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1 Baird A. Brown SBN: 56627
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a Supariogr ALE of
LAW OFFICES OF BAIRD BROWN, P.C eorsa
2 ‘Ounty
of Log An
3055 Wilshire Blvd, Suite 1200
Los Angeles, CA 90010 NOV 3.0 2015
Phone: (213) 487-8880 SI herri A. Carter, E:
4 || Fascimile: (213) 487-8884 utive Officer/Clerk
Deputy
5 Attorney for Plaintiffs
6
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DI\ Sutaune (& Ry
iguana
SUPERIOR COURT OF THE STATE OF CAL /
COUNTY OF LOS ANGELES
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11 MARGARET AHN and MICHELLE PAK. Case No. BC6 42853
12 Plaintiffs,
Vv.
13 COMPLAINT TO QUIET TITLE AND
STEVE PETERS, and all persons unknown. FOR RESULTING TRUST AND
claiming any legal or equitable right, title, CONSTRUCTIVE TRUST
15 estate, lien, or interest in the property
described in the complaint adverse to
16 plaintiffs’ title, or any cloud on plaintiffs’ title
thereto; and DOES 1 through 100, inclusive.
17
18 Defendants.
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20
Plaintiffs allege
21
THE PARTIES BPERB mo
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1 Plaintiffs MARGARET AHN and MICHELLE PAK at all relevant tines Hiv re
223 geoomSES Toy
in the County of Los Angeles, in the State of California. Plaintiff Ahn is pladptieeP 3S daughter.
24 2 Defendant STEVE PETERS (“Peters” or defendant) at all relevant timeg is sided
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= the County of Los Angeles, in the State of California. od
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3 The defendants herein named as “all persons unknown, claiming any legal.of-equitable
right, title, estate, lien, or interest in the property described in the complaint adore to plaints title,
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COMPLAINT TO QUIET TITLE AND FOR RESULTING TRUST AND CONSTRUCTIVE TRUST
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or any cloud on plaintiffs’ title thereto” are unknown to the plaintiffs (“Unknown Defendant
These Unknown Defendants, and each of them, claim some right, title, estate, lien, or interest in the
hereinafter-described property adverse to plaintiffs’ title; and their claims, and each of them,
constitute a cloud on plaintiffs’ title to that property.
4 The true names and capacities, whether individual, corporate, associate or otherwise of
defendants named herein as DOES 1 through 100 are unknown to plaintiffs who therefore sue these
defendants by their fictitious names. Plaintiffs will ask leave to amend this complaint to show their
true names and capacities when they have been ascertained. Plaintiffs are informed and believe and
thereon allege that some of these fictitious named defendants claim some right, title, estate, lien, or
10 interest in the hereinafter-described property adverse to plaintiffs’ title and their claims, and each of
11 them, constitute a cloud on plaintiffs’ title to that property.
12 5 Plaintiffs are informed and believe and thereon allege that at all times herein mentioned
defendants were acting on their own behalf and as agents or employees of each of the other
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14 defendants, and the: acts described hereinafter were done in the course and scope of such agency or
15 employment, as well as on their own behalf. Further, defendants were authorized by defendant
16 principals in the doing and the manner of the acts alleged, and ratified said behavior.
17 FIRST CAUSE OF ACTION
18 QUIET TITLE
19 (Against All Defendants)
20 6 Plaintiffs reallege and incorporate by reference paragraphs | through 5 above.
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21 The'real property which forms the subject matter of this litigation is located in the City
22 of Lomita, County of Los Angeles, State of California. It consists of a parcel of land with a single
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be 23 family residence situated thereon commonly known as 1916 Callison Street, Lomita, California 90717
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24 (the “Property”). The legal description of the Property is as follows:
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o 25 “Parcel 3 of Parcel Map No. 25014, in the City of Lomita, County of Los Angeles,
26 State of California, as per map recorded in Book 286, Pages 87 and 88 of Maps, in the
27 Office of the County Recorder of said County.”
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COMPLAINT TO QUIET TITLE AND FOR RESULTING TRUST AND CONSTRUCTIVE TRUST
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8 Plaintiffs purchased the Property in 1999. Plaintiffs paid the down payment, but agreed
to Peters’ name being included on the deed as a grantee based on his representation to plaintiffs that
he would pay the Property’s mortgage payments, taxes, insurance, utilities, maintenance expenses and
home improvement expenses.
9 Escrow closed in October 1999 and a grant deed was executed and recorded. Pursuant
thereto the Property seller granted title to the Property to Peters and plaintiff Ahn as joint tenants.
10. In 2001, Peters executed and recorded a grant deed pursuant to which he purported to
grant title to the Property to his sister, Elena Prioteasa (“Prioteasa”), and plaintiff Ahn as joint tenants.
11. In 2002, Prioteasa and plaintiff Ahn granted title to the Property to Prioteasa as to an
10 undivided 50% interest and to plaintiffs as joint tenants as to an undivided 50% interest.
11 12. Subsequently, in 2008 plaintiff Pak quitclaimed her interest in the Property to plaintiff
12 Ahn, and in July 2016, plaintiff Ahn quitclaimed to plaintiff Pak an undivided half interest in her
13 interest in the Property.
14 13. In October 2016, Prioteasa caused a deed to be recorded that purported to grant a 50%
15 interest in the Property to Peters.
16 14. Neither Peters nor Prioteasa ever lived in the Property except for Peters’ living there
17 for approximately one year in 1999-2000. Plaintiffs and their family members otherwise have been the
18 only residents of the Property since plaintiffs purchased it in 1999.
19 15. Neither Peters nor Prioteasa ever made any mortgage payments on the Property.
20 Plaintiffs have made all of the mortgage payments.
21 16. Neither Peters nor Prioteasa ever made any tax payments on the Property. Plaintiffs
22 have made all of the tax payments.
223 17. Neither Peters nor Prioteasa ever made any insurance payments on the Property.
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24 Plaintiffs have made all of the insurance payments.
25 18. Neither Peters nor Prioteasa ever made any payments for utilities provided to the
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26 Property. Plaintiffs have made all of the utility payments.
27 19. Neither Peters nor Prioteasa ever made any payments for maintenance of the Property.
28 Plaintiffs have made all of the maintenance payments.
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COMPLAINT TO QUIET TITLE AND FOR RESULTING TRUST AND CONSTRUCTIVE TRUST
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20. Plaintiffs have spent more than $160,000 improving and remodeling the Property.
Neither Peters nor Prioteasa made any payments therefor.
21. The deed transfers to and from Peters and Prioteasa are void. Neither Peters nor
Prioteasa had or has valid title to the Property.
22. Plaintiffs seek to quiet title against the claims of all defendants to the Property. The
claims are without any right whatever, and defendants have no right, title, estate, lien, or interest
whatever in the Property or any part thereof.
