Preview
Electronically Filed by Superior Court of California, County of Orange, 06/20/2022 08:47:45 AM.
30-2022-01265551-CU-PA-WJC - ROA # 2 - DAVID H. YAMASAKI, Clerk of the Court By Katie Trent, Deputy Clerk.
PLD-Pl-001
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Stale Bar number. and address): FOR COURT USE ONLY
.._ Brian G. Beecher (SBN 239486)
THE LAW OFFICES OF ARASH KHORSANDI, PC
2960 Wilshire Boulevard, Third Floor
Los Angeles, California 90010
(310) 277-7529
TELEPHONE NO FAXNO (Optional) (310) 388-8442
service@arash law .com
E M/\IL /\DDRESS (Optional):
ATTORNEY FOR (Name) Plaintiffs, JULIO MARTINEZ SANCHEZ, et al.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Orange
sTREET ADDREss 700 Civic
Orange Center
County DriveCourt
Superior West
MAILINGADDREss 700 WestCivic
Justice
Center
CenterDrive West
8141 13th
c1TY AND z1P coDE: Santa AnaStreet
92701
Westminster,
BRANCH NAME Central Justice CACenter
92683
PLAINTIFF: JULIO MARTINEZ SANCHEZ; MARIA ISABEL
ALCANTAR RUIZ
DEFENDANT: PETER y AM POON WOO; GLORIA PIKKWAN
WOO;AND
W DOES 1 TO 100
COMPLAINT-Personal Injury, Property Damage, Wrongful Death
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0 AMENDED (Number):
Type (check all that apply):
[ZJ MOTOR VEHICLE [ZJ OTHER (specify): Gen. Neg.; Neg. Per Se
o r
m
W
Property Damage
Personal Injury
D
W
Wrongful Death
Other Damages (specify):
P
Neg. Ent; LOC
s
s
Jurisdiction (check all that apply): CASE NUMBER
CJ ACTION IS A LIMITED CIVIL CASE
Amount demanded D
does not exceed $10,000
D
c e
exceeds $10,000, but does not exceed $25,000
c
[ZJ ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000)
CJ ACTION IS RECLASSIFIED by this amended complaint Assigned for All Purposes
D
D
from limited to unlimited
from unlimited to limited
a A
1. Plaintiff (name or names) :
d i
JULIO MARTINEZ SANCHEZ; MARIA ISABEL ALCANTAR RUIZ
alleges causes of action against defendant (name or names):
2.
a. D M e
PETER YAM POON WOO; GLORIA PIKKWAN WOO; AND DOES 1 TO 100
This pleading, including attachments and exhibits, consists of the following number of pages: 8
3. Each plaintiff named above is a competent adult
except plaintiff (name) :
(1) CJ a corporation qualified to do business in California
(2) CJ an unincorporated entity (describe) :
(3) CJ a public entity (describe) :
(4) D
a minor D
an adult
(a) D
for whom a guardian or conservator of the estate or a guardian ad litem has been appointed
(b) D
other (specify):
(5) D
other (specify) :
b. D except plaintiff (name) :
(1) D a corporation qualified to do business in California
(2) D an unincorporated entity (describe) :
(3) D a public entity (describe):
(4) D a minor D an adult
(a) D for whom a guardian or conservator of the estate or a guardian ad litem has been appointed
(b) D other (specify) :
(5) D other (specify) :
D Information about additional plaintiffs who are not competent adults is shown in Attachment 3.
Page 1 of 3
Form Approved for Optional Use
Judicial Council of California
COMPLAINT-Personal Injury, Property Code of Civil Procedure, § 425 12
www.courtinfo.ca gov
PLD-Pl-001 [Rev. January 1, 2007] Damage, Wrongful Death
PLD-Pl-001
SHORT TITLE: CASE NUMBER:
SANCHEZ, et al. v. WOO, et al.
4. D Plaintiff (name) :
is doing business under the fictitious name (specify) :
and has complied with the fictitious business name laws.
