9 Reception@delshadleg. II From: Jonathan delshad Law O?ices ofjorm t?an J. wels?ad.? 11663 SMILE 135011: Suite 220 Loxj?t'ng?s, 90025 13.131 DVD :ang Fax: (424) 256-7899 Pho??ar JONATHAN J. DELSHAD, Bar No. 246176 1663 Sawtelle Blvd, Suite 220 Los Angeles, CA 90025 Telephone: 424.255.8376 Fax: 424.256.7899 E-mail: jdelshad@delshadlegal.com Attorney for Plaintiffs ALEXANDER POLONSKY, BRIAN ZAGHI each individually, and on behalf of all others similarly situated, Plaintiffs, vs. WELLS FARGO BANK COMPANY, 21 Delaware Corporation; WELLS FARGO BANK, NATIONAL and DOES 1 through 50, inclusive, Defendants. others similarly situated, allege: To: Stanley Moslr Civil EiIirTsTaif'd2?1'3?i1253244 LAW OFFICES OF JONATHAN J. DELSHAD, I Page 9 of 3609122112016 1:37 PM 915231 Fl CW2 LosAngeles Superior Court LED PC- 3 2915. rter. Exeeuu I3 9 .!??tlQ!Srk QEBHW Sherri R. By H?m Dawn 51611611115 SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES, UNLIMITED JURISDICTION CiiseNoch"6 5' CLASS ACTION COMPLAINT FOR: 1. WRONGFUL . IN VIOLATION OF CALIFORNIA LABOR CODE 1102.5; RONGFUL TERMINATION IN VIOLATION OF PUBLIC VIOLATION OF BUSINESS PROFESSIONAL CODE ??17200 and 17203 UNLAWFUL BUSINESS PRACTICES 4. FAILURE TO PAY WAGES. JURY TRIAL DEMANDED 3 (3311131338 oaser?fs 11:1 65:21) srr?m?sui,? :araa 31w: 2213039 {smog 1: 113132333 if? 5-. armor: 0.6300 GOOD -1- #3310." WEEDS Ham." .1. I v. Wells Fargo - Complaint For Damages I: If 01:36:56 I 10 I Reception@delshadled. From: Jonathan delshad Law O?ces ofjona Man J. 11663 Smute?i: (Bf:sz Suite 220 La: ?ngcl'es, 9002.? can (.151 EN MI hail re;- 'mll. 11?; .I Fax: (424) 256-7899 Page 100f 36 09f22f2016 1:37 PM To: Stanley Mosk Civil Filing Fax: +12136253244 PARTIES 1. ALEXANDER POLONSKY (hereinafter referred to as ?Named Plaintiff was at all relevant times herein employed by WELLS FARGO BANK COMPANY and WELLS FARGO BANK, NATIONAL ASSOCIATION (hereinafter collectively referred to as 2. BRIAN ZAGHI (hereinafter referred to as ?Named Plaintiff together with Named Plaintiff 1, the ?Named Plaintiffs?) was at all relevant times herein employed by Wells Fargo. INTRODUCTION TO THE CLAIMS fraudulent?scheme and scam to?increase .Wellerargostock-~ . . - price by aggressively pushing their employees to open accounts to increase their cross?sell numbers and not putting any barriers or checks in place to see if the accounts were fraudulently and illegally opened or not. The scheme was orchestrated by the CEO John Stumpf who wanted to have Wells Fargo customers have an average of 8 accounts per person regardless of whether the customers needed those accounts This fraudulent scam was ef?ciently and identically perpetrated among all branches, and pushed to all bankers of Wells Fargo nationwide. 4. I In his time as chairman and CEO of Wells Fargo, John Stumpf has been famous for cross-selling, which is pushing existing customers to open more accounts. Cross-selling is one of the main reasons that Wells Fargo has become the most valuable bank the world. Wells Fargo measures cross-selling by the number of different accounts a customers has with Wells Fargo. In 12 conference calls, CEO of Wells Fargo, John Stumpf personally cited Wells Fargo?s success at cross-selling retail accounts as one of the main reasons to buy more stock in the company. Wells Fargo was aware that many of the accounts that were being open were either illegally opened, unwanted, carried a zero balance, or were simply a result of unethical business practices described below. Wells Fargo knew that their unreasonable quotas were driving these unethical behaviors that were used to fraudulently increase their stock price and benefit the CEO at the expense of the low level employees. -2- Polonsky v. Wells Fargo - Complaint For Damages i i 11] Reception?delshadleg. Fax: (424) 256-7899 From: Jonathan delshad Las?ngd'es, 90025 Law O?ices ofjonat?an J. 0:135:11 (PC 11663 5mute?'z suite 220 3 E: {3 .n m? I'Maf? Ma'- Ct" ooxim oixo To: Stnley Mosk Civil Filing Fax: +12136253244 I Page Hot 36 091222016 1:37 PM 3 5. Whereas the average bank had 3 products per customer, Wells Fargo had 6, and was not happy there. They pushed for a goal of 8 per customer. To reach this goal, Wells Fargo placed knowingly unrealistic and impossible cross sell quotas on their bankers. 6. Wells Fargo?s fraudulent scam which was set at the top and directed toward the bottom was to squeeze employees to the breaking point so they would cheat customers so that the CEO could drive up the value of Wells Fargo stock and put hundreds of millions of dollars in his own pocket. Wells Fargo could then place the blame on thousands of $12 an hour employees who were just trying to meet cross-sell quotas that made the CEO rich. 7. Those that bought Wells Fargo stock based on the scam have not lost much as the stock ?sioa'r'edi'dife'fih? ?rst 5 {1315i ii?li'a??dii?is torture" opened fraudulently will undoubtedly be compensated for any fees they were forced to pay and can easily close their accounts and move on with their lives without much concern. 8. The biggest victims of this scheme are a class of people that nobody else has talked about. The biggest victims of Wells Fargo?s scam is the class of victims that were ?red because they did not meet these cross sell quotas by engaging in the fraudulent scam that would line the pockets. The good employees with a conscious who tried to meet the sales quotas without engaging in fraudulent scams are the biggest victims of this scam. They are the employees that this lawsuit seeks to redress. 9. In order to be able to perpetrate their fraudulent scam, Wells Fargo ?red employees who did not meet their impossible quotas. Without ?ring or demoting employees who failed to perpetuate the scam, Wells Fargo could not suf?ciently ?motivate? or encourage those employees who met impossible quotas by taking fraudulent and illegal actions to increase ?cross sells? so that Wells Fargo?s stock price would double. 10. Defendant Wells Fargo Company is, and at all times relevant hereto was, a corporation organized and existing under the laws of the State of Delaware, with its principal place of business in San Francisco, California. Wells Fargo Company is a ?nancial services company with $1.5 trillion in assets, and provides banking, insurance, investments, mortgage, and consumer and commercial finance through more than 9,000 locations, 12,000 ATMs, and - 3 - Polonsl:y v. Wells Fargo - Complaint For Damages 12 Reception?deishadleg. It From: Jonathan delshad 11663 03de Suite 220 Las?nge?es. 90025 Law O??ices ofjona t?an j. @a?s?acf can on Mr Ml .CESI lam-??Fax: (424) 256-7899 To: Stanley Mosk Civil Filing Fax: +12136253244 Page 120f 36 09220016 1:37 PM the Internet. It has approximately 265,000 full-time employees, and is ranked 29th on Fortune Magazine?s 2014 rankings of America?s 500 largest corporations. ll. Defendant Wells Fargo Bank, National Association is, and at all times relevant hereto was, a national banking association chartered under the laws of the United States, with its primary place of business in Sioux Falls, South Dakota. Wells Fargo Bank, National Association provides Wells Fargo Company?s personal and commercial banking services, and is Wells Fargo Company?s principal subsidiary. 12. Named Plaintiffs will ask leave of Court to amend this complaint to reflect the defendants true names and capacities when the same have been ascertained if not correctly named as of yet. Named Plaintiffs are informed and believe, and thereon allegeiithait. each of said defendants are responsible, jointly and severally, for the events and injuries described herein and caused damages thereby to plaintiff as alleged herein. 13. It further is alleged that defendants, each and together, at all times relevant hereto, constituted an ?iritegrated enterprise? with interrelated operations, common management, centralized control of labor relations, and common ownership and/or ?nancial control. 14. On information and belief, it further is alleged that the defendants were at all times relevant hereto, the alter egos of each other such that to af?rm the legal separateness of the defendants for purposes of the claims presented in this action would lead to an injustice and/or inequitable result. There is a unity of interest and ownership between the company and its equitable owner(s) that the separate personalities of the company and its shareholders do not in reality exist. Defendants exhibit an interrelation of Operations, commingling of funds, lack of observation of corporate formalities, undercapitalization, centralized control, common management, and common financial control such that they are an integrated enterprise and/or are alter egos. The company is a mere shell, instrumentality, and conduit through which the individual defendant(s) carried on their business, exercising complete control and dominance of such business to the extent that any individuality or separateness of the defendants does not and did not exist. - 4 - Polonsky v. Wells Fargo - Complaint For Damages 13 Reception@delshadleg. 11 Fax: (424) 256-7899 From: Jonathan delshad Law O?ices afjanat?an J. (12:65:21 (PC 11663 .S'mute?'e State 220 Lar?ngc?s, 90025 Ci! gig! "h ma huh My. 1'53?! [avTo: Stanley Mosk Civil Filing Fax: +12136253244 Page 130f 36 09/222016 1:37 PM 15. Named Plaintiffs are informed and believe and thereon allege that at all times herein mentioned each of the defendants was acting as the partner, agent, servant, and employee of each of the remaining defendants, and in doing the things alleged herein was acting within the course and scope of such agency and with the knowledge of the remaining defendants. 16. Defendant Wells Fargo Company operates the fourth biggest bank in the United States, and the largest bank headquartered in California. It is California?s oldest bank, having begun banking services in 1852. Wells Fargo Bank, National Association is a subsidiary of Wells Fargo Company, and provides most of the banking products and services that are the subject of this action. 17. Wells Fargo boasts about the average number of products held by its customers, currently approximately six bank accounts or ?nancial products per customer. Wells Fargo seeks to increase this to an average of eight bank accounts or ?nancial products per account holder, a company goal Wells Fargo calls the ?Gr-eight? initiative. 