e ate @ FILED, ‘omy OF on Anger 1) Gary K. Daglian, Esq. (SBN No. 232717) DEC 08 2015 2|| DaGLian Law Grour, APLC Ste, epespwe UticerCie 701 N. Brand Blvd,, Suite 610 By pay 3]] Glendale, California 91203 Telephone: (818) 545-7700 4) Facsimile: (818) 545-3700 5} attorneys for Plaintiff 6 1 DT Suzanne 6. rugueras 8 SUPERIOR COURT OF CALIFORNIA 9 COUNTY OF LOS ANGELES, CENTRAL DISTRICT 10} a ANNIE R. LEE, an individual, CASENO. B06 03447 u Plaintifi(s), COMPLAINT For: vs. ) LUSIDA RUBBER PRODUCTS, INC., a 1, RELIGIOUS DISCRIMINATION - ‘TERMINATION OF EMPLOYMENT California Corporation, WILLIAM JOHONNESSON, an individual, WAYNE (Gov. Code § 12940(a) and (6); CHIN, an individual, and DOES 1 10 50, 2. FAILURE TO PREVENT RELIGIOUS inclusive, DISCRIMINATION (Gov. Code §12940 wos Defendants. 3. HARRASMENT IN VIOLATION OF FEHA 4. RETALIATION IN VIOLATION OF PUBLIC POLICY (Religious Discrimination); 5. WRONGFUL TERMINATION IN VIOLATION OF PUBLIC POLICY (Religious Discrimination) JURY TRIAL DEMANDED BABES g4 23 PARTIES R a mi 34 na 24 1. Plaintiff ANNIE R. LEE (“Plaintiff”) is an individual who Bae HhesBgor 28 3 25|| California. ” as 3 8 2 26 Ed 3 | : ap 8 27 Ba a 4 e 8 oe assa 3 ‘Commit 88838i ~ <7 Daglian Law Group ewe a ame wn ree ee ee ee ee BNRRESSESELREVRREBEES 2. Plaintiff is informed and believes and based thereon alleges that Defendant LUSIDA RUBBER PRODUCTS, INC. (“Defendant LUSIDA”) is a California corporation that operates within the County of Los Angeles and employs more than five employees. 3. Defendant WAYNE CHIN (“Defendant CHIN”) is an individual that resides in the State of California and within the County of Los Angeles. 4. Plaintiff ss informed and believes and based thereon alleges that Defendant CHIN is the principal of Defendant LUSIDA. 5. Defendant WILLIAM JOHONNESSON (“Defendant JOHONNESSON”) is an individual that resides in the State of California and within the County of Los Angeles 6. Defendant JOHONNESSON is the general manager of Defendant LUSIDA. 7. Plaintiff is ignorant of the true names and capacities of defendants sued herein as Does | through $0, inclusive, and therefore sues these defendants by such fictitious names under California Code of Civil Procedure § 474. Plaintiff will amend this Complaint to allege their true names and capacities when the same are ascertained, Plaintiff is informed and believes and thereon alleges that each of the fictitiously named defendants is legally responsible in some manner for the occurrences herein alleged and that the injuries of Plaintiff as herein alleged have been proximately caused by the aforementioned defendants, and each of them. 8. Plaintiff is informed and believes and thereon alleges that each of the defendants named herein has at all times relevant to this action been the officer, agent, employee and/or representative of the remaining defendants and has acted within the course and scope of such agency and employment, and with the permission and consent of the co-defendants. YENUE 9. Venue as to each Defendant is proper in this judicial district, pursuant to California Government Code § 12965. Actions and/or omissions leading to liability in this cease occurred in the County of Los Angeles. au aM ConranHe 7 Daglian Law Group ee yaw eon PRR eee ee ee BNRREBREBSSERRAESS FACTUAL ALLEGATIONS 10. Plaintiff was actively employed by Defendant LUSIDA from approximately June 23, 2014 to on or about December 18, 2014 as a customer service representative. 11. Plaintiff was a salaried employee earning approximately $2,500 per month. 12. In or about September 2014, Defendant LUSIDA hired Defendant JOHONNESSON as high ranking executive officer of Defendant LUSIDA. 13, Beginning in or about October of 2014, Defendant LUSIDA began requiring all of its employees to attend and engage in a mandatory thirty minute class during work hours that was based on the teachings of L. Ron Hubbard and the Church of Scientology. The courses were initially administered three times a week, but the frequency occurred to almost daily in December 2014. 14. Plaintiffs informed and believes and based thereon alleges that the teachings of the Church of Scientology were done at the urging of Defendant JOHONNESSON. 