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PLD-Pl-001
ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: 308224 FOR COURT USE ONLY
NAME: Giorgio Cassandra, Esq.
FIRM NAME: BD&J, PC
STREET ADDRESS: 9701 Wilshire Blvd., 12th Floor
CITY: Beverly Hills STATE: CA ZIP CODE: 90212
TELEPHONE NO .. (310) 887-1818 FAX NO .. (310) 887-1880
EMAIL ADDRESS: eservet2@bhattorneys.com
ATTORNEY FOR (name):
Jessica Matta
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN MATEO
STREET ADDRESS: 1050 Mission Road
MAILING ADDRESS: 1050 Mission Road
CITY AND ZIP CODE:
South San Francisco, 94080
BRANCH NAME:
Northern Branch
PLAINTIFF : Jessica Matta, an individual
DEFENDANT: Angela Nichole Cleveland, an individual; and
CJX DOES1 TO 20, inclusive
CASE NUMBER :
COMPLAINT-Personal Injury, Property Damage, Wrongful Death
CJ AMENDED (Number):
Type (check all that apply):
CJ
X MOTOR VEHICLE CJ
X OTHER (specify): GENERAL NEGLIGENCE
D
X Property Damage D
Wrongful Death
D
X Personal Injury D
Other Damages (specify):
Jurisdiction (check all that apply).
CJ ACTION IS A LIMITED CIVIL CASE (does not exceed $35,000)
Amount demanded D
does not exceed $10 ,000
D
exceeds $10 ,000
CJ
X ACTION IS AN UNLIMITED CIVIL CASE (exceeds $35,000)
CJ ACTION IS RECLASSIFIED by this amended complaint
Dfrom limited to unlimited
Dfrom unlimited to limited
1. Plaintiff (name or names). Jessica Matta, an Individual
alleges causes of action against defendant (name or names): Angela Nichole Cleveland, an Individual; and DOES 1 to 20,
inclusive
2. This pleading , including attachments and exhibits , consists of the following number of pages : 6
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) D a minor D an adult
(a) D 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) D 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 an adult
(a) D 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) .
D Information about additional plaintiffs who are not competent adults is shown in Attachment 3.
Page 1 of 3
Form Approve d fo r Optional Use COMPLAINT-Personal Injury, Property Code of Civ il Proce dure, § 425.12
Judicial Council of California www.courts .ca.gov
PLD-Pl-00 1 [Rev. January 1, 2024] Damage, Wrongful Death
Westlaw Doc & Form Builder·
PLD-Pl-001
ISHORTTITLE Matta v. Cleveland, et al.
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. DX Doe defendants (specify Doe numbers): 1 to 20, inclusive were the agents or employees of other
named defendants and acted within the scope of that agency or employment.
b. DX Doe defendants (specify Doe numbers): 1 to 20, inclusive 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. DX 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 [Rev. January 1, 2024] COMPLAINT-Personal Injury, Property Page 2 of 3
Damage, Wrongful Death
PLD-Pl-001
ISHORTTITLE, Matta v. Cleveland, et al. I ""'"MSc< 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. DX Motor Vehicle
b. DX General Negligence
C. D Intentional Tort
d. D Products Liability
e. D Premises Liability
f. CJ Other (specify):
11. Plaintiff has suffered (check all that apply)
a. CJX wage loss.
b. DX loss of use of property.
C. DX hospital and medical expenses.
d. DX general damage.
e. DX property damage.
f. DX loss of earning capacity.
g. CJ
X other damage (specify): For such other relief as the Court deems just and proper.
12. CJ The damages claimed for wrongful death and the relationships of plaintiff to the deceased are
a. CJ listed in Attachment 12.
b. CJ 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) CJ
X compensatory damages.
(2) CJ punitive damages.
b. The amount of damages is (in cases for personal injury or wrongful death, you must check (1)):
(1) CJ
X according to proof.
(2) CJ in the amount of: $
15. C]The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers):
â–º
Date: April 2, 2024
Giorgio Cassandra, Esq.
