McGlynn v. Stuho Complaint

EE
Ziil
SUM-100
SUMMONS
FOR COURT USE ONLY
(SOLO PARA uS0 DE LA CORTE)
(CITACION JUDICIAL)
NOTICE TO DEFENDANT:
CONFFifvfED GORY
(AVISO AL DENIANDADO):
Su53[!:{},G&#"Lr:8'Aii%l:i,%rgnia
OfiiGINAi FiLff r>
STUHO, a California Corporation; HOOVER - ADAMS HOLDING

A,:`,/ 2 9 2016
LLC, a California Limited Liability Company; -and-DOES 1 -I,000

YOU ARE BEING SUED BY PLAINTIFF:
Snerri R. Carter, Executive Ofilcer/Clerk
(LO ESTA DENIANDANDO EL DEMANDANTE):
y Cristlna Grijalva, Deputy
CONNOR MCGLYNN, an individual; ALEC PHILLIPS, an individual;

KIERAN STOLORZ, an individual
NOTICE! You have been sued. The court may decide against you without your being heard unless you respond within 30 days. Read the information
below.
You have 30 CALENDAR DAYS after this summons and legal papers are served on you to file a written response at this court and have a copy
served on the plaintiff. A letter or phone call will not protect you. Your written response must be in proper legal form if you want the court to hear your
case. There may be a court form that you can use for your response. You can find these court forms and more information at the California Courts
Online Self-Help Center (wrwwr.courfr'rtfo.ca.govl/se/the/p), your county law library, or the courthouse nearest you. If you cannot pay the filing fee, ask
the court clerk for a fee waiver form. If you do not file your response on time, you may lose the case by default, and your wages, money, and property
may be taken without further warning from the court.
There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may want to call an attorney
referral service. If you cannot afford an attorney, you may be eligible for free legal services from a nonprofit legal services program. You can locate
these nonprofit groups at the California Legal Services Web site (Mw./awhe/pea/from/.a.orty), the California Courts Online Self-Help Center
(Vlrww.cowl/.nfo.ca.gov/se/the/p), or by contacting your local court or county bar association. NOTE: The court has a statutory lien for waived fees and
costs on any settlement or arbitration award of $10,000 or more in a civil case. The court's lien must be paid before the court will dismiss the case.
iAVISOI Lo han demandado. Si no responde dentro de 30 dias, Ia corie puede decidir en su contra sin escuchar su version. Lea la informaci6n a
continuaci6n.
nene 30 DiAS DE CALENDARIO despues de que le entreguen esta citaci6n y papeles legales pare presentar una respuesta por escrito en esta
corfp y hacer que se entregue una copia al demandante. Una carta a una llamada telefonica no lo protegen. Su respuesta por escrito tiene que estar
e_n tomato legal correcto si desea que procesen su caso en la corte. Es posible que haya un formulario que usted pueda usar para su respuesta.
Puede encontrar estos formularios de la corte y mss informaci6n en el Centro de Ayuda de las Cortes de Califomia (\^^^^N.sucorte.ca.gov), en la
biblioteca de leyes de su condado o en la corte que le quede mss cerca. Si no puede pagar la cuota de presentaci6n, pida al secretario de la corte
que le de un formulario de exenci6n de pago de cuctas. Si no presenta su respuesta a tiempo, puede perder el caso por incumplimiento y la corie le
pod fa quitar su sueldo, dinero y bienes sin mas advertencia.
Hay ctros requisitos legales. Es recomendable que IIame a un abogado inmediatamente. Si no conoce a un abogado, puede IIamar a un servicio de
remisi6n a abogados. Si no puede pagar a un abogado, es posible que cumpla con los requisitos para obtener servicios legales gratuitos de un
programa de servicios legales sin filnes de lucro. Puede encontrar estos grupos sin fines de lucre en el sitio web de Califomia Legal Services,
(v\NIw.Iav\nèlpcatiifornfa.org). en el Centro de Ayuda de las Cortes de Califomia, (www.sucorte.ca.gov) o poniendose en contacto con la corte o el
colegio de abogados locales. AVISO: Por ley, Ia corte tiene derecho a reclamar las cuotas y los costos exentos por imponer un gravamen sobre
cualquier recuperacion de $10,000 6 mas de valor recibida mediante un acuerdo o una concesi6n de arbitrtye en un case de clerecho civil. Tiene que
pagar el gravamen de la corte antes de que la corte pueda desechar el caso.
The name and address of the court is:
CASE NUMBER:
(E/ nombre y df.recoi.6n de /a corfe es/.. Stanley Mosk (Central) Courthouse
(Nclmero del Caso):
Ill N Hill Street, Los Angeles, CA 90012

The name, address, and telephone number of plaintiffs attorney, or plaintiff without an attorney, is:
(EI nombre, la direcci6n y el nomero de tel6fono del abogado del demandante, o del demandante que no tiene abogado, es):
Sean Chandra, Esq., 515 S Flower Street, Floor 36, Los Angeles, CA 90071
P.ATE:` es3q# a $ 2Sts
/FechaJ -`
SllffiRIRCARER
clerk,by
/SecrefarJ.oJ
``}R!`9TjN4GRLjftLV`
,Deputy
(Adjunto)
(For proof Of service of this summons, use Proof of Service of Summons /room POS-070/J
(Para prueba de entrega de esta citati6n use el formulario Proof Of Serv.lee Of Summons. (POS-010)).
NOTICE TO THE PERSON SERVED: You are served
1. I as an individual defendant.
2. I as the person sued under the fictitious name of /spec/fyJ..
3. I on behalf of /spec/fy)..
under E= :::::;: t:::::at:oo:;orat,on,

I CCP 416.40 (association or partnership) I
E= :::::::i:::::,rvatee,
CCP 416.90 (authorized person)
I other /spec/fy)..
4. I by personal delivery on /dare/:
Form Adopted for Mandatory Use
Judicial Councll Of California
SUM-100 [Rev. July 1, 2009]
SUMMONS
Code of CMI Procedure 412.20, 465

www.courtlnfo.ca.gov
AB8g#E6:npa:#gsTqH.(U5fiTrd8Z5Yo/97e,Sla[eBarnumber,andaddress/
CM-010
FOR COURT USE ONLY
515 S Flower Street

Floor 36
Los Angeles, CA 90071
ATTOR::LyEFP:::rvEa::, !33:.)cfi::a22%ma]L.comFAX N
supERioR couRT OF CALIFORNIA, couNTV OF
sTREETADDREss
(213) 281 -9666
Los Angeles
1 1 1 N Hill Street
MAILING ADDRESS:
NCV 2 9 201.Caner,Ex@cutiveOfficer/Clerk\JCristinaGri)alva,Deputy
C'TYBARNADN::::::5tasnfe;ffiL:ki8e:9ral)LCourfhouse
CASE NAME:
herrl
CIVIL CASE COVER SHEETHunlimitedILimited(Amount(Amount
Complex Case DesignationICounterIJoinder
CASE NUMBER:
juDB 6 4 fd 0 8 4
demanded
exceeds $25,000)
demanded is
Filed with first appearance by defendant
$25,000 or less)
DEPT.
(Gal. Rules of Court, rule 3.402)
Items 1-6 below must be compl_efed (see instructions on page 2).
1. Check one box below for the case type that best describes this case:
Auto Tort
Contract
E:::s(:r2e)dmotorist(46)
H Breach of contractwarranty (06)

I Rule 3.740 collections (09)
Other Pl/PD/WD (Personal Injury/Property
DE=agAesTerst::{u#eath)Tort
I AntitrustITrade regulation (03)
I other collections (og)

I Insurance coverage (18)
I Other contract (37)
I Other Pl/PDAVD (23)
Non-Pl/PDAVD (Other) Tort
I Wrongful eviction (33)
I Product liability (24)

I Medical malpractice (45)
Provisionally Complex Civil Litigation

(Cal. Rules of Court, rules 3.400-3.403)
I Construction defect (10)
I Masstort(4o)
I Securities lmgation (28)
I EnvironmentalIToxic tort (30)
Real Property
Eminent domain/Inverse
condemnation (14)
I:nbsouvr:Tj#e%oreor,%fo:,aa,,,T:oa#3j,::rfsmethe
types (41 )
Enforcement of Judgment
E] Business tort/un;air business practice (o7) I Other real property (26)

Unlawful Defainer
I Enforcement of judgment (20)
I Fraud(16)
I Commercial (31)
I Residential (32)
I RICo(27)
I Intellectual property (19)

I Professional negligence (25)
I Drirgs (38)
I Other complaint /not speofi.ed above/ (42)
Judicial Review
I Other nan-Pl/PDAVD tort (35)
I Asset forfeiture (05)
I civil rights (o8)

I Defamation (13)
Miscellaneous Civil Complaint
Miscellaneous Civil Petition
I Partnership and corporate governance (21)
I Petition re: arbitration award (11)
E]p,o#Tonngtfu,term,nat,ont36,
I Other employment (15)
2.
I Other petition /nor specifed above/ (43)
I Writ of mandate (o2)
I Otherjudicial review (39)

Thiscase
Is not
complex under rule 3.400 of the california Rules of court. Ifthe case is complex, mark the
factors requiring exceptional judicial management:
a. I Large number of separately represented parties
d. I Large number of witnesses
b. I Extensive motion practice raising difficult or novel
e. I Coordination with related actions pending in one or more courts
c. I :::tsatnht:ati:EL::nt::fe;Cocnusmu:itnagrytetids:iv:
Remedies sought /check a// that applyj.. a.RI monetary
f. I :nubtsht:rn::#:;i:tga:ees;tjru:c::,tr::Sb;j,:|oan federa' Curt

b.I nonmonetary; declaratory or injunctive relief
C. Hpunitive
Number of causes of action /spec/fyJ.. 5
Thiscase
Eis
Hisnot
aclassactionsuit.
lf there are any known related cases, file and serve a notice of related case. /Yo
Date:
11/14/2016
Sean Chandra
(TYPEORPRINTN
(TYPE
OR PRINT NAME)
E
`L~
(SIGNATURE OF PARTY OR ATTORNEY FOR PARTY)
NOTICE
Plaintiff must file this cover sheet with the first paper filed in the action or proceeding (except small claims cases or cases filed
under the Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.) Failure to file may result
in sanctions.
File this cover sheet in addition to any cover sheet required by local court rule.
lf this case is complex under rule 3.400 et seq. of the California Rules of Court, you must serve a copy of this cover sheet on all
other parties to the action or proceeding.
Unlessthisisacollectionscaseunderrule3.740oracomplexCase,thiscoverSheetWlubeusedforStatisticalPurposesOnlyaae.of2
Fjg#?Ci:#eRdue;c|iTof:y%,d:a!fo:in+:se
C I VI L CA S E C OVE R S H E ET
Gal R u'%Sa,Ofs%#;#;eosf: u,;Fa,28*3#st;%:i%3a394:0;
CM-010
INSTRUCTIONS 0N HOW TO COMPLETE THE COVER SHEET

To Plaintiffs and Others Filing First Papers. If you are filing a first paper (for example, a complaint) in a civil case, you must
complete and file, along with your first paper, the C/.v/./ Case Cover Sheet contained on page 1. This information w"I be used to compile
statistics about the types and numbers of cases filed. You must complete items 1 through 6 on the sheet. In item 1, you must check
one box for the case type that best describes the case. If the case fits both a general and a more specific type of case listed in item 1,
check the more specific one. If the case has multiple causes of action, check the box that best indicates the primary cause of action.
To assist you in completing the sheet, examples of the cases that belong under each case type in item 1 are provided below. A cover
sheet must be filed only with your initial paper. Failure to file a cover sheet with the first paper filed in a civil case may subject a party,
its counsel, or both to sanctions under rules 2.30 and 3.220 of the California Rules of Court.
To Parties in Rule 3.740 Collections Cases. A "collections case" under rule 3.740 is defined as an action for recovery of money
owed in a sum stated to be certain that is not more than $25,000, exclusive of interest and attorney's fees, arising from a transaction in
which property, services, or money was acquired on credit. A collections case does not include an action seeking the following: (1 ) tort
damages, (2) punitive damages, (3) recovery of real property, (4) recovery of personal property, or (5) a prejudgment writ of
attachment. The identification of a case as a rule 3.740 collections case on this form means that it will be exempt from the general
time-for-service requirements and case management rules, unless a defendant files a responsive pleading. A rule 3.740 collections
case will be subject to the requirements for service and obtaining a judgment in rule 3.740.
To Parties in Complex Cases.
In complex cases only, parties must also use the Ci.vt./ Case Cover Sheet to designate whether the
case is complex. If a plaintiff believes the case is complex under rule 3.400 of the California Rules of Court, this must be indicated by
completing the appropriate boxes in items 1 and 2. If a plaintiff designates a case as complex, the cover sheet must be served with the
complaint on all parties to the action. A defendant may file and serve no later than the time of its first appearance a joinder in the
plaintiffs designation, a counterdesignation that the case is not complex, or, if the plaintiff has made no designation, a designation that
the case is complex.
CASE |TPES AND EXAMPLES
Provisionally Complex Civil Litigation (Cal.
Contract
Auto Tort
Auto (22)+ersonal Injury/Property
DamageAvrongful Death
Uninsured Motorist (46) (ff the
case involves an uninsured

motorist claim subject to
arbitration, check this item
instead Of Auto)
Other P[/PD/WD (Personal Injury/
Property Damage/Wrongful Death)
Tort
Asbestos (04)
Asbestos Property Damage
Asbestos Personal Injury/
Wrongful Death
Product Liability /r}Of asbestos or
toxic/environmental) (24)
Medical Malpractice (45)
Medical Malpractice-
Physicians & Surgeons

Other Professional Health Care
Malpractice
Other Pl/PDrm (23)

Premises Liability (e.g., slip
and fall)
Intentional Bodily Injury/PD/WD
(e.g., assault, vandalism)

Intentional Infliction of
Emotional Distress
Negligent Infliction of
Emotional Distress
Other Pl/PDrm
Non-Pl/PDAVD (Other) Tort
Business Tort/Unfair Business
Practice (07)
Civil Rights (e.g., discrimination,
false arrest) /r)of a/.v/./
harassment) (08)
Defamation (e.g., slander. libel)
(13)
Fraud (16)
Intellectual Property (19)
Professional Negligence (25)

Legal Malpractice
Other Professional Malpractice
(net medical or legal)
Other Non-Pl/PD/VVD Tort (35)
Employment
Wrongful Termination (36)
Other Employment (15)
CM-010 [Rev, July 1, 2007]
Breach of ContractM/arranty (06)

Breach of Rental/Lease
Corrfuact (not unlawful detainer
or wrongful eviction)
Contract/\^/arranty Breachseller
Plalir"ff (not fraud or negligence)
Negligent Breach of Contracv
Warranty
Other Breach of Contract/Warranty
Collections (e.g,, money owed, open
bcok accounts) (09)
Collection Case+Seller Plaintiff
Other Promissory Note/Collections
Case
lr`surance Coverage (not provisionally
complex) (18)
Auto Subrogation
Other Coverage
Other Contract (37)

Contractual Fraud
Other Contract Dispute
Real Property
Eminent Domain/Inverse
Condemnation (14)
Wrongful Eviction (33)
Other Real Property (e.g., quiet title) (26)
Writ of Possession of Real Property

Mortgage Foreclosure
Quiet Title
Other Real Property /not eminent

domain, IandlordAenant, or
foreclosure)
Unlawful Detainer
Commercial (31 )
Residential (32)
Drugs (38) (if the case involves illegal

drugs, check this item; othervise,
report as Commercial or Residential)
Judicial Review
Asset Forfeiture (05)
Petition Re: Arbitration Award (11)
Writ of Mandate (02)

WritIAdministrative Mandamus
Vvrit"andamus on Limited Court
Case Matter
WriLother Limited Court Case
Review
Other Judicial Review (39)
Review of Health Officer Order
Notice of AppeaLLabor
Commissioner
CIVIL CASE COVER SHEET
Rules of Court Rules 3.400-3.403)

Antitrust/TTade Regulation (03)
Construction Defect (10)
Claims Involving Mass Tort (40)
Securities Litigation (28)
EnvironmentalIToxic Tort (30)
Insurance Coverage Claims
(arising from provisionally complex
case type listed above) (41)

Enforcement of Judgment
Enforcement of Judgment (20)
Abst:aotino#udgment(Outof
Confession of Judgment /nandomestic relations)
Sister State Judgment
Administrative Ageney Award
(not unpaid taxes)
Petition/Certification of Entry of
Judgment on Unpaid Taxes

Other Enforcement of Judgment
Case
Miscellaneous Civil Complaint

R'CO (27)
thearb%3eT(La7t/nofspecifed
Declaratory Relief Only
lnjunctive Relief Only /I)on-
harassment)
Mechanics Lien
Other Commercial Complaint
Case ( nofrtorf/nan-complex)
Other Civil Complaint
(non-tortinonSomplex)
Miscellaneous Civil Petition
Partnership and Corporate
Governance (21)
Other Petition /nor speciifed
above/ (43)
Civil Harassment
Workplace Violence
Elder/Dependent Adult
Abuse
Election Contest
Petition for Name Change
Petition for Relief From Late
Claim
Other Civil Petition
CASENUMBER
sHORTTITLEMCGiynn v. stuho
BC 6 4 2 0 fl 4
CIVIL CASE COVER SHEET ADDENDUM AND

STATEIVIENT OF LOCATION
(CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION)

This form is required pursuant to Local Rule 2.3 in all new civil case filings in the Los Angeles Superior Court.
Step 1 : After completing the Civil Case Cover Sheet (Judicial Council form CM-010), find the exact case type in
Column A that corresponds to the case type indicated in the Civil Case Cover Sheet.
Step 2: In Column 8, check the box for the type of action that best describes the nature of the case.
Step 3: ln Column C, circle the number which explains the reason for the court filing location you have
chosen.
Applicable Reasons for Choosing Court Filing Location (Column C)

1. Class actions must be filed in the Stanley Mosk Courthouse, Central District.
7. Location where petitioner resides.
2. Permissive filing in central district.
8. Location wherein defendant/respondent functions wholly.
9. Location where one or more of the parties reside.
3. Location where cause of action arose.