5. Each defendant named above is a natural person
a. D except defendant (name): c. D except defendant (name):
(1) D a business organization, form unknown (1) D a business organization, form unknown
(2) D a corporation (2) D a corporation
(3) D an unincorporated entity (describe) : (3) D an unincorporated entity (describe):
(4) D a public entity (describe) : (4) D a public entity (describe):
(5) D other (specify): (5) D other (specify) :
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b. D except defendant (name):
(1) D a business organization, form unknown
d. D
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except defendant (name) :
D
P
(1) a business organization, form unknown
(2) D a corporation (2) D a corporation
(3) D
D
an unincorporated entity (describe) :
s s
(3) D
D
an unincorporated entity (describe) :
e
(4) a public entity (describe): (4) a public entity (describe) :
(5) D other (specify) :
c c (5) D other (specify):
D
A
Information about additional defendants who are not natural persons is contained in Attachment 5.
a
i
6. The true names of defendants sued as Does are unknown to plaintiff.
d
a. [2J Doe defendants (specify Doe numbers): 1-100 were the agents or employees of other
named defendants and acted within the scope of that agency or employment.
7. D
plaintiff.
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b. [2J Doe defendants (specify Doe numbers): 1-100 are persons whose capacities are unknown to
Defendants who are joined under Code of Civil Procedure section 382 are (names) :
8. This court is the proper court because
a. D at least one defendant now resides in its jurisdictional area.
b. D the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area.
c. [ZJ injury to person or damage to personal property occurred in its jurisdictional area.
d. D other (specify):
9. D Plaintiff is required to comply with a claims statute, and
a. D has complied with applicable claims statutes, or
b. D is excused from complying because (specify) :
PLD-Pl-001 [Rev January 1, 2007] COMPLAINT-Personal Injury, Property Page 2 of 3
Damage, Wrongful Death
PLD-Pl-001
SHORT TITLE: CASE NUMBER:
SANCHEZ, et al. v. WOO, et al.
10. The following causes of action are attached and the statements above apply to each (each complaint must have one or more
causes of action attached):
a. W Motor Vehicle
b. [Z] General Negligence
c. D Intentional Tort
d. D Products Liability
e. D Premises Liability
f. WOther (specify) :
Negligent Entrustment; Negligence Per Se
11. Plaintiff has suffered
a. [Z] wage loss
b. W loss of use of property
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r
c. [Z] hospital and medical expenses
W
o
d. general damage
e. W property damage
f. IT] loss of earning capacity
g. W other damage (specify) :
pain and mental suffering
s P
e s
12. D
a. D
c c
The damages claimed for wrongful death and the relationships of plaintiff to the deceased are
listed in Attachment 12.
b. D as follows:
a A
d i
M e
13. The relief sought in this complaint is within the jurisdiction of this court.
Plaintiff requests a trial by jury on all claims and causes of action. Defendants are residents of the State of
California at all times relevant herein.
14. Plaintiff prays for judgment for costs of suit; for such relief as is fair, just, and equitable; and for
a. (1) [ZJ compensatory damages
(2) CJ punitive damages
The amount of damages is (in cases for personal injury or wrongful death, you must check (1 )):
(1) W
according to proof
(2) D
in the amount of $
15. W The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers) :
1-15
Date: June )1 ,2022
Brian G. Beecher, Esq.
(TYPE OR PRINT NAME)
PLD-Pl-001 (Rev. January 1, 2007] COMPLAINT-Personal Injury, Property Page 3 of 3
Damage, Wrongful Death
PLD-Pl-001 ( 1)
SHORT TITLE : CASE NUMBER
SANCHEZ, et al. v. WOO, et al.
FIRST CAUSE OF ACTION-Motor Vehicle
(number)
ATTACHMENT TO [ZJ Complaint O Cross - Complaint
(Use a separate cause of action form for each cause of action.)
Plaintiff (name): JULIO MARTINEZ SANCHEZ
MV- 1. Plaintiff alleges the acts of defendants were negligent; the acts were the legal (proximate) cause of injuries
and damages to plaintiff; the acts occurred
on (date) : September 18, 2021
at (place):
or near I-405 NIB, 400 feet north Goldenwest Street, Huntington Beach, California 92647
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MV- 2. DEFENDANTS
o r
P
a. [Z] The defendants who operated a motor vehicle are (names):
PETER YAM POON WOO; and
[ZJ Does
-1 - - - -- to 100
s s
b. [Z]
e
The defendants who employed the persons who operated a motor vehicle in the course of their employment
are (names):
c
W Does 1 -----
-
A c to 100
c. [Z]
i a
The defendants who owned the motor vehicle which was operated with their permission are (names):
PETER YAM POON WOO; GLORIA PIKKWAN WOO; and
d
d. [ZJ
M e
[ZJ Does 1
GLORIA PIKKWAN WOO; and
to
-100
-----
The defendants who entrusted the motor vehicle are (names) :
[ZJ Does
-1 - - - - - to 100
e. IT] The defendants who were the agents and employees of the other defendants and acted within the scope
of the agency were (names):
PETER YAM POON WOO; and
IT] Does 1 to
-100- -- --
f. IT] The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are
0 listed in Attachment MV-2f [ZJ as follows:
W Does
-1 - -- - to 100 Page 4
Page 1 of 1
Form Approved for Optional Use
Judicial Council of California
CAUSE OF ACTION-Motor Vehicle Code of Civil Procedure 425 12
www.courtinfo,ca.gov
PLD-Pl-001 (1) [Rev January 1, 2007]
PLD-Pl-001 (2)
CASE NUMBER:
SHORT TITLE:
SANCHEZ, et al. v. WOO, et al.
