On March 14, 2024 a
Complaint,Petition
was filed
involving a dispute between
Guerra Mialeah,
Leano Jackson Tina Marie,
Leano Maribea Alice,
and
Borghani Vahid,
for Motor Vehicle - Personal Injury/Property Damage/Wrongful Death (General Jurisdiction)
in the District Court of Los Angeles County.
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PLD-Pl-001
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
FOR COURT USE ONLY
Jason Shamtoob, Esq. SBN 329692
California Accident Firm, 18653 Ventura Boulevard, Suite 579
Tarzana CA 91356
TELEPHONE NO: (818) 338-0020 FAX NO. (Optional): (818) 338-0021
E-MAIL ADDRESS (Optional) : lit@.cafirm.com
ATTORNEY FOR (Name): Tina Marie Leana Jackson: Maribea Alice Leana: Mialeah Guerra
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
STREET ADDRESS: 9425 Penfield Avenue
MAILING ADDRESS:
cITY AND ZIP coDE:Chatsworth. CA 91311
BRANCH NAME: Chatsworth Courthouse
PLAINTIFF:Tina Marie Leano Jackson; Maribea Alice Leano; Mialeah Guerra
DEFENDANT:Vahid BorQhani
[KJ DOES 1 TO 10
COMPLAINT-Personal Injury, Property Damage, Wrongful Death CASE NUMBER:
CJ AMENDED (Number):
Type (check all that apply):
[KJ MOTOR VEHICLE CJ OTHER (specify):
[KJ Property Damage CJ Wrongful Death
[KJ Personal Injury CJ Other Damages (specify):
Jurisdiction (check all that apply):
CJ ACTION IS A LIMITED CIVIL CASE
Amount demanded CJ does not exceed $10,000
CJ exceeds $10,000, but does not exceed $25,000
LL] ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000)
CJ ACTION IS RECLASSIFIED by this amended complaint
D from limited to unlimited
D from unlimited to limited
1. Plaintiff (name or names): Tina Marie Leano Jackson; Maribea Alice Leano; Mialeah Guerra
alleges causes of action against defendant (name or names):
Vahid Borqhani; and DOES 1 throuqh 10
2. This pleading, including attachments and exhibits, consists of the following number of pages: 3
3. Each plaintiff named above is a competent adult
a. D except plaintiff (name):
(1) D a corporation qualified to do business in California
(2) D an unincorporated entity (describe):
(3) D a public entity (describe):
(4) CJ a minor CJ an adult
(a) CJ for whom a guardian or conservator of the estate or a guardian ad litem has been appointed
(b) D other(specify):
(5) D other (specify) :
b. D except plaintiff (name) :
(1) CJ a corporation qualified to do business in California
(2) D an unincorporated entity (describe) :
(3) D a public entity (describe):
(4) D a minor D a n adult
(a) D for whom a guardian or conservator of the estate or a guardian ad litem has been appointed
(b) CJ other(specify):
(5) D other (specify) :
D Information about additional plaintiffs who are not competent adults is shown in Attachment 3.
Page 1 of3
Form Approved for Optional Use COMPLAINT-Personal Injury, Property Code of Civil Procedure,§ 425.12
Judicial Council of California www.courts.ca.gov
PLD-Pl-001 IRev. January 1, 2007] Damage, Wrongful Death
PLD-Pl-001
SHORT TITLE: CASE NUMBER:
Jackson v. Borghani
4. D 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. D except defendant (name): c. D except defendant (name):
(1) D a business organization, form unknown (1) D a business organization, form unknown
(2) D a corporation (2) D a corporation
(3) D an unincorporated entity (describe): (3) D an unincorporated entity (describe):
(4) D a public entity (describe): (4) D a public entity (describe):
(5) D other(specify): (5) D other(specify):
b. D except defendant (name): d. D except defendant (name):
(1) D a business organization, form unknown (1) D a business organization, form unknown
(2) D a corporation (2) D a corporation
(3) D an unincorporated entity (describe): (3) D an unincorporated entity (describe):
(4) D a public entity (describe): (4) D a public entity (describe):
(5) D other (specify): (5) D other (specify):
D 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. CK] Doe defendants (specify Doe numbers): 1-5 were the agents or employees of other
named defendants and acted within the scope of that agency or employment.
b. CK] Doe defendants (specify Doe numbers): 6-10 are persons whose capacities are unknown to
plaintiff.
