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San Francisco Superior Courts
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Document Scanning Lead Sheet
Apr-21-2005 1:40 pm
Case Number: CGC-04-435182
Filing Date: Apr-15-2005 1:29
Juke Box: 001 Image: 01183454
CROSS COMPLAINT
*ECK CAB COMPANY DBA VETERANS CAB COMPANY VS. MATHEW MELANDRES DEA
001001183454
Instructions:
Please place this sheet on top of the document to be scanned.1 | Thomas M. Crowell [SBN 172799] FILED ar
MUHAR, ROBERTS, SUPERIOR GO cISCO
2| FAMA, KRAMER & MONTY COUNTY OF SA\
One Front Street, Suite 500 005
3] San Francisco, CA 94111 APR 15 a
Telephone: (415) 318-1492 ARK-LI, Clerk
4 | Facsimile: (415) 296-8582 GORDOYP _
BY: Deputy Cierk
5] Attorney for: Defendants,
MATHEW MELENDRES DEASIS
6] and ALICIA DEASIS a
7 & a
8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 IN AND FOR THE COUNTY OF SAN FRANCISCO
10 LIMITED JURISDICTION
11
12 | SPECK CAB COMPANY dba VETERANS Case No.: CGC-04-435182
CAB COMPANY,
13 CROSS-COMPLAINT OF
Plaintiff, MATHEW MELENDRES DEASIS
14 and ALICIA DEASIS
1 5 Vv.
MATHEW MELENDRES DEASIS, ALICIA
16] DEASIS; and DOES 1 - 20,
17 Defendants.
/
18
MATHEW MELENDRES DEASIS and ALICIA
19] DEASIs,
20 Cross-Complainants,
2 1 ve.
SPECK CAB COMPANY dba VETERANS
22 | CAB COMPANY; and ROES 1 -10, inclusive,
23 Cross-Defendants.
24
25
6 COMES NOw, Defendant/Cross-Complainants, MATHEW MELENDRES DEASIS and
7 ALICIA DEASIS and, as against Cross-Defendants SPECK CAB COMPANY dba VETERANS
28 CAB COMPANY and ROES 1-10, allege as follows:
MUWAR, RoBERTs,
FAMA, KRAMER de MONTY 1
I Faowt Staeer, Ste, 500
IAN FRANCISCO, CA_94111 CROSS-COMPLAINT
(415) 318-14921 FIRST CAUSE OF ACTION
2 (Total Indemnity)
3 1. At all times herein mentioned, Cross-Complainants were individuals residing in the
4] State of California.
5 2. Cross-Complainants are informed and believe and thereon allege that Cross-Defendant
6] SPECK CAB COMPANY dba VETERANS CAB COMPANY is a business entity, form unknown,
7 | doing business in the State of California.
8 3. The true names and capacities of Cross-Defendants ROES 1-10, inclusive, are
9] unknown to Cross-Complainants. Cross-Compiainants, therefore, sue said Cross-Defendants by such
10 | fictitious names. Cross-Complainants will seek leave of Court to amend this Cross-Complaint to
11] insert the true names and capacities of the fictitiously named Cross-Defendants when the same have
12] been ascertained.
13 4. Cross-Complainants are informed and believe and thereon allege that each Cross-
14] Defendant desi gnated as a ROE herein is responsible in some manner for the acts, occurrences and
15 | liabilities hereinafter alleged and referred to,
16 5. At all times herein mentioned, each Cross-Defendant was the agent, servant and
17 | employee of each and every other remaining Cross-Defendant, and the acts of each Cross-Defendant
18] was within the course and scope of said agency and employment.
19 6. Plaintiff filed a Complaint in the Superior Court for the County of San Francisco
20 alleging that as a direct and proximate result of Defendants’ negligence, the damages, as alleged in
21] the Complaint, were incurred by the Plaintiff.
22 7. An actual controversy has arisen and now exists between Cross-Complainants and
23 | Cross-Defendants, and each of them, regarding the rights, obligations and duties of the Cross-
24| Defendants which exist between Cross-Complainants and the Cross-Defendants, and each of them.
25 8. Cross-Complainants contend that if they are held liable, which liability is specifically
26 | denied, then Cross-Defendants, and each of them, are primarily and actively responsible and
27 | negligent in causing and bringing about the alleged injuries to Plaintiff. Any liability of Cross-
28 | Complainants will be computed on the basis of vicarious or secondary liability and not as a result of
Faun Kate Novy 2
UFrowr Sraeer, STE, $00
SAN FRANCISCO, CA 94111 CROSS-COMPLAINT
(415) 318-1492.! any active negligence or any other acts on the part of Cross-Complainants.
