F Bw N
Do we NA wD
FI LE D
of San rane
HERRERA PURDY WEILER LLP AUG
Laura E, Seidl, Esq. (State Bar No. 269891) / 2 0 2020
1300 Clay Street, Suite 600
Oakland, CA 94612 a OOERK OF THE count
(510) 422-4700 ‘ Leg
Attorneys for Plaintiffs
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Case No.: CGC-19-572719
RAFAEL GUZMAN; DOES 1-10 FILE FIRST AMENDED COMPLAINT
Assigned for all purposes to:
Garrett L. Wong in Dept. 610
Complaint Filed: January 11, 2019
Trial Date: May 18, 2020
Debbrah Ruffin (“Plaintiff or “Tenant”) and Rafael Guzman. (“Defendant” or “Landlord”)
have agreed and stipulate that Plaintiff should be granted leave to file a First Amendment Complaint
adding additional Plaintiffs. The proposed First Amended Complaint is attached as Exhibit A. A
blackline tracking all changes from the original complaint is attached as Exhibit B. Because the
initial complaint was drafted in Word Perfect by Plaintiff's previous counsel, the track changes
function was difficult to employ, and is not reliable. The substantive changes are therefore
(1) Add the following language to the narrative section (before the causes of action are listed):
Prior to the day Plaintiff was sexually assaulted by Defendant in her own living room, Defendant
never claimed that Plaintiff owed any money for back rent. Once it became c...
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