Judge: David Sotelo, Case: 21STCV42690, Date: 2022-08-24 Tentative Ruling



Case Number: 21STCV42690    Hearing Date: August 24, 2022    Dept: 40

MOVING PARTY:               Plaintiff Agouram Abdelmajid (Motion for Preliminary Injunction);

Defendants Fahiem Gaffoor as Trustee to the Gaffoor Family Trust Dated August 18, 2014, Cameron Irons, Max Greenbriar Properties LLC, Max Le Grande Properties LLC, Max Valley Properties LLC, and SVN Vanguard (the “Business Entity Defendants”) (
Demurrer and Motion to Strike); and

Defendant Fahiem Gaffoor, as Individual (
Motion to Strike).

 

Several motions, all opposed, are before the Court, including: (1) a Motion for Preliminary Injunction made by Plaintiff Abdelmajid seeking to restrain the Defendants’ ability to harass or pursue unlawful detainer actions against Plaintiff Abdelmajid during the pendency of this litigation; (2) a Demurrer made by the Business Entity Defendants against all of the Complaint’s (thirteen) causes of action on sufficiency, uncertainty, and lack of clarity in pleading as to type of contract at issue; (3) a Motion to Strike made by the Business Entity Defendants against the Complaint’s punitive damages and attorney’s fees prayer allegations; and (4) a Motion to Strike the 19th to 32nd paragraphs from the Complaint as improper and irrelevant, as made by Fahiem Gaffoor, Individually, where the allegations include claims that Fahiem Gaffoor has had substance abuse problems, a troubled relationship with his father Mahomed Gaffoor and was/is envious of Plaintiff Abdelmajid’s prior relationship with Mahomed Gaffoor. For the reasons discussed infra, the Court:

 

(1) GRANTS Abdelmajid’s Motion for Preliminary Injunction;

 

(2) SUSTAINS, With Leave to Amend, the Business Entity Defendants’ Demurrer to the Complaint’s First through Seventh and Tenth through Thirteenth Causes of Action;

 

(3) OVERRULES the Business Entity Defendants’ Demurrer to the Complaint’s Eighth and Ninth Causes of Action but only as alleged against Defendant Cameron Irons;

 

(4) GRANTS the Business Entity Defendants’ Motion to Strike Punitive damages prayer allegations from the Complaint as to Defendants (a) Fahiem Gaffoor as Trustee to the Gaffoor Family Trust Dated August 18, 2014, (b) Max Greenbriar Properties LLC, (c) Max Le Grande Properties LLC, (d) Max Valley Properties LLC, and (e) SVN Vanguard;

 

 (5) DENIES the Business Entity Defendants’ Motion to Strike Punitive damages allegations as to Business Entity Defendant, Cameron Irons; and

 

(6) DENIES Defendant Fahiem Gaffoor’s Individual Motion to Strike Paragraphs 19 to 32 from the Complaint as irrelevant and improper.

 

Alleged Background

 

2008-2021:  Agouram Abdelmajid—apparently represented by counsel as of August 10, 2022, but theretofore appearing in pro per—was hired in 2008 by Mahomed Gaffoor (“Mahomed”) to serve as Mahomed’s Personal Assistant. Mahomed is the father of Defendant Fahiem Gaffoor. Abdelmajid states that, as personal assistant, he worked more than full time hours between 2008 and 2021, assisting Mahomed manage his vast business affairs related to real properties in California (Hollywood, Corona, Chino and Newport Beach) and in the Country of South Africa. Abdelmajid’s duties included visiting and inspecting these (close to 200 apartment unit) locations. Abdelmajid’s position of trust gave him access to many bank accounts owned and operated by Mahomed and his companies: Defendants Max Le Grande Properties, LLC, Max Greenbriar Properties, LLC, and Max Valley Properties, LLC.

 

Abdelmajid claims that Mahomed requested that Abdelmajid take on these duties because Mahomed was estranged from his family—particularly from his son Defendant Fahiem Gaffoor, who had allegedly moved to South Africa in 2018. According to Abdelmajid, much of the alienation between father and son stemmed from Fahiem Gaffoor’s alcoholism and gambling, which caused Fahiem to demand money from his religiously devoted father.

 

Plaintiff alleges that due to his own close relationship to Mahomed and Mahomed’s wife, the latter two individuals wished Abdelmajid to act as the Successor Trustee over the couple’s Trust following the couple’s death, i.e., the Gaffoor Family Trust Dated August 18, 2014, a trust that would benefit the Gaffoor’s children, including Fahiem.

 

Plaintiff alleges the Trust was amended four (4) times—in 2015, 2018, 2019 and 2021—and that each of those times, except for the last, the Trust contained a provision naming Abdelmajid as Successor Trustee, specifically disfavoring the Decedent’s son—Fahiem Gaffoor. The first three Amendments to the Trust also contained specific gifts to Abdelmajid, including a real property interest in the property located at 421 Mavis Drive, Los Angeles, California 90065 (hereafter, the “Mavis Property”), where Abdelmajid has a residence in Apartment #C.

 

During the years he worked for Mahomed, Plaintiff personally interacted with Fahiem Gaffoor and assisted Mahomed with problems that Mahomed experienced with Fahiem. The Complaint alleges that Fahiem held animus against Abdelmajid, born of Fahiem’s envy for the affection his father had toward Abdelmajid.

 

The Complaint alleges that Fahiem has, in the past, threatened Abdelmajid with physical harm and death, once chased Plaintiff in a vehicle pursuit, and once physically assaulted Plaintiff Abdelmajid, shoving the latter to the ground. This conduct increased after Mahomed and Fahiem appeared to have resolved their father/son differences sometime in August 2018.

 

2021-22: In January of 2021, Mahomed was hospitalized. (Mahomed’s wife had passed away years before in August of 2014, shortly after the Gaffoor Family Trust was executed on August 18, 2014, but before the four Amendments to the Gaffoor Family Trust were executed in 2015, 2018, 2019 and 2021.)

 

While Mahomed was still in the hospital, on January 22, 2021, a Fourth Amendment to the Gaffoor Family Trust was executed despite Mahomed’s infirm condition. The language of the Fourth Amendment to the Gaffoor Family Trust removed Abdelmajid as Successor Trustee and removed any previous gifts to Abdelmajid, i.e., an interest in the Mavis Property. Mahomed died the next day—on January 23, 2021.

 

Three days later, on January 26, 2021, Plaintiff was “frozen out” of all the bank accounts related to his work for Mahomed and Mahomed’s companies. Abdelmajid was also ‘locked out’ of all business transactions related to the properties and on-going real estate projects in Southern California and South Africa. One, or both, of the individual Defendants—Fahiem Gaffoor or Cameron Irons as commercial real estate manager over the properties—ordered the staff, contractors, lawyers, and all the tenants of each of the Defendant entities (the Max Greenbriar, Le Grande, and Valley Property companies) not to communicate with Plaintiff, but instead to keep track of his every movement—and to call the police if they saw Abdelmajid.

