Complaint

Cal. Super. - 3rd Dist.June 9, 2021

O o o O N DB D o H B R Ww W NY eB - oO 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NOLAN R. JONES, ESQ. / SBN: 309151 DREYER BABICH BUCCOLA WOOD CAMPORA, LLP 20 Bicentennial Circle ELECTRONICALLY FILED Telephone: (S16) 379 3500 superior Court of California, clepnone: , County of Placer F le: (916) 379-3599 DEBWC-ESERVICE@dbbwe-com 06/09/2021 at 11:18:03 AM By: Kathrine Zaragoza, Deputy Clerk Attorneys for Plaintiff SUPERIOR COURT OF CALIFORNIA COUNTY OF PLACER CHRISTINE HORTON, Case No.: S-CcV¥-0046938 Plaintiff, COMPLAINT FOR PERSONAL INJURIES Vv. SASHA WAGNON, and DOES 1 through 10, inclusive, Defendants. FIRST CAUSE OF ACTION (Personal Injury: CHRISTINE HORTON) Plaintiff CHRISTINE HORTON complains against Defendants SASHA WAGNON and DOES 1 through 10 and alleges as follows: 1. The true names and capacities -- whether individual, corporate, associate or otherwise -- of Defendants DOES 1 through 10, 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. Each of the Defendants, and DOES 1 through 10, are legally responsible in some manner -- negligently, in warranty, strictly, or otherwise -- for the incident that is the subject of this Complaint. /// Complaint for Personal Injuries o O o O N D O UN F& F WY NY & h t e © 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 within the County of Placer, State of California. Plaintiff further alleges that each Defendant is a citizen and resident of, or doing business within, the County of Placer, State of California. The amount in controversy is in excess of the minimal jurisdictional limits of this Court. 3. Defendants SASHA WAGNON and DOES 1 through 10 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 SASHA WAGNON and DOES 6 through 10 were the agents, employees or contractors of Defendants SASHA WAGNON and DOES 1 through 5, 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 Defendants. 5. Defendants SASHA WAGNON and DOES 1 through 5 also negligently hired, trained, and/or supervised Defendants SASHA WAGNON and DOES 6 through 10 in such a fashion as to cause and/or contribute to the occurrence of the incident described herein. 6. On August 8, 2019, Plaintiff CHRISTINE HORTON was driving on West Eureka Road in the City of Roseville in the County of Placer, State of California. At the same time and general location, Defendants SASHA WAGNON and DOES 6 through 10 were driving the subject vehicle directly behind Plaintiff CHRISTINE HORTON driving on West Eureka Road in the City of Roseville, when Defendant SASHA WAGNON failed to see traffic stopped ahead of her and rear-ended Plaintiff, thereby causing injury and damages to Plaintiff. 7. Defendants negligently entrusted, managed, maintained, drove, operated, repaired, manufactured and designed the vehicle so as to cause the collision and the resulting injuries and damages to Plaintiff. 8. As a result of the negligence of Defendants, Plaintiff CHRISTINE HORTON suffered personal / bodily injuries, resulting in economic and noneconomic 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 -2- Complaint for Personal Injuries Nn FD Ww W Ff W N O o @ 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 use. Noneconomic damages include, but are not limited to (1) past and future physical and mental suffering, (2) loss of enjoyment of life, (3) anxiety, and (6) emotional distress. physical impairment, (4) inconvenience, (5) Plaintiff CHRISTINE HORTON prays for judgment against Defendants for: a. Noneconomic damages in excess of the jurisdictional limit of this Court; b. All medical and incidental expenses according to proof; c. All loss of earnings according to proof; d. Prejudgment interest to the extent permitted by law; e. All costs of suit; and f. Such other and further relief as this Court may deem just and proper. DATED: June 9, 2021 DREYER BAB BUCCOLA WOOD CAMPORA, LLP MS T NO 7 NES Complaint for Personal Injuries