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SUPERIOR COURT OF CALIFORNIA
COUNTY OF RIVERSIDE

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Attorney for PlaintiffJohn Villani

NOV 2 9., 2016
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SUPERIOR COURT OF THE STATE OF CALIFORNIA

9

FOR THE COUNTY OF RIVERSIDE

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PALM SPRINGS BRANCH

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Case No:

JOHN VILLANI, an individual,
vs.

COMPLAINT FOR DAMAGES FOR
VIOLATION OF LABOR CODE§ 1102.5

Plaintiff,

PALM SPRINGS UNIFIED SCHOOL
DISTRICT, a public entity, and DOES 1-5,
17 Inclusive,
16

PSC · 16 l) 6 0 7'2·'

DEMAND FOR JURY TRIAL

Defendants.

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Plaintiff John Villani ("Villani"), complaining of Palm Springs Unified School District

("School District"), respectfully alleges as follows:

INTRODUCTION
1.

Summary. In February 2016, David Yoder, a former teacher's aide at the Palm

24 Springs Unified School District, was convicted of multiple felony counts, including committing

25

26

27
28

oral copulation with a minor, involvement in child pornography, inducing a minor to engage in

commercial sex acts, and lewd and lascivious acts with a minor under age 14. Some of this could

have been prevented had �chool officials paid heed to the reports and complaints of Plaintiff

John Villani. Villani, a special education teacher at the School District, spent over a year
Complaint for Damages (Villani v. Palm Springs Unified School District)
1

ORIGINAL

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 1 reporting his suspicions that Yoder was potentially engaged in inappropriate sexual conduct with
2

students. For reasons unfathomable to Villani, school administrators rallied around Yoder, failed

3

and refused to investigate Yoder's behavior, and retaliated against Villani, ultimately forcing

4

him to resign from the School District in June 2014 to avoid-a threatened termination. The

5

School District then blackballed Villani, interfering with his efforts to find other local

6 employment. The School District's conduct, besides being morally reprehensible, violated Labor
7 Code§ 1102.5. Villani brings this action for constructive discharge in violation of§ 110_2.5 and
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seeks lost past and future wages and emo_tional distress damages. Plaintiff also seeks recovery of

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attorney's fees under California Code of Civil Procedure ("C.C.P.")§ 1021.5.

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THE PARTIES AND KEY ACTORS
2.

Defendant Palm Springs Unified School District. Palm Springs Unified School

District ("School District"), is a government entity and school district in the Coachella Valley

14 region of Southern California. It employs in excess of 2000 employees. The School District is
15
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governed by a five-person elected Board of Education.
3.

Center for Learning and Development. The Center for Learning and

17

Development ("Center") was a school for developmentally disabled, mentally disabled and

18

special needs children. It was a. subdivision of and operated by the School District. It was located

19 in Desert Hot Springs, California, in Riverside County. The Center was shut down in the
20

summer of 2013.

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4.

Della Lindly Elementary School. Della Lindly Elementary School ("Della

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Lindly") is an elementary school within the School Dis.trict's system. It is located in Thousand

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Palms, California, in Riverside County. The Center's programs were transferred to Della Lindly

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at the beginning of the 2013-2014 school year.

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5.

Plaintiff Villani. Plaintiff John Villani ("Villani") is an individual 'now resi_ding in
.
.
26 the State ofldaho, County of Ada. From 2011 to 2014, Villani resided in Riverside County and
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was an employee of the School District. Villani started working the Center in January 2012, at

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the beginning of the Spring semester of the 2011-2012 school year. From 2012 to 2014 he served
Complaint for Damages (Villani v. Palm Springs Unified School District)
2

 1

as a credentialed intern at three schools in the School District: the Center, Della Lindly, and Mt.

2 San Jacinto High School in Cathedral City. Villani was a student at National University while
3

employed by the School District, and was earning his teaching credential at the time. His teacher

4 and credentialing program supervisor at National University was Robert Kawka. As an educator,
5

Villani was a "mandated reporter" within the meaning of the California Child Abuse and Neglect

6 Reporting Act ("CANRA"), Cal. Penal Code § § 11164 et seq.
7

6.

