On April 30, 2021 a
Complaint,Petition
was filed
involving a dispute between
Choi, Yeonho,
and
Washington, Krystal,
for (22) Unlimited Auto
in the District Court of Butte County.
Preview
PLD-PI-001
‘ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
James E. Gingrich, State Bar No. 143026
ChicoLawyers.com
313 Walnut Street, Suite 120
Chico, CA 95928
FOR COURT USE ONLY
Superior Court of California F
County of Butte |
TeLEPHONENO: (0886901 Pn: enon nisty 4/30/2021 L
Deput:
E-MAIL ADDRESS (Optional): JGingrich@ChicoLawyers.com
ATTORNEY FOR (Name): Plaintiff YEONHO CHOI
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Butte
STREET ADDRESS: 1775 Concord Avenue
MAILING ADDRESS: 1775 Concord Avenue Electronically FILED
CITY AND ZIP CODE:Chico, CA 95928
BRANCH NAME: North Butte County Courthouse
PLAINTIFF: YEONHO CHO!
DEFENDANT: KRYSTAL WASHINGTON
[J DOES 1 TO 25
COMPLAINT—Personal Injury, Property Damage, Wrongful Death
(] AMENDED (Number): 21CV01114
Type (check all that apply):
[2] MOTOR VEHICLE = [__] OTHER (specify):
[] Property Damage [__] Wrongful Death
Personal Injury _[__] Other Damages (specify):
Jurisdiction (check all that apply):
[_] ACTION IS A LIMITED CIVIL CASE
Amount demanded [__] does not exceed $10,000
[__] exceeds $10,000, but does not exceed $25,000
[Gq ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000)
[J ACTION IS RECLASSIFIED by this amended complaint
[) from limited to unlimited
[) from unlimited to limited
1. Plaintiff (name or names): YEONHO CHO!
alleges causes of action against defendant (name or names):
KRYSTAL WASHINGTON
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)[_] aminor [_] anadult
(a) [7] 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) (J a corporation qualified to do business in California
(2) [) an unincorporated entity (describe):
(3) [] a public entity (describe):
(4) aminor [7] anadult
(a) [) for whom a guardian or conservator of the estate or a guardian ad litem has been appointed
(b) [J other (specify):
(5) [J other (specify):
| Information about additional plaintiffs wno are not competent adults is shown in Attachment 3.
2omr—n
CASE NUMBER:
Page 1 of 8
Form Approved for Optional Use COMPLAINT—Personal Injury, Property Code of Civil Procedure, § 425.12
Judicial Council of California wenw.courts.ca.gov
PLO-PI.001 (Rov. January 1. 2007) Damage, Wrongful DeathPLD-PI-001
SHORT TITLE:
YEONHO CHOI v. KRYSTAL WASHINGTON
CASE NUMBER:
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):
(1) [] a business organization, form unknown
(2) [] a corporation
(3) [J an unincorporated entity (describe):
(4) [_) a public entity (describe):
(5) [__] other (specify):
b. [[_] except defendant (name):
(1) ) a business organization, form unknown
(2) [] a corporation
(3) [_] an unincorporated entity (describe):
(4) [__] a public entity (describe):
(5) [J other (specify):
c. [__] except defendant (name):
(1) [) a business organization, form unknown
(2) [) a corporation
(3) [__] an unincorporated entity (describe):
(4) [_) a public entity (describe):
(5) [__] other (specify):
d. [__] except defendant (name):
(1) [_] a business organization. form unknown
(2) [__] a corporation
(3) [] an unincorporated entity (describe):
(4) [__] a public entity (describe):
(5) [_] other (specify):
[] 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. [3c] Doe defendants (specify Doe numbers): 21-25
were the agents or employees of other
named defendants and acted within the scope of that agency or employment.
plaintiff.
Doe defendants (specify Doe numbers): 1-20
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. [__] atleast one defendant now resides in its jurisdictional area.
. [_] other (specify):
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):
. [] 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.
