^co¡TÜ5eo¡¡£7- - American Bar · PDF fileBreach of contract/warranty (06) ... Judicial Council of California ... a prejudgment writ of attachment

Gary A. Dordick, Esq. S/B# 128008 GARY A. DORDICK, A LAW CORPORATION 509 South Beverly Drive Beverly Hills, California 90212

TELEPHONE NO.: 310-551-0949 fax no .: 855-299-4444SUPERIOR COURT OF CALIFORNIA, COUNTY OF L O S A N G E L E S

s tre e t address: 1 1 1 N o r t h H i l l S t r e e tm aiungaddress 1 1 1 N o r t h H i l l S t r e e t «

c ity and zip code: L o s A n g e le s , C a l i f o r n i a 9 0 0 1 2 * BRANCH NAME: C e n t r a l D i s t r i c t

R - w aiter, Executive Q ttteet/C ierk

B y.Jud iLara.O e im W

CASE NAME: Y E L C H IN , e t a l . , v s . F C A U S L L C , e t a l .

C IV IL C A S E C O V ER S H E E T 1 X 1 Unlim ited 1 1 Lim ited

(Amount (Amount demanded demanded is exceeds $25.000) $25.000 or less)

Com plex Case Designation 1 1 Counter 1 1 JoinderFiled with first appearance by defendant

(Cal. Rules of Court, rule 3.402)

CASE NUMBER: ---------- -

— B C i _ 2 J _ f l L g 4 —

DEPT:

items 7-o oeiow must oe completed (see instructions on p a o e 2 i_ -------------------------------1. Check one box below for the case type that best describes this case: ' ----------

*co¡*TÜ5eo¡¡£7- C O N F O R M E D C O P YORIGINAL FILEDSuSrtor Court Ol CaWpmmfcountv o< Los Anortes

Auto TortAuto (22)Uninsured motorist (46)

O ther PUPD/WO (Personal In ju iy /P roperty Dam ago/W rongful Death) Tort

I I Asbestos (04)

□ D Product liability (24)I I Medical malpractice (45)I I Other PI/PD/W D (23)Non-PI/PD/W D (O ther) Tort I I Business tort/unfair business practice (07) C U Civil rights (08)I I Defamation (13)

I I Fraud (16)I I Intellectual property (19)I I Professional negligence (25)I I Other non-PI/PD/W D tort (35)Em ploym entI I Wrongful termination (36)

I I Other employment (15) ___________

ContractBreach of contract/warranty (06)

Rule 3.740 collections (09)

Other collections (09)Insurance coverage (18)Other contract (37)

R eal PropertyI I Eminent dom ain/lnverse

condemnation (14)I I Wrongful eviction (33)I I Other real property (26)

Unlaw fu l Detainer1 I Commercial (31)

I I Residential (32)I I Drugs (38)Jud icial Review

I I Asset forfeiture (05)

I I Petition re: arbitration award (11) I I W rit of mandate (02)I I Other judicial review (39)

Provlslonalhr C om plex C iv il L itigation (Ca1, Ru,es ° * C ourt, ru les 3.400-3.403)j-----j AnW nist/Trade regulation (03)L . I Construction defect (10)I I Mass tort (40)

L . I Securities litigation (28)

1 , 1 Envtrownenlal/Toxic tort (30)□ Insurance coverage claim s arising from the

above listed provisionally complex case types (41)

Enforcem ent o f Judgm ent

C~ - I Enforcement of judgm ent (20) M iscellaneous C iv il C om plain t

( Z D RICO (27)

I____I Other complaint (not specified above) (42)M iscellaneous C iv il P etition

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

This case I I is I X I 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:a. I I Large number of separately represented parties d. I I Large number of witnessesb. I I Extensive motion practice raising difficult or novel e. I I Coordination with related actions pending in one or more courts

___ issues that will be time-consuming to resolve ____ in other counties, states, or countries, or in a federal courtc. I I Substantial amount of documentary evidence f. ( _ J Substantial postjudgment judicial supervisionRemedies sought (check all that apply): a. I X I monetary b. I X I nonmonetary; declaratory or injunctive relief c. I X I punitive

4. Number of causes of action (specify): 45. This case I I is I X I is not a class action suit.6. If there are any known related cases, file and serve a notice of related case. (You Date: August 2, 2016Gary A. Dordick. Esa._____________________

(TYPE OR PRINT NAME)

NOTICE T• 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 W elfare 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 California Rules of Court, you must serve a copy of this cover sheet on all

other parties to the action or proceeding.• Unless this is a collections case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes only. ^

Form Adoptad (or Mandatory Ute Judicial Council of California CIVIL CASE COVER SHEET 081 SU

IN S T R U C T IO N S O N H O W T O C O M P L E T E TH E C O V E R S H E E T CM-OTOTo P laintiffs and O thars F iling F irst Papare. If you are filing a first paper (for example, a complaint) in a civil case, you m ust complete and file, along with your first paper, the C ivil C ase C o v e r S h ee t contained on page 1. This information will be used to compile statistics about the types and numbers of cases filed. You must complete items 1 through 6 on the sheet In item 1, you must check one box for the case type that best describes 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 prim ary 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 CourtTo Parties in Rule 3.740 C ollections 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 Com plex C ases. In complex cases only, parties must also use the C iv il C ase C o ve r S h e e t to designate whether the case is complex. If a plaintiff believes the case is complex under rule 3.400 of the California Rules of Court, this must be indicated by completing the appropriate boxes in items 1 and 2. If a plaintiff designates a case as complex, the cover 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 plaintiffs 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. case types and examples

Auto TortAuto (22)— Personal tnjury/Property

Damage/W rangful Death Uninsured Motorist (46) {If the

case invoices an uninsured motorist claim subject to arbitration, check this item instead o f Auto)

O ther PIIPD /W D (Personal In ju ry / Property Dam age/W rongful O eath) Tort

Asbestos (04)Asbestos Property Damage Asbestos Personal Injury/

Wrongful Death Product Liability (not asbestos o r

toxicfenvironmental) (24) Medical Malpractice (45)

Medical M alpractice-Physicians & Surgeons

Other Professional Health Care Malpractice

Other PI/PD /W D (23)Premises Liability (e.g ., slip

and fell)Intentional Bodily Injury/PD/W D

(e.g., assault, vandalism ) Intentional Infliction of

Emotional Distress Negligent Infliction of

Emotional Distress Other PI/PD/W D

Non-PI/PO/W D (O ther) Tort Business Tort/Unfeir Business

Practice (07)Civil Rights (e.g., discrimination,

false arrest) (not civil harassment) (08)