Christine Anderson. Christine Anderson ("Anderson") was at relevant times the

8

Superintendent of the School District. As Superintendent, she was the highest ranking staff

9

member of the District. Villani is informed and believes and thereon alleges that at all relevant

10 times Anderson resided in Riverside County. Villani is also informed and believes that Anderson
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retired from her Superintendent position in early 2016. As an educator, Anderson was a CANRA

12

"mandated reporter."

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7.

Kathy Little. Kathy Little ("Little") was at relevant times tl}e Director of Special

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Education for the School District, and the Principal at the Center. Villani is informed and

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believes and thereon alleges that at all relevant times Little resided in Riverside County. Little

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continued to serve as Director of Special Education after the programs were moved to Della

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Lindly (see 14 above). As an educator, Little was a CANRA "mandated reporter."

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8.

Debra Sather. Debra Sather ("Sather") was at relevant times Villani's immediate

19 supervisor at the Cent�r. Sather was a program specialist at the Center. Villani is informed and
20

believes and thereon alleges that at all relevant times Sather resided in Riverside County. As an

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educator, Sather was a CANRA "mandated reporter."

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9.

Dr. Simon Kovats. Dr. Simon Kovats ("Kovats") was at relevant times the

Principal of Della Lindly Elementary School, where the School District's special education

24 programs were housed beginning in the Fall semester of the 2013-2014 school year. Villani is
25 informed and believes and thereon alleges that at all relevant times Kovats resided in Riverside
26
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County. As an educator, Kovats was a CANRA "mandated reporter."
10.

Elena LaBautista. Elena LaBautista was at relevant times, an "employee" of the

28 School District and a supervisor in its Mental Health Department. She was a mental health
Complaint for Damages (Villani v. Palm Springs Unified School District)
3

 1

therapist assigned to assist with Villani's case load. Villani is informed and believes and thereon

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alleges that at all times relevant, LaBautista resided in Riverside County. As an educator,

3

LaBautista was a CANRA "mandated reporter."

4

11.

Mauricio Arellano. Mauricio Arellano ("Arellano") was at relevant times, an

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Assistant Superintendent of Human Resources at the School District. Villani is informed and

6

believes and thereon alleges that at all relevant times Arellano resided in Riverside County. As

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an educator, Arellano was a CANRA "mandated reporter."

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12.

Janice Ruetz. Janice Ruetz ("Ruetz") was at relevant times an employee of the

School District and in the Director of Paraprofessionals (i.e., teacher-aides) at the Center and

1 O Della Lindly. Villani is informed and believes and thereon alleges that at all relevant times Ruetz
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resided in Riverside County. As an educator, Ruetz was a CANRA "mandated reporter."
13.

John Yoder. John Yoder ("Yoder") was employed by the School District as a

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paraprofessional classroom special education aide at the Center from approximately 2010

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through the end of the 2012-2013 school year. Yoder was employed as a classroom special

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education aide at Della Lindly beginnjng with the start of the 2013-2014 school year. Villani is

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informed and believes, and based on such information and belief alleges, that at all relevant

17 times, to Yoder resided in Riverside, County. Yoder is approximately 44 years old. He was also a
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foster parent of one or more children who resided with him at his Riverside County home.
14.

Child Doe. Plaintiff Villani refers to this individual by the fictitious name Child

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Doe because he is a minor and Villani seeks to preserve his privacy and confidentiality; and

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because he was the victim of sexual abuse by Yoder. Child Doe was a student at the Center from

22 approximately January 2013 until July 2013. Child Doe has a serious mental disability. At the ·
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time of the events described in this Complaint, Child Doe was 12 years old, but had the mental

24 capacity of a 6-year old.
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15.

