Bob-Lee-civil-suit

-1- COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 BD&J, PC OLIVIER ALAIN TAILLIEU, ESQ. [SBN 206546] ot@bhattorneys.com ELIZABETH A. HERNANDEZ, ESQ. [SBN 204322] eah@bhattorneys.com 11175 Santa Monica Blvd. Los Angeles, California 90025 Telephone: (310) 887-1818 Facsimile: (424) 522-1351 GUTMAN LAW ALAN S. GUTMAN, ESQ. [SBN 128514] alangutman@gutmanlaw.com 9350 Wilshire Boulevard, Suite 350 Beverly Hills, CA 90212 Telephone: (310) 385-0700 Attorneys for Plaintiffs, THE ESTATE OF ROBERT HAROLD LEE, by and through its personal representative, TIMOTHY OLIVER LEE; DAGNY LEE, an individual; and SCOUT LEE, a minor, by and through her Guardian Ad Litem, KRISTA LEE SUPERIOR COURT OF THE STATE OF CALIFORNIA THE ESTATE OF ROBERT HAROLD LEE, by and through its personal representative, TIMOTHY OLIVER LEE; DAGNY LEE, an individual; and SCOUT LEE, a minor, by and through her Guardian Ad Litem, KRISTA LEE, Plaintiffs, v. NIMA MOMENI, an individual; KHAZAR MOMENI, an individual; DINO ELYASSNIA, M.D., an individual; MAHNAZ TAYARANI, an individual; SECURITAS SECURITY SERVICES USA, INC., a Delaware corporation; PORTSIDE HOMEOWNERS’ ASSOCIATION, a California Nonprofit Corporation; PORTSIDE MASTER OWNERS’ASSOCIATION, a California Nonprofit Corporation; SF OAKLAND BAY LLC, a Limited Liability Company, and DOES 1 through 100, inclusive. Defendants. Case No.: COMPLAINT FOR DAMAGES: 1) NEGLIGENCE (Survival Action) [CCP § 377.30] 2) WRONGFUL DEATH [CCP § 377.60] 3) AIDING AND ABETTING 4) CONSPIRACY 5) INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS 6) INVASION OF PRIVACY DEMAND FOR JURY TRIAL FOR THE COUNTY OF SAN FRANCISCO CGC-25-623810 ELECTRONICALLY F I L E D Superior Court of California, County of San Francisco 03/28/2025 Clerk of the Court BY: SAHAR ENAYATI Deputy Clerk -2- COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 COME NOW Plaintiffs, THE ESTATE OF ROBERT HAROLD LEE, by and through its personal representative, TIMOTHY OLIVER LEE; DAGNY LEE, an individual; and SCOUT LEE, a minor, by and through her Guardian Ad Litem, KRISTA LEE (collectively “Plaintiffs”), for causes of action against Defendants NIMA MOMENI, an individual; KHAZAR MOMENI, an individual; DINO ELYASSNIA, M.D., an individual; MAHNAZ TAYARANI, an individual; SECURITAS SECURITY SERVICES USA, INC., a Delaware corporation; PORTSIDE HOMEOWNERS’ ASSOCIATION, a California Nonprofit Corporation; PORTSIDE MASTER OWNERS’ASSOCIATION, a California Nonprofit Corporation; SF OAKLAND BAY LLC, a Limited Liability Company, and DOES 1 through 100, inclusive (collectively “DEFENDANTS”) as follows: THE PARTIES 1. Plaintiff DAGNY LEE (hereinafter “Dagny” or “Plaintiff”) is and was at all times herein mentioned, an individual, residing in the County of Marin, State of California. Plaintiff DAGNY LEE is an adult, and his date of birth is August 22, 2005. 2. Plaintiff SCOUT LEE (hereinafter “Scout” or “Plaintiff”), a minor, by and through her Guardian Ad Litem, KRISTA LEE, is and was at all times herein mentioned, an individual, residing in the County of Marin, State of California. Krista Lee (hereinafter “Krista,” “ex-wife,” or “Guardian ad Litem for Scout Lee”) is the natural mother of Plaintiff SCOUT LEE. Plaintiff SCOUT LEE is a minor and her date of birth is June 22, 2008. 3. Plaintiffs DAGNY LEE and SCOUT LEE (collectively, “Plaintiffs”) are the biological children of Decedent, ROBERT HAROLD LEE (hereinafter, “Bob,” “Bob Lee” or “Decedent”), who was born on December 20, 1979. Decedent died in the city and county of San Francisco, California, on April 4, 2023, at the age of 43. 4. As the surviving heirs of the Decedent under the applicable laws of intestate succession, Plaintiffs DAGNY LEE and SCOUT LEE, by and through her Guardian ad Litem, KRISTA LEE, are the persons entitled to bring a wrongful death action under California Code of Civil Procedure § 377.60. -3- COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 5. Plaintiff THE ESTATE OF ROBERT HAROLD LEE is and was at all times herein mentioned, an established estate that is being handled by its personal representative, TIMOTHY OLIVER LEE. 6. Defendant NIMA MOMENI (hereinafter, “Nima” or “Defendant Nima Momeni”), is and was at all relevant times herein mentioned, an individual residing in the State of California. On the date of Bob Lee’s death on April 4, 2013, Defendant NIMA MOMENI was residing in the city of Emeryville, County of Marin, State of California. He is currently incarcerated at San Francisco County Jail #3 in the County of San Mateo, State of California. 7. Defendant KHAZAR MOMENI (hereinafter, “Khazar” or “Defendant Khazar Momeni”), is and was at all relevant times herein mentioned, an individual residing in the County of San Francisco, State of California. 8. Defendant DINO ELYASSNIA, M.D. (hereinafter, “Dr. Elyassnia” or “Defendant Dino Elyassnia, M.D.”), is and was at all relevant times herein mentioned, an individual residing in the County of San Francisco, State of California. 9. Defendant MAHNAZ TAYARANI (hereinafter, “Defendant Tayarani” or “Defendant Mahnaz Tayarani”), is and was at all relevant times herein mentioned, an individual residing in the County of Marin, State of California. 10. Defendant PORTSIDE HOMEOWNERS’ ASSOCIATION, a California Nonprofit Corporation (hereinafter, “Defendant Portside Homeowners’ Association”), owns, controls, manages, and operates a condominium complex known as The Portside II, located at 403 Main Street, San Francisco, CA 94105, including, but not limited to its closed-circuit televisions (“CCTV”), and surveillance and/or security video footage. Defendant PORTSIDE HOMEOWNERS’ ASSOCIATION regularly transacts business in the County of San Francisco, State of California. 11. Defendant PORTSIDE MASTER OWNERS’ ASSOCIATION, a California Nonprofit Corporation (hereinafter, “Defendant Portside Master Owners’ Association”), owns, controls, manages, and operates an apartment complex known as The Portside II, located at 403 Main Street, San Francisco, CA 94105, including, but not limited to closed-circuit televisions -4- COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 (“CCTV”), and surveillance and/or security video footage. Defendant PORTSIDE MASTER OWNERS’ ASSOCIATION regularly transacts business in the County of San Francisco, State of California. 