SECOND CAUSE OF ACTION-General Negligence Page
- -- -
5
(number)
ATTACHMENT TO W Complaint LJ Cross - Complaint
(Use a separate cause of action form for each cause of action.)
GN-1 . Plaintiff (name): JULIO MARTINEZ SANCHEZ
alleges that defendant (name): PETER YAM POON WOO; GLORIA PIKKWAN WOO; AND
[ZJ Does 1 to 100
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was the legal (proximate) cause of damages to plaintiff. By the following acts or omissions to act, defendant
negligently caused the damage to plaintiff
on (date): September 18, 2021
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at (place) :
(description of reasons for liability):
s P
or near I-405 NIB, 400 feet north Goldenwest Street, Huntington Beach, CA 92647
e s
1. Plaintiff JULIO MARTINEZ SANCHEZ ("Plaintiff') hereby re-alleges, adopts and
incorporates by reference all the allegations contained in Plaintiffs First Cause of Action for
c
Motor Vehicle Collision as if set forth in full herein.
c
A
2. Defendants PETER YAM POON WOO; GLORIA PIKKW AN WOO; AND DOES 1 TO 100
("Defendants") owed a duty to Plaintiff and other pedestrians and drivers on the road, to use
i a
reasonable care when operating a motor vehicle on the roadway.
d
3. However, at all times, Defendants negligently breached said duties and unreasonably and
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negligently operated a motor vehicle on September 18, 2021, so as to cause a collision that
severely injured and harmed Plaintiff.
4. Defendants' negligence was a direct, proximate and legal cause of the injuries sustained by
Plaintiff.
Page 1 of 1
Form Approved for Optional Use Code or Civil Procedure 425 12
Judicial Council of California CAUSE OF ACTION-General Negligence www.courtinfo ca gov
PLD-Pl-001 (2) [Rev January 1, 2007)
MC-025
CASE NUMBER:
SHORT TITLE:
SANCHEZ, et al. v. WOO, et al.
ATTACHMENT (Number) : 2 / page 6
(This Attachment may be used with any Judicial Council form.)
THIRD CAUSE OF ACTION - Negligence Per Se
1. Plaintiff JULIO MARTINEZ SANCHEZ ("Plaintiff'') hereby re-alleges, adopts, and incorporates by
reference all the allegations contained in Plaintiffs First Cause of Action for Motor Vehicle Collision,
Plaintiffs Second Cause of Action for General Negligence.
2. Defendants PETER YAM POON WOO; GLORIA PIKKWAN WOO; AND DOES 1 TO 100
caused/allowed their motor vehicle to be driven in a negligent, careless and unreasonable manner, and, in
doing so, Plaintiff is informed and believes that Defendants violated California Vehicle Codes, including but
not limited to section 22350 (basic speed law) which states: "No person shall drive a vehicle upon a highway at
surface and width of, the highway, and in no event at a speed which endangers the safety of persons or
property."
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a speed greater than is reasonable or prudent having due regard for weather, visibility, the traffic on, and the
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3. Defendants' negligence, carelessness, and/or unreasonable operation of a vehicle was a direct, proximate,
and legal cause of the injuries sustained by Plaintiff.
s P
e s
c c
a A
d i
M e
(If the item that this Attachment concerns is made under penalty of perjury, all statements in this Page 6 of 8
Attachment are made under penalty of perjury.)
(Add pages as required)
Form Approved for Optional Use www.courtinfo_ca_gov
Judicial Council of California
ATTACHMENT
MC-025 (Rev July 1, 2009] to Judicial Council Form
MC-025
CASE NUMBER:
SHORT TITLE :
SANCHEZ, et al. v. WOO, et al.
ATTACHMENT (Number) : 2 / page 7
(This Attachment may be used with any Judicial Council form.)
