FRDM- T-SEE F-SSD



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05' Lil 4:1- UJ '0 '39 Lin CD

 

 

Roger B. Booth Bar No. 154691
Carly L. Sanchez Bar No. 300469

BOOTH ?5 
21250 Hawthorne Boulevard, Suite 475 I 
Torrance, CA 90503 . . .
310515-1361; Fax: 310540-0433 
Attorneys for Plaintiff 3/ 7/ 201 8
A. Rangel
By Fax

SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF RIVERSIDE

GAIL C., a minor by and through her
guardian ad litem, Marla C. Mahoney

RIC1804569

Plaintiff,
VS.









COMPLAINT FOR DAMAGES
COUNTY OF RIVERSIDE, NIKISHA I













 

BROWN, TIFFANI DAVIS, IRENE
MOLINA, ROSEANN MURO,
BRIETTA LOONEY, and DOES 1
through 50, inclusive

Defendants.

 

Plaintiff GAIL C., a minor by and through her guardian ad litem, Marla C. Mahoney, alleges

as follows:

1. Plaintiff Gail C. is a minor, a resident of the County of Riverside and a dependent of
the Juvenile Court of the County of Riverside. Her date of birth is December 13, 2013. On April
6, 2017, the Juvenile Court appointed attorney Marla C. Mahoney as Gail?s guardian ad litem with
regard to any lawsuit arising out of physical abuse or neglect suffered by Gail.

2. At the time of the events detailed below, defendants Nikisha Brown, Tiffani Davis,
Irene Molina, Roseann Muro, and Brietta Looney were social workers employed by defendant

County of Riverside in the Children?s Services Division of the Department of Public Social Services

 

Pleadings\Complaint.wpd
Complaint

 

03-02318 'll :04 FRDM- St 310-540-0433 P0004f00?l? F-SSD






 

 

These individuals, and the County of Riverside as a whole, will sometimes jointly be
referred to in this complaint as ?Defendants."

3. Plaintiff, through her guardian ad litem, presented a governmental claim to the
County of Riverside on August 17, 2017, and the County of Riverside rejected the claim on
September 12, 2017.

4. The true names of defendants sued as Does 1 through 50 are unknown to plaintiff.
These Doe defendants were the agents or employees of other named defendants and acted within the
scope of that agency 01' employment or are persons whose capacities are unknoWn to plaintiff.

5. Each defendant is the agent, servant andfor employee of the other defendants, and
each defendant was acting within the scope of his, her or its authority as an agent, servant andfor
employee of the other defendants. Defendants, and each of them, are individuals, corporations,
partnerships and other entities which engaged in, joined in and conspired with the other wrongdoers
in carrying out the tortious and unlawful activities described in this complaint, and defendants, and

each of them, rati?ed the acts of the other defendants as described in this Complaint.

Defendants? Failure to Protect Gail from Physical, Mental, and

Emotional Abuse and Severe Neglect

6. In December 2013, Gail?s mother admitted to using methamphetamine while
pregnant with Gail. While still hoSpitalized after Gail's birth, her mother was acting erratically
and showed signs of severe mental health disorders, including bipolar disorder and
schizophrenia. Gail?s mother revealed that she had stopped taking her medications
While pregnant with Gail, and that she did not see the need to continue taking those medications.
On or about January 14, 2014, the Los Angeles County Superior Court, Juvenile Court detained
Gail and placed her in the custody of the Los Angeles County Department of Children and
Family Services. On August 8, 2014, the Los Angeles County Superior Court, Juvenile Court,
ordered that Gail could be returned to her mother?s custody, as Gail and her mother lived
with Gail?s maternal grandmother. Despite this condition, Gail and her mother soon moved out

of the grandmother's home and began living on their 

 

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approximately June or July 2015, Gail's mother became pregnant. She again
stopped taking her medications and told several people, including DPSS social
workers, that she was not receiving any prenatal care for her unborn child and that she planned to
give birth in her home.

3. Throughout early 2016, DPSS received regular referrals alleging that Gail was the
Victim of abuse and neglect. Gail was living in a ?lthy home and was not being properly
supervised by her mother. Gail's maternal family members routinely called DPSS to inform
social workers that Gail?s mother suffered from bipolar disorder and schizophrenia, was not
taking her medications, and was refusing to allow the family members any access to Gail.

