On December 05, 2017 a
Complaint,Petition
was filed
involving a dispute between
Jubran, Sadiq,
and
Does 1 Through 20,
Gonzales, Martha,
Reyes, Jose,
for (22) Unlimited Auto
in the District Court of San Mateo County.
Preview
PLD-Pl-001
_ Philip A.
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
Segal, Esq. (137633)
FOR COURT USE ONLY
Kern Segal & Murray
1388 Sutter Street, Suite 600
San Francisco, CA 94109
TELEPHONE No:
(415) 474- 1 900 (415) 474-03 02
FAX NO. (Optional):
E-MAIL ADDRESS (Optional):
Plaintiff,
ATTORNEY FOR (Name): SADIQ .TUBRAN
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN MATEO
" ”TI
STREET ADDRESS:400 County Center
MAlLINGADDRESS: F E E47 E5
Redwood
CITY AND ZIP CODE: City, California 94063 SAN INIATEU CGUNTY
BRANCH NAME:
PLAINTIFF: SADIQ IUBRAN
DEFENDANT: JOSE REYES; MARTHA GONZALES; AND
DOES 1TO 20
COMPLAINT—Personal Injury, Property Damage, Wrongful Death
:1 AMENDED (Number):
Type (check all that apply):
MOTOR VEHICLE I:| OTHER (specify):
Property Damage
Personal Injury
|:I
I:]
Wrongful
Other
Death
Damages (specify):
Jurisdiction (check all that apply): CASE NUMBER:
I:[ ACTION IS A LIMITED CIVIL CASE
[:I
-
|:]
Amount demanded
ACTION IS RECLASSIFIED
CI
I:I
does not exceed
exceeds
ACTION IS AN UNLIMITED CIVIL CASE
$10,000
$10, 000,but does not exceed
(exceeds $25, 000)
by this amended complaint
from limited to unlimited
$25, 000
1 I?
C
,
I V (j 5: 5 5 0
I:I from unlimited to limited
1. Plaintiff (name ornames): SADIQ IUBRAN
alleges causes of action against defendant (name or names):
JOSE REYES; MARTHA GONZALES; AND DOES 1 TO 20
2. This pleading,including attachments and exhibits, consists of the following number of pages:
4
3. Each plaintiff named above is a competent adult
a. |:I except plaintiff (name):
|:|
(1)
(2)
(3)
I:
|:|
a corporation qualified to do business in California
an unincorporated entity (describe):
a public entity (describe):
(4) |:| a minor |:| an adult
(a) |:] forwhom a guardian or conservator of the estate or a guardian ad litem has been‘appointed
(b) I:I other (specify): , _n_,,__ ,E____L.
5() |:I other (specify): aim—05550
I:]
4
b. except plaintiff (name): Complaint
|:|
W: a corporation qualified to do business California
(1) In
(2) El an unincorporated entity (describe). 78H
3()|:I a public entity (describe):
IIIIIIIIIIIII
a()|:I for whom a guardian or conservator of the estate or a guardian ad litem has been appointed
b)|:] other (specify).
(5) 1:!» other (specify).
I:I information about additional plaintiffs who are not competent adults is shown in Attachment 3.
Page1of 3
Form Approved for Optional Use
Judicial Council of Califomia
COM P LAI NT _ '
Person al In] U I'y, P roperty Code of Civil Procedure, § 42512
www.courtinfo.ca.gov
PLD-Pl—001 IRev. January 1, 2007] Damage, Wrongful Death
PLD-Pl-001
SHORT TITLE: CASE NUMBER:
lJUBRAN v. REYES, et a1.
4. |:I 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. 1:] except defendant (name):
)|:]
(1) a business organization, form unknown
o. |:| except
(1) [:I
defendant (name):
a business organization, form unknown
)E] CI
(2)
(3)I: a corporation
an unincorporated entity (describe).