 

Defendant Fahiem Gaffoor (either individually and/or as Trustee of the Gaffoor Family Trust) thereafter hired Defendant Cameron Irons and Irons’s company, Defendant SVN Vanguard (a commercial real estate advisor and property management company) to oversee the assets owned by the Gaffoor Family Trust, including the Max Greenbriar, Le Grande, and Valley Property companies.

 

On February 24, 2021, Abdelmajid alleges to have filed some sort of Petition with the Los Angeles Superior Court seeking an Order confirming himself as Trustee over the Gaffoor Family Trust.

 

On February 26, 2021, Defendants—or a representative of the Defendants—went to the Mavis Property and told the tenants not to pay any rents to Abdelmajid.

 

On March 2, 2021, Abdelmajid obtained copy of the Fourth Amendment to the Gaffoor Family Trust.

 

On March 16, 2021, Abdelmajid filed a Petition with Orange County Superior Court for an Order invalidating the Fourth Amendment to the Gaffoor Family Trust and for Financial Elder Abuse, i.e., In re The Gaffoor Family Trust, dated August 18, 2014, as Amended and Restated (O.C. Super. Ct. Case No. 30-2021-01190223-PR-TR-CJC) (the “Orange County Probate Case”).

 

On March 25, 2021, Defendants threatened to tow Plaintiff’s vehicles from Plaintiff’s assigned parking space at the 1750 North Western Ave., Los Angeles, California 90027, where Abdelmajid has a residence in Apartment #207 (the “Le Grande Property”), if the vehicle was not removed by April 1, 2021. On May 5, 2021, the Defendants—or their agents—broke into Plaintiff Abdelmajid’s storage shed on the Le Grande Property, where Abdelmajid kept personal property.

 

Between May and October 2021, Defendants or their agents also broke into and/or trespassed on Plaintiff’s Le Grande and Mavis private quarters and property in different ways. On September 4, 2021, Plaintiff was informed that one of the Defendants would be changing the locks on Plaintiff’s quarters on the Mavis Property.

 

Between October 22, 2021 and November 8, 2021, Abdelmajid was served eviction-related notices by publication and by personal service at his rental units at the Mavis and Le Grande Properties. On the latter occasion—November 8, 2021—Cameron Irons effectuated the “personal service” of a substantial packet of legal documents on Plaintiff when Irons “push[ed] … documents in[to] the body of Plaintiff” while confronting Plaintiff outside his apartment at the Le Grande Property. (The Court notes that is the same date appearing on a proof of service related to the Orange County Probate matter.)

 

 

 

 

 

Complaint

 

Abdelmajid (as a self-represented litigant) then brought this action on November 19, 2021, alleging thirteen causes of action for:

 

(1) Wrongful Termination against All Defendants

(2) Breach of the Implied Covenant of “Good Cause” against All Defendants;

(3) Breach of the Implied Covenant of Good Faith and Fair Dealing against All Defendants;

(4) Unfair Business Practices against All Defendants;

(5) Failure to Prevent Discrimination, Harassment, and Retaliation in Violation of the Fair Employment and Housing Act (“FEHA”) against unclear but seemingly All Defendants;

(6) Violation of Labor Code section 6310 against All Defendants;

(7) Retaliation in Violation of FEHA against All Defendants;

(8) Assault against Fahiem Gaffoor Individually and Cameron Irons;

(9) Battery against Fahiem Gaffoor Individually and Cameron Irons;

(10) Trespass to Chattels against All Defendants;

(11) Harassment against All Defendants (unclear if based on FEHA or Penal Code);

(12) Wrongful/Unlawful Retaliatory Eviction against unclear but seemingly All Defendants; and (13) IIED against All Defendants.

 

(When the Complaint was filed on November 19, 2019, the pleadings failed to allege that Abdelmajid had vacated or abandoned the Le Grande and Mavis Properties, either voluntarily or otherwise.)

 

On December 17, 2021, Abdelmajid made a Motion for Preliminary Injunction, seeking an Order enjoining the Defendants’ ability to harass or evict him from any properties owned by the Gaffoor Family Trust during the pendency of this litigation. (The Motion was opposed by Defendants Fahiem Gaffoor as Trustee to the Gaffoor Family Trust Dated August 18, 2014, Cameron Irons, Max Greenbriar Properties LLC, Max Le Grande Properties LLC, Max Valley Properties LLC, and SVN Vanguard—hereafter, the “Business Entity Defendants”—first on January 19, 2022 to request a continuance, and again on May 13, 2022 to provide a substantive Opposition, with Defendant Fahiem Gaffoor Individually joining both Oppositions by Joinder.)

 

On January 6, 2022, Plaintiff Abdelmajid filed a Lis Pendens Notice on the Mavis Property.

 

On March 3, 2022, the Business Entity Defendants made an anti-SLAPP Motion against portions of the Complaint related to service of process effected on Plaintiff Abdelmajid in October and November 2021 in relation to unlawful detainer proceedings against Abdelmajid in the Mavis and Le Grande Properties.

 

Also on March 3, 2022, (1) the Business Entity Defendants filed a Demurrer against the Complaint’s thirteen causes of action based on lack of pleading sufficiency, uncertain pleading, and/or lack of clarity as to type of contract being pleaded, (2) the Business Entity Defendants filed a Motion to Strike punitive and attorney’s fees prayer allegations from the Complaint as improper and irrelevant, and (3) Fahiem Gaffoor Individually filed a Motion to Strike as improper and irrelevant a number of allegations in the Complaint related to Fahiem, including allegations that Fahiem has a substance abuse problem, had a troubled relationship with Mahomed Gaffoor, and envies(d) Plaintiff Abdelmajid’s relationship with Mahomed Gaffoor. (Plaintiff Abdelmajid separately opposed all three motions on August 11, 2022, with the Defendants filing separate replies on August 17, 2022.)

 

(The Court briefly notes that, pursuant to Code of Civil Procedure section 1014, though the Defendants had not answered the November 19, 2021 Complaint in this action, all Defendants generally appeared in this case by filing a Demurrer and/or (Special) Motion(s) to Strike on March 3, 2022.)

 

The Court heard the anti-SLAPP motion on April 12, 2022, at which time the Court inquired into whether any Unlawful Detainer actions had been initiated against Plaintiff Abdelmajid. Counsel for Defendants represented that, as of that date, no such case had been filed against Abdelmajid.

 

The Court ultimately denied the anti-SLAPP Motion on April 14, 2022.

 

On April 22, 2022, the Business Entity Defendants filed with the Court a Notice of Filing of Motion to Transfer and Coordinate Cases with the Orange County Probate Case, set, at that time, for hearing in Orange County Superior Court on July 6, 2022.

 

On May 19, 2022, Fahiem Gaffoor as Trustee to the Gaffoor Family Trust Dated August 18, 2014, filed an Unlawful Detainer Action (22STUD02342) against Abdelmajid seeking Abdelmajid’s vacatur from the Mavis Property.

 

On May 26, 2022, the Court continued the hearing on Abdelmajid’s Motion for Preliminary Injunction to this date and continued the Business Entity Defendants’ Demurrer from August 23, 2022 to August 24, 2022, i.e., the same date on which the Business Entity Defendants’ and Fahiem Gaffoor’s individual Motions to Strike would be heard by the Court.

