erage of 20 919Z7 99750 wen aweurn 10 u 2 1B 4 15 16 7 18 19 2 23 2s 26 a 28 wy FILED Victor L. George, State Bar No, 110504 Sugotior Coat of Calfomia Elvis Tran, State Bar No. 281620 Sie aeraret LAW OFFICES OF VICTOR L. GEORGE WAY 06 208 20355 Hawthome Boulevard, First Floor Torrance, Califomia 90503 en OfoenCiok. Telephone: (310) 698-0990 : 2 Facsimile: (310) 698-0995 coat Exmail: ygcorge@vgeorgelaw.com Attomeys for Plaintift MARIANNA SELLECCHIA SUPERIOR COURT OF THE STATE OF CALIFORNIA. FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT FSG: 10/ 20 gory TRL!) 067 27 0s0.057 067 2019 MARIANNA SELLECCHIA, CASE NO. by and through her Guardian ad Litem, BC619782 ‘CONNIE SCCA, . COMPLAINT FOR DAMAGES FOR: Plait 1. ELDER ABUSE AND NEGLECT; 2. NEGLIGENCE/PREMISES v. LIABILITY; and . : 3, PROFESSIONAL NEGLIGENCE. SUNRISE SENIOR LIVING é MANAGEMENT, INC. dba SUNRISE OF STUDIO CITY, a DEMAND FOR JURY TRIAL ‘business, form unknown; SUNRISE. SENIOR LIVING SERVICES, INC., ‘a business, form unknown; and, ‘DOES | through 100, inclusive, Defendants. a8 Plainiff MARIANA SELLECCHIA, by and through her Guardian ad ig 3 Connie Sellecca, alleges the following: 8S 3 mW 5 m asel 3 i 8888 5 ‘COMPCAINT FOR DAMAGES taser *38HO/419. zeLe1908 oot 4 Page# 1 ~ boo 1D = 1654029082 - Doo aype + onan(rage 2 of 16) 1 EIRST CAUSE OF ACTION (Against All Defendants for Elder Abuse and Neglect) _ GENERAL ALLEGATIONS 1, Defendant SUNRISE SENIOR LIVING MANAGEMENT, INC. dba SUNRISE OF STUDIO CITY (hereinafter “SUNRISE OF STUDIO CITY”) is, and at all times relevant hereto was, a for profit long term care facility and at all times mentioned herein, was and is authorized to do business in the State of Califomia, located at 4610 Coldwater Canyon Boulevard, Studio City, California, providing long term care services to “4 ee § persons who are seniors, some of whom suffer from disabilities, such as Plaintiff, 10 2. Defendant SUNRISE SENIOR LIVING SERVICES, INC. (hereinafter 11 ] “SUNRISE SERVICES”), is, and atal times relevant hereto was, a for profit long term care 12 } company and at all times mentioned herein, was and is authorized to do business in the State 13 | of California, SUNRISE SERVICES operates over 300 assisted living facilites. It is 14 || headquartered in McLean, Virginia and cmploys over 29,000 individuals. 4 1S 3. The true names and capacities, whether individual, corporate, associate or 4 16 || otherwise, of Defendants Does 1-100, inelusive, are unknown to Plaintiff at this time, who Ree 17 therefore sues said Defendants by such fictitious names. Plaintiff will ask leave of Court to 18 || amend this Compiaint to insert their true names and capacities when the same have been i: 19 } ascertained. a | 2 4, Plaintiff is informed and believes, and thereon alleges, that Defendants, : 21 || SUNRISE OF STUDIO CITY, Does 1-100, inclusive, and each of them, were the agents, 22 | servants and employees of each other and in doing the things herein alleged, were acting 23 | within the scope of such agency and employment. 4 5. At all times mentioned herein, Plaintiff MARIANNA SELLECCHIA. 25 | (hereinafter “SELLECCHIA”) wasan “elder” within the meaning of Welfare and Institutions 26 | Code Section 15600, et seq., being born in March 1929, making her now 87 years old. 2 6. Atal times mentioned herein, Defendants, and each of them, were “Care 28 | Custodians” or “Health Practitioners” within the meaning of Welfare and Institutions Code 9197799759 2 ‘COMPLAINT FOR DAMAGES a ee eee Cree renee eee er Doct 1 Fagen @ = Bee TD = 1651820082 ~ boo fype f oF(rage 3 of 18) 10 u 12 13 4 Is 16 7 18 19 20 2 23 24 25 99750 a reer g B Section 15600, et seg. Defendants also provided care to SELLECCHIA within the meaning of Welfare and Institutions Code Section 15610.57. FACTS 7. On November 2, 2015, Plaintiff was accepted and admitted to live at SUNRISE OF STUDIO CITY. At the time of her admission, Plaintiff had a number of physical and mental challenges, which left Plaintiff totally dependent on the employees and staff of SUNRISE OF STUDIO CITY. These challenges which Plaintiff came to SUNRISE OF STUDIO CITY with included: aphasia, impaired vision in her right eye, loss of use of her right leg and arm due to a stroke she suffered on July 26, 2015. Plaintiff was dependent ‘on her wheelchair, Earlier in 2015 she had suffered: (1) a broken hip which was repaired through surgery; (2) a watershed stroke; and (3) gallbladder surgery which left her for some, ‘time on life support. Plaintiff recovered from these medical issues and three (3) months later ‘was fortunate to retum to the life she previously had. She had a history of hypertension, congestive heart failure, lives with atrial fibrillation (irregular heart beat) for which she takes blood thinners, These challenges were all on top of her preexisting dementia. 