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R TRAUT
!JAR #84839
ERTCVTRAUT
BAR#146644
TRAUT FIRM
5 HUTTON CENTRE, SUITE 700
SANTA ANA CALII'OH.NIA 92707
(714) R.l5-7000
FAX (714) 835-5900
Rfi:PRF.Sfi:NTING PI .AINTIFF
ILo\RRIS EVANS
SUPER!


GEtES
MAR 2 2 2012
SUPERTOR COURT OF TilE STATE OF CALITORNIA
r'OR THE COUNTY OF LOS ANGELES
HARmS EVANS,
Plainli n;
-vs-
NARCONON OF NORTHERN CALIFORNTA
(a COI1Jorali.on); MIKE DIPALMA; STEVEN
STEIN, M.D.; and DOES 1 through 100,
Inclusive,
Defendants.
BC481302
) CASE NO.
)
) COMPLAINT FOR DAMAGES
)
) NEGLIGENCE; PROFESSIONAL
) NEGLIGENCJ.l; 13REACH OF
) CONTRACT; FRAtffi; BREACII
) OF FIDUCIARY DUTY
)
j II BY FAX II
)
)
COMMON ALLEGATIONS
I. Plainti Jl'is ignonml oFLhe true names and capacities of defendants sued herein as DOES
I through 1 00, inclusive, and thcrel!1re sues said ddemlants by such fictitious names. Plain tiff wi II

amend this Complaint to allege their true names and capacities wht:n ;:;1
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inl'cnmed and bdiews, ;md thereon alleges, that the fictitiously named .: :!' !:'
-=:c:z:::t:C"") "=
responsible in some manner lor tl1e occurrences. inji.1rics and damages hcreinaller aiieiil d. * 8 ...,
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2. Plainti IT inl1lrmccl and believes, and thereon alleges, that at all times herein mentioned
in lhis complaint defendants were the "gents and employees oftheir co-dd'tlndants and in doing
the things alleged in this complaint were acting within the and scope of that agency and
employment. In the altemativc, each defendant authorized, consented to and/or ratified the conduct
of the remaining de i'endants, and each of them.
3. At all relevant times herein mentioned, plaintiff was a man suffering l'rom various forms
or psychosis, including schizoplll'enia, psychosis and depression. The dekndants were well aware
of his psycho$i$.
4. AI all times herein mentioned, dei'endants NARCONON OF NORTHERN
CALIFORNIA and DOES 1 tlU"ough I 0 (hereafter cumulatively referred to as OWNER) is and was
a corporation, to do business and doing business in the City oi'Watsonvillc, California,
with its principal ofhusincss at or ncar 262 Gaffey Road, in the City of Watsonville, County
of Santa Cruz, California. Said solicited and entered into the contract with plaintiff
and his mother in Los Angeles County.
A. At all rdevanl times herein mentioned, OWNER was the (nvner oi'the land and
thereon at 262 (Iaffey Road, in the City ofWatsonville, and it owned the business
comn1only known as Vista Bay at that same location.
13. At all times herein n1t:ntioned, OWNER's Vista Bay facility was an Alcohol and
Drug Program, authorized and licensed hy the State of California to operate an alc\>holism or drug
abuse recovery or treatment facility, and was licensed to provide, anJ it provided, non-medical
serv1ces.
1. In the alternative, OWNER was a health care provider: among other
things, OWNER claimed. told plainliJTherein and advertised that medical doctors and nurses were
on its staff. In t11e OWNER claims, or it is otherwise determined, that OWNER a health
care provider, and i r plaintiff was required to serve a Notice of Inteni to bring an action against
OWNER as a health care provider, then plaintiff did so: a correct copy of that notice, which was
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Complaint

