ComplaintCal. Super. - 3rd Dist.August 2, 2017 - <> e PLD-P1-001 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY \- Michael R. Loewen 105197 Law Office of Michael R. Loewen PO Box 417078 Sacramento, CA 95841-7078 TecepHone No. 916-344-2300 FAX NO (Optional: E-MAIL ADDRESS (Optional): ATTORNEY FOR (Name); Glen Plushanski SUPERIOR COURT OF CALIFORNIA, COUNTY OF Placer street anoress: 10820 Justice Center Drive ie ZL am Eo cing maine aopress: 10820 Justice Center Drive u ory ano zp cove. Roseville, CA 95678 ee ae BRANCH NAME: A 0 | PLAINTIFe: Glen Plushanski JA ERS ‘ EXECUTIVE OFFICER & CLERK DEFENDANT: Kellie Gray By: C. Vallan-Brown, Deputy B e a s DOES 1 TO 20, inclusive COMPLAINT-Personal Injury, Property Damage, Wrongful Death () AMENDED (Number): Type (check ail that apply): MOTOR VEHICLE [(_] OTHER (specify): PropertyDamage § (_} Wrongful Death Personal Injury Other Damages (specify): Pre-Judgment Interest Jurisdiction (check all that apply): CASE NUMBER: (-} ACTION IS A LIMITED CIVIL CASE Amount demanded [(_] does not exceed $10,000 (-} exceeds $10,000, but does not exceed $25,000 ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000) S C VO0 398 25 Cc) ACTION IS RECLASSIFIED by this amended complaint : 2 [] from limited to unlimited [) from unlimited to limited | 1. Plaintiff (name or names): Glen Plushanski | alleges causes of action against defendant (name or names): Kellie Gray ! 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. (_) except plaintiff (name): B Y = fy VW (1) (C) a corporation qualified to do business in California FAL (2) (_} an unincorporated entity (describe): (3) C) a public entity (describe): (4) J aminor (2) an adult (a) [_} for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b) (LJ other (specify): (5) (_} other (specify): b. [_} except plaintiff (name): {1) a a corporation qualified to do business in California (2) (CJ an unincorporated entity (describe): (3) (_} a public entity (describe): (4) CJ aminor (C) anadutt (a) [_) for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b) LL] other (specify): (8) CL} other (specify): (_} information about additional plaintiffs who are not competent adults is shown in Attachment 3. Page 1 of 3 Fi J Ma rorma Aevnened tea eaanat ise CEB’ COMPLAINT-Personal Injury, Property Cone ee PLD-PI-001 (Rev. January 1, 2007] 209 (3) Forms: Damage, Wrongful Death Plushanski, Glen . @e - PLD-PI-001 SHORT TITLE: Plushanski v. Gray CASE NUMBER: 4. (C)} 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. [J except defendant (name): (1) (C) a business organization, form unknown (2) [} acorporation (3) (] an unincorporated entity (describe): (4) () a public entity (describe): (5) LL) other (specify): b. [] except defendant (name): (1) (CQ a business organization, form unknown (2) (] a corporation (3) [LJ an unincorporated entity (describe): (4) [) a public entity (describe): (5) [) other (specify): c. [) except defendant (name): (1) (CJ a business organization, form unknown (2) LC) acorporation (3) (<3 an unincorporated entity (describe): (4) (_} a public entity (describe): (5) [J other (specify): d. (C2 except defendant (name}: (1) (} a business organization, form unknown (2) (C] a corporation (3) [) an unincorporated entity (describe): (4) [a public entity (describe): (5) [J other (specify): [_) 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): 1-10..____+_+_-=__--ss sere the agents or employees of other named defendants and acted within the scope of that agency or employment. b. Doe defendants (specify Doe numbers): 11-20... are persons whose capacities are unknown to plaintiff. 7. {C.) Defendants who are joined under Code of Civil Procedure section 382 are (names): 8. This court is the proper court because a. (C) at least one defendant now resides in its jurisdictional area. b. (C] 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. (J other (specify): 9. [C)} Plaintiff is required to comply with a claims statute, and a. [_] has complied with applicable claims statutes, or b. (] is excused from complying because (specify): PLD-PI-001 [Rev. January 1, 2007} COMPLAINT-Personal Injury, Property Page 2 of 3 CEB Esponma Damage, Wrongful Death Plushanski, Glen e. e SHORT TITLE: CASE NUMBER. Plushanski v. Gray PLD-PI-001 10. The following causes of action are attached and the statements above apply to each (each compfaint must have one or more causes of action attached): Motor Vehicle General Negligence {_} intentional Tort {_} Products Liability (_]} Premises Liability (} Other (specify) : m o a o o ® m 11. Plaintiff has suffered wage loss loss of use of property hospital and medical expenses [@) general damage property damage joss of earning capacity other damage (specify) : Pre-Judgment Interest e r e na oo Dp [_] The damages claimed for wrongful death and the relationships of plaintiff to the deceased are a. [_]} listed in Attachment 12. b. [) as follows: 43. 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) (] punitive damages The amount of damages is (in cases for personal injury or wrongful death, you must check (1)): (1) L2) according to proof (2) (J in the amount of: $ 15. [} The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers): Date: 7/31/2017 yf ee Michael R. Loewen_ (TYPE OR PRINT NAME) (Sr@NATURE OF PLAINTIFF OR ATTORNEY) PLD-PL001 (Rey, January 1, 2007} COMPLAINT-Personal Injury, Property Page 3 of 3 CEB’ Sona! Damage, Wrongful Death Plusbanski, Glen oe. e: e SHORT TITLE: CASE NUMBER: Plushanski v. Gray PLD-P1-001(1) FIRST. CAUSE OF ACTION- Motor Vehicle (number} ATTACHMENT TO Complaint [] Cross-Complaint (Use a separate cause of action form for each cause of action.) Plaintiff (name): Glen Plushanski 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): 11/04/16 at (place): Elm Street and Lincoln, Placer County, California. MV-2. DEFENDANTS a. The defendants who operated a motor vehicle are (names): Kellie Gray Det iin OO es b. The defendants who employed the persons who operated a motor vehicle in the course of their employment are (names): Kellie Gray Dbtes 1D 2h. c. The defendants who owned the motor vehicle which was operated with their permission are (names): Kellie Gray Dele lank. Se. d. The defendants who entrusted the motor vehicle are (names): Kellie Gray fete fo. (40 2 e. The defendants who were the agents and employees of the other defendants and acted within the scope of the agency were (nares): Kellie Gray Doe 2. te f. (} The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are (J listed in Attachment MV-2f [_} as follows: Dd Ot © ncn oO ee Page Page 10f 1 Fe for Optional Use ivi} Procedu . Jide Gounel of California CAUSE OF ACTION - Motor Vehicle sates’ por 0 PLD-PI-004{1) [Rev. January 1, 2007} CER | Essential Plushanski, Glen cabcom | §2/Forms:
