SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN MATEO GENERAL ALLEGATIONS

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1 COOLEY LLP PATRICK P. GUNN ( ) ( ABIGAIL E. PRINGLE () 1 California Street, th Floor San Francisco, CA 1-00 FILED Telephone: ( ) -00 SAN MATEO COUNY Facsimile: ( ) - Attorneys for Plaintiff TRESTLE GLEN ASSOCIATES Ales o JUL, U SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN MATEO XUIJ edor ourt TRESTLE GLEN ASSOCIATES, a California limited partnership, V. Plaintiff, SEGUE CONSTRUCTION, INC.; and DOES 1 through 0, inclusive, Defendants. Case No. glys' oe COMPLAINT FOR NEGLIGENCE; BREACH OF CONTRACT; BREACH OF PROFESSIONAL CONTRACT; BREACH OF EXPRESS WARRANTIES; BREACH OF IMPLIED WARRANTIES; AND BREACH OF THIRD PARTY BENEFICIARY OBLIGATION BY FAX Coop LLP ATTORNEYS AT LAN SAN FRANCISCO 1 Plaintiff Trestle Glen Associates, a California limited partnership ( " Trestle Glen" or Plaintiff') alleges as follows: GENERAL ALLEGATIONS 1. Plaintiff is, and at all times herein mentioned was, a business entity organized and existing under and by virtue of the laws of the State of California, and doing business in the State of California, County of San Francisco.. Plaintiff is informed and believes and thereon alleges that Defendant Segue Construction, Inc. ( " Segue ") is, and at all times mentioned herein was, a corporation organized and existing under and by the virtue the laws of the State of California, County of Alameda.. Plaintiff is ignorant of the true names and capacities of Defendants sued herein as Does 1 through 0, inclusive, and therefore sue these Defendants by such fictitious names. 1.

2 Plaintiff prays leave to amend this Complaint to allege their true names and capacities when the II same have been ascertained.. Plaintiff is informed and believes and thereon alleges that Segue and Does 1 through 0, and each of them, were involved, in some manner, with the design and construction of the one hundred nineteen unit complex located at 0 F Street, Colma, California, commonly referred to as the " Trestle Glen" ( the " Property ").. Defendant Segue provided general contracting services to Plaintiff with respect to the Property. Does 1 through 0, inclusive, are identified as " SUBCONTRACTORS" and participated in some manner in the construction of, or provision of labor and materials to construct the Property.. Does 1 through 0, inclusive, are identified as " SUPPLIERS" and participated in some manner in the manufacture and/ or supply of products used at and/ or installed at the Property.. Does 1 through 0, inclusive, are identified as " DESIGN PROFESSIONALS" and provided, in some manner,. engineering and/ or other professional design services for the Property. Where Plaintiff is required to file a Certificate of Merit regarding the allegations CooLEY LLP ATTORNEYS AT LAW SAN FYANCISCn 1 against Cross - Defendant DESIGN PROFESSIONALS, including Does 1 through 0, inclusive, such Certificates of Merit will be filed on said Cross - Defendant DESIGN PROFESSIONALS, including Does 1 through 0, inclusive, pursuant to California Code of Civil Procedure Section... Plaintiff is informed and believes and thereon alleges that at all times herein mentioned each Defendant was the agent and employee of each of the remaining Defendants, and was, at all times, acting within the purpose and scope of such agency and employment.. Plaintiff at all times herein mentioned was, and is, the owner of the Property.. Plaintiff is informed and believes and thereon alleges that Defendants, and each of them, including Does 1 through 0, and each of them, contributed to the design and/ or construction of the Property, in some manner, by performing work, providing services and/ or.

3 supplying materials related to the construction of the Property.. Plaintiff is informed and believes and thereon alleges that construction of the Property began approximately in August 0 and was substantially completed in January.. Plaintiff is informed and believes and thereon alleges that the Property was defectively designed and/ or constructed, that certain materials installed in, on or at the Property were and are defective, and that as a result, certain components of the Property are defective. Said defects have caused tangible property damage to the Property.. Within the last three ( ) years from the date of this Complaint, Plaintiff discovered that there were certain deficient conditions at the Property, resulting in water intrusion causing tangible property damage thereto. Specifically, Plaintiff is informed and believes, and based thereon alleges, that there are design and construction defects involving various components at the Property. FIRST CAUSE OF ACTION. Negligence Against Defendants Segue and Does 1-0). Plaintiff hereby realleges and incorporates by this reference each and every through, inclusive,,of its Complaint, as though fully set 1. At all times mentioned herein, Defendant Segue and Does 1-0, and each of them, owed an obligation and duty to Plaintiff that the work, labor, services, design services, consulting services, and materials employed and used in the construction of the Property would be performed in a workmanlike manner, in a manner consistent with requirements of a project of this nature, and in accordance with the appropriate standard of care.. - Defendants Segue and Does 1-0, and each of them, breached the duty owed to Plaintiff by performing work and/ or supplying the services, consulting services, labor and CODLEY LLP ATT1) RNv.YS AT LAW SAN FRANOSCn materials in such a manner as to allow tangible property damage to the Property.. As a direct and proximate result of the negligence of Defendants Segue and Does 1-0, Plaintiff has suffered damage in an amount to be shown according to proof at trial, including but not limited to the cost of repairing and replacing the defective materials and.

