1 2 3 Bruce Kokozian, Esq. (#195723) KOKOZIAN LAW FIRM, APC 9440 South Santa Monica Boulevard, Suite 510 Beverly Hills, CA 90210 Telephone (323) 857-5900 Fax Number (310) 275-6301 , County of Los Angles MAR 1,72016 4 Attorneys for Plaintiff 5 ^ 004^ ANITA MAYNARD FILED Superior Court 6fCalifornia By. V^^^? Judl Lora 6 , Deputy 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT 10 11 ANITA MAYNARD, an individual CASE NO.: BC«l422g COMPLAINT FOR: 12 Plaintiff, 1. 13 FAILURE TO PAY OVERTIME WAGES; v. 14 BETTY WHITE LUDDEN, an individual and 15 2. DOES 1 through 100, Inclusive WAGES; Defendants 16 FAILURE TO PAY MINIMUM 3. FAILURE TO PROVIDE MEAL PERIODS OR COMPENSATION IN LIEU THEREOF; 17 18 4. FAILURE TO AUTHORIZE AND PERMIT PAID REST PERIODS; 19 5. 20 FAILURE TO TIMELY FURNISH ACCURATE ITEMIZED WAGE STATEMENTS; 21 6. VIOLATION OF LABOR CODE §203; 22 gn'S UNFAIR BUSIHESS-JMCJI^ES §jjlfn% £ 3E i> x "o .. i-i 23 7. 24 DEMAND FOR Jlto^glAL* to g> £2 c * rr.. * o n 03 o o -J hi 25 w COMES NOW plaintiff ANITA MAYNARD (hereinafter "Plaintiff") and alleges % 0- 26 -J h> O follows: fi en 27 /// 28 o 1 COMPLAINT o o tn TO . . . . C..J O o io Q o O o O o W CO ALLEGATIONS COMMON TO ALL CAUSES OF ACTION 1 2 3 4 5 6 1. Plaintiff is and was, at all times relevant hereto, a resident ofthe County ofLos Angeles, Stateof California. 2. Plaintiff is informed and believes, and alleges that defendant BETTY WHITE LUDDEN ("Defendant") is and was an individual residing in the County of Los Angles, State of California. 3. Defendant BETTY WHITE LUDDEN and DOES 1 through 100 arejoint 7 employers ofPlaintiff (hereinafter collectively Defendants) in that they are and were operating as a 8 joint enterprise; suffered and permitted Plaintiffto work; controlled Plaintiffs hours and working 9 conditions; controlled Plaintiffs wages and made the decision to hire and fire Plaintiff and 10 therefore and they are both the employer ofPlaintiff. Defendant BETTY WHITE LUDDEN and 11 Does 1through 100 are referred to collectively as"Defendants". 12 4. The true names and capacities, whether individual, corporate orassociate, or 13 otherwise, ofthe defendants named herein as DOES 1through 100, inclusive, are unknown to 14 Plaintiff, who therefore sues said defendants by such fictitious names pursuant to California Code of 15 Civil Procedure §474, and Plaintiff will amend his complaint to show their true names and 16 capacities when the same have been ascertained. Plaintiff is informed and believes and based upon 17 such information and belief, alleges that all defendants sued herein as DOES are in some manner 18 responsible for the acts herein alleged and that Plaintiffs damages were proximately caused by their 19 conduct. 20 5. Plaintiff is informed and believes, and based thereon alleges, that at all times 21 mentioned herein, each ofthe Defendants and DOES whether specifically named and/or designated 22 herein as a DOE were the agents, principals, employees, employers, representatives, joint venturer 23 orco-conspirators, management companies and/or representatives, or alter ego ofeach ofthe other 24 Defendants and DOES, either actually or ostensibly, and in doing the things alleged herein acted 25 within the course and scope of such agency, employment, jointventure, conspiracy, reinsurance 26 agreement, co-insurance agreement, management company agreement, alter ego agreement and/or 27 service with the approval, knowledge, authority, acquiescence and/or ratification ofeach ofthe 28 remaining Defendants and DOES. COMPLAINT 6. 1 All of the acts and conduct herein and below described ofeach and every corporate 3 defendant was duly authorized, ordered, and directed by the respective and collective defendant corporate employers, and the officers and management-level employees of said corporate 4 employers. In addition thereto, said corporate employers participated in the aforementioned acts and 5 conduct of their said employees, agents and representatives, and each ofthem; and upon completion 6 ofthe aforesaid acts and conduct of said corporate employees, agents and representatives, the 2 8 defendant corporation respectively and collectively ratified, accepted the benefits of, condoned, lauded, acquiesced, authorized and otherwise approved ofeach and all ofthe said acts and conduct 9 ofthe aforementioned corporate employees, agents and representatives. 