15. The courses were not optional and every employee at Defendant LUSIDA was required to participate in it regardless of their religious affil n. 16. After Plaintiff began participating in the mandatory courses, she soon realized that she was being pressured and brainwashed into accepting thoughts, methodologies, and religious beliefs that were not in line with her religious beliefs. Plaintiff soon realized that, contrary to what Defendants told her, it was not related to her job or her job duties. Rather, Plaintiff was forced to take online courses entitled “Breaking the Code,” which undoubtedly is authored by L. Ron Hubbard, the founder of the Church of S tology. 17. When Plaintiff informed her superiors, including general manager Defendant JOHONNESSON, that she did not fee! comfortable with participating in these mandatory training courses, she was told that she had no choice. Moreover, she was told by Defendant JOHONNESSON that if she did not know how to wear “multiple hats” that she was not fit to work for the company. Apparently, the term “wearing multiple hats” is one of the teachings of L. Ron Hubbard. Conrtaine7 Daglian Law Group ee wane wn = RBNSRSRERBRBESSRERRRAESEEES 18. Also, Defendant JOHONNESSON repeatedly spoke negatively about other religions in front of Plaintiff and other employees and urged Plaintiff to denounce her existing religious beliefs and adopt Scientology as her new religion. 19. Plaintiff was given books to read and pressured to learn about Scientology. 20. On or about December 2, 2014, after Plaintiff had participated in yet another mandatory training course based on the teachings of L. Ron Hubbard and the Church of Scientology, Plaintiff (and other employees) were asked a written question as to why they had taken the class and what they learned from it, Plaintiff responded to the question by stating that she did not want to join the class and that she was forced to do so and that she did not want to lear any of the teachings of the Church of Scientology that Defendants were imposing on her. 21. Shortly thereafter, on or about December 18, 2014, Plaintiff was given poor performance reviews and terminated, 22. Plaintis informed and believes and based thereon alleges that Defendant LUSIDA, through the actions of Defendant JOHONNESSON and Defendant CHIN, have terminated other employees who, like Plaintiff, have refused to participate in the mandatory Church of Scientology courses. Interestingly, most (if not all) employees who have replaced the terminated employees have been members of the Church of Scientology. 23. On November 30, 2015, Plaintiff filed a complaint with the Department of Fair Employment and Housing (“DFEH”). On that same date, the DFEH issued Plaintiff his Right-to- Sue letter. This action is filed within one year of the date of that Right-to-Sue letter. A true and correct copy of the Right To Sue letter is attached hereto as Exhibit "1." FIRST CAUSE OF ACTION Religious Discrimination —Termii ion of Employment (California Government Code § 12940(a)) Against Defendant LUSIDA. 24. Plaintiff incorporates by reference all previously alleged paragraphs as though fully set forth herein. Companee wane wn Be oS ES A FRSPESRONR I cOHPORATON & Daglian Law Group 25. Atall times relevant to this Complaint, the California Fair Employment and Housing Act (“FEHA”) (Cal. Gov. Code § 12900 et seq.) and its implementing regulations were in full force and effect and binding on the Defendants. 26. Pursuant to Government Code § 12940(a) unlawful for an employer to discriminate against an employee because of the employee's religious beliefs or refusal to adopt its employer’s religious teachings 27. Pursuant to Government Code § 12940(c) itis unlawful for any person to discriminate against any person in the termination for that person because of the religious creed of the person discriminated against. 28. Plaintiffs informed and believes and thereon alleges that the conduct, including but not limited to, being given poor performance reviews and eventually being terminated immediately after Plaintiff expressed her disdain of participating in these mandatory courses, was motivated by her religious belief’ and refusal to adopt the teachings of the Church of Scientology. 29. The aforepled conduct of Defendants, and each of them, constitutes discrimination based on Plaintiff's religion and accordingly violates Government Code § 12940(a) and other provisions of FEHA. 30. Asa proximate result of the said discrimination, PI if has suffered mental anguish and emotional suffering in an amount in excess of the minimum jurisdiction of this Court and according to proof. 