SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Document Scanning Lead Sheet Nov-01?2017 3:18 pm Case Number: Filing Date: Nov-O1-2017 3:11 Filed by: BOWMAN LIU Image: 06088524 COMPLAINT ULLA A. TANDRUP ET AL VS. CORPORATION ET AL 001006088524 Instructions: Please place this sheet on top of the document to be scanned. restroom (cnf?fW?'g?m norrca 'ro DEFENDANT: (AVISO AL DEMANDADO): PACIFIC GAS ELECTRIC and DOES I through 100, incI'usive YOU ARE BEING SUED BY PLAINTIFF: (LO ESTA DEMANDANDO EL DEMANDANTE): ULLA A. AND LARS c; TANDRUP noncar You have been sued. The court may decide against you without your being heard unless you respond within so days. Read the information below You have 30 CALENDAR DAYS after this summons and legal papers are served on you to file a written response at this court and have a copy served on the plaintiff. A letter or phone call will not protect you. Your written response mat be In proper legal form If you want the court to hear your case. There may be a court form that you can use for your response. You can find these court forms and more information at the California Courts Onllne Self-Help Center (moourtinfecagcv/seiihaip). your county law library. or the courthouse nearest you. If you cannot pay the ?ling fee. ask the court stark for a fee waiver form. if you do not ?le your response on time. you may lose the case by default. and your wages. money. and property may be taken without further warning from the court. There are other legal requirements. You may want to call an attorney right away. if you do not know an attorney. you may want to call an attorney referral service. If you cannot afford an attorney. you may be atiglble for free legal services from a nonpro?t legal services program You can locate these nonprofit groups at the California Legal Services Web site the California Courts Oniine Self-Help Center (mcourtinfocageuiseiiheip). or by contacting your local court or county bar association. NOTE: The court has a statutory lien for waived fees and costs on any settlement or arbitration award of $10,000 or more in a civil case. The court's lien must be paid before the court will dismiss the case. 1A Lo hen domandado. Si no responds denim do 30 dies. ia certs pueda docidir en su contra sin ascuchar su varsidn. Leo is informacion a con nuacidn. Trans 30 DIAS DE despues de que lo ontroguon esta' citacr'?n papoios iogaios para presenter una respuosro per ascrio en asia cone tracer qua so onirogue una sepia oi demandanta. Una carts 0 one llamado teiofdnica no to protogen. Su rospuosta per escriro tiene que ester an ionnato legal correcto at doses qua pmcaaen on case en la certs. Es poslbio que hays un iormuian'o qua ustad pueda usarpara su raspuosta. Pueda enoontrar esfes fonnufan'os do is eerie mas inferrnecidn on oi Centre do Ayuda do ias Cortes do Ca?iomia (Www.sucerte.ca.gov), en la do ioyes do so condado on is certo que lo quads mas carca. Si no puode pagaria cuota do prasantacfon. pida aisocraiario do is corfe qua is do on fonntriorio do oxencidn do page do copies. 8! no presents an respuesta a riempo. puede perder or case per incumpiimienie yia certs ie podro quitar su suaido. dinono bienos sin mos advenencia. *2 Hay otros requisites iogaias. Es rocemondabie qua flame a un abegado inmediatemonfe. Si no comes a un abogade, puodo iiamar a un sorvicio do remision a abogados. Si no pueda pager a un abogodo. as posibie qua cumpia con ios requisites para coroner servicios iagaias gratuires do un ?2 - programs do sorvicies iagaios sin fines do iucro. Puade encenfrar astos grapes sin fines do iucro on of siilo web do California Legal Services. - Mmlawhelpcalifomlaerg). an of Centre do Ayuda do ias Cortes do an.aucorte.ca.gov) penidndoso an contacte con to cone 0 of ceiegio do obogodos iecaios. A For fey. la eerie fiono dorooho a rociamar ias cuotas fes castes exonies per impener un gravaman sabre cuaiquiar recuperacion do 810,000 :5 mos do valor racibida medianro un acuerdo a una ceneasion do arbitrajo an un case do darecno civil. Tiane qua pager aigravamon do to eerie antes do qua to aorta puoda dosochar of case. The name and address of the court to (Einembro direcor'dn do is eerie Superior Court of California, County of San Francisco Civil Center Cou rthousc 400 McAIiister Street. San Francisco, CA 94l02 The name. address. and telephone number of plaintiffs attorney. or plaintiff wltheut an attorney. is: (El hombre, is direccidn at namere do feiofone def abogado del demandanie. 0 doi demandante que no tiene abegado. as): Bill Robins Esq. (SBN 296?!) i Robert T. Bryson, Esq. (SBN 156953) i Kevin M. Pollack, Esq. (SEN 272786) ROBINS CLOUD LLP. 808 Wilsltire Boulevard, Suite 450, Santa Monica. CA 90401 DATE: DEPUTY erk. by 1,5th) NOV 0 1 7n17 Rigs .. . - .7. 1 . (Munro) (For proof of service of this summons. use Proof of Service of summons it (Para pruoba do entrega de esta citatidn use of iorrnuiario Proof of Service 0 one. FiMr?mN Lm NOTICE TO THE PERSON SERVED: You are sewed 1-. as an individual defendant. 2. E: as the person sued under the ?ctitious name of (special): Tel: (310; 929-1200 . Deputy on behalf of (specify): under: GOP 416.10 (corporation) cop 416.60 (miner) CCP 418.20 (defunct corporation) CCP 416.70 (conservatee) con 416.40 (association or partnership) C3 CCP 416.90 (authorized person) other (specify): 4. a by personal delivery on (date): PM Form Adapted for Honduory Use Code of Civil Procedure 412.20. 405 Motor Courts! oi Cum SUMMONS gov aura-100 they. July 1. aces] 1 Bill Robins (SBN 296101) Robert T. Bryson (SBN 156953) 3:750, 00%; C?omiaD 2 Kevin M. Pollack (SBN 272786) WW of San Francisco ROBINS CLOUD LLP 3 808 Wilshire Boulevard, Suite 450 NOV 0 1 20? 4 Santa Monica, CA 90401 CLE THE URT 5' Tel.: (310) 929-4200 Fax: (310) 566-5900 BY: 2 i i robins@robinscloud.com lerk 6 OMMW if? kpollack@robinscloud.com 7 Donald S. Edgar (SBN 139324) 8 EDGAR LAW FIRM 9 408 College Avenue Santa Rosa, CA 95401 10 Tel.: (707) 7994090 Fax: (707) 324-6796 11 don@classattorneys.com 12 Attorneys for Plaintiffs 13 SUPERIOR COURT OF THE STATE OF CALIFORNIA 14 COUNTY OF SAN FRANCISCO 15 16 ULLA A. AND CASE no: 17 LARS c. TANDRUP Judge: C8331 Dept: 18 Plaintiffs, CIVIL 19 vs. 20. COMPLAINT FOR DAMAGES PACIFIC GAS 21 ELECTRIC and DOES I. - through 100, inclusive, 2. INVERSE 22 3. 23 Defendants. 