8, Because of Plaintiff's dependent status, Plaintiff was required to rely on the Defendants’ employees to assist her with most of her daily functions, including: transfers from bed to chair, from chair to toilet, grooming, brushing teeth, showering, diaper changes, prompting for cating, dispensing medications, transporting from room to room in the ‘wheelchair, entertainment, securing safety, as well as other functions. 9. OnFebruary 2, 2016, at about 4:00 p.m. an employee of Sunrise telephoned PlaintifP’s guardian/daughter, Connie Sellecca indicating that het mother/tenant SELLECCHIA had fallen out of her wheelchair and was being rushed by ambulance to a local hospital. At the hospital, it was determined that Plaintiff had tragically suffered a fractured C2. She also suffered a fractured nose and fractured cheekbone, Many complications followed for plaintiff including blood pressure spikes, and a very significant urinary tract infection, After Plaintiffs fall, her family was told bedside at St. Joseph's Hospital, that Sunrise caregiver Osear told upper management that he had recently noticed 3 “COMPLAINT FOR DAMAGES eer E Ee eee eeeeee Pee eee eee rH ‘Doct 1 Pagel 3 - boo ID = 1651829052 — boo Type | | t : be(age 4 of 16) 1} Plaintife trying to get out of her wheelchair. Even though Oscar reported that Plaintiff was i trying to get out of her wheelchair before her fall, Plaintiff was still left unattended in het wheelchair on February 2, 2016, until she fell. B 10. Plaintiff was left completely alone so that caregiver Oscar could go and take 4 care of preparing dinner. Sunrise was understaffed to do the job of caring for residents with needs. LL. Plaintiff alleges on information and belief that Plaintiff then attempted to stand up on her own, and somehow fell face first from the wheelchair to the floor. Plaintiff ewer auneon is not to be left entirely alone in her wheeichair as there is no restraint mechanism and she 10 || was left without even pushing Plaintiff's chair up to a table to help cushion any potential fall. ul 12. At the time that Defendants’ Sunrise caregiver Oscar abandoned Plaintiff, 12] Defendants knew, or should have known, of Plaintif?'s serious mental and physical 13 || limitations and the need for Defendants’ total assistance. 4 13, Further, atthe time that Defendants eft Plaintif alone inher wheeler, they 15 || knew or should have known, that because of Plaintiff's physical and mental limitations, she 16 || could not be left unattended without any CNA care and her wheelchair just left in an open ' 17 || area with the Plaintiff in it. 18 14, As stated, Defendants were further negligent and careless in not physically 19 || preventing Plaintiff from falling out of her wheelchair. 20 15. _ Inaddition, Defendants were negligent and carelessin failing to properly hire, 21 || train, supervise and manage their employees, including the caregivers, in how to transport, 22 || properly move the residents and care for disabled elderly residents. Pare: 2B 16. Plaintiffalleges that Defendants acted maliciously and oppressively when they : 24 || failed to secure the Plaintiff, leaving her unattended and abandoned for at least eight (8) @ 25 | minutes in which time she managed to fall out of her wheelchair suffering the catastrophic . 26 | fracture to her C2. } 2 27 17. Plaintiff was discharged from Saint Joseph’s Hospital on February 12, 2016 = 28 || (lOdaysatter her fall) to Plaintiff's daughter's home where she was provided 24-hoursa day, 4 ‘COMPLAINT FOR DAMAGES Aa oot i Rog 47 Yoo = MSLe2SSD ~ bes pe bomeoge 5 of 16) e e 1 |] 7 days a week registered nurse care based on the severity ofthe C2 fracture, 2 18, Defendants? conduct, as alleged herein, was authorized and/or ratified by 3 | Defendants’ upper management, managing agents, executive board, and employees in 4 | supervisory positions at both Defendants’ Stadio City and McLean, Virginia offices. 