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STEVEN H. GARDNER, ESQ. CSBN #70921

2
9595 Wilshire Blvd. #610
Beverly Hills, Cal 90212 FILED
LOS ANGELES STTl'F.RTOR COURT
3 Tel: (310) 246-2300
Fax: (310) 246-2328 OCT 162006
4 Email: sgardner@sgardnerlaw.com lark, E~ecutive Officer/Clerk
5 Attorneys for Plaintiff , Deputy

6 case ass1lned .A"i. L JJ_


7 to Judge fr1AQ...~ I rloYyqOY! flOVS.f..., ~l7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 1)
9 FOR THE COUNTY OF LOS ANGELES

10

11 CIRGADYNE, INCORPORATED, a ) 7. 60'3 '3 7


California Corporation, individually and doing) CASE NO.: 13 C.)
12 business as Liquor License Specialists and )
LLS, )
13 )
Plaintiff, ) COMPLAINT FOR INJUNCTION AND
14 ) DAMAGES
v. )
15 )
JASON FEDERMAN, an individual and doing)
16 business as Liquor License Services, and )
DOES 1 through 100, Inclusive, )
17 )
Defendants. )
18 -------------)
19

20 Plaintiff alleges:

21 FIRST CAUSE OF ACTION

22 SERVICEMARK INFRINGEMENT
23 (Against All Defendants)
24 I. Plaintiff, Cirgadyne Incorporated ("Cirgadyne") , is now, and at all times mentioned

25 in this complaint was, a corporation organized and existing under the laws of the State of California,
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n 26 with its principal place of business in Pacific Palisades, Los Angeles County, California, and does
"
27 business under the fictitious business names of "Liquor License Specialists" and 'LLS".
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28 II
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t) 1

ClRGADYNElFEDERMANIPUCO:MP-1 COMPLAINT
1 2.

Defendant, Jason Fedennan ("Fedennan"), at all times mentioned in this Complaint,

2 was and is an individual doing business as Liquor License Services, with its principal place of

3 business in Duarte, Los Angeles County, California.

4 3. The true names and capacities, whether individual, corporate, associate or otherwise,

5 of Defendants Does I through I 00, inclusive, are unknown to Plaintiff, which therefore sues said

6 Defendants by such fictitious names, and Plaintiff will ask leave of Court to amend this Complaint

7 to show their true names and capacities when the same have been ascertained.

8 4. Plaintiff is infonned and believes, and thereon alleges, that, at all times referenced

9 herein, each Defendant was acting as the authorized agent and/or employee of the other Defendants,

10 and in doing the acts and omissions alleged herein, were acting within the scope of their authority

11 and with the pennission and consent of each other Defendant.

12 5. Plaintiff is infonned and believes, and thereon alleges, that, at all times referenced

13 herein, each Defendant was in some manner proximately responsible for the events and happenings

14 alleged in this Complaint and for Plaintiffs damages.

15 6. Plaintiff is now, and at all times mentioned in this Complaint was, engaged in the

16 business of liquor license consulting, procurement, sales, facilitator and brokerage services

17 ("Services'). Since 1986, Plaintiff has been doing business under the names and marks of "Liquor

18 License Specialists" and "LLS". Since 1986, Plaintiff has consistently identified, adopted,

19 advertised and used the mark "LLS" in advertising and prominently displaying its Services.

20 7. From 1999-2000 and again from 2003-2004, Defendant, Jason Fedennan

21 ("Fedennan"), was a broker/sales employee of an affiliate of Plaintiff and during such employment

22 worked closely with, utilized, and had knowledge of, and access to, Plaintiffs contacts, procedures,

23 and know-how used in connection with the advertising and providing of Services by Plaintiff under

24 the mark and tradename "LLS". During this time of employment Defendant Fedennan had actual

;:
25 notice of Plaintiffs use of the mark "LLS" in connection with the Services.
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u 26 8. On August 16, 2006, Plaintiff filed and published its fictitious business name

27 statement for the mark "LLS".

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2
Law Offib~s
Steven H. Gardner
CIRGADYNEIFEDERMANIPUCO:MP- I COMPLAINT
I 9.

