1 Aperture Law Firm

Robert B. Salgado, Esq. (SBN 297391)
2 PO Box 17741
San Diego, CA 92117
3 Attorney for Plaintiff: Iraj Khosroabadi
4
ATTORNEY(S) FOR PLAINTIFF:
5
6 SUPERIOR COURT OF THE STATE OF CALIFORNIA
7 COUNTY OF ORANGE – CIVIL COMPLEX CENTER
8
) Case No.:
9 IRAJ KHOSROABADI, an Individual ) CX-102
)
10 Plaintiff, ) VERIFIED CLASS ACTION
) COMPLAINT FOR:
11 vs. )
MAZGANI SOCIAL SERVICES, INC, a ) 1. Intentional (Actual) Fraud (Cal. Civ.
12 )
California Corporation, MAHVASH Code §1572);
)
13 MAZGANI, NAZANIN MAZGANI, NEYAZ ) 2. Violation of the Unfair Business
MAZGANI, and DOES 1 through 25, ) Practices (Cal. B&P §17200);
14 inclusive, ) 3. Violation of the False Advertising Law
) (Cal. Bus. & Prof. Code §§ 17500, Et
15 Defendant(s) ) Seq.);
)
16 _____________________________________ ) 4. Breach of Fiduciary Duty (20 CFR
) 404.1705);
17 ) 5. California Consumers Legal Remedies
) Act;
18 )
6. Financial Elder Abuse (Welf.&Inst.
19 Code §§15610.30 & 15657.5;
7. Racketeer Influenced and Corrupt
20 Organizations Act (RICO).
21
EXPEDITED JURY TRIAL REQUESTED
22 PURSUANT TO CALIFORNIA ELDER
ABUSE STATUTES
23
24
25 INTRODUCTION
26 1. Iraj Khosroabadi (hereinafter “Plaintiff”), by and through his attorney of record,
27 brings this action on behalf of himself, and all others similarly situated, and the general public,
1
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28 against Defendants Mahvash Mazgani, Nazanin Mazgani, Neyaz Mazgani and Mazgani Social

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COMPLAINT
1 Services, a California registered corporation (entity # C2509317) and DOES 1 through 25,
2 inclusive (hereinafter, collectively referred to as “Defendants”).
3 2. Defendant Mazgani Social Services, INC. (hereinafter “MSSI”) is a California
4 registered corporation with at least one office at 1110 Robertson Blvd. #1, Los Angeles, CA
5 90035, that provides aid to Americans (mostly of Iranian descent) in applying for and receiving
6 Social Security, Disability and other benefits provided by the State of California and the United
7 States Federal Government. Exhibit F.
8 3. Plaintiff is informed and believes, and therein alleges that that Defendants illegally
9 charge for their services above and beyond the fees allowed by State and Federal Agencies and
10 engage in systematic and harassing billing practices long after their services have been provided.
11 JURISDICTION AND VENUE
12 4. Jurisdiction is conferred upon this Court because Defendants do business in this
13 judicial district, they hold themselves out and market to this jurisdiction, and they actually
14 conduct significant transactions in this jurisdiction. Under Plaintiff’s state law claims, more than
15 75% of those affected in the class (and perhaps an even greater percentage) are residents of the
16 State of California, such that on the state law claims alone, the Local Controversy Exception bars
17 Federal Courts from asserting jurisdiction under the Class Action Fairness Act. Supplemental
18 jurisdiction exists over the RICO causes of action.
19 5. This Court has original jurisdiction over the subject matter of this action pursuant to
20 18 U.S.C. §1964. This is a civil action seeking restitution, disgorgement of profits, injunctive
21 relief and other equitable relief under the California Unfair Competition Law (Business and
22 Professions Code §§ 17200 and 17500 et seq.); restitution, damages and injunctive relief under
23 the Consumer Legal Remedies Act (Civil Code § 1750 et seq.). This Court has subject matter
24 jurisdiction as the aggregate amount of the claims of all class members exceeds $25,000, and
25 personal jurisdiction over defendants under Code of Civil Procedure § 410.10, in that defendants
26 reside and/or do business in the State of California, or otherwise have the requisite minimum
27 contacts with the State such as to justify this Court exercising jurisdiction over them.
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28 6. This court has personal jurisdiction over the defendants pursuant to 18 U.S.C.

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COMPLAINT
1 §§1695(b), (d).
2 7. Venue as to each defendant is proper in this judicial district, pursuant to Business
3 and Profession Codes § 17203, Civil Code § 1780, and Code of Civil Procedure §§
4 392(a)(1), 395(a) and 395.5.
5 8. Plaintiff hereby asserts their demand for a jury trial and an expedited trial under
6 California elder abuse statutes.
7 9. Venue is proper in this Court because a substantial part of the events or omissions
8 giving rise to Plaintiff’s claims occurred here, a substantial part of the property that is the subject
9 of this action is situated here, and Defendants are subject to personal jurisdiction, in this District.
10 10. Defendant MSSI is subject to the jurisdiction of this Court. MSSI has been engaged
11 in continuous and systematic business in California, and most, if not all, of MSSI’s services are
12 provided in California.
13 11. Plaintiff is informed and believes, and therein alleges that each of the Defendants
14 named herein acted as co-conspirator, single enterprise, joint venture, or alter ego of, or for, the
15 other Defendants with respect to the acts, omissions, violations, representations, and common
16 course of conduct alleged herein, and ratified said conduct, aided and abetted, or is other liable.
17 Defendants have agreements with each other, and other unnamed co-conspirators and have
18 reached agreements to market and promote MSSI’s services and products as alleged herein.
19 12. Plaintiff is informed and believes, and therein alleges that Defendants have engaged
20 in systematic and ongoing victimization of mostly elderly first generation Iranians through
21 rampant and salacious violations of California State and federal law
22 THE PARTIES
23 13. Iraj Khosroabadi is a United States citizen residing in the County of Los Angeles.
24 14. Mahvash Mazgani is a natural person residing in the County of Los Angeles.
25 15. Nazanin Mazgani is a natural person residing in the County of Los Angeles.
26 16. Defendant Neyaz Mazgani is a natural person residing in the County of Los Angeles.
27 17. Defendant Mazgani Social Services, Inc., is a California corporation with its main
3
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28 office in the County of Los Angeles, and which has been organized under the laws of the State of

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COMPLAINT
1 California.
2 18. Plaintiff is ignorant of the true names and capacities of Defendants sued herein as
3 Does 1-25, inclusive and therefore sue these Defendants by such fictitious names. Plaintiff will
4 amend this complaint to allege their true names and capacities when they have been ascertained.
5 Plaintiffs are informed and believe that each of said fictitiously named Defendants are
6 responsible in some manner for the occurrences herein alleged, and that Plaintiffs’ injuries as
7 herein alleged were proximately caused by the acts and/or omissions of each.
8 OVERVIEW OF ALLEGATIONS
9 19. Plaintiff is informed and believes, and therein alleges that Defendants have engaged
10 in systematic and ongoing victimization of mostly elderly first generation Iranians through
11 rampant and salacious violations of state and federal law. Mahvash and her two daughters
12 Nazanin and Neyaz (hereinafter the “Mazgani Family”) provide their services directly to,
13 directly through, or for the pecuniary benefit of themselves, MSSI and the Law Offices of
14 Nazanin Mazgani 1. See also Exhibits C & E.
15 20. At its core, the Mazgani Family represents itself to be a “social services agency”.
16 MSSI’s advertisements are geared toward non-English speakers who primarily speak and read in
17 Farsi. As Exhibits A, B and C clearly demonstrate, not a single operative word is written in
18 English on either the full-page color advertisement or the half page black-and-white
19 advertisement.
20 21. The Mazgani Family primarily targets that segment of the Iranian-American
21 population who qualify for, or who are in need of, social services provided by the state and
22 federal governments. This population is primarily composed of disabled and the elderly
23 individuals who are a typically vulnerable and often isolated segment of the population. In this
24 case, the victims are even more vulnerable and isolated due to their inherent language barrier.
25 22. Obtaining benefits through social services, social security income (hereinafter “SSI”)
26 or social security disability (hereinafter “SSD”) is a complicated, form-laden process that many
27
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28 1
The Law Offices of Nazanin Mazgani list “Social Security Disability and SSI” as one of the practice areas. See
[http://mazganilaw.com/practice-areas/immigration/social-security-disability-and-ssi] (as of 03/09/2017 at 22:54).

