Case 2:16-cv-03595 Document 1-1 Filed 05/24/16 Page 1 of 13 Page ID #:5

EXHIBIT A
 Case 2:16-cv-03595 Document 1-1 Filed 05/24/16 Page 2 of 13 Page ID #:6

SUMMONS $aLo
FOR COUR'I USE OI,ILY
PARA USO De tA CORTE'

(ctT4ctoM JUDICTAL)
NOTICE TO DEFENDANT:
(AV|SO AL DEMANDAÐO):
:Wþiffie^-ff'fr:*"
VALVE CORPORATION and DOES I through 10, inclusive
APR l2 2016

YOU ARE BEING SUED BY PLAINTIFF: Executive Ofliær/Glerk

Sheni R' Carter'
(LO ESTA DEMANÐANDO EL DEMANDANTE): """" ðn"'na Griiatva' DePtnY
är'
A.M.

NOTICE] You have been sué¿. The court may decide against you without your being heard unless you respond wilh¡n 30 days, Read the information
below.
You have 30 CALENÐAR DAYS afler this summons and legal papers are served on you to file a written response at this court and have a coPy
seryed on ihe plaintiff. A lelter or phone call will not protect you. Your written response must be in proper legal forrn if you want the court to hear your
case. There rnay be a court form that you can use for your response. You can lìnd these court forms and more information at the California Courts
Online Self-Help Center (www.couftlnfo.ca.gov/selfheip), your county Íaw library, or tfre courthouse nearest you. lf you cânnot Pay the filing fee, ask
the court clerk ior a fee waiver fonn. lf you do not file your response on time, you rnay lose the cãse by default, and your wages, money, and propefty
may be taken without further warning from the court.
Íhere are other legal requirements. You may want to oall an attorney right away, lf you do not know an attorñey, you may wanl to.c¿ll an attorney
referral servioe. lf you cannot atford an attomey, yoq may þe eligiþle for free legal serulces from a nonprofit legaf services progtarn. You can locåte
these nonproflt gróups at the Callfornia Legel SeMces Wêb site (www.tawhelpca!ífornia.org), the California Courts Online Self-Heip Center
lfen for walved fees and
lwww.coirtinlo.óa.gou/setfhetpl, or by contacting your local court o¡ counly bar association. NOTE: The court has a stâtutory
òosts on any settlement or arbitration award of $10,000 or more in a civil case, The court's lien rnust be pald before the Çourt wlll dlsmiss tho case.
¡.4VISOI Lo'han demandado. SÍ no respon de dentro de 30 días, la corte puede decidir en su contra sin escuchar su versìón. Lea ta información d
continuación,
Tíene 30 DIAS DE CALENDARTO después de que te enteguen esta citación y papeles i/egales para þrcsèntar un1 rêspuasta por escrifo en esfa
ctrte y hacer que se enlregue una copia al demandante, IJna cafta o una llamada lelefônica no lo protagen. Su têspuesta pot êscrito tiene gue esfar
en îormato legal correcta s,'desea quê procesen s¿, caso ên ta coie. Es posr'b/e quë haya un formularío que usted pueda usar para sü respuosfâ'
puede oncoitrat estos formularÍos de ta corte y nás ¡nforffiaciön en e! Çentro dø Ayuda de /as Corfes de California (www.sucorte.ca .gov), en la
btbtioteca de /eyês de su condado o øn la corle que te quede mâs cerca. Si no puede pagar la cuota de presantacìón, P¡da al secretar¡o de Ia corte
que le dé un formutario de exencion de pago de cøoles, Si no presenf€ su respr.resta a tiempo, puede pêrdør øl caso por incumplim¡ênto y la cofte lê
podrá
- qulrar su sualdo, dinero y ôlenes sin nâs advertencla.
Hay òtros requlsl¡os legaies.'Es recomendable que llame a un abogado inmediatamente. Si no conoce a un abogado, puede llamar a un servicio de
remii¡ón a aÞogados. Si no puede pagar a un abogado, os posrb/e que cumpla con /os regulsilos para obtener seruicios legales gratuítos de un
programa de servlcios legalos si¡t fines de lucro. Puede encontar aslos grupos srn fines de luao an el sítio web de California Lagal Serv/ces,
ponìéndose en contacto con la corle o e!
ltvww.tawnelpcalifornia.org), en el Centro de Ayuda de las Corfes de Ôalifornia,lwww,sucorte.ca .gov) o
cotegio de abogedos toÇates. ,AVJSO; Por tey, ta corte t¡ene derecho â rcclamar las cuo¡âs y /os cosjos exe¡ttos por ¡mponer un grauamen sobre
cuanu¡er recuieracion de $10,000 ó más cta valor rêctb¡da medlantë uh acuëtdo o una concesiön de ârb¡traie en un caso de deracho civit. Tlena que
pagat et gravâmên dë la cofte antes dø que la corte pueda desechar el caso,
CASE NUMBER:
The name and address of the court is: (Númsrc dsl Casr:
(EI nombre y Los Angeles Superior Court
direccíon de ta Çorte esJi
I l1 N. Hill St. Los Angeles, CA 90012