4. PRIVATE 5. VIOLATION OF PUBLIC 24 UTILITIES CODE ?2106; AND 6. VIOLATION OF HEALTH 25 SAFETY CODE ?13007 26 JURY TRIAL DEMANDED 27 28 1 COMPLAINT FOR DAMAGES c: - 0 TO THE CLERK OF THE ABOVE-ENTITLED COURT AND TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 1.0 INTRODUCTION Beginning on or about October 8, 2017, residents and property owners in Sonoma, Mendocino, Lake, Napa, Butte and Solano Counties were devastated by severe wild?res (collectively the ?Wine Country Fires?). The Wine Country Fires were started when electrical infrastructure owned, Operated and maintained by CORPORATION and PACIFIC GAS ELECTRIC COMPANY (hereinafter came into contact with vegetation inspected and maintained by The Wine Country Fires, to date, have burned more than 220,000 acres, burned more than 3,000 homes, burned numerous commercial structures, and other structures. In addition, the Fire caused the deaths of at least 41 people, and injured others. The Plaintiffs in this case are victims of the Wine Country Fires who individually seek just compensation and damages. Specifically, Plaintiffs in this action seek damages for, inter alia, personal injury; medical care and treatment; loss of earnings and/or loss of earning capacity; pain and suffering and/or emotional suffering; dis?gurement; physical impairment; damage to and loss of use of real and personal preperty; injury to livestock and/or pets; damage to trees and/or vegetation; loss of income; consequential and incidental damages; fear and anxiety, inconvenience, and all other harm and losses caused by the wrongful conduct of CORPORATION, PACIFIC GAS ELECTRIC COMPANY, and Does 100, inclusive. 2.0 JURISDICTION AND VENUE 2.1 The Plaintiffs are now and at all times relevant herein individuals, residents, domiciliaries and property owners who resided in in Sonorna County. All of their claims arise from events or occurrences related to the Wine Country Fires within which resulted in the damages, losses, and injuries as hereinafter alleged. 2.2 At all times herein mentioned Defendants CORPORATION and PACIFIC GAS ELECTRIC COMPANY, were corporations authorized to do business, and doing business, 7 DAMAGES gnu A in the State of California, with their principal place of business in the County of San Francisco, State of California. Defendant CORPORATION is an energy-based holding company headquartered in San Francisco. It is the parent company of Defendant PACIFIC GAS ELECTRIC COMPANY. CORPORATION subsidiaries provide customers with public utility services, and services relating to the generation of energy, transmission of electricity and natural gas, generation of electricity, and the distribution of energy. 2.3 At all times mentioned herein, CORPORATION, PACIFIC GAS ELECTRIC COMPANY, and DOES I through 50, and each of them, were suppliers of electricity to members of the public. As part of supplying electricity to members of the public, installed, constructed, built, maintained, and operated overhead power lines, together with supporting poles and appurtenances, for the purpose of conducting electricity for delivery to members of the general public. Furthermore, on information and belief, CORPORATION, PACIFIC GAS ELECTRIC COMPANY, and DOES 1 through 100, are responsible for maintaining vegetation near, around, and in proximity to their electrical equipment in compliance with State and Federal Regulations, speci?cally including but not limited to Public Resource Code 4292, Public Resource Code 4293, General Order 95, and General Order 165. 2.4 Plaintiffs are informed and believe that the Defendants herein, and each of them, were agents and/or employees each of the other and in acting and/or failing to act as alleged herein, the Defendants, and each of them, were acting in the course and scope of said agency and/or employment relationship. 2.5 Accordingly, this Court has jurisdiction of this action pursuant to Section 410.10 of the California Code of Civil Procedure. 2.6 Venue is preper in this Court pursuant to Sections 392, 395 and 395.5 of the California Code of Civil Procedure because Defendants are headquartered here, Plaintiffs reside, own, or had interests here, and/or Plaintiffs? property and/or business are or were located here, and/or the liability arising from the Wine Country Fires occurred in this venue. 3 COMPLAINT FOR DAMAGES 3.0 THE PLAINTIFFS 3.1 The Plaintiffs are individuals who suffered severe injuries, damages, losses, and harm as a result of the Wine Country Fires. Plaintiffs were severely burned while ?eeing their home located at 955 Quietwater Ridge, Santa Rosa CA 95404. 3.2 Plaintiffs Ulla A. Tandrup and Lars C. Tandrup owned and resided at the property located at 955 Quietwater Ridge, Santa Rosa CA 95404. 4.0 THE DEFENDANTS 4.1 PACIFIC GAS ELECTRIC COMPANY is both an ?Electrical Corporation? and a ?Public Utility? pursuant to, respectively, Sections 218(a) and 216(1) of the California Public Utilities Code. is in the business of providing electricity to the residents of at least two counties and 26 cities, including but not limited, to Sonoma County and, more particularly, to Plaintiffs' residences and/or properties through a network of electrical transmission and distribution lines. 42 CORPORATION is a publicly traded company that owns and/or manages an ?Electric Plant" as de?ned in Section 2l7 of the Public Utilities Code, and, like its subsidiary, PACIFIC GAS ELECTRIC COMPANY, is both an ?Electric Corporation? and a ?Public Utility? pursuant to, respectively, Sections 218(a) and 216(a) of the Public Utilities Code. It develops and operates energy infrastructure assets related to the production and distribution of energy such as power plants, electric lines, natural gas pipelines and lique?ed natural gas receipt terminals. 4.3 Plaintiffs allege on information and belief that CORPORATION and PACIFIC GAS ELECTRIC COMPANY are jointly and severally liable for each other's negligence, conduct and wrongdoing as alleged herein, in that: a. CORPORATION and PACIFIC GAS ELECTRIC COMPANY Operate as a single business enterprise operating out of the same building located at 77 Beale St, San Francisco, California for the purpose of effectuating and carrying out CORPORATIONS business and 4 COMPLAINT FOR DAMAGES 00 \1 ON U1 OKD 00?s.} 0\ U: A 3 operations and/or for the bene?t of Defendants do not operate as completely separate entities, but rather, integrate their resources to achieve a common business purpose; PACIFIC GAS ELECTRIC COMPANY is so organized and controlled, and its decisions, affairs, and business so conducted as to make it a mere instrumentality, agent, conduit, or adjunct of PACIFIC GAS ELECTRIC income contribution results from function integration, centralization of management and economies of scale with Defendants? of?cers and management are intertwined and do not act completely independent of one another; Defendants' officers and managers act in the interest of CORPORATION as a single enterprise; CORPORATION has control and authority to choose and appoint PACIFIC GAS ELECTRIC board members as well as its other top officers and managers; Despite both being Electric Companies and Public Utilities, Defendants do not complete with one another, but have been structured and organized and business effectuates so as to create a synergistiCLintegrated single enterprise where various components operate in concert one with another; CORPORATION maintains uni?ed administrative control over PACIFIC GAS ELECTRIC Defendants are insured by the same