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PLD-PI-001
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
Roger Schweitzer, In Pro Per
PO Box 3191
Redondo Beach, CA 90277
TELEPHONE NO: (310)670-5844 FAX NO, (Options:
E-MAIL ADDRESS (Optional):
ATTORNEY FOR (Name): In Pro Per
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Orange
street aooress: 700 Civic Center Drive
MAILING ADDRESS:
ciryanpzecooe: Santa Ana, CA 90701
srancuname: Central Justice Center
PLAINTIFF: Roger Schweitzer, Trustee of the William and
Barbara Schweitzer Trust
DEFENDANT: Melanie Schweitzer, and
[7] poes1to 10
COMPLAINT—Personal Injury, Property Damage, Wrongful Death
AMENDED (Number):
Type (check aif that apply):
[7] MOTOR VEHICLE ¥_| OTHER (specify):
[J Property Damage Wrongful Death
Personal Injury ¥_] Other Damages (specify): theft
Jurisdiction (check all that apply):
ACTION IS A LIMITED CIVIL CASE
Amount demanded [__]} does not exceed $10,000
¥_| ACTION IS AN UNLIMITED CIVIL. CASE (exceeds $25,000)
{-] ACTION IS RECLASSIFIED by this amended complaint
from limited to unlimited
from unlimited to limited
[J exceeds $10,000, but does not exceed $25,000
FOR COURT USE ONLY
SUPERIOR ROURT OF FP CALIFORNIA
COUNTY OF ORANGE
CENTRAL Justice CENTER
MAY 92 2012
ALAN CARLSON, Clerk of the Cour:
C12
30-2012
00566133
1. Plaintiff (name or names): Roger Schweitzer, Trustee of the William and Barbara Schweitzer Trust
alleges causes of action against defendant (name or names):
Melanie Schweitzer
2. This pleading, including attachments and exhibits, consists of the following number of pages: 5
3. Each plaintiff named above is a competent adult
a. except plaintiff (name): Roger Schweitzer
(1) a corporation qualified to do business in California
(2) an unincorporated entity (describe):
(3) a public entity (describe):
(4) aminor [__] anadult
(b) [] other (specify):
(5) [v7] other (specify): Acting as Trustee of Family Trust
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
(b) other (specify):
(5) (7) other (specify):
(a) [for whom a guardian or conservator of the estate or a guardian ad litem has been appointed
(a) L__] for whom a guardian or conservator of the estate or a guardian ad litem has been appointed
Information about additional plaintiffs who are not competent adults is shown in Attachment 3.
Page 1 ofa
Fam Aperoved fot Gplenal Usa COMPLAINT—Personal Injury, Property Case of Givi Proce 3a 52
PLD-PH.001 {Rev. January 1, 2007] Damage, Wrongful DeathPLD-PI-001
SHORT TITLE:
Schweitzer v. Schweitzer
‘CASE NUMBER:
4, Plaintiff (name):
is doing businass under the fictitious name (specify):
and has complied with the fictitious business name laws.
5, Each defendant named above is a natural person
a. [__] except defendant (name):
6.
8.
(i) a business organization, form unknown
(2) (1) a corporation
(3) (-) an unincorporated entity (describe):
(4 a public entity (describe):
(5) [_] other (specify):
except defendant (name):
(1) [] a business organization, form unknown
(2) a corporation
(3) [) an unincorporated entity (describe):
(4) [__] a public entity (describe):
(5) other (specify):
c. [] except defendant (name):
(1) [__} a business organization, form unknown
(2) [7] acomoration
(3) [J an unincorporated entity (describe):
(4) [) a public entity (describe):
(8) CJ other (specify):
d. except defendant (name):
(1) a business organization, form unknown
(2) a corporation
(3) (7) an unincorporated entity (describe):
(4) [7] a public entity (describe):
(8) [] other (specify):
[1 Information about additional defendants who are not natural persons is contained in Attachment 5.
