR BREACH OF LEASE
) AND RENT
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INTRODUCTION
1. COME NOW Plaintiffs, by and through their counsel, the Law Office of
Motaz M. Gerges, and to show the Court the following:

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2. Plaintiffs, Abdullah Abed and Diana Abed(“hereinafter Abed”), are
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individuals and are now and at all times mentioned in this complaint were,
a resident of Los Angeles County, California.
3. Plaintiffs are now and at all times mentioned in this complaint were, the
owner of the single family resident located at 5015 Escobedo Drive,
Woodland Hills CA 91364, (the “Subject Property”).

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4. Defendant, Michael Stevenson (“Stevenson”), is now, and at all times
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mentioned in this complaint was, individual residing in Los Angeles
County, California.
5. Plaintiffs do not know the true name of defendants DOES 1 through 4, and
therefore sue them by those fictitious names. Plaintiffs are informed and
believe, and on the basis of that information and belief allege, that each of

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those defendants was in some manner legally responsible for the events
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and happenings alleged in this complaint and for plaintiffs’ damages. The
names, capacities and relationships of DOES 1 through will be alleged by
amendment to this complaint when they are known.
JURISDICTION AND VENUE

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6. This Court has proper jurisdiction over this action pursuant to §410.10 of
the California Code of Civil Procedure. The violations of law complained
of herein occurred in this county. Furthermore, the amounts in
controversy exceed the jurisdictional minimum of this Court.
7. Venue is proper in the Superior Court of the County of Los Angeles
pursuant to California Code of Civil Procedure §§395 and 395.5.

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CAUSE OF ACTION
Breach of Contract
8. On or about May 4, 2010, plaintiffs and defendant entered into a written
lease for the premises described in paragraph 2, under the terms of which
plaintiffs leased the premises to defendant for the term of One Year (1) at
the agreed monthly rent of Three Thousand Five Hundred Dollars

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($3,500.00) payable in advance on the first day of each month commencing
on May 10, 2010 and terminating on May 10, 2011. A copy of the lease
agreement is attached to this complaint as Exhibit “1” and is incorporated
by reference.

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9. Defendant entered into possession of the premises on May 10, 2010, and
paid the monthly rent pursuant to the lease terms from May 10, 2010 to
May 31, 2010.
10. Defendants failed to pay plaintiffs the monthly rent on October 1, 2010,
and have failed to pay to plaintiff any part of the rent owing on or
becoming due since that date. Further, on or October 17, 2010, without
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plaintiffs’ consent or agreement, and contrary to the term of the lease,
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defendant vacated and abandoned the premises.
11. The lease described in paragraph 2 and attached to this complaint as
Exhibit 1 specifically provides in section 35 that even though defendant
has breached the lease and abandoned the property, the lease will continue
in effect for so long as plaintiff does not terminate the defendants' rights

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to possession, and that plaintiff may enforce all plaintiffs’ rights and
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remedies under the lease, including the right to recover rent as it becomes
due under the lease.
12. Plaintiffs have not terminated defendant's rights to possession of the
premises nor have plaintiffs terminated the lease.

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13. Plaintiffs have continued to perform all obligations and covenants
plaintiffs are obligated to perform under the lease.
14. Since October 1, 2010, defendant has failed to pay rent due and owing
under the terms of the lease. And has abounded the Subject Property by
leaving the premises over night without first informing Plaintiffs. As a
proximate result of defendant's failure to pay rent plaintiffs have been
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damaged in the amount of $10,762.50 which represents rent due and owing
for the period October 1, 2010, to December 31, 2010, plus interest on that
amount calculated at the legal rate.
15. Additionally, Plaintiffs were damaged in the amount of $260.00 for wood
blind repair and restring. Also Plaintiffs were damaged in the amount of

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$6,432.00 for repair and replacement of carpet in master Bedroom and 2 n d
bedroom including tax in the amount of $627.00.
16. Furthermore, Plaintiffs were damaged in the amount of $2,864.00 by way
of removal of Landlord’s Property more specifically, the Pioneer Elite
Plasma Television that was installed in the Living Room, and Samsung

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Plasma Television in the amount of $1,685.00, in accordance with
Paragraph 12, of the Lease Agreement.
17. Additionally, Plaintiffs are entitled for the actual cost of recovery of
damages in restoration of the Subject Property to rental condition,
advertising and net loss incurred in the amount of $1,500.00, in
accordance with Paragraph 35 of the lease.
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18. Plaintiffs are entitled to recovery of attorneys’ fees and court costs in
accordance with paragraph 20 of the lease provision providing for
recovery of attorney fees.
WHEREFORE, plaintiffs request the court enter a judgment against
defendant Michael Stevenson, awarding plaintiffs:
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1. Rent in the amount of $3,500, representing rent due for the periods of
October 1, 2010, to January 31, 2011, in the amount of $10,500.00; and
interest on this amount calculated at the legal rate;
2. Pre judgment interest on the rent amount at the legal rate beginning
October 1, 2010;
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3. For actual damages of replacement of carpet and wood blind including
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tax for the sum of $7,319.00;
4. For the cost of replacement of Pioneer Elite Plasma and Samsung Plasma
Televisions in the sum of $4,549.00;
5. For reasonable attorneys fees;
6. For the Costs of this suit; and

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7. Any other and further relief the court considers proper.
DATED: March 25, 2011
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LAW OFFICES OF MOTAZ M. GERGES

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___________________________
Motaz M. Gerges, Esq.
Attorneys for Plaintiffs