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RIOR COURT
RIOR COURT
RECEIVED FOR SCANNIN
G PLD-PI-001
| ATTORNEY OR PARTY WITHOUT ATTORNEY (Né fo, Sato Bar nambor and watrosay
Jason G. Eisenberg (SBN# 307084)
Eisenberg Law Group PC JAN 1 1 2023
23801 Calabasas Road, Suite 2030
Calabasas, CA 91302
FOR COURT USE ONLY
TELEPHONE NO: 818-591-8058 FAX NO. (Optione: 818-591-8040
E-MAIL ADDRESS (Optional): office@gcelaw.com
ATTORNEY FOR (Name): PLAINTIFFS
SUPERIOR COURT OF CALIFORNIA, COUNTY OF VENTURA
‘STREET ADDRESS: 800 S. Victoria Avenue
‘MAILING ADDRESS:
icity AND Zip Cops: Ventura, CA 93009
BRANCH NAME: Ventura - Hall of Justice
PLAINTIFF: Jacqueline Santana and Tyler Wright
DEFENDANT: Connor James Reiman; Shelly Reiman; and DOES 1 to 25, inclusive
{J Does 1 To
COMPLAINT—Personal Injury, Property Damage, Wrongful Death CASE NUMBER:
(AMENDED (Number):
Type (check all that apply):
{3} MOTOR VEHICLE (GZ) OTHER (specify): DEMAND FOR JURY TRIAL
(5<] Property Damage [__] Wrongful Death
[3c] Personal Injury _["_] Other Damages (specify):
Jurisdiction (check all that apply):
I[__] 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
[1 from unlimited to limited
1. Plaintiff (name or names): Jacqueline Santana and Tyler Wright
alleges causes of action against defendant (name or names):
Connor James Reiman; Shelly Reiman; and DOES 1 to 25, Indusive
2. This pleading, including attachments and exhibits, consists of the following number of pages: 6
3. Each plaintiff named above is a competent adult
a. [) except plaintiff (name):
(1) ) a corporation qualified to do business in California
(2) [J an unincorporated entity (describe):
HG (3) LJ a public entity (describe):
(4)[) aminor = [[] an adult
(a) (-) for whom a guardian or conservator of the estate or a guardian ad litem has been appointed
(b) () other (specity):
(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) (2) aminor ~([_) an adult
(a) [_] for whom a guardian or conservator of the estate or a guardian ad litem has been appointed
(b) [J other (specify):
(5) [) other (specify):
[[) Information about additional plaintiffs who are not competent adults is shown in Attachment 3.
Page 1of3
Fe
oe eee. een tse COMPLAINT—Personal Injury, Property te ON oer cages
PLO-PI-001 [Rev. January 1, 2007) Damage, Wrongful DeathPLD-PI-001
SHORT TITLE: ‘CASE NUMBER:
Santana v. Reiman
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. [__] except defendant (name): c. [_] except defendant (name):
(1) [) a business organization, form unknown (1) [_) a business organization, form unknown
(2) [J a corporation (2) [] a corporation
(3) [-_] an unincorporated entity (describe): (3) [J an unincorporated entity (describe):
(4) (_] a public entity (describe): (4) [] a public entity (describe):
(5) (_] other (specify): (5) [-_] other (specify):
b. [__] except defendant (name): d. [[_] except defendant (name):
(1) [] a business organization, form unknown (1) [] a business organization, form unknown
(2) [] a corporation (2) (J a corporation
(3) [] an unincorporated entity (describe): (3) [J an unincorporated entity (describe):
(4) (_] a public entity (describe): (4) [_] a public entity (describe):
(5) [__] other (specify): (5) [-] other (specify):
[1 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): 1 to 25 were the agents or employees of other
named defendants and acted within the scope of that agency or employment.
b. [3c] Doe defendants (specify Doe numbers): 1 to 25 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. (__] atleast 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. [<1 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 DeathPLD-P1-001
SHORT TITLE: CASE NUMBER
Santana v. Reiman
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. [4c] Motor Vehicle
b. [3] General Negligence
c. [__] Intentional Tort
d. [__] Products Liability
e. [__] Premises Liability
f.