Defemation (e.g., slander, libel)(13)

Fraud (16)Intellectual Property (19) Professional Negligence (25)

Legal Malpractice Other Professional Malpractice

(not medical o r legal)Other Non-PI/PD/W D Tort (35)

Em ploymentWrongful Termination (36)Othar Employment (15)

ContractBreach of Contract/W arranty (06)

Breach o f Rental/LeaseContract (not unlawful detainer

o r wrongful eviction) Contract/W arranty Breach— Seller

Plaintiff (not baud o r negligence) Negligent Breach of Contract/

W arranty Other Breach o f Contract/W arranty

Collections (e.g ., money owed, open book accounts) (09)Collection Case— Seller Plaintiff Other Promissory Note/Collectlons

CaseInsurance Coverage (not provisionally

complex) (18)Auto Subrogation Other Coverage

Other Contract (37)Contractual Fraud Other Contract Dispute

Real PropertyEminent Dom ain/lnverse

Condemnation (14)Wrongful Eviction (33)Other Real Property (e.g ., quiet title) (26)

W rit of Possession of Real Property Mortgage Foreclosure Quiet TitleOther Real Property (not eminent domain, landlordAenant, or foreclosure)

Unlaw ful D etainer Commercial (31)Residential (32)Drugs (38) (If the case Involves illegal

drugs, check this Item ; otherwise, reportas Com m ercial or Residential)

Judicial Review Asset Forfeiture (05)Petition Re: Arbitration Award (11)W rit of Mandate (02)

W rit-Adm inistrative Mandamus W rit-Mandam us on Limited Court

Case M atter W rit-O ther Lim ited Court Case

Review Other Judicial Review (39)

Review of Health O fficer Order Notice of Appeal-Labor

Commissioner Appeals

P rovisionally C om plex C iv il L itigation (C al. R ules o f C ourt R u les 3 .400 -3 .403 )

Antltrust/Trade Regulation (03) Construction Defect (10)Claims Involving Mass Tort (40) Securities Litigation (28) Environmentat/Toxic Tort (30)Insurance Coverage Claims

(arising from provisionally complex case type listed above) (41)

Enforcem ent o f Judgm entEnforcem ent of Judgment (20)

Abstract o f Judgment (Out of County)

Confession of Judgment (nondom estic relations)

Sister State Judgment Administrative Agency Award

(not unpaid taxes) Petition/Certlficatlon of Entry of

Judgm ent on Unpaid Taxes Other Enforcem ent of Judgment

CaseM iscellaneous C iv il C om plaint

RICO (27)Other Complaint (not specified

above) (42)Declaratory R elief Only Injunctive R elief Only (non

harassm ent)Mechanics Lien Other Comm ercial Complaint

Case (non-tort/non-complex) Other Civil Complaint

(non-tort/non-complex) M iscellaneous C iv il P etition

Partnership and Corporate Governance (21)

Other Petition (not specified above) (43)Civil Harassm ent « .W orkplace Violence Elder/Dependent Adult

Abuse Election Contest Petition for Nam e Change

■ Petition for Relief from Late Claim

Other Civil Petition

CM-010[Rev. July 1.2007] nun f iA S F r.nvpp s h p p t P*g< 2 oT 2

s h o r t t r i e YELCHIN, et al., vs. FCA US LLC, et al. CASE NUMBERBC o 29 0 p

CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION

(CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION)

This form is required pursuant to Local Rule 2.0 in all new civil case filings in the Los Angeles Superior Court

Item I. Check the types of hearing and fill in the estimated length o f hearing expected for this case:

JURY TRIAL? D C YES CLASS ACTION? □ □ YES LIMITED CASE? □ YES TIME ESTIMATED FOR TRIAL7-10 [ I H O U R S/H T 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 Cover Sheet heading for your case in the left margin below, and, to the right in Column A , the Civil Case Cover Sheet case type you selected.

Step 2: Check one Superior Court type of action in Column B below which best describes the nature of this case.

Step 3 : In Column C, circle the reason for the court location choice that applies to the type of action you have checked. For any exception to the court location, see Local Rule 2.0.

Applicable Reasons for Choosing Courthouse Location (see Column C below)

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.

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A B cCivil Case Cover Sheet Type of Action Applicable Reasons -

Category No. (Check only one) See Step 3 Above

Auto (22) 1 1 A7100 Motor Vehicle - Personal Injury/Property DamageAA/rongful Death 1., 2.,4.

Uninsured Motorist (46) [ ¡ A7110 Personal Injury/Property DamageA/Vrongful Death - Uninsured Motorist 1., 2., 4.

i A6070 Asbestos Property Damage 2.Asbestos (04)

'___ | A7221 Asbestos - Personal Injury/Wrongful Death 2.

Product Liability (24) [ X A7260 Product Liability (not asbestos or toxic/environmental) 1 ..2 ..3 ..4 .8.

H A7210 Medical Malpractice - Physicians & Surgeons 1., 4.Medical Malpractice (45)

1 ! A7240 Other Professional Health Care Malpractice 1., 4.

: __j A7250 Premises Liability (e.g.. slip and fall) 1.. 4.Other

Personal Injury 1 1 A7230 Intentional Bodily Injury/Property DamageAA/rongful Death (e.g . assault, vandalism, etc.) 1 4Property Damage

Wrongful Death 1 1 A7270 Intentional Infliction of Emotional Distress 1., 3.(23) [___ i A7220 Other Personal Injury/Property Damage/Wrongful Death 1., 4.

LACIV109 (Rev 03/11)LASC Approved 03-04

CIVIL CASE COVER SHEET ADDENDUMAND STATEMENT OF LOCATION

Local Rule 2.0Page 1 of 4

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CASE NUMBERSHORT t i t l e YELCHIN, et al., vs. FCA US LLC, et al.

ACivil Case Cover Sheet

Category No.

BType of Action

(Check only one)

cApplicable Reasons -

See Step 3 Above

Business Tort (07) [ A6029 Other Commercial/Business Tort (not fraud/breach of contract) 1., 3.

Civil Rights (08) i 1 A6005 Civil Rights/Discrimination 1., 2.. 3.

Defamation (13) 1 ¡ A6010 Defamation (slander/libel) 1.. 2., 3.

Fraud (16) I A6013 Fraud (no contract) 1.. 2.. 3.