5 19. ‘These persons are managing agents of Defendant SUNRISE OF STUDIO 6 | CITY based on the following: 7 (®) —_Uppermanagement includes, all persons in supervisory positions at 8 ; SUNRISE OF STUDIO CITY and were the upper management 9 agents atthe time of Plaintif?'s injury. 10 (©) Upper management runs the day-to-day functions of SUNRISE in SERVICES. : 2 (©) "Upper management reports to the SUNRISE OF STUDIO CITY 13, owners. “4 @ Upper management supervises over 50 persons, 15 (©) AtSUNRISE OF STUDIO CITY, there are various departinents, 16 including: Nursing, Staff Development, Dietary, Environmental 1” Services, Central Supply, Activities Department, Department of 18 Social Services and Medical Records. a 19 ( _Allofthe Department Heads at SUNRISE OF STUDIO CITY report i 20 directly to upper management at SUNRISE SERVICES. | 2 (@) It was upper management who needed to determine what to do 2 regarding Sunrise employee Oscar for hi actions contributing to 2B Plaintif’s injury. 2 (3) The upper management at SUNRISE SERVICES runs the “safety 25, department” committee of SUNRISE OF STUDIO CITY. 4 26 @ ‘Upper management, including Risk Management/Loss Pievention 20 itself conducted an investigation into Plaintiff's injury. 28 ‘GONPLAINT FOR DAMAGES ‘Doo! X Faget 6 = boo ID = 1651829052 ~ boc Type p OERage © of 16) 1 20. Asadirectand proximate result ofthe aforesaid acts of Defendants, and each 2] of them, as alleged herein, Plaintiff suffered catastrophic injuries causing great upset, oot 3 || distress, and suffered a huge amount of pain and deterioration of her physical condition. As 4 || aresult, Plaintiff claims general damages for mental and physical pain, suffering and physical 5 || deterioration in a sum according to proof at the time of trial. 6 21. Asa further proximate result ofthe actions of Defendants, and each of them, 7 g 9 as alleged herein, Plaintiff incurred medical expenses and will incur future medical expenses according to proof. | ‘ 22. Pursuant to Welfare arid Institutions Code Section 15657, Plaintiffs entitled 10 | to recover reasonable attomey fees and costs in tis action from Defendants, H 23, Because the acts taken toward Plaintiffafter her fall from the wheelchair were 12 ] carried out with the authorization and/or ratification of managing agents of all Defendants 13 || and because the acts alleged in Paragraphs 9 though 19 were deliberate, callous, and eee eae ee 14] intentional, Plaintiff is entitled to punitive damages against Defendants in an amount ‘| 15 J‘according to proof atthe time of tral 7 Plaintiff MARIANNA SELLECCHIA, by and through her Guardian ad Litem, 18 || Connie Sellecca, further alleges: 19 ‘SECOND CAUSE OF ACTION 20 (Against All Defendants for Negligence/Premises Liability) 2 GENERAL ALLEGATIONS 2 24, Plaintiff refers to and incomporates by reference Paragraphs 1 through 23 of 23 || this Complaint and incorporates them herein by reference. a 25, _Asaproximateresultof Defendants’ negligence, Plaintiff suffered the injuries 25 | and damages hereinafter alleged, anne 26 26, Asadirect and proximate result ofthe aforesaid acts of Defendants, and each 27 || ofthem, as alleged herein, Plaintiff became upset, distressed and suffered a great deal of pain 91ez/ 99769 28 } and deterioration of her physical condition, Asaresult, Plaintiff claims general damages for 6 ‘COMPLAINT FOR DAMAGES |g ‘ooh 4 Pageh 6 - Boo ED = 1651009082 - Doo Type b ome irage 7 of 16 1] her catastrophic injury, including both mental and physical pain, suffering and physical . deterioration in a sum according to proof at the time of trial. 27. Asa further proximate result ofthe actions of Defendants, and each of them, a asalleged herein, Plaintffincurred medical expenses and will incur future medical expenses ‘according to proof. Plaintiff MARIANNA SELLECCHIA, by and through her Guardian ad Litem, Connie Sellecca, further alleges: ‘THIRD CAUSE OF ACTION 10 (Against All Defendants for Professional Negligence) n GENERAL ALLEGATIONS ‘yn 28, Plaintiff refers to and incorporates herein by reference Paragraphs 1 through 13 | 27 ofthis Complaint and incorporates them herein by reference. 