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275307
Simon Esfandi, Esq.
Compass Law Group, LLP
8665 Wilshire Boulevard, Suite 302
Beverly Hills CA 90211
(310) 289-7126 (310) 289-7156
lit@cmplawgroup.com
Kyli Jaye Brown
SAN MATEO
400 County Center
400 County Center
Redwood City, 94063
Southern Branch: Hall of Justice and Records
Kyli Jaye Brown
Carl Wayne Carlile, Kehe Distributors, LLC, and
X 25
X
X
X
Kyli Jaye Brown
Carl Wayne Carlile, Kehe Distributors, LLC, and DOES 1 TO 25
5
Brown v. Carlile, et al.
X Kehe Distributors, LLC
X LLC
X DOES 1 TO 25
X
X DOES 1 TO 10
X DOES 11 TO 25
X
Brown v. Carlile, et al.
X
X
X
X
X
X
X Any and all other general and special damages according to proof at the time of trial.
X
X
X
5(a) and 5(b)
April 9, 2024 Compass Law Group, LLP
Simon Esfandi, Esq.
Brown v. Carlile, et al.
FIRST
X
Kyli Jaye Brown
May 25, 2022
At or near Peninsula Avenue and Channing Road, in San Mateo, CA 94401
X Carl Wayne Carlile and
X 1 5
X
Kehe Distributors, LLC, and
X 6 10
X
Kehe Distributors, LLC, and
X 11 15
X Kehe Distributors, LLC, and
x 16 20
X
Carl Wayne Carlile and
X 1 25
4
Brown v. Carlile, et al.
SECOND 5
X
Kyli Jaye Brown
Carl Wayne Carlile, Kehe Distributors, LLC, and
X 1 25
May 25, 2022
At or near Peninsula Avenue and Channing Road, in San Mateo, CA 94401.
On May 25, 2022, Plaintiff Kyli Brown (hereinafter "Plaintiff) was southbound on Peninsula Avenue and was in the left
turn lane, suddenly Defendant, Carl Wayne Carlile, who was in the course and scope of his employment with
Defendant, Kehe Distributors, LLC (hereinafter collectively "Defendants") was also traveling southbound on Peninsula
Avenue in the number one (1) lane suddenly collided into Plaintiff's vehicle.
Defendants and DOES 1 to 25, negligently owned, maintained, operated and drove the vehicle as to be the legal cause of
Plaintiff's injuries and damages as described below. The negligent operation, maintenance, and driving of Defendants
was the legal cause of Plaintiff's injuries and damages as described herein.
As a result of such negligence, Plaintiff was injured in her health, strength, activity and everyday wellbeing. Plaintiff
sustained injuries to her mind and body, shock, great physical and mental pain and suffering. Said injuries have caused
and continue to cause Plaintiff to suffer damages including, but not limited to, loss of quality of life, in an amount to be
determined according to proof at trial.
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275307 Simon Esfandi, Esq. Compass Law Group, LLP 8665 Wilshire Boulevard, Suite 302 Beverly Hills CA 90211 (310) 289-7126 (310) 289-7156 lit@cmplawgroup.com Kyli Jaye Brown SAN MATEO 400 County Center 400 County Center Redwood City, 94063 Southern Branch: Hall of Justice and Records Kyli Jaye Brown Carl Wayne Carlile, Kehe Distributors, LLC, and X 25 X X X Kyli Jaye Brown Carl Wayne Carlile, Kehe Distributors, LLC, and DOES 1 TO 25 5 Brown v. Carlile, et al. X Kehe Distributors, LLC X LLC X DOES 1 TO 25 X X DOES 1 TO 10 X DOES 11 TO 25 X Brown v. Carlile, et al. X X X X X X X Any and all other general and special damages according to proof at the time of trial. X X X 5(a) and 5(b) April 9, 2024 Compass Law Group, LLP Simon Esfandi, Esq. Brown v. Carlile, et al. FIRST X Kyli Jaye Brown May 25, 2022 At or near Peninsula Avenue and Channing Road, in San Mateo, CA 94401 X Carl Wayne Carlile and X 1 5 X Kehe Distributors, LLC, and X 6 10 X Kehe Distributors, LLC, and X 11 15 X Kehe Distributors, LLC, and x 16 20 X Carl Wayne Carlile and X 1 25 4 Brown v. Carlile, et al. SECOND 5 X Kyli Jaye Brown Carl Wayne Carlile, Kehe Distributors, LLC, and X 1 25 May 25, 2022 At or near Peninsula Avenue and Channing Road, in San Mateo, CA 94401. On May 25, 2022, Plaintiff Kyli Brown (hereinafter "Plaintiff) was southbound on Peninsula Avenue and was in the left turn lane, suddenly Defendant, Carl Wayne Carlile, who was in the course and scope of his employment with Defendant, Kehe Distributors, LLC (hereinafter collectively "Defendants") was also traveling southbound on Peninsula Avenue in the number one (1) lane suddenly collided into Plaintiff's vehicle. Defendants and DOES 1 to 25, negligently owned, maintained, operated and drove the vehicle as to be the legal cause of Plaintiff's injuries and damages as described below. The negligent operation, maintenance, and driving of Defendants was the legal cause of Plaintiff's injuries and damages as described herein. As a result of such negligence, Plaintiff was injured in her health, strength, activity and everyday wellbeing. Plaintiff sustained injuries to her mind and body, shock, great physical and mental pain and suffering. Said injuries have caused and continue to cause Plaintiff to suffer damages including, but not limited to, loss of quality of life, in an amount to be determined according to proof at trial.