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Electronically Filed by Superior Court of California, County of Orange, 02/01/2022 11:36:23 AM.
30-2022-01243334-CU-PA-CJ C - ROA #2 - DAVID H. YAMASAKI, Clerk of the Court By Katie Trent, Deputy Clerk.
PLD-PI-001
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Daniel Petrov (SBN 254316) Christine Palcisko (SBN 297575)
Petrov Law Firm
380 S. Melrose Dr. Suite 201
Vista, CA 92081
TeLePHone No: 619.344.0360 FAX NO. (Optional): 619.377.7668
E-MAIL ADDRESS (Optiona): Christie@petrovlawfirm.com
ATTORNEY FOR (Name): Plaintiff Dawn Robbins
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Orange
street appress: 700 Civic Center Drive West
maine aopress: 700 Civic Center Drive West
city AnD zip cove: Santa Ana, CA 92701
BrancH Name: Central Justice Center
PLAINTIFF: Dawn Robbins
DEFENDANT: Aidan Flynn, Daniel Flynn
&] poes1To 10
COMPLAINT—Personal Injury, Property Damage, Wrongful Death
(0 AMENDED (Number):
Type (check all that apply):
EK MOTOR VEHICLE (1 OTHER (specify):
KX] Property Damage C1 Wrongful Death
KX] Personal Injury [1 Other Damages (specify):
Jurisdiction (check all that apply): CASE NUMBER:
ACTION IS A LIMITED CIVIL CASE
Amount demanded [1 does not exceed $10,000 30-2022-01243334-CU-PA-CIC
[1 exceeds $10,000, but does not exceed $25,000
X ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000)
Oo ACTION IS RECLASSIFIED by this amended complaint Assigned for All Purposes
[1 from limited to unlimited
Judge DerekW. Hunt
(1 from unlimited to limited
Plaintiff (name or names): Dawn Robbins
alleges causes of action against defendant (name or names): Aidan Flynn, Daniel Flynn and DOES 1 to 10
This pleading, including attachments and exhibits, consists of the following number of pages: 5
Each plaintiff named above is a competent adult
a. 1 except plaintiff (name):
a) O a corporation qualified to do business in California
2 O an unincorporated entity (describe):
3) O a public entity (describe):
4) O a minor 0 anadult
(a) [11 for whom a guardian or conservator of the estate or a guardian ad litem has been appointed
(b) [1 other (specify):
(5) [11 other (specify):
b. Oo except plaintiff (name):
a) O a corporation qualified to do business in California
2 O an unincorporated entity (describe):
3) O a public entity (describe):
4) O a minor 0 anadult
(a) [11 for whom a guardian or conservator of the estate or a guardian ad litem has been appointed
(b) [1 other (specify):
6 O other (specify):
[1 Information about additional plaintiffs who are not competent adults is shown in Attachment 3.
Page 1 of 3
Form Approved for Optional Use COMPLAINT—Personal Injury, Property ‘Code of GWvil Procedure, § 425.12
Judicial Council of California www.courtinfo.ca.gov
PLD-PI-001 (Rev. January 1, 2007] Damage, Wrongful Death ‘American LegalNet, Inc.
www.FormsWorkflow.com
PLD-PI-001
SHORT TITLE: CASE NUMBER:
Robbins v. Flynn
4 DO Plaintiff (name):
is doing business under the fictitious name (specify):
and has complied with the fictitious business name laws.
5. Each defendant named above is a natural person
a. 1 except defendant (name): c. C1 except defendant (name):
(1) ($a business organization, form unknown (1) abusiness organization, form unknown
(2) a corporation (2) [1 acorporation
(3) Oo an unincorporated entity (describe): (3) [1 an unincorporated entity (describe):
(4) Oo a public entity (describe): (4) [1] apublic entity (describe):
(5) Oo other (specify): (5) [] other (specify):
oO except defendant (name): Oo except defendant (name):
(1) Oo a business organization, form unknown (1) Oo a business organization, form unknown
(2) Oo a corporation (2) Oo a corporation
(3) Oo an unincorporated entity (describe): (3) ou an unincorporated entity (describe):
(4) Oo a public entity (describe): 4 O a public entity (describe):
(5) Oo other (specify): 6) O other (specify):
oO 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): 1 to 10 were the agents or employees of other
named defendants and acted within the scope of that agency or employment.
b. KX) Doe defendants (specify Doe numbers): 1 to 10 are persons whose capacities are unknown to
plaintiff.