(TYPE OR PRINT NAME)
-~ (SIGNATURE OF PLAINTIFF OR ATTORNEY)
PLD-Pl-001 [Rev. January 1, 2024] COMPLAINT-Personal Injury, Property Page 3 of 3
Damage, Wrongful Death
PLD-Pl-001 (2)
SHORT TITLE: Matta v. Cleveland, et al.
FIRST CAUSE OF ACTION-General Negligence Page 4 of 6
-----
(number)
ATTACHMENT TO DX Complaint D Cross - Complaint
(Use a separate cause of action form for each cause of action.)
GN-1. Plaintiff (name): Jessica Matta, an individual
alleges that defendant (name): Angela Nichole Cleveland, an individual; and
DX Does 1 to 20, inclusive
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): On or about April 11, 2022
at (place): At or near the intersection Oyster Point Boulevard and Airport Boulevard, in the City of South San
Francisco, County of San Mateo, State of California, 94080
(description of reasons for liability):
On or about April 11, 2022, Plaintiff JESSICA MATTA, was traveling Eastbound on Oyster Point Boulevard, in the
City of South San Francisco, in the County of San Mateo, in the State of California, and was waiting for the green light
near the intersection with Airport Boulevard. Defendants ANGELA CLEVELAND, and DOES 1 to 20, inclusive, and
each of them, failed to keep a proper lookout and negligently and carelessly rear-ended Plaintiff's vehicle at excessive
speed for so as to cause a collision with Plaintiff and Plaintiff’s vehicle. Defendants ANGELA CLEVELAND, and
DOES 1 to 20, inclusive, and each of their vehicles forcefully and violently collided with Plaintiff JESSICA MATTA's
vehicle, resulting in injuries and damages to Plaintiff JESSICA MATTA.
At all times herein mentioned, Defendants ANGELA CLEVELAND and DOES 1 to 20, inclusive, were acting within
the course and scope of her employment, agency, joint enterprise and/or independent contractor relationship with
Defendants DOES 1 to 20 inclusive, and each of them, so that Defendants, and DOES 1 to 20, inclusive and each of
them are vicariously liable for the negligence of Defendants ANGELA CLEVELAND.
Defendants ANGELA CLEVELAND, and DOES 1 to 20, inclusive, and each of them, negligently operated their
motor vehicle by, inter alia, failing to keep a proper lookout for other vehicles, including Plaintiff JESSICA MATTA's
vehicle. Defendants ANGELA CLEVELAND, and DOES 1 to 20, inclusive, violated the applicable California Vehicle
Code Section, 22350, by driving at an unsafe speed; and California Vehicle Code Section 21703, for following
Plaintiff's vehicle too closely than is reasonable and prudent, having due regard for speeds, traffic, and other road
conditions.
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-Pl-001 (2) [Rev. January 1. 2007] Westlaw Doc & Form Builder·
MC-025
CASE NUMBER:
~HORT TITLE, Matta v. Cleveland, et al.
GN-1
ATTACHMENT (Number): _ _ _ _ _ __
(This Attachment may be used with any Judicial Council form.)
As a direct and proximate result of the acts and omissions of Defendants ANGELA CLEVELAND, and DOES 1 to 20,
inclusive, Plaintiffs received severe injuries to Plaintiff's body and shock and injuries to Plaintiff's nervous system, all of which
caused and continue to cause Plaintiff severe pain and discomfort and Plaintiff are informed and believe, and based upon such
information and belief allege, that Plaintiff will in the future suffer severe mental, physical and nervous pain and suffering, all to
Plaintiff's general damages in a sum according to proof at the time of trial.
As a direct, legal, and proximate result of the acts and omissions of Defendants ANGELA CLEVELAND, and DOES 1 to 20,
inclusive, and each of them, and the injuries resulting therefrom, Plaintiff necessarily employed physicians and surgeons for
medical examination, treatment, and care of Plaintiff's injuries, and incurred medical and incidental expenses. Plaintiff will also
have to incur additional like expenses in the future all in amounts presently unknown to Plaintiff. Plaintiff therefore ask leave of
the court to amend this complaint to show the amount of Plaintiff's medical expenses, when ascertained, or to prove the amount
at trial.