23. Plaintiffs seek to quiet title as of the date this complaint is filed with the court.
SECOND CAUSE OF ACTION
10 RESULTING TRUST
11 (Against All Defendants)
12 24, Plaintiffs reallege and incorporate by reference paragraphs 1 through 23 above.
13 25. Plaintiffs provided all of the consideration for the purchase of the Property and Peters,
14 despite his promises, provided nothing. A trust thereby resulted in favor of plaintiffs as to defendants’
15 claimed interest in the Property.
16 26. Plaintiffs have suffered consequential damages by virtue of defendants’ actions in an
17 amount to be established according to proof.
18 27. In doing the foregoing acts, defendants acted in a willful, wanton, malicious,
19 oppressive, and fraudulent manner toward plaintiffs, and in conscious disregard of plaintiffs’ known
20 rights, with the intention of benefiting themselves financially, and with the intent of, or a conscious
21 disregard of the probability of, causing plaintiffs injury. In so acting, defendants intended to and did
22 vex, annoy, injure, and harass plaintiffs, and consciously disregarded its rights, so as to warrant the
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223 assessment of exemplary and punitive damages against defendants in a sum to be established
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24 according to proof.
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COMPLAINT TO QUIET TITLE AND FOR RESULTING TRUST AND CONSTRUCTIVE TRUST
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THIRD CAUSE OF ACTION
CONSTRUCTIVE TRUST
(Against All Defendants)
28 Plaintiffs reallege and incorporate by reference paragraphs 1 through 27 above.
29. Plaintiffs provided all of the consideration for the purchase, maintenance and
improvement of the Property, and Peters, despite his promises, provided nothing. A constructive trust
thereby arose in favor of plaintiffs as to defendants’ claimed interest in the Property.
30. Plaintiffs have suffered consequential damages by virtue of defendants’ actions in an
amount to be established according to proof.
10 31. In doing the foregoing acts, defendants acted in a willful, wanton, malicious,
11 oppressive, and fraudulent manner toward plaintiffs, and in conscious disregard of plaintiffs’ known
12 rights, with the intention of benefiting themselves financially, and with the intent of, or a conscious
13 disregard of the probability of, causing plaintiffs injury. In so acting, defendants intended to and did
14 vex, annoy, injure, and harass plaintiffs, and consciously disregarded its rights, so as to warrant the
15 assessment of exemplary and punitive damages against defendants in a sum to be established
16 according to proof.
17
18 WHEREFORE, plaintiffs pray for judgment as follows:
19 1 For a judgment declaring that plaintiffs are, the owners in fee simple of the Property
20 and that none of the defendants herein has any estate, right, title, interest or lien in and
21 to the Property, that title of plaintiffs in and to the Property be quieted against any and
22 all of the defendants, and that each and all of the defendants be and are forever
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ine 23 restrained and enjoined from asserting any estate, right, title, interest or lien in and to
24 the Property adverse to that of plaintiffs;
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9= 25 For imposition of a resulting trust on defendants’ claimed interest in the Property;
26 For imposition of a constructive trust on defendants’ claimed interest in the Property;
27 For consequential damages according to proof;
28 For exemplary and punitive damages according to proof;
5
COMPLAINT TO QUIET TITLE AND FOR RESULTING TRUST AND CONSTRUCTIVE TRUST
@
For attorney fees to the extent authorized by law;
For costs of suit incurred in this action; and
For such other and further relief as the Court deems just and proper.
5 || DATED: November 30, 2016 LAW OFFICES OF BAIRD A. BROWN
A Professional Corporation
Baird A. Brown
Attorneys for Plaintiffs
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COMPLAINT TO QUIET TITLE AND FOR RESULTING TRUST AND CONSTRUCTIVE TRUST
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VERIFICATION
STATE OF CALIFORNIA
COUNTY OF LOS ANGELES
Ihave read the foregoing document described as COMPLAINT TO QUIET TITLE AND
FOR RESULTING TRUST AND CONSTRUCTIVE TRUST and know its contents.
Iam a party to this action. The matters stated in the foregoing document are true of my own
knowledge, except as to those matters which are stated on information and belief, and as to those
matters, I believe them to be true.
I declare under penalty of perjury under the laws of the State of California that the foregoing is
10 true and correct.
1 Executed on November 30, 2016 at Los Angeles, California.
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COMPLAINT TO QUIET TITLE AND FOR RESULTING TRUST AND CONSTRUCTIVE TRUST
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. @ CM-01
ATTORNEY OR PARTY WITHOUT egipaner (Name, State Bar number, and aaa) FOR COURT USE ONLY
| Baird Brown, SBN 56627
LAW OFFICES OF BAIRD BROWN, P.C.
3055 Wilshire Blvd, Suite 1200
Los Angeles, CA 9001
raxno: 213-487-8884
“8 ‘Ounty
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of Logot CGFaltornia
reveponeno: 213-487-8880
ATTORNEY FOR (Name): Plaintiffs, Margaret Ahn and Michelle Pak
SUPERIOR COURTOF CALIFORNIA, COUNTY OF Los Angeles NOY 3.0 29
street aporess: |] ] North Hill Street Sherri R, Carter,
MAILING ADDRESS: By, Exeputive OticenCy
eles 90012 Aaalnad Broctsy
bi istrict
cry anozip cove: Los Any Depi
erancu awe: Central
CASE NAME:
AHN vs. PETERS
‘CASE NUMBEI
CIVIL CASE COVER SHEET
BC 642353
Complex Case Designation
Unlimited Limited
(Amount (Amount [5 counter (J) Joinder
JOGE:
demanded demanded is Filed with first appearance by defendant
exceeds $25,000) $25,000 or less)
(Cal. Rules of Court, rule 3.402) DEPT:
Items 1-6 below must be completed (see instructions on page 2).