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COMPLAINT
1 simply cannot navigate without some form of representation.
2 23. Plaintiff is informed and believes, and therein alleges that many of the Mazgani
3 Family’s victims are already desperate, and particularly susceptible to their aggressively bullish
4 tactics, often having to borrow large sums of money from friends and family to appease the
5 Defendants.
6 24. Plaintiff is informed and believes, and therein alleges that the Defendants are able to
7 quickly gain the trust and confidence of their victims by using their ethnicity and background to
8 coerce victims into putting their guard down. Once the Mazgani Family creates the requisite
9 deference in their victims they are better able increase their economic gain through fraud,
10 manipulation, intimidation and fear.
11 25. By taking criminal advantage of the most vulnerable segment of an already isolated
12 population, the Mazgani Family has made millions of dollars and ruined thousands of lives.
13
GENERAL ALLEGATIONS COMMON TO ALL CAUSES OF ACTION
14
15 26. The Mazgani Family are well-educated and sophisticated. Mahvash Mazgani is an

16 urbane, British educated businesswoman; Nazanin Mazgani is a seasoned attorney licensed to

17 practice law in the State of California, (SBN: 270258); and Neyaz Mazgani has spent the last 18-

18 years of her life (post-secondary school) in academia and is currently on the fast track to obtain a

19 doctorate in law. Exhibit A touts Mahvash’s “52” years of Social Security experience.

20 27. After Plaintiff made contact with Mahvash Mazgani to inquire about SSI and SSD

21 benefits on February 23, 2017, he was instructed by Mahvash Mazgani to appear at her office at

22 11:00 a.m. on March 1, 2017 and to bring with him a money order in the amount of $500 to

23 cover the initial fee. See Exhibit G.

24 28. On February 28, 2017, Plaintiff obtained a Money Order from Western Union

25 bearing number *******6814 and noted in Farsi on the check that it be payable to Mazgani and

26 that it was a payment for SSA related work to receive SSI and SSD. See Exhibit G (Plaintiff

27 does not have a copy of the check at this time).
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28 29. On March 1, 2017, Plaintiff appeared at the office of Mazgani Social Services, Inc.,

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COMPLAINT
1 located at 1110 South Robertson Blvd, Suite 103, Los Angeles, CA 90035.
2 30. At that March 1, 2017 meeting, Plaintiff personally met with Mahvash Mazgani and
3 that Mahvash Mazgani took the $500 money order from Iraj Khosroabadi, later cashing the
4 money order on March 2, 2017.
5 31. Since paying the initial $500 fee, Plaintiff has been harassed by the Defendants
6 and/or their agents attempting to acquire additional money for fees related to their services, with
7 the threat that failing to do so would cause Plaintiff to forfeit his rights to collect SSI and/or SSD
8 benefits.
9 32. The Defendants informed the Plaintiff that since 2005 they have helped “thousands”
10 of people obtain social security benefits and that the Defendants mainly represent Iranian-
11 Americans, particularly elderly and disabled Iranian Americans, before the Social Security
12 Administration.
13 33. Plaintiff is informed and believes, and therein alleges that the Law Offices of
14 Nazanin Mazgani also assists MSSI’s clients in obtaining benefits in her independent capacity as
15 a licensed attorney in the State of California, knowing that Defendants MSSI, Mahvash Mazgani,
16 Neyaz Mazgani and DOES 1 through 10 had already collected a fee from (1) the SSA, (2) the
17 client, and/or (3) were in the process of collecting said fees. See Exhibit E.
18 34. Plaintiff is informed and believes, and therein alleges that the Law Offices of
19 Nazanin Mazgani derived pecuniary gain through their business dealings with MSSI, Mahvash
20 Mazgani, Neyaz Mazgani, and DOES 1 through 10, benefitting from, and in furtherance of, the
21 fraudulent business practices of MSSI and their agents.
22 A. Defendants Collected Illegal Fees
23 35. 20 CFR §404.1705 authorizes an individual to appoint a representative in dealings
24 with the SSA. This individual may either be (1) a licensed attorney that is not otherwise
25 disqualified or suspended from acting as a representative and is not otherwise prohibited by law
26 from acting as a representative, or (2) a non-attorney generally known to have a good character
27 and reputation who is capable of providing valuable help with the claim and who is not
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28 disqualified, prohibited or suspended from acting as a representative.

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COMPLAINT
1 36. 20 CFR §404.1720 restricts the mode and the amount of compensation that a
2 representative like the Mazgani Family can receive for representing an applicant before the SSA.
3 37. The language of CFR §404.1720 is unambiguous, stating that “[a] representative
4 may charge and receive a fee for his or her services as a representative only as provided in

5 paragraph (b) of this section.”

6 38. Language of CFR § 404.1720 (b) is also unambiguous stating that when charging

7 and receiving a fee related to your claim, “(1) [t]he representative must file a written request with

8 us before he or she may charge or receive a fee for his or her services. (2) We decide the amount

9 of the fee, if any, a representative may charge or receive. (3) Subject to paragraph (e) of this