12. Defendant SECURITAS SECURITY SERVICES USA, INC. is a Delaware corporation that controls, manages, and operates the security and security systems including, but not limited to, closed-circuit televisions (“CCTV”), and surveillance and/or security video footage, for a condominium complex known as The Portside II, located at 403 Main Street, San Francisco, CA 94105. Defendant SECURITAS SECURITY SERVICES USA, INC. regularly transacts business in the County of San Francisco, State of California. 13. Defendant, SF OAKLAND BAY LLC, a Limited Liability Company, is the owner, controller, manager, agent, director and/or operator of The Portside II in San Francisco, California. Defendant SF OAKLAND BAY LLC, a Limited Liability Company, regularly transacts business in the County of San Francisco, State of California. 14. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, Defendants DOES 1 through 100 are persons or entities whose true names and identities are presently unknown to Plaintiffs, and who, therefore, are sued under fictitious names. Plaintiffs are also informed and believe, and thereon allege, that at all times mentioned herein, Defendants, and each of them, including DOES 1 through 100, inclusive, are, and at all times mentioned herein were, the employers, partners, agents, servants, representatives, alter egos, employees, successors in interest, and/or joint venturers of each of the other Defendants, and that each Defendant was acting within the course and scope of his, her, or its authority as the employer, partner, agent, servant, representative, alter ego, employee, successor in interest, and/or joint venturer of each of the other Defendants and with the permission, consent and ratification of each other Defendant. Consequently, each Defendant named in this Complaint, including DOES 1 through 100, inclusive, is jointly and severally liable to Plaintiffs for the damages sustained as a proximate result of their conduct. Plaintiffs will hereafter seek leave of Court to amend this Complaint to show the true names and capacities of Defendants after the same have been ascertained. Each reference within this Complaint to “Defendants,” -5- COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 “Defendants’” or to a specifically named Defendant shall refer to all Defendants, including fictitiously named Defendants, unless the context indicates otherwise. 15. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, at all times herein mentioned, the acts and omissions of various Defendants, and each of them, concurred and contributed to the various acts and omissions of each and all of the other Defendants in proximately causing the injuries and damages to Plaintiffs as herein alleged. 16. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, at all times herein mentioned, Defendants, and each of them, including DOES 1 through 100, ratified each and every act or omission complained of herein. 17. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, Defendants, and each of them, collectively, were members of, and engaged in, a common enterprise, and acting within the course and scope of, and in pursuance of, said common enterprise. 18. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, Defendants, and each of them, aided and abetted the acts and omissions of each and all of the other Defendants in proximately causing the injuries and damages to Plaintiffs as herein alleged. Plaintiffs are also informed and believe and based thereon allege, that at all times herein mentioned, each Defendant conspired with and aided and abetted each and every other Defendant in committing the acts and omissions alleged herein. JURISDICTION AND VENUE 19. Venue is proper in the County of San Francisco pursuant to Section 395(a) of the California Code of Civil Procedure because the subject incident causing Decedent’s injuries, death and damages occurred in San Francisco County, California, including the acts and omissions complained of herein. 20. This Court has jurisdiction over this matter because Defendants either reside and/or conduct business in the State of California. -6- COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 21. The amount of controversy exceeds the jurisdictional minimum of this Court. GENERAL ALLEGATIONS 22. Plaintiffs reallege and incorporate each of the allegations contained in the above paragraphs and by this reference, incorporate said paragraphs as though fully set forth herein. 23. This wrongful death case stems from a heartbreaking tragedy that needlessly cut short the life of a beloved father, son, brother, and friend. On Tuesday, April 4, 2023, 43-year￾old, BOB LEE, tragically died after he was stabbed multiple times with a kitchen knife by Defendant NIMA MOMENI at approximately 2:30 a.m. In short, Defendant NIMA MOMENI murdered Bob Lee. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, Defendant NIMA MOMENI was approximately 38 years old when he murdered BOB LEE near the San Francisco-Oakland Bay Bridge. Bob leaves behind his two children: his son, Dagny Lee, and his daughter, Scout Lee, a minor. Bob also leaves behind his father, brother, and his ex-wife, Krista Lee, who is the mother of his children. Although divorced, Bob and Krista remained close friends. 24. Bob was a devoted father to his two children. He lived in Florida, but made frequent trips to San Francisco so that he could spend time with his children. 25. In addition to being a devoted and loving father, Bob was considered to be a mogul in the tech industry. At the time of his death, Bob was the Chief Product Officer (“CPO”) of MobileCoin and the Chief Technology Officer of Square. Prior to those roles, he founded the financial service, Cash App. While he was in his early twenties, Bob helped develop the Android operating system at Google. Bob’s overall contributions to the tech world were significant. His untimely death robbed the world of a brilliant mind and a remarkable innovator in technology. 26. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, in early April 2023, Bob was in the San Francisco area to see his children and to support his daughter, Scout, as she performed in her school’s play. 27. Plaintiffs are informed and believe, and thereon allege, that at all times -7- COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 mentioned herein, on the afternoon of Tuesday, April 3, 2023, Bob attended a party at Jeremy Boivin’s apartment. Bob’s friend, Borzoyeh Mohazzabi (“Bo”), arrived at the party around 3:30 p.m. Some of the guests at the party were consuming alcohol and using recreational drugs. After a short while, Bob and Bo left the party. One of the guests at the party was Defendant KHAZAR MOMENI, who is Defendant NIMA MOMENI’s sister. Bob Lee knew Defendant, KHAZAR MOMENI. As Bob and Bo were leaving, Bob invited Khazar to join them, but she declined and decided to remain at the party. While at the party, Khazar and friends partied with alcohol and recreational drugs including GHB, which is also known as a date rape drug. One of Khazar’s friends woke up after passing out and noticed that Khazar was crying while changing her clothes. Khazar then called for her brother, Defendant NIMA MOMENI and her husband, Defendant DINO ELYASSNIA, M.D. to pick her up from the party. 28. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, after Bob and Bo left the party, they went to the bar at Bob’s hotel. Later, they went to Bob’s room to hang out. During that time, Bob spoke with his ex-wife Krista Lee by phone at around 8:00 p.m. 29. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, video footage from The Millennium Tower recorded the Defendant NIMA MOMENI arriving at the building on April 3, 2023, at approximately 8:31 p.m. while driving a white 2020 BMW Z4 Roadster with a California license plate number 8LZX449. He was wearing a white T-shirt and dark-colored pants. He proceeded to exit the vehicle, walk through the main entrance of The Millennium Tower and take an elevator to a higher floor. 30. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, sometime after Bob spoke with Krista Lee, Bo witnessed Bob receiving a video phone call from Defendant, NIMA MOMENI, and could hear what Bob was saying at the time. Nima had already picked up his sister, Khazar, from the party that Bob and Bo were at earlier in the day. During the video call, Nima aggressively questioned Bob over events that occurred at the party including drug use and Khazar’s conduct. Nima specifically interrogated Bob about “the girls getting naked” at the party, which included his sister. Bo overheard Bob -8- COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 telling Defendant NIMA MOMENI that he wasn’t there, but everything is fine. 31. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, after the video call ended with Defendant NIMA MOMENI, Bob and Bo went to The Battery Club, and subsequently to Bo’s condo. Shortly after midnight, Bo wanted to call it a night. At approximately 12:30 a.m. on Wednesday, April 4, 2023, Bob left Bo’s apartment and decided to continue his evening by taking an Uber and heading over to The Millennium Tower to visit with Defendant KHAZAR MOMENI. When he arrived at Khazar’s condo, he also met Defendant NIMA MOMENI there. Video footage shows Bob entering The Millennium Tower at approximately 12:39 a.m. on April 4, 2023, while wearing a black hoodie with dark-colored pants and black shoes. 32. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, just over an hour of Bob arriving at The Millennium Tower, there is video footage, at approximately 1:58 a.m., of Bob in the elevator at the same luxury condo building leaving with Defendant NIMA MOMENI. At this time, Defendant NIMA MOMENI was wearing a tan-colored jacket with a white collar and a black beanie hat. The two of them took the elevator to the lobby level and exited The Millennium Tower together. They both proceeded to get into Defendant NIMA MOMENI’s white BMW Z4 Roadster. Defendant MINA MOMENI entered the driver’s side of the vehicle, while Bob Lee sat in the front passenger seat. The vehicle remained stationary for approximately seven minutes before while Bob and Defendant NIMA MOMENI were still in the car, before they drove away at approximately 2:07 a.m. 33. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, Defendant NIMA MOMENI drove with Bob to the 400 block of Main Street, which is a secluded area underneath the Bay Bridge. The investigating officers obtained street camera footage from different locations which captured segments of the white BMW travelling to the secluded area from The Millennium Tower. There is also footage of the white BMW driving southbound on Main Street, arriving at the secluded area and parking on the street. 34. Plaintiffs are informed and believe, and thereon allege, that at all times -9- COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 mentioned herein, Defendant NIMA MOMENI and Bob remained in the white BMW for approximately thirteen minutes while it was parked alongside the road, before Bob Lee emerged from the vehicle. 35. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, there is video footage of Defendant NIMA MOMENI attacking Bob Lee. There is distant video footage showing two men, who were wearing clothing that was consistent with the outfits Defendant NIMA MOMENI and Bob Lee were wearing when they left The Millenium Tower together. In the video, the two men appeared to be standing together for about six minutes on the west sidewalk, which bordered a CalTrans fence. The grainy video also captured Defendant NIMA MOMENI suddenly lunging toward Bob Lee. The video also shows Defendant NIMA MOMENI physically advancing toward Bob Lee, while Bob is retreating backwards toward the CalTrans fence. 36. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, Defendant NIMA MOMENI stabbed Bob Lee once in his right hip and at least twice in his left chest. At least one of the stab wounds to Bob’s chest punctured his heart. Bob lost a lot of blood from the stab wounds. 37. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, following the attack, Bob Lee quickly turned and headed northbound on Main Street. From the same video footage that captured the attack, Defendant NIMA MOMENI can be seen following Bob Lee for a few moments before Nima makes an overhand throwing motion near the CalTrans fence. Defendant NIMA MOMENI then appears to head in the same direction as the parked white BMW. 38. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, the San Francisco Police Department acquired video footage from Harrison Street cameras which captures Bob Lee walking away from Main Street, clutching his chest and attempting to use his cell phone. 39. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, after attacking Bob Lee, there is video footage that the San Francisco Police -10- COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Department obtained which captures the white BMW Z4 Roadster pulling away from the scene as Bob Lee is walking northbound on Main Street, and pulling up his shirt to look at his midsection, in the same area where he had been stabbed. There is other video footage of the white BMW Z4 Roadster speeding away from the area at around 2:34 a.m. on April 4, 2023. The investigating officers were able to follow the white BMW Z4 Roadster, through other video surveillance, as it traveled onto the San Francisco Bay Bridge at around 2:37 a.m. on April 4, 2023. 40. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, at around 2:30 a.m., Bob called 911 on his cell phone after being stabbed multiple times. On the 911 call, he can be heard saying that someone had stabbed him and he is pleading for help multiple times. 41. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, that video footage shows Bob staggering down the street and pleading for help from an unknown driver in a stopped vehicle, who ultimately drove away without providing any assistance. The video shows Bob collapsing in the middle of Harrison Street before staggering toward the direction of Main Street. 42. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, video footage obtained from Defendants, PORTSIDE HOMEOWNERS’ ASSOCIATION, PORTSIDE MASTER OWNERS’ ASSOCIATION, SECURITAS SECURITY SERVICES USA, INC., and SF OAKLAND BAY LLC, a Limited Liability Company, and DOES 1 through 100, inclusive, shows Bob staggering down Main Street to the front of The Portside II condominium building located at 403 Main Street, San Francisco, California. Bob can be seen staggering toward a callbox, which is located outside of the front entrance to The Portside II and leaving a trail of blood. He can also be seen falling to the ground, then managing to get up with a struggle while fumbling with his cell phone in hand, before staggering onto Main Street. He collapsed onto Main Street in front of The Portside II. Additional footage shows Bob lying unresponsive on Main Street. 43. Plaintiffs are informed and believe, and thereon allege, that at all times -11- COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 mentioned herein, video footage obtained from Defendants, PORTSIDE HOMEOWNERS’ ASSOCIATION, PORTSIDE MASTER OWNERS’ ASSOCIATION, SECURITAS SECURITY SERVICES USA, INC., and SF OAKLAND BAY LLC, a Limited Liability Company, and DOES 1 through 100, inclusive, was released to the news media without the permission of Bob’s Estate, heirs or family. Bob’s two children, who were both minors at the time of his death, saw the video footage on news reports, and they were horrified at what they saw in the video. The video footage they saw of their father, after he had been stabbed, traumatized them and have caused them significant emotional distress. 44. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, within minutes of Bob’s 911 call, officers from the San Francisco Police Department arrived at the scene and found Bob unresponsive. Officers performed CPR, and Bob was transported to a nearby hospital. 45. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, investigating officers from the San Francisco Police Department obtained video footage that shows Defendant NIMA MOMENI’s white BMW arriving at his Emeryville residence at approximately 2:47 a.m. 46. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, medical doctors and healthcare practitioners tried to save Bob’s life for approximately four hours, but they were not successful. Bob was pronounced dead at approximately 6:49 a.m. on April 4, 2023. 47. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, officers from the San Francisco Police Department were able to follow a blood trail starting about a half a block away from where Bob collapsed. They were able to trace the blood trail backwards from the location where they found him unresponsive to the front of a fenced-off parking lot. On the other side of the fence, officers located a Joseph, Joseph pairing knife, with a black handle and a blade that was approximately 3.5 inches long. There was blood on the blade of the knife. The police sent the knife to a crime lab to obtain a DNA sample. The sample confirmed that the blood on the blade belonged to Bob Lee and -12- COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Defendant NIMA MOMENI’s DNA was on the handle of the knife. 48. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, the San Francisco Police Department collected text messages from Defendant KHAZAR MOMENI to Bob, who was killed before he received the messages, which include, but are not limited to, the following content: • April 4, 2023 at 8:31:14 a.m.: “Just wanted to make sure your doing ok” • April 4, 2023 at 8:31:32 a.m.: “Cause I know nima came wayyyyyy down hard on you” • April 4, 2023 at 8:31:51 a.m.: “And thank you for being such a classy man handling it with class” 49. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, the San Francisco Police Department obtained a search warrant relating to Defendant KHAZAR MOMENI’s home at The Millennium Tower. As part of that lawful search, the San Francisco Police Department discovered that Defendant, KHAZAR MOMENI had a Joseph Joseph knife in her home, which is the same manufacturer of the knife that was used to stab and kill BOB LEE. 50. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, that Defendant, NIMA MOMENI, took a Joseph Joseph pairing knife from his sister’s apartment at The Millennium Tower on April 4, 2023 and used it to repeatedly stab, and subsequently kill, BOB LEE. 51. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, Defendant NIMA MOMENI had already retained a criminal defense attorney within days of Bob’s death. During that time frame, Defendant, NIMA MOMENI had not been interviewed, arrested nor charged with any crime. 52. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, there is video footage which shows Defendant NIMA MOMENI talking to a private investigator in a parking lot just days after Bob’s murder. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, the video footage shows -13- COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Defendant NIMA MOMENI pantomiming to the investigator how he stabbed Bob on April 4, 2023. Plaintiffs are further informed and believe, and thereon allege, that at all times mentioned herein, in the video footage, Defendant NIMA MOMENI is demonstrating to the private investigator how he threw the murder weapon over the fence on April 4, 2023, where law enforcement officers subsequently found it with blood on the blade. 53. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, Defendant NIMA MOMENI hid at his mother’s home sometime after he arrived at his Emeryville residence on April 4, 2023. Defendant MAHNAZ TAYARANI is the mother of Defendant NIMA MOMENI. 54. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, Defendant NIMA MOMENI’s family including, but not limited to, Defendants KHAZAR MOMENI, and DINO ELYASSNIA, M.D., and DOES 1 through 100, inclusive, helped Defendant MAHNAZ TAYARANI, and DOES 1 through 100, inclusive, store his white BMW Z4 Roadster and its contents away from his residence, and at her residence, so that it could not immediately be found by the investigating officers of the San Francisco Police Department and the Plaintiffs. 55. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, Defendants, MAHNAZ TAYARANI, an individual; KHAZAR MOMENI, an individual; DINO ELYASSNIA, M.D., an individual; and DOES 1 through 100, inclusive, attempted to sell Defendant NIMA MOMENI’s white BMW in an effort to hide evidence from law enforcement officers at the San Francisco Police Department and Plaintiffs. 56. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, Defendants, MAHNAZ TAYARANI, an individual; KHAZAR MOMENI, an individual; DINO ELYASSNIA, M.D., an individual; and DOES 1 through 100, inclusive, attempted to and/or deleted information from their cell phones and purchased new cell phones after the death of Bob Lee. 57. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, Defendant, DINO ELYASSNIA, M.D., an individual; and DOES 1 through -14- COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 100, inclusive, conducted a search on the Internet on how to erase information from a cell phone, which search had been subsequently deleted. 58. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, that the investigating officers from the San Francisco Police Department received a tip from one of Bob Lee’s friends, suggesting that Bob may have gone to The Millennium Tower on the night he died. 59. Plaintiffs are also informed and believe, and thereon allege, that at all times mentioned herein, that Bob Lee’s ex-wife, Krista Lee, received a text message on or about April 5, 2023, at approximately 11:42 p.m. from someone who told her to tell the police to check The Millennium Tower security footage of the lobby. 60. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, on or about April 13, 2023, law enforcement officers arrested Defendant NIMA MOMENI for the murder of Bob Lee. Defendant NIMA MOMENI was charged with Bob Lee’s murder. The murder trial began on approximately October 14, 2024, in San Francisco. On or about December 16, 2024, a jury found Defendant NIMA MOMENI guilty of second-degree murder for the death of BOB LEE. 61. As a direct consequence of the matters herein alleged, Decedent sustained severe injuries to his body that after an appreciable period of time resulted in his death. As a result of the foregoing, Plaintiff, the ESTATE OF ROBERT HAROLD LEE, hereby asserts a survivor’s claim on behalf of Decedent pursuant to Code of Civil Procedure §§ 377.10, 377.20, 377.30, et seq., and based upon all other applicable statutes and case law and succeed to causes of action that might have been brought by Decedent. Plaintiff, the ESTATE OF ROBERT HAROLD LEE, therefore, seeks all damages accruing to the Decedent in a survival action, pursuant to Code of Civil Procedure § 377.34. All of said damages combine to a sum in excess of the jurisdictional minimum of this Court that the Decedent would have been entitled to had he lived including pain, suffering, or disfigurement, which will be stated according to proof pursuant to Code of Civil Procedure § 425.10. Plaintiff, the ESTATE OF ROBERT HAROLD LEE, is also seeking punitive or exemplary damages for the acts and/or omissions of Defendants, and DOES -15- COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 through 100, inclusive, which were willful, wanton, reckless, malicious, oppressive and/or done with a conscious or reckless disregard for the rights of the Decedent. 62. The acts and/or omissions of Defendants, and DOES 1 through 100, inclusive, were willful, wanton, reckless, malicious, oppressive and/or done with a conscious or reckless disregard for the rights of the Decedent and the Plaintiffs. FIRST CAUSE OF ACTION NEGLIGENCE (Survival Action) (By Plaintiff, the ESTATE OF ROBERT HAROLD LEE by and through its personal representative, TIMOTHY OLIVER LEE, Against Defendant NIMA MOMENI, and DOES 1 through 100, inclusive) 63. Plaintiff realleges each and every allegation contained in the above paragraphs and by this reference incorporates said paragraphs as though fully set forth herein. 64. Plaintiff is informed and believes, and thereon alleges, that at all times mentioned herein, Defendant NIMA MOMENI, and DOES 1 through 100, inclusive, owed a duty of care to Decedent not to cause harm to him. Defendant NIMA MOMENI, and DOES 1 through 100, inclusive, breached that duty and violated the standard of care when he murdered BOB LEE. 65. Plaintiff is informed and believes, and thereon alleges, that at all times mentioned herein, Defendant NIMA MOMENI carelessly, negligently, and recklessly repeatedly stabbed BOB LEE so as to legally and proximately cause severe injuries to Decedent and his eventual death after an appreciable period of time. 66. Plaintiff is informed and believes, and thereon alleges, that Defendant NIMA MOMENI failed in his duty not to harm Decedent, by repeatedly stabbing BOB LEE, which was the direct, legal, and proximate cause of the injuries and damages to Decedent, including his death, as herein alleged. Defendant NIMA MOMENI knew, or in the exercise of reasonable care, should have known of the probable and dangerous consequences of his conduct and omissions, yet deliberately failed to avoid said consequences. -16- COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 67. As a direct and proximate result of the conduct and omissions by Defendant NIMA MOMENI, and DOES 1 through 100, inclusive, BOB LEE died. 68. As a direct and proximate result of the conduct and omissions by Defendant NIMA MOMENI, and DOES 1 through 100, inclusive, Decedent suffered from pain, suffering and disfigurement before his death in a sum within the jurisdiction of this court, which will be established according to proof at the time of trial. 69. As a further direct and proximate result of the conduct of Defendant NIMA MOMENI, and DOES 1 through 100, inclusive, Decedent, before his death, had to seek medical care and treatment and employed the services of hospitals, physicians, nurses, and the like to care for and treat Decedent and hospital, medical, professional, and incidental expenses were incurred in a sum which will be established according to proof at trial pursuant to Code of Civil Procedure § 425.10. 