l . i summons - FOR COURT USE ONLY USO DEUI CORE) Cross-Complaint Ci TA Ci ON NOTICE TO CROSS-DEFENDANT: (A VISO AL CON TRA-DEMANDADO): RAYMONDO an individual; MAD BROOKS, an individual; and Runs 1 through 20 YOU ARE BEING SUED BY CROSS-GOMPLAINANT: (LO ESTA DEMANDANDO EL CONTRADEMANDANTE): KEILEY WOLFF, an individual KW. A8 (1am You have 30 CALENDAR DAYS after this summons and legal papers are served on you to tile 3 written response at this court and have a curry served on the amoewcampiainant. it letter or phone call will not protect you. Your written reopenee must be in proper legal form If you want the court to hear your case. There may he a court form that you can use for your response. You can ?nd these court forms and more Information at the Gellfomlo Courts Cinline Sell-Help Center your county law library. or the courthouse nearest you. It you cannot pay the filing fee, cell: the court clerk for a fee waiver fonn. If you do not file your response on time. you may the case by default, and your wages. money. and property may be taken without further warning from the court. ?i?here are other legal requirements. You may want to nail an attorney right away. if you do not know an attorney. you may want to cell an attorney referral service. If you cannot alford an attorney. you may be for free legal oervioee from a nonproflt legal eorvloee program. You can locate these nonprofit groups at the California Legal Services Web site W.iowhelpceiifomie.ora). the California Courts Onllne Self?Help Center or by contacting your local court or county bar association. NOTE: The court has a statutory lien for waived fees and costs on any settlement or arbitration award of $10,000 or more in a civil case. The court's lien must be paid before the court will dlemlee the case. Tiene 30 DIAS DE CALENOARIO deepuee do que le enlreguen esta oiteoion papeies legoies pore presenter one rospuesto por candle on core cone tracer one so entregue una copia oi controdemendente. Una cede nna iiarnado no lo prolegen. Su respuesle per eecrito done one ester en fennan legal coneoro oi desert one procecen so noon on ie corte. Es positde one ireye on fonnuiedo one ostedprrede usarparo so reepuesta. Poetic uncontror coins formuiorios de lo code mas infomecion en el Centro de Ayude do ins Cortes de California en in biblioterre do ieyes do so oondado on in code one ie quede mes ceroe. Si no puede pager in cuote do presentecion. pide oi eecrelodo do to code one to do on fonnuiario dc exencion do page do circles. Si no pressure on respuesra a tiompo, poode pero'or ei coco per Moumpiimiento in corle ie padre quiler so sueido, dinero bionee sin mes edtremncie. Hey olroo requisites insoles. Es moomendebie one demo 8 un ebogodo inmedietemente. Si no conoce on ebogedo. puede iiernor a on servicio de romioion a noogados. Si no puede paper a on ebogodo, es poeibie one cunrple con Joe requisites pore octaner servicios legeies gratuitos do on programs do sendcios legeies sin iinee do iocro. Parade ocean ?or notes grapes sin fines de iucro en ei side we]: do California Legal Services, lwwaowhelpcalIlornianrgi. en el Centre de Ayudo do ins Cortes de Ceiifi'mrie oniendose en con recto con la oorte 0 cl coloyio do conga doe locales. For lay. in eerie ilene dereciro reciamnr ins coerce-y los castes exenros per importer on gravamen score cuoiquier recuperecion dc $10,000 6 mos do veior rocibide mediocre on eouerdo 0 one concesion o'e aroiqu'e on on coco do derecno civil. Tieno one mgar?gmamon do in code antes de corle puede downer ei ceeo. The no me and address of the court is: SHORT NAME OF cASEim meme mum saw): (El nombro direccidn do in code cs): - W0 luff Santa Clara Superior court CASE NUMEER. 191 N. First: Street, San Jose, CA 95113 1'15'cv'273103 The name. address. and telephone number of cross-complainant's attorney. or crosocompiainanl without an attorney. is: noigbro. $8 direccidn oi ndmom do iei?fono do! abogodo do! coniredemondonto, dol conirodomondonta one no done a age 0, es: Gloria Allred (State Bar No. 65033) 323-653-6530 Allred. Maroko 8: Goldberg. 6300 Wilshire Blvd. . Suite 1.500 Los Angeles, CA 90048 Sm DATE: DAVID H. YAMA Clerk. by Sn - . Deputy (Footie) MAY 5 Chief Executive Of?cer. Clerk {Secretedoi . AM (Adjunlo) (Ferment of service (within summons, use Proof ofTSTeryice of Summons (form I {Pore pruobe do outrage do esio citation use ei fonnuiado Proof of Service of Summons NOTICE To THE PERSON SERVED: You are served 1. as an individual cross-defendant. 