4. Mandatory personal injury filing in North District.
10. Location of Labor Commissioner Office.
5. Location where performance required or defendant resides.
11. Mandatory filing location (Hub Cases -unlawiul detainer, limited

non-collection, limited collection, or personal injury).
6. Location of property or permanently garaged vehicle.
Civil Case Cover Sheet
Type of Action
(Check only one)
Applicable Reasons -
Category NO-
See Step 3 Above
Auto (22)
1]
A7100 Motor vehicle -Personal Injury/Property Damage/\/Vrongful Death
1, 4,11
Uninsured Motorist (46)
A7110 Personal Injury/Property DamageM/rongful Death -Uninsured Motorist
1 , 4. 1 1
A6070 Asbestos property Damage
1,11
A7221
tll
A7260 Product Liability (not asbestos or toxic/environmental)
Asbestos (04)
Product Liability (24)
Asbestos -Personal Injury/\/Vrongful Death
1, 4,11
A7210 Medical Malpractice -Physicians & Surgeons
1, 4,
11
A7240 Other professional Health care Malpractice
1, 4,
11
A7250 Premises Liability (e.g., slip and fall)
H
Medical Malpractice (45)
Other Personal
Injury Property
Damage Wrongful
Death (23)
LACIV 109 (Rev 2/16)
LASC Approved 03-04
A7230 Intentional Bodily Injury/Property Damage/Wrongful Death (e.g.,

assault, vandalism, etc.)
1, 4,11
1, 4,111,4,111,4,11
A7270 Intentional Infliction of Emotional Distress
A7220 Other personal Injury/Property Damage/Wrongful Death
CIVIL CASE COVER SHEET ADDENDUM

AND STATEMENT OF LOCATION
Local Rule 2,3
Page 1 of 4
RE
SHORT TITLE.
CASE NUMBER
MCGlynn v. Stuho
C Applicable

Category No.
Type of Action
(Check only one)
Reasons - See Step 3

Above
Business Tort (07)
A6029 Other commercial/Business Tort (not fraud/breach of contract)
Civil Rights (08)
A6005 Civil Rights/Discrimination
1, 2, 3
Defamation (13)
A6010 Defamation (slander/libel)
1, 2, 3
Fraud (16)
A6013 Fraud (no contract)
1, 2, 3
A6017 Legal Malpractice
1, 2, 3
A6050 Other professional Malpractice (not medical or legal)
1, 2, 3
Other (35)
A6025 Other Non-Personal Injury/Property Damage tort
1, 2, 3
Wrongful Termination (36)
A6037 Wrongful Termination
1, 2, 3
A6024 Other Employmentcomplaint case
1, 2, 3
A6109 LaborcommissionerAppeals
10
A6004 Breach of Rental/Lease contract (not unlawful detainer or wrongful
1, 2, 3
Professional Negligence (25)
Other Employment (15)
2,52,51,2, 51,2,5
eviction)
Breach of Contract/ Warranty(06)

(not insurance)
A6008 Contract/Warranty Breach -Seller plaintiff (no fraud/negligence)
A6019 Negligent Breach of contract/Warranty (no fraud)
H
I
A6028 Other Breach of contract/Warranty (not fraud or negligence)

A6002 Collections case-Seller plaintiff
5, 6,11
Collections (09)
Insurance Coverage (18)
Other Contract (37)
Eminent Domain/InverseCondemnation(14)
Wrongful Eviction (33)
Other Real Property (26)
Unlawful Detainer-Commercial(31)
Unlawful Detainer-Residential(32)
Unlawful Detainer-Post-Foreclosure(34)
unlawiul Detainer-Drugs (38)
LASC Approved 03-04
1]
A6012 Other promissory Note/Collections case
5,11
A6034 Collections Case-Purchased Debt (Charged Off consumer Debt

Purchased on or after Januarv 1, 2014)
5, 6,11
A6015 Insurance coverage (not complex)
1, 2, 5. 8
A6009 Contractual Fraud
1, 2, 3, 5
A6031
1, 2, 3, 5
A6027 Other contract Dispute(not breach/insurance/fraud/negligence)
1, 2, 3, 8, 9
A7300 Eminent Domain/Condemnation
2,6
Tortious Interference
Number of parcels
A6023 Wrongful Eviction case
2,6
A6018 Mortgage Foreclosure
2,6
A6032 QuietTitle
2,6
A6060 Other Real property (not eminent domain, landlord/tenant, foreclosure)
2,6
A6021
6,11
A6020 Unlawful Detainer-Residential (not drugs or wrongful eviction)
6,11
A6020F unlawiul Detainer-Post-Foreclosure
2, 6,11
A6022 Unlawiul Detainer-Drugs
2, 6,11
Unlawiul Detainer-Commercial (not drugs or wrongful eviction)

Local Rule 2.3
Page 2 of 4
Eil
SHORT TITLE:
CASE NUMBER
MCGlynn v. Stuho

Category No.
Type of Action
(Check only one)
C Applicable
Reasons - See Step 3

Above
Asset Forfeiture (05)
A6108 Asset Forfeiture case
2, 3, 6
Petition re Arbitration (11 )
A6115 Petition to compel/Confirmlvacate Arbitration
2,5
Writ of Mandate (02)
A6151
Writ -Administrative Mandamus
2,8
A6152 Writ -Mandamus on Limited court case Matter
A6153 Writ -Other Limited court case Review
Other Judicial Review (39)
A6150 0therwrit/Judicial Review
2,8
Antitrust/Trade Regulation (03)
A6003 Antitrust/Trade Regulation
1, 2, 8
Construction Defect (10)
A6007 Construction Defect
1, 2, 3
1]
A6006 Claims Involving Mass Tort
1, 2, 8
Claims Involving Mass Tort(40)
Securities Litigation (28)
Toxic TortEnvironmental (30)
Insurance Coverage ClaimsfromComplexCase(41)
A6035 Securities Litigation case
1]
A6036 Toxic Tort/Environmental
1]
Enforcement
of Judgment (20)
RICO (27)
A6014 Insurance coverage/Subrogation (complex case only)
A6141
SisterstateJudgment
1, 2, 8
1, 2, 3, 8
1, 2, 5, 8
2, 5, 11
A6160 Abstract of Judgment
2,6
A6107 Confession of Judgment (non-domestic relations)
2,9
A6140 Administrative Agency Award (not unpaid taxes)
2,8
A6114 Petition/Certificate for Entry of Judgment on unpaid Tax
2,8
A6112 Other Enforcement of Judgment case
2, 8, 9
A6033 Racketeering (RICO) Case
1, 2, 8
A6030 Declaratory Relief only
1, 2, 8
Other Complaints
1]
(Not Specified Above) (42)
A60110ther commercial complaint case (non-tort/non-complex)
1, 2, 8
A6000 Other civil complaint (non-tort/non-complex)
1, 2, 8
A6113 Partnership and corporate Governance case
2,8
A6121
2, 3, 9
Partnership CorporationGovernance(21)
H
Other Petitions (Not
Specified Above) (43)
2, 3, 9
2, 3, 9
A6190 Electioncontest
A6110 Petition for change of Name/Change of Gender
LASC Approved 03-04
Civil Harassment
A6123 Workplace Harassment
2,8
A6124 Elder/DependentAdult Abuse case
A6040 lnjunctive Relief only (not domestic/harassment)
A6170 Petition for Relieffrom Late claim Law
A6100 0thercivil petition

2,7
2, 3, 8
2,9
Local Rule 2.3
Page 3 of 4
J+
EH
SHORT TITLE:
CASE NUMBER
MCGlynn v. Stuho
Step 4: Statement of Reason and Address: Check the appropriate boxes for the numbers shown under Column C for the
type of action that you have selected. Enter the address which is the basis for the filing location, including zip code.
(No address required for class action cases).
ADDRESS.
REASON:
2595 S Hoover Street, Los Angeles, CA 90007
1. /_, 2. L_I 3. i 4. T 5. I 6. I_, 7.
I 8. i`
9. -110. LJ 11.
CITY.
STATE-
ZIP CODE:
Los Angeles
CA
90007
Step 5: Certification of Assignment: I certify that this case is properly filed in the Central
District of
the Superior Court of California, County of Los Angeles [Code Civ. Proc., 392 et seq., and Local Rule 2.3(a)(1)(E)].
Dated: 11/14/2016
OF ATTORNEY/FILING PARTY)
PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY
COMMENCE YOUR NEW COURT CASE:
1.
Original complaint or petition.
2.
If filing a complaint, a completed summons form for issuance by the clerk.
3.
Civil case cover sheet, Judicial council form cM-010.
4.
Civil Case Cover Sheet Addendum and Statement of Location form, LACIV 109, LASC Approved 03-04 (Rev.
02/16).
5.
Payment in full of the filing fee, unless there is court order for waiver, partial or scheduled payments.
6.
Asigned orderappointingthe Guardian ad Litem, Judicial council form CIV-010, if the plaintifforpetitioneris a
mlnor under 18 years of age will be required by Court in order to issue a summons.
7.
Additional copies of documents to be conformed by the Clerk. Copies of the cover sheet and this addendum
must be served along with the summons and complaint, or other initiating pleading in the case.
LASC Approved 03-04

AND STATEIVIENT OF LOCATION
Local Rule 2.3
Page 4 of 4
Bid
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Sean Chandra (SBN 249058)

515 S Flower Street
36th Floor

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Tel: (323) 454-3321

Fax: (213) 281-9666
NCV 2 9 2016
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SherriR.Carter,ExecutjveOffieer/Clerk
8vCrit'naGri).alva,Deputy
EVICTION DEFENSE NETWORK

Elena I. Popp (SBN 129531)
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Claudia Medina (SBN 249139)

1930 Wilshire Blvd
Suite 208
Attorneys for Plaintiffs

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SUPERIOR COURT FORTHE STATE 0F CALIFORNIA

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COUNTY 0F LOS ANGELES

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caseNo.:
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CONNOR MCGLYNN, an individual;

ALEC PHILLIPS, an individual;
KIERAN STOLORE, an individual;
Be643$4
COMPLAINT FOR DAMAGES

DEMAND FOR TURY TRIAL
Plaintiffs,
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17
VS.
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19
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STUHO, a California Corporation;
HOOVER -ADAMS HOLDING LLC, a

California Limited Liability Company;
-andDOES 1-1,000,
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Defendants.
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25
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28
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INTRODUCTION
1. The plaintiffs in this lawsuit are USC students who fell victim to a classic bait-
and-switch. The students leased expensive housing, conveniently located within

walking distance of USC's campus, several months in advance of the 2016-17
academic year. The students knew that the leases they signed had one important
caveat: the ELEMENT-the property that the students had signed up to live
in-was under construction.

2. The defendants in this lawsuit are real estate companies that capitalize on the
tight market for student housing at USC. Knowing that construction of the
ELEMENT would not be complete in time to house students at the beginning of
the fall term, the defendants nevertheless concealed this fact from the students.
Meanwhile, Defendants continued to market available units via social media.
3. After it became public-two weeks before the students expected to move inthat no end to the construction was in sight, Defendants made the students a
series of empty promises, failed to provide them adequate replacement housing,
and acted oppressively and in bad faith. Nearly four months of the students' lease
had elapsed before the owners of the ELEMENT gave them permission to move
in.
4. The affected students, including the Plaintiffs, were marooned in overcrowded

quarters at the Da Vinci apartment complex in Bunker Hill, nearly five miles
away from campus. During peak rush hour, it often took them 45 minutes or
more to commute to or from campus. Defendants refuse to compensate the
students for being displaced from the USC community, nor did Defendants
adequately mitigate the harm they caused. The students demand compensation
for having suffered academically as a result.
//
//
//
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PARTIES AND PRELININARY ALLEGATIONS

5. As of the date of this complaint, Plaintiffs CONNOR MCGLYNN, ALEC
PHILIIPS, and KIERAN STOLORZ (collectively, "Plaintiffs") are students
enrolled at the University of Southern California ("USC") .
6. As of the date of this complaint, the ELEMENT is an under-construction

apartment complex located at 1105 West Adams Boulevard, Los Angeles.
7. Defendant STUHO, a California Corporation, is the property manager of the
ELEMENT.
8. Defendant HOOVER - ADAMS HOLDING LLC ("HAH"), a California
Limited Liability Company, is the owner of the ELEMENT.
9. On information and belief, Defendants STUHO and HOOVER - ADAMS

HOLDING LLC are entities with common ownership, and, for all intents and
purposes, are each other's alter ego. Each entity is responsible for the acts and
omissions of the other as alleged in this lawsuit.
10. Plaintiffs entered into lease agreements with STUHO during the 2015-16 school
year.
11.A copy of the LEASE as entered into between KIERAN STOLORZ and
STUHO is attached to this complaint as Exhibit 1, and is hereby incorporated
by reference within each of the allegations in this complaint.
12.On information and belief, the LEASE signed by KIERAN STOLORZ is

identical to the lease signed by every other displaced student tenant of the
ELEMENT, including each of the named plaintiffs herein, with the exception of
the names of the tenants and any guarantors.
13.Plaintiff is currently unaware of the true identities of DOES 1-1,000. These
Defendants are sued pursuant to Code of Civil Procedure 474. Plaintiff asks the
Court's permission to amend this complaint by inserting herein the true names
and capacities of those defendants when they become known.
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14. Plaintiffs are informed and believe that each defendant in each respective cause
of action of this complaint was at pertinent times an agent and representative of
every other defendant in that cause of action.

15. As used in each and any cause of action of this complaint, the term "defendants"
4
5
refers to all of the defendants, including "Doe" defendants, expressly named or
designated as such in the title of that particular cause of action; and only to those
designated or named defendants.
GENERAL ALLEGATIONS
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10
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14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
A.
STUHO Entiees plainti_i is Ilo sign Leases ln The un_finished ELEMENT

16. Housing, and especially housing in close proximity to campus, is a scarce and
highly valuable commodity for USC students.

17.Because housing near USC is so scarce, Defendant STUHO encouraged USC
students, via an aggressive and effective marketing campaign, to sign leases
committing them to live in the ELEMENT-a yet-to-be-completed apartment

complex planned for the intersection of Hoover Street and Adams Boulevard in
South Los Angeles-well in advance of the fall semester.

18.Nine months before he would begin his senior year, Plaintiff CONNOR
MCGLYNN ("Connor") thought he had solved his searcb for housing. In or
about November 2015, he came across advertisements for the ELEMENT,

which is within walking distance from USC's campus.
19. Connor got in touch with a representative of the property manager, STUHO,
and found that the planned property met his needs. He was initially concerned
about whether the property would be ready to move in to on time, but STUHO
representatives assuaged his fears. They assured him that the project would be
completed before the beginning of classes. Still concerned, he asked what would
happen if construction faced unforeseen delays. STUHO representatives again
assured him that the property would be ready on time, but told him that in the
COMPIAINI
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unlikely event the property was not ready in time, residents would be temporarily
housed in a "hotel on campus." As a result of these assurances, Connor signed a
lease.
20.Each unit at the EIEMENT was advertised as a three-bedroom apartment

designed to accommodate six students, two per bedroom, with an extra-long
twin bed and desk provided for each student, along with furnishings for the
common areas.
21.After signing his lease, Connor began searching for other students to fill the
apartment. Six months before the lease was set to begin, Connor had filled the
apartment. Two of his would-be roommates were Plaintiffs ALEC H. PHIILIPS

("Alec") and KIERAN STOLORZ ("FGeran"). Alec and Kieran signed leases in
February, 2016 .
22.Each individual student expected to pay approximately $884 each, per month,
for the right to share a three-bedroom apartment with five other students. Tbe
total rental cost for the Plaintiffs' three-bedroom apartment was $5,304.00 per
month.
8. TevovIeeks Bet;ore_School Starts. The First Inkling Of A Problerii.

23. On or about July 14, 2016, little more than two weeks before Plaintiffi expected
to move into their quarters, the would-be tenants of the ELEMENT received
notices that the building was no longer expected to be finished on time for the
beginning of school.
24.STUHO gave some students the option of canceling their lease and finding
replacement housing. The initially-named plaintiffs in this suit received no such
option. Even if these plaintiffs had received such an option, it is unlikely that they
would have been able to find alternate housing in such a short time frame.
25. Few+if any-f the students who were offered an option to cancel actually did
so, because STUHO continued to misrepresent the completion date of the
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EL@
project. Because most students were out of I.os Angeles for the summer, they
were unable to drive by the property to verify STUHO's claim that construction
was nearly complete. Had they visited the property, they might have known
immediately that construction was nowhere near done. STUHO, nevertheless,

continued to placate the students with false promises.
26. Even if the students had known, as of July 14, 2016, that the construction delays
were not minimal, it would have been difficult, if not impossible, for the affected
students to find alternative housing in the tight market at the last minute.
27.Most, if not all students, ultimately chose to put up with the delays because of
STUHO's continued representations that construction would be complete

imminently.
C.
A T:Iineline of Emt>tw promises
28.On or about July 14, 2016, in its initial notice to students that the property
would not be ready, STUHO-who shares common ownership with, and is the
alter ego of HOOVER -ADAMS HOLDING ILC ("HAH"), the developertold students that "the developer of the Element... informed us that the timeline
for the Element's launch has unfortunately been pushed back to between
"September lst 2016 to September 30th 2016. However, the developer has
informed us that they have secured alternative, toprof-the-line housing for you
that is approximately 4 miles away from campus. They know what an
inconvenience this for you [sic.], and as such, will be discounting your rent by
20% for the entire Fall semester (through December 2016), as well as providing
a dedicated shuttle service to and from campus."
29.The email went on to describe the features and benefits of the students'
temporary quarters, "luxury" apartments known as "the Davinci."
30. This email had the unfortunate effect of reassuring students that a small amount
of patience on their part would be rewarded, and that they should not look for
COMPIJAINI
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alternative housing to mitigate the damages they expected to suffer from being
displaced.
31. As the month of September came to an end, students began to pressure STUHO
for an update. On September 22, 2016, HAH sent the students an update
through its agents at STUHO, apologizing for the construction delays, blaming
them on "scheduling and timing issues for inspections with the city, county, and
safety authorities. "
32.In the same email dated September 22, 2016, IIAH assured students that they
would just have to wait one more month. "You will be able to move in starting
the week of October 24th, 2016. As a reminder, please remember that the last
day at the Da Vinci will be October 31st, 2016; accordingly, please arrange to
move out on or before that date."

33.In the same email dated September 22, 2016, for the first time, HAH offered
affected students the option to cancel their lease.
34. "Due to the unanticipated delays," HAH wrote, "we are offering the following
two options to you:"
35.The
first
option
offered
by
HAH:
"You
can
stay
at
the
temporary
accommodations at the Da Vinci until October 3lst, 2016; this will provide
flexibility for you to schedule your move at your convenience during the week of
October 24th, 2016. To help ease the transition we will have utilities set up for
your unit at Element and will pay for your utilities for the remainder of the Fall
2016 semester. You will not need to sign any paperwork in order to exercise this
option.
36.The second option offered by HAH: "You can choose to be released from your
lease obligations effective as of October 31st, 2016 (as set forth in the link below
which contains the Termination Agreement), and be free to make your own
housing arrangements elsewhere .... Should you choose to be released from your
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lease obligations, please sign and return the attached Termination Agreement on
or before Thursday, September 29, 2016 at 5 p.in."1
37.In short, HAH promised students, in no uncertain terms, that they would be
able to move in on October 24th, and offered them inducements to continue
their tenancy. Alternatively, HAH told students they could exit their leases at the
end of October, but that they would have only one week to find alternative
housing on their own.
38.The first three weeks of October came and went without any word from the
ELEMENT's developer or its management about a move-in date. The students,
10
assuming that they would be moving in between October 24-31, made
11
arrangements and plans to accommodate a move during that week.
12
39.On October 21, 2016, the students received an update: "all of the interiors of
13
buildings 1 and 2 are now fully complete, furniture has been installed and is
14
ready to go, and the apartments will be given a sparkle clean next Wednesday,
15
October 2lst, 2016. ''2
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40. No move-in date was given. The only hint of progress was this statement: "At this
17
point, all they are waiting for is for the city to issue their certificate occupancy
18
[sic.] so that they can finally move you in. As this is unfortunately outside of their
19
control, they do not have a speciflc date to give you just yet, but they are
20
expecting to know when this will be issued by the middle of next week."
21
41.Further, the students were "advise[d] against making travel arrangements so as
22
to avoid having to potentially shift them."
23
42. The middle of next week came and went.
24
43.After pressuring STUHO for anotber update, the students received another
25
email on October 28, 2016, stating that "the developer is almost at the finish
26
line!"
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28
;FnT#:citsdi:t::ingl;nr::.ina,.
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44. In this email, STUHO also stated that HAH "...informed us that the city will be
coming out early next week for the purposes of final inspections that will allow
them to issue the developer that certificate."
45. Early next week came and went.

