rage of 26) eas anne eve 10 a 42 13 14 15 16 u 18 19 20 2a 22 23 24 2% 26 2a 28 James B, Blancarte, Esq., (SBN: 2911 BLANCARTE LAW ee 633 W. Fifth St, Suite 1100 Los Angeles, California 90071 Office: (213}629-7030 Fax: (213)229-2499 Cristal L, Cabrera, Esq, (SBN: 295307) LAW OFFICE OF CRISTAL L. CABRERA 1055 West 7th Street, Suite 3341 Los Angeles, California 90017 e see ED sree MAY 08 2017 Cine genni Bepoy ‘Telephone: (323) 844.252 : Paes: Gas 86et088 A. G37 i Attomeys for Plaintiff, Yeo’ e | CINDY RUEDA DW WR ‘SUPERIOR COURT OF THE STATE OF CALIFORNIA, FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT CINDY RUEDA Plaintiff, CE OPCO, LLC, DBA COMBS: ENTERPRISES, LLC, a business entity form unknown; COMBS ENTERPRISES, LLC, a New York Corporation; 207 ANDERSON, LLC, a business entity form unknown; TRINET HR Ill, INC., a California sorporation; SEAN JOHN COMOBS, an individual; and DOES 1 through 100, inclusive, Defendants. ) ) ) ) 2 d ) ) ) d d 2 2 ) } ) d ) d CASE NO.: B68 60655 COMPLAINT FOR: 1. SEXUAL HARASSMENT; 2, QUID PRO QUO SEXUAL \SSMENT; 3. HOSTILE WORK ENVIRONMENT; 4, FAILURE TO PREVENT HARASSMENT AND RETALIATION; 5. VIOLATION OF WHISTLEBLOWER Bese oN LABOR CODE 6. WRONGFUL DISCHARGE IX § VIOLATION OF PUBLIC © & "] POLICY; geee8 23 7, RETALIATION; 32 A- & DEFAMATION; = 3 = 9. INTENTIONAL INFLICTION EMOTIONAL DISTRESS; 10. NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS; 11, FAILURE TO PAY OVERTIME. WAGES; ‘Doct 1 Pager 1 ~ Doo ZD = 1696515676 - noo Type = OTHER(age 2 of 26) 1 2 3 4 5 6 7 8 9 )" P.KNGWING AND INTENTIONAL 3 FAILURE TO COMPLY WITH ITEMIZED EMPLOYEE WAGE STATEMENT PROVISIONS; 13, FAILURE TO PAY WAGES UPON TERMINATION; and ) 14. VIOLATION OF BUSINESS ano PROFE: a7 seq. DEMAND FOR JURY TRIAL ‘NOW COMES plaintiff, CINDY RUEDA, (“Plaintiff” or “Ms. Rueda”) who alleges as follows: z ALLEGATIONS COMMON TO ALL CAUSES OF ACTION 1. Plaintiff, Ms, Rueda, is and was at all times relevant ‘hereto, a resident of the ‘County of Los Angeles, State of California. . 2. Plaintiff is informed and believes and thereon alleges that defendant CE OPCO, LLC, DBA COMBS ENTERPRISES, LLC (“Defendant” or “CE OPCO") is and was at all times relevant hereto a business entity, form unknown, conducting business fa Los Angeles County, State of California. Plaintiff is informed and believes and based on such information and belief, alleges that Defendant operates as COMBS ENTERPRISES, LLC in arid around Los Angeles ‘County. 3. Plaintiff is informed and believes and thereon alleges that defendant COMBS: ENTERPRISES, LLC (“Defendant” or “Combs. Enterprises”), is and was, at times relevant hereto, a comporation registered with the Secretary of State of New York and conducted business in conjunction with CE OPCO in and around the County of Los Angeles, State of California. 4, Plaintiff is informed and believes and thereon alleges that ‘defendant 207 ANDERSON, LLC (“Defendant” or“Anderson LLC"), is and was, at times relevant hereto, for unknown, conducting business inthe County of Los Angeles, State of California. Plaintiff is informed and believes and based on such information and belief, alleges that Defendant served as the record employer for payroll purposes = ding her employment in the [County of Los Angeles, State of California, ait business e 2 COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL sssesasa7e - Doo ype = omrage 5 of 26) Cer annew ne 5. Plaintiffs informed and believes and thereon alleges tht defendant TRINET HR Ii, INC. (*Defendant” or “TriNet", is and was, at times relevant hereto, a conporation registered withthe Secretary of State of Califciia, Plan is informed and belies tht TrNet served as the payroll processing agency during her employment in the County of Los Angeles, State of California, : 6, Plaintiff is informed and balieves ‘and thereon alleges that defendant SEAN JOHN ‘COMBS (‘“Defendant” or “Mr. Combs”), is and was, at times relevant hereto, an individual who ‘is and was an owner, officer, director, partner, supervisor and/or ‘managing agent of CE.OPCO, ‘Combs Enterprises, Anderson LLC, and TriNet; moreover, Plaintiff is informed and believes that} ‘Mr, Combs is a resident of the County of Los Angeles, State of California, 7, The true names and capacities, whether individual, corporate or associate, or otherwise, of the defendants named herein as DOES | through 100, inclusive, are unknown to Plaintiffs, who therefore sues said defendants by such fictitious names pursuant to California | Code of Civil Procedure §474, and Plaintiff will amend his complaint to show their true names Jand capacities when the same have been ascertained, Plaintiff is informed and believes and based| upon such information and belief, alleges that all defendants sued herein as DOES are in some /manner responsible for the acts herein alleged and that Plaintiff's damages were proximately caused by their conduct, : 8. Plaintiffs informed and believes, and bastd thereon alleges, that at all times /mentioned hercin, the defendants CE OPCO, Combs Enterprises, Anderson LLC, TriNet, and Mr. Combs (colletively, “Defendants”) and DOES whether specifically nied and/or ‘designated herein as a DOE were the agents, principles, employces, employers, representatives, joint venture or co-conspirators, managemenit companies and/or representatives, or ater go of each ofthe other defendants and DOES, either actually or ostensibly, and in doing the things alleged herein acted within the course and scope of suchiagency, employment; joint venture, conspiracy, reinsurance agreement, o-insirance agreemeit, management company agieement, alter ego agreement and/or service with the approval, knowledge, authority, acquiescence and/or ratification of each of the remaining defidants and DOES: <-> “4 COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL" : «Bash & Faget 3 ~ Bae 1D = 169652546 - Doo Typo = ommERrage 4 of © ar nonwne 10 12 13 14 15 16 17 18 19 20 21 22 23 24 28 2h 28 26) 9. All ofthe acts and condutt herein and below described of each and evety defendant was duly authorized, ordered, and dinested by the respective and collective defendant corporate ‘employers, and the officers and management-Level employees of said corporate employers. In addition thereto, said corporate employers participated in the aforementioned acts and conduct o their sid employees, agents and representatives, and each of them; and upon completion of the aforesaid acts and conduct