10 section, a representative must not charge or receive any fee unless we have authorized it, and a
representative must not charge or receive any fee that is more than the amount we authorize. (4)
11
If your representative is an attorney or an eligible non-attorney, and you are entitled to past-due
12
benefits, we will pay the authorized fee, or a part of the authorized fee, directly to the attorney or
13
eligible non-attorney out of the past-due benefits, subject to the limitations described in
14
§ 404.1730(b)(1). If the representative is a non-attorney who is ineligible to receive direct fee
15
payment, we assume no responsibility for the payment of any fee that we have authorized.”
16
39. Plaintiff is informed and believes, and therein alleges that from 2005 to the date of
17
this Complaint, the Mazgani Family has uniformly collected an unlawful fee from thousands of
18
Iranian-Americans, most of whom were elderly and/or disabled, it represented before the SSA.
19
40. The Mazgani Family accomplishes its vile intent by requesting as much as $3,500 in
20
addition to what the SSA will authorize as its payment pursuant to CFR §404.1720 et seq.
21
41. Plaintiff is informed and believes, and therein alleges that MSSI requests fees before
22
submitting any fee requests to the SSA by charging $500 or more at the initial meeting with a
23
client, and then by demanding subsequent fees from their clients in denominations less than
24
$3,000, but in an aggregate amount of $3,000 or more (usually 6-checks in the amount of $500
25
each). Defendants insist that their clients either pay in cash or with a check or money order with
26
the “Pay to the Order of” line on the check left blank.
27
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COMPLAINT
CLASS ACTION ALLEGATIONS
1
42. Plaintiff is informed and believes and thereon alleges on information and belief that
2
Defendants, and each of them, were the agents, servants, employees, co-conspirators, joint
3
venture partners, contractors and alter egos of each of the other Defendants, and at all times
4
mentioned herein, each were acting within the knowledge and direction of each other and within
5
the purpose, scope and course of their agency, service, employment, joint venture and with the
6
express and/or implied knowledge, permission, consent and ratification of the remaining
7
Defendants and each thereby has conspired, approved, aided, abetted, encouraged, incentivized
8
and ratified the acts of the other Defendants.
9
43. This action is maintainable as a representative action pursuant to California Code of
10
Civil Procedure section 382. Plaintiff seeks to represent a statewide class action as follows: “All
11
persons who were charged by Defendants, and each of them, for a fee related to SSA, California
12
State, or US Federal Government benefits in excess of an established permissible amount and/or
13
without express permission where required from December 23, 2005 to the present.”
14
a. Whether the conduct complained of constitutes unlawful, unfair or fraudulent
15
business practices, in violation of the UCL, Business and Professions Code § 17200
16
et seq.;
17
b. Whether defendants passed off services as those of another, in violation of the
18
Consumer Legal Remedies Act (“CLRA”), Civil Code § 1770(a)(1);
19
c. Whether defendants misrepresented their affiliation, connection, or association with
20
another, in violation of the CLRA, Civil Code § 1770(a)(3);
21
d. Whether defendants used representations that their services had sponsorship,
22
approval, characteristics, or benefits which they did not have, or that a person has a
23
status which he or she does not have, in violation of the CLRA, Civil Code §
24
1770(a)(5);
25
e. Whether defendants represented that their services are of a particular standard, quality
26
or grade, when they are of another, in violation of the CLRA, Civil Code §
27
8

1770(a)(7);
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28

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COMPLAINT
1 f. Whether plaintiffs and members of the Class have sustained damages, and if so, the
2 proper measure of damages;
3 g. Whether plaintiffs and members of the Class should be awarded punitive damages;
4 and
5 h. Whether plaintiffs and members of the Class are entitled to equitable relief, and, if so,
6 the nature of that relief.
7 44. Subject to confirmation, clarification and/or modification based on discovery to be
8 conducted in this action, Plaintiff also seeks to represent a sub-class in California, defined as
9 follows:
10 “All persons who were aged 65 or older when they paid the Defendants a fee related to
11 SSA, California State, or US Federal Government benefits/income in excess of an established
12 permissible amount and/or without express permission where required from December 23, 2005
13 to the present.”
14 45. The individuals included within the alleged class are so numerous that joinder of
15 each of them would be impractical, and the disposition of the claim in a class action, rather than
16 in numerous individual actions, will benefit the parties, the court and the interest of justice.
17 46. The Plaintiff and the members of the Class suffered, and will continue to suffer harm
18 as a result of the Defendants’ unlawful and wrongful conduct. A class action is superior to other
19 available methods for the fair and efficient adjudication of the present controversy. Individual
20 joinder of all members of the Class is impracticable. Even if individual Class members had the
21 resources to pursue individual litigation, it would be unduly burdensome to the courts in which
22 the individual litigation would proceed. Individual litigation magnifies the delay and expense to
23 all parties in the court system of resolving the controversies engendered by Defendants’ common
24 course of conduct. The class action device allows a single court to provide the benefits of
25 unitary adjudication, judicial economy, and the fair and efficient handling of all Class members’
26 claims in a single forum. The conduct of this action as a class action conserves the resources of
27 the parties and of the judicial system and protects the rights of the class members. Furthermore,
9
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28

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COMPLAINT
1 for many, if not most, a class action is the only feasible mechanism that allows an opportunity
2 for legal redress and justice.
3 47. Adjudication of individual Class members’ claims with respect to Defendant would,
4 as a practical matter, be dispositive of the interests of other members not parties to the
5 adjudication, and could substantially impair or impede the ability of other class members to
6 protect their interests.
7 48. Plaintiff’s claims are typical of the claims of the members of the Class. Plaintiff and
8 all members of the Class have been similarly affected by Defendants common course of conduct
9 since they all relied on Defendants’ representations concerning the fees to be paid for their
10 representation and assistance in obtaining SSA, California State or US Federal Government
11 benefits.
12 49. Among the proposed class, there is a well-defined community of interest in the
13 question of law and/or fact involved, affecting the class members. These common questions
14 include, but are not limited to:
15 a. The collection of fees in access of what the SSA permits from class members.
16 b. The disgorgement of fees received by the Defendants directly from the SSA in
17 violation of CFR §404.1720 et seq.
18 50. Common questions of law and/or fact predominate over questions that affect only
19 individual class members. Plaintiff’s claims are typical of those belonging to the members of the
20 class he seeks to represent, and plaintiff can adequately represent the class he seeks to represent.
21 51. While the exact number of members in the Class are unknown to Plaintiff at this
22 time, and can only be determined by appropriate discovery, membership in the class and
23 subclasses is ascertainable based upon the records maintained by Defendants. It is estimated that
24 the members of the Class number in the thousands.
25 52. Therefore, the Class is so numerous that individual joinder of the entire Class is
26 impracticable under Fed. R. Civ. P. 23(a)(1).
10

27 53. Plaintiffs will fairly and adequately represent and protect the interests of the Class.
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28 Plaintiffs have retained counsel with substantial experience in handling complex class action

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COMPLAINT
1 litigation in general and consumer fraud claims in particular. Plaintiffs are also well connected
2 to the affected population that will likely account for the majority of the class members.
3 Plaintiffs and their counsel are committed to vigorously prosecuting this action on behalf of the
4 Class and have the financial resources to do so.
5 54. A class action is superior to other available means for the fair and efficient
6 adjudication of this controversy and will result in a substantial benefit to the Class, the public
7 and the Court. The likelihood of individual Class members prosecuting separate claims is
8 remote, and individual members of the Class do not have a significant interest in individually
9 controlling the prosecution of separate actions. Because the damages suffered by individual
10 Class members is relatively small, the expenses and burden of individual litigation would make it
11 difficult, if not impossible, for individual members of the Class to redress the wrongs done to
12 them. The cost to the judicial system of the adjudication of many individualized claims would
13 substantial whereas the litigation of these claims simultaneously as a class action will result in
14 substantial savings of judicial resources. Furthermore, the prosecution of separate actions by
15 individual Class members would create a risk of inconsistent and varying adjudications
16 concerning the subject of this action, which adjudications could establish incompatible standards
17 of conduct for defendants under the law alleged herein. Class treatment will permit a large
18 number of similarly situated persons to prosecute common claims in a single forum
19 simultaneously, efficiently and without unnecessary duplication of effort and expense that
20 individual actions would engender. Class treatment will enable the Class members to redress the
21 wrongs done to them and to serve the public interest by ensuring that defendants’ conduct be
22 punished and enjoined from future repetition. Class treatment will thus result in the most fair and
23 efficient adjudication of this controversy, as well as conferring substantial benefits on the
24 litigants, the public and the Court.
25 55. This action has been brought and may properly be maintained as a class action
26 pursuant to Code of Civil Procedure § 382 and Civil Code § 1781, in that there is an
11

27 ascertainable class, a well-defined community of interest, the Class is so numerous as to make it
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28 impracticable to bring all of its members before the Court, the adjudication of this action as a