(1 Defendants who are joined under Code of Civil Procedure section 382 are (names):
8 This court is the proper court because
a KK) at least one defendant now resides in its jurisdictional area.
b. the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area.
c. KX injury to person or damage to personal property occurred in its jurisdictional area.
d. Ls other (specify):
9. C1 Plaintiff is required to comply with a claims statute, and
a TZ has complied with applicable claims statutes, or
b. CZ is excused from complying because (specify):
PLD-PI-001 [Rev. January 1, 2007] COMPLAINT—Personal Injury, Property Page 2 of 3
Damage, Wrongful Death
‘American LegalNet, Inc.
‘wwww.FormsWorkflow.com
PLD-PI-001
SHORT TITLE: CASE NUMBER.
Robbins v. Flynn
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
General Negligence
Intentional Tort
Products Liability
Premises Liability
Other (specify):
1 Plaintiff has suffered
wage loss
loss of use of property
hospital and medical expenses
general damage
property damage
loss of earning capacity
other damage (specify):
12. (1 The damages claimed for wrongful death and the relationships of plaintiff to the deceased are
a. 1 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) KX] compensatory damages
(2) [J punitive damages
The amount of damages is (in cases for personal injury or wrongful death, you must check (1)):
(1) KX] according to proof
(2) (1 in the amount of: $
15. (1 The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers):
Date: 2/1/2022
Christine Palcisko, Esq. SBN 297575
(TYPE OR PRINT NAME)
(pn fal_~
» ~T (SIGNATURE OF PLAINTIFF OR ATTORNEY)
PLD-PI-001 (Rev. January 1, 2007] COMPLAINT—Personal Injury, Property Page 3 of 3
Damage, Wrongful Death
‘American LegalNet, Inc.
‘wwww.FormsWorkflow.com
PLD-PI-001(2)
SHORT TITLE: CASE NUMBER:
Robbins v. Flynn
CAUSE OF ACTION—General Negligence Page 4
(number)
ATTACHMENT TO &X Complaint [] Cross - Complaint
(Use a separate cause of action form for each cause of action.)
GN-1. Plaintiff (name): Dawn Robbins
alleges that defendant (name): Aidan Flynn, Daniel Flynn
KX] Does 1 to 10
was the legal (proximate) cause of damages to plaintiff. By the following acts or omissions to act, defendant
negligently caused the damage to plaintiff
on (date): 10/21/2020
at (place): San Clemente, CA
(description of reasons for liability):
Defendant rear-ended Plaintiff's vehicle
Page 1 of 1
Form Approved for Optional Use Code of Civil Procedure 425.12
Judicial Council of California CAUSE OF ACTION—General Negligence ‘www.courtinfo.ca.gov
PLD-PI-001(2) (Rev. January 1, 2007]
‘American LegalNet, Inc.
www. FormsWorkflow.com
PLD-PI-001(1)
SHORT TITLE: CASE NUMBER:
Robbins v. Flynn
CAUSE OF ACTION—Motor Vehicle
(number)
ATTACHMENT TO [XJ — Complaint Oo Cross - Complaint
(Use a separate cause of action form for each cause of action.)
Plaintiff (name): Dawn Robbins
MV- 1. Plaintiff alleges the acts of defendants were negligent; the acts were the legal (proximate) cause of injuries
and damages to plaintiff; the acts occurred
on (date): 10/21/2020
at (place): San Clemente, CA
MV- 2. DEFENDANTS,
a. The defendants who operated a motor vehicle are (names): Aidan Flynn
X Does 1 to 10
The defendants who employed the persons who operated a motor vehicle in the course of their employment
are (names):
XI Does 1 to 10
The defendants who owned the motor vehicle which was operated with their permission are (names):
X Does 1 to 10
The defendants who entrusted the motor vehicle are (names):
x Does 1 to 10
The defendants who were the agents and employees of the other defendants and acted within the scope
Of the agency were (names):
KX] Does 1 to 10
The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are
Oo listed in Attachment MV-2f Cas follows:
Does to Page5
Paget of 1
Form Approved for Optional Use CAUSE OF ACTION—Motor Vehicle Code of Civil Procedure 425.12
Judicial Council of California ‘www.courtinfo.ca.gov
PLD-PI-001(1) [Rev. January 1, 2007]
‘American LegalNet, Inc.