 

On June 22, 2022, Abdelmajid filed a Notice of Filing of Opposition to Defendants’ Motion to Transfer and Coordinate this action with the Orange County Probate Case in the Orange County Superior Court.

 

(It is unclear to the Court whether the hearing in the Orange County Superior Court as to the Orange County Probate Case in fact took place on July 6, 2022, and if so, what the outcome of the proceedings were.)

 

On July 11, 2022, Defendant Max Le Grande Properties filed an Unlawful Detainer Action (22STUD03593) against Plaintiff Abdelmajid seeking Abdelmajid’s vacatur from the Le Grande Property. (22STUD02342 and 22STUD03593 unlawful detainer actions collectively referred to as the “Unlawful Detainer Actions.”)

 

On July 28, 2022, Plaintiff Abdelmajid filed a Motion to Quash a Deposition for Production of Business Records subpoena served on JP Morgan Chase Bank.

 

On July 28, 2022, Abdelmajid also filed a Notice of Related Case with the Court, seeking to relate this action with the Unlawful Detainer Actions, which the Court granted on August 16, 2022.

 

On August 17, 2022, the Business Entity Defendants filed an Objection to the evidence filed by Plaintiff Abdelmajid in Reply to the Defendants’ Opposition to the Motion for Preliminary Injunction, arguing Plaintiff Abdelmajid improperly submitted evidence for the first time on Reply the (1) Abdelmajid Motion for Preliminary Injunction, (2) Business Entity Defendants’ Demurrer, (3) Business Entity Defendants’ Motion to Strike, and (4) Fahiem Gaffoor’s individual Motion to Strike are now before the Court.

 

Evidentiary Objections

 

Business Entity Defendants’ Evidentiary Objections, Motion for Preliminary Injunction

Objection Nos.   . 

None:   .

 

Plaintiff Agouram Abdelmajid’s Motion for Preliminary Injunction

 

Preliminary Consideration: The Court is unconvinced by the Defendants’ argument on Opposition that they had no notice of the relief sought by Plaintiff Abdelmajid in his Motion for Preliminary Injunction based on Abdelmajid’s Notice of Motion failing to cite Code of Civil Procedure section 527 (see Injunction Opp’n, 4;15-5:17), particularly where the Points and Authorities supporting the Injunction Motion reference the statute and clearly state the grounds upon which relief is sought. (See Injunction Mot., p. 4, line 5 & p. 11, Legal Standard; see Reply, 2:5-15.)

 

The Court also exercises its discretion in accepting the evidence provided by Plaintiff Abdelmajid for the first time along with his Reply papers with the caveat that, as necessary, the Court will permit the Defendants to either present testimony against Abdelmajid’s evidence at the hearing on this Motion for Preliminary Injunction or submit further briefing respond to Plaintiff Abdelmajid’s evidence on Reply. (Alliant Ins. Services, Inc. v. Gaddy (2008) 159 Cal.App.4th 1292, 1308 [In a preliminary injunction proceeding, “the trial court had discretion whether to accept new evidence with the reply papers” where the responding party was allowed to testify in opposition to the new evidence at the motion’s hearing]; see Injunction Opp’n, Aug. 17 Objection to Evidence on Reply, Objection Nos. 1-24.)

 

Legal Standard: An injunction is a writ or order requiring a person to refrain from a particular act; it may be granted by the court in which the action is brought, or by a judge thereof; and when granted by a judge, it may be enforced as an order of the court. (Code Civ. Proc., § 525.) An injunction is an equitable remedy available generally in the protection or to prevent the invasion of a legal right. (Meridian, Ltd. v. City and County of San Francisco, et al. (1939) 13 Cal.2d 424, 447.) Otherwise stated, an injunction may be more completely defined as a writ or order commanding a person either to perform or desist from performing a particular act. (See Comfort v. Comfort (1941) 17 Cal.2d 736, 741; McDowell v. Watson (1997) 59 Cal.App.4th 1155, 1160.) The courts look to the substance of an injunction to determine whether it is prohibitory or mandatory. (See, e.g., Agricultural Labor Relations Bd. v. Superior Court (1983) 149 Cal.App.3d 709, 713 [“… [The i]njunction before [Court] … is mandatory … [because] [i]t compels [the party] to take affirmative action by terminating present employees”].)

 

The purpose of a preliminary injunction is to preserve the status quo pending final resolution upon trial. (Gray v. Bybee (1943) 60 Cal.App.2d 564, 571; Major v. Miraverde Homeowners Assn. (1992) 7 Cal.App.4th 618, 623; Grothe v. Cortlandt Corp. (1992) 11 Cal.App.4th 1313.) Accordingly, a mandatory injunction—one that mandates a party to affirmatively act—carries a heavy burden: “[t]he granting of a mandatory injunction pending trial is not permitted except in extreme cases where the right thereto is clearly established.” (Teachers Ins. & Annuity Assoc. v. Furlotti (1990) 70 Cal.App.4th 1487, 1493 [citations omitted].)

 

Preliminary injunctive relief requires the use of competent evidence to create a sufficient factual showing on the grounds for relief. (See ReadyLink Healthcare v. Cotton (2005) 126 Cal.App.4th 1006, 1016; see, e.g., Ancora-Citronelle Corp. v. Green (1974) 41 Cal.App.3d 146, 150.) Injunctive relief may be granted based on a verified complaint only if it contains sufficient evidentiary, not ultimate, facts. (See Code Civ. Proc. § 527, subd. (a).) A pleading alone rarely suffices.

 

The burden of proof is on the plaintiff as moving party. (O’Connell v. Superior Court (2006) 141 Cal.App.4th 1452, 1481.) The decision to grant a preliminary injunction generally lies within the sound discretion of the trial court and will not be disturbed on appeal absent an abuse of discretion. (Thornton v. Carlson (1992) 4 Cal.App.4th 1249, 1255 [citation omitted].)

 

Injunction Factors and Grounds for Relief:

The trial court considers two factors in determining whether to issue a preliminary injunction: (1) the likelihood the plaintiff will prevail on the merits of its case at trial, and (2) the interim harm the plaintiff is likely to sustain if the injunction is denied as compared to the harm the defendant is likely to suffer if the court grants a preliminary injunction. (Husain v. McDonald’s Corp. (2012) 205 Cal.App.4th 860, 866-67; see Code Civ. Proc., § 526, subd. (a).)

 

Plaintiff Abdelmajid seeks a preliminary injunction that will (1) enjoin all Defendants from “harassment … [of] Plaintiff … [i.e.,] ending [the Defendants’] wrongful efforts at eviction and harassment of Plaintiff” and (2) “stay any further proceedings in the state court eviction proceedings” by the Defendants against Abdelmajid. (Injunction Mot., p. 11, § IV.)

 

Abdelmajid clarifies the relief sought in his Reply, indicating he seeks to (1) enjoin the Defendants from “[h]arassing, intimidating, stalking, threatening, assaulting, attacking, striking, hitting, abusing, destroying [Abdelmajid’s] personal property or disturb [Abdelmajid’s] peace” and (2) to “stay … any eviction [sought against Abdelmajid by the Defendants, e.g., the Unlawful Detainer Actions separately filed by Fahiem Gaffoor as Trustee and by Max Le Grande Properties in May and July 2022] pending the resolution of who has superior title under the competing trusts” (i.e., the outcome of the Orange County Probate Case). (Reply, ¶¶ 27-28.)