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timely served on said defendant was attached t\1 the Anise Evans lawsuit.
2. Whether or not said defendant was a health care provider, said defendant
was not equipped to treat, hnndlc, counsel or provide services for those who had an extensive
institutional or psychiatric history which includes psychotropic drugs, as such cases should be
rekned to a psychiatric care i'acilily. 'Extensive" means long-term usc and administration of
psychi<ttric care, including the long-tenn and consistent usc of psychotropic medications and/or
long-term care under the advisement or direct visitution of a psychiatrist who had an accurate
and tJue diagnosis of a mental disorder that occulTed prior to any illicit drug history; further, said
defendant was not eyuipped lo treat, handle, C\lunsel or provide services l(lf those who had been
diagnosed, or were apparently psychotic: i.e., a person who demonstrably insane, violent or raving
psychotic. Such people require constant 24 hour care by a specialized team of professionals. Said
defendant acknowledged these limitations on their services and as they were the subject
\II' the Executive Directive oJ' October II, 2001 and revised on October I 0, 2002.
5. OWNER was licensed, authorized, franchised, owned, operated, controlled and
supervised by defendants, ASSOCIATION fOR DETTER LIVING AND EDUCATION
INTERl"'ATIONAL, a corporation, und DOES 11 through 20 (hereafter cumulatively referred to
a;; ABLE). ABLF tlw trademarks and marks "Narconon" and/or "Vistu Bay", and
mllhnrized OWNER to use them.
6. Defendants, MIKE DIP ALMA and DOES 21 through 40 (hereafter cumulatively
referred to us MANAGING AGENT) is and was an agent a managing agent, and an employee of
OWNER. His acts and omissions, as hereinalter alleged, during the wmse and scope of
his employment with OWNER. In !he ahemative, each deJ'endanl authorized, to and/or
mtified the conduct of the remaining defendants, and each of them.
7. Defendants STEVEN STEIN, M.D. and DOES 41 through 50 (hereafter cumulatively
t\1 as DOCTOR) was a doctor, licensed to practice medicine and practicing
medicine in Cali J'omia. DOCTOR was an agent and employee of OWNER and was, at all times
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herein mentioned, acting within the course and scope or his agency and employment with and tor
us OWNER's "medical director" lor OVI'NER's Vista flay J'aeility. Plaintiff was required to
provide Notice oflntcnt, and provided DOCTOR with Notice of Intent to bring an action
a health care provider. and plaintiff did so timely.
g, In early January, 2011, plaintiff's mother, Anise Evans, was quite concerned ahoul her
son. lie had been diagnosed with paranoid schizophrenia, and depression; he was
hospitalized at Kedren, a psychiatric hospital in Los Angeles and was given psychotropic
medications to control U1e voices and urges of schizophrenia; this was his fifth such hospitalization
during the preceding year: on ofthese hospitalizations, he was then being held against
will Lmder We/fare & lnstitulions section 5150 as he had evinced, demonstrated and/or
threatened to do harm to himself or others; and, so long as he took the anti-psychotic and anti-
depressive plaintiff was fine, hut he did not take such medications aller his releases
hom other hospitals.
9. So, plaintiffs mother started investigating alternatives to this 'revolving door' oC
psychiatric treatment through emergency admissions to psychiatric hospitals - where plaintiff
would take his anti-schizophrenia and anti-psychotic nwdications, thereby regaining his sanity and
mental health- followed hy periods of insanity, paranoid schi<,ophrenic hallucinations, paranoia,
dehtsions and other maladies, upon discharge.
I 0. Her search led her to a website; the website led her to a couple of other and,
ultimately, to a Greg Potts of Carpc Diem Intervention Services and Consultation. Plaintiffs
mother explained to Mr. Polls the matters set forth in parat,'Taph 9. Mr. Potts told plaintitfs mother
that 0\ThTER's Vista Bay. and only Vista Bay, was equipped to deal plaintiff. He did Mt tell her
that Vista Bay was affiliated with Narconon; and he did not tell her that Narconon was ai'11Jiakd
with the Church or Scientology.
11. Plaintiffs then contacted OWNER's Vista ilay and spoke withMANAGJNG
A<JENT. Again, she explained background of HARRIS's clinical presentation as set forli1 in
Complaint


