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Case 2:16-cv-03595 Document 1-1 Filed 05/24/16 Page 1 of 13 Page ID #:5

EXHIBIT A

Case 2:16-cv-03595 Document 1-1 Filed 05/24/16 Page 2 of 13 Page ID #:6

SUMMONS
(ctT4ctoM JUDICTAL)

FOR COUR'I USE OI,ILY


CORTE'
PARA USO De

tA

$aLo

NOTICE TO DEFENDANT:
(AV|SO AL DEMANDAO):

:Wiffie^-ff'fr:*"

VALVE CORPORATION and DOES I through

10, inclusive

APR

l2

2016

Executive Oflir/Glerk
Sheni R' Carter'
"""" n"'na Griiatva' DePtnY

YOU ARE BEING SUED BY PLAINTIFF:


(LO ESTA DEMANANDO EL DEMANDANTE):

r'

A.M.
NOTICE] You have been su. The court may decide against you without your being heard unless you respond wilhn 30 days, Read the information
below.

You have 30 CALENAR DAYS afler this summons and legal papers are served on you to file a written response at this court and have a coPy
seryed on ihe plaintiff. A lelter or phone call will not protect you. Your written response must be in proper legal forrn if you want the court to hear your
case. There rnay be a court form that you can use for your response. You can lnd these court forms and more information at the California Courts
Online Self-Help Center (www.couftlnfo.ca.gov/selfheip), your county aw library, or tfre courthouse nearest you. lf you cnnot Pay the filing fee, ask
the court clerk ior a fee waiver fonn. lf you do not file your response on time, you rnay lose the cse by default, and your wages, money, and propefty
may be taken without further warning from the court.
here are other legal requirements. You may want to oall an attorney right away, lf you do not know an attorey, you may wanl to.cll an attorney
referral servioe. lf you cannot atford an attomey, yoq may e eligile for free legal serulces from a nonprofit legaf services progtarn. You can locte
these nonproflt grups at the Callfornia Legel SeMces Wb site (www.tawhelpca!fornia.org), the California Courts Online Self-Heip Center
lfen for walved fees and
lwww.coirtinlo.a.gou/setfhetpl, or by contacting your local court o counly bar association. NOTE: The court has a sttutory
osts on any settlement or arbitration award of $10,000 or more in a civil case, The court's lien rnust be pald before the ourt wlll dlsmiss tho case.
VISOI Lo'han demandado. S no respon de dentro de 30 das, la corte puede decidir en su contra sin escuchar su versn. Lea ta informacin d

.4

continuacin,
Tene 30 DIAS DE CALENDARTO despus de que te enteguen esta citacin y papeles i/egales para rcsntar un1 rspuasta por escrifo en esfa
ctrte y hacer que se enlregue una copia al demandante, IJna cafta o una llamada lelefnica no lo protagen. Su tspuesta pot scrito tiene gue esfar
en ormato legal correcta s,'desea qu procesen s, caso n ta coie. Es posr'b/e qu haya un formularo que usted pueda usar para s respuosf'
puede oncoitrat estos formularos de ta corte y ns nforffiacin en e! entro d Ayuda de /as Corfes de California (www.sucorte.ca .gov), en la
btbtioteca de /eys de su condado o n la corle que te quede ms cerca. Si no puede pagar la cuota de presantacn, Pda al secretaro de Ia corte
que le d un formutario de exencion de pago de coles, Si no presenf su respr.resta a tiempo, puede prdr l caso por incumplimnto y la cofte l
podr
qulrar su sualdo, dinero y lenes sin ns advertencla.
Hay tros requlslos legaies.'Es recomendable que llame a un abogado inmediatamente. Si no conoce a un abogado, puede llamar a un servicio de
remiin a aogados. Si no puede pagar a un abogado, os posrb/e que cumpla con /os regulsilos para obtener seruicios legales gratutos de un
programa de servlcios legalos sit fines de lucro. Puede encontar aslos grupos srn fines de luao an el stio web de California Lagal Serv/ces,
ponndose en contacto con la corle o e!
ltvww.tawnelpcalifornia.org), en el Centro de Ayuda de las Corfes de alifornia,lwww,sucorte.ca .gov) o
cotegio de abogedos toates. ,AVJSO; Por tey, ta corte tene derecho rcclamar las cuos y /os cosjos exettos por mponer un grauamen sobre
cuanuer recuieracion de $10,000 ms cta valor rctbda medlant uh acutdo o una concesin de rbtraie en un caso de deracho civit. Tlena que
pagat et gravmn d la cofte antes d que la corte pueda desechar el caso,
CASE NUMBER:
(Nmsrc dsl Casr:

The name and address of the court is:

Los Angeles Superior Court


I l1 N. Hill St. Los Angeles, CA 90012

(EI nombre

direccon de ta orte esJi

BC6

t 6 7 ns

The name, address, and telephone number of plaintiffs attorney, or plaintff without an attorney, is:
(EI nombre, Ia direccin y el nmero de telfono del abogado del demandanle, o del demandante que no tiene abogado, es):

Chad Biggins206922,370l Wilshire Blvd., Suite 410, Los Angeles,


DATE:
(Fecha)

APR

I Z 2016

CA

90010

Tel: 213-387-3100
, Deputy
(Adjunto)

Clerk, by
tario)

of this summonq use Proof


(Para prueba de entrega de esfa ctatin use el formulano Proof of Service of Summons,
NOTICE TO THE PERSON SERVED: You are serued
[SEAL
as an indivdual defendant.
as the person sued under the fctitious name of (specfy)
2.

NI.GRI,IALVA

f1

3.

f-l

on behalf of (specify):

under:

4.
Form Adoptd for lvtndly Use
Judldl Councl of allforn8
SUM-100 [Rev. ly l, 20091

T-l

l--l
[:l
L*l
l---l

cP 416.10 (corporation)
CCp 416.20(defunct corporation)
CCp 416,40 (association or prtnership)

t_f

CCP 416.60 (minor)


CCP 416.70 (conservatee)
CCP 4'10.90 (authorized person)

other (specify):
personal
delivery on (date):
by

SUMMONS

Po
Code of c|vil Procdure S$

f2.20, 485

www.cow'liilo.ce,gv

EXHIBIT A
1

Case 2:16-cv-03595 Document 1-1 Filed 05/24/16 Page 3 of 13 Page ID #:7

I
L
5

Chad Biggins, sq. (State Bar No. 206922)

Biggins Law Group


3701 Wilshire Blvd, Suite 410
Los Angeles, CA 90010
T:213-387-3100
F: 213-387-3 t0l
chadbiggins@grnail, com

:'?lfff,ftffiF,g*'

ulerrr ourt of Qalliornia


\,ol,lnly ':t L,oS Angel,S

APR

Sherri R. Carter, Executive Officer/Clerk

I 2 2T16

Attomeys for Plairrtiff


A.M.

By Cristina Grljalva, Deputy

7
8

SUPERIOR COURT OF TI.IE STATE OF CA.LIFORNIA


9

FOR THE COUNTY OF LOS ANGELES


10

1l

Case No.

A.M.,

12

COMPLINT FOR:

Plaintiff,

l3
vs,

t4
15
T6

VALVE CORPORATION and DOES


through 10, inclusive
Defendants

17

ts0e16?60

1) WRONGFUL TERMINATION
2) DTSCRIMINATION
3) FATLURE TO ACCOMMODATE OR
ENGAGE IN INTERACTIVE PROCESS
4) HOSTILE \ilORK ENVIRONMENT
s) RETALIATION
6) UNPAID WAGES (OVERTIME)
7) BUS. & PROF'.. CODE $ 17200
8) MISCLASSIFICATION

18

IDEMAND FOR JURY TRIAL]

l9
20

2t

Plaintiff A.M. ("Plantiff'), by

22

1.

arrd through her attorney, alleges aud avers as follo"vs:

Plaintiff is infonned and believes and based thereon alleges that, at all times herein

relevant, defendant VALVE CORPORATION (hereinafter referred to as "Defendant"), was, and

24

still is, a corporation with its principal location in the state of Washington' Defendant is a

25

prominent company in the video garne industry. It develops video garnes and sells games otl the

26

Internet. Its titles and content

27

world.

are translated into numerous larrguages and distributed all over the

28
Case

No
COMPLAINT

EXHIBIT A
2

Case 2:16-cv-03595 Document 1-1 Filed 05/24/16 Page 4 of 13 Page ID #:8

Z.