4 workmanship, testing and investigation of such defective materials and workmanship, lost rents and income, and professional fees and costs, as well as other incidental and consequential damages. WHEREFORE, Plaintiff prays for judgment against Defendants Segue and Does 1-0, and each of them, as hereinafter set forth. SECOND CAUSE OF ACTION Breach of Contract against Defendant Segue) 1. Plaintiff hereby realleges and incorporates by this reference each and every through, inclusive, of its Complaint, as though fully set. Plaintiff entered into a written contract ( "Contract') with Defendant Segue for the performance of general contracting services during construction of the Property.. In the Contract, Defendant Segue covenanted and warranted to Plaintiff that, among other things, all work. would be of good quality, free from faults and defects, and in conformance with the contract documents, and that work not conforming to those requirements may be considered defective. In addition, Plaintiff is informed and believe and thereon allege that, in the Contract, Defendant guaranteed to Plaintiff that its work at the Property was done in accordance with the drawings and specifications for the Property. 1. Plaintiff has fully performed all terms, conditions, covenants and promises required of it pursuant to the terms of the Contract, except those that have been discharged, CooLEYLLP ATwmmEyY AT LAW SAN FRANCISCO excused, waived or prevented.. Plaintiff is informed and believes and thereon alleges that Defendant Segue has breached the terms of the Contract by, among other things, failing to originally construct the improvements at the Property in accordance with the applicable plans, drawings, specifications and contract documents, failing to utilize its best skill and judgment in the performance of its work, and failing to use reasonable care and diligence in the supervision of subcontractors.. Plaintiff is informed and believe and thereon alleges that, as a direct and proximate result of the breaches by Defendant Segue, Plaintiff has been damaged in an amount to be shown.

5 according to proof at trial, including but not limited to the cost of repairing and replacing the defective materials and workmanship, testing and investigation of such defective materials and workmanship, lost rents and income, and professional fees and costs, as well as other incidental and consequential damages. WHEREFORE, Plaintiff prays for judgment against Defendant Segue, as hereinafter set I forth. THIRD CAUSE OF ACTION Breach of Professional Services Contract against Does 1-0). Plaintiff hereby realleges and incorporates by this reference each and every through, inclusive, of its Complaint, as though fully set. Plaintiff entered into contracts with DESIGN PROFESSIONALS, for the provision of design and/or engineering services related to construction of the Property ( " Design Contracts ").. Plaintiff is informed and believes and thereon alleges that, in the Design Contracts, Does 1-0 covenanted and warranted to Plaintiff that, among other things, all services would be performed with care, skill, and diligence in accordance with generally and currently accepted architectural and/ or engineering standards of practice. 1. Plaintiff has fully performed all terms, conditions, covenants, and promises CoOLEYLLP ATTORNEYS AT LAW SAN FRANCISCO required of it pursuant to the terms of the Design Contracts, except those that have been discharged, excused, waived or prevented.. Plaintiff is informed and believes and thereon alleges that Does 1-0 have breached the terms of the Design Contracts by, among other things, failing to originally design the improvements at the Property in a manner consistent with professional skill and the orderly progress of the Property, failing to utilize the professional care, skill, and diligence in accordance with generally and currently accepted standards of practice. 0. Plaintiff is informed and believe and thereon alleges that, as a direct and proximate result of the breaches by Does 1-0, and each of their respective breaches, Plaintiff has been. COMPLAINT FOR NEGLIGENCE; BREACH OF CONTRACT; BREACH OF PROFESSIONAL CONTRACT; BREACH OF EXPI

6 damaged in an amount to be shown according to proof at trial, including but not limited to, costs associated with repairs due to design deficiencies, testing and investigation of claims, lost rents and incomes, professional fees and costs, as well as other incidental and consequential damages. WHEREFORE, Plaintiff prays for judgment against Does 1-0, and each of them, as hereinafter set forth. FOURTH CAUSE OF ACTION Breach of Express Warranties against Defendant Segue) 1. Plaintiff hereby realleges and incorporates by this reference each and every through 0, inclusive, of its Complaint, as though fully set. The Contract between Plaintiff and Defendant Segue contains provisions in which Defendant Segue agreed that the work performed at the Property would be free from defects, that the work would conform to the requirements of the Contract, that the Property would be developed and/ or constructed in a good and workmanlike manner and in accordance with proper construction practices, and/ or that material used would be merchantable, fit for the intended purpose, and free from defects.. Plaintiff relied on the written express warranties set forth in the Contract.. Plaintiff has reasonably notified Defendant Segue of the breach of the express COOLEYLLP ATTORN /.TA AT LAW AN FRANCISCO 1 warranties.. Plaintiff is informed and believes and thereon alleges that Defendant Segue has breached these express warranties, as the work was not free from defects and failed to conform to the requirements of the Contract.. Defendant Segue has been notified of the deficiencies which constitute the breaches of warranty alleged herein.. Plaintiff is informed and believes and thereon alleges that, as a direct and proximate result of the aforementioned breaches of express warranty by Defendant Segue, Plaintiff has been damaged in an amount to be shown according to proof at trial, including but not limited to the costs of repairing and replacing the defective materials and workmanship, testing.