2. as the person cued under the fictitious name of (specify): 3. I: on behalf of {specif?i under: cop 418.10 (corporation) can 413.30 (minor) CCP 418.20 (defunct corporation) CCP 416.70 (coneewetee) GOP 416.40 (association or partnership) CCP 416.00 {authorized person) other fspeci?r): 4. by personal delivery on (date): summousn-oeossucomemm'r 303m DD Page 1 ol 1 Gods of Civil Procedure. 412.20. 420.00. 485 3 Form Adopted tor Mandatory lice Judidol Comet! oi Commie BUM-110 lRoe. July 1.2000 "mm" Carpenter. Zuokerman ti: Rowlev, LLP 8827 West Olvm ic Blvd. Beverly Hills. 902? no. 3 10-2734 230 I . MTORNEY roe rem.- Cross-Complainant Kelley Wolff rsueenron oounr or counwor Santa Clara 2-615 HAY 5 F3 Fax no; 3 10358-1063 awesomeness: 191 North First Street mtrnenooness: 191 North First Street cmmozocooe Santa Clara, CA 95] 13 am? We: Downtown CASE NAME: Wolff v. McDonald CASE COVER SHEET Complex Case Designation ?55 Unlimited Limited l-iS-cv-278108 {An-mum (Amount Cl Counter CI Joinder . woos: Lucas demanded demanded in Filed with ?rst appearance by defendant exceeds $25,000) 525.000 or less) (Cal. Rules of Court. rule 3.402) new: 02 items 1?6 below must be completed (see instructions on page 2). 1. Check one box below for the case type that best describes this case: Auto Tort mot Provisionan complex Civil Litigation Ame (22? Breach of mmamnnw (03] (Gel. Rules of Court, rules SAW-3.403) Uninsured motorist {46) Rule 3.740 collections (no) I: AntnrucIITrade regulation (03) Other {Personal Injuwerporly Other collections (09). Construction defect (10) Death] Tort Insurance sewage (15} Mass tort (40] Mbems Othef comm: Securities litigation Product liability (24) goal prawn, Environmentatti?esic tort {30) Medic? ma'P'wm? (45} Emm?lit dm'??ini?em? Insurance coverage claims arising from the Other (14) abetre listed prominently complex case (Other) Tort ?2 BMW (33) Business tortlunfair business practice (07) CI 01"" man (26) Emmomam of Judgment I: Civil rights (08) i win! Detainer Enforcement of judgment (20) Datamation (13) [ii Commercial (31) Miscellaneous Civil Complaint CI Fraud (16) Residential (32) I: RICO Intellectual property (19) 00108 other complaint (not specified adore) (42) Professional "collection (25) Judicial miscellaneous one Petition Other ten (35) Asset ?manure {05) partnership and corporaie'govamam (21) Em laymen! Milli" "mm" I: Other petition (not Specified above} (43) Wrongful tenninaiion (36) Writ of mandate (02) Other moment (15) Other ludicial review (so) 2. This case LJ is is not complex under rule 3.400 of the Celiiomla Rules of Court. It the case is complex, out: the [actors requiring exceptional Judicial management: a. I: Large number of separater represented parties b. Extensive motion practice raising dif?cult or novel issues that will be time-consuming to resolve c. Substantial amount of documentary evidence d. Large number of witnesses e. I: Coordination with related actions pending in one or more courts in other counties. states. or countries, or In a federal court f. Substantial postjudgment judicial supervision 3 Remedies sought (check altihateppw: a. monetary nonmonetary: deciaratory 4. Number of causes of action (special): 5. This case is is not a class action suit. 6. ii there are any known related cases. lite and serve a notice oi related case. (You i use a -- Date: May 5, 2015 John C. Carpenter . 0- punitive injunctlue relief meson enter unite) NOTICE . Plaintiff must the this cover sheet with the ?rst paper filed in the action or proceeding (ex pt small otaltns cases or cases ?led under the Probate Code. Family Code. or Welfare and institutions Code). (Get. Rules oi curt. rule 3.220.) Failure to tile may result in sanctions. File this cover sheet in addition to any cover sheet required by local court rule. 0 II this case is complex under rule 3.400 et seq. of the California Rules of Court, you. our serve a copy of this cover sheet on all other parties to the action or proceeding. Unless this is a collections case under rule 3.740 or a complex case. this cover sheet will be used for statistical purposes only. a ll '0 mumma?nmm CIVIL CASE COVER SHEET circle (Res. July 1. 2007] Cal. Rules lilies 2.00. 3.220. 0.4004300. 