18. For years, Wells Fargo has victimized their customers by using pernicious and often illegal sales tactics to maintain high levels of sales of their banking and financial products. The banking business model employed by Wells Fargo is based on selling customers multiple banking products, which Wells Fargo calls ?solutions.? 19. In order to achieve its goal of selling a high number of ?solutions? to each customer, Wells Fargo imposes unrealistic sales quotas on its employees and has fired or demoted employees who do not meet this unrealistic quota. 20. Wells Fargo has adopted policies that have, predictably and naturally, encouraged bankers to engage in fraudulent behavior to meet those unreachable goals or else be ?red or demoted as result of not engaging in fraudulent behavior. 21. As a result, Wells Fargo?s employees who did NOT engaged in unfair, unlawful, and fraudulent conduct to meet quotas were all similarly, systematically and routinely demoted, terminated [and made as example of so that all other employees would learn that they must engage in these fraudulent actions in order to meet the unrealistic sales quotas or else lose their jobs. -5- Polonsky v. Wells Fargo - Complaint For Damages 14[ Receptio?delshacui. I I From: Jonathan delshad Fax: (424)256-7899 To: Stanley Mosk Civil Filing Fax: +12136253244 Page 14of 36 092212016 1:37 PM 1 22. Wells Fargo has known about and encouraged these practices for years. Wells Fargo 2 encouraged bankers to systematically and uniformly open illegal accounts without clients? 3 authorization. Wells Fargo would uniformly and consistently train managers to provide 4 bankers with a pre-signed application and encourage bankers to open as many accounts as 5 possible under such pre-signed application. Wells Fargo ?red or demoted employees who failed to meet unrealistic quotas while at the same time providing promotions to employees who met these quotas by opening fraudulent accounts. Through these illegal and systematic practices, the common scheme of opening fraudulent accounts happened at each and every Wells Fargo branch without exception. :30 23. The extent and commonality of this fraudulent scheme is evident from the 5,000 or so 11 employees that Wells Fargo had to ?re as a result of this fraud coming to light. 12 24. The extent and commonality of Wells Fargo?s illegal actions was unknowns before 13 recent federal hearing in which Wells Fargo?s CEO has since apologized for the failure and has 14 since agreed to end its sales quota system at the end of the year. It also plans to reach out to all L05 ?ngc?s. 90325 15 customers going back to 2009 to verify whether the accounts were authorized. 16 25. Moreover, Wells Fargo continued to impose the same companywide goals of attaining Law O?icas ofjana t?an fDeEs?acf (PC 11663 Smute?i: (3&th sum 220 17 as many accounts as possible at any-expense, thereby fostering the practice of gaming. Wells 18 Fargo thus puts its employees between a rock and a hard place, forcing them to choose between 19 keeping their jobs and opening unauthorized accounts. 20 26. Yet nothing is being done for the thousands of employees who were demoted or ?red 21 for opposing or failing to engage in the illegal practices that Wells Fargo now looks to end. 22 27. Wells Fargo?s resulting market dominance has come at a signi?cant price to employees 23 who are not willing to engage in fraudulent activity, because it has been achieved in large part 24 through an ambitious and strictly enforced sales quota system. Wells Fargo quotas are difficult 25 for many bankers to meet without resorting to the abusive and fraudulent tactics described 26 further below. Therefore, thousands of employees who failed to resort to illegal tactics were 27 either demoted or ?red as result. 28 - 6 - Polonsky v. Wells Fargo - Complaint For Damages 15 Reception@delshadleg. From: Jon atiian delshad Fax: (424)256-7899 To: Stanley Mosk Civil Filing Fax: +12136253244 Page 15M 36 092212016 1:37 PM 28. Moreover, Wells Fargo enforces its sales quotas by constant monitoring. Daily sales for each branch, and each sales employee, are reported and discussed by Wells Fargo?s District Managers four times a day, at11200 am, 1:00 pm, 3:00 pm, and 5:00 pm. Those failing to meet daily sales quotas are approached by management, and often reprimanded and/or told to ?do whatever it takes? to meet their individual sales quotas. Consequently, Wells Fargo?s managers and bankers have for years engaged in practices called ?gaming.? Gaming consists of, among other things, opening and manipulating fee-generating customer accounts through often unfair, fraudulent, and unlawful means, such as omitting signatures and adding unwanted secondary accounts to primary accounts without permission. Other practices utilized as part ?of these ?gaming? schemes have included misrepresenting the costs, bene?ts, fees, and/or attendant services that come with an account or product, all in order to meet sales quotas. 29. These gaming practices are so pervasive in Wells Fargo?s business model that some methods of gaming have even been given their own names, For example: a. "Sandbagging" refers to Wells Fargo?s practice of failing to open accounts when requested by customers, and instead accumulating a number of account applications to be opened at a later date. Specifically, Wells Fargo employees collect manual applications for various products, stockpile them in an unsecured fashion, and belatedly open up the accounts (often with additional, unauthorized accounts) in the next sales reporting period, frequently before or after banking hours, or on bank holidays such as New Year?s Day. b. ?Pinning? refers to Wells Fargo?s practice of assigning, without customer authorization, Personal Identification Numbers to customer ATM card numbers with the intention of, among other things, impersonating customers on Wells Fargo computers, and enrolling those customers in online banking and online bill paying without their consent. 0. "Bundling" refers to Wells Fargo?s practice of incorrectly informing customers that certain products, are available only in packages with other products such as additional accounts, insurance, annuities, and retirement plans. -7- Polonsky v. Wells Fargo - Complaint Fer Damages 16 ?eception@delshadleg. Fax: (424) 256-7899 From: Jonathan delshad . Los?nge?s. 90027 Law Q?ices ofjonat?an J. me?t?ad: (PC 11663 sawed?: (Bind June 220 C5: (.1531 f?u? hm.? M3 53' r-vTo: Stanley Musk Civil Filing Fax: +12136253244 Page 160f 360912212016 1:37 PM (See ?Banker Assessment Presentation? intemal memo highlighting Wells Fargo?s policy mandating employees to open accounts regardless of customers objections, attached hereto as Exhibit 1). 30. Wells Fargo has rewarded employees for these ?gaming? practices. Wells Fargo has encouraged gaming by promoting those who ?gamed? customers the most to positions of authority and thereby and perpetuating the problem. Worst of all, employees who did not ?game? were surely demoted and or fired. Once it became public knowledge that Wells Fargo was encouraging illegal behavior by terminating or demoting employees for not meeting ..the quota, .WellsFargoceased to use the quota. However those employees who lost their job as a result of not engaging in illegal activity to meet quotas were never compensated. 31. Defendants hired Named Plaintiffs as bankers to meet certain ?solutions? quotas each day. Each of the Named Plaintiffs was demoted and/or terminated as a result of not meeting such quotas because Named Plaintiffs opposed and would not engage the illegal ?gaming? practiced described above to meet such quotas like other employees employed with Wells Fargo. 32. The class of Plaintiffs covered by this case (?Plaintiff Class?) is defined as all employees who worked for Wells Fargo at any time in the?ten years in California preceding the ?ling date of this complaint or who continue to work for Wells Fargo and was either demoted, forced to resign, or terminated for the performance based reason of not meeting their ?solutions? quota. The Plaintiff Class and Named Plaintiffs are hereinafter collectively referred to as (?Plaintiffs?). 33. Named Plaintiffs bring this action on their own behalf, on behalf of the general public, and on behalf of all ?aggrieved persons? and all other persons similarly situated within the Plaintiff Class of employees who were demoted, retaliated against and/or terminated in violation of the California Labor Code by Defendant within the State of California at any time between the date 10 years prior to the ?ling of this complaint. and the date of entry of judgment after trial as further set forth below. -3- v. Wells Fargo - Complaint For Damages 17 I Reception@delshadleg. I From: Jonathan delshad Fax: (424) 256-7899 Law O??ices ofjona t?rm j. (DelkEaJ. (PC 11663 Smutc? Suite 220 i I. m" {-41 ?31 [mg-h ram [.05 90025 MAD-IN OOQON To: Stanley Mosk Civil Filing Fax: +12136253244 Page 17ch 36 09/222016 1:37 PM 34. Plaintiffs do not know the true names or capacities of defendants sued herein as Does 1 through 50, inclusive and Named Plaintiffs su'e these defendants by such ?ctitious names. Named Plaintiffs will seek to amend this Complaint and include these Doe Defendants? true names and capacities as soon as they can be reasonably ascertained. Doe Defendants may include other individuals holding an ownership interest in the Defendants? business. Doe Defendants may include other joint employer entities. 