7 and investigation of such defective materials and workmanship, lost rents and income, and professional fees and costs, as well as other incidental and consequential damages. WHEREFORE, Plaintiff prays for judgment against Defendant Segue, as hereinafter set forth. FIFTH CAUSE OF ACTION Breach of Implied Warranties against Defendant Segue). Plaintiff hereby realleges and incorporates by this reference each and every through, inclusive, of its Complaint, as though fully set COOLEYLLP ATTI. YNEVS AT LAW SAN Fw ' Isco 1. Plaintiff is informed and believes and thereon alleges that, at all times mentioned herein, Defendant Segue, in designing, manufacturing, supplying and/ or distributing building materials, components or other supplies utilized in the construction of the Property, impliedly warranted that all such goods and materials were of merchantable quality, fit for their intended purpose and were free from any defects in design or manufacture. 0. Plaintiff relied on the skill of Defendant Segue to develop and/ or construct the Property in a manner which would be fit for the intended purposes, and/ or to manufacture or supply material fit for the intended purpose, merchantable, and free from defects. 1. Plaintiff is informed and believes and thereon alleges that Defendant Segue breached its implied warranties by failing to develop and/ or construct the Property in a manner fit for the intended purpose, and/ or by failing to manufacture or supply material fit for the intended purpose, merchantable, and free from defects.. Defendant Segue has been notified of the deficiencies which constitute the breaches of warranty alleged herein.. Plaintiff is informed and believes and thereon alleges that, as a direct and proximate result of the aforementioned breaches of implied warranty by Defendant Segue, Plaintiff has been damaged in an amount to be shown according to proof at trial, including but not limited to the costs of repairing and replacing the defective materials and workmanship, testing and investigation of such defective materials and workmanship, lost rents and income, and.

8 professional fees and costs, as well as other incidental and consequential damages. WHEREFORE, Plaintiff prays for judgment against Defendant Segue, as hereinafter set I forth. SIXTH CAUSE OF ACTION Breach of Third - Party- Beneficiary Obligation against Subcontractors (Does 1-0). Plaintiff hereby realleges and incorporates by this reference, each and every through, inclusive, of its Complaint, as though fully set. Plaintiff is informed and believes and thereon alleges that subsequent to entering into the Contract with Defendant Segue, Segue entered into various subcontract agreements with Subcontractor Does 1-0, and each of them, to construct certain portions of the Property.. Plaintiff is further informed and believes and thereon alleges that under the terms of the written subcontract agreements entered into between Defendant Segue and Does 1-0, and 1 each of them, Does 1-0 warranted that the work performed under their respective written subcontract agreements would be free from all material defects and in compliance with the contract documents and/ or building codes.. Plaintiff is further informed and believes and thereon alleges that at the time the written subcontract agreements were entered into by and between Defendant Segue and Does 1-0, and each of them, Does 1-0 understood that Defendant Segue intended to benefit the owner of the Property, through the performance of the written subcontract agreements.. Does 1-0, and each of them, breached their written subcontract agreements by failing to perform all work associated with the Property in a workmanlike manner and accordance with the terms of the contract agreements. in CwLEY LLP ATTOMF.YS AT LAW SAN FtANf1AC[. As a direct and proximate result of the breaches by and Does 1-0, and each of them, Plaintiff, as the intended beneficiary of the written subcontract agreements, has been damaged in an amount to be shown according to proof of trial, including, but not limited to, the cost of repairing and replacing the defective materials and workmanship, testing and investigation of such defective materials and workmanship, lost rents and incomes, professional fees and costs,.

9 as well as other incidental and consequential damages. WHEREFORE, Plaintiff prays for judgment against Does 1-0, and each of them, as hereinafter set forth. PRAYER ON ALL CAUSES OF ACTION: 1. For general and special damages according to proof;. For cost of suit incurred;. For interest at the maximum legal rate;. For attorneys' fees as provided in the applicable Contruction Contracts, and. For such other and further relief as the Court deems just and proper. Dated: July 0, COOLEY LLP PATRICK P. GUNN ( ) By: Patrick P. Gunn ( ) Attorneys for Plaintiff TRESTLE GLEN ASSOCIATES, a California limited partnership 1, 0/SF COOLEYLLP ATTORNFrc AT LAW SAN FRANIISCit.

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