 

Likelihood of Success on the Merits: ESTABLISHED.

 

The plaintiff has the burden of presenting facts showing a reasonable probability of succeeding on the merits. (Citizens for Better Streets v. Board of Supervisors of the City & County of San Francisco¿(2004) 117 Cal.App.4th 1, 6; Trader Joe’s Co. v. Progressive Campaigns,¿Inc.¿(1999) 73 Cal.App.4th 425, 429-30.) The likelihood of plaintiff’s ultimate success on the merits affects the showing necessary to a balancing-of-hardships analysis whereby the more likely it is that the plaintiff will ultimately prevail, the less severe must be the harm the plaintiff alleges will occur if the¿injunction¿is not issued, particularly true when the requested¿injunction¿maintains, rather than alters, the status quo. (Take Me Home Rescue v.¿Luri¿(2012) 208 Cal.App.4th 1342, 1350.) “The granting of a mandatory injunction pending trial is not permitted except in extreme cases where the right thereto is clearly established.” (Teachers Ins. & Annuity Assoc., supra, 70 Cal.App.4th at p. 1493.)

 

Analysis: Here, the Court finds that Plaintiff has provided sufficient arguments on Motion and evidence on Reply to demonstrate a likelihood of success on the merits of this action at trial for the great majority of the causes of action stated therein.

 

Abdelmajid’s Motion for Preliminary Injunction argues that he will succeed on all his causes of action at trial in this lawsuit because “Defendants have wrongfully terminated Plaintiff and have denied him his rights, repeatedly and flagrantly assaulted, abused and harassed Plaintiff” Abdelmajid. (Injunction Mot., pp. 13-14.)

 

The Complaint alleges and Abdelmajid’s Injunction Reply provides supporting evidence for causes of action pleading:

 

(1) Wrongful Termination against All Defendants, premised on the economic and non-economic damages suffered by Plaintiff Abdelmajid after being frozen out of the Gaffoor family business on or around January 26, 2021, under circumstances where Abdelmajid’s termination from the family business would be wrongful if the Fourth Amendment to the Gaffoor Family Trust is found by the Orange County Superior Court to be a product of undue influence or lack of capacity—the Fourth Amendment was signed by Mahomed Gaffoor on his deathbed no more than a single day before his death and, for the first time in five trust drafts/amendments, divested Plaintiff Abdelmajid of Successor Trusteeship in favor of Fahiem Gaffoor—because the Third Amendment to the same Trust made Abdelmajid Successor Trustee over the assets of the Gaffoor Family Trust, including the Max Greenbriar, Le Grande, and Valley Property companies from which Plaintiff Abdelmajid was constructively terminated on January 26, 2021 (Complaint, ¶¶ 50-62, 77, 79-81; Injunction Reply, Ex. 2 [Third Amended Petition filed by Abdelmajid with Orange County Superior Court and seeking to invalidate the January 22, 2021 Fourth Amendment to the Gaffoor Family Trust based on Undue Influence and Lack of Capacity), Ex. 3 [copies of the original 2014 Gaffoor Family Trust and subsequent First, Second, and Third Amendments to the Trust all showing successor trusteeship in favor of Abdelmajid, and showing in the Amendments a specific gift of the Mavis Property to Abdelmajid], Ex. 5 [medical records for Mahomed Gaffoor for dates surrounding his death of January 22, 2021 indicating that Mahomed was intermittently confused, sedated, and noncompliant with care]).

 

(2) Breach of the Implied Covenant of “Good Cause” against All Defendants based on the Defendants discharging Abdelmajid from his employment, without cause, under the same circumstances discussed ante, resulting in economic damages to Abdelmajid (Complaint, ¶¶ 50-62, 84-87; Injunction Reply, Exs. 2-3, 5).

 

(3) Breach of the Implied Covenant of Good Faith and Fair Dealing against All Defendants based on the Defendants discharging Abdelmajid from his employment, without cause, under the same circumstances discussed ante, resulting in economic damages to Abdelmajid (Complaint, ¶¶ 50-62, 88-91; Injunction Reply, Exs. 2-3, 5).

(4) Unfair Business Practices against All Defendants based on “wrongful discharge, discrimination, failure to comply with public polices, and failure to comply with the Labor Code,” resulting economic damages and an injunction against future unfair business practices (Complaint, ¶¶ 50-62, 92-96; Injunction Reply, Exs. 2-3, 5).

 

(5) Failure to Prevent Discrimination, Harassment, and Retaliation under FEHA against unclear (but from the pleadings, apparently against All) Defendants for failure in preventing discrimination and harassment against Abdelmajid through January 26, 2021 (date of constructive discharge) as based on Abdelmajid’s “race, national origin, color, sexual orientation, marital status, and/or other protected statuses or protected activities,” entitling Abdelmajid to economic and punitive damages and attorney’s fees (Complaint, ¶¶ 49 [assault and battery by Fahiem Gaffoor against Plaintiff Abdelmajid], 97-104; Injunction Reply, Ex. 6 [video still shots of Fahiem Gaffoor assaulting Abdelmajid on February 17, 2020].)

 

(6) Violation of Labor Code section 6310 against All Defendants on the grounds that this statutory section prohibits terminating an employee based on complaint of unsafe working conditions or practices and on Defendants terminating Abdelmajid’s employment from the Max Greenbriar, Le Grande, and Valley Property companies, resulting in economic damages to Abdelmajid (Complaint, ¶¶ 50-62, 105-108 [erroneously repeating paragraph 108 as paragraph 105]; Injunction Reply, Exs. 2-3, 5).

 

(8) Assault against Defendants Fahiem Gaffoor and Cameron Irons based on Fahiem Gaffoor hitting Abdelmajid and pushing Abdelmajid to the ground and Cameron Irons serving unlawful detainer documents on Abdelmajid by pushing the same into Abdelmajid’s torso, causing Abdelmajid non-economic damages and entitling him to punitive damages (Complaint, ¶¶ 49 [Fahiem shoves Abdelmajid to the ground on February 17, 2020], 76 [Irons shoves documents into chest of Abdelmajid], 115, 117, 120; Reply, ¶ 17 [Irons shoves documents into chest of Abdelmajid], Ex. 6 [video still shots of Fahiem Gaffoor assaulting Abdelmajid on February 17, 2020]).

 

(9) Battery against Defendants Fahiem Gaffoor and Cameron Irons based on Fahiem Gaffoor hitting Abdelmajid and pushing Abdelmajid to the ground and Cameron Irons serving unlawful detainer documents on Abdelmajid by pushing the same into Abdelmajid’s torso, causing Abdelmajid non-economic damages and entitling him to punitive damages (Complaint, ¶¶ 49 [Fahiem shoves Abdelmajid to the ground on February 17, 2020], 76 [Irons shoves documents into chest of Abdelmajid], 123, 125, 127; Reply, ¶ 17 [Irons shoves documents into chest of Abdelmajid], Ex. 6 [video still shots of Fahiem Gaffoor assaulting Abdelmajid on February 17, 2020]).

