You are on page 1of 7
ectonicaly FILED by Superior Court of California, County of Los Angeles on 8/16/2022 11:10 AM Sher. Cater, Exocuve OfcerClek of Cour, by G, Glorioso, Deputy Clerk up-101 [arTORNEY OR PARTY WITHOUT ATTORNEY TATE BAR WuNBER: 232339, 307251 (FoR COURT USE OMLY awe: Jed White; David Root rratnaue BRYAN CAVE LEIGHTON PAISNER LLP street aooness: 120 Broadway, Suite 300 ery: Santa Monica staeCA —necooe:90401 jrexzrvone no. (310) 576-2100 raxno:(310) 576-2200 wat aooness:jed.white@belplaw.com; david.root@bclplaw.com |artonnev FoR rms REGUS MANAGEMENT GROUP, LLC. [SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES, stmeer ooness: 300 East Walnut St, ans aooress: 300 East Walnut St. ‘ary avo 2» cove: Pasadena 91101 eeanch nave: Pasadena Courthouse PLAINTIFF: REGUS MANAGEMENT GROUP, LLG DEFENDANT: QUEEN SEARLES, et al. case muunen: PLAINTIFF'S MANDATORY COVER SHEET AND SUPPLEMENTAL ALLEGATIONS—UNLAWFUL DETAINER 22PDUD01959 ‘Al plaintifs in unlawful detainer proceedings must file and serve this form. Filing this form complies with the requirement in Code of iil Procedure section 1179.01.5(c). * Serve this form and any attachments to it with the summons. ‘if summons has already been served without this form, then serve it by mail or any other means of service authorized by law. + if defendant has answered prior to service ofthis form, there is no requirement for defendant to respond to the supplemental allegations before tral. To obtain a summons in an unlawful detainer action for nonpayment of rent due between March 1, 2020, and March 31. 2022, on a residential property, a plaintiff must verily that they applied for governmental rental assistance that was not granted, that no application) {for governmental rental assistance is pending, or that the tenancy began after September 30, 2021. (See item 3.) To obtain a judgment in an unlawful detainer action for nonpayment of rent on a residential property, a plaintiff must verily that no ental assistance or other financial compensation has been received for the amount demanded in the notice or accruing afterward, and} {that no application is pending for such assistance. To obtain a default judgment, plaintiff must use Verification by Landlord Regarding Rental Assistance—Unlawful Detainer (form UD-120) to make this verification and provide other information required by statute, | | 1. PLAINTIFF (name each): Regus Management Group, LLC, a California limited liability company alleges causes of action in the complaint fled inthis action against DEFENDANT (namo each): ‘Queen Searles; and DOES 1-50 2. Statutory cover sheet allegations (Code Civ. Proc., § 1179,01.5(¢)) 1. This action seeks possession of real property that Is (check ail that apply): Residentiat commercial (ir residential" is checked, complete items 3 and 4 and all remaining tems that apply o this action. i only “commercial” is ‘checked, no further tems need lo be complatad except the signature and verification on page 5; a summons may be issued.) b. This action is based, in whole or in part, on an alleged default in payment of rant or other charges. C] Yes] No Verifications required for issuance of summons—residential (Code Civ. Proc., § 1179.11(@)) 2. | this action based, in whole or in part, on a defendant's nonpayment of rent or other financial ebligation during the period between March 1, 2020, and March 31, 20227) Yes No. {if no is checked, no further Hems need fo be completed excep! the signature and verification on page 8, and item 12 ifthe ction s based in whole or in parton nonpayment of rent during some other time lrame; a summons may be issued.) b. Is this action on a tenancy that was intially established before October 1.20217 C] Yes] No {ifno is checked, the further lems inal need (0 be completed are th signature and veriftcation on page 8, and tems 10 or 11, Sand 12 I'he action Is based in whole orn part on nonpayment of ren a summons may be issued. (See Code Civ. Proc. §1179.09(h) 0 loam more about what “inaly establshod” means.) ‘epapaeinvancy oe PLAINTIFF'S MANDATORY COVER SHEET AND Cetera cman iT et wes 20) SUPPLEMENTAL ALLEGATIONS—UNLAWFUL DETAINER ae up-101 DEFENDANT: QUEEN SEARLES, et al PLAINTIFF: REGUS MANAGEMENT GROUP, LLC ‘CASE MER 4 3. . If you answered yes to questions 3a and 3b above, check and complete (1), (2), or (3) below, or a summons may not be issued. (1) Z There is no determination pending on an application filed before Api 1, 2022, for governmental rental assistance to ‘cover any part of the rental debt demanded from the defendant in this ection (2) 1) Before ting the complaint in this action, plant applied for governmental rental assistance to cover the rent or other fancialebigatons damanded ns schon, be appcsion nos dene and sae ¢ Sakae the assistance is attached. o ‘Note