Complaint Unlimited Fee AppliesCal. Super. - 6th Dist.April 6, 2021“Q PLD-PI-OO‘I A'ITORNEY OR PARTY WITHOUT ATTORNEY (Name. State Ba! nwnbar. and addrBss) FDR COURT"55 ONLY Kerry Russell (In Pro Per) 250 Del Medio Avenue. #215 Mountain \fiew, CA 94040 TELEPHONE No: (650) 963-6880 FAX NO‘ (Opficnaflr s-MAJL ADDRESS (optional).- Arroausv Foremamo): Kerry Russell SUPERIOR couar 0F CALIFORNIA, coum'v 0F SANTA CLARA AP R 0 6 2021 srREErAnonEss: 191 N. First Street MAILING ADDRESS. f thmmzp cone San Jose. 0A 951 13 A Eh%urt BRANCH NAME gmfiflgfii 0A fin fink Clard BY DEPU rv PLAINTIFF: Russell v. Singh DEFENDANT: Dhanwanl Singh, Yellow Checker Cab Company. Inc. and DOES 1 To 20 CASE NUMBER:COMPLAINT-Personal Injury, Property Damage, Wrongful DeathD AMENDED (Number): Type (check all that apply):E MOTOR VEHICLE E OTHER(speciry):E Property Damage E Wrongful Death Personal Injury E] Other Damages (specify): JurIsdiction {check allthatapply): . fl e Q 3 fi 9 1 5 3D ACTION IS A LIMITED CIVIL CASE a Amount demanded D does not exceed $10,000D exceeds $10,000. but does not exceed $25.000 ACTION ls AN UNLIMITED CIVIL. CASE (exceeds $25.000)D ACTION IS RECLASSIFIED by this amended complaintD from limited to unlimitedE from unlimited to limited 1. Plaintiff (name or names): Kerry Russell alleges causes of action against defendant (name ornames): Dhanwant Singh. Yellow Checker Cab Company. Inc. and Does 1-20 . 2. This pleadlng. including attachments and exhibits, consists of the following number of pages: 4 3. Each plaintiff named above is a competent adult a. E except plalnfiff (name): (1)D a corporation quaiified to do buslness in California (2)a an un1ncorporated entity (describe): (3)E a puinc entity (describe): (4):(a minor D an adultmg for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b)D other(specify): (5)D other(specify): b. E except plaintiff (name): (1) E] a corporation qualified to do business in California (2)E an unincorporated entity (describe): (3)E a pubiic entlty (describe): (4)E a minor E an adult (a)E for whom a guardian or conservator of the estate or a guardian ad Iltem has been appointed (b)E other(specify): (5)E other (specify):E Information about additional plalntifis who are not competent adults is shown In Attachment 3. Page‘l 0'3 Form Approved {orowonal Use COMPLAINT-Personal Injury, Property Code crew Fromm 5 425.12" 00 ca! m 1 . méugllgga [REJgngryjtnzauon Damage: wrongfu' Death mmmawgw ) PLD-Pl-001 SHORT TITLE: CASE NUMBER Russell v. Singh ' 4. D Plaintiff {name}: ls doing buslness under the fictitious name (specify): and has complied with the fictitious business name laws. 5. Each defendant named above I5 a natural person a. except defendant (name): Yellow'Checker Cab Compam c. E except defendant (name): (1) a business organlzation. form unknown (1)E a business organization. form unknown (2)E a corporation (2)D a corporation (3)a an unincorporated entity (describe): (3)E an unincorporated entlty (describe): (4)E a public entity (descn‘be): (4)E a public entity (describe): (5)E other (spacing: (5) E] other (specify): b. E éxcept defendant (name): d. D except defendant (name): (1)E a business organization, form unknown (1)S a buslness organization, form unknown (2)E a carporation (2)D a corporation (3)E an unincorporated entity (describe): (3)E an unincorporated entity (describe): (4) C] a pubiic entity (describe): , (4) E3 a public entity (describe): (5)D other (specify): (5)E otherwpecffy): a Information about addiflonal defendants who are not natural persons is contained in Attachment 5. 6. The hue names of defendants sued as Does are unknown to plaintiff. a. Doe defendants {specify Doe numbers): 1-20 were the agents or emp1oyees of olher named defendants and acted wlthln the scope of that agency or employment. b. Doe defendants (specify Doe numbers): 1-20 are persons whose capacities are unknown to plaintiff. 