Fictitiously Named Defendants. The true names and capacities of Defendants

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named herein as DOES 1 through 5, inclusive, whether individual, corporate, associate, or

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otherwise, are unknown tq Plaintiff Villani, who therefore sues such Defendants by fictitious

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Complaint for Damages (Villani v. Palm Springs Unified School District)
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names pursuant to California Code of Civil Procedure §474. Plaintiff will amend this Complaint

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to show such true names and capacities if and when they have been determined.

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16.

Defendants Acting Within Scope of Agency. Plaintiff Villani is informed and

4 believes and upon such information and belief alleges that Defendants, and each of them, except
5

to the extent expressly stated otherwise, were the agents, employees, servants, joint ventures

6 and/or co-conspirators of the remaining Defendants and were acting in the course and scope of
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such agency, employment, joint venture and/or conspiracy; that the Defendants, and each of

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them, who were doing the things alleged, were the actual and/or ostensible agents of the

9 remaining Defendants and were acting within the course and scope of said agency; and that each
10 and every Defendant approved, supported, participated in, authorized and/or ratified the acts
11 and/or omissions of said employees, agents, servants, conspirators, and/or joint venturers.
12
RELEVANT FACTS

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17.

Villani's Responsibilities. From approximately January 2012 until Spring 2013

15 Villani was employed by the District as a special education teacher / case manager at the Center.
16 He was responsible for a class of approximately 3-6 students in grades 1-5. His responsibilities
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included helping developmentally and mentally disabled children reach their academic goals,

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managing and supervising paraprofessionals (teacher-aides), and communicating with

19 administrators who had responsibilities over the Center.
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18.

Villani's Training in Detection of Sexual Abuse. California maintains training

21 standards for public school teachers. Among other things, teachers are required to undertake
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training in the detection of sexual abuse. Villani took such training. Villani is informed and

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believes, and based on such information and belief alleges that Anderson, Little, Sather, Kovats,

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LaBautista, Ruetz and Arellano also took this training.

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19.

Yoder is Assigned to Villani's Class. Yoder was assigned as a teacher-aide in

26 Villani's classroom from the inception ofVillani's employment with the School District during
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the 2011-2012 school year.

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Complaint for Damages (Villani v. Palm Springs Unified School District)
5

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20.

Villani Observes Troubling Conduct by Yoder. Soon after he began his

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employment with the District, Villani began to observe _Yoder engage in suspicious and

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inappropriate conduct. Among other things, he observed Yoder usin:g school computers to search

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for young boys to adopt. Villani asked him to stop those activities, but Yoder answered "I �ant

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to find a beautiful boy to add to my collection."

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21.

Villani Complains to Sather. Villani brought Yoder's troubling behavior to

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Sather's attention in April 2012, advising her of Yoder's inappropriate conduct. Sather told

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Villani to "think nothing of it," and that David "is a good man." This was the first of many

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verbal and written reports, complaints and objections made by Villani that were rebuffed by

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Sch9ol District management.
22.

Yoder's Inappropriate Conduct Continues. Throughout the remainder of the

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2011-2012 school year ,Villani observed Yoder engage in inappropriate conduct with young

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male students. Villani· continued to report to Sather that he was concerned that Yoder made

· 14 inappropriate sexual comments, but Sather fold him only to "manage [his] people better."
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23.

2012 Fall Semester.Villani returned to the Center in the Fall semester of the

16 2012-2013 school year. Yoder also returned as _a teacher's aide, and continued to engage in the
17 · same type ofinappropriate verbal conduct Villani had observed the previous school year. Villani
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asked Sather to speak with Yoder about Villani's concerns, but Sather declined to do so.
24.