. [_] Other (specify):
1
. Plaintiff has suffered
a. [5] wage loss
b. [5] loss of use of property
c. [3%] hospital and medical expenses
d. [3<] general damage
e. [5¢] property damage
f. Gq 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) [3¢] compensatory damages
(2) [__] punitive damages
The amount of damages is (in cases for personal injury or wrongful death, you must check (1)):
(1) [<] according to proof
(2) [_] in the amount of: $
15. [__] The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers):
Date: January 10, 2023
Jason G. Eisenberg > Gascon Coaenberg
(TYPE OR PRINT NAME) VU (SIGNATURE OF PLAINTIFF OR ATTORNEY)
PLD-PL-001 Rev January 1, 2007} COMPLAINT—Personal Injury, Property Page 3of3
Damage, Wrongful DeathPLD-PI-001(1)
SHORT TITLE: CASE NUMBER:
SANTANA v. REIMAN
ONE (1) 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): JACQUELINE SANTANA and TYLER WRIGHT
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): Jan 29, 2021
at (place):
On or about S. Victoria Avenue, at or about Webster St., in the City of Ventura, County of Ventura, State of California 93009
MV- 2. DEFENDANTS
a. [3] The defendants who operated a motor vehicle are (names):
Connor James Reiman and DOES 1 to 10
Does to
b. Ga The defendants who employed the persons who operated a motor vehicle in the course of their employment are
(names):
Shelly Reiman and DOES 11 to 20
[-) Does to
c. [5€] The defendants who owned the motor vehicle which was operated with their permission are (names):
Shelly Reiman and DOES 11 to 20
Does to
d. [4] The defendants who entrusted the motor vehicle are (names):
Shelly Reiman and DOES 11 to 20
Does to
e. Gd The defendants who were the agents and employees of the other defendants and acted within the scope of the
agency were (names):
Connor James Reiman; Shelly Reiman; and DOES 1 to 25
Does to
f. [(_] The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are
(1 listed in Attachment MV-2f [__] as follows:
Does to
Page4
Page tof
Form Approved for Optiona, Uso Code of Givi Procedure 425.12
radical ee eer CAUSE OF ACTION—Motor Vehicle oe ri ae courts oa ‘gov
PLD-PI-001(1) (Rev. January 1, 2007]PLD-PI-001(2)
SHORT TITLE: CASE NUMBER
Santana v. Reiman
TWO (2) CAUSE OF ACTION—General Negligence Page 5
(number)
ATTACHMENT TO [x] Complaint [“_] Cross - Complaint
(Use a separate cause of action form for each cause of action.)
GN-1. Plaintiff (name): Jacqueline Santana and Tyler Wright
alleges that defendant (name): Shelly Reiman; Connor James Reiman; and DOES 1 to 25, Inclusive
Does to
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): January 29, 2021
at (place): On or about S. Victoria Avenue, at or about Webster St, city of Ventura, County of Ventura State of California
(description of reasons for liability):
Defendants, Connor James Reiman and DOES 1 to 10, Inclusive and each of them, failed to exercise due care in the
management, operation and use of their vehicle and as a result thereof struck the plaintiffs’ vehicle which caused serious
injuries and damages to the plaintiffs in an amount to be proven at the time of trial.
Defendants Shelly Reiman and DOES 11 - 25, Inclusive and each of them, were the owners of the vehicles involved in the
subject accident, they negligently entrusted, allowed, and permitted Connor James Reiman to use their vehicle
even though they knew or should have known that he did not possess the requisite skill, care, control, training,
knowledge and management to operate a motor vehicle and did not possess the requisite skill, care, control, training,
knowledge and management to operate a motor vehicle on the public streets of the County of Ventura, and knew that he
would and could endanger the health and well being of persons on the street and in vehicles in the area where he operated
their vehicle.
As a result of the negligence of the defendants and each of them, the plaintiffs were injured in his health and well being
all in an amount that will be proven at the time of trial.
Page 1 of1
Form Approved for Optional Use i Code of Civil Procedure 425.12
“Judiezal Council of Calfomia CAUSE OF ACTION—General Negligence wor courts.cb gov
PLO-PI-001(2) [Rev. January 1, 2007]SHORT TITLE: Santana v. Reiman CASE NUMBE-X:
o
a
27
DEMAND FOR JURY TRIAL
PLAINTIFFS HEREBY DEMANDS A TRIAL BY JURY ON ALL CLAIMS AND CAUSES OF
ACTION HEREIN.
(Required for verified pleading) The items on this page stated on information and belief are (specify item numbers, not line
numbers):
This page may be used with any Judicial Council form or any other paper filed with the court.