of said corporate employees, agents and representatives, the defendant corporation respectively and collectively ratified, aocepted the benefits of, condoned, lauded, acquiesced, authorized and otherwise approved of each and all of the said acts and conduct of the| aforementioned corporate employees, agents and representatives. : 10, Plaintiff began working asa chef forthe benefit of Defendants a the home of Mr. Combs in Los Angeles County in the State of Califomia in January of 2015. During this time Plaintiff worked on the weekends from 9;00 a.m. to midnight or 2:00 a.m, Plaintiff worked almost every Saturday and Sunday with Chef Khristian Uy and was paid a flat rate of $150 per day. 11. In the middle of May of 2015, Plaintiff was askel! to work a a chef six (6) days per ‘week from 9:00 am. to midnight, Plaintiff accepted and was paid $150 per day. 12. In June of 2015, Defendants offered Plaintiff fulltime work asa chef, however, Plaintiff declined due tothe unreasonable houts and pay. Plaintiff continued her regular weekend| schedule on Saturdays and Sundays from 9:00 a.m, to midnight or 2:00 am. for $150 per day. 13, On or around September 27, 2015, Defendants offered Plaintf in writing ful time work as an exempt employee chef. Plaintiff accepted and worked every day’ as the lead chef for the California residence of Mr, Combs. Plaintiff was required to report to work daily at 9:00 am. and tobe available to work until midnight or 2:30am, depending onthe activities of and events hosted by Mr. Combs. 14, Plaintiff was also required to travel with Mr. Combs when his work required him io appear at events outside of Los Angeles, California, 15, Plaintiff was not provided additional income for days she was required to work until 2:30 a.m. or days she was required to travel with Mr. Combs. 4 COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL Doon 2 Fagor & =rage 5 of 26) 16. On or around October of 2018 when Plain first aveled with Mr. Combs, Plaintiff }complained about not receiving additional pay for having to travel for eight (8) days with Mr. Combs to serve as his personal chef during his travels. Plaintiff was old by Christina Khorram, he personal assistant of Me, Combs, and Stacy Friend the esate director for Mr. Combs, that | Plaintiff would only receive her regular pay, despite the required travel. 17, Onor around December 2015 wien Plaintiff traveled for the second time with Mr Cons, Plant coraplined to Stacy Friend tat she should receive additonal compensation for having to travel with Mr. Combs for fourteen (14) days. Stacy Friend then asked Plaintiff to keer 9 || tack of her hours and permitted Plaintiff vacation time. 10 18, After her vacation, Plaintiff retimed to hor employment and was required to report t| 11 || work daily at 9:00 a.m. and to be available to work until midnight or 2:30 a.m. depending on the 12 |] activities of and events hosted by Mr. Combs. 13 19, Having been instructed to Keep track of her hours, Plaintiff believed that she would 14 |] paid per the hours she worked and reported, however, Defendants continued to pay Plaintiff as 15 || an exempt employee. Plaintiff made no less than three (3) more complaints to Stacy Friend 16 || regarding additional compensation for excessive working houts, however, Plaintiff was only pi 17 | |the fat rate unt! her termination on or around May 8, 2016, 18 20. In addition to her complaints regarding pay, Plaintiff also complained to Stacy Friend| ! 19 || about inappropriate conduct and harassing:confrontations while she worked. During her 20 || employment, Plaintiff worked asa chéf,and she also served to Mr. Combs and his guests the 21 || meals she prepared for Mr. Combs and his house gues. 22 21. Plaintiff was regularly summoned by Mr. Combs to prepare and serve entrees and 23 || eppetizers to him and his guests while Mr. Combs and/or is guests were engaged in or 24 ||immediately following sexual activity, 2 22. On no less than one occasion when Plaintiff was summoned by Mr. Combs to'serve 26 |) him a post coital mea, as Plaintiff entered the room, Mr. Combs was naked and made commests 2/1 |] about his body to Plaintiff and ultimately asked the visibly uncomfortable Plaintiff is she was 28 |) attracted to or liked his naked body. 5 COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL ‘boot 1 Page# § ~ Doo ID = 1696515676 - Doo Type = OTHERage 6 of 26) en. a 23. Onno ess than one other oodasion, while Plaintiff was in the kitchen preparing a ‘meal, a male house guest of Mr. Combs approached Pla in the aude to ask her to look at and| admire his genitals aftr he had engaged in sexual activity with another house guest. Plaintiff wag ‘mortified and complained to Stacy Friend. 24, Plai ff made multiple complains to Stacy Friend about these and other instances ‘where Plaintiff was exposed to activity and approached with conversations of a sexual nature. 25, Plaintiff alleges that because of her complains regarding pay and her complaints about the regular exposure to sexual activity and harassing conversations, she was lured into a situation where she could be accused of theft and ultimately terminated. 26. It was known by the house personnel that Iris the executive ‘housekeeper regularly salvaged items discarded by Mr. Combs at his residence, In 2016, Iris approached Plaintiff with watch Iris represented she had found in the garbage can. Iris asked Plaintiff if she wanted it since itwas discarded by Mr. Combs. Plaintiff aid yes, and Iris told her to take it 27. In the days following, Plaintiff was accused of theft and told that she would not be prosecuted if she returned the watch and signed a waiver of all rights and claims against, Defendants as they relates to her employment by Defendants. Plaintiff retumed the watch, however, she refused to sign the waver of rights and claims. Defendants ukimately terminated Plaintiff on or around May 8, 2016. 