www.FormsWorkflow.com
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Electronically Filed by Superior Court of California, County of Orange, 02/01/2022 11:36:23 AM. 30-2022-01243334-CU-PA-CJ C - ROA #2 - DAVID H. YAMASAKI, Clerk of the Court By Katie Trent, Deputy Clerk. PLD-PI-001 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Daniel Petrov (SBN 254316) Christine Palcisko (SBN 297575) Petrov Law Firm 380 S. Melrose Dr. Suite 201 Vista, CA 92081 TeLePHone No: 619.344.0360 FAX NO. (Optional): 619.377.7668 E-MAIL ADDRESS (Optiona): Christie@petrovlawfirm.com ATTORNEY FOR (Name): Plaintiff Dawn Robbins SUPERIOR COURT OF CALIFORNIA, COUNTY OF Orange street appress: 700 Civic Center Drive West maine aopress: 700 Civic Center Drive West city AnD zip cove: Santa Ana, CA 92701 BrancH Name: Central Justice Center PLAINTIFF: Dawn Robbins DEFENDANT: Aidan Flynn, Daniel Flynn &] poes1To 10 COMPLAINT—Personal Injury, Property Damage, Wrongful Death (0 AMENDED (Number): Type (check all that apply): EK MOTOR VEHICLE (1 OTHER (specify): KX] Property Damage C1 Wrongful Death KX] Personal Injury [1 Other Damages (specify): Jurisdiction (check all that apply): CASE NUMBER: ACTION IS A LIMITED CIVIL CASE Amount demanded [1 does not exceed $10,000 30-2022-01243334-CU-PA-CIC [1 exceeds $10,000, but does not exceed $25,000 X ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000) Oo ACTION IS RECLASSIFIED by this amended complaint Assigned for All Purposes [1 from limited to unlimited Judge DerekW. Hunt (1 from unlimited to limited Plaintiff (name or names): Dawn Robbins alleges causes of action against defendant (name or names): Aidan Flynn, Daniel Flynn and DOES 1 to 10 This pleading, including attachments and exhibits, consists of the following number of pages: 5 Each plaintiff named above is a competent adult a. 1 except plaintiff (name): a) O a corporation qualified to do business in California 2 O an unincorporated entity (describe): 3) O a public entity (describe): 4) O a minor 0 anadult (a) [11 for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b) [1 other (specify): (5) [11 other (specify): b. Oo except plaintiff (name): a) O a corporation qualified to do business in California 2 O an unincorporated entity (describe): 3) O a public entity (describe): 4) O a minor 0 anadult (a) [11 for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b) [1 other (specify): 6 O other (specify): [1 Information about additional plaintiffs who are not competent adults is shown in Attachment 3. Page 1 of 3 Form Approved for Optional Use COMPLAINT—Personal Injury, Property ‘Code of GWvil Procedure, § 425.12 Judicial Council of California www.courtinfo.ca.gov PLD-PI-001 (Rev. January 1, 2007] Damage, Wrongful Death ‘American LegalNet, Inc. www.FormsWorkflow.com PLD-PI-001 SHORT TITLE: CASE NUMBER: Robbins v. Flynn 4 DO Plaintiff (name): is doing business under the fictitious name (specify): and has complied with the fictitious business name laws. 5. Each defendant named above is a natural person a. 1 except defendant (name): c. C1 except defendant (name): (1) ($a business organization, form unknown (1) abusiness organization, form unknown (2) a corporation (2) [1 acorporation (3) Oo an unincorporated entity (describe): (3) [1 an unincorporated entity (describe): (4) Oo a public entity (describe): (4) [1] apublic entity (describe): (5) Oo other (specify): (5) [] other (specify): oO except defendant (name): Oo except defendant (name): (1) Oo a business organization, form unknown (1) Oo a business organization, form unknown (2) Oo a corporation (2) Oo a corporation (3) Oo an unincorporated entity (describe): (3) ou an unincorporated entity (describe): (4) Oo a public entity (describe): 4 O a public entity (describe): (5) Oo other (specify): 6) O other (specify): oO 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): 1 to 10 were the agents or employees of other named defendants and acted within the scope of that agency or employment. b. KX) Doe defendants (specify Doe numbers): 1 to 10 are persons