On August 22, 2006, the California Secretary of State issued California Servicemark

2 Registration No. 62470 to Plaintiff covering the use of the mark "LLS" for use in relation to

3 consultant, brokerage and facilitator services in connection with the sale and purchase of liquor

4 licenses. A copy of said Registration is attached hereto as Exhibit A and incorporated herein by this

5 reference.

6 10. On or about September 6, 2006, Plaintiff discovered the use by Defendants of

7 Plaintiffs mark "LLS" on Defendants' website: www.liquorlicenseservices.comin connection with

8 the advertisement of services offered by Defendants which are identical to the Services offered by

9 Plaintiff. Defendant Federman was notified in writing to cease and desist from the use of Plaintiffs

10 mark "LLS" in connection with Defendants' website www.liquorlicenseservices.com and all other

11 uses in connection with services offered by Defendant which are substantially similar or identical to

12 the Services offered by Plaintiff. Notwithstanding Defendant Federman's actual notice of the use by

13 Plaintiff of Plaintiffs mark, in accordance with Business & Professions Code 14242, registration

14 of Plaintiffs mark operates as constructive notice, to Defendants and everyone else, of Plaintiffs

IS claim of ownership of said mark "LLS" used in connection with the Services.

16 II. Defendants, and each of them, have, unlawfully and without Plaintiffs consent,
17 affixed the mark "LLS" in a prominent position on Defendants' website

18 www.liquorlicenseservices.com so as to advertise the mark "LLS" in connection with services

19 offered by Defendants which are identical to the Services offered by Plaintiff. Defendants' use of

20 the mark "LLS" on Defendants' website www.liguorlicenseservices.com to advertise the mark

21 "LLS" in connection with services offered by Defendants which are identical to the Services offered

22 by Plaintiff is unlawful and likely to cause confusion or mistake or to deceive members of the public

23 as to the source of origin of the Services. These actions by Defendants constitute trademark

24 infringement pursuant to Business & Professions Code 14320(a)(l).

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25 12. Plaintiff is informed and believes, and on that basis alleges, that as a direct and
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U 26 proximate result of Defendants and each of their wrongful conduct, use, display and advertising of
27 "LLS" in connection with the providing of services including but not limited to the "procurement or

28 selling ofliquor licenses", the "purchase and sale ofliquor licenses", the tasks of "locating licenses,

Lawoffitbs
3
Steven H. Gardner
CIRGADYNEJFEDERMANIPUCOMPI COMPLAINT
1

negotiations, application preparations, field surveys and public notifications", and "facilitation of
2 your liquor license needs" which are indistinguishable from Plaintiffs Services rendered under
3 Plaintiffs "LLS" mark, Defendants have derived profits in an amount which exceeds the limited
4 jurisdiction of this Court and which amount will be subject to proof at the time of triaL Pursuant to
5 Business & Professions Code 14340(a), Plaintiff is entitled to recover up to three (3) times these
6 profits.
7 SECOND CAUSE OF ACTION
8 COMMON LAW TRADEMARK
9 INFRINGEMENT
10 (Against All Defendants)

11 13. Plaintiff realleges and incorporates herein by reference each and every allegation set
12 forth in Paragraphs 1 through 7, 9, 10, 11, and 12 as though set forth in full hereat.

13 14. Plaintiff has used the servicemark "LLS" since 1986 to identify and distinguish the
14 Services it provides in the liquor license industry from those similar services offered by others, by,
15 among other things, prominently displaying the "LLS" mark in its advertising materials, use of the
16 "LLS" mark in correspondence, and use of the 'LLS" mark in its website.
17 15. As a result of the rendition of Services and advertising by Plaintiff under its 'LL8"
18 mark, the mark has developed and now has a secondary and distinctive trademark meaning to
19 potential buyers and sellers of liquor licenses in California, in that such potential customers have
20 come to associate the mark "LLS" with the Services provided by Plaintiff. As a result of this
21 association, the use of the "LLS" mark by Defendants and each of them is likely to cause confusion
22 or mistake or to deceive the public as to the source of origin ofthe services offered by Defendants
23 which services are identical to the Services offered by Plaintiff.
24 THIRD CAUSE OF ACTION
25 UNFAIR BUSINESS PRACTICES
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Ei 26 (Against All Defendants)


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27 16. Plaintiff realleges and incorporates herein by reference each and every allegation set
28 forth in Paragraphs 1 through 7,9,10, 11, 12, 14 and 15 as though set forth in full hereat.

