S. David Sedaghat v. Jerry Roles

I. INTRODUCTION

On October 22, 2024, plaintiff S. David Sedaghat (“Sedaghat” or “plaintiff’), appearing in pro per, filed this action in Los Angeles County Superior Court against the following defendants: the United States Department of Health and Human Services (“HHS”): the United States Trustee Program (“USTP”); the California Department of Consumer Affairs; the California Franchise Tax Board; Jerry Roles; SAVA SeniorCare Administrative Services, LLC: SSCTOC Assignment for the Benefit of Creditors LLC (“SSCTOC”):' Tarzana Health and Rehabilitation; SSC Tarzana Operating Company, LP LLC; SSC Equity Holdings LLC; Jonathan J. Wernick; and Does 1-50. Dkt. 1-4 (“Compl.”). The Court refers to HHS and USTP as the “Federal Defendants,” the California Department of Consumer Affairs and the California Franchise Tax Board as the “State Defendants,” and the remaining defendants as the “individual and SAVA defendants.”? Sedaghat asserted eight claims: (1) negligence; (2) fraud; (3) conspiracy: (4) public endangerment; (5) unjust enrichment; (6) breach of fiduciary duty; (7) violation of the Uniform Fraudulent Transfer Act, Cal. Civ. Code § 3439 et seq.: and (8) Although not…