31. Asa further proximate result of said discrimination as aforepled, Plaintiff has suffered a loss of tangible employment benefits including lost wages and fringe benefits in an amount in excess of the minimum jurisdiction of the Court and according to proof. 32. Asa further proximate result of the discrimination as aforepled,, Plaintiff was required to and did retain attomeys, and is accordingly entitled to an award of attomey’s fees according to proof, 33. Asa further proximate result of said discrimination, Plaintiff has incurred and will continue to incur medical expenses in amount according to proof at the time of trial. Comma~ uD Daglian Law Group ee 3 aw ew Ree ee ee ee ee BNRREBRESSRERRAEBESEES 34. Indoing the things alleged herein, the Defendants’ conduct was despicable, and the Defendants, and each of them, acted toward Plaintiff with malice, oppression, fraud, and with willful and conscious disregard of Plaintiff's rights, entitling Plaintiff to an award of punitive damages. 35. Plaintiff is informed and believes, and thereon alleges, that Defendant LUSIDA. ratified or authorized the said conduct because the acts of oppression or malice and/or the acts of ratification or authorization were on the part of a managing agent or owner acting on behalf of Defendant LUSIDA. 36. _Inaddition to the damages requested herein, Plaintiff also seeks injunctive relief enjoining Defendant LUSIDA from requiring its employees to participate in mandatory courses based on the teachings of L. Ron Hubbard and/or the Church of Scientology. ‘SECOND CAUSE OF ACTION Failure to Prevent Discrimination Or Retaliation (California Government Code § 12940(k)) Against Defendant LUSIDA 37. Plaintiff incorporates by reference all previously alleged paragraphs as though fully set forth herein. 38. _Atall times relevant to this Complaint, the FEHA and its implementing regulations were in full force and effect and binding on the Defendants. 39. Pursuant to Government Code § 12940(k), it is unlawful for an employer to fail to prevent discrimin: nor retaliation from existing in the workplace. 40. In engaging in the conducts described above, the Defendant LUSIDA failed to engage in any reasonable steps to prevent discrimination or retaliation against Plaintiff. 41, Defendant LUSIDA, through its general manager and principal, knew that Plaintiff and other employees refused to participate in the teachings of the Church of Scientology, yet they ignored their protests and continued to mandate the courses. And when Plaintiff became vocal and more forceful with her rejection of the teachings, Plaintiff was terminated, Companee a am ee NY LF Daglian Law Group RRREBREBSEDABDEBS 2 8 42. Asa proximate result of the said discrimination, Plaintiff has suffered mental anguish and emotional suffering in an amount in excess of the minimum jurisdiction of this Court and according to proof. 43. Asa further proximate result of said discrimination as aforepled, Plaintiff has suffered a loss of tangible employment benefits including lost wages and fringe benefits in an amount in excess of the minimum jurisdiction of the Court and according to proof, 44. Asa further proximate result of the discrimination as aforepled, Plaintiff was required to and did retain attorneys, and is accordingly entitled to an award of attorney's fees ‘according to proof. 45. Asa further proximate result of said discri nation, Plaintiff has incurred and will continue to incur medical expenses in amount according to proof at the time of trial. 46. In doing the things alleged herein, the Defendants’ conduct was despicable, and the Defendants, and each of them, acted toward Plaintiff with malice, oppression, fraud, and with willful and conscious disregard of Plaintiff's rights, entitling Plaintiff to an award of punitive damages, 47. Plaintiff is informed and believes, and thereon alleges, that Defendant LUSIDA ratified or authorized the said conduct because the acts of oppression or malice and/or the acts of ratification or authorization were on the part of a managing agent or owner acting on behalf of Defendant LUSIDA. 