Professional Negligence (25)!___ ¡ A6017 Legal Malpractice

U A6050 Other Professional Malpractice (not medical or legal)

1., 2.. 3.1.. 2., 3.

Other (35) ! 1 A6025 Other Non-Personal Injury/Property Damage tort 2..3.

Wrongful Termination (36) ! 1 A6037 Wrongful Termination 1.. 2.. 3.

Other Employment (15)!___ i A6024 Other Employment Complaint Case1 1 A6109 Labor Commissioner Appeals

1.. 2.. 3. 10.

Breach of Contract/ Warranty (06)

(not insurance)

__J A6004 Breach of Rental/Lease Contract (not unlawful detainer or wrongfuleviction)

71 A6008 Contract/Warranty Breach -Seller Plaintiff (no fraud/negligence)

i A6019 Negligent Breach of Contract/Warranty (no fraud)

1 1 A6028 Other Breach of Contract/Warranty (not fraud or negligence)

2., 5.

2., 5

1., 2., 5.

1., 2., 5.

Collections (09)1 ¡ A6002 Collections Case-Seller Plaintiff

! 1 A6012 Other Promissory Note/Collections Case

2., 5„ 6.

2.. 5.

Insurance Coverage (18) [___ ] A6015 Insurance Coverage (not complex) 1.. 2., 5., 8.

Other Contract (37)

1 1 A6009 Contractual Fraud

[___j A6031 Tortious Interference

! 1 A6027 Other Contract Dispute(not breach/insurance/fraud/negligence)

1.. 2.. 3.. 5.

1.. 2.. 3.. 5.

1.. 2„ 3., 8.

Eminent Domain/lnverse Condemnation (14) I A7300 Eminent Domain/Condemnation Number of parcels 2.

Wrongful Eviction (33) 1 1 A6023 Wrongful Eviction Case 2.. 6.

Other Real Property (26)

! 1 A6018 Mortgage Foreclosure

1 1 A6032 Quiet Title

J A6060 OtherRealProperty(noteminentdomain,landlord/tenant, foreclosure)

2.. 6.

2.. 6

2., 6.

Unlawful Detainer-Commercial (31)

_ j A6021 Unlawful Detainer-Commercial (not drugs or wrongful eviction) 2., 6.

Unlawful Detainer-Residential(32) J A6020 Unlawful Detainer-Residential (not drugs or wrongful eviction) 2., 6.

Unlawful Detainer- Post-Foreclosure (34) [ J A6020F Unlawful Detainer-Post-Foreclosure 2.. 6

Unlawful Detainer-Drugs (38) 1___ ¡ A6022 Unlawful Detainer-Drugs 2.. 6

LACIV 109 (Rev. 03/11)LASC Approved 03-04


Local Rule 2.0Page 2 of 4

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SHORTTITLE YELCHIN, et al. , vs. FCA US LLC, et al CASE NUMBER

A B cCivil Case Cover Sheet

Category No.Type of Action

(Check only one)Applicable Reasons -

See Step 3 Above

Asset Forfeiture (05) 1 1 A6108 Asset Forfeiture Case 2., 6.

Petition re Arbitration (11) 1___ 1 A6115 Petition to Compel/Confirm/Vacate Arbitration 2.. 5.

1 ! A6151 Writ - Administrative Mandamus 2., 8.Writ of Mandate (02) 1 1 A6152 Writ - Mandamus on Limited Court Case Matter 2.

1 1 A6153 Writ - Other Limited Court Case Review 2.

Other Judicial Review (39) i___ ! A6150 Other Writ/Judicial Review 2.. 8

Antitrust/Trade Regulation (03) 1 ] A6003 Antitrust/Trade Regulation 1.. 2., 8.

Construction Defect (10) [___ ] A6007 Construction Defect 1., 2.. 3.

Claims Involving Mass Tort (40) [___ ] A6006 Claims Involving Mass Tort 1.. 2., 8.

Securities Litigation (28) [ J A6035 Securities Litigation Case 1., 2., 8.

Toxic Tort Environmental (30) 1 1 A6036 Toxic Tort/Environmental 1.. 2.. 3.. 8

Insurance Coverage Claims from Complex Case (41) 1 1 A6014 Insurance Coverage/Subrogation (complex case only) 1., 2.. 5., 8

1 A6141 Sister State Judgment 2.. 9.

1___ A6160 Abstract of Judgment 2., 6

Enforcement ] A6107 Confession of Judgment (non-domestic relations) 2.. 9.of Judgment (20) [ I A6140 Administrative Agency Award (not unpaid taxes) 2.. 8

[___ | A6114 Petition/Certificate for Entry of Judgment on Unpaid Tax 2., 8.

1 i A6112 Other Enforcement of Judgment Case 2.. 8., 9.

RICO (27) [___ 1 A6033 Racketeering (RICO) Case 1., 2.. 8

___ ] A6030 Declaratory Relief Only 1.. 2.. 8.

Other Complaints j A6040 Injunctive Relief Only (not domestic/harassment) 2„ 8(Not Specified Above) (42) ___ j A6011 Other Commercial Complaint Case (non-tort/non-complex) 1.. 2.. 8.

___ A6000 Other Civil Complaint (non-tort/non-complex) 1.. 2.. 8

Partnership Corporation Governance (21)

[ 1 A6113 Partnership and Corporate Governance Case 2„ 8

[ A6121 Civil Harassment 2., 3., 9.

71 A6123 Workplace Harassment 2.. 3., 9.

Other Petitions 1 1 A6124 Elder/Dependent Adult Abuse Case 2.. 3.. 9

(Not Specified Above) ¡ j A6190 Election Contest 2.(43)

A6110 Petition for Change of Name 2., 7.

!___ j A6170 Petition for Relief from Late Claim Law 2.. 3.. 4.. 8

A6100 Other Civil Petition 2.. 9

LACIV 109 (Rev. 03/11)LASC Approved 03-04


Local Rule 2.0D o n o *3 o f A . w y w ~ vJ. ‘ »

SHORTTiuH: Y E L C H IN , e t a l . ( v s . FCA US L L C , e t a l . CASE NUMBER

Item III. Statement of Location: Enter the address of the accident, party's residence or place of business, performance, or other circumstance indicated in Item II., Step 3 on Page 1, as the proper reason for filing in the court location you selected.