46.On November 3, 2016, the students received their next update: "We have
received the necessary approvals from the vast majority of agencies having
jurisdiction. With just a couple left to obtain from the city, we are confident that
we will have permission to occupy the building by this coming Wednesday,
November 9th. "
47.The city issued a temporary certificate of occupancy to the owners of the
ELEMENT on November 10, 2016. On information and belief, the students will
be allowed to move in during the week of November 14-18, and they must vacate
their units at the Davinci by November 30.
D.
De_i;endants ' Excuses For The Delays concealed The Truth
48.While Defendants were blaming the bureaucracy of the City of Los Angeles for
its construction delays, Plaintiffs are now informed and believe that the time it
took to build the ELEMENT was not far off from the average amount of time it
can reasonably be expected to build a project like the ELEMENT, and that the
city inspectors responsible for approving the certificate of occupancy were
quickly responsive to requests for inspections.
49. Additionally, Plaintiffs are informed and believe that if there were delays beyond
those expected in the ordinary course of housing construction, they were related
to the Defendant's conscious choices-including their choice to prioritize the

needs of commercial tenants over those of tbe students, and their choice to leave
students without housing alternatives closer to campus so that students would
remain trapped in their leases through the school year. Knowing that Defendants
would be hard-pressed to find tenants to fill the ELEMENT for only the spring
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and summer sessions, which would have cost Defendants upwards of $2 million
in income, Defendants deliberately strung Plaintiffs along, thereby depriving

them, in bad faith, of the negotiated benefits of their lease agreement.
50. Defendants were intentionally and recklessly wrongful, and/or negligent, in
misrepresenting to the students that their housing would be ready for them at the
beginning of the school year, because they knew or should have known that
constructlon could take much longer than anticipated. Further, Defendants

knew or should have known much earlier than July 14, 2016 that the students
would not be able to move in to their units on time. Defendants had notice that
the Plaintiffs, being students, had insufficient connections to the community to
find housing in the short time frame provided by Defendants, were particularly
vulnerable to being injured by the Defendants' breaches of their duties under
contract and tort.
E. Da:n!.afEes Sttffered Bv Plaintiffs

51.Alec, Kieran, and Connor were each attracted to the ELEMENT primarily due
to its location within close proximity of USC. Location of their housing was
crucial in accommodating their packed schedules consisting of coursework, on-
campus
work, athletics, and
extracurricular commitments
to the
USC
community.
52.Alec, pursuing a degree in environmental studies with an ROTC scholarship,
spends most of his days on campus, beginning as early as 6am for his ROTC
physical training exercises. He drives to campus early, because STUIIO's shuttle
service is not available that early in the morning. He then drives back home
through Downtown L.A. during the morning commute to shower and change
before shuttling back to USC for a 10:00 ani class. He spends as much as 12
hours per day on campus.
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53. Kieran, a senior Computer Engineering student who also competes in USC's
weightlifting program, is obliged to keep a rigid and consistent training schedule,
and USC's gymnasium has the equipment he needs to meet his physical training
needs. He must also leave before the shuttle begins running to fit his athletics
commitments into his class schedule. Combined with his busy schedule, Kieran's
lack of proximity to campus has made it prohibitively difficult to schedule oncampus interviews for post-college jobs, one of the most important aspects of the
career path of a college senior in the technology field. As a result, Kieran has
fallen behind his peers in his job search and fears that he will not have a good job
after graduation-ven though he is a highly accomplished student in an indemand field.
54. Connor, a dedicated student at USC's Annenberg School for Journalism and
Communication, has a heavy load of campus commitments in addition to his full

load of journalism and writing coursework. He covers the USC football team for
the student press and produces a student-run television show. On a typical day
he arrives at the USC campus at 7:00 am and leaves after midnight.

55. As the months wore on, their senior year slipping away, these students heard little
more than empty promises from STUHO. With no end to construction in sight,
each of these students was taxed past the limits of exhaustion. Their academics
suffered. They were unable to take advantage of many of the campus activities
enjoyed by USC students who are housed close to campus. They signed up for
courses and committed to campus life without expecting that they would be
commuting to school. Now, they demand to be fairly compensated for the

injuries they suffered as a result of STUHO's failure to disclose accurate
constructlon updates to the students in time for them to find alternative housing.
56. Furthermore, as construction delays mounted, Defendants grew increasingly
frugal with the students. Initially, Defendants reimbursed the students for
incidental expenses related to their distant location from campus, such as
COMPll
BIB
parking spots at the Da Vinci and Uber rides after for late trips back home from
campus after the shuttle had stopped running. As the months wore on,
Defendants gave up on placating the students and left them to their own devices.
This placed an added strain on the students financially, many of whom were
living on scholarships and student loans, and had to choose between staying on
campus late and paying for an Uber car that they could not afford, or arriving
home with the last shuttle and missing out on valuable time on campus. Now,
they demand to be fairly compensated for the injuries they suffered as a result of
STUHO's failure to live up to Its contract.
57.Although Defendants have, at long last, been issued a temporary Certiflcate of
Occupancy for the EI.EMENT, construction of the building is ongoing, and is

expected to continue through the academic year. Substantial parts of the
common facilities of the building remain unfinished, including the gymnasium
and swimming pool that were advertised as part of the complex. Therefore,
Plaintiffs also demand to be fairly compensated for the loss of use of these
common areas, in addition to the expected loss of their quiet enjoyment of their
property during construction.
FIRST CAUSE 0F ACTION

FOR BREACH OF CONTRACT
Against Defendants STUH0 and HOOVER -ADAMS HOLDING LLC
58.Plaintiffs restate, verbatim, Paragraphs 1 through 57 in this complaint and
hereby incorporate those paragraphs within this cause of action.

59.As set forth in Paragraphs 21, 22, and elsewhere in this complaint, including in
the LEASE attached for reference as Exhibit 1 to this complaint, a written
contract exists between each of the Plaintiffs and Defendants STUHO and
HOOVER -ADAMS HOLDING LLC ("IIAH") .
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60.Plaintiffs have performed each and every one of their obligations under the
LEASE. All conditions of Defendants' performance under the lease have either
been performed by the Plaintiffs and/or excused by Defendants' failure to
perform.
61.STUHO and HAH had a duty "to make every effort to conclude constructlon
and make the Residence rent-ready by the lease start date."3 STUHO and HAH
failed in this aspect of their performance under the LEASE.
62. STUIIO and IIAH had a duty, in the event the ELEMENT was not rent-ready
by August 1, 2016, to provide Plaintiffs "reasonable temporary accommodations
until such time as the Residence is rent-ready." Because the Da vinci apartments
were located in a substantially different location, they did not constltute
"reasonable temporary accommodations." Therefore, STUHO and HAH failed

in this aspect of tbeir performance under the LEASE.
63. STUHO and HAH have a duty under California law to provide Plaintiffs with
quiet enjoyment of their quarters at the ELEMENT. Because construction is
planned to continue throughout the academic year, which will result in
disruptions to the Plaintiffs' academic studies, STUHO and HAH are expected
to fail in this aspect of their performance under the LEASE.
64.As set forth in Paragraphs 51 through 57 of this complaint, Plaintiffs suffered
damages as a proximate result of the breaches of STUHO's and HAH's duties

under the LEASE, in excess of the jurisdictional minimum of this Court.
//
//
//
//
3 See Exhibit I, p.18.
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SECOND CAUSE OF ACTION

FOR BREACII OFTIIE COVENANT OF GOOD FAITII AND FAIR
DEALING
(Against Defendants STUII0 and II00VER -ADAMS II0LDING LLC)
65.Plaintiffs restate, verbatim, Paragraphs 1 through 64 of this complaint and
66. The allegations contained within and referenced by the First Cause of Action, for
Breach of Contract, establish that a written contract exists between each Plaintiff
and both of the Defendants named in this cause of action, that Plaintiffs fully
performed under those written contracts, and that all conditions on Defendants'
performance under those contracts have been performed and/or excused.
67.As set forth in Paragraphs 1-57, Defendants deliberately strung the Plaintiffi
along while construction was delayed, encouraging Plaintiffs to believe that their
displacement from the USC neighborhood would be short and insignificant.

Defendants did so deliberately and in bad faith, with a financial motive. In so
doing, Defendants unfairly interfered with each Plaintiff s right to receive the
benefits of the LEASE.
68.As set forth in Paragraphs 51-57 of this complaint, the unfair conduct of
Defendants harmed each of the Plaintiffs by amounts in excess of the

jurisdictional minimum of this Court.
THIRD CAUSE OF ACTION

FO R NEGLIGENT MISREPRESENTATION
(Agaainst Defendants STUHO and HOOVER -ADAMS HOLDING LLC)
69.Plaintiffi restate, verbatim, Paragraphs 1 through 57 of this complaint and
70. The Defendants named in this cause of action represented to each Plaintiff that
construction of the EIEMENT would be complete, and that the Plaintiffs would
be able to occupy their leased apartment units at the ELEMENT at the
beginning of their lease, August 1, 2016.
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71. After that representation proved inaccurate, the Defendants named in this cause
of action made successive representations to each Plaintiff that construction
would be complete, and that the Plaintiffs would be able to occupy their leased
apartment umts, on short order. First, they promised that the students would be
able to move in September, and then in October. Finally, the students were given
permission to move in to the ELEMENT on November 14, 2016.
72.Even if the Defendants believed that construction of the ELEMENT would be

complete in time for the beginning of the lease term and USC's fall term, as
construction delays mounted they had no reasonable grounds for believing the
representation was true. Even up to mid-July, the Defendants continued to
advertise available apartments at the ELEMENT for the fall semester on their
website. Although many students had expressed concern about whether the
project would be completed on time, the Defendants failed to inform their

prospectlve tenants until it was too late for them to find alternative bousing.
73. Based on the track record of the contractor they negligently hired and negligently
failed to supervise for timeliness, the Defendants had no reasonable grounds for
believing that any of these representations were true.
74.On or about July 14, 2016, when the Defendants made a representation to the
students that the ELEMENT would be available to move into sometime in

September, the Defendants had no reasonable grounds for believing that
representation was true.
75. On or about September 22, 2016, when the Defendants made a representation
to the students that the ELEMENT would be available to move into on October
21, 2016, and at the same time offered the students a time-limited option to exit
their leases, the Defendants had no reasonable grounds for believing that
representation was true.
76.Each
of
the
above
misrepresentations,
in
addition
to
the
list
of
misrepresentations described above, were negligently provided to the students by
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individuals employed by STUHO and/or HOOVER - ADAMS HOI.DING

IIC, and these individuals lacked the expertise and the reasonable grounds to
make these representations accurately.
77.Each successive misrepresentation described above, in addition to the list of
misrepresentations described in the general allegations between Paragraphs 16-
47, caused the Plaintiffs to continue their tenancies reasonable reliance on the
negligently provided falsehood that their move to the ELEMENT was just
around the corner.
78.As described in paragraphs 51-57, Plaintiffs were damaged by the above
negligent misrepresentations.
FOURTH CAUSE OF ACTION

FORVI0IAII0N 0F GAL. BUS. & PROF. CODE 17500` et sea.
ffALSE ADVERTISING)
79. Plaintiffs incorporate all of the preceding and foregoing paragraphs and causes of
action, as well as the contents of all exhibits attached hereto, within this cause of
action as though set forth verbatim.

80. Defendants have violated and continue to violate Business & Professions Code
17500 by making or causing to be made untrue or misleading statements, which
they know or by the exercise of reasonable care should know are untrue or
misleading, with the intent to induce members of the public to rent housing at
the ELEMENT. Defendants' violations of this section include, but are not
limited to, the following: By disseminating or causing to be disseminated
statements concerning their ability to lease rental housing at the ELEMENT at

or before the start of USC's fall semester in the 2016-17 school year, Defendants
represented that they could do so. The statements were misleading because the
Defendants knew that the ELEMENT would not be ready in time long before
July 14, 2016, when they finally informed students of the delays.
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FIFTH CAUSE 0F ACTION

FORVI0LATI0N 0F GAL. BUS. & PROF. CODE 17200. et sea.
(UNFAIR BUSINESS PRACTICES)
81. Plaintiff incorporates all of the preceding and foregoing paragraphs and causes of
action in this complaint, as well as the contents of all exhibits attached hereto,
within this cause of action as though set forth verbatim.

82. California's unfair competition statute, Business and Professions Code 17200
et seq., prohibits any unfair competition, which means "any unlawful, unfair or
fraudulent business act or practice." This tripartite is disjunctive and the plaintiff
need only allege one of the three theories to properly plead a claim under
17200. Section 17200 was written broadly in order to allow the courts maximum
discretion to prohibit new scbemes to defraud. The statute provides that unfair
competition includes unlawful, unfair, or fraudulent business practices and
unfair, deceptive, untrue, or misleading advertising.
83.As set forth throughout this complaint, Defendants STUHO and HOOVER -
ADAMS HOIDING IIC made false representations about the progress of

construction of the EI.EMENT and concealed material information about the
timeline for Plaintiffs' move-in to the ELEMENT. These misrepresentations and
concealments convinced Plaintiffs to stay in their leases and forgo seeking
alternative housing.
84. The acts listed in the preceding paragraph and throughout the complaint are all
business practices that are unlawful, unfair, and/or fraudulent under Business
and Professions Code 17200. STUHO, HOOVER -ADAMS HOIDING

LLC, and the interests making up their common ownership, have a custom and
practice of engaging in this behavior not just toward the Plaintiff in this action,
but also towards other USC students seeking housing in the rental market near
USC.
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85. Plaintiff also seeks remedies, including attorney fees, under California's private
attorney general statute
2
3
86.Because of the unfair, unlawful, and/or fraudulent acts listed in this cause of
action, Plaintiffs suffered damage to their academic careers, reputations, and
prospects.
6
7
8
WHEREFORE, Plaintiff seeks judgment as follows:
1.
A money judgment, that plaintiffs shall recover jointly and severally from each
10
and all of the defendants all compensatory damages alleged in these causes of action
11
and proved at trial, together with accrued interest.
12
2.
Punitive damages according to proof.
13
3.
Reasonable attorney fees, as authorized by contract, for enforcement of the
14
Lease.
15
4.
Costs of suit.
16
5.
Disgorgement of profits, revenues, and incomes obtained by way of Defendants'
17
wrongdoing.
18
6.
Further relief as is deemed proper by the court.
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20
2]
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COMPLAINT
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STUDENT HOUSING
RENTAL AGREEMENT
2595 Hoover St, Los Angeles, CA 90007
QUICK GLANCE
Premises:
2595 Hoover st #18-3. Los Anaeles. CA 90007
which includes common areas in the "Student llousing Prpject'' (\^rhich is also kno\^m as "SHP")).
Parties to Student Housina Rental Aareement:

-Tenant[s]: Alec H. PhilliDs and Kieran S. Stolorz,
(Hereinafter known collectively as `rTenant').
- Landlord: Hoo\rerAdams Holdina. LLC (hereinafter known as I.Landlord') by Stuho lnc.. Agent, Manager Of "Student
Housing Project" (SHP)

Rent per Month: $1.768.00
Rent Due Date: 1st Dav Of each Month
Rent Start Date: Auaust 1. 2016
Returned Check Fee: $50.00
Late Rent Charge: Z3& of monthly rent received after the 3[g day Of the due date
Security Deposit: $500.00
Parking Space(s): RA
Parking Space Number(s): D!A
Rental Term:
Aunust 1. 2016throughJulv 31. 2017
Landlord Owned Personal Property: Common area furniture: TV: sofa. table(s}. chair(sl. ADDliances: stove/oven.
refriaerator. dishwasher. washer/drver. Bedroom furniture: bed(sl. desk/sl. chair(sl.
Pet ryIN): u
Utilities Included:
a Internet Service
a rv Service
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TThis agreement is entered in the 24h day of February, 2QJf by and between: HooverAdams Holdina. LLC Landlord
Landlord rents to the Tenant[s]
Alec H. PhilliDs and Kieran S. Stolorz,Tenant[s]
Tenant[s] rents from the Landlord the Premises as described above under the Terms and Conditions that follow:
Only the named person[s] above shall occupy the Premises or any part Of the Student Housing Prqject listed above
and no other, without Landlords prior written consent. Tenants shall indicate next to their signature on the signature
page their individual Premises number/letter Of their personal choice in the Student Housing Project.
This Lease is a binding contract between both pardes referenced. It specifies the terms of the agreement including
without limitation the rent, occupants, lease terms and obligations bet`^reen the parties. Before signing this Lease,
read it carefully so that all terms are understood.
SECTION 1 -TERM
1.
Term: Commencing on: Auaust 1. 2016 and ending on: Juiv 31. 2017 at 12:00pm NOON. If tenant[s] move in prior to the
commencement date, all terms and conditions of this agreement shall be in full force. Landlord shall use its best efforts to
put Tenant in possession of the Premises on the beginning of the Rental Agreement term. If Landlord is urrable to timely
provide the Premises, rent shall abate for the period of delay at the pro-rated rental amount. Tenant shall make no other
claim against Landlord for any such delay. No failure of Landlord to enforce any term hereof shall be deemed a waiver of
said term, nor shall any acceptance of partial payment of rent be deemed a waiver of Landlord's right to the full amount
thereof. The tenants will be held jointly and severally liable for the terms of this Agreement,
2.
Guarantors: Guarantors are supiect to Landlord approval and terms that required completion of the "Student Housing
Guaranty Agreement" addendum. Tenant(s) agree to pay an additional 10% increase of the monthly rental rate if
Landlord does not receive completed GLiarantor Application and Guaranty Agreement within ten (10) days of the
execution of this Agreement. Tenant(s) without Landlord approved Guarantors are subject to a larger deposit equivalent
to two (2) times the monthly rental amount.
3.
Surrender of Premises: Tenant agrees on the last day of the term of this Agreement by j2!fl to vacate and surrender to
Landlord the Premises. Failure to do so will result in Holdover Charges (See Section 1, #8).
4.
Multiple Tenants: Each Tenant is jointly and severally liable for all Rental Agreement obligations, including and
without limitation the payment Of rent and fees. If Tenant, any invitee or occupant violates the Rental Agreement or
rules of the SHP, all Tenants are considered to have violated the Rental Agreement. Requests and notices to any Tenant
constitute notices to all Tenants and Occupants. Notices and requests from any one Tenant shall constitute notice from all
Terrants.
5.
Early Termination: lf for any reason Tenant vacates the Premises prior to the term as agreed in the Lease Agreement or
any Extension Period, Tenant shall pay 100% of the costs to re-lease the Premises until such time that the Premises is
re-rented. Tenant shall be responsible to pay for lost rents for the remainder of the Agreement Term as they become due if
Landlord is rot able to rent to a new resident. If Landlord is not able to rent to a new resident at the same Agreement Rent,
Tenant will be respensible to pay the difference for the remainder of the Agreement Term.
6. Assignment / New Tenant Addition & Fee Terms: No potion of said Premises shall be sublet nor this agreement
assigned without Landlords prior written approval and completion of the New Tenant Addition Procedure (See New Tenant
Addition Procedure addendum). AIl violations will be subject to a fine.
a.
7.
Change in Terms and or Conditions Fee: Any change in Terms and Conditions in the Agreement shall incur a fee of
$200.00 payable by `Tenant in advance.
Renewal Of Student Housing Rental Agreement: Provided that Tenant shall not then be in default hereunder, Terrant
shall have the option to extend the term Of this Agreement for one (1) additional term upon the same terms and conditions
herein contained, except for fixed minimum monthly rental. Tenant understands that the security depesit of the original
rental agreement will rollover to the renewal rental agreement and as such, will not be refunded until the end of the
renewal term. Renewal request may be asked in writing, of the Tenant up to eight (8) months prior to the move out date.
Renewal request received within eight (8) months of the lease end date are subject to Landlord approval. Tenant will pay
to Landlord a holding fee equivalent to 2Q2fa of the monthly renewal rental rate. This fee will be nonrefundable in the event
that the Tenant fails to complete any of the fallowing:
a.
If requested by Landlord, a new rental application must be filled out by all Terrants
b.
If requested by Landlord, Tenant must provide qualified guarantors of the rental agreement
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c.
Signing of a new lease agreement by all Tenants AIl paperwork and documentation associated with the renewal
process must be properly completed and received by Landlord before the mutually agreed upon and established date
by both Tenant and Landlord as outlined in the attached Renewal Letter of Intent Addendum (RLol). If Tenant
completes the leasing process by said date, the holding fee will be considered a portion of the first month's rent for the
renewal rental term.
8.
Holdover Daiinages: Tenant agrees not to extend their occupaney in the SHP without prior written approval from Landlord.
Tenant understands and agrees that any un-authorized holdover will delay the Landlord in preparing the unit for in-coming
Tenants causing extreme hardship resulting in monetary losses to Landlord. Terrant agrees to pay, in advance $150.00 per
day as damage to Landlord for any un-authorized holdover. The terms and conditions of this Agreement shall remain in full
force except the daily rental amount during the un-authorized holdover period by Tenant.
9.
Cancellation Policy: There will be no cancellation or grace period to opt-out once the Rental Agreement is executed by
the parties.
SECTION 2 - MONTHLY RENT
10. Rent Due Date: Tenant agrees to pay Landlord in advance on the jj! calendar day of each month at the rental amount
Of $1.768.00 beginning on Auaust 1. 2016. AIl monetary obligations of Tenant to Owner under the terms of this
Rental/Lease Agreement, including but not limited to late fees, shall be deemed and referred to in this lease to be rent.
Each Tenant, if more than one (1) Tenant, agrees that they are jointly and severally lieble for the full payment of rent and
fees when due.

