On May 31, 2019 a
Complaint,Petition
was filed
involving a dispute between
Juarez Alvarez, Yolanda,
and
Bessemer Trust Company, N.A.,
City Of Fontana,
Does 1 Through 100,
Does 5 Through 100, Inclusive,
Hunt Enterprises, Inc.,
Hunt, Priscilla,
Hunt Priscilla Living Trust,
for Complaint for Damages Unlimited
in the District Court of San Bernardino County.
Preview
1
PLD PI 002
AITORNEY OR PARTV VNTHOUT ATTORNEY Name stafe banrum6er and addiess FOR CQURl USEONLY a
Allison K Hilgers Esq SBN 228862
Alderman and I Iilgers
1 I50 S Olive Street Suite 1800
Los Angeles CA 90015 a
y
TELFPHONE NO Z 13 772 OGOV FAXNO OpfionaQ 213 99G 32 Z SUP i 1C7
7 1
1J
f r
1i
j
E MAILAODRESS Opfionaq aI111ge1 S LI c I1C llaW COITl cC
f
h r
a i r l I i I i
7
ATTORNEY FOR Name ne feIlU lllt City of Fontana
NAME OF COURT San elI111 dlri0 SAp01 101 COUI Q 5 j I I
STREETADDRESS
MAILING ADDRESS 2L 7 WeSt Tlllld StPeet
CI1Y AND ZIP CODE SAIl B01 1laPCI1110 92415
r
i a
l l f
BRANCH NAME S aI1 Be1 Il1I I110 if i ir jt r i
1 l
SHORT TITLE
i
ALVAREZ v HLTNT PRISCILLA LIVING 1RUS1
CROSS COMPLAINANT
i
CITY OF FON IANA
i
I
CROSS DEFENDANT
HUNT PRISCILLA LIVING TRUST LOURDES RAMIREZ GABRIEL
ORDA7 and ROES 1 20
i
DOES 1 TO
I
CROSS COMPLAINT Personal Injury Property Damage Wrongful Death
0 AMENDED NumberJ I
Causes of Action check all that applyJ
X Apportionment of Fault Declaratory Relief
X Indemnification Other specify I
cnse NUMeER
Jurisdiction check all that
apply
ACTION IS A LIMITED CIVIL CASE 25 000 or less
CIVDS 1916334
0 ACTION IS AN UNLIMITED CIVIL CASE exceeds 25 000
It 0 is XO is not reclassified as unlimited by this cross complaint
1 CROSS COMPLAINANT name
CI 1 Y OF FONTANA
alleges causes of action against CROSS DEFENDANT name
HiJNT PRISCILLA LIVING TRUST LOURD S RAMIREZ GABRIEL ORDAZ and ROES 1 20
the following number of pages 3
f
2 This pleading including exhibits and attachments consists of
i
3 Each cross complainant named above is a competent adult
a except cross complainant name
City of Fontana
1 a corporation qualified to do business in California
2 0 an unincorporated entity descnbe
3 0 a public entity descinbe
4 a minor 0 an adult I
a for whom a guardian or conservator of the estate or a guardian ad litem has been appointed
b other specify
5 0 other specify i
information about additional cross complainants who are not competent adults is contained in
Cross Complaint Attachment 3
Pag 1 of 3
FonnApprovedforOplionalUse CodeofCivilProcedure 425 12
CROSS COMPLAINT Personal Injury
J dicial Council of Califomia
PLD PI002 Rev
January 1 2007
Property Damage Wrongful Death
PLD PI 002
cnsENUMaER
SHORT TITLE
ALVAREI v HiJNT PRISCILLA LIVING TRUST 1988437 CNDS 1916334
4 Each cross defendant named above is a natural person
a except cross defendant name Hunt 1 riscilla Living Trust b except cross defendant name
1 a business organization form unknown 1 0 a business organization form unknown
2 a corporation 2 0 a corporation
3 an unincorporated entity describeJ 3 an unincorporated entity describe
4 0 a public
entity describe 4 0 a public entity describe
5 0 other speci y 5 other specify
Information about additional cross defendants who are not natural persons is contained in
Cross Complaint Attachment 4
5 The true defendants Does to
names and capacities of cross sued as are unknown cross complainant
i
6 Cross complainant is required to comply with a claims statute and
a 0 has complied with applicable claims statutes or
b is excused from complying because specify
i
i
I
i
i
7 FIRST Cause of Action Indemnification
NUMBER
a Cross defendants were the agents employees co venturers partners or in some manner agents or principals or both j
for each other and were acting within the course and scope of their agency or employment
b The principal action alleges among other things conduct entitling plaintiff to compensatory damages against me I
i
contend that I am not liable for events and occurrences described in plaintiff s compiaint i
c If I am
described in
found in some manner responsible to plaintiff or to anyone else as a result of the incidents and occurrences
i
plaintiffs complaint my liability would be based solely upon a derivative form of liability not resulting from my i
conduct but only from an obligation imposed upon me by law therefore I would be entitled to complete indemnity from
i
each cross defendant
8 Cg7 SECOND Cause of Action Apportionment of Fault
NUMBER
a Each cross defendant was responsible in whole or in part for the injuries if any suffered by piaintiff
b If I am judged liable to plaintiff each cross defendant should be required 1 to pay a share of plaintiffs judgment which is
i
in proportion to the comparative negligence of that cross defendant in causing plaintiffs damages and 2 to reimburse me
for any payments I make to plaintiff in excess of my proportional share of all cross defendants negligence