whose capacities are unknown to plaintiff. (1 Defendants who are joined under Code of Civil Procedure section 382 are (names): 8 This court is the proper court because a KK) at least one defendant now resides in its jurisdictional area. b. the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area. c. KX injury to person or damage to personal property occurred in its jurisdictional area. d. Ls other (specify): 9. C1 Plaintiff is required to comply with a claims statute, and a TZ has complied with applicable claims statutes, or b. CZ is excused from complying because (specify): PLD-PI-001 [Rev. January 1, 2007] COMPLAINT—Personal Injury, Property Page 2 of 3 Damage, Wrongful Death ‘American LegalNet, Inc. ‘wwww.FormsWorkflow.com PLD-PI-001 SHORT TITLE: CASE NUMBER. Robbins v. Flynn 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 General Negligence Intentional Tort Products Liability Premises Liability Other (specify): 1 Plaintiff has suffered wage loss loss of use of property hospital and medical expenses general damage property damage loss of earning capacity other damage (specify): 12. (1 The damages claimed for wrongful death and the relationships of plaintiff to the deceased are a. 1 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) KX] compensatory damages (2) [J punitive damages The amount of damages is (in cases for personal injury or wrongful death, you must check (1)): (1) KX] according to proof (2) (1 in the amount of: $ 15. (1 The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers): Date: 2/1/2022 Christine Palcisko, Esq. SBN 297575 (TYPE OR PRINT NAME) (pn fal_~ » ~T (SIGNATURE OF PLAINTIFF OR ATTORNEY) PLD-PI-001 (Rev. January 1, 2007] COMPLAINT—Personal Injury, Property Page 3 of 3 Damage, Wrongful Death ‘American LegalNet, Inc. ‘wwww.FormsWorkflow.com PLD-PI-001(2) SHORT TITLE: CASE NUMBER: Robbins v. Flynn CAUSE OF ACTION—General Negligence Page 4 (number) ATTACHMENT TO &X Complaint [] Cross - Complaint (Use a separate cause of action form for each cause of action.) GN-1. Plaintiff (name): Dawn Robbins alleges that defendant (name): Aidan Flynn, Daniel Flynn KX] Does 1 to 10 was the legal (proximate) cause of damages to plaintiff. By the following acts or omissions to act, defendant negligently caused the damage to plaintiff on (date): 10/21/2020 at (place): San Clemente, CA (description of reasons for liability): Defendant rear-ended Plaintiff's vehicle Page 1 of 1 Form Approved for Optional Use Code of Civil Procedure 425.12 Judicial Council of California CAUSE OF ACTION—General Negligence ‘www.courtinfo.ca.gov PLD-PI-001(2) (Rev. January 1, 2007] ‘American LegalNet, Inc. www. FormsWorkflow.com PLD-PI-001(1) SHORT TITLE: CASE NUMBER: Robbins v. Flynn CAUSE OF ACTION—Motor Vehicle (number) ATTACHMENT TO [XJ — Complaint Oo Cross - Complaint (Use a separate cause of action form for each cause of action.) Plaintiff (name): Dawn Robbins MV- 1. Plaintiff alleges the acts of defendants were negligent; the acts were the legal (proximate) cause of injuries and damages to plaintiff; the acts occurred on (date): 10/21/2020 at (place): San Clemente, CA MV- 2. DEFENDANTS, a. The defendants who operated a motor vehicle are (names): Aidan Flynn X Does 1 to 10 The defendants who employed the persons who operated a motor vehicle in the course of their employment are (names): XI Does 1 to 10 The defendants who owned the motor vehicle which was operated with their permission are (names): X Does 1 to 10 The defendants who entrusted the motor vehicle are (names): x Does 1 to 10 The defendants who were the agents and employees of the other defendants and acted within the scope Of the agency were (names): KX] Does 1 to 10 The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are Oo listed in Attachment MV-2f Cas follows: Does to Page5 Paget of 1 Form Approved for Optional Use CAUSE OF ACTION—Motor Vehicle Code of Civil Procedure 425.12 Judicial Council of California ‘www.courtinfo.ca.gov PLD-PI-001(1) [Rev. January 1, 2007] ‘American LegalNet, Inc. www.FormsWorkflow.com