Complaint Unlimited Fee Applies

Cal. Super. - 6th Dist.April 1, 2021

|:_|:” Fn PLD-PI-001 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): Brennan S. Huelse, Esq. SBN: 31 1467 OAKWOOD LEGAL GROUP, LLP 470 S. San Vicente Blvd., 2nd Floor Los Angeles, CA 90048 TELEPHONE No: (31 O) 205-2525 FAX No. (Optional): (31 0) 773-5573 E-MAIL ADDRESS (Optional): brennan@oakwoodlegal.com ATTORNEY FOR (Name): Plaintiff, THERESA CAMPOS SUPERIOR COURT OF CALIFORNIA, COUNTY OF 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: THERESA CAMPOS DEFENDANT: BENERVA SUAREZ; and DOES 1 TO 25 inclusive 4/1/202‘?R?2{‘UGSNW Clerk of Court Superior Court of CA, County of Santa Clara 21 CV381429 Reviewed By: D Harris COMPLAINT-Personal Injury, Property Damage, Wrongful DeathE AMENDED (Number): Type (check all that apply): MOTOR VEHICLE E OTHER (specify): Property Damage E WrongfulDeath | x | Personallnjury I I Other Damages (specify): Jurisdiction (check all that apply):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) | | ACTION IS RECLASSIFIED by this amended complaintE from limited to unlimitedE from unlimited to limited CASE NUMBER: 21 CV381 429 1. Plaintiff (name or names): THERESA CAMPOS alleges causes of action against defendant (name or names): BENERVA SUAREZ; and DOES 1 TO 25, inclusive 2. This pleading, including attachments and exhibits, consists of the following number of pages: 4 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 of3 Form Approved for Optional Use COMPLAINT-Personal Inj u ry, Property Code of Civil Procedure, § 425.12 Judicial Council of California PLD-Pl-001 [Rev. January 1, 2007] Damage, Wrongful Death www. courts. ca.gov PLD-PI-001 SHORT TITLE: CASE NUMBER: CAMPOS v. SUAREZ 4. 5. 6. E Plaintiff (name): is doing business under the fictitious name (specify): and has complied with the fictitious business name laws. Each defendant named above is a natural person a. E except defendant(name): c. 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): 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. The true names of defendants sued as Does are unknown to plaintiff. a. Doe defendants (specify Doe numbers): 1 to 12 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): 13 to 25 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. 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 its jurisdictional 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-PI-oo1 [Rev. January 1, 2007] COMPLAINT-Personal Injury, Property Page 2 of3 Damage, Wrongful Death PLD-PI-001 SHORT TITLE: CASE NUMBER: CAMPOS v. SUAREZ 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): MotorVehicIeE General NegligenceE IntentionaITortE Products LiabilityE Premises LiabilityE Other (specify): rhsvslovsv A co-hcnglpo-m-x I . Plaintiff has suffered . wageloss . loss of use of property hospital and medical expenses general damage . property damage loss of earning capacity . E otherdamage (specify): 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 for judgment 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: $ 15. -The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers): A|| except 1 through 4 Date: March 30, 2021 Brennan S. Huelse, Esq. ’ ' (TYPE OR PRINT NAME) (SIGNATURE OF PLAINTIFF OR ATTORNEY) PLD-PI-oo1 [Rev. January 1, 2007] COMPLAINT-Personal Injury, Property Page 3 of3 Damage, Wrongful Death PLD-PI-oo1(1) SHORT TITLE: CASE NUMBER: CAMPOS v. SUAREZ FIRST CAUSE OF ACTION-Motor Vehicle (number) ATTACHMENT TO ComplaintE Cross-Complaint (Use a separate cause of action form for each cause of action.) Plaintiff (name): THERESA CAMPOS 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): April 19, 2019 at (place): Intersection of McKee Rd. and Capitol Ave., City of San Jose, County of Santa Clara, State of California. MV- 2. DEFENDANTS a. The defendants who operated a motor vehicle are (names): BENERVA SUAREZ; and E Does 1 t0 25 b. The defendants who employed the persons who operated a motor vehicle in the course of their employment are (names): BENERVA SUAREZ; and Does 1 t0 25 c. The defendants who owned the motor vehicle which was operated with their permission are (names): BENERVA SUAREZ; and Does 1 t0 25 d. The defendants who entrusted the motor vehicle are (names): BENERVA SUAREZ; and Does 1 t0 25 e- The defendants who were the agents and employees of the other defendants and acted within the scope of the agency were (names): BENERVA SUAREZ; and Does 1 to 25 f. E 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: E Does to Page4 Page 1 of1 F A v df O ti IU - C d fCiviIP d 425.12 argicg‘igoincfigf gafipoamiase CAUSE OF ACTION_M°t°r vehICIe O e0 wéfigobgescagov PLD-Pl-001(1) [Rev. January 1, 2007]