48. In addition to the damages requested herein, Plaintiff also seeks injunctive relief enjoining Defendant LUSIDA from requiring its employees to participate in mandatory courses based on the teachings of L. Ron Hubbard and/or the Church of Scientology. THIRD CAUSE OF ACTION Harassment in Violation of FEHA Against All Defendants 49. Plaintiff incorporates by reference all previously alleged paragraphs as though fully set forth herein, ‘Conmcannr~ 7 Daglian Law Group Re elon eta aati en ers! Re oe ee BNRRREBRESSERVRRESEES 50. The aforepled conduct of Defendants, and each of them, violates the FEHA, which provides that the harassment of employees on the basis of religious creed is unlawful. 51. Plaintiff and other employees who refused to participate in the teachings of Scientology were subjected to unwanted harassing conduct by Defendants JOHONNESSON and CHIN, which created an oppressive, ho: , intimidating and offensive work environment for all 52. The harassing conduct of Defendants was so severe or pervasive that Plaintiff, and any reasonable person in Plaintiff's position would, consider the work environment to be hostile. 53. Asa proximate result of the hostile work environment, Plaintiff has suffered mental anguish and emotional suffering in an amount in excess of the minimum jurisdiction of this Court and according to proof. 54, Asa further proximate result of said hostile work environment as aforepled, Plaintiff has suffered a loss of tangible employment benefits including lost wages and fringe benefits in an amount in excess of the minimum jurisdiction of the Court and according to proof. 55., Asa further proximate result of the hostile work environment as aforepled, Plaintiff ‘was required to and did retain attomeys, and is accordingly entitled to an award of attomney’s fees according to proof. 56. Asa further proximate result of said hostile work environment, Plaintiff has incurred and will continue to incur medical expenses in amount according to proof at the time of trial, 57. Inddoing the things alleged herein, the Defendants’ conduct was despicable, and the Defendants, and each of them, acted toward Plaintiff with malice, oppression, fraud, and with willful and conscious disregard of Plaintiff's rights, entitling Plaintiff to an award of punitive damages. 58. Plaintiff's informed and believes, and thereon alleges, that Defendant LUSIDA ratified or authorized the said conduct because the acts of oppression or malice and/or the acts of ratification or authorization were on the part of a managing agent or owner acting on behalf of Defendant LUSIDA. Comma7 Daglian Law Group 0) Ses Noy BNRRERBSESSERNRAEEEES 59. In addition to the damages requested herein, Plaintiff also seeks injunctive relief enjoining Defendant LUSIDA from req. ing its employees to participate in mandatory courses based on the teachings of L. Ron Hubbard and/or the Church of Scientology. FOURTH CAUSE OF ACTION Retaliation (California Government Code § 12940(h)) Against Defendant LUSIDA 60. Plaintiff incorporates by reference all previously alleged paragraphs as though fully set forth herein, 61. Atal times relevant to this Complaint, the FEHA and its implementing regulations ‘were in full force and effect and binding on the Defendant, 62. Pursuant to Government Code § 12940(h) itis unlawful for an employer to retaliate against an employee for opposing any practice forbidden under the FEHA. 63. Asset forth above, on a number of occasions Plaintiff expressed her concern about the forced teachings of Scientology and refused to participate in the mandatory training courses. 64. Asa result of her complaints and her refusal to denounce her religion and adopt Scientology, Plaintiff was wrongfully terminated. 65. Plaintiff's complaints about the mandatory courses served as a motivating factor in the Defendants’ decisions to terminate her. 66. Asa proximate result of the said retaliation, Plaintiff has suffered mental anguish and emotional suffering in an amount in excess of the minimum jurisdiction of this Court and according to proof. 67. Asa further proximate result of said retaliation as aforepled, Plaintiff has suffered a loss of tangible employment benefits including lost wages and fringe benefits in an amount in excess of the minimum jurisdiction of the Court and according to proof. 