that a inal decision” does not include rejection based on plain not completing the application or doing so Correctly, notification that the application is pending further action, or notifiation that paint or defendants applied to the wrong government agency. (Code Civ. Proc, § 1179.09(d),) (3) D1 Before fling the complaint n this action, plain completed an application for governmental renal assistance to cover the rent or other financial obligations demanded inthis action, including all the required contact information and ‘documentation, and all of the following are true: (2) Atleast 20 days have passed since the later of either (check ane): D_The date the plaintiff submitted the completed application, or D__ The date the plaintf served the three-day notice underlying the complaint. and {b) Plaintiff has not received any notice from the governmental agency to which defendant has applied for governmental Fental assistance to cover the rent or other financial obligations demanded from the defendant in his action. and (©) Plaintif has not received a communication from the defendant that defendant has applied for governmental rental assistance to cover the rent or other financial obligations demanded from the defendant inthis action. 4, Tenants subject to COVID-19 Tenant Relief Act (Code Civ, Proc.,§ 1179.02{h)) (1) One or more defendants in this action is a natural person: [J] Yes [] No (2) Identify any defendant not a natural person: (if no is checked, then no further items need to be completed except the signature and verification, and item 12.f the action is based on nonpayment of rent.) ». (1) All defendants named inthis action maintain occupancy as described in Civil Cade section 1940(): LC] Yes C) No (2) Identity any defendant who does not: (if yes is checked, then no further items need to be completed except the signature and verification, and item 12 ifthe action is ‘based on nonpayment of rent.) 5. C1) Unlawful detainer notice expired before March 1, 2020 ‘The unlawful detainer complaint n this action is based solely on a notice to qui, to pay or quit, oF to perform covenants or uit in which the time period spectied in the notice expired before March 1, 2020, if his i the only basis for he action, no Turther tems need to be completed except the signature and verification on page 6. (Code Civ. Proc., § 1178,03.5(2\1).)) 6. C2 Rentor other financial obligations due between March 1, 2020, and August 31, 2020 (protected time period) “The unlawful detainer complaint in his ation is based, a least in pat on a demand for payment of rent or cher facial obligations due in te protected tme period, (Check al nat apply) 2. Cl Detendant (name each): was provided al the required versions of the “Notice rom the State of California" required by Code of Civil Procedure section ‘{779.08. (Provide information regarding service ofthe natee or notices in tem @ below) b. (Defendant (name oach): 1 served with atleast 15 days! notice to pay rent or other fanclal obligations, quit or deliver a declaration, and an unsigned ee i te onto rolled nancial vsti fom and wih Content rare in Code f GM Procaauevacoon 41179.03(0) and (). tied defendent as @ high-income tenant and requested submission of documentation supporting any Fie tet saondanl sunita, compte om © below, (Cade Gv. Proc. § 117802.) 100 with this form and item 6b ls checked, speci ths 15:dey notice In tm 94(7) on form UD-100. attach i to tical compat form, and prove a requested horton abot service on tat an) Tee PLAINTIFF'S MANDATORY COVER SHEET AND wets ‘SUPPLEMENTAL ALLEGATIONS—UNLAWFUL DETAINER 37 up-101 PLAINTIFF: REGUS MANAGEMENT GROUP, LLC. CASE NUWER DEFENDANT: QUEEN SEARLES, et al. 6. 6. Response to notice (check all hat apply) (1) 0 Defendant (name each): delivered a declaration of COVID-19-related financial distress on landlord in the time required. (Code Civ. Proc., § 1179.03(0,) (2) 0 Defendant (name each): did not deliver a declaration of COVID-19-related financial distress on landlord in the time required. (Code Civ. Proc., § 1179.03(9,) 7. O_ Rent or other financial obligations due between September 1, 2020, and September 30, 2021 (the transition time period) The unlawful detainer complaintn this action fs based, at least in part, on a demand for payment of rent or other financial obligations due during the transition time period. a. 1 Defendant (name each) \was provided all the required versions of the "Notice from the State of Califomia" as required by Code of Civil Procedure section 1179.04. (Provide information regarding service of the notice or notices in item 8 below.) b. C1) Defendant (name each): was served with at least 15 days’ notice to pay rent or other financial obligations, qui, or deliver @ declaration, and an unsigned declaration of COVID-19-related financial