Child Doe Enters Villani's Class. In November 2012, Villani learned that Child

20 Doe would be entering the class in January 2013. Even before the student arrived, Yoder took an
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immediate interest in him and told Villani, "I get to work with the new boy, because he will love

22

me more." Again, Villani reported this to Sather, and Sather told Villani that Yoder should be

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allowed to work with Child Doe. When Child Doe joined the class in January 2013, Yoder

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formed an immediate attachment with Child Doe, paying undue and excessive attention to him

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while ignoring the needs of other students. Yoder often whispered into Child Doe's ear, and kept

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in close physical proximity to him. Yoder also learned information causing him to suspect that

27 Yoder was bringing Child Doe to his home, in violation of school rules.
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Complaint for Damages (Villani v. Palm Springs Unified School District)
6

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25.

Villani Again Voices Concerns to Management About Yoder. After Child Doe

2 joined Villani's class, Villani again complained to management about Yoder's inappropriate
3

behavior. This time, he complained not only Sather but to Little as well. He told them he was

4 concerned that Yoder violated school rules by bringing Child Doe into his home, and asked that
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they investigate his suspicions. He also told them Yoder acted insubordinately and consistently

6 ignored his (Villani's) directives and instructions, and asked that Little and Sather intervene.
7 They refused to do anything, told Villani he was worrying needlessly, and refused to investigate
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Villani's concern that Yoder was bringing Child Doe to his home.
26.

Management Ignores New Round of Complaints. For the remainder of the

Spring semester (January- June, 2013), Yoder continued to pay inordinate attention to Child

11 Doe, and engaged in other forms of questionable conduct as well. On one occasion, Child Doe
12 yelled at Yoder about something that had occurred at Yoder's home over the weekend. On
13

another, Child Doe came to school _and yelled: "I will tell on you if you make me do any work

14

today." Concerned about potential sexual misconduct by Yoder, Villani reported this to Sather,

15

who instructed Villani not to interfere with the "progress" that Yoder was making with Child ·

16 Doe. In May, Sather authorized Yoder to work one-on-one with Child Doe in a separate
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classroom, even though this violated school protocols. On one occasion, Yoder commented

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about the "great physiques" of young boys at a neighboring middle school, expressing a desire to

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"manage them." Villani asked Yoder not to make these types of comments, and reported them to

20 Sather. At one point he told Sather, LaBautista and Dawn Castiglione (an occupational therapist
21 employed by the District) that he hoped Yoder does not molest any young boys, and expressed
22

frustration that the School District was not investigating Yoder. His comments were dismissed

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and ignored. During this school year, Sather told Villani to stop "harassing" Yoder. She asked

24 Villani if he hated Yoder because Yoder was gay; Villani responded that he did not know Yoder
25 was gay, and was concerned only with Yoder's inappropriate behavior with the students. During
26 this school year, Villani also shared his concerns with Superintendent Anderson and Assistant
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Superintendent Arellano, and complained to them that his supervisors had refused to investigate

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Complaint for Damages (Villani v. Palm Springs Unified School District)
7

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his complaints or take them seriously. As before, his concerns were ignored, and no investigation

2

was initiated.

3

27.

Report to Child Protective Services. In Spring 2013, Villani verbally reported his

4 reasonable suspicions about Yoder to the Palm Springs Child Protective Services ("CPS"). CPS
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did not ask Villani to submit a written report. Fearful that the School District's hostility to his ·

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reporting might result in retaliation from Sather or Little, he did not put his complaint in writing.

7

28.

Center Programs Transferred to Della Lindly. In about June 2013, Villani

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expressed concerns to management that it would be difficult for him to return to the classroom if

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Child Doe and Yoder were not separated. Over the summer, the School District transferred the·

10

Center's programs to Della Lindly. When Villani returned to work at Della Lindly in about

11 August 2013 for the Fall semester, Child Doe remained in Villani's class, and Yoder continued
12

to work for the School District but in a different assignment. Yoder continued to have access to

13. Child Doe.
14
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29.

Villani Observes Continuing Inappropriate Conduct by Yoder. At the .

beginning of the 2013-2014 school year, Villani learned that Child Doe had spent the night at

16 Yoder's home. Villani reported this to Arellano, who told him to speak with Little and comply
17

with Little's directives. Villani reported this to Little, who did nothing. In May 2013, Villani sent