 

(10) Trespass to Chattels against All Defendants based agents of the Defendants trespassing into Plaintiff’s premises on the Mavis Property between May and October 2021, including “peep[ing] over the windows and … peep[ing] from the vents on the roof to Plaintiff’s quarters, tak[ing] pictures and video tape of Plaintiff [Abdelmajid]’s personal property[,] all without permission or notice,” causing Plaintiff economic damages, non-economic damages, and entitling him to punitive damages (Complaint, ¶¶ 64, 131-135; Reply, ¶¶ 10, 13-14, 18 [Defendants’ agents trespassing onto Abdelmajid’s rental premises and interfering with possession of or outright converting Abdelmajid’s chattel], Exs. 7-8 [video still shots of trespass onto Abdelmajid’s property by the Defendants or their agents]).

 

(12) Unlawful Retaliatory Eviction against unclear (but from the pleadings, apparently against All) Defendants in violation of California Civil Code 1942.5 and Government Code section 12955, subdivision (f), making it unlawful to take adverse action against a tenant for the purpose of retaliation, on the grounds that Defendants served 30-Day Notices to Terminate Abdelmajid’s tenancy from the Mavis and Le Grande Properties, under circumstances indicating a pattern of retaliation against Abdelmajid for challenging the Fourth Amendment to the Gaffoor Family Trust, causing Abdelmajid economic and non-economic damages, and entitling him to punitive damages (Complaint, ¶¶ 50-62, 63-76, 143-45, 148-50; Reply, Exs. 2-3, 5).

 

(13) Intentional Infliction of Emotional Distress against All Defendants, either as principals or ratifiers of tortious conduct, based on the Defendants engaging in outrageous conduct so extreme as to go beyond the bounds of decency, under circumstances where Fahiem Gaffoor obtained full control to the estate of Mahomed Gaffoor through a Fourth Amendment to the Gaffoor Family Trust, signed on Mahomed Gaffoor’s deathbed, by a seemingly confused and sedated Mahomed Gaffoor, and where the Defendants thereafter engaged in a pattern of trespass and attempted or threatened evictions of Abdelmajid from the Mavis and Le Grande Properties (Complaint, ¶¶ 50-62, 63-76, 153-58; Reply, Exs. 2-3, 5 [evidence of dispute over Gaffoor Family Trust], 6-8 [evidence of subsequent wrongful acts, like trespass and assault and battery]).

 

The Court recognizes that the Complaint’s Seventh Cause of Action for Retaliation in Violation of FEHA against All Defendants and Eleventh Cause of Action for Harassment against all Defendants (unclear whether under FEHA or under a Penal Code section) are not as adequately supported by the pleadings or evidence, showing a lower likelihood of success on the merits.

 

The Court further recognizes that the Complaint is not certainly pleaded as to eleven of the thirteen causes of action due to lack of clarity in pleading as to which defendant is liable for the actions supporting those causes of action—a defect not without remedy though amendment, which the Court has granted. (See Demurrer discussion infra.)

 

Overall, however, the Court finds that the pleadings and evidence supporting the Complaint’s other eleven causes of action support an inference that Abdelmajid could succeed on most if not all his claims at trial. This conclusion is reinforced by the pendency of the Orange County Probate Case, which could result in a voiding of the Fourth Amendment of the Gaffoor Family Trust and paint all the Defendants’ actions in a negative and retaliatory light, subject to adequate pleading.

 

Abdelmajid provides sufficient allegations and supporting evidence to show a likelihood of success on the merits of his Complaint’s thirteen causes of action.

 

Balancing of Harms in Favor of Movant: ESTABLISHED.

 

“An evaluation of the relative harm to the parties upon the granting or denial of a preliminary¿injunction¿requires consideration of: ‘(1) the¿inadequacy of any other remedy; (2) the degree of irreparable¿injury the denial of the¿injunction¿will cause; (3) the necessity to preserve the status quo; [and] (4) the degree of adverse effect on the public¿interest or¿interests of third parties the granting of the¿injunction¿will cause.’” (Vo v. City of Garden Grove¿(2004) 115 Cal.App.4th 425, 435; see also Imperial v. Castruita (C.D. Cal. 2006) 418 F.Supp.2d 1174.,1177-78 [federal courts in Ninth Circuit employing traditional-criteria test for a preliminary injunction—requires showing of (1) a strong likelihood of success on the merits, (2) the possibility of irreparable injury to plaintiff if preliminary relief is not granted, (3) a balance of hardships favoring the plaintiff, and (4) advancement of the public interest—and the alternative-criteria test—where the plaintiff must show either a combination of probable success on the merits and the possibility of irreparable injury or that serious questions are raised and the balance of hardships tips sharply in his favor].)

 

Inadequacy of Other Remedies & Absence of Remedy at Law: A plaintiff seeking injunctive relief must show the absence of an adequate damages remedy at law. (See Code Civ. Proc. § 526, subds. (a)(4)-(5); Thayer Plymouth Center, Inc. v. Chrysler Motors (1967) 255 Cal.App.2d 300, 307; Department of Fish & Game v. Anderson-Cottonwood Irrigation Dist. (1992) 8 Cal.App.4th 1554, 1565.) The idea of “inadequacy of the legal remedy” or “inadequacy of damages” dates from the time of the early courts of chancery, the idea being that an injunction is an unusual or extraordinary equitable remedy which will not be granted if the remedy at law (usually damages) will adequately compensate the injured Plaintiff. (Department of Fish & Game, at p. 1565.)

 

Here, Plaintiff points to two grounds from which the Court could find that other remedies are inadequate/that no adequate remedy at law exists should Abdelmajid’s Motion for Preliminary Injunction be denied: (1) Plaintiff is facing eviction from the Mavis and Le Grande Properties; and (2) the Defendants’ threatened disposal of Abdelmajid’s chattel from these properties. (Injunction Mot., p. 15, § B.)

 

The Court finds the former of these grounds sufficient to afford Abdelmajid relief in his Motion for Preliminary Injunction insofar as Plaintiff’s eviction from the Mavis and Le Grande Properties would deprive Abdelmajid of unique housing to which he claims be lawfully entitled and because such an action would be wrongful if the Fourth Amendment to the Gaffoor Family Trust is voided by the Orange County Superior Court.

 

Irreparable Injury: Abdelmajid’s risk of irreparable injury is readily apparent: the same risk of losing unique housing in the Mavis and Le Grande Properties when he may be legally entitled to rental in these Properties (Injunction Mot., p. 15, § B), particularly if the Fourth Amendment to the Gaffoor Family Trust is voided by the Orange County Superior Court, the Third Amendment of the Trust is revived, and Abdelmajid thus comes into partial or complete ownership of the Mavis Property and management over the remainder of the Gaffoor Family Trust estate.