68. Asa further proximate result of the retaliation as aforepled, Plaintiff was required to and did retain attomeys, and is accordingly entitled to an award of attorney's fees according to proof. Compan7 Daglian law Group ee a awe wr 8 PRNReRBR eee eee ee BSRRPEBRESSEDATREBS 69. Asa further proximate result of said retaliation, Plaintiff has incurred and will continue to incur medical expenses in amount according to proof at the time of trial. 70. In doing the things alleged herein, the Defendants’ conduct was despicable, and the Defendants, and each of them, acted toward Plaintiff with malice, oppression, fraud, and with ful and conscious disregard of Plaintiff's rights, entitling Plaintiff to an award of punitive damages. 71. Plaintiff is informed and believes, and thereon alleges, that Defendant LUSIDA ratified or authorized the said conduct because the acts of oppression or malice and/or the acts of ratification or authorization were on the part of a managing agent or owner acting on behalf of Defendant LUSIDA. 72. in addition to the damages requested herein, Plaintiff also seeks injunctive relief enjoining Defendant LUSIDA from requiring its employees to participate in mandatory courses based on the teachings of L. Ron Hubbard and/or the Church of Scientology. FIRTH CAUSE OF ACTION Wrongful Termination in Violation of Public Policy Against Defendant LUSIDA 73. Plaintiff incorporates by reference all previously alleged paragraphs as though fully set forth herein, 74. NM the public policy of the State of California to prohibit employers from discharging employees in a discriminatory or retaliatory manner. This public policy is embodied in, inter alia, the California Government Code, the California Code of Regulations and the case of Tameny v. Atlantic Richfield Company (1980) 27 Cal.3d 167. 75. The Defendants’ decision to terminate Plaintiff was motivated at least in part by Plaintiff's refusal to adopt the teachings of Scientology and expressing her concern about the mandatory training courses and the constant urging of Plaintiff to join the Church of Scientology. Mt Mt ‘Compan7 Daglian Law Group ee aw awe wy Ree eee ee ee BNRREREBERESSREVARES 76. The policy violated by Defendants was one that inures to the benefit of the public at large since the termination of Plaintiff violated statutes forbidding termination based on religious creed. 77. Asa proximate result of the said discrimination, Plaintiff has suffered mental anguish and emotional suffering in an amount in excess of the minimum jurisdiction of this Court ‘and according to proof. 78. Asa further proximate result of said discrimination as aforepled, Plaintiff has suffered a loss of tangible employment benefits including lost wages and fringe benefits in an amount in excess of the minimum jurisdiction of the Court and according to proof. 79. Asa further proximate result of said discrimination, Plaintiff has incurred and will continue to incur medical expenses in amount according to proof at the time of trial 80. _Inddoing the things alleged herein, the Defendants’ conduct was despicable, and the Defendants, and each of them, acted toward PI with malice, oppression, fraud, and with willful and conscious disregard of Plaintiff's rights, entitling Plainti to an award of punitive damages. 81. Plaintiff is informed and believes, and thereon alleges, that Defendant LUSIDA ratified or authorized the said conduct because the acts of oppression or malice and/or the acts of ratification or authorization were on the part of a managing agent or owner acting on behalf of Defendant LUSIDA. 82, _Inaddition to the damages requested herein, Plaintiff also seeks injunctive relief enjoining Defendant LUSIDA from requiring its employees to participate in mandatory courses based on the teachings of L. Ron Hubbard and/or the Church of Scientology. WHEREFORE, Plaintiff prays for relief as set forth below. PRAYER FOR JUDGMENT 1 For special, general, and compensatory damages according to proof at trial; 2. For punitive damages according to proof at trial; Commannrwey an een 3. Forinjunetive relief; 4, For reasonable attomeys’ fees, expert witness fees, and other litigation expenses pursuant to California Government Code § 12965(b); 5. Forall other relief the Court deems appropriaée and just. DATED: December 7, 2015 Respectfully Submitted, DAGLIAN Law Group, APLC ‘ComPuannrEXHIBIT 1DEPARTMENT OF FaIR EMPLOYMENT & HousiNG ‘ime CTOR KEM KH Scnestiteernob ew veo stew dehengort el ca ceereh.cgov November 30, 2015 Annie R. Lee 153 Fano Street, Apt. D Arcadia California 91006 RE: Notice of Case Closure and Right to Sue DFEH Matter Number: 716896-196861 Right to Sue: Lee / Lusida Rubber Products, Inc. Dear Annie R. Lee, ‘This letter informs you that the above-referenced complaint was filed with the Department of Fair Employment and Housing (DFEH) has been closed effective November 30, 2015 because an immediate Right to Sue notice was requested. DFEH will ake no further action on the complain. ‘This letter is also your Right to Sue notice. According to Government Code section 12965, subdivision (b), 2 civil action may be brought under the provisions of the Fair Employment and Housing Act against the person, employer, labor organization or employment agency named in the above-referenced ‘complaint. The civil action must be filed within one year from the date of this letter. ‘To obtain a federal Right to Sue notice, you must visit the U.S. Equal Employment Opportunity Commission (EEOC) to file a complaint within 30 days of receipt ofthis DFEH Notice of Case Closure ‘oF within 300 days of the alleged discriminatory act, whichever is earlier. Sincerely, Department of Fair Employment and HousingDEPARTMENT OF FaiR EMPLOYMENT & HOUSING ioeee ieee Tab copreosaee = SE ‘rena gov ema cot cener@leca.po" Enclosures ccc: Wayne Chin William Jobannesoncm.o1 [Gary K Daolian, Feo, (SBN OQ) e es Daglian Taw Groun, APLC ALN Raa aap eo ong hBER ilendale. ( Sener Cour Of Calorla ‘TeLervone 00: 818-545-7700 raxno: 818-545-3700 "County OfLar Angeles srronvey Fox wanes: Plaintiff IsuPERIOR COURT OF CALIFORNA, COUNTY OF LOS ANGELES smeeeraoosess: 1] N. Hill Street sac aooness: 11] N. Hill Street emvano ze cove: Los Angeles, CA 90012 sraxcnwe. Stanley Mosk Courthouse CASE NAME: Lee v. Lusida Rubber Products, Inc. DEC 08 2015 Shem apyeen opeopuve Ucar. Tua Deputy CIVIL CASE COVER SHEET Complex Case Designation Liesl Unlimited Limited EX untiites LT Limite Cleaner Cl sinter — | BOG 03-447 demanded demandedis | ” Filed wth fist appearance by defendant exceeds $25,000) _ $25,000 or less) (Cal. Rules of Court, rule 3.402) | err lems 1-6 below must be competed (see insuctions on page 2) [i Chack one box below forthe case ype that best describes this case ‘Auto Tort Contract Provisionally Complex Civil Litigation TE} ato 22) [ET breach of conraciwarranty (06) (Cal Rules of Cour rules 340023 903) ‘Uninsured motorist (46) [1 Rute 3:740 cotections (09) [J Antitrust trade reguiation (03) ‘Other PUPDIWD (Personal Injury/Property L_] Other collections (09) (Construction defect (10) DamageNrongful Death) Tort [insurance coverage (18) ‘Mass tort (40) ‘Asbestos (04) 1 otner contract (37) ‘Securities itigation (28) LE] Product atitty 24) Real Property Environmental Toxic tot (30) Meal malpractice (46) Eminent domeinnverse Insurance coverage clas aang fom cmrrwomn gs S sensor sceoteesremencaisabe fan Non-PUPDAWD (Other) Tort TJ Wrongtt eviction (33) types (41) Business torvunfair business practice (67) [| Other real property (26) Enforcement of Judgment Gi ght (08) Unil Detainer [J Eenoroement of judgment (20) Defamation (13) (J Commerciat (31) Miscellaneous Civil Complaint Fraud (16) (I Residential (32) [J rico 7) Intellectual property (18) CT onugs 2) Other complaint (not spectied above (42) Professions negigence (25) luiciat Review ance eae 1 otter non-pupoWD tort (35) Asset forfeiture (05) Partnership and corporate governance (21) Employment 1 other petition (not speciiod above) (43) Wrongful termination (36) Pelion re: arbitration award (11) 2 writer mandate 02) [_) other employment (15) [) other judicial review (38) 2. This case [_Jis [XJis not — complex under rule 3.400 of the California Rules of Cour. Ifthe case is complex, mark the factors requiring exceptional judicial management: 2. Large numberof separately represented pares ». [=] extensive maton practice rising dict or novel issues that willbe tme-consuming to reeove cc. [] Substantial amount of documentary evidence 44, ] Large number of witnesses. ¢. Coordination with elated actions pending in one or more courts in other counties, states, or counties, or in a federal court 1, [2] Substantial postjudgment judicial supervision 3. Remedies sought (chock a that apy): aK] monetary _».