On May 21, 2024 a
Complaint,Petition
was filed
involving a dispute between
Nunley, Glenn Michael, Ii,
and
Cea, Ernesto,
Cea, Ramon,
for Auto Unlimited (22)
in the District Court of Napa County.
Preview
PLD-PI-001
ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: 277067 FOR COURT USE ONLY
NAME: Shaun J. Bauman, Esq.
FIRM NAME: BAUMAN LAW APLC
STREET ADDRESS: 24003A Ventura Blvd, 2nd Floor
CITY: Calabasas STATE: CA ZIP CODE: 91302
TELEPHONE NO.: 818-285-0222 FAX NO.: 818-285-0224
EMAIL ADDRESS: info@bauman.law
ATTORNEY FOR (name): Glenn Michael Nunley II
SUPERIOR COURT OF CALIFORNIA, COUNTY OF NAPA
STREET ADDRESS: 825 Brown St.
MAILING ADDRESS: Same as above
CITY AND ZIP CODE: Napa, CA 94559
BRANCH NAME: Historic Courthouse
PLAINTIFF: Glenn Michael Nunley II
DEFENDANT: Ernesto Cea; Ramon Cea; and
✖ DOES 1 TO 20
CASE NUMBER:
COMPLAINT—Personal Injury, Property Damage, Wrongful Death
AMENDED (Number):
Type (check all that apply):
✖ MOTOR VEHICLE OTHER (specify):
✖ Property Damage Wrongful Death
✖ Personal Injury Other Damages (specify):
Jurisdiction (check all that apply):
ACTION IS A LIMITED CIVIL CASE (does not exceed $35,000)
Amount demanded does not exceed $10,000
exceeds $10,000
✖ ACTION IS AN UNLIMITED CIVIL CASE (exceeds $35,000)
ACTION IS RECLASSIFIED by this amended complaint
from limited to unlimited
from unlimited to limited
1. Plaintiff (name or names): Glenn Michael Nunley II
alleges causes of action against defendant (name or names):
Ernesto Cea; Ramon Cea; and DOES 1 to 20
2. This pleading, including attachments and exhibits, consists of the following number of pages: Five
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) a public entity (describe):
(4) a minor an adult
(a) for whom a guardian or conservator of the estate or a guardian ad litem has been appointed.
(b) 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 an adult
(a) for whom a guardian or conservator of the estate or a guardian ad litem has been appointed.
(b) other (specify):
(5) other (specify):
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, § 425.12
www.courts.ca.gov
PLD-PI-001 [Rev. January 1, 2024] Damage, Wrongful Death
PLD-PI-001
SHORT TITLE: CASE NUMBER:
Nunley II vs. Cea, 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. except defendant (name): c. except defendant (name):
(1) a business organization, form unknown. (1) a business organization, form unknown.
(2) a corporation. (2) a corporation.
(3) an unincorporated entity (describe): (3) an unincorporated entity (describe):
(4) a public entity (describe): (4) a public entity (describe):
(5) other (specify): (5) other (specify):
b. except defendant (name): d. except defendant (name):
(1) a business organization, form unknown. (1) a business organization, form unknown.
(2) a corporation. (2) a corporation.
(3) an unincorporated entity (describe): (3) an unincorporated entity (describe):
(4) a public entity (describe): (4) a public entity (describe):
(5) other (specify): (5) other (specify):
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. ✖ Doe defendants (specify Doe numbers): 1 to 20 were the agents or employees of other
named defendants and acted within the scope of that agency or employment.
b. ✖ Doe defendants (specify Doe numbers): 1 to 20 are persons whose capacities are unknown to
plaintiff.
7. Defendants who are joined under Code of Civil Procedure section 382 are (names):
8. This court is the proper court because
a. at least one defendant now resides in its jurisdictional area.
b. the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area.
c. ✖ injury to person or damage to personal property occurred in its jurisdictional area.
d. other (specify):
9. Plaintiff is required to comply with a claims statute, and
a. has complied with applicable claims statutes, or
b. is excused from complying because (specify):
PLD-PI-001 [Rev. January 1, 2024] COMPLAINT—Personal Injury, Property Page 2 of 3
Damage, Wrongful Death
PLD-PI-001
SHORT TITLE: CASE NUMBER:
Nunley II vs. Cea, 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. Intentional Tort
d. Products Liability
e. Premises Liability
f. Other (specify):
11. Plaintiff has suffered (check all that apply)
a. ✖ wage loss.
b. ✖ loss of use of property.
c. ✖ hospital and medical expenses.
d. ✖ general damage.
e. ✖ property damage.
f. ✖ loss of earning capacity.
g. ✖ other damage (specify):
Future loss of earnings and future medical expenses.
12. The damages claimed for wrongful death and the relationships of plaintiff to the deceased are
a. listed in Attachment 12.
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) ✖ compensatory damages.
(2) punitive damages.
b. The amount of damages is (in cases for personal injury or wrongful death, you must check (1)):
(1) ✖ 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):
All paragraphs.