REASON: Check the appropriate boxes for the numbers shown under Column C for the type of action that you have selected for this case.

aooress: B e r r y D r iv e

□ i E i 2. a 3. a 4. n 5 0 6 .1z 17.0 8 . a 9.010.CITY: STATE. ZIP CODE

S tu d io C i t y CA 91604

Item IV . Declaration of Assignment I declare under penalty of perjury under the laws of the State of California that the foregoing is trueand correct and that the above-entitled matter is properly filed for assignment to the L o s A n g e le s ___________ courthouse in the

C e n t r a l_________ District of the Superior Court of California, County o f Los Angeles [Code Civ. P r p c r r T ^ et seq., and LocalRule 2 .0 , subds. (b), (c) and (d)J.

Dated:A u g u st 2 . 2016

PLEASE HAVE THE FOLLOW ING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY COMMENCE YOUR NEW COURT CASE:

1. Original Complaint or Petition.

2. If filing a Complaint a completed Summons form for issuance by the Clerk.

3. Civil Case Cover Sheet Judicial Council form CM-010.

4. Civil Case Cover Sheet Addendum and Statement of Location form, LA C IV109, LASC Approved 03-04 (Rev. 03/11).

5. Payment in full of the filing fee, unless fees have been waived.

6. A signed order appointing 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.

LACIV 109 (Rev. 03/11)

LASC Approved 03-04CIVIL CASE COVER SHEET ADDENDUM

AND STATEMENT OF LOCATIONLocal Rule 2.0

Page 4 of 4

SUM-100(CITACION JUDICIAL)

NOTICE TO DEFENDANT: FCA OS LLC; ZF NORTH AMERICA, (A V IS O A L D E M A N D A D O ): INC.; AUTO COMPANY XXIII, INC., dba AUTONATION CHRYSLER DODGE JEEP VALENCIA and CA SUPERSTORES VALENCIA CJD; and DOES 1 to 100, Inclusive

YOU ARE BEING SUED BY PLAINTIFF: VICTOR YELCHIN, an ( L O E S T Á D E M A N D A N D O E L D E M A N D A N T E ): individual, IRINA YELCHINA, an individual; and the ESTATE OF ANTON YELCHIN, by and through his Successors-in-Interest, VICTOR YELCHIN and IRINA YELCHINA

« » COURT USE O NLY (SO LO PARA USO DE LA COftTQ

C O N F O R M E D C O P Y O R IG IN A L FILED

Superior Court ol California County of Los Annoles

MJG 0 2 W 6

! h e rri R . C arter, Executive « Ite e r/C le rk By: Juéi Lara. Deputy

NOTICEI You have been sued. The court may decide against you without your being heard unless you respond within 30 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 w ill not protect you. Your written response must be in proper legal form if you want the court to hear your case. There tray be a court form that you can use for your response. You can find these court forms and more information at the California Courts Online Self-Help Center (vm w.courfinfo.ca.gov/sefflrefo), your county law library, or the courthouse nearest you. If you cannot pay the filing fee, ask the court derk for a fee waiver form. If you do not file your response on time, you m ay tose 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 m ay w ant to call an attorney tight away. If you do not know an attorney, you may want to call an attorney referral service. If you cannot afford an attorney, you m ay be eligible for free legal services from a nonprofit legal services program. You can loarte these nonprofit groups at the California Legal Services W eb site (iraw .lawtielpcalifom ia.org), the California Courts Online Seif-Help Center (www.courlrnfo.ca.gov/seffoefo). or by contacting your local court or county bar association. NO TE: The court has a statutory lien for waived fees and costs on any settlement or arbitration award o f $10,000 or more in a civil case. The court's lien must be paid before the court will dismiss the case. lA V IS O l Lo hen demandado. Sr’ no responde dentro de 30 dies, la corte puede decidir en su contra sin escuchar su versión. Lea la información a continuación

Tiene 3 0 DÍAS D E CALENDARIO después de que le entreguen esta citación y papeles legales para presentar una respuesta por escrito en esta corte y hacer que se entregue una copia a l dem andante. Una carta o una llamada telefónica no lo protegen. Su respuesta por escrito tiene que estar en tom ato legal correcto sf desea que procesen su caso en la corte. Es posible que haya un formulario que usted p ia d a usar para su respuesta. Puede encontrar estos formularios de la corle y m ás información en el Centro de Ayuda de las Cortas de California (Www.sucorte.ca.gov), en la biblioteca de leyes de su condado o en la corte que le quede m is cerca. S i no puede pagar la cuota de presentación, pida a l secretario de la corte que le dé un formulario de exención de pago de cuotas. S i no presenta su respuesta a tiempo, puede perder e l caso por incumplimiento y la corte te podrá quitar su sueldo, dinero y bienes sin más advertencia.

Hay otros requisitos legales. Es recomendable que llam e a un abogado inmediatamente. S i no conoce a un abogado, puede llam ara un servicio de remisión a abogados. Si no puede pagar a un abogado, es posible que cumpla con los requisitos para obtener servicios legales gratuitos de un programa de servidos legales sin fines de lucro. Puede encontrar estos grupos sin Unes de lucro en e l sido web de California Legal Services, (Wvm.lawhelpcalifomia.org), en e l Centro de Ayuda de las Cortes de California, (Www.sucorte.ca.gov) o poniéndose en contacto con la corte o e l colegio de abogados locales. A VISO: Por ley, la corte tiene derecho a reclam ar las cuotas y los costos exentos por im poner un gravamen sobre cualquier recuperación de $10,000 ó m is de valor redbida mediante un acuerdo o una concesión de arbitraje en un caso de derecho civil. Tiene que pagar el gravamen de la corte antes de que la corte pueda desechar e l caso.___________________

The name and address ot the court is:(E l nom bra y d irección d e la corte e s ):SUPERIOR COURT OF CALIFORNIA 111 North Hill Street Los Angeles, California 90012 Central DistrictThe name, address, and telephone number of plaintiffs attorney, or plaintiff without an attorney, is:(E l nom bre, la d irección y e l núm ero d e te lé fo n o d e l abogado d el dem andante, o d e l d em and ante que no tien e abogado, es ):Gary A. Dordick, Esq. S/B# 128008 Tel: 310-551-0949 Fax: 855-299-4444GARY A. DORDICK, A LAW CORPORATION

CASE NUMBER:, (Núm ero d e l 6 2 9 0 9 6

509 South Beverly Drive Beverly Hills, CaliforniaSSL 2 2816

90212 gHERRULCARIERClerk, by

&(Secretario)

Deputy(Adjunto)

(For proof ol service of this summons, use Proof of Service of Summons (form POS-010).)(Para prueba de entrega de esta citatión use el formulario Proof of Service of Summons, (POS-010)).