[X] nonmonetary; dectaratory or injunctive relief 4. Number of causes of action (specif): FIVE (5) 5. This case [lis isnot a class action suit , there are any known elated cases, fie and serve a notice of relat Qate: Dec. 7, 2015 Gary K. Dagtian, Esq. TPE OR PNT ET cK ]punitive ' Plaintiff must file this cover sheet with the first paper filed in the actd 1 under the Probate Code, Family Code, or Welfare and Institutions Cotk ', 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 of this cover sheet on all ‘other parties to the action or proceeding. * Unless tis sa collections case under rule 3.740 ora complex case, this cover sheet wil be used fr statistical purposes only, Fermnarpesionnoneaey Um CIVIL CASE COVER SHEET “ie Count Cooma ieonor uy 2007 re to file may result Tal fanaa on, uP SHO TOA 37Lee, Annie Ruby v, Lusida Rubber Products, Inc., et a. BC6 03447 CIVIL CASE COVER SHEET ADDENDUM AND. STATEMENT OF LOCATION (CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION) This form is required pursuant to Local Rule 2. all new civil case filings in the Los Angeles Superior Court. Item I. Check the types of hearing and fi in the estimated length of hearing expected for this case: sur Tru? BR ves cuassaction? C1] ves umrep case? Clves ive estMATeo FOR TRIAL S-7_O) HouRs/ oaYS Item I. 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, tothe right in Column A, the Civil Case Cover Sheet case type you selected Step 2: Check one 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 tothe court location, see Local Rule 2.0 Applicable Reasons for Choo! n (see Column C below) 4, Gass acions must be fle inthe Stniy Mosk Counnouse, central ditt. 6 Location of property or pamanenty garaged vec. 42 Siaybe ogi cena (oter county. or Po oaly Syren Sona 4 Lette sre pulhon eaes, 5, Location where cause ot aeton arate eee ee & [eaion wherein cofendantrespondent functions wholly. & alo er aay ny ea of dae cere 8 Esalon tere oe orate he pes ae 5. Lesaton wns partomanessequed or Galera es 16: LSealan of fabri’ Ofte ‘Step 4: Fill in the information requested on page 4 in Item Ill; complete Item IV. Sign the declaration. A B c Ci Case Cover Sheet Type of Acton Aoplcaba Reasons Satogor No. (Check ony one See Sep 3 Above ee auto 22) 1. ATI00 Motor Vehicle - Personal IjuyiPropery DamagetongtlDeath [1.2.4 ze Uninsured Motorist (46) A710 Personal injury’Property Damage/Wrongful Death ~ Uninsured Motorist | 1., 2. 4. 1D. AGO70 Asbestos Property Oamage 2 Asbestos (04) teat is A7221_ Asbestos - Persona uryongul Death 2 es Ei | _Preduatisomy an | 47260 Proivtleity rt atestos or ote 1.2.3,4.8 BS {2 A7210 Medical Maracie -Physcons& Sugeons 14 S| edica marae 45) 2 107240 ther roessonal Heath Care Malpracice tA 8 5 © A280 Prenss sity. ip era) i 2 Ofer 2 Persseatinuy | ©. -A7290 Intentional Bodily njuryPreperty OamageMrongfl Death. ta i eee saul vandalom te) \Wrongil Death O_A7270 Intentional Infiction of Emotional Distress 13 _A7220 Other Personal Injury/Property Damage/Wrongful Death 14 ACW 109 (Rev. 03/11) CIVIL CASE COVER SHEET ADDENDUM Local Rule 20 ASC Approved 03-04 . AND STATEMENT OF LOCATION Page 1 of 4[Lee, Annie Ruby v. Lusida Rubber Products, Inc. A B c Ci Case Cover Sheet Type of Acton Aeplcadie Reasons - Category. (Check only ene See Step 3 Above Business Tot (G7) [2 A6029 Other CommercavBusiness Tort (nt raubreaeh of contrat) 1.3 25 ge Civ Figts (06) [10 AS0O8 Civ Rights/isrminton 1.2.3 &3 $8 Detamaton(ts) [8010 Defamation sandetbe 1.2.3 = re 12.8 5s 85 8017 Lega Mapactce 1.2.3 EB | ProtessonaiNeotoenc 25) te 11 A6050 Other Profesional Mabpracte (net medal olga) 1.2.3 otner (95) 18025 Other Non Personal nucyPronery Damage tort 2.8 § [wrong temnien 95) Te A0n07 Wwongia Tematen Oo z z D_A6024 Other Employment Complaint Case 4,.2,3 2 (other Employment (15) oaeanes : 5 6109 Labor Commissioner Appeals 10 1 ASODH Breach of RentalLease Contact (rot uniewfulaetanerorwrorat | evicton : Breach of Conwecl Warrant | cy 46008 ContractWarranty Breach Seller Paint (no faudineghgence) a (not insurance) 1 A6019 Negligent Breach of ContractWarranty (no fraud) age O A6028 Other Breach of Contract Warranty (not fraud or negligence) aa z 1D. AG0c2 Collections Case-Seler Plant 5.6. z ‘Collections (09) 3 © AGOI2 Other Promissory NottColecons Case 5 insurance Coverage 16) | AGOIS Insurance Coverage (not complex) 1.2.5.8 © AGGO9 Convactual Froud 1.2.3.5 Ctner Contact 67) | A091 Tortous interterence 1.2.3.5 © ABG27 Other Contract isputtnat breachinsurancetausnegigene) 1.2.3.8 Enno boventnerse emjpomamnes Tc 47300 Eminent DomsivGondemnaton Number of parc 2 E [wong Evson cs |. aetes wrong ewan cove 28 3 1D A6018 Mortgage Foreclosure « Other Real Property (26) |) AG032 Cuiet Tite 6 . 