On April 06, 2021 a
Complaint,Petition
was filed
involving a dispute between
Gomez, Umberto,
and
7-Eleven, Inc.,
Bhavnani, Dilip,
Does 1 Through 50,
Karma Dali Development, Llc,
for Other PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
Kim (SBN 272184)
Richard F i L E ED
SUPERIOR COURT 0F
LAW OFFICES 0F RICHARD KIM, PC CALIForiNn/x
COUNTY 0F SAN BERNARD"
SAN BERNARmNo 013mm
6131 Orangethorpe Ave., Suite 370
Buena Park, CA 90620
APR 0 5 2021
Telephone: (714) 276-1122
Facsimile: (714) 276-1120
BY
Rkim@Richkimlaw.com (H
ANA! coma MIREi? DEF Ln“?
\OOONQKII-hUJN Attorneys for Plaintiffs,
UMBERTO GOMEZ
SUPERIOR COURT OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
10
11
12
l3
UMBERTO GOMEZ, an Individual,
VS.
Plaintiff, W
CaseNo.
1.
C'VSB
COMPLAINT FOR
DAMAGES FOR:
NEGLIGENCE
2109 B 50
2. PREMISES LIABILITY
14 DILIPBHAVNANI, an individual; KARMA
DALI DEVELOPMENT, LLC, a Delaware
15 Corporation; 7-ELEVEN, INC., a Texas
16
Corporation; and DOES 1 through 50,
inclusive,
17
Defendants.
.
f
M”; .
fl“!é:
13'7"“ V733 3‘: 4;?
.3
18
'9'
I
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21
22
23
24
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28
COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL
1
Plaintiff UMBERTO GOMEZ, hereby alleges and states as follows:
PARTIES
1. Plaintiff UMBERTO GOMEZ (hereinafter, “Mr. Gomez” or “P1aintiff’) was at all
times relevant to this Complaint was a resident of California.
\OOOQQU‘IAUJNH
2. At times relevant, defendant DILIP BHAVNANI (hereafter “Bhavnani”) is and
was an individual residing in California. At times relevant, Bhavnani was a franchisee and
operator of a 7-Eleven store located at 16701 Arrow Boulevard in Fontana, California in the
county of San Bernardino.
3. At all relevant times herein, defendant KARMA DALI DEVELOPMENT, LLC
(hereinafter, “Defendant Karma”) is, and at all times mentioned in this complaint, was authorized
to operate by the State of California and authorized to do business in the County of San
Bernardino. Plaintiff believes and thereon alleges that defendant Karma has a principal place of
business through its agent for service located at 522 Wilshire Boulevard, Ste G Santa Monica CA
90401in the County of Los Angeles.
NNNNMNNN—q‘p—Ar—tr—Ar—cr—dwn—tu—AH
gNQMbWNHOQWNONMAWNi—‘O
4. At all relevant times herein defendant 7-ELEVEN, INC. (hereinafter, “7—Eleven”)
w isand was a Texas Corporation. authorized to do business and doing. business in the County of
San Bemardino, State of California.
5. Plaintiff is ignorant of the true names and capacities, whether individual,
corporate, associate, or otherwise, of defendant does 1 through 50. Such doe defendants are sued
pursuant to the provisions of C.C.P. §474. Plaintiff is informed, believes and thereon alleges that
each doe defendant was in some manner responsible, participated in, or contributed to the
matters and things of which plaintiff complains herein, and in some fashion, has legal
responsibility therefor. When the exact nature and identity of such doe defendants are
COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL
2
Document Filed Date
April 06, 2021
Case Filing Date
April 06, 2021
Category
Other PI/PD/WD Unlimited
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Kim (SBN 272184) Richard F i L E ED SUPERIOR COURT 0F LAW OFFICES 0F RICHARD KIM, PC CALIForiNn/x COUNTY 0F SAN BERNARD" SAN BERNARmNo 013mm 6131 Orangethorpe Ave., Suite 370 Buena Park, CA 90620 APR 0 5 2021 Telephone: (714) 276-1122 Facsimile: (714) 276-1120 BY Rkim@Richkimlaw.com (H ANA! coma MIREi? DEF Ln“? \OOONQKII-hUJN Attorneys for Plaintiffs, UMBERTO GOMEZ SUPERIOR COURT OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO 10 11 12 l3 UMBERTO GOMEZ, an Individual, VS. Plaintiff, W CaseNo. 1. C'VSB COMPLAINT FOR DAMAGES FOR: NEGLIGENCE 2109 B 50 2. PREMISES LIABILITY 14 DILIPBHAVNANI, an individual; KARMA DALI DEVELOPMENT, LLC, a Delaware 15 Corporation; 7-ELEVEN, INC., a Texas 16 Corporation; and DOES 1 through 50, inclusive, 17 Defendants. . f M”; . fl“!é: 13'7"“ V733 3‘: 4;? .3 18 '9' I 20 21 22 23 24 25 26 27 28 COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL 1 Plaintiff UMBERTO GOMEZ, hereby alleges and states as follows: PARTIES 1. Plaintiff UMBERTO GOMEZ (hereinafter, “Mr. Gomez” or “P1aintiff’) was at all times relevant to this Complaint was a resident of California. \OOOQQU‘IAUJNH 2. At times relevant, defendant DILIP BHAVNANI (hereafter “Bhavnani”) is and was an individual residing in California. At times relevant, Bhavnani was a franchisee and operator of a 7-Eleven store located at 16701 Arrow Boulevard in Fontana, California in the county of San Bernardino. 3. At all relevant times herein, defendant KARMA DALI DEVELOPMENT, LLC (hereinafter, “Defendant Karma”) is, and at all times mentioned in this complaint, was authorized to operate by the State of California and authorized to do business in the County of San Bernardino. Plaintiff believes and thereon alleges that defendant Karma has a principal place of business through its agent for service located at 522 Wilshire Boulevard, Ste G Santa Monica CA 90401in the County of Los Angeles. NNNNMNNN—q‘p—Ar—tr—Ar—cr—dwn—tu—AH gNQMbWNHOQWNONMAWNi—‘O 4. At all relevant times herein defendant 7-ELEVEN, INC. (hereinafter, “7—Eleven”) w isand was a Texas Corporation. authorized to do business and doing. business in the County of San Bemardino, State of California. 5. Plaintiff is ignorant of the true names and capacities, whether individual, corporate, associate, or otherwise, of defendant does 1 through 50. Such doe defendants are sued pursuant to the provisions of C.C.P. §474. Plaintiff is informed, believes and thereon alleges that each doe defendant was in some manner responsible, participated in, or contributed to the matters and things of which plaintiff complains herein, and in some fashion, has legal responsibility therefor. When the exact nature and identity of such doe defendants are COMPLAINT FOR DAMAGES; DEMAND FOR JURY TRIAL 2