NOTICE TO THE PERSON SERVED: You are served1. I I as an individual defendant.2. I I as the person sued under the fictitious name of (sp ecify ):

3. I I on behalf of (specify):

under: | | CCP 416.10 (corporation)I I CCP 416.20 (defunct corporation)I I CCP 416.40 (association or partnership)I I o ther (specify):

4. I I by personal delivery on (date):_________________

|------1 CCP 416.60 (minor)|----- 1 CCP 416.70 (conservatee)| | CCP 416.90 (authorized person)

Pago 1 oM

Fora Adopted tor Mandatory Use •tósaal Coursi o! CaWcma

SUM-100 [Rav July 1.20091

SUMMONS Cods of Civil Procedure §§ 412.20,465

SoiuOgnsS^Plus

http://www.courlrnfo.ca.gov/seffoefo

http://Www.sucorte.ca.gov

http://Www.sucorte.ca.gov

fr

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Gary A. Dordick, Esq. S/B# 128008Diana S. Diskin, Esq. S/B# 251366GARY A. DORDICK, A LAW CORPORATION509 South Beverly DriveBeverly Hills, California 90212-4514Tel: (310) 551-0949 • Fax: (855) 299-4444Email: [email protected]: [email protected]

Attorneys for Plaintiffs

C O N F O R M E D C O P Y O R IG IN A L F ILED

Superior Court of CaliforniaCounty of Los Ancietes

MIG 02 2016

Sherri R. Carter, Executive Otflcer/Clerk By: Judi Lara, Deputy

SUPERIOR COURT FOR THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

VICTOR YELCHIN, an individual, IRINA ) CASE NO.: 1C $ & * °YELCHINA, an individual: and the )ESTATE OF ANTON YELCHIN, by andthrough his Successors-in-lnterest, ) COMPLAINT FOR DAMAGESVICTOR YELCHIN and IRINAYELCHINA,

Plaintiffs, ) JURY TRIAL DEMANDED

v. j

FCA US LLC; ZF NORTH AMERICA, )INC.; AUTO COMPANY XXIII, INC., dba)AUTONATION CHRYSLER DODGE JEEP VALENCIA and CA )SUPERSTORES VALENCIA CJD; and DOES 1 to 100, Inclusive, j

Defendants. )

VICTOR YELCHIN, an individual; IRINA YELCHINA, an individual; and the

ESTATE OF ANTON YELCHIN, by and through his Successors-in-lnterest, VICTOR

YELCHIN and IRINA YELCHINA, allege as follows:

1. Plaintiff VICTOR YELCHIN is the surviving father to decedent ANTON

YELCHIN and is a resident of Los Angeles County, California. Plaintiff VICTOR

YELCHIN has standing to file this action for Decedent’s wrongful death pursuant to

Code of Civil Procedure sections 377.11,377.32, and 377.60. Plaintiff VICTOR

___________________________________1.________________________________COMPLAINT FOR DAMAGES

mailto:[email protected]


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YELCHIN succeeded to the Decedent's interest in the action because, at the time of

Decedent's death, the Decedent was not married and had no children. The statement

required pursuant to Code o f Civil Procedure section 377.32 is attached hereto as

Exhibit “1”.

2. Plaintiff IRINA YELCHINA is the surviving mother to decedent ANTON

YELCHIN and is a resident of Los Angeles County, California. Plaintiff IRINA

YELCHINA has standing to file this action for Decedent’s wrongful death pursuant to

Code of Civil Procedure sections 377.11,377.32, and 377.60. Plaintiff IRINA

YELCHINA succeeded to the Decedent's interest in the action because, at the time of

Decedent’s death, the Decedent was not married and had no children. The statement

required pursuant to Code o f Civil Procedure section 377.32 is attached hereto as

Exhibit T .

3. Plaintiffs are informed and believe, and based upon such information and

belief, allege that they are the Decedent’s lawful heirs and successors-in-interest, and

therefore this Complaint does not name any adverse heir in connection with this claim

for Wrongful Death.

4. Plaintiffs are informed and believe and, based upon such information and

belief, allege that Defendant FCA US LLC is now and at all times mentioned herein an

unknown business entity authorized and/or qualified to do business and is doing

business in the State of California.


belief, allege that Defendant FCA US LLC engages in the business of designing,

manufacturing, testing, marketing, and distributing the 2015 Jeep Grand Cherokee

Model, License No. 7HXG997 (hereinafter the “Subject Vehicle") which included the

defective monostable gear selector, also known as a monostable electronic "E-shift”

gear shift assembly (hereinafter the “Subject Gear Selector”) which has caused the

death of ANTON YELCHIN.

Ill

__________________________________ 2.__________________________________COMPLAINT FOR DAMAGES

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belief, allege that Defendant ZF NORTH AMERICA, INC., is now and at all times

mentioned herein an unknown business entity authorized and/or qualified to do

business and is doing business in the State of California.


belief, allege that Defendant ZF NORTH AMERICA, INC., engages in the business of

designing, manufacturing, testing, marketing, and distributing the Subject Gear Selector

featured in the Subject Vehicle which has caused the death of ANTON YELCHIN.


belief, allege that Defendant AUTO COMPANY XXlll, INC., dba AUTONATION

CHRYSLER DODGE JEEP VALENCIA and CA SUPERSTORES VALENCIA CJD, is

now and at all times mentioned herein an unknown business entity authorized and/or

qualified to do business and is doing business in the State of California.


belief, allege that Defendant AUTO COMPANY XXlll, INC., dba AUTONATION

CHRYSLER DODGE JEEP VALENCIA and CA SUPERSTORES VALENCIA CJD,

engages in the business of selling and/or leasing vehicles, including the Subject Vehicle

which has caused the death of ANTON YELCHIN.


belief, allege that Defendants FCA US LLC, ZF NORTH AMERICA, INC., AUTO

COMPANY XXlll, INC., dba AUTONATION CHRYSLER DODGE JEEP VALENCIA and

CA SUPERSTORES VALENCIA CJD, and DOES 1 to 100, and each of them were the

manufacturers, designers, developers, processors, producers, assemblers, builders,

testers, inspectors, installers, equippers, endorsers, exporters, wholesalers, retailers,

lessors, renters, sellers, modifiers, servicers, repairers, providers and otherwise

distributors of the Subject Vehicle and Subject Gear Selector.