3.140: Cal. Standards oi Judicial Monument?. aid. 3.10 XVCI A8 (HTH CHI-010 INSTRUCHONS ON HOW TO COMPLETE THE COVER SHEET To Plaintiffs and Others Filing First Papers. complete and file. along with your ?rst paper. the statistics about the types and numbers of cases one box for the case type that best describes the case. If the check the more speci?c one. if the case has multiple causes of To assist you in completing the sheet. examples of the cases that be sheet must be filed only with your initial paper. Failure to tile a cover Its counsel. or both to sanctions under rules 2.30 and 3.220 of the Califomla Rules of Court. under rule 3.740 is defined as an action for recovery of money and attorney?s fees. arising from a transaction in To Parties to Rule 3.740 Collections Cases. A ?collections case owed in a sum stated to be certain that is not more than $25,000. exclusive of Interest which property. services. or money was acquired on credit. A collections case does no damages, (2) punitive damages. (3) recovery of real property. If you are tiling a first paper (for exam pie. or complaint) in a civil case. you must Civil Case Cover Sheet contained on page 1. This Information will be used to compile ?led. You must complete items 1 through 6 on the sheet. In Item 1. you must check case tits both a general and a more specific type of case listed in item 1. action. check the box that best indicates the primary cause of action. long under each case type in item 1 are provided below. A cover sheet with the first paper ?ied In a civil case may subject a party. 1 include an action seeking the following: (1) fort recovery of personal property. or (5) a prejudgrneni writ of attachment. The identi?cation of a case as a rule 3.?40 collections case on this form means that it will be exempt from the general time-ior~service requirements and case management rules. case will be sublect to the requirements for stamina and obtaining a judgment in rule 3.740. To Parties In Complex Cases. In complex cases only. case is complex. If a plaintiff believe completing the appropriate boxes in complaint on all parties to the action. A defendant may file and serve no i plaintiffs designation. a counter?designation that the case is not complex. or. the case is complex. the case is complex under rule 3.400 oft unless a defendant tiles a responsive pleading. A rule 3.740 collections parties must also use the Civil Case Cover Sheet to designate whether the he California Rules of Court. this must be indicated by items 1 and 2. If a plaintiff designates a case as complex. the cover sheet must be served with the star than the time at its ?rst appearance a Joinder in the if the plaintifl has made no designation. a designation that CASE TYPES AND Auto Tort Contract Provisionally Complex Litigation (Cal. Auto (22Warsonsl Breach of ContractIWarranty (06) Rules of Court Rules sane?sans} Damagenivrongful Death Breach of anwe'a?as?m I I. gun?gradg rigging? (03) ninsu caste ?twigs: or wrongful eviction) Claims Involving Mass Tort (40) morons; crap? subject to ContractM'arranty Breach-Seller Securities Litigation (28} arbitration. check this item Plaintifi {not fraud ornegligence) Environmentaln'oxic Tort (30} instead turning) Negligent of Contractf Insurance times 553m" I Other FlaniWD Personal I all? m9 pm "It WW 9* properly n-amag?anmumgm, Other Breach of Contracwlarranty case type listed above} (41-) "ran Collections leg. money owed. open Enforcement of Judgment muscles [04) boolt accounts) (09) Enforcement ct Judgment (20) Asbestos ramped}, Damage Collection Cass-Seller Plaintiff Abstract of Judgment (Out of Asbestos Fem?: lulu?; Other Promissory NoterCollections Gaunt?) Wrongfm Damn Case Confession of Judgment (non- pwduu [jammy [not asbestos or insurance Coverage {not provisionally damas?g [glam-us) {24) complex! (15) Sister State Judgment Medical Malpractice {46} Auto Subrost Administrative Agency Award Medical Moipraotleew Other Coverage {not unpaid taxes) Physiolansa Surgeons Patience-mm otEntrv of Other Professional Health Care Contractual Fraud Judgment on Unpaid Taxes Malpractice 01ml- cgmu-acl Dispute Othe? Enforcement of Judgment Other (23) Real Property 553 Premises Liability te.g.. slip Eminent Domawlnverse Miscellaneous Complaint and fall) Condemnation (14) 2-7) lnteniional Bodily lnjurylpolwo Wrongful Eviction (as) incl speci?ed tit-9? 