SUMMONS Gross-Complaint eo Satsooe cnsoerg (CITACION JUDICIAL-CONTRADEMANDA) . NOTICE TO CROSS-DEFENDANT: FILE (AVISO AL CONTRA-DEMANDADO): RAYMONDO MCDONALD, an individual; AHMAD BROOKS, an individual; and Roea 1 through 20 WIS NAY-5 P 3 08 el ‘You have 30 GALENDAR DAYS aftor this summons and legal papers are served on you to filo a writin response at tis court and have a| ‘copy served on the oress-complainant. A letter or phone call wil net protect you. Your weltten response must bein propor legal form I you| ‘want the courtto hear your ease. There may be a court form that you can use for your response. You can find these court forme and mare ‘Information atthe Callforia Courts Online SellsHelp Center (www.courtinfo.ca gov’selihelp), your county law llbrary, or the courthouse nearest you. tf You cannot pay the fing feo, ask tne court clark for a fee waiver form. you do nat fle your response on tne, you may {eae the case by defauit, and your wages, maney, and property may be taken without further warning from the cour. "There ore other legal requirements, You may wart to eal an attorney right away. lyou do not know an attorney, You may want to call an ‘attorney referal service, if you cannot afford an attorney, you may ba eligibe for free legal services from a nonprofit lagal services ‘program, You ean lecats these nonprofit groups atthe Califomia Legal Services Wob site (www lawhalncalfornla.org), the Calforala Courts Onitne Self-Help Center (www.courtinfe.ca.gov/setihelp) or by contecting your local court or county bar association, NOTE: Tho: ‘court hes a tatutory lin for walved fees and costs on ary settioment or arbitration award of $10,000 or more In acl case, The courts en must te paid afore the court will dlamise the eano. Tiene 20 DIAS DE CALENDARIO después do qua le entrequen esta citaclon y papeleslogales pare prosentar una respuesta por esqto en esta corte y hacer que se entregue una copla.al contrademandante. Una carta o una lamads (alenica no lo protoyen. Su respuosta for erto tne qe extar on format lag! erect i dese qu proces su caso ent crt, Es posible ave hay an frm que ‘Usted punda usar para su respuesta. Puede uncontrar estos do fa corte y mds Informacién en of Centro de Ayude de as Cortes do Calforia (wun sucarte.ce.gov), en la bbilotece de loyes de su condadt o en f corte que fe quede més cerca. S! no puede ‘pagar le cuote de presentactée, plda al secretaro dela corte quo lo db un formutaro de exenclon de pago de cuotas. Sino prasenta Su ‘respuesta a tiempo, puede perder # caso por incumpllmlentay la corte fe podeé quilar su sueldo, dinero y blanes sin mds advartancl. Hay ofros roquistos gales. Es recomsandable que leme a un abogadlo hmmediataments, $i 0 conoce a un abogado, puede fomar a un seriefo de remisién a abogados. Sino puede pagar a un abogsdo, es pasibfe quo cumpla con los requisiios para obtener servicios legales ‘gratuites de un programa de sarvelos gales cin fines de lvero, Puede encontrar estos grupos sin fins de lucro on et sito web de Catfornta Legal Services, (wer lawhelpcalitorla.org, on el Centro de Ayu de las Corts de California (www. sucorte.ca.gov), © ‘niéndase en contacto con la corte o el colaplo de abogados iocales. AVISO: Por ley, le core tlene derecho a reclamar las cuotes y los costes exentos por imponer un gravamen sobre cualquler recuperscién de $10,000 6 ms le valor recibids mediante un acuerdo 0 une onessién de arbtaje en un caso de derecho civil. Tene que pagar el ravamen de [a core antes de que la corte pueda desechar ol or80, YOU ARE BEING SUED BY CROSS-CONPLAINANT: (LO ESTA DEMANDANDO EL CONTRADEMANDANTE): KEILEY WOLFF, an individual ‘The name and adress ofthe courts: ‘HORT NAVE OF CE en ang oi (El nombre y ceccién de le corte es): McDonald v. Wolff Santa Clara Superior Court CAREER pine Cons: 191 N. First Street, San Jose, CA 95113 A245-Gv-279208 ‘The name, address, and telephone number of cross-complainant’sattomey, or crose-complainant without an attomey, i: {Eloombe deco y mar de loo del aogado de! condemandens, 0 def cantradamandante que ro tiene Gloria Allred (state Bar No. 65033) 323-653-6530 Allred, Maroko & Goldberg, 6300 Wilshize Blvd., Suite 1500 jaa Angeles, CA 20048 DAVID H. YAMASABI — Gjerk, py Deputy ffocray MAY 0 5 2085 Chie Brecutie Ofer, Clerk fen tao —— ‘aunty ‘Far pil of ona of i semana, use Prost of Svcs o Soman (oma POST {Pan proba de onrega do esa ction ue of fordero Prot of Sen of Summons (P0S-010)) NOTICE TO THE PERSON SERVED: You are served — 1. (2) as.sn individual cross-defendent, 2. [5] asthe person sued under the ficitous name of (specly): 3. [) onbehall of (specity): under: CCP 416.10 (corporation) CGP 416.60 (minor) (CCP 446.20 (defunct corporation) CCP 416.70 {conservatoo) ‘CCP 416.40 (association or partnership) ‘CCP 416.90 (authorized person) 7) other fspecity): 4. (1) typermonaldetvery on (toy totes ‘SUMMONS—CROSS-COMPLAINT shine XVd Ad Gaia |La ese 1230 10-858-1063 ears mee ‘omplainant Keiley Weitt — FILED fsuPeRioR cour oF cauironma, counry oF Santa Clara ‘sweet ooress 19] North First Street wan ooness 19] North First Street, cerraozecooe: Santa Clara, CA 95113 sowie. Downtown “CASE NAWE: WIS MAY =-§ P 307 ll ge Wolff v. McDonald CIVIL CASE COVER SHEET ‘Gompiox Gave Designation aaa Vaintied Lo) tentiod eee 1-15-0v-278108 — — counter) sotndor oe ‘demanded demanded is FFted wih frst appearance by defendant | YO exceeds $25,000) $250000rless)| _(Cal, Rules of Court rte 3.402) | owrr: 02 Toms 1-6 below tat be Comte (see Iairuclons on page 7). [i Check ene box below forthe case ype that best descrbes tis cane: ‘uta Ton ovsinaty Complex Cl Ltn =~ Pr mnnon RERSIERII, ‘Urinsures motorist (46) (1 Rute 3:740 cotectons (08) (E) nutrsirrrade reguation 03) Cher PIPOMD (Personal ry Property ter are (0) Convctn dete (10), Danngatrontal Oval Tot aronce coveen (1) Nass ton eee tate ‘Other contact (37) ‘Secuiies Rigation (28) TE) Product aby (26) Rew Property Enviconmenttaxi for (30) (toto moran ee tmarmes comp coe ay te Oaiaeenaear ‘codensaton (0 Seve Bled renter comp cse oarsmen Wrote ae uses ota busines praca (7) CI} ere! rope 2) Enforcement of Jdgment [2] crits 08) Dotainer Enforcement of judgment (20) Detenaon (13) ‘Cones 1) Macotangcus Gl Complat Freud (16) ‘Residential (32) 2 cog titecu propery (13) re 8) Char cemeteries ob) 62) S ‘Professions nagigence (25) ei Rao a fiapetencue cet etn ter on PUPOMND tt (8) fotonre Pane an compoe gov 2) Employment Peon: iraton svar 11) 7 ia ster ie 1 otnerpetton ce spectted above) 43) L_[] omer enpioymers (10) [77 other jut even 2 Thiscase [Tis (eTJisnot complex under rule 3.400 of the California Rules of Court Wihe case Is complex, mark the ‘actor reguting exceptional dal management 2.2) Large number of separately represerted partes '.[—] Extensive motion practic ralsing dificult or novel ‘asves at wi be tne-consuming o resolve 1) Substantial amount of documentary evidence ‘3, Remedies sought (check all that apply): .[7] monetary b.[—] nonmonetay; 4, Number of causes of action (specify 6, thiscaso [Js [2] isnot 8 cass action su, ‘8, hare are any known related casos, file and serve @ nofice of related case, (You, Date: May 5, 2015, John C. Carpenter TRESR NT ‘+ Plain must fle his cover sheat wth he fst Lnder the Probale Code, Family Cade, or ‘sanctions, ‘+ File is cover sheet in adtion to any cover sheet requied by local court rule. WOTICE— ‘ith case fs complex under rule 2.400 et s09, ofthe Calfomna Ruves of Cour, you ‘other partes tothe action or proceeding, ‘= Untens this is colections case unter rule 9.740 or a complex case, this cover sheet wil be used for slaetcal puposes apse IVIL CASE COVER SHEET ‘Beto 28 3 Mod in the action or pracoeding and initalons Code). (Cal, Rules of 4.1 Large number of winesses 1 coordination wih related actions pending in ane or more courts ‘nother counts, sats, or coies, ona federal cout £. [1 Subetantat posyudpment judia syperisin ectoretaryorirjunctive reef aa small claims cases or cases fled ur ule 3.220.) Fale to le may sesut ‘Serve a copy ofthis cover sheet on all "St Susie onda Acre 49) XVd AG CaT | | i | icm.o10 INSTRUCTIONS ON HOW TO COMPLETE THE COVER SHEET ‘To Plaintiffs and Others Filing First Papers. If you are flag a first paper (lr example, 8 complainl) in a cil case, you must ‘complate and fe, elong wth your fret paper, tha Civl Caso Cover Sheet contained on page 1. This information wl te used to compile ‘Hallstos obout the types end numbers of coses fled, You must complete Rem 1 through 6 on he sheet In fem 1, you must check ‘One box or the case type that best describes the case, Ifthe case fis bolha general ard a more specific type of vase sted in tem 1, check the more specie one. the case has multe causes of acon, check the Dox thal best indicales the primary ceuse of econ. ‘To assist you in completing the shoe, examples of the casos thal Delong under each case type in tems 1 are provided below. A cover ‘sheet must bo fled only wath your inal paper, Faure to fle a cover sheet with the first paper fled ina cv case may subject» ply, {is counsel, or both io senctions under rules 2.80 and 8.220 ofthe Calfomia Rule of Cour. ‘To Parties In Rule 3.740 Collections Casas, A “colecitons case” under rule 3.740 fs defined ¢ an acton for recovery of money ‘owed in 8 sum stated io be certela tha is not more than $25,000, exclusive of Interest and attorney’ fees, arising from a trensaciion in ‘Wtich property, servicas, or money was acquired on eredl. A collections case does not Incude an action secking the folloning: (1) tort. ‘damages. (2) punttve damages, (3) recovery of real property, (6) recovery of personel propery, or (6) @ prejudgment wil of ‘attachment. The idenlfcallon of a cave ae a rule 3.740 cotections caso on this form moans thet it wil be exempt fom the general time-fr-serce requirements end case management rules, unless a defendart fles a responsive pleading. A rule 3.740 colectons ‘cage wil be eibjeet tothe requirements for service and obtaining a judgment In rule 3.740 ‘To Parties in Complex Casse. in complex caves only, panies must also use the Chil Case Cover Shoat to designate whether the ave is complex. fa plein believes the ease I complex under rule 3.400 af the California Rutes of Cour, tris must be inloied by ‘Completing the appropriate boxes in lems 1 and 2. I's plalntff designates a case as complex, the cover sheet must be served wih te ‘complaint on all parbes to the aclion, A delendant may Ma and serve no later than the time of its frst appearance a Janda in the plaints designation, @ counter designation thatthe cage isnot complex, o,f the plaintiff hes mado no designation, a designation that the — (CASE TYPES AND EXAMPLES: ‘uo Trt contrac, rovishnaty Complex chil Lgaton (Ca ‘te (2)-Pesoa nuyerepety rea Conran 09 Ff ee Ree ‘amogatrang Death veh ot Reno "anu ae Reganon aun oped courmeeteccen, ochre ton ‘sot cate su Contact Worranty Breach-Selier ‘Seourtties Litigalion a rot aogier) ronments To o> Negigant roach oneal insures Comaps Cs, i ‘ter bench of Cokaetaraty Sie ppetieo iow OO Cofactor fg. eey owed open Enforcement eo assur cere chs Coe Ste Peta ‘oot spent Oot ‘tet omar NobaColectons conten snes “rauranet Coverage (not proviionaly reetions) ono (8) Siar Sata stpmen ‘ao taogeton ey Art scores on elit of ay coma Conreat ica Camden Fin “Sipe on Orga eae roa recat oa ote tng orament of ert ‘inner Bonsintavere maconaoous Ct Complant Sorderaion 0) ce erga 3) ‘het Coma (rt pected Ct eal Prope ea, et He 20) 7 ay ata pmeln ie nay Decale te oust See est Proper fret embent Meer or Case, Unit beter onan eaoga ‘Commer oot ne Retort stances Ot Brags (0 case vob eat err od Capers “age eck as em aero, oneerad ‘mee Canmore or Resi) “ uate Ror 40 ay Fein fe: arsatonAvard 1) Were lees ‘Wht of Nardate 2) mineponcen eat ror Pettion for Name Change “comin Wit-OtherUiited Court Cave ee ee ee ober Gt Potion te i Rai (0) ave ooo Stee Order Note ef pesado Comer Apes Paniatinniay GIVIL CASE COVER SHEET eneeGloria Allred, SBN 65033 SBN 155610 IBN 155539 [AN & ROWLEY, LLP suum for Defendant, UO FILED mis KAY -§ P30 eek sees ioe SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SANTA CLARA RAYMONDO MeDONALD, an individual Plaintiff, ve. KELLEY WOLFF aka KEILEY WOLFF, end ‘Does J through X, ‘Defendants, KEILEY WOLFF, an individual Cross-Complainant, vs, RAYMONDO McDONALD, an individual; AHMAD, ROCKS, a individual; ond Roes 1 Defendants, ‘CASE NO. 1-15-0v-278108 Assi Feds March 16, 2015 ‘Trial Date: Not set MPLAINANT KEILEY /OLEE'S FOR DAMAGES: 1, ASSAULT AND BATTERY; 2. NEGLIGENCE; 3. INTENTIONAL INELICTION OF EMOTIONAL DISTRESS; AND 4, FALSE IMPRISONMENT **DEMAND FOR JURY TRIAL** Sedge: Hon: Pca M. Lc XVI Ad GSTCrose-Complainant Keiley Wolff alleges: PARTIES 1. Cross-Complainant Kelley WolfT is an individual and is now, and a ll times mentioned in this complaint was, «resident of California. 2, Cross-Defendant Raymondo McDonald was at ail times mentioned inthis complaint a resident of California and a member of the San Francisco 49ers professional football tam, Mr, McDonald is currently a player forthe Chicago Bears. His current residence is unknown, 3. Cross-Defendant Ahmad Brooks isan individual and is now, end a al times mentioned in this complaint was, a resident of California, Mr. Brooks is a player for the San Francisco 49ers, a professional football (eam. 4, ‘The trae names and capacities of the defendants sued herein as ROES I through 20, are unkoown to the cross-complainant, who therefore sues such defendants by such fetitious names pursuant to Code af Civil Procedure § 474, Cross-Complainant alleges that each Altitiously named defendant acted or flled to get in such a manner that each has caused the damages to the eross-complainant alleged herein. Cross-Complainant will seek leave to amond {his complaint to set forth the true names ofthe fictitiously named defendants and their capacitios ‘when ascertained, Reforence herein to any defendant shall include reference to all defendants, Including all named and all fltitiously named cross-defendants, 5. Atal times relevant herein, Cross-Defendant Raymondo McDonald owned ‘maintained, controlled, and managed the residence at 2516 Bentley Ridge Drive, San Jose, California 95138 (hereinafter the "Subject Property”), 6. The cross-complainant js informed and believes and thereon alloges that at all times mentioned in this complaint, all of the defendants — inctuding ROES } through 20 ~ were the agents and employees of their co-defendants, and in doing the things slleged in this complaint wore noting withln the course and scope of thet agency and employment and with the knowledge, permission, and consent of each of the co-defendants. Cross-Complainant is further informed een a TT rear ceee aCe 2‘and believes and thereon alleges that each of the defendants designated ROE is respousible in some manner for the events and bappenings herein referred to and thereby proximately caused {injuries and damages to the cross-complainent as horcin alleged, 7, ‘Theerass-complainant further alleges that cach defendant ralified and approved of the acts of each ofthe other defendants and that each ofthe defendants participated in a common plan or scheme and wilfully agreed and conspired with each of the other defendants todo the acts ‘and actin the manner horcin alleged, and that in doing the acis herein alleged, each ected pursuant to and in furtherance of said common plan or scheme. GENERAL ALLEGATIONS 8 On or about December 14, 2014, the cross-complainant was invited by Cross- Defendant McDonald to visit his residence, the Subject Property. On that day, the cross- complainant did infact visit tho Subject Property, 9, Prior to that day, the cross-complainant was unaware thet Defendant McDonald ‘was a professional football player. Cross-complainant was further imaware that Defendant McDonald had been in the news for allegations of domestic violence. 10, Cross-complainant is informed and believes that surveillance video at the Subject Property shows the following, without limitation: ‘A. The cross-complainant slipped and fall on a negligently maintained, dangerously slippery deck near the swimming pool and struck her head. Cross-complainant is informed and believes thot she suffored a traumatic brain injury, including a loss of consciousness for more than eight minutes, B, —_Cyoss-complainant is informed end believes thot while she was lying ‘unconscious on the poo! deck, Cross-Defendant McDonald erroneously believed her to be dead, did not call 911, and told others that he did not want a dead female to be found on his property. c Cross-complainant is informed and believes that she regained semi- ‘consciousness, but then fell on additional occasions due to her altered state from the bead injury and earlier consumption of alcohol.D. _Cross-complainant is informed and believes thet while she was ‘unconscious from a subsequent fall, Cross-Defendant Brooks groped her person in a sexoal ‘manner, E, —_Cross-complainant i informed and belioves that prior to regaining full consciousness and while she was unable to give consent, the cross-complalnant was carried upstairs by Cross-Defendant McDonald to his bedroom, 11, Thereafter, Cross-Defendant McDonald removed the cross-complainant’s clothes and then eogaged in un-consented touching, restraint, nd sex with the cross-complainant. Atal times, the cross-complainant could not consent (othe touching and did not consent. 12, Such un-consented touches continued through the following day. EIRST CAUSE OF ACTION (Ascault and Battery agaist All Cross-Defendants ) 13. Cross-Complainant incorporates herein by reference as though set forth in ful here a, paragraphs | through 12, inclusive of the Cross-Complaint herein as though set forth in full here, 14. nor about December 14, 2014, at the Subject Property, Cross-Defendants Brooks, McPonald, and Roes 1-20 intentionally caused harmful and offensive contact and foree ‘with the cross-complainant’s person by his willfel and intentional acts of harmful and offeasive touching. 15. ‘The cross-complainant did not consent to any of the offensive contact or ‘attempted contacts with her person. 16, ‘The cross-defendants threatened ond instilled inthe cross-complainam an apprehension, intimidation, and fear of immediate offensive, violent and unlawful injury on her Person, and actual injury on her person. ‘17. ‘The cross-defendants’ acts were authorized, approved, condoned and/or ratified by each of the defendants. 18. Ase proximate result of the cross-defendants’ cts as deseribed above, the rass- Coa oa 4complainant was hurt in her health, strength, and activity, sustaining injury to her body and shock and injury to hee nervous system, and person all of which injuries have caused and continu to ‘cause the cross-complainant great physical, mental, and nervous pain and suffering all to ber ‘general damages in an amount to be proven at trial and incurred damages all to her general damages in an emount to be proven at tial 19. Asa further proximate result of Cross-Defendants acts” and each of them, as ‘mentioned herein, and because of the injuries it was necessary for the eross-complainant to receive medical care and treatment and the cross-complainant did incur hospital, medical, and incidental expenses and will inthe future be compelled to incur additional expenses in an amount unknown to the orass-complainant ot the present time but to be proven at trial. As a further proximnie result ofthe negligence of Defendants and each of ther, the cross-comploinant's ‘earning capacity hes been greatly impaired, both inthe past and in the present in an amount according to proof, 20, The aforementioned acts of Cross-Defendants wore despicable, willful, and malicious and were intended to oppress and cause injury 1o Cross-Complainant within the meaning of the Civil Code § 3294, and, therefore, the Cross-Complainant is entitled to an award of exemplary and punitive damages in an amount sufficient to punish Cross-Defendans, and 10 eter the Crose-Defendants from committing similar acs inthe Future, SECOND CAUSE ACTION (Negligence Against Cross-Defendants McDonald and Roes 1-20) 21, Cross-Complainant incorporates herein by reference as though sot forth in fll here a, paragraphs 1 through 20, inclusive of the Cross-Complaint herein as though set forth in fall bere, ‘22, Qn or about December 14, 2014, at the Subject Property, Cross-Complainant ‘slipped and fell near the pool deck, catusing the cross-complainant to sustain serious injuries and damages as described herein, 23, At the aforementioned time and place, the cross-defendants negligently ae 5‘maintained, managed, controlted, installed, and operated the Subject Proporty, causing the cross- ‘complainant to be injured. These cross-defendants, knew, or inthe exercise of reasonable care should have known, the pool deck area constituted x dangerous condition and unreasonable risk ‘offarm. These cross-defendants negligently, and in reckless disrepard, failed to take steps to ‘either make the condition safe, or warn the eross-complainant of the dangerous condition, all of ‘which caused the cross-complainant to suffer the injuries and damages hereinafter desoribed all ‘of which wore directly and proximately caused by the cross-defendants’ negligence, 24, Asa further direct and proximate result of the negligence of the cross-defendants as se forth above, the crass-complainant sustained the following serious injuries and damages: ‘She was injured in her health, srengih and activity, sustaining injury to her body and shock and injury to her norvous system, and person, and extreme and severe menial anguish and emotionat distress all of which have emused and continus to cause the cross-complainant great physical, ‘mental, and nervous pain and suffering all to her general damages in an amount to be proven at ‘vial, 25, Asa further proximate result ofthe negligence ofthe cross-defendants and cach of them, as mentionod herein, and because of the injuries it was necessary forthe cross-complainant to receive medical care and treatment and the cross-complainant did incur hospital, medica, and incidental expenses and will in the future be compelled to incur additional expenses in an amount ‘unknown to the cross-complainant ut the present time bul to be proven at tral, 26, Asa further proximate result of the negligence of the cross-defendants and each of them, the eross-complainant’s eaming capacity has been greatly impaired, both inthe past and in the present in an amount according to proof, ‘THIRD CAUSE OR ACTION Wor Intentional Infliction of Emotional Distress against all Cross-Defendants) 27. —_ Cross-Complainant incorporates herein by reference as though set forth in full hore at, paragraphs 1 through 26, inclusive ofthe Cross-Complaint herein as though set forth in full hepe, —eSSS 628, ‘Through the outrageous conduct described above, Crass-Defendants, and each of them, acted with the intent to cause, or with reckless distogard forthe probobility of causing the ‘Cross-Complainant to suffer severe emotional distress, 29, Asadirect and proximate eause of action or inaction by the eross-defendants, the cross-complainamt has suffered and will continue to suffer pain and suffering, oss of sleep, and extreme and severe mental anguish ond emotional distress; she has incurred and will continue 10 incur medical exponses for treatment by psychotherapists and other health professionals, and for other incidental expenses; and she has suffered and will continue to suffer a Joss of earnings and othor employment benefits and job opportunities. The cross-complainant is thereby ened to general and compensatory damages in amounts to be proven at trial, 30, Tho aforementioned acts of cross-defendants, were despicable, willful, and ‘maliclous and were intended to oppress and cause injury 10 eross-camplainant within the ‘waning ofthe Civil Code section 3294, and, therefore, the cross-complainant is entitled to an award of exemplary and punitive damages in an amount sufficient to punish cross-defendants, tnd to deter the eross-defendants from commiting similar acs in the future. FOURTH CAUSE OF ACTION (False imprisonment against All Cross-Defendants ) 31, The cross-complainant re-alleges each and every allegation contained in the above paragraphs 1 through 30, and by this reference incorporates said paragraphs as though fully set forth herein, 32, Onoor about December 14, 2014, a the Subject Property, Cross-Defendants {intentionally deprived the cross-complainant of her freedom of movement by use of physica {force and unreasonable duress, 33. The confinement aod restraint of the cross-camplainant compelled the oross- complainant to stay for an appreciable amount of time, 34, The croas-complainant did not consent, 35. Asa proximato result of the cross-defendants’aots as deseribed above, the cross SSEaEEEEEEEETTTUETEECEC UT TTTETEECEE TT TTveTee Smee eC TITTIES TSSETCTTOT ee TTTTTTTTEcomplainant was hurt in her health, strength, and activity, sustaining injury to her body and shock and injury to her nervous system, and person all of which injuries have caused and continus to ‘enuse the cross-complainant great physical, mental, and nervous pain and suffering all o her {general damages in an amount to be proven at trial and incurred damages all to her generat damages in an amount (o be proven at trial. 36. Asa further proximate result of the cross-defendants ects’ and each of them, us ‘mentioned herein, and because ofthe injuries it wes necessary for the eross-complainant to receive medical care und treatment and the cross-complainant did incur hospital, medical, and incidental expenses and will in the future be compelled to inour additional expenses in an amount unknown fo the eross-complainant atthe present time but to be proven at tral, Asa futher proximate result ofthe negligence of cross-defendants and cach of them, the cross-complainant’s earning capacity has becn greatly impaired, both inthe past and inthe presers in an amount according to proof, 37, ‘The aforementioned acts of eross-defendants were despicable, willful, and malicious and were intended to oppress and cause injury to crose-complainant within the meaning of the Civil Code seetion 3294, and, therefore, tho cross-complainant i entitled ton ‘award of exemplary and punitive damages in an emount sufficient to punish crose-defendants, and to doter the cross-defendants from comunitting similar ects inthe future, Mt ut ut m a uaWHEREFORE Cross-Complainant prays judgment against the Defendants and cach of them, as follows: ‘ALL CAUSES OF ACTION: aw eee For general and compensatory damages according to proof; For all special medical and incidental expenses accarding to proof; For lost eaming and lost earning capacity; Punitive and exemplary damages (except as to Cause of Action No. 2), Costs of suit; and For such other and further relief as to the Court may secm just and proper, DATED: May 5, 2015 Respectfully submitted, ALLRED, MAROKO & GOLDBERG LLL Aease a ewe RRB BS DEMAND FOR JURY TRIAL ‘The Cross-Complainant hereby demands a tral by jury on all eauses of action. DATED: May 5, 2015 Respectfully submitied, ALLRED, MAROKO & GOLDBERG Z en ‘Attomeys for Cross-Complainant IAN & ROWLEY, LLP John C, ‘Atlameys for ross-Complainant 20BRR EB PROOF OF SERVICE. STATE OF CALIFORNIA, COUNTY OF LOS ANGELES \ DISMAY -§ PL 3 08 Tam. in the County of Los State of California, oat | to ta within action 3 my business fs: 8827 West 0 a i © May 5, 2015] pred the ataced dosmret COMPLAIN. lias CROSS. COMPLAINT FOR DAMAGES onal (rere paves thi ston by la the tru copies thereof enlonedin ele envelopes adresed as ate onthe atch naling it by pacing © Oth original @ a rue copy thereof enclosed in sealed envelopes addressed as BONS a palit do Glens 951 ines fray” mBY U.S. MAIL © | dapsie such envelop inthe mail at Los Angels, California, The envelope rnalled wih ponage thereon fall repel bean ii re @ As follows: [ am “readil furiliar” withthe rns practice of collection and rae tame aes recat yi aio service on that same in Is, in 5 business ervey service is cee err EXECUTED on May 5, 2015, at Beverly Hills, California, @ STATE - | declare under penalty of perjury under the laws of the Spfte of California tht the above is true and canect, uae = ae a