Академический Документы
Профессиональный Документы
Культура Документы
11 Q*B9984
BEHROUZ "BENJAMIN" SIOUNIT. Case No.:
12
Id t1
13 Plaintiff, COMPLAINT FOR DAMAGES AND
INJUNCTIVE RELIEF FOR
v. VIOLATIONS OF THE CALIFORNIA
1i FAIR EMPLOYMENT AND HOUSING
Q 2 ACT (FEHA)
16 CITY OF PALOS VERDES ESTATES, and
U <
DOES 1 through 10 INCLUSIVE, 1. FEHA - Discrimination
17
21 Cm 4. FEHA - Retaliation
i-
2fy en
'X'
27..
28-
C4
**
-a.
*fr *f* 'A
o o '-' in
COMPLAINT o o o
o o o
I
PRELIMINARY STATEMENT
2 1. This is a complaint for damages and injunctive reliefbrought under the California
3 Fair Employment and Housing Act("FEHA") against Defendant City of Palos Verdes Estates
4 for race, religious creed, national origin, and ancestry discrimination, harassment, retaliation for
5 Plaintiffs opposition of these unlawful actions, and failure to prevent that discrimination and
6 retaliation. Plaintiff, a Jewish Iranian immigrant and police officer working at the City of Palos
7 Verdes Estates' Police Department, was abruptly terminated after complaining to his superiors
8 about the discriminatory and harassing treatment he suffered. Rather than making any effort to
9 address the issues complained of by Plaintiff, the Department chose instead to remove Plaintiff
10 himself. Therefore, he now brings this action seeking damages and injunctive relief.
2. Plaintiff BEHROUZ "BENJAMIN" SIOUNIT ("Plaintiff or "Siounit") was an
employee of Defendant City, employed as a Level II Reserve Police Officer within the Palos
^J c
^ 13 Verdes Estates Police Department, a peace officer pursuant to California Penal Code 830.6
<<J &
*. Oft
aS 14 and 832.6.
< i/i 15 3. At all times mentioned in this complaint, Defendant CITY OF PALOS VERDES
Q S
UJ
c
a:
16 ESTATES ("the City") was a municipal corporation organized and existing under the laws of the
17 State of California. The Palos Verdes Estates Police Department is an operating department of
18 the City.
19 4. The true names and capacities of the Defendants named herein as DOES I
20 through 10, whether individual, government, corporate, associate, or otherwise, are unknown to
21 Plaintiff who therefore sues such Defendants by such fictitious names pursuant to the California
22 Code of Civil Procedure, Section 474 et. seq.
23 5. Defendant DOES 1 through 10, were at all times alleged herein, employers,
24 employees, agents, partners, servants and joint venturers of Defendants and each of them and in
f; }
25. some capacity were responsible for the wrongful acts herein complained of. Plaintiff is informed
26 and believes that the DOE Defendants herein are California residents and will amend this
Complaint to show their true names and capacities when they have been ascertained.
28 6. The acts alleged and complained of herein were committed within the County of
COMPLAINT
2
Los Angeles, within the jurisdiction of this Court.
2 7. Each and all of the acts of the Defendants as alleged herein were done by
3 Defendants, their agents, servants, and employees, and each of them as individuals and under the
4 color and pretense of the statutes, ordinances, regulations, customs and usages of the State of
5 California, and under the authority of their employment with full knowledge and approval of
6 their superiors as agents. Defendants are jointly and severally liable for the injuries and damages
7 sustained by Plaintiff.
8 8. At all times mentioned herein, the City regularly employed five or more persons
9 within the provisions of the California Government Code. All conditions precedent to
10 jurisdiction under California Government Code 12940 et seq. have been complied with: timely
11 charges of unlawful employment practices were filed with the Department of Fair Employment
56
12 and Housing (DFEH) and subsequent "Right to Sue Letters" were issued to Plaintiff.
O p
13 9. All facts stated herein in any one section are incorporated, reiterated, and
<* c
UJ _j
14 realleged in every other section.
S c
< <7 15 FACTS RELATING TO EACH CAUSE OF ACTION
16 10. Plaintiff was hired by Defendant City as a Level II Reserve Police Officer on June
U <
17 19, 2007. Throughout his time with Defendant City, Plaintiff has consistently been a highly
18 valuable contributor to the City's and Department's law enforcement efforts.
19 11. Prior to his unlawful termination, he had never received a negative performance
20 review, nor been disciplined.