8833""; vandalism) Dolor Real Pro 9 e. .. uiet title 26 . Intentional in?iction of marlin? Pedammra Emotional Distress Managua Fofgdogum ?motive [y {new Negligent in?iction of quiet True 2:33:32? moiion?al Distress it i not amine We" swarm: mal?anin or 01"? ?mammal?! (Other) Tort foreclosure} om Bearings]: TorUUnioIr Business Unlawful Ballgliligu ?lm . mlIla a ca (07) Come a Civil Rights (as. discrimination. Residentiaitazl margin. false arrest) tool can Drugs (as) lire-case rams illegal (21, Defamation te.g.. slander. libel) report as Commarolal or Residential) above {43) Hand Asset Fmil?i?? workplace ?013nm lmle?ual Property (19} Petition Re: Arbitration Award (11] Eldememndem Mun Professional Negligence (25) will or Mandala (02} Abuse Legal Malpractice Writ?Administrative Mandamus E'ewm Gama Other Professional Malpractice innit?Mandamus on Limile Court Petition for Name Chen a {mmw?wwem ca? Petition for ReliefFrom tale Tori {35) Writ-Other Limited Court Case clam [35? Other .133:ngle (as) 0mm? Pam" Othei?mp'wmm?si Review oil-tealth Of?cer Order Notice of Appeal-Labor Commissioner Appeals ctr-ole law. July I. 20071 CIVIL CASE COVER SHEET 9min?! [Gloria Allrod. SEN 65033 Nathan Goldberg, sow 01292 ALLRED MAROKO a: GOLDBERG 6300 Wilsilire Boulevard, Suite 1500 Los Angelos, California 90048 Tole hone: (323') 653-6530 Foes mile: (323 653-1660 Email: gall glamoom John C.C enter. SEN 155610 Paul S. Zu crman, SEN 155539 CARPENTER. ZUCKERMAN ROWLEY, LLP 0827 West Olym ic Boulevard Beverly Hills, Ca ifomia 9021 1 Tel hone: (310) 273-1230 Foes mile: (310) 858-1063 Email: veronioa?ozrlaw.com Allow a for Defendant, Kelley olff SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SANTA CLARA RAYMONDO an individual CASE N0. 5-0v-278108 Plaintiff, Action Filed: March I6. 2015 Trial Data: Not so! vs. CROSS-COMPLAINANT KEILEY KELLEY WOLFF aka KEILEY WOLFE and CROSS-COMPLAINT Does I through X, DAMAGES: Defendants. 1. ASSAULT AND 2. 3. INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS: AND 4. FALSE V8. FOR JURY RAYMONDO an individual; AHMAD BROOKS, an individual; and Roe: . De em: 02 through 20, J11 go: Hon. Patricia M. Lucas KEILEY an individual Cross-Complainant. Defendants. CMIComplolnt XVH A8 (1311:! Cross-Complainant Keiley Wolff alleges: Rm 1. Cross-Complainant Kciley Wolff is an individual and is new. and at all times mentioned in this complaint was, a resident of California. 2. Cross-Defendant Raymondo' McDonald was at all times mentioned in this complaint a resident of California and a member of the San Francisco 49ers professional football team. Mr. McDonald is currently a player for the Chicago Bears. His current residence is unknown. 3. Ahmad Brooks is an individual and is new, and at all times mentioned in this complaint was. a resident of California. Mr. Brooks is a player for the San Francisco 49ers, a professional football team. 4. The true names and capacities of the defendants sued herein as ROES tltrough 20. are unknown to the cross-complainant, who therefore cues such defendants by such ?ctitious names pursuant to Code afCivii? Procedure Cross-Complainant alleges that each ?ctitiously canted defendant acted or failed to act in such a manner that each has caused the damages to the cross-complainant alleged herein. Cross-Complainant will seek leave to amend this complaint to set forth the true names of the ?ctitioust named defendants and their capacities when ascertained Reference herein to any defendant shall include reference to all defendants, including all named and all ?ctitioust named cross-defendants. 5. At all times relevant herein, Cross-Defendant Raymondo McDonald owned maintained. controlled, and managed the residence at 2516 Bentley Ridge Drive, San Jose, California 95138 (hereina?er the ?Subject Property"). 6. The cross-complainant is infomed and believes and thereon alleges that at all times mentioned in this complaint. all of the defendants - including ROES 1 through 20 - were the agents and employees of their (to-defendants. and in doing the things alleged in this complaint were acting within the course and scope of that agency and employment and with the knowledge, permission. and consent ofeaeh of the ctr-defendants. Cross-Complainant is further informed Crest-Cetan 2 asE and believes and thereon alleges that each ofthe defendants designated ROE is responsible in some manner for the events and happenings herein referred to and thereby proximately caused injuries and damages to the cross-complainant as herein alleged. 7. The emsseomplainant further alleges that each defendant rati?ed and approved of the acts of each of the other defendants and that each of the defendants participated in a common plan or scheme and wilfully agreed and conspired with each of the other defendants to do the acts and act in the maturer herein alleged, and that in doing the acts herein alleged, each acted pursuant to and in furtherance of said common plan orschente. 