70. As a further direct and proximate result of the conduct of Defendant NIMA MOMENI, and DOES 1 through 100, inclusive, Decedent lost income, earnings and other financial losses, all to Decedent’s economic damages in a sum which will be established according to proof at trial pursuant to Code of Civil Procedure § 425.10. 71. As alleged herein, Defendant NIMA MOMENI’s, and DOES 1 through 100, inclusive, conduct constitutes a want of even scant care and an extreme departure from the ordinary standard of conduct. Such outrageous lack of care represents Defendant NIMA MOMENI’s, and DOES 1 through 100, inclusive, willful and conscious disregard for the safety of others, like Decedent. Said despicable conduct resulted in Decedent’s injuries and death, which were probable consequences of Defendant NIMA MOMENI’s acts and omissions. Defendant NIMA MOMENI, and DOES 1 through 100, inclusive, knew, or should have known, of the probable dangerous consequences of his actions and omissions, yet he deliberately failed to avoid these consequences by repeatedly stabbing and murdering Decedent on the date of the incident. As alleged herein, Defendant NIMA MOMENI, and DOES 1 through 100, inclusive, are guilty of oppression, fraud, and/or malice as defined in the Code of Civil Procedure § 3294, and thus Plaintiffs should recover, in addition to actual damages, exemplary and punitive -17- COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 damages to make an example of and to punish Defendant NIMA MOMENI, and DOES 1 through 100, inclusive, in an amount according to proof. SECOND CAUSE OF ACTION WRONGFUL DEATH (By Plaintiff, DAGNY LEE, an individual, and SCOUT LEE, a minor, by and through her Guardian Ad Litem, KRISTA LEE, Against Defendant NIMA MOMENI and DOES 1 through 100, inclusive) 72. Plaintiffs reallege each and every allegation contained in the above paragraphs and by this reference incorporate said paragraphs as though fully set forth herein. 73. At all times herein mentioned, Plaintiffs were and are the biological children of Decedent, BOB LEE. 74. As a direct and legal result of the conduct and omissions of Defendant NIMA MOMENI, an individual; and DOES 1 through 100, inclusive, Bob Lee died. 75. As a further direct and proximate result of the wrongful death of Decedent, the Plaintiffs have been permanently deprived of Decedent’s love, companionship, comfort, care, assistance, protection, affection, society, and moral support and guidance, all to Plaintiffs’ non￾economic damages in an amount in excess of the minimum jurisdiction of this Court and which will be established according to proof at trial. 76. By reason of Defendant NIMA MOMENI’s, and DOES 1 through 100, inclusive, conduct and omissions, Plaintiffs have incurred medical, funeral, and burial expenses, have lost the financial support of Decedent and have incurred or will incur other financial losses, loss of gifts or benefits, all to Plaintiffs’ economic damages in a sum which will be established according to proof at trial. 77. As alleged herein, Defendant NIMA MOMENI’s, and DOES 1 through 100, inclusive, conduct constitutes a want of even scant care and an extreme departure from the ordinary standard of conduct. Such outrageous lack of care represents Defendant NIMA MOMENI’s, and DOES 1 through 100, inclusive, willful and conscious disregard for the safety -18- COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 of others, like Decedent. Said despicable conduct resulted in Decedent’s injuries and death, which were probable consequences of Defendant NIMA MOMENI’s acts and omissions. Defendant NIMA MOMENI, and DOES 1 through 100, inclusive, knew, or should have known, of the probable dangerous consequences of his actions and omissions, yet he deliberately failed to avoid these consequences by repeatedly stabbing and murdering Decedent on the date of the incident. As alleged herein, Defendant NIMA MOMENI, and DOES 1 through 100, inclusive, are guilty of oppression, fraud, and/or malice as defined in the Code of Civil Procedure § 3294, and thus Plaintiffs should recover, in addition to actual damages, exemplary and punitive damages to make an example of and to punish Defendant NIMA MOMENI, and DOES 1 through 100, inclusive, in an amount according to proof. THIRD CAUSE OF ACTION AIDING AND ABETTING (By All Plaintiffs Against Defendants, MAHNAZ TAYARANI, an individual; KHAZAR MOMENI, an individual; DINO ELYASSNIA, M.D., an individual; and DOES 1 through 100, inclusive) 78. Plaintiffs reallege each and every allegation contained in the above paragraphs and by this reference incorporate said paragraphs as though fully set forth herein. 79. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, Defendants, MAHNAZ TAYARANI, an individual; KHAZAR MOMENI, an individual; DINO ELYASSNIA, M.D., an individual; and DOES 1 through 100, inclusive, knew on and after April 4, 2023 that Defendant NIMA MOMENI had murdered BOB LEE. 80. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, once Defendants, MAHNAZ TAYARANI, an individual; KHAZAR MOMENI, an individual; DINO ELYASSNIA, M.D., an individual; and DOES 1 through 100, inclusive, learned on or after April 4, 2023, that Defendant NIMA MOMENI had murdered BOB LEE, each and every one of them gave substantial assistance to Defendant NIMA MOMENI to hide and/or destroy evidence including, but not limited to, storing Defendant -19- COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NIMA MOMENI’s white BMW Z4 Roadster and its contents away from his residence, so that it could not immediately be found by the investigating officers of the San Francisco Police Department and the Plaintiffs; trying to sell Defendant NIMA MOMENI’s white BMW after Bob Lee’s death; attempting to delete and/or deleting information from their cell phones and Defendant NIMA MOMENI’s cell phone, and obtaining new cell phones; and by Defendant, DINO ELYASSNIA, M.D., an individual; and DOES 1 through 100, inclusive, conducting a search on the Internet on how to erase information from a cell phone, which search had been subsequently deleted. 81. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, the conduct and/or omissions of Defendants, MAHNAZ TAYARANI, an individual; KHAZAR MOMENI, an individual; DINO ELYASSNIA, M.D., an individual; and DOES 1 through 100, inclusive, were a substantial factor in causing harm to the Plaintiffs. 