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COMPLAINT
1 class action is a superior method of resolving this controversy, and substantial benefits will
2 accrue to members of the Class, the public and the Court.
3 CAUSES OF ACTION
4 FIRST CAUSE OF ACTION
5 INTENTIONAL (ACTUAL) FRAUD (CAL. CIV. CODE §1572)
6 (By Plaintiff and on Behalf of the Primary Class and Sub-Classes as Against Defendants)
7 56. Plaintiff incorporates by reference each and every allegation contained above as
8 though fully set forth herein.
9 57. This cause of action is brought pursuant to California Civil Code §1572.
10 58. Defendants violated and continue to violate §1572 by engaging in the following
11 practices with intent to deceive the Plaintiff and the Class which were intended to induce them to
12 enter the contract: “(1) [t]he suggestion, as a fact, of that which is not true, by one who does not
13 believe it to be true; (2) [t]he positive assertion, in a manner not warranted by the information of
14 the person making it, of that which is not true, though he believes it to be true; (3) [t]he
15 suppression of that which is true, by one having knowledge or belief of the fact; (4) [a] promise
16 made without any intention of performing it; or, (5) [a]ny other act fitted to deceive.”
17 59. The Defendants committed intentional fraud in requiring clients to make a
18 preliminary payment during the first meeting for their services when they knew that a written
19 request for said fees must be submitted to SSA before any fees may be collected.
20 60. Defendants also induced Plaintiff and Class members to continue to remit payments
21 under threat that they would forfeit their rights to receive the benefit for which Defendants
22 represented their interests.
23 61. Defendants knew they could not bill the Plaintiff or the Class members before
24 submitting requests to the SSA because they subsequently submitted those requests after taking
25 payment from the Plaintiff and the Class members.
26 62. Plaintiff and Class members would not have made any unauthorized payments to
12

27 Defendants had they known the Defendants’ claims were untrue.
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28 63. Plaintiff and Class members’ reliance on Defendants’ misrepresentations was

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COMPLAINT
1 reasonable because they were a vulnerable and isolated population who enlisted the aid of the
2 Defendants with whom a fiduciary duty was created upon Defendants’ acceptance of that
3 representation pursuant to 20 CFR 404.1705.
4 64. As a result of Defendants’ misrepresentations, Plaintiff and Class members were
5 harmed when they were overcharged for services.
6 65. Pursuant to Cal. Civ. Code §1572 Plaintiff and Class members seek an order of this
7 Court awarding Plaintiff and the Class restitution, disgorgement, damages and punitive damages.
8 SECOND CAUSE OF ACTION
9 UNFAIR BUSINESS PRACTICES (CAL. B&P §17200)
10 (By Plaintiff and on Behalf of the Primary Class and Sub-Classes as Against Defendants)
11 66. Plaintiff incorporates by reference each and every allegation contained above as
12 though fully set forth herein.
13 67. California’s Unfair Competition Law, Business and Professions Code §17200 (the
14 “UCL”) prohibits any “unfair, deceptive, untrue or misleading advertising.” For the reasons
15 discussed above, Defendant has engaged in unfair, deceptive, untrue and misleading advertising,
16 and continue to engage in such business conduct, in violation of the UCL
17 68. The UCL’s three prongs are read in the disjunctive, and the UCL separately prohibits
18 any “unlawful … business act or practice.” Defendant has violated the UCL’s prohibition
19 against engaging in unlawful acts and practices by, inter alia, making the representations and
20 omissions of material facts, as set forth more fully herein, and by violating, among others, 20
21 CFR §§ 404.1717, 404.1720, 404.1725, 404.1730, Welf. & Inst. Code §§ 15610.30, 15657.5,
22 Cal. Civ. Code §1572, and the common law. Such conduct is ongoing and continues to this date.
23 69. Plaintiffs and the Class reserve the right to allege other violations of law which
24 constitute other unlawful business acts or practices. Such conduct is ongoing and continues to
25 this date.
26 70. The UCL also prohibits any “unfair”… business act or practice.”
13

27 71. Defendant’s acts, omissions, misrepresentations, practices and nondisclosures as
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28 alleged herein also constitute “unfair” business acts and practices within the meaning of the UCL

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COMPLAINT
1 in that their conduct is substantially injurious to consumers, offends public policy, and is
2 immoral, unethical, oppressive, and unscrupulous as the gravity of the conduct outweighs any
3 alleged benefits attributable to such conduct. In the alternative, Defendant’s business conduct as
4 described herein violates relevant laws designed to protect consumers and business from unfair
5 competition in the marketplace. Such conduct is ongoing and continues to date.
6 72. Plaintiffs also allege violations of consumer protection, unfair competition and truth
7 in advertising laws in California and other states resulting in harm to consumers. Plaintiffs assert
8 violation of the public policy of engaging in false and misleading advertising, unfair competition
9 and deceptive conduct towards consumers. This conduct constitutes violations of the unfair
10 prong of the UCL. Such conduct is ongoing and continues to this date.
11 73. There were reasonably available alternatives to further Defendant’s legitimate
12 business interests, other than the conduct described herein.
13 74. The UCL also prohibits any “fraudulent business act or practice.”
14 75. Defendant’s claims, nondisclosures (i.e., omissions) and misleading statements, as
15 more fully set forth above, were false, misleading and/or likely to deceive a reasonable consumer
16 within the meaning of the UCL. Such conduct is ongoing and continues to this date.
17 76. Defendant’s conduct caused and continues to cause substantial injury to Plaintiffs
18 and the other Class members. Plaintiff has suffered injury in fact as a result of the Defendants’
19 unfair conduct.
20 77. Defendant has thus engaged in unlawful, unfair and fraudulent business acts and
21 practices and false advertising, entitling Plaintiff and the Class to injunctive relief against
22 Defendant, as set forth in the Prayer for Relief.
23 78. Pursuant to Business and Professions Code §17203, Plaintiff and the Class seek an
24 order requiring Defendant to immediately cease such acts of unlawful, unfair and fraudulent
25 business practices and requiring Defendant to engage in a corrective advertising campaign.
26 79. The Plaintiff, on behalf of the Class, also seeks an order for the disgorgement and
14

27 restitution of all monies from the sale of the services they purchased, which was unjustly
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28 acquired through acts of unlawful, unfair, and/or fraudulent competition. The Plaintiff, on behalf

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COMPLAINT
1 of the Class and himself, further seeks an order for prospective and retrospective injunctive
2 relief.
3 80. Tolling applies to the UCL under a recent decision by the California Supreme
4 Court, Aryeh v. Canon Bus. Sols., Inc., 55 Cal. 4th 1185, 1191-1202 (2013). The “silence”
5 about tolling and accrual of claims under the UCL “trigger[ed] a presumption in favor of
6 permitting settled common law accrual rules to apply” and “the UCL is governed by
7 common law accrual rules to the same extent as any other statute.” DC Comics v. Pac.
8 Pictures Corp., 2:10-CV-03633-ODW, 2013 WL 1389969 (C.D. Cal. Apr. 4, 2013) (citing
9 Aryeh, 55 Cal. 4th at 1193).
10 THIRD CAUSE OF ACTION
11 VIOLATION OF THE FALSE ADVERTISING LAW (Cal. B&P §§ 17500, et seq.)
12 (By Plaintiff and on Behalf of the Primary Class and Sub Classes as Against Defendants)
13 81. Plaintiff incorporates by reference each and every allegation contained above as
14 though fully set forth herein.
15 82. The Plaintiff has standing to pursue this claim as the Plaintiff has suffered injury in
16 fact as a result of Defendants’ actions as set forth herein. Specifically, prior to the filing of this
17 action, Plaintiff purchased the Defendants’ services in reliance upon Defendants’ marketing
18 claims. Plaintiff paid the initial fee required by the Defendants, but has yet to be provided any of
19 the promised benefits.
20 83. Defendants’ business practices as alleged herein constitute unfair, deceptive, untrue,
21 and misleading advertising pursuant to California Business and Professions Code section 17500,
22 et seq. because Defendants advertised their services, Plaintiff purchased those services in
23 reasonable reliance on Defendants’ representations and advertisements which were ultimately
24 communicated in a manner that was untrue and misleading, and that is known or reasonably
25 should have been known to Defendants that their advertisements and representations were untrue
26 and/or misleading.
15