8. On or about December I4, 20?, the cross-complainant was invited by Cross- Det?endant McDonald to visit his residence, the Subject Property. 011 that day. the cross- complainant did in fact visit the Subject Property. 9. Prior to that day, the cross-complainant Was unaware that Defendant McDonald was a professional football player. Cross-complement was ?trther unaware that Defendant McDonald had been in the news for allegations of domestic violence. It). Crossucotnploinant is informed and believes that surveillance video at the Subject Property shows the following, without limitation: A. The cross-complainant slipped and fell on a negligently maintained, dangerously slippery their near the swimming pool and struck her head. is infomed and believes that she suffered a traumatic brain injury, including a loss of consciousness for more titan eight minutes. B. Cross-complainant is infonned and believes that while she was lying unconscious on the pool deck, Crossobefendant McDonald erroneously believed her to be dead, did not call ill I, and told others that he did not want a dead female to he found on his property. C. Cross-complainant is informed and believes that shezregained semi- conselousness, but then fell on additional occasions due to her altered state from the head injury and earlier consumption of alcohol. Tress-(templatm 3 28 D. Crosscompiainant is informed and believes that while she was unconscious from a subsequent fall, Cross-Defendant Brooks groper! her person in a sexual manner. Cross-complainant is informed and believes that prior to regaining full consciousness and while she was unable to give consent, the cross-complainant was carried upstairs by Cross-Defendant McDonald to his bedroom. I l. Thereafter, Cross-Defendant McDonald removed the cross-complainant?s clothes and then engaged in tun-consented touching, restraint, and sex with the cross-complainant. At all times, the cross-complainant could not consent to the touching and did not consent. 12. Such nit-consented touches continued through the following day. (Assault and Battery against All Cross-Defendants 13. Cross-Complainant incorporates herein by refenenoe as though set forth in full here at, paragraphs 1 through l2. inclusive of the Cross-Complaint herein as though set forth in full here. 14. On or about December i4, 20?, at the Subject Property, Cross?Defendants Brooks, McDonald, and Rees l~20 intentionally caused harmful and o??ensive contact and force with the cross-complainant?s person by his and intentional acts of harmful and offensive touching. 15. The cross-complainant did not consent to any of the offensive contact or attempted contacts with her person. Hi. The cross-defendants threatened and instilled in the cross-complainant an apprehension, intimidation, and fear of immediate, offensive. violent. and unlaw?tl injury on her person. and. actual injury on her person. 17. The emssdefendants? acts Were authorized, approved, condoned rati?ed by each of the defendants. I 8. As a proximate result of the cross-defendants? acts asdesorihed above, the cross- Crm-wmtaint I 4 complainant was hurt in her health. strength, and activity. sustaining injury to her body and shock and injury to her nervous system. and person all of which injuries have caused and continue to cause the cross-complainant great physical, mental, and nervous pain and suffering all to her general damages in an amount to be provcn at trial and incurred damages all to her general damages in an amount to be proven at trial. 19. As a further proximate result of Cross-Defendants acts? and each of them, as mentioned herein, and because of the injuries it was necessary for the to receive medical care and treaunent and the crosecomplain'ant did incur hospital. medical. and incidental expenses and will in the future be compelled to incur additional expenses in an amount unknown to the crossneomplainant at the present time but to be proveo at trial. As a further proximate result ofthe negligence of Defendants and each of them, the eroseeomplalnant's earning capacity has been greatly impaired, both in the past and in the present in an amount according to proof. 