21 12. Plaintiff is also a Jewish Iranian American citizen. He observes his religious
22 beliefs strictly and maintains great pride in his Iranian heritage. He immigrated to the United
23 States as a teenager after being granted "refugee asylum" status by the federal government, due
24_ to the severely hostile and targeted anti-Semitic policies in Iran.
2Sl; 13. Despite his valuable service to Defendant City, and his past escapes from hostile
persecution, Plaintiff has been subject to anti-Semitic and racist discriminatory treatment and
27.' harassment throughout his time with the Department, ultimately leading to his termination from
28- employment. This discriminatory and harassing conduct had been, and possibly still is,
1 pervasive throughout the Department.
2 14. Within the first few months after being hired, Plaintiff was told by a large group
3 of fellow officers that Plaintiff and "the rest of (his) bleeding heart liberal Jewish tribe were
4 responsible for having President Obama elected." This same comment has been repeated by
5 other officers, in addition to the ones at this initial confrontation, on numerous occasions.
6 15. Throughout Plaintiffstime with the Department, almost every single time he
7 walked into a room with otherofficers, he was greeted with a loud "Allah-o-Akbar", attempted
8 mimicked Arabic phrases, and shouts of "Ah La La La" with fists pumped into the air. There
9 was a group of three fellow officers that did this consistently. Countless other officers were
10 encouraged and joined in repeatedly. This behavior was witnessed by management numerous
times.
Iz 16. Plaintiffs Jewish kosher Iranian diet was constantly ridiculed by fellow and
5 3
O j:
16 Plaintiff, the officer told him that his grandfather was a Nazi guard in a concentration camp, and
u <
<
_l 17 died when he accidentally fell off of the guard tower. Afterfinishing thisegregious insult, he
18 looked at other fellow officers gathering around, and all started laughing uncontrollably.
19 18. In or around March of 2011, Plaintiff made a formal complaint to Captain Mark
20 Velez about the consistent anti-Semitic and racist discrimination and harassment he had been
21 receiving from fellow and superior officers, including reference to specific instances such as
22 those recounted above.
23 19. Based upon information and belief, the Department never followed up on the
24 complaint in any way. No investigation was initiated and no resolution was had.
,")
2,5, 20. In or around August of 2011, a fellow officer, with other fellow and superior
2& officers surrounding, asked Plaintiff how he felt about the fact that "Jews were responsible for
y-.'s
ij... killing Jesus", or that Jews routinely "take advantage" of other people. This officer also told
28 Plaintiff that Jews "are taught and obligated to cheat and steal from the gentiles." The officer
then handed Plaintiff an eleven-page document, printed from the Department's briefing room
printer, which detailed more ridiculous and incredibly anti-Semitic propaganda, and suggested
that Plaintiff should "learn more" about his religion.
4 21. In or around Decemberof 2011, Plaintiff was approached in the parking garage of
5 the station by a fellow officer and asked, in front of supervising officers, if he knew "why Jews
6 and Arabs keep fighting each other like cats and dogs." No supervising officers intervened.
7 22. In addition to the confrontations above, throughout his time with the Department,
8 Plaintiff has been scheduled and forced to work on Jewish holy days, despite repeated and prior
9 requests to not be scheduled on such days. When Plaintiff made these requests, he was told that
10 he had no choice, and that adverse employment actions would be taken against him if he didn't
11 work the days as scheduled. Based upon information and belief, the Department made no effort
12 to schedule around the holy days observed by Plaintiff.
o 6
13 23. Plaintiff also had particular difficulty meeting his required firearm range
<
*
UJ
c
-1
14 qualifications, because range managers, including two in particular, refused to schedule Plaintiff
I p.
k. c
< 7. 15 on days that did not conflict with his observed religious holidays and worship, despite Plaintiffs
a s
Ui C
^
a:
e-
16 repeated requests. Based upon information and belief, they did this with the intent to make it
17 difficult for Plaintiff to make his firearm qualifications.
18 24. During a meeting on or about February 6, 2012, with Sergeants Eric Gaunt and
19 Lou Warnick, Plaintiffagain made a formal complaint about the anti-Semitic and racist treatment
20 from fellow and superior officers. When this issue was brought up, Sergeant Gaunt replied "let's
21 not go there," making it clear that neither he nor the Department had any concern about the
22 treatment received by Plaintiff, and did not intend to do anything about it.