27 84. Defendants’ wrongful business practices have caused injury to the Plaintiff and the
Page

28 Class.

______________________________________________________________________________
________
COMPLAINT
1 85. Pursuant to section 17535 of the California Business and Professions Code, the
2 Plaintiff and the Class seek an order of this court enjoining Defendants from continuing to
3 engage in deceptive business practices, false advertising, and any other act prohibited by law,
4 including those set forth in the complaint.
5 86. Plaintiff also seeks an order for the disgorgement and restitution of all monies from
6 the sale of the services which were unjustly advertised through acts of unlawful, unfair, and/or
7 fraudulent competition.
8 FOURTH CAUSE OF ACTION
9 BREACH OF FIDUCIARY DUTY (20 CFR 404.1705)
10 (By Plaintiff and on Behalf of the Primary Class and Sub Classes as Against Defendants)
11 87. Plaintiff incorporates by reference each and every allegation contained above as
12 though fully set forth herein.
13 88. When the Defendants held themselves out to the public as a Social Services Agency
14 in the business of representing the general public in their Social Service/Government Benefit
15 claims. To do this, Defendants must sign a notice appointing that person as their representative,
16 and submit that notice to the Social Security Agency. See 20 CFR 404.1707.
17 89. Representatives who are not attorneys must be capable of giving valuable help to you
18 in connection with your claim and must be generally known to have a good character and
19 reputation. 20 CFR 404.1705. Attorneys must abide by the California Rules of Professional
20 Conduct, and must not otherwise be forbidden from representing their client. Id. As such, the
21 representative is authorized to (1) “[o]btain information about your claim to the same extent that
22 you are able to do; (2) [s]ubmit evidence; (3) [m]ake statements about facts and law; and (4)
23 [m]ake any request or give any notice about the proceedings before [the SSA].” 20 CFR
24 404.1710.
25 90. As such, a fiduciary duty between the Plaintiff and Defendants as a principal and
26 agent. A fiduciary duty between a principal and agent is imposed by California law. See
16

27 Oakland Raiders v. National Football League, 131 Cal.App.4th 621 (2005) and Recorded Picture
Page

28 Company [Productions] Ltd. v. Nelson Entertainment, Inc., 53 Cal.App.4th 350, 369-370 (1997).

______________________________________________________________________________
________
COMPLAINT
1 91. The Defendants breached their duty of loyalty when they knowingly acted against
2 the interests of the Plaintiff by requiring Plaintiff to pay erroneous and illegal charges for their
3 services up front causing the Plaintiff financial loss and hardship.
4 92. The Defendants also breached their duty of reasonable care when, after assuming the
5 role of the Plaintiff’s agents for the purposes of representing the Plaintiff to apply for SSA
6 benefits, Defendants failed to act as a reasonably careful agent would have acted under similar
7 circumstances by charging the Plaintiff in an amount and manner inconsistent with the statutory
8 requirements of such a relationship, causing financial loss and hardship to the Plaintiff.
9 Defendants’ willful acts were a direct cause of Plaintiff’s financial damages.
10 93. As stated above, Defendants’ acts of fraud and inducement also breached their
11 fiduciary duty with the Plaintiff, causing him financial and emotional harm.
12 94. Pursuant to California’s common law Breach of Fiduciary Duty, the Plaintiff and the
13 Class seek restitution damages, disgorgement, and punitive damages.
14 FIFTH CAUSE OF ACTION
15 CALIFORNIA CONSUMERS LEGAL REMEDIES ACT
16 (By Plaintiff and on Behalf of the Class Members Against All Defendants)
17 95. Plaintiff incorporates by reference each and every allegation contained above as
18 though fully set forth herein.
19 96. Defendants’ use of their agency relationship to gain access to the Plaintiff and
20 similarly situated Class members to bully, harass, threaten, and manipulate through lies and
21 intimidation for their own financial gain is offensive enough. When that conduct is directed at
22 some of the most vulnerable members of our society (the elderly and the disabled), the
23 Defendants’ conduct becomes outrageous.
24 97. Defendants (a business woman, lawyer and academic) knowingly take advantage of
25 the elderly and disabled because they know that they are easy victims, especially when they are
26 already isolated from the rest of society through language and ethnic barriers. Since 2005 (and
17

27 possibly earlier) the Defendants have been taking advantage of the most vulnerable individuals
Page

28 in our society by acting as additional gate-keepers to a government program that is designed to

______________________________________________________________________________
________
COMPLAINT
1 help alleviate their suffering, not cause more of it. See Exhibit F.
2 98. This Cause of Action is brought pursuant to the Consumer Legal Remedies Act,
3 Civil Code § 1750 et seq. (“CLRA”).
4 99. At all times herein mentioned, plaintiffs and Class members were consumers within
5 the meaning of Civil Code § 1761(d).
6 100. Defendants’ policies, acts and practices were intended to result in the defrauding all
7 of the consumers contained within the class along with the United States government. By their
8 wrongful conduct as alleged herein, defendants, and each of them, have created, engaged in,
9 and/or participated in unfair practices in violation of section 1770(a)(1) of the Civil Code.
10 101. Defendants’ policies, acts and practices were intended to result in the
11 misrepresentation of the affiliation, connection, or association with another in that they caused
12 plaintiffs and members of the Class to reasonably believe that unless they paid the unauthorized
13 fees to the Defendants, their application for aid would not be approved. By their wrongful
14 conduct as alleged herein, defendants, and each of them, have created, engaged in, and/or
15 participated in unfair practices in violation of section 1770(a)(3) of the Civil Code.
16 102. Defendants’ policies, acts and practices were intended to result in defendants making
17 representations that the services had sponsorship, approval, characteristics, or benefits which
18 they did not have, or that a person has a status which he or she does not have, in that they: (a)
19 failed to adequately notify plaintiffs and the Class either that they were paying monies to the
20 Defendants that were not permitted by law by the Defendants to take. By their wrongful conduct
21 as alleged herein, defendants, and each of them, have created, engaged in, and/or participated in
22 unfair practices in violation of section 1770(a)(5) of the Civil Code.
23 103. Defendants’ policies, acts and practices were intended to result in defendants making
24 representations that aid to the class members were not available unless they paid the Defendants
25 the fees to which they were not entitled to. By their wrongful conduct as alleged herein,
26 defendants, and each of them, have created, engaged in, and/or participated in unfair practices in
18