HI

III

3.COMPLAINT FOR DAMAGES

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belief, allege that DOES 1 to 100, and each of them, are individuals, corporations,

partnerships, limited partnerships, associations, trusts, parent companies and/or

subsidiaries put together with the other aforementioned individuals or entities duly

authorized to do and are doing business in the State of California.

12. The true names and capacities - whether individual, corporate,

governmental, associate(d) or otherwise - of Defendants Does 1 through 100, inclusive,

and each of them, are unknown to Plaintiffs, who therefore sue said Defendants by

such fictitious names.

13. Plaintiffs are informed and believe and, upon such information and belief,

allege that each of the Defendants fictitiously named herein as a Doe is legally

responsible, negligently or in some other actionable manner, for the events and

happenings hereinafter referred to and that, thereby, each proximately caused the

wrongful death of ANTON YELCHIN and the injuries and damages to Plaintiffs as

hereinafter alleged.

14. Plaintiffs will amend this Complaint to show the true names and capacities

of such fictitiously named Defendants when such names and capacities have been

ascertained together with the proper charging allegations.


belief, allege that all of the acts, conduct, and nonfeasance herein carried out by each

and every representative, employee, or agent of each and every corporate and

business Defendant was authorized, ordered, and directed by their and/or its respective

Defendant’s corporate or business employers, officers, directors, and/or managing

agents. In addition thereto, said corporate or business employers, officers, directors,

and/or managing agents had advance knowledge of and authorized and participated in

the herein described acts, conduct, and nonfeasance of their representatives,

employees, agents, and each of them. In further addition thereto, upon the completion

of the aforesaid acts, conduct, and nonfeasance of the aforesaid employees and


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agents, the aforesaid corporate and business employers, officers, directors, and/or

managing agents respectively ratified, accepted the benefits of, condoned and

approved of each and all of said acts, conduct, and/or nonfeasance of their

co-employees, employees, and agents. In addition, at all times herein relevant, each

Defendant, whether named herein or designated as a Doe, was a principal, master,

employer, and/or joint venturer of every other Defendant, and every Defendant was

acting within the course and scope of said agency, authority, employment and joint

venture.


belief, allege that between at least 2011 and 2015, Defendants FCA US LLC and ZF

NORTH AMERICA, INC., designed and manufactured the defective Subject Gear

Selector.


belief, allege that between at least 2011 and 2015, Defendant FCA US LLC designed

and manufactured certain vehicles, including the 2012-2014 Dodge Charger, 2012-

2014 Chrysler 300, 2014 Dodge Durango, 2014-2015 Jeep Grand Cherokee, and the

Subject Vehicle, and that said vehicles included the defective Subject Gear Selector.


belief, allege that between at least 2011 and 2015, Defendants FCA US LLC and AUTO

COMPANY XXIII, INC., dba AUTONATION CHRYSLER DODGE JEEP VALENCIA and

CA SUPERSTORES VALENCIA CJD, and DOES 1 to 100, inclusive, sold certain

vehicles, including the 2012-2014 Dodge Charger, 2012-2014 Chrysler 300, 2014

Dodge Durango, 2014-2015 Jeep Grand Cherokee, and the Subject Vehicle, to the

general public and that said vehicles included the defective Subject Gear Selector.


belief, allege that the Subject Vehicle, the Subject Gear Selector, and/or their

components possessed one or more defects in design, manufacture, or otherwise,

which were either known or should have been known by Defendants. The defect(s)


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substantially caused ANTON YELCHIN’s death and Plaintiffs’ injuries as more fully

described herein.

20. More specifically, Plaintiffs are informed and believe and, based upon

such information and belief, allege that the design and/or manufacture of the Subject

Vehicle - and other certain vehicles, including the 2012-2014 Dodge Charger, 2012-

2014 Chrysler 300, 2014 Dodge Durango, and 2014-2015 Jeep Grand Cherokee - as

well as the design and/or manufacture of the Subject Gear Selector were defective in

that the Subject Gear Selector has an unfamiliar movement that is not intuitive and that

provides poor tactile and visual feedback to drivers, increasing the potential for

unintended gear selection and vehicle rollaway. Drivers could exit these vehicles when

the engine is running and the transmission is not in PARK, resulting in unattended

vehicle rollaway. Further, the Subject Vehicle - and these other certain vehicles,

including the 2012-2014 Dodge Charger, 2012-2014 Chrysler 300, 2014 Dodge

Durango, 2014-2015 Jeep Grand Cherokee- failed to include sufficient rollaway

prevention features as well as sufficient warning features and/or measures so as to

prevent drivers from exiting these vehicles with the engine running and the transmission

not in PARK and/or to avoid vehicle rollaway

21. Plaintiffs are also informed and believe and, based upon such information

and belief, allege that the design and/or manufacture of the Subject Vehicle - and other

certain vehicles, including the 2012-2014 Dodge Charger, 2012-2014 Chrysler 300,

2014 Dodge Durango, and 2014-2015 Jeep Grand Cherokee - as well as the design

and/or manufacture of the Subject Gear Selector were defective in that these vehicles’

ignition START/STOP button could fail to engage, resulting in incidents where drivers

believed they put the vehicle in PARK and attempted to shutoff the vehicle using the

ignition ON/OFF button, then exited the vehicle without realizing that the vehicle was

not in PARK and the engine continued to run.

Ill

III


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belief, allege that, by at least August 2015, Defendants FCA US LLC, ZF NORTH

AMERICA, INC., and AUTO COMPANY XXIII, INC., dba AUTONATION CHRYSLER

DODGE JEEP VALENCIA and CA SUPERSTORES VALENCIA CJD, and DOES 1 to

100, inclusive, were aware of multiple crashes and numerous additional complaints

attributed to the defective Subject Gear Selector in its Chysler 300 and Dodge Charger.

Nevertheless, Defendants and each of them recklessly installed the defective Subject

Gear Selector into the 2014 and 2015 Grand Cherokee. As of April 12,2016, the

defective design and/or manufacture of the Subject Vehicle and Subject Gear Selector

had resulted in at least 700 field reports to Defendant FCA US LLC that were potentially

related to this issue, including 212 crashes, 308 claims of property damage, and at

least 41 injuries. The defective design and/or manufacture of the Subject Vehicle and

Subject Gear Selector affected at least 800,000 vehicles.


belief, allege that, despite said actual knowledge of the defective design and/or

manufacture of the Subject Vehicle and Subject Gear Selector, Defendants FCA US

LLC, ZF NORTH AMERICA, INC., AUTO COMPANY XXIII, INC., dba AUTONATION

CHRYSLER DODGE JEEP VALENCIA and CA SUPERSTORES VALENCIA CJD, and

DOES 1 to 100, inclusive, failed to timely and/or adequately remedy the defective

Subject Vehicle and/or defective Subject Gear Selector.


belief, allege that, on June 19, 2016, decedent ANTON YELCHIN was the operator of

the Subject Vehicle and that the Subject Vehicle was being used in a reasonably

foreseeable manner in Studio City, in the State of California.

