Sandra Khalili

Representative Experience

• Obtained dismissal with prejudice of employee’s six-figure claim for unpaid wages and overtime and retaliation for a walk-away.
• Favorably resolved a wage and hour claim against a ranch by a disgruntled former employee who had been seeking significant six-figure relief.
• Achieved a judgment of dismissal for an apparel industry client accused of stealing trade secrets and interfering with prospective economic advantage.
• Represented overseas apparel manufacturer as plaintiff in a contract dispute against a California garment wholesaler/buyer and one of its principals; obtained a prejudgment right to attach order against the entity; first chaired a three-week jury trial and obtained judgment in favor of client for compensatory and punitive damages of approximately $2,750,000, which she collected in full.
• Represented overseas garment manufacturer as plaintiff in a contract dispute against two New York wholesalers and their principal; successfully defended against challenges to personal jurisdiction; obtained a $4,300,000 prejudgment right to attach order against the entities, and reached a settlement pursuant to which she obtained a judgment in favor of her client and against entity and individual defendants.
• Represented defendant oil company in a jury trial, after being engaged approximately two weeks before trial commenced, where client was exposed to substantial compensatory and punitive damages; at the commencement of trial, client admitted liability (upending plaintiff’s trial strategy) and after a two-week trial with a focus on damages, the jury returned a verdict with minimal damages.
• Represented numerous apparel manufacturers and wholesalers as plaintiffs and defendants in various types of disputes, including, without limitation, successful defense of actions for nonpayment based on non-conformity and defects in goods, and failure to comply with the California Commercial Code requirements for sale of goods.
• Represented elderly client (he was in his 90s) and minority shareholder in a two-shareholder entity against his elderly brother (in his 80s) attempting to oust client from the entities, and litigated derivative and direct claims on client’s behalf for breach of fiduciary duty and financial elder abuse; secured an order disqualifying a well-known national law firm from representing the brother due to his lawyer’s conflict of interest, preventing the conflicted lawyer from directing the litigation, and obtained a favorable settlement for the client.
• Represented partner/joint venturer as plaintiff in a three-week Zoom bench trial during the Covid-19 pandemic. The trial involved over 70 affordable housing projects subject to HUD requirements, and defendants’ failure to pay client for its share from the proceeds of sales of general and limited partner interests in the properties, which the defendants controlled; litigation was complex and contentious and involved accounting for multiple partnerships and projects. This was the first Zoom civil bench trial in the Santa Monica Superior Court, where the case was pending.
• Represented managing member of three family- and friend-owned real estate limited liability companies in the simultaneous defense of multiple civil (both derivative and direct) and probate lawsuits against client for, among other things, embezzlement of millions of dollars (which client had admitted prior to retaining counsel); through critical legal strategies, we defeated one plaintiff’s application for a right to attach order seeking millions of dollars; client reached a favorable resolution of all disputes after several years of litigation, without any punitive damages.
• Represented minority member of two-member California limited liability company which owned a strip mall against the manager/majority member for, among other things, breach of fiduciary duty and accounting; reached a favorable settlement with client continuing to own her interest in the entity and receiving monetary damages from defendant for past misconduct, with entity hiring an outside management company to operate the business with transparency and to prevent defendant’s future theft of entity funds.
• Represented children of the deceased 50% partner of a partnership, which owned a commercial real property, against the other 50% owner, who rented the partnership’s real property for his sole benefit at below-market rent and failed to make distributions; the parties reached a settlement through which the defendant/partner purchased client’s interest in the partnership (and the real estate) at a favorable purchase price which included back rent.
• Represented high-profile stunt driver as plaintiff in litigation involving derivative and direct claims against long-time business partner in three entities and several parcels of real property; successfully resolved the dispute through mediation by client taking corporate control of two entities and purchasing the real estate on favorable terms.
• Represented client, purchaser of a multi-million dollar industrial property in East Los Angeles, against a neighboring exotic dance club which refused to remove several parking covenants recorded against the client’s property before client’s purchase; and attempted to prevent client from obtaining a certificate of occupancy through the city; Ms. Khalili defeated the club’s application for a temporary restraining order, after which the parties entered into a settlement with the club owner agreeing to remove all parking and related covenants against the client’s property, with city’s approval.
• Represented well-known wholesale and retail apparel company in defense of wage/penalty and California Private Attorney General Act (PAGA) cases in which several models that client had engaged through talent agencies filed suit for waiting time penalties and attorneys’ fees, alleging that they were client’s employees and client had misclassified them as independent contractors. The disputes were settled on very favorable terms.
• Represented employer in wrongful termination and discrimination cases involving high six- and seven-figure demands and resolved them for low five figures.
• Represented well-known wholesale and retail apparel company in age discrimination and wrongful termination case where former employee was terminated in his 60s, sought millions of dollars in compensatory damages and punitive damages; after taking the employee’s deposition and filing a defense motion for summary judgment, the lawsuit was settled for low five figures.
• Represented insurance broker in defense of lawsuit involving wrongful termination and failure to provide reasonable accommodation; after conducting discovery and forensic analysis of former employee’s computer, the parties reached a settlement wherein employee agreed to dismiss the case with prejudice in exchange for a walk-away.
• Represented client, a rape victim of a well-known public figure, in civil lawsuit for recovery of money for, among other things, violation of client’s privacy rights. The well-known defendant had been prosecuted in an extremely publicized and sensationalized criminal trial on several charges, including raping the client. Subsequent to defendant’s conviction, client sued defendant’s mother and a national news agency, who, with the help of defendant’s mother, had obtained and broadcast portions of videotapes of client being molested by defendant.  After defeating defendants’ Anti-SLAPP motions, the parties reached a multi-million dollar settlement.
• Represented conservator for a mental health patient against the patient’s psychiatrist for medical malpractice and abuse of a dependent adult, including, without limitation, for release of the mental health patient from a locked health facility to the streets without the conservator’s permission or consent, without any medicine and without any support; the dispute was settled for substantially more than California’s limits on medical malpractice damages, with the psychiatrist’s malpractice carrier paying a settlement in the high six figures that would stay on the psychiatrist’s record for insurance purposes indefinitely.
• Represented doctors in a lawsuit by another doctor in the practice; obtained funds from the insurance broker’s carries to settle the dispute due to insurance broker’s failure to tender the claim.
• Represented clients in a variety of other litigation matters, including, without limitation, commercial and higher-end residential unlawful detainer cases and construction litigation.
• Represented clients in bankruptcy matters, including, without limitation, filing of proofs of claim, non-dischargeability complaints, and challenging trustees’ avoidance claims.
• Obtained writ from Court of Appeal reversing trial court’s discovery order, which required client, a rape victim filing lawsuit as a Doe, to disclose her name in discovery verifications. This case is published.
• Obtained writ from Court of Appeal regarding trial court’s wrongful denial of client’s application for a right to attach order because the trial court applied the wrong standard regarding the parties’ burdens of proof; the appellate court remanded the case to the trial court, with instructions to apply the correct standard. This led to the client obtaining a right to attach order and ultimately a favorable resolution.
• Defeated defendant’s appeal from a trial court finding in summary judgment that a settlement providing for a discount for early payment of an undisputed debt does not constitute an improper liquidated damages provision or illegal penalty. This case is published.