27 violation of section 1770(a)(7) of the Civil Code.
Page

28 104. Defendants, and each of them, aided and abetted, encouraged and rendered

______________________________________________________________________________
________
COMPLAINT
1 substantial assistance in accomplishing the wrongful conduct and their wrongful goals and other
2 wrongdoing complained of herein. In taking action, as particularized herein, to aid and abet and
3 substantially assist the commission of these wrongful acts and other wrongdoings complained of,
4 each defendant acted with an awareness of its primary wrongdoing and realized that its conduct
5 would substantially assist the accomplishment of the wrongful conduct, wrongful goals, and
6 wrongdoing.
7 105. Pursuant to Civil Code § 1780(a), plaintiffs and the other members of the Class seek
8 actual damages, an order of this Court enjoining defendants from engaging in the methods, acts
9 or practices alleged herein, restitution of property, and punitive damages.
10 SIXTH CAUSE OF ACTION
11 FINANCIAL ELDER ABUSE (Welf. & Inst. Code §§15610.30 & 15657.5)
12 (By Plaintiff and on Behalf of those Class Members Who Were Age 65 and Older When
13 they Suffered Pecuniary Loss from Defendants, and Against Defendants)
14 106. Plaintiff incorporates by reference each and every allegation contained above as
15 though fully set forth herein.
16 107. California’s Elder Abuse and Dependent Adult Civil Protection Act protects the
17 elderly from being ripped-off by predatory con-artists.
18 108. As discussed in greater detail above, Defendants appropriated the Plaintiff’s money
19 to help the Plaintiff apply for SSI and SSD benefits. Defendants then took advantage of the
20 Plaintiff and similarly situated Class members by demanding more in fees than was allowed by
21 statute, and laundering the money so they wouldn’t get caught. Defendants were working in
22 conjunction with each other and for their mutual benefit by either directly committing the fraud,
23 or by facilitating its commission through aid and/or encouragement.
24 109. In fact, Defendants were pocketing the extra money they were appropriating from the
25 Plaintiff and the Class members, and billing the SSA on the front-end. The Plaintiff was caused
26 financial loss and emotional hardship as a direct result of the Defendants’ actions.
19

27 110. Depending on the specific award by SSA, Defendants would have either received a
Page

28 percentage of the benefit payment, or would have been paid directly from the SSA for their

______________________________________________________________________________
________
COMPLAINT
1 representation.
2 111. As argued above, Defendants acted with purpose, intent and knowledge when they
3 committed fraud and appropriation, and their conduct was objectively outrageous.
4 112. Pursuant to California’s Elder Abuse and Dependent Adult Civil Protection Act,
5 Plaintiff is asking for compensation for mental suffering, emotional distress, punitive damages,
6 compensatory damages and all enhanced remedies provided by § 15610.30.
7 SEVENTH CAUSE OF ACTION
8 Violation of RICO (18 USC §1961 et seq.)
9 (By Plaintiff and on Behalf of the Primary Class and all Sub Classes, Against Defendants)
10 113. Plaintiff incorporates by reference each and every allegation contained above as
11 though fully set forth herein.
12 114. This cause of action arises under the Racketeer Influenced and Corrupt
13 Organizations Act, 18 U.S.C. §1961 et seq.
14 115. Defendants, and others willfully and intentionally violated and continue to violate
15 RICO and California law with the goal of obtaining money, directly and indirectly, through a
16 pattern of racketeering activities in violation of 20 CFR 404.1700 et seq.
17 116. Defendants are required to complete all requests for payment through the SSA
18 wirelessly pursuant to 20 CFR 404.1713. When the Defendants force their victims to pay a fee
19 up front for their services, then subsequently bill the SSA, they are committing wire fraud, and
20 thus in violation of 18 US Code 1343.
21 117. When the Defendants refuse to assist their victims unless they make additional
22 payments for their services, the Defendants are committing extortion, and are in violation of 18
23 US Code 1951.
24 118. Each of the Defendants are engaged in activities of federal interstate and foreign
25 commerce, and are entities capable of holding a legal or beneficial interest in property. All
26 Defendants are “persons,” as that term is defined by’ 18 U.S.C. §1961(3).
20

27 119. The Defendants together make up the “Mazgani Family” as an association of entities
Page

28 and individuals associated in fact to operate an illegal Social Security scheme. The Mazgani

______________________________________________________________________________
________
COMPLAINT
1 Family is not a legal entity within the meaning of “enterprise” as defined in 18 USC § 1961(4),
2 although it does include a lawyer and a California corporation, MSSI. The Defendants have
3 been members the Mazgani Family” since they were born, but only in the Social Security
4 business since 2005 and continuing until the present. MSSI and the Law Offices of Nazanin
5 Mazgani are separate entities from and play separate and distinct roles in the operation of the
6 Mazgani Family Social Security scheme.
7 120. Mahvash is the founder, president and primary beneficiary of MSSI. Through
8 interstate wire and mails, emails faxes and the internet, it coordinates with the SSA to secure
9 payments to themselves through their clients and the Class members.
10 121. MSII employs the Defendants to coordinate operations and to pursue the SSA in
11 legal challenges to secure their fees. Mahvash employs her daughters Neyaz and Nazanin in
12 procuring their fees from the SSA and illegally directly from their clients.
13 122. Several fraudulent misrepresentations and extortion allegations have been discussed
14 in detail above concerning the Mazgani Family. Mahvash, through MSSI has engaged in
15 systematic wire fraud through misrepresenting payments to the SSA and through concealing the
16 source of the money they get directly from their clients.
17 123. As discussed above, the Mazgani Family has engaged is several instances of
18 Racketeering activity both through interstate commerce, wire fraud, mail fraud and extortion.
19 124. Defendants are liable to Plaintiff and the Class members for treble damages, together
20 will all costs of this action plus reasonable attorney’s fees, all as provided under 18 USC
21 1964(c), the Business and Professions Code and all other causes of action pled above.
22
PRAYER FOR RELIEF
23
24 WHEREFORE, plaintiffs, individually, on behalf of the Class and on behalf of the

25 public, pray for judgment as follows:

26 A. That this action be certified as a class action, pursuant to Code of Civil Procedure §
21

27 382 and/or the Consumer Legal Remedies Act, Civil Code § 1781;
Page

28 B. That pursuant to Business and Professions Code §§ 17204 and 17535, all defendants,

______________________________________________________________________________
________
COMPLAINT
1 their officers, directors, principals, assignees, successors, agents, representatives, employees,
2 subsidiaries, affiliates, and all persons, corporations and other entities acting by, through, under,
3 or on behalf of said defendants, or acting in concert or participation with them, be permanently
4 enjoined from directly or indirectly making any illegal, untrue or misleading statements in
5 violation of Business and Professions Code §§ 17200 and 17500, including, but not limited to,
6
the untrue or misleading statements alleged in this complaint;
7
C. That pursuant to Business and Professions Code § 17204, all defendants, their officers,
8
directors, principals, assignees, successors, agents, representatives, employees, subsidiaries,
9
affiliates, and all persons, corporations and other entities acting by, through, under, or on behalf
10
of said defendants, or acting in concert or participation with them, be permanently enjoined
11
from directly or indirectly committing any violations of Business and Professions Code § 17200
12
et seq., including, but not limited to, the violations alleged in this complaint;
13
D. Ordering the disgorgement of all sums unjustly obtained from plaintiffs, the members
14
15 of the Class and the public;

16 E. Ordering defendants to make restitution to plaintiffs, the members of the Class and the

17 public;
F. That the Court assume jurisdiction in this case and grant a jury trial and expedited trial
18
19 under California elder abuse statutes;