23 25. During that same meeting, Plaintiff informed his superiors of other misconduct
24. and unlawful behavior by fellow officers that he had witnessed. Plaintiff was told that the
0
25> purpose of the meeting was not to talk about those issues. Immediately thereafter. Plaintiffwas
2'6 asked to leave for a few minutes as the others wanted to speak amongst themselves. He was also
asked if he had been tape recording the meeting, which he did not.
2'8 26. When Plaintiff was asked back in to the room, he was told that he was not
}..>
i '')
COMPLAINT
5
allowed to work patrol any longer, and that he needed to take a leave of absence. No explanation
was given.
27. Five days later, on or about February 11, 2012, Plaintiff again met with Sergeants
Gaunt and Warnick. Plaintiff was given two documents; a resignation letter and a termination
letter, and told to chose between the two. After Plaintiff informed the two Sergeants that he was
not able to make a decision that very moment, Sergeant Gaunt said the "offer" of resignation was
only good for the night.
28. Plaintiff was then immediately terminated from employment. He was escorted to
his locker where he emptied his personal belongings, and then escorted to his car.
10 FIRST CAUSE OF ACTION
11 FEHA Discrimination
6S
12 Government Code 12940 (a)
29. Plaintiff re-alleges each and every preceding paragraph as though set forth in full
here.
id. 15 30. In doing the things alleged to have been done, Defendant violated 12940(a).
4. a.
16 The California Fair Employment and Housing Act (FEHA) (Gov. C. 12900 et seq.) prohibits
O <
<
17 employment discrimination on the basis of "race, religious creed...national origin" or "ancestry."
18 Gov't Code 12940(a).
19 31. Defendant and its agents had knowledge of Plaintiffs Jewish religion and Iranian
20 race, national origin, and ancestry. Defendants took the discriminatory actions and treatment
21 described above because of that knowledge. As such, Plaintiff is a member of a protected class.
22 (Gov't Code 12926(n) and (p).)
23 32. Plaintiff performed competently in his job: Plaintiff was never disciplined during
24 his career. Plaintiff also never received a negative performance review.
2|: 33. Plaintiff was subjected to an adverse employment action because of his race,
26 religious creed, national origin, and ancestry: Plaintiff was terminated without cause which
resulted in an effective end to his law enforcement career and substantial economic loss related
%
28' to his inability to find future law enforcement employment.
f":')
COMPLAINT
6
34. Even before Plaintiff was terminated, he was subjected to numerous adverse
2 employment actions and other acts ofdiscriminatory animus because ofhis race, religious creed,
3 national origin, or ancestry, including, but not limited to constant ridicule about his Iranian race,
4 national origin, and ancestry, constant ridicule about his Jewish religion, consistent refusal by his
5 employer to accommodate his religious beliefs, and consistent refusal by his employer to
6 investigate the discriminatory treatment suffered.
7 35. Based on information and belief, Plaintiffs race, religious creed, national origin,
8 and ancestry were the motivating reasons for the actions taken against Plaintiff, including those
9 listed above.
10 36. As a direct and proximate result of the Defendant's conduct, Plaintiffhas suffered
11 and continues to suffer in his capacity to earn his salary, and has lost, and will continue to lose,
12 the ability to have a law enforcement career.
o &
u.
UJ C
i<: a.
16 37. Plaintiff re-alleges each and every preceding paragraph as though set forth in full
o <
17 here.
18 38. In doing the things alleged to have been done, Defendant City violated
19 I2940(l)(l ) Government Code section 12940(0(1) makes it unlawful for an employer to fail to
20 make reasonable accommodations for an employee's religious beliefs or observance, or to
21 discriminate against a person in the terms, conditions, or privileges of employment because of a
22 conflict between those religious beliefs or observance and any employment requirement.
23 39. At all times relevant to this complaint, Defendant City of Palos Verdes Estates
24 was an "employer" under Gov't Code sections 12940 and 12926(d).
K 40. At all times relevant to this complaint, Plaintiff was an employee of Defendant.
26-- 41. As recounted above, despite Plaintiffs repeated requests, Defendant and its
agents consistently refused to schedule Plaintiff around his observed Jewish Sabbath and other
28-.. holy days. "Religious belief or observance," includes "observance of a Sabbath or other religious
COMPLAINT
7
1 holy day or days." (Gov't Code 12940(0(1).)
2 42. As such, Defendant City of Palos Verdes Estates failed to provide reasonable
5 terminated his career as a police officer and resulted in a substantial economic loss related to his
6 inability to find future law enforcement employment.
