On October 08, 2019 a
Complaint,Petition
was filed
involving a dispute between
Acosta, Sandy,
Jetcruzer International, Llc.,
and
Acosta, Sandy,
Does 3 Through 50,
Guzman, Marvin J.,
Zepeda, Ulises A.,
for Fraud
in the District Court of San Bernardino County.
Preview
L
1 Angelica Acosta Samaniego SBN 235423
VARNER BRANDT LLP
2 1
3750 University Avenue Suite 610
SUPERIOR COURI F CALIFORNIA
Riverside California 92501 COUNTY OF SAN Eti RNARDINO
3 SAN BERNARJiNO DISTRICT
Telephone 951 274 7777
4 Facsimile 951 274 7770
T 2 1
5 Attorneys for Plaintiff
BY Q
JETCRUZER INTERNATIONAL LLC
6 ALPAA VALLtJO GAR r GEPUTY
7
SUPERIOR COURT OF THE STATE OF CALIFORNIA
8
9 FOR THE COUNTY OF SAN BERNARDINO
10 C V J 9 1 2
JETCRUZER INTERNATIONAL LLC Case No
11
Plaintiffs COMPLAINT FOR
a 12
rn
s 13 1 INTENTIONAL INTERFERENCE WITH
o 14
SANDY ACOSTA an individual and
ECONOMIC ADVANTAGE
N DBA CH1N0 AIRCRAFT INTERIORS 2 NEGLIGENT INTERFERENCE WITH
PAINT and CH1N0 AIRCRAFT ECONOMIC ADVANTAGE
a 15 TERIORS CAI DOES 1 through
and 3 UNFAIR BUSINESS PRACTICES
50 inclusive 17200 B P
16
i 4 CONVERSION
1 7 5 CONSPIRACY
6 FRAUD AND DECEIT
1 g 7 BREACH OF CONTRACT
8 BREACH OF THE COVENANT OF S ao
19
GOOD FAITH AND FAIR DEALING
Ibd
20
a
21
j
GENERAL ALLEGATIONS
22 1 Plaintiff JETCRUZER INTERNATIONAL LLC hereinafter Plaintiff or
23 JETCRUZER is and all times relevant hereto was a California Limited Liability Company
24
with its primary place of business in San Bernardino County California
25 2 Plaintiff is informed and believes and thereon alleges that Defendant SANDY
26 ACOSTA is and at all times relevant hereto was an individual and a resident of Orange County
27
California Plaintiff is further informed and believes and thereon alleges that Defendant SANDY
28 ACOSTA is business CHINO AIRCRAFT INTERIORS PAINT and or CHINO
doing as
1
COMPLAINT
1 AIRCRAFT INTERIORS CAI with a primary place of business is in San Bernardino County
2 California SANDY ACOSTA CHINO AIRCRAFT INTERIORS PAINT and CHINO
3 AIRCRAFT INTERIORS CAI will be referred to collectively herein as CHINO AIRCRAFT
4 3 Plaintiff is informed and believes and thereon alleges that CHINO AIRCRAFT S
5 fictitious business name statement for CHINO AIRCRAFT INTERIORS PAINT was filed
6
with the county clerk recorder in San Bernardino County California pursuant to fictitious
7 business name filing FBN20190008665 on July 26 2019 CHINO AIRCRAFT INTERIORS
8 CAI was filed with the county clerk recorder in San Bernardino County California pursuant to
9 fictitious business name filing FBN20130000834 on January 24 2013 and renewed on April
10 O5 2018 under filing FBN20180003983
11 4 The true names and capacities whether individual corporate associate or
12 otherwise of Defendants DOES 1 through 25 inclusive are unknown to Plaintiff who therefore
a
a n
13 sues said Defendants and each of them by such fictitious names Plaintiffis informed and
m 14 believes and thereon alleges that the Defendants designated herein as DOES 1 through 25
o 3 U
b 15 inclusive are responsible in some manner for the events and happenings herein referred to and
16 caused injuries and damages to the P lainti ff as herein allege d
o
17 5 At all times herein mentioned each Defendant was the agent and employee of
18 each of the remaining Defendants and were at all times acting within the purpose course and
19 scope of said agency and employment
20 6 Plaintiff is engaged in the aerospace aeronautics business JETCRUZER began
21 doing business with CHINO AIRCRAFT as part of a program to develop a prototype of a new
22 model of high end luxury private business class jet aircraft
23 7 Defendants CHINO AIRCRAFT are also engaged in the aircraft aeronautics
24 business providing interior amenities painting and other craftsmanship services for building
25 remodeling or refurbishing of aircraft CHINO AIRCRAFT advertises itself as setting the
Q
26 standard for custom aircraft interior exterior refurbishment for years We only use the
27 finest leathers fabrics and carpets while offering you the highest quality of craftsmanship all at
28 fair and reasonable prices
2
COMPLAINT
Document Filed Date
October 08, 2019
Case Filing Date
October 08, 2019
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L 1 Angelica Acosta Samaniego SBN 235423 VARNER BRANDT LLP 2 1 3750 University Avenue Suite 610 SUPERIOR COURI F CALIFORNIA Riverside California 92501 COUNTY OF SAN Eti RNARDINO 3 SAN BERNARJiNO DISTRICT Telephone 951 274 7777 4 Facsimile 951 274 7770 T 2 1 5 Attorneys for Plaintiff BY Q JETCRUZER INTERNATIONAL LLC 6 ALPAA VALLtJO GAR r GEPUTY 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 9 FOR THE COUNTY OF SAN BERNARDINO 10 C V J 9 1 2 JETCRUZER INTERNATIONAL LLC Case No 11 Plaintiffs COMPLAINT FOR a 12 rn s 13 1 INTENTIONAL INTERFERENCE WITH o 14 SANDY ACOSTA an individual and ECONOMIC ADVANTAGE N DBA CH1N0 AIRCRAFT INTERIORS 2 NEGLIGENT INTERFERENCE WITH PAINT and CH1N0 AIRCRAFT ECONOMIC ADVANTAGE a 15 TERIORS CAI DOES 1 through and 3 UNFAIR BUSINESS PRACTICES 50 inclusive 17200 B P 16 i 4 CONVERSION 1 7 5 CONSPIRACY 6 FRAUD AND DECEIT 1 g 7 BREACH OF CONTRACT 8 BREACH OF THE COVENANT OF S ao 19 GOOD FAITH AND FAIR DEALING Ibd 20 a 21 j GENERAL ALLEGATIONS 22 1 Plaintiff JETCRUZER INTERNATIONAL LLC hereinafter Plaintiff or 23 JETCRUZER is and all times relevant hereto was a California Limited Liability Company 24 with its primary place of business in San Bernardino County California 25 2 Plaintiff is informed and believes and thereon alleges that Defendant SANDY 26 ACOSTA is and at all times relevant hereto was an individual and a resident of Orange County 27 California Plaintiff is further informed and believes and thereon alleges that Defendant SANDY 28 ACOSTA is business CHINO AIRCRAFT INTERIORS PAINT and or CHINO doing as 1 COMPLAINT 1 AIRCRAFT INTERIORS CAI with a primary place of business is in San Bernardino County 2 California SANDY ACOSTA CHINO AIRCRAFT INTERIORS PAINT and CHINO 3 AIRCRAFT INTERIORS CAI will be referred to collectively herein as CHINO AIRCRAFT 4 3 Plaintiff is informed and believes and thereon alleges that CHINO AIRCRAFT S 5 fictitious business name statement for CHINO AIRCRAFT INTERIORS PAINT was filed 6 with the county clerk recorder in San Bernardino County California pursuant to fictitious 7 business name filing FBN20190008665 on July 26 2019 CHINO AIRCRAFT INTERIORS 8 CAI was filed with the county clerk recorder in San Bernardino County California pursuant to 9 fictitious business name filing FBN20130000834 on January 24 2013 and renewed on April 10 O5 2018 under filing FBN20180003983 11 4 The true names and capacities whether individual corporate associate or 12 otherwise of Defendants DOES 1 through 25 inclusive are unknown to Plaintiff who therefore a a n 13 sues said Defendants and each of them by such fictitious names Plaintiffis informed and m 14 believes and thereon alleges that the Defendants designated herein as DOES 1 through 25 o 3 U b 15 inclusive are responsible in some manner for the events and happenings herein referred to and 16 caused injuries and damages to the P lainti ff as herein allege d o 17 5 At all times herein mentioned each Defendant was the agent and employee of 18 each of the remaining Defendants and were at all times acting within the purpose course and 19 scope of said agency and employment 20 6 Plaintiff is engaged in the aerospace aeronautics business JETCRUZER began 21 doing business with CHINO AIRCRAFT as part of a program to develop a prototype of a new 22 model of high end luxury private business class jet aircraft 23 7 Defendants CHINO AIRCRAFT are also engaged in the aircraft aeronautics 24 business providing interior amenities painting and other craftsmanship services for building 25 remodeling or refurbishing of aircraft CHINO AIRCRAFT advertises itself as setting the Q 26 standard for custom aircraft interior exterior refurbishment for years We only use the 27 finest leathers fabrics and carpets while offering you the highest quality of craftsmanship all at 28 fair and reasonable prices 2 COMPLAINT