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

Size: px
Start display at page:

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

Transcription

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.

SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SOMEWHERE ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SOMEWHERE ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Harvey C. Berger (SBN POPE & BERGER 0 West "C" Street, Suite 100 San Diego, California 1 Telephone: (1-1 Facsimile: (1 - Attorneys for Plaintiff PLAINTIFF SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND

More information

Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA LOS ANGELES COUNTY CENTRAL DISTRICT STANLEY MOSK COURTHOUSE

Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA LOS ANGELES COUNTY CENTRAL DISTRICT STANLEY MOSK COURTHOUSE VACHON LAW FIRM Michael R. Vachon, Esq. (SBN ) 0 Via Del Campo, Suite San Diego, California Tel.: () -0 Fax: () - Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA LOS ANGELES COUNTY CENTRAL

More information

No. 45TH. Plaintiff EDGEWOOD INDEPENDENT SCHOOL DISTRICT files its Original Petition

No. 45TH. Plaintiff EDGEWOOD INDEPENDENT SCHOOL DISTRICT files its Original Petition FILED 9/24/2014 10:11:33 AM Donna Kay McKinney Bexar County District Clerk Accepted By: Roxanne Mujica 2014CI15241 No. W/ JD EDGEWOOD INDEPENDENT SCHOOL DISTRICT v. Plaintiff, KOONTZ/MCCOMBS CONSTRUCTION,

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA Jack Anderson, Esq. SBN 0 JACK ANDERSON, ESQ., APLC Balboa Avenue, Suite E San Diego, California Tel.: ( - Fax: ( 0- jackandersonaplc@yahoo.com Attorney for Defendant and Cross-Complainant Starline Windows,

More information

SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES

SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES (SPACE BELOW FOR FILING STAMP ONLY) LAW FIRM OF KAISER, DEBIASO. ANDREW AND SWINDELLS SUMfTOMO TOWER NINTH FLOOR 444 WEST OCEAN BOULEVARD LONG BEACH, CALIFORNIA 90802-4516 (310) 590-8471 ERIC C. DEMLER

More information

1 2 3 4 5 [ATTORNEY NAME] (ATTORNEY STATE BAR NUMBER) [ATTORNEY EMAIL ADDRESS] [LAW FIRM NAME] [LAW FIRM STREET ADDRESS] [LAW FIRM CITY/STATE/ZIP CODE] [LAW FIRM TELEPHONE NUMBER] [LAW FIRM FAX NUMBER]

More information

Case No.: CLASS ACTION COMPLAINT FOR BREACH OF IMPLIED WARRANTY OF WORKMANSHIP AND HABITABILITY. Plaintiffs,

Case No.: CLASS ACTION COMPLAINT FOR BREACH OF IMPLIED WARRANTY OF WORKMANSHIP AND HABITABILITY. Plaintiffs, 1 1 1 1 1 1 0 1 Stephen L. Weber, Esq. (AZ SBN 01) Michael J. White, Esq. (AZ SBN 01) James W. Fleming, Esq. (AZ SBN 0) KASDAN SIMONDS WEBER & VAUGHAN LLP 00 N. Central Ave., Suite 0 Phoenix, AZ 0 E-Mail:

More information

Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA SAN BERNARDINO COUNTY CIVIL DIVISION. MARIA GODINEZ, an individual,

Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA SAN BERNARDINO COUNTY CIVIL DIVISION. MARIA GODINEZ, an individual, VACHON LAW FIRM Michael R. Vachon, Esq. (SBN ) 0 Via Del Campo, Suite San Diego, California Tel.: () -0 Fax: () - Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA SAN BERNARDINO COUNTY

More information

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO, WEST DISTRICT 9 10 11 12 13 14 15 16 17 18

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO, WEST DISTRICT 9 10 11 12 13 14 15 16 17 18 JAMES W. JOHNSTON ATTORNEY AT LAW 00 S. Flower Street, Suite 10 Los Angeles, California 001 State Bar No. (1) 1- Attorney for Plaintiff IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO,

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ALAMEDA

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ALAMEDA JOHN A. RUSSO, City Attorney (SBN ) RANDOLPH W. HALL, Chief Asst. City Attorney (SBN 00) JAMES F. HODGKINS, Supervising Trial Attorney (SBN 1) One Frank H. Ogawa Plaza, th Floor Oakland, California Telephone:

More information

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SOLANO. Defendants. ) THE PARTIES

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SOLANO. Defendants. ) THE PARTIES '. 1 6 MILLSTONE PETERSON & WATTS, LLP Attorneys at Law GLENN W. PETERSON, ESQ (SBN 6 Lava Ridge Court, Suite Roseville, CA 661 Phone: -80-8 Fax: -80-8 Attorneys for Plaintiff Otto W. Giuliani ENDORSED

More information

FILED: NEW YORK COUNTY CLERK 01/17/2014 INDEX NO. 650177/2014 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/17/2014

FILED: NEW YORK COUNTY CLERK 01/17/2014 INDEX NO. 650177/2014 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/17/2014 FILED NEW YORK COUNTY CLERK 01/17/2014 INDEX NO. 650177/2014 NYSCEF DOC. NO. 1 RECEIVED NYSCEF 01/17/2014 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK - - - - - - - - - - - - - - - - - - -

More information

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN FRANCISCO UNLIMITED CIVIL CASE

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN FRANCISCO UNLIMITED CIVIL CASE Christopher B. Dolan (SBN ) Shawn R. Miller (SBN ) Market Street San Francisco, CA Tel: () -00 Fax: () -0 Attorneys for Plaintiff CHARLENE HASTINGS IN SUPERIOR COURT OF STATE OF CALIFORNIA IN AND FOR COUNTY

More information

-1- SECOND AMENDED COMPLAINT

-1- SECOND AMENDED COMPLAINT VACHON LAW FIRM Michael R. Vachon, Esq. (SBN ) 0 Via Del Campo, Suite San Diego, California Tel.: () -0 Fax: () - Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES

More information

Case 3:10-cv-02236-DRD Document 31 Filed 05/05/11 Page 1 of 9

Case 3:10-cv-02236-DRD Document 31 Filed 05/05/11 Page 1 of 9 Case 3:10-cv-02236-DRD Document 31 Filed 05/05/11 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO DAVID ASHE Plaintiff, CIVIL NO. 10-2236 ( DRD ) vs. DISTRIBUIDORA NORMA,

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN DIEGO

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN DIEGO 1 0 1 MARC D. ADELMAN Attorney at Law State Bar No. Liberty Station Historic Decatur Road, Suite 00 San Diego, CA - (1) -0 Phone (1) -0 Fax Email: AdelmanMD@aol.com Attorney for Plaintiff SUPERIOR COURT

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN DIEGO - CENTRAL DIVISION. Plaintifl. Defendants.

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN DIEGO - CENTRAL DIVISION. Plaintifl. Defendants. 1 EDMUND G. BROWN JR. Attorney General of California CATHERINE Z. YSRAEL Supervising Deputy Attorney General JUDITH FIORENTINI Deputy Attorney General State Bar No. 1 West A Street, Suite 10 San Diego,

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN BERNARDINO

SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN BERNARDINO 1 1 1 1 1 1 1 1 0 1 LAW OFFICES OF FERNANDO F. CHAVEZ Fernando Fabela Chavez, Esq., (SBN: 0 10 The Alameda #01 San Jose, CA 1 (0 1-0 Telephone / (0 1-0 Facsimile Attorneys for Plaintiffs GUILLERMINA MORALES

More information

THE STATE OF MINNESOTA TO THE ABOVE-NAMED DEFENDANTS: the Complaint which is herewith served upon you within twenty (20) days after the service of

THE STATE OF MINNESOTA TO THE ABOVE-NAMED DEFENDANTS: the Complaint which is herewith served upon you within twenty (20) days after the service of STATE OF MINNESOTA COUNTY OF DAKOTA DISTRICT COURT FIRST JUDICIAL DISTRICT CASE TYPE: Personal Injury ERIC GUSTAFSON and JENNIFER GUSTAFSON, Individually and as parents and natural guardians for CALLIE

More information

COMPLAINT. Plaintiff [PLAINTIFF] hereby sues the Defendants, [DEFENDANT #1], [DEFENDANT INTRODUCTION

COMPLAINT. Plaintiff [PLAINTIFF] hereby sues the Defendants, [DEFENDANT #1], [DEFENDANT INTRODUCTION Form 2:40-2 Complaint Negligence, Motor Vehicle IN THE CIRCUIT COURT OF THE ## JUDICIAL CIRCUIT IN AND FOR [COUNTY], FLORIDA [PLAINTIFF], Plaintiff, CASE NO.: ##-##### ## ## GENERAL JURISDICTION vs. [DEFENDANT

More information

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION COMPLAINT

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION COMPLAINT IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION Plaintiff, CASE NUMBER: JUDGE: vs. Defendant. / COMPLAINT COMES NOW, Plaintiff,, and hereby sues

More information

Case 15-02065 Doc 1 Filed 04/07/15 Entered 04/07/15 11:42:31 Desc Main Document Page 1 of 13

Case 15-02065 Doc 1 Filed 04/07/15 Entered 04/07/15 11:42:31 Desc Main Document Page 1 of 13 Document Page 1 of 13 George Hoffman (10005) Benjamin J. Kotter (9592) Adam H. Reiser (13339) COHNE KINGHORN, P.C. 111 East Broadway, 11 th Floor Salt Lake City, Utah 84111 Telephone: (801) 363-4300 Facsimile:

More information

Attorneys for Plaintiff People of the State of California FOR THE COUNTY OF ORANGE. Defendants.

Attorneys for Plaintiff People of the State of California FOR THE COUNTY OF ORANGE. Defendants. BILL LOCKYER, Attorney General of the State of California HERSCHEL T. ELKINS Senior Assistant Attorney General ALBERT NORMAN SHELDEN Supervising Deputy Attorney General HOWARD WAYNE (State Bar No. ) Deputy

More information

FILED 15 JUL 27 AM 9:22

FILED 15 JUL 27 AM 9:22 FILED JUL AM : KING COUNTY SUPERIOR COURT CLERK E-FILED CASE NUMBER: --- KNT JUDITH JORGENSEN, vs. SUPERIOR COURT OF WASHINGTON KING COUNTY Plaintiff, JAMES WONG and TYRA WONG, husband and wife creating

More information

Filing # 40778264 E-Filed 04/27/2016 11:43:26 AM

Filing # 40778264 E-Filed 04/27/2016 11:43:26 AM Filing # 40778264 E-Filed 04/27/2016 11:43:26 AM THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA VILLAS AT CYPRESS SPRINGS HOMEOWNERS ASSOCIATION, INC. Case No.: Plaintiff,

More information

Authority for the County Attorney to Initiate Litigation in the Case of Pinellas County v. Verizon Florida, LLC

Authority for the County Attorney to Initiate Litigation in the Case of Pinellas County v. Verizon Florida, LLC TO: FROM: SUBJECT: The Honorable Chairman and Members of the Board of County Commissioners James L. Bennett, County Attorney Authority for the County Attorney to Initiate Litigation in the Case of Pinellas

More information

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA Case:-cv-0 Document Filed0// Page of 0 0 LAKESHORE LAW CENTER Jeffrey Wilens, Esq. (State Bar No. 0 0 Yorba Linda Blvd., Suite 0-0 Yorba Linda, CA --0 --0 (fax jeff@lakeshorelaw.org Attorney and Plaintiff

More information

SETTLEMENT AGREEMENT AND RELEASE

SETTLEMENT AGREEMENT AND RELEASE SETTLEMENT AGREEMENT AND RELEASE This Settlement Agreement and Release (hereinafter "the Agreement") is entered into by and between Plaintiff, CITY OF PIEDMONT, CALIFORNIA, and its respective City entities,

More information

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO UNLIMITED JURISDICTION

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO UNLIMITED JURISDICTION JAMES C. STURDEVANT (SBN 94551 JESPER I. RASMUSSEN (SBN 121001 THE STURDEVANT LAW FIRM A Professional Corporation 475 Sansome Street, Suite 1750 San Francisco, California 94111 Telephone: (415 477-2410

More information

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case :-cv-0 Document Filed 0/0/ Page of 0 0 JANET M. HEROLD Regional Solicitor IAN H. ELIASOPH (CSBN Counsel for ERISA GRACE A. KIM, Trial Attorney (CSBN Office of the Solicitor United States Department

More information

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES 9 10 11 12 13 14 15 16 17 18

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES 9 10 11 12 13 14 15 16 17 18 JAMES W. JOHNSTON ATTORNEY AT LAW 00 S. Flower Street, Suite 00 Los Angeles, California 001 State Bar No. (1) 1- Attorney for Plaintiff IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES

More information

CONSULTING SERVICES AGREEMENT

CONSULTING SERVICES AGREEMENT CONSULTING SERVICES AGREEMENT THIS AGREEMENT ("Agreement") is entered into on / /, between SCWOA ("Consultant"), a CA corporation with its principal place of business located at PO Box 1195, Pacifica,

More information

California Civil Code 2782.05

California Civil Code 2782.05 California Civil Code 2782.05 (a) Except as provided in subdivision (b), provisions, clauses, covenants, and agreements contained in, collateral to, or affecting any construction contract and amendments

More information

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF UTAH, CENTRAL DIVISION. In Re: Bankruptcy No. 09-26549. (Chapter 11) Filed Electronically

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF UTAH, CENTRAL DIVISION. In Re: Bankruptcy No. 09-26549. (Chapter 11) Filed Electronically Document Page 1 of 16 Steven C. Tycksen, #3300 Chad Shattuck, #9345 TYCKSEN & SHATTUCK, L.C. 12401 South 450 East, Unit E1 Draper, Utah 84020 Telephone: 801-748-4081 Facsimile: 801-748-4087 steve@tyshlaw.com

More information

Filing # 22009228 Electronically Filed 12/29/2014 03:48:06 PM

Filing # 22009228 Electronically Filed 12/29/2014 03:48:06 PM Filing # 22009228 Electronically Filed 12/29/2014 03:48:06 PM PENELOPE BELVOIR, as Executor de son Tort for the Pending Estate of Robert Belvoir, Deceased, vs. Plaintiff, ROPES COURSES, INC., FB ORLANDO

More information

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON AT SEATTLE NO. Defendant

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON AT SEATTLE NO. Defendant William D. Marler Marler Clark LLP PS 01 Second Ave, Suite 00 Seattle, WA 1-0 Ph: IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON AT SEATTLE DOROTHY H. PEARCE, vs. Plaintiff,

More information

DATED: April 29, 2002 BARRY NOVACK

DATED: April 29, 2002 BARRY NOVACK BLANCHARD E. TUAL, Administrator CASE NO. EC 034380 of the Estate of BONNY LEE BAKLEY on behalf of the Heirs of COMPLAINT FOR DAMAGES FOR said Decedent, WRONGFUL DEATH Plaintiff, vs. ROBERT BLAKE, aka

More information

Case 2:11-cv-02535-GMS Document 1 Filed 12/21/11 Page 1 of 11

Case 2:11-cv-02535-GMS Document 1 Filed 12/21/11 Page 1 of 11 Case :-cv-0-gms Document Filed // Page of 0 LAWRENCE BREWSTER Regional Solicitor DANIELLE L. JABERG Counsel for ERISA CA State Bar No. KATHERINE M. KASAMEYER Trial Attorney CA State Bar No. Office of the

More information

CASE NO.: COMPLAINT. Plaintiff, [PLAINTIFF S NAME], by and through her parent and natural guardian

CASE NO.: COMPLAINT. Plaintiff, [PLAINTIFF S NAME], by and through her parent and natural guardian Form 2:150 Dog Bite Sample Complaint IN THE CIRCUIT COURT OF THE TH JUDICIAL CIRCUIT IN AND FOR COUNTY, FLORIDA [PLAINTIFF S NAME], by and through her parent and natural guardian, [PLAINTIFF S PARENT S

More information

Case 2:12-cv-02025-JWL-JPO Document 7 Filed 02/10/12 Page 1 of 17 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

Case 2:12-cv-02025-JWL-JPO Document 7 Filed 02/10/12 Page 1 of 17 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS Case 2:12-cv-02025-JWL-JPO Document 7 Filed 02/10/12 Page 1 of 17 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS HOSPITAL DISTRICT NO.1 OF CRAWFORD COUNTY, KANSAS, d/b/a, GIRARD MEDICAL

More information

INDEPENDENT CONTRACTOR AGREEMENT (ICA)

INDEPENDENT CONTRACTOR AGREEMENT (ICA) INDEPENDENT CONTRACTOR AGREEMENT (ICA) (This agreement is not a construction contract within the meaning of Civil Code section 2783, and is not an agreement for the provision of construction services within

More information

Case: 1:15-cv-00608 Document #: 1 Filed: 01/21/15 Page 1 of 5 PageID #:1

Case: 1:15-cv-00608 Document #: 1 Filed: 01/21/15 Page 1 of 5 PageID #:1 Case: 1:15-cv-00608 Document #: 1 Filed: 01/21/15 Page 1 of 5 PageID #:1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION TRAVELERS CASUALTY AND SURETY COMPANY

More information

STATE OF WISCONSIN CIRCUIT COURT KENOSHA COUNTY BRANCH CASE NO. Plaintiff,

STATE OF WISCONSIN CIRCUIT COURT KENOSHA COUNTY BRANCH CASE NO. Plaintiff, STATE OF WISCONSIN CIRCUIT COURT KENOSHA COUNTY BRANCH Denis W. Stearns, Wis. Bar No. 1020675 MARLER CLARK, L.L.P., P.S. 701 Fifth Avenue, Suite 6600 Seattle, WA 98104 Telephone: (206) 346-1888 Facsimile:

More information

CIVIL ACTION COMPLAINT

CIVIL ACTION COMPLAINT Gregg D. Trautmann, Esq. TRAUTMANN PRYOR & LUTHER, LLC 262 East Main Street Rockaway, NJ 07866 (973) 316-8100 Attorney for Plaintiff ROBYN KLEINHANS Plaintiff vs. RALPH CLAYTON AND SONS, INC. (A New Jersey

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ............... Attorneys for Estate Representative SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF Estate of CASE NO... WAIVER OF ACCOUNTING AND PETITION.., FOR FINAL DISTRIBUTION; STATUTORY

More information

vs. JURY TRIAL DEMANDED COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL Plaintiff JAMES SCHAIRER, by and through undersigned counsel, hereby sues

vs. JURY TRIAL DEMANDED COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL Plaintiff JAMES SCHAIRER, by and through undersigned counsel, hereby sues IN THE CIRCUIT COURT OF THE th 16 JUDICIAL CIRCUIT IN AND FOR MONROE COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO. JAMES SCHAIRER, individually, Plaintiff, vs. JURY TRIAL DEMANDED PAUL KERCHER,

More information

Case 14-90056-LT Filed 05/14/14 Entered 05/14/14 14:14:36 Doc 6 Pg. 1 of 13

Case 14-90056-LT Filed 05/14/14 Entered 05/14/14 14:14:36 Doc 6 Pg. 1 of 13 Case -00-LT Filed 0// Entered 0// :: Doc Pg. of NANCY L. STAGG, CA Bar No. 0 nstagg@foley.com MATTHEW J. RIOPELLE, CA Bar No. 0 mriopelle@foley.com FOLEY & LARDNER LLP VALLEY CENTRE DRIVE, SUITE 00 SAN

More information

CONSULTANT AGREEMENT

CONSULTANT AGREEMENT Douglas County School District Re.1 Castle Rock, Colorado CONSULTANT AGREEMENT This agreement, dated effective as of is made and entered into by and between the Douglas County School District Re.1, Douglas

More information

Case 2:10-cv-01224-JCM-LRL Document 1 Filed 07/22/10 Page 1 of 8

Case 2:10-cv-01224-JCM-LRL Document 1 Filed 07/22/10 Page 1 of 8 Case :0-cv-0-JCM-LRL Document Filed 0//0 Page of Reno, NV ( -00 Fax ( 0-0 0 Mark R. Thierman, NV# laborlawyer@pacbell.net THIERMAN LAW FIRM, P.C. Reno, Nevada Tel: ( -00 Fax: ( 0-0 David R. Markham, CAL#

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES Fernando F. Chavez, Esq. SBN 0 CHAVEZ LAW GROUP 00 West Beverly Blvd., Montebello, Ca 00 Phone: () 00-0, Facsimile: (0) 1-01 E-mail: ffchavez0@gmail.com Attorneys for Plaintiffs SUPERIOR COURT OF THE STATE

More information

The Honorable Chairman and Members of the Board of County Commissioners

The Honorable Chairman and Members of the Board of County Commissioners TO: FROM: The Honorable Chairman and Members of the Board of County Commissioners James L. Bennett, County Attorney ~ COMMISSION AGENDA,#':.ett~ -:# /H, SUBJECT: DATE: Notice ofnew Lawsuit and Defense

More information

SETTLEMENT AGREEMENT AND MUTUAL RELEASE OF CLAIMS

SETTLEMENT AGREEMENT AND MUTUAL RELEASE OF CLAIMS SETTLEMENT AGREEMENT AND MUTUAL RELEASE OF CLAIMS This Settlement Agreement ( Agreement ) is entered into by and between The LAPD Newton Area Police Activities League, Inc. ( Plaintiff ) and the City of

More information

IN THE CIRCUIT COURT OF THE NINTH JUDICAL CIRCUIT IN AND FOR ORANGE COUNTY FLORIDA. Case No.

IN THE CIRCUIT COURT OF THE NINTH JUDICAL CIRCUIT IN AND FOR ORANGE COUNTY FLORIDA. Case No. IN THE CIRCUIT COURT OF THE NINTH JUDICAL CIRCUIT IN AND FOR ORANGE COUNTY FLORIDA SUZANNE MATTEIS, Plaintiff, DARDEN CORPORATION, a Florida Corporation. v. Case No. COMPLAINT FOR DAMAGES FOR PERSONAL

More information

CITY OF FIFE PERFORMANCE & PAYMENT BOND WITH GUARANTY

CITY OF FIFE PERFORMANCE & PAYMENT BOND WITH GUARANTY CITY OF FIFE PERFORMANCE & PAYMENT BOND WITH GUARANTY Name of Project Contractor(Principal) Project/Contract # Surety Bond Amount $ Bond # 1. Date and Parties This performance and payment bond with guaranty

More information

IN THE SUPERIOR COURT OF CHATHAM COUNTY STATE OF GEORGIA

IN THE SUPERIOR COURT OF CHATHAM COUNTY STATE OF GEORGIA IN THE SUPERIOR COURT OF CHATHAM COUNTY STATE OF GEORGIA ROBERT DOWSE AND URSULA DOWSE ) ) Plaintiffs, ) v. ) CIVIL ACTION NUMBER: ) CV99-0302-BA ) SOUTHERN GUARANTY INSURANCE ) COMPANY ) ) Defendant,

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF MONTEREY. No.

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF MONTEREY. No. TREVOR A. GRIMM, State Bar No. JONATHAN M. COUPAL, State Bar No. 1 TIMOTHY A. BITTLE, State Bar No. 00 Howard Jarvis Taxpayers Foundation 1 Eleventh Street, Suite 1 Sacramento, CA 1 (1-0 Attorneys for

More information

Complaint as permitted by Case Management Order # 4 and Implementing Order PARTIES, JURISDICTION AND VENUE

Complaint as permitted by Case Management Order # 4 and Implementing Order PARTIES, JURISDICTION AND VENUE [INSERT NAME], Plaintiff(s) vs. HOWMEDICA OSTEONICS CORPORATION, a New Jersey Corporation, d/b/a STRYKER ORTHOPAEDICS, JILL DOE MANUFACTURERS (1-10), JACK DOE WHOLESALERS (1-10), JAKE DOE SELLERS (1-10),

More information

Case5:15-cv-03698-HRL Document1 Filed08/12/15 Page1 of 10

Case5:15-cv-03698-HRL Document1 Filed08/12/15 Page1 of 10 Case:-cv-0-HRL Document Filed0// Page of 0 Donald E. J. Kilmer, Jr. [SBN: ] LAW OFFICES OF DONALD KILMER Willow Street, Suite 0 San Jose, California Voice: (0) - Fax: (0) - E-Mail: Don@DKLawOffice.com

More information

NOTICE OF PROPOSED CLASS ACTION SETTLEMENT

NOTICE OF PROPOSED CLASS ACTION SETTLEMENT Patricia Buzenes v. Nuvell Financial Services LLC, et al. Los Angeles County Superior Court, Case No. BC407366 The Court ordered this Notice This is not a solicitation from a lawyer and You are not being

More information

Return completed applications to: APAC-Texas, Inc. P.O. Box 20779 Beaumont, TX 77720 (409) 866-1444 Phone (409) 866-5541 Fax

Return completed applications to: APAC-Texas, Inc. P.O. Box 20779 Beaumont, TX 77720 (409) 866-1444 Phone (409) 866-5541 Fax Return completed applications to: APAC-Texas, Inc. P.O. Box 20779 Beaumont, TX 77720 (409) 866-1444 Phone (409) 866-5541 Fax APPLICATION FOR BUSINESS CREDIT Date: NOTE: This application for Business Credit

More information

SUPERIOR COURT FOR THE STATE OF CALIFORNIA IN THE COUNTY OF ORANGE. Plaintiffs, Defendants

SUPERIOR COURT FOR THE STATE OF CALIFORNIA IN THE COUNTY OF ORANGE. Plaintiffs, Defendants BRODIE & FLOCKHART MICHAEL A. BRODIE (State Bar No. 0) MONICA M. FLOCKHART (State Bar No. 1001) Chardonnay Irvine, California Telephone No. () - / Facsimile No. () 1- Attorneys for Plaintiffs, TAYLEE BLISCHKE,

More information

Case 3:14-cv-00137-AC Document 10 Filed 03/26/14 Page 1 of 14 Page ID#: 43

Case 3:14-cv-00137-AC Document 10 Filed 03/26/14 Page 1 of 14 Page ID#: 43 Case 3:14-cv-00137-AC Document 10 Filed 03/26/14 Page 1 of 14 Page ID#: 43 Calvin L. Keith, OSB No. 814368 CKeith@perkinscoie.com Sarah J. Crooks, OSB No. 971512 SCrooks@perkinscoie.com PERKINS COIE LLP

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. INFANT SWIMMING RESEARCH, INC., v. Plaintiff, FAEGRE & BENSON, LLP, MARK FISCHER, JUDY HEUMANN, NORMAN HEUMANN, BOULDER

More information

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA Case:-cv-0 Document Filed0// Page of Michael Millen Attorney at Law (#) Calle Marguerita Ste. 0 Telephone: Fax: (0) -0 mikemillen@aol.com Attorney for Plaintiff UNITED STATES DISTRICT COURT NORTHERN DISTRICT

More information

Case 3:08-cv-00920-JAP-JJH Document 1 Filed 02/20/2008 Page 1 of 13 UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY ) ) ) ) ) ) ) ) ) ) ) ) ) )

Case 3:08-cv-00920-JAP-JJH Document 1 Filed 02/20/2008 Page 1 of 13 UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case 3:08-cv-00920-JAP-JJH Document 1 Filed 02/20/2008 Page 1 of 13 Laurence M. Rosen, Esq. THE ROSEN LAW FIRM, P.A. 236 Tillou Road South Orange, NJ 07079 Telephone: (973 313-1887 Fax: (973 833-0399 lrosen@rosenlegal.com

More information

Case 3:10-cv-01946-SRU Document 1 Filed 12/10/10 Page 1 of 9 UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT : : : : : : : : : : : : : : :

Case 3:10-cv-01946-SRU Document 1 Filed 12/10/10 Page 1 of 9 UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT : : : : : : : : : : : : : : : Case 310-cv-01946-SRU Document 1 Filed 12/10/10 Page 1 of 9 UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT TRAVELERS CASUALTY AND SURETY COMPANY as successor to THE AETNA CASUALTY AND SURETY CO.,

More information

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR DAMAGES

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR DAMAGES IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION WAYNE WILLIAMS, on behalf of himself and all others similarly situated, v. Plaintiff, PROTECT SECURITY, LLC. Defendant.

More information

Case3:15-cv-03986-JCS Document1 Filed09/01/15 Page1 of 11 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

Case3:15-cv-03986-JCS Document1 Filed09/01/15 Page1 of 11 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA Case:-cv-0-JCS Document Filed0/0/ Page of KRONENBERGER ROSENFELD, LLP Karl S. Kronenberger (Bar No. ) Jeffrey M. Rosenfeld (Bar No. ) Ansel J. Halliburton (Bar No. 0) 0 Post Street, Suite 0 San Francisco,

More information

IN THE CIRCUIT COURT OF THE THIRD CIRCUIT STATE OF HAWAII ) ) ) ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF

IN THE CIRCUIT COURT OF THE THIRD CIRCUIT STATE OF HAWAII ) ) ) ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF ROBERT D.S. KIM A Law Corporation Attorney At Law ROBERT D.S. KIM 4255-0 77-6400 Nalani Street, Suite A-1 Kailua-Kona, Hawaii 96740 Telephone (808 329-6611 Attorney for Plaintiffs IN THE CIRCUIT COURT

More information

Kaskaskia Tool & Machine, Inc. Purchase Order Terms & Conditions

Kaskaskia Tool & Machine, Inc. Purchase Order Terms & Conditions The following terms and conditions provide Standard suppliers with the guidelines and legal stipulations of our purchase order contract. 1. Agreement. This Purchase Order ("Order") is Kaskaskia Tool &

More information

M AINTENANCE S ERVICE A GREEMENT L ABOR O NLY

M AINTENANCE S ERVICE A GREEMENT L ABOR O NLY M AINTENANCE S ERVICE A GREEMENT L ABOR O NLY This Maintenance Service Agreement ("Agreement") is entered into as of the day of, 2002 between, (the "Client"), whose address is, and Florida Sound Engineering

More information

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA Case :-cv-000-jah -CAB Document Filed 0// Page of 0 Joshua B. Swigart, Esq. (SBN: ) josh@westcoastlitigation.com Robert L. Hyde, Esq. (SBN: ) bob@westcoastlitigation.com Hyde & Swigart Camino Del Rio South,

More information

Case: 3:12-cv-00012-wmc Document #: 1 Filed: 01/05/12 Page 1 of 11 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WISCONSIN. Defendants.

Case: 3:12-cv-00012-wmc Document #: 1 Filed: 01/05/12 Page 1 of 11 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WISCONSIN. Defendants. Case: 3:12-cv-00012-wmc Document #: 1 Filed: 01/05/12 Page 1 of 11 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WISCONSIN FATWALLET, INC., a Delaware corporation, v. ANDREW CHIU, an individual, and

More information

2006 WL 6142740 (Miss.Cir.) (Trial Pleading) Circuit Court of Mississippi. Lee County. No. CV05-045 (A)L. June 12, 2006. Second Amended Complaint

2006 WL 6142740 (Miss.Cir.) (Trial Pleading) Circuit Court of Mississippi. Lee County. No. CV05-045 (A)L. June 12, 2006. Second Amended Complaint 2006 WL 6142740 (Miss.Cir.) (Trial Pleading) Circuit Court of Mississippi. Lee County Charlene DUNN, Plaintiff, v. John A. MURPHY, Future Benefits, Inc. American Equity Investment Life Insurance Company,

More information

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION. Plaintiff, Defendants, Nominal Defendant.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION. Plaintiff, Defendants, Nominal Defendant. 1 1 1 1 1 1 1 1 0 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION In re ORACLE CORPORATION DERIVATIVE LITIGATION SCOTT OZAKI, derivatively and on behalf of ORACLE CORPORATION,

More information

LABOR PERMITS, TAXES, CERTIFICATIONS

LABOR PERMITS, TAXES, CERTIFICATIONS DATE: Company: ATT: Fax No. : Phone No. : STANDARD TERMS AND CONDITIONS FOR FIELD SERVICE Dear Customer: ITEC is in receipt of your request for on-site service(s) (hereinafter Services ) by an ITEC Field

More information

Case 3:14-cv-00671-HU Document 1 Filed 04/23/14 Page 1 of 12 Page ID#: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON

Case 3:14-cv-00671-HU Document 1 Filed 04/23/14 Page 1 of 12 Page ID#: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON Case 3:14-cv-00671-HU Document 1 Filed 04/23/14 Page 1 of 12 Page ID#: 1 OSB#013943 sean.riddell@live.com Attorney At Law 4411 NE Tillamook St Portland, OR 97140 971-219-8453 Attorney for Plaintiff IN

More information

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE. DHL EXPRESS (USA), Inc. ( DHL ) by its attorneys, Bauer Moynihan & Johnson

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE. DHL EXPRESS (USA), Inc. ( DHL ) by its attorneys, Bauer Moynihan & Johnson THE HONORABLE JOHN C. COUGHENOUR UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE 1 1 MICROSOFT CORPORATION, Plaintiff, v. DHL EXPRESS (USA), Inc., Defendant / Third-Party Plaintiff.

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SANTA CLARA UNLIMITED JURISDICTION

SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SANTA CLARA UNLIMITED JURISDICTION E. CRAIG MOODY, ESQ., SBN: Post Street, Suite 0 San Francisco, CA craig@ecraigmoodylaw.com Telephone: () 1-00 Telecopier: () 1-01 Attorney For Petitioner Existence Genetics, LLC SUPERIOR COURT OF THE STATE

More information

IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF [COUNTY]

IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF [COUNTY] IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF [COUNTY] [PLAINTIFF], CASE NO. Plaintiff, (Negligence Medical Malpractice v. Claim Not Subject to Mandatory Arbitration [NAMES] (Prayer Amount

More information

Case5:15-cv-00404-HRL Document1 Filed01/28/15 Page1 of 12

Case5:15-cv-00404-HRL Document1 Filed01/28/15 Page1 of 12 Case:-cv-000-HRL Document Filed0// Page of 0 ERIC DONEY, #0 edoney@donahue.com JULIE E. HOFER, # jhofer@donahue.com ANDREW S. MACKAY, #0 amackay@donahue.com DONAHUE FITZGERALD LLP Harrison Street, th Floor

More information

ex rel. BILL LOCKYER, ATTORNEY GENERAL OF THE STATE OF CALIFORNIA,

ex rel. BILL LOCKYER, ATTORNEY GENERAL OF THE STATE OF CALIFORNIA, BILL LOCKYER Attorney General of the State of California RICHARD M. FRANK Chief Assistant Attorney General DENNIS ECKHART Senior Assistant Attorney General MICHELLE L. FOGLIANI Deputy Attorney General

More information

This page left blank intentionally

This page left blank intentionally ATTACHMENT 13 PERFORMANCE AND PAYMENT BONDS This page left blank intentionally RFP #0606-14 Attachment 13: Payment & Performance Bonds Page 1 of 8 PAYMENT BOND (CALIFORNIA PUBLIC WORK) KNOW ALL MEN BY

More information

Information or instructions: Defendant s Cross-claims and counterclaims PREVIEW

Information or instructions: Defendant s Cross-claims and counterclaims PREVIEW Information or instructions: Defendant s Cross-claims and counterclaims 1. The purpose of counterclaims and cross-actions is to join persons and actions, as permitted by TRCP 39, 40, 41, 49, 50, and 51,

More information

Services Agreement between Client and Provider

Services Agreement between Client and Provider Services Agreement between Client and Provider This Services Agreement is part of the Member Contract between Client and Provider, effective upon Client s award and Provider s acceptance of a Job on the

More information

Attorneys for Maricopa County Community College District Board IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF MARICOPA

Attorneys for Maricopa County Community College District Board IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF MARICOPA O S B O R N M A L E D O N A P R O F E S S I O N A L A S S O C I A T I O N A T T O R N E Y S A T L A W The Phoenix Plaza 1st Floor North Central Avenue Phoenix, Arizona 01- P.O. Box Phoenix, Arizona 0-

More information

CASE NO.: CIVIL DIVISION COMPLAINT. through undersigned counsel, and hereby sues Defendant, Winn-Dixie Stores, Inc., a Florida GENERAL ALLEGATIONS

CASE NO.: CIVIL DIVISION COMPLAINT. through undersigned counsel, and hereby sues Defendant, Winn-Dixie Stores, Inc., a Florida GENERAL ALLEGATIONS IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA, vs. Plaintiff, CASE NO.: CIVIL DIVISION WINN-DIXIE STORES, INC., Defendant, / COMPLAINT COMES NOW Plaintiff,,

More information

California Senate Bill 474 Impact on Owners & Contractors

California Senate Bill 474 Impact on Owners & Contractors California Senate Bill 474 Impact on Owners & Contractors Beginning January 1, 2013, project owners, general contractors ( GC ), construction managers ( CM ) and any lower tier contractor who employs subcontractors

More information

COMPLAINT PARTIES. of Transportation & Public Facilities, which is a state agency. propulsion system design, manufacture, sales, and service.

COMPLAINT PARTIES. of Transportation & Public Facilities, which is a state agency. propulsion system design, manufacture, sales, and service. IN THE SUPERIOR COURT FOR THE STATE OF ALASKA FIRST JUDICIAL DISTRICT AT JUNEAU STATE OF ALASKA, ALASKA MARINE HIGHWAY SYSTEM, Plaintiff, vs. ROBERT E. DERECKTOR, INC., MTU FRIEDRICHSHAFEN, GMBH, and MTU

More information

IN THE THIRD JUDICIAL DISTRICT COURT, SALT LAKE COUNTY STATE OF UTAH. Case No. : Judge:

IN THE THIRD JUDICIAL DISTRICT COURT, SALT LAKE COUNTY STATE OF UTAH. Case No. : Judge: Alan W. Mortensen (6616) DEWSNUP, KING & OLSEN 36 South State Street, Ste. 2400 Salt Lake City, UT 84111 Telephone (801) 533-0400 Facsimile (801) 363-4218 Attorneys for Plaintiffs IN THE THIRD JUDICIAL

More information

No. Plaintiff Kelvin Bledsoe ( Plaintiff ), by his undersigned counsel, brings claims

No. Plaintiff Kelvin Bledsoe ( Plaintiff ), by his undersigned counsel, brings claims UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK KELVIN BLEDSOE, Plaintiff, v. SAAQIN, INC., No. COMPLAINT FOR VIOLATION OF FAIR LABOR STANDARDS ACT JURY TRIAL DEMANDED Defendant. Plaintiff Kelvin

More information

SECURITY DEALER SIGNAL RELAY AGREEMENT

SECURITY DEALER SIGNAL RELAY AGREEMENT SECURITY DEALER SIGNAL RELAY AGREEMENT THIS AGREEMENT WAS MADE ON THE DATE STATED BELOW BY AND BETWEEN IPDATATEL, LLC, A TEXAS LIMITED LIABILITY COMPANY, HEREINAFTER CALLED "COMPANY, AND ALARM DEALER (AS

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY DEFENDANT S ANSWER

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY DEFENDANT S ANSWER Case 1:14-cv-05919-JEI-KMW Document 19 Filed 02/13/15 Page 1 of 11 PageID: 84 Frank L. Corrado, Esquire Attorney ID No. 022221983 BARRY, CORRADO & GRASSI, PC 2700 Pacific Avenue Wildwood, NJ 08260 (609)

More information

IN THE COURT OF COMMON PLEAS, FRANKLIN COUNTY, OHIO. Plaintiffs, ) CASE NO. 08 CVH 12 18090. -vs- ) JUDGE LYNCH

IN THE COURT OF COMMON PLEAS, FRANKLIN COUNTY, OHIO. Plaintiffs, ) CASE NO. 08 CVH 12 18090. -vs- ) JUDGE LYNCH IN THE COURT OF COMMON PLEAS, FRANKLIN COUNTY, OHIO C. PAUL TIPPS, et al., ) Plaintiffs, ) CASE NO. 08 CVH 12 18090 -vs- ) JUDGE LYNCH NEIL S. CLARK, et al., ) Defendants. ) ANSWER OF DEFENDANTS NEIL S.

More information

) Verified c-o-m-p-la-in-t- --;o~~&"-a~a~e~a6d4 0. Plaintiff, ) Demand for Jury Trial. Defendants. ) Over $25,000.00 ----------------------------~)

) Verified c-o-m-p-la-in-t- --;o~~&-a~a~e~a6d4 0. Plaintiff, ) Demand for Jury Trial. Defendants. ) Over $25,000.00 ----------------------------~) \\.. I' 1 1 1 1 ORIAEDCOPY ~~G'NAL F'L~~rt LeOS Angeles Superior Michael B. Eisenberg, Esq. #0 EISENBERG & ASSOCIATES 0 Wilshire Blvd, Suite OC1 1 Los Angeles, California 00 =... Telephone: () 1-1 John

More information

PURCHASE ORDER TERMS AND CONDITIONS

PURCHASE ORDER TERMS AND CONDITIONS PURCHASE ORDER TERMS AND CONDITIONS This purchase order is subject to the following terms and conditions. The terms and conditions herein set forth constitute an offer by Purchaser and may be accepted

More information

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA 1 MICHAEL P. VERNA(# 4070) NATHANIEL B. DUNCAN (#463) 2 JEANNE YANG (#4) BOWLES & VERNA LLP 3 N. California Blvd., Suite 75 Walnut Creek, CA 456 4 Telephone: () 35-3300 Facsimile: () 35-0371 5 Email: mverna@bowlesverna.com

More information

THIRD JUDICIAL DISTRICT COURT IN AND FOR SALT LAKE COUNTY, STATE OF UTAH

THIRD JUDICIAL DISTRICT COURT IN AND FOR SALT LAKE COUNTY, STATE OF UTAH James W. McConkie #2156 PARKER & McCONKIE Attorneys for Plaintiffs City Center I, Suite 900 175 East 400 South Salt Lake City, Utah 84111 Telephone (801) 264-1950 Facsimile (801) 328-4988 THIRD JUDICIAL

More information

IN THE CIRCUIT COURT OF BALDWIN COUNTY, ALABAMA * *

IN THE CIRCUIT COURT OF BALDWIN COUNTY, ALABAMA * * IN THE CIRCUIT COURT OF BALDWIN COUNTY, ALABAMA vs. Plaintiffs, CIVIL ACTION NUMBER CV-99-792 Defendants. COMPLAINT 1. Plaintiffs, Bryan K. Bunten and Lisa Bunten, are over the age of nineteen (19) years

More information

SUPERIOR COURT OF THE STATE OF CALIFORNIA

SUPERIOR COURT OF THE STATE OF CALIFORNIA Paul L. Hoffman, CSB #1 Michael D. Seplow, CSB # 0 K. Arianne Jordan, CSB # 1 SCHONBRUN DeSIMONE SEPLOW HARRIS & HOFFMAN LLP Ocean Front Walk Venice, California 01 Telephone: ( -01 Fax: ( -00 Gloria Allred,

More information