9. Although Defendants? subsequent investigations Were inadequate and improperly
performed according to the County?s own guidelines and standards, Defendants did develop
significant concerns regarding Gail?s mother?s mental health issues and her ability to care for
Gail. For example, on March 29, 2016, a Structured Decision Making Safety Assessment tool
was completed to determine whether it was safe for Gail to remain in her mother?s home. The
tool concluded that there was a high risk of abuse and neglect, and the tool's recommendation
was to promote the case open a DPSS case for Gail). Nevertheless, Defendants overrode
that recommendation and chose not to premote Gail?s case, on the basis that Gail's mother the
very woman who was being accused of abusing and neglecting her child - was not coOperating
with DPSS.

10. On April 5, 2016, defendant social worker Nakisha BroWn received an emergency
response referral alleging that Gail?s mother no longer appeared to be pregnant. The reporting
party further stated that she had not heard Gail cry or make any noise for approximately one
week. Ms. Brown and defendant social worker Tiffani Davis made an unannounced Visit to
Gail?s home. Gail?s mother opened the door in her underwear, looking fearful and anxious.
When she was told to put on clothes, she closed the door and refused to open it again. In her
contact note of that date, Ms. Brown wrote that she could not observe the inside of the home.
Later in that same note, Ms. Brown wrote the completely contradictory statement that she saw

Gail through the front door and that Gail did not appear to have any marks or bruises and did not

 

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appear to be afraid or distressed. Ms. Brown considered calling the police that day, but was told
not to by her supervisor, defendant Irene Molina. Gail was left in her mother?s care and home.

11. On April 19, 2016, Ms. Brown and defendant social worker Brietta Looney made
another unannounced visit to Gail?s home. Gail?s mother opened the door momentarily, before
slamming it in their faces. Despite this, Ms. Brown wrote in her contact note of that date that she
was able to observe Gail, who appeared dirty, but without any marks or bruises, and did not
appear to be in any distress. Later in the same contact note, Ms. Brown Wrote the contradictory
statement that she was not able to see into the home. She ?irther stated that she did not smell any
odors coming from the home.

12. On April 21, 2016, a neighbor ?agged down a passing police of?cer, complaining
of a strong, foul odor coming from the apartment where Gail lived with her mother. Based on
the odor, the neighbor believed there was a dead persun in the house. The of?cer gained entry to
the home and found Gail lying on a mattress next to a deceased infant. The of?cer stated that
Gail was hugging the corpse, which was mummi?ed and emitting a strong odor of decay. Gail's
mother insisted that the deceased infant was not dead, but was ?faking it? and stated that the
infant would be waking up seen.

13. As a result of repeated mental, emotional, and physical abuse and neglect, and the
failure of Defendants to protect her, Gail suffered severe physical, emotional and 

harm that will affect her for the rest of her life.

FIRST CAUSE OF ACTION - Violation of Child Abuse and Neglect Renertine Act

14. Plaintiff hereby incorpOra?tes by this reference all paragraphs of this complaint as
if fully set forth herein.

15. Pursuant to California Penal Code section 11165.7 and other provisions of the
California Child Abuse and Neglect Reporting Act Defendants, by and through
their employees and agents, are ?mandated reporters? with regard to any reasmlable suspicion of
child abuse, neglect or an unsuitable home. Defendants knew or reasonably suspected that

plaintiff had been subjected to mental, emotiOnal, and physical abuse and severe neglect and was

 

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Ix37.

 

 

living in an unsuitable home, and this gave rise to a duty to report this knowledge and suspicion,
including each separate instance of abuse and neglect (pursuant to Penal Code section 11166).
This duty also included cross-reporting to law enforcement and the District Attorney's of?ce.
Defendants failed to make such reports. In particular, Defendants failed to report the suspected
abuse and severe neglect of Gail when they learned that Gail?s mother was no longer pregnant in
April 2016 and that, therefore, Gail was likely living with a deceased newborn baby in the house.
Moreover, Defendants failed to properly train their employees regarding the duties of mandated
reporters.

