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AITO
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
May-14-2012 1:52 pm
Case Number: CGC-12-520772
Filing Date: May-14-2012 1:49
Filed by: ELIAS BUTT
Juke Box: 001 Image: 03613805
COMPLAINT
T'JADE JACKSON VS. CITY AND COUNTY OF SAN FRANCISCO et al
001003613805
Instructions:
Please place this sheet on top of the document to be scanned.PLD-PI-001
, ATTORNEY OR FARTY WITHOUT ATTORNEY (Name, Ox and address). @ FOR COURT USE ONLY
|- Sanford M. Cipinko, Esq., SBN 88102
Law Offices of Sanford M. Cipinko
55 Francisco Street, Suite 403
San Francisco, CA 94133
revepvoneno. (415) 693-9905 FAXNo (Option (415) 693-9904
E-MAIL ADDRESS (Optenst) scipinko@cipinkolaw.com
ATTORNEY FOR Name) T'Jade Jackson
SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Francisco
streetaporess 400 McAllister Street
MAILING ADDRESS:
eiryannziecooe San Francisco, CA 94102
BRANCH NAME
PLAINTIFF: T' Jade Jackson
THE GO
fey 14
Se Gierk
DEFENDANT: City and County of San Francisco,
David Ebarle, Robert Rubeshaw
GQ does 1 To 50
COMPLAINT-Personal Injury, Property Damage, Wrongful Death
(2) AMENDED (Number):
Type (check ali that apply):
CQ) MOTOR VEHICLE = (2): OTHER (specify):
(CJ Property Damage = (L] Wrongful Death
(X] Personal Injury (2) Other Damages (specify):
| Jurisdiction (check ail that apply): ‘CASE NUMBER:
{L] ACTION IS A LIMITED CIVIL CASE
Amount demanded oOo does not exceed $10,000
Co] exceeds $10,000, but does not exceed $25,000 ~ - .
[Q) ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000) c & c . i 2 5 2 6 ? ? 2
() ACTION IS RECLASSIFIED by this amended complaint
(2) from limited to unlimited
©) from unlimited to limited
1. Plaintiff (name ornames)) T' Jade Jackson
alleges causes of action against defendant (name ornames)) City and County of San Francisco
David Ebarle, Robert Rubeshaw and DOES 1 to 50
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. (CL) except plaintiff (name):
(1) () a corporation qualified to do business in California
2) (_] an unincorporated entity (describe):
(3) CC) a public entity (describe):
(4) CQ aminor (2) an adult
(a) (C) for whom a guardian or conservator of the estate or a guardian ad litem has been appointed
(b) (2) other (specify):
5) LL] other (specify):
b. CC) except plaintiff (name):
(1) ) a corporation qualified to do business in California
(2) (2) an unincorporated entity (describe):
(3) (CC) a public entity (describe):
(4) CQ) aminor () an adutt
(a) (] for whom a guardian or conservator of the estate ora guardian ad litem has been appointed
(b) (2) other (specify):
(5) (2) other (specify):
(} Information about additional plaintiffs who are not competent adults is shown in Attachment 3.
Page 1of3
FOr eect eno Mart Deans COMPLAINT-Personal Injury, Property Gado of Cw Procedure § 425 12
Bieri Rev lanay 207k = ESSEMTIAL FORMS" Damage, Wrongful Death
Jackson, T'JadePLD-P1t-001
SHORT TITLE: @
Jackson v. CCSF
4. () Plaintiff (name): T' dade Jackson
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. [QJ except defendant (name):
City and County of San Francisco
(1) (2) abusiness organization, form unknown
(2) (2) acorporation
(3) [) an unincorporated entity (describe):
(4) [) a public entity (describe):
(6) (2) other (specify):
b. (L) except defendant (name):
(1) (2) abusiness organization, form unknown
(2) (2) acorporation
(3) () an unincorporated entity (describe):
(4) oO a public entity (describe):
(5) (2) other (specify):
c. C) except defendant (name):
(1) oO @ business organization, form unknown
(2) () acorporation
(3) () an unincorporated entity (describe)
(4) (Ch a public entity (describe):
(5) (2) other (specify):
d. Co) except defendant (name):
(1) (2) a business organization, form unknown
(2) (2) acorporation
(3) (CQ an unincorporated entity (describe):
(4) [LQ a public entity (describe):
(5) (2) other (specify):
(CJ 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) Doe defendants (specify Doe numbers); i=50 were the agents or employees of other
named defendants and acted within the scope of that agency or employment.
b. [3] Doe defendants (specify Doe numbers): 1=50 are persons whose capacities are unknown to
plaintiff.