35. Named Plaintiffs both worked for Wells Fargo at various times during the relevant time period. They were given account forms with nothing more than a signature ?lled out and were told that they had to meet a quota of opening TEN accounts a day. Named Plaintiffs both ?lled Ac??ii'?t' rail-a; with. any the proper iamountwof a'eagaa'aadaagtea aria than ?bundling? or engaging in any of the other illegal ?gaming? practices mentioned herein. As a result of Named Plaintiffs? reluctance to meet the quotas by ?gaming,? the Named Plaintiffs were connseled, demoted and later terminated. Named Plaintiffs suffered both economic and non-economic damages including loss of income, back and front pay, and emotional distress. JURISDICTION AND VENUE This class action is brought pursuant to ?382 of the California Code of Civil Procedure. Plaintiff is informed and believes and based on such information and belief alleges that venue is proper in the Los Angeles County Superior Court because Plaintiffs performed work for Defendants in said County and because Wells Fargo regularly does business in Los Angeles County and own and operate numerous facilities - and employ numerous putative class members - in Los Angeles County. The Defendants' liability to the Plaintiffs arose in party within Los Angeles County and some of the wrongful acts complained of occurred in Los Angeles County. - 9 PolonSky v. Wells Fargo - Complaint For Damages 1s Reception@delshadleg. i ll Fax: (424) 256-7899 From: Jonathan delshad Law O?ices ofjanat?an j. (Delft?adi 11663 save-Ea 035m?. State 220 Los?ngefes. 90025 To: Stanley Mosk Civil Filing Fax: +12136253244 Page 36 0912212016 1:37 PM CLASS ACTION ALLEGATION 36. Named Plaintiffs bring this action on their own behalf and on behalf of the class set Paragraph 32 forth above. 37. Numerosity/Impracticability of Joinder: The members of the Class are so numerous that joinder of all members would be impractical. The members of the class are so numerous that joinder of all members would be unfeasible and impractical. Named Plaintiffs are informed and believes, and on that basis alleges that there are well over 50 persons within the Plaintiff Class. The identity of individuals qualifying for class membership is readily ascertainable via inspection of the personnel records and other documents maintained by -- Defendants. 38. Commonality and Predominance: There are common questions of law and fact that predominate over any questions affecting only individual members of the class so that a class action is superior to other forms of action. The claims of the Named Plaintiffs are typical of those of every other member of the Plaintiff Class. All the class members were treated in a similar fashion and suffered similar harm as a consequence of Defendants' conduct, as alleged, and Defendants? demotion and/or termination of Named Plaintiffs? employment for failing to meet the strictly enforced sales quotas that were so unrealistic that Defendant coached employees to deploy fraudulent sales practices, and retaliation towards those employees who did not engage in fraudulent practices to want other employees not to avoid using systematic fraudulent practices to avoid demotions or termination of employment, are and were uniform between class members. 39. For Plaintiffs and the Class, the common legal and factual questions include, but are not limited to the following: A. Whether Wells Fargo knew or should have known that its sales-quota of 10 accounts per day and goal of 8 accounts per customer would require employees to engage in unlawful, deceptive, fraudulent or unethical practices in order to boost their stock price; . - 10 - Polonsl:y v. Wells Fargo - Complaint For Damages 0 19] Reception?delshadle5. II From: Jonathan delshad 11653 Sawte?i: (35? Swim 220 La: ?ngefes. 90025 Law O??iczs ofjonat?an 028500? 7 :7 i .: l?l 15'? 914Fax: (424) 256-7899 To: Stanley Mask Civil Filing Fax: +12136253244 Page 190f 36 09.920016 1:37 PM B. Whether Wells Fargo knew or should have known that ?ring employees who failed to meet unrealistic quotas would result in the remaining additional unlawful ?gaming? practices; C. Whether, as a result of Wells Fargo?s conduct,'Plaintiffs and the Class have suffered damages; and if so, the appropriate amount thereof; and D. Whether as a result of Wells Fargo?s misconduct, Plaintiffs and the Class are entitled to equitable and declaratory relief, and, if so, the nature of such relief. ?Typica'lityr?lhe representative Plaintiffs? claims are typical of the claims= of the members of the Class. Plaintiffs and all the members of the class have been injured by ?the same wrongful practices of Wells Fargo. Plaintiffs? claims arise from the same practices and course of conduct that give rise to the claims of the members of the class and are based on the same legal theories. Named Plaintiffs will fairly and adequately represent the interests of the Plaintiff Class because Named Plaintiffs are a member of the class and Named Plaintiffs do not have an interest that is contrary to or in con?ict with those of the Plaintiff Class. There is a well?de?ned community of interest in the questions of law and fact affecting the class of persons that Named Plaintiff represents as a whole. Each member of the Plaintiff Class was subjected to illegal practices of Defendants under the California Labor Code, including but not limited to retaliation for not engaging in the illegal practices instituted by Defendants. Each member of the Plaintiff Class was terminated in violation of the California Labor Code and in violation of public policy. 41. Superiority: A class action is superior to any other form of action for the fair and efficient adjudication of this lawsuit. Individual employees such as Plaintiffs have a dif?cult time prosecuting an individual action against large corporate employers such as Defendants. Even if any class member could afford individual litigation against Defendants, it would be unduly burdensome to the court system. Individual litigation of such numerous claims magni?es the delay and expense to all parties and the court system. By contrast, a class action 11 v. Wells Fargo - Complaint For Damages 20 Reception@delshadleg. From: Jonathan delshad Law O?icas afjona Him: 3. mels?adi 11665 5mm (and. state 220 L05 ?ngc?s. 90025 can jam-i: cm ea haw-'5 -- Fax: (424) 256-7899 kin-bub) 0:To: Stanley Mcisk Civil Filing Fax: +12136253244 Page 200f 36 091222016 1:37 PM presents far fewer management dif?culties and affords the bene?ts of unitary adjudication, economies of scale, and comprehensive supervision by a single court. Concentrating this litigation in one forum will promote judicial economy and parity among the claims of individual class members and judicial consistency in rulings. Notice of the pendency and any resolution of this action can be ef?ciently provided to class members by mail, print, broadcast, internet, and/or multimedia publication. Requiring each class member to both establish individual liability and pursue and individual remedy would discourage the assertion of lawful claims by employees who would be disinclined to pursue an action against their present and/or former employer for fear of retaliation and permanent damage to their careers at present and/or . of a common buvs'irieissipractice or factual-pattern, of the I Named Plaintiff experienced, is representative of the alleged class and will establish the right of each of the members of the alleged class to recovery on the claims alleged herein. 42. The prosecution of separate actions by individual class members, even if possible, would create: a substantial risk of inconvenient or varying verdicts or adjudications with respect to the individual class members against the Defendants herein; and/or legal determinations with reSpect to individual class members which would, as a practical matter, be dispositive of the other class members not parties to the adjudications or which would substantially impair or impede the ability of class members to protect their interests. Further, the claims of the individual members of the class are not sufficiently large to warrant vigorous individual prosecution considering all of the concomitant costs and expenses attending thereto. Plaintiff is unaware of any difficulties that are likely to be encountered in the management of this action that would preclude its maintenance as a class action. 43. Adequacy: Plaintiffs are representatives who will fully and adequately assert and protect the interests of the Class, and have retained class counsel who are experienced and quali?ed in prosecuting class actions. Neither Plaintiffs nor their attorneys have any interests contrary to or in conflict with the Class. 44. Plaintiffs do not anticipate any difficulty in the management of this litigation. -12- Polonsl:y v. Wells Fargo - Complaint For Damages [21] Reception@delshadleg. From: Jonathan delshad L05 ?nga?'s. 9002i Law O?ices afJanat?an j. mefs?ad 1.1663 5.611078% (35d: Suite 220 RD bu}! M. m- I631 I133 '15 1 Fax: (424) 256-7899 LII ?To: Stanley Mosk Civil Filing Fax: +12136253244 Page 21 of 36 091222016 1:37 PM 45. Wells Fargo has, or has access to, address and/or other contact information for the members of the class, which may be used for the purpose of providing notice of the pendency of this action. 46. Named Plaintiff requests permission to amend the complaint to include other individuals as class representatives in the event that Named Plaintiff is deemed not to be an adequate representative of the Plaintiff Class. Named Plaintiff further requests permission to amend the complaint to revise the Plaintiff Class de?nition as appropriate after discovery. 