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Brian Jacobson, Esq. SBN 310869 W $7


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Jacobson Law 4,04b10440
2 7424 Cliffside Ct. ir tY PIP'"
(k 1:;
3 West Hills, CA 91307
APR 1 0 2017
Telephone (818) 314-2010 Sham R.
4 thebmj@gmail.com
' alive Officer/Clerk
5 Attorney for Plaintiff: Carmello Iglesias Dewar

6 SUPERIOR COURT OF THE STATE OF CALIFORNIA


7
FOR THE COUNTY OF LOS ANGELES
8
CARMELO IGLESIAS ' CASE NO.
9 BC65719
Assigned to Dept.
10
Plaintiff,
11 VERIFIED COMPLAINT
v. 1. MALICIOUS PROSECUTION
12 ) 2. ASSUALT
MAZGANI SOCIAL SERVICES, INC, A ) 3. BATTERY
13 CALIFORNIA CORPORATION, ) 4. FALSE IMPRISONMENT
MAHVASH MAZGANI, NEVAZ ) 5. INTENTIONAL INFLICTION OF
14
MAZGANI, AND DOES 1 THROUGH 25, ) EXTREME EMOTIONAL
15 INCLUSIVE, ) DISTRESS
)
16 Defendants )
)
17
)
18 )
)
19 )
20

Plaintiff, Carmelo Iglesias, alleges, follows:

PARTIES
24 I. Plaintiff is Carmelo Iglesias, a resident of the County of Los Angeles is suing in his individual

25 capacity

26 2. Defendant Mazgani Social Services, Inc., ("MSS") is a company formed under the laws of the

27 State of California and doing business in the City and County of Los Angeles.

28

1
1 3. Defendant Mahvash Mazgani is an individual who resides in the County and City of Los
2 Angeles and is the President of Co-Defendant Mazgani Social Services, Inc.

3 4. Defendant Neyaz Mazgani is an individual who resides in the County and City of Los Angeles

4 and is the Chief Financial Officer of Co-Defendant Mazgani Social Services, Inc.

5 5. The true names and capacities of cross-defendants DOES 1 through 25, inclusive, are unknown

6 to Complainant, who therefore sues said cross-defendants by such fictitious names pursuant to

7 California Code of Civil Procedure section 474. Complainant is informed and believes and thereon
alleges that each of the defendants designated herein as "DOE" is legally and/or equitably responsible
8
in some manner for the events, transactions, occurrences, and happenings alleged herein. The
9
complainant will seek leave of the court to amend this Complaint when said true names and capacities
10
have been ascertained.
11
JURISDICTION AND VENUE
12
6. This Court has jurisdiction over this action pursuant to California Code of Civil Procedure
13
section 410.10.
14
7. This action arises under California law, and the amount in controversy exceeds $25,000.00.
15
8. The venue is proper in this Court because all of the material events and transactions giving rise
16
to this action took place in Los Angeles County.
17
GENERAL FACTUAL ALLEGATIONS
18
9. On April 3, 2017, responding to an advertisement on www.craigslist.com for a "SIGN
19
HOLDER", the Plaintiff is hired to hold a sign and pass out flyers outside of MSS. MSS is located at
20
1110 South Robertson, Los Angeles, CA 90035. A copy of the www.craigslist.com advertisement is
21
attached hereto and incorporated herein by reference as Ex. A.
22 10. Plaintiff applied for the job because he needed the money and the advertisement was for
23 picketing a business that victimizes the elderly and the disabled. Stopping the victimization of the
24 elderly and the disabled are causes that Plaintiff himself identifies with and fully supports, and he
25 undertook the task both as an advocate and as an independent contractor.
26
27
28
VERIFIED COMPLAINT
1 11. On April 4, 2017, at 10:30 a.m. Plaintiff was paid $30.00 and given the sign to wear around his
2 neck and flyers to hand out. A copy of the sign that Plaintiff had tied to his neck at all relevant times

3 is attached hereto and incorporated herein by reference as Ex. B.

4 12. A picture of the Plaintiff holding up the sign outside of the MSS located at 1110 South

5 Robertson, Los Angeles, CA 90035, is attached hereto and incorporated herein by reference as Ex. C.
13. The sign that Plaintiff wore on his was 3 feet across and 4 feet long.
6
14. On April 4, 2017, at or about 11:42 a.m., while standing outside of the MSS Defendant
7
Mahvash Mazgani offered the Plaintiff money to abandon his sign and leave his picketing.
8
15. On April 4, 2017, at or about 11:42 a.m., while standing outside of the MSS, Defendant
9
Mahvash Mazgani runs towards' the Plaintiffs person, and proceeds to physically grab the sign that is
10
around Plaintiffs' neck, and then attempts to pull the sign away from the neck of the Plaintiff. The
11
sign was held in place by heavy twine, and did not tear away from the neck of the Plaintiff, but instead
12
jerked down his skull, in the style of a guillotine, several times.
13
16. On April 4, 2017, at or about 11:43 a.m., Defendant Neyaz Mazgani and Mahvash Mazgani
14
surrounded the Plaintiff and obstructed his movement on the sidewalk. Neyaz and Mahvash's
15 obstruction of Plaintiff left him unable to escape, and Defendants refused to get out of Plaintiffs way
16 when Plaintiff asked them to do so.
17 17. On April 4, 2017, Defendant Neyaz Mazgani began verbally assaulting the Plaintiff with
18 derogatory words and told the Plaintiff "I am going to ruin your life."
19 18. On April 4, 2017, Defendant Neyaz Mazgani called the Los Angeles Police Department and
20 falsely told the police that Plaintiff had threatened her life and that she was in fear for her life.

21 19. On April 4, 2017, at or about 12:28 a.m., while standing outside of the MSS, Defendant

22 Mahvash Mazgani vouched for Neyaz Mazgani's false accusations to Los Angeles Police Department

23 ("LAPD"). LAPD then arrested Plaintiff at the request of Neyaz Mazgani, Mahvash Mazgani, and

24 MSS.
20. On April 4, 2017, Plaintiff was taken into LAPD custody and transported to Los Angeles
25
Metropolitan Detention Center and charged with Cal Penal Code 422 and held on $50,000.00 bond.
26
21. On April 6, 2017, all charges were dropped by the District Attorney's Office, and Plaintiff was
27
freed after spending over 48 hours in custody.
28
VERIFIED COMPLAINT
1 22. At all times, relevant hereto, Mahvash Mazgani was acting personally and as an agent for
2 MSS.

3 23. At all times, relevant hereto, Neyaz Mazgani was working individually and as an agent for

4 MSS.

5
FIRST CAUSE OF ACTION FOR MALICIOUS PROSECUTION
6
(AGAINST MAHVASH MAZGANI, NEYAZ MAZGANI, AND MAZGANI SOCIAL SERVICES,
7
8 INC. DOE 1-25)

9 24. Plaintiff incorporates by reference the allegations of paragraphs 1-23, supra, as fully set forth
10 herein.
11 25. Defendant and Mazgani Social Services, Inc, Mahvash Mazgani, and Neyaz Mazgani actively
12 instigated for Plaintiff to be falsely prosecuted for allegedly violating Penal Code 422 (making
13 criminal/terrorist threats).
14 26. Neyaz Mazgani falsely reported on April 4, 2017, to the LAPD, that Plaintiff had threatened

15 her life and that she was in fear for her safety and life. When the LAPD officers arrived at the MSS,

16 Defendant Mahvash Mazgani falsely reported to the LAPD that she had heard Plaintiff make the

17 threats that Neyaz Mazgani.


27. Defendant's falsely reporting of Plaintiff was caused by an unlawful purpose to cause Plaintiff
18
to abandon his Constitutionally permitted rights to free speech, picketing, and free assembly.
19
28. On April 4, 2017, Defendants instigated criminal proceedings against based on his arrest on
20
these false charges.
21
29. The Plaintiff never said a word to the Defendants other than "Please move out of my way"
22
when they were blocking his movement and blocking the view of the sign that was hanging from
23
Plaintiffs neck.
24
30. No reasonable person would have caused the false arrest of Plaintiff, which lead to his
25
Plaintiffs malicious prosecution.
26 31. Defendants Mahvash Mazgani, Neyaz Mazgani, and MSS acted primarily for a purpose other
27 than to bring Plaintiff to justice. To this point Defendant specifically told the Plaintiff "I am going to
28
VERIFIED COMPLAINT
1 ruin your life." The conduct of Defendants Mahvash Mazgani, Neyaz Mazgani, and MSS was geared
2 to shut down the First Amendment Rights of the Plaintiff.

3 32. On April 6, 2017, the criminal proceedings against Plaintiff terminated after all charges were

4 dropped by the District Attorney's Office.

5 33. Plaintiff suffered emotionally and physically when he was incarcerated for over 48 hours.

6 34. The acts of Defendants Mahvash Mazgani, Neyaz Mazgani, and MSS were the sole cause of
the harm that Plaintiff suffered.
7
35. Defendant's conduct in having the Plaintiff wrongfully arrested and prosecuted on false
8
charges is grounds to find that Defendant's should be held liable for punitive damages pursuant to
9
Civil Code 3294.
10 SECOND CAUSE OF ACTION FOR ASSAULT
11
(AGAINST MAHVASH MAZGANI, NEYAZ MAZGANI, AND MAZGANI SOCIAL
12
SERVICES, INC. DOE 1-25)
13
14 36. Plaintiff incorporates by reference the allegations of paragraphs 1-23, supra, as fully set forth

15 herein.

16 37. On April 4, 2017, at or about 11:42 a.m., while Plaintiff was standing outside of MSS

17 picketing, Defendant Mahvash Mazgani ran towards' the Plaintiffs person.


38. At no time did Plaintiff consent to Defendant's actions.
18
39. Mahvash Mazgani then proceeded to grab the sign that is around Plaintiffs' neck physically
19
and attempted to pull away from the sign away from the neck of the Plaintiff. The sign was held in
20
place by heavy twine and did not tear away from the neck of the Plaintiff, but instead jerked down his
21
skull in the style of a guillotine several times.
22
40. Plaintiff was placed in reasonable apprehension that he was about to be touched in an offensive
23
manner.
24
41. Any reasonable person would perceive being rushed by a person and then having a sign
25
unsuccessfully yanked from their neck causing his skull to jerk down several times, as a harmful or
26 offensive contact.
27
28
VERIFIED COMPLAINT
1 42. Plaintiff suffered emotionally and physically when he was subjected to being placed in fear of
2 a harmful touching.
43. The acts of Defendants Mahvash Mazgani, Neyaz Mazgani, and MSS were the sole cause of
3
4 the harm that Plaintiff suffered.

5 44. Defendant's conduct in having assaulted Plaintiff is grounds to find that Defendant's should be

6 held liable for punitive damages pursuant to Civil Code 3294.


7 THIRD CAUSE OF ACTION FOR BATTERY
8
(AGAINST MAHVASH MAZGANI AND MAZGANI SOCIAL SERVICES, INC. DOE 1-
9
25)
10
11 45. Plaintiff incorporates by reference the allegations of paragraphs 1-44, supra, as fully set forth

12 herein.

13 46. On April 4, 2017, at or about 11:42 a.m., while Plaintiff was standing outside of MSS

14 picketing, Defendant Mahvash Mazgani runs towards' the Plaintiffs person.

15 47. Mahvash Mazgani then proceeded to grab the sign that is around Plaintiffs' neck physically,
and attempted to pull away from the sign away from the neck of the Plaintiff. The sign was held in
16
place by heavy twine and did not tear away from the neck of the Plaintiff, but instead jerked down his
17
skull, in the style of a guillotine, several times.
18
48. At no time did Plaintiff consent to this touching.
19
49. Plaintiff suffered emotionally and physically when he was subjected having his neck and head
20
yanked around as a result of Mahvaash Mazgani attempting to jerk the sign away from his person.
21
50. Any reasonable person would perceive being rushed by a person and then having a sign
22
unsuccessfully yanked from their neck causing his skull to jerk down several times, as a harmful or
23 offensive contact.
24 51. The acts of Defendants Mahvash Mazgani, on behalf of MSS were the sole cause of the harm
25 that Plaintiff suffered.
26 52. Defendants conduct in having battered Plaintiff is grounds to find that Defendant's should be
27 held liable for punitive damages pursuant to Civil Code 3294.
28
VERIFIED COMPLAINT
1
FOURTH CAUSE OF ACTION FOR FALSE IMPRISONMENT
2
3 (AGAINST MAHVASH MAZGANI, NEYAZ MAZGANI AND MAZGANI SOCIAL

4 SERVICES, INC. DOE 1-25)

5
53. Plaintiff incorporates by reference the allegations of paragraphs 1-52, supra, as fully set forth
6
herein.
7
54. Mahvash Mazgani, Neyaz Mazgani and MSS, intentionally deprived Plaintiff of his freedom of
8
movement by use of physical barriers, force, threats of force, menace, unreasonable duress and by
9 summoning the police for a false complaint that Plaintiff had threatened the life of Neyaz Mazgani.
10 55. Plaintiff had not said a word other than "Please get out of my way" to anyone while lawfully
11 picketing on the sidewalk in the City of Los Angeles and handing out flyers that complained about the
12 business practices of the Defendants.
13 56. That Defendant's restraint, confinement, and detention of Plaintiff compelled Plaintiff to stay
14 blocked into a position between the wall and the physical barrier that the Defendants had erected with

15 their bodies until the police appeared and for an appreciable amount of time.

16 57. The conduct of Mahvash Mazgani, Neyaz Mazgani, and MSS, was a substantial factor in

17 causing Plaintiff harm.


58. The conduct of Mahvash Mazgani, Neyaz Mazgani, and MSS, was malicious and done with
18
the intent to extinguish the right of the Plaintiff to lawfully picket and led to an unjust imprisonment
19
of him on false charges for over 48-hours in jail. To this point Defendant specifically told the Plaintiff
20
"I am going to ruin your life."
21
59. The conduct is richly deserving of punitive and exemplary damages against the Defendants
22
and each of them in an amount to be proven pursuant to Civil Code 3294.
23
24
FIFTH CAUSE OF ACTION FOR INTENTIONAL INFLICTION OF EXTREME
25
EMOTIONAL DISTRESS
26
(AGAINST MAHVASH MAZGANI, NEYAZ MAZGANI, AND MAZGANI SOCIAL
27
SERVICES, INC. DOE 1-25)
28
VERIFIED COMPLAINT
1 60. Plaintiff incorporates by reference the allegations of paragraphs 1-59, supra, as fully set forth
2 herein.

3 61. On April 4, 2017, at or about 11:42 a.m., while standing outside of the MSS, Defendant

4 Mahvash Mazgani ran towards' the Plaintiffs person and proceeded to physically grab the sign that is

5 around Plaintiffs' neck and pull away from the sign away from the neck of the Plaintiff. The sign was

6 held in place by thick twine and did not tear away from the neck of the Plaintiff, but instead jerked
down his skull, in the style of a guillotine, several times.
7
62. On April 4, 2017, at or about 11:43 a.m., Defendant Neyaz Mazgani and Mahvash Mazgani
8
surrounded the Plaintiff and obstructed his movement on the sidewalk. Neyaz and Mahvash's
9
obstruction of Plaintiff left him unable to escape, and these Defendants refused to get out of Plaintiffs
10
way when Plaintiff asked them to so.
11
63. On April 4, 2017, Defendant Neyaz Mazgani called the Los Angeles Police Department and
12
falsely told the police that Plaintiff had threatened her life and that that she was in fear for her life.
13
64. On April 4, 2017, at or about 12:28 a.m., while standing outside of the MSS, Defendant
14
Mahvash Mazgani vouched for Neyaz Mazgani's false accusations to Los Angeles Police Department
15 ("LAPD"). LAPD then arrested Plaintiff at the request of Neyaz Mazgani, Mahvash Mazgani, and
16 MSS.
17 65. On April 4, 2017, Plaintiff was taken into LAPD custody and transported to Los Angeles
18 Metropolitan Detention Center and charged with Cal Penal Code 422 and held on $50,000.00 bond.
19 66. On April 6, 2017, all charges were dropped by the District Attorney's Office, and Plaintiff was
20 freed after spending over 48 hours in custody.

21 67. Defendant's actions in intentionally creating a false police report, leading to the arrest of

22 Plaintiff of terrorist charges in derogation of Plaintiff Constitutional rights to free speech, and

23 Plaintiffs resulting incarceration for 48 hours is "outrageous" conduct that is intolerable to a

24 reasonable and civilized person. To this point Defendant specifically told the Plaintiff "I am going to
ruin your life."
25
68. Defendant's intentionally caused Plaintiff to suffer extreme emotional distress in order to
26
prevent him from exercising his Constitutional rights and in retribution.
27
28
VERIFIED COMPLAINT
1 69. Plaintiff has suffered extreme emotional distress from Defendant's actions resulting in his false
2 arrest and incarceration for over 48 hours, as well as Defendant's actions resulting in malicious

3 prosecution, assault, and battery.

4 70. Plaintiff incorporates by reference the allegations of paragraphs 1-23, supra, as fully set forth

5 herein.

6 71. Defendant's conduct in having caused Intentional Infliction of Extreme Emotional Distress to
Plaintiff is grounds to find that Defendant's should be held liable for punitive damages pursuant to
7
Civil Code 3294.
8
WHEREFORE, Complainants, pray for judgment as follows:
9
a. For compensatory damages;
10
b. For punitive damages,
11
c. Injunctive Relief,
12
13 d. Compensation for pain and suffering, emotional trauma and duress,

14 e. For reasonable attorneys' fees and reimbursement of all costs for prosecution of this
15 action;
16
f. For such other and further relief as the Court deems just and appropriate.
17
JURY TRIAL REQUESTED
18
Plaintiffs hereby request a jury trial in this matter.
19
20
21 Respectfully submitted,
22
DATED: April 10, 2017
23
By:
24 Brian Jacobson
Attorney for Plaintiff
25
26
27
28
VERIFIED COMPLAINT
APR-10-2017 12:03 PM P.03

VERIFICATION
STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
I have read the foregoing VERIFIED COMPLAINT

and know its contents.


7 CHECK APPLICABLE PARAGRAPHS
all I am a party to this action. The matters stated in the foregoing document are true of my own knowledge except as to those
matters which are Stated on Information and belief, and as to those matters I believe them to be true.
I am 0 an Officer 01 a partner
of
a party to this action, and am authorized to make this verification for and on Its behalf, and I make this verification for that reason.
p I am informed and believe and on that ground allege that the matters stated in the foregoing document are true. 0The matters
stated in the foregoing document are true of my own knowledge except as to those matters which are stated on Information and
belief, and as to those matters I believe them to be true.
0 I am one of the attorneys for
a party to this action. Such party is absent from the county of aforesaid where such attorneys have their offices, and I make this
verification for and on behalf of that party for that reason. I am Informed and believe and on that ground allege that the matters
stated In the foregoing document are true.
Executed on 4/10/2017 , at Pasadena , California.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
`.
Carmelniglesias 614..
. :404 -J-
TYPO OR PRINT NAME SIGNATURE

PROOF OF SERVICE
lolSa (a) CCP Revised 2004
STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
I am employed In the county of , State of California.
I am over the age of 18 and not a party to the within action; my business address is:

On , I served the foregoing document described as

on In this action
0 by placing the true copies thereof enclosed In sealed envelopes addressed as stated on the attached mailing list:
0 by placing 0 the original 0 a true copy thereof enclosed in sealed envelopes addressed as follows:

BY mew.
I deposited such envelope In the mall at , California.
The envelope was mailed with postage thereon fully prepaid.
As follows: I am 'readily familiar with the firm's practice of collection and processing correspondence for mailing. Under
that practice it would be deposited with U.S. postal service on that same day with postage thereon fully prepaid at
California In the ordinary course of business. I am aware that on motion of the
party served, service is presumed Invalid If postal cancellation date or postage meter date is more than one day after date of
deposit for mailing In affidavit.
Executed on , at , California.
0 "(BY PERSONAL SERVICE) I delivered such envelope by hand to the offices of the addressee.
Executed on , at , California.
0 (State) I declare under penalty of perjury under the laws of the State of California that the above Is true and correct.
0 (Federal) I declare that I am employed in the office of a member of the bar of this court at whose direction the service was
made.

TYPE OP PRINT NAME SIGNATURE

MY SIONATURE MAT BE Off PERSON DEPOSITING ENVELOPE IN


MAIL SLOT, BOX, OR SAG)
.11,OR PERSONAL SERVICE SIGNATURE MUST Be THAT OF MESSENGER)

NONJC-015 (Rev. 01/01/2s1 I ) VERIFICATION/PROOF OF SERVICE


Iglesias Carmelo
EssiimAt Nut -
CL

reply Posted

SIGN HOLDER (ROBERTSON BETWEEN PICO AND OLYMPIC) (1110


Robertson Blvd)

41111111.0

Alaseptai Sersion and Slahranit Alaaposesi and her two kids


I Nero /ad Xtwanin 1 are financial ponlators who have rayed on
the pont and eldest,. Iranians tar too loop, Visit
%Acid:Ai klCANISI.IiVICFS.CONt to anointoostsly resider and
be helped to gel back: all sit Tour moots and In awarded penalties .

Ilemeter

I unite aro t`9,: Mai/gaol Social S.:RA:es Karr

;he IW %Pi alit dt at 1 .d lrairran fin det;;Oes mots and

tht3 rycn steal from rani] %fahi,,I*11 lazgarti ha, forrvor

charti.ckl the poor will ili,


ahlro Iranian, ihrupsaiNI,.. or dolt** to
maist lh4rri in goo Pl.! Slatii3! 4.110. N.:4N IT. 1111:0111IL It
ZS illegal to ttiaqic plc any thior to help them get Soria'
craigslist - Map data OpenStreetMal
Si:yin-11y in.iortii.s :11 oik rit t (demi Regti1;011q1:,..11.14. 721.11. ts)
120 ('114 faii4.1121.0i1
1110 South Robertson Blvd
trii hair Ihrrri a Okra . +ictiro ssl
thc Maryain C liu i plcas.c itnisrr..nroui13. conic to be t%cbalic of (=ogle map)
'42L' AZ)Ai trgi otir. mow. iirkl contact
inforinstion ideinity gill wart he ,
harisl ant rtati tstdl tic
asai l'ark all rafrrairronny,, anti ;LI perraltio.a6 compensation: $50 a day. Cash

Sign holder to complain about a business with bad business practice of ripping off the elderly and disabled.

NO EXPERIENCE NECESSARY AND NO SIGN SPINNING


Must be in good shape

Monday- Friday : 11:00-3:00 PM

Hiring immediately!!! $50 a day cash

The sign you will be wearing is less than a pound.

o do NOT contact me with unsolicited services or offers


Mazgani Social Services and Mahvash Mazgani and her two kids
(Neyaz and Nazanin) are financial predators who have prayed on
the poor and elderly Iranians far too long. Visit
WWW.MAZGANISERVICES.COM to anonymously register and
be helped to get back all of your money and be awarded penalties .
.......1111111111111.6.

The Mazgani Family and the Mazgani Social Services have


defrauded the poor and disabled Iranian for decades now and
they even steal from family. Mahvash Mazgani has forever
charged the poor and disabled Iranians thousands of dollars to
assist them in getting Social Security and Disability Income. It
is illegal to charge people anything to help them get Social
Security benefits. 20 Code of Federal Regulations 404.1720(b)
(20 CFR 404.1720(b)). If you have been a client / victim of
the Mazgani Clan please anonymously come to the website of
www.mazganiservices.com and register your name and contact
information. Your identity will never be shared and you will be
assisted to get back all of your money and get penalties as well.