JACOBY & MEYERS ATTORNEYS LLP

1 SHANE HAPUARACHY, State Bar No. 271887 E-FILED

[email protected] 1/27/2022 12:30 PM
2 GRETA M. CURRY, State Bar No, 328584 Superior Court of California
County of Fresno
[email protected]
3 10900 Wilshire Boulevard, 15th Floor By: I. Herrera, Deputy
Los Angeles, California 90024
4 Tel: (310) 312-3300 | Fax: (310) 715-8331
5 Attorneys for Plaintiffs, SHARON RICHARDSON, CHARLES RICHARDSON, BRANDON
ROGERS, and SUSAN DAHLSTROM
6

7 SUPERIOR COURT OF THE STATE OF CALIFORNIA

8 COUNTY OF FRESNO
9
Telephone: (310) 312-3300 Facsimile: (310) 715-8331

10
22CECG00280
SHARON RICHARDSON, an individual; Case No.:
CHARLES RICHARDSON, an individual;
JACOBY & MEYERS ATTORNEYS LLP
10900 Wilshire Boulevard, 15th Floor

11 BRANDON ROGERS, and individual; and COMPLAINT FOR DAMAGES:

Los Angeles, California 90024

SUSAN DAHLSTROM, an individual,

12 1. PREMISES LIABILITY
Plaintiffs,
13 2. NEGLIGENCE
vs. 3. WRONGFUL DEATH
14
TRAIL’S END MOBILE HOME PARK, 4. SURVIVOR’S ACTION
15 entity type unknown; JOAN KEVORKIAN, an
individual; THE COUNTY OF FRESNO, a DEMAND FOR JURY TRIAL
16 public entity; THE CITY OF FRESNO, a
public entity; the CALIFORNIA
17 DEPARTMENT OF HOUSING AND
COMMUNITY DEVELOPMENT, a public
18 agency; and DOES 1 through 50, inclusive,
19 Defendants.
20

21
COMES NOW SHARON RICHARDSON, CHARLES RICHARDSON, BRANDON
22
ROGERS, individually and as the successors in interest to RONALD RICHRDSON, and SUSAN
23
DAHLSTROM (collectively, “Plaintiffs”) complain and allege as follows:
24
INTRODUCTION
25
On April 29, 2021, RONALD RICHARDSON (the “Decedent”) tragically perished while
26
he was a visitor at Defendant TRAIL’S END MOBILE HOME PARK (the “PARK”). The
27
Decedent along with a friend, Plaintiff SUSAN DAHLSTROM (“DAHLSTROM”), were visiting
28

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PLAINTIFF’S COMPLAINT FOR PERSONAL INJURIES
 1 the mobile home located at Unit #27. Once the fire broke out, the Decedent entered the unit
2 several times to rescue others who were stuck inside, including DAHLSTROM. He was able to
3 help multiple people inside the unit escape, but ultimately could not escape himself. He was
4 trapped inside the burning unit and succumbed to his injuries.
5 At the time of the incident, the PARK had been cited numerous times over the previous
6 years for a number of habitability issues, including but not limited to, various fire hazards. The
7 PARK did not make any efforts to address the violations. These fire hazards, which included a
8 great deal of trash, old appliances and other combustible debris, continued to pile up. These
9 hazards resulted in multiple fires in the PARK leading up to the April 29, 2021 fire. Given the
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10 failure to address the violations, Defendant CALIFORNIA DEPARTMENT OF HOUSING AND

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COMMUNITY DEVELOPMENT (“HCD”) suspended the PARK’s license to operate just three
10900 Wilshire Boulevard, 15th Floor