11. Payment: Tenant payment of rent and charges shall be paid at the office listed below during normal business hours !!
10AMPM except holidays. Payments shall be made payable to: !EQ, and sent to: 2905 S Vermont Ave #08. Los
Anaeles. CA 90007. Payments are accepted in the form of personal checks, cashier's check or money orders. Landlord
may offer electronic payments through a third-party service provider by way of ACH, debit or credit card, It is Tenant's
responsibilfty to comply with the service provider's policies that may require additional fees. Tenant is responsible for
ensuring that the rent payment arrives in good funds and on time. Late and returned payments are subject to the late
charges listed below (See Section 2, #12). Rent checks tendered from individuals or entities rot named in this Agreement,
including Co-Signers and Guarantors (if any) to this Agreement will be considered third-party checks and will rot be
accepted without Landlords prior written approval. Landlord's acceptance of a rent payment for the Premises from a
third-party shall not corrstitute a Landlord & Tenant relationship, or any other legal relationship between Landlord and any
third party. Nothing herein shall be deemed to require Landlord to accept a third-party check at any time without pnor
written approval.
12. Late Charges and Returned Checks: lf Landlord does not receive Tenant's complete rent payment PRloR T0 THE
THIRD /3rdt Of each month; Tenant agrees to pay a Late Rent Charge of Z% of the monthly rent. AII parties to this
Agreement acknowledge that damages resulting from the late payment of rent would be impracticable or extremely difficult
to fix and that this agreed amount is fair. If Tenant's rent check is returned by Tenant's bank for any reason, Tenant shall
pay Landlord SQ]QQ for the costs inourred thereon. Tenant will automatically inour the late charge provided above if
Tenant's check is returned after the third day the rent is due. If two (2) of the Tenant's checks are returned by Tenant's
bank, Landlord reserves the right to require Tenant to make future rent payments dy cashiers check or money order only.
Landlord will apply payment first to any unpaid balances and then unpaid rent (See Section 2, #13), By accepting less than
the full amount of rent due, Landlord does rot waive any other remedy provided by law, regardless of any endorsement or
statement Tenant makes in connection with the payment.
13. Applying Payments: Under Civil Code Sec. 1479, all sums received by Owner from Tenant shall first be applied to past
due rent and fees, then to ourrent amounts due.
14, Written Notations on Payment: Written notatlons by Tenant or third party on any payment due to the Landlord in
accordance with this Agreement shall be null and void, and shall not be considered by Landlord as a satisfaction, accord,
limitation or condition in accepting payment.
15. Responsibility for Utilfty Payments: Residents shall be the utilfty provider's oustomer, and are solely responsible for the
following utilities (as checked):
a Water/sewer
a Trash
uGas
a Electricity
Tenant agrees to establish the utility services checked above in their own name(s) at least three (3) days before the
commencement of the Term. Terrant understands that falling to do so could result in any interruption of such utilfty
services. Tenant releases Landlord from any obligation to provide any Of the utilfty services checked above. Furthermore,
Tenant agrees to reimburse Landlord for any bills paid by Landlord for utilfty services checked above that have been
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provided to the Premises after the start of the Agreement Term.

a.
Internet / Video Service: If Internet and or Video service is provided to the Tenant(s) it is provided free of charge and
as a courtesy to the Tenant. AIl service related matters are to be directed to the Internet/ Video Service provider.
Tenant agrees to the terms and conditions of the Internet Use Poliey Addendum referred to as, "Internet and Video
Use Policy A". Internet and or Video services where applicable, are provided as a courtesy and shall not be
considered as part of monthly rent.
b.
Internet / Video Service lvlodems: Tenant is responsible for the condition of the modems for services provided as a
courtesy. Tenants will be held financially responsible for damaged and missing modems and accessories such as but
not limited to remotes and cables. In addition to replacement costs, tenants will be charged a $300.00 processing fee
upon move out.
16. Default by Tenant: ln the event of a default made by Tenant in the payment of rent when due to Landlord, Tenant shall
have three (3) days after receipt of written notice thereof to cure such default. In the event of a default made by Tenant in
any of the other covenants or conditions to be kept, observed and performed by Tenant its guests and invitees, Tenant
shall have three (3) days after receipt of written notice thereof to cure such default. In the event that the Tenant shall fail to
cure any default within the time allowed under this paragraph or Tenant or Tenants invitee caused an incurable breech of
this Agreement, Landlord may declare the term of this Lease ended and terminated by giving Tenant written notice of such
intention. If possession of the Premises is not surrendered, Landlord may reenter said premises. Landlord shall have, In
addition to the remedy above provided, any other right or remedy available to Landlord on account of any Tenant default,
either in law or equity. Landlord shall use reasonable efforts to mitigate its damages.
SECTION 3 -SECURITY DEPOSIT
17. Security Deposit: Tenant shall deposit with Landlord, as a security deposit, the sum of $500.00. The Security Deposit
shall not be deemed rent, or any portion thereof, for any rental month. Landlord will inform tenant with at least 24-hour
notice and 2 weeks prior to the ending date of the Agreement, of the complete inspection details of the premises for the
purpose of the Landlord to notify the Tenant of any obvious deductions for cleaning and repairs. The Tenant shall then
have the right to use a licensed and bonded person to put the unit back in the same condition as it was prior to Tenant
occupying the Premises, less normal wear and tear. Landlord shall make a final inspection of the Premises after the
Tenant has vacated the Premises of all persons and personal property. Landlord in compliance with California Civil Code
Sec. 1950.5 and local laws, will not hold the Security Deposit in trust or in an interest-bearing account, segregate the
Security Deposit, or pay Tenant any interest on the Security Deposit, unless otherwise required by law. Any Security
Deposit discrepancies must be provided in writing to the Landlord within fourteen (14) days upon receipt. Discrepancles
received after fourteen (14) days will be null and void.
18. Condition of Premises / Alterations / Damage / Repairs: Unless otherwise stated in this agreement, it is the
representation of both the Tenant and Landlord that the Premises has been inspected prior to Tenant taking possession
and agreed that the Premises is thoroughly clean, freshly painted, free of holes in any walls, carpets are either new or
recently shampooed and in good condition (without holes), drapery/blinds are clean, in good condition (without holes) and
functioning properly; all appliances (if any) are in good working order, all electrical, plumbing, and heating systems are
functioning properly and in good working order. Any attached, glued, painted improvements to the Premises (whether or
not Landlord has consented) will become Landlord's property - unless Landlord agrees in writing otherwise. Tenant shall
not place/install any "air conditioners" of any kind, through any window, door openings or any place in or about the
Premises or the SHP without Landlords prior written approval. Any violation is subject to a fine. Tenant shall be held fully
responsible for the costs of clearing any plumbing stoppages caused in the Premises due to Tenant or Tenants invitees as
well as (but not limited to) stoppages due to hair or foreign matter. Additionally, Tenant shall be responsible for the cost of
service calls/repairing appliances within the Premises, when the repair technician determines that the Tenant and or
Tenant invitees directly caused the problem. It is the responsibility of Tenant to provide access to the Premises at all
reasonable times in order for repairs to be made. During Tenant occupaney of the premises, any damage (other than
normal wear and tear) detected and repaired on the premises or common area shall be paid by Tenant to the Landlord
upon fifteen (15) days written notice of work performed and the amount due. If locks are changed by tenant without written
pre-approval from landlord, the tenant will be subject to a fine.
19. Security Deposit Refunds and Deductions: Landlord will deduct the amount necessaiy to compensate Landlord for
cleaning (the cleaning of the premises upon termination of the tenaney necessary to return the unit to the same level of
cleanliness it was in at the inception of the tenancy), damage to the premises, or unpaid rent and fees will be deducted
from the Security Deposit. Tenant agrees to pay to Landlord within ten (10) days of notification of any deficiency, as
outlined above, not covered by the Security Deposit. In the event that any part of the Security Deposit is used during the
Term of the lease, Tenant must restore the Security Deposit to its full amount within three (3) days after Landlords written
notification to Tenant of the deduction and a demand that the Security Deposit be restored in full.
a.
Tenant is responsible for maintaining the Premises in a clean, safe and damage free condition.
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b. When Tenant gives notice to vacate the Premises, Tenant agrees to inform Landlord of Tenant's forwarding address,
which will allow prompt delivery of Tenant's Security Deposit. If Tenant does not provide a forwarding address, then
Landlord shall mail the security deposit to the address of the subject Premises.
c.
Tenant's occupancy of the Premises is considered terminated when Landlord receives all of the Premises' keys and all
of Tenant's personal property is removed. Until both conditions are met, Rent will continue to be assed to Tenant.
Tenant agrees that any and all personal property of Tenant remaining on SHP property after term of this Agreement
ends or any earlier termination shall be considered abandoned by Tenant and hereby authorizes Landlord to dispose
of such Tenant Abandoned Property without further notice. Tenant understands that all keys or entry devices issued to
Tenant must be returned upon move-out. There is a minimum charge of $25 per apartment key, $50 per electronic
apartment key, $15 per mailbox key, $50 per garage remote, $25 per common area key and $25 per parking
registration not returned during move-out. Keys not returned by 12:Oopm NOON to the Landlord office on above
referenced term end date will be charged a $150.00 processing fee.
d.
Tenant will not be charged for "ordinary wear and tear" in the Premises, which is defined as "the deterioration of any
item resulting from its ordinary use by persons who exercise reasonable care in maintaining the apartment in a safe
and sanitary manner".
i.
If Tenant lived in the Premises for at least twenty-four (24) months before moving out, painting within "normal wear
and tear" conditions, is included at no charge. Otherwise, if painting is necessary and not due to ordinary wear and
tear, painting costs will be charged. Painting charges are for only one (1) coat of paint; additional necessary coats
have additional charges.
PAINTING PRO-RATE BREAKDOWN
UNIT TYPE
0 - 6 MONTHS
7 -12 MONTHS
13 - 24 MONTHS
25 MONTHS +
ALL
FULL COST
2/3 COST
1/3 COST
N0 DEDUCTIONSOTHERTHANDAMAGES
ii.
If Tenant lived in the Premises for at least sixty (60) months before moving out, flooring material within "normal
wear and tear" conditions is included at no charge, Otherwise, if repairs or replacements are necessary and not
due to ordinary wear and tear, flooring material will be charges. Carpet cleaning charges for stain / spot removal
will result in additional charges.
FLOORING IVIATERIAL REPLACEMENT
UNIT TYPE
0-12 MONTHS
13~24 MONTHS
25-36 MONTHS
3748 MONTHS
49JsO MONTHS
ALL
100%
80%
60%
40%
20%
iii. Any part of the Premises that has been damaged, burned, discolored, odorized or otherwise affected by
smoking in or on the Premises is NOT considered normal \^rear and tear. The cost to repair, replace and/or
deodorized the Premises will be charged at 100% of the repair costs to the Tenant.
20. Common area charge: ln the event that the Tenants shares a Common Area, Landlord may deduct from each Tenants
Security Deposit in the Student Housing Project 100% (each Tenant in the SHP is responsible for an equal amount of the
charge) of the repair cost to put the common area back in the same condition as it was at the inception of the tenancy, less
normal wear and tear.
21. Common Area Definition: Common Areas include but are not limited to laundry rooms, kitchens, bathrooms, hallways,
and all other jointly used spaces for the common use of Tenants, Tenants guests and invitees on the Student Housing
Project. All Tenants of the SHP are jointly and severally responsible for the condition and upkeep of the common areas.
22. Damages: All persons signing this Agreement as Tenants are jointly and severally liable for all rent under this Rental
Agreement and for all damages to the Premises and Common Areas used or permitted by Tenants and their guests and
invites.
23. Early Termination: ln the event that Tenant vacates the SHP prior to the end of the term of this Agreement, Landlord shall
notice the remaining Tenants of the time Landlord will examine the SHP common areas for necessary repairs above
normal wear and tear, giving the Tenants two (2) weeks to complete any required repairs in a workman like manner.
Landlord shall make a final inspection of the common areas and complete any repairs to return the Premises to the same
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level of repair and cleanliness it was prior to occupancy by Tenants. Tenant vacating early shall have their portion of the
expense deducted, along with any other deductions from Tenants security deposit. The remaining Tenants agree to pay
Landlord within 15 days of receiving a statement indicating the work performed in the common areas and the percentage
of amount due.
SECTloN 4 - MAINTENANCE
24. Emergency Maintenance Requests: Emergency maintenance requests should be made immediately, without delay
through the provided twenty-four (24) hour maintenance phone number: (877` 838-1927. Failure to report emergency
maintenance issues will result in the responsibilfty of the tenant for the cost of repairs. Request made to the emergency
maintenance lines that are deemed nonremergeney will result in a $50 fine.
25. Reasonable Care of Property and Common Areas: Terrant must take reasonable care of the rented property and
common areas. California Civil Cede section 1941.2 requires the tenant to do all of the following:
a.
Keep the premises "as clean and sanitary as the condition of the premises permits."
b.
Use and operate gas, electrical and plumbing fixtures property. (Examples of improper use include overloading
electrical outlets, flushing large, foreign objects down the toilet, and allowing any gas, electrical or plumbing fixture to
become filthy.)
c.
Dispose of trash and garbage in a clean and sanitary manner.
d. Not destroy, damage, or deface the premises, or allow anyone else to do so.
e.
Not remove any part of the structure, dwelling unit, facilities, equipment or appurfenances, or allow anyone else to do
sO.
f.
Use the premises as a place to live, and use the rcoms for their proper purposes. For example, the bedrcom must be
used as a bedroom and not as a kitchen.
9.
Notify the landlord when deadbolt and window locks or security devices do not operate property. Tenant is responsible
for the replacement of light bulbs and batteries.
26. Gross Negligence: Tenant will be held financially responsible for maintenance requests resulting in gross negllgence on
behalf of the tenant and/or their guests and invitees.
27. Significant Maintenance: lf significant maintenance and or repairs NOT resulting from gross negligence on the part of the
Tenant, which could include but not limited to, fumigation, pest control, repainting the premises requires Tenant to remaln
out of the premises, Tenant agrees to vacate the Premises for the necessary time to accomplish the significant
maintenance and repeirs and shall comply with all written instructions from the fumigator/pest controller or person in
charge of the task, regarding preparation of the premises for the work to be done on or at the Premises. Landlord will credit
from the next month's rent due an amount equal and not to exceed the daily rental rate of the Premises multiplied by the
number of days Tenant did not have use of the Premises.
28. Default by Landlord: Landlord shall not be in default of this Agreement unless Landlord fails to perform obligations
required of Landlord within a reasonable time, but in ro event less than 30 days written notice by Tenant to Landlord
specifying the repairs Landlord has failed to perform; provided, however, that if the nature of Landlord's obligation is such
that more than 30 days are required for repairs, then Landlord shall not be in default if Landlord commences performance
within such 30 day period and diligently prosecutes same to completion; however if Landlord receives oral or written notice
of a problem and Landlord determines such problem is an emergeney, Landlord shall act as soon as reasonable possible
fdilowing notice by Tenant.
29. Alterations and Repairs: Tenant must not make any alternations or improvements to the Premises such as paint, wall
coverings, removing or installing walls or floors, and built+n shelving. Repair and maintenance costs shall be born as
follows.
a.
By Landlord: lf the condition requiring repair is one that makes the Premises 'tenantable" as defined in California Civil
Code Section 1941.1, then Landlord shall bear the expense of the repair.
b.
By Tenant(s): Tenant will be required to bear the expense of the repair if an 'tenantable" condition is caused by the
tenants (1) lack of ordinary care; (2) failure to keep the Premises reasonably clean and sanitary; (3) failure to properly
operate and clean appliances and plumbing fixtures; (4) destruction, impairment or removal of any part of the Premises
or Property; (5) use of the Premises other than as a residence or use of the living, sleeping, cooking or dining areas for
a use other than which they were designed or intended. If the condition requiring repair does NOT make the Premises
'tenantable" or is NOT due to ordinary wear and tear, then that tenant shall bear the repair expenses. Tenant is
responsible for the replacement of lights bulbs and batteries.
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SECTioN 5 - iNspECTioN & srovviNGs