FOURTH CAUSE OF ACTION - Negligent Entrustment of a Motor Vehicle
1. Plaintiff JULIO MARTINEZ SANCHEZ ("Plaintiff') hereby re-alleges, adopts, and incorporates by
reference all the allegations contained in Plaintiffs First Cause of Action for Motor Vehicle Collision, and
Plaintiffs Second Cause of Action for General Negligence, and Plaintiffs Third Cause of Action for
Negligence Per Se.
2. Defendants PETER YAM POON WOO; GLORIA PIKKWAN WOO ; AND DOES l TO 100 were
negligent in operating a motor vehicle on September 18, 2021.
3. Defendants GLORIA PIKKWAN WOO; AND DOES 1 TO 100 owned the motor vehicle operated by
Defendants PETER YAM POON WOO; AND DOES 1 TO 100 on September 18, 2021, and Defendants
PETER YAM POON WOO; AND DOES 1 TO 100 had possession of the subject motor vehicle with the
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permission of Defendants GLORIA PIKKWAN WOO; AND DOES 1 TO 100.
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P
4. Defendants GLORIA PIKKWAN WOO; AND DOES 1 TO 100 knew, or should have known, that
Defendants PETER YAM POON WOO; AND DOES 1 TO 100 were incompetent or unfit to operate the
subject motor vehicle.
s
e s
5. Nevertheless, Defendants GLORIA PIKKWAN WOO; AND DOES 1 TO 100 negligently permitted and
c c
entrusted Defendants PETER YAM POON WOO; AND DOES 1 TO 100 to operate the subject motor vehicle
owned by Defendants GLORIA PIKKWAN WOO; AND DOES 1 TO 100.
A
6. Defendants PETER YAM POON WOO; AND DOES 1 TO 100's incompetence and/or unfitness to operate
a
i
the subject motor vehicle was a substantial factor in causing harm to Plaintiff JULIO MARTINEZ SANCHEZ.
e d
M
(If the item that this Attachment concerns is made under penalty of perjury, all statements in this Page 7 of 8
Attachment are made under penalty of perjury.)
(Add pages as required)
Form Approved for Optional Use www.courtinfo ca gov
Judicial Council of California
ATTACHMENT
MC-025 [Rev July 1, 2009] to Judicial Council Form
MC-025
CASE NUMBER:
SHORT TITLE:
SANCHEZ, et al. v. WOO, et al.
ATTACHMENT (Number) : 3 / page 8
(This Attachment may be used with any Judicial Council form.)
FIFTH CAUSE OF ACTION - FOR LOSS OF CONSORTIUM
(By Plaintiff MARIA ISABEL ALCANTAR RUIZ Against All Defendants)
1. Plaintiffs JULIO MARTINEZ SANCHEZ and MARIA ISABEL ALCANTAR RUIZ (collectively
"Plaintiffs") re-allege and incorporate herein by reference each and every allegation contained in the prior
pages of this Complaint.
2. At all times relevant to this action, Plaintiffs JULIO MARTINEZ SANCHEZ and MARIA ISABEL
ALCANTAR RUIZ were and continue to be husband and wife.
3. Defendants PETER YAM POON WOO; GLORIA PIK.KWAN WOO; AND DOES 1 TO 100
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("Defendants") owed the duties set forth herein to Plaintiffs, and Defendants' acts and/or omissions and
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negligence, and/or defective warnings, and/or intentional acts were a both a breach of said duties and also a
has also resulted in a loss of consortium by Plaintiff MARIA ISABEL ALCANTAR RUIZ.
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direct, proximate and legal cause of the injuries sustained by Plaintiff JULIO MATINEZ SANCHEZ-and this
s P
4. As a result of Plaintiff JULIO MARTINEZ SANCHEZ's injuries he has been, and will be unable to provide
his wife with the affection, care, attention, companionship, comfort, aid, solace, romance, and the duties and
from her husband.
e s
assistance of a husband that Plaintiff MARIA ISABEL ALCANTAR RUIZ would have otherwise received
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5. By reason thereof, Plaintiff MARIA ISABEL ALCANTAR RUIZ has been deprived and will continue to
ALCANTAR RUIZ's damage.
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be deprived of the consortium of Plaintiff JULIO MARTINEZ SANCHEZ all to Plaintiff MARIA ISABEL
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6. Accordingly, as a result of the misconduct described herein, Defendants have caused, and threaten to cause,
substantial and irreparable harm to Plaintiff MARIA ISABEL ALCANTAR RUIZ in an amount to be proven
at time of trial.