25. Plaintiffs are informed and believe and allege that, on or about June 19,

2016, decedent ANTON YELCHIN parked the Subject Vehicle at or near the top of his

driveway, then exited the Subject Vehicle and traversed towards the base of his

driveway. As a result of the defective design and/or manufacture of the Subject


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Vehicle, the Subject Vehicle did not properly engage and/or maintain the “Park” gear

position, causing the unmanned Subject Vehicle to travel down the driveway, where it

impacted ANTON YELCHIN. ANTON YELCHIN was crushed and lingered alive for

some time, trapped and suffocating until his death.

FIRST CAUSE OF ACTION BY PLAINTIFFS AGAINST FCA US LLC. ZF NORTH

AMERICA. INC.. AUTO COMPANY XXIII. INC., dba AUTONATION CHRYSLER

DODGE JEEP VALENCIA and CA SUPERSTORES VALENCIA CJD. AND DOES 1

TO 100. INCLUSIVE FOR STRICT LIABILITY

26. Plaintiffs re-allege Paragraphs 1 through 25 and incorporate them by

reference as though fully set forth herein.

27. Plaintiffs are informed and believe and thereon allege that at all times

herein mentioned, Defendants FCA US LLC, ZF NORTH AMERICA, INC., AUTO

COMPANY XXIII, INC., dba AUTONATION CHRYSLER DODGE JEEP VALENCIA and

CA SUPERSTORES VALENCIA CJD, and DOES 1 through 100, inclusive, and each of

them, were the manufacturers, designers, developers, processors, producers,

assemblers, builders, testers, inspectors, installers, warners, equippers, endorsers,

exporters, wholesalers, retailers, renters, sellers, lessors, modifiers, servicers, repairers,

providers, and/or distributors of the Subject Vehicle as well as the Subject Gear

Selector used in the Subject Vehicle.


belief, allege that the Subject Vehicle and the Subject Gear Selector in the Subject

Vehicle was defective at the time of its manufacture, design, development, production,

assembly, building, testing, inspection, installation, equipping, endorsement,

exportation, importation, wholesaling, retailing, selling, renting, leasing, modification,

service, repair and entrustment.


belief, allege that the Subject Vehicle along with the Subject Gear Selector failed to


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meet the reasonable expectations of safety for the class of persons of which Decedent

and Plaintiffs were members.


belief, allege that any benefits derived from the design of the Subject Vehicle and/or

Subject Gear Selector were substantially outweighed by the risk of harm inherent in

said design in that, and not by way of limitation, despite the availability to defendants of

safer alternative designs, said defective Subject Vehicle and/or Subject Gear Selector

presented a substantial and unreasonable risk of injury and/or death to the users of the

Subject Vehicle or those in the vicinity of the Subject Vehicle.

31. Specifically, Plaintiffs are informed and believe and, based upon such

information and belief, allege that said Subject Vehicle and Subject Gear Selector were

defective in their design, construction, assembly and manufacture and dangerous to life

and limb of the users and occupants thereof, in that, among other things and not by

way of limitation, the Subject Vehicle and Subject Gear Selector were so poorly

designed and manufactured that they failed to maintain their integrity under normal

operating conditions, including the subject incident. The aforementioned defects

created a substantial danger which was unknown to Decedent and Plaintiffs and to the

public in general, and would not be recognized by the ordinary user, and Defendants

and each of them failed to give adequate warning of such danger.


belief, allege that prior to the sale and distribution of said Subject Vehicle, Defendants

FCA US LLC, ZF NORTH AMERICA, INC., AUTO COMPANY XXIII, INC., dba

AUTONATION CHRYSLER DODGE JEEP VALENCIA and CA SUPERSTORES

VALENCIA CJD, and DOES 1 through 100, inclusive, and DOES 1 to 100, knew the

Subject Vehicle and/or Subject Gear Selector were in a defective condition as

previously described. Further, said Defendants, through their officers, directors and

managing agents, had prior notice and knowledge of the defects and/or defective

design of Subject Vehicle and Subject Gear Selector and that these defects and/or

__________________________________ 9.__________________________________COMPLAINT FOR DAMAGES

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defective design presented a substantial and unreasonable risk of harm to the

American motoring public, including decedent ANTON YELCHIN and Plaintiffs in that

said defects and/or defective design unreasonably subjected vehicle operators and/or

occupants to injury and death as a result of failure in the event of foreseeable motor

vehicle use and misuse. Defendants’ prior notice and knowledge arose from several

sources, including but not limited to multiple tests, investigations, and test results

available prior to the date of said accident, internal memoranda and correspondence,

industry publications, as well as notice of multiple injuries and hundreds of complaints

caused by the design of the Subject Vehicle and Subject Gear Selector.

33. Additionally, Plaintiffs are informed and believe and, based upon such

information and belief, allege that Defendants, and each of them, had unfettered ability,

after years of extensive in-house, government, and independent testing to minimize the

substantial risk of serious bodily harm or death caused by the Subject Vehicle and

Subject Gear Selector by redesigning or warning of the potential for serious risk or

harm, thereby minimizing or eliminating said potential. But Defendants consciously

chose not to take steps to exercise that ability, including but not limited to, providing

proper design and manufacturing provisions, and Defendants' failure to take such steps

allowed Defenadnts to save money, avoid loss of sales, and repair and recall costs.

Defendants’ acts prevented the public from becoming aware that the defects in the

Subject Vehicle and Subject Gear Selector were, in reality, unsafe, dangerous, and

defective, and/or prevented the public from realizing the extent of danger presented by

the defects, thereby causing the injuries, death, and damages to Decedent and

Plaintiffs. In addition, Plaintiffs are informed and believe and thereon allege that the

aforementioned malfeasance, nonfeasance, defects, failure to warn, were done with the

advanced knowledge, authorization, approval and ratification of officers, directors

and/or managing agents of the aforesaid Defendants.


belief, allege that Defendants, and each of them, failed to timely admit that the Subject


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Vehicle and Subject Gear Selector were defectively designed and/or manufactured, and

unreasonably delayed in issuing an effective recall of the Subject Vehicle.