Pa a e2ofJ
CROSS COMPLAINT Personal
PL D P 1 002 Rev 1 2007
January Injury
Damage Wrongfui Death
Property
Document Filed Date
July 05, 2019
Case Filing Date
May 31, 2019
Category
Complaint for Damages Unlimited
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1 PLD PI 002 AITORNEY OR PARTV VNTHOUT ATTORNEY Name stafe banrum6er and addiess FOR CQURl USEONLY a Allison K Hilgers Esq SBN 228862 Alderman and I Iilgers 1 I50 S Olive Street Suite 1800 Los Angeles CA 90015 a y TELFPHONE NO Z 13 772 OGOV FAXNO OpfionaQ 213 99G 32 Z SUP i 1C7 7 1 1J f r 1i j E MAILAODRESS Opfionaq aI111ge1 S LI c I1C llaW COITl cC f h r a i r l I i I i 7 ATTORNEY FOR Name ne feIlU lllt City of Fontana NAME OF COURT San elI111 dlri0 SAp01 101 COUI Q 5 j I I STREETADDRESS MAILING ADDRESS 2L 7 WeSt Tlllld StPeet CI1Y AND ZIP CODE SAIl B01 1laPCI1110 92415 r i a l l f BRANCH NAME S aI1 Be1 Il1I I110 if i ir jt r i 1 l SHORT TITLE i ALVAREZ v HLTNT PRISCILLA LIVING 1RUS1 CROSS COMPLAINANT i CITY OF FON IANA i I CROSS DEFENDANT HUNT PRISCILLA LIVING TRUST LOURDES RAMIREZ GABRIEL ORDA7 and ROES 1 20 i DOES 1 TO I CROSS COMPLAINT Personal Injury Property Damage Wrongful Death 0 AMENDED NumberJ I Causes of Action check all that applyJ X Apportionment of Fault Declaratory Relief X Indemnification Other specify I cnse NUMeER Jurisdiction check all that apply ACTION IS A LIMITED CIVIL CASE 25 000 or less CIVDS 1916334 0 ACTION IS AN UNLIMITED CIVIL CASE exceeds 25 000 It 0 is XO is not reclassified as unlimited by this cross complaint 1 CROSS COMPLAINANT name CI 1 Y OF FONTANA alleges causes of action against CROSS DEFENDANT name HiJNT PRISCILLA LIVING TRUST LOURD S RAMIREZ GABRIEL ORDAZ and ROES 1 20 the following number of pages 3 f 2 This pleading including exhibits and attachments consists of i 3 Each cross complainant named above is a competent adult a except cross complainant name City of Fontana 1 a corporation qualified to do business in California 2 0 an unincorporated entity descnbe 3 0 a public entity descinbe 4 a minor 0 an adult I a for whom a guardian or conservator of the estate or a guardian ad litem has been appointed b other specify 5 0 other specify i information about additional cross complainants who are not competent adults is contained in Cross Complaint Attachment 3 Pag 1 of 3 FonnApprovedforOplionalUse CodeofCivilProcedure 425 12 CROSS COMPLAINT Personal Injury J dicial Council of Califomia PLD PI002 Rev January 1 2007 Property Damage Wrongful Death PLD PI 002 cnsENUMaER SHORT TITLE ALVAREI v HiJNT PRISCILLA LIVING TRUST 1988437 CNDS 1916334 4 Each cross defendant named above is a natural person a except cross defendant name Hunt 1 riscilla Living Trust b except cross defendant name 1 a business organization form unknown 1 0 a business organization form unknown 2 a corporation 2 0 a corporation 3 an unincorporated entity describeJ 3 an unincorporated entity describe 4 0 a public entity describe 4 0 a public entity describe 5 0 other speci y 5 other specify Information about additional cross defendants who are not natural persons is contained in Cross Complaint Attachment 4 5 The true defendants Does to names and capacities of cross sued as are unknown cross complainant i 6 Cross complainant is required to comply with a claims statute and a 0 has complied with applicable claims statutes or b is excused from complying because specify i i I i i 7 FIRST Cause of Action Indemnification NUMBER a Cross defendants were the agents employees co venturers partners or in some manner agents or principals or both j for each other and were acting within the course and scope of their agency or employment b The principal action alleges among other things conduct entitling plaintiff to compensatory damages against me I i contend that I am not liable for events and occurrences described in plaintiff s compiaint i c If I am described in found in some manner responsible to plaintiff or to anyone else as a result of the incidents and occurrences i plaintiffs complaint my liability would be based solely upon a derivative form of liability not resulting from my i conduct but only from an obligation imposed upon me by law therefore I would be entitled to complete indemnity from i each cross defendant 8 Cg7 SECOND Cause of Action Apportionment of Fault NUMBER a Each cross defendant was responsible in whole or in part for the injuries if any suffered by piaintiff b If I am judged liable to plaintiff each cross defendant should be required 1 to pay a share of plaintiffs judgment which is i in proportion to the comparative negligence of that cross defendant in causing plaintiffs damages and 2 to reimburse me for any payments I make to plaintiff in excess of my proportional share of all cross defendants negligence Pa a e2ofJ CROSS COMPLAINT Personal PL D P 1 002 Rev 1 2007 January Injury Damage Wrongfui Death Property