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Mar. 22 2012 8:19AM


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purugruph 9, including the fact that HARRIS was, at that moment, held against his will under a
5150 hold at a psychiatric hospitaL Then, and over the course of several conversutiom;,
MANAGiNG AGENT told plaintilrs mother herein:
A. That despite the facts, as specifically acknowkdged by MANAGING AGENT,
that plainti IT was currently admitted at a reputable psychiatric hospitaL taking the
psychotic and medictttions that were prescribed to him by licensed
psychiatrists there; the tact that he had been admitted to five psychiatric hospitals over the
past years, usually because he had been deemed a danger to himself' and/or others (to wit
'5150 holds'); and that similar anti-psychotic an<l anti-schizophrenia medications were
prescribed and administered to plain tilT on each of those admissions, Vista Buy, and \mly
Vista Bay, was equipped to deal with plaintiff: and, that the anti-psychotic medic(ttions that
were controlling plaintiffs delusions, hallucinations, the voices <ITid urges were, in fact,
poisoning him. He told her and plaintiff that it was imperative that plaintiff be admitted to
Vista Bay, without delay, to begin an immediate detoxitlcation from marijuana, alcohol,
and his anti-psychosis dntgs; and, that he must cease, immediately, taking the anti-psychotic
and anti-depressive medications that were controlling his symptoms or paranoid
schizophrenia and psychoses;
B. That MANAGING AGENT, 0\VNER's Vista Bay and the staff, employees and
agents at OWNER's Vist<t Bay were not affiliated with the Church of Scientology; and,
C. That licensed medical doctors and registered nurses were on the statT ut Vista
Hay;
D. That it was a matter of critical importance to plaintiff's health that plaintiff be
transferred ti:om the psychiatric hospital to Vista Bay without delay to begin his treatment there.
12. When MANAGTNG ACiENT told plaintiff and his mother the matters set forth in
paragraph 11. he represented that these important facts were tmc. But, they were not true. When
MANAGING A(iENT made those representations, he knew that they were f1llse. In the allenmtive,
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he made representations recklessly and without regard for their truth. lie intended that
plaintitr and his mother rely on the trutl1 oflhose representations, and tl1ey both did so.
A. As a result of those representations, and plaintiffs reasonable thereon,
he complied with MANAGING AGENT's direction to use Mr. Potts' services to escort
plaintiff and his mom lo Vista Ray, at an approximate c<1sl ol'$1 ,500.00, which she agreed
to pay, paid; and agreed to pay, and she p<tic.l, approximately $35,000.00 to Vista
Bay for services in treating plaintiff.
13. Thereafter, Mr. Polls (personally) and MANAGING AGENT (telephonically,
electronically ami via mail) started speaking with plaintiJl; showing him brochures; and
MANAGING AGENT with the hospitul, louting the benefits of defendants' Vista Bay
anc.l for treating HARRIS. In order, HAR!US was transferred lhnn Kender
psychiatric hospital to defendants' Vista Ray.
14, Plaintifl' 'o mom helped him pack his belonging:; lor the trip. Among other things, she
packed including anti-psychotic and anli-schimphrenia medications and gave them
to Mr. with instructions to deliver tl1em to the stall. physicians and nurses at Vista Bay.
IS. On or about January 6, 2011, plaintiff was transported by Mr. Ports to c.ld'tlnc.lants' Vista
!:lay,
16. On or about January 7, 20 II, DOCTOR, a:; the agent and employee of OWNER,
condudec.l a medical examination and evaluation or plaintiii His findings included 'recent
psychosis', that he was suicidal; tlmt he was taking anti-psychotic and anti-schizophrenia
medications Celerex and (but he had stopped taking those medications two days before):
and, despite tl1ese lindings, he approved the plan for 'residential rehab' al Vista Ray, with the
special recommendation 'observe for psychotic symptoms'.
17. Plainli IT was then admitted to defendants' Vista Bay. There, he was not permitted to
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take the anti-psychotic and which were taken from Mr. Potts, not
adminiskred by defendants to plaintiff, and withheld hy and of them from
Plainti IT.
18. Plaintiffs condition qLLickly out of control. Without his anti-psychotic and
;mti-schizoprcnia medications. he lost his sanity, paranoid delusions and hallucinations and
and by January 11, 2011, he his dehtsions on including
defendant$' counselors at Vista Bay- were carrying guns, trying to hurt him. unc.l each
of them did not call an amhLLiance; c.liu not call Emergency Medical Services: and, did notlransf'er