carriers and provide uniform or similar pension, health, life, and disability insurance plans for employees; Defendants have unified 401(k) Plans, pensions and investment plans, bonus programs, vacation policies, and paid time off from work schedules and policies; 5 COMPLAINT FOR DAMAGES I?vl Defendants invest these funds from their programs and plans by a consolidated and/or coordinated Bene?ts Committee controlled by CORPORATION and administered by common trustees and administrators; Defendants have uni?ed personnel policies and practices and/or a consolidated personnel organization or structure; Defendants have uni?ed accounting policies and practices dictated by CORPORATION and/or common or integrated accounting organizations or personnel; Defendants are represented by common legal counsel; CORPORATIONS of?cers, directors and other management make policies and decisions to be effectuated by PACIFIC GAS ELECTRIC COMPANY and/or otherwise play roles in providing directions and making decisions for PACIFIC GAS ELECTRIC of?cers, directors, and other management direct certain ?nancial decisions for PACIFIC GAS ELECTRIC COMPANY including the amount and nature of capital outlays; written guidelines, policies, and procedures control PACIFIC GAS ELECTRIC COMPANY, its employees, policies, and practices; CORPORATION ?les consolidated earnings statements factoring all revenue and losses from PACIFIC GAS ELECTRIC COMPANY as well as consolidated tax returns, including those seeking tax relief; and/or, without limitation; CORPORATION generally directs and controls PACIFIC GAS ELECTRIC relationship with, requests to, and responses to inquiries from, the California Public Utilities Commission and uses such direction and control for the bene?t of Defendant CORPORATION. 6 COMPLAINT minimises-s an: I-w-l i?I inn-A s?I n?I p-u-A 00 \1 43 U) maintain and repair the electric transmission lines, and other equipment associated with their duty . 4.4 The true names of DOES 1 through 100, whether individual, corporate, associate, or otherwise, are unknown to Plaintiffs who, under California Code of Civil Procedure Section 474, sue these Defendants under ?ctitious names. Each of the ?ctitiously named Defendants is responsible in some manner for the conduct alleged herein, including, without limitation, by way of conspiracy, aiding, abetting, furnishing the means and/or acting in capacities that create agency, reSpondeat superior, and/or predecessor-or successor-in-interest relationships with the Defendants. The DOE Defendants are private individuals, associations, partnerships, corporations, or otherwise that actively assisted and participated in the negligent and wrongful conduct alleged herein in ways that are currently unknown to Plaintiffs. Some or all of the DOE Defendants may be residents of the State of California. Plaintiffs may amend or seek to amend this Complaint to allege the true names, capacities, and responsibility of these DOE Defendants once they are ascertained, and to add additional facts and/or legal theories. Plaintiffs make all allegations contained this Complaint against all Defendants, including DOES 1 through 100. 5.0 BACKGROUND. 5.1 Prior to October 8, 2017 Defendants, and each of them, had a duty to properly I to transmit electricity and to keep vegetation properly trimmed and maintained so as to prevent contact with power lines and other electrical equipment. In the construction, repair, maintenance, and operation of such equipment and power lines the Defendants, and each of them, had an obligation to comply with statutes, regulations, and standards, speci?cally including, but not limited to, Public Resource Code 4292, Public Resource Code 4293, General Order 95, and General Order 165. In addition, the Defendants, and each of them, were speci?cally aware that such standards and regulations were minimum standards and that Defendants, and each of them, had a duty to make their tines safe under all the exigencies created by the surrounding circumstances and conditions and that a failure to do constituted negligence and would expose members of the general public to a serious risk of injury or death. 7 COMPLAINT FOR DAMAGES h?A ix) 5.2 At all times mentioned herein, Defendants, and each of them, were aware that the 3 State of California, had been in a state of drought, and even though it received more rain this past winter, the summer months brought back drought like conditions. Defendants, and each of them, were aware that the drought conditions had existed and were aware that ?re danger was at an extraordinarily high level, particularly given the increased vegetation arising from the 2017 winter rains. Defendants, and each of them, knew that if the power lines or other equipment came into contact with, or caused electricity to come into contact with vegetation it was probable that a ?re would result and that, given the drought conditions, a resulting ?re would likely result in the loss of life, signi?cant damage to real and personal property and damage to members of the general public, including these Plaintiffs. 5.3 Defendants, and each of them, were negligent in that they failed to preperly maintain, repair, and inspect the subject lines, equipment and adjacent vegetation and negligently failed to properly trim, prune, remove, and/or otherwise maintain vegetation near their electrical equipment . so as to secure safety to the public in general, speci?cally including these Plaintiffs. As a direct, 3 proximate, and legal result of the negligence of the Defendants, and each of them, Plaintiffs suffered the injuries and damages alleged herein. 5.4 On information and belief, beginning on or about October 8, 2017 as a direct proximately result of the negligence of the Defendants, and each of them, power lines and/or other electrical equipment came in contact with vegetation and caused the Wine Country Fires, which I burned in excess of 220,000 acres, including property owned or occupied by these plaintiffs. 6.0 GENERAL ALLEGATIONS 6.1 Defendants are, and were, aware of the danger from ?res in Sonoma, Mendocino, Lake, Napa, Butte and Solano Counties during the summer months when environmental conditions are favorable for extensive con?agration and the high temperatures, absence of moisture, and the prevalence of wind renders the extinguishment of a burning ?re dif?cult. 6.2 Wires and other equipment carrying electricity are a dangerous instrumentalities and a hazardous and dangerous activity requiring the exercise of increased care commensurate with and 8 COMPLAINT FOR cooncnmawme INproportionate to that increased danger so as to make the transport of electricity through wires safe under all circumstances and exigencies offered by the surrounding environment, including the risk of ?re. 6.3 Defendants failed in their duty to exercise care commensurate with and proportionate to the combined danger of an area susceptible to wild?re and the dangerous activity of wires carrying electricity, thereby being a substantial factor in the cause of the ?res, as more fully set forth below. 