Plaintiff is unaware of the tlue names and capacities of the defendants sued herein

DOES 1 through 10, inclusive, and therefore, pursuant to section 474 of the Code of Civil

as

Proce{ure, sues these defendants by such fictitious nalnes. Defendants DOES I through l0 are

responsible in some rnaltner for the activities alleged herein and each was acting as an agent for the

others. Plaintiff witl arnencl this Complaint to add the true names of DOES I tlrough l0 once they

are ascertained,

3.

At all times herejn urentioned, Califomia Governnrent Code ("Cocle") $ 12940 et

seq., the Fair Employment and Housing Act

binding on Defendants.

("FEHA"), was in full force and effect and was

r0

4IRST CAU$E OF AqIION AGAINST DF.FENDANTS

ll

FOR \MRONGJUL TERMINATION

4.

T2
13

Plaintiffincorporates by reference and re-alleges as if fully stated herein the

material allegations set out above in the preceding paragraphs-

5.

l4

At all times relevant, Plaintiffwas an employee of Defendants. Her position was


well

as other duties, such as acting as a

iiaison with

l5

primarily translating contsnt into Spanish,

16

law enforcement officers of Spanish speaking countries' governments and providing customer

t7

service.

t8

6.

as

Prior to 2012,Plaintiff worked as an ernployee irr the Washington headquarters.

19

I{orvever, in about 20t2 shedecided to undergo gendertransition, and to do so, she needed to

20

move to Los Angeles where her cloctors r.vere locatecl arrcl she could also recover frorn the surgical

21

procedures while still working. Defendants accommodated her request to relocate and allowed lter

22

to work fi-om home due to the gender transition issues, as well as related disabilities including

23

depression and other socialization issues.

24

However, as a condition of moving to Los Angeles, Deferrdants required that

25

Plaintiff be classified as an "independsnt conttactor" aithough slre was still perfonning the same

26

duties as when she lvas classified as an "enrployee." The title "independent contractor" is

27

irrelevant as Ptairtff was absolutely an employee under the law and she was tnis-classif,red as an

28
Case No.

COMPLAINT

EXHIBIT A
3

Case 2:16-cv-03595 Document 1-1 Filed 05/24/16 Page 5 of 13 Page ID #:9

met'

independent contractor from 2012-2016. Every element of the control test is

performing service in whicli the Defendants were engaged; Her work was a part of the regular

busiress of Defedants; She maintained the same position fbr many years and was paid on au

hourly basis (as opposecl to being paid for a specif,rc project); and most imporlantly the Defendants

maintained close control ancl direction over Plaintiffs q'ork.

8.

She was

The classification as "independent contractor" was hannful to Plaintiff because she

lost her-employee benefits, including healtii benefits, and she was also not paid overtime wages for

the hours she worked overlime.

9.

Plaitiff continued working frorn

horne in Los Angeles. However, she began

10

complaining to humap resources about their unfair business practices of utilizing peopie who were

11

interested in their products to provide translation services for free. She complained that thess

12

unpaid translators, often very young minors, were being exploited and lured to work for

t3

Defendants based on faise promises made by her supervisor, Torsten Zabka. lndeed, they would

14

work hours upon hours based on promises that their work could lead to a paid position, but in the

l5

end Torsten Zabka invariably found excusos to renege on his

16

exploited minors and complained to Human Resources about this issue, and other complaints

17

involving Torsten Zabka creating a hostile work environtnent and mistreating ernployees.

18

10.

promises. Plaintiff felt bad for the

Then, within days afler a written complaint about the hostile work environment,

19

(whc complainls were never addressed by hmtan resources), on or about January 15,2016,

20

Plaitiff was termiriated without any valid basis. The stated reason for the termination was tllat

21

Plaintiffs job was beiug relocated to Washington. Howevet', when Plaintiff offered to relocate

22

back to Wastrington, Defendant refused. Thc stated Teason for tennination was pretextual and on

23

information and belief, there was never any actual iutent to relocate the job to Washingtorr.

