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PLD-Pl-001
ATTORNEY OR PARTY V\,1THOUT ATTORNEY STATE BAR NUMBER: FOR COURT USE ONLY
NAME: James J. Romag #241887 I Ashley N. Grindstaff#300964 / Daniel Ojeda #170539
FIRM NAME BROWN, KORO & ROMAG, LLP
STREET ADDRESS: 6101 Bollinger Canyon Road, Suite 322
cITY San Ramon STATE: CA zIP coDE: 94583 ELECTRONICALLY
TELEPHONE NO.. 925-830-4878 FAX NO.: 925-830-4879
EMAILADDREss jim@russbrown.com / ashleyg@russbrown.com / daniel@russbrown.com
FILED
Superior Court of California,
ATTORNEY FOR (name/: Plaintiff, Johnny D. Anderson County of San Francisco
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO
STREET ADâ–¡RESS: 400 McAllister Street
06/18/2024
Clerk of the Court
MAILING ADDRESS: 400 McAllister Street BY: JAMES FORONDA
CITY AND ZIP CODE: San Francisco, CA 94102 Deputy Clerk
BRANCH NAME: Civic Center Courthouse
PLAINTIFF: Johnny D. Anderson
DEFENDANT: Uber Technologies, Inc.; Rasier, LLC; Rasier-CA, LLC; Jiro K. Yanagitsuru; et al.
[KJ DOES 1 TO 100, Inclusive
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 [KJ Other Damages (specify):Wage Loss
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 CGC-24-615513
[KJ ACTION IS AN UNLIMITED CIVIL CASE (exceeds $35,000)
CJ ACTION IS RECLASSIFIED by this amended complaint
D from limited to unlimited
CJ from unlimited to limited
1. Plaintiff (name or names): Johnny D. Anderson
alleges causes of action against defendant (name or names):
Uber Technologies, Inc.; Rasier, LLC; Rasier-CA, LLC; Jira K. Yanagitsuru; and DOES 1 to 100, Inclusive.
2. This pleading, including attachments and exhibits, consists of the following number of pages: 5
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 flas been appointed.
(b) CJ other(specify):
(5) D other (specify):
b. CJ except plaintiff (name):
(1) D a corporation qualified to do business in California.
(2) D an unincorporated entity (describe):
(3) CJ 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):
CJ Information about additional plaintiffs who are not competent adults is shown in Attachment 3.
Page 1 of 3
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 [Rev. January 1. 2024] Damage, Wrongful Death
PLD-Pl-001
SHORT TITLE: CASE NUMBER:
Anderson v. Uber Technologies, Inc., 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. [KJ except defendant (name): Uber Technologies, Inc. c. [KJ except defendant (name): Rasier-CA, LLC
(1) D
a business organization, form unknown. (1) D
a business organization, form unknown.
(2) [KJ a corporation. (2) D a corporation.
(3) D an unincorporated entity (describe): (3) [KJ an unincorporated entity (describe):
Limited Liability Company
(4) D a public entity (describe): (4) D a public entity (describe):
(5) D other (specify): (5) D other (specify):
b. [KJ except defendant (name): Rasier, LLC 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) [KJ an unincorporated entity (describe): (3) D an unincorporated entity (describe):
Limited Liability Company
(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. [KJ Doe defendants (specify Doe numbers): 1 to 50 were the agents or employees of other
named defendants and acted within the scope of that agency or employment.
b. [KJ Doe defendants (specify Doe numbers): 51 to 100 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. [KJ 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. D 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
SHORT TITLE: CASE NUM BER:
Anderson v. Uber Technologies , Inc., 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. [KJ Motor Vehicle
b. [KJ General Negligence
c. D Intentional Tort
d. D Products Liability
e. D Premises Liability
f. D Other (specify):
11 Plaintiff has suffered (check all that apply)
a. [KJ wage loss.
b. [KJ loss of use of property.
c. [KJ hospital and medical expenses.
d. [KJ general damage.
e. [KJ property damage.
f. [KJ loss of earning capacity.
g. [KJ other damage (specify):
Past and future loss of earnings , employment benefits , loss of earning capacity, loss of ability to provide household
services and attendant care damages, loss of use damages, prejudgment interest according to Civil Code section 3291 .
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.
b. The amount of damages is (in cases for personal injury or wrongful death, you must check (1)):
(1) w 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: 06/18/2024
James J. Romag, 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 (1)
SHORT TITLE: CASE NUMBER:
Anderson v. Uber Technologies, Inc., et al.
