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PLD-PI-001
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Brian L. Larsen 158252
Law Offices of Brian L. Larsen
530 Jackson Street, 2nd Floor
San Francisco, CA 94133
TELEPHONE NO.: (415) 398-5000 FAX NO.(Optional): (415) 398-5080
E-MAIL ADDRESS (Optional): brian@brianlarsenlaw.com
ATTORNEY FOR (Name): Plaintiff
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Alameda
STREET ADDRESS: 1225 Fallon Street
MAILING ADDRESS:
CITY AND ZIP CODE: Oakland, CA 94612
BRANCH NAME:
PLAINTIFF: Gamela Hassan
DEFENDANT: Yan Kwong Lee, Chiung Kuang Lee, and DOES 1 to 10.
‰ DOES 1 TO
COMPLAINT-Personal Injury, Property Damage, Wrongful Death
‰ AMENDED (Number):
Type (check all that apply):
‰
X MOTOR VEHICLE ‰ OTHER (specify):
‰
X 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): Gamela Hassan
alleges causes of action against defendant (name or names): Yan Kwong Lee, Chiung Kuang Lee, and DOES 1 to 10.
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 Hassan, Gamela
PLD-PI-001
SHORT TITLE: CASE NUMBER:
Hassan v. Lee, et al.
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) ‰ 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):
b. ‰ except defendant (name): d. ‰ except defendant (name):
(1) ‰ a business organization, form unknown (1) ‰ a business organization, form unknown
(2) ‰ 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 Doe defendants (specify Doe numbers): 1 to 5 were the agents or employees of other
named defendants and acted within the scope of that agency or employment.
b. ‰ X Doe defendants (specify Doe numbers): 6 to 10 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 Hassan, Gamela
PLD-PI-001
SHORT TITLE: CASE NUMBER:
Hassan v. Lee, et al.
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. ‰ X loss of use of property
c. ‰ X hospital and medical expenses
d. ‰ X general damage
e. ‰ X 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):
MV-1; MV-2
6/16/2023
Date:
Brian L. Larsen
(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
Hassan, Gamela
PLD-PI-001(1)
SHORT TITLE: CASE NUMBER:
Hassan v. Lee, et al.
FIRST (number) CAUSE OF ACTION- Motor Vehicle
ATTACHMENT TO ‰ X Complaint ‰ Cross-Complaint
(Use a separate cause of action form for each cause of action.)
Plaintiff (name): Gamela Hassan
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): July 15, 2021
at (place): At or near Southbound I-880 north of Lewelling Blvd. in
San Leandro, California.
MV-2. DEFENDANTS
a. ‰
X The defendants who operated a motor vehicle are (names):
Defendants
‰X Does 1 to 10
b. ‰
X The defendants who employed the persons who operated a motor vehicle in the course of their employment
are (names): Defendants
‰X Does 1 to 10
c. ‰
X The defendants who owned the motor vehicle which was operated with their permission are (names):
Defendants
‰X Does 1 to 10
d. ‰
X The defendants who entrusted the motor vehicle are (names):
Defendants
‰
X Does 1 to 10
e. ‰
X The defendants who were the agents and employees of the other defendants and acted within the scope
of the agency were (names):
Defendants
‰
X Does 1 to 10
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 Code of Civil Procedure § 425.12
Judicial Council of California CAUSE OF ACTION - Motor Vehicle www.courtinfo.ca.gov
PLD-PI-001(1) [Rev. January 1, 2007]
Hassan, Gamela
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PLD-PI-001 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Brian L. Larsen 158252 Law Offices of Brian L. Larsen 530 Jackson Street, 2nd Floor San Francisco, CA 94133 TELEPHONE NO.: (415) 398-5000 FAX NO.(Optional): (415) 398-5080 E-MAIL ADDRESS (Optional): brian@brianlarsenlaw.com ATTORNEY FOR (Name): Plaintiff SUPERIOR COURT OF CALIFORNIA, COUNTY OF Alameda STREET ADDRESS: 1225 Fallon Street MAILING ADDRESS: CITY AND ZIP CODE: Oakland, CA 94612 BRANCH NAME: PLAINTIFF: Gamela Hassan DEFENDANT: Yan Kwong Lee, Chiung Kuang Lee, and DOES 1 to 10. ‰ DOES 1 TO COMPLAINT-Personal Injury, Property Damage, Wrongful Death ‰ AMENDED (Number): Type (check all that apply): ‰ X MOTOR VEHICLE ‰ OTHER (specify): ‰ X 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): Gamela Hassan alleges causes of action against defendant (name or names): Yan Kwong Lee, Chiung Kuang Lee, and DOES 1 to 10. 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 Hassan, Gamela PLD-PI-001 SHORT TITLE: CASE NUMBER: Hassan v. Lee, et al. 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) ‰ 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): b. ‰ except defendant (name): d. ‰ except defendant (name): (1) ‰ a business organization, form unknown (1) ‰ a business organization, form unknown (2) ‰ 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 Doe defendants (specify Doe numbers): 1 to 5 were the agents or employees of other named defendants and acted within the scope of that agency or employment. b. ‰ X Doe defendants (specify Doe numbers): 6 to 10 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 Hassan, Gamela PLD-PI-001 SHORT TITLE: CASE NUMBER: Hassan v. Lee, et al. 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. ‰ X loss of use of property c. ‰ X hospital and medical expenses d. ‰ X general damage e. ‰ X 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): MV-1; MV-2 6/16/2023 Date: Brian L. Larsen (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 Hassan, Gamela PLD-PI-001(1) SHORT TITLE: CASE NUMBER: Hassan v. Lee, et al. FIRST (number) CAUSE OF ACTION- Motor Vehicle ATTACHMENT TO ‰ X Complaint ‰ Cross-Complaint (Use a separate cause of action form for each cause of action.) Plaintiff (name): Gamela Hassan 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): July 15, 2021 at (place): At or near Southbound I-880 north of Lewelling Blvd. in San Leandro, California. MV-2. DEFENDANTS a. ‰ X The defendants who operated a motor vehicle are (names): Defendants ‰X Does 1 to 10 b. ‰ X The defendants who employed the persons who operated a motor vehicle in the course of their employment are (names): Defendants ‰X Does 1 to 10 c. ‰ X The defendants who owned the motor vehicle which was operated with their permission are (names): Defendants ‰X Does 1 to 10 d. ‰ X The defendants who entrusted the motor vehicle are (names): Defendants ‰ X Does 1 to 10 e. ‰ X The defendants who were the agents and employees of the other defendants and acted within the scope of the agency were (names): Defendants ‰ X Does 1 to 10 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 Code of Civil Procedure § 425.12 Judicial Council of California CAUSE OF ACTION - Motor Vehicle www.courtinfo.ca.gov PLD-PI-001(1) [Rev. January 1, 2007] Hassan, Gamela