24

The real reason for tennination was that Plaintiff was con:plairiing about the hostile

25

work environnrent and illegal busiuess practices as stated above. Moreover, Plaintiff vvas

26

tenninated due to her trans-gelrder status, While Defendants accommodated her at first, her direct

27

supervisor, Torsten Zabka,refen'ed to her in a derogatory fashion. He refemecl to Plaintiff as "it" -

28
Case No,

COMPLAINT

EXHIBIT A
4

Case 2:16-cv-03595 Document 1-1 Filed 05/24/16 Page 6 of 13 Page ID #:10

which is highly offensive to a trans-gender person. The term "it" dehumanizes transgender persons

and the usage of such a term by Torsten Zabka shows that he was biased against her and shorvs

that her trausgender status was another reason he decided to terminate her. The real reasols for

ter:nination are unlawful.

lZ.

As a direct and proximate result of tlie afcresaid acts of Defendants, Plaintiff has

will continue to suffer actual, cotlsequential

and inciclental financial losses, including

suffered arrd

without limitation, loss of salary and benefits, all n an imount subject to proof at the tirne of trial.

Plaintiff clairns such amount as damages together with prejudgment interest pursuant to Civil Code

$ 3287 and any other provision of law provicling for ptejudgment interest'

l0

13.

lt

suffered and

t2

embarrassment, depression, stress, anxiety, fear and mental pain and anguish, all to

l3

damage in an amount to be proven at time of trial.

14

14.

As a direct and proximate result of said wrongful acts by Defendants, Plaintiff has

will continue to suffer Post Traumatic

Stress Disorder, humiliation, shame, despair,

Plaintiff

As a direct and proximate result of said wrongful acts by Defendants, Plaintiff has

t5

incurred attorneys' fees in an amount to be determined, for which Plaintiff claims a sum to be

16

established according to proof.

l7

15.

The above recited actions of Defendants were done with malice, fraud andior

l8

oppression and in reckless disregard of the rights of Plaintiff under the Fair Ernployrnent and

l9

Housing Act, Defendants'conduct was despicable and justifies an award of punitive datnages in an

20

amount sufficient to deter them from errgaging iu such conduct again in the future, irl an arnouut

2t

according to proof at time of trial.

22

16.

OnQ3/3012016, Plaintiff filed a cornplaint with the State of Califomia, Department

23

of Far Ernployrnent and Housing. On that same day, DEFH closed Plaintiff

24

allorv Plaintiff to pursue her action in court and issued a Rigt-to-Sue letter.
SEC OI\ID CA USE

25

ACTION AGAINST

EFEN DANTS

FOR DISABI-L.ITY / GENDER IDENTITY DISCRIMINATION

26
27

-O-F'

in order to

s case

17

Plaintiff incorporates all prior allegations

as

if fully

set forth herein.

28
Case No

4
COMPLAINT

EXHIBIT A
5

Case 2:16-cv-03595 Document 1-1 Filed 05/24/16 Page 7 of 13 Page ID #:11

18.

At all times relevant, Plaintiff had

disability, to wit, depression and a-social

issues including Asperger's Syndrome. Defendants knew about these disabilities and

accomrrodated them in 2012 rvhen they allowed Plaintiff to move to Los Angeles and work from

home, (The

ancl interactiori

also r.vith avoiding practical clifficulties of havirig to work in an office with people while

recoverirrg from surgcal proceclures.)

issue with r.vorking in the office as opposed to horne has to do with the socialization

1g.

with people, which is extremely difficult for Plaintiff due to these disabilities and

Plaintiff was able to perfbnn her job ciuties with the reasonable accomrnodation of

I
I

working from home.

10

20.

Defendants t'ailed to provide the reasot:able accommodation based on the stated

11

reason for termination, to wit, that Plaintiff was being fired because they required her to work in

t2

the office in Washington. V/hen Plaintiff agreed to do this in order to save her job, despite her

r3

disabilities, Defendants flat out refused and said "'We ate not interested in moving you back to a

t4

full tirne position at Valve."

l5
t6
t7

Zl..
ZZ.

20
21

Defendants' failure to provide

a reasonable

accomnrodation to Plaintiff was a

substantial factor in causing her hann.

THIRD CAU..$E OF ACTION AAINST DEFEI\iDANTS

18
19

Defndats terminated Plaintiffdue to her disability / transgender status,

AoR FAILURE To AC,9MM-0DAT-P / ENGAGE IN THP INTE"RT{CT-IVE PROCESS


23, Plaintiff incorporates all prior allegations as if fully set forth herein.

24.

