FILED

8uperior Court Of ornia,

SaVatnertto
C2107/201 3
By
CasE Numb.
34-2013-0013
CAROL C. BALDWIN, an Individual
8032 Red Pine Court
Citrus Heights, CA 95610-4626
Phone: 916-729-5213
Fax: 916-729-7468
btg2011@surewest.net
Attorney: In Pro Per
Deputy
552
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN THE COUNTY OF SACRAMENTO
UNLIMITED JURISDICTION
CASE NO:
DEPARTMENT
ASSIGNMENTS
Case Management 36
Law and Motion 54
Minors Compromise 45
CAROL C. BALDWIN, an individual,
Plaintiff,
v.
SUNRISE HOMEOWNERSASSOCIATION
INC., a California nonprofit mutual benefit
corporation; and DOES 1 -225, inclusive,
Defendants.
COMPLAINT FOR:
1. DISABILITY DISCRIMINATION
2. DENIAL OF CIVIL RIGHTS;
(Gov. Code 12955)
3. DENIAL OF CIVIL RIGHTS;
(Gov. Code 12948)
4. DENIAL OF DUE PROCESS
5. BREACH OF CONTRACT
6. BREACH OF FIDUCIARY DUTY
7. INTENTIONAL INFLICTION OF
EMOTIONAL DISTRESS
8. CIVIL CONSPIRACY
Date:
Time:
Dept:
Before:
Date Action Filed:
JURY TRIAL DEMANDED
COMPLAINT
1. Comes now Plaintiff, CAROL C. BALDWIN, an individual (hereinafter referred to as
CAROL C. BALDWIN'S COMPLAINT FOR DISABILITY DISCRIMINATION Page 1 of 25.

HOMEOWNERS ASSOCIATION, INC., DOES 1 -225, and each of them, to pay Plaintiff CAROL
C. BALDWIN emotional distress and suffering damages in the amount not less than One Million
Dollars ($1,000,000.00);
4. As to the First through Eight Causes of Action, order Defendants SUNRISE
HOMEOWNERS ASSOCIATION, INC., DOES 1- 225, and each of them, to pay Plaintiff CAROL
C. BALDWIN actual damages and for all their costs and expenses, in an amount to be proven at
trial, plus annual interest, as required by law;
5. As to the First through Eight Causes of Action, order Defendants SUNRISE
HOMEOWNERS ASSOCIATION, INC., DOES 1 - 225, and each of them, to provide such other
relief as the Court deems to be just and proper.
CERTIFICATE
I, CAROL C. BALDWIN, state under the penalty of perjury under the laws of the State of
California that I have read the foregoing Complaint and all is true to the best of their information
and belief.
Dated:
del3
JAM:ft!
/4004
CAROL C. BALDWIN, an individual person, by
CHARLES F. BALDWIN, under Power of Attorney.
CAROL C. BALDWIN'S COMPLAINT FOR DISABILITY DISCRIMINATION Page 25 of 25.