11
Los Angeles, California 90024

12 months prior to the April fire. Despite the violations, the fires, and the suspension, the PARK
13 continued to operate. Neither the HCD, Defendant COUNTY OF FRESNO (the “COUNTY OF
14 FRESNO”), nor Defendant the CITY OF FRESNO (the “CITY OF FRESNO”) used the authority
15 vested in them to shut down the PARK, which would have prevented this tragic incident.
16 THE PARTIES
17 1. Plaintiff SHARON RICHARDSON is, and at all relevant times was, a resident of
18 Fresno, County of Fresno, State of California. She is the mother of the Decedent.
19 Plaintiff SHARON RICHARDSON is the successor in interest to the Estate of Decedent as
20 provided in California Code of Civil Procedure section 377.60. Plaintiff SHARON
21 RICHARDSON makes this claim for survivor benefits and the wrongful death of Decedent.
22 2. Plaintiff CHARLES RICHARDSON is, and at all relevant times was, a resident of
23 Fresno, County of Fresno, State of California. He is the father of the Decedent.
24 Plaintiff CHARLES RICHARDSON is the successor in interest to the Estate of Decedent as
25 provided in California Code of Civil Procedure section 377.60. Plaintiff CHARLES
26 RICHARDSON makes this claim for survivor benefits and the wrongful death of Decedent.
27 3. Plaintiff BRANDON ROGERS is, and at all relevant times was, a resident of
28 Fresno, County of Fresno, State of California. He is the son of the Decedent. Plaintiff BRANDON

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PLAINTIFF’S COMPLAINT FOR PERSONAL INJURIES
 1 ROGERS is the successor in interest to the Estate of Decedent as provided in California Code of
2 Civil Procedure section 377.60. Plaintiff BRANDON ROGERS makes this claim for survivor
3 benefits and the wrongful death of Decedent.
4 4. Plaintiff SUSAN DAHLSTROM at all relevant times was, a resident of Fresno,
5 County of Fresno, State of California.
6 5. Plaintiffs are informed and believe and thereon allege that, at all times herein
7 mentioned, defendant PARK and DOES 1-10, were and are California corporations authorized to
8 do business and doing business in the County of Fresno, State of California.
9 6. Plaintiffs are informed and believe and thereon allege that, at all times herein
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10 mentioned, defendant JOAN KEVORKIAN and DOES 11-20, were individuals and entities that
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10900 Wilshire Boulevard, 15th Floor

11 own and operate PARK.

Los Angeles, California 90024

12 7. Plaintiffs are informed and believe and thereon allege that, at all times herein
13 mentioned, defendant HCD and DOES 21-30, is and was a public agency, governed by the State
14 of California, with the plenary responsibility for inspecting and issuing citations to Mobile Home
15 Parks throughout the State.
16 8. Plaintiffs are informed and believe that defendant COUNTY OF FRESNO and
17 DOES 31-40, is and was at all times pertinent, a public entity within the State of California and
18 transacting business within the State.
19 9. Plaintiffs are informed and believe that defendant CITY OF FRESNO, and DOES
20 41-50, is and was at all times pertinent, a public entity within the jurisdiction of Fresno County,
21 California and transacting business in Fresno County.
22 10. The true names and capacities, whether individual, plural, corporate, partnership,
23 associate or otherwise of DOES 1 through 50, inclusive, are presently unknown to Plaintiffs, who
24 therefore sue said Defendants by such fictitious names. The full extent of the facts linking such
25 factiously sued Defendants with the causes of action alleged herein is unknown to Plaintiffs.
26 Plaintiffs are informed and believe, and thereupon allege, that each of the Defendants designated
27 herein as a DOE was and is negligently, carelessly, recklessly, unlawfully, tortuously, wantonly,
28 wrongfully, illegally, or in some other actionable matter, responsible for the events and

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PLAINTIFF’S COMPLAINT FOR PERSONAL INJURIES
 1 happenings hereinafter referred to, and thereby negligently, carelessly, recklessly, unlawfully,
2 tortuously, wantonly, wrongfully, and illegally proximately caused the hereinafter described
3 injuries and damages to Plaintiffs. Plaintiffs will later file an amendment to this Complaint or
4 seek leave of Court to amend this Complaint to show Defendants’ true names and capacities after
5 the same has been ascertained.
6 11. Plaintiffs are informed and believe, and thereupon allege, that at all times
7 mentioned herein, Defendants, and each of them, including DOES 1 through 50, inclusive, and
8 each of them, were agents, servants, employees and joint venturers of each other, and were, as
9 such, acting within the course, scope and authority of said agency, employment and joint venture,
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10 and that each and every Defendant, as aforesaid, when acting as a principal, was negligent in the
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11 selection and hiring of each and every Defendant as an agent, employee, contractor, subcontractor
Los Angeles, California 90024