. 18

Sather and Little a log of incidents in his class that included reports of suspected misconduct by

19 Yoder. He never heard back from Sather or Little about it.
20
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30. · .. Retaliation. As a result of his complaints at,out Yoder, the School District
retaliated against Villani.
(a)

Negative Evaluations and Threat of Retaliation. As a candidate for a

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teaching credential, Villani received evaluations from Little and Kawka. His evaluations

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were excellent until about November 2013. At that time, Little began to give Villani

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unjustifiably critical evaluations in retaliation for his repeated reports, disclosures and

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complaints about Yoder. In particular, Little criticized Villani for how he handled his

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paraprofessionals. Kqvats also gave Villani unjustified negative evaluations. Villani

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complained to Arellano, who said to him something to the effect of "you just couldn't let
Complaint for Damages (Villani v. Palm Springs Unified School District)
8

 1

your concerns about David [Yoder] go and you would not follow your supervisor's

2

directions. You can resign now or we could fire you in which case you will have a bad

3

chance of getting a job elsewhere."

4

31.

5

Threat of Termination. On about April 29, 2014, Villani met with Arelleno,

Tony Signoret (an assistant superintendent), and Mark Acker (a union representative) in

6 Arellano's office. At the meeting, Arelleno criticized Villani for how he handled his
7 paraprofessionals, criticizing him for have "harassed" Yoder and not managing another
8

paraprofessional. Arellano then told Villani he would be terminated because of his conduct

9

toward Yoder and another paraprofessional, unless he chose to resign instead. Arellano said

10

either you can finish the year out on administrative leave or we have a place for you; the

11 District's alternative high school (Mt. San Jacinto). Villani responded that he was not going to
12

go out on leave as if he was guilty of something, and wanted to continue working with kids.

13

Villani told Arellano he was making a mistake in accusing him (Villani) of wrongdoing toward

14

the two paraprofessionals.

15

32.

Transfer. Villani was transferred to Mt. San Jacinto High School for the

16

remainder of the year. That school did not have a formal position for Villani and he was utilized

17

as. an "Intervention Teacher" on a sporadic basis, spending most of his time with nothing to do.

18

Villani resigned from the School District in about June 2014, at the end of the 2013-2014 school

19

year, on threat of termination.

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33.

Blackballing. After resigning, Villani sought employment with other school

21

districts in the Coachella Valley. Although he had a superior resume, and many positive

22

interviews, he was repeatedly rejected for employment by other school districts. Villani is

23 -informed and believes, and based on such information and belief alleges, that members of
24

School District management made false and disparaging statements about him, and reported to

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prospective employers that Villani made false accusations against other School District

26

employees. Unable to obtain employment in the Coachella Valley area, he applied for jobs
I
elsewhere, ultimately find a job in Boise, Idaho. He moved to Boise in 2014.

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Complaint for Damages (Villani v. Palm Springs Unified School District)
9

 I

·.

.

1

34.

.

I

Yoder is Arrested and Charged with Child Pornography. In February 2015,

2 David Yoder was arrested in Riverside and charged with involvement in a child pornography
3

ring. Charges included violations of Penal Code§ 288a (oral copulation with a minor under age

4

14), Penal �ode§ 236.1 (attempt to induce minor to engage in co�ercial.sex act), Penal Code

5 § 182 (conspiracy to commit crime of using minors to perform sex acts), Penal Code§ 288(a)
6

(lewd and lascivious acts with minor under age 14), and Penal Code§ 32 (harboring another

7

individual with knowledge the individual committed child pornography). Among other things,

8

Yoder was accused· of engaging in sex acts with Child Doe.

9

10

35.

Yoder is Convicted. Iri February 2016, after a month long trial, Yoder was

convicted of multiple felony counts, and sentenced to 20 years in prison. Child Doe testified at

11 the criminal trial that he had been molested by Yoder.
12

DAMAGES

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36.

