On August 27, 2021 a
Complaint,Petition
was filed
involving a dispute between
Ronnie Newton, Sr.,
and
Madden Trust Property Management,
for Civil Rights
in the District Court of Alameda County.
Preview
AA
INT 240737281
~~
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FON wens uae UNLY
Kone eetors Scag ont load,co Hs
TELEPHONE No: F//S, fs GS: S7 7 Got/ FAX NO. (Optional):
E-MAIL ADDRESS (Optional): A_Je Son) Kune kl @® ) Yen Aco “Com
SUPERIOR COUR OF CALFORNA COUNNOE © TWD GON COUNT owe | ALiDA GULTY
ATTORNEY FOR (Name): an
MAILING ADDRESS: . 1225 Falion Street
CITY AND ZIP CODE: Oak an d, C. A 9461 2
BRANCH NAME:
PLAINTIFF: KOWANe Abu Hon) Sc
DEFENDANT: mMaddex) trust Qropecly Mlenkgeme
[__] poEs 1To
COMPLAINT—Personal Injury, Property Damage, Wrongful Death
[~~] AMENDED (Number):
Type (check all that apply):
[__] MOTOR VEHICLE [__] OTHER (specify):
[__] Property Damage [__| Wrongful Death
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
[7] ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000) RE, 2 1 { ‘i 104 3
[__] ACTION IS RECLASSIFIED by this amended complaint
from limited to unlimited
[___] from unlimited to limited
1. Plaintiff (name or names): Lownie Aeu)ton Me , Tess t prope ely a pegene H-
alleges causes of action against defendant (name or names):
2. This pleading, including attachments and exhibits, consists of the following number of pages:
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) ] aminor [7] 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) [_] aminor [_] 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):
[J information about additional plaintiffs who are not competent adults is shown in Attachment 3. Page tof 3
Form Approved for Optional Use COMPLAINT—Personal Injury, Property Code of Civil Procedure, § 425.12
Judicial Council of California www.courtinfo.ca.gov
PLD-PI-001 [Rev. January 1, 2007] Damage, Wrongful Death
PLD-PI-001
ie
SHORT TITLE: . CASE NUMBER:
Di Stns nia rachion) Sct
4. (__] Plaintiff (name): Kanaie JJevrfow) S-
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 / [ 4 ort
a. [__] except defendant (name): c. [__] exceptdefendant (name): M : cust | a Va
(1) [£_] a business organization, form unknown (h) a business organization, form unknown
(2) [-_] a corporation (2) [__] acorporation
(3) [-_] an unincorporated entity (describe): , (3) [[_] an unincorporated entity (describe):
(4) [__] a public entity (describe): (4) 7] 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) [7] 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. [__] Doe defendants (specify Doe numbers): were the agents or employees of other
named defendants and acted within the scope of that agency or employment.
b. [__] Doe defendants (specify Doe numbers): 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
. [__] atleast one defendant now resides in its jurisdictional area.
pe]
. [_] the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area.
ao 5
[-_] injury to person or damage to personal property occurred in its jurisdictional area.