28. Throughout Plaintiff's employment, she was misclassified as exempt and not paid overtime for work performed over eight (8) hours per day or forty (40) hours per week, was not paid double time for work performed over twelve (12) hours per day, was not provided with accurate itemized wage statements, and was not provided all wages eamed upon her termination. ‘Moreover, Plaintiff alleges that Defendants retaliated against her and ultimately fired her because} of her ongoing complaints regarding unhealthy conditions ineluding excessive hours without the ‘equired compensation and the ongoing and pervasive sexual harassment by Defendant Combs and his house guests. Additionally, on o around May 8, 2016, aftr Paintiff made a series of [complaints regarding the excessive hours. ai ongoing sexual harassment, Plaintiff was given a atch and then cused of theft and ultima fred based on thu eeustons ofthe 6 COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL 6 ~ Boo Xb = 1696515476 - noe Type = oTKERcraze? of 26) 1 {asa pretext for her prior complaints 2 29. On or around May 4, 2017, Plaintiff filed a complaint with the Department of Fair 3 || Employment and Housing and obtained a ight to sue notice which was thereafter served on all 4 || Defendants via U.S. Certified Mail. a 5 FIRST CAUSE OF ACTION - 6 SEXUAL HARASSMEN’ ie AG: YANTS AND'DOES 8 30. Plaintiff realleges and incorporates by reference all ofthe allegations contained inthe 9 || preceding paragraphs of this Complaint aj though fully set forth herein. 10 31, Phintff was an employee af or a person proving service under a contract with 11 || Defendants. 12 32. Because she was a woman, Plaintiff was subject to unwanted harassing cbnduct | 23 [iain bt tinted ove hase suchas bse nua, demeaning comments 14 |} slurs, or visual harassment, including but not limited to exposure to offensive situations or | 15 |) objects, or unwanted sexual advances expressed or communicated through’ ‘interpersonal relations 16 || in the workplace which were outside ofthe scope of necessary job performance, and instead, for 17 || personal gratification. 7 18 33. The harassing conduct was severe or pervasive and not ofa type necéssery for the 19 || management ofthe employer's business or supervision of Plant sjob. 20 34. A reasonable woman in Plainif’s circumstances would have considered the work 21 || environment to be hostile or abusive. 22 35. Plaintiff considered the work environment to be hostile or abusive. 23 36. A supervisor engaged in the conduct, and Defendants or its supervisors or agents knew of or should have known of the conduct and failed to take immediate and appropriate corrective action. 26 37. Plaintiff was harmed. a 38. The conduct was a substantial factor in causing Plaintiff's harm, 28 ya To COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL oct 1 Paget 7 = Dog 2D = 1696515476 - Boo Type = onHERtrage 8 of 20 39. Claimant is entitled to recover past and future economic loss including lost earnings, and past and future non-economic loss including humiliation, pain and suffering, 40. Claimant i entitled to recover punitive damages pursuant to Civil Cade §3294. SECOND CAUSE OF ACTION: UID PRO. UXUAL HAI MENT AGAIN MEFENDAN’ iD DOES: 41. Plaintiff realleges and incorporates by reference all ofthe allegations contained in the receding paragraphs of this Complaint as though fully set forth herein 42, Plaintiff was an employee of Defendants. 10 43, Defendant Sean John Combs arid his house guests made unwanted sexual advances Cera newne 11 ||to Plaintiff or engaged in other unwanted verbal or physical conduct of a sexual nature around or 12 |] directed at Plaintiff while she was working. 13 44, The terms of employment, job benefits, or favorable working conditions were made 14 |] contingent, by words or conduct, on PlaintifP’s acceptance of Defendant” sexual advances or 15 ||sexual conduct. ‘| 7 16 45, At the time of the conduct Defendant Sean John Combs was a supervisor of Plaintiff 17 |Joran agent for Defendants. 18 46. Plaintiff was harmed. 19 47, Defendants? conduct was a substantial factor in causing Plaintif?’s harm. 20 48. Claimant is entitled to recover past and future economic loss including lost earnings, 21 |}and past and future non-economic loss including humiliation, Pain and suffering, 22 49. Claimant is entitled to recover punitive damages pursuant to Civil Code §3294. ‘THIRD CAUSE OF ACTION HOSTILE WORK ENVIRONMENT AGAISNT DEFENDANTS AND] OES ‘50. Plaintiff realleges and incorporates by reference all, ofthe allegations contained in the 25 || preceding paragraphs of this Complaint as though fully set forth herein. BM 8 COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL. ‘Doct 4 Paget # = Boo 1D = 1696535476 - Doc type = OmERrage 2 of 26) 1 51. Plant was an employee of Defendants or a person providing services under a 2 || contract with Defendants. : ue 3 52. Plaintiff was subject to whwanted harassing conduct because she was a woman. 4 53. The harassing conduct was severe and pervasive.” 5 ‘54. A reasonable woman in Plaintiff's circumstances would have considered the work 6 [environment to be hostile or abusive. 7 55, Plaintiff considered the work environment tobe hostile or abusive. 8 56. Defendant or a supervisor participated in, engaged in, assisted iin, or encouraged the 9 || harassing conduct; or Defendants and its agents knew or should have known ofthe harassing 10 |eonduct and failed to take immediate and appropriate corrective action. LL (57. Plaintiff was harmed. 12 ‘58. The conduct was a substantial factor in causing Plaintiff's harm, 13 59. Claimant i entitled to recover past and future economic loss including lost earings, 14 |] and past and future non-economic loss including humiliation, pain and suffering, 15 60. Claimant is entitled to recover punitive damages pursuant to Civil Code §3294, 16 FOURTH CAUSE OF ACTION , 17 ‘AILURE TO PREVENT HAI ISMENT A! RET \TION 18 AGAINST DEFENDANTS AND DOES 19 61. Plaintiff realleges and incorporates by reference all ofthe allegations contained in the 20 || preceding paragraphs of this Complaint as though fully set forth herein, ~ 21 ©2, Plaine was an employee of Defendants or was a person providing services under a 22 || contract with Defendants. 23 63. Plait? was subjected to harassment, discrimination, or retaliation in the course of 24 | employment. a z 6 64. Defendants failed to take ail reasonable steps to prevent the hatassment, a discrimination or retaliation, a 65, Plaintiff was harmed. 28 || ‘ 9 COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL ‘Dock 3 Faged 9°. Dee HD ~ 1696515476 - noe Type = OMMERrage 10 of 26) 1 66. Defendants’ failure to take all reasonable steps to prevent harassment, discrimination 2 || orretaliation was a substantial factor causing Paints harm, 3 67. Claimant is entitled to recover past and future economic loss including lost earnings, 4 || and past and future non-economic loss including humiliation, pain and suffering. 