47. Wells Fargo knew, or in the exercise of reasonable care should have known, that its employees open unauthorized accounts. For example: Customers often enter Wells Fargo?s branches to complain aboutrunauthorized accounts; many victims have even contacted Wells Fargo management by telephone. b. Wells Fargo has access to, and frequently monitors, actions taken on its computers by employees. Wells Fargo has been put on notice by unusual activity such as: numerous accounts being opened on January 1, a bank holiday; numerous unfunded accounts; frequent reOpening of closed accounts; and customer accounts with the only account activity being Wells Fargo fees; c. Wells Fargo requires that all new customer accounts be approved by a branch manager or assistant manager, thereby providing Wells Fargo management with aiclear record of the number and types of accounts opened for each customer. d. Wells Fargo is also aware its daily, weekly and quotas are unrealistic for employees during normal working hours, since they have generated numerous complaints and lawsuits by employees. e. Online banking accounts are often opened by Wells Fargo with obviously false customer contact information such as noname@wellsfargo.com. -13- Polonsl:y v. Wells Fargo - Complaint For Damages I Reception@delshadle. II From: Jonathan delshd Law O?ices ofjana tlian j. (Dels?acf. 11663 Smute?k 5mm 220 L05 ?ngd?s. 90025 OO-JON Fax: (424) 256-7899 To: Stanley Mask Civil Filing Fax: +12136253244 Page 220f 36 0912212016 1:37 PM GENERAL ALLEGATIONS 48. Plaintiffs, who were assigned the task of signing up Defendants? clients with accounts, were pressured by Defendants to meet aggressive sales quotas daily and Defendants strictly enforced and closely monitored sales quota system that made it difficult for Plaintiffs to keep their jobs without resorting to fraud. Plaintiffs were thus encouraged and directed by Defendants? managing employees to use various illegal schemes to open accounts fraudulently. Most commonly fraudulent practice consisted coaching employees to open unauthorized fee generating accounts and/or secondary accounts for existing customers and often transferred . fundstotheseaccounts from the owners? other accounts, without clients?. knowledge or consent. Plaintiffs who did not follow through with these fraudulent practices were retaliated against by poor performance reviews, demotions and subsequent terminations under the pretext of not meeting the sales quotas. Although this policy was known to top executives of Defendants, Plaintiffs, as bankers, were blamed for harm to clients and retaliated against by Defendants. 49. During the last 10 years, Defendants have demoted and/or terminated Plaintiffs for failing to meet the sales quotas and engaging commonly practiced fraudulent schemes that were initiated by the Defendants? management. This practice results in signi?cant monetary damages to Plaintiffs. 50. Wells Fargo further stated in its 2014 Annual Report to the U.S. Securities Exchange Commission: ?we continued to maintain our solid customer relationships across the Company, with retail banking household cross-sell of 6.17 products per household (November 2014); Wholesale Banking cross-sell of 7.2 products per relationship (September 2014); and Wealth, Brokerage and Retirement cross-sell of 10.49 products per retail banking household (November 2014).? Wells Fargo further stated in that same filing: ?We believe there is more opportunity for cross-sell as we continue to earn more business from our customers. Our goal is eight products per household . . . - 14 Polonsl:y v. Wells Fargo - Complaint For Damages I 23] Reception@delshadleg. I I From: Jonathan delshad Fax: (424) 256-7899 To: Stanley Mosk Civil Filing Fax: +12136253244 Page 230f 36 09f22fZD16 1:37 PM 51. In order to achieve its goal of eight accounts 'per household, Wells Fargo puts 2 unrelenting pressure on its bankers to open numerous accounts per customer. 3 52. Wells Fargo has strict quotas regulating the number of daily ?solutions? that its bankers 4 must reach; these ?solutions? include the opening of all new banking and credit card accounts. 5 Managers constantly hound, berate, demean and threaten employees to meet these unreachable quotas. Managers often tell employees to do whatever it. takes to reach their quotas. 53. Employees who do not reach their quotas are often required to work hours beyond their typical work schedule without being compensated for that extra work time, and/or are threatened with demotion and/or termination. 54.? Transits 'i'frib?'s??d was f?i'g'b 6h ii?'??iploye'?? a;shariaaggregating?' 11 there simply are not enough customers who enter a branch on a daily basis for employees to 12 meet their quotas through traditional means. 13 55. Wells Fargo?s bankers are thus naturally and predictably forced to resort to alternative 14 means to meet quotas, including using high pressure sales tactics to coerce customers into [.05 ?ags-(es. 90025 15 opening additional accounts or using inaccurate or misleading information about potential 16 accounts to induce customers to open them. [Jaw O?ices quana t?an j. me?c?aaf CFC 11663 sawmme sum.- 220 17 56. Wells Fargo employees also pressure their own family members and friends to sign up 18 for accounts to meet their quotas. Some employees report that they have ?tapped out? every 19 family member and friend for accounts. Others report that they spend holiday dinners trying to 20 convince family members to sign up for accounts. Management encourages employees to 21 achieve ?solutions? through family members. Since these accounts are opened by friends and 22 family as favors, they are often unfunded, and can result in fees charged by Wells Fargo to its 23 own employees? families or acquaintances, even for such ?zero balance? accounts. 24 57. Employees thus resort to gaming tactics to increase their ?solutions,? and meet i 25 minimum quotas. Gaming is so ingrained in the business of Wells Fargo that many of the 26 tactics employed to meet these sky-high quotas have commonly-used names as mentioned 27 above. Employees were, and are, instructed by management to lie to customers by telling them 28 that each checking account automatically comes with a savings account, credit card, or other -15- v. Wells Fargo - Complaint For Damages wgww?gm I 24] Reception@delshadleg. I ll From: Jonathan delshad Law O?ices ofjanat?an J. (Dellsfiai 11663 smell: (abut. sum: 220 901725 ?Fax: (424) 256-7899 To: Stanley Mosk Civil Filing Fax: +12136253244 Page 240f 36 09f22f2016 1:37 PM product such as life insurance, and/or ?Express Send? (an online program that allows customers to send money to foreign countries). 58. When customers discover an unauthorized account and inquire of Wells Fargo about it, they are often informed that the products and services came with the authorized accounts automatically. Even in the face of customer complaints, the ?bundling? continues. Customers who complain about receiving credit cards they did not request are advised by Wells Fargo to simply destroy the unrequested and unauthorized cards. However, simply destroying these unauthorized cards does not close the account or repair the impact to a customer?s credit pro?le. 59. Because of ?Wells Fargo?s Ion-going setting-of unrealistic Fargo employees have engaged in, and continue to engage in, other gaming tactics, including: 3. Making misrepresentations to customers to get them to open additional accounts such as falsely stating: ?you will incur a fee on your checking account until you add a savings account.? b. Misrepresenting that. additional accounts do not have fees, when they actually do incur such fees. 0. Referring unauthorized, and therefore unfunded, accounts to collections because Wells Fargo?s practices cause the accounts to have negative balances. d. Targeting individuals holding Mexican Matriculada Consular cards because the lack of a Social Security Number makes it easier to open numerous fraudulent accounts. Wells Fargo employees provide false information to complaining customers, and advise many of these victims to ignore the unauthorized fees and letters from collection agencies because the lack of a Social Security number means the debt will not affect them. e. Advising customers who do not want credit cards that they will be sent a credit card anyway, and to just tear it up when they receive it. 60. Employees could easily meet their sales quotas if they engaged in these illegal, fraudulent and improper sales tactics. Therefore, to encourage these fraudulent actions, Wells -16- Polonsky v. Wells Fargo - Complaint For Damages 125] Reception?delshadleg. From: Jonathan delshad Law O??ices ofjanat?an j. mefr?ad: 11663 Smute?i: (1350:! State 220 Las?ngeks. (Di 90025 [5.3 lg; he r5321 Fax: (424) 25e7999 To: Stanley Mosk Civil Filing Fax: 442136253244 Page 250f 36 09f22f2016 1:37 PM Fargo implemented its sales quota system. As a result, when employees failed to engage in these behaviors, Wells Fargo illegally retaliated against them under the guise of stating that they did not meet their sales quota. Therefore, all employees who were demoted or ?red because they did not meet this sales quota were effectively demoted or ?red because they refused to participate and or opposed to engage in fraudulent activity to meet those quotas as was expected of them. 61. California has strict laws against making false ?nancial statements. 62. It is unlawful to use another?s personal data for illegal purposes: ?[E]very person who willfully obtains personal identifying information . . . of another person, and uses that information for any unlawful purpose, including to obtain, or attempt to obtain, credit, goods, services, real property, or medical information without the consent of that person, is guilty of a public offense . . (Penal Code Pursuant to the Penal Code: ?personal identifying information? includes name, address, telephone number, health insurance number, taxpayer identi?cation number, school identification number, state or federal driver?s license, or identi?cation number, social security number, place of employment, employee identi?cation number, professional or occupational number, mother?s maiden name, demand deposit account number, savings account number, checking account number, PIN (personal identi?cation. number) or password, alien registration number, government passport number, [and] date of birth.? (Penal Code 63. In California, if a business is in possession of ?computerized data that includes personal information,? that business ?shall disclose any breach of the security of the system following discovery or noti?cation of the breach in the security of the data to any resident of California whose personal information was, or is reasonably believed to have been, acquired by an unauthorized person.? (Civil Code ?