 

Necessity of Preserving Status Quo: The status quo has been defined to mean the last actual peaceable, uncontested status which preceded the pending controversy. (Voorhies v. Greene (1983) 139 Cal.App.3d 989, 995 [quoting United Railroads v. Superior Court (1916) 172 Cal. 80, 87]; see also 14859 Moorpark Homeowner's Assn. v. VRT Corp. (1998) 63 Cal.App.4th 1396, 1408.)

Here, the last peaceable, uncontested status prior to Abdelmajid filing this lawsuit involves Abdelmajid living as a tenant at the Mavis and Le Grande Properties. (See Injunction Opp’n, 2:11-4:12 [Business Entity Defendants explaining Abdelmajid’s tenancy or possession in the Mavis and Le Grande Properties].)

 

The Court finds that maintaining this status quo is necessary considering the extreme harm that Abdelmajid would suffer if he were evicted from the Mavis and Le Grande Properties without resolution to the Orange County Probate Case—which may find that Abdelmajid and not Fahiem Gaffoor is entitled to manage the affairs and properties owned by the Gaffoor Family Trust—particularly when compared to the relatively minimal harm to the Defendants if Abdelmajid remains in these properties—i.e., lost rental income for the relevant Defendants, offset by any undertaking ordered herein.

 

Public Interest: Here, the Orange County Probate Case does not appear to be resolved. (See docket generally.) Under these circumstances and considering the contested nature of the Gaffoor Family Trust and the resulting relationship between the parties, the Court finds that the public interest neither supports nor undercuts the Motion for Preliminary Injunction.

 

Additional Considerations: The Court briefly notes that the injunction being sought by Plaintiff Abdelmajid is prohibitory (restricting a party’s ability to behave in a particular way) rather than mandatory (seeking to force the Defendants to act in a particular way), which is subject to a lower degree of scrutiny from the trial court. (Teachers Ins. & Annuity Assoc., supra, 70 Cal.App.4th at p. 1493.)

 

Injunction Conclusion: The Court thus GRANTS the Motion for Preliminary Injunction subject to Abdelmajid filing with the Court a Proposed Order consistent with Abdelmajid’s Reply and posting bond as follows.

 

Undertaking Requirement: ORDERED at $10,000.

 

A preliminary injunction ordinarily cannot take effect unless and until the plaintiff provides an undertaking for damages which the enjoined defendant may sustain by reason of the injunction if the court finally decides that the plaintiff was not entitled to the injunction. (See Code Civ. Proc. § 529, subd. (a); City of South San Francisco v. Cypress Lawn Cemetery Assn. (1992) 11 Cal.App.4th 916, 920; see, e.g., ABBA Rubber Co. v. Seaquist (1991) 235 Cal.App.3d 1, 10 [finding that bond is an “indispensable prerequisite to the issuance of a preliminary injunction” and the duty to order a bond is “mandatory, not discretionary”].) In addition, an injunction is void without an undertaking. (See Federal Automotive Services v. Lane Buick Co. (1962) 204 Cal.App.2d 689, 695 [holding injunction inoperative and of no effect because the order did not require a bond pursuant to Code of Civil Procedure section 529].)

 

Procedurally, notwithstanding California Rules of Court, rule 3.1312, whenever an application for a preliminary injunction is granted, a proposed order must be presented to the judge for signature, with an undertaking in the amount ordered, within one court day after the granting of the application or within the time ordered. (Cal. Rules of Court, rule 3.1150, subd. (f).) Unless otherwise ordered, any restraining order previously granted remains in effect during the time allowed for presentation for signature of the order of injunction and undertaking. (Cal. Rules of Court, rule 3.1150, subd. (f).) If the proposed order and the undertaking required are not presented within the time allowed, the TRO may be vacated without notice. (Cal. Rules of Court, rule 3.1150, subd. (f).) All bonds and undertakings must comply with rule 3.1130. (Cal. Rules of Court, rule 3.1150, subd. (f).)

 

The Court ORDERS Abdelmajid to provide a Proposed Order within five court days of this hearing and post Bond in the amount of $10,000 within forty-five (45) calendar days of this hearing.

 

Business Entity Defendants’ Demurrer

 

A demurrer for sufficiency tests whether the complaint states a cause of action. (Hahn v. Mirda (2007) 147 Cal.App.4th 740, 747; see Code Civ. Proc., § 430.10, subd. (e).) “To survive a [general] demurrer, the complaint need only allege facts sufficient to state a cause of action; each evidentiary fact that might eventually form part of the plaintiff’s proof need not be alleged.” (C.A. v. William S. Hart Union High School Dist. (2012) 53 Cal.4th 861, 872.) In testing the sufficiency of the cause of action, the demurrer admits the truth of all material facts properly pleaded. (Aubry v. Tri-City Hospital Dist. (1992) 2 Cal.4th 962, 966-67.) A demurrer, however, “does not admit contentions, deductions or conclusions of fact or law.” (Daar v. Yellow Cab Co. (1967) 67 Cal.2d 695, 713.)

 

A demurrer for uncertainty lies where a pleading is uncertain, ambiguous, or unintelligible. (Code Civ. Proc. § 430.10, subd. (f).) “A demurrer for uncertainty is strictly construed, even where a complaint is in some respects uncertain, because ambiguities can be clarified under modern discovery procedures.” (Khoury v. Maly’s of California, Inc. (1993) 14 Cal.App.4th 612, 616.) Where complaint is sufficient to state a cause of action and to apprise defendant of issues he is to meet, it is not properly subject to a special demurrer for uncertainty. (See ibid.; see also Gressley v. Williams (1961) 193 Cal.App.2d 636, 643 [“A special demurrer [for uncertainty] should be overruled where the allegations of the complaint are sufficiently clear to apprise the defendant of the issues which he is to meet”].)

 

In a contract action, a defendant can file a special demurrer to a complaint on the ground that it cannot be determined from the pleadings whether the contract is written, oral, or implied by conduct. (Code Civ. Proc., §¿430.10, subd. (g); see Holcomb v. Wells Fargo Bank (2007) 155 Cal.App.4th 490, 500-01.)

 

Preliminary Note: Abdelmajid’s Opposition to the Demurrer completely fails to respond to the uncertainty of pleading arguments raised by the Business Entity Defendants. (See Demurrer Opp’n generally [no mention of uncertainty]; see also Demurrer, 8:2-27 [Business Entity Defendants’ uncertainty arguments].)

 

Complaint, First to Seventh Causes of Action: SUSTAINED, With Leave, as to Business Entity Defendants.

 

In relevant part, the Business Entity Defendants challenge the Complaint’s First through Seventh Causes of Action on the grounds that these claims are uncertainly pleaded because “Plaintiff directs all seven of his employment claims (the First through Seventh Causes of Action) at all seven Defendants, even though there is no allegation that any of the Defendants employed him (much less all seven Defendants).” (Demurer, 8:12-14.) The Court agrees.

 

First, Abdelmajid fails to address these grounds for demur in his Demurrer Opposition. (See Demurrer Opp’n generally [no arguments regarding uncertainty in pleading].)