5 ‘68. Claimant is entitled to recover punitive damages pursuant to Civil Code §3294, 6 FIFTH CAUSE OF ACTCION 7 |OLATION OF WHISTI WER PROT! [ON LABOI 1102.5 8 AGAINST DEFENDANTS AND DOES: 9 69. Plaintiff realleges and incorporate by reference al of the allegations contained in the 10 |} preceding paragraphs of this Complaint as though fully set forth herein, 1 70. Atl relevant times, Plaimiff was a non-exempt employee of Defendants covered by 12 || Labor Code'§1102.5. 13 TL. Defendants were the employers of Plaintiff. 14 ‘72. Defendants believed that Plaintiff had disclosed to persons with authority over 15 || Plaintiff that there were legal violations in the work Place, 16 73. Plaintiff had reasonable cause to believe that the information she disclosed was a 17 || violation of local, state or federal statutes, rules, or regulations. 18 74, Defendants subsequently discharged Plaintiff. 19 ‘75. Plaintiff's disclosure of information was a contributing factor in Defendants’ decision| 20 || to discharge Plaintiff. 21 76, Plaintiff was harmed. * 22 77. Defendants’ conduct was a substantial factor in causing Plaintiff harm. ‘ 23 78. Plaintiff is entitled to recover past and future economic loss including lost earnings, 24 |fand past and future non-economic loss including pain and suffering, 28 79. PlaimtfVs entitled to recover punitive damages pursuant to Civil Code §3294. 26 | 7 Prd it 28 iit 10 COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL oot 3 Fagaw 30 ~ bee 15 = 1696515476 ~ Doc Type = OmERcage 2 of 26) SIXTH CAUSE OF ACTION WRONGFUL DISCHARGE IN VIOLATION OF-PUBLIC POLICY AGAINST DEFENDANTS AND DOES ‘80. Plaintiff realleges and incorporates by reference all of the allegations contained in the preceding paragraphs of this Complaint as though fully set forth herein. 8:1, Plaintiff claims that she was discharged fom employment for reasons that violate Public policy. Its a violation of public poliy for employers to discharge employees who tempt to exercise a statutory right or privilege. Moreover it fsa violation of publi policy for eer AaHaewne employers to discharge employees who report a violation of a statute of public importance, 10 ‘82. Plaintiff was a non-exempt employee of Defendants from January 2015 to May 8, 11 ||2016. During that time, Defendants the Labor Code and the Fair Employment and Housing Act 12 [by faitng to pay overtime wage to Plaintif, maintaining a harassing working environment, 13 || discriminating against Plaintiff, retaliating against Plaintiff, and ultimately firing Plaintiff after 14 }/ she complained about these violations. 15 83. It is a violation of public policy for employers to discharge employees who attempt to 16 || exercise a statutory right or privilege. Moreover iti a violation of public policy for employers to 17 |} discharge employees who report a violation of a statute of public importance. 18 84, Plaintiff's discharge caused her harm in the form of lost earnings and pain and 19 || suffering according to proof. 20 85, Plaintiff is entitled to recover punitive damages pursuant to Civil Code §3294. 21 SEVENTH CAUSE OF ACTION : 22 RETALIATION , 23 AGAINST DEFENDANTS AND DOES 24 86. Plaintiff realleges and incorporates by reference all of the allegations contained in the 25 | preceding pargraphs ofthis Complaint a though filly set forth herein ue 26 87. At all relevant times, Plaintiff was a non-exempt employee of Defendants covered by 23 |] Labor Code 5110250) 28 || : COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL ‘och 2 paged 11, Gee 7D = 1696535476 ~ Dox type = onmenrage 22 of 20) 88, Pursuant to Labor Code §11025(),“an employer any person stig on behalf the employer, shall not retaliate against an employee for disclosing inforsation... a person wre with authority over the employee or another employee who haste authority to investigate, discover, or correct the violation or noncompliance...if the employee has reasonable cause to believe thatthe information discloses violation of state oF federal statute or federal statute, or violation or noncompliance with aca, state, or federal rue or regulation.” : 89, Plaintiff engaged ina protected activity including reporting to hee supervisors ‘violations of the Labor Code and the Fair Employment and Housing Act. i 9 90. Plaintiff's complaints regarding non payment of overtime wages and sexual 10 ||harassment were substantial motivating reasons for Defendants’ decision to. discharge Plaintiff. 11 91 Plaintiff suffered harm and Defendants’ conduct was a: substantial factor in causing 12 {harm to Plain. : 13 92, Defendants subjected Plaintiff to adverse employment action including termination. 14 ‘93, There is a causal link between Plaintiff's protected activity and her termination, 1s 94, Plaintiff is entitled to recover past and future economic loss including lost earnings, 16 || and past and future non-economic loss including pain and suffering, 17 95, Plaimtffis entitled to recover punitive damages pursyant to Civil Code §3294 and 18 |{attomey’s fees pursuant to Government Code §12965(b).. , 19 EIGHTH CAUSE OF ACTION * 20 | DEFAMATION 21 GAINS INDANTS AND DOES’ 22 96 Plaintiff realleges and incorporates by reference all of the allegations contained in the | 23 }[preceding paragraphs of this Complains though fully set forth herein : 24 97. Defendants made one or more defamatory statements about Plaintiff stealing to 25 || persons other than Plaintiff. 28 98. This person or these people reasonably understood the statements to mean that’ 22 || Plaintiff had committed a crime or thatthe statements were about Plaintiff, 26 || ’ 12 COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL ooh 1 Faget 12 - Dee XD = 2696515476 - Doo Type = OMERe@ ; 1 99. The fects and circumstarices knowm tothe listener ofthe statements tended to injure 2 || Plaintiff in her occupation or expose her to hatred, contempt, fi icule, shame, or discouraged 3 || others from associating or dealing with Plaintiff. a if 4 100. Defendants failed to use reasonable care to deterrhine the truth or falsity of the | 5 || statements made. ; | 6 101. Plaintiff suffered harm to her business, trade, profession, or occupation including t 7 |[ but not limited to money spent asa result ofthe defamatory statements, 8 102. Plaintiff suffered harin to her reputation, shame, trotfction, or hist eng. 9 103. Defendants’ statements wére a substantial factor in causing Plaintiff's harm, ! 