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ELECTRONICALLY FILED
RUBEN DURAN, Bar N0. 197780 SUPERIOR COURT OF CALIFORNIA
ruben.duran@bbklaw.com COUNTY OF SAN BERNARDINO
AARON CHANDLER, Bar N0. 296361 SAN BERNARDINO DISTRICT
aaron.chandler@bbklaw.com
CLARISSA THURSTON, Bar N0. 339886 11/6/2023 4:06 PM
clarissa.thurst0n@bbklaw.com
By: Brian Summers, DEPUTY
BEST BEST & KRIEGER LLP
2855 E. Guasti Road, Suite 400
Ontario, CA 91761
Telephone: (909) 989-8584
Facsimile: (909) 944-1441
Attorneys for Plaintiffs
OF CALIFORNIA Government Code section 6103.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 COUNTY OF SAN BERNARDINO
11
12 CITY OF ONTARIO, a municipal Case N0. CIV882328951
corporation; and Judge:
13 PEOPLE OF THE STATE OF
CALIFORNIA, by and through the CITY VERIFIED COMPLAINT FOR
14 OF ONTARIO, NUISANCE ABATEMENT AND
INJUNCTIVE RELIEF
15 Plaintiffs,
1. Public Nuisance (CiV. Code, §§ 3479,
16 V. 3480, 3491, 3494; Code CiV. Proc.,
§§ 526(a)(1), 731.)
17 HUAIQING REN, an individual; 2. Nuisance Per Se (OMC §§ 1-2.02; 3-
XIA CUI, an individual; 1.105; 4-13.02; 4-13.03 et seq.; 4-
18 and 13.04(a); 5-22.02 et seq.; 8-1.02; ODC
DOES 1 through 25, inclusive, § 5.02.005(A)(1); CBC § 105.1)
19
Defendants. [Deemed Verified per Code CiV. Proc. § 446]
20
21
22
23
24
25
26
27
28
46700.20140\41791016.1
_1_
VERIFIED COMPLAINT FOR NUISANCE ABATEMENT AND INJUNCTIVE RELIEF
COMPLAINT FOR NUISANCE ABATEMENT AND INJUNCTIVE RELIEF
The Plaintiffs, City of Ontario (“City”) and People 0f the State of California (“People”), by
and through the City (collectively, “Plaintiff” 0r “City”), allege as follows:
PARTIES
1. The City of Ontario brings this suit in the name of the People of the State of
California under Civil Code sections 3479 and 3480, Code of Civil Procedure section 731, and in
its own capacity under Ontario Municipal Code (“OMC”) section 1-2.01 and Ontario Development
Code (“ODC”) section 1.02.015, among others.
2. Plaintiff is a municipal corporation organized under the laws of the State of
10 California and located in San Bernardino County, California.
400
11 3. The City seeks nuisance abatement, injunctive relief, imposition of civil penalties,
LLP
SUITE
LAW
761
12 and other remedies against the parcel of real property identified as 131 15 South Ontario Avenue,
91
KRIEGER
AT
ROAD,
CA
EYS
13 Ontario, California, 91761, Assessor’s Parcel Number 0218-1 1 1-06-0000 (“Subject Property”).
&
ONTARIO,
GUASTI
BEST
ATTORN
14 4. Plaintiff is informed and believes, and based thereon alleges, that defendants
E.
BEST
15 Huaiqing Ren (“Defendant Ren”), and Xia Cui (“Defendant Cui”), are the owners of the Subject
2855
16 Property, at all relevant times mentioned herein.
17 5. The true name and capacities, whether individual, corporate, associate, 0r otherwise
18 of the defendants named herein as Does 1 through 25, inclusive, are unknown t0 Plaintiff, Who
19 therefore sues said Defendants by fictitious names. Plaintiff will amend this Complaint to allege
20 the true names and capacities When they have been ascertained. Plaintiff is informed and believes
21 and thereon alleges that each such defendant is responsible in some manner for the nuisance and
22 substandard conditions herein alleged.
23 6. Plaintiff is informed and believes, and based thereon alleges, that at all times herein
24 mentioned, Defendants Huaiqing Ren, Xia Cui, and Does 1 through 25 (collectively, “Defendants”)
25 were the agents and authorized representatives of each of the other Defendants, and in doing the
26 things hereinafter alleged, was acting within the course and scope of such agency and
27 representation.
