Mohammad Tehrani v. City of Los Angeles et al.

I. Introduction

On September 16, 2021, Mohammad Tehrani (“Plaintiff” or “Tehrani”) brought this action against City of Los Angeles (“City”), Derek Anthony Dale (“Dale”) and Does 1–1001 (collectively, “Defendants”) in the Los Angeles Superior Court, asserting claims arising from an alleged assault and wrongful arrest. Dkt. 1-1. On September 19, 2023, the Superior Court clerk entered default against Dale, who had failed to appear in the action. Dkt. 1-36. On June 4, 2025, Plaintiff filed a First Amended Complaint, which is the operative one. Dkt. 1-64. Dale was not served the First Amended Complaint.

The FAC advances the following causes of action:

1. Monell liability - City (42 U.S.C. § 1983); 2. Conspiracy to Violate Civil Rights (42 U.S.C. § 1985(3)); 3. Violation of the Bane Act (California Civil Code § 52.1); 4. Battery; 5. False Arrest and False Imprisonment; 6. Intentional Infliction of Emotional Distress; 7. Municipal Vicarious Liability (Ca. Gov’t. Code § 815.2); 8. Negligence; and 9. Civil conspiracy.

Dkt. 1-64 ¶¶ 28–99. The First, Third, Fourth, Fifth, Sixth, Seventh, and Eighth Causes of Action are asserted against the City. The Second, Third, Fourth, Sixth, and…