The name, address, and telephone number of plaintiffs attorney, or plaintíff without an attorney, is:
BC6 t 6 7 ns
(EI nombre, Ia dirección y el número de teléfono del abogado del demandanle, o del demandante que no tiene abogado, es):
Chad Biggins206922,370l Wilshire Blvd., Suite 410, Los Angeles, CA 90010 Tel: 213-387-3100

DATE:
APR I Z 2016 Clerk, by , Deputy
(Fecha) tario) (Adjunto)
of this summonq use Proof
(Para prueba de entrega de esfa c¡tatión use el formulano Proof of Service of Summons, NIÊ.GRI,IALVA
NOTICE TO THE PERSON SERVED: You are serued
[SEALì
as an indiv¡dual defendant.
2. f1
as the person sued under the fìctitious name of (specìfy)

3. f-l on behalf of (specify):

under: l--l ÇcP 416.10 (corporation) CCP 416.60 (minor)

[:l CCp 416.20(defunct corporation) t_f CCP 416.70 (conservatee)
L*l CCp 416,40 (association or pârtnership) CCP 4'10.90 (authorized person)
l---lother (specify):
4. T-l by personal delivery on (date):
Pâoê I ôf {
Form Adopt€d for lvt€ndâlûy Use Code of c|vil Proc€dure S$ f2.20, 485
Judld¿l Counc¡l of Çallforn¡8
SUMMONS 4
www.cow'liilo.ce,gëv
SUM-100 [Rev. ûly l, 20091
EXHIBIT A
1
 Case 2:16-cv-03595 Document 1-1 Filed 05/24/16 Page 3 of 13 Page ID #:7

I Chad Biggins, Ësq. (State Bar No. 206922)

Biggins Law Group
L 3701 Wilshire Blvd, Suite 410
Los Angeles, CA 90010
:'?lfffË,ftffiF,ßg*'
öulerrÐr Çourt of Qalliornia
5 \,ol,lnly ':t L,oS Angel€,S
T:213-387-3100
4 F: 213-387-3 t0l APR I 2 2T16
chadbiggins@grnail, com
5 Sherri R. Carter, Executive Officer/Clerk

Attomeys for Plairrtiff By Cristina Grljalva, Deputy

6 A.M.
7

8
SUPERIOR COURT OF TI.IE STATE OF CA.LIFORNIA
9
FOR THE COUNTY OF LOS ANGELES
10

1l A.M., Case No.

ts0e16?60
12
Plaintiff, COMPLÄINT FOR:
l3 1) WRONGFUL TERMINATION
vs,
t4 2) DTSCRIMINATION
3) FATLURE TO ACCOMMODATE OR
15 ENGAGE IN INTERACTIVE PROCESS
VALVE CORPORATION and DOES 1
4) HOSTILE \ilORK ENVIRONMENT
through 10, inclusive s) RETALIATION
T6
6) UNPAID WAGES (OVERTIME)
17 Defendants 7) BUS. & PROF'.. CODE $ 17200
8) MISCLASSIFICATION
18
IDEMAND FOR JURY TRIAL]
l9
20

2t Plaintiff A.M. ("Plaíntiff'), by arrd through her attorney, alleges aud avers as follo"vs:

22 1. Plaintiff is infonned and believes and based thereon alleges that, at all times herein
¿5 relevant, defendant VALVE CORPORATION (hereinafter referred to as "Defendant"), was, and

24 still is, a corporation with its principal location in the state of Washington' Defendant is a
25 prominent company in the video garne industry. It develops video garnes and sells games otl the
26 Internet. Its titles and content are translated into numerous larrguages and distributed all over the

