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PLD-PI-001
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
David K. Cohn, SBN 68768 \ Chad J. A. Boyles, SBN 276508
CHAIN | COHN | CLARK, A Law Corporation
1731 Chester Avenue
Bakersfield, CA 93301
TELEPHONE NO: (661) 323-4000 FAX NO. (Optional): (661) 324-1352
E-MAIL ADDRESS (Optional): dcohn@chainlaw.com; cboyles@chainlaw.com
ATTORNEY FOR (Name): Plaintiff JADYN DANETTE CALVILLO
SUPERIOR COURT OF CALIFORNIA, COUNTY OF KERN
STREET ADDRESS: 1215 Truxtun Avenue
MAILING ADDRESS: -
CITY AND ZIP CODE: Bakersfield 93301
BRANCH NAME: Metropolitan Division
PLAINTIFF: JADYN DANETTE CALVILLO
DEFENDANT: CRUZ OLIVIA GASTELUM SOTO; and
X DOES 1 TO 50, inclusive
COMPLAINT—Personal Injury, Property Damage, Wrongful Death
AMENDED (Number):
Type (check all that apply):
X MOTOR VEHICLE OTHER (specify):
Property Damage Wrongful Death
X Personal Injury Other Damages (specify):
Jurisdiction (check all that apply): CASE NUMBER:
ACTION IS A LIMITED CIVIL CASE
Amount demanded does not exceed $10,000
exceeds $10,000, but does not exceed $25,000
X ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000)
ACTION IS RECLASSIFIED by this amended complaint
from limited to unlimited
from unlimited to limited
1. Plaintiff (name or names): JADYN DANETTE CALVILLO
alleges causes of action against defendant (name or names): CRUZ OLIVIA GASTELUM SOTO and DOES 1 to 50, inclusive
2. This pleading, including attachments and exhibits, consists of the following number of pages: 4
3. Each plaintiff named above is a competent adult
a. except plaintiff (name):
(1) a corporation qualified to do business in California
(2) an unincorporated entity (describe):
(3) a public entity (describe):
(4) a minor an adult
(a) for whom a guardian or conservator of the estate or a guardian ad litem has been appointed
(b) other (specify):
(5) other (specify):
b. except plaintiff (name):
(1) a corporation qualified to do business in California
(2) an unincorporated entity (describe):
(3) a public entity (describe):
(4) a minor an adult
(a) for whom a guardian or conservator of the estate or a guardian ad litem has been appointed
(b) other (specify):
(5) other (specify):
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-PI-001 [Rev. January 1, 2007] Damage, Wrongful Death
LexisNexis® Automated California Judicial Council Forms
PLD-PI-001
SHORT TITLE: CASE NUMBER:
Calvilllo v. Soto
4. 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. X except defendant (name): DOES 1 to 10 c. X except defendant (name): DOES 21 to 30
(1) X a business organization, form unknown (1) a business organization, form unknown
(2) a corporation (2) a corporation
(3) an unincorporated entity (describe): (3) X an unincorporated entity (describe):
(4) a public entity (describe): (4) a public entity (describe):
(5) other (specify): (5) other (specify):
b. X except defendant (name): DOES 11 to 20 d. except defendant (name):
(1) a business organization, form unknown (1) a business organization, form unknown
(2) X a corporation (2) a corporation
(3) an unincorporated entity (describe): (3) an unincorporated entity (describe):
(4) a public entity (describe): (4) a public entity (describe):
(5) other (specify): (5) other (specify):
Information about additional defendants who are not natural persons is contained in Attachment 5.
6. The true names of defendants sued as Does are unknown to plaintiff.
a. X 1 to 50
Doe defendants (specify Doe numbers): _________________________ were the agents or employees of other
named defendants and acted within the scope of that agency or employment.
b. X 1 to 50
Doe defendants (specify Doe numbers):_________________________ are persons whose capacities are unknown to
plaintiff.
7. Defendants who are joined under Code of Civil Procedure section 382 are (names):
8. This court is the proper court because
a. at least one defendant now resides in its jurisdictional area.
b. the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area.
c. X injury to person or damage to personal property occurred in its jurisdictional area.
d. other (specify):
9. Plaintiff is required to comply with a claims statute, and
a. has complied with applicable claims statutes, or
b. is excused from complying because (specify):
PLD-PI-001 [Rev. January 1, 2007] COMPLAINT—Personal Injury, Property Page 2 of 3
Damage, Wrongful Death
LexisNexis® Automated California Judicial Council Forms
PLD-PI-001
SHORT TITLE: CASE NUMBER:
Calvilllo v. Soto
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. X Motor Vehicle
b. General Negligence
c. Intentional Tort
d. Products Liability
e. Premises Liability
f. Other (specify):
11. Plaintiff has suffered
a. X wage loss
b. loss of use of property
c. X hospitaland medical expenses
d. X general damage
e. property damage
f. X loss of earning capacity
g. other damage (specify):
12. The damages claimed for wrongful death and the relationships of plaintiff to the deceased are
a. listed in Attachment 12.
b. as follows:
13. The relief sought in this complaint is within the jurisdiction of this court.
14. Plaintiff prays for judgment for costs of suit; for such relief as is fair, just, and equitable; and for
a. (1) X compensatory damages
(2) punitive damages
The amount of damages is (in cases for personal injury or wrongful death, you must check (1)):
(1) X according to proof
(2) in the amount of: $
15. X The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers):
5a; 5b; 5c; 15: At all times mentioned herein, Defendants, and each of them, were the agents and employees of each of the
remaining Defendants, and acted within the course and scope of said agency and employment.