13. AB060 Other Real Prope (ot eminent domain, andorenant,torecasue) | 26 ‘Unlawful Seton aes D_A8021 Unlawful Detainer-Commercial (not drugs or wrongful eviction) 2.6. UnlewlDetainerRescental 1-5 p5r20 UnlewlDetainerResdental (ot rugs or wong eviction 2.6 Uni Detar. pulawie elaine | 6020 Unawtl Detsine Post Forecosue 2.8 Unie Deliver Drugs (38) | A602 Unawtl Detine-Dngs 2.6 tek LAgjy 108 Re. 03%) CIVIL CASE COVER SHEET ADDENDUM Local Rule 20 LASC Approves 03.04 AND STATEMENT OF LOCATION Page 2014a ad =a Lee, Annie Ruby v. Lusida Rubber Products, Inc. A B c Ci Case Cover Sheet Type of Aton Aaplcabie Reasons Category No. (Check ony one) See Sep 3 Above Asset Focetue (05) | ASIO8 Asset Foreture Case 2.6 | Pettonreabiraton 11) | A615 Pettono CompelContemvacat Ariation 2.5 z é 1D ASI51 Wit Adminstatve Mandamus 2.8 tof wandste(02) | A152 wrt- Mandamus on Limited Cout Case Matter 2 = A659 Wet-OterLnited Cout Case Review 2 ther Judit Revew (36) [1 ABIS0 Other Wnt Judcl Revew 2.8 g__[ArtuavTrae Repuaton 03) [© AGOGD Artrusrade Regulation 1.2.8 5 Construction Defect (10) | 1 A6007 Construction Defect 1,2,3 ] | Claims tovotana Mass Ter | ry aga05 cians nvohing Mass Ton 4.2.8 e S| securities usaton 28) [12 6098 Secunes Ligation Case 4.2.8 5 eminem Tey) A808 Tone Tomo hake E | isuance Coverage cisens Tagore innurance CoveragerSutrogaton (complex case onl) 4.2.5.8 a AGIA} Serer Sot udgment 2.8 zi 15160 Abstract of udgment 2.8 bE oe eee 28 g3 ‘of Judgment (20) D_A6140 Administrative Agency Award (not unpaid taxes) 2.8. 22 53 ©. ASI FetitoniCeifcate for Enty of Judgment on Unpais Tax 2.8 © A612 Ofer Enforcement of Judgment Case 2.8.8 a Rico@n TI ASOES Racketeering (RIGO) Case 1.2.8 23 16090 Dedtratry Relat Only 1.2.8 BF | cmerconpains | AED inc Rel! On (et donestonsrssmen) ae BS | ietspectiesArove) 42) | asors omer Commercial Compan Case (on rtnon-complex) 1.2.8 ° 1D 8000 Other Civil Complaint (non-tortinon-compex) 1.2.8 Pannersnp Comaraten agi. Parner and Corporate Governance Case 2.8 © AGI21 Chit Harassment 2.3.8 3.8 0 A6123. Workplace Harassment 23,9, 53 cer etn [A124 ElderDependen Adi Abute Case 2.3.8 5 (Wot Specited Above) | 0 A6TE0 Election Contest 2 ze @ © ASI10 Petition for Change ofName 2.7 13_ASI70 Petin fr Rela om Lae Cia Low 2.3.4.8 5100 Other Ct Ptton 2.9 ‘ew 108 Rev. oar) CIVIL CASE COVER SHEET ADDENDUM Tocal Rule 20 LASC Approved 03.04 AND STATEMENT OF LOCATION Page 3.of4an ® oa [Lee, Annie Ruby v. Lusida Rubber Products, Inc. tem Ill. Statement of Location: Enter the address of the accident, party's residence or place of business, performance, or other circumstance indicated in item Il, Step 3 on Page 1, as the proper reason for fling inthe court location you selected REASON: Check the appropriate boxes for the numbers shown |712 S, Date Avenue under Column ¢ for the type of action that you have selected for this case. Oh. 2.03. 04. 05. 06.07. O08. 09. O10. |Alhambra ICA |91775 lem IV. Declaration of Assignment: | dectare 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 Stanley Mosk ‘courthouse in the Central District ofthe Superior Court of California, County of Los Angeles [Code Civ. Proc., § 392 et seq... and Local Rule 2.0, subds.(b), (c) and (4) Dated: Dec. 7, 2015 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 @ Complaint, a completed Summons form for issuance by the Clerk. 3. Civil Case Cover Sheet, Judicial Council form CM-010. 4 Quil Case Cover Sheet Addendum and Statement of Location form, LACIV 108, LASC Approved 03-04 (Rev. 03/11), 5. Payment in full of the filing fee, unless fees have been waived. 6. Assigned order appointing the Guardian ad Litem, Judicial Council form C1V-010, ifthe plaintif or petitioners 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 initiating pleading in the case. LABIV 109 (Rev. 03717) CIVIL CASE COVER SHEET ADDENDUM Local Rule 20 LASC Approved 03-08 AND STATEMENT OF LOCATION Page 4 of 4