7 44. The City of Palos Verdes Estates' failure to provide Plaintiff with reasonable
8 accommodations for his religious beliefs and observance was a substantial factor in causing
9 Plaintiffs harm.
10 45. As a direct and proximate result of the Defendant's conduct, Plaintiff has suffered
11 and continues to suffer in his capacity to earn his salary, and has lost, and will continue to lose,
2 c
< 15 Government Code 129400(1)
_ U..
16 46. Plaintiff re-alleges each and every preceding paragraph as though set forth in full
<J <
17 here.
18 47. In doing the things alleged to have been done. Defendant City violated
19 12940(j)(l). Section I2940(j)(l) makes it unlawful for an employer to harass an employee on the
20 basis of "race, religious creed. ..national origin," or "ancestry."
21 48. Defendant City harassed Plaintiff on the basis of his race, religious creed, national
12 origin, and ancestry because numerous, if not all, of its agents and supervisors knew of the
23 harassing treatment and conduct and failed to take immediate and appropriate action. As
24 recounted above, despite Plaintiffs repeated complaints about the unlawful harassment,
Defendant City did nothing.
26 49. Defendant City took no reasonable steps to prevent Plaintiffs suffered
harassment, despite being fully aware of such conduct by its agents and employees.
28 50. Defendant City is Plaintiffs "employer." Gov't Code 12940<j)(4)(A).
51. Plaintiff was harmed; specifically, he was terminated from employment which
prematurely ended his career as a police officer and resulted in a substantial economic loss
6 53. As a direct and proximate result of the Defendant's conduct, Plaintiff has suffered
7 and continues to suffer in his capacity to earn a salary in law enforcement going forward, and has
8 lost, and will continue to lose, the ability to have a law enforcement career, and has suffered
9 severe and substantial emotional injury.
10 FOURTH CAUSE OF ACTION
11 FEHA Retaliation
O 6
12 Government Code 12940(h)
o z
S 2 13 54. Plaintiff re-alleges each and every preceding paragraph as though set forth in full
<* 2
OS %
here.
2 c c
55. In doing the things alleged to have been done, DefendantCity violated
12940(h). Section 12940(h) makes it unlawful for an employerto retaliate against its employees
u <
COMPLAINT
9
59. Defendant City's conduct was a substantial factor in causing Plaintiffs harm.
60. As a direct and proximate result of the Defendant's conduct, Plaintiff has suffered
and continues to suffer in his capacity to earn a salary in law enforcement going forward, and has
4 lost, and will continue to lose, the ability to have a law enforcement career, and has suffered
5 severe and substantial emotional injury.
9 61. Plaintiff re-alleges each and every preceding paragraph as though set forth in full
10 here.
II 62. In doing the things alleged to have been done, Defendant City violated
Pi 12 I2940(k). Section 12940(k) makes it unlawful for an employer to fail to take all reasonable steps
'~> t
18 64. At all times relevant to this complaint, Plaintiff was an employee of Defendant
19 City.
20 65. Plaintiff was subjected to discrimination and harassment because of his race,
21 religious creed, national origin and ancestry.
22 66. Defendant City failed to take reasonable steps to prevent the discrimination and
23 harassment, despite Plaintiffs complaints and Defendant's knowledge.
24 67. Plaintiff was harmed; specifically, he was terminated which prematurely
2s; terminated his career as a police officer and resulted in a substantial economic loss related to his
26 inability to find future law enforcement employment, and suffered severe emotional damages as
r-,'
27. a result of constant and pervasive workplace harassment.
'j-1
28 68. Defendant City's failure to take reasonable steps to prevent the discrimination and
["-'
r'-.'j
COMPLAINT
10
harassment was a substantial factor in causing Plaintiffs harm.
2 69. As a direct and proximate result of the Defendant's conduct, Plaintiff has suffered
3 and continues to suffer in his capacity to earn a salary in law enforcement going forward, and has
4 lost, and will continue to lose, the ability to have a law enforcement career, and has suffered
5 severe and substantial emotional injury.