82. Plaintiffs were harmed by Defendant NIMA MOMENI’s actions when he murdered the Decedent. Plaintiffs were also harmed by the acts and omissions of Defendants, MAHNAZ TAYARANI, an individual; KHAZAR MOMENI, an individual; DINO ELYASSNIA, M.D., an individual; and DOES 1 through 100, inclusive. 83. As a direct and proximate result of the acts and omissions of Defendants, MAHNAZ TAYARANI, an individual; KHAZAR MOMENI, an individual; DINO ELYASSNIA, M.D., an individual; and DOES 1 through 100, inclusive, Plaintiffs suffered irreparable harm. As a result, Plaintiffs seek monetary damages in an amount presently unknown but exceeding the minimum jurisdictional limit of this Court and as proven at time of trial. /// /// /// /// /// /// -20- COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 FOURTH CAUSE OF ACTION CONSPIRACY (By All Plaintiffs Against Defendants, MAHNAZ TAYARANI, an individual; KHAZAR MOMENI, an individual; DINO ELYASSNIA, M.D., an individual; and DOES 1 through 100, inclusive) 84. Plaintiffs reallege each and every allegation contained in the above paragraphs and by this reference incorporate said paragraphs as though fully set forth herein. 85. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, Defendants, MAHNAZ TAYARANI, an individual; KHAZAR MOMENI, an individual; DINO ELYASSNIA, M.D., an individual; and DOES 1 through 100, inclusive, entered into an agreement to hide evidence from the Plaintiffs and law enforcement officers including, but not limited to, Defendant NIMA MOMENI’s white BMW and its contents, after he repeatedly stabbed the Decedent, BOB HILL, on April 4, 2023. After Bob Lee’s death, law enforcement officers were searching for, and unable to find, Defendant NIMA MOMENI’s white BMW. When law enforcement officers finally located the white BMW, they learned that Defendant NIMA MOMENI’s family, and in particular his mother, Defendant MAHNAZ TAYARANI, in addition to, Defendants, KHAZAR MOMENI, an individual; DINO ELYASSNIA, M.D., an individual; and DOES 1 through 100, inclusive, had been trying to sell the white BMW. 86. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, Defendants, MAHNAZ TAYARANI, an individual; KHAZAR MOMENI, an individual; DINO ELYASSNIA, M.D., an individual; and DOES 1 through 100, inclusive, entered into an agreement to hide evidence from the Plaintiffs and law enforcement officers, including but not limited to, attempting to sell Defendant NIMA MOMENI’s white BMW when law enforcement officers and Plaintiffs were searching for it. 87. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, Defendants, MAHNAZ TAYARANI, an individual; KHAZAR MOMENI, an individual; DINO ELYASSNIA, M.D., an individual; and DOES 1 through 100, inclusive, -21- COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 entered into an agreement to destroy and/or delete information, including but not limited to, information on their cell phones and on Defendant NIMA MOMENI’s cell phone, and that they all purchased new cell phones after the death of Bob Lee. 88. Plaintiffs are also informed and believe, and thereon allege, that at all times mentioned herein, Defendant NIMA MOMENI was hiding out at his mother’s house, after BOB LEE’s death. During this time, he had already hired criminal defense attorneys. When he retained the criminal defense attorneys, he had not yet been interviewed nor arrested by the police. 89. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, Defendants, MAHNAZ TAYARANI, an individual; and KHAZAR MOMENI, an individual, entered into an agreement with Defendant, DINO ELYASSNIA, M.D., an individual; and DOES 1 through 100, inclusive, for him to conduct a search on the Internet on how to erase information from a cell phone, which search had been subsequently deleted. 90. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, Defendants, MAHNAZ TAYARANI, an individual; KHAZAR MOMENI, an individual; DINO ELYASSNIA, M.D., an individual; and DOES 1 through 100, inclusive, were aware of their agreements and of each other’s plans to hide and/or destroy information and evidence related to Bob Lee’s murder. 91. Plaintiffs are informed and believe, and thereon allege, that at all times mentioned herein, Defendants, MAHNAZ TAYARANI, an individual; KHAZAR MOMENI, an individual; DINO ELYASSNIA, M.D., an individual; and DOES 1 through 100, inclusive, intended to hide and/or destroy information and evidence related to Bob Lee’s murder. 92. As a direct and legal result of the conduct and omissions of Defendants, MAHNAZ TAYARANI, an individual; KHAZAR MOMENI, an individual; DINO ELYASSNIA, M.D., an individual; and DOES 1 through 100, inclusive, Plaintiffs suffered irreparable harm, in that they and law enforcement officers did not have access to critical information and evidence, Defendant NIMA MOMENI’s white BMW and its contents, -22- COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 immediately after the stabbing and killing of Decedent, BOB LEE, and from the destruction of evidence by deleting information from their cell phones. As a result, Plaintiffs seek monetary damages in an amount presently unknown but exceeding the minimum jurisdictional limit of this Court and as proven at time of trial. FIFTH CAUSE OF ACTION INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS (By All Plaintiffs Against Defendants, MAHNAZ TAYARANI, an individual; KHAZAR MOMENI, an individual; DINO ELYASSNIA, M.D., an individual; and DOES 1 through 100, inclusive) 93. Plaintiffs reallege each and every allegation contained in the above paragraphs and by this reference incorporate said paragraphs as though fully set forth herein. 94. The conduct of Defendants, MAHNAZ TAYARANI, an individual; KHAZAR MOMENI, an individual; DINO ELYASSNIA, M.D., an individual; and DOES 1 through 100, inclusive, was extreme and outrageous and outside the bounds of common decency and human behavior. 95. Defendants, MAHNAZ TAYARANI, an individual; KHAZAR MOMENI, an individual; DINO ELYASSNIA, M.D., an individual; and DOES 1 through 100, inclusive, intended to cause Plaintiffs’ emotional distress and acted with reckless disregard of the probability that Plaintiffs would suffer emotional distress. 96. Plaintiffs suffered severe emotional distress as a result of the conduct of Defendants, MAHNAZ TAYARANI, an individual; KHAZAR MOMENI, an individual; DINO ELYASSNIA, M.D., an individual; and DOES 1 through 100, inclusive. 97. The conduct of Defendants, MAHNAZ TAYARANI, an individual; KHAZAR MOMENI, an individual; DINO ELYASSNIA, M.D., an individual; and DOES 1 through 100, inclusive, was a substantial factor in causing Plaintiffs’ severe emotional distress. 