4
law Offi~~s
Steven H. Gardner
CIRGADYNFJFEDERMANIPUCOMP-I COMPLAINT
1 17.

Defendants, and each of them, have engaged in an unlawful and unfair business

2 practice by utilizing Plaintiff's common law and registered mark "LLS" in connection with the

3 advertisement and offering of services similar to Services offered by Plaintiff in an effort to

4 capitalize on an tradename reference in the small, unique and specialized marketplace of the sale

5 and purchase of liquor licenses. Defendants and each of them have engaged in such unlawful

6 business practices so as gain increased customers and gain profit from this marketplace of liquor

7 license sellers and buyers. This is an unlawful and unfair business practice.

8 18. Defendants and each of them continue to engage in these and other unfair, unlawful

9 andlor fraudulent business practices, and will continue to do so unless the court orders Defendants

10 to cease and desist.

11 19. Defendants and each of their actions significantly threaten or harm competition. A

12 defendant that conducts illegal or unfair activities from which it profits is competing unfairly against

13 its competitors who use lawful means to produce their products and services. Here, Defendants and

14 each of them profit from their violation of laws. Competitors of Defendants who provide similar

15 services to buyers and sellers of liquor licenses in compliance with those laws are at a competitive

16 disadvantage.

17 20. As a direct competitor, Plaintiff has standing to maintain this cause of action.

18 WHEREFORE, Plaintiff demands judgment against Defendants and each of them, for the

19 following:

20 A. ON THE FIRST AND SECOND CAUSES OF ACTION

21 1. A preliminary and permanent injunction enjoining Defendants and each of

22 them from using, displaying, or advertising the mark 'LLS" in California, including but not limited

23 to any internet website, in connection with the offering or rendition of any services in connection

24 with liquor licenses, including but not limited to the (a) procurement or selling ofliquor licenses, (b)

25 the purchase and sale of liquor licenses, (c) the tasks oflocating liquor licenses, negotiations,
"
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u 26 application preparations, field surveys and public notifications thereof, and (d) facilitation of liquor

27 license needs;

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f 5
LawOffi~
Steven H. Gardner
CIRGADYNElFEDERMANIPUCOMP-1 COMPLAINT
1 2.

Damages in an amount to be proved at time of trial;

2 3. All profits realized by Defendants and each of them, to be accounted for by

3 Defendants, from the use, display, or advertisement ofthe mark 'LLS" in California, including but

4 not limited to any internet website, in connection with the offering or rendition of any services in

5 connection with liquor licenses, including but not limited to the (a) procurement or selling ofliquor

6 licenses, (b) the purchase and sale of liquor licenses, (c) the tasks of locating liquor licenses,

7 negotiations, application preparations, field surveys and public notifications thereof, and (d)

8 facilitation of liquor license needs;

9 B. ON THE THIRD CAUSE OF ACTION

10 1. The Court direct restitution of all money and property Defendants and each of

11 them have acquired by means of their acts of unfair competition, to the extent permitted by

12 California law;

13 2. A preliminary and permanent injunction enjoining Defendants and each of

14 them from further acts of unfair competition;

15 c. ON ALL CAUSES OF ACTION

16 1. Costs incurred in this action; and

17 2. Any other and further relief that the Court deems just and proper in the

18 premises.