7. D Defendants who are jolned under Code of Clvi] Procedure sectlon 382 are (names): 8. This court ls the proper court because a. E at least one defendant now resides in its jurisdictiona! area. b. the prlncipal place of business of a defendant corporation or unincorporated association is in its jurisdictional area. c. Injury to person or damaga to personal property occurred in iis Iurisdictional area. d . E other (specify): 9. E Plaintiff is requlred to comply with a claims statute. and a. E has complied with applicable dalms statutes. or b. E Es excused from compiylng because {specify}: Pmmoi [Requuary 1. 200?] COMPLAINT-Personal Injury, Property Pagozota Damage, Wrongful Death W PLD-Pl-001 SHORT TlT‘LE: - CASE Mumsak Russell v. Singh 10. The following muses of action are attached and the statements above apply to each (each complain! must have one or more causes ofaction attached): . E MotorVehicIe . D GenemlNegligence . D lntenfionaITort . E3 Products Liability . D Premises LiabilityE other (specify): FQQOUQ) 11. Plaintiff has suffered a. E wageloss b, E loss of use ufproperty c. E hospita1 and medical expenses d. generaldamage e. property damage f. loss of earning capacity g. D other damage (specify): 12.D The damages claimed for wrongful death and the relationships of pialntifl to the deceased are a. E listed in Attachment 12. b. E as follows: 13. The relief sought in this complalnt [s within the jurisdiction of this court. 14. Plaintiff prays forjudgment for costs of suit; for such relief as is fair. just, and equilab1e: and for a. (1)E compensatory damages (2)D punitive damages The amount of damages is fin cases for personal injury or wrongful death, you must check (1)): (1) according to proof (2)E in the amountof: s 15.-The paragraphs of this oomp1aint alleged on Information and belief are as follows (specify paragraph numbers): AII Paragraphs Date: March 24. 2021 I Keny Russell i MM r L-‘ m'PE 0Rmm NAME) (snoNAmRXOF pump: on mummy) PLDPl-om [Rev.Janunry 1. 200?] COMPLAINT‘Personal Injury, Pmper‘ty U P3903!“ Damage. Wrongful Death ’1 C " * r\ PLD-Pl-001(1) SHORT TITLE: CASE Numaem Russe” v. Singh Fm CAUSE OF ACTION-Motor Vehicle ‘ (number) ATTACHMENT TO ComplaintE Cross-Compla'rm (Use a separate cause of action form for each cause 0f action.) Plaintiff (name): Kerry Russell MV- 1.Plaintiff alleges the acts of defendants were negligent: the acts were the legal (proximate) muse of Injuries and damages lo plaintiff; the acts occurred on (date): April 11. 201 9 at (place): Park Avenue in Pato Alto, California when plaintiff was the passenger In a vehlcie where the defendant drlver negligently drove loo fast over a marked speed bump resulting In injury. MV- 2. DEFENDANTS a. The defendants who operated a motor vehicle are (names): Dhanwant Singh and Does 1 t0 20 b. The defendants who employed the persons who operated a motor vehicTe in the course of thelr employment are (names): Dhanwant Singh, Yellow Checker Cab Company. Inc. and E Does 1 to 20 c. The defendants who owned the motor vehicle which was operated with their permission are (names): Dhanwant Slngh, Yellow Checker Cab Company, lnc‘ and Does 1 to 20 d. The defendants who entrusted the motor vehicle are (names): Dhanwant Singh. Yellow Checker Cab Company. Inc. and Does 1 to 20 9- The defendants who were the agents and employees of the other defendants and acted within the scope of the agency were (names): Dhanwant Singh, Yellow Checker Cab Company, Inc. and Does 1 to 20 f. D The defendants who are liable to plaintiffs for other reasons and the reasons for the Iiability are E: listed in Attachment MV-Zf E as follows: Does to Page4 Page 1 of 1 Form Agaroved {or Optional Use Code o! Civil Procedure 425.1 2 Mahmud“Mcmm CAUSE 0F ACTION-Motor Vehicle Wmmflgw PLD‘Pl-OOIU) [Rev‘ Jammy 1. 2001']