30. Right Of Entry: Upon written notice of at least twenty-four (24) hours, Landlord may enter the Premises at any reasonable
time to make repairs, perform maintenance or renovations that Landlord deem necessary, or to show the Premises to
prospective purchasers, lenders or tenants. Landlord may enter the unit at any time without notice in the event of an
emergency that threatens life or property. Tenant agrees rot to add nor change any locks on the premises without
Landlords prior written approval. nor otherwise restrict entrances.
31. Early Showing during Occupaney: Landlord reserves the right to show Tenant units in the SHP to incoming Student
Tenants during the hours of lvlonday -Saturday loam -6pm, with proper advance notice to Tenant.
SECTION 6 - SECURITY & INSURANCE
32. Tenant / SHP Security: Landlord does not provide security for SHP or Tenants, nor should any action by Landlord be
considered as providing security for Tenant or SHP.
33. SHP NonResponsibilfty: SHP Landlord] Owner or its Agents assumes no responsibjlfty for the care or protection of any
of Tenant, Tenant's lnvitees. personal property while it is on any part of SHP property. Thefts or damages that occur
should be immediately reported to the Los Angeles Police Department and USC Police Department.
34. Entry to SHP and Installed Bars on Windows: Tenant acknowledges that gated or keyed points of entry to the SHP (if
applicable) and Security Bars (if applicable) are a courtesy to the Tenant and are rot to be construed as "Security Gates"
or "Security Bars" and are subject to vandalism, failure and/or malfunction (as well as repair delays), for which Landlord
nor Owner of SHP shall not be held responsible nor liable. Landlord nor Owner of SHP is not liable for any demage or loss
from any cause whatsoever, including but not limited to crimjmal acts of others, to the persorral property of any kind kept by
Tenant or Tenant's invitees about the Premises during the term of this Agreement or any extension thereof. Tenant agrees
to hold Landlord and Owner of SHP harmless from any and all liabilrty, loss, cost or obligation on account of demage to or
loss of Tenant's or Tenant's guests and invitee's personal property, regardless of the cause.
35. Security Bars: Tenant shall not install Security Bars to any windows or openings on Premises or anywhere in or about the
SHP without Landlords prior written approval. Tenant shall only install Security Bars as described above using a licensed
trade-person as required from the Crty of Los Angeles.
36. Bike Racks: Tenant acknowledges that bike racks (if applicable) are provided as a courtesy to the Tenant and are not to
be construed as "secured" areas for bike placement and are subject to vandalism, failure and theft. Tenant uses at their
own risks for which Landlord nor Owner of SHP shall be held responsible or liable for any damage or loss of property
regardless of the cause.
37. Landlord Notice Of Non Responsibilfty: SHP Landlord, owner or its agents assumes ro respensibilfty for the care or
protection of any vehicle or its content while it is on SHP property. Valuables should not be left in parked vehicles at any
time. Vehicles should be locked with no personal items visible when not in use. Thefts or damages that occur should be
immediately reported to the Los Angeles Police Department and USC Police Department.
38. Landlord/SHP Insurance: Tenant agrees and acknowledges that any property or liability insurance coverage purchased
by the Landlord or SHP Owner is not intended to and will rot protect against any loss or damage (i.e., burglary, vandalism,
fire, smoke, water, mildew, mold, act of God, or any other perils) to personal property or belongings or protect against any
loss or damage resulting from Tenants or Tenants invitees actions or omissions. Tenant also understand that, by not
having renter or personal liability insurance of their own, Tenant could be liable to third pahies and to the property Landlord
for certain losses and understands that Tenant should not expect the property Landlord or Owner of SHP to be responsible
for such losses. Tenant agrees and acknowledges that Landlord or Owner of SHP does not maintain insurance coverage
for "Personal Property" of Tenants in or about the Premises or anywhere on the SHP. "Personal Property" includes, but is
rot limited to vehicles and all contents inside, furniture and furnishings, appliances, electronic equipment, stereo and
computer equipment, clothing, jewelry, books, and all other property and things owned or belonging to Tenant, their family,
invites and all others. Insuring personal property is the responsibilfty of Tenant (not the Landlord or SHP Owner). Landlord
recommends that Tenant purchase insurance to protect their personal property.
39. Renters Insurance Coverage:

a I Alec H. PhilliDs and Kieran S. Stolorz HAVE RENTERS INSURANCE COVERAGE. I have and will maintain
through the term of my Rental Agreement the following coverage:
Insurance Company:
Policy Number:
property Limit: an
Liability Limit: an
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I I Alec H. PhilliDs and Kieran S. Stolorz DO NOT HAVE RENTERS INSURANCE COVERAGE. Although I, the
Tenant recognise my need for renters insurance, I will not at this time, be obtaining such insurance coverage and
understand that I will be personally responsible for any property or liability damage to the property of the Landlord's,
Landlord's, or third party's property as a result of my or guest`s/invites actions.
SECTION 7 - CONDUCT, RULES & REGULATION
40. Premises Rules/Regulations: Tenant agrees that they and those occupying said Premises with them (including invites),
shall abide by all reasonable rules and regulations that Landlord may post from time to time for the protection, good order,
safety and cleanliness of the Premises and SHP. Vlolation of any of these rules and regulations may result in the
termination of Tenants tenaney.
41. Garbage: Tenant agrees to dispose of all household trash in the containers/dumpsters that are provided on-site. Tenant
must rot place garbage outside of their Premises for any period of time. If garbage is found outside of the Premises,
Landlord will immediately remove without notice and charge the Tenant a fine of $25 per occurrence. If garbage is found in
common area of the SHP, all terrants will be held financially liable and responsible.
42. Parking: Tenant shall only park in a parking space assigned by Landlord on SHP property. Tenant shall rot, nor allow
invitees to wash or conduct any repairs, in any space or place on SHP property. Vlolation of this provision is grounds for
eviction. Landlord's election to not institute eviction proceedings upon any such occurrence shall not limit Landlords abilfty
to de so upen any such other occurrence in the future. Tenant shall rot assign nor sublet any such parking space.
Landlord may have umapproved vehicles towed away at Tenants expense. Tenant shall not park any vehicle that is not in
good running condition or not ourrentry licensed or registered in their assigned space or anywhere on the property of the
SHP property. Tenants shall not place or store any personal property (belonging to Tenant or to others) other than their
vehicle in Tenant assigned parking area. If Tenant has a car alarm, Tenant is responsible to ensure that the car alarm
does not activate unnecessarily. If a car owner cannot be contacted to disable the car alarm; the car will be to\ved at the
car owner's expense. Terrant shall provide Landlord with the license number, make and model for the vehicle, if a parking
space has been assigned, that they plan on parking in the assigned space only. Parking registration stickers must be
displayed and visible at all times while parking on SHP property. Failure to do so will result in immediate removal of the
vehicle at the Landlord's discretion without waning.
43. Placement Of Tenant Personal Property: Tenant shall not place any items of personal property outside of the Premises
or in any common areas, nor place any items (other than table and chairs specifically designed for outdoor use) in or on
Tenants personal balcony/patio area (if any). Any violation is subject to a fine.
44. Decks / Patios: Patios / Decks (if any) must remain neat and orderly. Only all weather manufactured furniture in good
condition are permitted. AII furniture and or decorations are sutyect to Landlord approval. No signs or other personal
property may be placed outside the Premises on the railings, patios, walls or fences or placed within the Premises so that
the item is visible from the outside.
45. cleanliness: Cleaning of carpets and window coverings during the tenaney is the Tenants responsibility. Tenant must use
products and systems designed for such cleaning. Window coverings damaged through cleaning are the tenent's
responsibility. Window screens must be left on all windows at all times.
46. Pictures: Pictures and mirrors may be hung with nailed picture hcoks. Gluing items to surfaces is rot permitted. Terrant
will be charged for holes left in the wall larger than that of a picture nail hook.
47. Garbage Disposals: Garbage disposal units, if provided, are only for the disposal of small amounts of food materials that
can be easily ground up. The disposal unit js to be operated only with the water running. Never pour grease or lard down
the sink. Misuse of the garbage disposal and required repeated service will require payment from the Tenant for the
maintenance requests.
48. Roofs: Tenants are not allo\^red to climb or walk on the rcof: violators are subject to immediate eviction.
49. No Smoking: Smoking is prchibited on all SCP properties. Any violation is subject to a fine.
50. Pests: Pest or insect issues must be immediately reported to the Landlord. If it is determined that all or part of the
Premises requires pest control service for hearth or public benefit, then Tenant will be notified at least twenty-four (24)
hours in advance. If the pest issues are found to be a result of neglisence on the part of the Tenant, Tenant will be held
liable for the treatment of the premises and treatment of the property where deemed necessary by a professional pest
Control Company.
51. Pets: No pets, birds, fish, nor any animal are allowed (even temporarily) anywhere in Tenant's apartment unit or on the
Property, except as medically necessary for Tenant assistance, without prior written consent from Landlord. Proof of pets
deemed medically necessary is required. Landlord, with PRIOR LANDLORD WRITTEN APPROVAL TO TENANT, may
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allow Tenant one spayed or neutered ourrently licensed animal ITenant shall provide Landlord proof that animal has been
spayed, neutered and ourrently licensed) in Tenant Premises and not in common areas of the SHP, PROVIDED THE
ANIMAL IS NOT one (1) of the following breeds or any part thereof of the following breeds: CHIHUAHUAS, CHOW
CHOW, COCKER SPANIEL, DACHSHUND, GIANT SCHNAUZER, JACK RUSSELL TERRIER, LLASA APSO,
MINIATURE PINSCHER, OLD ENGLISH SHEEPDOG, PEKINGESE, ROTTWEILER, STAFFORDSHIRE BULL
TERRIER, PAPILLON, TOY POODLE, OR ANY BREED OF BULL TERRIER. If a permissible pet becomes a nulsance
by, without limitation to: biting, barking or othewise interfering with other Tenants peaceful enjoyment of the SHP,
Tenant shall within twenty-four (24) hours after receiving written notice from Landlord remove the animal from the
Premises and SHP, otherwise Tenant will be in default and will be deemed to be in an inourable breach of this Agreement.
If a Terrant's or Tenant's invitees pet (animal) has been in or about the Premises and or the common area of the SHP
during Tenants term of occupaney with or without Landlords consent, Tenant shall pay Landlord the cost for de-fleaing,
deodorizing and/or shampooing the Premises to protect Tenants and invitees from possible health hazards in addition to
the damages caused by animal(s). Tenant shall not request for approval any animal that will weigh more than fifteen (15)
pounds as an adult animal. If any approved animal reaches suteen (16) peunds or more, Tenant shall remove the said
animal from the Premises and SHP within t\venty-four (24) hours of written notification from Landlord, otherwise Tenant will
be in default and in an incurable breach of this Agreement. An additional Security Deposit of $500.00 will become part of
the Security Deposit in Section 3 of this Agreement. Tenant agrees to furnish Landlord a picture of the pet, as allowed in
this Agreement, prior to allowing the animal on or in any pert of the SHP. Tenant further agrees: (1) to clean up after their
pet and to dispose of pet's waste properly and immediately; (2) to leave food or water for their pet inside their premises
only and rrot in any common areas, including anywhere in or upon the SHP grounds; (3) that Tenant will not tether (secure
with any object to the animal) to any place or thing in or on the SHP grounds, Any violation is subject to a fine.
52. Quiet Enjoyment: Tenant shall not commit or allow to be committed any noise upon the Premises or upon the common
areas or any nuisance or other act including amplifcation of sounds, which may disturb the quiet enjoyment of any other
Tenants on the property. Established quiet hours are from jQpm to Lam. Any violation is subject to a fine.
53. Guests/lnvitees: Tenant acknowledges that Tenant is allo\ved 2 guests overnight guest to stay on the Premlses no more
than j4 nights during any 6-month period. Tenants are held accountable for the conduct of their guests and invitees at all
times.
54. Prohibited Items: Tenant agrees not to possess anywhere on SHP property: fireworks, firearms, explosives, flammable
materials, hazardous materials, open flame cooking units, barbecues, or charcoal briquettes.
5i. Lockout Policy: If Tenant is locked out of premises during normal bLisiness hours MIF 10AM6PM except
holidays, Tenant may check out a key from our Ivlanagement Office located at 2905 S Vermont Ave #208. Los
Anaele. CA. 90007. For after hour lock outs, Tenant must contact a locksmith and directly pay all applicable fees.
56. Rules for All Recreational Areas (Where Applicable): Tenant uses recreational areas at their own risk and releases
SHP Landlord, Owner(s) and its agents of all responsibility.
57. Crime/Drug+roe Housing

a.
Tenant, any member of Tenant's household or guests shall not engage in criminal activrty, including drug-related
criminal activity, on or near the Premises or Property. "Drug-related criminal activity" ineans the illegal manufacture,
sale, distribution, use or possession with the intent to manufacture, sell, distribute, or use of a controlled substance (as
defined in Section 102 of the Controlled Substance Act (21 U.S.C. 802)).
b. Tenant, any member of Tenant's household or guests shall not engage in any act intended to facilitate criminal activity,
including drug-related criminal activfty, on or near the Premises or Property,
c.
Terrant, any member of Tenant's household or guests shall not engage in any act of violence or threats of violence,
including, but ro limited to, the unla\^rful discharge of firearms, on or near the Premises or Property.
d. Any Vlolations Of these crime/Drug free provisions shall be considered a material, nonurable breach Of the
lease and deemed good cause from an eviction due to public or private nuisance, and shall result in a 3-day
notice to quit being served immediately.
58. Laws: Tenant shall rot violate any law in the use of the Premises, commit any waste or nuisance, annoy, molest, or
interfere with any other Tenant or neighbor. Tenant shall comply with all statutes, ordinances and requirements Of
municipal, state, and federal authorities now in force or which may hereafter be in force, pertaining to the use of the
Premises and in or about the SHP. Any violation is subject to a fine.
SECTION 8 - DISCLOSURES & NOTICES
59. Mildew, Mold Notification: Mildew and Mold come in many varieties. It can be unsightly and may or may not be harmful
to the health of individuals, depending on the type and concentration on each individual's sensitivity thereto. Mold spores
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are ever present in the air and on all surfaces of all objects. Cleanliness, proper ventilation and dry conditions are required
to prevent the mold spores from sprouting and growing. Tenant acknowledges that a visual inspection of the Premises has
taken place and it is represented that Landlord knows of no wet or damp building materials, or of any mildew or mold
contamination. Tenant has also inspected the Premises and has found no visible evidence or smells that would indicate
mildew or mold at this time. Tenant acknowledges that Landlord and property Owner are not responsible for mildew or
mold caused by humid weather, lack of keeping closets, bathrooms, kitchens, etc. well ventilated, or by poor housekeeping
by Tenant. It is agreed by Tenant that the obligation to care for the Premises and to prevent mildew and or mold is the
Tenants. Specifically, Tenant agrees to keep the Premises free of dirt and debris that can harbor mildew and mold; to use
bathroom exhaust fans when showering or bathing; to use kitchen exhaust fans when cooking, baking and dishwashing; to
notify Landlord immediately in writing of all water drips and leaks immediately upon detection; and to keep the interior of
the Premises protected from external damp or wet conditions; to keep walls, floors and windowsill areas wiped dry. In
addition, Tenant agrees to promptly inform Landlord of any incidents of mildew or mold growth, or of water intrusion such
as flcods; plumbing leaks, drips, or sweating pipes; rain or other weather leaks; laundry or sewer leaks, or backups: roof
leaks, or leaks from appliances such as air conditioners, heaters, or dishwashers. Tenant shall thereafter cooperate with
Landlord in assuring that proper measures have been taken, or are taken to properly remedy growth of mildew, mold or the
water or moisture intrusion, including, but not limited to appropriate access to the Premises by Landlord and
tradespersons. Breaches by Tenant of the provisions contained herein are deemed as waste and subject to immediate
eviction upon three days. notice or such other minimum notice as provided by law. Landlord nor Owner of SHP shall not be
liable for any active or passive negligence of itself, its agents, employees, assigns, or representatives in regards to the
presence of mildew or mold, it specifically being understood that this waiver of the active and passive negligence on the
part of the Landlord is a specifically bargained for provision between Landlord and Tenant. Tenant agrees to indemnify and
hold, Owner of SHP, Landlord and Landlord's agents, employees, assigns, and representatives harmless for any damage,
injury, or loss resulting from any act (or failure to act) of Tenant in breaching the provision hereof or from any act (or failure
to act) of Landlord, or Landlord's agents, employees, assigns, and representatives in enforcing the provisions hereof. The
entirety of the costs to remedy mildew and mold contamination due to Tenant's breach hereof may be taken from the
security deposit without allowance or setoff for normal wear and tear. Mildew and Mold are not normal wear and tear. Any
violation is subject to a fine.
a.
"Tip Sheet on Mold" is included as an addendum to this Lease. It lists requirements and advice to retard or prevent
mold and mildew from accumulation in the Premises. You are responsible for damage to the Premises and your
personal property, as well as injury to you or your guests that results from your failure to comply with the requirements
and advice that are in the "Tip Sheet on Mold".
60. Lead Warning Statement, if premises were built before 1978 landlord's disclosure:
a Landlord has no knowledge of lead-based paint and/or lead-based hazards in the premises. Landlord has no reports
or records pertaining to lead-based paint and/or lead based paint hazards in the premlses.
I Landlord has knowledge of lead-based paint and/or lead based paint hazards that are present in the premises and
has provided the Tenant with all available records and reports pertaining to lead-based paint and/or lead based paint
hazards in the premises.
The following documents have been provided: Landlord and Tenant(s) have carefully read and reviewed this Rental
Agreement and by the execution of this Rental Agreement show their informed and voluntary consent thereto.
61. Disclosure Regarding Asbestos

a. Asbestos warning statement (if checked)
I This Property was built before 1981. Construction techniques before 1981 may have involved the uses of
asbestos-containing materials.
b.
Disclosure (if checked)
a Landlord has no knowledge of asbestos hazards at the Premises or Property

I Landlord is aware of asbestos hazards at the Premises or Property in the following areas: See sections 8,d and
8,e
c.
Records (if checked)

EI Landlord has no reports or records pertaining to asbestos hazards at the Premises or Property.
I Landlord has available records and reports pertaining to asbestos hazards at the Premises or Property. Copies
are available at the management office for review and/or copying.
d.
If asbestos hazards are contained in the ceilings, then Tenant and Tenant.s guests, employees and contractors shall
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rot take or permit any action that in any way demages or disturbs the ceiling or any part thereof, including without
limitation: (1) piercing the surface of the ceiling by drilling or any other method; (2) hanging plants, mobiles, or other
objects from the ceiling; (3) attaching any fixtures to the ceiling; (4) allowing any objects to come in contact with the
ceiling; (5) permitting water or any liquid, other than ordinary steam condensation, to come into contact with the ceiling;
(6) painting, cleaning, or undertaking any repairs of any portion of the ceiling; (7) replacing light fixtures, or; (8)
undertaking any activity that results in building vibration that way cause damage to the ceiling.
e.
Tenant must notify Landlord immediately in writing (1) if there is any damage to or deterioration of the ceiling or any
portion thereof, including without limitation flaking, lose, cracking, hanging or dislodged material, water leaks, or stains
in the ceiling, or (2) upon the occurrence of any of the events described in section 8.3.4..
62. Registered Sex Offenders Notice: Pursuant to Section 290.46 of the Penal Code, information about specified registered
sex offenders is made available to the public via an lntemet Web site maintained by the Department of Justice at
www.meganslaw.ca.gov. Depending on an offenders criminal history, this information will include either the address at
which the offender resides or the communfty or residence and ZIP Code in which they reside.
63. Smoke Detectors: The Premises is equipped with at least one (1) smoke alarm. Tenant agrees to be responsible for
testing all smcke alarms every month whether battery operated or hard-wired by pressing the "Push To Test" button on the
detector for about five (5) seconds until the alarm sounds. If there is no sound, Tenant agrees to immediately and without
delay inform the Landlord.
64. Indemnification: Tenant shall indemnify, protect, defend and hold Landlord, SHP Owner, its agents, employees, lenders
and ground lessor, if any, harmless from and against any and all loss and/or damages, costs, claims, liens, expenses, acts
of God, arising out of or concerning Tenant's use of the premises, or from any other activity, act of God, work or things
permitted or suffered by Tenant or invitees in or about the Premises. Tenant hereby assumes all risk of damage to
personal property of Tenant and their guests and invitees as well as injury to persons, in, upon or about the Premises
arising from any cause and Tenant hereby waives all claims in respect thereof against Landlord, and SHP Owner.
65. Attorney Fees: lf any legal action or proceedings are brought by either party to enforce any part of this Agreement, the
prevailing party shall recover, in addition to all other relief, reasonable attorney fees and costs Of litigation.
66. Delays by Either Party to Agreement: ln the event that either party shall be delayed or hindered in or prevented from the
performance of any act required under this Agreement, failure of power, regulations, weather, or a similar nature not the
fault of the party delayed in performing repairs or acts under the Terms and conditions of this Agreement, then
performance of such act shall be exoused for the peried of the delay, and the clock shall be stopped for that peried of
delay. The provisions of this section shall net exouse Tenant from prompt payment Of rent or other amounts due Landlord
under this Agreement.
67. Waiver: Failure of either party to this Agreement to exercise any power or right shall not constitute a waiver of that right.
68. Severance: lf any provision of this Agreement is invalid under the laws of any jurisdiction, this Agreement will be
construed as if it did rot contain that provision.
69. Addendums: The following Addendums are attached to this Lease and incorporated herein by reference:
a Thirty (30) Day Notice
Rental Agreement Addendum
a Internet and video poliey
a student Housing Guaranty Agreement
a pet Addendum
n Tip sheet on Mold
70. Entire Agreement: This Rental Agreement and the Addende's hereto constitute the entire agreement between the parties.
There are no oral or written representations or agreements made by Tenant or Landlord that supersede or modify this
Agreement. In the event any provision of this Agreement shall be deemed illegal or unenforceable, it shall not void this
contract, or any provision thereof. The balance of the terms and conditions herein shall remain in full force and effect. Any
violation to the lease agreement is subject to a fine.
71. Receipt Of Agreement: By signing below, it is understood that the Tenant has read and understands this Agreement and
hereby acknowledges receipt of a copy of this Agreement.
72. Counterparts, Fax and Electronic Signature Disclosure: Tenant further acknowledges and agrees that Tenant's fax
and/or electronic signature is to have the same binding and legal effect as a physical ''pen and paper" signature. This
Agreement may be executed in counterpart, each which will be a valid and binding original, but all together will constitute
one and the same instrument. Landlord may rely on a faxed or electronic copy of this Agreement as if it was the original.
IN WITNESS WHEREOF, the pahies have executed this Agreement at Los Anaeles. CA
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Signed by Alec H. PhillipEi
Signed by Kieran S. Stolorz
Wed Feb 2410:36:57 AM PST 2016

Key: C311259C; IP Address: 68.170.78.79
Wed
Key:
Date
Alec H. Phillips /Res/.dent/
Sat Feb 27 05:55:33 PM PST 2016

Key: B0FD586F; IP Address: 172.250.120.115
Date
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48413E63,. IP Address: 68.170.78.79
Kieran S. Stolorz /Resi.denf/
Signed by U. M. Bhakta
U. M. Bhakta /Agenwanager/
Feb
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THIRTY (30) DAY NOTICE

TENANT`S INTENT TO VACATE
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TO: Stuho lnc.
You are hereby given notice that ltwe Alec H. Philljos and Kieran S. Sto]orz rtenant") intend to terminate the tenaney and to
move from the premises known as:
2595 Hcover St rsl8. Los Anaeles. CA 90007, as of July 31. 2017.

