Professional Documents
Culture Documents
EXHIBIT 145
SUMMONS .
(CITAC/ON JUDICIAL)
CONFORMED COPY
ORIGINAL m..ED
s~Co'ort OICal!fornl
r.ountf or
NOTICE TO DEFENDANT:
(AV/SO AL DEMANDADO):
NATIONAL ASSOCIATION OF FORENSIC COUNSELORS, INC., Nevada Corporation; NATIONAL
ASSOCIATION OF FORENSIC COUNSELORS; AMERICAN ACADEMY OF CERTIFIED FORENSIC
COUNSELORS, INC. dba AMERICAN COLLOOE OF CERTIFIED FORENSIC COUNSELORS, a Nevada
Corporation; KARLA DEISLER TAYLOR; FRANCIS DEISLER, aka FRANK JOHN PALANI; and DOES I JO
Loo"""'..
OCT 06 2014
BCS59767
3.
CJ
on behalf of (specify):
under:
4.
Fonn Adopted for Mandaloly Use
Judiclal Coundl of California
SUM-100 (Rev. July 1, 2009)
D
D
D
D
D
other (specify):
by personal delivery on (date):
Pa
SUMMONS
1Of1
6:14-cv-00187-RAW
Document
Filed inCOUNTY
ED/OK on
Page 3 of 25
SUPERIOR
COURT 480-17
OF CALIFORNIA,
OF 11/13/14
LOS ANGELES
NOTICE OF CASE ASSIGNMENT - CLASS ACTION CASES
Case Number~~~~~~~~~~~~~~~
THIS .FORM IS TO BE SERVED WITH THE SUMMONS AND COMPLJ\ INT
Your case is as~~ncd for ullpu_!l!.oscs to tbcj udicl11I officer indicated below_iLocnl Rule 3.Jlc .
ASSIGNED JUDGE
DEPT
ROOM
310
1412
308
141 5
307
1402
SC 6 5 9 7 6 7
OTHER
Instructions for handling Class Action Civil Cases
The following critical provisions of the Chapter Three Rules, as applicable in the Central District, are summarized for your assistance.
APPLICATION
The Chapter Three Rules were effective January I, 1994. They apply to all general ci''.{il cases.
!!_RIORITY OVER OTHER RULES
The Chapter Three Rules shall have priority over all other Local Rules to the extent the others are inconsistent.
TIME STANDARDS
Cases assigned to the Individual Calendaring Court will be subject to processing under the following time standards:
COMPLAINTS: All complaints shall be served within 60 days of filing and proof of service shall be filed within 90 days of filing.
CROSS~COMPLAINTS: Without leave of court first being obtained, no cross-complaint may be filed by any party after their answer is
filed. Cross-complaints shall be served within 30 days of the filing date and a proof of service filed within 60 days of the filing date.
A Status Conference will be scheduled by the assigned Independent Calendar Judge no later than 270 days after the filing of the compl11int.
Counsel must be fully prepared to discuss the following issues: alternative dispute resolution, bifurcation, settlement, trial date, and expert
witnesses.
time standards or deadlines established by the Court or by the Chapter Three Rules. Such sanctions may be on a party or if appropriate on
counsel for the party.
This is not a complete delineation of the Chapter Three Rules, and adherence only to the above provisions is therefore not a guarantee against the imposition of
snnctions under Trial Court Delay Reduction. Careful rending and compliance with the actual Chapter Rules is absolutely imperative.
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0_6_Z_O_l_
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Telephone:
(213) 613-4655
Facsimile:
(213) 613-4656
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persons,
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Plaintiff,
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vs.
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C1
f)
LI"
t.~
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NATIONAL ASSOCJATION OF
FORENSIC COUNSELORS, INC., a
Nevada Corporation; NATIONAL
ASSOCIATION OF FORENSIC
COUNSELORS; AMERICAN
ACADEMY OF CERTIFIED
FORENSIC COUNSELORS, INC. dba
AMERICAN COLLEGE OF
CERTIFIED FORENSIC
COUNSELORS, a Nevada CorporationKARLA DEISLER TAYLOR;
FRANCIS DEISLER, aka FRANK
JOHN PALANI; and DOES 1-10
Case No.
