David Jordan,
Esq. State Bar # 69052
LAW OFFICES OF DAVID JORDAN
315 W. Arden Avenue, Suite 28
Glendale, California 91203 (818) 242-1100
Attorney for Plaintiff
Rudy Rodriguez
MUNICIPAL COURT OF THE
STATE OF CALIFORNIA
LOS ANGELES JUDICIAL DISTRICT
RUDY RODRIGUEZ
)
Plaintiff,
)
CASE NUMBER 93 C 05776
)
) COMPLAINT FOR
) PERSONAL INJURY AND
) PROPERTY DAMAGES
)
-
vs. - )
)
)
CASEY CHRISTIANSEN )
DOES 1 THROUGH 30, )
)
)
Defendants.
)
_____________________)
COMES NOW, the Plaintiff,
RUDY RODRIGUEZ, and for a cause of action against the defendants,
and each of them, complains and alleges as follows:
1. The true names and capacities, whether individual,
corporate, associate, or otherwise
of defendants, DOES 1 through 30, inclusive, are unknown, to Plaintiff,
who therefore sues said defendants by such fictitious names. When
the true names and capacities have been ascertained, Plaintiff
will seek leave of Court to amend this Complaint accordingly.
Plaintiff is informed and believes, and based thereon alleges
that the defendants designated herein as DOE are in some manner
negligently responsible for the events and happenings complained
of herein, and are thus the proximate cause of the injuries and
damages to Plaintiff complained of herein.
2. At all times herein mentioned, the defendants, and each of
them, were theagents, employees, and servants of each and every
other defendant, and the acts and omissions complained of herein
were performed within the course and scope of said agency and
employment, and were performed with the full knowledge, consent,
and permission of each and every other defendant.
3. At 1 times herein mentioned Plaintiff, was and is a resident
the county of Los Angeles,
State of California.
4. At all times herein mentioned, defendant CASEY CHRISTENSON,
was a resident in the County of Los Angeles, State of California.
5. At all times herein mentioned, Plaintiff, RUDY RODRIGUEZ, was the driver of his vehicle, a 1988 Honda Civic, License Number 3AOS590 (California) which was involved in the described accident.
6. At all times herein mentioned, defendant, CASEY CHRISTENSON, was the operator and registered owner of a certain vehicle, namely a GMC truck which was involved in the hereinafter described accident.
7. At all times herein mentioned, the Interstate 5 freeway, near the intersection of the 60 (Pomona) freeway was a freeway in the City of Los Angeles, County of Los Angeles, State of California, and for purposes of jurisdiction, the Los Angeles Judicial District is where the tort occurred and is therefore the proper jurisdiction for the filing and prosecuting of said action.
8. On or about July 24, 1995, at approximately 6:30 A.M. on the Interstate 5 freeway, near the intersection of the 60 freeway, in the City of Los Angeles, County of Los Angeles, State of California, the defendant(s) , and each of them, did so negligently, carelessly, wantonly and recklessly, drive, control, operate, maintain, manage and entrust the aforesaid automobile so as to cause it to collide and hit the rear of plaintiff's vehicle which was completely stopped due to traffic congestion.
9. That as a further proximate result of the negligence, carelessness, recklessness, wantonness, and unlawfulness of the defendants, and each of them, Plaintiff has been injured in his health, strength, and activity, and has sustained great and severe mental, emotional and physical pain and suffering, as well as great and severe shock and strain to his body and nervous system, all to his damages in an amount to be determined at the time of trial.
10. That as a further
proximate result of the conduct of the defendants, and each of
them, Plaintiff has been forced to, and in the future will continue
to be forced to incur liability for medical and related expenses,
the exact amount of which is unknown, but which will be presented
according to proof at the time of trial.
11. . That as a further proximate result of the conduct of the
defendants, and each of them, Plaintiff has incurred a loss of
earnings and earning capacity, the exact amount of which is unknown,
but which will be presented according to proof at the time of
trial.
12. That as a further proximate result of the conduct of the defendants,
and each of them, Plaintiff has been forced to incur additional
and extraordinary household and living expenses, the exact amount
of which is unknown, but which will be presented according to
proof at the time of trial.
13. That as a further proximate result of the conduct of the defendants, and each of them, Plaintiff's, vehicle has been depreciated in value and Plaintiff has been forced to incur liability for repairs to it, the exact amount of said depreciation and cost of repairs is unknown, but which will be presented according to proof at the time of trial.
WHEREFORE, Plaintiff prays for judgment against the defendants,
and each of them, as follows:
1. For general damages, as proven;
2. For medical and related
expenses, past and future, as proven;
3. For loss of earnings and earning capacity, as proven;
4. For additional and extraordinary household and living expenses, as proven;
5. For depreciation and costs of repairs of Plaintiff's vehicle, as proven;
6. For costs of suit incurred;
7. For such other and further damages as may be discovered prior to judgment:
8. For such other and further relief as the Court may deem just and proper;
Plaintiff remits any damages in excess of the jurisdiction of this court ($25,000)
Dated: July 4, 1996
Law Offices of David Jordan
By___________________________
David Jordan, Esq. SB # 69052
Attorney for Plaintiff