6 WHEREFORE, Plaintiff prays for judgment against the Defendant, as follows:
7 1. General, compensatory, and special damages according to proof:
8 2. For injunctive relief ordering Defendant City of Palos Verdes Estates:
9 a) To immediately expunge any negative personnel documents generated by
10 Defendants relating to the adverse actions that are the subject of this
II action;
12 b) to take any and all necessary and reasonable steps to remove the stigma
S3 13 and negative perception of Plaintiff; and
<a
14 c) to return Plaintiff to the position he would have been in had he not been
| 5
S C
'< C. 15 subjected the unlawful conduct;
y g 16 3. For attorney's fees in an amount to be shown according to proof (Government
^ o.
O <
17 Code 12965(b));
18 4. For interest provided by law including, but not limited to, Civil Code 3291;
19 5. For costs of suit; and
20 6. For each other and further relief as the Court deems just and proper.
21
22 Dated: January 28, 2013 LACKIE DAMMEIER MCGILL & ETHIR APC
23
24
28.
DEMAND FOR TRIAL BY JURY
2
Plaintiff hereby demands a trial by jury.
3
4
Dated: January 28, 2013 LACKIE DAMMEIER MCGILL & ETHIR APC
5
8
Michael A. McGill
9 Zachery A. Lopes
Attorneys for Plaintiff*
10 BEHROUZ "BENJAMIN" SIOUNIT
II
12
13
"
UJ u
m _
14
2 <
2 c
< </; 15
.. u.
(A! C
16
<
17
18
19
20
21
22
23
24
25^
26:
2f-j
28*.
CM-010
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name. Stale Bar number, and address): FOR COURT USE ONLY
-Zachery A. Lopes, SBN 284394
LACKIE, DAMMEIER & MCGILL, APC
367 N. Second Avenue
Upland, CA 91786 FILED
telephone no: 909-985-4003 fax no.: 909-985-3299
attorney for w Plaintiff, BEHROUZ "BENJAMIN" SIOUNIT
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS AllgdCS
street address: 110 N. Grand Avenue
JAN 28 2013
MAILING AODRESS:
Joba A. uante, Gxecuttve Qffieei/Clerk
city and zip code. Los Armeies, CA 90012
branch name: StanleyTvlosk Courthouse Ll Cns^WiaR!P
CASE NAME:
Siounit v. City of Palos Verdes Estates, et al.
CIVIL CASE COVER SHEET
GZH Unlimited I I Limited
I
Complex Case Designation
I Counter I I Joinder
~ffC4 99 984
(Amount (Amount JUOGE:
demanded Filed with first appearance by defendant
demanded is
exceeds $25,000) $25,000 or less) (Cal. Rules of Court, rule 3.402) OEPT:
This form is required pursuant to Local Rule 2.0 in all new civil case filings in the Los Angeles Superior Court.
Item I. Check the types of hearing and fill in the estimated length of hearing expected for this case:
JURY TRIAL? fi_J YES CLASS ACTION? O YES LIMITED CASE? QyES TIME ESTIMATED FOR TRIAL 5 D HOURS/ El DAYS
Item II. Indicate the correct district and courthouse location (4 steps - If you checked "Limited Case", skip to Item III, Pg. 4):
Step 1: After first completing the Civil Case Cover Sheet form, find the main Civil Case CoverSheet heading for your
case in the left margin below, and, to the right in Column A, the Civil Case Cover Sheet case type you selected.
Step 2: Check one SuperiorCourttype of action in Column B below which best describes the nature of thiscase.
Step 3: In Column C, circle the reason for the court location choice that applies to the type of action you have
checked. For any exception to the court location, see Local Rule 2.0.
1 Class actions must be filed in the Stanley Mosk Courthouse, central district. 6. Location of property or permanently garaged vehicle.
2. May be filed in central (other county, or no bodily injury/property damage). 7. Location where petitioner resides.
3 Location where cause of action arose. 8. Location wherein defendant/respondent functions wholly.
4. Location where bodily injury, death or damage occurred. 9. Location where one or more of the parties reside.
5. Location where performance required or defendant resides. 10. Location of Labor Commissioner Office
Step 4: Fill in the information requested on page 4 in Item III; complete Item IV. Sign the declaration.
A B C
Civil Case Cover Sheet Type of Action Applicable Reasons -
Category No. (Check only one) See Step 3 Above
O
<u <u
D A7250 Premises Liability (e.g., slip and fall)
O) Other 1.. 4.
a.
Personal Injury D A7230 Intentional Bodily Injury/Property Damage/Wrongful Death (e.g.,
S 1., 4.
Property Damage assault, vandalism, etc.)
Wrongful Death O A7270 Intentional Infliction of Emotional Distress 1..3.
(23)
1., 4.