8C559767
COMPLAINT FOR:
(l) CONSUMER FRAUD AND UNFAIR
COMPETITION, CAL. BUS. & PROF.
CODE 17200 et seq.
(2) FRAUDULENT AND FALSE
ADVERTISING, CAL. BUS. & PROF.
CODE 17500 and
(3)FRAUD
Defendants.
25
26
~ 27
~~
28
COMPLAINT
Plaintiff Clark Carr ("Plaintiff'), on behalf of himself and all similarly situated
2
persons in the state of California ("Class," and defined more fully at paragraph 26),
alleges as follows:
4
5
alcohol and drug counselors in exchange for membership and renewal fees.
California alcohol and other drug counselors ("AOD") that Defendants' certifications
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12
Department of Alcohol and Drug Programs (and its successor, the Department of
13
Health Care Services) may register and certify AOD counselors in California. The
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Since April 1,
California.
3.
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is a certifying organization incorporated under the laws of the state of Nevada which
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25
continuously transacting business in the state of California by, among other things,
26
27
for membership fees and annual dues. NAFC has never registered with the Secretary
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1
COMPLAINT
4.
profit corporation which is the certification commission of the NAFC. ACCFC receives
all of the income and pays all of the expenses for NAFC. According to the Defendants,
review requirements for NAFC certifications. ACCFC has never registered with the
5.
Executive Officer of NAFC and, on information and belief, the majority owner of
I0
NAFC.
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13
6.
She is a resident of Indiana, but for at least 10 years she has been doing
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Deisler, aka Frank John Palani, manages, directs, supervises and controls NAFC and
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ACCFC with Taylor. The Defendants are the agents, partners and co-venturers with
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each other to such an extent that it would be a fraud on the court to treat them as
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18
"Defendants."
ALLEGATIONS OF FACT
19
20
7.
Up until the time Plaintiff began investigating the grounds for this
21
lawsuit, Plaintiff assumed that NAFC, its founder, and officers were legitimate and
22
trustworthy. However, only in the last several weeks did Plaintiff, through diligent
23
research, learn that NAFC was a fraudulent enterprise from its very beginning, and was
24
brought into being by a violent, convicted felon who repeatedly tried to conceal his past
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26
8.
27
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President, with Deisler noted in the corporate records as a member of its board. Yet
that these confusing and interlocking for-profit and non-profit corporations, with
overlapping directors and officers, are all the same entity, doing business as National
10
9.
11
NAFC and ACCFC. Taylor and Deisler receive salaries, benefits, and other monetary
12
payments directly or indirectly through NAFC and ACCFC as a result of the fraudulent
13
and unlawful collection from Plaintiff and the Class of certification fees.
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15
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access"
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18
19
10.
to
''NAFC
curriculum
approved
certification
Deisler
training."
20
fraudulent enterprise, providing certifications for drug and alcohol counselors without
21
appropriate and required authorization from state agencies, and fraudulently and
22
intentionally concealing its lack of authority and government recognition from its
23
members/customers.
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11.
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unlawful, fraudulent, deceptive and misleading conduct is part of a pattern and practice
26
27
28
12.
The NAFC letterhead has these three words immediately below the phone
none of those qualities in connection with their dealings with the general public or the
Class. Although NAFC's own rules provide that "advertising is acceptable as long as
such advertisements are accurate and provide information necessary for potential
necessary for their clients to make informed decisions about whether to affiliate with
NAFC. In addition to concealing from the Class that the Department of Alcohol and
Drug Programs never approved NAFC to register and certify AOD counselors in the
state of California, the Defendants concealed from the Class the Defendants' criminal
10
history and lack of honesty, competency and integrity. Such concealment included:
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two female minors. Deisler was charged with armed bank robbery,
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stalking, and rape. One of the victims was 14 years old. In November of
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Deisler escaped from a prison hospital. Local media noted, "Deisler has
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His recent sentence which took place last November was for armed
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and Sheboygan. His record of arrests date back to 1956, and he reportedly
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has served terms at the Attica and Sing Sing prisons in New York State."