(If the item that this Attachment concerns is made under penalty of perjury, all statements in this Page 5 of _6__
Attachment are made under penalty of perjury.)
(Add pages as required)
Form Approved for Optional Use www.courlinfo.ca.gov
Judicial Council of California ATTACHMENT Westlaw Doc & Form Builder-
MC-025 [Rev. July 1, 2009] to Judicial Council Form
PLD-Pl-001 (1)
SHORT TITLE: Matta v. Cleveland, et al. CASE NUMBER:
SECOND CAUSE OF ACTION-Motor Vehicle
(number)
ATTACHMENT TO DX Complaint D Cross - Complaint
(Use a separate cause of action form for each cause of action.)
Plaintiff (name): Jessica Matta, an individual
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): On or about April 11, 2022
at (place): At or near the intersection Oyster Point Boulevard and Airport Boulevard, in the City of South San
Francisco, County of San Mateo, State of California, 94080
MV- 2. DEFENDANTS
a. D
X The defendants who operated a motor vehicle are (names): Angela Nichole Cleveland, an individual; and
DX Does 1 to 20, inclusive
b. DX The defendants who employed the persons who operated a motor vehicle in the course of their employment
are (names): Angela Nichole Cleveland, an individual; and
DX Does 1 to 20, inclusive
c. DX The defendants who owned the motor vehicle which was operated with their permission are (names):
DX Does _ _ _ 1 _ _ _ to 20, inclusive
d. DX The defendants who entrusted the motor vehicle are (names):
DX Does 1 ___
___ to 20, inclusive
e. DX The defendants who were the agents and employees of the other defendants and acted within the scope
of the agency were (names): Angela Nichole Cleveland, an individual; and
DX Does _ _ _ 1 _ _ _ to 20, inclusive
f. DX 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:
DX Does 1 to 20, inclusive Page 6 of 6
Page 1 of 1
Form Approved for Optional Use
Judicial Council of California
CAUSE OF ACTION-Motor Vehicle Code of Civil Procedure 425.12
www.courtinfo.ca.gov
PLD-Pl-001 (1) [Rev. January 1, 2007] Westlaw Doc & Form Builder
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PLD-Pl-001 ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: 308224 FOR COURT USE ONLY NAME: Giorgio Cassandra, Esq. FIRM NAME: BD&J, PC STREET ADDRESS: 9701 Wilshire Blvd., 12th Floor CITY: Beverly Hills STATE: CA ZIP CODE: 90212 TELEPHONE NO .. (310) 887-1818 FAX NO .. (310) 887-1880 EMAIL ADDRESS: eservet2@bhattorneys.com ATTORNEY FOR (name): Jessica Matta SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN MATEO STREET ADDRESS: 1050 Mission Road MAILING ADDRESS: 1050 Mission Road CITY AND ZIP CODE: South San Francisco, 94080 BRANCH NAME: Northern Branch PLAINTIFF : Jessica Matta, an individual DEFENDANT: Angela Nichole Cleveland, an individual; and CJX DOES1 TO 20, inclusive CASE NUMBER : COMPLAINT-Personal Injury, Property Damage, Wrongful Death CJ AMENDED (Number): Type (check all that apply): CJ X MOTOR VEHICLE CJ X OTHER (specify): GENERAL NEGLIGENCE D X Property Damage D Wrongful Death D X Personal Injury D Other Damages (specify): Jurisdiction (check all that apply). CJ ACTION IS A LIMITED CIVIL CASE (does not exceed $35,000) Amount demanded D does not exceed $10 ,000 D exceeds $10 ,000 CJ X ACTION IS AN UNLIMITED CIVIL CASE (exceeds $35,000) CJ ACTION IS RECLASSIFIED by this amended complaint Dfrom limited to unlimited Dfrom unlimited to limited 1. Plaintiff (name or names). Jessica Matta, an Individual alleges causes of action against defendant (name or names): Angela Nichole Cleveland, an Individual; and DOES 1 to 20, inclusive 2. This pleading , including attachments and exhibits , consists of the following number of pages : 6 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) D a minor D an adult (a) D 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) D 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 an adult (a) D 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) . D Information about additional plaintiffs who are not competent adults is shown in Attachment 3. Page 1 of 3 Form Approve d fo r Optional Use COMPLAINT-Personal Injury, Property Code of Civ il Proce dure, § 425.12 Judicial Council of California www.courts .ca.gov PLD-Pl-00 1 [Rev. January 1, 2024] Damage, Wrongful Death Westlaw Doc & Form Builder· PLD-Pl-001 ISHORTTITLE Matta v. Cleveland, et al. 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. DX Doe defendants (specify Doe numbers): 1 to 20, inclusive were the agents or employees of other named defendants and acted within the scope of that agency or employment. b. DX Doe defendants (specify Doe numbers): 1 to 20, inclusive 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. DX 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 [Rev. January 1, 2024] COMPLAINT-Personal Injury, Property Page 2 of 3 Damage, Wrongful Death PLD-Pl-001 ISHORTTITLE, Matta v. Cleveland, et al. I ""'"MSc< 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. DX Motor Vehicle b. DX General Negligence C. D Intentional Tort d. D Products Liability e. D Premises Liability f. CJ Other (specify): 11. Plaintiff has suffered (check all that apply) a. CJX wage loss. b. DX loss of use of property. C. DX hospital and medical expenses. d. DX general damage. e. DX property damage. f. DX loss of earning capacity. g. CJ X other damage (specify): For such other relief as the Court deems just and proper. 12. CJ The damages claimed for wrongful death and the relationships of plaintiff to the deceased are a. CJ listed in Attachment 12. b. CJ 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) CJ X compensatory damages. (2) CJ punitive damages. b. The amount of damages is (in cases for personal injury or wrongful death, you must check (1)): (1) CJ X according to proof. (2) CJ in the amount of: $ 15. C]The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers): ► Date: April 2, 2024 Giorgio Cassandra, Esq. (TYPE OR PRINT NAME) -~ (SIGNATURE OF PLAINTIFF OR ATTORNEY) PLD-Pl-001 [Rev. January 1, 2024] COMPLAINT-Personal Injury, Property Page 3 of 3 Damage, Wrongful Death PLD-Pl-001 (2) SHORT TITLE: Matta v. Cleveland, et al. FIRST CAUSE OF ACTION-General Negligence Page 4 of 6 ----- (number) ATTACHMENT TO DX Complaint D Cross - Complaint (Use a separate cause of action form for each cause of action.) GN-1. Plaintiff (name): Jessica Matta, an individual alleges that defendant (name): Angela Nichole Cleveland, an individual; and DX Does 1 to 20, inclusive 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): On or about April 11, 2022 at (place): At or near the intersection Oyster Point Boulevard and Airport Boulevard, in the City of South San Francisco, County of San Mateo, State of California, 94080 (description of reasons for liability): On or about April 11, 2022, Plaintiff JESSICA MATTA, was traveling Eastbound on Oyster Point Boulevard, in the City of South San Francisco, in the County of San Mateo, in the State of California, and was waiting for the green light near the intersection with Airport Boulevard. Defendants ANGELA CLEVELAND, and DOES 1 to 20, inclusive, and each of them, failed to keep a proper lookout and negligently and carelessly rear-ended Plaintiff's vehicle at excessive speed for so as to cause a collision with Plaintiff and Plaintiff’s vehicle. Defendants ANGELA CLEVELAND, and DOES 1 to 20, inclusive, and each of their vehicles forcefully and violently collided with Plaintiff JESSICA MATTA's vehicle, resulting in injuries and damages to Plaintiff JESSICA MATTA. At all times herein mentioned, Defendants ANGELA CLEVELAND and DOES 1 to 20, inclusive, were acting within the course and scope of her employment, agency, joint enterprise and/or independent contractor relationship with Defendants DOES 1 to 20 inclusive, and each of them, so that Defendants, and DOES 1 to 20, inclusive and each of them are vicariously liable for the negligence of Defendants ANGELA CLEVELAND. Defendants ANGELA CLEVELAND, and DOES 1 to 20, inclusive, and each of them, negligently operated their motor vehicle by, inter alia, failing to keep a proper lookout for other vehicles, including Plaintiff JESSICA MATTA's vehicle. Defendants ANGELA CLEVELAND, and DOES 1 to 20, inclusive, violated the applicable California Vehicle Code Section, 22350, by driving at an unsafe speed; and California Vehicle Code Section 21703, for following Plaintiff's vehicle too closely than is reasonable and prudent, having due regard for speeds, traffic, and other road conditions. 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-Pl-001 (2) [Rev. January 1. 2007] Westlaw Doc & Form Builder· MC-025 CASE NUMBER: ~HORT TITLE, Matta v. Cleveland, et al. GN-1 ATTACHMENT (Number): _ _ _ _ _ __ (This Attachment may be used with any Judicial Council form.) As a direct and proximate result of the acts and omissions of Defendants ANGELA CLEVELAND, and DOES 1 to 20, inclusive, Plaintiffs received severe injuries to Plaintiff's body and shock and injuries to Plaintiff's nervous system, all of which caused and continue to cause Plaintiff severe pain and discomfort and Plaintiff are informed and believe, and based upon such information and belief allege, that Plaintiff will in the future suffer severe mental, physical and nervous pain and suffering, all to Plaintiff's general damages in a sum according to proof at the time of trial. As a direct, legal, and proximate result of the acts and omissions of Defendants ANGELA CLEVELAND, and DOES 1 to 20, inclusive, and each of them, and the injuries resulting therefrom, Plaintiff necessarily employed physicians and surgeons for medical examination, treatment, and care of Plaintiff's injuries, and incurred medical and incidental expenses. Plaintiff will also have to incur additional like expenses in the future all in amounts presently unknown to Plaintiff. Plaintiff therefore ask leave of the court to amend this complaint to show the amount of Plaintiff's medical expenses, when ascertained, or to prove the amount at trial. (If the item that this Attachment concerns is made under penalty of perjury, all statements in this Page 5 of _6__ Attachment are made under penalty of perjury.) (Add pages as required) Form Approved for Optional Use www.courlinfo.ca.gov Judicial Council of California ATTACHMENT Westlaw Doc & Form Builder- MC-025 [Rev. July 1, 2009] to Judicial Council Form PLD-Pl-001 (1) SHORT TITLE: Matta v. Cleveland, et al. CASE NUMBER: SECOND CAUSE OF ACTION-Motor Vehicle (number) ATTACHMENT TO DX Complaint D Cross - Complaint (Use a separate cause of action form for each cause of action.) Plaintiff (name): Jessica Matta, an individual 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): On or about April 11, 2022 at (place): At or near the intersection Oyster Point Boulevard and Airport Boulevard, in the City of South San Francisco, County of San Mateo, State of California, 94080 MV- 2. DEFENDANTS a. D X The defendants who operated a motor vehicle are (names): Angela Nichole Cleveland, an individual; and DX Does 1 to 20, inclusive b. DX The defendants who employed the persons who operated a motor vehicle in the course of their employment are (names): Angela Nichole Cleveland, an individual; and DX Does 1 to 20, inclusive c. DX The defendants who owned the motor vehicle which was operated with their permission are (names): DX Does _ _ _ 1 _ _ _ to 20, inclusive d. DX The defendants who entrusted the motor vehicle are (names): DX Does 1 ___ ___ to 20, inclusive e. DX The defendants who were the agents and employees of the other defendants and acted within the scope of the agency were (names): Angela Nichole Cleveland, an individual; and DX Does _ _ _ 1 _ _ _ to 20, inclusive f. DX 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: DX Does 1 to 20, inclusive Page 6 of 6 Page 1 of 1 Form Approved for Optional Use Judicial Council of California CAUSE OF ACTION-Motor Vehicle Code of Civil Procedure 425.12 www.courtinfo.ca.gov PLD-Pl-001 (1) [Rev. January 1, 2007] Westlaw Doc & Form Builder