10 104. Plaintiffs entitled to receive compensation forall assumed harm, punitive : 11 || damages, and compensation for actual damages. ae 12 NINTH'CAUSE OF ACTION 13 INTENTIONAL INELICTION OF EMOTIONAL DIST, TRESS u AGAINST DEFENDANTS AND.DOES + : 1s 105. Plaintiff realleges and incorporates by reference all of the allegations contained in| 16 |] the preceding paragraphs of this Complaint as though fully set forth herein. uy 106. Defendants engaged in extreme and outrageous conduct. 18 107. Defendants abused 4 position. of authority or a relationship that gave Defendants 1.9 ||real or apparent power to affect Plaintiff's interests. — 20 108. Defendants knew that Plaintiff was particularly vulnerable to emotional distress. 21 109. Defendants knew that their conduct would likely result in harm due to mental 22 || distress. ° 23 0. ‘Defendants intended to cause Plaintiff injury in the form of emotional distress or 24 || Defendants acted with reckless disregard of the probability that Plaintiff would suffer injury in 28 the form of emotional distress, knowing that Plaintiff was present when the conduct occurred. 26 Lil, Defendants knew that emotional distress would probably result from their conduct] i a or Defendants gave little or no thought to the probable effects of their conduct. 28 Mt z : i 13 COMPLAINT FOR DAMAGES.AND DEMAND-FOR JURY TRIAL ree eee rere ee ne _ : ‘Dost i Pageh 13 — boo TD = 69658476 - Doc ype = oTrage 4 of 26) 1 112, Plaintiff suffered sevieeinotionel distress that was not mild‘or brief twas so 2 || substantia or long lasting that no re8Somable person in actilized soeiety should be expected to 3 |] bear it. : 4 113. Defendants’ conduct was'a substantial factor in causing Paintif?’s severe 5 || emotional distress. 6 114, —Plaintiffis entitled to recover past and future economic loss and past and future 7 ||noneconomic loss, : 8 TENTH CAUSE OF ACTION 9 NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS 10 AGAINST DEFENDANTS AND DOES wu 115. Plaintiff realleges and incorporates by reference all of the allegations contained in 12 || the preceding paragraphs ofthis Complaint as though fully set forth herein, 13 116. Plaintiff was accused of theft as a result of Defendants’ negligent conduct. 14 117. Defendants were negligent, or acted with malice, oppression, or fraudulent intent 15 || because Defendants intended to cause injury to Plaintiff; or Defendants conduct was. despicable 16 |]and was carried out with a willful or ‘conscioys disregard of Plaintiff's rights or safety; or 17 |} Defendants’ conduct was despicable and subjected Plaintiff to cruel and unjust hardship in 18 || conscious disregard of Plaintiff's rights; or Defendants intentionally misrepresented or concealed| 19 |}a material fact known to Defendants, intending to cause Plaintiff hann. 20 118. Plaintiff suffered serious emotional distress 21 119. Defendants’ negligence was a substantial factor in causing Plaintiff's serious 22 |] emotional distress that which an ordinary, reasonable person would be unable to cope. 23 120. Plaintiff is entitled to recover past and future economic loss and past and future 24 || noneconomic loss. 2 lla 26 || 2% ll 28 ll 4 COMPLAINT FOR DAMAGES, AND DEMAND FOR JURY TRIAL och 1 Fagen 16 - Doe iD = 2696518476 ~ Doo Type = OMERape 15 of 26 ELEVENTH CAUSE OF ACTION = * FAILURE TO PAY OVERTIME WAGES: AGAINST DEFENDANTS AND DOES. 121. Plaintiff realleges and incorporates by reference all of the allegations contained in| the preceding paragraphs of this Complain as though fll set fort herein 122, Throughout her employment, Plaintiff was paid a flat rate despite the number of hous she worked per day or per week. Many times Plaintiff was made to work in exces of eight (@) hours per day or in excess of forty (40) hous per week without any additional compensation 9 |] from her base rate of pay. : eran wre 10 123, By requting Plaintiff to work in excess of eight (8) hours per day and forty (40) : 11 |/hours per week without compensating her at the rate of time and one half and requiring Plaintiff 12 || to work in excess of twelve (12) hours per day without compensating her at the rate of double 13 || time the regula rate of pay during which Plaintiff was required to work, as alleged above, 14 || Defendants wilfully violated the provisions of Labor Code §1194, 15 124, As aresult of the unlawful acts of Defendants, Plaintiff has bepn deprived of 16 || wages and/or overtime/double time wages in amounts to be determined at ‘trial, and is entitled to 17 ||recovery of such amounts, plus interest and penalties thereon, attomey's fees, and costs, pursuant 18 | to Labor Code §§1194 and 1199; Code of Civil Procedure §1021.5; and Civil Code §3287. 19 ‘TWELTH CAUSE OF ACTION : 20 KNOWING AND INTENTIONAL FAILURE TO COMPLY WITH ITEMIZED 21 MPLO} \GE STATEMENT PROVISIONS 22 AGAINST DEFENDANTS AND DOES 23 125. Plaintiff realleges and.incorporates by reference. alkof thé ‘allegations contained in| 24 || the preceding paragraphs of this Complaint as though fully set forth hereii, + 28 126. California Labor Code §226(a) requires Defendants to provide Plaintiff itemized 2 |) wage statements consisting of gross wages eamed, total hours worked, all deductions from 2 || payment of wages, net wages eamed, the inclusive dates ofthe period for which the employee is 28 || paid, the name and address of the legal entity that is the employer, and all applicable hourly rates 1s . COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL, ‘Doct 1 Fage# 18 ~ boo HD ~ 2696515476 - nos type = ona(rage 16 0f 26 7 in effect during the pay period and the eoresponding numberof hours woiked at each hourly ate by the employee, Defendants have knowingly and intentionally fled to comply with Labor Code §226(a) by failing to provide any wage statements compliant with the Labor Code, Ultimately, Defendants failed to provide any statements ivhich included all regular and overtime hours worked, the applicable hourly and overtie rates. : 127, Asaresult of Defendants’ unlawful Conduct, Plaintiff has suffered injury. The sbsence of wage statements has delayed timely challenge to Defendants’ unlawful pay practices, ete discovery and mathematical computations to determine the amount of wages owed, ern ewne 9 || causes difficulty and expense in attempting to reconstruct time and pay records, and led to 10 || submission of inaccurate information about wages and aniounts deducted from wages to state 11 |/and federal government agencies. : i 12 128. As a consequence of Defendants failure to comply with Labor Code §226(a), 13 || Plaititris entitled to recover all applicable penalties from Defendants and an award of casts and| 14 ||reasonable attomey's fees pursuant to Labor Cade §226(c). 