16. Had Defendants properly reported the abuse and neglect of plaintiff and the fact
that she was living in an unsuitable home, this likely would have lead to law enforcement
conducting a further investigation, which would have lead to the discovery that Gail was living in
the home with a deceased infant. It further would have lead to the discovery that Gail?s mother
was completely unable to care for Gail due to her severe mental health problems. Gail?s mother
likely would have been given the help that she needed (and is currently receiving). This would
have prevented Gail from being subjected to nearly a month of living in the home with a
deceased child.

17. Additionally, Penal Code section 11166 requires DPSS to investigate reports of
suspected child abuse and severe neglect and to take further action when an objectively
reasonable person in the same situation would suspect child abuse. Here, DPSS failed to make
the required contacts with Gail and her mother, and failed to properly investigate reports that it
received that indicated that Gail was the victim of abuse and severe neglect. Moreover, the
information that DPSS did receive on those occasions when social workers went to Gail?s home
would have lead a reasonable person to suspect that Gail was being abused andfor severely
neglected. failure to take further action in light of this information resulted in Gail
suffering severe emotional distress from living with her deceased sister for an extended period of
time.

18. CANRA, as well as own rules, also require that, in response to each

referral of abuse or neglect, DPSS reach a meaningful conclusion as to whether the allegations

 


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to I?l I?ll I?l- n?are substantiated, inconclusive or unfounded, set forth that conclusion in writing and report all
substantiated ?ndings to the California Department of Justice (With notice to the perpetrator).
Defendants violated this requirement by falsely stating that the abuse and neglect allegations
involving Gail were inconclusive, due to the fact that Gail?s mother would not cooperate with the
investigation, despite the fact that Defendants acknowledged that there was a high risk that Gail
would be neglected and abused. This false ?inconclusive? label made it far less likely that social
workers, law enforcement of?cers, and others Who subsequently interacted with Gail and her
mother would take the abuse and neglect allegations seriously and take appropriate action.

19. Pursuant to Government Code sections 815.2(a) and 320 and Evidence Code
section 669, the individual social worker defendants are liable for violating CANRA and the
County of Riverside is vicariously liable for these violations.

20. As a result of Defendants? violaticn of CANRA, plaintiff sustained injuries and

damages as alleged herein.

SECOND CAU ACTION Breach of Mandate Duties

21. Plaintiff hereby incorporates by this reference all paragraphs of this complaint as
if set forth fully herein.

22. In addition to CANRA, Defendants violated various other mandatory duties
intended to protect children from abuse and neglect and are therefore liable for plaintiffs injuries
pursuant to Government Code sectioa 815.6. These mandatory duties included, but were not
limited to, the following:

Welfare Institutions Code Section 16501.1, which required a case plan to
ensure that Gail received protection and prOper care and that apprOpriate services
were provided to Gail and her mother, with the child?s health and safety being the
paramount concern;

California Department of Social Services regulation Ell?125.1, which
required DPSS to determine whether Gail was at risk of abuse or neglect and in

need of child welfare services or removal from the home;

 


6 Cumplaint

 

 ll :33 



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DPSS regulation 31425.2, which required DPSS to have in?person contact with
Gail and at least one adult who had information regarding the allegations;

DPSS regulation 31-205, which required DPSS to gather, evaluate and document
assessment information pertaining to other significant persons who were known to
reside in the same home as plaintiff, including, but not limited to, Gail?s mother;
CDSS regulation 31-205, which required DPSS to gather, evaluate and document
information as to whether Gail could safely remain in her family home, by taking
actions which include, but are not limited to, completing SDM Safety and Risk
Assessments within two days of receiving a referral;

CDSS regulation 31?310, which required DPSS to monitor Gail?s physical and
emotional condition and to take necessary action to ensure that her protective
needs continued to be met;

CDSS regulation 31-320, which required DPSS to adequately conduct face-to-
face contacts with Gail and to assess her safety and well?being;

CDSS regulation 31-335, which required DPSS to have contact with other
professionals working with Gail and her mother in order to monitor the safety of
the child and obtain their perception of the child?s well?being and in order to
determine whether the parent is following through with her commitments;

CDSS regulation 31-501, which required DPSS to report every known or
suspected instance of child abuse andIor neglect to law enforcement; and

The Riverside County Children?s Services Handbook, Module 1, Chapter 2,
Section A, which required DPSS employees, agents, and staff to document all
contacts made within ?ve business days.

