Complaint Unlimited Fee AppliesCal. Super. - 6th Dist.March 23, 2021P_F” Fr) PLD-PI-001 ATTORNEY (Name, S a e Bar number, and address): .U LY -“"&F}”§§ ?.PGRVTJJHLHSXZL Esq. SBN 3221649 13/23/202"?WWI?” M&Y Personal Injury Lawyers Clerk Of Court 4929 Wilshire B1vd., Suite 960 Superior Court 0f CA, L03 Angelesa CA 90010 County of Santa Clara TELEPHONE No: (877) 771-8175 FAX No. (Optional): (323) 475_7773 21 CV381 01 8 E-MAIL ADDRESS (Optional): greg@my1aWCOl’npany. COIIl ATTORNEY FOR (Name): Plaintiff EVCI' TOI‘I'GS SUPERIOR COURT OF CALIFORNIA, COUNTY OF santa Clara STREET ADDRESS: 191 North First Street MAILING ADDRESS: CITY AND ZIP CODE: San JOSG, CA 951 13 BRANCH NAME: Downtown Superior Court PLAINTIFF: EVGI‘ Torres Reviewed By: V. Taylor DEFENDANT: William Bradford Hart, Jr.; and DOES 1 To 10 COMPLAINT-Personal Injury, Property Damage, Wrongful DeathE AMENDED (Number): Type (check all that apply): MOTOR VEHICLE E OTHER (specify): Property Damage E Wrongful Death Personal Injury E Other Damages (specify): Jurisdiction (check aII 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) 21 CV381 O1 8E ACTION Is RECLASSIFIED by this amended complaintE from limited to unlimitedE from unlimited to limited 1. Plaintiff (name or names): Ever Torres alleges causes of action against defendant (name or names): William Bradford Hart, Jr.; and Does 1 t0 10 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 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): E Information about additional plaintiffs who are not competent adults is shown in Attachment 3. Page 1 o” Form Approved for Optional Use COMPLAINT_Persona| lnju ry’ Property Code of Civil Procedure, § 425.12 Judicial Council of California www.courtinfo.ca.gov PLD-PI-oo1 [Rev. January 1, 2007] Damage, Wrongful Death PLD-PI-001 SHORT TITLE: CASE NUMBER: Torres V. Hart, Jr. 4. E 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. except defendant (name): Andrian, Inc. c. E except defendant (name): (1)E a business organization, form unknown (1) E a business organization, form unknown (2) a corporation (2)E a corporation (3)E an unincorporated entity (describe): (3) E an unincorporated entity (describe): (4) E a public entity (describe): (4) E a public entity (describe): (5)E other (specify): (5) E other (specify): b. E except defendant (name): d. E except defendant (name): (1)E a business organization, form unknown (1) E a business organization, form unknown (2)E a corporation (2) E a corporation (3)E an unincorporated entity (describe): (3) E an unincorporated entity (describe): (4) E a public entity (describe): (4) E a public entity (describe): (5)E other (specify): (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): 1'5 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): 6-10 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. E at least one defendant now resides in itsjurisdictional area. . E the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area. injury to person or damage to personal property occurred in its jurisdictional area.E other (specify):9.06 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-PI-001 [Rev. January 1, 2007] COMPLA|NT_Persona| |njury’ Property Page 2 of 3 Damage, Wrongful Death PLD-PI-001 SHORT TITLE: CASE NUMBER: Torres V. Hart, Jr. 10. 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): a. Motor Vehicle b. General Negligence . E Intentional Tort . E Products Liability . E Premises LiabilityE Other (specify):.‘hCDQO 11. 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): Emotional distress eorhwslovsv 12. 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: 13. The relief sought in this complaint is within the jurisdiction of this court. 14. 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) accordingto proof (2)E in the amountof: $ 15. E The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers): Date: March 23, 2021 p gm?»WfiflmGreg R. Woodhead . (TYPE OR PRINT NAME) (SIGNATURE OF PLAINTIFF OR ATTORNEY) pLD-p|-oo1 [Rev.January1,2oo7] COMPLAINT-Personal Injury, Property Page3°f3 Damage, Wrongful Death PLD-PI-oo1(1) SHORT TITLE: CASE NUMBER: Torres V. Hart, Jr. One CAUSE OF ACTION-Motor Vehicle (number) ATTACHMENTTO Complaint E Cross-Complaint (Use a separate cause of action form for each cause of action.) Plaintiff (name): Ever Torres MV- 1. 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): June 4, 2019 at (place): Market St & Water St., Santa Cruz, CA 95060 MV- 2. DEFENDANTS a. The defendants who operated a motor vehicle are (names): William Bradford Hart, Jr.; and Does 1 to 10 b. The defendants who employed the persons who operated a motor vehicle in the course of their employment are (names): William Bradford Hart, Jr.; and Does 1 to 10 c. The defendants who owned the motor vehicle which was operated with their permission are (names): William Bradford Hart, Jr.; and Does 1 to 10 . The defendants who entrusted the motor vehicle are (names): William Bradford Hart, Jr.; and Q. Does 1 to 10 e. The defendants who were the agents and employees of the other defendants and acted within the scope of the agency were (names): William Bradford Hart, Jr.; and Does 1 to 10E The defendants who are liable to plaintiffs for other reasons and the reasons for the liability areE listed in Attachment MV-2f E as follows:_-h E Does to Page 4 Page 1 of 1 Form Approved for Optional Use CAUSE 0F ACT|ON_Motor Vehic|e Code of Civil Procedure 425.12 Judicial Council of California www.courtinfo.ca.gov PLD-PI-001(1) [Rev. January 1, 2007] PLD-PI-oo1(2) SHORT TITLE: CASE NUMBER: Torres V. Hart, Jr. Two 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): Ever Torres alleges that defendant (name): William Bradford Hart, Jr.; and mDoes 1 to 10 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): June 4, 2019 at (place): Market St & Water St., Santa Cruz, CA 95060 (description of reasons for liability): Defendants and each 0f them negligently, carelessly, and unlawfully owned, drove, operated, entrusted, and maintained their vehicle causing it t0 collide with Plaintiffs vehicle in an accident, thereby causing personal injuries and damages t0 Plaintiffs. As a result of Defendants' negligence, Plaintiffs were required t0 undergo medical treatment, incurred medical expenses, suffered lost earnings, and sustained pain and suffering. Page 1 of 1 Form Approved for Optional Use - Code of Civil Procedure 425.12 Judicial Council ofCaIifomia CAUSE OF ACTION-General Negllgence www.courtinfo.ca.gov PLD-PI-001(2) [Rev. January 1, 2007]