2 9. Cross-Complainants have not been negligent or responsible in any manner whatsoever
3 for the alleged injuries to Plaintiff.
4 10. If Cross-Complainants are held liable, which liability is specifically denied, then
5 Cross-Defendants, and each of them, are directly, actively and primarily responsible for, and
6 contributorily negligent in causing the injuries to Plaintiff.
7 11. Cross-Complainants are entitled to be indemnified for any and all recovery that
8 Plaintiff may realize against Cross-Complainants.
° SECOND CAUSE OF ACTION
10 (Declaratory Relief - Implied Partial Indemnity)
11 12. Cross-Complainants hereby incorporate by reference each and every allegation
12] contained in Paragraphs 1-11 inclusive, of the First Cause of Action, as though fully set forth at
13] length herein.
14 13. Cross-Complainants contend that if they are held liable in any ascertainable
15 | percentage, that percentage is not equal to total or complete liability and that the remaining
16 percentage of liability should be assessed against Cross-Defendants, and each of them, according to
17 | the principles of partial indemnity.
18 14. Cross-Complainants are not singularly, uniquely or totally liable for any damages
19} incurred by Plaintiff.
20 15. If Cross-Complainants are held liable, which liability is specifically denied, Cross-
21] Complainants should be only partially responsible for the alleged injuries, damages and other
22] detriment allegedly suffered or sustained by Plaintiff. Such partial responsibility should be based
23] upon the finding that Cross-Defendants, and each of them, were negligent or otherwise responsible
24 | for the alleged injuries and damages. The distribution of those responsibilities among Cross-
25 | Complainants and Cross-Defendants, and each of them, should be apportioned on the basis of partial
26 | indemnity.
27 16. Cross-Defendants, and each of them, have a duty to indemnify Cross-Complainants
28 | for any recovery that Plaintiff SPECK CAB COMPANY dba VETERANS CAB COMPANY may
rest 3
SAN FRANCISCO, CA 94111 CROSS-COMPLAINT1 realize, in an amount proportionate to the comparative responsibility and degree of fault of Cross-
2 Complainants and Cross-Defendants, and each of them.
3 17. As a direct and proximate result of the acts of Cross-Defendants, and each of them,
4 Cross-Complainants have incurred the costs of suit, attorney's fees and investigation expenses.
5 Cross-Complainants are entitled to recover from Cross-Defendants, and each of them, those amounts
6 expended for costs of suit, attorney's fees and investigation.
? THIRD CAUSE OF ACTION
8 (Declaratory Relief - Equitable Apportionment)
9 18. Cross-Complainants hereby incorporates by reference each and every allegation
10 | contained in Paragraphs 1-17, inclusive, of the First and Second Causes of Action, as though fully set
11] forth at length herein.
12 19, An actual controversy has arisen and now exists between Cross-Complainants and
13] Cross-Defendants, and each of them, regarding the respective liability and the responsibility of Cross-
14 Defendants, and each of them, for the alleged injuries of Plaintiff.
15 20. Cross-Complainants contend that if Plaintiff suffered or sustained any loss, injury,
16 | damage or detriment, the same was directly and proximately caused and contributed by the primary,
17] active, sole and direct responsibility and contributory negligence of the Cross-Defendants, and each
18] of them.
19 21. Cross-Complainants are not liable for any damages incurred by Plaintiff from the
20 | above-described incidents.
21 22. If Cross-Complainants are held liable, which liability is specifically denied, Cross-
22 Complainants should be only partially responsible for the alleged injuries, damages and other
23 | detriment allegedly suffered or sustained by the Plaintiff. Such partial responsibility should be based
24 | upon the finding that Cross-Defendants, and each of them, were negligent or otherwise responsible
25 | for the alleged injuries and damages. The distribution of those responsibilities among Cross-
26 | Complainants and Cross-Defendants, and each of them, should be apportioned on the basis of their
27 | respective percentages of negligence and responsibility in contributing to the alleged damages.
28 23. Cross-Defendants, and each of them, have a duty to contribute and indemnify Cross-
reer ne 4
SAN FRANCISCO, CA 94ITL CROSS-COMPLAINT
(415) 31821492co ON DH PB WH
NY N YY NY WY wv
Waa ORE SSCREATRGESH IG
28
Muwak, Romenrs,
Complainants for any recovery that Plaintiff may realize, in an amount proportionate to the
comparative negligence and responsibility of Cross-Complainants and Cross-Defendants, and each of
them.
24. If Cross-Complainants are held liable, which liability is specifically denied, Cross-
Complainants should be entitled to bear responsibility for a several judgment separate and distinct
from any joint and/or several liability judgment that might be rendered against Cross-Defendants, and
each of them.
25. Asa direct and proximate result of the acts of Cross-Defendants, and each of them,
Cross-Complainants have incurred the costs of suit, attorney's fees and investigation expenses.
Cross-Complainants are entitled to recover from Cross-Defendants, and each of them, those amounts
expended for costs of suit, attorney's fees and investigation expenses.
26. Cross-Complainants desire a judicial determination of the duties, rights and liabilities,
if any, of each and every party herein for the damages alleged by Plaintiff SPECK CAB COMPANY
dba VETERANS CAB COMPANY.
FOURTH CAUSE OF ACTION
Negligence
27. The Cross-defendant who operated the motor vehicle is ROE 1. The Cross-defendants
who owned the motor vehicle which was operated with their permission are SPECK CAB
COMPANY dba VETERANS CAB COMPANY and ROES 1-10.
28. On or about April 22, 2004, on or near the intersection of Fell and Masonic in the City
and County of San Francisco, California, Cross-defendants negligently owned, operated, maintained,
and or in trusted their vehicle so as to collide with Cross-Complainants’ vehicle.
29, As a result of Cross-defendant’s negligence, and each of them, Cross-complainants
have suffered injury to their property. As a result of Cross-defendant’s negligence, and each of
them, Cross-complainants have suffered property damage which cross-defendants at this time are
informed and believe to be in the amount of $19,835.98, as well as loss of use of property in an
amount yet to be ascertained.
WHEREFORE, Cross-Complainants pray for judgment against Cross-Defendants, and each
Pama, KRAMER & MONTY 5
UPRONT STREET, STE. 500
‘AN FRANCISCO, CA 94111 CROSS-COMPLAINT
(AIS) 318-4921 of them, as follows:
2
3 FIRST CAUSE OF ACTION:
4 For judgment against Cross-Defendants, and each of them, declaring that they are under a
5 duty to indemnify Cross-Complainants for the full amount of any judgment rendered against them.
6
7 SECOND CAUSE OF ACTION:
8 For judgment against Cross-Defendants, and each of them, declaring that they are under a
9 duty to partially indemnify Cross-Complainants for a proportionate amount of any judgment rendered
10 against them.
i THIRD CAUSE OF ACTION:
12 For judgment against Cross-Defendants, and each of them, declaring that the liability for the
13 damages alleged by the Plaintiff must be borne proportionately by the Cross-Defendants, and each of
14 them, and that Cross-Complainants bear no liability with respect to any of the damages allegedly
15 resulting from the incident involved herein or any damages allegedly suffered by Plaintiff SPECK
16 CAB COMPANY dba VETERANS CAB COMPANY.
"7 For judgment against Cross-Defendants, and each of them, declaring that they may recover
18 from Cross-Complainants only so much of the damages allegedly sustained as bears a proportion to
19 the responsibility of Cross-Complainants in bringing about said damages.
20
21
FOURTH CAUSE OF ACTION:
2 . .
2 For judgment against Cross-Defendants, and each of them, for compensatory damages
23 .
according to proof.
24
25
ON ALL CAUSES OF ACTION:
26 1. For costs of suit incurred herein;
7 2. For attorney's fees;
28
aaa Kann & Mowry 6
1 Frowt STREET, STE. 500
SAN FRANCISCO, CA94111 CROSS-COMPLAINT
(415) 318514923. For investigation expenses;
4. For such further relief as the court may deem just and proper.
DATED: ul Ho 5 MUHAR, ROBERTS,
Thomas M. Crowell, Esq.
Attorney for Defendants, MATHEW MELENDRES
DEASIS and ALICIA DEASIS
oot Dn FF WwW NY
Ny NY YN WN
SaaS SSK SSECRRVRAREBDHSS
28
Monan, Roaents,
Fa, KRAMER £ MONTY 7
U FRONT STREET, STE. 500
SAN FRANCISCO, CA 94111 CROSS-COMPLAINT
(415) 318-1492
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OU San Francisco Superior Courts Information Technology Group Document Scanning Lead Sheet Apr-21-2005 1:40 pm Case Number: CGC-04-435182 Filing Date: Apr-15-2005 1:29 Juke Box: 001 Image: 01183454 CROSS COMPLAINT *ECK CAB COMPANY DBA VETERANS CAB COMPANY VS. MATHEW MELANDRES DEA 001001183454 Instructions: Please place this sheet on top of the document to be scanned.1 | Thomas M. Crowell [SBN 172799] FILED ar MUHAR, ROBERTS, SUPERIOR GO cISCO 2| FAMA, KRAMER & MONTY COUNTY OF SA\ One Front Street, Suite 500 005 3] San Francisco, CA 94111 APR 15 a Telephone: (415) 318-1492 ARK-LI, Clerk 4 | Facsimile: (415) 296-8582 GORDOYP _ BY: Deputy Cierk 5] Attorney for: Defendants, MATHEW MELENDRES DEASIS 6] and ALICIA DEASIS a 7 & a 8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE COUNTY OF SAN FRANCISCO 10 LIMITED JURISDICTION 11 12 | SPECK CAB COMPANY dba VETERANS Case No.: CGC-04-435182 CAB COMPANY, 13 CROSS-COMPLAINT OF Plaintiff, MATHEW MELENDRES DEASIS 14 and ALICIA DEASIS 1 5 Vv. MATHEW MELENDRES DEASIS, ALICIA 16] DEASIS; and DOES 1 - 20, 17 Defendants. / 18 MATHEW MELENDRES DEASIS and ALICIA 19] DEASIs, 20 Cross-Complainants, 2 1 ve. SPECK CAB COMPANY dba VETERANS 22 | CAB COMPANY; and ROES 1 -10, inclusive, 23 Cross-Defendants. 24 25 6 COMES NOw, Defendant/Cross-Complainants, MATHEW MELENDRES DEASIS and 7 ALICIA DEASIS and, as against Cross-Defendants SPECK CAB COMPANY dba VETERANS 28 CAB COMPANY and ROES 1-10, allege as follows: MUWAR, RoBERTs, FAMA, KRAMER de MONTY 1 I Faowt Staeer, Ste, 500 IAN FRANCISCO, CA_94111 CROSS-COMPLAINT (415) 318-14921 FIRST CAUSE OF ACTION 2 (Total Indemnity) 3 1. At all times herein mentioned, Cross-Complainants were individuals residing in the 4] State of California. 5 2. Cross-Complainants are informed and believe and thereon allege that Cross-Defendant 6] SPECK CAB COMPANY dba VETERANS CAB COMPANY is a business entity, form unknown, 7 | doing business in the State of California. 8 3. The true names and capacities of Cross-Defendants ROES 1-10, inclusive, are 9] unknown to Cross-Complainants. Cross-Compiainants, therefore, sue said Cross-Defendants by such 10 | fictitious names. Cross-Complainants will seek leave of Court to amend this Cross-Complaint to 11] insert the true names and capacities of the fictitiously named Cross-Defendants when the same have 12] been ascertained. 13 4. Cross-Complainants are informed and believe and thereon allege that each Cross- 14] Defendant desi gnated as a ROE herein is responsible in some manner for the acts, occurrences and 15 | liabilities hereinafter alleged and referred to, 16 5. At all times herein mentioned, each Cross-Defendant was the agent, servant and 17 | employee of each and every other remaining Cross-Defendant, and the acts of each Cross-Defendant 18] was within the course and scope of said agency and employment. 19 6. Plaintiff filed a Complaint in the Superior Court for the County of San Francisco 20 alleging that as a direct and proximate result of Defendants’ negligence, the damages, as alleged in 21] the Complaint, were incurred by the Plaintiff. 22 7. An actual controversy has arisen and now exists between Cross-Complainants and 23 | Cross-Defendants, and each of them, regarding the rights, obligations and duties of the Cross- 24| Defendants which exist between Cross-Complainants and the Cross-Defendants, and each of them. 25 8. Cross-Complainants contend that if they are held liable, which liability is specifically 26 | denied, then Cross-Defendants, and each of them, are primarily and actively responsible and 27 | negligent in causing and bringing about the alleged injuries to Plaintiff. Any liability of Cross- 28 | Complainants will be computed on the basis of vicarious or secondary liability and not as a result of Faun Kate Novy 2 UFrowr Sraeer, STE, $00 SAN FRANCISCO, CA 94111 CROSS-COMPLAINT (415) 318-1492.! any active negligence or any other acts on the part of Cross-Complainants. 2 9. Cross-Complainants have not been negligent or responsible in any manner whatsoever 3 for the alleged injuries to Plaintiff. 4 10. If Cross-Complainants are held liable, which liability is specifically denied, then 5 Cross-Defendants, and each of them, are directly, actively and primarily responsible for, and 6 contributorily negligent in causing the injuries to Plaintiff. 7 11. Cross-Complainants are entitled to be indemnified for any and all recovery that 8 Plaintiff may realize against Cross-Complainants. ° SECOND CAUSE OF ACTION 10 (Declaratory Relief - Implied Partial Indemnity) 11 12. Cross-Complainants hereby incorporate by reference each and every allegation 12] contained in Paragraphs 1-11 inclusive, of the First Cause of Action, as though fully set forth at 13] length herein. 14 13. Cross-Complainants contend that if they are held liable in any ascertainable 15 | percentage, that percentage is not equal to total or complete liability and that the remaining 16 percentage of liability should be assessed against Cross-Defendants, and each of them, according to 17 | the principles of partial indemnity. 18 14. Cross-Complainants are not singularly, uniquely or totally liable for any damages 19} incurred by Plaintiff. 20 15. If Cross-Complainants are held liable, which liability is specifically denied, Cross- 21] Complainants should be only partially responsible for the alleged injuries, damages and other 22] detriment allegedly suffered or sustained by Plaintiff. Such partial responsibility should be based 23] upon the finding that Cross-Defendants, and each of them, were negligent or otherwise responsible 24 | for the alleged injuries and damages. The distribution of those responsibilities among Cross- 25 | Complainants and Cross-Defendants, and each of them, should be apportioned on the basis of partial 26 | indemnity. 27 16. Cross-Defendants, and each of them, have a duty to indemnify Cross-Complainants 28 | for any recovery that Plaintiff SPECK CAB COMPANY dba VETERANS CAB COMPANY may rest 3 SAN FRANCISCO, CA 94111 CROSS-COMPLAINT1 realize, in an amount proportionate to the comparative responsibility and degree of fault of Cross- 2 Complainants and Cross-Defendants, and each of them. 3 17. As a direct and proximate result of the acts of Cross-Defendants, and each of them, 4 Cross-Complainants have incurred the costs of suit, attorney's fees and investigation expenses. 5 Cross-Complainants are entitled to recover from Cross-Defendants, and each of them, those amounts 6 expended for costs of suit, attorney's fees and investigation. ? THIRD CAUSE OF ACTION 8 (Declaratory Relief - Equitable Apportionment) 9 18. Cross-Complainants hereby incorporates by reference each and every allegation 10 | contained in Paragraphs 1-17, inclusive, of the First and Second Causes of Action, as though fully set 11] forth at length herein. 12 19, An actual controversy has arisen and now exists between Cross-Complainants and 13] Cross-Defendants, and each of them, regarding the respective liability and the responsibility of Cross- 14 Defendants, and each of them, for the alleged injuries of Plaintiff. 15 20. Cross-Complainants contend that if Plaintiff suffered or sustained any loss, injury, 16 | damage or detriment, the same was directly and proximately caused and contributed by the primary, 17] active, sole and direct responsibility and contributory negligence of the Cross-Defendants, and each 18] of them. 19 21. Cross-Complainants are not liable for any damages incurred by Plaintiff from the 20 | above-described incidents. 21 22. If Cross-Complainants are held liable, which liability is specifically denied, Cross- 22 Complainants should be only partially responsible for the alleged injuries, damages and other 23 | detriment allegedly suffered or sustained by the Plaintiff. Such partial responsibility should be based 24 | upon the finding that Cross-Defendants, and each of them, were negligent or otherwise responsible 25 | for the alleged injuries and damages. The distribution of those responsibilities among Cross- 26 | Complainants and Cross-Defendants, and each of them, should be apportioned on the basis of their 27 | respective percentages of negligence and responsibility in contributing to the alleged damages. 28 23. Cross-Defendants, and each of them, have a duty to contribute and indemnify Cross- reer ne 4 SAN FRANCISCO, CA 94ITL CROSS-COMPLAINT (415) 31821492co ON DH PB WH NY N YY NY WY wv Waa ORE SSCREATRGESH IG 28 Muwak, Romenrs, Complainants for any recovery that Plaintiff may realize, in an amount proportionate to the comparative negligence and responsibility of Cross-Complainants and Cross-Defendants, and each of them. 24. If Cross-Complainants are held liable, which liability is specifically denied, Cross- Complainants should be entitled to bear responsibility for a several judgment separate and distinct from any joint and/or several liability judgment that might be rendered against Cross-Defendants, and each of them. 25. Asa direct and proximate result of the acts of Cross-Defendants, and each of them, Cross-Complainants have incurred the costs of suit, attorney's fees and investigation expenses. Cross-Complainants are entitled to recover from Cross-Defendants, and each of them, those amounts expended for costs of suit, attorney's fees and investigation expenses. 26. Cross-Complainants desire a judicial determination of the duties, rights and liabilities, if any, of each and every party herein for the damages alleged by Plaintiff SPECK CAB COMPANY dba VETERANS CAB COMPANY. FOURTH CAUSE OF ACTION Negligence 27. The Cross-defendant who operated the motor vehicle is ROE 1. The Cross-defendants who owned the motor vehicle which was operated with their permission are SPECK CAB COMPANY dba VETERANS CAB COMPANY and ROES 1-10. 28. On or about April 22, 2004, on or near the intersection of Fell and Masonic in the City and County of San Francisco, California, Cross-defendants negligently owned, operated, maintained, and or in trusted their vehicle so as to collide with Cross-Complainants’ vehicle. 29, As a result of Cross-defendant’s negligence, and each of them, Cross-complainants have suffered injury to their property. As a result of Cross-defendant’s negligence, and each of them, Cross-complainants have suffered property damage which cross-defendants at this time are informed and believe to be in the amount of $19,835.98, as well as loss of use of property in an amount yet to be ascertained. WHEREFORE, Cross-Complainants pray for judgment against Cross-Defendants, and each Pama, KRAMER & MONTY 5 UPRONT STREET, STE. 500 ‘AN FRANCISCO, CA 94111 CROSS-COMPLAINT (AIS) 318-4921 of them, as follows: 2 3 FIRST CAUSE OF ACTION: 4 For judgment against Cross-Defendants, and each of them, declaring that they are under a 5 duty to indemnify Cross-Complainants for the full amount of any judgment rendered against them. 6 7 SECOND CAUSE OF ACTION: 8 For judgment against Cross-Defendants, and each of them, declaring that they are under a 9 duty to partially indemnify Cross-Complainants for a proportionate amount of any judgment rendered 10 against them. i THIRD CAUSE OF ACTION: 12 For judgment against Cross-Defendants, and each of them, declaring that the liability for the 13 damages alleged by the Plaintiff must be borne proportionately by the Cross-Defendants, and each of 14 them, and that Cross-Complainants bear no liability with respect to any of the damages allegedly 15 resulting from the incident involved herein or any damages allegedly suffered by Plaintiff SPECK 16 CAB COMPANY dba VETERANS CAB COMPANY. "7 For judgment against Cross-Defendants, and each of them, declaring that they may recover 18 from Cross-Complainants only so much of the damages allegedly sustained as bears a proportion to 19 the responsibility of Cross-Complainants in bringing about said damages. 20 21 FOURTH CAUSE OF ACTION: 2 . . 2 For judgment against Cross-Defendants, and each of them, for compensatory damages 23 . according to proof. 24 25 ON ALL CAUSES OF ACTION: 26 1. For costs of suit incurred herein; 7 2. For attorney's fees; 28 aaa Kann & Mowry 6 1 Frowt STREET, STE. 500 SAN FRANCISCO, CA94111 CROSS-COMPLAINT (415) 318514923. For investigation expenses; 4. For such further relief as the court may deem just and proper. DATED: ul Ho 5 MUHAR, ROBERTS, Thomas M. Crowell, Esq. Attorney for Defendants, MATHEW MELENDRES DEASIS and ALICIA DEASIS oot Dn FF WwW NY Ny NY YN WN SaaS SSK SSECRRVRAREBDHSS 28 Monan, Roaents, Fa, KRAMER £ MONTY 7 U FRONT STREET, STE. 500 SAN FRANCISCO, CA 94111 CROSS-COMPLAINT (415) 318-1492