 

Second, the Complaint’s First through Seventh Causes of Action are all based on statutory violations against Abdelmajid in the workplace (Unfair Business Practices including individual defendants Fahiem Gaffoor and Cameron Irons; Failure to Prevent under FEHA; Violation of Labor Code; and Retaliation under FEHA) or as a result of Abdelmajid’s constructive discharge from his employment (Wrongful Termination, Breach of Implied Covenant of Good Cause, Breach of Implied Covenant of Good Faith and Fair Dealing), but only Defendants Max Greenbriar, Le Grande, and Valley Property companies appear to have employed Plaintiff Abdelmajid. (Complaint, ¶ 1.) Defendant Fahiem Gaffoor as Trustee simply appears to have, for the moment, won out on Trusteeship over the Gaffoor Family Trust. (Complaint, ¶ 1.) Fahiem Gaffoor and Abdelmajid may have overlap in employment under Mahomed Gaffoor, but the nature and extent of such relationship is not provided to the Court. Last, the Court refers to Abdelmajid’s Motion for Preliminary Injunction, which alleges that Defendant Cameron Irons and SVN Vanguard began working with the remaining Defendants only after Plaintiff Abdelmajid was already constructively discharged from his employment. (Injunction Mot., 6:1-4.)

 

Under these circumstances, the Court finds that the allegations in the Complaint’s First through Seventh Causes of Action are uncertainly pleaded because the Defendants will have a difficult time ascertaining the issues they are to meet at trial if they cannot be sure how or which of the Defendants harmed Abdelmajid within an employment context.

 

Complaint, Tenth, Eleventh, and Thirteenth Causes of Action: SUSTAINED, With Leave, as to Business Entity Defendants.

 

In relevant part, the Business Entity Defendants demur to the Complaint’s Tenth, Eleventh, and Thirteenth Causes of Action for Trespass to Chattels, Harassment, and IIED on the grounds that these claims are directed “at all seven Defendants – including all four entity-defendants – without identifying which person allegedly ‘trespassed,’ ‘harassed,’ or inflicted emotional distress.” (Demurrer, 8:15-18.) The Court agrees.

 

Again, Abdelmajid fails to address these grounds for demur in his Demurrer Opposition. (See Demurrer Opp’n generally [no arguments regarding uncertainty in pleading].)

 

Second, just like with the Complaint’s First through Seventh Causes of Action, it is difficult for the Defendants in this action to be apprised of the facts and circumstances supporting the Trespass to Chattels, Harassment, and IIED claims against them because these causes of action are pleaded without differentiation as to which of the Defendants engaged in the tortious conduct against Abdelmajid, or otherwise explaining how the Defendants acted in concert to effect this harm on Abdelmajid, thus imputing liability onto all Defendants not directly responsible for the conduct harming Abdelmajid (trespass, harassment, IIED). (See Complaint, ¶¶ 131-36, 137-42, 153-59.)

 

Complaint, Twelfth Cause of Action: SUSTAINED, With Leave, as to Business Entity Defendants.

 

In relevant part, the Business Entity Defendants demur to the Complaint’s Twelfth Cause of Action for Unlawful Retaliatory Eviction on the grounds that this claim is uncertainly pleaded for failure to “identify[] which ‘defendants’ [Abdelmajid] accuses of wrongfully evicting him.” (Demurrer, 8:19-21.) The Court agrees.

 

Abdelmajid fails to address these grounds for demur in his Demurrer Opposition. (See Demurrer Opp’n generally [no arguments regarding uncertainty in pleading].)

 

The Court finds that the Complaint fails to sufficiently differentiate between the actions of each of the Defendants as to the Unlawful Retaliatory Eviction claim, making it incredibly difficult if not impossible to determine whether each Defendant can properly be apprised of the grounds for a claim of unlawful retaliatory eviction against Abdelmajid. For example, the Complaint does not sufficiently explain that either each Defendant participated in the retaliatory eviction attempts against Abdelmajid or that the Defendants acted as agents, alter egos, or joint ventures of one another. (See Complaint, ¶¶ 143-52.)

 

Complaint, Eighth and Ninth Causes of Action: OVERRULED.

 

“The essential elements of a cause of action for assault are: (1) defendant acted with intent to cause harmful or offensive contact, or threatened to touch plaintiff in a harmful or offensive manner; (2) plaintiff reasonably believed she was about to be touched in a harmful or offensive manner or it reasonably appeared to plaintiff that defendant was about to carry out the threat; (3) plaintiff did not consent to defendant’s conduct; (4) plaintiff was harmed; and (5) defendant’s

conduct was a substantial factor in causing plaintiff’s harm.” (So v. Shin (2013) 212 Cal.App.4th 652, 668-69 [citations omitted].) Common law battery consists of circumstances where the “(1) defendant touched plaintiff, or caused plaintiff to be touched, with the intent to harm or offend plaintiff; (2) plaintiff did not consent to the touching; (3) plaintiff was harmed or offended by defendant’s conduct; and (4) a reasonable person in plaintiff’s position would have been offended by the touching.” (Id. at pp. 669 [citations omitted].)

 

The Business Entity Defendants demur to the Eighth and Ninth Cause of Action based solely on sufficiency of pleading grounds with respect to Defendant Cameron Irons. (See Demurrer, 12:16-14:5.) Specifically, the Business Entity Defendants argue that the Complaint fails to allege Assault or Battery against Defendant Irons for failure to plead adequate (1) intent, (2) harmful or offensive touching, and/or (3) apprehension of immediate harmful or offensive contact. (See Demurrer, 13:1-14:5.)

 

On Opposition, Abdelmajid argues that he has sufficiently pleaded the Assault and Battery claims based on the allegations in the Complaint. (Demurrer Opp’n, 9:22-10:22.)

 

The Court agrees with Abdelmajid and therefore OVERRULES the Business Entity Defendants’ demur to the Complaint’s Eighth and Ninth Causes of Action. (See Complaint, ¶¶ 49 [Fahiem shoves Abdelmajid to the ground on February 17, 2020], 76 [Irons shoves documents into chest of Abdelmajid], 117 [assault], 125 [battery].)

 

Business Entity Defendants’ Motion to Strike

 

Legal Standard: Any party, within the time allowed to respond to a pleading may serve and file a notice of motion to strike the whole or any part thereof. (Code of Civ. Proc. § 435, subd. (b)(1); Cal. Rules of Court, rule 3.1322, subd. (b).) The court may, upon a motion or at any time in its discretion and upon terms it deems proper: (1) strike out any irrelevant, false, or improper matter inserted in any pleading; or (2) strike out all or any part of any pleading not drawn or filed in conformity with the laws of California, a court rule, or an order of the court. (Code Civ. Proc. § 436, subd. (a)-(b); Stafford v. Shultz¿(1954) 42 Cal.2d 767, 782 [“Matter in a pleading which is not essential to the claim is surplusage; probative facts are surplusage and may be stricken out or disregarded”].) However, Courts have noted that a motion to strike should be applied cautiously and sparingly because it is used to strike substantive defects. (PH II, Inc. v. Superior Court (1995) 33 Cal.App.4th 1680, 1682-83.) A party cannot use a motion to strike as a “line-item veto.” (Id. at p. 1683 [“We emphasize that such use of the motion to strike should be cautious and paring” and “have no intention of creating a procedure ‘line-item veto’ for the civil defendant”].)