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25
26
27
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Deisler received a
he cited the time he spent in his own Life Skills Counseling Center in
juvenile detention center under the auspices of the Life Skills Counseling
reports of abuse. There were charges that boys were beaten, not fed
10
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12
remove seven boys from the facility as the detention method endangered
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the boys.
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13.
15
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In or about November of 1996, Deister began soliciting persons working in the field of
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Counselor (CCDC) certificate that Deister and Taylor had created. Several months
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later, in March of 1997, Deister claimed that the NAFC had 20,000 members
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nationwide.
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14.
Deister and Taylor were married in 1997, and went forward in the
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dissolving several corporations in Indiana and Nevada using the name National
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25
Inc., both as for-profit and not for-profit entities. They used the same pattern of filing,
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dissolving and refiling for the National Board of Addiction Examiners, which allegedly
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5
COMPLAINT
15.
noted by one judge in Indiana, Deisler had such an extensive criminal record that he
16.
Deisler to be recognized to certify drug and alcohol counselors. Most importantly, they
falsely stated that NAFC certificates were recognized by the state of California.
17.
NAFC began issuing, and continues to issue, certificates to California AOD counselors
l0
11
12
NAFC, Taylor, and Deisler caused representations to be made to Plaintiff and the Class
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15
represented that the NAFC certifications are "nationally accredited" and "nationally
16
17
18
programs as meeting NCCA standards only. The NCCA rules for use of its name allow
19
an accredited program to state that "NCCA reviewed the program and found at the time
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of the review that the program met the NCCA accreditation standards. The accredited
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program may also point out that it submits annual reports to NCCA and must undergo
22
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NCCA accreditation must be accurate and truthful." Defendants intentionally used the
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NCCA name in a misleading manner and omitted from its advertising that the only
25
"national recognition" which NAFC actually received was that the program met the
26
standards of the NCCA. Defendants intentionally omitted from their advertising and
27
other statements to the Class that NAFC is not recognized by any national
28
governmental body, that several states have specifically declined to recognize its AOD
Defendants falsely
6
COMPLAINT
approved before the certifying organization could lawfully register and certify AOD
counselors, and that NAFC had not been approved. Defendants' representations and
advertising were false, deceptive, and likely to mislead. California never authorized,
19.
2005, the State approved ten organizations to register and certify AOD counselors.
NAFC was never one of the approved organizations. (See 13005 listing the approved
10
certifying organizations, attached as Exhibit 1). At this time, Deisler was President of
11
12
and/or material omissions about NAFC's inability to register and certify AOD
13
counselors in California. Plaintiff is informed and believes and thereon alleges that
14
Defendants knew at all material times that NAFC was not approved by the relevant
15
state agency and that NAFC was acting in violation of 13035, and that Defendants
16
made a conscious and deliberate decision not to obtain approval, not to comply with the
17
regulations, and to affirmatively conceal both the regulations and their non-compliance
18
from Plaintiff and the Class. Plaintiff justifiably relied on Defendants to inform them
19
of the standards for certification in the state of California because, inter alia, Defendant
20
ACCFC, acting in concert with the other Defendants, developed and promoted its
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20.
Since 2004, Defendants have falsely advertised on the NAFC website and
23
in other publications that (a) "the certified practitioner from the NAFC and ACCFC
24
qualifies as an expert witness under the Federal Rules of Evidence"; and (b) that
25
membership benefits include "national credential & recognition." (See copy of web
26
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certifications would understand this representation to mean that the "national credential
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and recognition" means that the certifications are recognized as valid throughout the
7
COMPLAINT
entire United States and in each of the United States. Defendants concealed in their
California and that the NAFC certificates are unapproved, improper, and misleading to
attempts to force other states -- such as Pennsylvania and Ohio -- to recognize their
AOD certifications through litigation. Plaintiff is informed and believes and thereon
alleges that NAFC certificates do not qualify the holder of the certificate as an expert
21.
