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PLD-PI-001
[ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Joseph L. Cagigas, Jr. (SBN 315295)
Albert G. Stoll, Jr., A Law Corporation
235 Montgomery St, Suite 1220
San Francisco CA 94104 ELECTRONICALLY FILED
‘TELEPHONE No: (415) 576-1500 FAXNO. (Optoma): (415) 576-1501 Superior Court of California,
E-MAIL ADDRESS (Optional): jcagigas@stoll-law.com County of Alameda
ATTORNEY FOR (Name): Gustavo Macias Valdez
[SUPERIOR COURT OF CALIFORNIA, COUNTY OF Alameda 04/14/2024 at 02:05:27 PM
STREET ADDRESS: 1221 Oak Street, 3rd and 4th Floors iy: Milagros Cortez,
MAILING ADDRESS: Deputy Clerk
city anp zip cove: Oakland 94612
BRANCH NAME: Administration Building
PLAINTIFF: Gustavo Macias Valdez
DEFENDANT: Bacle G. Taylor, and FBD Vanguard Construction, Inc.;
[4] DOES 1 To 10
COMPLAINT—Personal Injury, Property Damage, Wrongful Death CASE NUMBER:
[| AMENDED (Number): 2407071 426
Type (check all that apply):
[7] MOTOR VEHICLE [J OTHER (specify):
[] Property Damage [__] Wrongful Death
7] Personal Injury Other Damages (specify):
Jurisdiction (check ail that apply):
[-_] ACTION IS A LIMITED CIVIL CASE
Amount demanded [_] does not exceed $10,000
exceeds $10,000, but does not exceed $25,000
[¥] ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000)
[J ACTION IS RECLASSIFIED by this amended complaint
LJ from limited to unlimited
[) from unlimited to limited
Plaintiff (name or names): Gustavo Macias Valdez
alleges causes of action against defendant (name or names):
Bacle G. Taylor, and FBD Vanguard Construction, Inc.
2. This pleading, including attachments and exhibits, consists of the following number of pages: Four
3. Each plaintiff named above is a competent adult
a. [__] except plaintiff (name):
(1) [) a corporation qualified to do business in California
(2) [__] an unincorporated entity (describe):
(3) L__] a public entity (describe):
(4) [_] a minor [J an adult
(a) [__] for whom a guardian or conservator of the estate or a guardian ad litem has been appointed
(b) [J other (specify):
(5) [] other (specify):
b. [__] except plaintiff (name):
(1) [__] a corporation qualified to do business in California
(2) [-] an unincorporated entity (describe):
(3) [-_] a public entity (describe):
(4) [) a minor [J an adult
(a) [J for whom a guardian or conservator of the estate or a guardian ad litem has been appointed
(b) [__] other (specify):
(5) [_] other (specify):
[J Information about additional plaintiffs who are not competent adults is shown in Attachment 3.
Page 1 of 3
Form Approved for Optional Use
Judicial Council of California COMPLAINT—Personal Injury, Property Code of Civil Procedure, § 426.12
www.courts.ca.gov
PLD-PI-001 (Rev. January 1, 2007] Damage, Wrongful Death
PLD-PI-001
SHORT TITLE: CASE NUMBER:
Macias Valdez v. Taylor et al
4. [_] 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. [V7] except defendant (name): FBD Vanguard Construction, Inc. ¢. [—] except defendant (name):
(1) [7] a business organization, form unknown (1) [_] a business organization, form unknown
(2) [__] a corporation (2) [__] a corporation
(3) [) an unincorporated entity (describe): (3) [J an unincorporated entity (describe):
(4) [] a public entity (describe): (4) () a public entity (describe):
(5) [J other (specify): (5) [J other (specify):
b. [__] except defendant (name): d. [__] except defendant (name):
(1) [_] a business organization, form unknown (1) [J a business organization, form unknown
(2) [__] a corporation (2) [__] a corporation
(3) [] an unincorporated entity (describe): (3) [j an unincorporated entity (describe):
(4) [J a public entity (describe): (4) [_] a public entity (describe):
(5) [J other (specify): (5) [_] other (specify):
[J Information about additional defendants who are not natural persons is contained in Attachment 5.
The true names of defendants sued as Does are unknown to plaintiff.
a. [¥ | Doe defendants (specify Doe numbers): 1 to 5 were the agents or employees of other
named defendants and acted within the Scope of that agency or employment.
b. [7] Doe defendants (specify Doe numbers): 6 to 10 are persons whose capacities are unknown to
plaintiff.
7. [__]Defendants who are joined under Code of Civil Procedure section 382 are (names):
This court is the proper court because
. [__] atleast one defendant now resides in its jurisdictional area.
the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area.
. [__] injury to person or damage to personal property occurred in its jurisdictional area.
. [_] other (specify):
9. [7] Plaintiff is required to comply with a claims statute, and
a. [__] has complied with applicable claims statutes, or
b. [1 is excused from complying because (specify):
PLD-PI-O01 (Rev. January 1, 2007] COMPLAINT—Personal Injury, Property Page 2 of 3
Damage, Wrongful Death
PLD-PI-001
SHORT TITLE: CASE NUMBER,
Macias Valdez v. Taylor et al
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 [¥] Motor Vehicle
b. [-_] General Negligence
c., - [J Intentional Tort
d | [_] Products Liability
e. [J Premises Liability
f. [) Other (specify):
1 Plaintiff has suffered
a. [¥] wage loss
b. [7] loss of use of property
c. [¥] hospital and medical expenses
d. [¥] general damage
e. [¥_] property damage
f. [YJ loss of earning capacity
g . [_] other damage (specify):
12.[_] The damages claimed for wrongful death and the relationships of plaintiff to the deceased are
a. [[] listed in Attachment12.
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) [4] compensatory damages
(2) [-] punitive damages
The amount of damages is (in cases for personal injury or wrongful death, you must check (1)):
(1) [4] according to proof
(2) [__] in the amount of: $
15. [__]The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers):
Date: April 11, 2024
Joseph L. Cagigas, Jr., Esq.
(TYPE OR PRINT NAME)
Cy Laer ce
ZSIGNATURE OF @LAINTIF® OR ATTORNEY)
PLD-PI-001 (Rev. January 1, 2007] COMPLAINT—Personal Injury, Property Page 3 of 3
Damage, Wrongful Death
PLD-PI-001(1)
SHORT TITLE: CASE NUMBER;
Macias Valdez v. Taylor et al
First CAUSE OF ACTION—Wotor Vehicle
(number)
ATTACHMENTTO [¥_] Complaint [_] Cross
- Complaint
(Use a separate cause of action form for each cause of action.)
Plaintiff (name): Gustavo Macias Valdez
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):01/11/2024
Weta 680 southbound near Andrade Rd, in Sunol, California
MV- 2. DEFENDANTS
a. [% ] The defendants who operated a motor vehicle are (names):
Bacle G. Taylor, and FBD Vanguard Construction, Inc.;
(%] Does 1 to 10
. LY] The defendants who employed the persons who operated a motor vehicle in the course of their employment
are (names):
Bacle G. Taylor, and FBD Vanguard Construction, Inc.;
(¥] Does 1 to 10
7 iv] The defendants who owned the motor vehicle which was operated with their permission are (names):
Bacle G. Taylor, and FBD Vanguard Construction, Inc.;
(¥] Does 1 to 10
“ The defendants who entrusted the motor vehicle are (names):
Bacle G. Taylor, and FBD Vanguard Construction, Inc.;
(¥] Does 1 to 10
[4] The defendants who were the agents and employees of the other defendants and acted within the scope
of the agency were (names):
Bacle G. Te aylor, and FB Vanguard Construction, Inc.;
[¥] Does 1 to 10
The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are
C4 listed in Attachment MV-2f [___] as follows:
[| Does to Page 4
Page 1 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]
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PLD-PI-001 [ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Joseph L. Cagigas, Jr. (SBN 315295) Albert G. Stoll, Jr., A Law Corporation 235 Montgomery St, Suite 1220 San Francisco CA 94104 ELECTRONICALLY FILED ‘TELEPHONE No: (415) 576-1500 FAXNO. (Optoma): (415) 576-1501 Superior Court of California, E-MAIL ADDRESS (Optional): jcagigas@stoll-law.com County of Alameda ATTORNEY FOR (Name): Gustavo Macias Valdez [SUPERIOR COURT OF CALIFORNIA, COUNTY OF Alameda 04/14/2024 at 02:05:27 PM STREET ADDRESS: 1221 Oak Street, 3rd and 4th Floors iy: Milagros Cortez, MAILING ADDRESS: Deputy Clerk city anp zip cove: Oakland 94612 BRANCH NAME: Administration Building PLAINTIFF: Gustavo Macias Valdez DEFENDANT: Bacle G. Taylor, and FBD Vanguard Construction, Inc.; [4] DOES 1 To 10 COMPLAINT—Personal Injury, Property Damage, Wrongful Death CASE NUMBER: [| AMENDED (Number): 2407071 426 Type (check all that apply): [7] MOTOR VEHICLE [J OTHER (specify): [] Property Damage [__] Wrongful Death 7] Personal Injury Other Damages (specify): Jurisdiction (check ail that apply): [-_] ACTION IS A LIMITED CIVIL CASE Amount demanded [_] does not exceed $10,000 exceeds $10,000, but does not exceed $25,000 [¥] ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000) [J ACTION IS RECLASSIFIED by this amended complaint LJ from limited to unlimited [) from unlimited to limited Plaintiff (name or names): Gustavo Macias Valdez alleges causes of action against defendant (name or names): Bacle G. Taylor, and FBD Vanguard Construction, Inc. 2. This pleading, including attachments and exhibits, consists of the following number of pages: Four 3. Each plaintiff named above is a competent adult a. [__] except plaintiff (name): (1) [) a corporation qualified to do business in California (2) [__] an unincorporated entity (describe): (3) L__] a public entity (describe): (4) [_] a minor [J an adult (a) [__] for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b) [J other (specify): (5) [] other (specify): b. [__] except plaintiff (name): (1) [__] a corporation qualified to do business in California (2) [-] an unincorporated entity (describe): (3) [-_] a public entity (describe): (4) [) a minor [J an adult (a) [J for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b) [__] other (specify): (5) [_] other (specify): [J Information about additional plaintiffs who are not competent adults is shown in Attachment 3. Page 1 of 3 Form Approved for Optional Use Judicial Council of California COMPLAINT—Personal Injury, Property Code of Civil Procedure, § 426.12 www.courts.ca.gov PLD-PI-001 (Rev. January 1, 2007] Damage, Wrongful Death PLD-PI-001 SHORT TITLE: CASE NUMBER: Macias Valdez v. Taylor et al 4. [_] 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. [V7] except defendant (name): FBD Vanguard Construction, Inc. ¢. [—] except defendant (name): (1) [7] a business organization, form unknown (1) [_] a business organization, form unknown (2) [__] a corporation (2) [__] a corporation (3) [) an unincorporated entity (describe): (3) [J an unincorporated entity (describe): (4) [] a public entity (describe): (4) () a public entity (describe): (5) [J other (specify): (5) [J other (specify): b. [__] except defendant (name): d. [__] except defendant (name): (1) [_] a business organization, form unknown (1) [J a business organization, form unknown (2) [__] a corporation (2) [__] a corporation (3) [] an unincorporated entity (describe): (3) [j an unincorporated entity (describe): (4) [J a public entity (describe): (4) [_] a public entity (describe): (5) [J other (specify): (5) [_] other (specify): [J Information about additional defendants who are not natural persons is contained in Attachment 5. The true names of defendants sued as Does are unknown to plaintiff. a. [¥ | Doe defendants (specify Doe numbers): 1 to 5 were the agents or employees of other named defendants and acted within the Scope of that agency or employment. b. [7] Doe defendants (specify Doe numbers): 6 to 10 are persons whose capacities are unknown to plaintiff. 7. [__]Defendants who are joined under Code of Civil Procedure section 382 are (names): This court is the proper court because . [__] atleast one defendant now resides in its jurisdictional area. the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area. . [__] injury to person or damage to personal property occurred in its jurisdictional area. . [_] other (specify): 9. [7] Plaintiff is required to comply with a claims statute, and a. [__] has complied with applicable claims statutes, or b. [1 is excused from complying because (specify): PLD-PI-O01 (Rev. January 1, 2007] COMPLAINT—Personal Injury, Property Page 2 of 3 Damage, Wrongful Death PLD-PI-001 SHORT TITLE: CASE NUMBER, Macias Valdez v. Taylor et al 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 [¥] Motor Vehicle b. [-_] General Negligence c., - [J Intentional Tort d | [_] Products Liability e. [J Premises Liability f. [) Other (specify): 1 Plaintiff has suffered a. [¥] wage loss b. [7] loss of use of property c. [¥] hospital and medical expenses d. [¥] general damage e. [¥_] property damage f. [YJ loss of earning capacity g . [_] other damage (specify): 12.[_] The damages claimed for wrongful death and the relationships of plaintiff to the deceased are a. [[] listed in Attachment12. 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) [4] compensatory damages (2) [-] punitive damages The amount of damages is (in cases for personal injury or wrongful death, you must check (1)): (1) [4] according to proof (2) [__] in the amount of: $ 15. [__]The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers): Date: April 11, 2024 Joseph L. Cagigas, Jr., Esq. (TYPE OR PRINT NAME) Cy Laer ce ZSIGNATURE OF @LAINTIF® OR ATTORNEY) PLD-PI-001 (Rev. January 1, 2007] COMPLAINT—Personal Injury, Property Page 3 of 3 Damage, Wrongful Death PLD-PI-001(1) SHORT TITLE: CASE NUMBER; Macias Valdez v. Taylor et al First CAUSE OF ACTION—Wotor Vehicle (number) ATTACHMENTTO [¥_] Complaint [_] Cross - Complaint (Use a separate cause of action form for each cause of action.) Plaintiff (name): Gustavo Macias Valdez 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):01/11/2024 Weta 680 southbound near Andrade Rd, in Sunol, California MV- 2. DEFENDANTS a. [% ] The defendants who operated a motor vehicle are (names): Bacle G. Taylor, and FBD Vanguard Construction, Inc.; (%] Does 1 to 10 . LY] The defendants who employed the persons who operated a motor vehicle in the course of their employment are (names): Bacle G. Taylor, and FBD Vanguard Construction, Inc.; (¥] Does 1 to 10 7 iv] The defendants who owned the motor vehicle which was operated with their permission are (names): Bacle G. Taylor, and FBD Vanguard Construction, Inc.; (¥] Does 1 to 10 “ The defendants who entrusted the motor vehicle are (names): Bacle G. Taylor, and FBD Vanguard Construction, Inc.; (¥] Does 1 to 10 [4] The defendants who were the agents and employees of the other defendants and acted within the scope of the agency were (names): Bacle G. Te aylor, and FB Vanguard Construction, Inc.; [¥] Does 1 to 10 The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are C4 listed in Attachment MV-2f [___] as follows: [| Does to Page 4 Page 1 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]