Preview
A s
A'I'I'ORNEY
'— OR PARTY WITHOUT A'I'I’ORNEY 6N)ame, Mar number, and address): FOR COURT USE ONLY
TIONNA DOLIN (SBN 29901
Strategic Legal Practices, APC
1840 Century Park East, Suite 430 F i L E
SUPER'OR COURT OF CALIFORMA
Los Angeles, California 90067 COUNTY 0F
I
_ NO" (3
t
10) 943 _ 3838 SAN BERNASfi$¥NB§§5§§§?é¥O
mORLEELYEQSNEaZZL Bléggfaftlgpgmo DIAZFAX
SUPERIOR COURT or CALIFORNIA, COUNTY 0F SAN BERNARDIN O
STREETADDRESS; 247 West 3rd Street FEB 2 6 2021
MAILING ADDRESS: Same u
FAXEf}
cm AND ZIP CODE: San Bernardino, CA 92415 DY
BRANCH NAME; Civil Division of San Bemardino Justice Center
DEILONZO BOARD, DEPUT;
CASE NAME:
Diaz V. FCA US, LLC et a1
CASE NUMBER: .
CIVIL CASE COVER SHEET Complex Case DeSIgnatIon
. .
unlimited
(Amount
E Limited
(Amount
E Counter D Joinder
CIV SB
JUDGE:
2 1 05 1 S V
demanded demanded is Filed with first appearance by defendant
$25,000 or less) Rules of Court, rule 3.402) DEPT:
exceeds $25,000) (Cal.
Items 1—6 below must be completed (see instructions on page 2).
1. Check one box below for the case type that best describes this case:
Auto Tort Contract Provisionally Complex Civil Litigation
(Cal. Rules of Court, rules 3.4oo—3.403)
Auto (22)
Uninsured motorist (46) D
D
Breach of contramarramy (06)
Rule 3.740 collections (09) D
D Antitrust/Trade regulation (03)
Construction defect (10)
Other PIIPDIWD (Personal InjuryIProperty
Damage/Wrongful Death) Tort
Asbestos (O4)
D
D
Other collections (09)
Insurance coverage (18)
Other contract (37) E Mass tort (40)
Securities litigation (28)
Product liability (24) Real Property Environmental/Toxic tort (30)
Medical malpractice (45) Eminent domain/lnverse Insurance coverage claims arising from the
D Other PIIPDIWD (23)
E condemnatlon (14)
I
Wrongful eviction (33)
above listed provisionally
types (41)
complex case
Non-PIIPDIWD (Other) Ton
Business tomunfair business practice (07) D Other real property (26) Enforcement of Judgment
D
E
E Civil rights (O8)
DUnlawful Detainer
commerdal
Enforcement ofjudgment (20)
Complaint
E:
Defamation (13)
Fraud (16) D
D Residential (32)
(31) Miscellaneous
E
D Rico (27)
Civil
D
D Intellectual property (19) DFUQS (38) Other complaint (not specified above) (42)
Professional negligence (25)
Other "on‘Pl/PD/WD t0” (35) D
D
JUdiCia' ReVieW
Asset forfeiture (05)
MiscelIaneous Civil Petition
Partnership and corporate governance (21)
Eflloyment
D
Petition re: arbitration
mandate
award (11)
D Other petition (not specified above) (43)
2.
D D m
This case
Wrongful termination (36)
Other employment (15)
is is not
D
complex under
Writ of
Other
rule
judicial
(02)
review (39)
3.400 of the California Rules of Court. If the case is complex, mark the
management:
D
factors requiring exceptional judicial
Large number of separately represented parties d. D
D
Large number of witnesses
D a.
b. Extensive motion practice raising difficult or novel e. Coordination with related actions pending in one or more courts
in other counties, states, or countries, or in a federal court
D c.
issues that
Substantial
will
amount
be time-consuming to resolve
of documentary evidence f. D Substantial postjudgmentjudicial supervision
Remedies sought (check all thatapply): am monetary hm nonmonetary; dec|aratory or injunctive relief c. mpunitive
Number of causes of action (specify): Six (6)
91:5.“
E
3%
This case is is not a class action suit.
and serve a notice of related case. (You may use form CM—015.)
6 If there are any known related cases, file
Date: 02/25/21
TIONNA DOLIN b
(SIGNATURE OF PARTY OR ATTORNEY FOR PARTY)
(TYPE OR PRINT NAME)
NOTICE I
_
or cases flled
. Plaintiff must
paper filed in the action or proceeding (except small claims cases
file this cover sheet with the first
Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.) Failure to file may result
under the Probate Code, Family Code, or
in sanctions. _
I File this cover sheet in addition to any cover sheet reqUIred by local court
rule. _
Rules of Court, you must serve a copy of thls cover sheet on all
0 If this case is complex under rule 3.400 et seq. ofthe California
other parties to the action or proceeding. .
' I
purposes oleIég
0 a collections case under rule 3.740 or a
complex case, this cover sheet wnl be used for statlstlcal
e1of2
Unless this is
3.400—3.403. 3.740;
Cal. Rules of Court, rules 2.30, 3.220.
Form Adapted Manda'mry'use
for' CIVIL CASE COVER SHEET Cal‘ Standards of Judicial Administration,
s‘d. 3.10
WWW .coumnfaca-gov
Judicial CounCIl of Cahfomla
CM-010 [Rev. July 1, 2007]
V V CM-o1o
INSTRUCTIONS 0N HOW TO COMPLETE THE COVER SHEET
If you are filing a first paper (for example, a compla
Filing First Papers.
int) in a civil case, you must
To Plaintiffs and Others
the Civil Case Cover Sheet contai ned on page 1. This information will be used to compile
complete and file, along with your first paper,
statistics about the types and numbers of cases filed.
You must complete items 1 through 6 on the sheet. In item 1, you must check
bes the case. If the case fits both a general and a more specifi
c type of case listed in item 1,
one box for the case type that best descri
box best indicat es the primary cause of action.
check the more specific one. If the case has multiple causes of action, check
the that
es the cases that belong under each case type in item 1 are provided below, A cover
To assist you in completing the sheet, exampl of
with the first paper filed in a civil case may subject a party,
sheet must be filed only with your initial paper. Failure to file a cover sheet
and 3.220 of the Califor nia Ru|es of Court.
its counsel, or both to sanctions under rules 2.30
A tions case" under rule 3.740 is defined as an action for recovery of money
To Parties in Rule 3.740 Collections Cases. "collec
not more than $25,00 0, exclus ive of interest and attorney's fees, arising from a transaction in
owed in a sum stated to be certain that is
ton
ions case does not include an action seeking the following: (1)
which property, services, or money was acquired on credit. A collect
es, recove ry of real propert y, recove ry of personal property, or (5) a prejudgment writ of
damages, (2) punitiv damag
e (3) (4)
general
ions case on this form means that it will be exempt from the
attachment. The identification of a case as a ru|e 3.740 co||ect
unless a defendant files a responsive pleadin g. A ru|e 3.740 collect ions
time-for—service requirements and case management rules,
ng a judgme nt rule 3.740.
case will be subject to the requirements for service and obtaini
in
the Civil Case Cover Sheet to designate whether the
To Parties in Complex Cases. |n complex cases only, parties must also use
es the case is comple x under ru|e 3.400 of the California Rules of Court, this must be indicated by
case is complex. If a plaintiff believ
f design ates a case as complex, the cover sheet must be served with the
completing the appropriate boxes in items 1 and 2. If a plaintif
A defend ant may file and serve no later than the time of its first appearance a joinder in the
complaint on all parties to the action.
is not comple x, the plaintif f has made no designation, a designation that
f‘s designation, a counter-designation that the case
or, if
plaintif
the case '3 comp'ex' CASE TYPES AND EXAMPLES
Provisionally Complex Civil Litigation (Cal.
Auto Tort Contract
Breach of Contract/Warranty (06) Rules of Court Rules 3.400—3.403)
Auto (22)-Personal Injury/Property Antitrust/Trade Regu|ation (03)
Breach of Rental/Lease
Damage/Wrongful Death Construction Defect (10)
Contract (not unlawful detainer
Uninsured Motorist (46) (ifthe or wrongful eviction) Claims Involving Mass Tort (40)
case involves an uninsured Securities Litigation (28)
Contract/Warranty Breach—Seller
motorist claim subject to Environmental/Toxic Tort (30)
Plaintiff (not fraud or negligence)
arbitration, check this item Insurance Coverage Claims
Negligent Breach of Contract/
instead of Auto) (arising from provisionally complex
Warranty
Other Pl/PDIWD (Personal Injury] case type listed above) (41)
Other Breach of Contract/Warranty
Property DamageIWrongfuI Death) Collections (e.g., money owed, open
Enforcement of Judgment
Tort Enforcement of Judgment (20)
book accounts) (09)
Asbestos (04) Abstract of Judgment (Out of
Collection Case—Seller P|aintiff
Asbestos Property Damage County)
Other Promissory Note/Collections
Asbestos Personal lnjury/ Confession of Judgment (non—
Case
Wrongful Death Insurance Coverage (not provisionally domestic relations)
Product Liability (not asbestos or complex) (1 8) Sister State Judgment
toxic/environmental) (24) Auto Subrogation Administrative Agency Award
Medical Malpractice (45) (not unpaid taxes)
Other Coverage
Medical Malpractice- Petition/Certification of Entry of
Other Contract (37) Judgment on Unpaid Taxes
Physicians & Surgeons
Contractual Fraud Other Enforcement of Judgment
Other Professional Health Care
Other Contract Dispute Case
Malpractice
Real Property Miscellaneous Civil Complaint
Other Pl/PDNVD (23)
Eminent Domain/Inverse RICO
Premises Liability (e.g., slip (27)
Condemnation (14)
Other Complaint (not specified
and fall)
Injury/PDNVD Wrongful Eviction (33) above) (42)
Intentional Bodily
(e.g., assault, vandalism) Other Real Property (e.g., quiet title) (26) Declaratory Relief Only
Intentional lnfliction of
Writ of Possession of Real Property lnjunctive Relief Only (non—
Emotional Distress Mortgage Foreclosure harassment)
Negligent Infliction of Quiet Title Mechanics Lien
Emotional Distress Other Real Property (not eminent Other Commercial Complaint
Other Pl/PDNVD domain, landlord/tenant, or Case (non-tort/non-comp/ex)
foreclosure) Other Civil Complaint
Non-Pl/PD/WD (Other) Tort
Unlawful Detainer (non-tort/non-complex)
Business Tort/Unfair Business
Commercial (31) Miscellaneous Civil Petition
Practice (07)
Residential (32) Partnership and Corporate
Civil Rights (e.g., discrimination,
civil Drugs (38) (if the case involves illegal Governance (21)
false arrest) (not
drugs, check this item; othem/ise, Other Petition (not specified
harassment) (08)
report as Commercial or Residential) above) (43)
Defamation (e.g., slander, libel)
Civil Harassment
Judicial Review
(1 3)
Asset Forfeiture (05) Workplace Violence
Fraud (16) Elder/Dependent Adult
Petition Re: Arbitration Award (1 1)
Intellectual Property (19) Abuse
Writ of Mandate (02)
Professional Negligence (25) Mandamus Election Contest
Writ—Administrative
Legal Malpractice Limited Court Name Change
Writ—Mandamus on Petition for
Other Professional Malpractice Petition for Relief From Late
Case Matter
(not medical or legal) Claim
Writ—Other Limited Court Case
Other Non-Pl/PD/WD Tort (35)
Other Civil Petition
Employment Review
Wrongful Termination (36) Other Judicial Review (39)
Other Employment (15) Review of Health Officer Order
Notice of AppeaI—Labor
com missioner A eals Page 2 of 2
CM-01O [Rev, July 1, 2007] CIVIL CASE COVER SHEET
Preview
A s A'I'I'ORNEY '— OR PARTY WITHOUT A'I'I’ORNEY 6N)ame, Mar number, and address): FOR COURT USE ONLY TIONNA DOLIN (SBN 29901 Strategic Legal Practices, APC 1840 Century Park East, Suite 430 F i L E SUPER'OR COURT OF CALIFORMA Los Angeles, California 90067 COUNTY 0F I _ NO" (3 t 10) 943 _ 3838 SAN BERNASfi$¥NB§§5§§§?é¥O mORLEELYEQSNEaZZL Bléggfaftlgpgmo DIAZFAX SUPERIOR COURT or CALIFORNIA, COUNTY 0F SAN BERNARDIN O STREETADDRESS; 247 West 3rd Street FEB 2 6 2021 MAILING ADDRESS: Same u FAXEf} cm AND ZIP CODE: San Bernardino, CA 92415 DY BRANCH NAME; Civil Division of San Bemardino Justice Center DEILONZO BOARD, DEPUT; CASE NAME: Diaz V. FCA US, LLC et a1 CASE NUMBER: . CIVIL CASE COVER SHEET Complex Case DeSIgnatIon . . unlimited (Amount E Limited (Amount E Counter D Joinder CIV SB JUDGE: 2 1 05 1 S V demanded demanded is Filed with first appearance by defendant $25,000 or less) Rules of Court, rule 3.402) DEPT: exceeds $25,000) (Cal. Items 1—6 below must be completed (see instructions on page 2). 1. Check one box below for the case type that best describes this case: Auto Tort Contract Provisionally Complex Civil Litigation (Cal. Rules of Court, rules 3.4oo—3.403) Auto (22) Uninsured motorist (46) D D Breach of contramarramy (06) Rule 3.740 collections (09) D D Antitrust/Trade regulation (03) Construction defect (10) Other PIIPDIWD (Personal InjuryIProperty Damage/Wrongful Death) Tort Asbestos (O4) D D Other collections (09) Insurance coverage (18) Other contract (37) E Mass tort (40) Securities litigation (28) Product liability (24) Real Property Environmental/Toxic tort (30) Medical malpractice (45) Eminent domain/lnverse Insurance coverage claims arising from the D Other PIIPDIWD (23) E condemnatlon (14) I Wrongful eviction (33) above listed provisionally types (41) complex case Non-PIIPDIWD (Other) Ton Business tomunfair business practice (07) D Other real property (26) Enforcement of Judgment D E E Civil rights (O8) DUnlawful Detainer commerdal Enforcement ofjudgment (20) Complaint E: Defamation (13) Fraud (16) D D Residential (32) (31) Miscellaneous E D Rico (27) Civil D D Intellectual property (19) DFUQS (38) Other complaint (not specified above) (42) Professional negligence (25) Other "on‘Pl/PD/WD t0” (35) D D JUdiCia' ReVieW Asset forfeiture (05) MiscelIaneous Civil Petition Partnership and corporate governance (21) Eflloyment D Petition re: arbitration mandate award (11) D Other petition (not specified above) (43) 2. D D m This case Wrongful termination (36) Other employment (15) is is not D complex under Writ of Other rule judicial (02) review (39) 3.400 of the California Rules of Court. If the case is complex, mark the management: D factors requiring exceptional judicial Large number of separately represented parties d. D D Large number of witnesses D a. b. Extensive motion practice raising difficult or novel e. Coordination with related actions pending in one or more courts in other counties, states, or countries, or in a federal court D c. issues that Substantial will amount be time-consuming to resolve of documentary evidence f. D Substantial postjudgmentjudicial supervision Remedies sought (check all thatapply): am monetary hm nonmonetary; dec|aratory or injunctive relief c. mpunitive Number of causes of action (specify): Six (6) 91:5.“ E 3% This case is is not a class action suit. and serve a notice of related case. (You may use form CM—015.) 6 If there are any known related cases, file Date: 02/25/21 TIONNA DOLIN b (SIGNATURE OF PARTY OR ATTORNEY FOR PARTY) (TYPE OR PRINT NAME) NOTICE I _ or cases flled . Plaintiff must paper filed in the action or proceeding (except small claims cases file this cover sheet with the first Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.) Failure to file may result under the Probate Code, Family Code, or in sanctions. _ I File this cover sheet in addition to any cover sheet reqUIred by local court rule. _ Rules of Court, you must serve a copy of thls cover sheet on all 0 If this case is complex under rule 3.400 et seq. ofthe California other parties to the action or proceeding. . ' I purposes oleIég 0 a collections case under rule 3.740 or a complex case, this cover sheet wnl be used for statlstlcal e1of2 Unless this is 3.400—3.403. 3.740; Cal. Rules of Court, rules 2.30, 3.220. Form Adapted Manda'mry'use for' CIVIL CASE COVER SHEET Cal‘ Standards of Judicial Administration, s‘d. 3.10 WWW .coumnfaca-gov Judicial CounCIl of Cahfomla CM-010 [Rev. July 1, 2007] V V CM-o1o INSTRUCTIONS 0N HOW TO COMPLETE THE COVER SHEET If you are filing a first paper (for example, a compla Filing First Papers. int) in a civil case, you must To Plaintiffs and Others the Civil Case Cover Sheet contai ned on page 1. This information will be used to compile complete and file, along with your first paper, statistics about the types and numbers of cases filed. You must complete items 1 through 6 on the sheet. In item 1, you must check bes the case. If the case fits both a general and a more specifi c type of case listed in item 1, one box for the case type that best descri box best indicat es the primary cause of action. check the more specific one. If the case has multiple causes of action, check the that es the cases that belong under each case type in item 1 are provided below, A cover To assist you in completing the sheet, exampl of with the first paper filed in a civil case may subject a party, sheet must be filed only with your initial paper. Failure to file a cover sheet and 3.220 of the Califor nia Ru|es of Court. its counsel, or both to sanctions under rules 2.30 A tions case" under rule 3.740 is defined as an action for recovery of money To Parties in Rule 3.740 Collections Cases. "collec not more than $25,00 0, exclus ive of interest and attorney's fees, arising from a transaction in owed in a sum stated to be certain that is ton ions case does not include an action seeking the following: (1) which property, services, or money was acquired on credit. A collect es, recove ry of real propert y, recove ry of personal property, or (5) a prejudgment writ of damages, (2) punitiv damag e (3) (4) general ions case on this form means that it will be exempt from the attachment. The identification of a case as a ru|e 3.740 co||ect unless a defendant files a responsive pleadin g. A ru|e 3.740 collect ions time-for—service requirements and case management rules, ng a judgme nt rule 3.740. case will be subject to the requirements for service and obtaini in the Civil Case Cover Sheet to designate whether the To Parties in Complex Cases. |n complex cases only, parties must also use es the case is comple x under ru|e 3.400 of the California Rules of Court, this must be indicated by case is complex. If a plaintiff believ f design ates a case as complex, the cover sheet must be served with the completing the appropriate boxes in items 1 and 2. If a plaintif A defend ant may file and serve no later than the time of its first appearance a joinder in the complaint on all parties to the action. is not comple x, the plaintif f has made no designation, a designation that f‘s designation, a counter-designation that the case or, if plaintif the case '3 comp'ex' CASE TYPES AND EXAMPLES Provisionally Complex