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San Francisco Superior Courts
Information Technology Group
Document Scanning Lead Sheet
May-05-2008 2:58 pm
Case Number: CGC-08-474925
Filing Date: May-05-2008 2:51
Juke Box: 001 Image: 02112113
COMPLAINT
LUDMILA KISSELEVA VS. JORGE RAMIREZ GONZALEZ et al
001002112113
Instructions:
Please place this sheet on top of the document to be scanned.SUMMONS
(CITACION JUDICIAL)
NOTICE TO DEFENDANT:
(AVISO AL DEMANDADO):
JORGE RAMIREZ GONZALEZ, ELIZABETH JOHANNA
FORRANTE, JOHN ROBERT FERRANTZ, and
DOE ONE through DOE TEN
YOU ARE BEING SUED BY PLAINTIFF:
(LO ESTA DEMANDANDO EL DEMANDANTE):
LUDMILA KISSELEVA, also known as
LUDMILA KISSELEVA EGGLETON
You have 30 CALENDAR DAYS after this summons and legal papers are served on you to file a written response at tits court and have a
copy served on the plaintiff. A letter or phone call will not protect you. Your written response must be in proper legal form if you want the
court to hear your case. There may be a court form that you can use for your response. You can find these court forms and more
information at the California Courts Ontine Seff-Help Center (www.courtinfo.ca.goviselfhelp), your county law library, or the courthouse
nearest you. Hf you cannot pay the filing fee, ask the court clerk for a fee waiver form. If you do not file your response on time, you may
lose the.case by default, and your wages, money, and property may be taken without further warning from he court.
‘There are other legal requirements. You may want to call an attomey right away. If you do not know an attomey, you may want to call an
attorney referral service. If you cannot afford an attorney, you may be eligible for free legal services from a nonprofit legal services
program. You can locate these nonprofit groups at the California Legal Services Web site (www.lawhelpcalifornia.org), the California
Courts Online Self-Help Center (www.courtinfo.ca.gov/selfhelp), or by contacting your local court or county bar association.
Tiene 30 DIAS DE CALENDARIO después de que le entreguen esta citacién y papeles legales para presentar una respuesta por escrito
en esta corte y hacer que se entregue una copia al demandante. Una carta 0 una llamada telefénica no to protegen. Su respuesta por
en ef Centro de Ayuda de las Cortes de California,
en contacto con Ia corte o ef colegio de abogados focales.
The name and address of the court is:
(El nombre y direcci6n de la corte es): SUPERIOR COURT OF THE
STATE OF CALIFORNIA, CITY AND COUNTY OF SAN FRANCISCO, UNLIMITED CIVIL
JURISDICTION, 400 McAllister Street, Room 103, San Francisco, CA 94102-4512
The name, address, and telephone number of plaintiff's attorney, or plaintiff without an attomey, is:
(El nombre, la direccién y el némero de teléfono del abogado del demandante, o de! demandante que no tiene abogado, es):
HERBERT W. YANOWITZ, STATE BAR NO, 37300, 225 Bush Street, Sixth Floor,
San Francisco, CA 94104-4207, terephone. (a 32-1365
Gia ANE ‘
DATE ines
(Fecha) MAY 5 = 2008 7
(For proof of service of this summons, use Proof of Service of Summons (form POS-010).)
(Para prueba de entrega de esta citatién use el formulario Proof of Service of Summons, (POS-010)).
NOTICE TO THE PERSON SERVED: You are served
1. [] as an individual defendant.
2. (__] as the person sued under the fictitious name of (specify):
3, (2) onbehalt of (specify):
under. [] CCP 416.10 (corporation) (~] ccp 416.60 (minor)
s [1 CCP 416.20 (defunct corporation) [-] CCP 416.70 (conservatee)
{] CCP 416.40 (association or partnership) [__] CCP 416.90 (authorized person)
(1 other (specify):
4. [[_) by persona! delivery on (date): page tot 4
‘Cade of Civi Procedure §§ 412.20, 465
SUNCAOD [Rev denusry 1 2004) SUMMONS
4 Number of cause ot ~ ay oH oo declaratory or injunctive relief c punitive
5. This case [_] is [2X] isnot aclass action sult
6.