[P]ersonal information? includes: individual?s first name or first initial and last name,? along with one or more of the following: Social Security number; driver?s license number or California identi?cation card number; account number, credit or debit card number ?in combination with any required security code, access code, or password that would permit access to an 17 v. Wells Fargo - Complaint For Damages I 26] Reception@delshadleg. I From: Jonathan delshad Lox?ngc?s. 9002; Law O??ices ofjonat?an j. me?c?adf (PC 11663 Sauna-Ea (351d: sum 220 mi Pu.) N1. art's! ku?? gr: I kWhFax: (424) 256-7899 To: Stanley Mosk Civil Filing Fax: +12136253244 Page 260f 36 09f22l2016 1:37 PM individual?s ?nancial account,? medical information; or health insurance information. (Civil Code ?Personal information? also includes: user name or email address, in combination with a password or security question and answer that would permit access to an online account.? (Civil Code For purposes of this law, ?breach of the security system? refers to ?unauthorized acquisition of computerized data that compromises the security, con?dentiality, or integrity of personal information maintained by the person or business.? (Civil Code 64. It is illegal to knowingly access and without permission use ?any data, computer, computer system, or computer network in order to either (A) devise or execute any scheme or arti?ce to defraud, deceive, or extort or (B) wrongfully control or obtain money, property, or data.? (Penal Code 65. Furthermore, it is unlawful to knowingly access and without permission: ?take[], cop or make[] use of any data from a computer, computer system, or computer network . . whether existing or residing internal or external to a computer, computer system, or computer network.? (Penal Code 66. Under the California Penal Code ?the word ?person? includes a corporation as well as a. natural person.? (Penal Code 7) 67. Pursuant to the Gramm-Lcach-Bliley Act, 15 United States Code section 6801, et seq., and the rules and regulations promulgated thereunder, ?nancial institutions have a duty to keep and protect the personal information of their customers from unauthorized access or misuse. When an ?institution determines that misuse of its information has occurred or is reasonably possible, it should notify the affected customer as soon as possible. (70 Fed. Reg. 1575', 12 C.F.R. Part 30, App. B.) 68. It is also illegal to engage in Securities Fraud by boosting stock prices as a result of conduct which one knows to be fraudulent, such as the scam perpetrated by Wells Fargo as stated above. - 13 Polonsky v. Wells Fargo - Complaint For Damages I 27] Reception@delshadleg. From: Jonathan delshad 11663 Saw-1:02 (35M. Suite 220 L05 ?ngeas, ca 90025 [law O??ices afjonat?an J. @afs?aaf (PC (44! ml Ml no r? 27 Fax: (424) 256-7899 OOKJONKJIJBWN DVD 69. To: Stanley Mosk Civil Fiting Fax: +12136253244 Page 27 of 36 09/222016 1:37 PM FIRST CAUSE OF ACTION [Termination, Retaliation and Other Conduct in Violation of California Labor Code 1102.5] Plaintiffs hereby incorporate each and every allegation contained above, and re?allege said allegations as if fully set forth herein. 70. In doing the things herein alleged, and as otherwise will be proven at trial, Defendants, and each of them, violated Labor Code 1102.5, which provides, in part, that: 71. i An employer may not make, adopt, or enforce any rule, regulation, or policy preventing an employee from disclosing information to a government or law enforcement agency, where the employee has reasonable cause to believe that the information discloses a violation of state or federal statute, or a violation or noncompliance with a state or federal rule or regulation. An employer may not retaliate against an employee for disclosing information to a government or law enforcement agency, where the employee has reasonable cause to believe that the information discloses a violation of state or federal statute, or a violation or noncompliance with a state or federal rule or regulation. (0) An employer may not retaliate against an employee for refusing to participate in an activity that would result in a violation of state or federal statute, or a violation or noncompliance with a state or federal rule or regulation. An employer may not retaliate against an employee for having exercised his or her rights under subdivision or in any former employment.? By terminating class members in retaliation for not opening unauthorized accounts to meet sales quotas, Defendants, and each of them, violated Labor Code 1102.5. Class -19- Polonsky v. Wells Fargo Complaint For Damages zsl Reception@delshadleg. II From: Jonathan delshad [.05 ?ngc?s, 90025 Law Q?'ices ofjanat?an j. mefs?aJ, 11663 smm?'a (Mud? Suite 220 {5,1 1:151 Mail me C33 fill?.? OOKJON ONO Fax: (424) 256-7899 To: Stanley Musk Civil Filing Fax: +12136253244 Page 280f 36 09/220016 1:37 PM members were all coached, encouraged and expected to engage in fraudulent acts that violated the laws set forth above to achieve the unrealistic sales quotas that were set forth by Wells Fargo. Wells Fargo effectively retaliated against all employees such as Named Plaintiffs who were given quotas but did not engage in fraudulent acts that violated the laws set forth above as was demanded of them. 72. By refusing to engage in ?gaming? to meet quotas, the Plaintiffs opposed the illegal scam that was being perpetrated by Wells Fargo, from the CEO down. 73. Because it was impossible to consistently meet a quota without engaging in ?gaming?, as Wells Fargo now recognizes, Class Members who opposed or otherwise did not engage in the fraudulent acts that violated the laws set forth above could not meet their quotas ion a consistent basis and were therefore demoted and/or fired for not engaging in opposing behavior that violates the law. 74. As a direct and proximate result of Defendants? conduct, Plaintiffs have suffered damages, including, but not limited to, lost past and future wages and bene?ts and mental anguish and emotional suffering, all in an amount to be proven at trial and in excess of the jurisdictional minimum of this court. 75. In doing the things herein alleged, Defendants were guilty of oppression, fraud and malice in that they, among other things, acted with a willful and conscious disregard for Plaintiffs? rights, insofar as the things alleged were attributable to employees of Defendants, said employees were employed with a conscious disregard for the rights of others and/or Defendants authorized or rati?ed the wrongful conduct and/or there was advance knowledge, conscious disregard, authorization, ratification or act of oppression, fraud or malice on the part of an officer, director or managing agent of Defendants all entitling Plaintiffs to the recovery of exemplary and punitive damages. - 20 v. Wells Fargo - Complaint For Damages 29] Reception@delshadleg. From: Jonathan delshad Law O?ices afjonat?an j. malls/fad QC 11663 Jamm- 93de Suite 220 [as ?nge?s. 9w25' (?Ca Ml Fail ugh! i?nh ij?i Fax: (424) 256-7899 OONJONKJI-D-UJN :To: Stanley Mosk Civil Filing Fax: +12136253244 Page 290f 36 0922/2016 1:37 PM SECOND CAUSE OF ACTION [Wrongful Termination in Violation of Public Policy] 76. Plaintiffs hereby incorporate each and every allegation contained above, and re?allege said allegations as if fully set forth herein.? 77. The public policy of the State of California, as codi?ed, eXpressed and mandated in Labor Code 1102.5 and other applicable law is to prohibit employers from: (1) implementing policies preventing employees from disclosing reasonably based suspicions of violations of state or federal statutes; (2) retaliating against employees who have disclosed reasonably based suspicions of violations of state or federal statutes to government agencies; and (3) retaliating against employees who oppose or refuse to participate in activities that they reasonably believe would result in violations of state or federal statutes. This public policy of the State of California is designed to protect all employees and to promote the welfare and well-being of the community at large. 78. By opposing refusing to engage in ?gaming? to meet their quotas, the Plaintiffs were engaging in protected activity and opposing practices that were violating the law. The Defendants? termination demotion of the Plaintiffs for engaging in protected activity are in direct violation of the public policies which are codi?ed and made illegal by the actions express in paragraphs 62-69 above Securities Fraud, Data Breach, False Financial Statements, etc.). 79. As a direct and proximate result of Defendants? conduct, Plaintiffs have suffered damages, including, but not limited to, lost past and future wages and bene?ts and mental anguish and emotional suffering, all in an amount to be proven at trial and in excess of the jurisdictional minimum of this court. 80. In doing the things herein alleged, Defendants were guilty of oppression, fraud and malice in that they, among other things, acted with a willful and conscious disregard for Plaintiffs? rights, insofar as the things alleged were attributable to employees of Defendants, said employees were employed by Defendants with advance knowledge of the unfitness of the employees and/or they were employed with a conscious disregard for the rights of others -21- v. Wells Fargo - Complaint Fer Damages 01:36:56 p.rn.O9-22-2016 I 30 I Reception@de shadle. II From: Jonathan delshad Law O?fces ofjonat?an 5. fDeEs?aJ. (PC 11663 Smute?'e (vad: June 220 La: ?rrgel?s. 90025 g; mm mm AWN LII Fax: (424) 256-7899 To: Stanley Mask Civil Filing Fax: +12136253244 Page 300f 36 092212016 1:37 PM and/or Defendants authorized or ratified the wrongful conduct and/or there was advance knowledge, conscious disregard, authorization, ratification or act of oppression, fraud or malice on the part of an of?cer, director or managing agent of Defendants all entitling Plaintiffs to the recovery of exemplary and punitive damages. THIRD CAUSE OF ACTION Unlawful Business Practices [Violation of Business Professions Code ??17200 and 17203] 81. Plaintiffs hereby incorporate each and every allegation contained above, and re-allege said allegations as if fully set forth herein. .Atallmaterial times, Plaintiff Class are and were affected with injuries in fact within the meaning of Business Professions Code ?17204. 83. Plaintiffs allege, on information and belief, that during the last ten years and to the present date, Defendants knowingly engaged in unlawful business practices and unlawful labor practices by ?ring demoting each member of the Plaintiff Class as described above in order to achieve their fraudulent scam and goal of forcing employees to meet sales quotas through fraudulent and unethical means. 