PLD-PI-001 [Rev. January 1, 2007]
COMPLAINT—Personal Injury, Property
Page 2 of 3
Damage, Wrongful DeathPLD-PI-001
SHORT TITLE: ‘CASE NUMBER:
YEONHO GHOI v. KRYSTAL WASHINGTON
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):
Motor Vehicle
General Negligence
Intentional Tort
Products Liability
Premises Liability
se ae op
OOUUUU#
other (specify):
1. Plaintiff has suffered
wage loss
loss of use of property
hospital and medical expenses
Co
Ga
Gd
[2] general damage
Gd
Co
1
a.
b,
Cc.
d.
e. property damage
i loss of earning capacity
g. other damage (specify):
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) (__] punitive damages
The amount of damages is (in cases for personal injury or wrongful death, you must check (1)):
according to proof
(2) [] in the amount of: $
15. DeyThe paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers):
All
fyi] 32 202% \
JAMES E. GINGRICH, ESQ.
(TYPE OR PRINT NAME)
PLO-P1-001 (Rev. January 1, 2007] COMPLAINT—Personal Injury, Property Page 3 of 3
Damage, Wrongful Death
Date:
For your protection and privacy, please press the Clear
This Form button after you have printed the form.PLD-PI-004(1)
SHORT TITLE: CASE NUMBER
YEONHO CHOI v. KRYSTAL WASHINGTON
FIRST CAUSE OF ACTION—Wotor Vehicle
J
ATTACHMENT TO Complaint [__] Cross-Complaint
(Use a separate cause of action form for each cause of action.)
Plaintiff (name): YEONHO CHO.
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): May 10, 2019
at (place):
The Westpark Plaza apartment complex parking lot located at 920 W. 4th Avenue, city of Chico, Butte County, California.
Mv- 2. DEFENDANTS
a. The defendants who operated a motor vehicle are (names):
KRYSTAL WASHINGTON
x] Does 1 to 5
b. [5¢] The defendants who employed the persons who operated a motor vehicle in the course of their employment are
(names):
xX] Does 6 to 10
c. [5¢] The defendants who owned the motor vehicle which was operated with their permission are (names):
KRYSTAL WASHINGTON
x | Does 11 to 15
d. [5¢] The defendants who entrusted the motor vehicle are (names):
x] Does 16 to 20
e. [5] The defendants who were the agents and employees of the other defendants and acted within the scope of the
agency were (names):
x] Does 21 to 25
f. [__] The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are
[] listed in Attachment MV-2f [[_] as follows:
Does to
Page 4
Pago 1 of 1
Form Approved tor Opional Use ; Coo of Gt Procedure 426.12
“iudeal Counc of Cafornia CAUSE OF ACTION—Motor Vehicle ort Ci oes 4052
PLD-PI-007(1) (Rev. January 1, 2007)
For your protection and privacy, please press the Clear
This Form button after you have printed the form.
Document Filed Date
April 30, 2021
Case Filing Date
April 30, 2021
Category
(22) Unlimited Auto
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Preview
PLD-PI-001 ‘ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): James E. Gingrich, State Bar No. 143026 ChicoLawyers.com 313 Walnut Street, Suite 120 Chico, CA 95928 FOR COURT USE ONLY Superior Court of California F County of Butte | TeLEPHONENO: (0886901 Pn: enon nisty 4/30/2021 L Deput: E-MAIL ADDRESS (Optional): JGingrich@ChicoLawyers.com ATTORNEY FOR (Name): Plaintiff YEONHO CHOI SUPERIOR COURT OF CALIFORNIA, COUNTY OF Butte STREET ADDRESS: 1775 Concord Avenue MAILING ADDRESS: 1775 Concord Avenue Electronically FILED CITY AND ZIP CODE:Chico, CA 95928 BRANCH NAME: North Butte County Courthouse PLAINTIFF: YEONHO CHO! DEFENDANT: KRYSTAL WASHINGTON [J DOES 1 TO 25 COMPLAINT—Personal Injury, Property Damage, Wrongful Death (] AMENDED (Number): 21CV01114 Type (check all that apply): [2] MOTOR VEHICLE = [__] OTHER (specify): [] Property Damage [__] Wrongful Death Personal Injury _[__] Other Damages (specify): Jurisdiction (check all that apply): [_] ACTION IS A LIMITED CIVIL CASE Amount demanded [__] does not exceed $10,000 [__] exceeds $10,000, but does not exceed $25,000 [Gq ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000) [J ACTION IS RECLASSIFIED by this amended complaint [) from limited to unlimited [) from unlimited to limited 1. Plaintiff (name or names): YEONHO CHO! alleges causes of action against defendant (name or names): KRYSTAL WASHINGTON 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)[_] aminor [_] anadult (a) [7] 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) (J a corporation qualified to do business in California (2) [) an unincorporated entity (describe): (3) [] a public entity (describe): (4) aminor [7] anadult (a) [) for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b) [J other (specify): (5) [J other (specify): | Information about additional plaintiffs wno are not competent adults is shown in Attachment 3. 2omr—n CASE NUMBER: Page 1 of 8 Form Approved for Optional Use COMPLAINT—Personal Injury, Property Code of Civil Procedure, § 425.12 Judicial Council of California wenw.courts.ca.gov PLO-PI.001 (Rov. January 1. 2007) Damage, Wrongful DeathPLD-PI-001 SHORT TITLE: YEONHO CHOI v. KRYSTAL WASHINGTON CASE NUMBER: 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): (1) [] a business organization, form unknown (2) [] a corporation (3) [J an unincorporated entity (describe): (4) [_) a public entity (describe): (5) [__] other (specify): b. [[_] except defendant (name): (1) ) a business organization, form unknown (2) [] a corporation (3) [_] an unincorporated entity (describe): (4) [__] a public entity (describe): (5) [J other (specify): c. [__] except defendant (name): (1) [) a business organization, form unknown (2) [) a corporation (3) [__] an unincorporated entity (describe): (4) [_) a public entity (describe): (5) [__] other (specify): d. [__] except defendant (name): (1) [_] a business organization. form unknown (2) [__] a corporation (3) [] an unincorporated entity (describe): (4) [__] a public entity (describe): (5) [_] other (specify): [] 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. [3c] Doe defendants (specify Doe numbers): 21-25 were the agents or employees of other named defendants and acted within the scope of that agency or employment. plaintiff. Doe defendants (specify Doe numbers): 1-20 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. [__] atleast one defendant now resides in its jurisdictional area. . [_] other (specify): 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): . [] 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. PLD-PI-001 [Rev. January 1, 2007] COMPLAINT—Personal Injury, Property Page 2 of 3 Damage, Wrongful DeathPLD-PI-001 SHORT TITLE: ‘CASE NUMBER: YEONHO GHOI v. KRYSTAL WASHINGTON 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): Motor Vehicle General Negligence Intentional Tort Products Liability Premises Liability se ae op OOUUUU# other (specify): 1. Plaintiff has suffered wage loss loss of use of property hospital and medical expenses Co Ga Gd [2] general damage Gd Co 1 a. b, Cc. d. e. property damage i loss of earning capacity g. other damage (specify): 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) (__] punitive damages The amount of damages is (in cases for personal injury or wrongful death, you must check (1)): according to proof (2) [] in the amount of: $ 15. DeyThe paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers): All fyi] 32 202% \ JAMES E. GINGRICH, ESQ. (TYPE OR PRINT NAME) PLO-P1-001 (Rev. January 1, 2007] COMPLAINT—Personal Injury, Property Page 3 of 3 Damage, Wrongful Death Date: For your protection and privacy, please press the Clear This Form button after you have printed the form.PLD-PI-004(1) SHORT TITLE: CASE NUMBER YEONHO CHOI v. KRYSTAL WASHINGTON FIRST CAUSE OF ACTION—Wotor Vehicle J ATTACHMENT TO Complaint [__] Cross-Complaint (Use a separate cause of action form for each cause of action.) Plaintiff (name): YEONHO CHO. 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): May 10, 2019 at (place): The Westpark Plaza apartment complex parking lot located at 920 W. 4th Avenue, city of Chico, Butte County, California. Mv- 2. DEFENDANTS a. The defendants who operated a motor vehicle are (names): KRYSTAL WASHINGTON x] Does 1 to 5 b. [5¢] The defendants who employed the persons who operated a motor vehicle in the course of their employment are (names): xX] Does 6 to 10 c. [5¢] The defendants who owned the motor vehicle which was operated with their permission are (names): KRYSTAL WASHINGTON x | Does 11 to 15 d. [5¢] The defendants who entrusted the motor vehicle are (names): x] Does 16 to 20 e. [5] The defendants who were the agents and employees of the other defendants and acted within the scope of the agency were (names): x] Does 21 to 25 f. [__] The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are [] listed in Attachment MV-2f [[_] as follows: Does to Page 4 Pago 1 of 1 Form Approved tor Opional Use ; Coo of Gt Procedure 426.12 “iudeal Counc of Cafornia CAUSE OF ACTION—Motor Vehicle ort Ci oes 4052 PLD-PI-007(1) (Rev. January 1, 2007) For your protection and privacy, please press the Clear This Form button after you have printed the form.