plaintiff to a medical or psychiatric facility. fnslead, they his mother and directed her to
come l\ Vista Bay, immediately, and retrieve her son because they coulc.l not cure for him there.
She begged them to call m1 ambulance and take him to a medical or psychiatric hospital.
Defendants, and each of them. And, although defendants' own practices, procedLtres and
internal regulations provided that under SLLCh circumslmiCes, they would- at a minimum ... transport
a to a local homeless shelter or medical !:wilily, they told plaintiff's mother that they
were taking p\a.inlirl' to u specific intersection in Bakers11eld, where could retrieve him on
January 14,20 II. n1ese were dictated to plaintiffs mother by said delendm1ts. <md
the terms of these arrangements were non-negotiable.
19. On J<muary 14, 2011, plaintiff's mother and her husband then drove to the designated
intersection in Bakersfield. They retrieved plaintiff and started to c.lrive him buck to Los Angeles
and another psychiatric hospital. By that time, plaintiff was insane, SLd'f'ering !i01n delusions,
hallucinations and other mani f'eslalions of schizophrenia and psychosis and he was physically,
mentally, emotionally, medically, psychiatri10ally and psychologically incapable of controlling his
body volitionally and voluntarily. independent of' the psychosis,schizophrcnia and other Ll1l\ladies
from which he wa> su!lering.
20. While en route liom Bakersfield to Los Angeles, anc.l as a result of the misconduct of
c.lefendants and each of them, plaintiff attacked and choked his mother's husbm1d to death.
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20.
PLAINTIFF'S FIRST CAUSE OF ACTION
AGAINST DEFENDAN!S OWNER,
MANi\CiiNG AGENT, ABI .F AND HARRIS
(Negligence)
21. Plaintiff incmvorates by lhe allegations contained in paragraphs I through
22. At the limes, places and in the manner aforesaid, OWNER, ABU::, MANAGING
AGENT negligently and carelessly facilitated the attack by plaintiff of
23. As a further leg<ll result of said defendants' tortious misconduct, as aforesaid, plaintiff
has been incarcermed.
24. As a 1\trUler legal resLtlt of defendants' tortious misconduct, as aforesaid, plaintiff has
suffered general damages in an amount according to pn.1ot:
25. Upon compliance with Cal{fornia Code of' Civil Procedure section 998, plaintiiTwill
an award ol'prejudgmcnt interest and costs, pursuant to California Civil Code section 3291,
in a wm according to proof.
PLAINTIFF'S SECOND CAUSE OF ACTION
AGAINST DEFENDANTS OWNF.R AND DOCTOR
(Professional
26. Plaintiff incorporates by reference the allegations contained in paragraphs 1 through 20.
27. Plainti IT does not dispute Umt DOCTOR is a defendant who is entitled to the
and protections of MICRA. However, plaintiff docs ll(J( believe that OWNER was <1 health care
provider; that he was legally obligated to on OWNER Notice ol' Intent to bring an action
against a health care provider, or that OWNER can legally avml itself of the benefits, protections
and limitations of MICRA. 11; however, the COIUt with plaintifi' on these points, and in
an abundance of caution, plainti IT served such notice of intent, as pleaded hereinabove, and herein
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OWNER as if it a health care that is entitled to the benefits and protections of
MICRA, in allemativc to her first of action said defendant, us fi.,Jlows:
28. At the limes, places and in the manner as OWNER and DOCTOR were health
providers who. in the exercise of rcasonabk care, were obligated to possess and use tlmt level
ol'skill. knowledge and <:are in the diagnosis and treatment ofplaintilT that other reasonably careful
doctors (in of DOCTOR) and care (in the case of OWNER) would have
used in the circumstances des<:ribed hereinabove.
29. At tl1e times, places and in the manner as aforcdescribed, DOCTOR and OWNER did
not usc or possess SLtCh skill, knowledge and care in the and treatment ofplaintiiT.
30. As a legal result of said delendants' professional negligence, they facilitated the attack
by pluintil'l' on decedent causing death.
31. As a furtl1er legal result of said defendants' tortious misconduct, as aforesaid, plaintiff
suffered general dumages in an amount according to proof.
32. Upon compliance witl1 Cal!fim1ia Code of' Civil Procedure section 998, plaintiff will
seek an award of prejudgment interest and costs, pursuant to California Civil Code section 3291.
in a sum according to prool'.
PLAINTIFF'S THllill CAUSE OF
ACTION AGAINST OWNER AND ABLE
(BREACH OF CONTRACT)
33. Plaintiff incorporates hy reference the allegations contained in paragraphs I through 20.
34. At ti1e times, places and in ti1e manner as aforesaid, plaintifTund said defendant entered
into an oral contract. l j nder the terms am! conditions of that contract, 0 WN I::R, individually and