Page
6
Form Approved by the ADDITIONAL PAGE
Judictal Council of California Attach to Judicial Council Form or Other Court Paper
MC-020 [New January 1, 1987)
‘CRC 201, 501
Preview
RIOR COURT RIOR COURT RECEIVED FOR SCANNIN G PLD-PI-001 | ATTORNEY OR PARTY WITHOUT ATTORNEY (Né fo, Sato Bar nambor and watrosay Jason G. Eisenberg (SBN# 307084) Eisenberg Law Group PC JAN 1 1 2023 23801 Calabasas Road, Suite 2030 Calabasas, CA 91302 FOR COURT USE ONLY TELEPHONE NO: 818-591-8058 FAX NO. (Optione: 818-591-8040 E-MAIL ADDRESS (Optional): office@gcelaw.com ATTORNEY FOR (Name): PLAINTIFFS SUPERIOR COURT OF CALIFORNIA, COUNTY OF VENTURA ‘STREET ADDRESS: 800 S. Victoria Avenue ‘MAILING ADDRESS: icity AND Zip Cops: Ventura, CA 93009 BRANCH NAME: Ventura - Hall of Justice PLAINTIFF: Jacqueline Santana and Tyler Wright DEFENDANT: Connor James Reiman; Shelly Reiman; and DOES 1 to 25, inclusive {J Does 1 To COMPLAINT—Personal Injury, Property Damage, Wrongful Death CASE NUMBER: (AMENDED (Number): Type (check all that apply): {3} MOTOR VEHICLE (GZ) OTHER (specify): DEMAND FOR JURY TRIAL (5<] Property Damage [__] Wrongful Death [3c] Personal Injury _["_] Other Damages (specify): Jurisdiction (check all that apply): I[__] 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 [1 from unlimited to limited 1. Plaintiff (name or names): Jacqueline Santana and Tyler Wright alleges causes of action against defendant (name or names): Connor James Reiman; Shelly Reiman; and DOES 1 to 25, Indusive 2. This pleading, including attachments and exhibits, consists of the following number of pages: 6 3. Each plaintiff named above is a competent adult a. [) except plaintiff (name): (1) ) a corporation qualified to do business in California (2) [J an unincorporated entity (describe): HG (3) LJ a public entity (describe): (4)[) aminor = [[] an adult (a) (-) for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b) () other (specity): (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) (2) aminor ~([_) an adult (a) [_] for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b) [J other (specify): (5) [) other (specify): [[) Information about additional plaintiffs who are not competent adults is shown in Attachment 3. Page 1of3 Fe oe eee. een tse COMPLAINT—Personal Injury, Property te ON oer cages PLO-PI-001 [Rev. January 1, 2007) Damage, Wrongful DeathPLD-PI-001 SHORT TITLE: ‘CASE NUMBER: Santana v. Reiman 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. [__] except defendant (name): c. [_] except defendant (name): (1) [) a business organization, form unknown (1) [_) a business organization, form unknown (2) [J a corporation (2) [] a corporation (3) [-_] an unincorporated entity (describe): (3) [J an unincorporated entity (describe): (4) (_] a public entity (describe): (4) [] a public entity (describe): (5) (_] other (specify): (5) [-_] other (specify): b. [__] except defendant (name): d. [[_] except defendant (name): (1) [] a business organization, form unknown (1) [] a business organization, form unknown (2) [] a corporation (2) (J a corporation (3) [] an unincorporated entity (describe): (3) [J an unincorporated entity (describe): (4) (_] a public entity (describe): (4) [_] a public entity (describe): (5) [__] other (specify): (5) [-] other (specify): [1 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): 1 to 25 were the agents or employees of other named defendants and acted within the scope of that agency or employment. b. [3c] Doe defendants (specify Doe numbers): 1 to 25 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. (__] atleast 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. [<1 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 DeathPLD-P1-001 SHORT TITLE: CASE NUMBER Santana v. Reiman 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. [4c] Motor Vehicle b. [3] General Negligence c. [__] Intentional Tort d. [__] Products Liability e. [__] Premises Liability f. . [_] Other (specify): 1 . Plaintiff has suffered a. [5] wage loss b. [5] loss of use of property c. [3%] hospital and medical expenses d. [3<] general damage e. [5¢] property damage f. Gq 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) [3¢] compensatory damages (2) [__] punitive damages The amount of damages is (in cases for personal injury or wrongful death, you must check (1)): (1) [<] according