Economic Damages. As a direct and foreseeable result of the aforesaid acts of

15

Defendant School District, Plaintiff Villani has and will continue to lose income and benefits in

16

an amount to be proven at the time of trial, but exceeding the limited jurisdictional threshold of

17

this Court.

18

37.

Non-Economic Damages. As a result of the aforesaid acts of Defendant School

19 District, Plaintiff Villani has suffered general damages for severe mental and emotional distress
20 and aggravation in an amount to be proven at the time of trial. ,
21
22

FIRST CAUSE OF ACTION

23

· Violation of Labor Code§ 1102.5

24

25
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38.

Plaintiff Villani reasserts and incorporates by reference each and every allegation

contained in paragraphs 1 through 37, inclusive, as though fully set forth herein.
39.

California Labor Code§ 1102.5 provides in pertinent part that an employer, or any

27 person acting on behalf of an employer, shall not retaliate against an employee for disclosing
28
Complaint for Damages (Villani v. Palm Springs Unified School District)
10

 ,,

1

infonnation to a government agency or to a supervisor of the employee, if the employee has

2 reasonable cause to believe that the infonnation disclosed violates state or federal statutes;
3

40. . Plaintiff Villani had reasonable cause to believe that the info�ation he conveyed.

4 to the School District administration disclosed violation(s) of one or more state or federal
statutes. These statutes include� but are not limited to, Civil Code§§ 5 l. 7, 51.9, 52.1 and 1708.5;
..
.
6 Education Code§§ 234 et seq.;.and Penal Code§§ 288(a) and 111�4 et seq.

5

7

41.

8

§ 1102.5.

.

'

.

B y constructively �erminating Villani, the School District violated Labor Code

9
10

WHEREFORE, Plaintiff prays for judgment against Defendants as follows:

11

(1)

12

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For special damages, including but not limited to, lost past and future e�ings,

benefits and/or out-of-pocket expenses in an amount to be established at the time of trial;
(2)

For general damages, including but not limited to emotional distress damages� in

an amount to be established at the time of trial;

15

(3)

For interest;

16

(4)

For reasonable attorney's fees under C.C.P. § 1021.5; and

17

(5)

For ·such other and further legal and equitable relief as the Court deems just and ·

18

proper.

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November 29, 2016

LAW OFFICES OF STEVEN J. KAPLAN, P.C.

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By ______,...,...,,,=-,..,,..,,,------STEVEN J. KAPLAN
Attorneyfor PlaintiffJohn Villani

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Complaint for Damages
(Villani v. Palm Springs Unified School District)
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 JURY TRIAL DEMAND

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Plaintiff demands a jury trial on all issues so triable.
November 29, 2016

LAW OFFICES OF STEVEN J. KAPLAN, P.C.

��-�
By_-===�-==--,-=,=--=--=-=------STEVEN J. KAPLAN
Attorneyfor PlaintiffJohn Villani

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Complaint for Damages (Villani v. Palm Springs Unified School District)
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ATTORNEY OR PARTYWITHOUT ATTORNEY(Name, State Bar number, andaddross):
,_ Law Offices of Steven J. Kaplan
Steven J. Kaplan (SBN 83451)
1880 Century Park East, Ste. 614
Los Angeles, CA 90067
TELEPHONE NO.: V 10) 312-1500
FAXNO.: (424) 652-2221
ATTORNEY FOR (Name): laintiff John Villani
sTREET AooREss:
MAILJNG Ao□REss:
· cITYANDZ1PcooE:
BRAN H NAME:
C
CASE NAME:

FOR COURT USE ONLY

CM-01(

Riverside
3255 E. Tahquitz Canyon Way
3255 E. Tahquitz Canyon Way
Palm Spr�ngs, CA 92262
Palm Spnngs

SUPERIOR COURT OF CALIFORNIA, COUNTY OF

Villani v. Palm Springs-Unified School District

CIVIL CASE COVER SHEET
Limited
[LI Unlimited

D

(Amount
demanded
exceeds $25,000)