19 DATED: 16/0/
f I
2006
20

21
STEVEN H. GARDNER
22 Attorneys for Plaintiff
Cirgadyne Incorporated
23

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6
LawOtrk~s
Steven H. Gardner
CIRGADYNEIFEDERMAN/PUCOMP-l COMPLAINT

1 VERIFICATION

2
3 I, Craig Block, declare:
4 That I am an authorized officer of Cirgadyne Incorporated, the Plaintiff in this action; that I
5 have read the foregoing Complaint and know the contents thereof; and that I am informed and
6 believe that the foregoing allegations are true and correct, and on that basis alleges that the matters
7 stated therein are true.
8 I declare under penalty of perjury under the laws of the State of alifomia that the foregoing
9 is true and correct, and that this declaration is executed on ---;;;".,:::.::::::c(ltjfJLL__ 2006, at Los
10 Angeles, California.
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Lavi:Offices
Steven~ti. Gardner
CM.010
ATIORNEY OR PARTY WITHOUT ATTORNEY (Name, Sf number, and address): FOR COURT USE ONLY
hS;~e37en H. Gardner
Law Offices of Steven H. Gardner
9595 Wilshire Blvd. #610
Beverly Hills, CA 90212
TELEPHONE NO.' (31 0 ) 246-2300 FAX NO,; (310 ) 246-2328
FILED
,",OS ANOIlUIS SUPllRlOR COURT
ATTORNEY FOR (Name):

SUPERIOR COURT OF CALIFORNIA, COUNTY OF Los Angeles OCT 16 200S


111 N. Hill Street
STREET ADDRESS:
MAILING ADDRESS: 111 N. Hill Street ohn ~~.E~ecutive Officer/Clerk
CITYANDZIPCODE:Los Anyeles, CA 90012
BRANCH NAME: Centra y t7 D. Garcia ' Deputy
CASE NAME: Cirgadyne v. Federman
CIVIL CASE COVER SHEET CASE NUMBER
lD Unlimited
(Amount
D
Limited
(Amount
Complex Case Designation
o Counter 0Joinder
8C360337
Filed with first appearance by defendant
demanded demanded is JUDGE:
(Cal. Rules of Court, rule 1811)
exceeds $25,000) $25,000 or less) DEPT.:

Items 1-5 below must be completed (see instructions on page 2).

1. Check one box below for the case type that best describes this case:
Auto Tort Contract Provisionally Complex Civil Litigation

8
~o
Auto (22) Breach of contracUwarranty (06) &al. Rules of Court, rules 1800-1812)
Uninsured motorist (46) Collections (09) _ AntitrustITrade regulation (03)
Other PI/PDIWD (Personal Injury/Property Insurance coverage (18) _ Construction defect (10)
DamageIWrongful Death) Tort Other contract (37) _ Mass tort (40)

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Asbestos (04) Real Property _ Securities litigation (28)
Product liability (24) Eminent domain/Inverse _ EnvironmentalfToxic tort (30)
Medicai malpractice (45) condemnation (14) _ Insurance coverage claims arising from the
Other PI/PDIWD (23)
NonPI/PDIWD (Other) Tort
Business torUunfair business practice (07)
B
Wrongtul eviction (33)
Other real property (26)
Unlawful Detainer
above listed provisionally complex case
types (41)
Enforcement of Judgment
o
_ Civil rights (08)
_ Defamation (13)
_ Fraud (16)
_ inteiiectual property (19)

Commercial (31)
Residential (32)
Drugs (38)
Judicial Review B
Enforcement of judgment (20)
Miscellaneous Civil Complaint
RICO (27)
Other complaint (not specified above) (42)
_ Professional negligence (25)
_ Other non-PIIPDIWD tort (35) 8
Asset forfeiture (05)
Petition re: arbitration award (11)
Miscellaneous Civil Petition

B Partnership and corporate governance (21)


Other petition (not specified above) (43)

8
Employment
Wrongful termination (36)
Other employment (15)
8 Writ of mandate (02)
Other judicial review (39)

2. This case D
is lD
is not complex under rule 1800 of the California Rules of Court. If the case is complex, mark the

b.
8
factors requiring exceptional judicial management:
a. Large number of separately represented parties
Extensive motion practice raising difficult or novel
d.
e.
8
Large number of witnesses
Coordination with related actions pending in one or more courts
issues that will be time-consuming to resolve in other counties, states, or countries, or in a federal court
c. 0
Substantial amount of documentary evidence f. 0
Substantial postjudgment judicial supervision
3. Type of remedies sought (check al/ that apply):
a. lD
monetary b. IX) nonmonetary; declaratory or injunctive relief c. 0
nitive
4. Number of causes of action ~ecify): Three (3)
5. This case 0
is llU is not a class action suit.
6. If there are any known related cases, file and serve a notice of related case.(You m use form CM-015.)