Date: 05/21/2024
Shaun J. Bauman, Esq.
(TYPE OR PRINT NAME) (SIGNATURE OF PLAINTIFF OR ATTORNEY)
PLD-PI-001 [Rev. January 1, 2024] 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. Print this form Save this form Clear this form
PLD-PI-001(1)
SHORT TITLE: CASE NUMBER:
Nunley II vs. Cea, et al.
First CAUSE OF ACTION—Motor Vehicle
(number)
ATTACHMENT TO ✔ Complaint Cross - Complaint
(Use a separate cause of action form for each cause of action.)
Plaintiff (name): Glenn Michael Nunley II
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): 07/29/2022
at (place):
Brown St & 3rd St., Napa, CA 94559
MV- 2. DEFENDANTS
a. ✔ The defendants who operated a motor vehicle are (names):
Ernesto Cea and
✔ Does 1 to 20
b. ✔ The defendants who employed the persons who operated a motor vehicle in the course of their employment
are (names):
Ernesto Cea; Ramon Cea; and
✔ Does 1 to 20
c. ✔ The defendants who owned the motor vehicle which was operated with their permission are (names):
Ramon Cea and
✔ Does 1 to 20
d. ✔ The defendants who entrusted the motor vehicle are (names):
Ernesto Cea; Ramon Cea; and
✔ Does 1 to 20
e. ✔ The defendants who were the agents and employees of the other defendants and acted within the scope
of the agency were (names):
Ernesto Cea; Ramon Cea; and
✔ Does 1 to 20
f. ✔ The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are
listed in Attachment MV-2f ✔ as follows:
Ernesto Cea; Ramon Cea; and
✔ Does 1 to 20 Page Four
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-PI-001(1) [Rev. January 1, 2007]
PLD-PI-001(2)
CASE NUMBER:
SHORT TITLE:
Nunley II vs. Cea, et al.
Second CAUSE OF ACTION—General Negligence Page Five
(number)
ATTACHMENT TO ✔ Complaint Cross - Complaint
(Use a separate cause of action form for each cause of action.)
GN-1. Plaintiff (name): Glenn Michael Nunley II
alleges that defendant (name): Ernesto Cea; Ramon Cea; and
✔ Does 1 to 20
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): 07/29/2022
at (place): Brown St & 3rd St., Napa, CA 94559
(description of reasons for liability):
The Defendants owned and operated a motor vehicle. The Defendants owed a duty to those
around them to safely operate said motor vehicle. The Defendants breached this duty when they
suddenly and negligently collided with the Plaintiff's vehicle, causing damage to the Plaintiff's
person and property.
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-PI-001(2) [Rev. January 1, 2007]
Document Filed Date
May 21, 2024
Case Filing Date
May 21, 2024
Category
Auto Unlimited (22)
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PLD-PI-001 ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: 277067 FOR COURT USE ONLY NAME: Shaun J. Bauman, Esq. FIRM NAME: BAUMAN LAW APLC STREET ADDRESS: 24003A Ventura Blvd, 2nd Floor CITY: Calabasas STATE: CA ZIP CODE: 91302 TELEPHONE NO.: 818-285-0222 FAX NO.: 818-285-0224 EMAIL ADDRESS: info@bauman.law ATTORNEY FOR (name): Glenn Michael Nunley II SUPERIOR COURT OF CALIFORNIA, COUNTY OF NAPA STREET ADDRESS: 825 Brown St. MAILING ADDRESS: Same as above CITY AND ZIP CODE: Napa, CA 94559 BRANCH NAME: Historic Courthouse PLAINTIFF: Glenn Michael Nunley II DEFENDANT: Ernesto Cea; Ramon Cea; and ✖ DOES 1 TO 20 CASE NUMBER: COMPLAINT—Personal Injury, Property Damage, Wrongful Death AMENDED (Number): Type (check all that apply): ✖ MOTOR VEHICLE OTHER (specify): ✖ Property Damage Wrongful Death ✖ Personal Injury Other Damages (specify): Jurisdiction (check all that apply): ACTION IS A LIMITED CIVIL CASE (does not exceed $35,000) Amount demanded does not exceed $10,000 exceeds $10,000 ✖ ACTION IS AN UNLIMITED CIVIL CASE (exceeds $35,000) ACTION IS RECLASSIFIED by this amended complaint from limited to unlimited from unlimited to limited 1. Plaintiff (name or names): Glenn Michael Nunley II alleges causes of action against defendant (name or names): Ernesto Cea; Ramon Cea; and DOES 1 to 20 2. This pleading, including attachments and exhibits, consists of the following number of pages: Five 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) a public entity (describe): (4) a minor an adult (a) for whom a guardian or conservator of the estate or a guardian ad litem has been appointed. (b) 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 an adult (a) for whom a guardian or conservator of the estate or a guardian ad litem has been appointed. (b) other (specify): (5) other (specify): 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, § 425.12 www.courts.ca.gov PLD-PI-001 [Rev. January 1, 2024] Damage, Wrongful Death PLD-PI-001 SHORT TITLE: CASE NUMBER: Nunley II vs. Cea, 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. except defendant (name): c. except defendant (name): (1) a business organization, form unknown. (1) a business organization, form unknown. (2) a corporation. (2) a corporation. (3) an unincorporated entity (describe): (3) an unincorporated entity (describe): (4) a public entity (describe): (4) a public entity (describe): (5) other (specify): (5) other (specify): b. except defendant (name): d. except defendant (name): (1) a business organization, form unknown. (1) a business organization, form unknown. (2) a corporation. (2) a corporation. (3) an unincorporated entity (describe): (3) an unincorporated entity (describe): (4) a public entity (describe): (4) a public entity (describe): (5) other (specify): (5) other (specify): 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. ✖ Doe defendants (specify Doe numbers): 1 to 20 were the agents or employees of other named defendants and acted within the scope of that agency or employment. b. ✖ Doe defendants (specify Doe numbers): 1 to 20 are persons whose capacities are unknown to plaintiff. 7. Defendants who are joined under Code of Civil Procedure section 382 are (names): 8. This court is the proper court because a. at least one defendant now resides in its jurisdictional area. b. the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area. c. ✖ injury to person or damage to personal property occurred in its jurisdictional area. d. other (specify): 9. Plaintiff is required to comply with a claims statute, and a. has complied with applicable claims statutes, or b. is excused from complying because (specify): PLD-PI-001 [Rev. January 1, 2024] COMPLAINT—Personal Injury, Property Page 2 of 3 Damage, Wrongful Death PLD-PI-001 SHORT TITLE: CASE NUMBER: Nunley II vs. Cea, 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. Intentional Tort d. Products Liability e. Premises Liability f. Other (specify): 11. Plaintiff has suffered (check all that apply) a. ✖ wage loss. b. ✖ loss of use of property. c. ✖ hospital and medical expenses. d. ✖ general damage. e. ✖ property damage. f. ✖ loss of earning capacity. g. ✖ other damage (specify): Future loss of earnings and future medical expenses. 12. The damages claimed for wrongful death and the relationships of plaintiff to the deceased are a. listed in Attachment 12. 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) ✖ compensatory damages. (2) punitive damages. b. The amount of damages is (in cases for personal injury or wrongful death, you must check (1)): (1) ✖ 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): All paragraphs. Date: 05/21/2024 Shaun J. Bauman, Esq. (TYPE OR PRINT NAME) (SIGNATURE OF PLAINTIFF OR ATTORNEY) PLD-PI-001 [Rev. January 1, 2024] 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. Print this form Save this form Clear this form PLD-PI-001(1) SHORT TITLE: CASE NUMBER: Nunley II vs. Cea, et al. First CAUSE OF ACTION—Motor Vehicle (number) ATTACHMENT TO ✔ Complaint Cross - Complaint (Use a separate cause of action form for each cause of action.) Plaintiff (name): Glenn Michael Nunley II 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): 07/29/2022 at (place): Brown St & 3rd St., Napa, CA 94559 MV- 2. DEFENDANTS a. ✔ The defendants who operated a motor vehicle are (names): Ernesto Cea and ✔ Does 1 to 20 b. ✔ The defendants who employed the persons who operated a motor vehicle in the course of their employment are (names): Ernesto Cea; Ramon Cea; and ✔ Does 1 to 20 c. ✔ The defendants who owned the motor vehicle which was operated with their permission are (names): Ramon Cea and ✔ Does 1 to 20 d. ✔ The defendants who entrusted the motor vehicle are (names): Ernesto Cea; Ramon Cea; and ✔ Does 1 to 20 e. ✔ The defendants who were the agents and employees of the other defendants and acted within the scope of the agency were (names): Ernesto Cea; Ramon Cea; and ✔ Does 1 to 20 f. ✔ The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are listed in Attachment MV-2f ✔ as follows: Ernesto Cea; Ramon Cea; and ✔ Does 1 to 20 Page Four 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-PI-001(1) [Rev. January 1, 2007] PLD-PI-001(2) CASE NUMBER: SHORT TITLE: Nunley II vs. Cea, et al. Second CAUSE OF ACTION—General Negligence Page Five (number) ATTACHMENT TO ✔ Complaint Cross - Complaint (Use a separate cause of action form for each cause of action.) GN-1. Plaintiff (name): Glenn Michael Nunley II alleges that defendant (name): Ernesto Cea; Ramon Cea; and ✔ Does 1 to 20 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): 07/29/2022 at (place): Brown St & 3rd St., Napa, CA 94559 (description of reasons for liability): The Defendants owned and operated a motor vehicle. The Defendants owed a duty to those around them to safely operate said motor vehicle. The Defendants breached this duty when they suddenly and negligently collided with the Plaintiff's vehicle, causing damage to the Plaintiff's person and property. 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-PI-001(2) [Rev. January 1, 2007]