12 and joint venture, and that each Defendant, by and through its officers, officials, directors,
13 managers, supervisors and/or managing agents, authorized, ratified and otherwise approved the
14 acts of the remaining Defendants, and that said officers, directors, or managing agents participated
15 in said acts with the Defendants, including DOES 1 through 50, inclusive, and each of them.
16 JURISDICTION AND VENUE
17 12. This court has jurisdiction in this matter pursuant to California Code of
18 Civil Procedure Section 410.10 because the accident, incident, death, and/or injury occurred
19 within Fresno County, State of California.
20 13. Plaintiffs are required to comply with a claim statute and have complied with said
21 statute, said claims being rejected by Defendant HCD through the State of California on January 6,
22 2022.
23 14. Plaintiffs are required to comply with a claim statute and have complied with said
24 statute, said claims being rejected by Defendant COUNTY OF FRESNO on October 19, 2021.
25 15. Plaintiffs are required to comply with a claim statute and have complied with said
26 statute, said claims being rejected by Defendant CITY OF FRESNO on November 5, 2021.
27 16. The claims asserted herein against Defendant HCD, CITY OF FRESNO and
28 COUNTY OF FRESNO are presented pursuant to California Government Code Sections 815.2,

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PLAINTIFF’S COMPLAINT FOR PERSONAL INJURIES
 1 815.4 and 815.6.
2 GENERAL ALLEGATIONS
3 17. Plaintiffs repeat, reallege and incorporate by this reference as though set forth in
4 full herein all prior allegations of this Complaint.
5 18. Plaintiffs are informed and believe, and thereon allege, that at all times herein
6 mentioned, Defendant PARK is a mobile home park located at 104 E. Sierra Ave., Fresno, CA
7 93710.
8 19. Plaintiffs are informed and believe, and thereon allege, that at all times herein
9 mentioned, PARK was negligently maintained, operated, managed, inspected and otherwise
Telephone: (310) 312-3300 Facsimile: (310) 715-8331

10 controlled in such a way that the PARK presented a public nuisance and presented a danger to its
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10900 Wilshire Boulevard, 15th Floor

11 inhabitants and guests.

Los Angeles, California 90024

12 20. Plaintiffs are informed and believe, and thereon allege, that the PARK, CITY OF
13 FRESNO, COUNTY OF FRESNO and HCD received numerous complaints from the PARK
14 residents about the various conditions on the premises for a number of years, yet did nothing to
15 rectify the problem.
16 21. Plaintiffs are informed and believe, and thereon allege, that HCD, as the state
17 agency with the primary responsibility and duty of inspecting mobile home parks made numerous
18 inspections of the PARK pursuant to the authority vested in them pursuant to California Heath and
19 Safety Code Section 18400.1.
20 22. Plaintiffs are informed and believe, and thereon allege, that HCD issued numerous
21 citations and other notifications to PARK for various violations of the Mobile Home Parks Act,
22 (California Health and Safety Code Division 13, Part 2.1, Section 1800 et. Seq.). These violations
23 were issued over a number of years. The violations included but were not limited to various fire
24 hazards in PARK as outlined below (the list below is not exhaustive):
25 a. On July 7, 2020, HCD issued a notice of violation to PARK for various hazards
26 related to a homeless encampment that had been erected in the PARK. In
27 addition to suspected illegal activity going on, the homeless and other tenants in
28 the PARK had allowed a great deal of trash, debris and other combustible

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PLAINTIFF’S COMPLAINT FOR PERSONAL INJURIES
 1 materials to accumulate around the PARK.
2 b. On September 25, 2020, HCD again issued a notice of violation for various
3 hazards in PARK that had not been remedied.
4 c. On October 1, 2020, HCD issued a Final Compliance Order to PARK for
5 failure to correct the violations, ordering PARK to remedy violations within 35
6 days.
7 d. On November 18, 2020, an additional notice of violation was issued to PARK
8 for failure to correct similar violations.
9 e. On November 23, 2020, HCD issued a Notice of Intent to Suspend PARK’s
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10 operational permit. This notice was posted at the PARK.

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11 f. On January 19, 2021, HCD issued yet another Notice of Violation for failure to
Los Angeles, California 90024

12 correct various hazards around the PARK.

