Daily Legal News - Common Pleas Notices

  • LEGAL NOTICE

    890020—Frank A. Hughes, Trustee of the Phyllis Hughes Trust dated October 22, 2001, et al. vs. Hamid Farid Sadji, et al.

    Hamid Farid Sadji, whose last known place of residence is 14000 St. Clair Avenue, Cleveland, OH 44110, otherwise whose place of residence is unknown; Farid Mohamad, Inc., whose last known address is 14000 St. Clair Avenue, Cleveland, OH 44110, otherwise whose address is unknown; Mohamad S. Oudabachi, whose last known place of residence is 14000 St. Clair Avenue, Cleveland, OH 44110, otherwise whose place of residence is unknown; Unknown Agent of Farid Mohamad, Inc., whose last known address is 14000 St. Clair Avenue, Cleveland, OH 44110, otherwise whose address is unknown, will take notice that on December 5, 2017, the undersigned, Frank A. Hughes, Trustee of the Phyllis Hughes Trust dated October 22, 2001 and Estate of Phyllis Hughes, filed their complaint in the Court of Common Pleas, 1200 Ontario Street, Cleveland, Ohio 44113, of Cuyahoga County, Ohio, alleging that on October 22, 2001, Plaintiff Hughes entered into a written Land Installment Contract (hereinafter "Contract") with Defendant Sadji for the purchase and sale of real estate located at 11005 St. Clair Avenue, City of Cleveland, County of Cuyahoga, and State of Ohio, Auditor's PPN 111-01-001.

    As of October 22, 2001, Phyllis Hughes was the titled owner of the real estate located at 11005 St. Clair Avenue, Cleveland, Ohio 44108, Cuyahoga County Auditor PPN 111-01-001. On May 9, 2002, said real estate was transferred to the Plaintiff Trust. On October 9, 2003, said real estate was transferred by the Plaintiff Trust to Defendant Corporation.

    Defendant Sadji breached the material terms of the Contract, in an amount in excess of $25,000.00 and caused damage to Plaintiff Hughes in an amount in excess of $25,000.00 and caused damage to Plaintiff Trust in an amount in excess of $25,000.00.

    Defendant Sadji, Defendant Oudabachi and Defendant Unknown Agent had control over the corporation so complete that the corporation had no separate mind, will or existence of its own, exercised control over the corporation in such a manner as to commit fraud or an illegal act against Plaintiffs, and injury or unjust loss resulted to the Plaintiffs from such control and wrong.

    Plaintiffs seek to disregard the corporate entity that Defendant Corporation may assert, and in addition to holding Defendant Corporation liable, hold Defendant Sadji, Defendant Oudabachi and Defendant Unknown Agent personally liable, jointly and severally, for the damage they each caused to Plaintiff.

    Defendants Corporation, Oudabachi and Unknown Agent, jointly and severally, breached the material terms of the Contract, each and collectively in an amount in excess of $25,000.00, and caused damage jointly and severally to Plaintiff Estate in an amount in excess of $25,000.00, and caused damage jointly and severally to Plaintiff Trust in an amount in excess of $25,000.00.

    Wherefore, Plaintiff Estate demands the following relief, jointly and severally against all named Defendants:

    1. Damages for breach of contract in a sum in excess of $25,000.00;

    2. Incidental damages in the maximum sum authorized by law;

    3. Consequential damages in the maximum sum authorized by law;

    4. Non-economic damages in the maximum sum authorized by law;

    5. Punitive damages in the maximum sum authorized by law;

    6. Attorney fees;

    7. Court Costs; and

    8. All other relief that this Honorable Court deems fair, just and equitable.

    Further, Plaintiff Trust demands the following relief, jointly and severally against all named Defendants:

    1. Damages for breach of contract in a sum in excess of $25,000.00;

    2. Incidental damages in the maximum sum authorized by law;

    3. Consequential damages in the maximum sum authorized by law;

    4. Non-economic damages in the maximum sum authorized by law;

    5. Punitive damages in the maximum sum authorized by law;

    6. Attorney fees;

    7. Court Costs; and

    8. All other relief that this Honorable Court deems fair, just and equitable.

    The defendants named above are required to answer on or before the 18th day of October, 2018.

    Frank A. Hughes, Trustee of the Phyllis Hughes Trust dated October 22, 2001 and Estate of Phyllis Hughes.

    By Bradley Hull IV, Esq, Attorney for Plaintiffs.

    Aug16-23-30Sep6-13-20, 2018

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