6.4 The conditions and circumstances existing at the time of the ignition in known ?re origin areas, including the extended drought, high temperature, low humidity, and tinder-like dryness of vegetation, were reasonably foreseeable, if not expected, by a reasonable and prudent person and were reasonably foreseeable by and to be expected by, Defendants, eSpecialiy with their special knowledge and expertise. 6.5 This action seeks damages for each Plaintiff named in this case, according to their individual proof, and not as a part of a "class action," for any and all harm they suffered as a result of the Wine Country Fires. Plaintiffs are informed and believe and herein allege that and DOES 1-100 knew of the dangerous conditions of the property that eventually resulted in the Wine Country Fires, but recklessly and with careless and conscious disregard to human life and safety decided to ignore the ?re risks, inclusive of warnings and danger signs regarding trees within in close proximity to power lines, and other equipment that resulted in the Wine Country Fires. To make sure that the necessary precautions are taken in the future, this action seeks punitive and exemplary damages against Defendants. 7.0 FIRST CAUSE OF ACTION Negligence (Against CORPORATION, PACIFIC GAS ELECTRIC COMPANY, and DOES 1 through 100) 7.1 Plaintiffs incorporate and re-allege each of the paragraphs above as though fully set forth herein at length. 7.2 Defendants CORPORATION and PACIFIC GAS ELECTRIC COMPANY, including their employee/agents DOES 1- 50, have a non-delegabie duty to apply a 9 COMPLAINT FOR DAMAGES- i??D?dD?lh-dr?ll?J r?l . a level of care commensurate with and proportionate to the danger of designing, engineering, constructing, operating, and maintaining electrical transmission and distribution Systems, including vegetation clearance. 7.3 Defendants CORPORATION and PACIFIC GAS ELECTRIC COMPANY, including their employee/agents DOES 1? 50, have a non-delegable duty of vigilant oversight in the maintenance, use, operation, repair, and inspection appropriate to the changing conditions and circumstances of their electrical transmission and distribution systems. 7.4 Prior to the subject ?re, Defendant hired, retained, contracted, allowed, and/or 5 otherwise collaborated with the DOE Defendants and/or other parties to perform work along and . maintain the network of distribution lines, infrastructure, and vegetation. The work for which the DOE Defendants were hired involved a risk of ?re that was peculiar to the nature of the agency relationship. A reasonable property/easement owner and/or lessee in the position of the knew, or should have recognized, the necessity of taking special precautions to protect adjoining property owners against the risk of harm created by work performed, work to be performed, and/or work otherwise not performed. 7.5 Defendants, and each of them, knew or should have known that the activities of the DOE Defendants, and/or other parties, involved a risk that was peculiar to the operation of Defenda?nts? business that was foreseeable and arose from the nature and/or location of the work. Notwithstanding this, Defendants, and each of them, failed to take reasonable precautions to protect adjoining property owners against the foreseeable risk of harm created by their activities. 7.6 Defendants, and each of them, have special knowledge and expertise far above that Iof a layperson that they were required to apply to the design, engineering, construction, use, Operation, inspection, repair, and maintenance of electrical lines, infrastructure, equipment, and vegetation in order to assure safety under all the local conditions in their service area, including but I not limited to, those conditions identified herein. 7.7 Defendants negligently breached those duties by, among other things: a. Failing to conduct reasonably prompt, proper, and frequent inspections of the electrical transmission lines, wires, and associated equipment; 10 COMPLAINT FOR ES moo-qamhwm 7.8 Failing to design, construct, monitor, and maintain high voltage transmission and distribution lines in a manner that avoids igniting ?re during long, dry seasons by allowing those lines to withstand foreseeable conditions and avoid igniting ?res; Failing to design, construct,,operate, and maintain high voltage transmission and distribution lines and equipment to withstand foreseeable conditions to avoid igniting ?res; Failing to maintain and monitor high voltage transmission and distribution lines in ?re prone areas to avoid igniting ?re and spreading ?res; Failing to install the equipment necessary, and/or to inspect and repair the equipment installed, to prevent electrical transmission and distribution lines from improperly sagging, operating or making contact with other metal wires placed on its poles and igniting ?res; Failing to keep equipment in a safe condition at all times to prevent ?res; Failing to inspect vegetation within proximity to energized transmission and distribution lines; Failing to de-energize power lines during ?re prone conditions; Failing to de-energize power lines after the ?re's ignition; Failing to properly investigate, vet, hire, train, and supervise employees and agents responsible for maintenance and inspection of the distribution lines; Failing to implement and follow regulations and reasonably prudent practices to avoid ?re ignition; Failing to properly investigate, monitor, and maintain vegetation suf?cient to mitigate the risk of ?re. The ?re alleged herein was a direct, legal, and proximate result of the negligence of Defendants CORPORATION, PACIFIC GAS ELECTRIC COMPANY, and DOES I to 100, and each of them. Defendants, and each of them, further breached their duties owed to Plaintiffs in that said Defendants (I) failed to comply with the applicable statutes, regulations and standards, 11 COM PLAINT FOR DAMAGES (2) failed to timely and properly maintain and inspect the subject line and adjacent vegetation, (3) failed to preperly cut, trim, prune, and/or otherwise keep vegetation from contact with its line, and (4) failed to make the overhead lines safe under all the exigencies created by the surrounding circumstances and conditions. Defendants, and each of them, negligently installed, constructed, maintained, operated, inspected, and/or repaired the line and as a direct, proximate, and legal result the line caused a ?re and Plaintiffs? damages. As a direct, proximate, and legal result of said negligence these Plaintiffs suffered damages as alleged herein. 