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  • ISMAEL IDEAS et al vs PRATIK CHAUDHARI Auto Unlimited (22)  document preview
  • ISMAEL IDEAS et al vs PRATIK CHAUDHARI Auto Unlimited (22)  document preview
  • ISMAEL IDEAS et al vs PRATIK CHAUDHARI Auto Unlimited (22)  document preview
  • ISMAEL IDEAS et al vs PRATIK CHAUDHARI Auto Unlimited (22)  document preview
  • ISMAEL IDEAS et al vs PRATIK CHAUDHARI Auto Unlimited (22)  document preview
  • ISMAEL IDEAS et al vs PRATIK CHAUDHARI Auto Unlimited (22)  document preview
  • ISMAEL IDEAS et al vs PRATIK CHAUDHARI Auto Unlimited (22)  document preview
  • ISMAEL IDEAS et al vs PRATIK CHAUDHARI Auto Unlimited (22)  document preview
						
                                

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PIL ET aero ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): ISMAIL IDEAS .ATA ALAFAGHANI 4162 Piper dr San Jose Ca 95117 TELEPHONE NO: 408 648 8663 FAX NO, (Optional): [E-MAIL ADDRESS (Option ATTORNEY FOR (Namo): ISUPERIOR COURT OF CALIFORNIA, COUNTY OF STREET ADDRESS: 191 N FIRST ST MAILING ADDRESS: 191 N FIRST ST CITY AND 2iP CODE: San Jose Ca 95113 BRANCH NAME: Downtown Superior Courthouse-Civil Division PLAINTIFF: ISMAIL IDEAS.ATA ALAFAGHANI DEFENDANT: PRATIK DILIP CHAUDHARI x] DOES 1 TO 10 FOR COURT USE ONLY wo AUG g P Pit x_] AMENDED (Number): Type (check all that apply): COMPLAINT—Personal Injury, Property Damage, Wrongful Death Rivet X_] MOTOR VEHICLE OTHER (specify): [<] Property Damage Wrongful Death (321 Personal Injury [x] Other Damages (specify): ACTION IS A LIMITED CI Amount demanded Jurisdiction (check all that apply): IVIL CASE does not exceed $10,000 (J exceeds $10,000, but does not exceed $25,000 (3¢ ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000) [_x_] ACTION IS RECLASSIFIED by this amended complaint (<1 from limited to unlimited [1 from unlimited to limited ‘CASE NUMBER: 14cv 35/208 1. Plaintiff (name or names): ISMAIL IDEAS . ATA ALAFAGHANI alleges causes of action against defendant (name or names): and DOES 1-10 2. This pleading, including attachments and exhibits, consists of the following number of pages: 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 (b) other (specify): (6) [_] other (specify): b. except plaintiff (name): (1) ] a corporation qualified to do business in Catifornia (2) an unincorporated entity (describe); (3) [__] a public entity (describe): (4) Jaminor [ an adult (b) other (specify): (5) (_] other (specify): (a) for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (@) for whom a guardian or conservator of the estate or a guardian ad litem has been appointed Information about additional plaintiffs who are not competent adults is shown in Attachment 3. Page 1 of 3 Form Approved for Optional Use: PLD-P1-001 [Rev. January 1, 2007] COMPLAINT—Personal Injury, Property 3 e100 Rew dononry 42D Damage, Wrongful Death Code of Ciil Procedure, § 425.12 wanw.courts.ca.govPLD-PI-001 SHORT TITLE: ‘CASE NUMBER: IDEAS etal. V.CHAUDHARI { g CV 2 5] 20 4. [oC] 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): _ a | except defendant (name). (iy a business organization, form unknown (1) a business organization, form unknown (2) [[_] a corporation (2) [__] acorporation (3) () an unincorporated entity (describe): (3) an unincorporated entity (describe): (4) a public entity (describe): (A) a public entity (describe): (5) [7] 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): (6) other (specify): 6. The true names of defendants sued as Does are unknown to plaintiff. a. [3C] Doe defendants (specify Doe numbers): 1-5 b. [3C] Doe defendants (specify Doe numbers): 6-10 plaintiff. Information about additional defendants who are not natural persons is