Complaint

Cal. Super. - 3rd Dist.November 27, 2019

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CRAIG C. SHEFFER, ESQ. / SBN: 131243 DREYER BABICH BUCCOLA WOOD CAMPORA, LLP 20 Bicentennial Circle Sacramento, CA 95826 Telephone: (916) 379-3500 Facsimile: (916) 379-3599 FILED ee Pe eun ene California Attorneys for Plaintiff NOV 27 2019 edeati’ Chatters tive Officer & Cle, By: O. Lucatuorto, Deputy SUPERIOR COURT OF CALIFORNIA COUNTY OF PLACER GUONG VAN NGUYEN, Case No.: cv 0044108 Plaintiff, COMPLAINT FOR PERSONAL INJURIES Vv. WILLIAM JAMES CARR and DOES 1 through 25, inclusive, Defendants. Plaintiff GUONG VAN NGUYEN complains against Defendants, WILLIAMS JAMES CARR and DOES 1 through 25, inclusive and alleges as follows: FIRST CAUSE OF ACTION (NEGLIGENCE - MOTOR VEHICLE COLLISION) 1. The true names and capacities -- whether individual, corporate, associate or otherwise -- of Defendants DOES 1 through 25, are unknown to Plaintiff, who therefore sues such DOES by such fictitious names. Plaintiff will amend this Complaint to show their true names and capacities when the same have been ascertained. Plaintiff is informed and believes and thereon alleges that Defendants DOES 1 through 25, and each of them, are responsible under law in some manner negligently, in warranty, strictly or otherwise, for the events and happenings herein referred to and proximately thereby caused injuries and damages to Plaintiff as herein alleged. = ifs COMPLAINT FOR PERSONAL INJURIES 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2. Plaintiff is now, and at all times herein mentioned, was a citizen of and resident of the State of California. The subject incident occurred in the County of Placer, State of California, and the amount in controversy is in excess of the minimum jurisdiction of an unlimited civil action. Plaintiff is informed and believes and thereon alleges that, at all times herein mentioned, Defendants, WILLIAMS JAMES CARR and DOES, and each of them, were, and are residents within the County of Placer, in the State of California. 3. Defendants, WILLIAMS JAMES CARR and DOES, were the owners and/or operators of the subject vehicle. All Defendants operated the vehicle with the knowledge and consent of all other Defendants. 4. Defendants, WILLIAMS JAMES CARR and DOES, were the agents, employees or contractors of Defendants, WILLIAMS JAMES CARR and DOES, and were at all times acting within the course and scope of said agency, employment or contract, and with the permission, knowledge and consent of each remaining Defendant. 5; Defendants, WILLIAMS JAMES CARR and DOES, also negligently hired, trained, and/or supervised Defendants, WILLIAMS JAMES CARR and DOES, in such a fashion as to cause and/or contribute to the occurrence of the incident described herein. 6. On or about December 11, 2017, Plaintiff was stopped at a traffic light on Douglas Boulevard at Sierra College Boulevard in the County of Placer, State of California. 7. That at the time and place of the aforementioned above, Defendant, WILLIAMS JAMES CARR was operating a motor vehicle and caused his vehicle to collide with the rear of Plaintiff’s vehicle, thereby causing injury and damages to Plaintiff. 8. As a direct result of the negligence of Defendants, Plaintiff, GUONG VAN NGUYEN, suffered personal/bodily injuries, resulting in economic and non-economic damages. Economic damages include, but are not limited to, (1) past and future medical and/or ancillary related expenses, (2) past and future income and/or earning capacity loss, (3) loss of ability to provide household services, and (4) incidental and consequential damages and/or property damage and loss of use. Non-economic damages include, but are not limited to, (1) past and future physical and mental suffering, (2) loss of enjoyment of life, (3) physical impairment, (4) inconvenience, =D: COMPLAINT FOR PERSONAL INJURIES 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 and (5) emotional upset. WHEREFORE, Plaintiff prays for judgment against Defendants, WILLIAMS JAMES CARR, and DOES 1 through 25, and each of them, for: 1. General damages in an amount in excess of the minimum jurisdiction of an unlimited civil action; 2. For all medical and incidental expenses according to proof; 3. All loss of earnings according to proof; 4. All property damage and loss of use damages; Prejudgment interest according to law on all general and special damages; 6. All costs of suit; and, 7. Such other and further relief as this court may deem just and proper. DATED: November 21, 2019 DREYER BABICH BUCCOLA WOOD CAMPORA, LLP By: CRAIG C. SHEFFER 7. COMPLAINT FOR PERSONAL INJURIES