4. Check one box below for the case type that best describes this case:
Auto Tort Contract Provisionally Complex Civil Litigation
Breach of contract/warranty (06) (Cal. Rules of Court, rules 3.400-3.403)
Auto (22)
Uninsured motorist (46) CI Rule 3.740 collections (09) [7 antitusttrade regulation (03)
Other PYPDIWD (Personal Injury/Property CJ Other collections (09) Construction defect (10)
Damage/Wrongful Death) Tort CI Insurance coverage (18) [J Mass tort (40)
(J Asbestos (04) C] Other contract (37) Securities litigation (28)
Product liability (24) Real Property Environmental/Toxic tort (30)
.dical malpractice (45) Eminent domain/Inverse Insurance coverage claims arising from the
CJ other pveowo (23) condemnation (14) above listed provisionally complex case
Non-Pi/PDIWD (Other) Tort (1 weongtut eviction (33) types (4
Other real property (26) Enforcement of Judgment
Business tort/unfair business practice (07)
Civil rights (08) Untawful Detainer Enforcement of judgment (20)
Defamation (13) Commercial (31) Miscellaneous Civil Complaint
Fraud (16) Residential (32) RICO (27)
intellectual property (19) Oo Drugs (38) Other complaint (not specified above) (42)
Professional negligence (25) Judicial Review Miscellaneous Civil Petition
Other non-PI/PD/WD tort (35) Asset forfeiture (05) Partnership and corporate governance (21)
loyment
cj
Petition re: arbitration award (11) [] other petition (not specified above) (43)
Wrongful termination (36) [1 writ of mandate (02)
Ct) Other employment (15) [1 other judicial review (39)
This case L_Jis [Tis not complex under rule 3.400 of the California Rules of Court. If the case is complex, mark the
factors requiring exceptional judicial management:
a oo Large number of separately represented parties d. oO Large number of witnesses
b. CI Extensive motion practice raising difficult or novel e. CO Coordination with related actions pending in one or more courts
issues that will be time-consuming to resolve in other counties, states, or countries, or in a federal court
[71 substantial amount of documentary evidence f. OO Substantial postjudgment judicial supervision
3. Remedies sought (check all that apply): a. Wy monetary. Ww nonmonetary; declaratory or injunctive relief punitive
4 Number of causes of acti (specify): 3
5. This case L_lis is not a class action suit.
6. If there are any known related cases, file and serve a notice of related case. (You may use form CM-015.)
~Date:
“Baird
(TYPE OR PRINT NAME)
> (SIGNATURE OF PARTY OR ATTORNEY FOR PARTY)
NOTICE
. ¢ Plaintiff must file this cover sheet with the first paper filed in the action or proceeding (except small claims cases or cases filed
oe under the Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.) Failure to file may result
in sanctions.
© File this cover sheet in addition to any cover sheet required by local court rule.
© If this case is complex under rule 3.400 et seq. of the California Rules of Court, you must serve a copy of this cover sheet on alll
other parties to the action or proceeding.
© Unless this is a collections case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes only.
1of2|
Form Adopted for Mandatory Use CIVIL CASE COVER SHEET ‘Cal, Rulesof Court, rules 2.30, 3.220, 3.400-3.403, 3.740,
Judicial Council of Califomia Cal, Standards of Judicial Administration, std. 3.10
‘CM-010 [Rev. July 1, 2007) wonw.courtinfo.ca.gov
we @ ®
CM-010
INSTRUCTIONS ON HOW TO.COMPLETE THE COVER SHEET
To Plaintiffs and Others Filing First Papers. If you are filing a first paper (for example, a complaint) in a civil case, you must
complete and file, along with your first paper, the Civil Case Cover Sheet contained on page 1. This information will be used to compile
statistics about the types and numbers of cases filed. You must complete items 1 through 6 on the sheet. In item 1, you must check
‘one box for the case type that best describes the case. If the case fits both a general and a more specific type of case listed in item 1,
check the more specific one. If the case has multiple causes of action, check the box that best indicates the primary cause of action.
To assist you in completing the sheet, examples of the cases that belong under each case type in item 1 are provided below. A cover
sheet must be filed only with your initial paper. Failure to file a cover sheet with the first paper filed in a civil case may subject a party,
its counsel, or both to sanctions under rules 2.30 and 3.220 of the California Rules of Court.
To Parties in Rule 3.740 Collections Cases. A "collections case" under rule 3.740 is defined as an action for recovery of money
owed in a sum stated to be certain that is not more than $25,000, exclusive of interest and attorney's fees, arising from a transaction in
which property, services, or money was acquired on credit. A collections case does not include an action seeking the following: (1) tort
damages, (2) punitive damages, (3) recovery of real property, (4) recovery of personal property, or (5) a prejudgment writ of
attachment. The identification of a case as a rule 3.740 collections case on this form means that it will be exempt from the general
time-for-service requirements and case management rules, unless a defendant files a responsive pleading. A rule 3.740 collections
case will be subject to the requirements for service and obtaining a judgment in rule 3.740.
To Parties in Complex Cases. In complex cases only, parties must also use the Civil Case Cover Sheet to designate whether the
case is complex. If a plaintiff believes the case is complex under rule 3.400 of the California Rules of Court, this must be indicated by
completing the appropriate boxes in items 1 and 2. If a plaintiff designates a case as complex, the cover sheet must be served with the
complaint on all parties to the action. A defendant may file and serve no later than the time of its first appearance a joinder in the
plaintiff's designation, a counter-designation that the case is not complex, or, if the plaintiff has made no designation, a designation that
the case is complex. CASE TYPES AND EXAMPLES
Auto Tort Contract Provisionally Complex Civil Litigation (Cal.
Auto (22)}-Personal Injury/Property Breach of Contract/Warranty (06) Rules of Court Rules 3.400-3.403)
Damage/Wrongful Death Breach of Rental/Lease Antitrust/Trade Regulation (03)
Uninsured Motorist (46) (if the Contract (not unlawful detainer Construction Defect (10)
Claims Involving Mass Tort (40)
case involves an uninsured or wrongful eviction}
‘motorist claim subject to Contract/Warranty Breach-Seller Securities Litigation (28)
arbitration, check this item Plaintiff (not fraud or negligence) Environmental/T oxic Tort (30)
instead of Auto) Negligent Breach of Contract/ Insurance Coverage Claims