15 THIRTEENTH CAUSE OF ACTION 16 FAILURE TO PAY WAGES OF TERMINATED OR, RESIGNED EMPLOYEE i AGAINST DEFENDANTS AND DOES 18 129. Plaintiff realleges and incorpotates by reference all of the allegations contained in ‘19 |) the preceding paragraphs of this complaint as though fully set forth herein.. 20 130, California Labor Code §§201 and 202 requite Defendants to pay its employees al 21 || wages due immediately upon termination of employment or within seventy-two (72) hours of 22 ||resignation. Labor Code §203 provides that if an employer willfully fails to timely pay such 23 |] wages the employer must, as a penalty, continue to pay the subject employee's wages until the 24 |) back wages are paid in full or an action is commenced. The penalty cannot exceed thirty (30) 25 | days of wages : 2% 131. Asalleged above, Plaintiff is entitled to compensation for all wages including all 23 overtime and double time wages eared and premium wages fr unprovided and intruped mea 28 | and rest periods, but to date has not received such compensation ves 16 = COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL, ‘Doo! 1 Pagsh 16 ~ Doo 1D = 1696848475 - Doo aype ~ ormage 7 of 26) ae 132, Asa eonsequence of Defendants’ willful conduct in nt paying any wages or compensation, Plaintiffs entitled to shity (30) days wages a a pealtyuader Labor Code §203 foc (1 failure to pay legal wages, together with interest theredn and attorney's fes and costs [pursuant to Labor Code §§218.5, 1194; Code of Civil Procedure §1021.5; and Civil Code §3287,| FOURTEENTH CAUSE OF ACTION Mo! [ONOF UNF: MPETITION LAW AGAINST DEFENDANTS AND DOES 133. Plaintiff realleges and incotporates by reference all of the allegations contained in| 9 |! the preceding paragraphs of this Complaint as though fully set forth herein, 10 134, Defendants’ failure to pay Plaintiff overtime and double time wages as alleged eu naewne 11 |fherein, and faire to keep proper records as alleged herein constitute unlawfl activity 12 |} prohibited by Business & Professions Code §17200 et seq: 13 135. The actions of Defendants in failing to pay Plaintiff in a lawful manner, as will be] 14 || further alleged herein, constitutes false, unfair, fraudulent and deceptive business practices, 15 || within the meaning of Business & Professions Code §17200. 16 136. Plintif is entitled to an injunction and other equitable relief against such 17 |) unlawful practices in order to prevent future damage, for which there is no adequate remedy at 18 flaw, and to avoid a multiplicity of lawsuits. “ 19 137. Asaresult of its unlawful acts, Defendants should be enjoined from these 20 ||unlawfil activities and made to restore to Plaintiff the lost wages and beiefits and her 21 || wrongfully withheld compensation pursuant to Business & Professions Code §17203. Plaintiff s| 22 || informed and believes, and thereon alleges, that Defendants were and are unjustly enriched through their failure to pay to Plaintiff wages, including overtime and doubletime wages for all hours worked by Plaintiff. Plaintffis informed and believes, and thereon alleges that Plaintiff is prejudiced by Defendants’ unfair trade practices, 138. Asa direct and proximate result of the unfair business practices of Defendants, /and each of them, Plaintiff is entitled to restitution and/or disgorgement of all wages which have ‘been unlawfully withheld from Plaintiff as a result of the business acts and practices described 7 COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL ‘oot 1 Page# 27 ~ boo 10 = 1696535476 - Doc Type ~ omrage 28 of 26) A herein. Plaintiffs also entitled to an jeton cnjoining Defendants to cease and desis: fiom engaging in the unlawful wage and hour practices described terein 139, Theillegal conduc alleged herein is continuing, and there is no indication that Defendants will not continue such activity into the future, Plaintiff alleges that if Defendants are ‘not enjoined from the conduct set forth inthis Complaint, Defendants will continue to retaliate gains the employees and wil continue to fail to pay all wages eamed, wll continue to require ‘employees to work during rest periods-without providing appropriate compensation in liew exrHKA Hos wone thereof, and will continue to fail to pay and to avoid paying appropriate taxes, insurance, and 9 || unemployment withholdings. i" 10 140, Plaintiff further requests thatthe Court issue a preliminary and permanent 11 |} injunction prohibiting Defendants from requiring employees to work without compensation of 12 |] overtime and double time wages atthe Prevailing legal rate, and from continuing to require 13 |] employees to work through meal and rest periods or without providing compensation in liew 14 |) thereot : 15 PRAYER 16 WHEREFORE, Plaintiff prays for lief anda jadgment against Defendants as follows: 17 a. Past and future economic loss including lost earings; 18 b. Past and future non-economic loss including pain and suffering; 1g © Special damages; ae 20 4, Actual damages; 4 ai . Nominal damages; eee 22 £. Punitive damages pursuant to Civil cate $3294; 23 g. Damages for unpaid wages and/or overtime wages; ri 4 ‘h. Damages for unpaid wages and/or double time wages; 28 i, Damages for unpaid wages for rnissed rest periods; 28 4. Damages for unpaid wages for missed meal periods; 2 Penalties for failure to provide the personne! file upor' request; 28 1. Penalties for inaccurate wage statements; 18 COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL ‘Doct 2 Page 18 - boo 1D = L6SESLS876 - Doerage 19 0 26) i o @ 1 m. Damages for unpaid penaity wages; 2 8. Reston unde Busines and Professions Code §17203; 3 0. Pre-judgment interest; . 4 p. Costs; 5 4g. Reasonable attomeys” fees; 6 1. Preliminary and permanent injurictions prohibiting Defendants from further violating 7 the Califia Labor Cod and eqiing he esbishment of aproprite and 8 effective means to prevent future violations; a 9 's. Preliminary and permanent injunctions pursuant to Busines$ & Professions Code 10 §17203, enjoining and restraining Defendants from continuing the unlawful and 1 ‘unfair business practices set forth above and requiring the establishment of 12 appropriate and effective means to prevent future violations; and 13 t. For such other and further relief as the Court deems just and proper. 