(Amount
demanded is
$25,000 or less)

A
C

Complex Case Designation

D

D

SPSC

JUOGE:
Filed with first appearance by defendant
DEPT:
(Cal. Rules of Court, rule 3.402)
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 (22)
Uninsured motorist (46)

· Auto Tort

D
D

Other PI/PDIWD (Personal lnJurylProperty
Damage/Wrongful Death) Tort

D Asbestos (04)
D Product liability(24)
D Medical malpractice (45)
D Other PI/PDNVD(23)
Non-PIIPD/WD (Other) Tort
D Business tort/unfair business practice(07)
D Civil rights(08)
D Defamation(13)
D Fraud(16)
D Intellectual property(19)
D Professional negligence(25)
D Other non-PI/PDNvD tort (35)
Employment
D Wrongful termination(36)
[Z]

Other employment(15)

Counter

Joinder

D Breach of contract/warranty(06)
D Rule 3.740 collections(09)
D Other collections(09)
D Insurance coverage (18)
D Other contract(37)
Real Property
Eminent domain/Inverse
D .condemnation
(14)
D Wrongful eviction(33)
D Other real property(26)
Unlawful Detainer
D Commercial(31)
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D Drugs(38)
Judicial Review
D Asset forfeiture(05)
D Petition re: arbitration award(11)
D Writ of mandate (02)
D Other judicial review(39)
Contract

16 0 6 0

:

i

Provlslonally Complex Civil Litigation
(Cal. Rules of Court, rules 3.400-3.403)

D
D
D
D
D
D

AntitrusVTrade regulation(03)
Construction defect (10)
Mass tort(40)
Securities litigation(28)
EnvironmentalfToxic tort(30)

Insurance coverage claims arising from the
above listed provisionally complex case
types(41)
Enforcement of judgment(20)

Enforcement of Judgment

D

RICO(27)
Other complaint (not specified above)(42)

Miscellaneous Civil Complaint

0
D

Partnership and corporate governance (21)
Other petition (not specified above) (43)

Mlscellaneous Civil Petition

D
D

2. This case
is
is not
complex under rule 3.400 of the California Rules of Court. If the case is complex, mark the
factors requiring exceptional judicial management
d.
Large number of witnesses
a.
Large number of separately represented parties
e.
Coordination with related actions pending in one or more courts
Extensive
motion
practice
raising
difficult
or
novel
b.
iii other counties, states, or countries, or in a federal court
issues that will be time-consuming to resolve
c.
f.
Substantial posljudgment judicial supervision
Substantial amount of documentary evidence

3.
4.
5.
6.

LJ

l..LJ

D
D
D
b. D nonmonetary; declaratory or injunctive relief

D
D
D

Remedies sought (check all that apply): a.CZ] monetary
Number of causes of action (specify):
This case
is
is not a class action suit.
If there are any known related cases, file and serve a notice of related case. (You may use form CM-015.)

D

c.

D punitive

[l]

Date: November 22, 2016
Steven J. Kaplan

(TYPE OR PRINT NAME)

►

(SIGNATURE OF PAITTY OR ATTORNEY FOR PAITTY)

• Plaintiff must tile 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. Rules of Court, rule 3.220.) Failure to file may result
in sanctions.
• File this cover sheet in addition to any cover sheet required by local court rule.
• If this case is complex under rule 3.400 et seq. of the Califo rnia 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 sheet will be used for statistical purposes onlv.

Form Adopted for Mandatory Use
Judicial Council of Clll�ornla
CM-010 [Rev. July 1, 2007)

NOTICE

Cal. Rules of Court, rules 2.30, 3.220, 3.4oo-3.403, 3.740;
Cal. Stanoaras of JUdlclal Aaminislration, std. 3.10

JSaae 1 of 2

CIVIL CASE COVER SHEET

ww.v.courtlnfo.ca.gov

ORIGINAL