The true names of defendants sued as Doss are unknown to plaintiff.
a. [7] Doe defendants (specify Doe numbers): 1-5
b.
plaintiff.
were the agents or employees of other
named defendants and acted within the scope of that agency or employment,
¥_]| Doe defendants (specify Doe numbers). 6-10
are persons whose capacities are unknown to
Defendants who are joined under Cade of Civil Procedure section 382 are {namesy.
This court is the proper court because
a.
at least one defendant now resides in its jurisdictional area.
the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area.
other (specify):
*O
Plaintiff is required to comply with a claims statute, and
a. [_] has complied with applicable claims statutes, or
b. [1 is excused from complying because (specify):
b.
¢. [2] injury to person or damage to personal property occurred in its jurisdictional area.
d.
PLD-PI-001 [Rev. January 1, 2007]
COMPLAINT—Personal Injury, Property
Damage, Wrongful Death
Page 2 0f 3PLD-PI-001
SHORT TITLE:
CASE NUMBER:
Schweitzer v. Schweitzer
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):
[¥]
7
C3
CC
C4
“pans ®
14. Plaintiff ni
a CJ
6 CA
«LJ
4. [J]
e. (Z]}
f
9.
Motor Vehicle
General Negligence
intentional Tort
Products Liability
Premises Liability
Other (specify):
as suffered
wage loss
loss of use of property
hospital and medical expenses
general damage
property damage
loss of eaming capacity
. [7] other damage (specify):
Removed Plaintiff's property from residence
12. [__] The damages claimed for wrongful death and the relationships of plaintiff to the deceased are
listed in Attachment 12.
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) (4) compensatory damages
(2)
punitive damages
The al
mount of damages Is (in cases for personal injury or wrongful death, you must check (1):
(1)
according to proof
(2)
“Z| in the amount of $ 257,700
15. The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers):
Date: May 1, 2012
Roger Schw
eitzer
\LSAL
(TYPE. OR PRINT NAME) (SIGNATURE OF PLAINTIFF OR ATTORNEY}
PLD-PI-001 [Rev January 1, 2007) COMPLAINT—Personal Injury, Property
Damage, Wrongful Death
Page $of 3PLD-P1-001(3)
Sone TITLE:
CASE NUMBER
Schweitzer v. Schweitzer
First CAUSE OF ACTION—intentional Tort
(number)
ATTACHMENT TO LY] Complaint
Page 4
Cross - Complaint
(Use a separate cause of action form for each cause of action.)
IT-1, Plaintiff (name): Roger Schweitzer, Trustee of the William and Barbara Schweitzer Trust
alleges that defendant (name): Melanie Schweitzer
¥] Does | to 10
was the legal (proximate) cause of damages to plaintiff. By the following acts or omissions to act, defendant intentionally
caused the damage to plaintiff
on (date)through June 1, 2010
at (place)33632 Halyard Drive, Dana Point, CA
(description of reasons for liability):
Defendant destroyed and removed Plaintiff's property from residence
Fae Canal ee CAUSE OF ACTION-Intentional Tort
PLD-P1.001(3) [Rev. January 1, 2007}
Page tof 4
Code of Civil Procedura, § 426.42
wrew.courtiofo.ca,govPLD-P!-001(2)
SHORT TITLE: ‘CASE NUMBER
Schweitzer v. Schweitzer
Second CAUSE OF ACTION—General Negligence page 5
(number)
ATTACHMENT TO [4] Complaint ] Cross - Complaint
(Use a separate cause of action form for each cause of action.)
