Complaint Unlimited Fee AppliesCal. Super. - 6th Dist.November 23, 2020I Jessie Serna 1585 The Alameda, Suite 100 San Jose, CA 95126 3 Telephone (408) 294-9002 Facsimile (408) 294-5827 4 Attorney for Stephanie Bisceglia SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SANTA CLARA 16 17 DEFENDANTS. 10 STEPHANIE BISCEGLIA, 11 PLAINTIFF, 12 13 14 CHRISTOPER J. SOLORZANO AND DOES I THROUGH 100, INCLUSIVE, 15 CASE NO: COMPLAINT FOR PERSONAL INJURY UNLIMITED JURSIDICTION Demand Exceeds $25,000.00 18 COMES NOW THE PLAINTIFF who allege against the Defendants the following: 19 FIRST CAUSE OF ACTION 20 NEGLIGENCE 22 1. The true names or capacities, whether individual, corporate, associate, or otherwise, 23 of Defendants Does I through 100, are unknown to Plaintiff, who therefore sue said 24 Defendants by such fictitious names. Plaintiff is informed, believe and thereon alleges that 25 each of the Defendants designated herein as a DOE are negligently responsible in some manner 26 for the events and happenings herein referred to, and negligently caused injury and damages 27 to the Plaintiff alleged herein, and that each Defendant was acting within the scope of agency 78 E-FILED 11/23/2020 2:16 PM Clerk of Court Superior Court of CA, County of Santa Clara 20CV373929 Reviewed By: R. Tien 20CV373929 and or employment of each and every other Defendant. 2. Plaintiff alleges that the accident occurred on Winchester Boulevard and Tisch Way in the city of San Jose in the county of Santa Clara. 3. Plaintiff is informed and believes and thereupon alleges that at all times herein stated, CHRISTOPHER J. SOLORZANO and Does I through 5 was the driver of a vehicle, which caused the injuries to Plaintiff as alleged herein. Plaintiff is further informed and believes and based thereon allege that at all times material herein, Defendant CHRISTOPHER J. SOLORZANO, and Does 6 through 10 were the owner of said vehicle mentioned herein which 10 caused said injury to Plaintiff as alleged herein. 4. At all times here mentioned, each of the Defendants were at all times agents and/or 12 13 14 15 16 17 employees of each other Defendants and were acting within the purpose and scope of said agency and/or employment. 5. At all times here mentioned Winchester Boulevard and Tisch Way are located in the city of San Jose, State of California 6. On January 24, 2019 Plaintiff Stephanie Bisceglia was driving her vehicle on 18 Winchester Boulevard on the number three lane when suddenly defendant driver Christopher J. 19 Solorzano broadsided Plaintiff vehicle from the number two lane of Southbound Winchester 20 21 22 23 24 25 Boulevard. 7. At said time and place, the Defendants, and each of them, so negligently entrusted, managed, maintains, drove and operated their vehicle so as to proximately cause a collision with the automobile being driven by Plaintiff STEPHANIE BISCEGLIA and thereby causing the hereinafter described injuries and damages to Plaintiff STEPHANIE BISCEGLIA. 26 8. As approximate cause of said negligence of the Defendants, and each of them, Plaintiff 27 28 was hurt and injured in her health, strength and activity, sustaining serious injuries and person all of which have caused and continue to cause Plaintiff great tnental, physical and nervous pain and suffering. Plaintiff is informed and believes and thereon alleges, that said injuries will result in some permanent disability to Plaintiff, all to Plaintiffs general damages as prayed for herein. WHEREFORE, Plaintiff prays for judgment against the Defendants, and each of them, as follows: 1. For general damages according to proof; 2. For damages where permitted by law; 3. For costs of suit incurred herein; 10 4. For such other and further relief as the Court may deem just and proper. 12 13 14 Date: November 23, 2020 JE SERNA Attorney for Plaintiff Stephanie Bisceglia 15 16 17 18 19 20 21 23 24 25 26 27 28