13 23. Plaintiffs are informed and believe, and thereon allege, that CITY OF FRESNO
14 was also well aware of various problems and hazards in PARK. CITY OF FRESNO received
15 numerous complaints about PARK going back a number of years. These complaints are outlined
16 below (the list below is not exhaustive):
17 a. On February 28, 2017, Fresno City Police were notified about trash, rubbish
18 debris and other fire hazards contained in PARK.
19 b. On July 29, 2019, Fresno Code Enforcement received a complaint about junk,
20 garbage, inoperable vehicles and other fire hazards contained in PARK.
21 c. On August 22, 2019, CITY OF FRESNO received multiple complaints
22 regarding the accumulation of garbage, broken appliances, and other debris in
23 PARK.
24 d. On May 11, 2020, CITY OF FRESNO received a complaint about substandard
25 conditions, garbage, debris, feces and other human waste piling up in PARK.
26 e. On July 17, 2020, CITY OF FRESNO received a complaint about junk,
27 rubbish, debris and other fire hazards contained in PARK.
28 24. Plaintiffs are informed and believe, and thereon allege, that on January 21, 2021,

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PLAINTIFF’S COMPLAINT FOR PERSONAL INJURIES
 1 after numerous violations and failures by PARK to correct the violations, HCD suspended
2 PARK’s license to operate.
3 25. Plaintiffs are informed and believe, and thereon allege, that despite the suspension
4 of its license, PARK continued to operate, business as usual, and made no attempts to correct the
5 violations.
6 26. Plaintiffs are informed and believe, and thereon allege, that HCD, CITY OF
7 FRESNO, and COUNTY OF FRESNO all had a shared, mandatory duty to either enforce its
8 citations, bring an abatement action, or close the park down pursuant to California Health and
9 Safety Code Section 18402.
Telephone: (310) 312-3300 Facsimile: (310) 715-8331

10 27. Plaintiffs are informed and believe, and there on allege, that despite this duty,
JACOBY & MEYERS ATTORNEYS LLP
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11 HCD, the CITY OF FRESNO, and the COUNTY OF FRESNO, failed to act.
Los Angeles, California 90024

12 28. Plaintiffs are informed and believe, and thereon allege, that multiple fires were
13 ignited in the PARK due to the various fire hazards in 2020 and early 2021. HCD, CITY OF
14 FRESNO and the COUNTY OF FRESNO were aware of these fires.
15 29. Plaintiffs are informed and believe, and thereon allege, that on April 29, 2021,
16 while the Decedent and DAHLSTROM were guests at one of the units in the PARK, a fire broke
17 out. Given the hazards present in the PARK, the fire quickly spread. Due to the nature of the fire
18 combined with the existing hazards, the unit in which Decedent and DAHLSTROM were visiting
19 became engulfed in flames. Decedent lost his life, and DAHLSTROM sustained serious injury.
20
FIRST CAUSE OF ACTION
PREMISES LIABILITY
21
(Defendants PARK, JOAN KEVORKIAN, and DOES 1 through 20)
22 30. Plaintiffs re-allege and incorporate by reference each and every allegation above as
23 though full set forth in detail herein.
24 31. Defendants, and each of them, had a duty to use reasonable care to keep the
25 premises in a reasonably safe condition for use by Plaintiffs and others similarly situated.
26 Defendants, and each of them, had a duty to use reasonable care to discover any unsafe conditions
27 on the premises and to repair, replace, or give adequate warning of anything that could reasonably
28 be expected to harm others.

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PLAINTIFF’S COMPLAINT FOR PERSONAL INJURIES
 1 32. Defendants, and each of them, breached their above-described duties and failed to
2 use reasonable care to protect Decedent and Plaintiffs and others similarly situated form the
3 foreseeable harm caused by the dangerous and unsafe conditions that existed at the premises.
4 Defendants knew or should have known that the dangerous conditions were present and/or
5 Defendants (and/or their employees or agents) created such conditions. Defendants failed to take
6 reasonable steps to repair, replace, or give adequate warning of the dangerous and unsafe
7 conditions, which Defendants, and each of them, created or otherwise failed to repair
8 despite reasonable time and opportunity to take corrective action.
9 33. The above-described conditions created an unreasonable risk of harm which
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10 Defendants and each of them, knew about, either because the Defendants created the condition or
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11 because Defendants, in the exercise of reasonable care, should have discovered through
Los Angeles, California 90024

12 reasonable, periodic inspections of the property.