as the agent, employee, servm11, lranchiscc and licensee or ABLE, agreed to provide drug
rehabilitation services to plain tin: and plaintiffs mother agreed to pay OWNER therefor.
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35. PlaintiiTperlimned all acts, conditions and cove11ants as were reqLLired ol'him under
the agreement, except for such acts, conditions and covenants as were waived, excused or otherwise
satisfied.
36. Said ddl;!ndant faikd and rd'used to provide the promised
37. Defendant was paid $35,000 li1r 6 days. Dei'endant has 11ot retLtmed any oi'the monies
to plaintiff or his mother.
38. As a legal result of said defendant's misconduct and breach of the agreement, plaintiff
and his mother h<tve been c.htm<tged in the sum oC$35,000.00, and the $1500 his mother paid to
Mr. Potts, which payment, and the amount of the payment was foreseeable and speci lkally
contemplated by OWNER and plaintiff herein, when entering into this agreement.
PLAINTIFF'S FOURTH CAUSE
OF ACTION AGAINST OWNER
AND MANAGING AGENT
(Fraud)
39. Plainti !'I' incorporates the ulkgations contained in paragraphs 1 through20.
40. At the times, places and in the manner said c.lelt.nc.lants, by and through
MANAGING AGENT, made the intentional misrepresentations of material fact, as described
above, with tl1e intent to induce plaintiffs reasonable reliance thereon. Plaintiff reasonably relied
on those statements to his damage, to wit: his mother paid $35,000 to OWNER, she paid $1,500
to Mr. Potts, and plaintiff was to be treated al deli:!ndanl:;' Vista Bay and, w; a legal result, said
defendants facilitated the attack which led to the death of his mother's hLtshand.
41. As a legal result of the foregoing, plaintiff suffered general damages in an amotmt
according to proof.
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42. lipon with California Code '!(Civil Procedure section plaintiiTwill
an award of prejudgment inlcre>t and costs. pursuant to Civil Code section 3291,
in a sum according to proof.
20.
PLAINTIH'S FIFTH CAUSE OF ACTION
AGAINST ALL DEFENDANTS FOK
FOR 13KEACH OF FTDUCTARY DUTY
43. Plaintiff incorporates hy relerence the allegations contained in paragraphs 1 through
44. Defendant$ owed what is known as a fiduciary duly to plaintiff. Plaintiff as a patient
and defendants as caregivers. A 11duciary duty imposes on the caregiver$ a duty to act with the
utmost good faith in the best intcrc:sts o fplainli IT.
45. Defendants hrew.:hed that duty by failing to act as a careful care giver would
h(tve acted under the same or similar circumstances.
46. PlaintiU wus harmed by the breach by being taken off medication und ullowed to
become insane whkh led to the death of his mother\ lmsbund.
4 7. The conduct of failing to provide necessary medication and then delivering him to his
mother, instead of a treatment facility with $killed professionals who COltld deal with plaintiff, was
a substantial Cactur in causing the death of his mother"s husband and now all the consequences that
have severely affected the lile of plaintiff.
WIIEREFOKE, plainti IT prays for recovery of damage$ liom defendants, and each of them, as
lullows:
ON AI.L CAUSES OF ACTION
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Complaint
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I. General Damages. in a according to proof at the time oi'trial;
2. Special Dmuug<OS
3. For any prejudgment according to law;
4. of suit:
5. Any other nnd further relief that the Court considers proper; and,
6. Plainti IT hereby demands a jury triaL
ON FOURTH AND FIFTH CAUSES OF ACTION:
7. For pw1i(ive damages in a sum according to proof.
DATED: March 22, 2012
... _ _ __ ..----
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L.---ER:IC\T. TRA
Attorney for Plaintiff
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Complaint
M 22 2
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a r. . . I L 3 21AM No. 0049 p 15
CM 010 -
' ATTORNF.Y OR PARTY WITHOUT dr!d s':JCJr..ss)
FOR CO URi ONLY
V. TRAUT, ESQ. SBN 146644
TRAUT FIRM
FILED 5 Hutton Drive, Suite 700
Sunta Ana, California 92707
SUPERIOR COUR'r OF CALIFORNIA
COUNTY OFtOS ANGEJ.ES .
(714) 835-5900
TC.LCPIIQNENO.; 8!5-7000 rAANU ..
MAR 2 2012 A1J:9...ENEY ron lamtlfl ....
---
COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
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srREET AooREss, 111 North Hill Street
""uNGADoRESs P.O. Box 958
c1TY AND'" r.ooo, Los A1f,eles. CA 900 12
enj IUIO
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BRANCHNAMt CENT AL DISTRICT- STANLEY MOSK
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CASE NAME: F.VANS v. NARCONON OF NORTHERN CALIFORNIA,
et al.
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CIVIL CASE COVER SHEET
I
Complex Case Designation