(2)
(3) :1
a corporation
an unincorporated entity (describe):
(4) [:l a public entity (describe): ) [:1 a public entity (describe):
(5) |:| other (specify): ) I:l other (specify):
b. |:| except defendant (name): d. |:| except defendant (name):
1) I:] a business organization, form unknown (1) |:I a business organization, form unknown
I:] 1:]
(2)
(3) I: a corporation
an unincorporated entity (describe):
(2)
(3).[:1
a corporation
an unincorporated entity (describe):
4) 1:] a public entity (describe): (4) E) a public entity (describe):
5) I:] other (specify): 5) I:I other (specify):
1:] 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 t0 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. El Defendants who are joined under Code of Civil Procedure section 382 are (names):
8.
I:
This court is the proper court because
a.
b.
c.
d.
-
|:j
E:
at least one defendant now resides in its jurisdictional area.
the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area.
injury to person or damage to personal property occurred in its jurisdictional area.
other (specify).
9. I:] Plaintiff is required to comply with a claims statute, and
a. E] or
has complied with applicable claims statutes,
b. I:j is excused from complying because (specify):
PLD-Pl-001 (Rev. January 1, 2007] COMPLAINT—Personal Injury, Property Page 2 of 3
Damage, Wrongful Death
PLD-Pl-001
‘
SHORT TITLE: CASE NUMBER:
IJUBRAN v. REYES, et a1.
10. (each complaint musthave one or more
The following causes of action are attached and the statements above apply to each
causes of action attached):
3. Motor Vehicle
b. :1 General Negligence
. |:| Intentional Tort
. [:1 Products Liability
TtO
. |:|
CI
Premises Liability
Other (specify):
11. Plaintiff has suffered
a. wage loss
b. loss of use of property
0. hospital and medical expenses
d. general damage
e. property damage
f. loss of earning capacity
9. Z] other damage (specify):
12. 1:] The damages claimed for wrongful death and the relationships of plaintiff to the deceased are
a. E] in Attachment 12.
listed
b. I:I as follows:
13. The relief sought in this complaint is within the jurisdiction of this court.
14. Plaintiff prays forjudgment for costs of suit; for such relief as is fair, just, and equitable;
and for
a. (1) compensatory damages
(2) 1:! punitive damages
The amount of damages is (in cases for personal injury or wrongful death, you must check ( 1)):
(1) according to proof
(2) E] in the amount of: $
/
15. :1 The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers):
Date: NOVEMBER 20, 2017
\
PHILIP A. SEGAL, ESQ. P
(TYPE OR PRINT NAME) IV (SIGNA/TUR PLAINTIFF OR ATTORNEY)
PLD-PI-001 [Rem January 1. 20071 COMPLAINT—Personal Injury, Property -
Pageaofs
Damage, Wrongful Death
PLD-Pl-001 (1)
SHORT TITLE: CASE NUMBER:
JUBRAN V. REYES, et a1.
FIRST CAUSE OF ACTION—Motor Vehicle
(number)
ATTACHMENTTO Complaint l:l Cross-Complaint
(Use a separate cause of action form for each cause of action.)
Plaintiff (name):SADIQ JUBRAN
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): 05/18/2016
at (place):
Southbound on University Avenue towards Donohue Street in East Palo Alto, CA.