1.
It is understood as follows:
a.
b.
that this notice is required by Section 1948 of the Califomia Civil Code;
except as provided by law or the lease agreement, rent shall be due and payable to and including the date of
termination;
c.
early terminations require written confirmation from the Manager and are subject to provisions of the lease agreement;
and
d. any extension of the move-out date must be confirmed in writing from the Manager and subject to a service fee.
2.
The unit will be acknowledged as vacant after the tenant.s possessions are removed from the unit, at which point the
tenant will notify the property's manager and return the keys.
3.
4.
Inspection of the vacated unit and move-out processing require a minimum of 21 days before the rental deposit accounting
or any refund portion thereof can be returned to the tenant.
YOU ARE HEREBY NOTIFIED THAT the tenaney under which we the tenants and all other occupants that occupy the
premlses, shall end 30 days after the date of service of a copy of this notice upon you or your representative, or July 31.
2QZ which ever is the latest date, and we will deliver up possession of the premises to you or your representative, on or
before that date.
We the undersigned state that we will also remove all persons, personal property, and leave the premises in broom clean
condition.
We the undersigned state that any left personal property after the end of lease termination will be donated to the management
company.
Forwarding Address: TBD bv Tenant
Signed by Alec H. Phillips
Signed by Kierali S. Stolorz
Wed Feb 2410:37:21 AM PST 2016

Key: C311259C,. IP Address: 68.170.78.79
Wed
Alec H. Phillips (Resi'denf/
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Feb
2412:05:34 PM PST 2016

48413E63,. IP Address: 68.170.78.79
Kieran s. Stolorz /Res;.dent/
13
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INTERNET AND VIDEO USE POLICY A

The internet provider of access for Stuho lnc. and other Internet-related services, enables residents at Stuho lnc. and others
using the Stuho lnc. account to receive and send a great amount of public, private, commercial, and non-commercial
information and to interact with a large number of people. Stuho lnc. internet provider encourages this free flow of information
and the benefits it provides, and so we do not actively monitor use of the Service under normal circumstances except for
measuring the Network performance. This Acceptable Use Policy (AuP) supplements your lease agreement with Stuho lnc.
explains certain terms of the Service Agreement and is intended as a guide to rights and obligations when using our internet
providers services.
The goalls of the Acceptable use Policy include the following:
To ensure reliable service to all of our subscribers.
To ensure the security and privacy of our Network and the networks and computers of others.
To comply with existing federal, state and local laws, ordinances and regulations.
To maintain our reputation as a responsible service provider.
To encourage responsible use of the Internet and discourage activities which reduce the usability and value of Internet
services. To preserve the value of Internet resources as a conduit for free expression and exchange of information.
To preserve the privacy and security of individual subscribers.
When obtaining information through the Internet, subscribers must keep in mind that Stuho lnc..s internct provider
cannot monitor, verify, warrant, or vouch for the accuracy and quality Of the information that subscribers may
acquire. For this reason, subscribers must exercise their best judgment about relying on information obtained from
the Internet, and should also be aiware that some material posted to the Internet is sexually explicit or othenÎise
offensive. Furthermore, Stuho lnc.'s internct provider cannot accept any responsibility for injury to its subscribers
that results from inaccurate, unsuitable, offensive, or illegal Internet communications.
When placing information on the Internet, subscribers have the same liability as other authors for copyright
infringement, dofamation and other harmful speech. Also, because the information subscribers create is carried over
the internct and may reach a large number Of people, including other Stuho lnc. internet prcIvider subscribers and
non-subscribers, postings to the lnternct may harm our internct providers goodwill, business reputation, and
operations. For these reasons, subscribers will be held in violation of the Acceptable use Policy if subscribers
engage in any of the prohibited activities listed below.
Although we do not expect any of our subscribers to engage in a prohibited activities, each subscriber is contractually
obligated to abide by this Acceptable Use Policy when using the Service and to ensure that others whom they permit to access
the Service though the Stuho lnc. account likewise comply. If subscribers account is used to violate the Acceptable Use Poliey,
we reserve the right to terminate subscribers account with or without notice. We prefer to advise subscribers of inappropriate
behavior and any necessary corrective action, however flagrant violations of the Acceptable Use Policy will result in
termination. Our failure to enforce this policy, for whatever reason, shall not be construed as a waiver of our right to do so at
any time.
Stuho lnc.'s internet provider retains the right to revise, amend, or modify the Acceptable Use Policy and other policies and
agreements at any time, and any such modification shall be automatically effective for all customers when adopted by Stuho
lnc.'s internet provider.
1. Lawiul Use
Subscribers must use the Service in strict accordance with all federal, state and local laws, ordinances and
regulations. Subscribers may not use the Service to assist any other person or entity to violate any federal, stale or
local laws, ordinances or regulations. For example, prohibited activities may include but are not limited to: transmittal
Of unlawful content, intentionally spreading computer viruses, gaining or attempting to gain unauthorized access to
any Nctviiork, including Stuho lnc..s internet provider Network infrastructure, conducting or participating in illegal
gambling, and soliciting for "pyramids" or other illegal schemes.

Unlawiul content is that which violates any law, statute, treaty, regulation, or lawful order. This includes, but is not limited to:
obscene material; defamatory, fraudulent or deceptive statements; threatening, intimidating or harassing statements; material
which violates the privacy rights or property rights of others (copyrights, trademarks, trade secrets, software piracy, and
patents held by individuals, corporations, or other entities); and exporting encryption software over the Internet or otherwise to
points outside the United States,
Stuho lnc. internet provider is required by the Digital Millennium Copyright Act (DMCA) and other laws to remove or block
access to customer content upon receipt of a proper notice of copyright infringement. It is also Stuho lnc.'s internet provider
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policy to terminate the accounts of customers who commit repeat violations of copyright laws. When necessary to properly
operate the Service, to protect Stuho lnc.'s internet provider rights or the rights of third parties, or as may be required by law,
regulation, government agency or court order, we may disclose certain information, including records concerning subscribers
account.
2. Network Abuses
Consum-lng excessive Network resources. The service is intended for residential, not commercial, use for periodic,
active use of email, newsgroups, file transfers, Internet chat, games, and browsing the World Wide Web. Because the
Service operates on shared Network resources, subscribers may not use non-educational resource-intensive
programs that negatively impact other subscribers or the performance Of Stuho lnc. internet provider systems or
networks. using the Stuho lnc. account for commercial use is prohibited. Stuho lnc. internct provider will notify
subscribers if we deifect excessive resource consumption through the subscribers account, and failure to take
corrective action will result in termination of subscribers account. There are certain research and educational
activities that are high volume and high bandwidth applications. Stuho lnc. internct provider will work with those
students to ensure unique needs are mat on an individual-case basis.
Rese///.ng the Serv/.ce. Reselling the Service without Stuho lnc.'s internet provider written authorization js prohibited.
Subscribers are authorized to share subscriber's connection within the subscriber's residence/Unit at Stuho lnc., but sharing
the subscriber's connection with other residences/Units at the Stuho lnc. is a violation of the Acceptable Use Policy.
Servers and Prox/.es. Subscribers may not run on Stuho lnc.'s internet provider Network any program that makes a service or
resource available to others, including but not limited to port redirectors, proxy servers, chat servers, file servers, web servers
and lRC bots.
Unaufhor/.zed access. Accessing illegally or without authorization computers, accounts, or networks belonging to another
party, or attempting to penetrate security measures of another individual's system is prohibited. Also prohibited is any activity
that might be used as a precursor to an attempted system penetration (i.e. port scan, stealth scan, or other information
gathering activity). Subscribers may not use internet providers services, not included in subscribers account, nor devise ways
to circumvent security in order to access services subscribers are not paying for.
Ivetwock d/.smpfi.ans ar)d rna/t.ci.ous act/.v/fy. Using the Services for any activity which adversely affects the ability of other
people or systems to use the Service or the Internet is prohibited. This includes "denial of service" attacks (sending packets
with an illegal packet size, UDP flooding, ping-flooding, half-open TCP connection flooding, etc.), and "mail bombing" (i.e.
flooding a user or site with large or numerous email messages).
3. Newsgroups
The Service enables subscriber access to thousands of public newsgroups. These newsgroups allow subscribers to read and
post messages on a variety of topics. Subscribers should use their best judgment when posting to any newsgroup. Many
groups have charters, published guidelines, FAQs, or "community standards" describing what is and is not considered
appropriate. Newsgroups can be valuable resources jf used properly. Subscribers should familiarize themselves with basic
Usenet netiquette before posting to a newsgroup. Some prohibited newsgroup activities are: the continued posting of off-topic
articles, commercial advertisements that are off-topic for the newsgroups, and posting the same or similar messages to large
numbers of usenet newsgroup (spain).
4. Poor Conduct
Obscene Speech or MateH.a/s. It is prohibited to use Stuho lnc.s internet provider Network to advertise, transmit, store, post,
display, or otherwise make available pornography, obscene speech and materials, and content that is grossly repugnant to
community standards, including blatant expressions of bigotry, racism or hate. Stuho lnc. internet provider is required by law to
notify law enforcement agencies when it becomes aware of the presence of such content on or being transmitted through
Stuho lnc.'s internet provider.
Harassment. It is prohibited to use the Service to transmit any material (by email, uploading, posting, or otherwise) that
harasses another person or legal entity. Targeting others, with the apparent intention of causing distress, embarrassment, or
other discomfort is considered harassment. Examples of this include expressing personal attacks, using defamatory,
harassing, abusive, or threatening language, sending more than ten similar messages to the same e-mail address, or sending
more than 1 MB of data to a newsgroup.

Harm to in/'nors. It is expressly prohibited to using the Service to harm, or attempt to harm, minors in any way. Stuho lnc.
internet provider does not filter any information available on the Internet, and therefore parents or guardians are responsible
for setting up site filters and other protections for minors using their account. If subscribers allow subscribers children to
access the Service, please remind them of the dangers involved when corresponding or communicating with strangers or new
eL
initiaisLRE ife
15
lil
Eiil
Eiemen[
acquaintances on the Internet.
5. Third party rules.

Through the Service, subscribers may have access to search engines, subscription services, chat areas, bulletin boards, web
pages, newsgroups, and other services that disseminate rules, guidelines or agreements to govern their use. Subscribers
must adhere to any such rules, guidelines or agreements, which may include standards unique for the particular forum. In
addition, the use of any software or data in connection with or through the Service must be in accordance with any applicable
license agreements.
6. Security.
It is prohibited to use the Service to access, or to attempt to access, the accounts of others, or to penetrate, or attempt to
penetrate, Stuho lnc.'s internet provider security measures or another entity's computer software or hardware, electronic
communications system, or telecommunications system, whether or not the intrusion results in the corruption or loss of data. It
is the subscriber's responsibility to ensure that their home Network is con figured jn a secure manner that denies a third party
the capability to use their home Network in an illegal or inappropriate manner. Subscribers are responsible for any misuse of
their account, even if the inappropriate activity was committed by a friend, family member, guest or employee. Therefore,
subscribers must take steps to ensure that others do not gain access to their account. All violations of this policy that can be
traced to an individual account will be treated as the sole responsibility of the owner of that account.
7. Prohibitions Concerning Programming (Video Services). By entering into this agreement, You agree not toresell,
retransmit, or rebroadcast the Stuho lnc. Video Service Provider programming services. You also understand that (a) You are
prohibited from engaging in reselling, retransmitting, or rebroadcasting the Stuho lnc. Video Service Provider programming
services; (b) You will not make any efforts to attempt to cause Stuho lnc. Video Service Provider programming services to be
received by others than at those Units that are authorized under this Agreement; (c) You will not inhibit Stuho lnc. video
Service Provider programming services, other than programming purchased directly from Stuho lnc. Video Service Provider on
a subscription basis, being provided to the occupants of Units as a convenience of occupaney and without additional charge;
(d) You will not cause any modifications, additions, deletions, advertising insertions, or other alterations of any sort whatsoever
to be made to any of the Stuho lnc. Video Service Provider programming services; and (e) You will not cause Stuho lnc. Video
Service Provider programming services to be viewed in any locations in the Licensed Area that are generally accessible to the
commercial public, such as but not limited to restaurants, theaters and pubs.
We hope the Acceptable Use Policy is helpful in clarifying the obligations of Internet and Video users, including Stuho lnc.
internet and video service provider and its subscribers, as responsible members of the Internet and Video Services.
Read and accepted as a part of the lease agreement between Stuho lnc. owner and resident.
Signed by Alec H. Phillipg
Wed Feb 2410:38:15 AM PST 2016

Key: C311259C.,. IP Address: 68.170.78.79
Wed Feb 2412:06:00 PM PST 2016

Key: 48413E63,. IP Address: 68.170.78.79
Dale
Alec H. Phillips /Resi.dent/
Kieran s. Stolorz /Rest.dent/
Sat Feb 27 05:55:33 PM PST 2016
Key: BOFD586F; IP Address: 172.250.120.115
u. M. Bhakta /Agentfl/lanagerJ
Date
I J|.I"/
Initia|s
J31233EL
K.a.
is3123&L
16
Date
EiiE
Element
i ( i Zj
PET ADDENDUM
THIS AGREEMENT between the parties whose authorized signatures appear below as "Landlord" and 'Tenant" shall be
incorporated dy reference into any written rental agreement between the pahies covering the premises indicated below in the
same manner and to the same effect as if it had been originally incorporated therein.
Address of Premises: 2595 Hoover St Unit# |as Cfty: Los Anaeles State: QA Zip: 9QQQZ
No pets have been authorized at

PET Deposit Required: SQQQ
Lease Agreement Dated: Auaust 1. 2016 through July 31. 2017

WHERAS Tenant has expressed a desire to keep a pet or pets on the premises and recognises that certain demage or liabilrty
may result by reason of such pet; and whereas Tenant has agreed to indemnify Landlord from any and all damage or liability
caused by said pet or pets; NOW THEREFORE, the pardes mutually covenant and agree as follows:
1.
Landlord agrees to permit Tenant to keep the pet or pets described above on the premises subject to the terms and
conditions provided herein and Tenant agrees that no other pet or animal shall be kept on premises.
2.
Tenant agrees to deposit the sum of money specified above as additional security for the performance of the terms of this
agreement and any other lease agreement between the parties, receipt of which is herby acknowledged by Landlord.
3.
In addition, Tenant agrees to indemnify Landlord for any damage or liabilrty caused to Landlord by reason of said pet.
Landlord shall have the right to inspect the premises monthly and Tenant shall pay for all damage promptly within ten (10)
days of written notification from Landlord. Any damage not paid upon request of Landlord shall be added to the rental due
on the next rental payment date.
4. Tenant represents that the pet or pets involved are quiet and housebrcken and will not cause damage or annoy other
tenants. Tenant also agrees to abide dy the following rules:
a. If the pet is a dog, it must be on a leash at all times except when irrside the Tenant's premises. Vvalks for sanitary
b.
c.
purposes must be conducted away from the grounds or general premises of the building.
If the pet is a cat, it must be kept inside of the Tenant's premises at all times and a sanitary pan must be available for
the cat within the premises. If a cat is prone to scratch furniture owned by Landlord, Tenant shall provide a scratching
post.
If pet is a bird, it shall at no time be let out of the cage to roam premises. Containers for fish shall rot exceed ten
gallons.
5.
At the termination of Tenant's occupancy and after the premises have been completely vacated of Tenant's possessions,
the following procedure will be adopted: (1) lf there is no damage to the premises or furnishings if applicable, Landlord will
return the Pet Deposit to the Tenant; (2) If there are repairs to be made, Pet Deposit will be returned after the completion
of the repairs, less the cost of such repairs; (3) lf damage exceeds the deposit, Tenant agrees to promptly pay for such
excess within ten (10) days of written notification from Landlord.
6.
7.
It is understood that this document contains the full understanding of the pahies relative to pets and may not be modified.
In the event of default by Tenant of any of the above terms or representations, Tenant agrees to either remove the pet or
vacate the premises within three (3) days after recewing written notice of default from Landlord. Failure to comply with
such notice within the allotted time shall entitle Landlord to apply the Pet Deposit toward any costs of enforcing this
agreement and re-renting the premises, including loss of rent. Tenant further agrees to pay such additional legal expense,
including reasonable attorney's fees, as may be necessary to enforce any term of this agreement.
Wed Feb 2410:38:31 AM PST 2016

Key: C311259C; IP Address: 68.170.78.79
Wed
Alec H. Phillips /Resi.denf/
Key:
Dare
Sat Feb 27 05:55:33 PM PST 2016

Date
A.P'
lnitlals
!!3SEL
a.S`
:i3123S3La
2412:06:08
48413E63,.
Kieran s. Stoloiz /Res;.dent/
U. M. Bhakta /Agentfl/anagerJ
Feb
17
IP
PM
PST
Address:
2016
68.170.78.79
Date
Eiemri[
EE
ZiE]
+ , rF":
RENTAL AGREEMENT ADDENDUM