1O
statements and omissions, Plaintiff and the Class paid to defendants $90 per year for
11
membership fees and renewals from 2002 to 2011. Plaintiff discovered the true facts in
12
2012 and ceased making payments to Defendants for their worthless certificates. On
13
information and belief, hundreds of other persons in the state of California paid
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22.
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certification would permit the possessor to lawfully perform drug and alcohol
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23.
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24.
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CLASS ALLEGATIONS
26.
brings this action on behalf of himself and a class of persons defined as: all persons
8
COMPLAINT
who paid membership and/or renewal fees to Defendants in the four years prior to the
filing of this Complaint ("Class"). This includes but is not limited to all California
Specialist, and/or Baccalaureate Addictions counselor. Excluded from the class are
and the immediate families of counsel, who represent Plaintiff in this action; (c) the
10 judge presiding over this action; and (d) jurors who are impaneled to render a verdict on
11
12
13
that there are, upon information and belief, hundreds of persons who fit within the
14
Class definition.
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28.
Common questions of fact and law exist as to all members of the Class,
16
and these questions predominate over questions affecting only individual Class
17
members. The common questions include, but are not limited to:
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(a)
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20
(b)
21
(c)
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( d)
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25
26
27
28
Whether Plaintiff and the class members are entitled to a refund of the
money paid for membership and renewal fees ; and
(g)
29.
Plaintiff, like all Class members, paid money to Defendants for membership and
30.
members.
handling class actions. Neither Plaintiff, nor his counsel, has any interests which
31 .
Plaintiff will fairly and adequately protect the interest of other class
Plaintiffs counsel has more than 30 years of combined experience m
Certifying this case as a class action is the superior method for the fair
and efficient adjudication of this controversy. The injury sustained by Plaintiff and
10
11
impractical.
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13
14
15
16
32.
through 31, inclusive, as though they were set forth here in full.
33.
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19
20
21
CCR 13035(a);
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23
24
counselors in California;
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26
27
28
5
6
10
11
i.
12
13
34.
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CCDC certification from Plaintiff and the Class, although they knew that the
15
statements above were false and that the certification was unapproved, unlawful and
16
worthless in California. Plaintiff and Class members are each entitled to restitution of
17
18
35.
19
violated section 17200, and a preliminary and permanent injunction which requires
20
Defendants to (a) cease and desist from issuing certificates to AOD counselors, (b)
21
disclose the names, addresses and telephone numbers of each of its AOD California
22
certificate holders, and (c) inform the AOD certificate holders of his/her rights and
23
responsibilities, that the NAFC certifications are not approved or authorized by law and
24
that they must register with an approved certifying organization within the time limits
25
set forth in CCR, Title 9 Section 13035(d)(l-4) [the section which applies to certifying
26
27
28
11
COMPLAINT
4
5
6
36.
through 35, inclusive, as though they were set forth here in full.
37.
Defendants, with the intent to induce Plaintiff and other Class members,
have made representations regarding the CCDC certification which they knew to be
untrue or misleading.
following:
10
11
state of California;
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13
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15
California;
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17
18
proceedings;
19
20
Recognition;" and
21
22
23
Fraud
24
25
26
38.
through 37, inclusive, as though they were set forth here in full.
39.
Defendants
intentionally
misrepresented
and/or
omitted
material
27
information regarding the approval, sponsorship and certification of goods and services
28
40.
Plaintiff and the class justifiably relied upon Defendants' express and
implied representations, and material omissions, that the NAFC certificates were
5
6
7
41.
Defendants knew that Plaintiff and the Class would be misled by their
9
10
11
Plaintiff as class representative and his counsel as attorneys for the class and subclass
12
defined above;
13
2.
14
California's False Advertising Laws, Cal. Bus. & Prof. Code 17500 et seq., and
15
California's Unfair Competition Law, Business and Professions Code 17200 et seq.
