Complaint Unlimited Fee AppliesCal. Super. - 6th Dist.November 19, 2020I:_F” FD PLD-PI-001 A'I'I'ORNEY OR PARTY WITHOUT ATTORNEY Name, State Bar number, and address : .- Sima Baghramyan, Esq. (S(BN 331453) ) 1 1/1 gmmwriufaopm JT Legal Group, APC Clerk Of Court 801 N Brand Boulevard, Suite #1 130 Superior Court of CA, Glendale, California 91203 County Of Santa Clara TELEPHONE No: (.818)@7I415_19198 FAX No. (Optional): 818-574-6268 ZOCV373796 E-MAIL ADDRESS (Optional): Slma Jt ega group.C0m Reviewed B Iy. M VuATTORNEY FOR (Name); TABRIZI TAYMAZ SUPERIOR COURT 0F CALIFORNIA, COUNTY 0F Santa Clara STREET ADDRESS: 191 North First Street MAILING ADDRESS: 191 North First Street CITY AND ZIP CODE: San Jose, CA 951 13 BRANCH NAME: Downtown Superior Court PLAINTIFF: TABRIZI TAYMAZ, an individual; DEFENDANT: LILI LI, an individual; DOES 1 To 100 inclusive COMPLAINT-Personal Injury, Property Damage, Wrongful DeathE AMENDED (Number): Type (check all that apply): MOTOR VEHICLE OTHER(speciry): Negligence Property Damage E Wrongful Death Personal Injury Other Damages (specify): Demand for Jury Jurisdiction (check all that apply): CASE NUMBER:E ACTION IS A LIMITED CIVIL CASE Amount demanded E does not exceed $10,000E exceeds $10,000, but does not exceed $25,000 ACTION Is AN UNLIMITED CIVIL CASE (exceeds $25,000) ZOCV373796E ACTION Is RECLASSIFIED by this amended complaint |:| from limited to unlimitedE from unlimited to limited 1- Plaintiff (name 0r names}: Tabrizi Taymaz, an individual, alleges causes of action against defendant (name or names): Lili Li, an individual 2. This pleading, including attachments and exhibits, consists of the following number of pages: 5 3. Each plaintiff named above is a competent adult a. E except plaintiff (name): (1)E a corporation qualified to do business in California (2)E an unincorporated entity (describe): (3)E a public entity (describe): (4)E a minor E an adult (a) E for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b) E other (specify): (5)E other (specify): b. E except plaintiff (name): (1)E a corporation qualified to do busines~ in California (2)E an unincorporated entity (describe): (3)E a public entity (describe): (4)E a minor E an adult (a) E for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b) E other (specify): (5)E other (specify): E Information about additional plaintiffs who are not competent adults is shown in Attachment 3. Page 1 of 3 Form Approved fgr Optiqnal pse COMPLAINT_PersonaI Injury, Property Code of Civil Procedure‘, § 425.12 JudICIaI CounCIl of Callfornla www.courtlnfo.ca.gov PLD-PI-om [Rev‘ Januan/ 1, 2007] Damage, Wrongful Death PLD-PI-001 SHORT TITLE: CASE NUMBER: |Tabrizi Taymaz vs. Lili Li 4. D Plaintiff (name): is doing business under the fictitious name (specify): and has complied with the fictitious business name laws. 5. Each defendant named above is a natural person a. E except defendant (name): (1) E a business organization, form unknown (2) E a corporation (3) E an unincorporated entity (describe): (4) E a public entity (describe): (5) E other (specify): b. E except defendant (name): (1) E a business organization, form unknown (2) E a corporation (3) E an unincorporated entity (describe): (4) E a public entity (describe): (5) E other (specify): c. E except defendant (name): (1) E a business organization, form unknown (2) E acorporation (3) E an unincorporated entity (describe): (4) E a public entity (describe): (5) E other (specify): d. E except defendant (name): (1) E a business organization, form unknown (2) E acorporation (3) E an unincorporated entity (describe): (4) E a public entity (describe): (5) E other (specify): E Information about additional defendants who are not natural persons is contained in Attachment 5. 6. The true names of defendants sued as Does are unknown to plaintiff. a. Doe defendants (specify Doe numbers):|1 t0 100, inChlSiVe were the agents or employees of other named defendants and acted within the scope of that agency or employment. b. Doe defendants (specify Doe numbers): 1 t0 100, inCIUSiVe are persons whose capacities are unknown to plaintiff. 7. E Defendants who are joined under Code of Civil Procedure section 382 are (names): 8. This court is the proper court because a. at least one defendant now resides in itsjurisdictional area. b. E the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area. c. injury to person or damage to personal property occurred in itsjurisdictional area. d. E other (specify): 9. E Plaintiff is required to comply with a claims statute, and a. E has complied with applicable claims statutes, or b. E is excused from complying because (specify): PLD-Pl-001 [Rev. January 1, 2007] COMPLAINT-Personal Injury, Property Page 2 of 3 Damage, Wrongful Death PLD-PI-001 SHORT TITLE: CASE NUMBER: |Tabrizi Taymaz vs. Lili Li 10. 