7.9 At all times mentioned herein, Defendants CORPORATION, PACIFIC GAS ELECTRIC COMPANY, and DOES to 100, and each of them, failed to properly inspect and maintain the subject line and equipment which they knew, given the then existing drought conditions, posed a risk of serious inj ury, damage or death to others, including Plaintiffs. Defendants 3 CORPORATION, PACIFIC GAS ELECTRIC COMPANY, and DOES to 100, and each of them, were aware that if the subject line and/or subject equipment came in contact with vegetation that a ?re would likely result. Defendants, and each of them, also knew that, given the existing drought like conditions, said ?re was likely to pose a risk of serious injury, damage, and/or death to the general public, including these Plaintiffs. 7.10 Over the past approximately 10 years Defendants, CORPORATION, PACIFIC GAS ELECTRIC COMPANY, and DOES 1 to 100, and each of them, have been subject to numerous ?nes and penalties as a result of ongoing failure to abide by safety rules and regulations. The most recent ?ne/penalty imposed on for safety violations occurred on April 9, 2015, when the CPUC imposed a record $1.6 billion for safety violations that resulted in deaths, injuries, and destroyed homes related to the San Bruno Fire. One of the stated purposes of i the CPUC in rendering such a record ?ne against was to ?ensure that nothing like this happens again.? was also subjected to signi?cant ?nes and penalties for its role in causing the Butte Fire. In addition, disregard for safety has resulted in federal criminal charges. The United States of America has charged PACIFIC GAS ELECTRIC COMPANY with various crimes based on PACIFIC GAS ELECTRIC knowing and willful violation of various minimum safety standards. Despite these penalties and fines - indeed just months after the imposition of the 12 COMPLAINT FOR DAMAGES h?l CO a Li! 43>- UJ OONJ DJ $1.6 billion ?ne/penalty for the safety violations related to the San Bruno Fire - these Defendants have failed and refused to modify their behavior and they have continued to conduct their business with a conscious disregard for the safety of the public. As a result of the continued actions by these Defendants, in conscious disregard for the safety of others, the California Public Utilities Commission has ordered an investigation into the culture of ignoring safety at The CPUC President has recognized that these Defendants have failed and refused to modify their conduct. Despite penalties and ?nes, in July of 201 5, the President of the CPUC, speci?cally stated: Despite major public attention, ongoing CPUC investigations (0113) and rulemakings (OIRs) into actions and operations, including the investigations we voted on today, federal grand jury, and California Department of Justice investigation, continued safety lapses at continue to occur. 7.11 Nonetheless, Defendants continue to consciously disregard the safety of the public, including these Plaintiffs. Since December 2008, Defendants CORPORATION, PACIFIC GAS ELECTRIC COMPANY and DOES 1 to 100, and each of them, have been responsible for the deaths of at least fourteen people and burns and injuries suffered by at least 40 other people. Defendants have admitted to'putting pro?ts over safety and to having violated safety regulations. Prior to the Wine Country Fires, the Defendants, acting with conscious disregard for the safety of others, caused the deaths of eight peopie and destroyed an entire neighborhood in San Bruno, California. Defendants conduct continued with its role in causing the Butte Fire. The deaths, injuries, and damage occasioned by the Wine Country Fires are the result of the ongoing custom and practice of the Defendants, and each of them, of consciously disregarding the safety of the public and not following statues, regulations, standards and rules regarding their business operations. Despite having caused the death and injury to numerous peOpIe, these Defendants have continued to act in conscious disregard for the safety of others, and have rati?ed the conduct of their employees. Upon information and belief, no employee has been disciplined or discharged as a result of failing and/or refusing to comply with the regulations and/or as a result of the deaths of members of the public. These Defendants, in order to cut costs, failed to properly inSpect and maintain the subject line and/or the subject equipment with full knowledge that any incident was likely to result in a fire that would burn and/or kill people, damage property, and/or cause harm to the general public, 13 COMPLAINT FOR DAMAGES 0 including these Plaintiffs. The actions of these Defendants, and each of them, did in fact result in damages to these Plaintiffs. The Defendants and each of them, failed to make the proper inspections, failed to properly maintain the lines, failed to properly trim vegetation, failed to properly and timely remove vegetation, and failed to safely operate their line, in order to save money, while at the same time spending millions of dollars on a television advertising campaign falsely representing to the public that the defendants were acting in a safe manner. i 7.12 The negligence of Defendants was a substantial factor in causing Plaintiffs? damages. 7.13 Defendants' failure to comply with their duties of care proximately caused damage to Plaintiffs. 7.14 As a further direct and proximate result of Defendants' negligence, Plaintiffs suffered damages including, but not limited to personal injury; medical care and treatment; loss of earnings and/or loss of earning capacity; pain and suffering and/or emotional suffering; dis?gurement; physical impairment; damage to and loss of use of real and personal property; injury to livestock and/or pets; damage to trees and/or vegetation; loss of income; consequential and incidental damages; fear and anxiety, loss of cherished possessions, annoyance, disturbance, inconvenience, loss of quiet enjoyment of their property, costs related to Plaintiffs' evacuation as well as other losses and damages. 7.15 Further, the conduct alleged against Defendants in this complaint was despicable and subjected Plaintiffs to cruel and unjust hardship in conscious disregard of their rights, constituting oppression, for which Defendants must be punished by punitive and exemplary damages in an 3 amount according to proof. The conduct of the defendants evidences a conscious disregard for the safety of others, including Plaintiffs. The Defendants? conduct was and is despicable conduct and 3 constitutes malice as defined by Civil Code Section 3294. An of?cer, director, or managing agent of personally committed, authorized and/or rati?ed the despicable and wrongful conduct alleged in this complaint. Plaintiffs are entitled to an award of punitive damages sufficient to punish and make an example of these Defendants, and each of them. 14 COMPLAINT FOR DAMAGES p?A 00 ?4 Ch A La.) . 8.0 SECOND CAUSE OF ACTION Inverse Condemnation (Against CORPORATION, PACIFIC GAS ELECTRIC COMPANY, and DOES 1 through 100, and each of them) 8.1 Plaintiffs incorporate and re?allege each of the paragraphs above as though fully set forth herein at length. 