I x I L]Limitad
C:l
Countor 1::=1 Joinder
-
(Amount (Amounl
Fried wilh first appearance by defendant
JUDGE:
demanded demanded is

exceeds $25,000) $25,000 or lesS) I
(Cal. Rules of Court, rule 3.402)
..
Items 1-6 below must be completed (sea rnstructrons 011 page 2).
1. Check one "'th_e_c-'a"'se"'t"'y"peC...:::Cth"'a':'t best describes this case:
Auto Tort ContJ'aet
L .. ..l Auto (22) ! xi Breach of contracVwa11anty (06)
l .... l Uninsured motorist (46) LJ Rule 3.740 collections (09)
Other PIIPD/WD 1 1 Other collections (09)
Oamage/Wrongful Death) Tort c:::J Insurance coverage (18)
I Asbestos (04) I I Other contract (37)
D Productliabilily (24) Real Property
I X I Medical malpractice (45) ]''"l Eminent domain!lnver.le
LJ Other PIIPDIWD (23) condemnation (14)
! '\Wrongful eviction (33)
LJ Otl1er real property (26)
Non-PIIPDIWD (Othor) Tori
! !Business tort/unfair business practice (07)
i . I Civil rights (08) Unlawful Detainer
I .... 1 Defamation (13) I Commercial (31)
rl Fraud (16) I Residential (32)
II Intellectual property (19) 1 Drugs (38)
I I Professional negligence (25) Judicial Ravi9W
c:::::J Other non-PI/PDIWD tort (35) [::!Asset forteiture (05)
Employment re: arbitration award (11)
I I Wrongful termination (36) Writ of ma11date (02)
L .... I Other employment (15) I I Other judicial review (39)
Flrovlslonally Complex Civil Litigation
{Cal. Rules of Court, rulos 3.4003.403)
1-.::::J AnhtrusVTrade regulation (03)
.. \ Construction defect (10)
! ... _1 Mass tort {40)
D Securities litigation {28)
I I Environmental/Toxic tort (30)
D Insurance coverage claims arising from the
above listed provisionally complex case
types (41)
Enforcement of Judgment
[ .... ..J Enforcement of judgment (20)
Miscellaneous Civil Complaint
I ! RICO (27)
I I Other complaint (not specihed above) (42)
Miscellaneous Civil P'etltlon
) Partnership and corporate governance (21)
1--:J Other petition (not specified above) (43)
2. Til is case [ __ .) is I x I is not complex under rule 3.400 of the California Rules of Court. If the case is complex, mark the
requiring exceptional judicial management:
a. i l Large number of separately represented parties d. U Large number of witnesses
b. II Extensive motion practice raising difficult or novel e. i i Coordination with related actions pending in one or more courts
issues that will be time-consuming to resolve in other counties, states, or countries, or in a federal court
c. I I Substantial amount of documentary evidence f. U Substaotial postjudgment judicial supervision
3. Remedies sought (check all that apply). a. I.EJ monetary b. L .. I nonmonetary; declaratory or injunctive relief c. i x' I punitive
4. Number of causes of action (specify): Five
5. This case is ! x I is not a class action suit. ...------ ,
6. If there are .. known related cases, file. and serve a notice of related . .,;.. .
Date:, March 22,201 .,_ -c:::;:_ __ \
ERIC Y. I RAUl. ESQ. ---- r- . ..
(TYPE OR PRINT NM11::) '---- -- F PARTY OR ATTORNEY fOR rARTY)
NOTICE
Plaintiff must file this cover sheet with the first paper filed in the action or proceeding (except small claims cases or cases filed
under the Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.) Failure to file may result
in sanctions.
File this cover sheet in addition to any cover sheet required by local court rule .
If this case is complex under rule 3.400 et seq of the California Rules of Court, you must serve a copy ofthis cover sheet on all
other parties to the action or proceeding.
Unless lhis is a coli actions case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes only.
- 1 of 2
Fonn 1\Uop.o:<.J ful Mot'ld.!!loty
Judicial Council or cs.mornls
CM-010 IR"v. July;, ?t'Xl7]
CIVIL CASE COVER SHEET , c" ""'"or"'"" '"'"'3o .. 3220 )<co-,'"' 3.740,
So ut.
1
gnR' C.1l St;Jrw:I;Jms (:f e!d .3.10
td, Pnls
'
Mar. 22 2012 8:22AM

No. 0049
16

D
''
CIVIL CASE COVER SHEET ADDENDUM AND II BY FAX II
STATEMENT OF LOCATION
(CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION)
Is required to Local Rule all new civil In the Los Superior Court.
Item 1. Check the types of hearing and fill in the estimated length of hearing expected for this case:
JURY TRIAL? CXJ YES CLASS ACTION?! I YES LIMITED CASE? 0 YES TIME ESTIMATED FOR TRIAL4-5 1-J HOURS/I X I DAYS
Item II. Indicate the correct district and courthouse location (4 steps -If you checked "Limited Case", skip to Item Ill, Pg. 4):
Step 1: After first completing the Civil Case Cover Sheet form, find the main Civil Case Cover Sheet heading for your
case in the left margin below, and, to the right in Column A, the Civil Case Cover Sheet case type you selected.
Step 2: Check 2.'!!! Superior Court type of action in Column B below which best describes the nature of this case.
Step 3: In Column C, circle the reason for the court location choice that applies to the type of action you have
checked. For any exception to the court location, see Local Rule 2.0.
J Applicable for (see Column C
6. Location of property or permanently garaged vehicle. 1. Class actions must be filed in the Stanley Mosk Courthouse, central district.
:2. May be filed in central (other county, or no bodily injury/property damage).
3. Location where cause of action arose.
4. location where bodily injury, death or damage occurred.
7. Location where petitioner resides.
8. Location wherein dafandanUrespondent functions wholly.
9. Location where one or more of the p_arties reside.
5. Location where performance required or defendant resides 10. Location of Labor Commissioner Office
Step 4: Fill in the information requested on page 4 in Item Ill; complete Item IV. Sign the declaration.
Auto (22) A71 00 Motor Vehicle- Personal Injury/Property Damage/Wrongful Death 1., 2., 4.
Uninsured Motorist (46) I A7110 Personal Injury/Property Damage/Wrongful Death- Uninsured Motorist 1., 2., 4.
I A6070 Asbestos Property Damage
I ! A7221 Asbestos Personal Injury/Wrongful Death
Asbestos (04)
2.
2.
Product Liability (24) L.J A7260 Product Liability (not asbestos or toxiclenvironmental)
1 ., 2 ' 3 .. 4., 8.
Medical Malpractice (45)
Other
Personal Injury
Property Damage
Wrongful Death
(23)
LAC IV 109 (Rev. 03/t 1)
LASC Approved 0304
i'KJ A72t o Medical Malpractice- Physicians & Surgeons
I .. J A7240 Other Professional 1-lealth Care Malpractice
J :J A7250 Premioes Liability (e.g., slip and fall)
I ! A7230 Intentional Bodily Injury/Property Damage/Wrongful Dealh (e.g.,
assault. vandalism, etc.)
L. I A7270 Intentional Infliction of Emotional Distress
ii A7220 Other Personal Injury/Property DamageNVrongful Death
CIVIL CASE COVER SHEET ADDENDUM
AND STATEMENT OF LOCATION
1., 4.
t .. 4.
t., 4.
1.. 4.
t., 3.
t .. 4.
Local Rule 2.0
Page 1 of 4
LM:VH19
ti:t