11. 12. 13. 14. 15. The following causes of action are attached and the statements above apply to each (each complaint must have one or more causes of action attached): Motor Vehicle General NegligenceE Intentional TortE Products LiabilityD Premises LiabilityE Other (specify): rwvslovsn Plaintiff has suffered wage loss loss of use of property hospital and medical expenses general damage property damage loss of earning capacity other damage (specify): A11 other damages as allowed by law, according t0 proof. Plaintiff demands jury trial. «Pfisvgovsv E The damages claimed for wrongful death and the relationships of plaintiff to the deceased are a. E listed in Attachment 12. b. E as follows: The relief sought in this complaint is within the jurisdiction of this court. Plaintiff prays forjudgment for costs of suit; for such relief as is fair, just, and equitable; and for a. (1) compensatory damages (2) E punitive damages The amount of damages is (in cases for personal injury or wrongful death, you must check (1)): (1) according to proof (2) E in the amount of: $ The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers): pages 4 and 5 Date: INovember 18, 2020 ISima Baghramyan, Esq. I } (TYPE OR PRINT NAME) (SIGNATURE OF PLAINTIFF OR ATTORNEY) PLD-PI-om [Rem January 1, 20071 COMPLAINT-Personal Injury, Property Page 3 ofs Damage, Wrongful Death To keep other people from seeing what you entered on your form, please press the Clear This Form button at the end of the form when finished. PLD-PI-oo1 (1) SHORT TITLE: CASE NUMBER: Tabrizi Taymaz vs. Lili Li FIRST CAUSE OF ACTION-Motor Vehicle (number) ATTACHMENT To Complaint E Cross - Complaint (Use a separate cause of action form for each cause of action.) Plaintiff (name): Tabrizi Taymaz, an individual MV- ‘I. Plaintiff alleges the acts of defendants were negligent; the acts were the legal (proximate) cause of injuries and damages to plaintiff; the acts occurred on (date): November 28, 2018 at (place): Stevens Creek Boulevard at Exit 1A, San Jose, CA, 95051 MV- 2. DEFENDANTS a. The defendants who operated a motor vehicle are (names): Lili Li Does 1 to 100 b. The defendants who employed the persons who operated a motor vehicle in the course of their employment are (names): Does 1 to 100 c. The defendants who owned the motor vehicle which was operated with their permission are (names): Lili Li Does 1 to 100 d. The defendants who entrusted the motor vehicle are (names): Does 1 to 100 e. The defendants who were the agents and employees of the other defendants and acted within the scope of the agency were (names): - Does 1 to 100- The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are_-h g Lili Li Does 1 to 100 Page 4 Page 1 of1 Form Approved for Optional Use _ ' f ' '| P 42 .12 Judicial Council of California CAUSE OF ACTION MOtor vehICIe COdeo vallvwrggsgililrfi£a§gov PLD»PI-oo1(1) [Rev. January 1, 2007] For your protection and privacy, please press the Clear This Form _ _ _ _ button afteryou have printed the form. Save Thls Form Prlnt Thls Form I I Clear Thls Forml PLD-PI-oo1(2) SHORT TITLE: CASE NUMBER: Tabrizi Taymaz vs. Lili Li SECOND CAUSE OF ACTION-General Negligence Page 5 (number) ATTACHMENTTO Complaint E Cross-Complaint (Use a separate cause of action form for each cause of action.) GN-1. Plaintiff (name): Tabrizi Taymaz, an individual alleges that defendant (name): Lili Li, an individual Does 1 to 100 was the legal (proximate) cause of damages to plaintiff. By the following acts or omissions to act, defendant negligently caused the damage to plaintiff on (date): November 28, 2018 at (place): Stevens Creek Boulevard at Exit 1A, San Jose, CA, 9505 1 (description of reasons for liability): Plaintiff was Stevens Creek Boulevard trying t0 enter into the Freeway when Defendant rear-ended him which caused Plaintiff‘s vehicle t0 be pushed into a vehicle in front 0f him. As a direct and proximate cause 0f Defendant's negligence, Plaintiff suffered injuries. Plaintiff demands jury trial. Page 1 of1 Form Approved for Optional Use - Code of Civil Procedure 425.12 Judicial CouncilofCaIifomia CAUSE 0F ACTION-General Negllgence www.coufiinfo.ca.gov PLD-PI-001(2) [Rev. January 1, 2007]