14] 29. Defendants and DOES 1-100, inclusive, and each of them, are or were “care 15 | custodians” or “health practitioners”, rendering medical, nursing and other care and services 16 | to the general public, including Plaintiff; that all ofthe acts complained of herein against dad 17 | Defendants were done and performed by and through their duly authorized agents, servants, 18 | and employees, each of whom and all of whom were at all times acting within the course, 19 | purpose and scope of their agency, service and employment. 20 30, From November 2, 2015 through February 2, 2016, Plaintiff was inthe care 21 || and custody of Defendants and received custodial care, healthcare, nursing care and medical 22 || care from Defendants, and each of them. In so doing, Plaintiff placed herself under the 23 || primary care, control, management, treatment and advise of said Defendants, and each of: j i 24 | them. o 3 31. While Plaintiff was under the medical, nursing, custodial and healtheare | | = 26 | control of Defendants, and each of them, asalleged herein, Defendants negligently, carelessly ' eae. i 27} and unskiflly abandoned Plaimff causing her catastrophic personal injuries. 28] a. 2 ‘COMPLAINT FOR DAMAGES ——— Deck £ Fago# 7 - Doe ID = 1651829052 - Doo Type = OmERage 8 or 16) 1] * 32.” Defendants and DOES 1-100, inclusive, and each of them, negligently and 7 carelessly failed to possess and exercise that degree of skill and knowledge ordinarily possessed and exercised by other“care custodians” and “health practitioners”, including part- time RNs, LVNs, nurses and caregiver assistants engaged in said professions in the same locality as Defendants, and each of them. 33. Asa proximate result of Defendants negligence, and each of them, Plaintiff +b oma suffered the injuries and damages hereinafter alleged. wa us en 8 34. Asadirectand proximate result ofthe aforesaid acts of Defendants, and each Eee 9 | ofthem, as alleged herein, Plaintiffbecame upset, distressed and suffered a great deal of pain 10 } and deterioration of her physical condition. As aresult, Plaintiff claims general damages for 11 }| mental and physicel pain, suffering and physical deterioration in a sum according to proof 12 || at the time of ‘trial. 13 35. Asa further proximate result of the actions of Defendants, and each of them, 14 | as alleged herein, Plaintiff has incurred heavy medical expenses and which will continue to 15 | dramatically increase over future ever growing medical expenses according to proof. 16 7 PRAYER FOR RELIEE | 18 WHEREFORE, Plaintiff MARIANNA SELLECCHIA, by and through her Guardian a ' 19 | ad Litem, Connie Sellecca, prays for judgment against Defendants, and each of them, as * 20 || follows on the First Cause of Acti 2 1. For general damages in a sum according to proof at the time of trial; 2 2. For medical care and future medical care according to proof at the time of : 23, trial; oo 3. For reasonable attorney fees; 4 3g 3 4. For punitive and exemplary damages in an amount sufficient to punish and } > 6 deter Defendants; ; Son 5. For costs of suit incurred herein; and eee zon 6. For such other and further relief as the Court may deem just and proper. SORTA YOR OMA acer eee Se eeeeiceeeeeeeeea ee eee ee eer Pee Book 3 Bipeh © — Boo TD = 465625062 — aoe Roe } omm(rage 9 of 16) el oma fr ee san een 10 ul 2 3 4 15 7 18 19 20 a1 8 24 26 2 28 9107799750 16| WHEREFORE, Plaintiff MARIANNA SELLECCHIA, by and through her Guardian | ad Litem, Connie Sellecca, prays for judgment against Defendants, and each of them, as follows on her Second and Third Causes of Action for Negligence as follows: 1, For general damages in a sum according to proof at the time of trial; 2, For medical care and future medical care according to proof at the time of of trial; 3. Costs of suit ineurred herein; and 4, For such other and further relief as the Court may deem just and proper. ~ Dated: April 29, 2016 LAW OFFICES OF VICTOR L. GEORGE co VICTOR L. GEORGE ELVIS TRAN a Attomeys for Plaintiff MARIANNA SELLECCHIA 9 PAINT FOR DAMAGES nc ‘oot 1 Raged 9 = Doo 1D L451820052 = Doe Type F om(rage 10 of 26) e e 1 : DEMAND FOR JURY TRIAL 2 Plaintiff MARIANNA SELLECCHIA, by and