7. (2) Defendants who are joined under Code of Civil Procedure section 382 are (names):
8. This court is the proper court because
a. [2] at least one defendant now resides in its jurisdictional area.
b. (C) the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area
c. QE) injury to person or damage to personal property occurred in its jurisdictional area.
d. () other (specify):
9. [X) Plaintiff is required to comply with a claims statute, and
a. (J has complied with applicable claims statutes, or
b. (2) is excused from complying because (specify):
PLD-PI-001 [Rev January 1, 2007]
oy ve
+2 sem RMS
COMPLAINT-Personal Injury, Property
Damage, Wrongful Death
Page 2 of 3
Jackson, T' JadePLD-P1-001
| SHORT TITLE @ NUMBER
Jackson v. CCSF
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):
[QJ Motor Vehicle
C) General Negligence
(CC) Intentional Tort
(CL) Products Liability
C) Premises Liability
LL) Other (specify) :
meaoce
11. Plaintiff has suffered
QQ) wage loss
oO loss of use of property
[CX] hospital and medical expenses
(QJ general damage
() property damage
[loss of earning capacity
[QD other damage (specify) :
Loss of Household Services
a@-7eancp
12. (2) The damages claimed for wrongful death and the relationships of plaintiff to the deceased are
a. (C1 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) compensatory damages
(2) CQ punitive damages
The amount of damages is (in cases for personal injury or wrongful death, you must check (1):
(1) QQ) according to proof
(2) (C) in the amount of: $
15. [X] The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers):
10-14, MV1-MV2
Date: May 14, 2012
Sanford M. Cipinko >
(TYPE OR PRINT NAME} (SIGNATURE OF PLAINTIFF OR ATTORNEY)
Pi
P1001 [Rev January 1. 2007) COMPLAINT-Personal Injury, Property Page 30f 3
ones Oe ora aOR
ESSENTIAL FORMS jamage, Wrongrurmea Jackson, T'JadePLD-PI-001(1)
e.
x
SHORT TITLE:
Jackson v.
CASE NUMBER:
CCSF
One ey} CAUSE OF ACTION- Motor Vehicle
ATTACHMENT TO [{} Complaint {©} Cross-Complaint
(Use a separate cause of action form for each cause of action.)
Plaintiff (name): T' Jade Jackson
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): August 18, 2011
at (place!) Brannan street at 2nd Street in San Francisco, CA
Mv-2. DEFENDANTS
a. [QJ The defendants who operated a motor vehicle are (names):
David Fbarle,
Robert Rubeshaw
Ey Does 1 sto SQ
b. (Q] The defendants who employed the persons who operated a motor vehicle in the course of their employment
are(names):City and County of San Francisco,
David Ebarle,
Robert Rubeshaw
Ky Does 1 —s to. SQ ES
. EQ] The defendants who owned the moter vehicle which was operated with their permission are(names):
City and County of San Francisco,
David Ebarle, Robert Rubeshaw
(]) Does 1 = to SO
. GY The defendants who entrusted the motor vehicle are (names):
City and County of San Francisco,
David Ebarle, Robert Rubeshaw
Ey Does 1 = to SQ
e. [KJ The defendants who were the agents and employees of the other defendants and acted within the scope
of the agency were (names):
City and County of San Francisco,
David Ebarle, Robert Rubeshaw
Ey Does 1 Ss to SQ
f. (2) The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are
(2) listed in Attachment MV-2f [2] as follows:
() Does to
Page 4
Page 1 of 1
Form Aperoved for Optional Use Code of Civil Procedure § 425.12
CAUSE OF ACTION - Motor Vehicle
Jucicia) Council of California
PLO-PI-OD1(1) [Rav January 1, 2007]
Martin Deans
ESSENTIAL FORMS”
www.courtinfo.ca.gov
Jackson, T'JadeCM-010
Pa 9 armas
«Sanford M. Cipinko, Esf., SBN 88102
Law Offices of Sanford M. Cipinko
55 Francisco Street, Suite 403
San Francisco, CA 94133
revepHoneNo. (415) 693-9905 Faxno. (415) 693-9904
ATTORNEY FOR (Name).