27 world.
28

Case No
COMPLAINT
EXHIBIT A
2
 Case 2:16-cv-03595 Document 1-1 Filed 05/24/16 Page 4 of 13 Page ID #:8

I Z. Plaintiff is unaware of the tlue names and capacities of the defendants sued herein

2 as DOES 1 through 10, inclusive, and therefore, pursuant to section 474 of the Code of Civil

J Proce{ure, sues these defendants by such fictitious nalnes. Defendants DOES I through l0 are

4 responsible in some rnaltner for the activities alleged herein and each was acting as an agent for the

5 others. Plaintiff witl arnencl this Complaint to add the true names of DOES I tlrough l0 once they

6 are ascertained,

7 3. At all times herejn urentioned, Califomia Governnrent Code ("Cocle") $ 12940 et

8 seq., the Fair Employment and Housing Act ("FEHA"), was in full force and effect and was

9 binding on Defendants.

r0 4IRST CAU$E OF AqIION AGAINST DF.FENDANTS

ll FOR \MRONGJUL TERMINATION

T2 4. Plaintiffincorporates by reference and re-alleges as if fully stated herein the

13 material allegations set out above in the preceding paragraphs-

l4 5. At all times relevant, Plaintiffwas an employee of Defendants. Her position was

l5 primarily translating contsnt into Spanish, as well as other duties, such as acting as a iiaison with

16 law enforcement officers of Spanish speaking countries' governments and providing customer

t7 service.

t8 6. Prior to 2012,Plaintiff worked as an ernployee irr the Washington headquarters.

19 I{orvever, in about 20t2 shedecided to undergo gendertransition, and to do so, she needed to

20 move to Los Angeles where her cloctors r.vere locatecl arrcl she could also recover frorn the surgical

21 procedures while still working. Defendants accommodated her request to relocate and allowed lter

22 to work fi-om home due to the gender transition issues, as well as related disabilities including

23 depression and other socialization issues.

24 7 . However, as a condition of moving to Los Angeles, Deferrdants required that

25 Plaintiff be classified as an "independsnt conttactor" aithough slre was still perfonning the same

26 duties as when she lvas classified as an "enrployee." The title "independent contractor" is

27 irrelevant as Ptai¡rtíff was absolutely an employee under the law and she was tnis-classif,red as an

28

Case No. 2

EXHIBIT A
COMPLAINT

3
 Case 2:16-cv-03595 Document 1-1 Filed 05/24/16 Page 5 of 13 Page ID #:9

I independent contractor from 2012-2016. Every element of the control test is met' She was

2 performing service in whicli the Defendants were engaged; Her work was a part of the regular

J busir¡ess of Defe¡dants; She maintained the same position fbr many years and was paid on au

4 hourly basis (as opposecl to being paid for a specif,rc project); and most imporlantly the Defendants

5 maintained close control ancl direction over Plaintiffs q'ork.

6 8. The classification as "independent contractor" was hannful to Plaintiff because she

1 lost her-employee benefits, including healtii benefits, and she was also not paid overtime wages for

B the hours she worked overlime.

I 9. Plai¡tiff continued working frorn horne in Los Angeles. However, she began

10 complaining to humap resources about their unfair business practices of utilizing peopie who were

11 interested in their products to provide translation services for free. She complained that thess

12 unpaid translators, often very young minors, were being exploited and lured to work for

t3 Defendants based on faise promises made by her supervisor, Torsten Zabka. lndeed, they would

14 work hours upon hours based on promises that their work could lead to a paid position, but in the

l5 end Torsten Zabka invariably found excusos to renege on his promises. Plaintiff felt bad for the

16 exploited minors and complained to Human Resources about this issue, and other complaints

17 involving Torsten Zabka creating a hostile work environtnent and mistreating ernployees.

18 10. Then, within days afler a written complaint about the hostile work environment,

19 (whÌcþ complainls were never addressed by hmtan resources), on or about January 15,2016,

20 Plai¡tiff was termiriated without any valid basis. The stated reason for the termination was tllat

21 Plaintiffs job was beiug relocated to Washington. Howevet', when Plaintiff offered to relocate

22 back to Wastrington, Defendant refused. Thc stated Teason for tennination was pretextual and on

23 information and belief, there was never any actual iutent to relocate the job to Washingtorr.