7. D Defendants who are joined under Code of Civil Procedure section 382 are (names):
8. This court is the proper court because
a. D at least one defendant now resides in its jurisdictional area.
b. D the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area.
c. CK] injury to person or damage to personal property occurred in its jurisdictional area.
d. D other (specify):
9. D Plaintiff is required to comply with a claims statute, and
a. D has complied with applicable claims statutes, or
b. D is excused from complying because (specify):
PLD-Pl-001 [Rav. January 1, 2007] COMPLAINT-Personal Injury, Property Page2 of3
Damage, Wrongful Death
PLD-Pl-001
ISHORTTITLE, I """'â„¢"'' I
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):
a. [KJ Motor Vehicle
b. D General Negligence
c. D Intentional Tort
d. D Products Liability
e. D Premises Liability
f. D Other (specify):
11 . Plaintiff has suffered
a. [KJ wage loss
b. [KJ loss of use of property
c. [KJ hospital and medical expenses
d. [KJ general damage
e. w property damage
f. D loss of earning capacity
g. D other damage (specify):
12. D The damages claimed for wrongful death and the relationships of plaintiff to the deceased are
a. D listed in Attachment 12.
b. D 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) [KJ compensatory damages
(2) D punitive damages
The amount of damages is (in cases for personal injury or wrongful death, you must check (1)):
(1) [KJ according to proof
(2) D in the amount of: $
15. D The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers):
Date: March 14, 2024
Jason Shamtoob, Esq. â–º
(TYPE OR PRINT NAME) GNATURE OF PLAINTIFF OR ATTORNEY)
PLD-Pl-001 [Rev. January 1, 2007] COMPLAINT-Personal Injury, Property Page 3 of 3
Damage, Wrongful Death
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PLD-Pl-001 (1)
SHORT TITLE: CASE NUMBER:
Jackson v. Borghani
FIRST CAUSE OF ACTION-Motor Vehicle
(number)
ATTACHMENT TO [KJ Complaint O Cross - Complaint
(Use a separate cause of action form for each cause of action.)
Plaintiff (name) : Tina Marie Leano Jackson; Maribea Alice Leano; Mialeah Guerra
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): March 16, 2022
at (place):
the intersection of Independence Avenue and Devonshire Street in Los Angeles, CA 91311 .
MV- 2. DEFENDANTS
a. [KJ The defendants who operated a motor vehicle are (names) :
Vahid Borghani
[KJ Does to 10
-----------
b. D The defendants who employed the persons who operated a motor vehicle in the course of their employment are
(names):
D Does to
c. [KJ The defendants who owned the motor vehicle which was operated with their permission are (names) :
Vahid Borghani
[KJ Does to 10
-----------
d. D The defendants who entrusted the motor vehicle are (names):
D Does to
e. D The defendants who were the agents and employees of the other defendants and acted within the scope of the
agency were (names):
D Does to
f. D The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are
D listed in Attachment MV-2f D as follows:
D Does to
Page
Page 1 of 1
Form Approved for Optional Use Code of Civil Procedure 425.12
Judicial Council of California CAUSE OF ACTION-Motor Vehicle www.courts.ca.gov
PLD-Pl-001(1) IRev. January 1, 2007]
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Document Filed Date
March 14, 2024
Case Filing Date
March 14, 2024
Category
Motor Vehicle - Personal Injury/Property Damage/Wrongful Death (General Jurisdiction)
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PLD-Pl-001 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Jason Shamtoob, Esq. SBN 329692 California Accident Firm, 18653 Ventura Boulevard, Suite 579 Tarzana CA 91356 TELEPHONE NO: (818) 338-0020 FAX NO. (Optional): (818) 338-0021 E-MAIL ADDRESS (Optional) : lit@.cafirm.com ATTORNEY FOR (Name): Tina Marie Leana Jackson: Maribea Alice Leana: Mialeah Guerra SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES STREET ADDRESS: 9425 Penfield Avenue MAILING ADDRESS: cITY AND ZIP coDE:Chatsworth. CA 91311 BRANCH NAME: Chatsworth Courthouse PLAINTIFF:Tina Marie Leano Jackson; Maribea Alice Leano; Mialeah Guerra DEFENDANT:Vahid BorQhani [KJ DOES 1 TO 10 COMPLAINT-Personal Injury, Property Damage, Wrongful Death CASE NUMBER: CJ AMENDED (Number): Type (check all that apply): [KJ MOTOR VEHICLE CJ OTHER (specify): [KJ Property Damage CJ Wrongful Death [KJ Personal Injury CJ Other Damages (specify): Jurisdiction (check all that apply): CJ ACTION IS A LIMITED CIVIL CASE Amount demanded CJ does not exceed $10,000 CJ exceeds $10,000, but does not exceed $25,000 LL] ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000) CJ ACTION IS RECLASSIFIED by this amended complaint D from limited to unlimited D from unlimited to limited 1. Plaintiff (name or names): Tina Marie Leano Jackson; Maribea Alice Leano; Mialeah Guerra alleges causes of action against defendant (name or names): Vahid Borqhani; and DOES 1 throuqh 10 2. This pleading, including attachments and exhibits, consists of the following number of pages: 3 3. Each plaintiff named above is a competent adult a. D except plaintiff (name): (1) D a corporation qualified to do business in California (2) D an unincorporated entity (describe): (3) D a public entity (describe): (4) CJ a minor CJ an adult (a) CJ for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b) D