The interactive process required by the FEHA is an irfonlal process with the

22

ernployee to attempt to iclentify a reasonable accolnmodatiorr that

23

perfonn the j ob effecti vely.

24

25.

will enable the employee to

As stated above, Defendants failed and resed to accommodate Plaintiffs

25

disabilities and failed arrd refused to errgage in an interactive process to reasonably identify a way

26

to accommoclate. For exanrple, if (which is not the case) Defendarrts truly had a valid reason to

27

require Plaintiff to work in the oftce with the other ernployees, a reasonable accommodation

28
Case No,

COMPLAINT

EXHIBIT A
6

Case 2:16-cv-03595 Document 1-1 Filed 05/24/16 Page 8 of 13 Page ID #:12

might have been to give her a private office. But no such discussion was evetl engaged in because,

rashington to work, Defendant


although Plaintiff expressed a willingness to relocate back to

flatly refused her offer and refi'sed to discuss it further'

4
5

26.

Defclants' failure to provide a reasonablc ccommodation and failure to engage in

the interactive process was a substantial factor in causing Plaintiff harm.

FOUR,TH CAUSE OF'ACTION AAINST DEFENDANT

FOR HOSTILE WORI{ ENVIF.ONMpNT

l0
l1
1,2

13
T4

i5
t6

.
28.
Zg,

2"1

Plaintiff incorporates all prior allegations

as

if f'ully set forth

herein.

Plaintiff was subject to unwanted harassment because she is transgender.


Fufiher, her supervisor created a hostile work environtnent by sowing discord

among the employees. Plaintiff reported this conduct to human resources.

30.

A reasonable person in her circumstances would have considered the work

environment to be hostile or abusive.

31,

A supervisor engaged in the conduct, and Plaintiff reported the conduct to humart

resources who failed to take immediate and appropriate corrective action.

32.

Defeudants' conduct was a substantial factor in causing Plaintiffharm.

T7

FIF'TII CAIJSE OE ACTION AG.INST DEFETTDANTS

18

FOB.RETALIA.TION

19

20
21

22
23

24

33.
34.

PlaintifTincorporates all prior allegations as if fully set forth herein.

Plaintiff engaged in protectecl activjty by complaining about the hostile ivork

environment created by her supervisor.

35.
36.

Defendants discliarged her as a direct and proximate result.


Defendants' failure to provide a reasonable accommodation and failure to engage in

the interactive process was a substantial factor in causing Plaintiff hann'

25

STXTH CAUqE OF ATION,GAINST DE.FENDANTS

26

npR UNPAID WAGE$ (OVERTII\{S)

27

37

Plaintiff incorporates all prior allegations

as

if fully

set

forth herein.

28
Case No.

6
COMPLATNT

EXHIBIT A
7

Case 2:16-cv-03595 Document 1-1 Filed 05/24/16 Page 9 of 13 Page ID #:13

38.

Eight hours of labor constitutes a day's work, and any work in excess of 8 hours in I

workday and any work in excess of 40 hours in any one worklveek shall be compensated at the rate

of o less than one and one half times the regular rate of pay for an employee. Any work in excess

o1'12 hours in one day shaltbe cornpensated at the rate of no less than trvice the regular rate of pay

for an ernployee. (Labor code $ 510 and

39.

lwc

wage or<lerNo. 4-2001 $ 3(A).)

During all tirnes relevant to this action, Plaintiffworked more than

hours per

.1

workday, arrcl/or rnore than 40 hours per workrveek, in an amount to be proven at ttial, but clid not

receive any overtirne wages for overtjnre hours suffered or permitted to work.

40.

Plaintiff is informed and believes and based thereon alleges that she was not exempt

10

from overtime uncler any applicable exemption, and, thelefbre, she was and is entitled to overtime

11

compensation.

t2

41.

Based on the misconduct alleged in this Complaint, Plaintiff seeks to recover

t3

unpaid overtime compensation, penalties, interest, reasonable attorneys' fees, and costs in an

t4

amount to be detennined at trial.

15

t6

l7

42,
willfully failed

43.

Plaintiff is infonned and believes and based thereon alleges that Defendants
to pay Plaintiff accrued wages and other compensation due to upon termination'

Plaintiff is informed and believes and based thereon alleges that Defendants are

t8

liabte for statutory and civil waiting time penalties of up to 30 days of pay pursuant to Labor Code

19

$ 203 and other applicable laws and regulations.

20

2l

44.

Based on the rnisconcluct alleged in this Cotnplaint, Plaintiff seeks compensation

for oveftime and waiting tirne penalties and other remedies ir arr anrouut to be proven at trial.

SEVENTH CAUSE OF ACTION AGAINST DEFENDANT$.

22

FOR BIJ.S. & PRgF. CODE

23

24
25

26
27

45.
46.

Plairitiff irrcoryorates all prior allegations

as

1720q)

if fully

set forth herein.

Deferrdants, and each of them, are "persons" as defned under Business and

Professions Code $ 17021.

4'?.

Plaintiff is informed and l:elieve and

basecl thereon allege that Defendants

28
Case No,

7
COMPLAINT

EXHIBIT A
8

Case 2:16-cv-03595 Document 1-1 Filed 05/24/16 Page 10 of 13 Page ID #:14

committed the unfair business practices, as defined by Cal. Bus. & Prof' Code $ 17200, et seq., by

violating the laws alleged to have been violated in this Complaint and which allegations are

incorporatecl herein by reference and include, but are not lirnited to the

pay Plaintiff all rvages due and owing including overtime wages,

48.

following: a' Failing to

As a rssult of the above-allegecl misconduct, Plaintiff has been deprived of lar'vful

wages to which she is entitled in an amount to be detenninecl according to proof at trial.

49.

As a direct and proxirnate result of the aforesaid acts and conduct of said

Defendats, Plantiff is entitled to ancl hereby seeks attomeys' fees as permitted by law and

provided by for $ 1021.5 of the califomia code of civil Procedure.

EIGHTH CA

10

50.
51.

t2
13

52.
53.

set forth herein.

Plaintiff is informed and believes that Defendants willfully misclassified Plaintif[

Plaintiff has suffered damages as a result of her misclasslfication as an independent

Plaitiff

has also bcen damaged bsause she is unable to obtain unemployment

54.

Pursuant to Labor Code $ 226.8, Plaintiff is entitlecl to recover penalties and other

rernedies as set forth therein against Defendants.

PRAYTIR FOR RELIEF

2t
22

if fully

benefits and state disability benefits as a clirect and proxirnate result of the misclassification-

l9
20

as

contractor, including increased taxes and insurance'

t7
18

Plaintiff incorporates all prior allegations

and others, as independent contractors.

l5
16

EFENDANTS

FOR MISCLASSIFICATION ABOR,CODE . 226.8

1l

1.4

OF ACTTON GAINST

as

WHEREFORE, Plaintff prays for relief and judgment against Defeudants as follows:

23

A.

For general darnages in accordance with proof, estimated at $1,000,000.00;

24

B,

For puitive and exernplary damages iu an amount found appropriate by the trier of fact in
accordartce rvith proofl

25

26

C.

For special darnages iu accordance r.vith the proof, estimated at $ 1,000,000'00;

27

D.

For unpaid wages

& penalties, estimated

at $150'000'00;

28
Case No.

I
COMPLAINT

EXHIBIT A
9

Case 2:16-cv-03595 Document 1-1 Filed 05/24/16 Page 11 of 13 Page ID #:15

E.

For loss of earnings according to proof, estimated at $1,000,000'00;

F,

For prejudgrnent interest and post-judgment interest in accordance with law;

C.

For costs of suit, including attomey's fees pursuant to statute; and

H.

For such other relief as the Court deems just and proper'

4
5

Dated:

(L [,,

Chad Biggins

PRAYER FOR JUY TRIAL

Plaintiff hereby prays for a jury trial on all issues and causes of action so triable.

10

Dated:

Chacl Biggins

ll
l2
13

t4
l5

l
T7

l8

l9
z0

2l
22
23

24
25
26

27
28
Case No.

COMPLAINT

EXHIBIT A
10

Case 2:16-cv-03595 Document 1-1 Filed 05/24/16 Page 12 of 13 Page ID #:16


ATTORNEY (Nam6, Slal

Bil numbq,

FOR

and add.ess):

COUR USE ONLY

B Ivd 4 l0
310 w
Los Angeles, CA 900 l0
TELPHONE NO,:

2r3-387-3100

Plaintiff

ATTORNEY FOR

couRT oF GALIFoRNA, COUNTv


STRETADDRESS. 1

I N. HiII

BRANCHNAME:

les

LOs

213-387-3101
CONFStrMEB EPY

,.

or lg5 Angeles

cA

ORIGNL FIL

Superior Court of Californa


Cunry of Los Agle8

St.

MAILING ADORESS:

clTY AND ZrP COe'

Fp<No.:

APR

90012

I 3 2016

$herri R. Carier, Exutive Officer/Clsrlr

CASE NAME:

tion

A.M. v Valve

CIVIT CASE COVER SHEET

CASE

Complex Case Deslgn atlon

f7l unltmlteo l--l urit"u


(Amount
(Amount
demanded demanded is

[-

] counter ll

616?66

Joinder
JUDGE:

Filed with frst appearance by defendant


DEPT:
Cal. Rules of Court, rule
$25,000 or
exceeds $25,000
inslructions ort
Items 1-6 below must be
Check one box below for the case type that best describes this case:
Provislonally Complex Cvl Lllgation
Contrct
Auto Tort
(Cal. Rules of Court, rules 3.400-3'403)
Breach of contraVwananty (06)

D
E

l-_l

Auto (22)

Uninsured motorist (46)

Other PI/PDMID {Porsonal lnjuryiProperty


Death) Tort

otn.,

Pr/PD/vvD (23)

Non-PUPDM/D (other)

ort

Business lorUunfair business practice (07)

l--l

lntellectual propertY (19)


Profession al negligence (25)

Other real property (26)

cor.rtdal(31)

f*-l
[--l

Em

0)

I-l

lnarrrnae coverage claims arising from he


above listed provibionally complex case
types (41)

Enforcement ol Judgment

l--l

Enfor."renr of judgment (20)

Residential(32)

Mlscellaneous Civil ComPlaint


nrco (zz)

orugs (3s)

l-l

Of'trr complaint (nof sp ecilied

above)

(42)

Miscellaneous Civl Petltlon

Rsset torfeiture (05)

P"tition re: arbitration award (11)

E
l-l

Prrtn"rrhip and corporate governance

(21 )

Oth*t p"tition lnot specified above) (43)

Writ of mandate (02)

Wrongfu | termination (36)

ciaf review

(1

is not

complex under rule 3.400 of the california Rules of court. lf the case is complex, mark the

factors requiring exceptional judicial management;


Large number of separately represented parties d.
u.
Extensve motion practice raising diffcult or novel e.
b.
issues that will be time-consuming to resolve

[-l
[-]

c.

(1

Securities litigation (28)


Environmenlal/Toxic tort (30)

condemnatlon (14)
Wrongful eviction (33)

Judicaf Review

Other non-Pl/PDMVD tort (35)

ts

tl
f--l
fJ

Defarnation {13)
Fraud (16)

2. This case

Construction defect
Mass lort (40)

Unlawful Detalnr

Civil rights (08)

Other

Olher collections (09)

Ral Property
Erninent domaitflnverse

Medical malprctice (45)

l-l

AntitrusUTrade regulation (03)

In$urance coverage (18)


Other contract (37)

Asbestos (04)
Product liablllty (24)

Rule 3.740 collections (09)

Substantial arnount of documentary

evidence f

Large number of wtnesses


Coordination wth related actions pending in one or more coutls
in other cgunties, states, or countries, or in a federal court
Substantal postjudgment judicial supewision

monetary b. l--l nonmonetary; declaratory or injunctive relief


3. Remedies sought (check allthat apply): a
4. Number of causes of action (specify): 7
S
is not a class action suit
5. This case
6. lf there are ay known related cases, file and serve a notice of related case. (You may use form CM'015')

c.

l-Zlpunitive

Date: 4l7l16

Chad B

ins

RE

plaintiff must file this cover sheet with the flrst paper fted in the action or proceeding (exc_ept small claims cases or cases flled
to file may result
under the probate Code, Famity Code, or Weliari: and lnstitutions Code). (Cal. Rules of Court, rule 3.220.) Failure
in sanctions.
fil ttrs cover sheet in addition to ny cover sheet required by local court rulecover sheet on all
lf this case is complex under rule 3.O et seq. of the balifornia Rules of Court, you must serve a copy of this
other parties to the action or proceeding.
purposes onl
Unless this is a collections cse under iule 3.740 or a complex case, this cover sheet will be used for statistical

Form Adopled lor Mandalory Use


Judicil Council of Calif omi
CM410 {Rev. Juty l, 20071

CIVIL CASE COVER SHEET

2.30, 3.220. 3.40S-3,403, 3.740i


Stndrds of Judldl Admlnslrtion, std. 3'.l0

C|. Rules of
C1,

rwtw.codllnlo,cagov

EXHIBIT A
11

Case 2:16-cv-03595 Document 1-1 Filed 05/24/16 Page 13 of 13 Page ID #:17

Eotta

SUPERTOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES


NOTICG OF CASE ASSGNMENT. UNLIM|TEb CryIL CASE
IXOrV-CLAS NCTION)
Case Numbcr

Your case is assigned ro.

",

ASSIGNEDJUDCE

side of this form.

DEPT

ROOM

Hon, Kevin C, Brazite

,SSIGNED JUDGE

534

Hon. Elizbeth AIIen tVhits

DIPT
48

506

49

s09

Hon. Brber A. Meiers

12

636

Hon, Deirdre

Hon. Terry A. Green

t4

300

Hon. Teresa A, Berudet

50

508

Hon. Richard Fruin

t5

307

Hon. Micbel J. Rrphael

5l

stl

Hon, Rita Mlller

l6

306

Hon. Susan Bryant-Derson

52

5t0

Hon. Richard E. Rico

t?

309

Hon. Steven J. Klcifiold

53

5t3

Hon. Slcpharie Bowick

t9

311

Hon. Ernest M, Hiroshige

54

512

Hon. Dalll Corrol Lyons

20

31

Hon. Malcolm H, Mrckoy

55

5r5

Hon. Robert L, Hess

24

314

Hon. Michcl Johnson

56

5r4

Hon, Yvette M. Plazuclos

28

318

Hou, John P. Doyle

58

5t6

IIo. Barbar Schcper

30

400

Hon. Gregory Keosisn

6r

732

Hon. Ssmnth Jessner

3l

407

Hoo. Michael I,, Stcrn

62

600

32

406

Hon. Msrk Mooney

6E

6t1

4oB

Hon. Wllllam F. Fahey

69

621

/Hon.

Dnicl S. Murphy

Hon. Mlchael P. Linfield

(tr4 Y

Hill

Hon. Gregory Alarcon

36

410

Hon. SuznneG. Brugueru

7t

729

Hon, lltrc Mrrmaro

37

413

Ho. Ruth Ann Kwsn

72

73t

Hon, Msureen Duffy-Lewis

3E

4r7

Hon. Rfael Ongkeko

73

7J3

Hon. Elizabctl Fefter

39

4r5

Hon, Teres Snchez.Gordon

74

735

Hon. Michelle R. Rosenbltt

40

414

Hon. Gil Rudernan Feuer

78

7fi

Hon. Holly E, Kendig

42

416

Hon. lHel Red Recaor

45

s29

32{

ccw

Hon, Frederlck C. Shller

46

500

r#eintraub

47

507

324

ccw

Hon. Dbre

768

Hon. Emile H. Eliss


rProvlsionally Complex
Non-elssc Action Cases
Asignment ls Pending
Complcx Determlntion

*Cgmnlor

All no-class ction

cases derignated rs provisionally compler are forwarded


to the Supervising Judge of the Complex Ligrtion Program
locted in the Centrrl Clvil \esf Courthouse (600 S,
Commonwelth Ave., Los A ngelcs 90005), for complex/non-omplex
determination
pursuant to Locl Rule 3.3(k). This proceduro is for
thr purpose of assessing whether or not the cese is complex within thc
mcrning of
Californl Rules of Court, rule 3.400. Depen ding on the
outcome of tht sescment, the case may be reasrigned to one
of the Judges ofthe
Complex Litigation Program or reasslgned randomly
to a court in the Central District.

Given to tbe PlaintifVCross-ComptainenlAttorney of


Record on

APRi-ffi]t_
LACIV CCH 190 (Rev.0?16)
LASC Approvcd 0S,06

SHERNT R. CA
By

. NOTICE OF CASE ASSIGNMENT.


UNLIITJIITED CIVIL CASE

Oflicer/Clerk
Deputy Clerk
Page I ofZ

EXHIBIT A
12