24 I L The real reason for tennination was that Plaintiff was con:plairiing about the hostile

25 work environnrent and illegal busiuess practices as stated above. Moreover, Plaintiff vvas

26 tenninated due to her trans-gelrder status, While Defendants accommodated her at first, her direct

27 supervisor, Torsten Zabka,refen'ed to her in a derogatory fashion. He refemecl to Plaintiff as "it" -

28

Case No, 3
COMPLAINT
EXHIBIT A
4
 Case 2:16-cv-03595 Document 1-1 Filed 05/24/16 Page 6 of 13 Page ID #:10

I which is highly offensive to a trans-gender person. The term "it" dehumanizes transgender persons

2 and the usage of such a term by Torsten Zabka shows that he was biased against her and shorvs

that her trausgender status was another reason he decided to terminate her. The real reaso¡ls for
a
J

4 ter:nination are unlawful.

5 lZ. As a direct and proximate result of tlie afcresaid acts of Defendants, Plaintiff has

6 suffered arrd will continue to suffer actual, cotlsequential and inciclental financial losses, including

1 without limitation, loss of salary and benefits, all ín an iìmount subject to proof at the tirne of trial.

I Plaintiff clairns such amount as damages together with prejudgment interest pursuant to Civil Code

I $ 3287 and any other provision of law provicling for ptejudgment interest'

l0 13. As a direct and proximate result of said wrongful acts by Defendants, Plaintiff has

lt suffered and will continue to suffer Post Traumatic Stress Disorder, humiliation, shame, despair,

t2 embarrassment, depression, stress, anxiety, fear and mental pain and anguish, all to Plaintiff s

l3 damage in an amount to be proven at time of trial.

14 14. As a direct and proximate result of said wrongful acts by Defendants, Plaintiff has

t5 incurred attorneys' fees in an amount to be determined, for which Plaintiff claims a sum to be

16 established according to proof.

l7 15. The above recited actions of Defendants were done with malice, fraud andior

l8 oppression and in reckless disregard of the rights of Plaintiff under the Fair Ernployrnent and

l9 Housing Act, Defendants'conduct was despicable and justifies an award of punitive datnages in an

20 amount sufficient to deter them from errgaging iu such conduct again in the future, irl an arnouut

2t according to proof at time of trial.

22 16. OnQ3/3012016, Plaintiff filed a cornplaint with the State of Califomia, Department

23 of Faír Ernployrnent and Housing. On that same day, DEFH closed Plaintiff s case in order to

24 allorv Plaintiff to pursue her action in court and issued a Rigþt-to-Sue letter.

25 SEC OI\ID CA USE -O-F'

ACTION AGAINST D EFEN DANTS

26 FOR DISABI-L.ITY / GENDER IDENTITY DISCRIMINATION

27 17 , Plaintiff incorporates all prior allegations as if fully set forth herein.

28

Case No 4
COMPLAINT
EXHIBIT A
5
 Case 2:16-cv-03595 Document 1-1 Filed 05/24/16 Page 7 of 13 Page ID #:11

1 18. At all times relevant, Plaintiff had a disability, to wit, depression and a-social

2 issues including Asperger's Syndrome. Defendants knew about these disabilities and

J accomr¡rodated them in 2012 rvhen they allowed Plaintiff to move to Los Angeles and work from

4 home, (The issue with r.vorking in the office as opposed to horne has to do with the socialization

5 ancl interactiori with people, which is extremely difficult for Plaintiff due to these disabilities and

6 also r.vith avoiding practical clifficulties of havirig to work in an office with people while
n
recoverirrg from surgícal proceclures.)

I 1g. Plaintiff was able to perfbnn her job ciuties with the reasonable accomrnodation of

I working from home.

10 20. Defendants t'ailed to provide the reasot:able accommodation based on the stated

11 reason for termination, to wit, that Plaintiff was being fired because they required her to work in

t2 the office in Washington. V/hen Plaintiff agreed to do this in order to save her job, despite her

r3 disabilities, Defendants flat out refused and said "'We ate not interested in moving you back to a

t4 full tirne position at Valve."

l5 Zl.. Defènda¡ts terminated Plaintiffdue to her disability / transgender status,

t6 ZZ. Defendants' failure to provide a reasonable accomnrodation to Plaintiff was a

t7 substantial factor in causing her hann.