This Rental Agreement Addendum ('Addendum') is entered into on Februarv 24. 2016, as an addendum to the rental
agreement executed on Februarv 24. 2016, (hereinafter known as 'Agreement'), for the Student Housing Project Premises at
Element, (hereinafter known as 'Premises'). Alec H. PhilliDs and Kieran S. Stolorz (hereinafter collectively known as
Tenant') have entered into the Agreement with HooverAdams Holdina. LLC, the Landlord of the Premises (hereinafter
known as 'Landlord'). Stuho lnc. is the Leasing Agent and/or property Manager for the Premises (hereinafter known as
'Agent/Manager). If Tenant has any guarantors who have signed a Student Housing Guaranty Agreement addendum to the
Agreement, then they shall also be a party to this Addendum. The guarantors for the Agreement] if any, are: Christopher
PhilliDs Bridaet S. Stolorz.
This Addendum to the Agreement shall make a number of amendments to the terms of the Agreement. AIl of the terms and
conditions to the Agreement, except those modified herein, shall still apply in full force.
The amendments/modifications are as follows:
Terrant is avvare that Residence is cart Of a new construction development. Landlord shall make everv effort to
conelude constrLiction and make the Residence rent-ready bv the lease start date. In the event it is not. Landlord shall
Provide Tenant with reasonable temDorarv accommodations until such time as the Residence is rent-read\/. Tenant.
in turn. shall beain and continue to Dav rent to Landlord as Der the terms Of Lease Aareement.
If tenant: has been assianed a specific room in a specific aE)artment. as indicated on the first Dacie of the Lease
Aareement. then Tenant understands and acceots that it is oniv under the condition that Tenant is a Dart Of a arouD
that leases all of the rooms in that aDartment. Tenant acknowledaes that if anv arouD members fail to siam their
respective lease aareements for the other rooms within that apartment. then Tenant mav not be able to lease the
assianed room. and this Lease Aareement shal[ instead be for a TBD room. with the terms in the below TBD
DaraaraDh then beina in force. In this event. Landlord shall have the sole discretion to Place tenant in whichever
room it deems necessarv.
Section 1.6. the Ne\^/ Tenant Addition Procedure shall not be used for a sublease or assianment Of the Premises. A
sublease or assianment Of the Premises shall oniv occur with Landlord's written aDDroval. A S150-$300
administrative fee shall be collected bv Landlord from Tenant to Process a sublease or assianment Of the Premises.
Landlord must aDDrove in writina anv Dotentia[ sublessees or assianees. [n the event Of a lease assianment. the
Securit`r Deposit that Teriant Paid to Landlord shall be trarrsferred to the assianee. and shall not be refunded to
Tenant. An additiorra] lessee or ocouDant mav not be added to the lease without Landlord's Prior written aE)Droval.
Addina a teiiant to the lease mav triaaer an increase in the rent. at Landlord's discretion. If Tenant is an assianee of
the lease Of an assianor tenant. then Tenant aarees thev are acceDtina the Residence in asrfe conditiofi. Both
assjanor and assianee Tenants aaree that assianee tenant will also inherit the existina rental ledaer for the lease the\/
are takina over. includina anv monies Daid bv assianor tenant for rent or securit\/ deDosit. Assianor tenant must
make arranaements to be reimbursed for whate\rer the\/ deem aDDroDriate from assianee tenant.
dline for the Tenant to renew or extend their lease. which may onlv haDDen with Landlord'
ndlord may Ore-lease the Premises to another Dartv if
ion a renewal or extension lease
lso aarees to allow the Premises t
ve lessees even orior to the
r the DurDoses of of said or
raitlist for the Premises.
hall be 10/31/2016. Tenant undei
irst month's rent shall be due bv 7/1/2016. unless this lease is a renewal or extension Of an existina
se the rent will continue to be due on the first dav Of each month until the lease ends, Any and all
rent ororations Shall be calculated based on a 30 dav month. unless othenwise aareed to bv Landlord and Tenant.
Section 2.12. the lanauaae `PRIOR TO THE TIIIIRD (3rdl Of each month' shall be amended to òn or before the third
/3rdt Of each month'. The Late Rent Charae shall be 7% Of the balance or unDaid Portion Of the rent. and not the total
monthly rental amount.
Section 3.17. Landlord shall riot refund anv Portion Of the securit\/ deposit unless the Premises is comDletelv vacated
and Terrant has aiven notice to end the tenancv and has surrendered Possession Of the Premises bv retumina anv
and all kevs. No Dortion Of the securit`r deE]oit shall be refunded to anv de artina Tenants if one-or more Of the
Terrants renew or extend the lease: in this situation the securit\r deposit Shall be refunded at the end Of the renewal or
e)ctension Deriod. No oortion Of the securit`/ deoosit shall be refunded to Tenant if the lease is assianed to an
assianee. It is the resDonsibilitv Of anv de rtina Tenant to make arranaements with remainina Terrants to be
reimbursed for their share Of the deposit. If Tenant is a new Terrant reDlacina a deDartina Terrant Of the Previous
term's lease. then Tenant acknowledcles and aarees to lease the Residence in as-is condition. and understands the\/
malv be held responsible for any rental balances Of the deDartina Tenants whose lease the\/ are inheritina and
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18
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Element
continuing.
Section 4.29.8. the \^rord temantable' in this DaraaraDh shall be chanaed to ùntemantable'
Section 5.30. Tenant shall be notified bv the Landlord or their Aaent/Marraaer for the DurE]ose Of Landlord's and/or
Aoent/Marracier's entrv into the Premises at least 24 hours in advance Of said entrv. unless requested sooner bv
Tenant for maintenance, and/or for emeraencv or other reasonable DurDoses. Tenant aarees to be notified for entrv
y email from the Landlord or its Agena/Mariager. Tenant also agfees' that Landlord 6r Agent/Manager need only
notify for a range of time for entry into the Residence. so long as the range of time given for entry begins no less than
24 hoLJrs after the notice is sent to .the Tenant. It is Tenant's responsibility to notify lrandlord of any change in their
contact information. Tenant aarees to allow Landlord to show common areas Of the Premises. as \^re]l as anv vacant
rooms in and/or on the Premises. without Prior notice to the Tenant.
Section 8.59. Terrant shall be aiven the oDDortunit\/ to inspect the Premises upon commencement Of their lease term.
Tenant shall not be held liable for anv mold or mildew issues that are Dreexistina as Of the date on which the lease
commences.
The followina aDDlies ONLY for units desiamated as TBD on the first iraae of the lease. BEDROOM AND UNIT
ASSIGNIVIENT: At L.andlord.s option. Landlord mav not assian a Unit or Room space at the time Of the execution Of
this Lease. Tenant(sl exDressiv understands and aarees that Landlord.s decision not to assian a rental space at the
time Of the execution Of this Lease will not relieve Tenant(sl of Teiiantls\' resoonsibilities under the Lease. Tenant/s`
aarees that this Lease will remain effective so lona as Landlord is able. on or before the Commencement Date. to
assian to Tenant(sl a rental space in a 3 bedroom unit or as otherwise specified in this Lease. Landlord has the riqht
itemates to anv other bedroom(sl in the Unit before or durina the Lease Term without notice.
act arbitrarilv. Landlord has the riaht to relocate Tenant(sl from one Bedroom in the Unit to
unit or the apartment communitv. upon fifteen (15) davs written notice to such Tenant(s}. If
Iistina oniv the unit tvce and not a specific unit or bedroom. Landlord mav at a time
assicin Tenant(st a Unit or Bedroom. a6 the case mav be. To the extent Practical in
il[1rv to honor requests for a specific unit or bedroom. However. if Tenan
na. and th
nt(st will not be relieved of Tenant(s). obli

ions this Lease listina onlv the unit tvDe and not a
Landlord cannot Guarantee the availabilit\/ Of the u
owledae that anv and all occupants Of the Unit hav
I contained herein shall limit access Of anv occu
hat the
leased.
dwelling.
IN WITNESS THEREOF, the Parties agree to the terms of the foregoing Addendum to the Agreement, which js hereby
executed in Los Ancieles. CA.
Wed Feb 2410:38:50 AM PST 2016

Key: C311259C; IP Address: 68.170.78.79
Wed
Alec H. Phillips /Res/.denf/
Key:
Oats
Sat Feb 27 05:55:33 PM PST 2016

gL
in,tiaisife Life
2412:06:26
48413E63,-IP
Kieran s. Stolorz /Rest.dent/
U. M. Bhakta /AgenowanagerJ
Feb
Date
19
PM
PST
Address:
2016
68.170.78.79
Date
EiEI
E!emenS
Student Housing Guaranty Agreement

This Guaranty Agreement ("Guaranty") dated Februaarv 24. 2016 is made by ChristoDher PhilliDs and Bridciet S.
Se|QE in favor of HcoverAdams Holdina. LLC, by Stuho lnc., Agent, Manager of "Stucleut Housing Project" (SHP)
("Landlord"). HooverAdams Holding. LLC, by Stuho lnc., and Alec H. PhilliDs and Kieran S. Stolorz (Tenant") have
entered into a rental agreement dated Februarv 24. 2016 and addenda (if any) (collectively referrecl to as the
''Agreement"). Under the Agreement, Landlord rented to Tenant the Premises located at 2595 Hoover St rsl8-3. Los
Angles. CA 90007. Ae a condltJon to onterlng Into the Agreonent, Landlord has requlrod that Guarantor xocLrfe and
deliver to Landlord this Guaranty. Failure to do so within ten (10) days Of Agreement will result in a 10% increase to
the monthly rental amount.
As a material inducement to the Landlord to enter into the Agreement with the Tenant, Guarantor agrees as follows:
1.
Guaranty: Guarantor absolutely and unconditionally guarantees to Landlord the timely payment of all amounts that Tenant
owes under the Agreement, or any Agreement extensions, renewals or modifications. Guarantor further guarantees
Tenant's full, faithful, and timely performance of the Agreement, or any Agreement extensions, renewals, or modifications.
If Tenant fails to pay amounts due (whether rent or other amounts) or fails otherwise to perform any covenant or obligation
under the Agreement, Guarantor (at Guarantor's expense) will fully and promptly pay all amounts due and perform all of
Tenent's covenants and obligations under the Agreement on demand by the Landlord. Amounts due may include (but are
not limited to) rent, interest, costs advanced by Landlord, damages, cleaning costs, repair costs, or replacement costs for
real or personal property, and all expenses including, (but no limited to) court costs and reasonable attorney fees that may
anse because of Tenant's default. In addition, Guarantor agrees to pay reasonable attorney fees and all other costs and
expenses inourred by Landlord in enforcing this Guaranty or in any action or proceeding arising out of, or relating to, this
Guaranty.
2.
Term: This Guaranty will be come effective when it is signed and delivered to the Landlord. The term of the Guaranty will
begin at the Agreement commencement date, and notwithstanding any termination, renewal, and extensions or holding
over of the Agreement, this Guaranty will continue until all Tenants' obligations have been fully and completely performed.
3.
Terrant Definition: For purposes of the Guaranty, and the obligations and liabilfty of Guarantor, the term 'Tenant" includes
any and all occupants of the Premises, whether original Tenants, subtenants, assignees, or others directly or indirectly
leasing or occupying the Premises.
4.
Continuing Guaranty: This Guaranty will remain in full force notwithstanding the appointment of a receiver to take
possession of all or substantially all of the assets of Tenant, or an assignment by Tenant for the benefit of creditors, or any
action taken or suffered by Tenant under any insolvency, bankruptey, reorganization, moratorium, or other debtor relief act
or stature, whether now existing or later amended or enacted, of the disafflrmance of the Agreement in any action or
otherwise.
5.
Independent Obligations: The obligatlons of Guarantor are independent of, and may exceed, the obligations of Tenant.
At Landlord's option, a separate action may be brought and prosecuted against Guarantor, whether or not any action is
first or subsequently brought against Tenant, or whether or not Tenant is joined in any action, and Guarantor may be
joined in any action or proceeding initiated by Landlord against Tenant arising out of, in connection with, or based upon the
Agreement.
6.
Guarantor Waivers: Guarantor waives any right to (1) require Landlord to proceed against Tenant, other Guarantors, or
any other person of entity liable to Landlord or pursue any other remedy in Landlords power; (2) complain of delay in the
enforcement of Landlord's rights under the Agreement and; (3) require Landlord to proceed against or exhaust any security
held from Tenant or Guarantor. Guarantor waives any defense arising from any disabilrty or other defense of Tenant.
Guarantor waives any right of subrogation and demands upon and notices to Tenant and to Guarantor, including without
limitation, demands for performance, notices of nonperformance, and notices of ron-payment and notices of acceptance of
the Guaranty.
7.
No Reporting Duty: Guarantor assumes full responsibilfty for keeping fully informed of the financial condition of Tenant
and all other circumstances affecting Tenant's ability to perform Tenant's obligations under the Agreement. Guarantor
agrees that Landlord will have no duty to report to Guarantor any information that Landlord received about Tenant's
financial condition or any ciroumstances bearing on Tenant's ability to perform any obligations.
8. Agreement Extensions, Amendments, Assignments and Subletting: Guarantor agrees that the Agreement may be
extended, renewed, modified, assigned or sublet (by agreement of course of conduct) without consent or notice to
Girarantor and this Guaranty will guaranty the performance of the Agreement as extended, renewed, modified, assigned or
sublet.
9.
Estoppel Certificate: If Tenant has any obligation to sign and deliver estoppel certificates, Guarantor will have the same
J|.P.
inltiais EJ35EL
Lan
20
lil
Element
EE
`,,
obligation to provide estoppel certificates signed by the Guarantor .
10. Joint and Several Obligations: lf this Guaranty is signed by more than one party, or if the obligations of the Tenant are
otherwise guaranteed by more than one party, their obligations will be joint and several, and a release or liability limitation
of any one or more of the guarantors will not release or limit the liability of any other guarantors.
11. Successors and Assigns: This Guaranty will be binding upon Guarantor and Guarantor's heirs, administrators, personal
and legal representative, successors, and assigns, and will inure to the benefit of Landlord and Landlord's successors and
asslgns. Landlord may, without notice to or consent of Guarantor, assign this Guaranty, the Agreement. or the rents and
other sums payable under the Agreement, in whole or part.
12. Governing Law: The Guaranty is made under and will be governed by California law in all respects, including matters of
construction, validity, and performance. The Guaranty may not be waived, altered, modified, or amended except in a
writing signed by an authorized officer of Landlord any by Guarantor. Any action arising out for this Guaranty may be
brought in the county where the property is listed.
13. Severance: lf any provision of this Guaranty is invalid under the laws of any jurisdiction, this Guaranty will be construed as
if it did not contain that provision.
14. Counterparts, Electronic and Fax Signatures: This Guaranty may be executed in countei.part, each which will be a valid
and binding original, but all together will constitute one and the same instrument. Landlord may rely on a faxed or
electronic copy of this Guaranty as if jt was the original.
Signed by Bridget S. Stolorz

Wed Feb 2410:54:32 AM PST 2016
Key: 38255E88,. IP Address: 206.213.165.70
Christopher Phillips /GuarantorJ
Oafe
Bridget s. Stolorz /Gttarantor)
Sat,Feb 27 05:55:33 PM PST 2016
U. M. Bhakta /Agenwanager)
Date
state Of ca
Courty Of Los Ancleles
init,aisL Life
21
Date
Ziil
Element
ZEE
TIP SHEET ON MOLD

It is important for Tenants to minimize the potential for conditions that could lead to the growth of naturally occurring
mold. Tenants can help minimize mold growth in their units by taking the following actions:
Open windo\rs on days when the humidity is low. If it's not possible to open windows, run the air conditioner to
circulate fresh air throughout your unit. However, keep windows and doors closed when the outdoor humidity is
high and during damp or rainy \neather conditions.
If possible, maintain a temperature of between 50 and 80 degrees Fahrenheit.

clean and dust your unit on a regular basis as required by your lease. Regular vacuuming, mopping and use of
environmenta[ly safe household cleaners is important.
Periodically clean and dry walls and floors around the sink, bathtub, shower, toilets, windo\rs and balcony doors
using a common household disinfecting cleaner.
On a regular basis, wipe do\^rn and dry areas where moisture sometimes accumulates, like countertops, windo\rs
and windowsills.
Use the bathroom fan or alternative ventilation when bathing or showering and allow fan to run until all excess
moisture has vented from the bathroom. If ventilation fans are not present, following the first item of this list is
essential.
Use exhaust fans in kitchen when cooking or while the dish\rasher is running and allows the fan to run until all
excess moisture has vented from the kitchen.
Do not overfill closets or storage areas. Ventilation is important in these spaces.
Do notallowdamp or moiststacks of clothes orother cloth materials to lie in piles.
Immediately report to the management office any evidence of mold growth or musty odors.
Immediately report to the management office any evidence of a water leak or excessive moisture in your unit or
any common area.
Immediately report to the management office any malfunctions with your heating, ventilation, air-conditioning or
laundry system. Do not block any heating, ventilation or aironditioning ducts in your unit.
Signed by Alec H. PhillipB
Wed Feb 2410:39:29 AM PST 2ol6

Key: C311259C; IP Address: 68.170.78.79
Wed
Key:
Oats
Alec H. Phillips /I?esi'denf/
Sat Feb 27 05:55:33 PM PST 2016

CL5+
initiaisife ife
2412:06:59
48413E63,.
Kieran s. Stolorz /Resi.denf/
Signed by tJ. M. Bhakta

U. M. Bhakta /Agenowanager/
Feb
Date
22
PM
IP
PST
Address:
2016
68.170.78.79
Date
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES

NOTICE OF CASE ASSIGNMENT -UNLIMITED CIVIL CASE (NON-CLASS ACTION)
Case Number
THIS FORM IS TO BE SERVED WIITH THE SUMMONS AND COMPLAI
Res,d6eo#thfsg"84
Your case is assigned for all purposes to the judge indicated below, The+-e-Ts more information on the reverse side of thi's frn!
ASSIGNHD JUDGE
DEPT
ROOM
534
Hon. Barbara A. Meiers
12
Hon. Terry A. Green
DEPT
ROOM
Hon. Elizabeth AIIen White
48
506
636
Hon. Deirdre Hi.I
49
509
14
300
Hon. Teresa A. Beaudet
50
508
Hon. Richard Fruili
15
307
Hon. Michael J. Raphael
51
511
Hon. Rita Miller
16
306
Hop. Susan Bryant-Deason
S2
510
Hon. Richard E. Rico
17
309
Hon. Howard L. Halm
53
SIS
Hon. Stephanie Bowick
19
311
Hon. Ernest M. Hiroshige
54
512
Hon. Dalila Corral Lyons
20
310
Hon. Ma]colm H. Mackey
55
515
Hon. Robert L. Hess
24
314
Hon. Michael Johnson
56
514
Hon. Yvette M. Palazuelos
28
318
Hon. John P. Doylc
58
S16
Hon. Barbara Scheper
30
400
Hon. Gregory Keosian
61
732
Hob. Samantlla Jessner
31
407
Horn. Michael L. Stern
62
600
Hon. Daniel S. Murphy
32
406
Hon. Mark Mooney
68
617
Hon. Micliael P. Linrleld
34
408
Hob. William F. Fahey
69
621
Hon. Gregory Alarcon
36
410
Hon. Suzanne G. Bruguera
71
729
Hon. Mare Marmaro
37
413
Hob. Ruth Ann Kwan
72
731
H/MaureenDuffy-Lewis
38
412
Hob. Rafael 0hgkeko
73
733
Hon. Elizabeth Feffer
39
Hon. Teresa Sanchez-Cordon
74
735
Hon. Gall Ruderman Feuer
78
730
324
CCW
324
CCW
Hon. Kevin C. Brazile
./
ASSIGNED JUDGE
Hon. David Sotelo
`,4o
)4,5
414
Hon. Holly E. Kendig
42
416
Hob. Mel Red Recana
45
529
Hon. Frederick C. Shaller
46
500
Hon. Debre K. Weintraub
47
507
Hon. Steven J. Kleifield

*Provisionally ComplexNon-classActionCasesAssignmentisPendingComplexDetermination
*ComDlex
All nob-class action cases designated as provisionally complex are rorwarded to the Supervising Judge of the Complex Litigation Program
located in tlle Central Civil West Courtliouse (600 S. Commonwealth Ave.. Los Angeles 90005), for complex/nob-complex determination
Pursuant to Local Rule 3.3(k). This procedure is for the purpose of assessing whether or not the case is complex within the meaning of
California Rules of Court, rule 3.400. De|]ending on tlie outcome of tliat assessment, the case may be reassigned to one of tlle judges of the
comp'exLitigationprogramorreassignedrandom,ytoacourt.i`nht\:e;engtrftyR5trict.
-I_____ A
` ,-,,., J~ -,-.
Giventotheplaintiff/Cross-ComplainanvAttorneyofReSENol
SHERRI R. C
TER, Executive Officer/Clerk

