ComplaintCal. Super. - 3rd Dist.July 31, 201735 u u PLD-PI-001 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): | Stephen C. Baker (SBN: 112324) Diamond Baker Mitchell, LLP 149 Crown Point Court, Suite B Grass Valley, CA 95945 TELEPHONE NO: (530) 272-9977 FAX NO. (Optional): (530) 272-8463 E-MAIL ADDRESS (Optional): sbaker@diamondbaker. com ATTORNEY FOR (Name): Plaintiff, Eric Lawrence Knell SUPERIOR COURT OF CALIFORNIA, COUNTY OF Placer street aopress: 10820 Justice Center Drive MAILING ADDRESS: PO Box 619072 city ano zip cove: Roseville, CA 95678 BRANCH NAME: PLAINTIFF: Eric Lawrence Knell DEFENDANT: Alma Jean Iseger DoES1To 20 COMPLAINT-Personal Injury, Property Damage, Wrongful Death [__] AMENDED (Number): Type (check all that apply): MOTOR VEHICLE [__] OTHER (specify): [_] Property Damage [__] Wrongful Death Personal Injury [__] Other Damages (specify): FOR COURT USE ONLY I Superior Cox County wo JUL 31 2017 Jake Chaiters xecutive Officer & Clerk By: M. Anderson, Deputy 14 Jurisdiction (check all that apply): [__] 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) [_] ACTION IS RECLASSIFIED by this amended complaint L__] from limited to unlimited [__] from unlimited to limited CASE NUMBER: §CV 0039907 1. Plaintiff (name or names): Eric Lawrence Knell alleges causes of action against defendant (name or names): Alma Jean Iseger 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. [__] except plaintiff (name): (1) [__] a corporation qualified to do business in California (2) [__] an unincorporated entity (describe): (3) [__] a public entity (describe): (4) [--] aminor [__] an adult (a) [__] for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b) [__] other (specify): (5) [__] other (specify): b. [__] except plaintiff (name): (1) [__] a corporation qualified to do business in California (2) [__] an unincorporated entity (describe): (3) [__] a public entity (describe): (4) [__] aminor [__] an adult (a) [__] for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b) [__] other (specify): (5) [__] other (specify): [1 information about additional plaintiffs who are not competent adults is shown in Attachment 3. Page 1 of 3 Form Approved for Optional Use Judicial Council of California PLD-PI-001 [Rev. January 1, 2007] Damage, Wrongful Death COMPLAINT-Personal Injury, Property Code of Civil Procedure, § 425.12 www.courtinfo.ca.gov PLD-PI-001 SHORT TITLE: Knell v. Iseger CASE NUMBER: 4. [__] 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): (1) [_] a business organization, form unknown (2) [__] a corporation (3) [-_] an unincorporated entity (describe): (4) [__] a public entity (describe): (5) [__] other (specify): b. [__] except defendant (name): (1) [-_] a business organization, form unknown (2) [__] acorporation (3) [__] an unincorporated entity (describe): (4) [__] a public entity (describe): (5) [__] other (specify): c. [__] except defendant (name): (1) [__] a business organization, form unknown (2) [__] acorporation (3) [__] an unincorporated entity (describe): (4) [__] a public entity (describe): (5) [__] other (specify): d. [___] except defendant (name): (1) [-_] a business organization, form unknown (2) [__] acorporation (3) [-_] an unincorporated entity (describe): (4) [__] a public entity (describe): (5) [__] 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 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): 11 - 20 are persons whose capacities are unknown to plaintiff. 7. [_] Defendants who are joined under Code of Civil Procedure section 382 are (names): 8. This court is the proper court because a. [___] at least one defendant now resides in its jurisdictional area. b. [__] the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area. G injury to person or damage to personal property occurred in its jurisdictional area. d . [__] other (specify): 9. [__] 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 Damage, Wrongful Death PLD-PI-001 SHORT TITLE: CASE NUMBER: Knell v. Iseger 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): j Motor Vehicle : General Negligence . [__] Intentional Tort a b c d. [___] Products Liability e. [__] Premises Liability f. [__] Other (specify): 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): Pain and suffering. a m e a o o m 12. [__] The damages claimed for wrongful death and the relationships of plaintiff to the deceased are a. [__] listed in Attachment 12. b. [__] 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 as (1) compensatory damages (2) [__] punitive damages The amount of damages is (in cases for personal injury or wrongful death, you must check (1)): (1) according to proof (2) [__] in the amount of: $ 15. [__] The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers): Date: July 19, 2017 Stephen C. Baker (SBN 112324) > Qkolun @. £ ! aes (TYPE OR PRINT NAME) v (SIGNATURE OF PLAINTIFF OR ATTORNEY) PLD-PI-001 (Rev. January 1, 2007] COMPLAINT-Personal Injury, Property Page 3 of 3 Damage, Wrongful Death PLD-PI-001(1) SHORT TITLE: CASE NUMBER: Knell v. Iseger 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): Eric Lawrence Knell 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): February 2, 2017 at (place): State Route 49, north bound, near the intersection of State Route 49 and Hulbert Way, in Placer County California. MV- 2. DEFENDANTS a. The defendants who operated a motor vehicle are (names): Alma Jean Iseger Does | tor 75 b. The defendants who employed the persons who operated a motor vehicle in the course of their employment are (names): Does 4 to 10 The defendants who owned the motor vehicle which was operated with their permission are (names): Alma Jean Iseger oO Does 4 to .