20. The aforementioned acts of Cross-Defendants were despicable, willful, and malicious and were intended to oppress and. cause iniury to Cross-Complainant within the meaning of the Civil Code 3294, and, therefore, the Cross-Complainant is entitled to an award of exemplary and punitive damages in an amount suf?cient to punish Cross-Defendants. and to deter the CrossaDefendants from committing similar acts in the future. SECOND CAUSE ACTION (Negllgonee Against Crossnnefedants McDonald and Race MO) Cross-Contplainont incorporates herein by reference as though set forth in full here at, paragraphs 1 through 20. inclusive of the Cross-Complaint herein as though set forth in full here. 22. On or about December 14. 2014. at the Subject Property. Cross-Complainant slipped and fell near the pool deck, causing the cross-complainant to sustain serious injuries and damages as described herein. 23. At the aforementioned time and place. the crossvdefendanls negligently I CroteComnluint ?or. . -. maintained. managed. controlled, installed. and operated the Subject Property. causing the cross- oomplainan?t to be injured. These cross-defendants, knew, or in the exercise of reasonable care should have known. the pool deck area constituted a dangerous condition and Intreesonable risk ofharm. These cross-defendants negligently, and in reckless disregard, failed to take steps to either make the condition safe, or worn the emsseomplainant of the dangerous eondition. all of which caused the cross-complainant to suffer the injuries and damages hereina?er described all of which were directly and proximately caused by the cross-defendants? negligence. 24. As a further direct and proximate result of the negligence of the cross-defendants as set forth above. the crossacomplainant sustained the following serious injuries and damages: She was injured in her health, strength and activity, sustaining injury to her body and shock and injury to her nervous system, and person. and extreme and severe mental anguish and emotional distress all of which have caused and continue to cause the cross-complainant great physical, mental, and nervous pain and suffering all to her general damages in an amount to be proven at his]. 25. As a further proximate result of the negligence of the cross-defendants and each of them, as mentioned herein, and because of the injuries it was necessary for the to receive medical care and treatment and the ere-complainant did incur hospital, medical, and incidental expenses and will in the future be compelled to incur additional expenses in an amount unknown to the arose-complainant at the present time but to be proven at trial. 26. As a further proximate result of the negligenee of the cross-defendant's and each of them. the cross-complainant's coming capacity has been greatly-impaired, both in the past and in the present in an etuount to proo? THIRD TI (For Intentional Initiation of Emotional Distress against all Cress-Defendants) 27. Cross-Complainant incorporates herein by reference as though set forth in titll here at, paragraphs 1 through .26. inclusive of the Cross-Complaint herein as though set forth in full here. emu-Caeplnm 6 28. Through the outrageous conduct described above. Cross-Defendants, andeaeh of 2 titem. acted with the intent to cause. or with reckless disregard for the probability oi?causing the 3 Cross-Complainant to suffer severe emotional distress. 4 29. As a direct and proximate cause of action or inaction by the cross-defendants. the cross-complainant has suffered and will continue to seller pain and suffering, loss of sleep. and 6 extreme and severe mental anguish and emotional distress; she has incurred and will continue to 7 incur medical expenses" for treatment by and other health professionals. and for a other incidental expenses; and she has suffered and will continue to suffer a loss of earnings and. 9 other employment bene?ts and job opportunities. 111s cross-complainant is thereby entitled to to general and compensatory damages in amounts to be proven at trial. It 30. The aforementioned acts of cross-defendants, were despicable, willful, and I2 malicious and were intended to oppress and cause injury to cross-complainant within the 13 meaning ofthe Civil Code section 3294, and, therefore, the cross-complainant is entitled to an to award of exomplary and punitive damages in an amount suf?cient to punish ems-defendants. 15 and to deter the cross-defendants from committing similar acts in the future. I6 I8 (False Imprisonment against All Cross-Defendants 19 3 l. The cross-complainant rte-alleges each and every allegation contained in the above 20 1 paragraphs 1 though 30, and by this reference incorporates said paragraphs as though fully set 2 forth herein. 