20 G. That the Court award actual and compensatory damages in an amount to be proven at
21 trial, (but no less than the jurisdictional minimum of this Court);
22
H. That the Court award reasonable costs and attorney fees to Plaintiff under California’s
23
Elder abuse statute, California Civil Code 1021.5, and through other causes as argued above;
24
25 I. That the Court allow punitive damages designed to punish and deter Defendants from

26 engaging in similar future conduct;
22

27
J. That the Court award treble damages and that monetary penalties be assessed to each
Page

28
Defendant;

______________________________________________________________________________
________
COMPLAINT
K. That the Court order all the transactions VOID and unenforceable and Order that all
1
2 secret profits and ill-gotten gains be disgorged;

3 L. The defendants must be subjected to a detergent theory of disgorgement of all income
4
derived from representation of any class member before the SSA for period of 2005-2017 (and
5
onward till the day of judgment).
6
7 M. Injunctive Relief;

8 N. Appointment of a Receiver (to take hold of any incoming proceeds to the Defendants
9 and to assist in accounting for all illicit profits of the enterprise).
10
O. That the Court award such other and further relief as the Court deems just and proper.
11
12
13 RESPECTFULLY SUBMITTED

14 Dated: March 13, 2017
15 ________________
Robert B. Salgado, Esq.
16 Robert@aperturelaw.com
17
18
19
20
21
22
23
24
25
26
23

27
Page

28

______________________________________________________________________________
________
COMPLAINT
03/10/2017 13:43 213-489-2753 FEDEX OFFICE 4555 PAGE 01/01
VERIFICATION
STATE OF CALIFORNIA, COUNTY OF Orange
I have read the foregoing VERIFIED CLASS ACTION COMPLAINT

and know its contents.
D CHECK APPLICABLE PARAGRAPHS
0 I am a party to this action. The matters $lated in the fqregolng document are true of my own knowledge except as to those
matters which are stat e. d on information and belief, and as to those matter$ I believe them to be true.
0 I am O · an Officer O a partner
0 a 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.
D 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 a.re stated on information and
belief, and as to·those matters I believe them to be true.
CJ I am one of the attorneys for
a party.to. .th/s.actioo. S.uch. party is a!;,sent frwn the . county of afqresald where such attorneys have their offices, and I make this
verification for and on behalf of that party for that reason. I arn Informed · and believe and on that ground allege that the matters
stated in the foregoing document are true.
Executed on 3/10/2017 , at Los Angeles , California.
I declare under penalty of perjury under the laws of the State of Califol!Jn)i·a.t11.i1-�'"ft!F8!JQ"'1{l.Jl�
IRAJKHOSROABADl ......................
TYPE OR'f'RINT NAME -
... SIGNATURI:

PROOF OF SERVICE
1013a (3) CCP Revised 2004
STATE OF CALIFORNIA, COUNTY OF Orange
· I am employed in the county of , State of California.
I am over the ·age of 1. s and not a party to the within action; my business address is;

On , I served the foregoing document described as

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

CJ BYMAIL
CJ •1 deposited such envelope in tlie mail at , California.
The envelope was malled with postage thereon fully prepaid.
0 As follows: I am "readily familia�' 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
· day after date of
party served, service is presumed invalid if postal cancellation date or postage meter date is more than one
deposit for malling In affldav. lt
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 (Slate). 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.

TVPS OR PRINT NAME SIGNATURE
"(BY MAIL SIGNATURE MUST BE OF PERSON Of:POSITING ENVELOPJ;; IN
MAIL SLOT, BOX OR BAG)
'1FOR PERSONAL 8CfW10E 81GNATURE MUST BE THAT OF MESSENGER)
NONJC-015 (Rev. 01/01/2011) VERIFICATION/PROOF OF SERVICE
0
Khos.roabadi' lraj
� t11ENIIAL fDRMl·
EXHIBIT A
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"J'4 \l!/ J,j,t SSA ,SSI �� \.,- ·p
SDI , CAP1 ..,f�titJW j1 �Ji>


EXHIBIT B
SSA ,SSI.,.J� JI,.,-. J9D
SDI , CAPI ,.J�titJ'4 j1 JP

(949) 975 • 0874
Oru11 County
(310) 273 • 5228
110 S. R RTSON Blvd. Suite 3
1ele1, CA 90035
178
EXHIBIT C
Law Offices of Nazanin Mazgani
Inunigration
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Personal Injury / Accidents
�� ���·� I �Li��
Social Security Disability
(Initial Filings and Hearings)
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424 256 - 0095
310 892 - 0820
11400 W. Olyni__pic Blvd.,Suite 20
Los Angeles, CA 90064
224
EXHIBIT D
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THE IRANIAN POCKET DIRECTORY YELLOW PAGE...;;
29 th Edition
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www.lran411.com
310.IRAN411

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EXHIBIT E
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SELECT LANGUAGE I ....
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Law Offices· of
(310) 892-0820
CALL US NOW!

Nazanin Mazgani 11400 W. Olympic Boulevard, Suite 200
Los Angeles, California 90064

HOME ATTORNEY PRACTICE AREAS F.A.Q TESTIMONIALS USEFUL LINKS CONTACTS

PRACTICE AREAS ¥ Social Security Disability and SSI
A Immigration
Helping to obtain California Social Security disability benefits
> Visas for claimants throughout Los Angeles and Southern California.
> Citizenship
Social Security pays benefits to people who can't work
> Green Cards
because they have a medical condition that's expected to last
> Asylum / Refugee at least one year or result in death. Federal law requires this
> Work Permits very strict definition of disability. While some programs give
money to people with partial disability or short-term disability,
> Family Immigration
Social Security does not.
> Provisional Waivers
> Dream Act Certain members of your family may qualify for benefits
based on your work. They include:
) Obama's Executive Actions
• Your spousE, if he or she is age 62 or older;
> Temporary Protected Status • Your spouse at any age, if he or she is ca,ing for a child of
yours who is ·,ounger than age 16 or disabled;
A, Social Security Disability and SSI • Your unmanied child, including an adopted child, or in some

A Personal Injury ( Car Accident)
cases, a step child or grandchild. The child must be younger than age 18 (or younger than 19 if still in high
school);

A Surplus Funds Collection Offer
• Your unmanied child, age 18 or olde1; if he or she has a disability that sta,ted before age 22. The child's
disability must also meet the definition of disability for adults.

A, Trustee Sale
The Law Offices of Nazanin Mazgani provide disability claimants legal help through all four stages of the
disability process.

Will you qualify for Social Secu1ity disability benefits?
It depends or your age, education, recent jobs, and ability to work.
EXHIBIT F
State of California
Secretary of State
05 -573 1 70
STATEM ENT OF INFORMATION
(Domestic Stock Corporation)
..,____________________,________-t
FEES (Filing and Disclosure): $25.00. If amendment, see Instructions.
IMPORTANT - READ INSTRUCTIONS BEFORE COMPLETING THIS FORM
1. CORPORATE NAME (Please do not alter if name is prepr,nteo.)
FILED
or or
In the office tne Secretary State
M t\ Z.G:A N I S OC 1 1\ L Si=:.� \/IC.ES I � C.. •
or
the State of Callfomla

C. 250 9 3 , 1 DEC % 3 2005
I 0°1 5 'f MIi � A CH U .s cF rTS A v� .
L11.s ft N &.e L tFs... 04- 2 '-f °too
This Ss:,aee For Filing Use Only
DUE DATE:
CALIFOR�IA CORPORATE DISCLOSURE ACT (Corporations Code section 1502. 1)
A publicly traded corporation must file with the Secretary of State a Corporate Disclosure Statement (Form SI-PT) annually, within 1 50 days
after the end of its fiscal year. Please see reverse for additional information regarding publicly traded corporations.
COMPLETE ADDRESSES FOR THE FOLLOWING (Do not abbreviate the name of the cit . Uems 2 and 3 cannot be P.O. Boxes.)
2. STREET AOORESS OF PRINCIPAi,; EXECUTIVE OFFICE CITY AND STATE ZIP CODE
10'1SV mA-SsA CHus F TTS 1t ve . Lo� NJ , Ev"?a 01 Cfoo z y.