84. By firing and/or demoting Plaintiff Class members who did not engage in opposed ?gaming? and other illegal acts, Wells Fargo consolidated its power and reinforced its illegal scheme of forcing all other employees to engage in illegal acts to meet sales quotas by any means necessary. 85. The acts of the Defendants, as herein alleged, constitute unlawful, unfair and fraudulent business practices in that they terminated Plaintiffs for retaliatory reasons under the pretextual reasons of not meeting sales quotas. 86. Defendants? violation of law, as alleged herein, constitutes unlawful business practices because such violations were done in a. systematic manner and under the color of a business decision to the detriment of Plaintiff Class. -22- Polonsky v. Wells Fargo - Complaint For Damages [31] Reception?delshadleg. I I From: Jonathan delshad Fax: (424) 256-7899 To: Stanley Mosh Civil Filing Fax: +12136253244 Page 31 of 36 09/22/2016 1:37 PM 87. Defendants? acts and practices, as alleged herein, constitute a continuing and ongoing 2 unfair and/or unlawful business activity de?ned by Business Professions Code ?17200, and 3 justify restitution, and other equitable relief pursuant to Business Professions Code ?17203. 4 88. As a result of Defendants' unlawful, unfair, and fraudulent business practices, and 5 unfair competition within the meaning of the Business and Professions Code ?17200 et seq, 6 Plaintiffs have suffered the loss and enjoyment of their lawful property in the form of wages 7 and other compensation, all to be proved at time of trial. 8 89. As a result of the unfair business practices of Defendants as alleged herein, Plaintiffs 9 are entitled to compensations for damages. oi'?iifm mama and, during?tse'g?aa'essy?srins action, will 11 expenses for attorney's fees and costs herein. Such attorney's fees and costs are necessary for 12 the prosecution of this action and will result in a bene?t to Plaintiffs and other individuals 13 lawfully classi?ed as bona ?de employees in California. Plaintiffs are, therefore, entitled to reasonable attorney's fees under California Code of Civil Procedure ?1021.5. Los ?ngeks. 90025 FOURTH CAUSE OF ACTION 16 [Failure to pay wages, overtime, penalties as set forth in CA Labor Code] On behalf of Named Plaintiff 2 ONLY. Law O?ces ofjona t?an J. fDeLs?aaC 11663 San/teak (BEDJ Sm? 320 18 91. Plaintiffs hereby incorporate each and every allegation contained above, and re-allege 19 said allegations as if fully set forth herein. 20 92. Named Plaintiff 2, was forced to stay past closing and after working 8 hours a day to 21 work overtime in order to satisfy his quota on occasion. Wells Fargo required Named Plaintiff 22 2 to work off the clock to meet his quota or else be ?red. Wells Fargo did not ever pay Named 23 Plaintiff 2 for such work. Named Plaintiff 2 represents the ?Wage and Hour Class Plaintiffs? 24 which is defined as all California employees of Wells Fargo over the past 10 years who were [0 kl! similarly situated to Named Plaintiff 2 and did not receive all wages owed to them whether due ?i?i?sijir [0 Ch to violations of Labor code ??270, 203, 204, 216, 510, 558, 1194, 2704, or 1198 because of the 27 requirement to stay overtime and fulfill sales quotas. -23- - -- ouwg??. - v. Wells Fargo - Complaint For Damages i I 32 Reception@delshadle? I I From: Jonathan delshad Fax: (424) 256-7899 To: Stanley Mosk Civil Filing Fax: +12136253244 Page 320f 36 09I22Q016 1:37 PM 93. Labor Code section 200 broadly defines ?wages? to include ?all amounts for labor 2 performed by employees of every description, whether the amount is fixed or ascertained by the 3 standard of time, task, piece, commission basis, or other method of 4 94. Notwithstanding the duties imposed upon the Defendants by the provisions of this law, 5 by withholding monies owed to Wage and Hour Class Plaintiffs as described above, Wage and Hour Class Plaintiffs have suffered the injuries and damages set forth hereinafter. 95. During the last four years, and at all relevant times in this Complaint, Defendants required Wage and Hour Class Plaintiffs to perform labor for which Wage and Hour Class Plaintiffs were not paid wages. 00 96. The acts described in this complaint were authorized and ratified by the Defendants? 11 of?cers, directors, managerial and supervisory employees when they participated in the above 12 mentioned discriminatory practices and/or ratified the conduct of the Defendants? employees as 13 against Plaintiffs when they failed to take preventative measures or remedial measures after 14 receipt of knowledge of the unlawful practices. L05 ?nge?s, 90025 15 97. The acts described in this complaint were done in a malicious, fraudulent and oppressive 11663 Smut?e?'e (B?Jd-i Suite 220 . 16 manner with full knowledge that these acts were in violation of the law and otherwise in Law O?ices afjona t?an (Dafr?arf 17 conscious disregard of the Wage and Hour Class Plaintiffs? rights entitling plaintiffs to an award punitlve damages pursuant to Code Section 3294, in an amount sufficient to punish and set an example of Defendants for their conduct and to deter them from the commisSIOn Similar acts in the future. The exact amount of punitive damages is currently un-ascertalned but 21 which will be shown according to proof at the time of trial herein. 22 98. As a direct and proximate result of the conduct of the Defendants, the Wage and Hour 23 have suffered and continue to suffer emotional distress, anxiety, humiliation, 24 embarrassment and damage to their reputation and career which will be shown according to 25 proof at the time of trial herein. 26 99. As a direct and proximate result of the conduct of the Defendants, the Wage and Hour :2 Class Plaintiff have suffered loss of earnings and other employment benefits the exact amount - 24 - PolonSky v. Wells Fargo - Complaint For Damages [33 Reteption@delshadli. I I Fax: (424) 256-7899 from: Jonathan delshad 11663 Sawte? $524: Suite 320 Los?nge?s. 9&725' Law Q?ices ofjanat?an J. (Delk?adf (PC MANN \DOOxlm Page 33of 36 09I22I2016 1:37 PM To: Stanley Mask Civil Filing Fax: 442136253244 which is currently not ascertained but which will be shown according to proof at the time of trial herein. 100. As a direct and proximate result of the conduct of the Defendants, the Wage and Hour Class Plaintiffs have incurred attorney?s fees and costs to Wage and Hour Class Plaintiffs? . further damage and detriment in an amount which is currently not ascertained but which will be shown according to proof at the time of trial herein. 101. Wage and Hour Class Plaintiffs are entitled to recover attorney?s fees and costs pursuant to the provisions of California Labor Code section 218.5 which states, ?In any action brought for the nonpayment of wages, fringe benefits, or health and welfare or pension fund contributions, the court shall award reasonable attorney's fees and costs to the prevailing party if any party to the action requests attorney's fees and costs upon the initiation of the action.? WHEREFORE, Plaintiffs pray for relief as set forth below. -25- v. Wells Fargo - Complaint For Damages Reception@delshadle? From: Jonathan delshad IFlax: (424) 256-7899 To: Stanley Mosk Civil Filing Fax: +12136253244 Page 340f 36 090212016 1:37 PM 1 PRAYER FOR JUDGMENT 2 Plaintiff prays for judgment as follows: 3 . 4 1. General, compensatory, and statutory damages in amounts to be proven at trial; 5 2. For punitive damages according to proof at trial; 6 3. For injunctive relief; 7 4. For reasonable attomeys? fees, expert witness fees, and other litigation expenses; 8 5. For all statutory penalties as provided under the applicable sections of the California 9 Labor Code; ..6. ..For otherappropriate relief under Business and Professions Code ??17203 and 17535; 11 7. For costs of suitFor such other relief as the Court deems just and proper; and :3 a 13 9. Total damages of $2,600,000,000 and possibly more, according to proofDated: September 22, 2016 a a 17 Law Offices of Jonathan J. Delshad 18 19 20 21 By: Jonathan J. Delshad, Esq. Attorney for Plaintiffs Wells Fargo - Complaint For Damages Reception@delshadle?. From: Jonathan delshad . .4.-.-.. Law O??iczs ofjana (Han j. melk?ad: 11663 Smutc?'e leUJ. Sum! 220 Los?ngcl'cs. 90025 AWN OOQON \"ru (?Fax: (424) 256-7899 To: Stanley Mosk Civil Filing Fax: +12136253244 Page 350f 36 09/22/2016 1:37 PM EXHIBIT 1 -27- Polonsky v. Wells Fargo - Complaint For Damages I [361 Reception??delshadleg. From: Jonathan delshad Fax: (424) 256-7899 To: Stanley Mask Civil Filing Fax: +12136253244 Page 360f 36 091222016 1:37 PM Wells Fargo Recruiting Banker ?ssessrnenl; tires entatro Purpose ofthe ?Sell Our Products? Activity: As a Personal Banker in our stores, you will be responsible for selling various banking products to customers (both existing customers and new customers). it is important as a Personal Banker not only to know our products but also to be able to voice the bene?ts they provide. in doing so, you will be able to provide the best service to our customers by offering products that best ?ts their financial needs. in addition to this, being able to address and overcome customer objections is important. Presentation Guidelines: The following are instructions on what to do and what to expect for the presentation portion of your interview. The 5-7 minute presentation will be given standing up in front of Wells Fargo managers. Please feel free to enrich the presentation with the use - of-?visual there may be questions from the managers regarding your presentation: - -- I instructions: 1. Go to the website and/or visit any of our local stores to pick up information from the displays and learn about the different products and services Wells Fargo offers. 2. Review and learn about our products and services. 