22 32. On or about December 14, 2014, at the Subject Property. Cross-Defendants 23 lnteotionally deprived the cross-complainant of her freedom of movement by use of physical 24 force and unreasonable duress. 25 33. 1119. con?nement and restraint ofthe cross-complainant compelled the cross- 26 complaith to stay for an appreciable amount of time. 27 34. The cross-complainant did not consent. 28 35. As a proximate result of the crosswdoiendunts? sees as described above, the cross- ammonium 7 complainant was hurt in her health, strength, and activity, sustaining injury to her body and shock and injury to her nervous system. and person all of which injuries have caused and continue to cause the cross-complainant great physical, mental. and nervous pain and suffering all to her general damages loan amount to he proves at trial and incurred damages all to her general damages in an amount to be proven at trial. 36. As a further proximate result of the erossudefendants acts? and each of them, as mentioned herein. and because of the injuries it was necessary for the cross-complainant to receive medical care and treatment and the cross-complainant did incur hospital, medical, and" Incidental expenses and will in the future be compelled to incur additional expenses in an amount unknown to the crosswomplainant at the present time but to be proven at trial. As a proximate result of the negligence oferosswdefendants and each of them, the cross-complainant?s earning capacity has been greatly impelled, both in the past and in the present in an amount according to proof. 37. The aforementioned acts of crossodefendants were despicable, will?ii, and malicious and were intended to oppress and cause injury to cross-complainant within the meaning of the Code section 3294, and. dictators, tho crossocomplainant is entitled to an award of exemplary and punitive damages in an amount suf?cient to punish cross-defendants, and to deter the eross~defendants From. committing similar acts in the futureWe: WHEREFORE Cross-Complainant prays judgment against the Defendants and each of them, as follows: ALL CAUSES OF ACTION: 1. For general and compensatory damages according to proof; For all special medical and incidental expenses according to proof; Far lost earning and lost coming capacity; Costs of suit; and 2 3 4. Punitivc and exemplary damages (except as to Cause of Action No. 5 6 For such Other and further relief as to the Court may seem just and proper. DATED: May 5, 2015 Respectfully submitted, ALLRED. MAROKO ?5 GOLDBERG for Cross-Complainant ori AN ROWLEY, LLP John C. Carpcn Anomcys for ss~Complainant ?GUI-huhThe Cross-Complainant hereby demmds a trial by jury on all causes of action. DATED: May 5, 2015 Respect?JHy submitted. ALLRED. MAROKO GOLDBERG Allred Attorneys for Cross~Complainanl John C. ler Attorneys for asummplai'nam Winn? 10 28. STATE OF CAUFORNIA, COUNTY OF LOS ANGELES new I am emplo in the County of Los Angeles State of California. and not a party to within action; my business adthess is: 882'? West . . Hills, California 902! 1. On May 5. 2015. 1 served the attached document described as CROSS- KEILEY CROSS-COMPLAINT FOR DAMAGES on all interested parties in this action 0 by placing the true copies themel? enclosed in sealed envelopes addressed as stated on the attached mailing list. ?int placing the original a a true copy thereof enclosed in sealed envelopes addressed as ows: Steve M. De??ppis. Esq. PICONE a LIPPIS 625 North First Street San Jose, California 951 292-0441 hone) 287-6550 Fax Email: tl'msm?g?tl??ghmegm BY US. MAIL deposited auoh envelope in the mail at Los Angeles, Calitbmia. The envelope was mailed with postage thereon fully prepaid. a As follows: i am ?readil familiar" with the ?rm?s practice of collection and processing correspondence for and lag. Under that practice it would be deposited with the US. postal serviee on that same day with postage thereon fully prepaid at Beverly Hills, California in the ordinary course of business I am aware that on motion of the party served. service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in af?davit. a BY FAX to the Judicial Council, pursuant to CCP EXECUTED on May 5. 2015, a: newly Hills, Catiromia. a STATE - I declare under penalty of petjuly under the laws of the of C-alifomia that the above is true and correct. Type or Print Name Qignatare Cross-Complain? 1 1