Defendants breached each of the aforementioned mandatory duties by, among

other acts and omissions, failing to report the ongoing abuse and neglect, failing to have any in-

person contact with Gail and others residing in the home with her, failing to conduct a

meaningful investigation concerning the abuse and neglect, and failing to provide necessary child

welfare services. These breaches of duty contributed to the ongoing mental, emotional, and

 

Pleadings\Complaint.de

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maximum?tame.)

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physical abuse and severe neglect of Gail.
24. As a result of Defendants? violation of mandatory duties, plaintiff sustained

injuries and damages as alleged herein.

THIRD CADSE OF ACTION Breach of Duty Arising Under Special Relationship

25. Plaintiff hereby incorporates by this reference all paragraphs of this complaint as

if fully set forth herein.

26.- A special relationship was established between Defendants, on the one hand, and
both Gail and her mother, on the other hand, by virtue of Defendants having entered upon the
task of protecting Gail. This induced reliance and dependence on the part of Gail and her
mother, who reasonably believed that Defendants would protect Gail.

27. Defendants increased the danger to Gail by ratifying, sanctioning and encouraging
Gail?s mother to continue her pregnancy without any prenatal care, to give birth in her home, and
to continue to care for Gail despite the fact that she was not taking any of her prescribed
medications. Defendants knew or should have known that Gail?s mother suffered
from severe mental illnesses, including schizophrenia and bipolar disorder, and had little or no
ability to protect her children and was therefore dependent upon Defendants to take control of the
situation.

28. As a result of the special relationship between Defendants and Gail and her
mother, Defendants owed a duty to exercise reasonable care. Defendants breached that duty, as
discussed above, by failing to take meaningful steps to protect Gail from mental, emotional, and
physical abuse and neglect. I Among other acts and omissions, Defendants falsely stated that the
abuse and neglect allegations against Gail?s mother were inconclusive, allowed Gail to remain in
the home with her mother, failed to report the abuse and neglect to DPSS, law enforcement or the
District Attorney?s office, failed to have any in?person contact with Gail and others living in the
home with her, and failed to provide any ongoing supervision of Gail. Defendants never
seriously considered trying to remove Gail from the home and never made a discretionary

decision to allow her to remain in the home. They simply refused to do their jobs and instead

 

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@wqmmemm

 

looked for any opportunity to close their ?les and avoid taking meaningful action.

 


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29. As a result of Defendants? breaches of the duties arising under the special
relationship, plaintiff sustained injuries and damages as alleged herein.
WHERE-FORE: Plaintiff prays for judgment against Defendants as follovirs:
1. For compensatory damages according to proof; 
2. For costs of suit;
3. For interest according to law;
4. For such other relief as is fair, just, and equitable.
Dated: March 6, 2013 BOOTH a KOSKOFF
By: 
. he: f/
Attorne ~fersP?lai?t1ff
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9 Complaint

 

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JURY DEMAND

Pursuant to Code of Civil Procedure section 631, plaintiff demands a jury trial on all

issues so triable.

Dated: March 6, 2018 BOOTH 6?s KOSKOFF

By ?at/WW5
Carly? L. SW
Attorneys or Plaintiff



I?l s?I- I?l s?Pleadingsm?empleint.wpd

 

 

1 0 Complaint

 

 11:0? FRDM- 3t 310-540-0433 T-SEE F-SBD

 

 

 

 

 

 

 

DR PARTY WITHDI IT {Mannie Shem th' mlml?mr. .i'mr'f FDR CHURT USE ONL CM 010
Roger B. Booth - Bar No. 154691; Carly L. Sanchez - Bar No. 300469
Booth Koskoft?
21250 Hawthorne Boulevard, Suite 475, Torrance, CA 90503
TELEPHONE FAX 
FDFI {Nameerlaintiff Gail C.
susenion count or CALIFORNIA, couurv or RIVERSIDE
AnunEss:4050 Main Street, Riverside, CA 92501
MAILING ADDRESS:
CITY mo ZIP coosrkiverside, CA 92501
BRANCH NAME:Riversidc Historic Courthouse
CASE NAME: Gail C. v. County of Riverside, et :11.
CASE COVER SHEET Com lex Case Desi nation CASE Nu?:
Unlimited Limited IC 1 804569
(Am?unt (Amount Gaunter 
demanded demanded is Filed with first appearance by defendant 
exceeds $25,000) $25,000 or less) (Cal. Ftules of Court, rule 3.402) DEPT:

 

 

ltems 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 Provtsionally Complex Civil Litigation
Auto (22) El Breach of contract/warranty (05) (Cal. Rules ot Court, rules 3300?3303)

Uninsured motorist (46) El Ftule 3.740 collections (09) El regulation (03)

Other (Personal Other collections (09) El Construction defect (10)
Damage/Wrongful Death) Tort Insurance coverage (13) Mass tort (40)

Asbestos (04) I: Other contract l:l Securities litigation (23)

Product liability (24) He at Property Environmental/Toxic tort (30)

Medical malpractice (45) El Eminent Insurance coverage claims arising from the
0mm pupmwo (23) condemnation (14) above listed provisionally complex case
(other) Tort i:l Wrongful eviction (33) 

Business torllunfair business practice (07) Other real property (26) Enforcement ?1 Judgment

Civil (tame (03) Ho la wtui oeteiner l:l Enforcement ofiudsment (20)

El Defamation (13) El (31) Miscellaneous Civil Complaint

Fraud (is) Residential (32) atco (27)

CI Intellectual property (19) 90105 (33) Other complaint (notspeci?ed above) (42)
Professional negligence (25) Judicial REVIEW ?melting? Civil Petltlon

cther non- tort (as) Asset forfeiture (05) pannerghip and comma?, governancg (21)
Employment l:l Petition re: arbitration award (11) El Other petition above) (43)

Wrongful termination (36) El Writ of mandate (02)

El Other employment (15) Other iudicial review {39}

 

2. This case l:l is 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. IZI Large number of separately represented parties d. l:l Large number of witnesses

b. Extensive motion practice raising difficult or novel a. El Coordination with related actions pending in one or more courts
issues that will be timeeconsuming to resolve in other counties, states, or countries, or in a federal court

0. El Substantial amount of documentary evidence f. l:l Substantial posljudgment judicial supervision

 

 

 

3. Remedies sought (check all that apply: monetary nonmonetary; declaratory or injunctive relief c. mounitive
4. Number of causes of action 
5. This case i: is is not a class action suit.
6. If there are any known related cases, file and serve a notice of related case. You may use form (EM-015.)
DateiMarch 6, 2018
Cat-Iv L, Sanchez Bar No. 300460 
(TYPE DH PFIINT NAME) FDR PARTY)
NOTICE 

. Plaintiff must file this cover sheet with the first paper filed in the action or proceeding (except small claims cases or cases filed
under the Probate Code, Family Code, or Welfare and institutions Code). (Cal. Flutes of Court, rule 3.220.) Failure to file may result
in sanctions.

. File this comer sheet in addition to any cover sheet required by local court rule.

- if this case is complex under rule 3.400 at seq. of the California Flutes of Court, you must serve a copy of this cover sheet on all
other parties to the action or proceeding.

I Unless this is a collections case under rule 3.740 or a complex case, this cover sheet Will be used for statistical purposes only

 

 

 

. ago 1 of 2

Form Adopted lor Mandatory Lieu Cal. Pulse of Court, rules 2.80, 3.220, brim-0.400. 3.740:
Judicial Council oi California IVIL CASE COVER SH EET Cal. Standards of Judicial Administration. std. 3.10
GMr-?l? [Rem July 200?] ww.caurti'nfo.m.gotr

Westlew ?rst: 81 Form Builder

 it FRDM- 3i Sill-ElliD-D?i?? T-SEE PDD?l?ig?DDi?l F-SBD

INSTRUCTIONS on How To COMPLETE THE coves SHEET Gilli-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 file, along with your first paper, the Civil Case Cover Sheet contained on page i. This information will be used to compile
statistics about the types and numbers of cases filed. You must complete items 1 through 3 on the sheet. In item 1, you must check
one box for the case type that best describes the case. If the case fits both a general and a more specific type of case listed in 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 filed only with your initial paper. Failure to file a cover sheet with the first paper filed 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 $25,000, exclusive 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 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 form means that it will be exempt from the general
time-for-service 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 Flules of Court, this must be indicated by
completing the appropriate boxes in items 1 and 2. If a plaintiff designates a case as complex, the collar sheet must be served With the
complaint on all parties to the action. A defendant may file and serve no later than the time of its first appearance a joinder in the
plaintiff's designation, a counter-designation that the case is not complex, or, if the plaintiff has made no designation, a designation that

the case is complex.