MV— 2. DEFENDANTS
a. The defendants who operated a motor vehicle are (names):
JOSE REYES; AND
Does I to 20
b. The defendants who employed the persons who operated a motor vehicle in the course of their employment
are (names):
JOSE REYES; MARTHA GONZALES; AND
Does 1 to 20
c. The defendants who owned the motor vehicle which was operated with their permission are (names):
JOSE REYES; MARTHA GONZALES; AND
Does 1 to 20
d. The defendants who entrusted the motor vehicle are (names):
JOSE REYES; MARTHA GONZALES; 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):
JOSE REYES; MARTHA GONZALES; AND
Does 1 to 20
f. CI The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are
I:] listed in Attachment MV—2f [:1 as follows:
:1 Does to Page 4
Page
1 of1
Form Approved for Optional Use
Judicial Council of California
CAUSE OF ACTION—Motor vehicle Code of Civil Procedure 425:12
www.couninfo.ca.gov
PLD
Document Filed Date
December 05, 2017
Case Filing Date
December 05, 2017
Category
(22) Unlimited Auto
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Preview
PLD-Pl-001 _ Philip A. ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): Segal, Esq. (137633) FOR COURT USE ONLY Kern Segal & Murray 1388 Sutter Street, Suite 600 San Francisco, CA 94109 TELEPHONE No: (415) 474- 1 900 (415) 474-03 02 FAX NO. (Optional): E-MAIL ADDRESS (Optional): Plaintiff, ATTORNEY FOR (Name): SADIQ .TUBRAN SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN MATEO " ”TI STREET ADDRESS:400 County Center MAlLINGADDRESS: F E E47 E5 Redwood CITY AND ZIP CODE: City, California 94063 SAN INIATEU CGUNTY BRANCH NAME: PLAINTIFF: SADIQ IUBRAN DEFENDANT: JOSE REYES; MARTHA GONZALES; AND DOES 1TO 20 COMPLAINT—Personal Injury, Property Damage, Wrongful Death :1 AMENDED (Number): Type (check all that apply): MOTOR VEHICLE I:| OTHER (specify): Property Damage Personal Injury |:I I:] Wrongful Other Death Damages (specify): Jurisdiction (check all that apply): CASE NUMBER: I:[ ACTION IS A LIMITED CIVIL CASE [:I - |:] Amount demanded ACTION IS RECLASSIFIED CI I:I does not exceed exceeds ACTION IS AN UNLIMITED CIVIL CASE $10,000 $10, 000,but does not exceed (exceeds $25, 000) by this amended complaint from limited to unlimited $25, 000 1 I? C , I V (j 5: 5 5 0 I:I from unlimited to limited 1. Plaintiff (name ornames): SADIQ IUBRAN alleges causes of action against defendant (name or names): JOSE REYES; MARTHA GONZALES; AND DOES 1 TO 20 2. This pleading,including attachments and exhibits, consists of the following number of pages: 4 3. Each plaintiff named above is a competent adult a. |:I except plaintiff (name): |:| (1) (2) (3) I: |:| a corporation qualified to do business in California an unincorporated entity (describe): a public entity (describe): (4) |:| a minor |:| an adult (a) |:] forwhom a guardian or conservator of the estate or a guardian ad litem has been‘appointed (b) I:I other (specify): , _n_,,__ ,E____L. 5() |:I other (specify): aim—05550 I:] 4 b. except plaintiff (name): Complaint |:| W: a corporation qualified to do business California (1) In (2) El an unincorporated entity (describe). 78H 3()|:I a public entity (describe): IIIIIIIIIIIII a()|:I for whom a guardian or conservator of the estate or a guardian ad litem has been appointed b)|:] other (specify). (5) 1:!» other (specify). I:I information about additional plaintiffs who are not competent adults is shown in Attachment 3. Page1of 3 Form Approved for Optional Use Judicial Council of Califomia COM P LAI NT _ ' Person al In] U I'y, P roperty Code of Civil Procedure, § 42512 www.courtinfo.ca.gov PLD-Pl—001 IRev. January 1, 2007] Damage, Wrongful Death PLD-Pl-001 SHORT TITLE: CASE NUMBER: lJUBRAN v. REYES, et a1. 4. |:I 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. 