Preview
MUA
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
May-03-2010 3:52 pm
Case Number: CGC-10-497688
Filing Date: Apr-30-2010 3:49
Juke Box: 001 Image: 02838631
CROSS COMPLAINT
INFINITY INSURANCE COMPANY VS. BRANDI GREGG KEISER et al
001002838631
Instructions:
Please place this sheet on top of the document to be scanned.PLD-PI-002
[ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, oy ‘number, and address):
Narrmayet Taonus, In Pro Per
3016 8th Street
Sacramento, CA 95817
teLePHone no: (916) 912-5605
E-MAIL ADDRESS (Optional):
ATTORNEY FOR (Name; In Pro Per
FAX NO. (Optional):
FOR COURT USE ONLY
Qu 4
fOr Court of | i
Caan RY at
Name OF court. San Francisco County Superior Court
street appress: 400 McAllister, Room 103
MAILING ADDRESS:
crrvanpz cone: San Francisco, CA 94102
pranch Name, San Francsico District-Limited
SHORT TITLE: INFINITY V. KEISER
CROSS-COMPLAINANT: NARRMAYET TAONUS
CROSS-DEFENDANT: BRANDI GREGG KEISER
() does 1 To 10
CROSS-COMPLAINT-Personal Injury, Property Damage, Wrongful Death
() AMENDED (Number :
Causes of Action (check all that apply) :
[Z) Apportionment of Fault GQ) Declaratory Relief
[(Q) Indemnification (C) Other (specify :
Jurisdiction (check all that apply):
[(K) ACTION IS A LIMITED CIVIL CASE ($25,000 or less}
CJ ACTION Is AN UNLIMITED CIVIL CASE (exceeds $25,000)
tt Cis [CQ isnot reclassified as unlimited by this cross-complaint
CASE NUMBER:
CGC-10-497688
1. CROSS-COMPLAINANT (name): NARRMAYET TAONUS
alleges causes of action against CROSS-DEFENDANT (name) :
BRANDI GREGG KEISER
2. This pleading, including exhibits and attachments, consists of the following number of pages: 3
3. Each cross-complainant named above is a competent adult
a. [LJ except cross-complainant (name) :
(1) (2) a comporation qualified to do business in California
(2) (_] an unincorporated entity (describe) :
(3) QO a public entity (describe) :
(4) CJ aminor (2) an adult
(a) (2) for whom a guardian or conservator of the estate or a guardian ad litem has been appointed
(b) (2) other (specify) :
(5) C2) other (specify) :
(2) Information about additional cross-complainants who are not competent adults is contained in
Cross-Complaint-Attachment 3.
Page 1 of3
Form Approved for Optional Use
Judicial Counc of Califor
PLD-PI-002 [Rev. January 1, 2007)
CROSS-COMPLAINT-Personal Injury,
Property Damage, Wrongful Death
Coda of Cwil Procedure, § 425.12C oom PLD-PI-002
SHORT TITLE: fASE NUMBER:
INFINITY V. KEISER CGC-10-497688
4. Each cross-defendant named above is a natural person
a. (C) except cross-defendant (name) : C2 except cross-defendant (name):
(1) () a business organization, form unknown (1) (CJ a business organization, form unknown
(2) CQ a corporation (2) LQ a corporation
(3) () an unincorporated entity (describe) : (3) (LQ an unincorporated entity (describe) :
(4) (2) a public entity (describe) : (4) C2 a public entity (describe) ;
(5) (Cy other (specify) : (5) (Ly other (specify) :
(C1 Information about additional cross-defendants who are not natural persons is contained in Cross-Complaint-
Attachment 4.
5. The true names and capacities of cross-defendants sued as Does are unknown to cross-complainant.
6. [LJ] Cross-complainant is required to comply with a claims statute, and
a. [) has complied with applicable claims statutes, or
b. [Q) is excused from complying because (specify) :
7. (&) Eirst Cause of Action-Indemnification
(NUMBER)
a. Cross-defendants were the agents, employees, co-venturers, partners, or in some manner agents or principals, or both,
for each other and were acting within the course and scope of their agency or employment.
b. The principal action alleges, among other things, conduct entitling plaintiff to compensatory damages against me. |
contend that | am not tiable for events and occurrences described in plaintiffs complaint.
c, If lam found in some manner responsible to plaintiff or to anyone else as a result of the incidents and occurrences
described in plaintiffs complaint, my liability would be based solely upon a derivative form of liability not resulting from my
conduct, but only from an obligation imposed upon me by law; therefore, { would be entitled to complete indemnity from
each cross-defendant.
S id -
8. [J Secon WET Cause of Action-Apportionment of Fault
a. Each cross-defendant was responsible, in whole or in part, for the injuries, if any, suffered by plaintiff.
b. If am judged liable to plaintiff, each cross-defendant should be required: (1) to pay a share of plaintiffs judgment which is
in proportion to the comparative negligence of that cross-defendant in causing plaintiffs damages; and (2) to reimburse me
for any payments | make to plaintiff in excess of my proportional! share of all cross-defendants' negligence.
PLD-P1002 (Rev. January 1, 2007] CROSS-COMPLAINT-Personal Injury, Page 2 of 3
Estat RWS" Property Damage, Wrongful DeathPLD-PI-002
SHORT TITLE: KR SE NUMBER:
L INFINITY V. KEISER 'GC-10-497688
9 (J WER Cause of Action-Declaratory Relief
An actual controversy exists between the parties concerning their respective rights and duties because cross-complainant
contends and cross-defendant disputes oO as specified in Cross-Complaint-Attachment 9
(2) as follows:
1.) SEAT Cause of Action-(specify):
41. (2) The following additional causes of action are attached and the statements below apply to each (in each of the attachments,
“plaintiff” means "cross-complainant" and "defendant" means "cross-defendant’):
[) Motor Vehicle
CC) General Negligence
C) intentional Tort
(C) Products Liability
CC) Premises Liability
() Other (specify)
mp ange
12. CROSS-COMPLAINANT PRAYS for judgment for costs of suit; for such relief as is fair, just, and equitable; and for
a. [X) total and complete indemnity for any judgments rendered against me.
b. [&X)} judgment in a proportionate share from each cross-defendant.
c. QO a judicial determination that cross-defendants were the legal cause of any injuries and damages sustained by plaintiff
and that cross-defendants indemnify me, either completely or partially, for any sums of money which may be recovered
against me by plaintiff.
d. [.] compensatory damages
(1) QQ) (unlimited civil cases) according to proof.
(2) C) dimited civil cases) in the amount of: $
e. [) other (specify) :
For such other and further relief as the court deems just and proper.
Costs according to proof.
13. []} The paragraphs of this cross-complaint alleged on information and belief are as follows (specify paragraph numbers) :
Date: April 29, 2010 __
Narmayet Taos ‘} iy \ —
{TYPE OR PRINT NAME) (SIGNATURE OF CROSS-COMPLAINANT OR ATTORNEY)
PLO-PI-002 (Rev. January 1, 2007] CROSS-COMPLAINT-Personal Injury, Page 3of3
Property Damage, Wrongful DeathPOS-030
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Sta ‘aumber, and adress): FOR COURT USE ONLY
Narrmayet Taonus
3016 8th Street
Sacramento, CA 95817
tevepHoneno: (916) 912-5605 FAX NO (Optional):
E-MAIL ADDRESS (Opliona))
attorney FoR Wame; In Pro Per
SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Francisco
streetanoress) 400 McAllister, Room 103
MAILING ADDRESS:
ciryanoziecooe: San Francisco, CA 94102
arancHNawe: San Francsico District-Limited
PETITIONERPLAINTIFF: INFINITY INSURANCE COMPANY
RESPONDENT/DEFENDANT: BRANDI GREGG KEISER; NARRMAYET TAQ
CASE NUMBER:
CGC-10-497688
(Do not use this Proof of Service to shaw service of a Summons and Complaint}
PROOF OF SERVICE BY FIRST-CLASS MAIL - CIVIL.
1. bam over 18 years of age and not a party to this action. | am a resident of or employed in the county where the mailing
took place.
2. My residence or business address is:
Civil Self Help Center, Sacramento County Public Law Library
813 Sixth Street
Sacramento, CA 95814
3. On (date): April 29, 2010 | mailed from (city and state): Sacramento, CA
the following documents (specify):
Cross-Complaint-Personal Injury, Property Damage, Wrongful Death
() The documents are listed in the Attachment to Proof of Service by First-Class Mail - Civil (Documents Served)
(form POS-030(D)).
4. | served the documents by enclosing them in an envelope and(check one):
a. (2) depositing the sealed envelope with the United States Postal Service with the postage fully prepaid.
b. [XJ placing the envetope for collection and mailing following our ordinary business practices. | am readily familiar with this
business's practice for collecting and processing correspondence for mailing. On the same day that correspondence is
placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service in
a sealed envelope with postage fully prepaid.
5. The envelope was addressed and mailed as follows:
a. Name of person served: Michael R. Lea
b. Address of person served:
Lea & Navinskus, A Law Corporation
134 W. Wilshire Avenue
Fullerton, CA 92832
(C) The name and address of each person to whom I mailed the documents is listed in the Attachment to Proof of Service
by First-Class Mail-Civil (Persons Served) (POS-030(P)).
| declare under penalty of perjury under the laws of the State of Califomia that ing if true and correct.
Date: April 29, 2010
Victoria Jacobs
vi
PE OR PRINT NAME OF PERSON COMPLETING THIS FORM) TT” 4 ipproRe ‘OF PERSON COMPLETING THIS FORM)
Form Approved for Optional Use PROOF OF SERVICE BY FIRST-CLASS’MAIL - CIVIL Code of Civil Procedure, §§ 1013, 10134
‘Judicial Council of California ‘www courtinto.ca.gov
tartin Dean’ (Proof of Service)
SSENTIAL FORMS"
POS-030 [New January 1, 2005}
Preview
MUA SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Document Scanning Lead Sheet May-03-2010 3:52 pm Case Number: CGC-10-497688 Filing Date: Apr-30-2010 3:49 Juke Box: 001 Image: 02838631 CROSS COMPLAINT INFINITY INSURANCE COMPANY VS. BRANDI GREGG KEISER et al 001002838631 Instructions: Please place this sheet on top of the document to be scanned.PLD-PI-002 [ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, oy ‘number, and address): Narrmayet Taonus, In Pro Per 3016 8th Street Sacramento, CA 95817 teLePHone no: (916) 912-5605 E-MAIL ADDRESS (Optional): ATTORNEY FOR (Name; In Pro Per FAX NO. (Optional): FOR COURT USE ONLY Qu 4 fOr Court of | i Caan RY at Name OF court. San Francisco County Superior Court street appress: 400 McAllister, Room 103 MAILING ADDRESS: crrvanpz cone: San Francisco, CA 94102 pranch Name, San Francsico District-Limited SHORT TITLE: INFINITY V. KEISER CROSS-COMPLAINANT: NARRMAYET TAONUS CROSS-DEFENDANT: BRANDI GREGG KEISER () does 1 To 10 CROSS-COMPLAINT-Personal Injury, Property Damage, Wrongful Death () AMENDED (Number : Causes of Action (check all that apply) : [Z) Apportionment of Fault GQ) Declaratory Relief [(Q) Indemnification (C) Other (specify : Jurisdiction (check all that apply): [(K) ACTION IS A LIMITED CIVIL CASE ($25,000 or less} CJ ACTION Is AN UNLIMITED CIVIL CASE (exceeds $25,000) tt Cis [CQ isnot reclassified as unlimited by this cross-complaint CASE NUMBER: CGC-10-497688 1. CROSS-COMPLAINANT (name): NARRMAYET TAONUS alleges causes of action against CROSS-DEFENDANT (name) : BRANDI GREGG KEISER 2. This pleading, including exhibits and attachments, consists of the following number of pages: 3 3. Each cross-complainant named above is a competent adult a. [LJ except cross-complainant (name) : (1) (2) a comporation qualified to do business in California (2) (_] an unincorporated entity (describe) : (3) QO a public entity (describe) : (4) CJ aminor (2) an adult (a) (2) for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b) (2) other (specify) : (5) C2) other (specify) : (2) Information about additional cross-complainants who are not competent adults is contained in Cross-Complaint-Attachment 3. Page 1 of3 Form Approved for Optional Use Judicial Counc of Califor PLD-PI-002 [Rev. January 1, 2007) CROSS-COMPLAINT-Personal Injury, Property Damage, Wrongful Death Coda of Cwil Procedure, § 425.12C oom PLD-PI-002 SHORT TITLE: fASE NUMBER: INFINITY V. KEISER CGC-10-497688 4. Each cross-defendant named above is a natural person a. (C) except cross-defendant (name) : C2 except cross-defendant (name): (1) () a business organization, form unknown (1) (CJ a business organization, form unknown (2) CQ a corporation (2) LQ a corporation (3) () an unincorporated entity (describe) : (3) (LQ an unincorporated entity (describe) : (4) (2) a public entity (describe) : (4) C2 a public entity (describe) ; (5) (Cy other (specify) : (5) (Ly other (specify) : (C1 Information about additional cross-defendants who are not natural persons is contained in Cross-Complaint- Attachment 4. 5. The true names and capacities of cross-defendants sued as Does are unknown to cross-complainant. 6. [LJ] Cross-complainant is required to comply with a claims statute, and a. [) has complied with applicable claims statutes, or b. [Q) is excused from complying because (specify) : 7. (&) Eirst Cause of Action-Indemnification (NUMBER) a. Cross-defendants were the agents, employees, co-venturers, partners, or in some manner agents or principals, or both, for each other and were acting within the course and scope of their agency or employment. b. The principal action alleges, among other things, conduct entitling plaintiff to compensatory damages against me. | contend that | am not tiable for events and occurrences described in plaintiffs complaint. c, If lam found in some manner responsible to plaintiff or to anyone else as a result of the incidents and occurrences described in plaintiffs complaint, my liability would be based solely upon a derivative form of liability not resulting from my conduct, but only from an obligation imposed upon me by law; therefore, { would be entitled to complete indemnity from each cross-defendant. S id - 8. [J Secon WET Cause of Action-Apportionment of Fault a. Each cross-defendant was responsible, in whole or in part, for the injuries, if any, suffered by plaintiff. b. If am judged liable to plaintiff, each cross-defendant should be required: (1) to pay a share of plaintiffs judgment which is in proportion to the comparative negligence of that cross-defendant in causing plaintiffs damages; and (2) to reimburse me for any payments | make to plaintiff in excess of my proportional! share of all cross-defendants' negligence. PLD-P1002 (Rev. January 1, 2007] CROSS-COMPLAINT-Personal Injury, Page 2 of 3 Estat RWS" Property Damage, Wrongful DeathPLD-PI-002 SHORT TITLE: KR SE NUMBER: L INFINITY V. KEISER 'GC-10-497688 9 (J WER Cause of Action-Declaratory Relief An actual controversy exists between the parties concerning their respective rights and duties because cross-complainant contends and cross-defendant disputes oO as specified in Cross-Complaint-Attachment 9 (2) as follows: 1.) SEAT Cause of Action-(specify): 41. (2) The following additional causes of action are attached and the statements below apply to each (in each of the attachments, “plaintiff” means "cross-complainant" and "defendant" means "cross-defendant’): [) Motor Vehicle CC) General Negligence C) intentional Tort (C) Products Liability CC) Premises Liability () Other (specify) mp ange 12. CROSS-COMPLAINANT PRAYS for judgment for costs of suit; for such relief as is fair, just, and equitable; and for a. [X) total and complete indemnity for any judgments rendered against me. b. [&X)} judgment in a proportionate share from each cross-defendant. c. QO a judicial determination that cross-defendants were the legal cause of any injuries and damages sustained by plaintiff and that cross-defendants indemnify me, either completely or partially, for any sums of money which may be recovered against me by plaintiff. d. [.] compensatory damages (1) QQ) (unlimited civil cases) according to proof. (2) C) dimited civil cases) in the amount of: $ e. [) other (specify) : For such other and further relief as the court deems just and proper. Costs according to proof. 13. []} The paragraphs of this cross-complaint alleged on information and belief are as follows (specify paragraph numbers) : Date: April 29, 2010 __ Narmayet Taos ‘} iy \ — {TYPE OR PRINT NAME) (SIGNATURE OF CROSS-COMPLAINANT OR ATTORNEY) PLO-PI-002 (Rev. January 1, 2007] CROSS-COMPLAINT-Personal Injury, Page 3of3 Property Damage, Wrongful DeathPOS-030 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Sta ‘aumber, and adress): FOR COURT USE ONLY Narrmayet Taonus 3016 8th Street Sacramento, CA 95817 tevepHoneno: (916) 912-5605 FAX NO (Optional): E-MAIL ADDRESS (Opliona)) attorney FoR Wame; In Pro Per SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Francisco streetanoress) 400 McAllister, Room 103 MAILING ADDRESS: ciryanoziecooe: San Francisco, CA 94102 arancHNawe: San Francsico District-Limited PETITIONERPLAINTIFF: INFINITY INSURANCE COMPANY RESPONDENT/DEFENDANT: BRANDI GREGG KEISER; NARRMAYET TAQ CASE NUMBER: CGC-10-497688 (Do not use this Proof of Service to shaw service of a Summons and Complaint} PROOF OF SERVICE BY FIRST-CLASS MAIL - CIVIL. 1. bam over 18 years of age and not a party to this action. | am a resident of or employed in the county where the mailing took place. 2. My residence or business address is: Civil Self Help Center, Sacramento County Public Law Library 813 Sixth Street Sacramento, CA 95814 3. On (date): April 29, 2010 | mailed from (city and state): Sacramento, CA the following documents (specify): Cross-Complaint-Personal Injury, Property Damage, Wrongful Death () The documents are listed in the Attachment to Proof of Service by First-Class Mail - Civil (Documents Served) (form POS-030(D)). 4. | served the documents by enclosing them in an envelope and(check one): a. (2) depositing the sealed envelope with the United States Postal Service with the postage fully prepaid. b. [XJ placing the envetope for collection and mailing following our ordinary business practices. | am readily familiar with this business's practice for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service in a sealed envelope with postage fully prepaid. 5. The envelope was addressed and mailed as follows: a. Name of person served: Michael R. Lea b. Address of person served: Lea & Navinskus, A Law Corporation 134 W. Wilshire Avenue Fullerton, CA 92832 (C) The name and address of each person to whom I mailed the documents is listed in the Attachment to Proof of Service by First-Class Mail-Civil (Persons Served) (POS-030(P)). | declare under penalty of perjury under the laws of the State of Califomia that ing if true and correct. Date: April 29, 2010 Victoria Jacobs vi PE OR PRINT NAME OF PERSON COMPLETING THIS FORM) TT” 4 ipproRe ‘OF PERSON COMPLETING THIS FORM) Form Approved for Optional Use PROOF OF SERVICE BY FIRST-CLASS’MAIL - CIVIL Code of Civil Procedure, §§ 1013, 10134 ‘Judicial Council of California ‘www courtinto.ca.gov tartin Dean’ (Proof of Service) SSENTIAL FORMS" POS-030 [New January 1, 2005}