On September 29, 2022 a
Complaint,Petition
was filed
involving a dispute between
Clean Initiative Llc,
and
California Automobile Insurance Company,
Does 1-10,
Mercury Insurance Services, Llc,
for Other non-PI/PD/WD Tort Unlimited
in the District Court of San Bernardino County.
Preview
\J
Darren S. Schwartz, Esq. (SBN 290297)
The Morgan Law Group F I LE D
SUPERIOR COURT 0F CAUFORNIA
2041 Rosecrans Avenue, Ste. 395 coumv 0F SAN BERNAHDINO
E1 Segundo, California 90245 SAN BERNAnomo ousmm
b)
Telephone: (323) 991-9204 and (310) 946-0051
(305)443—6828
SEP 2 9 2022
Facsimile:
Email: dschwafizfibmorganlawgroup.net
e-Service: mlg.esewice@1norganlawgroup.net
a
BY? Sophia ;.Smnh, Deputy
flaw
Robert A. Waller, Jr. (SBN 169604)
LAW OFFICE OF ROBERT A. WALLER, JR.
00 P.O. Box 999
Cardiff—by—the-Sea, California 92007
Telephone: (760) 753-31 18
Facsimile: (760) 753-3206
10
Email: robertQDrobertwallerlaw.com
e-Service: m1g.eservice@morganlawgroupnet
11
12 Attorneys for Plaintiff
13 SUPERIOR COURT OF THE STATE OF CALIFORNIA
14 COUNTY OF SAN BERNARDINO
15 CLEAN INITIATIVE LLC, Case No. CIVSB 2221523
16
Plaintiff,
COMPLAINT FOR DAMAGES
17
18 x/
':
r7;
4&1 D)
H
_
19 MERCURY INSURANCE SERVICES, r V _.,.___._... I L../
LLC., and DOES 1 through 10, inclusive,
20
Defendants.
21
JURY TRIAL DEMANDED
22
23
24 Plaintiff CLEAN INITIATIVE LLC alleges:
25
THE PARTIES
26
1. Plaintiff CLEAN INITIATIVE LLC (“Plaintiff’) is a California Limited Liability
27
Company duly registered with the California Secretary of State (Registration No. 201628610180)
28
COMPLAINT FOR DAMAGES 1
and operating by and under the laws of the State of California.
2. Plaintiff is in the business of providing inspection and where necessary repairs to the
roofs of real property. Plaintiff received an assignment of insurance benefits from the underlying
policy holder (hereinafter “Policy Holder”) of Defendant’s insurance policy. Plaintiff received the
assignment of benefits from the Policy Holder after the loss happened and within the time limits of
the insurance policy issued by Defendant to the Policy Holder.
\DWVON
3. Based on information and belief, Defendant MERCURY INSURANCE SERVICES,
LLC. (“Defendant”) is an insurance company duly licensed in the State of California and registered
with the California Department of Insurance.
10
4. Defendant issued a policy of insurance identified with policy number CAHP
11
0000298588 to the Policy Holder the provisions of which cover the underlying claims giving rise to
12
this action. The Policy Holder assigned the benefits of Defendant’s policy to Plaintiff including but
13
not limited to payment of claims by Defendant for losses to the insured property.
14
15 5. Plaintiff is ignorant of the true names or identities of those fictitiously named
16 defendants identified herein as DOES 1—10, inclusive. Plaintiff will amend the complaint to
17 substitute the true names of those defendants if and when their true identities are discovered.
18 Plaintiff alleges the fictitiously named defendants were in some way responsible for the occurrences,
19 harms, losses and/or damages alleged herein.
20 were actual or ostensible agents, partners,
6. Plaintiff alleges all defendants herein
21 of
associates, or co-conspirators of each of other and the actions of each of them was in furtherance
22 and done for the benefit of each
their agency, partnership, association, and/or conspiracy relationship
23
0f them.
24
FACTUAL BACKGROUND
25
7. Plaintiff performed roof inspection and/or repair services for the benefit of the Policy
26
Holder for the purposes 0f identifying and/or repairing damage or other issues to the roof of the
27
Policy Holder’s premises which is/was insured by Defendant at the time the loss happened.