If there are any known related cases, file and serve a notice of related case. (Y,
Date: May 5, 2008 form CM-015,)
TYPE OR PRINT NAME)
m1
OF PARTY OR ATTORNEY FOR PARTY)
© Plaintiff must file this cover sheet with the first paper led in the actioi Or proceeding (except small claims cases o cases filed
under the Probate Code, Fami ly Code, or Welfare and Institutions Code). (Cal. Rules of Court, tule 3.220.) Failure to file may result
y
other parties to the action or edit
roc
* Unless this is a complex case, ver
sey Usa[TATE NES OR TARTS VaTHOUT AIT ORNEY tate Bu raat and adress)
HERBERT W. YANOWITZ, STATE BAR NO. 37300
225 Bush street, Sixth Floor
- may §~ 2008
Sor tne Cad 5 996221388 wor raxno. (415)362-1363
rk |
ATTORNEY TOR (Name) LUDMILA KISSELEVA, etc. N BAR c
SUPERIOR COURT OF CALIFORNIA couNTy oF SAN FRANCISCO BY:
Smacraooness, 400 McAllister Street, Room 103
mauincaoortss 400 McAllister Street, Room 103
ciryanozecoos San Francisco, CA 94102-4512
IAN NAME _
CASE NAME: LUDMILA KISSELEVA, etc. vs.
JORGE RAMIREZ GONZALEZ, et al.
CIVIL GASE COVER SHEET Complex Case Designation “CWC 0 3-4
(3) unlimited =] Limite J oO 74925
(Amount (Amount Counter Joinder - —
demanded demanded is Filed with first appearance by defendant | "°F
exceeds $25,000) —_ $25,000 or less)
Auto Tort ont Provisionally Compiex Civil Litigation
Xi} Auto (22) C_] Breach of contractwarranty (06) (Cal. Rules of Court, rules 3.400-3.403)
Uninsured motorist (46) {J Cottections (09) [_] Antitrust Trade raguiation (03)
Other PUPDIWD (Personal injury/Property || insurance coverage (18) [—] Construction defect (10)
Damage/rongful Death) Tort LL] other contract (37) L__} Mass tort (40)
Asbestos (04) Real Property -] Securities itigation (28)
Product liability (24) [7] Eminent domain/inverse Environmental/Toxic tort (30)
1} medical malpractice (45) condemnation (14) (_] insurance coverage claims arising from the
1 otmer PuPOWD (23) 11 wrongfut eviction (33) above listed provisionally complex case
Non-PUPDIWD (Other) Tort L._] other reat property (26) types (41)
Business tortlunfair business practice (07) Unfawful Detainer essnent of Judgment
Givil rights (08) {._.] Commercial (31) Enforcement of judgment (20)
| Defamation (13) C } Residential (32) eyneoe Civii Complaint
Fraud (16) C3 Drugs (38) RICO (27)
intelectual property (19) ‘Judicial Review J other complaint (not specified above) (42)
Professional negiigence (25) [_] Asset forfeiture (05) [i2sellansous Civ Petition
= {_] Partnership and corporate governance (21)
L._] other non-PuPDIWD tort (35) Petition re: arbitration award (11) (=
Em ment Writ of (02) C4 Other petition (not specified above) (43)
[__] Wrongful termination (36) [1] other judicial review (39)
L. _} Other employment (15)
2, Thiscase |_| is [XJ isnot complex under rule 3.400 of the Califoria Rules of Court. if the case is complex, mark the
factors requiring exceptional judicial management:
a. J Large number of separately represented parties d. Oo Large number of witnesses .
b. [] Extensive 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. [__] Substantial amount of documentary evidence f. 1 ‘Substantial postjudgment judicial supervision
3. Type of remedies sought (check ail that apply):
a. (-X] monetary b. [_] nonmonetary; declaratory or injunctive relief c. [_] punitive
4. Number of causes of action (specify): One
5. This case ] is CX] isnot aclass action suit.
6. If there are any known related cases, file and serve a notice of related case. (Ys
Date: May 5, 2008
[TYPE OR PRINT NAME) \TURE OF PARTY OR ATTORNEY FOR PARTY)
Ni E
© Plaintiff must file this cover sheet with the first paper filed in NO TICE 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 Califomia 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 complex case, this cover sheet will be used for statistical purposes only.