16
3.
17
Plaintiff and the members of the Class, including an order prohibiting Defendants from
18
19
4.
20
and telephone numbers of all putative class members and to disclose their obligations
21
to obtain proper certifications within the time limitations set forth in CCR, Title 9,
22
Section 13035(d);
23
5.
Restitution of all membership and renewal fees during the class period;
24
6.
25
7.
26
of the Defendants;
27
8.
28
9.
All other and further relief which the Court deems just and proper.
13
COMPLAINT
JURY DEMAND
2
3
Plaintiff hereby demands that this matter be set for trial by jury.
6
7
9
10
11
By:
David C. Scheper
Attorneys for Plaintiff ark Carr on his own
behalf and on behalf of a class of similarly
situated persons
12
13
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15
16
17
18
19
20
21
22
23
24
25
26
27
28
14
COMPLAINT
U:r?{: - FIUNG'3
111 tL !-{ILL STF'EET
LO~~; ANr3ELES CA 90012
ttATE PAID: 10/0t-."14
04 ~ 1? Pt1
RECEIPT #: CCW520:37213'i
CIT/CA:::E:
PC5~i9767
LEJ:!/DEF#:
$435.00
310
CA:?H:
:to.oo
CHl4Nr5;.
CAF:O;
tJ.00
:to .oo
CM-0_10
[jTTORN.fY OR PARlY WTHOUT ATTORNEY (NBJr1$, Stele &tr numbef; lllld llddre:sa}:
DAVID C. SCHEPER (State Bar No. 120174) /WJLLIAM H. FORMAN (State Bar No. I50477)
CONFORMED COPY
ORIGINAL PILED
FAXN0.:(213)613-4656
mEPHONENO.:
s--'-Co\ntOfCalllornlr
w~;ittOff.N -~
ANGELES
MAILING ADDRESS:
CASE NAME:
Unlimited
(Amount
demanded
exceeds $25,000)
Limited
(Amount
demanded is
$25,000 or less)
Counter
CASE NUMBER:
BC 5 5 9 7 6 7
Joinder
JUDGE:
DEPT:
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
0
D
D
D
D
D
D
~loyment
LJ
LJ
Drugs (38)
Judlclal Review
Asset forfeiture (05)
Petlllon re: arbitration award (11)
Writ of mandate (02)
Otherjydlclal reviewj39}_
Enforcement of Judgment
Enforcement of judgment (20)
D
D
RIC0(27)
D
0
2. This case
Is
is not
complex under rule 3.400 of the California Rules of Court. If the case is complex, mark the
factors requiring exceptional judicial management:
d.
b.
e.
c.
f.
a.
will
c.
ULJ punitive
4. Number of causes of action (specify):Three: I.) 17200, 2.) 17250, 3.) Fraud
5. This case
Is
is not a class action suit.
6. If there are any known related cases, file and serve a notice of related case. (You ma
Date:
October 6, 2014
David C. Scheper
{TYPE OR PRINT NAME)
NOTICE
Plaintiff must file this cover sheet with the first paper filed in the action or proceeding (except small claims ses or cases filed
under the Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.) Failure to file may result
In sanctions.
File this cover sheet in addition to any cover sheet required by local court rule.
If this case Is complex under rule 3.400 et seq. of the California Rules of Court, you must serve a copy of this cover sheet on all
other parties to the action or proceeding.
Unless this Is a collections case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes onlv.
ffa e 1 of
;~~Y\~;> '.f
ca1.Ru~~~s~~e:,~~~clin~:':~!i:;~
lexlsNexls Automated California Judlciaie;,::';;::
CM-010
To Plaintiffs and Others Filing First Papers. If you are filing a first paper (for example, a complaint) in a civil case, you must
complete and file, along with your first paper, the Civil Case Cover Sheet contained on page 1. This information will be used to compile
statistics about the types and numbers of cases filed. You must complete items 1 through 6 on the sheet. In item 1. you must check
one box for the case type that best describes the case. If the case fits both a general and a more specific type of case listed in item 1,
check the more specific one. If the case has multiple causes of action, check the box that best indicates the primary cause of action.
