Complaint Limited 10K and 25KCal. Super. - 6th Dist.March 30, 2021E-FILED 3/30/2021 11:42 AM Clerk of Court Superior Court of CA, County of Santa Clara 21CV381487 Reviewed By: V. Taylor 21CV381487 PLD-Pl-001 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): Tristan Yohan Jagroop, Esq. (SBN: 294381) F°R“0”" ”SE °"LY The Jagroop Law Office, Inc. Post Office Box 43 Union City, CA 94587 TELEPHONE No; (510)556401 3 FAX No. (Optional): (51 0)441 -2054 E-MAIL ADDRESS (Optional): Iawtrist@gmail,com ATTORNEY FOR (Name): Jerome Andrew Ward SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA STREET ADDRESS: 191 North First Street MAlLING ADDRESS: 191 North First Street CITY AND ZIP CODE: San Jose, CA 951 13 BRANCH NAME: Downtown Superior Court PLAINTIFF: Jerome Andrew Ward' 3- DEFENDANT: Maria Zavala, Ericka Acosta (also known as En‘cka Ruiz), and Does 1-60, inclusive.E DOES 1 TO COMPLAINT-Personal Injury, Property Damage, Wrongful Death CASE “UMBER:E AMENDED (Number): Type (check all that apply): ‘E MOTOR VEHICLE E OTHER (specify).-E Property Damage E Wrongful Death |_x7 Personal Injury ["‘l Other Damages (specify): Jurisdiction (check all that apply):E ACTION IS A LIMITED CIVIL CASE Amount demanded does not exceed $10,000 x exceeds $10,000, but does not exceed $25,000E ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000) E3 ACTION IS RECLASSIFIED by this amended complaintE from limited to unlimitedE from unlimited to limited 1. Plaintiff (name or names): Jerome Andrew Ward alleges causes of action against defendant (name or names): Maria Zavala, Ericka Acosta (also known as Ericka Ruiz). and Does 1-60, Inclusive. 2. This pleading, including attachments and exhibits, consists of the following number of pages: 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)D for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b)E 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 public entity (describe): (4)E a minor E an adult (a)D for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b)E other (specify): (5)E other (specific:E Information about additional plaintiffs who are not competent adults is shown in Attachment 3. Page 1 of 3 Form Approved for Optional Use COMPLAINT-Personal Inju ry, Property Code of Civil Procedure, § 425.12 Judicial Council of California wwonouns.ca.gov PLD-PI-om [Rev. January 1. 2007] Damage, Wrongful Death PLD-Pl-001 SHORT TITLE: Jerome Andrew Ward v. Maria Zavala, Ericka Acosta (also known as Ericka Ruiz), et al. CASE NUMBER: 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. 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 defendantmame): (1)E a business organization. form unknown (2)E a corporation (3)E an unincorporated entity (describe): (4)E a public entity (describe): (5)D other (specify): d. 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): 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. E] Doe defendants (specify Doe numbers): 1-30 were the agents or employees of other named defendants and acted within the scope of that agency or employment. b. EC] Doe defendants (special Doe numbers): 31-60 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. E injury to person or damage to personal property occurred in its jurisdictional area. d. E other (specify): 9. D 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-om [Rem January1.2oo7] COMPLAINT-Personal Injury: Pmperty Pagezofa Damage, Wrongful Death PLD-PI-001 SHORT TITLE: CASE NUMBER: Jerome Andrew Ward v. Maria Zavala, Ericka Acosta (also known as Ericka Ruiz), et al. 10. The following causes of action are attached and the statements above apply to each (each complaint musthave one or more causes of action attached): a. E MotorVehicle b. E GeneralNegligence . E] IntentionalTort . E Products Liability . E Premises LiabilityE other (specify): O 1"‘CDQ 11. Plaintiff has suffered a. E wageloss b. E loss ofuse of property c. E hospitaland medicalexpenses d. E] generaldamage e. E property damage f. E loss ofeaming capacity g. E otherdamage (specify): Pain and Suffering, Emotional Distress, Menta! Anguish, etc. 12.E The damages claimed for wrongful death and the relationships of plaintiffto 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)E compensatory damages (2)E punitive damages The amount of damages is (in cases for personal injUIy or wrongful death, you must check (1)): (1)E 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): Date: March 30, 2021 w Tristan Yohan Jagroop, Esq. > I Mk / (TYPE 0R PRINT NAME) (SIGNATU 0F PLAINy/KflJR ORNEY)” V PLD~Pmm [Rem January 1, 2007] COMPLAINT-Personal Injury. ProPerty II / Page 3 of 3 Damage, Wrongful Death PLD-PI-001(1) SHORT TITLE: a'aL CASE NUMBER: Jerome Andrew Ward v. Maria Zavala, Ericka Acosta (gin knew!“ c r En‘dc; [232}, First (1st) CAUSE OF ACTION-Motor Vehicle (number) ATTACHMENT TOE ComplaintE Cross-Complaint (Use a separate cause of action form for each cause of action.) Plaintiff (name): Jerome Andrew Ward 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 7, 2019 at (place): State of California. County of Santa Clara, City of Santa Clara; specifically, at (or approaching) the intersection of Capitol Expressway and Capitol Avenue. MV- 2. DEFENDANTS a. E The defendants who operated a motor vehicle are (names): _ Ericka Acosta (avg Icnawin 'a r en‘c (cg. ILw z) E Does 1 to 1O b. E The defendants who employed the persons who operated a motor vehicle in the course of their employment are (names): E Does 11 to 20 c. E The defendants who owned the motor vehicle which was operated with their permission are (names): E Does 21 to 30 d. E The defendants who entrusted the motor vehicle are (names): E Does 31 to 40 e. m The defendants who were the agents and employees of the other defendants and acted within the scope of the agency were (names): E Does 41 to 5O 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 51 to 60 Page One ( 1) Page 1 of 1 Form Approved for Optional Use - Code of Civi! Procedure 425,12 Judlciat Council of California CAUSE OF ACTION-MOtor vehICIe www.counsmgov PLD-PI-oom) [Rev‘ January 1. 2007]