8.2 On or about October 8, 2017, Plaintiffs were owners of real prOperty and/or personal property located within Sonoma County. 8.3 Prior to and on October 8, 2017, Defendant installed, owned, operated, used, controlled, and/or maintained power lines, and electrical equipment in the above mentioned counties. 8.4 On or about October 8, 2017, as a direct, necessary, and legal result of Defendants? installation, ownership, operation, use, control, and/or maintenance for a public use of the power lines and electrical equipment, Defendants? electrical lines and/or equipment came in contact with vegetation and caused a wild?re which burned in excess of 220,000 acres, including property owned or occupied by these plaintiffs. The ?re damaged and/or destroyed Plaintiffs' real and/or personal pr0perty. 8.5 The above described damage to Plaintiffs' property was proximately and substantiaily caused by the actions of Defendants, and each of them, in that Defendants? installation, ownership, operation, use, control, and/or maintenance for a public use of the power lines and equipment was negligent and caused the subject ?re. 8.6 Plaintiffs have not received adequate compensation for the damage to and/or destruction of their property, thus constituting a taking or damaging of Plaintiffs' property by the Defendants, and each of them, without just compensation. 8.7 As a direct and legal result of the above-described damages to Plaintiffs' property including loss of use, interference with access, enjoyment and marketability, and injury to personal property, Plaintiffs have been damaged in an amount according to proof at trial. 15 COMPLAINT FOR DAMAGES 3 8.8 Plaintiffs have incurred and will continue to incur attorney's, appraisal, and engineering fees and costs because of Defendant's conduct, in amounts that cannot yet be ascertained, but which are recoverable in this action under Code of Civil Procedure ?1036. 9.0 THIRD CAUSE OF ACTION Trespass (Against CORPORATION, PACIFIC GAS ELECTRIC COMPANY, and DOES 1 through 100) 9.1 Plaintiffs incorporate and re-allege each of the paragraphs above as though fully set forth herein at length. 9.2 At all times relevant herein, Plaintiffs were the owners and lawful occupiers of property damaged by the Wine Country Fires. 9.3 Defendants negligently allowed the Wine Country Fires to ignite and/or spread out of control, causing injury to Plaintiffs. The spread of a negligently caused ?re to the land of another constitutes a trespass. 9.4 Plaintiffs did not grant permission for Defendants to cause the Wine Country Fires to enter their properties. 9.5 As a direct, proximate, and substantial cause of the trespass, Plaintiffs have suffered and will continue to suffer damages, including but not limited to damage to property, discomfort, annoyance, and emotional distress in an amount to be proved at the time of trial. 9.6 As a further direct and proximate result of the conduct of Defendants, Plaintiffs, have hired and retained counsel to recover compensation for loss and damage and are entitled to recover all attorney?s fees, expert fees, consultant fees, and litigation costs and expense, as allowed under California Code of Civil Procedure, Section 1021.9. 9.7 As a further direct and proximate result of the conduct of Defendants, Plaintiffs seek treble or double damages for wrongful injuries to timber, trees, or underwood on their property, as allowed under California Civil Code, Section 3346. 16 COMPLAINT FOR DAMAGES h?d 9.8 Defendants? conduct was willful and wanton, and with a conscious contempt and disdain for the disastrous consequences that Defendants knew could occur as a result of their dangerous conduct. Accordingly, Defendants acted with malice towards Plaintiffs, which is an appropriate predicate fact for an award of exemplary/punitive damages in a sum according to proof. 10.0 FOURTH CAUSE OF ACTION Private Nuisance (Against CORPORATION, PACIFIC GAS ELECTRIC COMPANY, and DOES 1 through 100) 10.1 Plaintiffs incorporate and re-allege each of the paragraphs above as though fully set forth herein at length. 10.2 Defendants? actions, conduct, omissions, negligence, trespass and failure to act resulted in a ?re hazard and a foreseeable obstruction to the free use of Plaintiffs property, invaded the right to use the Plaintiffs? property, and interfered with the enjoyment of Plaintiffs? pmperty, causing the Plaintiffs unreasonable harm and substantial actual damages constituting a nuisance, pursuant to California Civil Code Section 3479. 10.3 As a direct and proximate result of the conduct of Defendants, Plaintiffs sustained loss and damage, including but not limited to damage to property, discomfort, annoyance, and emotional distress, the amount of which will be proven at trial. 10.4 Defendants? conduct was willful and wanton, and with a conscious contempt and I disdain for the disastrous consequences that Defendants knew could occur as a result of their dangerous conduct. Accordingly, Defendants acted with malice towards Plaintiffs, which is an appropriate predicate fact for an award of exemplary/punitive damages in a sum according to proof. 11.0 FIFTH CAUSE OF ACTION Violation of Public Utilities Code 2106 (Against PACIFIC GAS ELECTRIC COMPANY, and DOES 1 through 100) 1.1 Plaintiffs incorporate and re-allege each of the paragraphs above as though fully set forth herein at length. 17 COMPLAINT FOR DAMAGES i?nwr?Ih?Imr?Ah?Ar?t i?I 11.2 As Public Utilities, Defendants are legally required to comply with the rules and orders promulgated by the California Public Utilities Commission pursuant to Public Utilities Code Section 702. 11.3 Public Utilities that perform or fail to perform something required to be done by the California Constitution, a law of the State, or a regulation or order of the Public Utilities Commission, which leads to loss or injury, is liable for that loss or injury, pursuant to Public Utilities Code Section 2106. 11.4 As Public Utilities, Defendants are required to provide and maintain service, equipment and facilities in a manner adequate to maintain the safety, health and convenience of their customers and the public, pursuant to Public Utilities Code Section 451. 11.5 Defendants are required to design, engineer, construct, operate, and maintain electrical supply lines and associated equipment in a manner consonant with their use, taking into consideration local conditions and other circumstances, so as to provide safe and adequate electric service, pursuant to Public Utility Commission General Order 95, Rule 33.1 and General Order 165. 11.6 Defendants are required to maintain vegetation in compliance with California Public Resources Code Sections 4293, 4294, 4435 and Health Safety Code Section 13001. 11.7 Through their conduct alleged herein, Defendants violated Public Utilities Code Sections 702, 451 and/or Public Utilities Commission General Order 95, thereby making them liable for losses, damages and injury sustained by Plaintiff pursuant to Public Utilities Code Section 2106. 