GN-1. Plaintiff (name): Roger Schweitzer, Trustee of the William and Barbara Schweitzer Trust
alleges that defendant (name): Melanie Schweitzer
[T Does 1 to 10
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): through June 1, 2010
at (place): 33632 Halyard Drive, Dana Point, CA
(description of reasons for liability):
Defendant allowed and caused destruction of property beyond normal wear and tear
Page 1 of 1
iced Osun alton CAUSE OF ACTION—General Negligence Canepa
PLO-P001(2) (Rev. January 1, 2007]
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PLD-PI-001 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): Roger Schweitzer, In Pro Per PO Box 3191 Redondo Beach, CA 90277 TELEPHONE NO: (310)670-5844 FAX NO, (Options: E-MAIL ADDRESS (Optional): ATTORNEY FOR (Name): In Pro Per SUPERIOR COURT OF CALIFORNIA, COUNTY OF Orange street aooress: 700 Civic Center Drive MAILING ADDRESS: ciryanpzecooe: Santa Ana, CA 90701 srancuname: Central Justice Center PLAINTIFF: Roger Schweitzer, Trustee of the William and Barbara Schweitzer Trust DEFENDANT: Melanie Schweitzer, and [7] poes1to 10 COMPLAINT—Personal Injury, Property Damage, Wrongful Death AMENDED (Number): Type (check aif that apply): [7] MOTOR VEHICLE ¥_| OTHER (specify): [J Property Damage Wrongful Death Personal Injury ¥_] Other Damages (specify): theft Jurisdiction (check all that apply): ACTION IS A LIMITED CIVIL CASE Amount demanded [__]} does not exceed $10,000 ¥_| ACTION IS AN UNLIMITED CIVIL. CASE (exceeds $25,000) {-] ACTION IS RECLASSIFIED by this amended complaint from limited to unlimited from unlimited to limited [J exceeds $10,000, but does not exceed $25,000 FOR COURT USE ONLY SUPERIOR ROURT OF FP CALIFORNIA COUNTY OF ORANGE CENTRAL Justice CENTER MAY 92 2012 ALAN CARLSON, Clerk of the Cour: C12 30-2012 00566133 1. Plaintiff (name or names): Roger Schweitzer, Trustee of the William and Barbara Schweitzer Trust alleges causes of action against defendant (name or names): Melanie Schweitzer 2. This pleading, including attachments and exhibits, consists of the following number of pages: 5 3. Each plaintiff named above is a competent adult a. except plaintiff (name): Roger Schweitzer (1) a corporation qualified to do business in California (2) an unincorporated entity (describe): (3) a public entity (describe): (4) aminor [__] anadult (b) [] other (specify): (5) [v7] other (specify): Acting as Trustee of Family Trust 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 (b) other (specify): (5) (7) other (specify): (a) [for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (a) L__] for whom a guardian or conservator of the estate or a guardian ad litem has been appointed Information about additional plaintiffs who are not competent adults is shown in Attachment 3. Page 1 ofa Fam Aperoved fot Gplenal Usa COMPLAINT—Personal Injury, Property Case of Givi Proce 3a 52 PLD-PH.001 {Rev. January 1, 2007] Damage, Wrongful DeathPLD-PI-001 SHORT TITLE: Schweitzer v. Schweitzer ‘CASE NUMBER: 4, Plaintiff (name): is doing businass under the fictitious name (specify): and has complied with the fictitious business name laws. 5, Each defendant named above is a natural person a. [__] except defendant (name): 6. 8. (i) a business organization, form unknown (2) (1) a corporation (3) (-) an unincorporated entity (describe): (4 a public entity (describe): (5) [_] other (specify): except defendant (name): (1) [] a business organization, form unknown (2) a corporation (3) [) an unincorporated entity (describe): (4) [__] a public entity (describe): (5) other (specify): c. [] except defendant (name): (1) [__} a business organization, form unknown (2) [7] acomoration (3) [J an unincorporated entity (describe): (4) [) a public entity (describe): (8) CJ other (specify): d. except defendant (name): (1) a business organization, form unknown (2) a corporation (3) (7) an unincorporated entity (describe): (4) [7] a public entity (describe): (8) [] other (specify): [1 Information about additional defendants who are not natural persons is contained in Attachment 5. The true names of defendants sued as Doss are unknown to plaintiff. a. [7] Doe defendants (specify Doe numbers): 1-5 b. plaintiff. were the agents or employees of other named defendants and acted within the scope of that agency or employment, ¥_]| Doe defendants (specify Doe numbers). 