Preview
Electronically Filed by Superior Court of California, County of Orange, 02/01/2022 11:36:23 AM.
30-2022-01243334-CU-PA-CJ C - ROA #2 - DAVID H. YAMASAKI, Clerk of the Court By Katie Trent, Deputy Clerk.
PLD-PI-001
‘ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
| Daniel Petrov (SBN 254316) Christine Palcisko (SBN 297575)
Petrov Law Firm
380 S. Melrose Dr. Suite 201
Vista, CA 92081
TELEPHONE No: 619.344.0360 FAX NO. (Optiona): 619.377.7668
E-MAIL ADDRESS (Optiona): Christie@petrovlawfirm.com
ATTORNEY FOR (Name): Plaintiff Dawn Robbins
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Orange
street appress: 700 Civic Center Drive West
maine aopress: 700 Civic Center Drive West
city AnD zip cove: Santa Ana, CA 92701
BrancH Name: Central Justice Center
PLAINTIFF: Dawn Robbins
DEFENDANT: Aidan Flynn, Daniel Flynn
DOES 1TO 10
COMPLAINT—Personal Injury, Property Damage, Wrongful Death
AMENDED (Number):
Type (check all that apply):
MOTOR VEHICLE OTHER (specify):
Property Damage L_] Wrongful Death
Personal Injury Other Damages (specify):
FOR COURT USE ONLY
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
ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000)
ACTION IS RECLASSIFIED by this amended complaint
from limited to unlimited
from unlimited to limited
CASE NUMBER:
30-2022-01243334-CU-PA-CIC
Assigned for All Purposes
Judge Derek W. Hunt
1. Plaintiff (name or names): Dawn Robbins
alleges causes of action against defendant (name or names): Aidan Flynn, Daniel Flynn and DOES 1 to 10
. This pleading, including attachments and exhibits, consists of the following number of pages: 5
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
Form Approved for Optional Use COMPLAINT—Personal Injury, Property
Judicial Council of California
PLD-PI-001 (Rev. January 1, 2007] Damage, Wrongful Death
‘Code of GWvil Procedure, § 425.12
‘American LegalNet, Inc.
www.FormsWorkflow.com
www.courtinfo.ca.govPLD-PI-001
SHORT TITLE:
Robbins v. Flynn
CASE NUMBER:
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): 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): (5) other (specify):
b. except defendant (name): 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): (5) [] other (specify):
Information about additional defendants who are not natural persons is contained in Attachment 5.
The true names of defendants sued as Does are unknown to plaintiff.
a. [KX] Doe defendants (specify Doe numbers): 1 to 10 were the agents or employees of other
named defendants and acted within the scope of that agency or employment.
b. [XJ Doe defendants (specify Doe numbers): 1 to 10
plaintiff.
are persons whose capacities are unknown to
Defendants who are joined under Code of Civil Procedure section 382 are (names):
This court is the proper court because
a. [XJ atleast 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.
b.
c. XI injury to person or damage to personal property occurred in its jurisdictional area.
d. other (specify):
Plaintiff is required to comply with a claims statute, and
has complied with applicable claims statutes, or
b. is excused from complying because (specify):
~
PLD-PI-001 [Rev. January 1, 2007]
Page 2 of 3
COMPLAINT—Personal Injury, Property
Damage, Wrongful Death
‘American LegalNet, Inc.
‘wwww.FormsWorkflow.comPLD-PI-001
SHORT TITLE: CASE NUMBER:
Robbins v. Flynn
10.
11.
12.
13.
14.
15.
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):
moaooD
1 Motor Vehicle
1) General Negligence
Intentional Tort
Products Liability
Premises Liability
Other (specify):
Plaintiff has suffered
e>eaocp
WKN
wage loss
loss of use of property
hospital and medical expenses
general damage
property damage
loss of earning capacity
other damage (specify):
he damages claimed for wrongful death and the relationships of plaintiff to the deceased are
listed in Attachment 12.
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)
(2)
compensatory damages
punitive damages
The amount of damages is (in cases for personal injury or wrongful death, you must check (1)):
(1)
(2)
KX] according to proof
in the amount of: $
The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers):
Date: 2/1/2022
Christine Palcisko, Esq. SBN 297575
» Una
(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 Death
‘American LegalNet, Inc.
‘wwww.FormsWorkflow.comPLD-PI-001(2)
SHORT TITLE:
Robbins v. Flynn
CASE NUMBER:
(number)
CAUSE OF ACTION—General Negligence
ATTACHMENT TO [X] Complaint Cross - Complaint
(Use a separate cause of action form for each cause of action.)
GN-1. Plaintiff (name): Dawn Robbins
alleges that defendant (name): Aidan Flynn, Daniel Flynn
Does 1
to 10
Page 4
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): 10/21/2020
at (place): San Clemente, CA
(description of reasons
for liability):
Defendant rear-ended Plaintiff's vehicle
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
‘American LegalNet, Inc.
www. FormsWorkflow.comPLD-PI-001(1)
SHORT TITLE:
Robbins v. Flynn
CASE NUMBER:
CAUSE OF ACTION—Motor Vehicle
(number)
ATTACHMENT TO [XJ — Complaint Cross - Complaint
(Use a separate cause of action form for each cause of action.)
Plaintiff (name): Dawn Robbins
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):
at (place):
10/21/2020
San Clemente, CA
MV- 2. DEFENDANTS.
a &®
The defendants who operated a motor vehicle are (names): Aidan Flynn
KI Does 1 to 10
The defendants who employed the persons who operated a motor vehicle in the course of their employment
are (names):
Does 1 to 10
The defendants who owned the motor vehicle which was operated with their permission are (names):
KI Does 1 to 10
The defendants who entrusted the motor vehicle are (names):
KI Does 1 to 10
The defendants who were the agents and employees of the other defendants and acted within the scope
Of the agency were (names):
EI Does 1 to 10
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 PageS
Paget of 1
Form Approved for Optional Use CAUSE OF ACTION—Motor Vehicle Code of Givil Procedure 425.12
Judicial Council of California
PLD-PI-001(1) [Rev. January 1, 2007]
‘www.courtinfo.ca.gov
‘American LegalNet, Inc.
www.FormsWorkflow.com
Preview
Electronically Filed by Superior Court of California, County of Orange, 02/01/2022 11:36:23 AM. 30-2022-01243334-CU-PA-CJ C - ROA #2 - DAVID H. YAMASAKI, Clerk of the Court By Katie Trent, Deputy Clerk. PLD-PI-001 ‘ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): | Daniel Petrov (SBN 254316) Christine Palcisko (SBN 297575) Petrov Law Firm 380 S. Melrose Dr. Suite 201 Vista, CA 92081 TELEPHONE No: 619.344.0360 FAX NO. (Optiona): 619.377.7668 E-MAIL ADDRESS (Optiona): Christie@petrovlawfirm.com ATTORNEY FOR (Name): Plaintiff Dawn Robbins SUPERIOR COURT OF CALIFORNIA, COUNTY OF Orange street appress: 700 Civic Center Drive West maine aopress: 700 Civic Center Drive West city AnD zip cove: Santa Ana, CA 92701 BrancH Name: Central Justice Center PLAINTIFF: Dawn Robbins DEFENDANT: Aidan Flynn, Daniel Flynn DOES 1TO 10 COMPLAINT—Personal Injury, Property Damage, Wrongful Death AMENDED (Number): Type (check all that apply): MOTOR VEHICLE OTHER (specify): Property Damage L_] Wrongful Death Personal Injury Other Damages (specify): FOR COURT USE ONLY 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 ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000) ACTION IS RECLASSIFIED by this amended complaint from limited to unlimited from unlimited to limited CASE NUMBER: 30-2022-01243334-CU-PA-CIC Assigned for All Purposes Judge Derek W. Hunt 1. Plaintiff (name or names): Dawn Robbins alleges causes of action against defendant (name or names): Aidan Flynn, Daniel Flynn and DOES 1 to 10 . This pleading, including attachments and exhibits, consists of the following number of pages: 5 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 Form Approved for Optional Use COMPLAINT—Personal Injury, Property Judicial Council of California PLD-PI-001 (Rev. January 1, 2007] Damage, Wrongful Death ‘Code of GWvil Procedure, § 425.12 ‘American LegalNet, Inc. www.FormsWorkflow.com www.courtinfo.ca.govPLD-PI-001 SHORT TITLE: Robbins v. Flynn CASE NUMBER: 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): 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): (5) other (specify): b. except defendant (name): 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): (5) [] other (specify): Information about additional defendants who are not natural persons is contained in Attachment 5. The true names of defendants sued as Does are unknown to plaintiff. a. [KX] Doe defendants (specify Doe numbers): 1 to 10 were the agents or employees of other named defendants and acted within the scope of that agency or employment. b. [XJ Doe defendants (specify Doe numbers): 1 to 10 plaintiff. are persons whose capacities are unknown to Defendants who are joined under Code of Civil Procedure section 382 are (names): This court is the proper court because a. [XJ atleast 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. b. c. XI injury to person or damage to personal property occurred in its jurisdictional area. d. other (specify): Plaintiff is required to comply with a claims statute, and has complied with applicable claims statutes, or b. is excused from complying because (specify): ~ PLD-PI-001 [Rev. January 1, 2007] Page 2 of 3 COMPLAINT—Personal Injury, Property Damage, Wrongful Death ‘American LegalNet, Inc. ‘wwww.FormsWorkflow.comPLD-PI-001 SHORT TITLE: CASE NUMBER: Robbins v. Flynn 10. 11. 12. 13. 14. 15. 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): moaooD 1 Motor Vehicle 1) General Negligence Intentional Tort Products Liability Premises Liability Other (specify): Plaintiff has suffered e>eaocp WKN wage loss loss of use of property hospital and medical expenses general damage property damage loss of earning capacity other damage (specify): he damages claimed for wrongful death and the relationships of plaintiff to the deceased are listed in Attachment 12. 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) (2) compensatory damages punitive damages The amount of damages is (in cases for personal injury or wrongful death, you must check (1)): (1) (2) KX] according to proof in the amount of: $ The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers): Date: 2/1/2022 Christine Palcisko, Esq. SBN 297575 » Una (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 Death ‘American LegalNet, Inc. ‘wwww.FormsWorkflow.comPLD-PI-001(2) SHORT TITLE: Robbins v. Flynn CASE NUMBER: (number) CAUSE OF ACTION—General Negligence ATTACHMENT TO [X] Complaint Cross - Complaint (Use a separate cause of action form for each cause of action.) GN-1. Plaintiff (name): Dawn Robbins alleges that defendant (name): Aidan Flynn, Daniel Flynn Does 1 to 10 Page 4 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): 10/21/2020 at (place): San Clemente, CA (description of reasons for liability): Defendant rear-ended Plaintiff's vehicle 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 ‘American LegalNet, Inc. www. FormsWorkflow.comPLD-PI-001(1) SHORT TITLE: Robbins v. Flynn CASE NUMBER: CAUSE OF ACTION—Motor Vehicle (number) ATTACHMENT TO [XJ — Complaint Cross - Complaint (Use a separate cause of action form for each cause of action.) Plaintiff (name): Dawn Robbins 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): at (place): 10/21/2020 San Clemente, CA MV- 2. DEFENDANTS. a &® The defendants who operated a motor vehicle are (names): Aidan Flynn KI Does 1 to 10 The defendants who employed the persons who operated a motor vehicle in the course of their employment are (names): Does 1 to 10 The defendants who owned the motor vehicle which was operated with their permission are (names): KI Does 1 to 10 The defendants who entrusted the motor vehicle are (names): KI Does 1 to 10 The defendants who were the agents and employees of the other defendants and acted within the scope Of the agency were (names): EI Does 1 to 10 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 PageS Paget of 1 Form Approved for Optional Use CAUSE OF ACTION—Motor Vehicle Code of Givil Procedure 425.12 Judicial Council of California PLD-PI-001(1) [Rev. January 1, 2007] ‘www.courtinfo.ca.gov ‘American LegalNet, Inc. www.FormsWorkflow.com