M e
(If the item that this Attachment concerns is made under penalty of perjury, all statements in this Page 8 of 8
Attachment are made under penalty of perjury.)
(Add pages as required)
Form Approved for Optional Use www.courtinfo ca gov
Judicial Council of California ATTACHMENT
MC-025 [Rev July 1, 2009] to Judicial Council Form
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Electronically Filed by Superior Court of California, County of Orange, 06/20/2022 08:47:45 AM. 30-2022-01265551-CU-PA-WJC - ROA # 2 - DAVID H. YAMASAKI, Clerk of the Court By Katie Trent, Deputy Clerk. PLD-Pl-001 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Stale Bar number. and address): FOR COURT USE ONLY .._ Brian G. Beecher (SBN 239486) THE LAW OFFICES OF ARASH KHORSANDI, PC 2960 Wilshire Boulevard, Third Floor Los Angeles, California 90010 (310) 277-7529 TELEPHONE NO FAXNO (Optional) (310) 388-8442 service@arash law .com E M/\IL /\DDRESS (Optional): ATTORNEY FOR (Name) Plaintiffs, JULIO MARTINEZ SANCHEZ, et al. SUPERIOR COURT OF CALIFORNIA, COUNTY OF Orange sTREET ADDREss 700 Civic Orange Center County DriveCourt Superior West MAILINGADDREss 700 WestCivic Justice Center CenterDrive West 8141 13th c1TY AND z1P coDE: Santa AnaStreet 92701 Westminster, BRANCH NAME Central Justice CACenter 92683 PLAINTIFF: JULIO MARTINEZ SANCHEZ; MARIA ISABEL ALCANTAR RUIZ DEFENDANT: PETER y AM POON WOO; GLORIA PIKKWAN WOO;AND W DOES 1 TO 100 COMPLAINT-Personal Injury, Property Damage, Wrongful Death ta l 0 AMENDED (Number): Type (check all that apply): [ZJ MOTOR VEHICLE [ZJ OTHER (specify): Gen. Neg.; Neg. Per Se o r m W Property Damage Personal Injury D W Wrongful Death Other Damages (specify): P Neg. Ent; LOC s s Jurisdiction (check all that apply): CASE NUMBER CJ ACTION IS A LIMITED CIVIL CASE Amount demanded D does not exceed $10,000 D c e exceeds $10,000, but does not exceed $25,000 c [ZJ ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000) CJ ACTION IS RECLASSIFIED by this amended complaint Assigned for All Purposes D D from limited to unlimited from unlimited to limited a A 1. Plaintiff (name or names) : d i JULIO MARTINEZ SANCHEZ; MARIA ISABEL ALCANTAR RUIZ alleges causes of action against defendant (name or names): 2. a. D M e PETER YAM POON WOO; GLORIA PIKKWAN WOO; AND DOES 1 TO 100 This pleading, including attachments and exhibits, consists of the following number of pages: 8 3. Each plaintiff named above is a competent adult except plaintiff (name) : (1) CJ a corporation qualified to do business in California (2) CJ an unincorporated entity (describe) : (3) CJ a public entity (describe) : (4) D a minor D an adult (a) D for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b) D other (specify): (5) D other (specify) : b. D except plaintiff (name) : (1) D a corporation qualified to do business in California (2) D an unincorporated entity (describe) : (3) D a public entity (describe): (4) D a minor D an adult (a) D for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b) D other (specify) : (5) D other (specify) : D Information about additional plaintiffs who are not competent adults is shown in Attachment 3. Page 1 of 3 Form Approved for Optional Use Judicial Council of California COMPLAINT-Personal Injury, Property Code of Civil Procedure, § 425 12 www.courtinfo.ca gov PLD-Pl-001 [Rev. January 1, 2007] Damage, Wrongful Death PLD-Pl-001 SHORT TITLE: CASE NUMBER: SANCHEZ, et al. v. WOO, et al. 4. D Plaintiff (name) : is doing business under the fictitious name (specify) : and has complied with the fictitious business name laws. 5. Each defendant named above is a natural person a. D except defendant (name): c. D except defendant (name): (1) D a business organization, form unknown (1) D a business organization, form unknown (2) D a corporation (2) D a corporation (3) D an unincorporated entity (describe) : (3) D an unincorporated entity (describe): (4) D a public entity (describe) : (4) D a public entity (describe): (5) D other (specify): (5) D other (specify) : ta l b. D except defendant (name): (1) D a business organization, form unknown d. D o r