CIVIL CASE COVER SHEET = THOMSONCmrI DAU FB wWN |
Ww wWwWwkRwWwkwNYNNNNNNNNN YEE SP eee ees
DAARKDBHBFS SHA ADA AKRON HKH TCO HAADUN AWN TS
adds, D
HERBERT W. YANOWITZ
STATE BAR NO. 37300
225 Bush Street, Sixth Floor
San Francisco, CA 94104-4207
Telephone: (415) 362-1365
Fax: (415) 362-1363 OCT 3 - 2n08 - OMAN
Attorney for Plaintiffs DRPARTMENT219
SUPERIOR COURT OF THE STATE OF CALIFO! pe
CITY AND COUNTY OF SAN FRANCISCO ae seeUED
UNLIMITED CIVIL JURISDICTION
LUDMILA KISSELEVA, also known as GBC-08-474925
LUDMILA KISSELEVA EGGLETON,
COMPLAINT FOR
Plaintiff, PERSONAL INJURY
vs. (Auto)
JORGE RAMIREZ GONZALEZ,
ELIZABETH JOHANNA FORRANTE,
JOHN ROBERT FERRANTZ, and
DOE ONE through DOE TEN,
Defendants.
SSS SS SH SH SD
AS A CAUSE OF ACTION IN HER COMPLAINT AGAINST DEFENDANTS, AND
EACH OF THEM, FOR PERSONAL INJURY, PLAINTIFF ALLEGES:
1. Plaintiff is unaware of the true names and capacities, whether individual, corporate,
associate, or otherwise of the Defendants named herein as Doe One through Doe Ten, and, therefore,
sues the said Defendants by such fictitious names, and Plaintiff will ask leave to amend this complaint
to allege their true names and capacities when ascertained. Plaintiff is informed, believes, and upon
such information and belief alleges that each of the fictitiously named Defendants is in some manner
legally liable to Plaintiff on the matters alleged herein. Plaintiff is further informed, believes. and
upon such information and belief alleges that each of the named and fictitiously named Defendants
acted as the agent for each of the other named and fictitiously named Defendants and in doing the acts,
failing to do the acts, making the representations, and failing to make the disclosures involved herein
was acting within the course and scope of such employment and agency.
Mit
COMPLAINT FOR PERSONAL INJURY ~ PAGE 14%
2. On or about May 6 or May 7, 2006, Defendants Jorge Ramirez Gonzalez, Elizabeth
Johanna Forrante, and Doe One through Doe Five, and each of them, so negligently drove vehicles
owned by Defendants Jorge Ramirez Gonzalez, John Robert Ferrantz, and Doe Six through Doe Ten,
and each of them, as to strike the vehicle driven by Plaintiff and to proximately cause the injuries
hereinafter alleged.
3. As a direct and proximate result of the said conduct of Defendants, and each of them,
Plaintiff suffered physical injuries and emotional distress in an amount in excess of the jurisdictional
limitations of this Court which will be established in accordance with proof at the time of trial.
4. Asa further, direct, and proximate result of the said conduct of Defendants, and each
of them, Plaintiff was required to and has incurred expenses for medical and other related services in
an amount which will be established in accordance with proof at the time of trial.
5. As a further, direct, and proximate result of the said conduct of Defendants, and each
of them, Plaintiff has been damaged through loss of earnings and earning capacity in an amount that
will be established in accordance with proof at the time of trial.
6. Plaintiff prays for the award of interest in accordance with law.
WHEREFORE, Plaintiff prays for judgment against Defendants, and each of them, for
general damages in excess of the jurisdictional limitations of this Court, for medical and incidental
damages, and for loss of earnings and earning capacity, in accordance with proof; for interest as
provided by law; for costs of suit; and for such other and further relief as to the Court may seem just
and proper.