 

For the purposes of a motion to strike pursuant to Sections 435 to 437 of the Code of Civil Procedure, the term “pleading” means a demurrer, answer, complaint, or cross-complaint. (Code Civ. Proc., § 435, subd. (a).) An immaterial allegation or irrelevant matter in a pleading entails (1) an allegation that is not essential to the statement of a claim or defense, (2) an allegation that is neither pertinent to nor supported by an otherwise sufficient claim or defense, or (3) a demand for judgment requesting relief not supported by the allegations of the complaint or cross-complaint. (Code Civ. Proc.,¿§¿431.10, subds. (b)(1)-(3).)

 

Complaint, Punitive Damages: GRANTED, With Leave, as to Defendants (1) Fahiem Gaffoor as Trustee, (2)-(4) Max Greenbriar, Le Grande, and Valley Property companies, and (5) SVN Vanguard; DENIED, as to (6) Defendant Cameron Irons

 

The Business Entity Defendants seek to strike the punitive damages and attorney’s fees prayer allegations from the Complaint. (See Business Entity Strike Mot., 1:12-3:11.) The only two causes of action to survive demur were the Complaint’s Eighth and Ninth Causes of Action for Assault and Battery, alleged only against Defendants Fahiem Gaffoor individually and against Business Entity Defendant, Cameron Irons. (See Complaint, ¶¶ 115-22, 123-30.) As such, punitive damages allegations are improper as alleged against the remaining five Business Entity Defendants—Fahiem Gaffoor as Trustee, the Max Greenbriar, Le Grande, and Valley Property companies, and SVN Vanguard—and are STRUCK from the Complaint as to these Defendants alone. (See Business Entity Strike Mot., 1:12-2:22.) The Court notes, however, the Assault and Battery claims support punitive damages, and thus, the Motion is DENIED as to Defendant Cameron Irons. (See 569 East Cty. Blvd., LLC v. Backcountry Against the Dump, Inc. (2016) 6 Cal.App.5th 426, 429 n. 3 [“In California, ... punitive damages are ‘… an additional remedy that is dependent on a viable cause of action for an underlying tort’”].)

 

Complaint, Attorney’s Fees: GRANTED, With Leave, as to All Business Entity Defendants.

 

The Business Entity Defendants move to strike attorney’s fees prayer allegations from the Complaint on the grounds that pro per parties cannot recover attorney’s fees and on the grounds that the FEHA-based claims failed on demur. (Business Entity Strike Mot., 9:23-10:28.)

 

On Opposition, Abdelmajid argues that he is no longer self-represented and thus, there are no grounds for foreclosing attorney’s fees here as warranted by law, e.g., by Plaintiff’s FEHA-based claims. (Business Entity Strike Mot., Opp’n, 6:10-26.)

 

The Court notes that while Abdelmajid is no longer appearing pro per as of August 10, 2012 (see Aug 11. 2022 Substitution of Attorney), this change only took place recently and Plaintiff’s FEHA-based claims failed on demur. (See Demurrer discussion supra.) The Court thus GRANTS and STRIKES the attorney’s fees allegations from the Complaint against all Business Entity Defendants, With Leave to Amend. (See Business Entity Strike Mot., 2:24-3:11.)

 

Defendant Fahiem Gaffoor’s Individual Motion to Strike

 

Complaint, Paragraphs 19 to 32: DENIED.

 

In his individual Motion to Strike, Fahiem Gaffoor Individually moves to strike paragraphs 19 to 32 from the Complaint on the grounds that the allegations made against Fahiem Gaffoor are irrelevant to Causes of Action One through Seven and Ten to Thirteen and that such allegations are false, i.e., arguing that Fahiem Gaffoor never assaulted, battered, or caused emotional distress to Plaintiff Abdelmajid. (Fahiem Gaffoor Strike Mot., 2:16-3:13.)

 

On Opposition, Abdelmajid sparsely argues that these allegations are not improper or irrelevant because the “context[ualize] … the remainder of the [Complaint].” (Fahiem Gaffoor Strike Opp’n, 6:24-25, 7:5-7.) The Court agrees with Abdelmajid. The allegations at paragraphs 19 to 32 at, at the very least, critical in showing the underlying reasons for Retaliation, Wrongful Eviction, and Termination of Employment against Abdelmajid, and would be relevant to a factfinder in his or her consideration of the issues before the Court in this action.

 

Request for Sanctions

 

Monetary Sanctions: DENIED.

 

Any request for sanctions by the Parties are DENIED. (See Fahiem Gaffoor Strike Opp’n, 8:6-11.)

 

Conclusion

 

Agouram Abdelmajid’s Motion for Preliminary Injunction is GRANTED (subject to Proposed Order and Bond Undertaking filing) because Abdelmajid has shown (1) a likelihood of success on the merits of this action on the claims alleged in his Complaint and (2) a balancing on the harms favors the granting of the Preliminary Injunction.

 

This Grant will take effect only after Abdelmajid files with the Court and the Court signs off on a Preliminary Injunction Proposed Order to the effect of this Order and Abdelmajid posts bond in the amount of $10,000. (See Injunction Reply, ¶¶ 27-28.)

 

Abdelmajid is ORDERED to provide a Proposed Order within five court days of this hearing and post Bond in the amount of $10,000 within forty-five (45) calendar days of this hearing.

 

Defendants Fahiem Gaffoor as Successor Trustee of the Gaffoor Family Trust, Cameron Irons, Max Greenbriar Properties LLC, Max Le Grande Properties LLC, Max Valley Properties LLC, and SVN Vanguard’s Demurrer to Agouram Abdelmajid’s Complaint is (1) SUSTAINED, With Leave to Amend, as to the Complaint’s First though Seventh and Tenth to Thirteenth Causes of Action for uncertain pleading and (2) OVERRULED as to the Complaint’s Eighth and Ninth Causes of Action because the claims are sufficiently pleaded against Defendant Cameron Irons.

 

Defendants Fahiem Gaffoor as Successor Trustee of the Gaffoor Family Trust, Cameron Irons, Max Greenbriar Properties LLC, Max Le Grande Properties LLC, Max Valley Properties LLC, and SVN Vanguard’s Motion to Strike Portions of Abdelmajid’s Complaint is (1) GRANTED, With Leave to Amend, as to punitive damages prayer allegations lodged against Defendants Fahiem Gaffoor as Trustee, the Max Greenbriar, Le Grande, and Valley Property companies, and SVN Vanguard, (2) DENIED as to punitive damages prayer allegations against Defendant Cameron Irons, and (3) GRANTED as to the attorney’s fees prayer allegations in the Complaint with respect to all Business Entity Defendants.

 

Defendant Fahiem Gaffoor’s Motion to Strike Portions of Abdelmajid’s Complaint is DENIED because paragraphs 19 to 32 of the Complaint are not irrelevant or improper to the remainder of Abdelmajid’s pleading, but rather, provides necessary context for the relationship between Abdelmajid and Defendant Fahiem Gaffoor individually and as presumed Trustee over the Gaffoor Family Trust.

 

All Requests for Sanctions are DENIED.