through her Guardian ad Litem, 3] Connie Sellecca, hereby demands tral by jury inthis action now before the Court, i 4 5] Dated: April 29, 2016 LAW OFFICES OF VICTOR L. GEORGE | 6 : : g eal 9 MARINA SELLECCHA | 10 ul n 3 4 | 1s I : 16 : i 7 j 18 cs 19 3 \ 21 n B Py o 3% Son | Eon el ree SELLE eee Eee Eeeee ede HEHEHE ooh Faget 10~ Doe 3D SEDRRIOR ~ Doo Type Formage 11 of 16) BORE ORPRRTY VATIOUT ATTORNEY ana, corm, aaa FoR ESTRT ERT [Victor L. George (SBN 110504) sa Law Offices of Victor L. George 20355 Hawthorne Blvd., First Floor FILED Torrance, CA 90503 Sipetr Cour Cattoria Torrance, CA 90503 ‘oF Los Angelos weunowte: (310) 698-0990 farm: (310) 698-0995 MAY 06 2016 SUPEROR COURT OFCALIFORNA,COUNTYOFLos Angeles weerscoaess111 North Hill Street suune ooiess:111 North Hill Street etrmonrcore 08, Angeles, CA, 90012 sh ri. Otc Pr Deo waar incu Genera een ae om | MANAGEMENT, INC. et al. mab b107 82 plore Cv CASE COVER SHEET Campion Gave Designation alae : cx ny (Counter (—) Joinder } Fed with re appearance by defendant | ace } Sarat coy ee rie erie tr el be i ems 1-5 Blow rust be compte (50 nsnvefons on page 2. Fi Check one bax below forthe case tyne that best describes this case: ‘09 Tor Contact Provietonaly Comploe Chil Litgtin Ao @2) CJeceen otcomracwarany 06) (Gal Rules of Cour, rule 3400-3405) | a Soa” Sse i ‘iter PUPDIWD (Personal ljuniPropery ter dlecton Consttoncefect(10) Samagerongt ea Yon FAimcrcnente hy Fitton | asbestos 04) loner convection [| secuites gation 25 Product tabiity (26) Real Property [) EnvironmentaToxie tort (39) (Fetecicat mapracice 8) Jeon comatyvere 7 insuranesesverage cans aesng rom he : (lone Pueonnn oy coders {ove sta pronay aoc ono j ‘Non-PrPDIWD (Other) Tort (wironatt eviction (83) ‘types (41) easiness tert business pacice 7) I other ral propery (2) Exforcementof Judgment lewis 08) stant Detaner 1 entrcement ot judgment (20) | (Fhostanaten 19) eonmeres on) Miscellaneous Ci Complaint i Jrraue 16) reste! 2) C)rcoan Direct propery 19 orgs) ter cami rat specie above) (2) + (Glrretesscratretgence 25, ila Review !aeeaianaous Cal Potion H otter nan UPD tn (5) asset tree 05 [J Paterstip and expert govemance 2) i Employment Jeettenre:ativasonanat(11) J ote peen ct specie above) (3) H (2 wreongtet termination (96) Writ of mandate (02) other emptoyment (15) Other ust revo (9) Triscase [_]is CX] isnot complex under rule 3.4 i ing exceptional uccial management: Large numberof separately represented parties 1. [1 extenve mton pace lar cin nove {issues that wil be time-consuming to resolve . [2 Substantial amount of documentary evidence Number of causes of action (epeciyy: THREE (3) ‘Thiscase CJ is CX] isnot actasé action suit. Date: May 4, 2016 w ogee 04 PROT «+ aint must fle this cover sheet with the fist paper fled i LuRdor the Probate Code, Family Code, ‘sanctions, & artes to he action or pr ‘Stein sy . Ramee sought (ceca at eppi: a. LK] monetary b.(—]nonmonsay NOTICE in the action or proceeding (excep! small claims cases or cases fled ‘or Welfare anc Isttutions Code). (Cal. Rules of Cour, ule 3.220.) Faure to fle may res i cover sheet in addon to any cover sheet required by local court rule. ‘case is complex under rule 3400 et seq, ofthe Calforia Rules of Cour, you must senve.8 copy ofthis cover sheet an all # ntess this isa collections case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes. eee eae SiR oo ey (00 ofthe California Rules of Cour. Ifthe case ie complex, mark the 4. (=) Large number of witnesses ¢. [5 Coorginationwith related actions pending inone oc more courts In other counties, stales, oF countries, or ina federal court £. [) Substantial postudgment juice supervision only. Pont or EEO ‘Dock 1 Pages 21 ~ Doe 1D = 1692829082 - Doo Type b Onan(rage 22 of 16) t mistaucf®xs on How couecere re covflPsncer cua To Plainsitfs and Others Filing First Papors. If you ate fling a fist paper (lor exam, a complaint) in a cil case, you must ‘complete and fle, along vith your frst paper, the Cul Case Cover Sheet contained on page f. This infomation wil be used t comple Statisios about the tyes and numbers of cases fled. You must complete items 1 through 6 an the sheet. In Rem 1, yeu must check tone box fr the case ype thal best describes te case. ifthe case fs bath a general and a more