Hakim-Baba

I. BACKGROUND

A. The Pleadings Hakim-Baba sued defendants in April 2020. Hakim-Baba alleged he paid defendants $3.9 million in connection with an agreement that would provide him a membership interest in I & P (the “I & P Purchase Agreement”) and defendants had used about $2 million of Hakim-Baba’s payment to buy a property on Carmel Valley Road. But one of the individual defendants took title to the Carmel Valley property. Hakim-Baba alleged three causes of action. First, Hakim-Baba sought title to the Carmel Valley property through a quiet title claim. Second, Hakim-Baba sought damages, including statutory double damages and punitive damages, through a financial elder abuse claim.1 Third, Hakim-Baba sought rescission, including a return of his $3.9 million and the economic costs he incurred to procure those funds. Hakim-Baba sought interest on all “damages and/or restitution awarded.” Hakim-Baba alleged his contractual entitlement to attorney fees in connection with his financial elder abuse and rescission claims. In his operative fourth amended complaint, filed about a year later, Hakim-Baba included more detail in his factual allegations and more causes of action.…