3. Select three banking products Checking, Savings, Online Banking, Bill Pay, Equity loans/lines, etc.) that you will research in further detail to decide how to sell. 4. Prepare a 57 minute (max) presentation on how you would go about selling these three banking products to a new customer. Include in this presentation details on how you would overcome objections from a potential customer who is currently banking with another ?nancial institution and is receiving a product, service or benefit from our competitor that we don?t offer. no MI that: - Banker Assessment Presentation (updated 0212010) 3 Reception@delshadleg. From: Jonathan delshad Fax: (424) 256-7899 To: Stanley Mosk Civil Filing Fax: +12136253244 Page 3 of 36 092212016 1:37 PM CM-O1O ATTORNEY OR PARTY WITHOUT ATTORNEY (Name. Stale Bar number. and address): ?Law Of?ces ofJonathan l. Delshad Jonathan J. Delshad SBN 246176 1663. Sawtcilc Blvd..Suite 220 Los Angcles, CA 90025 TELEPHONE no.2 424-255-8376 FAX No.2 424-256-7399 moans: FOR (Name): ALEXANDER POLONSKY FOR COURT USE ONL FLED Los Angelou Superior Court SUPERIOR COURT or CALIFORNIA, coum'v or Log An geles STREETADDRESS: 1 1), N. Hi1] SL HI N. Hill St. a a cm ANozwcooE: Los CA 90012 CASEBSZPEQNAME: Stanley Courthouse Shem R. ?an Exacuu 9 9 . 1 B8 POLONSKY v. WELLS FARGO BANK COMPANY, eta]. Bv gs e33, it?! CASE COVE-R SHEET Complex Case Designation CASE "we - I Unlimited Limited . 6 3 4 4 7 5 (Amount (Amount Counter Jornder I - demanded demanded is Filed with first appearance by defendant .. exceeds $25900) $25000 Or 1955) (Cal. Rules of Court, rule 3.402) DEPT: 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 Contract Auto (22) Breach of contract/wane nty (06) ?Uninsured'motorist (45) -- Other PIIPDIWD (Personal Injury/Property DamagelWrortgful Death) Tort Asbestos (04) Product liability (24) Medical malpractice (45) Other PIIPDIWD (23) (Other) Tort Business tortluntalr business practice (07) Civil rights {08) Other collections (09) Insurance coverage (18) Other contract (37) ea! Property Eminent domain/inverse condemnation (14) Wrongful eviction (33) Other real property (26) nlawlul Detainer ?Danae El i3. Defamation (13) Commercialiat) i:i Fraud (16) Residential (32) Intellectual property (19) Drugs (38) i:i Professional negligence (25) Judicial Review Other tort (35) El Asset forfeiture (05) Employment i:i Petition re: arbitration award (11) Wrongful termination (36) Writ of mandate (02) Ci Otheremployment,(15) i:i Otherjurticiai review (39) Rule 3.740 Provisionally Complex Civil Litigation (Cal. Rules of Court, rules salon-3.403) DEBUG ntorcemont of Judgment Miscellaneous Civil Complaint l:l Miscellaneous Civil Petition l:l Construction detect (10) Mass tart (40) Securities litigation (28) EnvironmentallToxic tort (30) Insurance coverage claims arising from the above listed provisionally complex case types Enforcement of iudgment (20) RICO (27) Other complaint (not specified above) (42) Partnership and corporate governance (21) Other petition (not sp ecified above) (43) 2. Thiscase is 3 factors requiring exceptional judicial management: a. Large number of separately represented parties b. Extensive motion practice raising difficult or novel issues that will be time-consuming to resolve c. i:i Substantial amount of documentary evidence Remedies sought (check all that apply}: a. monetary b. nonmonetary; declaratory or injunctive relief is not complex under rule 3.400 of the California Rules of Court. if the case is complex. mark the d. Large number of witnesses e. i:i Coordination with related actions pending in one or more courts in other counties, states, or countries, or in a federal court f. E: Substantial postjudgment judicial supervision c. punitive 4 Number of causes of action (specify): 4 Cg. This case is Cl is not a class action suit. up. it there are any known related cases. ?le and serve a notice of related case,Zioale: 9-22-16 Jonathan I. i -. (TYPE 0R PRINT NAME) (SIGNAIUREOF PARTY pa merger FOR PARTY) r1197 . NOTICE in sanctions. I File this cover sheet in addition to any cover sheet required by local court 'rule. 0 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 this is a collections case under rule 3.740 or a complex case, this cover sheetwiil be used for statistical purposes only HI .3. - Plaintiff must ?le this cover sheet withthe ?rst paper ?led in the action or prooee (except small claims ceses or cases ?led 'under the Probate Code. Family Code. or Welfare and institutions Code). (Cal. uies of Court, rule 3.220.) Pailure to ?le may result age int ,2 Form Adcpled for Mandatory Use CIVIL CASE COVER SHEET Judicial Council or Caliiornia Chi-010 (Rev. July 1. 2007) Cal. Rules of Court. rules 2.30. 3.220. MOO-3.403. 3.740; Cal. Standards of Judicial Administration. std. 3.10 courlr?rifu.ca. go 4[ Reception@delshadleg. . From: Jonathan delshad Fax: (424) 256-7899 To: Stanley Mask Civil Filing Fax: +12136253244 Page 4 of 36 0912212016 1:37 PM ON HOW TO COMPLETE THE COVER SHEET CM 010 To Plaintiffs and Others Filing First Papers. If you are filing a first paper (for example, a complaint) in a civil case. you must complete and ?le, along with your ?rst paper. the Civil Case Cover Sheelcontained on page This information will be used to compile statistics about the types and numbers of cases ?led. You must complete items 1 through 6 on the sheet. in item 1, you must check one box for the case type that best describes he case. If the case ?le both a generaland a more specific type of case listed it item 1. check the more specific one. if the case has multiple causes of action. check the box that best indicates the primary cause of action. To assist you in completing the sheet. examples of the cases that belong under each case type in item 1 are provided below. A cover sheet must be ?led only with your initial paper. Failure to file a cover sheet with the first paper tiled in a civil case may subject a party. its counsel. or both to sanctions under rules 2.30 and 3.220 of the California Rules of Court. To Parties in Rule 3.740 Collections Cases. A "collections case" under rule 3.740 is defined as an action for recovery of money owed in a sum stated to be certain that is not more than 325.000. exclusive of interestand attorney's fees. arising from a transaction in which property, services, or money was acquired on credit. A collections case does not include an action seeking the following (1) tort damages. (2.) punitive damages. (3) recovery of real property. (4) recovery of personal property. or (5) a prejudgment writ of attachment. The identification of a case as a rule 3.740 collections. case on this fonn means that it will be exempt from the general time?for-servlce requirements and case management rules. unless a defendant files a responsive pleading. A rule 3.740 collections case will be subject to the requirements for service and obtaining a judgment in rule 3.740. To Parties in Complex Cases. in complex cases only. parties must also use the Civil Case Cover Sheet to designate whether the case is complex. if a plaintiff believes the case is complex under rule 3.400 of the California Rules of Court, this must be indicated by completing the appropriate boxes in items 1 and 2, if a plaintiffdesignates a case as complex. the cover sheet must be served with the complaint on all parties to the action. A defendant may ?le and serve no later than the time of its ?rst appearance a joinderin the plaintiff's designation. a counter-designation that the case is not complex. or. ifthe plaintiff has made no designation. a designation that the case is complex. Auto Tort OamagelWrongful Death Unlnsured Motorist (46) (if the case involves an uninsured motorist claim subject to arbitration, check this item lnslead of Auto) Other (Personal Injury! Property DamagelWrongfui Death) Tort Asbestos (04) Asbestos Property Damage Asbestos Personal lnjuryl Wrongful Death Product Liability (not asbestos or toxic/environmental) (24) Medical Malpractice (45) Medical Malpractice? Physicians Surgeons Other Professional Health Care Malpractice Other (23) Premises Liability slip and fail) intentional Bodily assault. vandalism) intentional Inflicticn of Emotional Distress Negligent lnlliction of Emotional Distress Other (Other) Tort Business "l'ortlUnfair Business Practice (07) Civil Rights discrimination. false arrest) (not civil cg. harassment} (08) Defamation slander. libel) is (13) Fraud (16) CASE TYPES AND EXAMPLES Contract - 'Breach of Contractharranty (06) Breach of Rental/Lease Contract (not unlawful delainer or wrongful eviction) ContracWVarranty Breach?Seller Plaintiff (not fraud or negligence) Negligent Breach of Warranty Other Breach of Contractharranty Collections money owed. open book accounts) (09) Collection Case?Seller Plaintiff Other NotelCollections Case insurance Coverage (not provisionally complex) (18) Auto Subrogation Other Coverage Other Contract (37) Contractual Fraud Other Contract Dispute Real Property Eminent Domain/inverse Condemnation (14) Wrongful Eviction (33) Other Real Property (9.9.. quiet title) (26) Writ of Possession of Real Property Mortgage Foreclosure Quiet Title Other Real Property (not eminent domain, landlord/tenant, or foreclosure) Unlawful Detainer Commercial (31) Residential (32) Drugs (38) (if the case involves illegal drugs, check this item; olhenvise, report as Commercial or Residential) Judicial Review Asset Forfeiture (05) Provisionally Complex Civil Litigation (Cal. "'Rules of'Court Rules 3400-32403)" Antitrusll?l?rade Regulation (03) Construction Defect (10) Claims involving Mass Tart (40) Securities Litigation (28) EnvironmentallToxic Tort (30) Insurance Coverage Claims (arising from provision ally complex case type. listed above) (41) Enforcement of Judgment Enforcement of Judgment (20) 1 Abstract of Judgment (Out of County) Confession of Judgment (non- domestic relations) Sister State Judgment Administrative Agency Award (not unpaid taxes) PetitionlCerti?cation of Entry of Judgment on Unpaid Taxes Oihecr Enforcement of Judgment ase Miscellaneous Civil Complaint (27.) Other Complaint. (not speci?ed above) (42) Declaratory Relief Only lnjunctive Relief Only (non- harassment) Mechanics Lien Olher Commercial Complaint Case (non-tort/non-complex) Other Civil Complaint (non-tori/nori-complex) Miscellaneous Civil Petition Partnership and Corporate Governance (21) Other Petition (not specified above) (43) Civil Harassment Workplace Violence intellectual Property (19) Petition Re: Arbitration Award (1 1) - Professional Negligence (25) Writ of Mandate (02) Eldeg?sfndem Mu? i Legal Malpractice Writ-Administrative Mandamus Election Contest I Other Professional Malpractice Writ?Mandamus on Limited Caur't Petition for Name Chan 8 m" (not medical or legal) Case Matter 9 Other Tort (35} Employment Wrongful Termination (36) Other Employment (15) cm-oro (Rev. July 1. 