13 34. Defendants’ breach of their duty of care was a legal cause of, and a substantial
14 factor in, Plaintiffs’ harm and damages as alleged herein. As a proximate result of the conduct of
15 the Defendants, and each of them, Decedent and DAHLSTROM sustained losses in an amount to
16 be determined at trial, including but not limited to, physical injuries to their bodies requiring
17 medical treatment and care, physical pain and mental suffering, loss of earnings and the capacity
18 to maintain gainful employment, among other general and special damages in an amount to be
19 determined according to proof.
20
SECOND CAUSE OF ACTION
NEGLIGENCE
21
(All Defendants)
22 35. Plaintiffs re-allege and incorporate by reference each and every allegation above as
23 though fully set forth in detail herein.
24 36. Plaintiffs are informed and believe and thereupon allege that Defendant PARK,
25 JOAN KEVORKIAN, HCD, CITY OF FRESNO, and COUNTY OF FRESNO; and DOES 1
26 through 20, and each of them, owned, leased, operated, maintained, designed, installed, built,
27 managed, supervised, inspected and/or otherwise controlled a mobile home park located at 104 E.
28 Sierra Ave., Fresno, CA 93710.

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PLAINTIFF’S COMPLAINT FOR PERSONAL INJURIES
 1 37. Defendants PARK, JOAN KEVORKIAN, HCD, CITY OF FRESNO, and
2 COUNTY OF FRESNO; and DOES 1 through 20, and each of them, owed a duty to Plaintiffs to
3 exercise ordinary care and skill to avoid causing foreseeable harm to Plaintiffs and other similarly
4 situated persons.
5 38. Defendants PARK, JOAN KEVORKIAN, HCD, CITY OF FRESNO, and
6 COUNTY OF FRESNO, and DOES 1 through 20, and each of them, breached that duty of care by
7 negligently and carelessly managing, operating, inspecting, controlling,
8 supervising and/or maintaining the premise in a reasonably safe condition by, without limitation,
9 failing to inspect, abate, enforce the numerous violations and otherwise address the numerous fire
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10 hazards contained within the premises despite both actual and constructive knowledge of the
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hazards. Prior to DAHLSTROM’s injury and the death of Decedent, this condition existed for
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Los Angeles, California 90024

12 sufficient time to have been discovered by Defendants in the exercise of due care, and would have
13 been so discovered by a reasonably adequate inspection system maintained, operated and enforced
14 with due care. Although Defendants should have known about the danger, they did nothing to fix
15 the problem or adequately warn Decedent and Plaintiffs about it.
16 39. On or about April 29, 2021, Decedent and DAHLSTROM were lawfully at and
17 upon the premises when they were trapped in a fire that broke out. Decedent and DAHLSTROM
18 were injured as a direct and proximate result of encountering the unsafe and dangerous conditions
19 that existed at Defendants’ premise. Decedent lost his life.
20 40. As a proximate result of the conduct of the Defendants, and each of them, Decedent
21 and DAHLSTROM sustained losses in an amount to be determined at trial, including but not
22 limited to, physical injuries to his body requiring medical treatment and care, physical pain and
23 mental suffering, loss of earnings and the capacity to maintain gainful employment, among other
24 general and special damages in an amount to be determined according to proof.
25 THIRD CAUSE OF ACTION
26
WRONGFUL DEATH
(All Defendants)
27
41. Plaintiffs re-allege and incorporate by reference each and every allegation above as
28
though fully set forth in detail herein.

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PLAINTIFF’S COMPLAINT FOR PERSONAL INJURIES
 1 42. Plaintiffs SHARON RICHARDSON, CHARLES RICHARDSON and BRANDON
2 ROGERS will sustain pecuniary and non-pecuniary losses by reasons of the death of Decedent.
3 43. As discussed herein, Plaintiffs SHARON RICHARDSON, CHARLES
4 RICHARDSON and BRANDON ROGERS are entitled under Sections 377 of the California Code
5 of Civil Procedure to bring action on behalf of Decedent for the injuries and damages Decedent
6 sustained prior to his death as a result of the above described acts or omissions of Defendants.
7 44. Defendants are liable for the wrongful death of Decedent stemming from the herein
8 allegations.
9 45. As a proximate and legal result of Defendants’ conduct, Plaintiffs SHARON
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10 RICHARDSON, CHARLES RICHARDSON and BRANDON ROGERS have been injured in an

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11 amount not presently ascertained. Such damages include loss of comfort and companionship, loss
Los Angeles, California 90024