except defendant (name) : D P (1) a business organization, form unknown (2) D a corporation (2) D a corporation (3) D D an unincorporated entity (describe) : s s (3) D D an unincorporated entity (describe) : e (4) a public entity (describe): (4) a public entity (describe) : (5) D other (specify) : c c (5) D other (specify): D A Information about additional defendants who are not natural persons is contained in Attachment 5. a i 6. The true names of defendants sued as Does are unknown to plaintiff. d a. [2J Doe defendants (specify Doe numbers): 1-100 were the agents or employees of other named defendants and acted within the scope of that agency or employment. 7. D plaintiff. M e b. [2J Doe defendants (specify Doe numbers): 1-100 are persons whose capacities are unknown to Defendants who are joined under Code of Civil Procedure section 382 are (names) : 8. This court is the proper court because a. D at least one defendant now resides in its jurisdictional area. b. D the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area. c. [ZJ injury to person or damage to personal property occurred in its jurisdictional area. d. D other (specify): 9. D Plaintiff is required to comply with a claims statute, and a. D has complied with applicable claims statutes, or b. D is excused from complying because (specify) : PLD-Pl-001 [Rev January 1, 2007] COMPLAINT-Personal Injury, Property Page 2 of 3 Damage, Wrongful Death PLD-Pl-001 SHORT TITLE: CASE NUMBER: SANCHEZ, et al. v. WOO, et al. 10. The following causes of action are attached and the statements above apply to each (each complaint must have one or more causes of action attached): a. W Motor Vehicle b. [Z] General Negligence c. D Intentional Tort d. D Products Liability e. D Premises Liability f. WOther (specify) : Negligent Entrustment; Negligence Per Se 11. Plaintiff has suffered a. [Z] wage loss b. W loss of use of property ta l r c. [Z] hospital and medical expenses W o d. general damage e. W property damage f. IT] loss of earning capacity g. W other damage (specify) : pain and mental suffering s P e s 12. D a. D c c The damages claimed for wrongful death and the relationships of plaintiff to the deceased are listed in Attachment 12. b. D as follows: a A d i M e 13. The relief sought in this complaint is within the jurisdiction of this court. Plaintiff requests a trial by jury on all claims and causes of action. Defendants are residents of the State of California at all times relevant herein. 14. Plaintiff prays for judgment for costs of suit; for such relief as is fair, just, and equitable; and for a. (1) [ZJ compensatory damages (2) CJ punitive damages The amount of damages is (in cases for personal injury or wrongful death, you must check (1 )): (1) W according to proof (2) D in the amount of $ 15. W The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers) : 1-15 Date: June )1 ,2022 Brian G. Beecher, Esq. (TYPE OR PRINT NAME) PLD-Pl-001 (Rev. January 1, 2007] COMPLAINT-Personal Injury, Property Page 3 of 3 Damage, Wrongful Death PLD-Pl-001 ( 1) SHORT TITLE : CASE NUMBER SANCHEZ, et al. v. WOO, et al. FIRST CAUSE OF ACTION-Motor Vehicle (number) ATTACHMENT TO [ZJ Complaint O Cross - Complaint (Use a separate cause of action form for each cause of action.) Plaintiff (name): JULIO MARTINEZ SANCHEZ MV- 1. Plaintiff alleges the acts of defendants were negligent; the acts were the legal (proximate) cause of injuries and damages to plaintiff; the acts occurred on (date) : September 18, 2021 at (place): or near I-405 NIB, 400 feet north Goldenwest Street, Huntington Beach, California 92647 ta l MV- 2. DEFENDANTS o r P a. [Z] The defendants who operated a motor vehicle are (names): PETER YAM POON WOO; and [ZJ Does -1 - - - -- to 100 s s b. [Z] e The defendants who employed the persons who operated a motor vehicle in the course of their employment are (names): c W Does 1 ----- - A c to 100 c. [Z] i a The defendants who owned the motor vehicle which was operated with their permission are (names): PETER YAM POON WOO; GLORIA PIKKWAN WOO; and d d. [ZJ M e [ZJ Does 1 GLORIA PIKKWAN WOO; and to -100 ----- The defendants who entrusted the motor vehicle are (names) : [ZJ Does -1 - - - - - to 100 e. IT] The defendants who were the agents and employees of the other defendants and acted within the scope of the agency were (names): PETER YAM POON WOO; and IT] Does 1 to -100- -- -- f. IT] The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are 0 listed in Attachment MV-2f [ZJ as follows: W Does -1 - -- - to 100 Page 4 Page 1 of 1 Form Approved for Optional Use Judicial Council of California CAUSE OF ACTION-Motor Vehicle Code of Civil Procedure 425 12 www.courtinfo,ca.gov PLD-Pl-001 (1) [Rev January 1, 2007] PLD-Pl-001 (2) CASE NUMBER: SHORT TITLE: SANCHEZ, et al. v. WOO, et al. SECOND CAUSE OF ACTION-General Negligence Page - -- - 5 (number) ATTACHMENT TO W Complaint LJ Cross - Complaint (Use a separate cause of action form for each cause of action.) GN-1 . Plaintiff (name): JULIO MARTINEZ SANCHEZ alleges that defendant (name): PETER YAM POON WOO; GLORIA PIKKWAN WOO; AND [ZJ Does 1 to 100 ta l was the legal (proximate) cause of damages to plaintiff. By the following acts or omissions to act, defendant negligently caused the damage to plaintiff on (date): September 18, 2021 o r at (place) : (description of reasons for liability): s P or near I-405 NIB, 400 feet north Goldenwest Street, Huntington Beach, CA 92647 e s 1. Plaintiff JULIO MARTINEZ SANCHEZ ("Plaintiff') hereby re-alleges, adopts and incorporates by reference all the allegations contained in Plaintiffs First Cause of Action for c Motor Vehicle Collision as if set forth in full herein. c A 2. Defendants PETER YAM POON WOO; GLORIA PIKKW AN WOO; AND DOES 1 TO 100 ("Defendants") owed a duty to Plaintiff and other pedestrians and drivers on the road, to use i a reasonable care when operating a motor vehicle on the roadway. d 3. However, at all times, Defendants negligently breached said duties and unreasonably and M e negligently operated a motor vehicle on September 18, 2021, so as to cause a collision that severely injured and harmed Plaintiff. 4. Defendants' negligence was a direct, proximate and legal cause of the injuries sustained by Plaintiff. Page 1 of 1 Form Approved for Optional Use Code or Civil Procedure 425 12 Judicial Council of California CAUSE OF ACTION-General Negligence www.courtinfo ca gov PLD-Pl-001 (2) [Rev January 1, 2007) MC-025 CASE NUMBER: SHORT TITLE: SANCHEZ, et al. v. WOO, et al. ATTACHMENT (Number) : 2 / page 6 (This Attachment may be used with any Judicial Council form.) THIRD CAUSE OF ACTION - Negligence Per Se 1. Plaintiff JULIO MARTINEZ SANCHEZ ("Plaintiff'') hereby re-alleges, adopts, and incorporates by reference all the allegations contained in Plaintiffs First Cause of Action for Motor Vehicle Collision, Plaintiffs Second Cause of Action for General Negligence. 2. Defendants PETER YAM POON WOO; GLORIA PIKKWAN WOO; AND DOES 1 TO 100 caused/allowed their motor vehicle to be driven in a negligent, careless and unreasonable manner, and, in doing so, Plaintiff is informed and believes that Defendants violated California Vehicle Codes, including but not limited to section 22350 (basic speed law) which states: "No person shall drive a vehicle upon a highway at surface and width of, the highway, and in no event at a speed which endangers the safety of persons or property." ta l a speed greater than is reasonable or prudent having due regard for weather, visibility, the traffic on, and the o r 3. Defendants' negligence, carelessness, and/or unreasonable operation of a vehicle was a direct, proximate, and legal cause of the injuries sustained by Plaintiff. s P e s c c a A d i M e (If the item that this Attachment concerns is made under penalty of perjury, all statements in this Page 6 of 8 Attachment are made under penalty of perjury.) (Add pages as required) Form Approved for Optional Use www.courtinfo_ca_gov Judicial Council of California ATTACHMENT MC-025 (Rev July 1, 2009] to Judicial Council Form MC-025 CASE NUMBER: SHORT TITLE : SANCHEZ, et al. v. WOO, et al. ATTACHMENT (Number) : 2 / page 7 (This Attachment may be used with any Judicial Council form.) FOURTH CAUSE OF ACTION - Negligent Entrustment of a Motor Vehicle 1. Plaintiff JULIO MARTINEZ SANCHEZ ("Plaintiff') hereby re-alleges, adopts, and incorporates by reference all the allegations contained in Plaintiffs First Cause of Action for Motor Vehicle Collision, and Plaintiffs Second Cause of Action for General Negligence, and Plaintiffs Third Cause of Action for Negligence Per Se. 2. Defendants PETER YAM POON WOO; GLORIA PIKKWAN WOO ; AND DOES l TO 100 were negligent in operating a motor vehicle on September 18, 2021. 