Date: October 10, 2022
Chad J. A. Boyles
(TYPE OR PRINT NAME) (SIGNATURE OF PLAINTIFF OR ATTORNEY)
PLD-PI-001 [Rev. January 1, 2007] COMPLAINT—Personal Injury, Property Page 3 of 3
Damage, Wrongful Death
LexisNexis® Automated California Judicial Council Forms
PLD-PI-001(1)
SHORT TITLE: CASE NUMBER:
Calvilllo v. Soto
FIRST CAUSE OF ACTION—Motor Vehicle
(number)
ATTACHMENT TO X Complaint Cross - Complaint
(Use a separate cause of action form for each cause of action.)
Plaintiff (name):JADYN DANETTE CALVILLO
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): or about January 29, 2021
at (place): or near Casa Loma Drive at Madison Street, Bakersfield, Kern County, California.
At said time and place, Defendants, and
each of them, did negligently and carelessly own, rent, lease, bail, operate, control, repair, maintain and entrust that certain
2010 Toyota Corolla bearing license 6LNU122, so as to cause the same to collide with a 2002 Hyundai Accent bearing
license 4VGY832 being operated by Plaintiff JADYN DANETTE CALVILLO, thereby directly and proximately causing
the damages complained of herein to Plaintiff.
MV- 2. DEFENDANTS
a. X The defendants who operated a motor vehicle are (names): CRUZ OLIVIA GASTELUM SOTO; and
X Does 1 to 50
b. X The defendants who employed the persons who operated a motor vehicle in the course of their employment
are (names): CRUZ OLIVIA GASTELUM SOTO; and
X Does 1 to 50
c. X The defendants who owned the motor vehicle which was operated with their permission are (names):
CRUZ OLIVIA GASTELUM SOTO; and
X Does 1 to 50
d. X The defendants who entrusted the motor vehicle are (names): CRUZ OLIVIA GASTELUM SOTO; and
X Does 1 to 50
e. X The defendants who were the agents and employees of the other defendants and acted within the scope
of the agency were (names): CRUZ OLIVIA GASTELUM SOTO; and
X Does 1 to 50
f. The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are
listed in Attachment MV-2f as follows:
Does to 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-PI-001(1) [Rev. January 1, 2007]
LexisNexis® Automated California Judicial Council Forms
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PLD-PI-001 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY David K. Cohn, SBN 68768 \ Chad J. A. Boyles, SBN 276508 CHAIN | COHN | CLARK, A Law Corporation 1731 Chester Avenue Bakersfield, CA 93301 TELEPHONE NO: (661) 323-4000 FAX NO. (Optional): (661) 324-1352 E-MAIL ADDRESS (Optional): dcohn@chainlaw.com; cboyles@chainlaw.com ATTORNEY FOR (Name): Plaintiff JADYN DANETTE CALVILLO SUPERIOR COURT OF CALIFORNIA, COUNTY OF KERN STREET ADDRESS: 1215 Truxtun Avenue MAILING ADDRESS: - CITY AND ZIP CODE: Bakersfield 93301 BRANCH NAME: Metropolitan Division PLAINTIFF: JADYN DANETTE CALVILLO DEFENDANT: CRUZ OLIVIA GASTELUM SOTO; and X DOES 1 TO 50, inclusive COMPLAINT—Personal Injury, Property Damage, Wrongful Death AMENDED (Number): Type (check all that apply): X MOTOR VEHICLE OTHER (specify): Property Damage Wrongful Death X Personal Injury Other Damages (specify): Jurisdiction (check all that apply): CASE NUMBER: ACTION IS A LIMITED CIVIL CASE Amount demanded does not exceed $10,000 exceeds $10,000, but does not exceed $25,000 X ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000) ACTION IS RECLASSIFIED by this amended complaint from limited to unlimited from unlimited to limited 1. Plaintiff (name or names): JADYN DANETTE CALVILLO alleges causes of action against defendant (name or names): CRUZ OLIVIA GASTELUM SOTO and DOES 1 to 50, inclusive 2. This pleading, including attachments and exhibits, consists of the following number of pages: 4 3. Each plaintiff named above is a competent adult a. except plaintiff (name): (1) a corporation qualified to do business in California (2) an unincorporated entity (describe): (3) a public entity (describe): (4) a minor an adult (a) for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b) other (specify): (5) other (specify): b. except plaintiff (name): (1) a corporation qualified to do business in California (2) an unincorporated entity (describe): (3) a public entity (describe): (4) a minor an adult (a) for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b) other (specify): (5) other (specify): 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-PI-001 [Rev. January 1, 2007] Damage, Wrongful Death LexisNexis® Automated California Judicial Council Forms PLD-PI-001 SHORT TITLE: CASE NUMBER: Calvilllo v. Soto 4. 