l'l
H

l'l
No. 0049 P. 17
Mar. 22. 20i2 S:WM


f:'"
Business Tort (07)
.,(2
0...::
C1vil Rights (08)
ero

;:._
Defamation (13)
. 2.2
" "' - <::
CQE
:;;;;,
Fraud (16)
"'-
:;;g,
"" "'
Professional Negligence (25)
1:. E
0"'
zo
Other (35)
;:
Wrongful Termination (36)
" E
;.,
0
a.
Other Employment (15)
E
w
Breach of Contract/ Warranty
(06)
(not insurance)
t;
::!
;:
Collections (09)
0
()
Insurance Coverage (18)
Other Contract (37)
Eminent Domain/Inverse
>.
Condemnation {14)
"

Wrongful EVICtiOn (33) c.
0
Q:
1i
0: Other Real Property (26)
Unlawful

w

]i Unlawful Detainer-Residential

(32)

Unlawful

I

'E
::> Unlawful (38)
LAC IV 109 (Rev, 03/11)
LASC Approved 03-04
C.] A6029 Other Commercial/Business Tort (not fraud/breach of contract) 1.. 3.
l._j A6005 Civil Rights/Discrimination 1., 2., 3.
1. ::::J A601 0 Defamation (slandernibel) 1., 2., 3 .
I A6013 Fraud (no contract)
1., 2 .. 3.
r
I A6017 Legal Malpractice 1., 2., 3.
I
! A6050 Other I or legal) 2., 3.
,.
) A6025 Other Non-Personallnjury/Propsrty Damage tort 2.,3.
I I A6037 Wrongful Tenmination 1., 2., 3.
I -l A6024 Other Employment Complaint Case 1., 2 .. 3.
r
I A61 09 Labor Commissioner Appeals 10.
: . .J A6004 Breach of Rental/Lease Contract (not unla'Nful detainer or wrongful 2., 5.
eviction)
I-I A6008 Contract/Warranty Breach Seller Plaintiff (no fraud/negligence)
I
I A6019 Negligent Breach of Contract/Warranty (no fraud)
[. i A6028 Other Breach of Contract/Warranty (not fraud or negligence)
r
\ A6002 Collections Case-Seller Plaintiff
I
I A6012 Other Promissory Note/Collections Case
I A6015 Insurance Coverage (not complex)
[5.:- I A6009 Contractual Fraud
["I A6031 Tortious Interference
A6027 Otl1er Contract Dispute( not breach/insurance/fraud/negligence)
L
I A7300 Eminent Domain/Condemnatlon Number of parcels ___
L-i A6023 Wrongful Eviction Case
J A6018 Mortgage Foreclosure
II A5032 Quiet Title
. J A6060 OtherReaiProperty(noteminentdomain, landlord/tenant,
] A6021 Unlawful Detainer-Commercial (not drugs or wrongful eviction)
c:::::J A6020 Unlawful Detainer-Residential (not drugs or wrongful eviction)
L._l A6020F Unlawful Detainer-Post-Foreclosure
D A6022 Unlawful Detainer-Drugs
CIVIL CASE COVER SHEET ADDENDUM
AND STATEMENT OF LOCATION
2., 5.
1, 2., 5.
1., 2., 5.
2., 5., 6.
2., 5.
1., 2., 5., 8 ..
1., 2., 3(:.v
1 . 2' 3., 5.
1., 2 . 3., 8.
2.
2., 6.
2, 6.
2., 6 .
2, 6.
2., 6.
2 .. 6.
2., 6.
2., 6.
Local Rule 2.0
Page2 of4
/
Mar. 22 2012 8 B,;M
Asset Fortoiture (05)
Petition re Arbitration (11)
Wnt of Mandato (02)
Other Judicial Review (39)