14 15 || DATED: May 8, 2017 BLANCARTE LAW 16 : 17 18 19 20 21 + LAW OFFICE OF CRISTAL L. CABRERA. 22 23 24 25 + Attorney for Plaintiff, ‘i 26 CINDY RUEDA. aE 28 ey COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL Dock 1 Paget 19 = Doo 1D = 1656515476 - Doo Type = OnE Paceceage 29 of 26) DEMAND FOR JURY TRIAL’ * Plaintiff hereby demands trial by jury on all issues so triable in the Complaint, DATED: May 8, 2017 BLANCARTE LAW eI Aes woe 9 CINDY RUEDA 10 LAW OFFICE OF CRISTAL L. CABRERA. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 28 28 2k 28 CINDY RUEDA 20 ‘COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL ‘Dooh 1 Paget 20 Doo ID = 1696815476 - Doc 2ype = OrIERrage 22 2€ 26) . : : : @ cuasg a — heneouneem FILED, : je th Stes 3 Fee : Urs angele Calorie 900 : tebe otra cree as292 ‘mens (323)386-4088 Se Sontag amgng/rospen Plant, Cidy Rueda ; Kvanon count oF cauromua cour or Los Angeles : ‘Since aocness: LHI Nor Hil Suet ae : MAY 08 2017 smexo,couse HHI Nott ‘crvmozrcece: Los Angeles, California 90012 ‘ner Cane, pete Ofc se Conal Ssrie ma 90 ket Mee emer CASE = Cindy Rueda v. CE Op Co dba Combs Enterprises, LLC, et al iv ASE COVER SHEET Complex Case Dasignaton [OC 8806-53 Untnted Uites : Uso Utatag evar CI vane | Shanes demaraedis | Fledyth st opearance by detent seeds $250c0) $250C0crless)| "(eal Rus orcour.rueSate) | cer “ems ¥-6 below hustbe completed (soe nstuctons 9 pa90 [F Gheck one box blow forthe case ype that best descibes is case: ‘ato Tor ‘convet Froonaly Compl i gation po ‘reer ol onctvarany (6) (Cat Raa Cour es 4040) Uninsured moons (46) Rue 3.740colecions(cs) —— [] AniousTrade requtaton (03) tor PuPDAND Porson! jaryPreperty — [] Other catoctions (0%) [constuction detect (19) DamageNrongt Death Tent, Insane evecoge (8) fasion 0) 4 ‘Asbestos (04) 1 otercentect (an secures gation 25) Prod kab (24) ‘Real Property [J evronmentar Toxic tot (20) TE) scat mabariee 5) Eneettcemsivivere —* [7] imuraen coverage come tn temthe 1 onerpipamo es) cncannoten Sores pov comp es Non PUPOMND (Olen Tot Wrong onion 29 beet TEI seasinss eater business pace ory C] citer rei propery (26) Enforcement of Judgment CS cones 9) Unlawful Detainor 7 estercerent ot véamene (0) Defame 19 Contos ) * scotanaous Ct Compleat, Frava (16) Ey Reeioensat (22) Rico en) ttc pry 19) TS onsen bacon spect oboe) Protest nepigere (25) penne Miasotaceoes Civ Paton Ce on PUPDIND ot 5) set ee Peccuesuaa Cos rears aan ef eeenamermmen Wor tembaon 2) FS wneetmaneate 02 Oar empeomert (5) TE one nctrevnt (0) 2 Trisease Tis (Tiere complex under re 3.400 ofthe California Rules of Gout Wie cave is complex, markihe {actos requing except juscil management. 2.) Large numberof separate represented parties] Large numberof winosses ». extensive motion race raising ttt er novel e. (] Cocrinaion with elated actions pending in one o: mare cous iceues tat wil be time-consuming to esohe In other eountes, tates, or ounte, or ina federal court (1 Substentalamountef documentary evidence” (] Susstantlposjadgment ucla supersion 3. Remedies sought (check a that ppt: a[Z] menetay *b-CZ] nonmenetary, declaratory orinjictve rit (7 Tpuntve 4 Number of causes of acon (pect 14 5 Tiscase Cis [Z]icnot actassacon suit 8, tthe are any known related cases, fe and serve a notice of elated Bote: May 8, 2017 ital L. Cabrera, Esq., (SBN: 295307) WOTICE Plainttt must le tis cover sheet withthe rst paper fle inthe acon or proceeding (except smal Gains cases or cases fled eer the Prebate Code, Farly Code, ot Welae and Instuions Code). (Cal Rules of Cour ule 3.220) Falute to le may result "Sp sanctons ' File is cover sheet ation to any cover sheet required by focal cout rl, * its case ia complex under nde 2.400 et seq, ofthe Cafemia Rutes of Cour, yeu must seve a copy of his cover sheet on alt ‘ter partes tothe acon or proceeding, + Unless tis sa olectons case unde ke 3.740 o a complex cas, ts cover sheet wll be used for tatisicel purposes cn) aa ‘Givi CASE COVER SHEET Saas eee : ae: ‘Dock 1, agen 21 bos 1 = 1ASESISK7E = Doc Type = oTrage 22 of 26) . 1 crore Isreons on How 70 conpLere ie cove HET «Tee st oe ua edo yg seg es ee itn os mat SBN Ca OS, cleo Se oars Tea a at Sines Sachi ete Sint Yeon eae tesa cn reece Sees tad fa teldacea tre ieee ete ae a at Sepa rdsu ' eseage cram aes ata ea eaare pe esaae ae ge Peseckis be cr cumes Stas Matnigtenrtcten mee eae esi aetane Caececetay tae tyny1at Macte, Noe Seine Mancina rest eee eee mega {Stan cence, kn ce he 37 ee ace ey ete Sen a an ST Se a td mae een ae "which property, services, or money wes acquired on credit. A collections case does net include en action seeking the fallowing: (1) tort Serie ae i ey dos ac oaceng pros aes ane ed a beta atte ha Sa i ate hate saa ge Pa a ea ieedreeet eins sen arapen Sein seca ie tres pay ile es SoeaweeN armen otleneatoes arneset te Tees noms carsgcuopres at tn aCCsCot Sam ei a ‘sehen sc ica eck nce ath a tease Se Rete ae rasp basepac epi art ond tae cotetrpee ia pate Sioanin at's Sue ating to sabes aieareg eras naam oe Bes gui scopic bate sneer teh oe aaa cat the cates comple, casenrsamecuce sone co sete cegcatnt “Sonrowamyecony — “Elazanatemn an RERmELGN eee seme oaitreates wean Secu een scenery eater any omnes cngittamiine Eta! ae Silanes ethan eee vena Sarees ae gna te er oe ieee cate SIEITE” - meta i ese, eae ee Se rae Salgnamt ee ema See, sy oe vce a tpn eee neces” a esate eer eee einer ne ee See repe Rectteme ohetnuach eR cya niet, eo Setanta aa Sere onthe ona ni g ew lca seguro ates canes oe votibenrmrene wage Bee race Smet Carer eae, a weal rane woe ee eee one Shomer. Seem Non-PUPDIND (Othor) Tort foreciosure) Pace Ten ——_ungale gs Sn OHREE? cee eon areata SESE ety ated ann eee ae seal “em atric Gietesl Property (18) Peon Re: Walon rar (1) ‘ Prteasnt Nagao (25) ‘it Manat 2) 2) Ole Preesenawaprcioe ‘Rreareams nutes a G2 Ge Presoan napa frauen me So not medcater eps ‘Cosette Potner Rael romtste ecponert Piro en ‘wicca Ute Gout Case ‘Sain layment Rereu ‘one Gi Pebion org Teminten (96) be: Jasia Review Gre Emlomen (15), Rava iain ter Oxer : Naioe popes + Coco: Apes, aR TT ra CIVIL CASE COVER SHEET "Bock 3 Baga 22 - Doo ID = 1686516876 ~ Doc Type = OTTERceage 23 of 26) s Sarr aaa haynes Ceontoas coment cas gpa BOBS CIVIL CASE COVER SHEET ADDENDUM AND. ‘STATEMENT OF LOCATION (CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION) This om i ragured ureanto Lea Rule 23 anew econ inane Lon Angle Super oun, ‘Step 4: After completing the Civil Case Cover Sheet (Judicial Council form CM-010), find the exact case type in ‘Column A that corresponds tothe case type indicated inthe Ci Case Cover Shae. ‘Step 2: n Column 8, check the box for the type of action that best describes the nature ofthe case Step 3: n Column ¢, cce the number whic explains the reason for the cout filing location you have chosen, Applicable Reasons for Choosing Curt Fling Location (Column) 1.Ciass acon must be iedin te Stary Mosk Course, Chia ste, T,Locatan ver pestone eis, 2, Pease fog in conta att £8 Lovaton erin defenantespendetfieone way, 3. Lecabon era cause a acon ose, 9 Locaton tre one rms’ of he parses, 4 Mata prea iuy Singin Not Det 10 Location of Leber ConmasioerOfes. ae 1 Mandatory fling location ub Case ni detested ieee eee rereiene eee aerate non cotton, ited coleztion, or personal ny. © Lovato of oper or prmanenty gaged vehi x B c ‘Cu Case Cover Sreet Type ct Aion ‘Apptnaie Reasons - ‘Galego (oreenonyene) ‘Bee Step 3Atove ‘0 2) 17109 Nota Veiie Personal bjuyPrepety Damaging Ceath ‘Auto Tort Usinsured Meiers 46) | ATIIO Person jPropeny Camagetarongi Desh nisi Mtot ASOD Asbesos Propery Damage an — zs hee D1 A722 Asbestos - Personal injuryVrongful Death ait fa ‘Product Linbity (26) D_A7260 Product Libitty (not ssbestos or texiclenvitermmentsl) tat Hl wa aca A eae Fame ooee rs 2 meas “ q fl eee vo BE a ea rts anon rn Sy Pmy, | 0 iene Hey reety meen Chao ey Z| Same. ‘cormetior a ~ ‘Death (23), D1 A7270 Intentional epee Distress oie i D._ A722) Other Personal injuryiProperty DamageWrongfu!Death wan Sd TAG 109 Rev 26) CIVIL CASE COVER SHEET ADDENDUM Local Rule 23 ASC Approved 3.04 AND STATEMENT OF LOCATION Page tof4 ‘ = + Boon 1 Fagen 28 - Goo 1D = 1696835476 ~ Doe Type = OnmERage 28 of 26) SONS Cindy Rueda v. CE Op Co dba Comp Enjerpises, LLC, eta, | “ME A . B * C Aoctcabie catgut Gost Ipsetlcen ramen Sens Sooo a ee ‘sow BesTaton [Ate onecanneanrienenToa(qaimateacetemtacd fires £2 | cumpoas (a nos oatuneamane = £9 [oven | sett ovmaiotimere - 138 33 2 Fraud (8) (2. ABOTS Freud ro cana) i 1.2.3 2 ; AT? epluapin q 1a ale : Nene L 24 creas) [a As OherionPonctnsyPrnntyOmegron = + Yuna a i Vergara @e) [a AT Pn Terai 7 my © ete Ge Raper cme 1 B | onersmroymen 5) See ener iu i © ree ae Gonna: Aes » © AGO Ona ol eile Gee oa awaone cm - wos . Benensh ores WATERY | n6i08 Contactar Bech Seer Pin bo tatnetgens) ie ce D AGOTS Negligent Breach of ContractWeranty (no fraud) = oe D A6028 Other Breach of ContractWarranty (not fraud or regtigence) ee 3 nn : cant : aa 2 Att Oter Peay Nats Ce sn ° D A6036 Collections Case-Purchased | Dare hase OF Corgoner Debt 5.6.11 ah Tuer Cope) [a AT inne Cop tense : ar © Pete Coase 4285 oneconmcan — | att To efor . tas © Neer Cher Covet epotomacicencetetinrenae) —*|3.2389 wl rr worotisen ay [a Az Wienplevcioncoe ae (O AGO1 Mortgage Foreclosure: i 26 onereserneiya [oa nei ait Tie 28 2 eta Goer Papen ot eit don edt onde) | 2.6 | UASNEIDSRES-CORSHSS TG pret Unevtdereronmewaltmtaumrermeghiewson [60 urea ceaeer Rec! [sen Wray OeararReemarpcongermeecsin |e ei beare naeaaa ; punstoeones [ea aecacrunascencerboaroe 2at ee 2a LACIV 109 (Rew 2716) CIVIL CASE COVER ‘SHEET ADDENDUM Local Rule 23 LASC Approved 03-04 AND STATEMENT OF LOCATION oe Page 20f4 ‘oth 3 Page 24 ~ Bog 1D = 16965R5176 - Doe type - OmUERdeage 25 of 26) + [°° cindy Rueda CE Op Goda Combs Eneries, 1, ta = A B . C Applicable ‘cra case Cove Sheet 4 Typect Acton Resse See Sep 3 eaten : clean ‘ie TanPosaes) [0 Ave Aa efeure coe axe Petr Abita) | AIG Pettis GnmelGaowe Anion 28 i ati coat alii 3g Wt of Mandate (02), C ABIS2 Wit-Mandamus on Limted Court Case Matior 2 3 1 Ats9 Wit-Oter Ld Cou Cas Rew fe ‘eranscaroioncey [O ASKE0 Obert uselReiee 28 ¢_ [smarinarRepeionen [OAD ArtatTiac Renato Tae 2 3 | commamostaco |e sea comiioouea 123 a | CoaitonTor TS pace exes nung an tae : 8 Secutfes Ligation (28) |] 0 AGO3S Secures Liigation Case: 128 2 [entiaiday [2 08 Tetons 12a "fon Cone ween 0 AG014 Inqurance CoveragelSubrogation {complex case ony) 12588 fait SaerSaenanet oe peo Ab emt Dae ace pene EB | sme (2 pow somunsesneyanedteresanenen ge 1 Abit Petboncati arty of tones cn Urea Tx : 0 tt2 Otertneearart etn aes EDEN YO AS edcere ROD Go Tae : : a5 1D AStG0 Desay Ret 128 St alee peeves ze BS | itosettioss a | sects erconmersconran cue ootomrconla) sae eS (2 Asa00 Other Civ Complain (non toton- 2 1 reno Penner OmngeNanethnecl Gxt a 1 To Peston Reena Cn an aie 1 te cerca Pan i 2 LACIV 109 (Rew 216) CIVIL CASE COVER SHEET ADDENDUM: Local Rute 23 LASC Approved 03-04 AND STATEMENT OF LOCATION Page 3ot4 Deol’ Faget 25 - Deo 1D ~ 2696515476 - Doo type = OnERage 25 of 26) » FPP orn ccorantomtarpen nw ‘Step 4: Statement of Reason and Address: Check the appropriate boxes for the numbers shown under Column Cfor the type of action that you have selected. Enter the address which isthe basis for the fling locaton, including zip code. {Wo address required for class action cases). . a 5 EASON 3200 Sunsett Boulevard, Suite 300 01.02,03.04.08.08.07. 08.0 9.010.011. Wiest Holywood cA} 90069, Step 5: Certification of assignment: crt that this casei prope fled inthe Cental District of ‘the Superior Court of California, County of Ls Angeles (Code Cv. Proc, 6352 et seq, and Locale 23(a)()()). Dated: May 8, 2017 : ~ ' (RowTuRcorarTomon TAR PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY ‘COMMENCE YOUR NEW COURTCASE: * Original Complaint or Pettion. fling a Complaint completed Summons form fr issuance by the Clerk. ivi Case Cover Sheet, Judiciat Council fomn CM-010. . Givi Case Cover Sheet Addendum and Satemert of Location farm, LACIV 109, ASC Approved 05-04 (Rev ). Payment in fu ofthe fing fee, unless tier is cout anor for waver, part or scheduled payments 6. A signed order appointing the Guardian ad Litem, Judicial Councilform CIV-010, ifthe plait or petoneris a ‘minor under 18 years of age willbe required by Cour in order to issue a summons. 7. Additonal copies of documents to be conformed by the Clerk. Copies ofthe cover sheet and ths addendum I ‘must be served along with the summons and complaint or other intating pleading inthe ease, LGW 109 Ree) CIVIL CASE COVER SHEET ADDENDUM Local Rue 23 ASC Aproved 03-04 AND STATEMENT OF LOCATION Page aot Doct 1 Paget 26 - Goo Hm 1696518476 ~ Doo type ~ onmR