October
Date: !J 2006
Steven H. Gardner
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY ORATIORNEY FOR PARTY)

" NOTICE
F1i~intiff must file this cover sheet with the first paper filed in the action or proceeding (except small claims cases or cases filed
Lirjder the Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 201.8.) Failure to file may result
ir.i sanctions.
~!Ie this cover sheet in addition to any cover sheet required by local court rule.
If-lhis case is complex under rule 1800 et seq. of the California Rules of Court, you must serve a copy of this cover sheet onall
other parties to the action or proceeding.
Unless this a complex case, this cover sheet will be used for statistical purposes only.
iA Page 1 of2

Form Adl.Rted for Mandatory Use


Judlciall}6Uncn of California
CIVIL CASE COVER SHEET Cal. Rules of Court, rules 201.8 1800-1812,
Standards of Judicial Administration, 19
CM-010 [Rev. January 1, 20061 www.courtinfo.ca.gov
LLS/Federman
BC3603 3
SHORT TITLE: SE NUMBER:
Cirgadyne v. Federman

CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION


(CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION)

This form is required pursuant to LASC Local Rule 2.0 in all new civil case filings in the Los Angeles Superior Court.

Item I. Check the types of hearing and fill in the estimated length of hearing expected for this case:

JURY TRIAL? IXJ


YES CLASS ACTION? 0
YES LIMITED CASE?O YES TIME ESTIMATED FOR TRIAL 3 0
HOURSAX) DAYS.
Item II. Select the correct district and courthouse location (4 steps - If you checked "Limited Case". skip to Item III. 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 beiow, and, to the right in ColumnA, the Civil Case Cover Sheet case type you selected.
Step 2: Check Q!!g Superior Court type of action in Column 8 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 Los Angeles Superior Court Local Rule 2.0.

Applicable Reasons for Choosing Courthouse Location (See Column C below)

1. Class Actions must be filed in the County Courthouse, Central District. 6.


Location of property or permanently garaged vehicle.
2. May be filed in Central (Other county, or no Bodily Injury/Property Damage). 7.
Location where petitioner resides.
3. Location where cause of action arose. 8.
Location wherein defendant/respondent functions wholly.
4. Location where bodily injury, death or damage occurred. 9.
Location where one or more of the parties reside.
5. Location where performance required or defendant resides. 10.
Location of Labor Commissioner Office.
Step 4: Fill in the information requested on page 4 in item III; compiete item iV. Sign the declaration.

A 8 C
Civil Case Cover Type of Action Applicable Reasons -
Sheet Category No. (Check only one) See Step 3 Above
Auto (22) 0 A7100 MotorVehicle - Personal Injury/Property DamageMlrongful Death 1.,2.,4.

Uninsured Motorist (46) 0 A7110 Personal Injury/Property DamageNVrongful Death - Uninsured Motorist 1.,2.,4.

Asbestos (04) 0 A6070 Asbestos Property Damage 2.


0 A7221 Asbestos - PersonallnjuryNVrongfui Death 2.

Product Liability (24) 0 A7260 Product Liability (not asbestos or toxic/environmental) 1.,2.,3.,4., B.

Medical Malpractice
(45) 0 A7210 Medical Malpractice - Physicians & Surgeons 1.,2.,4.
0 A7240 Other Professional Health Care Malpractice 1.,2.,4.

Other
Personal Injury 0 A7250 Premises Liability (e.g., slip and fall) 1.,2.,4.

Property Damage 0 A7230 Intentional Bodily Injury/Property DamageIWrongful Death


(e.g., assault, vandalism, etc.) 1.,2.,4.
Wrongful Death
(23) 0 A7270 Intentional Infliction of Emotional Distress 1.,2.,3.
0 A7220 Other Personallnjury/Properly DamageNVrongful Death 1.,2.,4.