28
Document Filed Date
September 29, 2022
Case Filing Date
September 29, 2022
Category
Other non-PI/PD/WD Tort Unlimited
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Preview
\J Darren S. Schwartz, Esq. (SBN 290297) The Morgan Law Group F I LE D SUPERIOR COURT 0F CAUFORNIA 2041 Rosecrans Avenue, Ste. 395 coumv 0F SAN BERNAHDINO E1 Segundo, California 90245 SAN BERNAnomo ousmm b) Telephone: (323) 991-9204 and (310) 946-0051 (305)443—6828 SEP 2 9 2022 Facsimile: Email: dschwafizfibmorganlawgroup.net e-Service: mlg.esewice@1norganlawgroup.net a BY? Sophia ;.Smnh, Deputy flaw Robert A. Waller, Jr. (SBN 169604) LAW OFFICE OF ROBERT A. WALLER, JR. 00 P.O. Box 999 Cardiff—by—the-Sea, California 92007 Telephone: (760) 753-31 18 Facsimile: (760) 753-3206 10 Email: robertQDrobertwallerlaw.com e-Service: m1g.eservice@morganlawgroupnet 11 12 Attorneys for Plaintiff 13 SUPERIOR COURT OF THE STATE OF CALIFORNIA 14 COUNTY OF SAN BERNARDINO 15 CLEAN INITIATIVE LLC, Case No. CIVSB 2221523 16 Plaintiff, COMPLAINT FOR DAMAGES 17 18 x/ ': r7; 4&1 D) H _ 19 MERCURY INSURANCE SERVICES, r V _.,.___._... I L../ LLC., and DOES 1 through 10, inclusive, 20 Defendants. 21 JURY TRIAL DEMANDED 22 23 24 Plaintiff CLEAN INITIATIVE LLC alleges: 25 THE PARTIES 26 1. Plaintiff CLEAN INITIATIVE LLC (“Plaintiff’) is a California Limited Liability 27 Company duly registered with the California Secretary of State (Registration No. 201628610180) 28 COMPLAINT FOR DAMAGES 1 and operating by and under the laws of the State of California. 2. Plaintiff is in the business of providing inspection and where necessary repairs to the roofs of real property. Plaintiff received an assignment of insurance benefits from the underlying policy holder (hereinafter “Policy Holder”) of Defendant’s insurance policy. Plaintiff received the assignment of benefits from the Policy Holder after the loss happened and within the time limits of the insurance policy issued by Defendant to the Policy Holder. \DWVON 3. Based on information and belief, Defendant MERCURY INSURANCE SERVICES, LLC. (“Defendant”) is an insurance company duly licensed in the State of California and registered with the California Department of Insurance. 10 4. Defendant issued a policy of insurance identified with policy number CAHP 11 0000298588 to the Policy Holder the provisions of which cover the underlying claims giving rise to 12 this action. The Policy Holder assigned the benefits of Defendant’s policy to Plaintiff including but 13 not limited to payment of claims by Defendant for losses to the insured property. 14 15 5. Plaintiff is ignorant of the true names or identities of those fictitiously named 16 defendants identified herein as DOES 1—10, inclusive. Plaintiff will amend the complaint to 17 substitute the true names of those defendants if and when their true identities are discovered. 18 Plaintiff alleges the fictitiously named defendants were in some way responsible for the occurrences, 19 harms, losses and/or damages alleged herein. 20 were actual or ostensible agents, partners, 6. Plaintiff alleges all defendants herein 21 of associates, or co-conspirators of each of other and the actions of each of them was in furtherance 22 and done for the benefit of each their agency, partnership, association, and/or conspiracy relationship 23 0f them. 24 FACTUAL BACKGROUND 25 7. Plaintiff performed roof inspection and/or repair services for the benefit of the Policy 26 Holder for the purposes 0f identifying and/or repairing damage or other issues to the roof of the 27 Policy Holder’s premises which is/was insured by Defendant at the time the loss happened. 28