distress, in the form and with the content required in Code of Civil Procedure section 1179,03(c) and (4), (if the notice identifed defendant as a high-income tenant and requested submission of decumentation supporting any ‘declaration the defendant submits, complete item 9 below. (Code Civ. Proc., § 1179.02.5(c).)) [if fing form UD-100 with this form and item 7b is checked, specity this 15-day notice in item 9a(7) on form UD-100, attach {copy of the notice to that complaint form, and provide all requested information about service on that form.) «. Response to notice (check al hat app) (1) D1 Defendant (name each) delivered a declaration of COVID-19-elated financial stress onthe landlord inthe time required. (Code Civ. Pro.. § 1170090) (2) Defendant (name each: {id not deliver a declaration of COVID-19-relaled financial distress on the landlord in the time required. (Code Civ. Proc. § 1179.0300.)) ¢. 1 Rentor other financial obligations due: (1) Rent or other financial obligations in the amount of $ was due between September 1, 2020, and ‘September 30, 2021. (2) Payment of § {for hat period was received by September 30, 2021. 8. Service of Code of Civil Procedure Section 1179.04 Notice from the State of California (You must complete this item if you ‘checked item 6 or 7 above. Section 1179.04 provides three separate versions of a “Notice from the State of Califorma” thatthe landlord was to provide to tenants at diferent times during the pandemic (the notices referenced in items 6a and 7a above). This lem addresses when and how those notices were provided.) a. September 2020 Notice. Plain provided the required notice for tenants who, as of September 1, 2020, had any unpaid rent ‘of other financial obligations due any time between March 1, 2020, and August 31, 2020 (Code Civ. Proc, § 1179.04(a)) 10 ‘defendants identified in 6a or as folows: (1) D0 By sending a copy by mall addressed to each named defendant on (date): (2) © Bypersonally handing a copy to each named defendant on (date) Tororo nea e202) PLAINTIFF'S MANDATORY COVER SHEET AND Cry SUPPLEMENTAL ALLEGATIONS—UNLAWFUL DETAINER up-101 PLAINTIFF: REGUS MANAGEMENT GROUP, LLC CASE NUMBER DEFENDANT: QUEEN SEARLES, et al - a. (3) By some other method of service described in Code of Civil Procedure section 1162, (if this box is checked, describe ‘the method and date of service on an attached page (you can use form MC-025) and tite it Attachment Ba.) (4) C1 In diferent ways for diferent defendants, this box is checkod, describe the method and dete of service for each defendant on an attached page (you can use form MC-025) and tte it Attachment 8a.) (81D) _Piaintit was not requited to serve the September 2020 notice on the named defendants. b. February 2021 Notice, Plaintif provided the required notice for tenants who as of February 1, 2021, had unpaid rent or other fancial obligations due any ime after March 1, 2020, (Code Civ. Proc., §1178,04(0) to defendants identified in 6a and 7a as follows (1) Bysending a copy by mail addressed to each named defendant on (date): (2) By personally nanding a copy to each named defendant on (date) (3) By some other method of service described in Code of Civil Procedure section 1162, (if this box is checked, describe ‘the method and date of service on an attached page (you can use form MC-025) and tive it Attachment 6b.) (4) C1 Inciflerent ways for diferent defendants. (this box is checked, describe the method and date of service for each {defendant on an attached page (you can use form MC-026) and tte it Attachment Bb) (5) D__ Plaintiff was not required to serve the February 2021 notice on the named defendants, July 2021 Notice. Plaintiff provided the required notice for tenants who as of July 1, 2021, had unpaid rent or other financial obligations due any time after March 1, 2020, (Code Civ. Proc., § 1179,04(c) to defendants identified in 6a and 7a as folows. (1) By sending a copy by mail addressed to each named defendant on (date): (2) O__ By personally handing @ copy to each named defendant on (date) (3) 0) By some other method of service described in Code of Civil Procedure section 1162. (If this box is checked, describe ‘he method and date of service on an attached page (you can use form MC-028) and tte it Attachment &c.) (4) C1 Indifferent ways for diferent defendants. (If this box is checked, describe the method and date of service for each defendant on an attached page (you can use form MC-025) and tile it Attachment 8c) (5) C1) Plaintif was not required to serve the July 2021 notice on the named defendants C_High-income tenant. The 15-day notice in item 6b or 7b above identified defendant as a high-income tenant and requested ‘submission of documentation supporting the tenant's claim that tenant had suffered COVID-19-related financial