Daniel T. Villagomez and Rosario DLG. Villagomez filed the complaint against Jin Apparel Inc. and Park Hun Soo for breach of contract.
The plaintiffs, through their counsel Judy DLG, Torres, are asking the court to grant them judgment against the defendants for expectation damages, reliance damages, restitution damages, incidental and special damages in an amount to be proven at trial, for the value of the contract, for reasonable attorney’s fees and costs, for other relief which the plaintiffs are entitled to receive, and any other equitable remedy even though not demanded for in any of the pleadings.
The plaintiffs stated that they executed a valid ground lease agreement with the defendants on April 2, 1987 which was filed with the recorder’s office on the following day.
The plaintiffs said the ground lease agreement, which was later amended states that the defendants agreed to pay the plaintiffs $2,000 every month and increased by 5 percent every 5 years from the date of the agreement.
The plaintiffs said the defendants failed to make any payments from January to March 2009.
On March 5, 2009, the plaintiffs notified the defendants in writing of the default and breach of the lease agreement and gave them until March 20, 2009 to make payments for the months the defendants failed.