AND COMPLETE ADDRESSES OF FOLLOWING OFFICERS (The corporation must have these three officers. A comparable f
for lhe s cifle officer ma be added· however Iha re inted titres on this form must not be altered.
4. CHIEF EXECUTIVE OFFICER/ ADDRESS CITY ANO STATE ZIP CODE
Mf\ \-%\/.'1.SH tY}ftZG A#J 101:/S'Y' m,t SSAhlUSETTS 1\-vE , Lo.S. -A, ,J t;.ELt!'S. o-{ 'iDDZ.1/
6. SECRETARY/ ADDRESS CITY ANO STATE ZIP CODE
Ntl U/JI/U M f,, 2 t!Atv/ r 01S"V A'JA!/5.Al'"IJU.U' n� 1't.E . � Los A/ll�tr-Lt"' s. ("'fr 100 2)1
6 CHIEF FINANCIAi.: OFFICER/ ADDRESS CITY ANO STATE ZIP CODE
=--
#JFy/fZ. Mtl Z& Atlll S'Y ,ndSSA t'Ht/Stl'T7S AV.f' . Lo� A A!t:.FL, S, <=, l)tJZ. !/
NAMES AND COMPLETE ADDRESSES OF ALL DIRECTORS, INCLUDING DIRECTORS WHO ARE ALSO OFFICERS (The corporat,on
must have al least one director. Attach additional es. If necessa •

8. NAME ADDRESS CITY ANO STATE ZIP CODE
/tlt1 'Zh/JIN flJl12&1V\II 1 O,� l'Jt?;s;tCH l\.S e-'77.S AV.E . Liu ,l:M .<:' Eq-""5 .
9 NAME
'1 ey,4 z. /'11'1U 1ttvl
ADDRESS
I o9.f"'I ;,-1rJSSA Ql u s c773
CITY AND STATE
vf. Lo!!. ANtt'ebrs.
_1 0. NUMF,ER OF VACANCIES ON THE BOARD OF DIRECTORS. IF M4Y·
AGENT FOR SERVICE OF PROCESS (lfthe agent is an individual, the agent mu11 reside in Cahforma and Item 12 must be completed with a California
address. If the agent is another corporation, the agent must have on file with the Califomia Secretary of Stale a certificate pursuant to Corporations Code
section 1 505 and Item 12 must be left blank.)
11. NAME OF AGENT FOR SERVICE OF PROCESS
ft1 AH v'AS 14 t't1 ft Z(S.. fi N /
12. ADDRESS OF AGENT FOR SERVICE OF PROCESS IN ��IFORNIA, IF AN INOIVIOUAL CITY STATE ZIP CODE
lo'tSY 1>1//5-5ACH ti.Sc :.S Av£. --A.t-JGEL6S CA '1 0()2 V
TYPE OF BUSINESS
5�vtCE...S
·-· ·
, •

14. BY SUBMITTING THIS STATEMENT OF INFORMATION TO THE SECRETARY OF STATE, THE CORPORATION CERTIFIES THE INFORMATION CONTAINED HEREIN.
INCLUDING ANY ATTACHMENTS, IS TRUE AND CORRECT. ,
MA HVI\.St\ M tt Zo.. tt/U J f>t?iES17::F1tll- _1_z_.z_1_.o_r
_
TYPE Off PRINT NAME OF PERSON COMPLETING THE FORM TITLE DATE

Sl-200 C (REV 0512005) APPROVED 8Y SECRETARY OF STATE
State of California s
Secretary of State
Statement of Information FH41 325
(Domestic Stock and Agricultural Cooperative Corporations}
FEES (Filing and Disclosure): $25.00.
If this Is an amendment, see Instructions.
FILED
IMPORTANT - READ INSTRUCTIONS BEFORE COMPLETING THIS FORM In the office of the Secretary of State
1 . CORPORATE NAME of the State of California
MAZGANI SOCIAL SERVICES INC.

DEC-06 201 6

2 . CALIFORNIA CORPORATE NUMBER
C250931 7 . This Space for Filing Use Only

3. If there have been any changes to the Information contained in the last Statement of Information flied with the California Secretary
of State, or no statement of information has been previously flied, this form must be completed in its entirety.
� If. there has been no change in any of the information contained in the last Statement of Information filed with the California Secretary
of State, check the box and proceed to Item 17.

Complete Addresses for the Followin (Do not abbreviate the name of the city. Items 4 and 5 cannot be P.O. Boxes.)
4. STREET ADDRESS OF PRINCIPAL EXECUTIVE OFFICE CITY STATE ZIP CODE

5. STREET ADDRESS OF PRINCIPAL BUSINESS OFFICE IN CALIFORNIA, IF ANY CITY STATE ZIP CODE

6. MAILING ADDRESS OF CORPORATION, IF DIFFERENT THAN ITEM 4 CITY STATE ZIP CODE

Names and Complete Addresses of the Following Officers {The corporation must list these three officers. A comparable title for the specific
officer may be added; however, the preprinted titles on this form must not be altered.)
7. CHIEF EXECUTIVE OFFICER/ ADDRESS CITY STATE ZIP CODE

8. SECRETARY ADDRESS CITY STATE ZIP CODE

9. CHIEF FINANCIAL OFFICER/ ADDRESS CITY STATE ZIP CODE

Names and Complete Addresses of All Directors, Including Directors Who are Also Officers (The corporation must have at least one
director. Attach additional pa es, if necessa .
10. NAME ADDRESS CITY STATE ZIP CODE

1 1 . NAME ADDRESS CITY STATE ZIP CODE

12. NAME ADDRESS CITY STATE ZIP CODE

1 3. NUMBER OF VACANCIES ON THE BOARD OF DIRECTORS, IF ANY:
Agent for Service of Process If the agent Is an individual, the agent must reside in California and Item 15 must be completed with a California street
address, a P.O. Box address is not acceptable. If the agent is another corporation, the agent must have on file with the California Secretary of State a
certificate ursuant to California Corporations Code section 1505 and Item 15 must be left blank.
14. NAME OF AGENT FOR SERVICE OF PROCESS

15. STREET ADDRESS OF AGENT FOR SERVICE OF PROCESS IN CALIFORNIA, IF AN INDMDUAL CITY STATE ZIP CODE

Type of Business
16. DESCRIBE THE TYPE OF BUSINESS OF THE CORPORATION

17. BY SUBMITTING THIS STATEMENT OF INFORMATION TO THE CALIFORNIA SECRETARY OF STATE, THE CORPORATION CERTIFIES THE INFORMATION
CONTAINED HEREIN, INCLUDING ANY ATTACHMENTS, IS TRUE AND CORRECT.
1 2/06/2016 STEVE HAGHANI ACCOUNTANT
DATE TYPE/PRINT NAME OF PERSON COMPLETING FORM TITLE SIGNATURE
S- (R 01 01 ) PROVED B E R YO TE
EXHIBIT G
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