To assist you in completing the sheet, examples of the cases that belong under each case type in item 1 are provided below. A cover
sheet must be filed only with your initial paper. Failure to file a cover sheet with the first paper filed in a civil case may subject a party,
its counsel, or both to sanctions under rules 2.30 and 3.220 of the California Rules of Court.
To Parties in Rule 3.740 Collections Cases. A "collections case" under rule 3.740 is defined as an action for recovery of money
owed in a sum stated to be certain that is not more than $25,000, exclusive of interest and attorney's fees, arising from a transaction in
which property, services, or money was acquired on credit. A collections case does not include an action seeking the following: (1) tort
damages, (2) punitive damages, (3) recovery of real property, (4) recovery of personal property, or (5) a prejudgment writ of
attachment. The identification of a case as a rule 3.740 collections case on this form means that it will be exempt from the general
time-for-service requirements and case management rules, unless a defendant files a responsive pleading. A rule 3.740 collections
case will be subject to the requirements for service and obtaining a judgment in rule 3.740.
To Parties in Complex Cases. In complex cases only, parties must also use the Civil Case Cover Sheet to designate whether the
case is complex. If a plaintiff believes the case is complex under rule 3.400 of the California Rules of Court, this must be indicated by
completing the appropriate boxes in items 1 and 2. If a plaintiff designates a case as complex. the cover sheet must be served with the
complaint on all parties to the action. A defendant may file and serve no later than the time of its first appearance a joinder in the
plaintiffs designation, a counter-designation that the case is not complex, or, if the plaintiff has made no designation, a designation that
Contract/Warranty Breach-Seller
Plaintiff (not fraud or negligence)
Negligent Breach of Contract/
Warranty
Other Breach of Contract/Warranty
Collections (e.g., money owed, open
book accounts) (09)
Collection Case-Seller Plaintiff
Other Promissory Note/Collections
Case
Insurance Coverage (not provisionally
complex) (18)
Auto Subrogation
Other Coverage
Other Contract (37)
Contractual Fraud
Other Contract Dispute
Real Property
Eminent Domain/Inverse
Condemnation (14)
Wrongful Eviction (33)
Other Real Property (e.g., quiet title) (26)
Writ of Possession of Real Property
Mortgage Foreclosure
Quiet Title
Other Real Property (not eminent
domain, landlord/tenant. or
foreclosure)
Unlawful Detainer
Commercial (31)
Residential (32)
Drugs (38) (if the case involves illegal
drugs, check this item; otherwise,
report as Commercial or Residential)
Judicial Review
Asset Forfeiture (05)
Petition Re: Arbitration Award (11)
Writ of Mandate (02)
Writ-Administrative Mandamus
Writ-Mandamus on Limited Court
Case Matter
Writ-Other Limited Court Case
Review
Other Judicial Review (39)
Review of Health Officer Order
Notice of Appeal-Labor
Commissioner Appeals
Enforcement of Judgment
Enforcement of Judgment (20)
Abstract of Judgment (Out of
County)
Confession of Judgment (nondomestic relations)
Petition/Certification of Entry of
Judgment on Unpaid Taxes
Other Enforcement of Judgment
Case
Miscellaneous Civil Complaint
RICO (27)
Other Complaint (not specified
above) (42)
Declaratory Relief Only
Injunctive Relief Only (n onharassment)
Mechanics Lien
Other Commercial Complaint
Case (non-tort/non-complex)
Other Civil Complaint
(non-tort/non-complex)
Page 2of 2
CASE NUMBER
scs
Item I. Check the types of hearing and fill In the estimated length of hearing expected for this case:
JURY TRIAL?
~ YES
CLASS ACTION?
Oves
7_~D~H~O~U....B~S/-~~D~A-Y~S
Item II. Indicate the correct district and courthouse location (4 steps - If you checked umited Case", skip to Item Ill, Pg. 4):
Step 1 : After first completing the Civil Case Cover Sheet form, find the main Civil Case Cover Sheet heading for your
case in the left margin below, and, to the right In Column A, the Civil Case Cover Sheet case type you selected.
Step 2: Check 2!!! Superior Court type of action In Column B below which best describes the nature of this case.
Step 3:
In Column C, circle the reason for the court location choice that applies to the type of action you have
checked. For any exception to the court location, see Local Rule 2.0.
Applicable Reasons for Choosing Courthouse Location (see Column C below)
1.
2.
3.
4.
5.
Class actions must be liled In the Stanley Mosk Courthouse, cenlral dlstrlcl.
May be flied In central (other county, or no bodUy Injury/property damage).
Location where cause of action arose.
Location where bodily injury, death or damage occurred.
Location where perfonnance required or defendant resides.
6.
7.
8.
9.
1O.
Step 4: Fill in the information requested on page 4 in Item Ill; complete Item IV.
,.
...
..
.. .
'
'
..
.. :..
: ..
Auto(22)
Uninsured Motorist (46)
Asbeslos (04)
e.
:....
TYJ>e of:ACtJon .
..
..
:.Appllcable Reasons
:: ::. "::-8-:~ 'Sl8J> 3Above
1., 2., 4.
1.,2.,4.
2.
2.
a
a
1.. 4.
1.,4.
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fil
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1.,4.
1.,4.
1., 3.
1.,4.
CASE N UMBER
-_ A-.
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- --
--.
Ci'vucase.c6vaJ'.-Sheef - L
,_ ' Category- No . .-_-.-_ _ :,
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- --- _,
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Business Tort (07)
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1., 2., 3.
Fraud (16)
1., 2., 3.
1., 2., 3.
1., 2., 3.
Other (35)
2. ,3.
1., 2., 3.
1., 2.. 3.
10.
2., 5.
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2., 5.
1., 2., 5.
1., 2., 5.
2., 5.. 6.
2., 5.
Eminent Domain/Inverse
Condemnation (14)
2., 6.
2.. 6.
2., 6.
2., 6.
Unlawful Detainer-Commercial
(31)
2., 6.
Unlawful Detainer-Residential
(32)
2. , 6.
2., 6.
2., 6.
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Number of parcels___
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Toxic Tort
Environmental (30)
Enforcement
of Judgment (20)
RICO (27)
Other Complaints
(Not Specified Above) (42)
Partnership Corporation
Governance (21)
Other Petitions
(Not Specified Above)
(43)
2., 9.
2., 6.
2., 9.
2., 8.
2., 8.
2., 8., 9.
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Local Rule
2.0
Page 3 of 4
CASE NUMBER
Item Ill. Statement of Location: Enter the address of the accident, party's residence or place of business, performance, or other
circumstance indicated in Item 11., Step 3 on Page 1, as the proper reason for filing in the court location you selected.
ADDRESS:
STATE:
Los Angeles
CA
ZIP CODE:
90027
Item IV. Declaration of Assignment: I declare under penalty of perjury under the laws of the State of California that the foregoing is true
and correct and that the above-entitled matter is properly filed for assignment to the Stanley Mosk
courthouse in the
_C_e_n_tr_a_I_ _ _ _ _ District of the Superior Court of California, County of Los Angeles [Code Civ. Proc .. 392 et seq., and Local
Rule 2.0, subds. (b}, (c) and (d)).
Dated:
PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY
COMMENCE YOUR NEW COURT CASE:
Civil Case Cover Sheet Addendum and Statement of Location form, LACIV 109, LASC Approved 03-04 (Rev.
03/11 ).
5.
Payment in full of the filing fee, unless fees have been waived.
6.
A signed order appointing the Guardian ad Litem, Judicial Council form CIV-010, if the plaintiff or petitioner is a
minor under 18 years of age will be required by Court in order to issue a summons.
7.
Additional copies of documents to be conformed by the Clerk. Copies of the cover sheet and this addendum
must be served along with the summons and complaint, or other initiating pleading in the case.