Other PIPDIWD (Personal Injury/ Warrant (arising from provisionally complex
Property Damage/Wrongful Death) Other Breach of Contract/Warranty case type listed above) (41)
‘ort Collections (e.g., money owed, open Enforcement of Judgment
Asbestos (04) book accounts) (09) Enforcement of Judgment (20)
Asbestos Property Damage Collection Case-Seller Plaintiff Abstract of Judgment (Out of
Asbestos Personal Injury! Other Promissory Note/Collections “ounty)
Wrongful Death Confession of Judgment (non-
Product Liability (not asbestos or Insurance Coverage (not provisionally domestic relations)
toxic/environmental) (24) complex) (18) Sister State Judgment
Medical Malpractice (45) Auto Subrogation Administrative Agency Award
Medical Malpractice— Other Coverage (not unpaid taxes)
Physicians & Surgeons Other Contract (37) Petition/Certification of Entry of
Judgment on Unpaid Taxes
Other Professional Health Care Contractual Fraud
Malpractice Other Contract Dispute Other Enforcement of Judgment
Other PI/PD/WD (23) Real Property
Premises Liability (e.g.. slip Eminent Domain/Inverse Miscellaneous Civil Complaint
and fall) Condemnation (14)
Intentional Bodily Injury/PDAWD Wrongful Eviction (33) Other Complaint (not specified
above)
(eg., assault, vandalism) Other Real Property (e.g., quiet title) (26) Declaratory Relief Only
Intentional Infliction of
Emotional Distress
Writ of Possession of Reai Property
Mortgage Foreclosure Injunctive Relief Only (non-
harassment)
Negligent Infliction of Quiet Title Mechanics Lien
Emotional Distress Other Real Property (not eminent Other Commercial Complaint
Other PI/PD/WD domain, landlordfenant, or Case (non-tortnon-complex)
Non-PUPD/WD (Other) Tort foreclosure) Other Civil Complaint
Business Tort/Unfair Business Unlawful Detainer (non-tortnon-complex)
Practice (07) Commercial (31) Miscellaneous Civil Petition
Civil Rights (e.g., discrimination, Residential (32) Partnership and Corporate
false arrest) (not civil Drugs (38) (if the case involves illegal Govemance (21)
harassment) (08) drugs, check this item; otherwise,
wm Other Petition (not specified
he Defamation (e.g., slander, libel) report as Commercial or Residential) above) (43)
(13) Judicial Review Civil Harassment
D> Fraud (16) Asset Forfeiture (05) Workplace Violence
i Intellectual Property (19) Petition Re: Arbitration Award (11) Elder/Dependent Adult
Professional Negligence (25) ‘Writ of Mandate (02) Abuse
mw Legal Malpractice ‘Writ-Administrative Mandamus Election Contest
2 Other Professional Malpractice Writ-Mandamus on Limited Court Petition for Name Change
tm (not medical or legal) Case Matter Petition for Relief From Late
> Other Non-Pl/PD/WD Tort (35) ‘Writ-Other Limited Court Case laim
Employment Review ‘Other Civil Petition
Wrongful Termination (36) Other Judicial Review (39)
Other Employment (15) Review of Health Officer Order
Notice of Appeal-Labor
Commissioner Appeals
‘CN-010 {Rev. July 1, 2007], Page
2 of 2
CIVIL CASE COVER SHEET
a
ve
@ @
SHORT TITLE:
‘AHN vs. PETERS
CASE NUMBER
BC642353
CIVIL CASE COVER SHEET ADDENDUM AND
STATEMENT OF LOCATION
(CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION)
This form is required pursuant to Local Rule 2.3 in all new civil case filings in the Los Angeles Superior Court.
Step 1: After completing the Civil Case Cover Sheet (Judicial Council form CM-010), find the exact case type in
Column A that corresponds to the case type indicated in the Civil Case Cover Sheet.
Step 2: In Column B, check the box for the type of action that best describes the nature of the case.
Step 3: In Column C, circle the number which explains the reason for the court filing location you have
chosen.
Applicable Reasons for Choosing Court Filing Location (Column C)
1. Class actions must be filed in the Stanley Mosk Courthouse, Central District. 7. Location where petitioner resides.
2. Permissive filing in central district. 8. Location wherein defendant/respondent functions wholly.
3. Location where cause of action arose. 9. Location where one or more of the parties reside.
4. Mandatory personal injury filing in North District. 10. Location of Labor Commissioner Office.
11. Mandatory filing location (Hub Cases — unlawful detainer, limited
5. Location where performance required or defendant resides. non-collection, limited collection, or personal injury).
6. Location of property or permanently garaged vehicle.
A B c
Civil Case Cover Sheet ‘Type of Action Applicable Reasons -
Category No. (Check only one) See Step 3 Above
Auto (22) A7100 Motor Vehicle - Personal injury/Property Damage/Wrongful Death 1,4,11
2
ae ‘Uninsured Motorist (46) A7110 Personal Injury/Property Damage/Wrongful Death ~ Uninsured Motorist 1,4,11
6070 Asbestos Property Damage 4,14
Asbestos (04)
AT221 Asbestos - Personal Injury/Wrongful Death 411
Fr
ar
gs Product Liability (24) A7260 Product Liability (not asbestos or toxic/environmental) 1,4,11
A7210 Medical Malpractice - Physicians & Surgeons 1,4,11
Medical Malpractice (45) 14,11
A7240 Other Professional Health Care Malpractice
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no
~2 A7250 Premises Liability (e.g., slip and fall)
14,11
Other Personal
Injury Property A7230 Intentional Bodily Injury/Property Damage/Wrongful Death (e.g.
1,4,11
ea Damage Wrongful assault, vandalism, etc.)
n Death (23) A7270 Intentional Infliction of Emotional Distress
1,4,11
ee
i A7220 Other Personal Injury/Property Damage/Wrongful Death
1,4,11
BP
LACIV 109 (Rev 2/16) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.3
LASC Approved 03-04 AND STATEMENT OF LOCATION Page 1 of 4
>a
v4
®
‘SHORT TITLE: CASE NUMBER
AHN vs. PETERS.
B C Applicable
Civil Case Cover Sheet Type of Action Reasons - See Step 3
Category No. (Check only one) ove
Business Tort (07) A6029 Other Commercial/Business Tort (not fraud/breach of contract) 1,2,3
oe Civil Rights (08) A6005 Civil Rights/Discrimination 4,2,3
>a Defamation (13) A6010 Defamation (slander/libel) 1,2,3
es
22
Fraud (16) A6013 Fraud (no contract) 1,2,3
A6017 Legal Malpractice 1,2,3
Professional Negligence (25)
A6050 Other Professional Malpractice (not medical or legal) 1,2,3
Other (35) o A6025 Other Non-Personal Injury/Property Damage tort 1,2,3
Wrongful Termination (36) Oo A6037 Wrongful Termination 1,2,3
A6024 Other Employment Complaint Case 1,2,3
Other Employment (15) 10
A6109 Labor Commissioner Appeals
A6004 Breach of Rental/Lease Contract (not unlawful detainer or wrongful 2,5
eviction)
Breach of Contract/ Warranty
Contract/Warranty Breach -Seller Plaintiff (no fraud/negligence)
2,5
A6008
(not insurance) oO A6019 Negligent Breach of Contrac¥Warranty (no fraud) 1,2,5
1,2,5
A6028 Other Breach of Contract/Warranty (not fraud or negligence)
A6002 Collections Case-Seller Plaintiff 5,6, 11