7 7. 10 Plaintiff has been employed by Defendants since at least February 23,1994 until 11 Plaintiffs employment ended in March 11,2016. Plaintiffwas employed as alive in domestic 12 worker. Plaintiff was not apersonal attendant because she spent more than 20 percent ofher time 14 performing work other than feeding and dressing aperson who needs supervision. Throughout the relevant period ofthis complaint, Plaintiffhas worked more than nine hours aday. Indeed, Plaintiff 15 worked in excess offourteen hours aday. Plaintiff was not paid overtime for work performed over 16 nine hours per day. Plaintiffwas not given twelve consecutive hours oftime off. Plaintiff was not 17 paid overtime rates for hours worked offduty or within the period she was meant to have off. 18 Plaintifffurther worked more than twelve hours aday and did not have three hours offree time, 13 f 20 either consecutively or not, during those twelve hours. Plaintiffworked six days awork week. Plaintiffwas not paid an overtime rate for work on the sixth day of her workweek. Plaintiff was not 21 paid double time for hours worked in excess ofnine hours on the six day she worked in awork 22 week. Plaintiff was not provide uninterrupted meal periods or compensation in lieu thereof, and was 23 not provided timely with accurate itemized wage statements. Plaintiffwas not paid all her wages 24 owed, including her vacation pay, upon her employment ending. 19 il'l 25 FIRST CAUSE OF ACTION 26 FAILURE TO PAY OVERTIME WAGES 27 AGAINST AM, DEFENDANTS 28 (Labor Code SI 194 et seq.) COMPLAINT ! L 8. 1 Plaintiff realleges and incorporates by reference all ofthe allegations contained in 4 the preceding paragraphs ofthis Complaint as though fully set forth herein. 9. Labor Code §204 establishes the fundamental right ofall employees in the State of California to be paid wages, including straight time and overtime, in atimely fashion for their 5 v/ork. 2 3 6 10. Labor Code §510(a) states in pertinent part: "Any work in excess of eight hours in 8 one workday and any work in excess of40 hours in any one workweek and the first eight hours worked on the seventh day ofwork in any one workweek shall be compensated at the rate ofno less 9 thatone and one-half times the regular rate of pay for an employee." 7 10 11 11. The applicable Industrial Welfare Commission Order No. 15 ("Order No. 15") special overtime rules for household occupations provides that all worked performed in excess of 17 nine hours aday by live in domestic workers who are not personal attendants ("Domestic Workers") shall be compensated at not less than 1.5 times the employees regular rate ofpay. Order No. 15 further provides that Domestic Workers shall have twelve consecutive hours oftime offduring a24 hour period and all work required or permitted during off-duty hours or during the 12 consecutive off-duty hours shall be compensated at the rate of 1.5 times the employee's regular rate ofpay. Order No. 15 also requires that Domestic Workers receive three hours of free time throughout their 18 twelve hour work day. Plaintiffwas not paid 1.5 times her regular rate ofpay for hours worked in 19 excess ofnine hours aday, was not given 12 consecutive hours off and was not paid 1.5 times her 2.0 regular rate of pay for work required or permitted during these off duty hours. Plaintifffurther did 21 not have three hours offthroughout her workday of more than twelve hours. 12 13 14 15 16 22 l\) 12. Pursuant toLabor Code §1198, it isunlawful toemploy person for longer than the 23 hours set by the Industrial Welfare Commission or under conditions prohibited by the IWC Wage 24 OrderfsY r .> 25 13. Defendants suffered and/or permitted Plaintiff to work inexcess ofeight (9) hours 26 per workday compensation for such excess hours worked. Defendants failed to pay Plaintiff 27 overtime compensation for work in excess ofeight (9) hours per day, Failed to pay Plaintiff 28 overtime compensation at double the hourly rate for work in excess of9hours on her sixth day of COMPLAINT 1 work and for all work performed on the seventh day of her work. 2 14. Defendant also suffered and/or permitted Plaintiffto work in excess of nine hours on 3 the sixth consecutive day of work in aworkweek without compensating such employees at the 4 appropriate overtime rates which Plaintiffwas required to work, as alleged above, Defendants 5 violated the provisions ofLabor Code §1194. 