Dated: May 5, 2008
COMPLAINT FOR PERSONAL INJURY — PAGE 2
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DOME San Francisco Superior Courts Information Technology Group Document Scanning Lead Sheet May-05-2008 2:58 pm Case Number: CGC-08-474925 Filing Date: May-05-2008 2:51 Juke Box: 001 Image: 02112113 COMPLAINT LUDMILA KISSELEVA VS. JORGE RAMIREZ GONZALEZ et al 001002112113 Instructions: Please place this sheet on top of the document to be scanned.SUMMONS (CITACION JUDICIAL) NOTICE TO DEFENDANT: (AVISO AL DEMANDADO): JORGE RAMIREZ GONZALEZ, ELIZABETH JOHANNA FORRANTE, JOHN ROBERT FERRANTZ, and DOE ONE through DOE TEN YOU ARE BEING SUED BY PLAINTIFF: (LO ESTA DEMANDANDO EL DEMANDANTE): LUDMILA KISSELEVA, also known as LUDMILA KISSELEVA EGGLETON You have 30 CALENDAR DAYS after this summons and legal papers are served on you to file a written response at tits court and have a copy served on the plaintiff. A letter or phone call will not protect you. Your written response must be in proper legal form if you want the court to hear your case. There may be a court form that you can use for your response. You can find these court forms and more information at the California Courts Ontine Seff-Help Center (www.courtinfo.ca.goviselfhelp), your county law library, or the courthouse nearest you. Hf you cannot pay the filing fee, ask the court clerk for a fee waiver form. If you do not file your response on time, you may lose the.case by default, and your wages, money, and property may be taken without further warning from he court. ‘There are other legal requirements. You may want to call an attomey right away. If you do not know an attomey, you may want to call an attorney referral service. If you cannot afford an attorney, you may be eligible for free legal services from a nonprofit legal services program. You can locate these nonprofit groups at the California Legal Services Web site (www.lawhelpcalifornia.org), the California Courts Online Self-Help Center (www.courtinfo.ca.gov/selfhelp), or by contacting your local court or county bar association. Tiene 30 DIAS DE CALENDARIO después de que le entreguen esta citacién y papeles legales para presentar una respuesta por escrito en esta corte y hacer que se entregue una copia al demandante. Una carta 0 una llamada telefénica no to protegen. Su respuesta por en ef Centro de Ayuda de las Cortes de California, en contacto con Ia corte o ef colegio de abogados focales. The name and address of the court is: (El nombre y direcci6n de la corte es): SUPERIOR COURT OF THE STATE OF CALIFORNIA, CITY AND COUNTY OF SAN FRANCISCO, UNLIMITED CIVIL JURISDICTION, 400 McAllister Street, Room 103, San Francisco, CA 94102-4512 The name, address, and telephone number of plaintiff's attorney, or plaintiff without an attomey, is: (El nombre, la direccién y el némero de teléfono del abogado del demandante, o de! demandante que no tiene abogado, es): HERBERT W. YANOWITZ, STATE BAR NO, 37300, 225 Bush Street, Sixth Floor, San Francisco, CA 94104-4207, terephone. (a 32-1365 Gia ANE ‘ DATE ines (Fecha) MAY 5 = 2008 7 (For proof of service of this summons, use Proof of Service of Summons (form POS-010).) (Para prueba de entrega de esta citatién use el formulario Proof of Service of Summons, (POS-010)). NOTICE TO THE PERSON SERVED: You are served 1. [] as an individual defendant. 2. (__] as the person sued under the fictitious name of (specify): 3, (2) onbehalt of (specify): under. [] CCP 416.10 (corporation) (~] ccp 416.60 (minor) s [1 CCP 416.20 (defunct corporation) [-] CCP 416.70 (conservatee) {] CCP 416.40 (association or partnership) [__] CCP 416.90 (authorized person) (1 other (specify): 4. [[_) by persona! delivery on (date): page tot 4 ‘Cade of Civi Procedure §§ 412.20, 465 SUNCAOD [Rev denusry 1 2004) SUMMONS 4 Number of cause ot ~ ay oH oo declaratory or injunctive relief c punitive 5. This case [_] is [2X] isnot aclass action sult 6. If there are any known related cases, file and serve a notice of related case. (Y, Date: May 5, 2008 form CM-015,) TYPE OR PRINT NAME) m1 OF PARTY OR ATTORNEY FOR PARTY) © Plaintiff must file this cover sheet with the first paper led in the actioi Or proceeding (except small claims cases o cases filed under the Probate Code, Fami ly Code, or Welfare and Institutions Code). (Cal. Rules of Court, tule 3.220.) Failure to file may result y other parties to the action or edit roc * Unless this is a complex case, ver sey Usa[TATE NES OR TARTS VaTHOUT AIT ORNEY tate Bu raat and adress) HERBERT W. YANOWITZ, STATE BAR NO. 37300 225 Bush street, Sixth Floor - may §~ 2008 Sor tne Cad 5 996221388 wor raxno. (415)362-1363 rk | ATTORNEY TOR (Name) LUDMILA KISSELEVA, etc. N BAR c SUPERIOR COURT OF CALIFORNIA couNTy oF SAN FRANCISCO BY: Smacraooness, 400 McAllister Street, Room 103 mauincaoortss 400 McAllister Street, Room 103 ciryanozecoos San Francisco, CA 94102-4512 IAN NAME _ CASE NAME: LUDMILA KISSELEVA, etc. vs. JORGE RAMIREZ GONZALEZ, et al. CIVIL GASE COVER SHEET Complex Case Designation “CWC 0 3-4 (3) unlimited =] Limite J oO 74925 (Amount (Amount Counter Joinder - — demanded demanded is Filed with first appearance by defendant | "°F exceeds $25,000) —_ $25,000 or less) Auto Tort ont Provisionally Compiex Civil Litigation Xi} Auto (22) C_] Breach of contractwarranty (06) (Cal. Rules of Court, rules 3.400-3.403) Uninsured motorist (46) {J Cottections (09) [_] Antitrust Trade raguiation (03) Other PUPDIWD (Personal injury/Property || insurance coverage (18) [—] Construction defect (10) Damage/rongful Death) Tort LL] other contract (37) L__} Mass tort (40) Asbestos (04) Real Property -] Securities itigation (28) Product liability (24) [7] Eminent domain/inverse Environmental/Toxic tort (30) 1} medical malpractice (45) condemnation (14) (_] insurance coverage claims arising from the 1 otmer PuPOWD (23) 11 wrongfut eviction (33) above listed provisionally complex case Non-PUPDIWD (Other) Tort L._] other reat property (26) types (41) Business tortlunfair business practice (07) Unfawful Detainer essnent of Judgment Givil rights (08) {._.] Commercial (31) Enforcement of judgment (20) | Defamation (13) C } Residential (32) eyneoe Civii Complaint Fraud (16) C3 Drugs (38) RICO (27) intelectual property (19) ‘Judicial Review J other complaint (not specified above) (42) Professional negiigence (25) [_] Asset forfeiture (05) [i2sellansous Civ Petition = {_] Partnership and corporate governance (21) L._] other non-PuPDIWD tort (35) Petition re: arbitration award (11) (= Em ment Writ of (02) C4 Other petition (not specified above) (43) [__] Wrongful termination (36) [1] other judicial review (39) L. _} Other employment (15) 2, Thiscase |_| is [XJ isnot complex under rule 3.400 of the Califoria Rules of Court. if the case is complex, mark the factors requiring exceptional judicial management: a. J Large number of separately represented parties d. Oo Large number of witnesses . b. [] Extensive 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. [__] Substantial amount of documentary evidence f. 1 ‘Substantial postjudgment judicial supervision 3. Type of remedies sought (check ail that apply): a. (-X] monetary b. [_] nonmonetary; declaratory or injunctive relief c. [_] punitive 4. Number of causes of action (specify): One 5. This case ] is CX] isnot aclass action suit. 6. If there are any known related cases, file and serve a notice of related case. (Ys Date: May 5, 2008 [TYPE OR PRINT NAME) \TURE OF PARTY OR ATTORNEY FOR PARTY) Ni E © Plaintiff must file this cover sheet with the first paper filed in NO TICE 