Civil Litigation (Cal. Auto Tort Contract Breach of Contract/Warranty (06) Rules of Court Rules 3.400—3.403) Auto (22)-Personal Injury/Property Antitrust/Trade Regu|ation (03) Breach of Rental/Lease Damage/Wrongful Death Construction Defect (10) Contract (not unlawful detainer Uninsured Motorist (46) (ifthe or wrongful eviction) Claims Involving Mass Tort (40) case involves an uninsured Securities Litigation (28) Contract/Warranty Breach—Seller motorist claim subject to Environmental/Toxic Tort (30) Plaintiff (not fraud or negligence) arbitration, check this item Insurance Coverage Claims Negligent Breach of Contract/ instead of Auto) (arising from provisionally complex Warranty Other Pl/PDIWD (Personal Injury] case type listed above) (41) Other Breach of Contract/Warranty Property DamageIWrongfuI Death) Collections (e.g., money owed, open Enforcement of Judgment Tort Enforcement of Judgment (20) book accounts) (09) Asbestos (04) Abstract of Judgment (Out of Collection Case—Seller P|aintiff Asbestos Property Damage County) Other Promissory Note/Collections Asbestos Personal lnjury/ Confession of Judgment (non— Case Wrongful Death Insurance Coverage (not provisionally domestic relations) Product Liability (not asbestos or complex) (1 8) Sister State Judgment toxic/environmental) (24) Auto Subrogation Administrative Agency Award Medical Malpractice (45) (not unpaid taxes) Other Coverage Medical Malpractice- Petition/Certification of Entry of Other Contract (37) Judgment on Unpaid Taxes Physicians & Surgeons Contractual Fraud Other Enforcement of Judgment Other Professional Health Care Other Contract Dispute Case Malpractice Real Property Miscellaneous Civil Complaint Other Pl/PDNVD (23) Eminent Domain/Inverse RICO Premises Liability (e.g., slip (27) Condemnation (14) Other Complaint (not specified and fall) Injury/PDNVD Wrongful Eviction (33) above) (42) Intentional Bodily (e.g., assault, vandalism) Other Real Property (e.g., quiet title) (26) Declaratory Relief Only Intentional lnfliction of Writ of Possession of Real Property lnjunctive Relief Only (non— Emotional Distress Mortgage Foreclosure harassment) Negligent Infliction of Quiet Title Mechanics Lien Emotional Distress Other Real Property (not eminent Other Commercial Complaint Other Pl/PDNVD domain, landlord/tenant, or Case (non-tort/non-comp/ex) foreclosure) Other Civil Complaint Non-Pl/PD/WD (Other) Tort Unlawful Detainer (non-tort/non-complex) Business Tort/Unfair Business Commercial (31) Miscellaneous Civil Petition Practice (07) Residential (32) Partnership and Corporate Civil Rights (e.g., discrimination, civil Drugs (38) (if the case involves illegal Governance (21) false arrest) (not drugs, check this item; othem/ise, Other Petition (not specified harassment) (08) report as Commercial or Residential) above) (43) Defamation (e.g., slander, libel) Civil Harassment Judicial Review (1 3) Asset Forfeiture (05) Workplace Violence Fraud (16) Elder/Dependent Adult Petition Re: Arbitration Award (1 1) Intellectual Property (19) Abuse Writ of Mandate (02) Professional Negligence (25) Mandamus Election Contest Writ—Administrative Legal Malpractice Limited Court Name Change Writ—Mandamus on Petition for Other Professional Malpractice Petition for Relief From Late Case Matter (not medical or legal) Claim Writ—Other Limited Court Case Other Non-Pl/PD/WD Tort (35) Other Civil Petition Employment Review Wrongful Termination (36) Other Judicial Review (39) Other Employment (15) Review of Health Officer Order Notice of AppeaI—Labor com missioner A eals Page 2 of 2 CM-01O [Rev, July 1, 2007] CIVIL CASE COVER SHEET