to proof (2) [_] in the amount of: $ 15. [__] The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers): Date: January 10, 2023 Jason G. Eisenberg > Gascon Coaenberg (TYPE OR PRINT NAME) VU (SIGNATURE OF PLAINTIFF OR ATTORNEY) PLD-PL-001 Rev January 1, 2007} COMPLAINT—Personal Injury, Property Page 3of3 Damage, Wrongful DeathPLD-PI-001(1) SHORT TITLE: CASE NUMBER: SANTANA v. REIMAN ONE (1) 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): JACQUELINE SANTANA and TYLER WRIGHT 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): Jan 29, 2021 at (place): On or about S. Victoria Avenue, at or about Webster St., in the City of Ventura, County of Ventura, State of California 93009 MV- 2. DEFENDANTS a. [3] The defendants who operated a motor vehicle are (names): Connor James Reiman and DOES 1 to 10 Does to b. Ga The defendants who employed the persons who operated a motor vehicle in the course of their employment are (names): Shelly Reiman and DOES 11 to 20 [-) Does to c. [5€] The defendants who owned the motor vehicle which was operated with their permission are (names): Shelly Reiman and DOES 11 to 20 Does to d. [4] The defendants who entrusted the motor vehicle are (names): Shelly Reiman and DOES 11 to 20 Does to e. Gd The defendants who were the agents and employees of the other defendants and acted within the scope of the agency were (names): Connor James Reiman; Shelly Reiman; and DOES 1 to 25 Does to f. [(_] The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are (1 listed in Attachment MV-2f [__] as follows: Does to Page4 Page tof Form Approved for Optiona, Uso Code of Givi Procedure 425.12 radical ee eer CAUSE OF ACTION—Motor Vehicle oe ri ae courts oa ‘gov PLD-PI-001(1) (Rev. January 1, 2007]PLD-PI-001(2) SHORT TITLE: CASE NUMBER Santana v. Reiman TWO (2) CAUSE OF ACTION—General Negligence Page 5 (number) ATTACHMENT TO [x] Complaint [“_] Cross - Complaint (Use a separate cause of action form for each cause of action.) GN-1. Plaintiff (name): Jacqueline Santana and Tyler Wright alleges that defendant (name): Shelly Reiman; Connor James Reiman; and DOES 1 to 25, Inclusive Does to 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): January 29, 2021 at (place): On or about S. Victoria Avenue, at or about Webster St, city of Ventura, County of Ventura State of California (description of reasons for liability): Defendants, Connor James Reiman and DOES 1 to 10, Inclusive and each of them, failed to exercise due care in the management, operation and use of their vehicle and as a result thereof struck the plaintiffs’ vehicle which caused serious injuries and damages to the plaintiffs in an amount to be proven at the time of trial. Defendants Shelly Reiman and DOES 11 - 25, Inclusive and each of them, were the owners of the vehicles involved in the subject accident, they negligently entrusted, allowed, and permitted Connor James Reiman to use their vehicle even though they knew or should have known that he did not possess the requisite skill, care, control, training, knowledge and management to operate a motor vehicle and did not possess the requisite skill, care, control, training, knowledge and management to operate a motor vehicle on the public streets of the County of Ventura, and knew that he would and could endanger the health and well being of persons on the street and in vehicles in the area where he operated their vehicle. As a result of the negligence of the defendants and each of them, the plaintiffs were injured in his health and well being all in an amount that will be proven at the time of trial. Page 1 of1 Form Approved for Optional Use i Code of Civil Procedure 425.12 “Judiezal Council of Calfomia CAUSE OF ACTION—General Negligence wor courts.cb gov PLO-PI-001(2) [Rev. January 1, 2007]SHORT TITLE: Santana v. Reiman CASE NUMBE-X: o a 27 DEMAND FOR JURY TRIAL PLAINTIFFS HEREBY DEMANDS A TRIAL BY JURY ON ALL CLAIMS AND CAUSES OF ACTION HEREIN. (Required for verified pleading) The items on this page stated on information and belief are (specify item numbers, not line numbers): This page may be used with any Judicial Council form or any other paper filed with the court. Page 6 Form Approved by the ADDITIONAL PAGE Judictal Council of California Attach to Judicial Council Form or Other Court Paper MC-020 [New January 1, 1987) ‘CRC 201, 501