L__] 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-P1-001 (Rev. January 1, 2007] COMPLAINT—Personal Injury, Property Page 2 of 3
Damage, Wrongful Death
PLD-PI-001
SHORT TITLE: CASE NUMBER:
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):
[ ~] Motor Vehicle
mopaogo®n
[-T General Negligence
{__] Intentional Tort
[_] Products Liability
[7 Premises Liability
[F7] Other (specify):
11. Plaintiff has suffered
a. [7] wage loss
b. [__] loss of use of property
|] hospital and medical expenses
{-_] general damage
aemroao
property damage
loss of earning capacity
{__]} 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) [__] compensatory damages
(2) [_] punitive damages
The amount of damages is (in cases for personal injury or wrongful death, you must check (1)):
(1) Cod according to proof
(2) C7] in the amount of: $
15. [__] The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers):
cae: 09/27/21
VLAN aL Alec teu) Se > Prniglliede
(TYPE OR PRINT NAME) gioeature OF PLAINTIFF OR ATTORNEY)
PLD-PI-001 [Rev. January 1, 2007] COMPLAINT—Personal Injury, Property Page 3 of 3
Damage, Wrongful Death
Document Filed Date
August 27, 2021
Case Filing Date
August 27, 2021
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AA INT 240737281 ~~ ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FON wens uae UNLY Kone eetors Scag ont load,co Hs TELEPHONE No: F//S, fs GS: S7 7 Got/ FAX NO. (Optional): E-MAIL ADDRESS (Optional): A_Je Son) Kune kl @® ) Yen Aco “Com SUPERIOR COUR OF CALFORNA COUNNOE © TWD GON COUNT owe | ALiDA GULTY ATTORNEY FOR (Name): an MAILING ADDRESS: . 1225 Falion Street CITY AND ZIP CODE: Oak an d, C. A 9461 2 BRANCH NAME: PLAINTIFF: KOWANe Abu Hon) Sc DEFENDANT: mMaddex) trust Qropecly Mlenkgeme [__] poEs 1To COMPLAINT—Personal Injury, Property Damage, Wrongful Death [~~] AMENDED (Number): Type (check all that apply): [__] MOTOR VEHICLE [__] OTHER (specify): [__] Property Damage [__| Wrongful Death 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 [7] ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000) RE, 2 1 { ‘i 104 3 [__] ACTION IS RECLASSIFIED by this amended complaint from limited to unlimited [___] from unlimited to limited 1. Plaintiff (name or names): Lownie Aeu)ton Me , Tess t prope ely a pegene H- alleges causes of action against defendant (name or names): 2. This pleading, including attachments and exhibits, consists of the following number of pages: 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) ] aminor [7] 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) [_] aminor [_] 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): [J information about additional plaintiffs who are not competent adults is shown in Attachment 3. Page tof 3 Form Approved for Optional Use COMPLAINT—Personal Injury, Property Code of Civil Procedure, § 425.12 Judicial Council of California www.courtinfo.ca.gov PLD-PI-001 [Rev. January 1, 2007] Damage, Wrongful Death PLD-PI-001 ie SHORT TITLE: . CASE NUMBER: Di Stns nia rachion) Sct 4. (__] Plaintiff (name): Kanaie JJevrfow) S- 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 / [ 4 ort a. [__] except defendant (name): c. [__] exceptdefendant (name): M : cust | a Va (1) [£_] a business organization, form unknown (h) a business organization, form unknown (2) [-_] a corporation (2) [__] acorporation (3) [-_] an unincorporated entity (describe): , (3) [[_] an unincorporated entity (describe): (4) [__] a public entity (describe): (4) 7] 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) [7] 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. [__] Doe defendants (specify Doe numbers): were the agents or employees of other named defendants and acted within the scope of that agency or employment. b. [__] Doe defendants (specify Doe numbers): 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 . [__] atleast one defendant now resides in its jurisdictional area. pe] . [_] the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area. ao 5 [-_] injury to person or damage to personal property occurred in its jurisdictional area. L__] 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-P1-001 (Rev. January 1, 2007] COMPLAINT—Personal Injury, Property Page 2 of 3 Damage, Wrongful Death PLD-PI-001 SHORT TITLE: CASE NUMBER: 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): [ ~] Motor Vehicle mopaogo®n [-T General Negligence {__] Intentional Tort [_] Products Liability [7 Premises Liability [F7] Other (specify): 11. Plaintiff has suffered a. [7] wage loss b. [__] loss of use of property |] hospital and medical expenses {-_] general damage aemroao property damage loss of earning capacity {__]} 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) [__] compensatory damages (2) [_] punitive damages The amount of damages is (in cases for personal injury or wrongful death, you must check (1)): (1) Cod according to proof (2) C7] in the amount of: $ 15. [__] The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers): cae: 09/27/21 VLAN aL Alec teu) Se > Prniglliede (TYPE OR PRINT NAME) gioeature OF PLAINTIFF OR ATTORNEY) PLD-PI-001 [Rev. January 1, 2007] COMPLAINT—Personal Injury, Property Page 3 of 3 Damage, Wrongful Death