2007] Writ?Other Limited Court Case Review Other Judicial Review (39) Review of Health Of?cer Order Notice of Appeal?Labor Commissioner Appeals CASE COVER SHEET Petition for Relief From Late Claim Other Civil Petition Page 2 of 2 Page 5 of 36 09f22f2016 1:37 PM 1 5 Reception@delshadleg. From: Jonathan delshad Fax: (424) 256-7899 To: Stanley Mosk Civil Filing Fax: +12136253244 SHORT TITLE: POLONSKY V. WELLS FARGO BANK COMPANY. et at. CASE NUMBER 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 2.0 in all new civil case filings in the Los Angeies Superior Court. Item I. Check the types of hearing and ?ll in the estimated length of hearing expected for this case: JURY YES CLASS YES LIMITED Dyes TIME ESTIMATED FOR TRIAL 8-10 :1 DAYS item It. indicate the correct district and courthouse location (4 steps if you checked "Limited Case". skip to ltem' Pg. 4): Step 1: After ?rst completing the Civil Case Cover Sheet form, ?nd the main Civil Case Cover Sheet heading for your case in the left margin below, and, to the right in Column A. the Civil Case Cover Sheet case type you-selected. of action in Cotumanelow which best describes the nature of-this Step 3: in Column C, circle the reason for the court location choice that applies to the type of action you have checked. For any exception to- the court location, see Local Rule 2.0. Applicable Reasons for Choosing Courthouse Location (see Column below) . Class actions must be ?led in the Stanley Mosk Courthouse. central district. 6. Location of property or permanently garaged vehicle. . May be ?led in central (other county. or no bodily damage). 7. Location wherepetitioner resides. . Location where cause pf action arose. 8. Location wherein defendant/respondent functions wholly. . Location where bodIly death or dama occurred. 9. Location where one or more of the Iprairties reside. . Location where performance reqwred or de endant resales. 10. Location of Labor Commissmner 0 Ice U?thNd Step 4: Fill in the information requested on page 4 in Item complete Item iV. Sign the declaration. Auto (22) Cl A7100 MotorVehicte-Personal Injury/Property Damage/Wrongful Death '5 Uninsured-Motorist (46) A7110 Personal lnjurnyroperty Damage/WrongfulDeath?Uninsured Motorist (0 Ci A6070 Asbestos Property Damage 2. Asbestos 4) Cl A7221 Asbestos-Personal InjuryIWrongfuI Death 2. x? (D Product Liability (24) A7260 Product Liability (not asbestosor toxic/environmentalA7210 Medical Mal - lg; . practice-PhysICIans&SurgeOITs .45 .52 Medical Malpractice (45) I El A7240 Other Professional Health Care Malpractice 1.. 4. 724': 0 [fig Cl. A7250 Premises Liability (e.g..slip and fall) 1 4 1" Other . -. . ?it 5? personal Injury [3 A7230 IntentIonal Bodily Injury/Property Damage/Wrongful Death (2.9., 1 4 assault.vandalism.etc.) a Property Damage Wmniifzugfeath A7270 Intentional In?iction of Emotional Distress 1"3' El A7220 Other Personal Injury/Preperty Damage/Wrongful Death 1"4? CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION Local Rule 2.0 Page 1 of4 LACIV 109 (Rev. 03/11) LASC Approved 03-04 . . . . -.: sew 5] Reception@de shadleg. . From: Jonathan delshad Fax: (424) 256-7899 To: Stanley Mosk Civil Filing Fax: +12136253244 Page 6 of 36 092212016 1:37 PM SHORT TITLE: CASE NUMBER WELLS FARGO BANK COMPANY, et al. Business Tort (07) CI A6029 Other Commercial/Business Tort (not fraudlbreach of contract) 1.. 3. ?5 . at" Civil Rights (08) A6005 CIVIIRightsIDiscrIminatron 1..2..3. E, 3 Defamation (13) A6010 DefamatIOn (slanderllibelFraud (16) A6013 Fraud (no contract) 3. 5 a I A6017 Legal Malpractice 1.. 2.. 3. n_ Professional Negligence (25) A6050 Other Professional-Malpractice (not medical or legalOther (35) E3 A6025 Other Non-Personal Injury/Property Damage tort I m? . Wrongful Termination (36) El Wrongful Termination 1 9 3. a E'Iiu? v. nunA6024 Other Employment Complaint Case 1., 2.. 3. 3 Other Employment (15) u, A6109 Labor Commissioner Appeals 10. El A6004 Breach of Rental/Lease'Contract (not unlawfutdetainer orwrongful . . 2.. 5. . - ct/W I Bmac 0 Carat; arm? A6008 Contract/Warranty Breach -Seiler Plaintiff (no fraudlnegligenoe) 2" 5? I (not insurance) 13 A6019 Negligent Breach of Contract/Warranty (no fraud) 1" 2" 5' I A6028 Other Breach of ContractIWarranty (not fraud or negligence) 1" 2" 5? E3 A6002 Collections Case-Seller Plaintiff 2.. 5.. 6. *5 Collections (09) 8 Ci A6012 OtherPromlssory Note/Collections Case 2.. 5. Insurance Coverage (18) . CI A6015 Insurance Coverage (not complex) 1.. 2.. 5.. 8. A6009 Contractual Fraud 1..2..3..5. Other Contract (37) CI A6031 Tortious Interference 1.. 2., 3.. 5. I El A6027 Other Contract Dispute(not 1.. 2.. 3.. 8. I Emcigi'ggnorgg'rfavgrw A7300 Eminent DomainICondemnation Number of parcels 2. wronng Eviction (33) A6023 Wrongful Eviction Case A6018 Mortgage Foreclosure 2.. 6 0 Di Other Real Property (26) 13 A6032 Quiet Title 2., 6. a. A6060 Other Real Property (not eminent domain.landlordltenant. foreclosure) 2.6 Mg. . . Un'awmluetig?r'bommema' A6021 Unlawful Detainer-Commerciai (not drugs or wrongful eviction) 2.6. a Uniawm? Dalggr'Resldem'at El A6020 Unlawful Detainer-Residential (no: drugs orwronglul eviction) 2.6. GEE 6" Unlawful Detainer? . a. 2 Post_F?reclosure (34) CI A6020F Unlawful Detainer Post Foreclosure 2., 6. r: :3 Unlawful Detainer~Drugs (36) A6022 Unlawful Detainer-Drugs 2.. 6. 5 wow 109 (Rev. 03/11) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.0 LASC Approved 03-04 AND STATEMENT OF LOCATION Page 2 of 4 From: Jonathen deishad Fax: (424) 256-7899 01:36:56p.m 09-22?2015 1 7] Reception@delshadleg. To: Stanley Mask Civil Filing Fax: +12136253244 Page 7 of 36 0912212016 1:37 PM SHORT TITLE. POLONSKY v. WELLS FARGO BANK COMPANY, et at. CASE NUMBER I Asset Forfeiture (05) Cl A6108 Asset Forfeiture Case 2.. 6. Petition re Arbitration (11) El A6115 Petition A6151 Writ -Administrative Mandamus 2.. 8. GU I Writ of Mandate (02) Cl A6152 Writ - Mandamus on Limited Court Case Matter 2. .2 CI A6153 Writ - Other Limited Court Case Review 2. Other Judicial Review El A6150 Other Writ IJudiciai Review 2.. 8. Antitrust/Trade Regulation (03) Cl A6003 Antitrust/Trade Regulation 1.. 2., 8 .2 ?36 .51" Construction Defect (10) El A6007 Construction Defect 1Clams invoglgf M385 To? l3 A6006 Claims Involving Mass Tan 1.. 2., 8. . I '1 Securities Litigation (28) 1:1 A6035 Securities Litigation Case 1.. 2., a I . . Toxrc Tort . . :3 Environmental] (30) Cl A6036 Toxrc Tort/Envrronmental 1" 2.. 3? 8? . - lnsurance Coverage Claims . o. from Complex Case (41) El A6014 insurance CoveragelSubrogatton (complex case only) 1.. 2.. 5.. 8. Ci A6141 Sister State Judgment 2.. 9. El A6160 Abstract ofJudgment 2.. 6. Enforcement El A6107 Confession of Judgment (non-domestic relations) 2.. 9. 5% (20) A6140 Administrative Agency Award (not unpaid taxes) 2.. 8. '6 Cl A6114 Petition/Certificate for Entry ofJudgment on Unpaid Tax 2., B. A6112 Other Enforcement of Judgment Case 2.. 8., 9. 8 RICO (27) El A6033 Racketeering (RICO) Case 1.. 2., 8 6 .5 13 A6030 Declaratory Relief Only 1., 2., 8. 8 Other Compiaims Ct A6040 Injunctive Relief Only (not domesticlharassment) 2.. 8. Spec'f?e?j Am?) (42) E3 A6011 Other Commercial Complaint Case (non-tortinon-complex) 1.. 2.. 8. A6000 Other Civil Complaint (non-tortlnon-complex) 1.. 2.. 8. Partnership Corporation . Governance (21) El A6113 Partnership and Corporate Governance Case 2.. 8 A6121 Civil Harassment 2.. 3.. 9. "2:"va 9.3 A6123 Workplace Harassment 2.. 3., 9. lei?"w r: El A6124 EIderIDe endent Adult Abuse Case 2., 3., 9. ME Other Petitions f? (Not Speci?ed Maw) 13 A6190 Election Contest 2. (43) A6110 Petition for Change of Name 2.. 7. Eli El A6170 Petition for Relief from Late Claim Law 2., 3.. 4.. 8. El A6100 Other Civil petition 2.. 9. LACIV CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.0 LASC Approved 03-04 AND STATEMENT OF Page 3 of 4 8 I Reception@delshadleg. . From: Jonathan delshad Fax: (424) 258-7899 To: Stanley Mosk Civil Filing Fax: +12136253244 Page 8 of 36 091222016 1:37 PM CASENUMBER POLONSKY v. WELLS FARGO BANK. COMPANY, et al. ltem Statement of Location: Enter the address of the accident. party's residence or place of business, performance. or other circumstance indicated in Item ll., Step 3 on Page 1, as the proper reason for filing in the court location you selected. ADDRESS: REASON: Check the appropriate boxes for the numbers shown 25552 The Old Rd under Column for the typeof action that you have selected for this case. :31. g2. :13. r34. r35. [36. (37. 1:8. D10. CITY: STATE: ZIP CODE: Stevenson Ranch CA 91381 ltem IV. Declaration of Assignment declare underpenalty of perjury underthe laws ofthe State of California that the foregoing is true and correct and that the above-entitled matter is properly tiled for assignment to the Stan'ey courthouse in the Central District of the Superior Court of California. County of Los Angetes [Code Civ. Proc.. 392 et seq., and Local Rule 22c, ?dbd's. and (an. a a Dated; 922?16 0 (SIGNVRE OF PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY COMMENCE YOUR NEW COURT CASE: 1 Complaint or Petltlon. 2 If ?ling a Complaint, a completed Summons form for issuance by the Clerk. 3. Civil Case Cover Sheet, Judicial Council form Gilli-010. 4 Civil Case Cover Sheet Addendum and Statement of Location form, 109, LASC Approved 03-04 (Rev. 03/11). Payment in-full of the ?ling fee, unless fees have been waived. .01 6. A signed order appointing the Guardian ad Litem, Judicial Council form 0, if the plaintiff or petitioner is a minor under 18 years of age will be required by Court in order to issue a summons. 7. Additional copies of documents to be conformed by the Clerk. Copies of the cover sheet and this addendum must be served along the summons and complaint, or other initiating pleading in the case. - L753 .. lug;- cal?! LACIV 109 (Rev. 03/11) CIVIL CASE COVER SHEET ADDENDUM _Local Rule 2.0 LAsc Approved 03-04 AND STATEMENT OF LOCATION Page 4 of 4