Business Tort (07) ID A6029 Other Commercial/Business Tort (not fraud/breach of contract) 1b),3
Civil Rights (DB) 0 A6005 Civil Rights/Discrimination 1.,2.,3.

Defamation (13) 0 A6010 Defamation (slander/libel) 1.,2.,3.


"
ifraud (16)
.,'
0 A6013 Fraud (no contract) 1.,2.,3.

Inteol.ctual Properly 0 A6016 Intellectual Property 2.,3.


(19)

CIV 1091$:p4 (Rev. 031(6) CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION LAse, rule 2.0
LASC Apptdved Page1of4
Martin Deia's Essential Forms TM
,-"
LLS/Federman
SHORT TITLE:
Cirgadyne v. Federman

A
B
E NUMBER

C
Civil Case Cover Type of Action Applicable Reasons
Sheet Category No. (Check only one) See Step 3 Above

Professional
Negligence
D A6017 legal Malpractice 1.,2.,3.

(25)
D A6050 Other Professional Malpractice (not medical or legal) 1.,2.. 3.

Other (35) D A6025 Other Non-Personal Injury/Property Damage tort 2.,3.

Wrongful Termination
(36) D A6037 Wrongful Termination 1.,2.,3.

Other Employment D A6024 Other Employment Complaint Case 1.,2.,3.


(15) D A6109 Labor Commissioner Appeals 10.

Breach of ContracU
D A6D04 Breach of Rental/Lease Contract (not Unlawful Detainer or 2.,5.
wrongful eviction)
Warranty
(06) D A6008 ContractNVarranty Breach-Seller Plaintiff (no fraud/negligence) 2.,5.

(not insurance)
D A6019 Negligent Breach of ContractlWarranty (no fraud) 1.,2.,5.
D A6028 Other Breach of ContractWarranty (not fraud or negligence) 1.,2.,5.

Collections D A6002 Collections Case-Seller Plaintiff 2.,5.,6.


(09) D A6D12 Other Promissory NotefCollections Case 2.,5.

Insurance Coverage
(18) D A6015 Insurance Coverage (not complex) 1.,2.,5.,8.

Other Contract
D A6009 Contractual Fraud 1.,2.,3.,5.

(37) D A6031 Tortious Interference 1.,2.,3.,5.


D A6027 Other Contract Dispute (not breach/insurance/fraud/negligence) 1.,2.,3.,8.

Eminent
Domain/Inverse
D A7300 Eminent Domain/Condemnation Number of parcels 2.

Condemnation (14)
Wrongful Eviction
(33) 1::1 A6023 WrongfUl Eviction Case 2.,6.

Other Real Property 1::1 A6018 Mortgage Foreclosure 2.,6.

(26) 1::1 A6032 Quiet Title 2.,6.


1::1 A6060 Other Real Property (not eminent domain, landlord/tenant, foreclosure) 2.,6.

Unlawful Detainer-
Commerciai (31) 1::1 A6021 Unlawful Detainer-Commercial (not drugs or wrongful eviction) 2.,6.

Unlawful Detainer-
Residential (32) 1::1 A6020 Unlawful Detainer-Residential (not drugs or wrongful eviction) 2.,6.

Unlawful Detainer-
Drugs (38) 1::1 A6022 Unlawful Detainer~Drugs 2.,6.

Asset Forfeiture (05) 1::1 A6108 Asset Forfeiture Case 2.,6.

Petition re Arbitration
(11 ) 1::1 A6115 Petition to Compel/ConfirmNacate Arbitration 2.,5.

CIV 109 <:$104 (Rev. 03/06) CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION LAse, rule 2,0
LAse Apl'rOved Page2of4
Marlin De~1'S Essential Forms
LLS/Federman
SHORT TITLE: E NUMBER
Cirgadyne v. Federman

A B , C
Civil Case Cover Type of Action Applicable Reasons -
Sheet Category No. (Check only one) See Step 3 Above
Writ of Mandate o A6151 Writ - Administrative Mandamus 2.,8.
(02) o A6152 Writ ~ Mandamus on Limited Court Case Matter 2.
o A6153 Writ - Other Limited Court Case Review 2.