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 Califomia 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 complex case, this cover sheet will be used for statistical purposes only. CIVIL CASE COVER SHEET = THOMSONCmrI DAU FB wWN | Ww wWwWwkRwWwkwNYNNNNNNNNN YEE SP eee ees DAARKDBHBFS SHA ADA AKRON HKH TCO HAADUN AWN TS adds, D HERBERT W. YANOWITZ STATE BAR NO. 37300 225 Bush Street, Sixth Floor San Francisco, CA 94104-4207 Telephone: (415) 362-1365 Fax: (415) 362-1363 OCT 3 - 2n08 - OMAN Attorney for Plaintiffs DRPARTMENT219 SUPERIOR COURT OF THE STATE OF CALIFO! pe CITY AND COUNTY OF SAN FRANCISCO ae seeUED UNLIMITED CIVIL JURISDICTION LUDMILA KISSELEVA, also known as GBC-08-474925 LUDMILA KISSELEVA EGGLETON, COMPLAINT FOR Plaintiff, PERSONAL INJURY vs. (Auto) JORGE RAMIREZ GONZALEZ, ELIZABETH JOHANNA FORRANTE, JOHN ROBERT FERRANTZ, and DOE ONE through DOE TEN, Defendants. SSS SS SH SH SD AS A CAUSE OF ACTION IN HER COMPLAINT AGAINST DEFENDANTS, AND EACH OF THEM, FOR PERSONAL INJURY, PLAINTIFF ALLEGES: 1. Plaintiff is unaware of the true names and capacities, whether individual, corporate, associate, or otherwise of the Defendants named herein as Doe One through Doe Ten, and, therefore, sues the said Defendants by such fictitious names, and Plaintiff will ask leave to amend this complaint to allege their true names and capacities when ascertained. Plaintiff is informed, believes, and upon such information and belief alleges that each of the fictitiously named Defendants is in some manner legally liable to Plaintiff on the matters alleged herein. Plaintiff is further informed, believes. and upon such information and belief alleges that each of the named and fictitiously named Defendants acted as the agent for each of the other named and fictitiously named Defendants and in doing the acts, failing to do the acts, making the representations, and failing to make the disclosures involved herein was acting within the course and scope of such employment and agency. Mit COMPLAINT FOR PERSONAL INJURY ~ PAGE 14% 2. On or about May 6 or May 7, 2006, Defendants Jorge Ramirez Gonzalez, Elizabeth Johanna Forrante, and Doe One through Doe Five, and each of them, so negligently drove vehicles owned by Defendants Jorge Ramirez Gonzalez, John Robert Ferrantz, and Doe Six through Doe Ten, and each of them, as to strike the vehicle driven by Plaintiff and to proximately cause the injuries hereinafter alleged. 3. As a direct and proximate result of the said conduct of Defendants, and each of them, Plaintiff suffered physical injuries and emotional distress in an amount in excess of the jurisdictional limitations of this Court which will be established in accordance with proof at the time of trial. 4. Asa further, direct, and proximate result of the said conduct of Defendants, and each of them, Plaintiff was required to and has incurred expenses for medical and other related services in an amount which will be established in accordance with proof at the time of trial. 5. As a further, direct, and proximate result of the said conduct of Defendants, and each of them, Plaintiff has been damaged through loss of earnings and earning capacity in an amount that will be established in accordance with proof at the time of trial. 6. Plaintiff prays for the award of interest in accordance with law. WHEREFORE, Plaintiff prays for judgment against Defendants, and each of them, for general damages in excess of the jurisdictional limitations of this Court, for medical and incidental damages, and for loss of earnings and earning capacity, in accordance with proof; for interest as provided by law; for costs of suit; and for such other and further relief as to the Court may seem just and proper. Dated: May 5, 2008 COMPLAINT FOR PERSONAL INJURY — PAGE 2