6-10 are persons whose capacities are unknown to Defendants who are joined under Cade of Civil Procedure section 382 are {namesy. This court is the proper court because a. at least one defendant now resides in its jurisdictional area. the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area. other (specify): *O Plaintiff is required to comply with a claims statute, and a. [_] has complied with applicable claims statutes, or b. [1 is excused from complying because (specify): b. ¢. [2] injury to person or damage to personal property occurred in its jurisdictional area. d. PLD-PI-001 [Rev. January 1, 2007] COMPLAINT—Personal Injury, Property Damage, Wrongful Death Page 2 0f 3PLD-PI-001 SHORT TITLE: CASE NUMBER: Schweitzer v. Schweitzer 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): [¥] 7 C3 CC C4 “pans ® 14. Plaintiff ni a CJ 6 CA «LJ 4. [J] e. (Z]} f 9. Motor Vehicle General Negligence intentional Tort Products Liability Premises Liability Other (specify): as suffered wage loss loss of use of property hospital and medical expenses general damage property damage loss of eaming capacity . [7] other damage (specify): Removed Plaintiff's property from residence 12. [__] The damages claimed for wrongful death and the relationships of plaintiff to the deceased are listed in Attachment 12. 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) (4) compensatory damages (2) punitive damages The al mount of damages Is (in cases for personal injury or wrongful death, you must check (1): (1) according to proof (2) “Z| in the amount of $ 257,700 15. The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers): Date: May 1, 2012 Roger Schw eitzer \LSAL (TYPE. OR PRINT NAME) (SIGNATURE OF PLAINTIFF OR ATTORNEY} PLD-PI-001 [Rev January 1, 2007) COMPLAINT—Personal Injury, Property Damage, Wrongful Death Page $of 3PLD-P1-001(3) Sone TITLE: CASE NUMBER Schweitzer v. Schweitzer First CAUSE OF ACTION—intentional Tort (number) ATTACHMENT TO LY] Complaint Page 4 Cross - Complaint (Use a separate cause of action form for each cause of action.) IT-1, Plaintiff (name): Roger Schweitzer, Trustee of the William and Barbara Schweitzer Trust alleges that defendant (name): Melanie Schweitzer ¥] Does | to 10 was the legal (proximate) cause of damages to plaintiff. By the following acts or omissions to act, defendant intentionally caused the damage to plaintiff on (date)through June 1, 2010 at (place)33632 Halyard Drive, Dana Point, CA (description of reasons for liability): Defendant destroyed and removed Plaintiff's property from residence Fae Canal ee CAUSE OF ACTION-Intentional Tort PLD-P1.001(3) [Rev. January 1, 2007} Page tof 4 Code of Civil Procedura, § 426.42 wrew.courtiofo.ca,govPLD-P!-001(2) SHORT TITLE: ‘CASE NUMBER Schweitzer v. Schweitzer Second CAUSE OF ACTION—General Negligence page 5 (number) ATTACHMENT TO [4] Complaint ] Cross - Complaint (Use a separate cause of action form for each cause of action.) GN-1. Plaintiff (name): Roger Schweitzer, Trustee of the William and Barbara Schweitzer Trust alleges that defendant (name): Melanie Schweitzer [T Does 1 to 10 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): through June 1, 2010 at (place): 33632 Halyard Drive, Dana Point, CA (description of reasons for liability): Defendant allowed and caused destruction of property beyond normal wear and tear Page 1 of 1 iced Osun alton CAUSE OF ACTION—General Negligence Canepa PLO-P001(2) (Rev. January 1, 2007]