28
_2_
VERIFIED COMPLAINT FOR NUISANCE ABATEMENT AND INJUNCTIVE RELIEF
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ELECTRONICALLY FILED RUBEN DURAN, Bar N0. 197780 SUPERIOR COURT OF CALIFORNIA ruben.duran@bbklaw.com COUNTY OF SAN BERNARDINO AARON CHANDLER, Bar N0. 296361 SAN BERNARDINO DISTRICT aaron.chandler@bbklaw.com CLARISSA THURSTON, Bar N0. 339886 11/6/2023 4:06 PM clarissa.thurst0n@bbklaw.com By: Brian Summers, DEPUTY BEST BEST & KRIEGER LLP 2855 E. Guasti Road, Suite 400 Ontario, CA 91761 Telephone: (909) 989-8584 Facsimile: (909) 944-1441 Attorneys for Plaintiffs OF CALIFORNIA Government Code section 6103. SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF SAN BERNARDINO 11 12 CITY OF ONTARIO, a municipal Case N0. CIV882328951 corporation; and Judge: 13 PEOPLE OF THE STATE OF CALIFORNIA, by and through the CITY VERIFIED COMPLAINT FOR 14 OF ONTARIO, NUISANCE ABATEMENT AND INJUNCTIVE RELIEF 15 Plaintiffs, 1. Public Nuisance (CiV. Code, §§ 3479, 16 V. 3480, 3491, 3494; Code CiV. Proc., §§ 526(a)(1), 731.) 17 HUAIQING REN, an individual; 2. Nuisance Per Se (OMC §§ 1-2.02; 3- XIA CUI, an individual; 1.105; 4-13.02; 4-13.03 et seq.; 4- 18 and 13.04(a); 5-22.02 et seq.; 8-1.02; ODC DOES 1 through 25, inclusive, § 5.02.005(A)(1); CBC § 105.1) 19 Defendants. [Deemed Verified per Code CiV. Proc. § 446] 20 21 22 23 24 25 26 27 28 46700.20140\41791016.1 _1_ VERIFIED COMPLAINT FOR NUISANCE ABATEMENT AND INJUNCTIVE RELIEF COMPLAINT FOR NUISANCE ABATEMENT AND INJUNCTIVE RELIEF The Plaintiffs, City of Ontario (“City”) and People 0f the State of California (“People”), by and through the City (collectively, “Plaintiff” 0r “City”), allege as follows: PARTIES 1. The City of Ontario brings this suit in the name of the People of the State of California under Civil Code sections 3479 and 3480, Code of Civil Procedure section 731, and in its own capacity under Ontario Municipal Code (“OMC”) section 1-2.01 and Ontario Development Code (“ODC”) section 1.02.015, among others. 2. Plaintiff is a municipal corporation organized under the laws of the State of 10 California and located in San Bernardino County, California. 400 11 3. The City seeks nuisance abatement, injunctive relief, imposition of civil penalties, LLP SUITE LAW 761 12 and other remedies against the parcel of real property identified as 131 15 South Ontario Avenue, 91 KRIEGER AT ROAD, CA EYS 13 Ontario, California, 91761, Assessor’s Parcel Number 0218-1 1 1-06-0000 (“Subject Property”). & ONTARIO, GUASTI BEST ATTORN 14 4. Plaintiff is informed and believes, and based thereon alleges, that defendants E. BEST 15 Huaiqing Ren (“Defendant Ren”), and Xia Cui (“Defendant Cui”), are the owners of the Subject 2855 16 Property, at all relevant times mentioned herein. 17 5. The true name and capacities, whether individual, corporate, associate, 0r otherwise 18 of the defendants named herein as Does 1 through 25, inclusive, are unknown t0 Plaintiff, Who 19 therefore sues said Defendants by fictitious names. Plaintiff will amend this Complaint to allege 20 the true names and capacities When they have been ascertained. Plaintiff is informed and believes 21 and thereon alleges that each such defendant is responsible in some manner for the nuisance and 22 substandard conditions herein alleged. 23 6. Plaintiff is informed and believes, and based thereon alleges, that at all times herein 24 mentioned, Defendants Huaiqing Ren, Xia Cui, and Does 1 through 25 (collectively, “Defendants”) 25 were the agents and authorized representatives of each of the other Defendants, and in doing the 26 things hereinafter alleged, was acting within the course and scope of such agency and 27 representation. 28 _2_ VERIFIED COMPLAINT FOR NUISANCE ABATEMENT AND INJUNCTIVE RELIEF