contained in Attachment 5. were the agents or employees of other named defendants and acted within the scope of that agency or employment. are persons whose capacities are unknown to 7. Defendants who are joined under Code of Civil Procedure section 382 are (names): 8. This court is the proper court because a. [3¢] atleast one defendant now resides in its jurisdictional area. other (specify): 9. [x] Plaintiff is required to comply with a claims statute, and 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. da a. has complied with applicable claims statutes, or b. is excused from complying because (specify): PLD-PL001 [Rev. January 4, 2007] COMPLAINT—Personal Injury, Property Page 2 0f3 Damage, Wrongful DeathPLD-PI-001 SHORT TITLE: . fieaaa CHAUDHARI . 14 ev 3 5 120 g 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): x] Motor Vehicle General Negligence Intentional Tort Products Liability Premises Liability f. [[) other (specify): gap ep . Plaintiff has suffered x] wage loss loss of use of property hospital and medical expenses general damage property damage LX] loss of earning capacity | other damage (specify): Plainttf is filing for Social security permanent disability. enroanse p pe} Jae fae] [oe 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) [3¢] compensatory damages (2) [3c] punitive damages The amount of damages is (in cases for personal injury or wrongful death, you must check (1)): (1) [BE] according to proof (2) [1 in the amount of: $ 200.000.00 45.[_]The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers): DatePAWAG- \T 2S ASMATL ADGAS (TYPE OR PRINT NAME) PLO-PI-001 [Rev. January 1, 2007] COMPLAINT—Personal Injury, Property Page 3 of 3 Damage, Wrongful Death (SIGNATURE OF PLAINTIFF OR ATTORNEY) For your protection and privacy, please press the Clear rr = This Form button after you have printed the form. Print this form-| | Save this form (Clear this:form:vs ~ PLD-PI-001(1) CASE NUMBER: SHORT TITLE: IDEAS et, al, v. CHAUDHARI \Q ev 251 258 CAUSE OF ACTION—Motor Vehicle (number) ATTACHMENT TO LX] Complaint Cross - Complaint (Use a separate cause of action form for each cause of action.) Plaintiff (name): ISMAEL IDEAS. ATA ALAFAGHANI 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 cn (date): November 6, 2017, at approximately 7:55 am plaintiffs were traveling S/B on San Thomas at (place): In Santa Clara, California, Mr. Chaudhari was travelling at an unsafe speed and rear-ended Mr. Ideas, causing great bodily injury to him and his passenger. MvV- 2. DEFENDANTS a. [32] The defendants who operated a motor vehicle are (names): PRATIK DILIP CHAUDHARI Gd Does. I to 10. . [) The defendants who employed the persons who operated a motor vehicle in the course of their employment are (names): os Does to c. Gad The defendants who owned the motor vehicle which was operated wilh their permission are (names): Lx] Does L to 19 d. Lx! The defendants who entrusted the motor vehicle are (names): Lx] Does L to 10 e. L__] The defendants who were the agents and employees of the other defendants and acted within the scope of the agency were (names): Does to f. LJ] The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are [1 iste in Attachment MV-2f as follows: [1 Does to Page Page 1 of 4 Fam Approved fer Optional Use CAUSE OF ACTION—Motor Vehicle Cote of Ci Procedure 425.12 PLO-PI401(1) [Rev. January 1, 2007] Westlaw Doc & Form Buideves ToS Ts . ARSC so ist we AH $0 ROT PRY AP GOSH syle wee FV ESS) DSTA WT 2 Rossi TY ero 3S Ww! “es aL QFE =e Ay oy \wYS opens Oy: sooty iorato ¥ Magy -°¥ FSeYI |: “SAVY? x [+ . Kos psd STOW, Aap sey Wu) : VOY ERO OD OT PT Saar} : “REE SWAY 7 SRO IY eyssyl+ OA ee re ASV AEG T THD Duds SYOSMY) 99 parry ~ AE S39 = “ef ore : g OTST NT ST NVI SHIR