Complaint,Petition: Ignacia Lopez vs William Lain

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                                PLD-PI-001

ATTORNEY OR PARTY WITHOUT ATTORNEY, (re tate Bar number, and address):

{- Zoi Amara Jones, Esq., $
Gonzalez & Jones, APC
901 Sunset Drive Suite 5
Hollister, CA 95023

TELEPHONE NO: (408)780-2652 FAX NO. (Optional: (408)847-8229

E-MAIL ADDRESS (Optionay: ZOI@Zonzalezjoneslaw.com

ATTORNEY FOR (Name): Ignacia Lopez

SUPERIOR COURT OF CALIFORNIA, COUNTY OF Santa Clara
sTREET ADDRESS: 19] N. First Street
matine appress: 19] N. First Street
city ano zie cove: San Jose, 95113
BRANCH NAME: Downtown Superior Court

PLAINTIFF: Tonacia Lopez

DEFENDANT: William Lain

CX] poes1to 10

COMPLAINT—Personal Injury, Property Damage, Wrongful Death
AMENDED (Number):

Type (check all that apply):

MOTOR VEHICLE [X] OTHER (specify):Slip and Fall
Property Damage Wrongful Death

LX] Personal Injury Other Damages (specify):

FOR COURT USE ONLY

E-FILED
6/30/2021 2:59 PM
Clerk of Court
Superior Court of CA,
County of Santa Clara
21CV385042

Reviewed By: D Harris

Jurisdiction (check all that apply):
ACTION IS A LIMITED CIVIL CASE

CASE NUMBER:

Amount demanded does not exceed $10,000
exceeds $10,000, but does not exceed $25,000 210V385042
ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000)
ACTION IS RECLASSIFIED by this amended complaint
from limited to unlimited
from unlimited to limited
1. Plaintiff (name or names):[gnacia Lopez
alleges causes of action against defendant (name or names):
William Lain
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. 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
(a) for whom a guardian or conservator of the estate or a guardian ad litem has been appointed
(b) other (specify):
(5) other (specify):
b. 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
(a) for whom a guardian or conservator of the estate or a guardian ad litem has been appointed
(b) other (specify):
(5) other (specify):

Information about additional plaintiffs who are not competent adults is shown in Attachment 3.

Page 1 of 3

Sporn noes ona Pane COMPLAINT—Personal Injury, Property

Judicial Council of California

PLO-PI-001 (Rev. January 1, 2007] Damage, Wrongful Death

Code of Civil Procedure, § 425.12
wnw.courtinfo.ca.gov

[American LegaiNet, Inc.
www. Forms Workflow.comPLD-PI-001

SHORT TITLE:
Lopez v. Lain

CASE NUMBER:

21CV385042

4. 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): c.
(1) a business organization, form unknown
(2) a corporation
(3) an unincorporated entity (describe):
(4) a public entity (describe):

(5) other (specify):

b. except defendant (name): d.
(1) a business organization, form unknown
(2) a corporation
(3) an unincorporated entity (describe):
(4) a public entity (describe):
(5) [__] other (specify):

6. The true names of defendants sued as Does are unknown to plaintiff.
a. Doe defendants (specify Doe numbers): 1-10

plaintiff.

except defendant (name):

(1)
(2)
(3)
(4)

(5)

a business organization, form unknown
a corporation
an unincorporated entity (describe):

a public entity (describe):

other (specify):

except defendant (name):

(1)
(2)
(3)

(4)

(5) CJ

a business organization, form unknown
a corporation

an unincorporated entity (describe):

a public entity (describe):

other (specify):

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.
b. [X] Doe defendants (specify Doe numbers): 1-10

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. at least one defendant now resides in its jurisdictional area.

other (specify):

b. the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area.
c. LX] injury to person or damage to personal property occurred in its jurisdictional area.
d

9. Plaintiff is required to comply with a claims statute, and
a. has complied with applicable claims statutes, or
b. is excused from complying because (specify):
PLD-PI-001 [Rev. January 1, 2007] COMPLAINT—Personal Injury, Property Page 2 of 3

Damage, Wrongful DeathPLD-PI-001

SHORT TITLE: CASE NUMBER:
Lopez v. Lain 210V385042
10. The following causes of action are attached and the statements above apply to each (each complaint must have one or more

11.

12.

13.

14.

155

causes of action attached):
Motor Vehicle

(X] General Negligence
[__] Intentional Tort
Products Liability
Premises Liability
Other (specify):

se aoc®

Plaintiff has suffered

wage loss

fF loss of use of property

. LX] hospital and medical expenses
general damage

property damage

loss of earning capacity

other damage (specify):

e@reaoge

The damages claimed for wrongful death and the relationships of plaintiff to the deceased are

a. listed in Attachment 12.
b. as follows:

The relief sought in this complaint is within the jurisdiction of this court.

Plaintiff prays for judgment for costs of suit; for such relief as is fair, just, and equitable; and for
a. (1) compensatory damages
(2) punitive damages
The amount of damages is (in cases for personal injury or wrongful death, you must check (1)):
(1) EX] according to proof
(2) in the amount of: $

The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers):

Date: 6/30/21

Zoi Amara Jones, Esq.

(TYPE OR PRINT NAME) (SIGNATURE OF PLAINTIFF OR ATTORNEY)

PLD-PI-001 [Rev. January 1, 2007] COMPLAINT—Personal Injury, Property Page 3 of 3

Damage, Wrongful DeathPLD-PI-001(2)

SHORT TITLE:
Lopez v. Lain

CASE NUMBER:

21CV385042

ONE

(number)

CAUSE OF ACTION—General Negligence _ Page 4

ATTACHMENT TO CX] Complaint Cross - Complaint

(Use a separate cause of action form for each cause of action.)

GN-1. Plaintiff (name): Ignacia Lopez

alleges that defendant (name): William Lain

x

Does | to 10

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): 7/16/20

at (place): 7781 Rosano St.

(description of reasons for liability):
Plaintiff rents a home owned by Defendant and located at 7781 Rosanna St. in Gilroy, California.
Plaintff was walking on the property and slipped and fell on a crack in the pavement causing

injuries.

Page 1 of 1

Form Approved for Optional Use
Judicial Council of California
PLD-PI-001(2) [Rev. January 1, 2007]

CAUSE OF ACTION—General Negligence

Code of Civil Procedure 425.12
www.courtinfo.ca.gov