apecife type af case ated in i 1, oe check the more speci one, Wthe-case has multiple causes of action, check ths box tha best indicates the primary cause of aston. ‘To assist you in completing the sheet, examples of he cases that belong under each case type in tem 1 are provided below. A ever ‘sheet must be filed only with your ital paper. Failure to file a cover sheet with the first paper filed in @ civil case may subject a palff, its } ‘counselor bath o sanctions under rules 2.30 and 3220 of the California Rules of Court. ia | ‘To Panto In Rule 3.740 Collections Cases. A elections case" under nue 3,740is defined as an action for recovery of money Sed in e sum slate to be certain thats not more than $25,000, excusive of interest and atomey' fees, arsing fom a varsacton nwhich Property, sevces, or money was acquired on cred, A collections cate does not induce en acton sooking the folowing: (1) tot ‘damages, 2) punlive damages, (3) recovery of real property, (4) recovery of personal property, or (6). prejudgment wit ofatachment. | ‘The Kenic of a case asa rule 3.740 cotectons cae on this form means that i'w be exempt tom the general ineorsenice | requirements and case management rule, unless a defendant fes a responswve pleading. Arle 3.740 calectons case wil be eubject {othe requirements for service and obtaining a judgment inrue 3.740, ate ‘To Parties in Complex Cases. In complex cases only, paige must also use the Civil Caso Cover Sheet to designate whether the | ‘cate is complex I plant believes the case Is complex under rule 8.400 of the Calfomia Rules of Cour, this must be indicated by | ‘completing the appropte boxes In tems 1 and 2 a plant designates a case a5 complex, the cover sheet mustbe servedwith he” | ‘complaint on all partes to the action. A defendant may fle and serve ro later than the Ue of is frst appearance a Joinder in the plaints designation, a counter-designaton that the case is nt complex or, ifthe plant has made no designation, a designation that = ‘he case is complex. ‘CASE TYPES AND EXAMPLES ‘Ato Tort Contract a. Prowsionally Complex Cv Ligation (Cal, to (22}—Persna!juryrapeny ‘Breach of Cnrawvarany (08) Roles of ovr Rules 3.403.403) ‘Damageiertl Death ‘rege of entarease ‘AniteasVTade Reguation (3) nina Metra 66) (0 Cont tebe deiner Const Detect (10) ase involves an uninsured coe ae Claims invoving Mass Tot (40) | oli clin ico cuacuwararty Brea Scares pion 0) \ rao, chock is a Gone Envronmerta/Toxe Tot 00) | Inaead of Ato) eieeny Insurance Coverage Cas j ther PIPDID (Personal Ion (arising tom rovisonly compton | Property Damagetrongtal beat) ate Yo ites oboe) Tor i Tstests (04 Sse eit Sctoxament cf coment | ‘Asbestos Popery Donage ‘Sherbrossey Reccalecons caren arid 20) ; sown Peron Case ‘coun i pei ‘ Prout ebiy (of asbases or Confassion ot sugmeat (oan i foscemeanartag 8 sit Stat eget Modealabrectoe (9) ugg | Neal apracioe- Adit Agency Avard feast ‘Prysisan & Surgeons Seneca Fad {oot eroai tree) } comer Protestanal neg are pie PeatonlGeafeaton ef entry of ; eal Propary Joegmant on UnpaldTares (ther PHPDID 23) Erinent amalvivense _ Older Enforcement Judgment i ‘Premises Ushi (sip ‘Cendermaton (te) Case i run eral eon) sn Imsestanots Ci Conant { Inter Bos ren/POMWD Prod es ‘eg euch cones) Wht Pasa ofa Prepery Sia Set resco i \etrainobonal Dae Quel Tite Declaratory Reset Ory } agai Dates (trer Reel Posey fot ominent iene Reet Oni ton } eigen iticton of ‘done lndordtenart of Trnovonal Datess ocosue) ettassmen) i ‘Other PPDMD ‘Uniawiut Datainor ‘Other Commercial Complaint i om UPON Fotar Tor ‘Commercial (31) ‘Case | Bushass Terra Bustos ester (2) ohne | Practice 07) rags (3 th cage mses toga! ‘honor comp | Chit RRS (e9., iscininaton, rags, check th tm otorvic, aaa cuatpanesnie t {age ares rte ‘partes Commercial or Resident Panes ond Goparte j arsomend (08) ati eview nen i ‘tamer (9, nde, be) fase Porte 05) he bane es i ~ Peles me aiaten Awad 1) ‘bov) 2) i Feud (1) Watt wand (02) (ta rastment Inebetal Prepay (19) ‘Wii-Adninitaive Mandamus WirtlaceVelnca Profesional Negigence (25) Was on inte Caan Pnecnoaib ary A Malpracice ase ate = Sr Mosse apace wit ed ot ase ete ee (not medical or toga) ar Petition for Name Change t “oer Now PIPONND Tot 8) tna Judit Rviow 20) Petition fr Reel from Late t Employment ‘cain ‘irangtl Termination 98) omer Cha Pest i ‘tne Enployert (16) eae 7 a mera oot 2 eget 32 = Doo 2 = ZEEEEDOE ~ Dee Te = onan(rage 13 of 16) ‘BATE SELLECCHIA V. SUNRISE SENIOR LIVING eammx BEF 9-482 LWANAGEMENT, INC., etal CIVIL CASE COVER SHEET ADDENDUM AND ‘STATEMENT OF LOCATION (CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION) ‘Tals form Is required pursuant to Local Rule 2.3 in all new civil case filings in the Los Angeles Superior Court. tom |. Check the types of hearing and fil in the estimated length of hearing expected for this case: JURY TRIAL?