1:] except defendant (name): )|:] (1) a business organization, form unknown o. |:| except (1) [:I defendant (name): a business organization, form unknown )E] CI (2) (3)I: a corporation an unincorporated entity (describe). (2) (3) :1 a corporation an unincorporated entity (describe): (4) [:l a public entity (describe): ) [:1 a public entity (describe): (5) |:| other (specify): ) I:l other (specify): b. |:| except defendant (name): d. |:| except defendant (name): 1) I:] a business organization, form unknown (1) |:I a business organization, form unknown I:] 1:] (2) (3) I: a corporation an unincorporated entity (describe): (2) (3).[:1 a corporation an unincorporated entity (describe): 4) 1:] a public entity (describe): (4) E) a public entity (describe): 5) I:] other (specify): 5) I:I other (specify): 1:] 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 t0 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. El Defendants who are joined under Code of Civil Procedure section 382 are (names): 8. I: This court is the proper court because a. b. c. d. - |:j E: at least one defendant now resides in its jurisdictional area. the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area. injury to person or damage to personal property occurred in its jurisdictional area. other (specify). 9. I:] Plaintiff is required to comply with a claims statute, and a. E] or has complied with applicable claims statutes, b. I:j is excused from complying because (specify): PLD-Pl-001 (Rev. January 1, 2007] COMPLAINT—Personal Injury, Property Page 2 of 3 Damage, Wrongful Death PLD-Pl-001 ‘ SHORT TITLE: CASE NUMBER: IJUBRAN v. REYES, et a1. 10. (each complaint musthave one or more The following causes of action are attached and the statements above apply to each causes of action attached): 3. Motor Vehicle b. :1 General Negligence . |:| Intentional Tort . [:1 Products Liability TtO . |:| CI Premises Liability Other (specify): 11. Plaintiff has suffered a. wage loss b. loss of use of property 0. hospital and medical expenses d. general damage e. property damage f. loss of earning capacity 9. Z] other damage (specify): 12. 1:] The damages claimed for wrongful death and the relationships of plaintiff to the deceased are a. E] in Attachment 12. listed b. I:I as follows: 13. The relief sought in this complaint is within the jurisdiction of this court. 14. Plaintiff prays forjudgment for costs of suit; for such relief as is fair, just, and equitable; and for a. (1) compensatory damages (2) 1:! punitive damages The amount of damages is (in cases for personal injury or wrongful death, you must check ( 1)): (1) according to proof (2) E] in the amount of: $ / 15. :1 The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers): Date: NOVEMBER 20, 2017 \ PHILIP A. SEGAL, ESQ. P (TYPE OR PRINT NAME) IV (SIGNA/TUR PLAINTIFF OR ATTORNEY) PLD-PI-001 [Rem January 1. 20071 COMPLAINT—Personal Injury, Property - Pageaofs Damage, Wrongful Death PLD-Pl-001 (1) SHORT TITLE: CASE NUMBER: JUBRAN V. REYES, et a1. FIRST CAUSE OF ACTION—Motor Vehicle (number) ATTACHMENTTO Complaint l:l Cross-Complaint (Use a separate cause of action form for each cause of action.) Plaintiff (name):SADIQ JUBRAN 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): 05/18/2016 at (place): Southbound on University Avenue towards Donohue Street in East Palo Alto, CA. MV— 2. DEFENDANTS a. The defendants who operated a motor vehicle are (names): JOSE REYES; AND Does I to 20 b. The defendants who employed the persons who operated a motor vehicle in the course of their employment are (names): JOSE REYES; MARTHA GONZALES; AND Does 1 to 20 c. The defendants who owned the motor vehicle which was operated with their permission are (names): JOSE REYES; MARTHA GONZALES; AND Does 1 to 20 d. The defendants who entrusted the motor vehicle are (names): JOSE REYES; MARTHA GONZALES; 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): JOSE REYES; MARTHA GONZALES; AND Does 1 to 20 f. CI The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are I:] listed in Attachment MV—2f [:1 as follows: :1 Does to Page 4 Page 1 of1 Form Approved for Optional Use Judicial Council of California CAUSE OF ACTION—Motor vehicle Code of Civil Procedure 425:12 www.couninfo.ca.gov PLD