6 15. As aresult ofthe unlawful acts ofDefendants, Plaintiff has been deprived of wages 7 and/or overtime/double time wages in an amounts to be determined at trial, and is entitled to 8 recovery of such amounts, plus interest and penalties thereon, attorneys' fees, and costs, pursuant to 9 Labor Code §1194: and Civil Code $3287. 10 SECOND CAUSE OF ACTION H FAILURE TO PAY MINIMUM WAGES AGAINST ALL DEFENDANTS 12 fLahor Code §1197 et seq) 13 16. Plaintiff incorporates by reference and realleges each and every one ofthe 14 allegations contained in the preceding and foregoing paragraphs ofthis Complaint as if fully set 15 forth herein. 16 17. Pursuant to Labor Code §1197, payment of less than the minimum wages fixed by 17 the Labor Commission is unlawful 18 18. California Code ofRegulations Title 8, §11000(s) and the IWC Wage Orders states 19 :"Every employer shall pay to each employee- wages not less than eight dollars ($8.00) per hour for 20 all hours worked, effective January 1,2008... and not less than nine dollars ($9.00) per hour for all 21 hours worked effective July 1,2014 and ten dollars ($10.00) per hour effective January 1,2016. 22 19. Defendants required Plaintiffremain under Defendants' control without paying (••> 23 Plaintifftherefore resulting in Plaintiff earning less than the legal minimum wage in State of 24 California. '.•' <•;> 25 20. Pursuant to Labor Code §1194(a), Plaintiff can recover in acivil action for the (•'» 26 unpaid balance of the full amount ofthe unpaid minimum wages owed, calculated as the difference 27 between the straight time compensation paid and the applicable minimum wage, including interest 28 thereon. COMPLAINT 21. 1 Pursuant to Labor Code §1194.2(a) (which provide that in any action under Labor. 3 Code §1194, an employee shall be entitled to recover liquidated damages, Plaintiffseeks recovery of liquidated damages on the straight-time portion ofuncompensated hours ofwork (not including the 4 overtime portion thereof) in an amount equal to the wages unlawfully unpaid and interest thereon. 2 5 6 7 8 22. Pursuant to Labor Code $218.6, Labor Code §1194(a) and Civil Code §3287 Plaintiff also see recovery ofpre-judgment interest on all amount recovered herein. 23. Pursuant to Labor Code §1194(a) Plaintiffrequests that the Court award reasonable attorneys' fees and costs incurred in this action. THIRD CAUSE OF ACTION 9 10 FAILURE TO PROVIDE MEAL PERIODS OR COMPENSATION 11 TN TIFII THEREOF AGAINST ALL DEFENDANTS 12 (labor Code 88226.7 and 512) 13 Plaintiffrealleges and incorporates by reference all ofthe allegations contained in 15 the preceding paragraphs ofthis Complaint as though fully set forth herein. 25. Pursuant to Labor Code §512, no employer shall employ an employee for awork 16 period of more than five (5) hours without ameal break of not less than thirty (30) minutes in which 17 the employee is relieved of all ofhis or her duties. Furthermore no employer shall employ an 14 19 employee for awork period of mor than ten (10) hours per day without providing the employee with asecond meal period ofnot less than thirty (30 minutes in which the employee is relieved ofall of 20 his or her duties. 18 21 <•;» 24. 26. Pursuant to Labor Code §226.7, ifan employer fails to provide an employee with a 22 meal period or rest period as provided in the applicable Wage Order ofthe Industrial Welfare 23 Commission, the employer shall pay the employee one additional hour ofpay at the employee's 24 regular rate of compensation for each work day that the meal period or rest period is not provided. 25 27. By failing to keep adequate time records required by Labor Code §§226 and 26 1174(d), Defendants have made it difficult to calculate the unpaid meal period compensation due 27 Plaintiff. 28 28. As a result ofthe unlawful acts ofDefendants, Plaintiff has been deprived ofone COMPLAINT 1 additional hour ofpay at the employee's regular rate ofcompensation for each work day that the 2 meal period was not provided, in amounts to be determined at trial, and is entitled to recovery of 3 such amounts, plus interest and penalties thereon, attorneys' fees, and costs, under Labor Code 226, 4 226.7, and 1194; and Civil Code §3287. 5 FOURTH CAUSE OF ACTION 6 FAILURE TO AUTHORIZE AND PERMIT PAID REST PERIODS 7 (AGAINST ALL DEFENDANTS) 8 29. Plaintiff incorporates by reference and reallege each and every one ofthe 9 allegations contained in the preceding and foregoing paragraphs ofthis Complaint as if fully set 10 forth herein. !i 30. Labor Code §226.7(a) states: "No employer shall require any employee to work 12 during any meal or rest period mandated by an applicable order ofthe Industrial Welfare 13 Commission." 14 31. Labor Code §516 provides that the Industrial Welfare commission may adopt or 15 amend working conditions orders with respect to break periods for any workers in California 16 consistent with the heal and welfare of those workers. 17 32. Section 12(A) of the IWC Wage Orderfs) states: "Every employer shall authorize and 18 permit all employee to take rest periods, which insofar as practicable shall be in the middle ofeach 19 work period. The authorized rest period time shall be based on the total hours worked daily at the 20 rate often (10) minutes net rest time per four (4) hours or major fraction thereof. However, arest 21 period need not be authorized for employees whose total daily work time is less then three and one22 half (3 V2) hours. Authorized rest period time shall be counted as hours worked for which there shall 23 be no deduction from wages." 24 33. Section 12(B) ofthe IWC Wage Orderfs) states: "Ifan employer fails to provide an 25 employee arest period in accordance with the applicable provisions ofthis order, the employer shall 26 pay the employee one (1) hour of pay at the employee's regular rate ofcompensation for each 27 workday that the restperiod is not provided." 2s 34. Plaintiff consistently worked over four (4) hours per shift and therefore were entitled COMPLAINT 1 to arest period ofnot less than ten (10) minutes prior to exceeding four (4) hours of employment. 35. 2 3 authorize and permit the required rest periods established by Labor Code §226.7 and Labor Code § 4 516 and Section 12of the TWC Wage Order(s). 5 6 36. Pursuant to Section 12 of the TWC Wage Orders(s) and Labor Code §226.7(b) which states "ifan employer fails to provide an employee ameal or rest period in accordance with an 10 applicable order ofthe Industrial Welfare Commission, the employer shall pay the employee one additional hour ofpay at the employee's regular rate ofcompensation for each work day that the meal or rest period is not provided," Plaintiffis entitled to damages in an amount equal to one (1) additional hour ofpay at each employee's regular rate ofcompensation for each work day that the 11 rest period was notsoprovided. 7 8 9 12 13 37. Pursuant to Labor Code §218.6 and CC §3287, Plaintiff seeks recovery ofpre judgment interest on all amounts recovered herein 14 FTFTH CAUSE OF ACTION 15 FAlMfRF, TO TIMELY FURNISH ACCURATE ITEMIZED WAGE STATEMENTS - 16 LABOR CODE §§226 AGAINST ALT DEFENDANTS) 17 18 19 38. Plaintiff incorporate by reference and reallege each and every one ofthe allegations contained in the preceding and foregoing paragraphs ofthis Complaint as if fully set forth herein. 39. Labor Code §226(a) states in pertinent part: "Every employer shall, semimonthly or 20 at the time of each payment ofwages, furnish each ofhis or her employees, either as adetachable 21 part ofthe check, draft, or voucher paying the employee's wages, or separately when wages are paid 23 by personal check or cash, an accurate itemized statement in writing showing (1) gross wages earned, (2) total hours worked by the employee...(4) all deductions...(5) net wages earned, (6) the 24 inclusive dates ofthe period for which the employee is paid...(8) the name and address ofthe legal 25 entity that is the employer, and (9) all applicable hourly rates in effect during each the pay period 26 and the corresponding number ofhours worked at each hourly rate by the employee...". 22 f.) As amatter ofDefendants' established company policy, Defendants failed to h'* 27 28 40. Further, the IWC Wage Orders states in pertinent part: "(A) Every employer shall keep accurate information with respect to each employee including the following: (3) Time records 8 COMPLAINT 1 showing when the employee begins and ends each work period and total daily hours worked 6 shall also be recorded...(5) Total hours worked in the payroll period and applicable rates ofpay...." 