[X]YES CLASS ACTION?[_] YES LIMITED CASE? [_] YES TIME ESTIMATED FOR TRIALLO [1 Hours/{ X loavs: Mem Il, Indicate the correct distict and courthouse location (4 steps ~ If you checked ‘Limited Case", skip to Item Ill, Pg, 4): ‘Step 1: After fist completing the Civil Case Cover Sheet form, find the main Cuil Case Cover Sheet heading for your case in the let margin below, and, to the right in Column A, the Civil Case Cover Sheet case type you selected. ‘Step 2: Check one Superior Court type of action in Column BB below which best describes the nature of this case. ‘Step 3: In Column C, cle the reason forthe cout lacation choice that epplis tothe type of action you have checked, For any exception to the court location, see Local Rule 2.3. ‘Applicable Reasons for Choosing Courthouse Location (see Column C below) Gastaorerustb Hehe Starey Moss Covtheuse canal. § Location cope or permarenty guage vec E Maybe cere er ety oro boda ‘so 4 LBSaton wns petiere a i ist airy oro boshy munpesery damage). Pa & re cause ot scbon 4 Eeeaion re detenaniesponen fron whol. on where bog Inury. deo ama 2 Locaton were one or rea. Sr premnet reghed or naan ese dese aipeeeery 114, Mandatory Fing Location (Hub Case) ‘Step 4: Filn the information requested on page 4 in Item Il; complete Item IV. Sign the dectaration. a ‘ato (22) ‘ATA00 Motor Vell -PersonallajuryPropety Oamagenrongfii Death | 1.2.4. ‘Ato Tort Uninsured Motont (46) |] A7110 Personal niryPrapery Damage/Wrongil Death ~ Uninsured Motos 1.2.4, a [ seore Astestos Proery Damane 2 s ere [1 A721 Asbeses Persona! urWrongl Death 2 iF Product inst 24) [=] Ar260 Pradut nity (nt tbe er tonenormenta Ta’ = BS : I a0 weasel tapas -Phsces & Spee Te a LSet [Ee cranenmanan crouse te sonal |] A7260 Premises Listy (c.g. slp and fl) & Gre ersonat =) 7250 tnteonal Boy lsryPropety OamageMrongtl Desh (29. obtede rh semana if ‘ean 23) I) rare tnernal econ of EmotenlDsress : g EI azz0 oer Pen Pree Oaneaeng Desh | ev tose CIVIL CASE COVER SHEET ADDENDUM Tecai eB . LASC Arpt 02-08 AND STATEMENT OF LOCATION age ota Boob a Fagen JB ~ ow > NSLERIOGE Poo Fpw F orm® e e /SHOATTME SELLECCHIA v. SUNRISE SENIOR LIVING CASE NUVEER MANAGEMENT, INC, et al. A B : ‘cut case Cover Shost “pe st Aton : Geiger No (Checker one : 2s Business Tort (07) {() Ast29 Other CommerciaiBusiness Tort (net fraudforeach of contract) | 1.,3. sf} crmcn & Cv Rigs 08) 7 Atoos civ Rognarocriminaten 12.3. | 3s Defamation 13) | [—] ASOIO Defamation (andere 12.8, 2 1 $F ee Tas 5s ! ee Profesional Negigence (25) | (_] 48017 Legal Malpractice 14.2.3 53 TE rene0 ctr Petes spate (et mdal eres) nas 4 ‘Other (35) (1 A802 Other Non-Persnal Injury/Property Damage tort 28. } i “Weoagfut Termination (36) | [_] A8037 Wrongful Termination 4.2.3, t i é : neta ober Enptynert Caren Ga 1a i BL Ores | rots te cone eae ‘a i SS] | ovcion 7 rach ot Cones Woranty | [] A6008 Coneaatarany Broach Ste Pat co tavdneaigencn) | = | i rot oocnce) sors Neatzent Breach of ContactWarrety (no fave) aera: ( neee other Breath of ContactWearanty (ot fraudornegigencey | 2-5. f enue \ z coneions on) | Ea) One cotectons Cat eter Para 2.5.6.1 i z | a6o12 other Promissory Note/Cebections Case 2,619 & TH neane cosnctons cace-ruenstes Debt (Creged Of Consumer Debt | 6,6, 11 { Fuchs oa orate ana { tnsrance Coverage 1) | =) A@015 Insurance Covrage oc cms hake | Nitto crnraserrave TES 4 | ‘her Conract(s7) | (_] A081 Totus tnteerence 1203.8. 