distress. Plaintif had proof before serving that notice that the tenant has an annual income that is at least 130 percent of the median income for the county the rental property is located in and not less than $100,000, (Code Civ. Proc., § 1179.02.5,) 2.) The tenant did not deliver a deciaration of COVID-19-related financial distress within the required time. (Code Civ. Proc., § 1179.03(9.) b. (1) The tenant did not deliver documentation within the required time supporting that the tenant had suffered COVID-19- ‘elated financial distress as asserted in the declaration, (Code Civ, Proc., § 1179.02.5(c).) C._ Rent or other financial obligations due between October 1, 2021, and March 31, 2022 (recovery peried rental debt). The unlawful detainer complaint in this action is based, a least in part, on a demand for payment of rent or other financial obligations due during the recovery period. (Check a or b) a.) _ Defendant (name each): was served with at least 3 days' notice to pay rent or other financial obligations or quit, na notice that included the information, about the government rental assistance program and possible protections, as required by Code of Civil Procedure section 1179.10. tach a copy of Ui ing form UD-100 with hs form and tis item is check, spec this note in tm 9(7) on form UD-100, the notes tel complaint form, and provide a requested hermaton about service on that fom) >. 0) The tenancy was not intaly stabished before October 1, 2021, and te special notice to qul required by Code of Ca Procedure section 1178.10 does not apply inthis action, (Rev pon 16 2022) PLAINTIFF'S MANDATORY COVER SHEET AND Praneots ‘SUPPLEMENTAL ALLEGATIONS—UNLAWFUL DETAINER at up-101 PLAINTIFF, REGUS MANAGEMENT GROUP, LLC ‘CASE NBER DEFENDANT: QUEEN SEARLES, et al. 11.0. Rentor otor financial obligations du after March 31, 2022. (Only applicable acter fled on or after Api 1, 2022.) Font etemand ferent or eter nancial abligallons on which he unit dtaner complaint n is acton is based is a ent due afler March 31, 2022. ince (Required in all actions based on nonpé “questions inthis tem and, iflater seeking @ defaut jut Verieation Regarding Rental Assistance—Unlawul Detainer (form UD-120),) a. Hos plist eceved renal assistance o other nancial compensation rom anyother source corespondin 1 the amount demanded in the notice underlying the complaint? C] Yes OJ No b.. Has plant received rental assistance or other financial compensation from any oth the notice underlying the complaint? C] Yes [No oes plan have any pending application for rental assistance or other nancial compensation from any other source core ponding to the amount demanded in the notice underyng the complaint? C] Yes Bl No 4. Does plant have any pending application for rental assslance or other fnancal compensation from any other source for rent acoruing aferthe date on the notice underying the complaint’? C] Yes Bx] No 13. (0. Other allegations Pant makes the folowing addtional alegetions: (State any adonal alegations below, wi each (6), ete If there is not enough space below, check the box below and use allegation lettered in order, starting with (a), (2), font0-025, tle t Attachment 13, and letter each allegation in order.) [_] Other allegations are on form MC-025. demand for payment of 12. (Statements regarding rental assistar obligation. Plaintiff must answer al the sayment of rent or any other financial idgment, will also need to file er source for rent accruing after the date of +14, [3] Number of pages attached (specify): 1 - Exhibit A which is Plaintiff's Verification ete: August 16,2022 i, ( Jed White » Toe NTT Ys anTRe INTIT RATORET { VERIFICATION (Use @ diferent verfeaton form ifthe verification Is by an attomey or fr a corporation or partnership) | am the plaintif in this proceeding and have read this complaint. | declare under penalty of perjury under the laws ofthe State of California thatthe foregoing is true and correct. Date: Tire on PANTIE) ean) PLAINTIFF'S MANDATORY COVER SHEET AND Pransets Corer a 2) ‘SUPPLEMENTAL ALLEGATIONS—UNLAWFUL DETAINER 4O EXHIBIT A XERIEICATION NP wo make this Veriation fo, jon hichalfof, plaingf Regos Managemen Group, LLC. Thave read the foregoing document entitled VERIFIED COMPLAINT FOR UNLAWFUL DETAINER, anil know its contents, Lam iaformed and believe, and on that ground allege, that the factual matters stated in dhe foragoing document are true and correct to the best of knowledge based upon ny review af business records. However, I make no assertion as to the any legal contentions oy cnnelusions contained in the foregoing document declare under penaly of perjury under the laws ofthe State of Californi thatthe foregoing foe spe ue and cone scutes TZ ayo us 2022 0» Crbendh@h carr NTAWFUL DETAINER : CONMTAINT TORT

You might also like