98. As a direct and proximate result of the acts and omissions of Defendants, MAHNAZ TAYARANI, an individual; KHAZAR MOMENI, an individual; DINO -23- COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ELYASSNIA, M.D., an individual; and DOES 1 through 100, inclusive, Plaintiffs suffered physical injuries, severe and substantial mental and emotional distress, humiliation, fear, apprehension, anxiety and anguish, all to their general damages in an amount in excess of the minimum jurisdictional amount of this Court, according to proof at the time of trial. 99. By reason of the foregoing, Defendants, MAHNAZ TAYARANI, an individual; KHAZAR MOMENI, an individual; DINO ELYASSNIA, M.D., an individual; and DOES 1 through 100, inclusive, are liable for, and Plaintiffs are entitled to recover, their general, special, actual and compensatory damages, including, but not limited to, their necessary medical and related expenses, past, present and future lost earnings, loss of future earning capacity, as well as past, present and future mental, emotional and physical pain and suffering, in an amount presently unknown but exceeding the minimum jurisdictional limit of this Court and as proven at time of trial. 100. The actions of Defendants, MAHNAZ TAYARANI, an individual; KHAZAR MOMENI, an individual; DINO ELYASSNIA, M.D., an individual; and DOES 1 through 100, inclusive, were willful, malicious, intentional and with reckless disregard for the health of Plaintiffs so as to warrant the imposition of punitive and exemplary damages. SIXTH CAUSE OF ACTION INVASION OF PRIVACY (Against Defendants PORTSIDE HOMEOWNERS’ ASSOCIATION, PORTSIDE MASTER OWNERS’ ASSOCIATION, SECURITAS SECURITY SERVICES USA, INC., SF OAKLAND BAY LLC, a Limited Liability Company, and DOES 1 through 100, inclusive) 101. Plaintiffs reallege each and every allegation contained in the above paragraphs and by this reference incorporate said paragraphs as though fully set forth herein. 102. Plaintiffs allege that Defendants, PORTSIDE HOMEOWNERS’ ASSOCIATION, PORTSIDE MASTER OWNERS’ ASSOCIATION, SECURITAS SECURITY SERVICES USA, INC., SF OAKLAND BAY LLC, a Limited Liability Company, -24- COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 and DOES 1 through 100, inclusive, violated their right to privacy. 103. Defendants, PORTSIDE HOMEOWNERS’ ASSOCIATION, PORTSIDE MASTER OWNERS’ ASSOCIATION, SECURITAS SECURITY SERVICES USA, INC., SF OAKLAND BAY LLC, a Limited Liability Company, and DOES 1 through 100, inclusive, released private information concerning the stabbing of Decedent and their father, BOB LEE. 104. Plaintiffs became aware of videos that were released by Defendants without the Plaintiffs’ permission or the permission of other family members. The videos showed in great detail how their father, BOB LEE, struggled and desperately pleaded for help after Defendant, NIMA MOMENI stabbed him. The videos specifically show BOB LEE pleading for help after he was stabbed, stumbling down the street while leaving traces of blood, falling to the ground multiple times before he became unresponsive. 105. Plaintiffs are reasonable persons who considered the publicity highly offensive. 106. Defendants, PORTSIDE HOMEOWNERS’ ASSOCIATION, PORTSIDE MASTER OWNERS’ ASSOCIATION, SECURITAS SECURITY SERVICES USA, INC., SF OAKLAND BAY LLC, a Limited Liability Company, and DOES 1 through 100, inclusive, acted with reckless disregard for the fact, that a reasonable person in Plaintiffs’ position would consider the publicity highly offensive. 107. The video footage was not a legitimate public concern, nor did it have a substantial connection to a matter of legitimate public concern. 108. As a direct and proximate result of the acts and omissions of Defendants, PORTSIDE HOMEOWNERS’ ASSOCIATION, PORTSIDE MASTER OWNERS’ ASSOCIATION, SECURITAS SECURITY SERVICES USA, INC., SF OAKLAND BAY LLC, a Limited Liability Company, and DOES 1 through 100, inclusive, Plaintiffs were harmed. As a result, Plaintiffs seek monetary damages in an amount presently unknown but exceeding the minimum jurisdictional limit of this Court and as proven at time of trial. /// /// /// -25- COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PRAYER FOR RELIEF WHEREFORE, Plaintiffs pray for judgment against Defendants and DOES 1 through 100 inclusive, and each of them, as follows: 1. For general damages (also known as non-economic damages), including but not limited to, past and future loss of love, companionship, comfort, care, assistance, protection, affection, society, moral support and guidance, in an amount in excess of the jurisdictional minimum, according to proof against Defendant, NIMA MOMENI, and DOES 1 through 100; 2. For special damages (also known as economic damages), including but not limited to, past and future financial support, loss of gifts and benefits, and funeral and burial expenses, in an excess of the jurisdictional minimum, according to proof against Defendant, NIMA MOMENI, and DOES 1 through 100; 3. For all damages allowable pursuant to Code of Civil Procedure § 377.34 against Defendant, NIMA MOMENI, and DOES 1 through 100; 4. For other economic and special damages according to proof against all Defendants, including but not limited to, loss of wages, earning capacity, hospital, medical, professional and incidental expenses suffered by Plaintiffs; 5. For punitive and exemplary damages in an amount according to proof as allowed under California Code of Civil Procedure § 3294 against Defendants NIMA MOMENI, MAHNAZ TAYARANI, KHAZAR MOMENI, DINO ELYASSNIA, M.D., and DOES 1 through 100, inclusive; 6. For loss of wages, earning capacity and/or business profits against all Defendants; 7. For pre-judgment interest according to proof; 8. For pre-trial interest, according to proof; 9. For all costs of suit incurred herein; and 10. For such other and further relief as the Court deems just and proper. /// /// -26- COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DEMAND FOR JURY TRIAL Plaintiffs, THE ESTATE OF ROBERT HAROLD LEE, by and through its personal representative, TIMOTHY OLIVER LEE; DAGNY LEE, an individual; and SCOUT LEE, a minor, by and through her Guardian Ad Litem, KRISTA LEE, hereby respectfully demand a trial by jury on all appropriate issues and as to all causes of action in the above-entitled action. DATED: March 28, 2025 BD& J, P.C. By:__ ____________________________ Olivier A. Tallilieu, Esq. Elizabeth A. Hernandez, Esq. Attorneys for Plaintiffs