other(specify): (5) D other (specify) : b. D except plaintiff (name) : (1) CJ a corporation qualified to do business in California (2) D an unincorporated entity (describe) : (3) D a public entity (describe): (4) D a minor D a n adult (a) D for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b) CJ other(specify): (5) D other (specify) : D Information about additional plaintiffs who are not competent adults is shown in Attachment 3. Page 1 of3 Form Approved for Optional Use COMPLAINT-Personal Injury, Property Code of Civil Procedure,§ 425.12 Judicial Council of California www.courts.ca.gov PLD-Pl-001 IRev. January 1, 2007] Damage, Wrongful Death PLD-Pl-001 SHORT TITLE: CASE NUMBER: Jackson v. Borghani 4. D 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. D except defendant (name): c. D except defendant (name): (1) D a business organization, form unknown (1) D a business organization, form unknown (2) D a corporation (2) D a corporation (3) D an unincorporated entity (describe): (3) D an unincorporated entity (describe): (4) D a public entity (describe): (4) D a public entity (describe): (5) D other(specify): (5) D other(specify): b. D except defendant (name): d. D except defendant (name): (1) D a business organization, form unknown (1) D a business organization, form unknown (2) D a corporation (2) D a corporation (3) D an unincorporated entity (describe): (3) D an unincorporated entity (describe): (4) D a public entity (describe): (4) D a public entity (describe): (5) D other (specify): (5) D other (specify): D 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. CK] Doe defendants (specify Doe numbers): 1-5 were the agents or employees of other named defendants and acted within the scope of that agency or employment. b. CK] Doe defendants (specify Doe numbers): 6-10 are persons whose capacities are unknown to plaintiff. 7. D Defendants who are joined under Code of Civil Procedure section 382 are (names): 8. This court is the proper court because a. D at least one defendant now resides in its jurisdictional area. b. D the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area. c. CK] injury to person or damage to personal property occurred in its jurisdictional area. d. D other (specify): 9. D Plaintiff is required to comply with a claims statute, and a. D has complied with applicable claims statutes, or b. D is excused from complying because (specify): PLD-Pl-001 [Rav. January 1, 2007] COMPLAINT-Personal Injury, Property Page2 of3 Damage, Wrongful Death PLD-Pl-001 ISHORTTITLE, I """'™"'' I 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): a. [KJ Motor Vehicle b. D General Negligence c. D Intentional Tort d. D Products Liability e. D Premises Liability f. D Other (specify): 11 . Plaintiff has suffered a. [KJ wage loss b. [KJ loss of use of property c. [KJ hospital and medical expenses d. [KJ general damage e. w property damage f. D loss of earning capacity g. D other damage (specify): 12. D The damages claimed for wrongful death and the relationships of plaintiff to the deceased are a. D listed in Attachment 12. b. D 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) [KJ compensatory damages (2) D punitive damages The amount of damages is (in cases for personal injury or wrongful death, you must check (1)): (1) [KJ according to proof (2) D in the amount of: $ 15. D The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers): Date: March 14, 2024 Jason Shamtoob, Esq. ► (TYPE OR PRINT NAME) GNATURE OF PLAINTIFF OR ATTORNEY) PLD-Pl-001 [Rev. January 1, 2007] COMPLAINT-Personal Injury, Property Page 3 of 3 Damage, Wrongful Death For your protection and privacy, please press the Clear This Form button after you have printed the form. Ir Print this form 11 Save this form I Clear this form PLD-Pl-001 (1) SHORT TITLE: CASE NUMBER: Jackson v. Borghani FIRST CAUSE OF ACTION-Motor Vehicle (number) ATTACHMENT TO [KJ Complaint O Cross - Complaint (Use a separate cause of action form for each cause of action.) Plaintiff (name) : Tina Marie Leano Jackson; Maribea Alice Leano; Mialeah Guerra 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): March 16, 2022 at (place): the intersection of Independence Avenue and Devonshire Street in Los Angeles, CA 91311 . MV- 2. DEFENDANTS a. [KJ The defendants who operated a motor vehicle are (names) : Vahid Borghani [KJ Does to 10 ----------- b. D The defendants who employed the persons who operated a motor vehicle in the course of their employment are (names): D Does to c. [KJ The defendants who owned the motor vehicle which was operated with their permission are (names) : Vahid Borghani [KJ Does to 10 ----------- d. D The defendants who entrusted the motor vehicle are (names): D Does to e. D The defendants who were the agents and employees of the other defendants and acted within the scope of the agency were (names): D Does to f. D The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are D listed in Attachment MV-2f D as follows: D Does to Page Page 1 of 1 Form Approved for Optional Use Code of Civil Procedure 425.12 Judicial Council of California CAUSE OF ACTION-Motor Vehicle www.courts.ca.gov PLD-Pl-001(1) IRev. January 1, 2007] For your protection and privacy, please press the Clear This Form button after you have printed the form. I Print this form ] ISave this form I Clear this form