12.0 SIXTH CAUSE OF ACTION Violation of Health Safety Code ?l3007 (Against CORPORATION, PACIFIC GAS ELECTRIC COMPANY, and DOES 1 through 100) 12.1 Plaintiffs hereby re~allege and incorporate by reference each and every allegation contained above as though the same were set forth herein in full. 12.2 By engaging in the acts and omissions alleged in this Complaint, Defendants, and each of them, willfully, negligently, and in violation of law, set ?re to and/or allowed ?re to be set to the property of another in violation of California Health Safety Code 13007. 18 COMPLAINT FOR DAMAGES 12.3 As a legal result of Defendants? violation of California Health Safety Code I 13007, Plaintiffs suffered recoverable damages to property under California Health Safety Code 13007.21 12.4 As a further legal result of the violation of California Health Safety Code 13007 by Defendants, Plaintiffs suffered damages that are entitled to reasonable attorney?s fees under California Code of Civil Procedure 1021.9 for the prosecution of this cause of action. 12.5 Further, the conduct alleged against Defendant in this complaint was despicable and subjected Plaintiffs to cruel and unjust hardship in conscious disregard of their rights, constituting Oppression, for which Defendants must be punished by punitive and exemplary damages in an amount according to proof. Defendants? conduct was carried on with a willful and conscious I disregard of the rights and safety of Plaintiffs, constituting malice, for which Defendant must be punished by punitive and exemplary damages according to proof. An of?cer, director, or managing agent of personally committed, authorized and/or rati?ed the despicable and wrongful conduct alleged in this complaint. PRAYER FOR RELIEF WHEREFORE, Plaintiffs pray for judgment against Defendants, CORPORATION, PACIFIC GAS ELECTRIC COMPANY, and DOES 1 through 100, each of them, as follows: For Negligence, Trespass, Nuisance, Violation of Public Utilities Code 2106 and Violation of Health Safety Code ?13007 1. Repair, depreciation, and/or replacement of damaged, destroyed, and/or lost personal and/or real preperty; 2. Loss of the use, alternative living expenses, bene?t, goodwill, and enjoyment of . Plaintiffs? real and/or personal property; I 3. Loss of wages, earning capacity, and/or business profits or proceeds and/or any 3 related displacement expenses; 4. Past and future medical expenses and incidental expenses according to proof at trial; 19 COMPLAINT FOR DAMAGE-s ch?m-pWNHOWOO?mM-bmm?c 10. Attorney?s fees, expert fees, consultant fees, and litigation costs and expense, as allowed under California Code of Civil Procedure, Section 1021.9; Treble or. double damages for wrongful injuries to timber, trees, or underwood on their property, as allowed under California Civil Code, Section 3346; Punitive/exemplary damages; All costs of suit; Prejudgment interest, according to proof; and General damages for fear, worry, annoyance, disturbance, inconvenience, mental anguish, emotional distress, loss of quiet enjoyment of property, personal injury, dis?gurement, physical impairment, and for such other and further relief as the Court shall deem proper, all according to proof. For Inverse Condemnation 1. Repair, depreciation, and/or replacement of damaged, destroyed, and/or lost personal and/or real property; Loss of the use, bene?t, goodwill, and enjoyment of Plaintiffs? real and/or personal property; Loss of wages, earning capacity, and/or business pro?ts or proceeds, and/or any related displacement expenses; All costs of suit, including attorneys? fees where apprOpriate, appraisal fees, engineering fees, and related costs; Prejudgment interest according to proof; 20 coM?rLAINf-mR-?amacns \DoosJoxmme 6.. For such other and further relief as the Court shall deem proper, all according to proof. Dated: November 1, 2017 ROBINS CLOUD LLP By ?Zia-J: Bill Robins 111 Robert T. Bryson Kevin M. Pollack Donald 8. Edgar (SBN 139324) EDGAR LAW FIRM 408 College Avenue Santa Rosa, California 95401 Attorneys for Plaintiffs JURY TRIAL DEMAND Plaintiffs hereby demand a jury trial on all causes of action for which a jury is available under the law. Dated: November 1, 2017 ROBINS CLOUD LLP By? Bill Re?t-as 111 Robert T. Bryson Kevin M. Pollack Attorneys for Plaintiffs Donald S. Edgar (SBN 139324) EDGAR LAW FIRM 408 College Avenue Santa Rosa, California 95401 Attorneys for Plaintiffs 21 COMPLAINT FOR DAMAGES at 'an a 1. Check one box below for the case type that best describes this case: 3 CM sins State Bar number and address): FOR counr use ONLY ROBINS CLOUD LLP 808 Wilshire Boulevard,l Suite 450 I I) saw Mm? 4200 (310)566-5900 mt cm a Gama rs EPHONE no - FAX no: arrows: FOR (Namo): {?laintiffs A. Tandrup, et a1. Of San Handsco ISUPERIOR counros CALIFORNIA. counrv OF SAN FRANCISCO NOV 0 1 201-, STREET ADDRESS: 400 McAllister Street CITY AND San Francisco CA 94102 BRANCH NAME Civil Center Courthouse CASE NAME. Tandrup. et .al. v. Corporation, ct a1. . CASE COVER SHEET - Complex Case Designation ?EggUnlimited I: leltied . I: Counter El Joinder (Amount (Amount .luoce- demanded demanded is Filed with ?rst appearance by defendant exceeds $25,000) $25,000 or less) (Cal. Rules of Court. rule 3.402) DEPT: Items 1?6 belbw must be complemd (see instructions on page 2). Auto Tort Contract Provisionally Complex Civil Litigation - Auto (22) Breach of contracuwananw (05) (Cal. Rules of Court. rules 3.400-3.403) Uninsured motorist (46) Rule 3.740 collections (09) Antitrusthrade regulation (03) Other PIIPDMID (Personal InjuryIProperty Other collections (09) I . Construction defect (10) DamageMirongful Death) Tort Insurance coverage (13) - Mass tort (40) Asbestos (04) Other contract (37) C: Securities litigation (23) Product liability (24) Real Property Environmentalfl?oxic tort (30) Medical malpractice (45) [j Eminent Insurance coverage ciaims arising from the Other PIIPDIWD (23) . condemnation (14) above listed provisionally complex case NOII- (other) Tan [3 \Nl'Ol'ingl (33) types (41) Business terttunfair'btisiness practice (07) Other real property (26) Enforcement of Judgment Civil rights (03) Unlawful Detainer '3 Enforcement ofiudgment (20) El Defamation (13) Commercial (31) Miscellaneous Complaint El Fraud (16) Residential (32) moo (27) intellectual property (19) Drugs (33) Other complaint {not speci?ed above) (42) E3 Professl?nalnegligen?e125) Miscellaneous Petition Other (35) Asset forfeiture (05) Partnership and corporate governance (21) Em loyment C3 Petition re: arbitration award (11) :1 Other petition (not speci?ed above) (43) Wrongful lamination (36) I: Writ of mandate (02) Other employment (15) Other judicial review (39) 2. This case is Ll is not complex under rule 3 400 of the California Rules of Court. It the case is complex. mark