Auto Tort

Auto (22)?Personal 
Damagelwi-ongiui Death

Uninsured Motorist (43) (if the
case involves an uninsured
motorist claim cubic ct to
arbitration, check this item
instead of Auto)

Other (Personal Injuryl
Property Death)
Tort

Asbestos (04)

Asbestos Property Damage
Asbestos Personal Injury!
Wrongful Death

Pmduct Liability {not asbestos or
toxic/err vironm ental) (24)

Medical Malpractice (45)

Medical Malpractice?
Physicians at Surgeons

Other Professional Health Care
Malpractice

Other (23)

Premises Liability slip
and fall)
Intentional Bodily 
assault, vandalism)
Intentional lniliction of
Emotional Distress
Negligent lniliction of
Emotional Distress
Other 
(Other) Tort
Business TortlUnfair Business
Practice (07)

Civil Flights discrimination,
false arrest) {not civil
harassment) (03)

Deta?gslgon slander, libel)

Fraud (13)
Intellectual Property (13)
Professional Negligence (25)
Legal Malpractice
Other Professional Malpractice
(not medical or legal)
Other Tort (35)
Employment
Wrongful Termination (36)
Other Employment (15)

cM-o1o (Ftev. July 1. zoo?)

CASE TYPES AND EXAMPLES
Contract
Breach of ContracllWarranty (OS)
Breach of FlentallLease
Contract (not unlawful detainer
or wrongful eviction)
Contractharranty Breach?Seller
Plaintiff (not fraud or negligence)
Negligent Breach of Contractl
Warranty
Other Breach of Contract/Warranty

Collections money owed, open
book accounts) toe)

Collection CasewSeller Plaintiff
Other Promissory NotelCollections
Case

Insurance Coverage (not provisionally
complex) (13)

Auto Subrogation
Other Coverage

Other Contract (37)
Contractual Fraud
Other Contract Dispute

Real Property

Eminent 
Condemnation (14)

Wrongful Eviction (33)

Other Fleal Property quiet title) (26)
Writ of Possession of Real Property
Mortgage Foreclosure
Quiet Title
Other Fleal Properly {not eminent
domain, landlord/tenant, or
foreclosure)

Unlawful Detainer

Commercial (31)

Residential (32)

Drugs (38) (it the case involves illegal
drugs, check this item: otherwise,
report as Commercial of Residential)

Judicial Ftevlew

Asset Forfeiture (05)

Petition Fla: Arbitration Award (11)

Writ of Mandate (02)
Writ?Administrative Mandamus
Writ?Mandamus on Limited Court

Case Matter
Writ?Other Limited Court Case
Fteview

Other Judicial Review 39)

Fleview of Health flicer Order
Notice of Appeal?Labor
Commissioner Appeals

CIVIL CASE COVER SHEET

Provisionally Complex Civil Litigation (Cal.
Flutes of Court Rules 3.400-43.403)
Regulation (03)
Construction Defect (10)
Claims Involving Mass Ten (40)
Securities Litigation (28)
EnvironmentaIlToxic Tort (30)
Insurance Coverage Claims
{arising from provisionally complex
case type listed above) (41)
Enforcement of Judgment
Enforcement of Judgment (20)
Abstract of Judgment (Out of
County)
Confession of Judgment (non-
dom esltc relations)
Sister State Judgment
Administrative Agency Award
(not unpaid taxes)
PetitionlCertitication of Entry of
Judgment on Unpaid Taxes
Other Enforcement of Judgment

Miscellaneous Civil Complaint
(27)
Other Complaint (not specified
above) (42)
Declaratory Relief Only
lnjunctive Relief Only (none
harassment)
Mechanics Lien
Other Commercial Complaint
Case (conformed-complex)
Other Civil Complaint
(non-tort/nonecomplex)
Miscellaneous Petition
Partnership and Corporate
Governance (21)
Other Petition {not specified
above} (43)
Civil Harassment
Workplace Violence
Eider/Dependent Adult
Abuse
Election Contest
Petition for Name Change
Petition for Ftelief From Late
Claim
Other Civil Petition

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