18 THIRD CAU..$E OF ACTION AçAINST DEFEI\iDANTS

19 AoR FAILURE To ACç,9MM-0DAT-P / ENGAGE IN THP INTE"RT{CT-IVE PROCESS
20 23, Plaintiff incorporates all prior allegations as if fully set forth herein.
21 24. The interactive process required by the FEHA is an i¡rfonlal process with the

22 ernployee to attempt to iclentify a reasonable accolnmodatiorr that will enable the employee to

23 perfonn the j ob effecti vely.

24 25. As stated above, Defendants failed and reñ¡sed to accommodate Plaintiffs

25 disabilities and failed arrd refused to errgage in an interactive process to reasonably identify a way

26 to accommoclate. For exanrple, if (which is not the case) Defendarrts truly had a valid reason to

27 require Plaintiff to work in the oftìce with the other ernployees, a reasonable accommodation

28

Case No, 5
COMPLAINT
EXHIBIT A
6
 Case 2:16-cv-03595 Document 1-1 Filed 05/24/16 Page 8 of 13 Page ID #:12

I might have been to give her a private office. But no such discussion was evetl engaged in because,
rüashington to work, Defendant
2 although Plaintiff expressed a willingness to relocate back to

J flatly refused her offer and refi'sed to discuss it further'

4 26. Defè¡clants' failure to provide a reasonablc âccommodation and failure to engage in

5 the interactive process was a substantial factor in causing Plaintiff harm.

6 FOUR,TH CAUSE OF'ACTION AÇAINST DEFENDANTÇ

7 FOR HOSTILE WORI{ ENVIF.ONMpNT

8 .
2"1 Plaintiff incorporates all prior allegations as if f'ully set forth herein.

9 28. Plaintiff was subject to unwanted harassment because she is transgender.

l0 Zg, Fufiher, her supervisor created a hostile work environtnent by sowing discord

l1 among the employees. Plaintiff reported this conduct to human resources.

1,2 30. A reasonable person in her circumstances would have considered the work

13 environment to be hostile or abusive.

T4 31, A supervisor engaged in the conduct, and Plaintiff reported the conduct to humart

i5 resources who failed to take immediate and appropriate corrective action.

t6 32. Defeudants' conduct was a substantial factor in causing Plaintiffharm.

T7 FIF'TII CAIJSE OE ACTION AGâ.INST DEFETTDANTS

18 FOB.RETALIA.TION

19 33. PlaintifTincorporates all prior allegations as if fully set forth herein.

20 34. Plaintiff engaged in protectecl activjty by complaining about the hostile ivork

21 environment created by her supervisor.

22 35. Defendants discliarged her as a direct and proximate result.

23 36. Defendants' failure to provide a reasonable accommodation and failure to engage in

24 the interactive process was a substantial factor in causing Plaintiff hann'

25 STXTH CAUqE OF AçTION¡,GAINST DE.FENDANTS

26 npR UNPAID WAGE$ (OVERTII\{S)

27 37 . Plaintiff incorporates all prior allegations as if fully set forth herein.

28

Case No. 6
COMPLATNT
EXHIBIT A
7
 Case 2:16-cv-03595 Document 1-1 Filed 05/24/16 Page 9 of 13 Page ID #:13

1 38. Eight hours of labor constitutes a day's work, and any work in excess of 8 hours in I

2 workday and any work in excess of 40 hours in any one worklveek shall be compensated at the rate

3 of ¡o less than one and one half times the regular rate of pay for an employee. Any work in excess

4 o1'12 hours in one day shaltbe cornpensated at the rate of no less than trvice the regular rate of pay

5 for an ernployee. (Labor code $ 510 and lwc wage or<lerNo. 4-2001 $ 3(A).)

6 39. During all tirnes relevant to this action, Plaintiffworked more than I hours per

workday, arrcl/or rnore than 40 hours per workrveek, in an amount to be proven at ttial, but clid not
.1

I receive any overtirne wages for overtjnre hours suffered or permitted to work.

9 40. Plaintiff is informed and believes and based thereon alleges that she was not exempt

10 from overtime uncler any applicable exemption, and, thelefbre, she was and is entitled to overtime

11 compensation.

t2 41. Based on the misconduct alleged in this Complaint, Plaintiff seeks to recover

t3 unpaid overtime compensation, penalties, interest, reasonable attorneys' fees, and costs in an

t4 amount to be detennined at trial.

15 42, Plaintiff is infonned and believes and based thereon alleges that Defendants

t6 willfully failed to pay Plaintiff accrued wages and other compensation due to upon termination'

l7 43. Plaintiff is informed and believes and based thereon alleges that Defendants are

t8 liabte for statutory and civil waiting time penalties of up to 30 days of pay pursuant to Labor Code

19 $ 203 and other applicable laws and regulations.

20 44. Based on the rnisconcluct alleged in this Cotnplaint, Plaintiff seeks compensation

2l for oveftime and waiting tirne penalties and other remedies i¡r arr anrouut to be proven at trial.

22 SEVENTH CAUSE OF ACTION AGAINST DEFENDANT$.

23 FOR BIJ.S. & PRgF. CODE I 1720q)

24 45. Plairitiff irrcoryorates all prior allegations as if fully set forth herein.

25 46. Deferrdants, and each of them, are "persons" as defìned under Business and

26 Professions Code $ 17021.

27 4'?. Plaintiff is informed and l:elieve and basecl thereon allege that Defendants

28

Case No, 7
COMPLAINT
EXHIBIT A
8
 Case 2:16-cv-03595 Document 1-1 Filed 05/24/16 Page 10 of 13 Page ID #:14

I committed the unfair business practices, as defined by Cal. Bus. & Prof' Code $ 17200, et seq., by

2 violating the laws alleged to have been violated in this Complaint and which allegations are

3 incorporatecl herein by reference and include, but are not lirnited to the following: a' Failing to

4 pay Plaintiff all rvages due and owing including overtime wages,

5 48. As a rssult of the above-allegecl misconduct, Plaintiff has been deprived of lar'vful

6 wages to which she is entitled in an amount to be detenninecl according to proof at trial.

7 49. As a direct and proxirnate result of the aforesaid acts and conduct of said

I Defenda¡ts, Plaíntiff is entitled to ancl hereby seeks attomeys' fees as permitted by law and as

9 provided by for $ 1021.5 of the califomia code of civil Procedure.

10 EIGHTH CA OF ACTTON ÄGAINST EFENDANTS

1l FOR MISCLASSIFICATION úABOR,CODE .ç 226.8ì

t2 50. Plaintiff incorporates all prior allegations as if fully set forth herein.

13 51. Plaintiff is informed and believes that Defendants willfully misclassified Plaintif[

1.4 and others, as independent contractors.

l5 52. Plaintiff has suffered damages as a result of her misclasslfication as an independent

16 contractor, including increased taxes and insurance'

t7 53. Plai¡tiff has also bcen damaged bsçause she is unable to obtain unemployment

18 benefits and state disability benefits as a clirect and proxirnate result of the misclassification-

l9 54. Pursuant to Labor Code $ 226.8, Plaintiff is entitlecl to recover penalties and other

20 rernedies as set forth therein against Defendants.

2t PRAYTIR FOR RELIEF

22 WHEREFORE, PlaintÍff prays for relief and judgment against Defeudants as follows:

23 A. For general darnages in accordance with proof, estimated at $1,000,000.00;

24 B, For pu¡itive and exernplary damages iu an amount found appropriate by the trier of fact in

25 accordartce rvith proofl

26 C. For special darnages iu accordance r.vith the proof, estimated at $ 1,000,000'00;

27 D. For unpaid wages & penalties, estimated at $150'000'00;

28

Case No. I
COMPLAINT
EXHIBIT A
9
 Case 2:16-cv-03595 Document 1-1 Filed 05/24/16 Page 11 of 13 Page ID #:15

I E. For loss of earnings according to proof, estimated at $1,000,000'00;

1 F, For prejudgrnent interest and post-judgment interest in accordance with law;

C. For costs of suit, including attomey's fees pursuant to statute; and

4 H. For such other relief as the Court deems just and proper'

Dated:
5
(L [,,
6 Chad Biggins

7 PRAYER FOR JUßY TRIAL

8 Plaintiff hereby prays for a jury trial on all issues and causes of action so triable.

10 Dated:
6 Chacl Biggins

ll
l2
13

t4
l5

ló
T7

l8
l9
z0

2l
22

23

24

25

26

27

28

Case No. 9
COMPLAINT
EXHIBIT A
10
 Case 2:16-cv-03595 Document 1-1 Filed 05/24/16 Page 12 of 13 Page ID #:16
Bil numbq, and add.ess): FOR COURÍ USE ONLY
ATTORNEY (Nam6, Slalè

310 w B Ivd 4 l0
Los Angeles, CA 900 l0

TELÊPHONE NO,: 2r3-387-3100 Fpù<No.: 213-387-3101

ATTORNEY FOR Plaintiff CONFStrMEB EÐPY
couRT oF GALIFoRN¡A, COUNTv or lg5 Angeles ,. ORIG¡NÀL FILËÐ
Superior Court of Californ¡a
STRÊETADDRESS. 1 I I N. HiII St. CÖunry of Los Añg€le8
MAILING ADORESS:

clTY AND ZrP COÞe' LOs les cA 90012 APR I 3 2016

BRANCHNAME: S k
CASE NAME: $herri R. Carier, Exæutive Officer/Clsrlr
A.M. v Valve tion
CASE
CIVIT CASE COVER SHEET Complex Case Deslgn atlon
f7l unltmlteo l--l urit"u [- ] counter ll Joinder
616?66
(Amount (Amount JUDGE:
demanded demanded is Filed with fìrst appearance by defendant
exceeds $25,000 $25,000 or Cal. Rules of Court, rule DEPT:

Items 1-6 below must be inslructions ort

Check one box below for the case type that best describes this case:
Auto Tort Contrâct Provislonally Complex C¡v¡l L¡llgation
D
E Auto (22)
Uninsured motorist (46)
l-_l
Breach of contraçVwananty (06)
(Cal. Rules of Court, rules 3.400-3'403)

Rule 3.740 collections (09) AntitrusUTrade regulation (03)

Olher collections (09) Construction defect (1 0)
Other PI/PDMID {Porsonal lnjuryiProperty
Death) Tort In$urance coverage (18) Mass lort (40)
Asbestos (04) Other contract (37) Securities litigation (28)
Product liablllty (24) Rêal Property Environmenlal/Toxic tort (30)
Medical malprâctice (45) Erninent domaitflnverse I-l lnarrrnae coverage claims arising from he
above listed provibionally complex case
l-l otn., Pr/PD/vvD (23)
condemnatlon (14)
types (41)
Wrongful eviction (33)
Non-PUPDM/D (other) Ïort
Business lorUunfair business practice (07) tl Other real property (26)
Unlawful Detalnêr
Enforcement ol Judgment
l--l Enfor."renr of judgment (20)
Civil rights (08)
Defarnation {13)
f--l cor.rtdal(31) Mlscellaneous Civil ComPlaint
Fraud (16) fJ Residential(32) l-l nrco (zz)
lntellectual propertY (19) l--l orugs (3s) E Of'trr complaint (nof sp ecilied above) (42)
Profession al negligence (25) JudicÍaf Review Miscellaneous Civl¡ Petltlon
Other non-Pl/PDMVD tort (35)
f*-l Rsset torfeiture (05) E Prrtn"rrhip and corporate governance (21 )

Em [--l P"tition re: arbitration award (11) l-l Oth*t p"tition lnot specified above) (43)
Wrongfu | termination (36) Writ of mandate (02)
Other (1 ciaf review

2. This case ts is not complex under rule 3.400 of the california Rules of court. lf the case is complex, mark the
factors requiring exceptional judicial management;
u. [-l Large number of separately represented parties d. Large number of w¡tnesses
b. [-] Extensìve motion practice raising diffìcult or novel e. Coordination wÍth related actions pending in one or more coutls
issues that will be time-consuming to resolve in other cgunties, states, or countries, or in a federal court
c. Substantial arnount of documentary evidence f Substantíal postjudgment judicial supewision

3. Remedies sought (check allthat apply): a monetary b. l--l nonmonetary; declaratory or injunctive relief c. l-Zlpunitive
4. Number of causes of action (specify): 7
5. This case ¡S ø is not a class action suit
6. lf there are aîy known related cases, file and serve a notice of related case. (You may use form CM'015')
Date: 4l7l16
Chad B ins
RE

r plaintiff must file this cover sheet with the flrst paper fìted in the action or proceeding (exc_ept small claims cases or cases flled
to file may result
under the probate Code, Famity Code, or Weliari: and lnstitutions Code). (Cal. Rules of Court, rule 3.220.) Failure
in sanctions.
. filé ttr¡s cover sheet in addition to âny cover sheet required by local court rule-
r cover sheet on all
lf this case is complex under rule 3.¿ôO et seq. of the balifornia Rules of Court, you must serve a copy of this
other parties to the action or proceeding.
. Unless this is a collections cåse under iule 3.740 or a complex case, this cover sheet will be used for statistical
purposes onl