D A7220 OtherPersonal Injury/Property Damage/Wrongful Death
LAGIV 109 (Rev. 03/11) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.0
LASC Approved 03-04 AND STATEMENT OF LOCATION Page 1 of 4
SHORT TITLE: CASE NUMBER
Siounit v. City of Palos Verdes Estates
A B C
Civil Case Cover Sheet Type of Action Applicable Reasons -
Category No. (Check only one) See Step 3 Above
Business Tort (07) Q A6029 Other Commercial/Business Tort (not fraud/breach of contract) 1., 3.
is
?>E Defamation (13) D A6010 Defamation (slander/libel) 1,2.. 3.
3 3
^ *
c o>
c Fraud (16) D A6013 Fraud (no contract) 1..2., 3.
is
(O
*- 4) O A6017 Legal Malpractice 1,2.3.
Professional Negligence (25)
c E D A6050 Other Professional Malpractice (not medical or legal) 1.2.3.
O s
z o
Eminent Domain/Inverse
Condemnation (14) D A7300 Eminent Domain/Condemnation Number of parcels 2.
<D
Wrongful Eviction (33) D A6023 Wrongful Eviction Case 2,6.
O
D A6060 Other Real Property (not eminent domain, landlord/tenant, foreclosure) 2,6
Unlawful Detainer-Commercial
(31)
D A6021 Unlawful Detainer-Commercial (not drugs or wrongful eviction) 2.6.
Unlawful Detainer-Residential
(32)
O A6020 Unlawful Detainer-Residential(not drugs or wrongful eviction) 2,6.
Unlawful Detainer-
D A6020F Unlawful Detainer-Post-Foreclosure 2.. 6.
Post-Foreclosure (34)
LAGIV 109 (Rev. 03/11) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.0
LASG. Approved 03-04 AND STATEMENT OF LOCATION Page 2 of 4
SHORT TITLE. CASE NUMBER
Siounit v. City of Palos Verdes Estates
A B c
Civil Case Cover Sheet Type of Action Applicable Reasons -
Category No. (Check only one) See Step 3 Above
on
A6151 Writ - Administrative Mandamus 2,8.
o Writ of Mandate (02) ' A6152 Writ - Mandamus on Limited Court Case Matter 2.
Partnership Corporation
Governance (21) D A6113 Partnership and Corporate Governance Case 2,8
(Y> D A6170 Petition for Relief from Late Claim Law 2., 3., 4, 8.
O A6100 Other Civil Petition 2,9.
f>;
LASIV 109 (Rev. 03/11) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.0
LASS Approved 03-04 AND STATEMENT OF LOCATION Page 3 of 4
SHORT TITLE: CASE NUMBER
Siounit v. City of Palos Verdes Estates
Item III. Statement ofLocation: Enter theaddress oftheaccident, party's residence orplace ofbusiness, performance, orother
circumstance indicated in Item II., Step 3 on Page 1, as the proper reason for filing in thecourt location you selected.
AOORESS:
REASON: Check the appropriate boxes for the numbers shown City of Palos Verdes Estates
under Column C for the type of action that you have selected for 340 Palos Verdes Dr West
this case.
Item IV. Declaration ofAssignment. Ideclare under penalty ofperjury under thelaws oftheStateofCalifornia thattheforegoing istrue
and correct and that the above-entitled matter is properly filed for assignment to the Stanley Mosk courthouse in the
Central
District of the SuperiorCourtof California, County of Los Angeles [CodeCiv. Proa, 392 et seq., and Local
Rule 2.0, subds. (b), (c) and (d)J.
Dated: 01/28/2013
(SIGNATURE OF ATTORNY/FILIN<4 PARTY)
PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY
COMMENCE YOUR NEW COURT CASE:
4. Civil Case Cover Sheet Addendum and Statement of Location form, LACIV 109, LASC Approved 03-04 (Rev
03/11).
5 Payment in full of the filing fee, unless fees have been waived.
6. Asignedorderappointing the Guardian ad Litem, Judicial Council form CIV-010, if the plaintiff or petitioner is a
minor under 18 years of age will be required by Court in order to issue a summons.
7. Additional copies of documents to be conformed by the Clerk. Copies of the cover sheet and this addendum
must be served along with the summons and complaint, or other initiating pleading in the case.
LACW 109 (Rev. 03/11) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.0
LASC, Approved 03-04 AND STATEMENT OF LOCATION Page 4 of 4