Other Judicial Review o A6150 Other WriUJudicial Review 2.,8.


(39)

AntitrustfTrade
OA6003 AntitrustfTrade Regulation 1.,2.,8.
Regulation (03)
Construction Defect
OA6007 Construction defect 1.,2.,3.
(10)
Claims Involving Mass
Tort (40)
o A6006 Claims Involving Mass Tort 1" 2" 8.

Securities Litigation
OA6035 Securities Litigation Case 1.,2.,8.
(28)

Toxic Tort
Environmental (30)
o A6036 Taxic TorUEnviranmental 1" 2., 3., 8.

Insurance Coverage
Claims from Complex
o A6014 Insurance Coverage/Subrogation (complex case only) 1.,2.,5.,8.

Case (41)

o A6141 Sister State Judgment 2.,9.


ClA6160 Abstract of Judgment 2.,6.
Enforcement
o A6107 Confession of Judgment (non-domestic relations) 2.,9.
of Judgment
(20)
o A6140 Administrative Agency Award (nat unpaid taxes) 2.,8.
OA6114 Petition/Certificate for Entry of Judgment on Unpaid Tax 2.,8.
o A6112 Other Enforcement of Judgment Case 2.,8.,9.

RICO (27) o A6033 Racketeering (RICO) Case 1.,2.,8.

Other Complaints o A6030 Declaratory Relief Only 1.,2.,8.


(Not Specified Above) OA6040 Injunctive Relief Only (not domestic/harassment) 2.,8.
(42) o A6011 Other Commercial Complaint Case (non~tortJnon-complex) 1.,2.,8.
o A600D other Civil Complaint (non-tortlnon-complex) 1.,2.,8.

Partnership Corporation
Governance (21)
o A6113 Partnership and Corporate Governance Case 2.,8.

o A6121 Civil Harassment 2.,3.,9.


Other Petitions
o A6123 Workplace Harassment 2.,3.,9.
(Not Specified Above)
(43)
o A6124 ElderJDependent Adult Abuse Case 2.,3.,9.
OA6190 Election Contest 2.
o A6110 Petition for Change of Name 2.,7.
o A6170 Petition for Relief from late Claim law 2.,3.,4.,8.
o A6100 Other Civil Petition 2.,9.

CIV 10903-9:4 (Rev. 03/06) CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION LASC, rule 2.0
LASC Appr<Mm Page" of4
Martin Dean"iEssential Forms TM
b LLS/Federman
SHQReT l'fTLE: E NUMBER
Cirgadyne v. Federman

Item III. Statement of Location: Enter the address of the accident, party's residence or place of business, performance, or other
circumstance indicated in item II., Step 3 on Page 1, as the proper reason for filing in the court location you selected.

REASON: CHECK THE NUMBER UNDER COLUMN C ADDRESS:


17383 Sunset Blvd. #A310
WHICH APPLIES IN THIS CASE
Pacific Palisades, CA 90272
o 1. IZJ 2. 0 3. o 4. 0 5. 0 6. 0 7. 0 8. 0 9. 010
I STATE:
I ~~~D;2
CITY:
Santa Monica California


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 Mos k
courthouse in the Central District of the Los Angeles Sup or Court (Code Civ. Proc., 392 et seq.,
and LASC Local Rule 2.0, subds. (b), (c) and (d.

Dated: October 2006

PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO
PROPERLY COMMENCE YOUR NEW COURT CASE:

1. Original Complaint or Petition.

2. If filing a Complaint, a completed Summons form for issuance by the Clerk.

3. Civil Case Cover Sheet form CM-010.

4. Complete Addendum to Civil Case Cover Sheet form LASC Approved CIV 109 03-04 (Rev. 03/06).

5. Payment in full of the filing fee, unless fees have been waived.

6. Signed order appointing the Guardian ad Litem, JC form 982(a)(27), if the plaintiff or petitioner is a minor under 18 years of age,
or if required by Court.

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.

CJV 109 ~-o4(Rev. 03106) CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION LAse, rule 2.0
Page 4 of 4
LASe AitProved
Marlin aeim's Essential Forms TM
LLS/Federman

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