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. X except defendant (name): DOES 1 to 10 c. X except defendant (name): DOES 21 to 30 (1) X a business organization, form unknown (1) a business organization, form unknown (2) a corporation (2) a corporation (3) an unincorporated entity (describe): (3) X an unincorporated entity (describe): (4) a public entity (describe): (4) a public entity (describe): (5) other (specify): (5) other (specify): b. X except defendant (name): DOES 11 to 20 d. except defendant (name): (1) a business organization, form unknown (1) a business organization, form unknown (2) X a corporation (2) a corporation (3) an unincorporated entity (describe): (3) an unincorporated entity (describe): (4) a public entity (describe): (4) a public entity (describe): (5) other (specify): (5) other (specify): Information about additional defendants who are not natural persons is contained in Attachment 5. 6. The true names of defendants sued as Does are unknown to plaintiff. a. X 1 to 50 Doe defendants (specify Doe numbers): _________________________ were the agents or employees of other named defendants and acted within the scope of that agency or employment. b. X 1 to 50 Doe defendants (specify Doe numbers):_________________________ are persons whose capacities are unknown to plaintiff. 7. Defendants who are joined under Code of Civil Procedure section 382 are (names): 8. This court is the proper court because a. at least one defendant now resides in its jurisdictional area. b. the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area. c. X injury to person or damage to personal property occurred in its jurisdictional area. d. other (specify): 9. Plaintiff is required to comply with a claims statute, and a. has complied with applicable claims statutes, or b. is excused from complying because (specify): PLD-PI-001 [Rev. January 1, 2007] COMPLAINT—Personal Injury, Property Page 2 of 3 Damage, Wrongful Death LexisNexis® Automated California Judicial Council Forms PLD-PI-001 SHORT TITLE: CASE NUMBER: Calvilllo v. Soto 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. X Motor Vehicle b. General Negligence c. Intentional Tort d. Products Liability e. Premises Liability f. Other (specify): 11. Plaintiff has suffered a. X wage loss b. loss of use of property c. X hospitaland medical expenses d. X general damage e. property damage f. X loss of earning capacity g. other damage (specify): 12. The damages claimed for wrongful death and the relationships of plaintiff to the deceased are a. listed in Attachment 12. b. as follows: 13. The relief sought in this complaint is within the jurisdiction of this court. 14. Plaintiff prays for judgment for costs of suit; for such relief as is fair, just, and equitable; and for a. (1) X compensatory damages (2) punitive damages The amount of damages is (in cases for personal injury or wrongful death, you must check (1)): (1) X according to proof (2) in the amount of: $ 15. X The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers): 5a; 5b; 5c; 15: At all times mentioned herein, Defendants, and each of them, were the agents and employees of each of the remaining Defendants, and acted within the course and scope of said agency and employment. Date: October 10, 2022 Chad J. A. Boyles (TYPE OR PRINT NAME) (SIGNATURE OF PLAINTIFF OR ATTORNEY) PLD-PI-001 [Rev. January 1, 2007] COMPLAINT—Personal Injury, Property Page 3 of 3 Damage, Wrongful Death LexisNexis® Automated California Judicial Council Forms PLD-PI-001(1) SHORT TITLE: CASE NUMBER: Calvilllo v. Soto FIRST CAUSE OF ACTION—Motor Vehicle (number) ATTACHMENT TO X Complaint Cross - Complaint (Use a separate cause of action form for each cause of action.) Plaintiff (name):JADYN DANETTE CALVILLO 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): or about January 29, 2021 at (place): or near Casa Loma Drive at Madison Street, Bakersfield, Kern County, California. At said time and place, Defendants, and each of them, did negligently and carelessly own, rent, lease, bail, operate, control, repair, maintain and entrust that certain 2010 Toyota Corolla bearing license 6LNU122, so as to cause the same to collide with a 2002 Hyundai Accent bearing license 4VGY832 being operated by Plaintiff JADYN DANETTE CALVILLO, thereby directly and proximately causing the damages complained of herein to Plaintiff. MV- 2. DEFENDANTS a. X The defendants who operated a motor vehicle are (names): CRUZ OLIVIA GASTELUM SOTO; and X Does 1 to 50 b. X The defendants who employed the persons who operated a motor vehicle in the course of their employment are (names): CRUZ OLIVIA GASTELUM SOTO; and X Does 1 to 50 c. X The defendants who owned the motor vehicle which was operated with their permission are (names): CRUZ OLIVIA GASTELUM SOTO; and X Does 1 to 50 d. X The defendants who entrusted the motor vehicle are (names): CRUZ OLIVIA GASTELUM SOTO; and X Does 1 to 50 e. X The defendants who were the agents and employees of the other defendants and acted within the scope of the agency were (names): CRUZ OLIVIA GASTELUM SOTO; and X Does 1 to 50 f. The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are listed in Attachment MV-2f as follows: Does to 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-PI-001(1) [Rev. January 1, 2007] LexisNexis® Automated California Judicial Council Forms