41. Therefore, pursuant to Labor Code §226(a) and the applicable IWC Wage Orders, California employers are required to maintain accurate records pertaining to the total hours worked for Defendants by Plaintiffs, including but not limited to, beginning and ending ofeach work period, meal period and split shift interval, the total daily hours worked, total wages paid, and the total 7 hours worked per pay period and applicable rates ofpay, 2 3 4 5 42. 8 9 10 11 12 Defendants did not and still do not furnish Plaintiffwith an accurate itemized statement in writing showing (1) gross wages earned, (2) total hours worked by the employee, (3) all deductions, (4) net wages earned and/or (5) all applicable hourly rates in effect during each respective pay period and the corresponding number ofhours worked at each hourly rate by each respective individual. 43. 13 14 In violation ofLabor Code §226(a) and the applicable IWC Wage Orders, In violation ofLabor Code §226(a) and the applicable IWC Wage Orders, Defendants did not and do not maintain accurate records pertaining to the total hours worked for 16 Defendants by Plaintiffs, including but not limited to, beginning and ending ofeach work period, meal period and split shift interval, the total daily hours worked, and the total hours worked per pay 17 period and applicable rates of pay. 15 44. 18 19 20 21 Plaintiffhas suffered injury as aresult ofDefendants' failure to maintain accurate records and have suffered injury as aresult ofDefendants' failure to maintain accurate records in that Plaintiffs were not timely provided written accurate itemized statements showing all requisite information, including but not limited to total hours worked by the employee, gross wages earned, 24 net wages earned, all deductions, and all applicable hourly rates in effect during the pay period and the corresponding number ofhours worked at each hourly at each hourly rate, in violation ofLabor Code §226 and the applicable TWC Wage Orders, such that Plaintiffwas misled by Defendants as 25 to the correct information regarding various items, including but not limited to total hours worked 26 by the employee, gross wages earned, net wages earned, all deductions, and all applicable hourly 27 rates in effect during the pay period and the corresponding number ofhours worked at each hourly 28 rate. 22 23 cil COMPLAINT 45. 1 Pursuant to Labor Code §226(e), Plaintiffis entitled to fifty dollars ($50.00) per 2 employer for the initial pay period in which aviolation hereunder occurs and one hundred dollars 3 ($100.00) per employer for each violation in asubsequent pay period, not exceeding an aggregate 4 penalty offour thousand dollars ($4,000.00). 46. 5 6 Pursuant to Labor Code §226(e) and/or §226(g), Plaintiffis entitled to an award of costs and reasonable attorneys' fees. S1YTH CAUSE OF ACTION 7 VIOLATIONS OF LABOR CODE 8 203 8 (AGAINST ALL DEFENDANTS) 9 10 11 12 13 14 15 47. Plaintiffincorporates by reference and realleges each and every one ofthe allegations contained in the preceding and foregoing paragraphs ofthis Complaint as if fully set forth herein. 48. Labor Code §203 provides that ifan employer willfully fails to pay, without abatement or reduction, in accordance with Labor Code §§ 201 and 202 any wages ofan employee who is discharged or who quits, the wages ofthe employee shall continue at the same rate, for up to thirty (30) days from the due date thereof, until paid or until action therefore is commenced. 16 49. Plaintiff is no longer employed byDefendants. 17 50. Defendants willfully failed to pay Plaintiffthe entire wages due and owing at the 18 time ofher termination or within seventy-two (72) hours ofher resignation, and failed to pay those 19 sums for thirty (30) days thereafter. Plaintiff was not paid overtime and minimum wages owed as 20 described above and also was not paid her vacation pay upon termination. 21 22 23 24 51. Defendants' willful failure to pay wages to Plaintiff violate Labor Code §203 because Defendants knew or should have known wages were due to Plaintiffbut failed to pay them. 52. Plaintiff is entitled to recovery pursuant to Labor Code §203, in the amount ofhis daily wage multiplied by thirty (30) days. '.-' <•:> 25 26 53. Pursuant to CC §3287, Plaintiff seeks recovery ofprejudgment interest on all amounts recovered herein. 