the factors requiring exceptional judicial management: a. Large number of separately represented parties d. - Large number of witnesses b. Extensive motion practice raising diff cult or novel 9. Coordination with related actions pending in one or more courts issues that wiil be time-consuming to resolve in other counties. states. or countries. or in a federal court c. Substantial amount of documentary evidence f. Substantial postjudgmentjudicial supervision Remedies sought (check all that apply): a. [a monetary bi: nonmonetary; declaratory or injunctive relief 0. .punitive Number of causes of action (speci?r): Six (6) This case I: is is not a class action suit. if there are any known related cases. ?le and serve a notice of related case. (You may use form CM-015.) Date: November 1, 2017 2 - - . Bill Robins Esq. A7 (TYPE PEI-lift? OF PARTY OR ATTORNEY FOR PARTY) HOWE Plaintiff must file this cover sheet with the ?rst paper ?led in the action or proceeding (except small claims cases or cases ?led under the Probate Code Family Code. or Welfare and Institutions Code) (Cal. Rules of Court. rule 3.220.) Failure to ?le may result in sanctions. Fits 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. 0 Unless this is collections case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes only. .1 939'an smartest" CM- Dtol?ev Juiy1.2007 CM-010 INSTRUCTIONS ON HOW TO COMPLETE THE COVER SHEET To Plaintiffs and Others Filing First Papers. complete and ?le. along with your ?rst paper. the Civil statistics about the types and numbers of cases ?led. You one box for the case type that best describes the check the more speci?c one. If the case has mul To assist you in completing the sheet. examp sheet must be ?led only with your initial paper. 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 owed in a sum stated to be certain that is not more than $25,000. exc les 0 case. If the case ?ts both a general and a tiple causes of action. check the box that best indicates the primary cause of action. fthe cases that belong under each case type in item 1 are provided below. A cover Failure to ?le a cover sheet with the ?rst paper ?led in a civil case may subject a party. if you are ?ling a ?rst paper (for example. a complaint) in a civil case. you must Case Cover Sheet contained on page 1. This information will be used to compile must complete items 1 through 6 on the sheet. In item 1. you must check more speci?c type of case listed in item 1. under rule 3.740 is de?ned as an action for recovery of money lusive of interest and attorney's fees. arising from a transaction in which property. services. or money was acquired on credit. A collections case does not inciude an action seeking the following: (1) tort damages. (2) punitive damages. (3) recovery attachment. The identi?cation of a case as a ru time-for-service requirements and case management rules. unless a 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, of real property. (4) recovery of personal property. or (5) a prejudgment writ of Is 3.740 collections case on this form means that it will be exempt from the general defendant ?les a responsive pleading. A rule 3.740 collections 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 complaint on all parties to the action. A plaintiffs designation. a counter?designation that the case is not complex. the case is complex. Auto Tort . Ma (mi-Personal, immortal-1v DamageiiMengiui Death Uninsured; Motorist-i453 (tithe. casaf'im?roivesan uninsured motorist stain subject to arbitration. check this item insi'oadofAula} mr-mmomo (Persona! initial" Wrongful Death) Asbestos (04) Asbestos Property Damage AsbestosPersmal (river toxichnvimnmenta (24) Medical Malpractice (its medical Maipraetioeev Physicians 8: Surgeons Other Professtonai Health Care Malpractice Other . slip 8 . I) . intentionai Bodily assault. vandalism) Intentional in?iction of Emotional Distress Negligent in?iction of Emotional Distress 'Oti?ier'PiIPWD (Other) Tort Business Tort/Unfair Business Practice (07) Civil discrimination. Masses!) {not can baseman (08) . Defamation fag. stander. libel) (133 Fraud (18) intelleciuai Professorial Negligence (25) 34893.1 Memes Other Malpractice (not medical or legal) Other Tort (35) Employment Wrongful Termination (36) Other Employment (15) Clot-010 (Rev. July 1. 20071 items 1 and 2. If a CASE TYPES AND EXAMPLES Contract . Smash of Commanty (06) Breach of?o'ntallLease Contract (not unlawful deiainer ormongiul eviction}. Contactililisrrantyarsachusial . i-Plaintifi (not had ornegligence) Negligent Breach of Contract! Warranty- . OM Reach of Contra cllWerranty (Intentions (Bran-mm Med. open book aomunts) (99) Collection Cass-Setter-Piaintifi one: Promissory NoteiCoilections . Case insurancecoversge (not provisionally maples) (1 8) Auto Submaation Outer 6093:3913. Other Contract (37) Oemmuai Fraud Other Contract OW Real Property Eminent Doitrainilnverse Condemnation (Mi Wrongful Eviction (33) Other Real Property. (cg. quiet title) (26) Writ of Possession of ?Real Property Mortgage Forectosure? Quiet Title one: Real Property (not eminent demon. .iandlord'tsnant. or More) Unlawful Detainer Commercial (31) Residential. (32} Drugs (38) (if the case arms illegal times. Check this item; cinemas. report as Ceremonial or Residential) Judiciai Rwi'ew Asset Forfeitwsrijr Petition Re: Arbitration Award (1 i} Writ-of Mandate. Mandamus Wile-Mandamus on Limited Coiun Case Matter Writ-Other Limited Court Case Review Other Judicial Review (39) Review of Health Of?cer Order Notice of Appeal-Labor Missioner Appeals CIVIL CASE COVER SHEET laintiff designates a case as complex. the cover sheet must be served with the defendant may ?le and serve no later than the time of its first appearance a joinder in the or. if the plaintiff has made no designation. a designation that Provisionaliy Complex Civil Litigation (Cal. Rules of Court Rules 3.400?3.403) Regulation (03) Construction Defect (10) Claims Invoiving Mass Ten (40) Securities Litigation (2.8) EnvironrriernailTosic Tort. (30) insurance Coverage Claims (arising from provisionally complex case type listed above) (41) amendment of Judgment Enforcement of Judgment (20) Abstract of Jadgment- (Out of County) Confession of Judgment (non- domesl?lc relations) Sister State Judgment Administrative Agency Award (not unpaid taxes) PetitionlCeriificallon of Entry of Judgment: on Unpaid Taxes Odie?ggercemant of Judgment Citrii Complaint RICO (27) Other faint not a cl?e'd mamas) pa Wat. Ratio! Omit! injun {non- harassment) Mechanics tier!" Cater-?Commas! Complaint Case (Misti/noncomplex) Other Civil Complaint (non-tort/non-compiex) Miscellaneous Civil Petition Partnership and Corporate Gowmanoe (21) Other Petition (not specified above)" Civil Harassment Wonrpleoe Violence Eideri?ependeni Adult Abuse Election Contest Petition for Norrie Change Petition for Relief From Late Claim Other Civil Petition Page 2 of: