IN THE SUPERIOR COURT OF FULTON COUNTY

STATE OF GEORGIA
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) CIVIL ACTION
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) FILE NO.: _______________
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FAROKH MAZAHERY,
Plaintiff,
v.
BEST DEAL MOVERS, L.L.C.,
ERROL VANNOY, AND
JOHN DEWAYNE PERRY,
Defendant.

COMPLAINT
COME NOW Plaintiff, Farokh Mazahery, and state his claims against Defendants Best
Deal Movers, L.L.C., Errol Vannoy, and John Dewayne Perry as follows:
PARTIES, JURISDICTION, AND VENUE
1.
Plaintiff is a resident of Forsyth County, Georgia.
2.
Defendant Best Deal Movers, L.L.C. is a Domestic Limited Liability Company operating
in Georgia. Best Deal Movers, L.L.C.'s principal place of business is 1360 Union Hill Road,
Suite 2F, Alpharetta, Georgia 30004. Best Deal Movers, L.L.C. can be served by delivering a
copy of this Complaint and Summons to its Registered Agent, Thomas L. Becker at 1360 Union
Hill Road, Suite 2F, Alpharetta, Forsyth County, Georgia 30004.

pg. 1

3.
Defendant Errol Vannoy is a resident of Fulton County, Georgia. Errol Vannoy can be
served by delivering a copy of this Complaint and Summons to him at 2311 Sandcove Court,
SW, Atlanta, Georgia 30331-8742.
4.
Defendant John Dewayne Perry is a resident of Dekalb County, Georgia. John Dewayne
Perry can be served by delivering a copy of this Complaint and Summons to him at 979 Park
Gate Place, Stone Mountain, Georgia 30083-2665.
5.
Venue in the above-styled civil action is proper in this County and Court.
6.
Defendant Best Deal Movers, L.L.C. is a moving company.
7.
Defendant Best Deal Movers, L.L.C. had hired Defendant John Dewayne Perry as an
employee.
8.
Defendant Best Deal Movers, L.L.C. had hired Defendant Errol Vannoy as an employee.
9.
Plaintiff and Defendant Best Deal Movers, L.L.C. contracted for Defendant Best Deal
Movers, L.L.C. to move certain items for Plaintiff.
10.
Defendant Best Deal Movers, L.L.C. contracted to supply moving vehicles and workers
to relocate items for Plaintiff from one resident to another.

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11.
On September 12, 2016, Defendant Errol Vannoy and Defendant John Dewayne Perry
arrived at Plaintiffs place of residence to move items on behalf of Defendant and for Plaintiff.
12.
While on Plaintiffs Property, Defendant Errol Vannoy and Defendant John Dewayne
Perry took fifteen (15) bottles of 2007 V. Sattui Winery Cabernet Sauvignon (red wine).
13.
Plaintiff had purchased each bottle of wine for $250.00 (total of $3,750.00) plus tax and
shipping costs.
14.
Defendant Errol Vannoy and Defendant John Dewayne Perry took the wines with
intention of depriving Plaintiff of the property, in violation of O.C.G.A. Section 16-8-2.
15.
Based on information and belief, Defendant Best Deal Movers, L.L.C. knew or should
have known of Defendant Errol Vannoy and Defendant John Dewayne Perrys criminal history,
propensity for theft, and Defendant Errol Vannoy and Defendant John Dewayne Perrys
intention to take property from Plaintiff.
16.
Defendant Best Deal Movers, L.L.C. instructed Defendants Errol Vannoy and John
Dewayne Perry to take Plaintiffs property.
17.
Defendant John Dewayne Perry has been convicted for Felony Entering Auto (O.C.G.A.
Section 16-8-18).

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18.
Defendant Best Deal Movers, L.L.C. negligently hired, retained, and supervised
employees.
19.
Defendant Best Deal Movers, L.L.C.s negligence caused Plaintiff property damage in
the amount of $3,750.00.
20.
Defendants converted Plaintiff's Property, thereby committing tort of Conversion.
21.
Defendants trespassed to Plaintiff's chattel.
22.
Defendants were unjustly enriched.
23.
In addition of actual costs of the property, Plaintiff is entitled to a judgment against
Defendants in the amount of $11,250.00 for liquidated exemplary damages.
24.
Plaintiff is entitled to recover damages in accordance with Georgia statutory laws
including but not limited to O.C.G.A. Section 51-10-6.
25.
Plaintiff is entitled to recover Punitive Damages against Defendants.
26.
In addition, Plaintiff is entitled to recover attorney fees and costs of litigation.

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RELIEF
WHEREFORE, Plaintiff prays for relief in the following manner:
a. that process issue and the Summons and Complaint be served upon the Defendants as
prescribed by law;
b. Plaintiff be granted trial by full panel of jury;
c. that the Court enter a finding against Defendants for Plaintiff on all counts;
d. that this Court Grant Plaintiff damages for expenses in an amount not less than
$7,909.30;
e. that this Court Grant Plaintiff exemplary and punitive damages;
f. that Plaintiff be granted costs of litigation for being forced to bring this action;
g. that Plaintiff be awarded pre-judgment and post-judgment interests in amounts
allowable by law;
h. that Plaintiff be granted reasonable and customary attorneys fees for being forced to
bring this action; and
i.

that Plaintiff be granted such other and further relief as the Court deems just,
equitable, and proper.

This 30th day of December, 2016.

/s/ Saeed S. Mahallati
SAEED S. MAHALLATI
Georgia Bar # 701652
Attorney for Plaintiff

The Law Office of Saeed Mahallati, LLC

904 Macy Drive
Roswell, Georgia 30076
Phone: 678-404-1231
Facsimile: 678-701-1712
Email: smahallati@mrlawman.com

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