SUPERIOR COURT OF CALIFORNIA, COUNTYOF San Francisco May Jt 2092
streetaporess 400 McAllister Street
HEALING ADDRESS CLERK OF THE.COURT
cimvanozpcooe:San Francisco, CA 94102 ey el .
BRANCH NAME: uo et
CASENAME: Jackson v. CCSF
ca unin CASE ar SHEET Complex Case Designation “hee 1 2 5 20 7 72
Unlimited Limited . - -
(Amount (Amount () Counter = (L) Joinder me G ~
demanded demanded is Filed with first appearance by defendant
exceeds $25,000) $25,000 or less) (Cal. Rules of Court, rule 3.402) DEPT.
Items 1-6 below must be completed (see instructions on page 2).
1. Check one box below for the case type that best describes this case:
Auto Tort Contract Provisionally Complex Civil Litigation
By Auto (22) Breach of contract/warranty (06) (Cai. Rutes of Court, rules 3.400-3.403)
Uninsured motorist (46) Rule 3.740 collections (09) Antitrust/Trade regulation (03)
Other collections (09) Construction defect (10)
Other P/PD/WD (Personal Injury/Property
Damage/Wrongful Death) Tort
Asbestos (04)
Insurance coverage (18) Mass tort (40)
Other contract (37) Securities litigation (28)
Environmental/Toxic tort (30)
Product liability (24) Rest Property insurance coverage claims arising from the
Medical malpractice (45) LQ} Eminent domain/Inverse above listed roreionall com i case
Other P/PDAWD (23) condemnation (14) p 'y comp!
Wrongful eviction (33) types (41)
Other real property (26) Enforcement of Judgment
(2) Enforcement of judgment (20)
Non-Pl/PD/WD (Other} Tort
Business tort/unfair business practice (07)
Civil rights (08) Unlawful Detainer
Defamation (13) Commercial (31) Miscellaneous Civil Complaint
Fraud (16) Residential (32) 4 RICO (27)
Intellectual property (19) Drugs (38) Other compiaint (not specified above) (42)
Professional negligence (25) Judicial Review Miscellaneous Civil Petition
Other non-PI/PDAWD tort (35) ‘Asset forfeiture (05) Partnership and corporate governance (21)
Employment Petition re: arbitration award (11) Other petition (not specified above) (43)
Wrongful termination (36) ‘Writ of mandate (02)
Other employment (15) Other judicial review (39)
2. Thiscase CJ is 1 is not complex under rule 3.400 of the California Rules of Court. If the case is complex, mark the
factors requiring exceptional judicial management:
a. Large number of separately represented parties d. Large number of witnesses
b €xtensive motion practice raising difficult or novel —_e. Coordination with related actions pending in one or more courts
issues that will be time-consuming to resolve in other counties, states, or countries, or in a federal court
c. (2) Substantial amount of documentary evidence f. Substantial postjudgment judicial supervision
Remedies sought (check aif that apply): a. [KX monetary b. nonmonetary; declaratory or injunctive relief c. [2] punitive
Number of causes of action pect One (motor vehicle)
Thiscase [Jis is not a Class action suit.
If there are any known related cases, file and serve a notice of related case. (You may use form CM-015,)
Date: May 14, 2012 a _—>
Sanfoxd_M—CiRjE Semrsams——————— ) _ORRTORC FPR ORATORY FORT
NOTICE
¢ Plaintiff must file this cover sheet with the first paper filed in the action or proceeding (except small claims cases or cases filed
under the Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.) Failure to file may result
in sanctions.
« File this cover sheet in addition to any cover sheet required by local court rule,
« If this case is complex under rule 3.400 et seq. of the California Rules of Court, you must serve a copy of this cover sheet on all
other parties to the action or proceeding.
« Unless this is a collections case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes only
Page 1 of
satin Deze CIVIL CASE COVER SHEET Cal, Rules of Cour, rules 2,20, 3.220, 3.400-3 403, 3 740,
in Dex Cai Slancards of Judicial Administration. ste. 3.10
wan courtnia,
ha Sa.gov
ATIAL FORMS Jackson, T'Jade
Dano
Form Adopted for Mandatory Use
Judicial Council of California
CW-O10 [Rev. July 7, 2007}