SAN FRANCISCO – A contractor doing business in San Francisco County is alleged to have misrepresented himself as a duly licensed general contractor.
Vladislav Chernoguz filed a complaint on Dec. 27 in the San Francisco County Superior Court against the Jerry K. Zbrzezny and Does 1-50 alleging breach of contract, fraud and other counts.
According to the complaint, the plaintiff is a holder in interest to nine properties in San Francisco and Sonoma.
The plaintiff alleges Zbrzezny held himself as a licensed general contractor under California law and the plaintiff has tendered him more than $1 million over the last 20 years for his construction-related needs.
The plaintiff alleges he learned after August 2018 that the defendant is not a licensed contractor because he did not have adequate workers' compensation for his laborers. The plaintiff alleges he sent the defendant a written demand to return door and mailbox keys and other items, which the defendant denied.
The plaintiff holds Zbrzezny and Does 1-50 responsible because the defendants allegedly engaged in false and misleading billing practices, failed to perform work in compliance with applicable laws and regulations and misrepresented that he is a duly licensed contractor.
The plaintiff requests a trial by jury and seeks judgment against defendants for declaratory and injunctive relief, accounting and disgorgement of profits, general and special damages, exemplary, treble and punitive damages, attorneys' fees, costs of suit, and further relief as the court deems just. He is represented by Aleksandr A. Volkov of Volkov Law Office in Walnut Creek.
San Francisco County Superior Court case number CGC-18-572370