.] A61 08 Asset Fortelture Case
[ ~ .. ! A6115 Petition to Compei/ConflrmNacate Arbitration
!.. I A6151 Writ- Administrative Mandamus
i A6152 Writ Mandamus on Limited Court Case Matter
L. I A6153 Writ Other Limited Court Case Review
I A6150 Other Writ/Judicial Review
No. 0049
2., 6.
2 .. 5.
2., 8.
2.
2.
2., 8 .
p 18
Regulation (03) . . l AG003 AntitrusVTrade Regulation 1., 2., 8.
Construction Defect (1 0)
Mass Tort
Securities Litigation (28)
Toxic Tort
Environmental (30)
Insurance Coverage Claims
from Complex Case (41)
Enforcement
of Judgment (20)
RICO (27)
Other Complaints
(Not Specified Above) (42)
Partnership Corporation
Governance (21)
Other Petitions
(Not Specified Abovo)
(43)
LACIV 109 (Rev. 031111
LASC Approved 03-04
L ... I A6007 Construction Defect
1 : ~ J A6006 Claims Involving Mass Tort
I ... J A6035 5ecurities Litigation Case
D A6036 Toxic Tort/Environmental
l A6014 Insurance CoveragefSubrogation (complex case only)
l _ _j A6141 Sisler State Judgment
l__. i A6160 Abstract of Judgment
r-J A6107 Confession of Judgment (non-domestic relations)
[ ~ I A6140 Administrative Agency Award (not unpaid taxes)
~ ~ A61 14 Petition/Certificate for Entry of Judgment on Unpaid Ta:x
L. I A6112 OtherEnforcementofJudgmentcase
I A6033 Racketeering (RICO) Case
C::J A6030 Declaratory Relief Only
[._j A6040 Injunctive Relief Only (not domestic/harassment)
D A6011 Otller Com me r e i ~ I Complaint Case (non-tort/non-complex)
I A6000 Other Civil Complaint (non-tort/non-complex)
[I A6113 Partnership a.nd Corporate Governance Case
1... I A6121 Civil Harassment
CJ A6123 Workplace Harassment
I.._J A6124 Elder/Dependent Adult Abuse Case
1-::=J A6190 Election Contest
I I A6110 Petition for Change of Name
l__j A6170 Petition for Relief from Late Claim Law
1
I A6100 Other Civil Petition
CIVIL CASE COVER SHEET ADDENDUM
AND STATEMENT OF LOCATION
1., 2 .. 3.
1., 2, B.
1., 2., 8.
1., 2, 3., 8.
1 .. 2, 5., 8
2., 9
2, 6.
2 .. 9.
2 .. e.
2 .. e.
2., e .. 9.
1 .. 2 .. e.
1., 2, 8.
2., 8.
1., 2 .. 8.
1 '2 .. 8.
2., 8.
2., 3., 9.
2., 3 .. 9.
2 .. 3., 9.
2.
2., 7.
2., 3., 4., 8.
2 .. 9.
Local Rule 2.0
Page 3 of4
Mar. 22 20'r2 8 23AM

No. 0049 P. 19
'"o"r"''"': EVANS v. NARCoNOl'rm NORJ HERN CALIFORNIA. I cASE NUMBER
ct al. - .
Item Ill. Statement of Location: Enter the address of the accident, party's residence or place of business, performance, or other
circumstance indicated in Item II, Step 3 on Page 1, as the properreason for filing in the court location you selected.
REASON: Check the approprlatg boxes for the numbers shown
AUUHSs: 5160 W. Adams Boule van.!
under Column C for the type of action that you havg selected for
this case.
01.02.i''l3.1 14 1X.J5.06.D7. Ds.rl9.1 110 .
...
CITY: STAI"t: Zlr CODE
Los Angeles CA 90018
- - ~ .....
ltom IV. Declaration of Assignment; I declare under penalty of perjury under the laws of the State of California that the foregoing is true
and correct and that the above-entitled matter is properly filed for assignment to the Los Angeles courthouse in t11e
Central District of the Superior Court of Calrfornia, County of Los Angeles [Code Civ. Proc., 392 et seq., and Local
Rule 2.0. subds. (b), (c) and (d)].
Dated: March 22. f."'0"-'12,___
PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY
COMMENCE YOUR NEW COURT CASE:
1. Original Complaint or Petition.
2. If filing a Complaint. a completed Summons form for issuance by the Clerk.
3. Civil Case Cover Sheet, Judicial Council form CM-010.
4. Civil Case Cover Sheet Addendum and Statement of Location form, LAC IV 109, LASC Approved 03-04 (Rev.
03/11)
5. Payment in full of the filing fee, unless fees have been waived.
6. A signed order appointing the Guardian ad Litem, Judicial Council form CIV-010, if the plaintiff or petitioner is a
minor under 18 years of age will be required by Court in order to issue a summons.
7. Additional copies of documents to be conformed by the Clerk. Copies of the cover sheet and this addendum
must be served along with the summons and complaint. or other in'itiat'rng pleading in the case.
LACIV 109 (Rev. 03/11)
LASC Approved 03-04
CIVIL CASE COVER SHEET ADDENDUM
AND STATEMENT OF LOCATION
Local Rule 2.0
Page4 of4

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