3. Defendants GLORIA PIKKWAN WOO; AND DOES 1 TO 100 owned the motor vehicle operated by Defendants PETER YAM POON WOO; AND DOES 1 TO 100 on September 18, 2021, and Defendants PETER YAM POON WOO; AND DOES 1 TO 100 had possession of the subject motor vehicle with the ta l permission of Defendants GLORIA PIKKWAN WOO; AND DOES 1 TO 100. o r P 4. Defendants GLORIA PIKKWAN WOO; AND DOES 1 TO 100 knew, or should have known, that Defendants PETER YAM POON WOO; AND DOES 1 TO 100 were incompetent or unfit to operate the subject motor vehicle. s e s 5. Nevertheless, Defendants GLORIA PIKKWAN WOO; AND DOES 1 TO 100 negligently permitted and c c entrusted Defendants PETER YAM POON WOO; AND DOES 1 TO 100 to operate the subject motor vehicle owned by Defendants GLORIA PIKKWAN WOO; AND DOES 1 TO 100. A 6. Defendants PETER YAM POON WOO; AND DOES 1 TO 100's incompetence and/or unfitness to operate a i the subject motor vehicle was a substantial factor in causing harm to Plaintiff JULIO MARTINEZ SANCHEZ. e d M (If the item that this Attachment concerns is made under penalty of perjury, all statements in this Page 7 of 8 Attachment are made under penalty of perjury.) (Add pages as required) Form Approved for Optional Use www.courtinfo ca gov Judicial Council of California ATTACHMENT MC-025 [Rev July 1, 2009] to Judicial Council Form MC-025 CASE NUMBER: SHORT TITLE: SANCHEZ, et al. v. WOO, et al. ATTACHMENT (Number) : 3 / page 8 (This Attachment may be used with any Judicial Council form.) FIFTH CAUSE OF ACTION - FOR LOSS OF CONSORTIUM (By Plaintiff MARIA ISABEL ALCANTAR RUIZ Against All Defendants) 1. Plaintiffs JULIO MARTINEZ SANCHEZ and MARIA ISABEL ALCANTAR RUIZ (collectively "Plaintiffs") re-allege and incorporate herein by reference each and every allegation contained in the prior pages of this Complaint. 2. At all times relevant to this action, Plaintiffs JULIO MARTINEZ SANCHEZ and MARIA ISABEL ALCANTAR RUIZ were and continue to be husband and wife. 3. Defendants PETER YAM POON WOO; GLORIA PIK.KWAN WOO; AND DOES 1 TO 100 ta ("Defendants") owed the duties set forth herein to Plaintiffs, and Defendants' acts and/or omissions and l negligence, and/or defective warnings, and/or intentional acts were a both a breach of said duties and also a has also resulted in a loss of consortium by Plaintiff MARIA ISABEL ALCANTAR RUIZ. o r direct, proximate and legal cause of the injuries sustained by Plaintiff JULIO MATINEZ SANCHEZ-and this s P 4. As a result of Plaintiff JULIO MARTINEZ SANCHEZ's injuries he has been, and will be unable to provide his wife with the affection, care, attention, companionship, comfort, aid, solace, romance, and the duties and from her husband. e s assistance of a husband that Plaintiff MARIA ISABEL ALCANTAR RUIZ would have otherwise received c c 5. By reason thereof, Plaintiff MARIA ISABEL ALCANTAR RUIZ has been deprived and will continue to ALCANTAR RUIZ's damage. a A be deprived of the consortium of Plaintiff JULIO MARTINEZ SANCHEZ all to Plaintiff MARIA ISABEL d i 6. Accordingly, as a result of the misconduct described herein, Defendants have caused, and threaten to cause, substantial and irreparable harm to Plaintiff MARIA ISABEL ALCANTAR RUIZ in an amount to be proven at time of trial. M e (If the item that this Attachment concerns is made under penalty of perjury, all statements in this Page 8 of 8 Attachment are made under penalty of perjury.) (Add pages as required) Form Approved for Optional Use www.courtinfo ca gov Judicial Council of California ATTACHMENT MC-025 [Rev July 1, 2009] to Judicial Council Form