27 SEVENTH CAUSE OF ACTION 28 UNFAIR BUSINESS PRACTICES 10 COMPLAINT (AGAINST ALL DEFENDANTS) 1 4 54. Plaintiffincorporates by reference and reallege each and every one ofthe allegations contained in the preceding and foregoing paragraphs ofthis Complaint as if fully set forth herein. 55. B&PC §17200 provides in pertinent part "...[U]nfair competition shall mean and 5 include any unlawful, unfair or fraudulent business act...." 2 3 56. 6 7 penalties provided for unfair competition "are cumulative to each other and to the remedies or 8 penalties available under all other laws of this state." 57. 9 B&PC §17204 provides that an action for any relief from unfair competition may be 10 prosecuted by any person who has suffered injury in fact and has lost money or property as aresult 11 of such unfair competition. 58. 12 Defendants have engaged in unlawful, unfair and fraudulent business acts or 14 practices prohibited by B&PC §17200, including those set for the in the preceding and foregoing paragraphs ofthe complaint, thereby depriving Plaintiffminimum working standards and conditions 15 due to them under the Labor Code and/or the TWC Wage Orders, as specifically described herein. 13 59. 16 Defendants have engaged in unfair business practices in California by practicing, ploying and utilizing the employment practices outlined in the preceding paragraphs, specifically, 17 emr 18 by requiring employees to perform the labor services complained ofherein without the requisite 19 compensation. 20 21 22 23 f .> B&PC §17205 provides that unless otherwise expressly provided, the remedies or 24 60. Defendants' use ofsuch practices constitutes an unfair business practice, unfair competition and provides and unfair advantage over Defendants' competitors. 61. Plaintiffhas suffered injury in fact and have lost money or property as aresult of such unfair competition. 62. Plaintiff seeks full restitution from Defendants, as necessary and according to proof, 25 restore any and all monies withheld, acquired and/or converted by Defendants by means ofthe 26 unfairpractices complained of herein. 27 28 63. Further, ifDefendants are not enjoined set forth, above, Defendants will continue to practice, employ and utilize the employment practices outlined in the preceding paragraphs. 11 COMPLAINT 64. 1 2 Therefore, Plaintiff requests that the Court issue apreliminary and permanent injunction prohibiting Defendants from engaging in the foregoing conduct. PRAYER FOR RELffiF 3 4 WHEREFORE, Plaintiff respectfully prays that this Court award relief, on all causes of 5 actions, as follows: 6 1. For all wages earned and owed; 7 2. Statutory penalties, according to proof; 8 3. Prejudgment and postjudgment interest at the maximum rate allowed by law; 9 4. Preliminary and permanent injunctions prohibiting Defendants from further violating 10 the California Labor Code and requiring the establishment ofappropriate and 11 effective means to prevent future violations; 12 5. Preliminary and permanent injunctions pursuant to Business &Professions Code 13 §17203, enjoining and restraining Defendants from continuing the unlawful and 14 unfair business practices set forth above and requiring the establishment of 15 appropriate and effective means to prevent future violations; 6. 16 Restitution ofwages and benefits due which were acquired by means ofany unfair business practice, according to proof; 17 18 7. For attorneys' fees in prosecuting this action; 19 8. For costs of suit incurred herein; and 20 9. For such other and further relief as the Court deemsjust and proper. DEMAND FOR JURY TRIAL 21 Plaintiff hereby demands trial ofher claims by jury to the extent authorized by law. 22 23 by law. 24 DATED: March 17,2015 KOKOZIAN LAW FIRM, APC 25 26 27 Bmeo Itokozian,-EsqT~ tomdys for Plaintiff 28 12 COMPLAINT CM-010 ATTORNEY ORPARTY WrTHOUT ATTORNEY (Name, StateBarnumber, andaddress): FOR COURT USE ONLY "Bruce Kokozian, Esq. (SBN 195723) KOKOZIAN LAW FIRM, APC 9440 South Santa Monica Blvd., Suite 510 Beverly Hills, CA 90210 TELEPHONENO.: (323) 857-5900 attorney for(Kame). FAXNO.: FILED Superior Court of California County ofLos Angeles (310) 275-6301 Plaintiff Anita Mavnard MAR 172016 SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS Angeles streetaddsess:111 North Hill Street mailingaddress: 111 North Hill Street crrrandzip code: Los Angeles,