4 (atta? omer Contract Disprte(not breachinsurancerteudinegiigence) | t.,2.,3, 8, f : RET GETEC GS” | [1 Art EmnertOomeiGencannaton Nanberofparele | & ; EB [_wrestsesson [1 ats winnie cae 2.6 j i a Asore morgage Fomcesre 26 I ‘Other Rea! Property (26) | [—] A6092 Quiet Title 26 f TH hseeo cnet ReatPepry at ence dann, ndodtear tren | 2, 6. i i ee nee eee 2) As021 Uniawtul Detainer-Commercial (aot drugs or wrongful eviction) — | 2,6. Gf | wise Dstane seta |) peo uns Detain Rese rt rg orwrengtaoeter) | 2.6 S| amMonares, [a senor inant oanerrat recone 2 | 3 [Las ounvwronas Go | CI ate? nowt Oaaaronne ze LAGIV 109 Rev 3/15) CIVIL CASE COVER SHEET ADDENDUM ‘Local Rule 2.3. 4 LASC Approved 03-04 AND STATEMENT OF LOCATION Page 2 of 4 ‘oot 2 paged 14 = boo XD = 1651829052 ~ ooo Type F OTHERerage 25 of 16) i * e e ‘Decl 4 Pages 25 - Doc ID = 2651029052 - Doo Type © OTHER ‘wearie SELLECCHIN V. SUNRISE SENTOR LIVING eae MANAGEMENT, INC., et al. 7A, ; ae arere ais C arose ‘cv Cata Cover Sheet Type ot Acton Reasane See Slop 3 Category No. : (Cheek ely one), ‘Above Asset Fores 05) |] Aston asset Feature Case 2.6 } Se 28 1 astst wet Administratve Mandamus. 2.8 ] ! | vetermencate 62 |) astse wer-tandams on Und cao se Mater 2 hens 3 (=) 6169 wat -oiner Limited Court Case Review 2 ‘ber Juice Revow (8) |=) ABt60 other Wat HuacltRevow = | 3 [onmsroengpte To [Fass cane nenea tte 1a z oe ee 128 ie Lee ae 2 [ mpumescerase cies |) nears tsuance GergelSctronnon (nein cas cn) 1288 | Ty pater sister sae scgrert 28 q =e Hy Aste Act of utara, 28. : ee Enccomert |=] AB107 Conesien of udpment er demestcrltons) 2.8 EE | otsarert a 1) astao acminsnate agency werd (ot unpaistoes) 28 ef as a] Asi Pettionerteae fer Ex of Judgment on Unpaid Tax 28 : 1 asta come efrcemert ct vdgrent Case 2.6.9, | RCO TT Asn Racetoang ICO) Cove 28 4 z a3 I P0000 GedartonRetetOny 128 ; 48 Comer compints |] ABO Inunctv Retief Only (not domestoharassment) y ES | terSeecteavow ez) [CT] asors oer commer compli case rontotnoncamplen | 142.8, eee 6 |) 8000 oMrer civ Comptsint (nontoninen-campien) 142.8, } Portzrchip Comparator [J sit Partnership and Corporate Govemance Cate 2.8, i asta cha Hersement ; 2.348 } ge Petes Wire Harossment 2.38 i £ : comer ettons wet |) A812 ElerDenentent Adu Abuse Caso 2.3.8 i 2 Species bow) 3) |[] Asis etocon contest 2 : ag peta Pettion or cnange of Nome 21 ! 7 TS pett0 Pett or Rete om te Clim Law 23448 4 e reson ote ation 20 L = a = | om i naive Revs) CIVIL CASE COVER SHEET ADDENDUM {ocal Rule 23 y sc Aeroed 0306 AND STATEMENT OF LOCATION Page sora } trage 16 of 16) SWORE SELLECCHIA v, SUNRISE SENIOR LIVING oneal INC., et al lem ll. Statement of Location: Enter the address ofthe accident, party's residence or place of business, performance, or other circumstance indicated in ter I, Step 3 on Page 1, as the proper reason for filng inthe court location you selected. peoness 4610 Coldwater Canyon Siva. : REASON: Check he appropiate Boxes forthe numbers shown - {rcer Colum torte yp of seen tat you have eles fr | Aioeos0o6O6.C7.ece.O10.o1] Studio City jca__|o2604 4 tem IV, Declaration of Assignment: | decare under penalty of perjury under the laws of the State of California thatthe foregoing is tue i ‘and correct and that the above-entiled matter Is propery fled for assignment to the Stanley Mosk courthouse in the Sentra District of the Supesior Court of California, County of Los Angeles [Code Civ. Proc. § 382 et seq. and Local Rute 23, subd. (2) LAW OFFICES OF VICTOR L. GEORGE ase as alae | LhtN tha VICTOR L. GEORGE Attorneys for Plaintiff {PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY | CONMENCE YOUR NEW COURT CASE: i 1. Original Complaint or Petition. 2. fing a Complaint, a completed Summons form for issuance by the Clerk. 3. Civil Case Cover Sheet, Judicial Council form CN-010. 4 GhilCase Cover Sheet Aadendum ar Statement of Location frm, LACY 108, LASC Approved 0804 (Rev -| Payment in full ofthe fling fee, unless fees have been waived. 6. signed order appointing the Guardian ad Liter, Judicial Counc frm CIV-010 the plant or pettonor is a minor under ¥8yeors of ¢ge il be requred ty Gourtin ener to saus' summons. \ 7. Additional copies of documents to be conformed by the Clerk. Copies of the cover sheet and this addendum } ‘must be served along withthe summons and cemplant, oF eer iiatng pleading nthe case. & 7 \ 2 = | 2 Trev 108 (Rev ans) CIVIL CASE COVER SHEET ADDENDUM ~~ Local Rule 23 ~ LASC Asproved 03-04, AND STATEMENT OF LOCATION Pages of 4 Doce 1 Fageu 16 - Doc ID = 1653075082 - Doc aype > onan