12 of affection, emotional pain, distress and suffering, and general damages not presently ascertained.
13 At such time as Plaintiffs SHARON RICHARDSON, CHARLES RICHARDSON and
14 BRANDON ROGERS are able to ascertain these damages, they will amend the complaint to
15 include these damages.
16 46. By reason of the occurrence made the basis of this suit, the support, inheritance and
17 contributions which Decedent made and would have made to Plaintiffs SHARON
18 RICHARDSON, CHARLES RICHARDSON and BRANDON ROGERS have been forever swept
19 away. Accordingly, Plaintiffs SHARON RICHARDSON, CHARLES RICHARDSON and
20 BRANDON ROGERS seek to recover a sum of money that would fairly and reasonably
21 compensate them for their pecuniary losses such as the loss of companionship, maintenance,
22 support, services, advice, counsel, and all other reasonable contributions having a pecuniary value.
23 47. Plaintiffs SHARON RICHARDSON, CHARLES RICHARDSON and BRANDON
24 ROGERS are also entitled to recover their pecuniary losses in the form of the lost earnings or
25 earning capacity and/or loss of household services which Decedent would have contributed to the
26 family had his life not been lost at the hands of the Defendant. Plaintiffs SHARON
27 RICHARDSON, CHARLES RICHARDSON and BRANDON ROGERS have also incurred
28 and seek to recover reasonable and customary medical bills for services rendered in an effort to

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PLAINTIFF’S COMPLAINT FOR PERSONAL INJURIES
 1 save Decedent’s life as well as reasonable and customary bills for Decedent’s funeral and burial.
2 FOURTH CAUSE OF ACTION
3
SURVIVOR CLAIM
(All Defendants)
4
48. Plaintiffs re-allege and incorporate by reference each and every allegation above as
5
though fully set forth in detail herein.
6
49. Plaintiffs SHARON RICHARDSON, CHARLES RICHARDSON and BRANDON
7
ROGERS are the successors in interest for purposes of bringing an action under CCP Section
8
377.30, et seq. Plaintiffs have and/or will comply with CCP Section 377.32.
9
50. Prior to his death, and in connection with his death, Decedent suffered extreme, and
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devastating injury, resulting in severe pain and suffering as a result of the injuries and what he was
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forced to endure prior to his death. The pain and suffering sustained by Decedent was a direct
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result of Defendants’ negligence. Decedent also incurred medical and incidental expenses prior to
13
his death. The general damages is an unknown amount that is rightfully left to the finder of fact.
14
The exact amount of medical expenses is unknown to Plaintiffs at this time.
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PLAINTIFF’S COMPLAINT FOR PERSONAL INJURIES
 1 PRAYER FOR RELIEF
2 WHEREFORE, Plaintiffs pray for judgment against the Defendants, and each of them, as
3 follows:
4 1. For past and future general damages, according to proof;
5 2. For special and compensatory damages, to the extent authorized by law, according
6 to proof;
7 3. For pre- and post-judgment interest;
8 4. For costs of suit incurred herein;
9 5. For such other and further relief as the Court deems just and proper.
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Dated: January 25, 2022 JACOBY & MEYERS ATTORNEYS LLP
JACOBY & MEYERS ATTORNEYS LLP
10900 Wilshire Boulevard, 15th Floor

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Los Angeles, California 90024

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By: ______________________________
13
Shane Hapuarachy
14 Greta Curry
Attorneys for Plaintiffs, SHARON
15 RICHARDSON,CHARLES
RICHARDSON, BRANDON
16 RICHARDSON, and SUSAN
DAHLSTROM
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PLAINTIFF’S COMPLAINT FOR PERSONAL INJURIES
 1 DEMAND FOR TRIAL BY JURY
2 Plaintiffs hereby demands a trial by jury on all issues triable by jury.
3
Dated: January 25, 2022 JACOBY & MEYERS ATTORNEYS LLP
4

6
By: ______________________________
7 Shane Hapuarachy
Greta Curry
8 Attorneys for Plaintiffs, SHARON
RICHARDSON, CHARLES
9 RICHARDSON, BRANDON
RICHARDSON, and SUSAN
Telephone: (310) 312-3300 Facsimile: (310) 715-8331

10 DAHLSTROM
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10900 Wilshire Boulevard, 15th Floor

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Los Angeles, California 90024

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