C¡|. Rules of 2.30, 3.220. 3.40S-3,403, 3.740i

Form Adopled lor Mandalory Use
Judiciâl Council of Calif omiå
CIVIL CASE COVER SHEET C€1, Stândârds of Judldâl Admln¡slr¿tion, std. 3'.l0
rwtw.codllnlo,cagov
CM410 {Rev. Juty l, 20071
EXHIBIT A
11
 Case 2:16-cv-03595 Document 1-1 Filed 05/24/16 Page 13 of 13 Page ID #:17
SUPERTOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES Eotta
NOTICG OF CASE ASS¡GNMENT. UNLIM|TEb CryIL CASE
Case Numbcr
IXOrV-CLASõ NCTION) 768
Your case is assigned ro.
", side of this form.
ASSIGNEDJUDCE DEPT ROOM ,ÀSSIGNED JUDGE DIPT
Hon, Kevin C, Brazite 534 Hon. Eliz¡beth AIIen tVhits 48 506
Hon. B¡rber¡ A. Meiers 12 636 Hon, Deirdre Hill 49 s09
Hon. Terry A. Green t4 300 Hon. Teresa A, Berudet 50 508
Hon. Richard Fruin t5 307 Hon. Micb¡el J. Rrphael 5l stl
Hon, Rita Mlller l6 306 Hon. Susan Bryant-Derson 52 5t0
Hon. Richard E. Rico t? 309 Hon. Steven J. Klcifiold 53 5t3
Hon. Slcpharie Bowick t9 311 Hon. Ernest M, Hiroshige 54 512
Hon. Dalll¡ Corrol Lyons 20 31û Hon. Malcolm H, Mrckoy 55 5r5
Hon. Robert L, Hess 24 314 Hon. Mich¡cl Johnson 56 5r4
Hon, Yvette M. P¡lazuclos 28 318 Hou, John P. Doyle 58 5t6
IIo¡. Barbar¡ Schcper 30 400 Hon. Gregory Keosisn 6r 732
Hon. Ssm¡nth¡ Jessner 3l 407 Hoo. Michael I,, Stcrn 62 600
/Hon.
D¡nicl S. Murphy 32 406 Hon. Msrk Mooney 6E 6t1
Hon. Mlchael P. Linfield (tr4 Y 4oB Hon. Wllllam F. Fahey 69 621
Hon. Gregory Alarcon 36 410 Hon. Suz¡nneG. Brugueru 7t 729
Hon, llt¡rc Mrrmaro 37 413 Ho¡. Ruth Ann Kwsn 72 73t
Hon, Msureen Duffy-Lewis 3E 4r7 Hon. R¡fael Ongkeko 73 7J3
Hon. Elizabctl¡ Fefter 39 4r5 Hon, Teres¡ S¡nchez.Gordon 74 735
Hon. Michelle R. Rosenbl¡tt 40 414 Hon. G¡il Rudernan Feuer 78 7fi
Hon. Holly E, Kendig 42 416

Hon. lHel Red Recaor 45 s29 Hon. Emile H. Eliss 32{ ccw
Hon, Frederlck C. Sh¡ller rProvlsionally Complex
46 500
Non-elssc Action Cases
Hon. Dçbre K r#eintraub 47 Asignment ls Pending
507
Complcx Determln¡tion 324 ccw
*Cgmnlor

All no¡-class åctioncases derignated rs provisionally compler are forwarded

to the Supervising Judge of the Complex Liügrtion Program
loc¡ted in the Centrrl Clvil \üesf Courthouse (600 S,
Commonwe¡lth Ave., Los A ngelcs 90005), for complex/non-ôomplex
pursuant to Loc¡l Rule 3.3(k). This proceduro is for determination
thr purpose of assessing whether or not the cese is complex within thc
Californl¡ Rules of Court, rule 3.400. Depen ding on the mcrning of
outcome of th¡t ¡¡sescment, the case may be reasrigned to one
Complex Litigation Program or reasslgned randomly of the Judges ofthe
to a court in the Central District.

Given to tbe PlaintifVCross-ComptainenlAttorney of

Record on _ SHERNT R. CA Oflicer/Clerk
I
APRi-ffi]t_ By Deputy Clerk

LACIV CCH 190 (Rev.0?16) . NOTICE OF CASE ASSIGNMENT.

LASC Approvcd 0S,06 Page I ofZ
UNLIITJIITED CIVIL CASE
EXHIBIT A
12