FIRST CAUSE OF ACTION-Motor Vehicle
(number)
ATTACHMENT TO [ZJ Complaint LJ Cross - Complaint
(Use a separate cause of action form for each cause of action.)
Plaintiff (name).· JOHNNY D. ANDERSON
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): 07/31/2022
at (place):
approximately 8: 12 p.111., at or near the intersection of SR-82 and 23rd Avenue, in the City and
County of San Mateo, State of California.
MV- 2. DEFENDANTS
a. [ZJ The defendants who operated a motor vehicle are (names):
JIRO K. YANAGITSURU
W Does to 100 Inclusive
b. [ZJ The defendants who employed the persons who operated a motor vehicle in the course of their employment
are (names):
UBER TECHNOLOGIES, INC.; RASIER, LLC; RASIER-CA, LLC
W Does to l 00 Jnclusive
c. [ZJ The defendants who owned the motor vehicle which was operated with their permission are (names):
JIRO K. YANAGITSURU
W Does _ _ _ _ __ to 100 Inclusive
d. [ZJ The defendants who entrusted the motor vehicle are (names):
JIRO K. YANAGITSURU; UBER TECHNOLOGIES, INC.; RASIER, LLC; RASIER-CA,
LLC
W Does to 100 Inclusive
e. [ZJ The defendants who were the agents and employees of the other defendants and acted within the scope
of the agency were (names):
JJRO K. YANAGITSURU
[ZJ Does _ _ _ __ _ to 100 Inclusive
f. [ZJ The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are
D listed in Attachment MV-2f [ZJ as follows:
DOES 1 TO 100 INCLUSIVE are liable to Plaintiff, the reasons therefore and the nature
and extent of which have not yet been ascertained.
[ZJ Does to 100 Jnclusive Page _ _4_ _
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]
American LegalNet, Inc.
www. Farms Work/low.com
PLD-Pl-001 (2)
CASE NUMBER:
SHORT TITLE:
Anderson v. Uber Technologies, Inc., et al.
SECOND CAUSE OF ACTION-General Negligence Page __5_ _
{number)
ATTACHMENT TO [X] Complaint CJ Cross • Complaint
(Use a separate cause of action form for each cause of action.)
GN-1. Plaintiff (name): JOHNNY D. ANDERSON
allegesthatdefendant(nameJ: UBER TECHNOLOGIES, INC.; RASIER, LLC; RASIER-CA, LLC;
JIRO K. YANAGITSURU; and
[XJ Does 1 to 100, 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); 07/31/2022
at (place): approximately 8: 12 p.m., at or near the intersection of SR-82 and 23rd Avenue,
in the City and County of San Mateo, State of California.
(description of reasons for liability):
The Defendants, JIRO K. YANAGITSURU, and DOES 1 through 50, Inclusive, during the
course and scope of their employment negligently and carelessly entrusted, managed,
maintained, supervised the operation of, drove and operated their motor vehicle so as to
cause an accident with a 2016 Kawasaki motorcycle being operated and occupied by
Plaintiff.
That Defendants, UBER TECHNOLOGIES, INC.; RASIER, LLC; RASIER-CA, LLC; and
DOES 51 through 100, Inclusive, negligently employed and dispatched their ridesharing
customers to Defendants, JIRO K. YANAGITSURU, and DOES 1 through 50, Inclusive, and
negligently and carelessly employed, entrusted and supervised the operation of said vehicle
during the course and scope of Defendants, JIRO K. YANAGITSURU, and DOES 1 through
50's, employment with Defendants, UBER TECHNOLOGIES, INC.; RASIER, LLC;
RASIER-CA, LLC: and DOES 51 through 100, Inclusive, and negligently hired, assigned,
managed and/or retained said Defendants.
That as a direct and proximate result of the negligence of said Defendants, and each of them,
and by reason of the collision thereby caused, Plaintiff sustained bodily injuries and
damages, including general damages, in a sum that is unknown to him; medical and
attendant care expenses in an amount not yet fully ascertainable; property damage,
including loss of use damages, in- an amount not yet fully ascertainable; and loss of earnings,
loss of earning capacity, and loss ·of ability to provide household services in an amount not
yet fully ascertainable.
Page1 of1
Fonn Approved for Optiooal Use Code of CM! Procedure 425.12
Judicial Councll of CaBfomla CAUSE OF ACTION-General Negligence www.ccutfinfo.ca.gov
PLD-Pl--001(2) [Rev. January 1, 2007]
American LegalNet, Inc.
www.FonnsWondlow.com
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PLD-Pl-001 ATTORNEY OR PARTY V\,1THOUT ATTORNEY STATE BAR NUMBER: FOR COURT USE ONLY NAME: James J. Romag #241887 I Ashley N. Grindstaff#300964 / Daniel Ojeda #170539 FIRM NAME BROWN, KORO & ROMAG, LLP STREET ADDRESS: 6101 Bollinger Canyon Road, Suite 322 cITY San Ramon STATE: CA zIP coDE: 94583 ELECTRONICALLY TELEPHONE NO.. 925-830-4878 FAX NO.: 925-830-4879 EMAILADDREss jim@russbrown.com / ashleyg@russbrown.com / daniel@russbrown.com FILED Superior Court of California, ATTORNEY FOR (name/: Plaintiff, Johnny D. Anderson County of San Francisco SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO STREET AD□RESS: 400 McAllister Street 06/18/2024 Clerk of the Court MAILING ADDRESS: 400 McAllister Street BY: JAMES FORONDA CITY AND ZIP CODE: San Francisco, CA 94102 Deputy Clerk BRANCH NAME: Civic Center Courthouse PLAINTIFF: Johnny D. Anderson DEFENDANT: Uber Technologies, Inc.; Rasier, LLC; Rasier-CA, LLC; Jiro K. Yanagitsuru; et al. [KJ DOES 1 TO 100, Inclusive 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 [KJ Other Damages (specify):Wage Loss 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 CGC-24-615513 [KJ ACTION IS AN UNLIMITED CIVIL CASE (exceeds $35,000) CJ ACTION IS RECLASSIFIED by this amended complaint D from limited to unlimited CJ from unlimited to limited 1. Plaintiff (name or names): Johnny D. Anderson alleges causes of action against defendant (name or names): Uber Technologies, Inc.; Rasier, LLC; Rasier-CA, LLC; Jira K. Yanagitsuru; and DOES 1 to 100, Inclusive. 2. This pleading, including attachments and exhibits, consists of the following number of pages: 5 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 flas been appointed. (b) CJ other(specify): (5) D other (specify): b. CJ except plaintiff (name): (1) D a corporation qualified to do business in California. (2) D an unincorporated entity (describe): (3) CJ 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): CJ Information about additional plaintiffs who are not competent adults is shown in Attachment 3. Page 1 of 3 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 [Rev. January 1. 2024] Damage, Wrongful Death PLD-Pl-001 SHORT TITLE: CASE NUMBER: Anderson v. Uber Technologies, Inc., 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. [KJ except defendant (name): Uber Technologies, Inc. c. [KJ except defendant (name): Rasier-CA, LLC (1) D a business organization, form unknown. (1) D a business organization, form unknown. (2) [KJ a corporation. (2) D a corporation. (3) D an unincorporated entity (describe): (3) [KJ an unincorporated entity (describe): Limited Liability Company (4) D a public entity (describe): (4) D a public entity (describe): (5) D other (specify): (5) D other (specify): b. [KJ except defendant (name): Rasier, LLC 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) [KJ an unincorporated entity (describe): (3) D an unincorporated entity (describe): Limited Liability Company (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. [KJ Doe defendants (specify Doe numbers): 1 to 50 were the agents or employees of other named defendants and acted within the scope of that agency or employment. b. [KJ Doe defendants (specify Doe numbers): 51 to 100 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. [KJ 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. D 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 SHORT TITLE: CASE NUM BER: Anderson v. Uber Technologies , Inc., 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. [KJ Motor Vehicle b. [KJ General Negligence c. D Intentional Tort d. D Products Liability e. D Premises Liability f. D Other (specify): 11 Plaintiff has suffered (check all that apply) a. [KJ wage loss. b. [KJ loss of use of property. c. [KJ hospital and medical expenses. d. [KJ general damage. e. [KJ property damage. f. [KJ loss of earning capacity. g. [KJ other damage (specify): Past and future loss of earnings , employment benefits , loss of earning capacity, loss of ability to provide household services and attendant care damages, loss of use damages, prejudgment interest according to Civil Code section 3291 . 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. b. The amount of damages is (in cases for personal injury or wrongful death, you must check (1)): (1) w 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: 06/18/2024 James J. Romag, 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 (1) SHORT TITLE: CASE NUMBER: Anderson v. Uber Technologies, Inc., et al. FIRST CAUSE OF ACTION-Motor Vehicle (number) ATTACHMENT TO [ZJ Complaint LJ Cross - Complaint (Use a separate cause of action form for each cause of action.) Plaintiff (name).· JOHNNY D. ANDERSON 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): 07/31/2022 at (place): approximately 8: 12 p.111., at or near the intersection of SR-82 and 23rd Avenue, in the City and County of San Mateo, State of California. MV- 2. DEFENDANTS a. [ZJ The defendants who operated a motor vehicle are (names): JIRO K. YANAGITSURU W Does to 100 Inclusive b. [ZJ The defendants who employed the persons who operated a motor vehicle in the course of their employment are (names): UBER TECHNOLOGIES, INC.; RASIER, LLC; RASIER-CA, LLC W Does to l 00 Jnclusive c. [ZJ The defendants who owned the motor vehicle which was operated with their permission are (names): JIRO K. YANAGITSURU W Does _ _ _ _ __ to 100 Inclusive d. [ZJ The defendants who entrusted the motor vehicle are (names): JIRO K. YANAGITSURU; UBER TECHNOLOGIES, INC.; RASIER, LLC; RASIER-CA, LLC W Does to 100 Inclusive e. [ZJ The defendants who were the agents and employees of the other defendants and acted within the scope of the agency were (names): JJRO K. YANAGITSURU [ZJ Does _ _ _ __ _ to 100 Inclusive f. [ZJ The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are D listed in Attachment MV-2f [ZJ as follows: DOES 1 TO 100 INCLUSIVE are liable to Plaintiff, the reasons therefore and the nature and extent of which have not yet been ascertained. [ZJ Does to 100 Jnclusive Page _ _4_ _ 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] American LegalNet, Inc. www. Farms Work/low.com PLD-Pl-001 (2) CASE NUMBER: SHORT TITLE: Anderson v. Uber Technologies, Inc., et al. SECOND CAUSE OF ACTION-General Negligence Page __5_ _ {number) ATTACHMENT TO [X] Complaint CJ Cross • Complaint (Use a separate cause of action form for each cause of action.) GN-1. Plaintiff (name): JOHNNY D. ANDERSON allegesthatdefendant(nameJ: UBER TECHNOLOGIES, INC.; RASIER, LLC; RASIER-CA, LLC; JIRO K. YANAGITSURU; and [XJ Does 1 to 100, 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); 07/31/2022 at (place): approximately 8: 12 p.m., at or near the intersection of SR-82 and 23rd Avenue, in the City and County of San Mateo, State of California. (description of reasons for liability): The Defendants, JIRO K. YANAGITSURU, and DOES 1 through 50, Inclusive, during the course and scope of their employment negligently and carelessly entrusted, managed, maintained, supervised the operation of, drove and operated their motor vehicle so as to cause an accident with a 2016 Kawasaki motorcycle being operated and occupied by Plaintiff. That Defendants, UBER TECHNOLOGIES, INC.; RASIER, LLC; RASIER-CA, LLC; and DOES 51 through 100, Inclusive, negligently employed and dispatched their ridesharing customers to Defendants, JIRO K. YANAGITSURU, and DOES 1 through 50, Inclusive, and negligently and carelessly employed, entrusted and supervised the operation of said vehicle during the course and scope of Defendants, JIRO K. YANAGITSURU, and DOES 1 through 50's, employment with Defendants, UBER TECHNOLOGIES, INC.; RASIER, LLC; RASIER-CA, LLC: and DOES 51 through 100, Inclusive, and negligently hired, assigned, managed and/or retained said Defendants. That as a direct and proximate result of the negligence of said Defendants, and each of them, and by reason of the collision thereby caused, Plaintiff sustained bodily injuries and damages, including general damages, in a sum that is unknown to him; medical and attendant care expenses in an amount not yet fully ascertainable; property damage, including loss of use damages, in- an amount not yet fully ascertainable; and loss of earnings, loss of earning capacity, and loss ·of ability to provide household services in an amount not yet fully ascertainable. Page1 of1 Fonn Approved for Optiooal Use Code of CM! Procedure 425.12 Judicial Councll of CaBfomla CAUSE OF ACTION-General Negligence www.ccutfinfo.ca.gov PLD-Pl--001(2) [Rev. January 1, 2007] American LegalNet, Inc. www.FonnsWondlow.com