Deputy Clerk
LACIV CCH 190 (Rev.06/16)
LASC Approved 05J)6
- NOTICE OF CASE ASSIGNMENT UNLIMITED CIVIL CASE
Page I of 2
INSTRUCTIONS FOR HANDLING UNLIMITED CIVIL CASES
The following critical provisions of the Chapter Three Rules, as applicable in the Central District, are summarized for your assistance.
APPLICATION
The Chapter Three Rules were effective January 1, 1994. They apply to all general civil cases.
PRIORITY OVER 0THHR RULES

The Chapter Three Rules shall have priority over all other Local Rules to the extent the others are inconsistent.
CIIALLENGE TO ASSIGNED JUDGE

A challenge under Code of Civil Procedure section 170.6 must be made within 15 days after notice of assignment for all purposes to a
judge, or if a party has not yet appeared, within 15 days of the first appearance.
TIME STANDARDS
Cases assigned to the Individual Calendaring Court will be subject to processing under the following time standards:
COMPLAINTS: All complaints shall be served within 60 days of filing and proof of service shall be filed within 90 days of filing.
CROSS-COMPLAINTS: Without leave of court first being obtained, no crossreomplaint may be filed by any party after their answer is
filed. Cross{omplaints shall be served within 30 days of the filing date and a proof of service filed within 60 days of the filing date.
A Status Conference will be scheduled by the assigned Independent Calendar Judge no later than 270 days after the filing of the complaint.
Counsel must be fully prepared to discuss the following issues: alternative dispute resolution, bifurcation, settlement, trial date, and expert
witnesses,
FINAL STATUS CONFERENCE

The Court will require the parties at a status conference not more than 10 days before the trial to have timely filed and served all motions
in limine, bifurcation motions, statements of major evidentiary issues, dispositive motions, requested jury instructions, and special jury
instructions and special jury verdicts. These matters may be heard and resolved at this conference. At least 5 days before this conference,
counsel must also have exchanged lists of exhibits and witnesses and have submitted to the court a brief statement of the case to be read to
the jury panel as required by Chapter Eight of the Los Angeles Superior Court Rules.
SANCTIONS
The court will impose appropriate sanctions for the failure or refusal to comply with Chapter Three Rules, orders made by the Court, and
time standards or deadlines established by the Court or by the Chapter Three Rules. Such sanctions may be on a party or if appropriate on
counsel for the party.
This is not a complete delineation of the Chapter Three Rules, and adherence only to the above provisions is therefore not a
guarantee against the imposition of sanctions under Trial Court Delay Reduction. Careful rcading and compliance with the
actual Chapter Rules is absolutely imperative.
LACIV CCH 190 (Rev.06/16)
LASC Approved 05-06
-NOTICE OF CASE ASSIGNMENT -
UNLIMITED CIVIL CASE
Page 2 of 2
VLUNFTARY EFFICIENFT ""GATION STIPULA"ONS
The Early Organizational Meeting Stipulation, Discovery

Resolution Stipulation, and Motions in Limine Stipulation are
Superior Court Of California
Coulity Of Los Angeles
voluntary stipulations entered into by the parties. The parties

may enter into one, two, or all three of the stipulations;
however, they may not alter the stipulations as written,

because the Court wants to ensure uniformity of application.
Los Angels County
Bar Association
These stipulations are meant to encourage cooperation
Litigation Sctlon
Los Angeles County

Bar Asociation Labor and
Employment Law Section
between the parties and to assist in resolving issues in a

manner that promotes economic case resolution and judicial
efficiency.
The
Consumer Attorneys
Association of Los Angeles
following
promoting
efficiency
organizations
in
litigation
endorse
and
the
goal
of
ask that counsel
consider using these stipulations as a voluntary way to
promote communications and procedures among counsel

and with the court to fairly resolve issues in their cases.
Los Angeles County Bar Association Litigation Section.

Southern California
Defense Counsel
Los Angeles County Bar Association
..``n,ap`::iAssociation of
Business Trial Lavryers
Labor and Employment Law Section.
Consumer Attorneys Association of Los Angeles.

SSouthern California Defense Counsel.
Association of Business Trial Lawyers.

California Employment
Lavyers Association
LACIV 230 (NEVV)
LASC Approved 4-11

For Optional Use
California Employment Lawyers Association.
NAME AND ADDRESS OF ATTOF`NEV OR PARTY WtTHOUT ATTORNEY:TELEPHONENO.:
FAX NO. (Op
sT^TE aAR NUMBEF`
Reowed /a. Clerk'8 Fe SfalTip
tional):
E-MAIL ADDRESS (Optional):
ATTORNEY FOR (Name):
SUPERIOR COURT OF CALIFORNIA, COUNTY 0F LOS ANGELES

COURTHOUSE ADDRESS:
PLAINTIFF:
DEFENDANT:
CASE NUMBER:
STIPULATION - DISCOVERY RESOLUTION
This stipulation is intended to provide a fast and informal resolution Of discovery issues
through limited paperwork and an informal conference with the Court to aid in the
resolution of the issues.
The parties agree that:

1. Prior to the discovery cut-off in this action, no discovery motion shall be filed or heard unless
the moving party first makes a written request for an Informal Discovery Conference pursuant
to the terms of this stipulation.
2. At the Informal Discovery Conference the Court will consider the dispute presented by parties
and determine whether it can be resolved informally. Nothing set forth herein will preclude a
party from making a record at the conclusion of an Informal Discovery Conference, either
orally or in writing.
3. Following a reasonable and good faith attempt at an informal resolution of each issue to be
presented, a party may request an Informal Discovery Conference pursuant to the following
procedures:
a. The party requesting the Informal Discovery Conference will:
i.
ii.
iii.
File a Request for Informal Discovery Conference with the clerk's office on the
approved form (copy attached) and deliver a courtesy, conformed copy to the
assigned department;
Include a briefsummary of the dispute and specify the reliefrequested; and
Serve the opposing party pursuant to any authorized or agreed method of service
that ensures that the opposing party receives the Request for Informal Discovery
Conference no later than the next court day following the filing.
b. Any Answer to a Request for Informal Discovery Conference must:

i.
Also be filed on the approved form (copy attached);
ii.
Include a briefsummary of why the requested reliefshould be denied;
LACIV 036 (new)

LASC Approved 04/1 1
For Optional Use
STIPULATloN -DISCOVERY RESOLUTION

Page 1 of 3
St+ORT TITIE.
CASE NUMBER:
iii.
iv.
Be filed within two (2) court days of receipt of the Request; and
Be served on the opposing party pursuant to any authorized or agreed upon

method of service that ensures that the opposing party receives the Answer no
later than the next court day following the filing.
c.
No other pleadings, including but not limited to exhibits, declarations, or attachments, will
be accepted.
d. If the Court has not granted or denied the Request for Informal Discovery Conference
within ten (10) days following the filing of the Request, then it shall be deemed to have
been denied. If the Court acts on the Request, the parties will be notified whether the
Request for Informal Discovery Conference has been granted or denied and, if granted,
the date and time of the Informal Discovery Conference, which must be within twenty (20)
days of the filing of the Request for Informal Discovery Conference.
e. If the conference is not held within twenty (20) days of the filing of the Request for
Informal Discovery Conference, unless extended by agreement of the parties and the
Court, then the Request for the Informal Discovery Conference shall be deemed to have
been denied at that time.
4. If (a) the Court has denied a conference or (b) one of the time deadlines above has expired
without the Court having acted or (c) the Informal Discovery Conference is concluded without
resolving the dispute, then a party may file a discovery motion to address unresolved issues.
5. The parties hereby further agree that the time for making a motion to compel or other
discovery motion is tolled from the date of filing of the Request for Informal Discovery
Conference until (a) the request is denied or deemed denied or (b) twenty (20) days after the
filing of the Request for Informal Discovery Conference, whichever is earlier, unless extended
by Order of the Court.
It is the understanding and intent of the parties that this stipulation shall, for each discovery
dispute to which it applies, constitute a writing memorializing a "specific later date to which
the propounding tor demanding or requesting] party and the responding party have agreed in
writing," within the meaning of Code Civil Procedure sections 2030.300(c), 2031.320(c), and
2033.290(c).
6. Nothing herein will preclude any party from applying ex parfe for appropriate relief, including
an order shortening time for a motion to be heard concerning discovery.
7. Any party may terminate this stipulation by giving twenty-one (21) days notice of intent to
terminate the stipulation.
8. References to "days" mean calendar days, unless otherwise noted. If the date for performing
any act pursuant to this stipulation falls on a Saturday, Sunday or Court holiday, then the time
for performing that act shall be extended to the next Court day.
LACIV 036 (new)

For Optional Use

Page 2 of 3
enoRT TTTiE.
CASE NUMBEF`:
The following parties stipulate:

Date:
(TYPE OR Pf`lNT NAME)
(AITORNEY FOR PLAINTIFF)
(lYPE OR PRINT NAME)
(ATTORNEY FOR DEFENDANT)
(TYPE OR PRINT NAME)
Date:
Date:
Date:
Date:
(ATTORNEY FOR
(ATTORNEY FOR
(AITORNEY FOR
LACIV 036 (new)

For Optional Use

Page 3 of 3
NAIAE AND AOORESS 0F ATTOFtNEY OFt PARTY VVITHOUT AITORNI=Y:TELEPHONENO.:
FAIK NO. (Op
STATE BAR NUMEreF`
Reserved for aerk'. Ffl. Stamp
tional):

COURTHOUSE ADDRESS:
PLAINTIFF:
DEFENDANT:
CASE NUMBER:
STIPULATION -EARLY ORGANIZATIONAL MEETING
This stipulation is intended to encourage cooperation among the parties at an early stage in
the lltigation and to assist the parties in efficient case resolution.

1. The parties commit to conduct an initial conference (in-person or via teleconference or via
videoconference) within 15 days from the date this stipulation is signed, to di.scuss and consi-der
whether there can be agreement on the following..
a. Are motions to challenge the pleadings necessary? If the issue can be resolved by
amendment as of right, or if the Court would allow leave to amend, could an amended
complaint resolve most or all of the issues a demurrer might otherwise raise? lf so, the parties
agree to work through pleading issues so that a demurrer need only raise issues they cannot
resolve. Is the issue that the defendant seeks to raise amenable to resolution on demurrer, or
would some other type of motion be preferable? Could a voluntary targeted exchange of
documents or information by any party cure an uncertainty in the pleadings?
b.
Initial mutual exchanges of documents at the "core" of the litigation.
(For example, in an
employment case, the employment records, personnel file and documents relating to the
conduct in question could be considered ``core." ln a personal injury case, an incident or
police report, medical records, and repair or maintenance records could be considered
"core.");
c.
Exchange of names and contact information of witnesses;
d. Any insurance agreement that may be available to satisfy part or all of a judgment, or to
indemnify or reimburse for payments made to satisfy a judgment;
e.
Exchange of any other information that might be helpful to facilitate understanding, handling,
or resolution of the case in a manner that preserves objections or privileges by agreement;
f.
Controlling issues of law that, if resolved early, will promote efficiency and economy in other
phases of the case. Also, when and how such issues can be presented to the Court;
9. Whether or when the case should be scheduled with a settlement officer, what discovery or
court ruling on legal issues is reasonably required to make settlement discussions meaningful,
and whether the parties wish to use a sitting judge or a private mediator or other options as
LACIV 229 (Rev 02/15)
LASC Approved o4/11

For Optional Use
STIPULATION -EARLY ORGANIZATIONAL MEETING

Page 1 of 2
SHORT TITLE:
CIASE NUMBER:
disoussed in the "Altemative Dispute Resolution (ADR) Information Package" served with the
complaint;
h.
Computation of damages, including doouments, not privileged or protected from disclosure, on

which such computation is based;
i.
Whether the case is suitable for the Expedited Jury Trial procedures (see information at
www.Iacourt.ora under "Civir' aT\d then uncler uGeneral Infomatiori").
The time for a defending party to respond to a complaint or oross-complaint will be extended
to
for the complaint, and
for the cross(INSERT DATE)
tlNSERT DATE)
complaint, which is comprised Of the 30 days to respond under Government Code 68616(b),
and the 30 days permitted by Code of Civil Procedure section 1054(a), good cause having
been found by the Civil Supervising Judge due to the case management benefits provided by
this Stipulation. A copy Of the General Order can be found at www./acourf.ore under "Cin.r,
chiick on "General Information" , then chiick on "Voluntary Efficient Litigation Stipulations .
The parties will prepare a joint report titled "Joint Status Report Pursuant to Initial Conference
and Earty Organizational Meeting Stipulation, and if desired, a proposed order summarizing
results Of their meet and confer and advising the Court Of any way it may assist the parties'
efficient conduct or resolution of the case. The parties shall attach the Joint Status Report to
the Case Management Conference statement, and file the documents when the CMC
statement is due.
4.
References to "days" mean calendar days, unless otherwise noted. If the date for performing
any act pursuant to this stipulation falls on a Saturday, Sunday or Court holiday, then the time
for performing that act shall be extended to the next Court day

Date:
(ATTORNEY FOR PLAINTIFF)
(ATTORNEY FOR
(rvpE oR PRINT NAME)
(AITORNEY FOR
(ATTORNEY FOR
LACIV229(Rev02/15)
sT|PULAT|ON -EARLY ORGANIZATIONAL MEETING

Page 2 of 2
NAME AND ADlESS 0F ATTORNEY OR PAFtTV WITHOUT ATTOF`NEY:TELEPHONENO.:
FAX NO. (Op
STATE BAR NUMBER
F`ceorved fo. Clerk's Ffl. Stamp
tional):

COURTHOUSE ADDRESS:
PLAINTIFF:
DEFENDANT:
INFORMAL DISCOVERY CON FERENCE
CASE NUMBEFt:
(pursuant to the Discovery Resolution Stipulation of the parties)
1. This document relates to:
I
I
2.
Request for Informal Discovery conference

Answer to Request for Informal Discovery conference
Deadline for Court to decide on Request:

the Request).
3.
(insert date 10 calendar days following filing of
Deadline for Court to hold Informal Discovery Conference:

days following filing Of the Request).
(insert date 20 calendar
4. For a Request for Informal Dlscovery Conference, !!][ describe the nature of the
discovery dispute, includlng the facts and legal arguments at issue. For an Answer to
Request for Informal Discovery Conference, [ig!y describe why the Court should deny
the requested discovery, including the facts and legal arguments at issue.
___J
LACIV 094 (new)
For Optional Use
INFORMAL DISCOVERY CONFERENCE

(pursuant to the Discovery Resolution Stipulation of the parties)
r\IAîE AND ^DOFÈss oF ATTORNEv oF` pARTv wlTHouT ATTORNEv:TELEPHONENO.:
FAX NO. (Op
STATE BAR NUMBER
Reserved lor Clerk'3 Fito Stamp
t,'Onal):
SUPERIOR COURT OF CALIFORNIA, COUNTY 0F LOS ANGELES

COURTHOUSE ADDRESS:
PLAINTIFF:
DEFENDANT:
CASE NUMBER:
STIPULATION AND ORDER -MOTIONS IN LIMINE
This stipulation is intended to provide fast and informal resolution of evidentiary

issues through diligent efforts to define and discuss such issues and limit paperwork.

1. At least _ days before the final status conference, each party will provide all other
parties with a list containing a one paragraph explanation of each proposed motion in
limine. Each one paragraph explanation must identify the substance of a single proposed
motion in limine and the grounds for the proposed motion.
2. The parties thereafter will meet and confer, either in person or via teleconference or
videoconference, concerning all proposed motions in limine. In that meet and confer, the
parties will determine:
a. Whether the parties can stipulate to any of the proposed motions. If the parties so
stipulate, they may file a stipulation and proposed order with the Court.
b. Whether any of the proposed motions can be briefed and submitted by means of a
short joint statement of issues. For each motion which can be addressed by a short
joint statement of issues, a short joint statement of issues must be filed with the Court
10 days prior to the final status conference. Each side's portion of the short joint
statement of issues may not exceed three pages. The parties will meet and confer to
agree on a date and manner for exchang.ing the parties' respective portions of the
short joint statement of issues and the process for filing the short joint statement of
issues.
3. All proposed motions in limine that are not either the subject of a stipulation or briefed via
a short joint statement of issues will be briefed and filed in accordance with the California
Rules of Court and the Los Angeles Superior Court Rules.
LACIV 075 (new)
Firs8pft:::ivuefe4/Jt
STIPULATION AND ORDER -MOTIONS IN L|M|NE
Page 1 Of 2
SHORT TITIE:
CASE NUMBER:

Date:
(ATTORNEY FOR PLAINTIFF)
(lYPE OR PRINT NAME)
(AITORNEY FOR DEFENDANT)
Date:
Date:
Date:
Date:
(AITORNEY FOR
(AITORNEY FOR
(ATTORNEY FOR
Date:
Date:
THE COURT SO ORDERS.

Date:
JUDICIAL OFFICER
#:V&7p5r6:%)o4m
STIPULATION AND ORDER -MOTIONS IN LIIVIINE
Page 2 of 2

McGlynn v. Stuho Complaint

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EE

FOR COURT USE ONLY

(SOLO PARA uS0 DE LA CORTE)

OfiiGINAi FiLff r>

STUHO, a California Corporation; HOOVER - ADAMS HOLDING

LLC, a California Limited Liability Company; -and-DOES 1 -I,000

Snerri R. Carter, Executive Ofilcer/Clerk

(LO ESTA DENIANDANDO EL DEMANDANTE):

y Cristlna Grijalva, Deputy

CONNOR MCGLYNN, an individual; ALEC PHILLIPS, an individual;

The name and address of the court is:

(E/ nombre y df.recoi.6n de /a corfe es/.. Stanley Mosk (Central) Courthouse

(Nclmero del Caso):

Ill N Hill Street, Los Angeles, CA 90012

under E= :::::;: t:::::at:oo:;orat,on,

Code of CMI Procedure 412.20, 465

515 S Flower Street

(213) 281 -9666

CIVIL CASE COVER SHEETHunlimitedILimited(Amount(Amount

Complex Case DesignationICounterIJoinder

H Breach of contractwarranty (06)

Other Pl/PD/WD (Personal Injury/Property

I AntitrustITrade regulation (03)

I other collections (og)

I Other Pl/PDAVD (23)

Non-Pl/PDAVD (Other) Tort

I Wrongful eviction (33)

I Product liability (24)

Provisionally Complex Civil Litigation

I Construction defect (10)

E] Business tort/un;air business practice (o7) I Other real property (26)

I Enforcement of judgment (20)

I Intellectual property (19)

I Other complaint /not speofi.ed above/ (42)

I Other nan-Pl/PDAVD tort (35)

I Asset forfeiture (05)

I civil rights (o8)

Miscellaneous Civil Complaint

Miscellaneous Civil Petition

I Partnership and corporate governance (21)

I Petition re: arbitration award (11)

I Other petition /nor specifed above/ (43)

I Writ of mandate (o2)

I Otherjudicial review (39)

a. I Large number of separately represented parties

d. I Large number of witnesses

b. I Extensive motion practice raising difficult or novel

e. I Coordination with related actions pending in one or more courts

f. I :nubtsht:rn::#:;i:tga:ees;tjru:c::,tr::Sb;j,:|oan federa' Curt

Number of causes of action /spec/fyJ.. 5

(SIGNATURE OF PARTY OR ATTORNEY FOR PARTY)

Gal R u'%Sa,Ofs%#;#;eosf: u,;Fa,28*3#st;%:i%3a394:0;

INSTRUCTIONS 0N HOW TO COMPLETE THE COVER SHEET

To Parties in Complex Cases.

case involves an uninsured

Physicians & Surgeons

Other Pl/PDrm (23)

(e.g., assault, vandalism)

false arrest) /r)of a/.v/./

Professional Negligence (25)

CM-010 [Rev, July 1, 2007]

Breach of ContractM/arranty (06)

Other Contract (37)