Collections (09)
A6012 Other Promissory Note/Collections Case 5,11
A6034 Collections Case-Purchased Debt (Charged Off Consumer Debt 5,6, 14
Purchased on or after January 1, 2014)
Insurance Coverage (18) o A6015 Insurance Coverage (not complex) 1,2,5,8
A6009 Contractual Fraud 1,2,3,5
Other Contract (37) a A6031 Tortious Interference 1,2,3,5
A6027 Other Contract Dispute(not breach/insurance/fraudinegiigence) 1, 2,3, 8,9
Eminent Domain/inverse A7300 Eminent Domain/Condemnation Number of parcels, 2,6
‘Condemnation (14)
‘Wrongful Eviction (33) a A6023 Wrongful Eviction
Preview
e go 1 Baird A. Brown SBN: 56627 jo" a Supariogr ALE of LAW OFFICES OF BAIRD BROWN, P.C eorsa 2 ‘Ounty of Log An 3055 Wilshire Blvd, Suite 1200 Los Angeles, CA 90010 NOV 3.0 2015 Phone: (213) 487-8880 SI herri A. Carter, E: 4 || Fascimile: (213) 487-8884 utive Officer/Clerk Deputy 5 Attorney for Plaintiffs 6 7 DI\ Sutaune (& Ry iguana SUPERIOR COURT OF THE STATE OF CAL / COUNTY OF LOS ANGELES 10 11 MARGARET AHN and MICHELLE PAK. Case No. BC6 42853 12 Plaintiffs, Vv. 13 COMPLAINT TO QUIET TITLE AND STEVE PETERS, and all persons unknown. FOR RESULTING TRUST AND claiming any legal or equitable right, title, CONSTRUCTIVE TRUST 15 estate, lien, or interest in the property described in the complaint adverse to 16 plaintiffs’ title, or any cloud on plaintiffs’ title thereto; and DOES 1 through 100, inclusive. 17 18 Defendants. 19 20 Plaintiffs allege 21 THE PARTIES BPERB mo BEM ma 22 1 Plaintiffs MARGARET AHN and MICHELLE PAK at all relevant tines Hiv re 223 geoomSES Toy in the County of Los Angeles, in the State of California. Plaintiff Ahn is pladptieeP 3S daughter. 24 2 Defendant STEVE PETERS (“Peters” or defendant) at all relevant timeg is sided 8 fh 22 aca 5 ca = the County of Los Angeles, in the State of California. od > a el 26 3 The defendants herein named as “all persons unknown, claiming any legal.of-equitable right, title, estate, lien, or interest in the property described in the complaint adore to plaints title, 28 az bboD e096 3 1 COMPLAINT TO QUIET TITLE AND FOR RESULTING TRUST AND CONSTRUCTIVE TRUST ® @ s”). or any cloud on plaintiffs’ title thereto” are unknown to the plaintiffs (“Unknown Defendant These Unknown Defendants, and each of them, claim some right, title, estate, lien, or interest in the hereinafter-described property adverse to plaintiffs’ title; and their claims, and each of them, constitute a cloud on plaintiffs’ title to that property. 4 The true names and capacities, whether individual, corporate, associate or otherwise of defendants named herein as DOES 1 through 100 are unknown to plaintiffs who therefore sue these defendants by their fictitious names. Plaintiffs will ask leave to amend this complaint to show their true names and capacities when they have been ascertained. Plaintiffs are informed and believe and thereon allege that some of these fictitious named defendants claim some right, title, estate, lien, or 10 interest in the hereinafter-described property adverse to plaintiffs’ title and their claims, and each of 11 them, constitute a cloud on plaintiffs’ title to that property. 12 5 Plaintiffs are informed and believe and thereon allege that at all times herein mentioned defendants were acting on their own behalf and as agents or employees of each of the other 13 14 defendants, and the: acts described hereinafter were done in the course and scope of such agency or 15 employment, as well as on their own behalf. Further, defendants were authorized by defendant 16 principals in the doing and the manner of the acts alleged, and ratified said behavior. 17 FIRST CAUSE OF ACTION 18 QUIET TITLE 19 (Against All Defendants) 20 6 Plaintiffs reallege and incorporate by reference paragraphs | through 5 above. 1 21 The'real property which forms the subject matter of this litigation is located in the City 22 of Lomita, County of Los Angeles, State of California. It consists of a parcel of land with a single bo be 23 family residence situated thereon commonly known as 1916 Callison Street, Lomita, California 90717 om 24 (the “Property”). The legal description of the Property is as follows: bo 2 o 25 “Parcel 3 of Parcel Map No. 25014, in the City of Lomita, County of Los Angeles, 26 State of California, as per map recorded in Book 286, Pages 87 and 88 of Maps, in the 27 Office of the County Recorder of said County.” 28 2 COMPLAINT TO QUIET TITLE AND FOR RESULTING TRUST AND CONSTRUCTIVE TRUST e @ 8 Plaintiffs purchased the Property in 1999. Plaintiffs paid the down payment, but agreed to Peters’ name being included on the deed as a grantee based on his representation to plaintiffs that he would pay the Property’s mortgage payments, taxes, insurance, utilities, maintenance expenses and home improvement expenses. 9 Escrow closed in October 1999 and a grant deed was executed and recorded. Pursuant thereto the Property seller granted title to the Property to Peters and plaintiff Ahn as joint tenants. 10. In 2001, Peters executed and recorded a grant deed pursuant to which he purported to grant title to the Property to his sister, Elena Prioteasa (“Prioteasa”), and plaintiff Ahn as joint tenants. 11. In 2002, Prioteasa and plaintiff Ahn granted title to the Property to Prioteasa as to an 10 undivided 50% interest and to plaintiffs as joint tenants as to an undivided 50% interest. 11 12. Subsequently, in 2008 plaintiff Pak quitclaimed her interest in the Property to plaintiff 12 Ahn, and in July 2016, plaintiff Ahn quitclaimed to plaintiff Pak an undivided half interest in her 13 interest in the Property. 14 13. In October 2016, Prioteasa caused a deed to be recorded that purported to grant a 50% 15 interest in the Property to Peters. 16 14. Neither Peters nor Prioteasa ever lived in the Property except for Peters’ living there 17 for approximately one year in 1999-2000. Plaintiffs and their family members otherwise have been the 18 only residents of the Property since plaintiffs purchased it in 1999. 19 15. Neither Peters nor Prioteasa ever made any mortgage payments on the Property. 20 Plaintiffs have made all of the mortgage payments. 21 16. Neither Peters nor Prioteasa ever made any tax payments on the Property. Plaintiffs 22 have made all of the tax payments. 223 17. Neither Peters nor Prioteasa ever made any insurance payments on the Property. > 24 Plaintiffs have made all of the insurance payments. 25 18. Neither Peters nor Prioteasa ever made any payments for utilities provided to the m 26 Property. Plaintiffs have made all of the utility payments. 27 19. Neither Peters nor Prioteasa ever made any payments for maintenance of the Property. 28 Plaintiffs have made all of the maintenance payments. 3 COMPLAINT TO QUIET TITLE AND FOR RESULTING TRUST AND CONSTRUCTIVE TRUST e @ 20. Plaintiffs have spent more than $160,000 improving and remodeling the Property. Neither Peters nor Prioteasa made any payments therefor. 21. The deed transfers to and from Peters and Prioteasa are void. Neither Peters nor Prioteasa had or has valid title to the Property. 22. Plaintiffs seek to quiet title against the claims of all defendants to the Property. The claims are without any right whatever, and defendants have no right, title, estate, lien, or interest whatever in the Property or any part thereof. 23. Plaintiffs seek to quiet title as of the date this complaint is filed with the court. SECOND CAUSE OF ACTION 10 RESULTING TRUST 11 (Against All Defendants) 12 24, Plaintiffs reallege and incorporate by reference paragraphs 1 through 23 above. 13 25. Plaintiffs provided all of the consideration for the purchase of the Property and Peters, 14 despite his promises, provided nothing. A trust thereby resulted in favor of plaintiffs as to defendants’ 15 claimed interest in the Property. 16 26. Plaintiffs have suffered consequential damages by virtue of defendants’ actions in an 17 amount to be established according to proof. 18 27. In doing the foregoing acts, defendants acted in a willful, wanton, malicious, 19 oppressive, and fraudulent manner toward plaintiffs, and in conscious disregard of plaintiffs’ known 20 rights, with the intention of benefiting themselves financially, and with the intent of, or a conscious 21 disregard of the probability of, causing plaintiffs injury. In so acting, defendants intended to and did 22 vex, annoy, injure, and harass plaintiffs, and consciously disregarded its rights, so as to warrant the ne 223 assessment of exemplary and punitive damages against defendants in a sum to be established @ 24 according to proof. bd I i= 25 p> 26 i 27 I 28 HW 4 COMPLAINT TO QUIET TITLE AND FOR RESULTING TRUST AND CONSTRUCTIVE TRUST @ THIRD CAUSE OF ACTION CONSTRUCTIVE TRUST (Against All Defendants) 28 Plaintiffs reallege and incorporate by reference paragraphs 1 through 27 above. 29. Plaintiffs provided all of the consideration for the purchase, maintenance and improvement of the Property, and Peters, despite his promises, provided nothing. A constructive trust thereby arose in favor of plaintiffs as to defendants’ claimed interest in the Property. 30. Plaintiffs have suffered consequential damages by virtue of defendants’ actions in an amount to be established according to proof. 10 31. In doing the foregoing acts, defendants acted in a willful, wanton, malicious, 11 oppressive, and fraudulent manner toward plaintiffs, and in conscious disregard of plaintiffs’ known 12 rights, with the intention of benefiting themselves financially, and with the intent of, or a conscious 13 disregard of the probability of, causing plaintiffs injury. In so acting, defendants intended to and did 14 vex, annoy, injure, and harass plaintiffs, and consciously disregarded its rights, so as to warrant the 15 assessment of exemplary and punitive damages against defendants in a sum to be established 16 according to proof. 17 18 WHEREFORE, plaintiffs pray for judgment as follows: 19 1 For a judgment declaring that plaintiffs are, the owners in fee simple of the Property 20 and that none of the defendants herein has any estate, right, title, interest or lien in and 21 to the Property, that title of plaintiffs in and to the Property be quieted against any and 22 all of the defendants, and that each and all of the defendants be and are forever ioe ine 23 restrained and enjoined from asserting any estate, right, title, interest or lien in and to 24 the Property adverse to that of plaintiffs; bee 9= 25 For imposition of a resulting trust on defendants’ claimed interest in the Property; 26 For imposition of a constructive trust on defendants’ claimed interest in the Property; 27 For consequential damages according to proof; 28 For exemplary and punitive damages according to proof; 5 COMPLAINT TO QUIET TITLE AND FOR RESULTING TRUST AND CONSTRUCTIVE TRUST @ For attorney fees to the extent authorized by law; For costs of suit incurred in this action; and For such other and further relief as the Court deems just and proper. 5 || DATED: November 30, 2016 LAW OFFICES OF BAIRD A. BROWN A Professional Corporation Baird A. Brown Attorneys for Plaintiffs 10 11 12 13 14 15 16 7 18 19 20 21 22 in, 923 24 be 25 o m 26 27 28 6 COMPLAINT TO QUIET TITLE AND FOR RESULTING TRUST AND CONSTRUCTIVE TRUST e 5 VERIFICATION STATE OF CALIFORNIA COUNTY OF LOS ANGELES Ihave read the foregoing document described as COMPLAINT TO QUIET TITLE AND FOR RESULTING TRUST AND CONSTRUCTIVE TRUST and know its contents. Iam a party to this action. The matters stated in the foregoing document are true of my own knowledge, except as to those matters which are stated on information and belief, and as to those matters, I believe them to be true. I declare under penalty of perjury under the laws of the State of California that the foregoing is 10 true and correct. 1 Executed on November 30, 2016 at Los Angeles, California. 12 13 14 15 16 17 18 19 20 21 22 223 24 325 26 27 28 1 COMPLAINT TO QUIET TITLE AND FOR RESULTING TRUST AND CONSTRUCTIVE TRUST oo . @ CM-01 ATTORNEY OR PARTY WITHOUT egipaner (Name, State Bar number, and aaa) FOR COURT USE ONLY | Baird Brown, SBN 56627 LAW OFFICES OF BAIRD BROWN, P.C. 3055 Wilshire Blvd, Suite 1200 Los Angeles, CA 9001 raxno: 213-487-8884 “8 ‘Ounty erikrli,it of Logot CGFaltornia reveponeno: 213-487-8880 ATTORNEY FOR (Name): Plaintiffs, Margaret Ahn and Michelle Pak SUPERIOR COURTOF CALIFORNIA, COUNTY OF Los Angeles NOY 3.0 29 street aporess: |] ] North Hill Street Sherri R, Carter, MAILING ADDRESS: By, Exeputive OticenCy eles 90012 Aaalnad Broctsy bi istrict cry anozip cove: Los Any Depi erancu awe: Central CASE NAME: AHN vs. PETERS ‘CASE NUMBEI CIVIL CASE COVER SHEET BC 642353 Complex Case Designation Unlimited Limited (Amount (Amount [5 counter (J) Joinder JOGE: demanded demanded is Filed with first appearance by defendant exceeds $25,000) $25,000 or less) (Cal. Rules of Court, rule 3.402) DEPT: Items 1-6 below must be completed (see instructions on page 2). 4. Check one box below for the case type that best describes this case: Auto Tort Contract Provisionally Complex Civil Litigation Breach of contract/warranty (06) (Cal. Rules of Court, rules 3.400-3.403) Auto (22) Uninsured motorist (46) CI Rule 3.740 collections (09) [7 antitusttrade regulation (03) Other PYPDIWD (Personal Injury/Property CJ Other collections (09) Construction defect (10) Damage/Wrongful Death) Tort CI Insurance coverage (18) [J Mass tort (40) (J Asbestos (04) C] Other contract (37) Securities litigation (28) Product liability (24) Real Property Environmental/Toxic tort (30) .dical malpractice (45) Eminent domain/Inverse Insurance coverage claims arising from the CJ other pveowo (23) condemnation (14) above listed provisionally complex case Non-Pi/PDIWD (Other) Tort (1 weongtut eviction (33) types (4 Other real property (26) Enforcement of Judgment Business tort/unfair business practice (07) Civil rights (08) Untawful Detainer Enforcement of judgment (20) Defamation (13) Commercial (31) Miscellaneous Civil Complaint Fraud (16) Residential (32) RICO (27) intellectual property (19) Oo Drugs (38) Other complaint (not specified above) (42) Professional negligence (25) Judicial Review Miscellaneous Civil Petition Other non-PI/PD/WD tort (35) Asset forfeiture (05) Partnership and corporate governance (21) loyment cj Petition re: arbitration award (11) [] other petition (not specified above) (43) Wrongful termination (36) [1 writ of mandate (02) Ct) Other employment (15) [1 other judicial review (39) This case L_Jis [Tis not complex under rule 3.400 of the California Rules of Court. If the case is complex, mark the factors requiring exceptional judicial management: a oo Large number of separately represented parties d. oO Large number of witnesses b. CI Extensive motion practice raising difficult or novel e. CO Coordination with related actions pending in one or more courts issues that will be time-consuming to resolve in other counties, states, or countries, or in a federal court [71 substantial amount of documentary evidence f. OO Substantial postjudgment judicial supervision 3. Remedies sought (check all that apply): a. Wy monetary. Ww nonmonetary; declaratory or injunctive relief punitive 4 Number of causes of acti (specify): 3 5. This case L_lis is not a class action suit. 6. If there are any known related cases, file and serve a notice of related case. (You may use form CM-015.) ~Date: “Baird (TYPE OR PRINT NAME) > (SIGNATURE OF PARTY OR ATTORNEY FOR PARTY) NOTICE . ¢ Plaintiff must file this cover sheet with the first paper filed in the action or proceeding (except small claims cases or cases filed oe under the Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.) Failure to file may result in sanctions. © File this cover sheet in addition to any cover sheet required by local court rule. © If this case is complex under rule 3.400 et seq. of the California Rules of Court, you must serve a copy of this cover sheet on alll other parties to the action or proceeding. © Unless this is a collections case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes only. 1of2| Form Adopted for Mandatory Use CIVIL CASE COVER SHEET ‘Cal, Rulesof Court, rules 2.30, 3.220, 3.400-3.403, 3.740, Judicial Council of Califomia Cal, Standards of Judicial Administration, std. 3.10 ‘CM-010 [Rev. July 1, 2007) wonw.courtinfo.ca.gov we @ ® CM-010 INSTRUCTIONS ON HOW TO.COMPLETE THE COVER SHEET To Plaintiffs and Others Filing First Papers. If you are filing a first paper (for example, a complaint) in a civil case, you must complete and file, along with your first paper, the Civil Case Cover Sheet contained on page 1. This information will be used to compile statistics about the types and numbers of cases filed. You must complete items 1 through 6 on the sheet. In item 1, you must check ‘one box for the case type that best describes the case. If the case fits both a general and a more specific type of case listed in item 1, check the more specific one. If the case has multiple causes of action, check the box that best indicates the primary cause of action. To assist you in completing the sheet, examples of the cases that belong under each case type in item 1 are provided below. A cover sheet must be filed only with your initial paper. Failure to file a cover sheet with the first paper filed in a civil case may subject a party, its counsel, or both to sanctions under rules 2.30 and 3.220 of the California Rules of Court. To Parties in Rule 3.740 Collections Cases. A "collections case" under rule 3.740 is defined as an action for recovery of money owed in a sum stated to be certain that is not more than $25,000, exclusive of interest and attorney's fees, arising from a transaction in which property, services, or money was acquired on credit. A collections case does not include an action seeking the following: (1) tort damages, (2) punitive damages, (3) recovery of real property, (4) recovery of personal property, or (5) a prejudgment writ of attachment. The identification of a case as a rule 3.740 collections case on this form means that it will be exempt from the general time-for-service requirements and case management rules, unless a defendant files a responsive pleading. A rule 3.740 collections case will be subject to the requirements for service and obtaining a judgment in rule 3.740. To Parties in Complex Cases. In complex cases only, parties must also use the Civil Case Cover Sheet to designate whether the case is complex. If a plaintiff believes the case is complex under rule 3.400 of the California Rules of Court, this must be indicated by completing the appropriate boxes in items 1 and 2. If a plaintiff designates a case as complex, the cover sheet must be served with the complaint on all parties to the action. A defendant may file and serve no later than the time of its first appearance a joinder in the plaintiff's designation, a counter-designation that the case is not complex, or, if the plaintiff has made no designation, a designation that the case is complex. CASE TYPES AND EXAMPLES Auto Tort Contract Provisionally Complex Civil Litigation (Cal. Auto (22)}-Personal Injury/Property Breach of Contract/Warranty (06) Rules of Court Rules 3.400-3.403) Damage/Wrongful Death Breach of Rental/Lease Antitrust/Trade Regulation (03) Uninsured Motorist (46) (if the Contract (not unlawful detainer Construction Defect (10) Claims Involving Mass Tort (40) case involves an uninsured or wrongful eviction} ‘motorist claim subject to Contract/Warranty Breach-Seller Securities Litigation (28) arbitration, check this item Plaintiff (not fraud or negligence) Environmental/T oxic Tort (30) instead of Auto) Negligent Breach of Contract/ Insurance Coverage Claims Other PIPDIWD (Personal Injury/ Warrant (arising from provisionally complex Property Damage/Wrongful Death) Other Breach of Contract/Warranty case type listed above) (41) ‘ort Collections (e.g., money owed, open Enforcement of Judgment Asbestos (04) book accounts) (09) Enforcement of Judgment (20) Asbestos Property Damage Collection Case-Seller Plaintiff Abstract of Judgment (Out of Asbestos Personal Injury! Other Promissory Note/Collections “ounty) Wrongful Death Confession of Judgment (non- Product Liability (not asbestos or Insurance Coverage (not provisionally domestic relations) toxic/environmental) (24) complex) (18) Sister State Judgment Medical Malpractice (45) Auto Subrogation Administrative Agency Award Medical Malpractice— Other Coverage (not unpaid taxes) Physicians & Surgeons Other Contract (37) Petition/Certification of Entry of Judgment on Unpaid Taxes Other Professional Health Care Contractual Fraud Malpractice Other Contract Dispute Other Enforcement of Judgment Other PI/PD/WD (23) Real Property Premises Liability (e.g.. slip Eminent Domain/Inverse Miscellaneous Civil Complaint and fall) Condemnation (14) Intentional Bodily Injury/PDAWD Wrongful Eviction (33) Other Complaint (not specified above) (eg., assault, vandalism) Other Real Property (e.g., quiet title) (26) Declaratory Relief Only Intentional Infliction of Emotional Distress Writ of Possession of Reai Property Mortgage Foreclosure Injunctive Relief Only (non- harassment) Negligent Infliction of Quiet Title Mechanics Lien Emotional Distress Other Real Property (not eminent Other Commercial Complaint Other PI/PD/WD domain, landlordfenant, or Case (non-tortnon-complex) Non-PUPD/WD (Other) Tort foreclosure) Other Civil Complaint Business Tort/Unfair Business Unlawful Detainer (non-tortnon-complex) Practice (07) Commercial (31) Miscellaneous Civil Petition Civil Rights (e.g., discrimination, Residential (32) Partnership and Corporate false arrest) (not civil Drugs (38) (if the case involves illegal Govemance (21) harassment) (08) drugs, check this item; otherwise, wm Other Petition (not specified he Defamation (e.g., slander, libel) report as Commercial or Residential) above) (43) (13) Judicial Review Civil Harassment D> Fraud (16) Asset Forfeiture (05) Workplace Violence i Intellectual Property (19) Petition Re: Arbitration Award (11) Elder/Dependent Adult Professional Negligence (25) ‘Writ of Mandate (02) Abuse mw Legal Malpractice ‘Writ-Administrative Mandamus Election Contest 2 Other Professional Malpractice Writ-Mandamus on Limited Court Petition for Name Change tm (not medical or legal) Case Matter Petition for Relief From Late > Other Non-Pl/PD/WD Tort (35) ‘Writ-Other Limited Court Case laim Employment Review ‘Other Civil Petition Wrongful Termination (36) Other Judicial Review (39) Other Employment (15) Review of Health Officer Order Notice of Appeal-Labor Commissioner Appeals ‘CN-010 {Rev. July 1, 2007], Page 2 of 2 CIVIL CASE COVER SHEET a ve @ @ SHORT TITLE: ‘AHN vs. PETERS CASE NUMBER BC642353 CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION (CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION) This form is required pursuant to Local Rule 2.3 in all new civil case filings in the Los Angeles Superior Court. Step 1: After completing the Civil Case Cover Sheet (Judicial Council form CM-010), find the exact case type in Column A that corresponds to the case type indicated in the Civil Case Cover Sheet. Step 2: In Column B, check the box for the type of action that best describes the nature of the case. Step 3: In Column C, circle the number which explains the reason for the court filing location you have chosen. Applicable Reasons for Choosing Court Filing Location (Column C) 1. Class actions must be filed in the Stanley Mosk Courthouse, Central District. 7. Location where petitioner resides. 2. Permissive filing in central district. 8. Location wherein defendant/respondent functions wholly. 3. Location where cause of action arose. 9. Location where one or more of the parties reside. 4. Mandatory personal injury filing in North District. 10. Location of Labor Commissioner Office. 11. Mandatory filing location (Hub Cases — unlawful detainer, limited 5. Location where performance required or defendant resides. non-collection, limited collection, or personal injury). 6. Location of property or permanently garaged vehicle. A B c Civil Case Cover Sheet ‘Type of Action Applicable Reasons - Category No. (Check only one) See Step 3 Above Auto (22) A7100 Motor Vehicle - Personal injury/Property Damage/Wrongful Death 1,4,11 2 ae ‘Uninsured Motorist (46) A7110 Personal Injury/Property Damage/Wrongful Death ~ Uninsured Motorist 1,4,11 6070 Asbestos Property Damage 4,14 Asbestos (04) AT221 Asbestos - Personal Injury/Wrongful Death 411 Fr ar gs Product Liability (24) A7260 Product Liability (not asbestos or toxic/environmental) 1,4,11 A7210 Medical Malpractice - Physicians & Surgeons 1,4,11 Medical Malpractice (45) 14,11 A7240 Other Professional Health Care Malpractice ~e no ~2 A7250 Premises Liability (e.g., slip and fall) 14,11 Other Personal Injury Property A7230 Intentional Bodily Injury/Property Damage/Wrongful Death (e.g. 1,4,11 ea Damage Wrongful assault, vandalism, etc.) n Death (23) A7270 Intentional Infliction of Emotional Distress 1,4,11 ee i A7220 Other Personal Injury/Property Damage/Wrongful Death 1,4,11 BP LACIV 109 (Rev 2/16) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.3 LASC Approved 03-04 AND STATEMENT OF LOCATION Page 1 of 4 >a v4 ® ‘SHORT TITLE: CASE NUMBER AHN vs. PETERS. B C Applicable Civil Case Cover Sheet Type of Action Reasons - See Step 3 Category No. (Check only one) ove Business Tort (07) A6029 Other Commercial/Business Tort (not fraud/breach of contract) 1,2,3 oe Civil Rights (08) A6005 Civil Rights/Discrimination 4,2,3 >a Defamation (13) A6010 Defamation (slander/libel) 1,2,3 es 22 Fraud (16) A6013 Fraud (no contract) 1,2,3 A6017 Legal Malpractice 1,2,3 Professional Negligence (25) A6050 Other Professional Malpractice (not medical or legal) 1,2,3 Other (35) o A6025 Other Non-Personal Injury/Property Damage tort 1,2,3 Wrongful Termination (36) Oo A6037 Wrongful Termination 1,2,3 A6024 Other Employment Complaint Case 1,2,3 Other Employment (15) 10 A6109 Labor Commissioner Appeals A6004 Breach of Rental/Lease Contract (not unlawful detainer or wrongful 2,5 eviction) Breach of Contract/ Warranty Contract/Warranty Breach -Seller Plaintiff (no fraud/negligence) 2,5 A6008 (not insurance) oO A6019 Negligent Breach of Contrac¥Warranty (no fraud) 1,2,5 1,2,5 A6028 Other Breach of Contract/Warranty (not fraud or negligence) A6002 Collections Case-Seller Plaintiff 5,6, 11 Collections (09) A6012 Other Promissory Note/Collections Case 5,11 A6034 Collections Case-Purchased Debt (Charged Off Consumer Debt 5,6, 14 Purchased on or after January 1, 2014) Insurance Coverage (18) o A6015 Insurance Coverage (not complex) 1,2,5,8 A6009 Contractual Fraud 1,2,3,5 Other Contract (37) a A6031 Tortious Interference 1,2,3,5 A6027 Other Contract Dispute(not breach/insurance/fraudinegiigence) 1, 2,3, 8,9 Eminent Domain/inverse A7300 Eminent Domain/Condemnation Number of parcels, 2,6 ‘Condemnation (14) ‘Wrongful Eviction (33) a A6023 Wrongful Eviction