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I � � <br /> Mojaddidi&Associates <br /> 3135 Clayton Rd#205 <br /> Concord,CA 94519 <br /> 925.549.9333 cell <br /> 925.407.2846 fax <br /> tariq@mojaddidilaw.com <br /> Privileged& Confidential Settlement Communication <br /> Cal. Evid. Code Sections 1152& 1154 <br /> TO: 5/10/2020 <br /> City of Pleasanton City Council <br /> RE OUR CLIENT: Hamed Akbarzada C/O SMOKERS GIFTSHOP <br /> Re: Council Hearing Regarding Prohibition of Flavored Tobacco <br /> MEETING DATE: MAY 5TH 2020 7 PM. <br /> Please be advised that this office represents the above-mentioned individual for <br /> damages arising out of potential prohibition of flavored tobacco. Our client owns and operates <br /> several businesses in Pleasanton, including SMOKERS GIFTSHOP, in which more than 60% of <br /> his business is derived from sales of tobacco and tobacco accessories. <br /> My client owns and operates a store in which a major portion of his sales are flavored <br /> tobacco. He has been in business for 15 years with multiple locations. He is an upstanding <br /> Pleasanton resident and his customers, all of whom are Pleasanton residents, rely on his <br /> product. He will be significantly impacted from many of your decisions and votes on these <br /> new ordinances. He will have major financial and economic hardships if you outlaw his <br /> inventory. Furthermore, limiting his business model and forcing him to sell his inventory over <br /> a unreasonable period of time is also improper and a violation of his rights. Please be advised <br /> that my client will be pursuing a collection of his economic damages.We will be filing in <br /> Alameda County Superior Court for several causes of action, including promissory estoppel, <br /> unfair business procedures, overreach of governmental powers, and overall breach of <br /> contractual obligations. <br /> The premise of Flavored tobacco was designed to decrease the use of actual tobacco <br /> and nicotine. Customers begin with a certain moderate level of nicotine and slowly decrease <br /> until they quit altogether. It is designed to taper off cigarette addicts. However,with these <br /> potential prohibitions in place,we will and have seen tobacco statistics dramatically <br /> increasing. Wall St Journal reports that Marlboro Company had major gains this past quarter, <br /> and mainly because use of cigarettes is back on the rise. We will also see an increase in <br /> smuggler traffic and violence and an unnecessary allocation of law enforcement resources as <br /> sellers will begin a black market for these products. <br />