35. As a further proximate result of the acts of defendants, and each of them,

and due to the dangerous condition as alleged, Plaintiffs have incurred substantial

funeral and burial expenses.

36. As a proximate result of the above-described conduct of Defendants, and

each of them, the Plaintiffs have and will, suffer the loss of Decedent's love,

companionship, guidance, comfort, society, solace, moral support, financial support and

physical assistance, all to their general damages, in a sum to be proven at time of trial.

37. Defendants FCA US LLC, ZF NORTH AMERICA, INC., AUTO COMPANY

XXIII, INC., dba AUTONATION CHRYSLER DODGE JEEP VALENCIA and CA

SUPERSTORES VALENCIA CJD, and DOES 1 through 100, inclusive, their acts

and/or omissions were either committed by or authorized, ratified, or otherwise

approved in a deliberate, cold, callous, malicious, reckless, intentional, and/or

unreasonable manner, as fully set forth above, under California Civil Code section

3294, causing injury and damage to plaintiffs, and the death of ANTON YELCHIN and

done with a conscious disregard of Plaintiffs’ and Decedent’s rights and safety,

Plaintiffs request the assessment of punitive damages against Defendants in an

amount appropriate to punish or set an example of them.

SECOND CAUSE OF ACTION BY PLAINTIFFS AGAINST DEFENDANTS FCA US

LLC. ZF NORTH AMERICA. INC.. AUTO COMPANY XXIII. INC., dba AUTONATION

CHRYSLER DODGE JEEP VALENCIA and CA SUPERSTORES VALENCIA CJD.

AND DOES 1 THROUGH 100. INCLUSIVE. FOR NEGLIGENT PRODUCT LIABILITY

38. Plaintiffs re-allege Paragraphs 1 through 37 and incorporates them by



belief, allege that, at all times herein mentioned, Defendants, and each of them, had a


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duty not to unreasonably manufacture, develop, design, process, produce, assemble,4

build, test, inspect, install, warn, equip, endorse, export, import, wholesale, retail, sell,

lease, rent, modify, service, repair, or entrust said Subject Vehicle and Subject Gear

Selector.


belief, allege that said Defendants, and each of them, breached their duty to Decedent

ANTON YELCHIN and plaintiffs, thereby causing injuries, death, and damages as

herein described. More specifically, Defendants, and each of them acted unreasonably

in designing, installing, selling, manufacturing, and marketing products which presented

a substantial and unreasonable risk of injury or death to vehicle occupants, including

Decedent ANTON YELCHIN and Plaintiffs, and in failing to warn of such dangers.


belief, allege that, at all relevant times herein mentioned, Defendants, and each of

them, breached their duty of ordinary care or skill in that they negligently, wantonly,

carelessly, recklessly and/or unlawfully installed, service, tested, inspected, maintained,

modified, changed, designed and manufactured and furnished the defective Subject

Vehicle and Subject Gear Selector so as to cause, permit and/or allow the same to be

in a dangerous, defective, unguarded and unsafe condition, and such acts and/or

omissions were a substantial factor contributing to the injuries suffered by Plaintiffs and

the death of ANTON YELCHIN, as herein alleged.


belief, allege that the negligence of said Defendants, and each of them, was a

substantial factor in causing the injuries, death, and damages herein alleged.

43. As a further proximate result of the acts and omissions of Defendants,

and each of them, and due to the dangerous condition as alleged, Plaintiffs have

incurred funeral and burial expenses and will continue to incur other cost related

expenses, the total amount of such expenses are not known to Plaintiffs at this time

III


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and plaintiffs will move to amend this complaint to state such amount when the same

becomes known to them, or on proof thereof.


each of them, the Plaintiffs have and will, suffer the loss of Decedent ANTON

YELCHIN’s consortium, love, companionship, guidance, comfort, society, solace, moral

support, all to their general damages, in a sum to be proven at time of trial.

45. Because the acts and/or omissions of Defendants FCA US LLC, ZF

NORTH AMERICA, INC., AUTO COMPANY XXIII, INC., dba AUTONATION


DOES 1 THROUGH 100, inclusive, were either committed by or authorized, ratified, or

otherwise approved in a deliberate, cold, callous, malicious, intentional, and/or

unreasonable manner, as fully set forth herein, causing injury and damage to Plaintiffs,

and the death of ANTON YELCHIN, and were done with a conscious disregard of

Plaintiffs’ and Decedent's rights and safety, Plaintiffs request the assessment of

punitive damages against Defendants in an amount appropriate to punish or set an

example of them, pursuant to under Civil Code section 3294.

THIRD CAUSE OF ACTION BY PLAINTIFFS AND AGAINST DEFENDANTS FCA US



AND DOES 1 THROUGH 100. INCLUSIVE. FOR BREACH OF WARRANTY




belief, allege that, at all times herein mentioned, Defendants FCA US LLC, ZF NORTH

AMERICA, INC., AUTO COMPANY XXIII, INC., dba AUTONATION CHRYSLER

DODGE JEEP VALENCIA and CA SUPERSTORES VALENCIA CJD, and DOES 1

THROUGH 100, inclusive, designed, developed, processed, repaired, serviced,


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inspected, represented, tested, distributed, sold, consigned, delivered, maintained,

installed, and operated for purpose of sale and distribution said Subject Vehicle and

Subject Gear Selector for use by the general public.


belief, allege that at the time and place of said sale, delivery, distribution, repair,

service, installation, consignment, maintenance, or operation of said products,

Defendants FCA US LLC, ZF NORTH AMERICA, INC., AUTO COMPANY XXIII, INC.,

dba AUTONATION CHRYSLER DODGE JEEP VALENCIA and CA SUPERSTORES

VALENCIA CJD, and DOES 1 THROUGH 100, inclusive, expressly, implicitly, and

impliedly warranted to each buyer and user and to all persons reasonably expected to

be in the immediate vicinity of said products during use in any manner, that said

Subject Vehicle and Subject Gear Selector were reasonably fit and safe for their

intended purposes, and that said products were accordingly of merchantable quality

throughout.


belief, allege that, at the time and place of said sale, delivery, installation, distribution or

supply, the Subject Vehicle and Subject Gear Selector were not reasonably fit and safe

for their intended uses by buyers, users, or persons reasonably anticipated to be in the

vicinity of the use of the Subject Vehicle, including Decedent ANTON YELCHIN, and

were, therefore, not of merchantable quality and constituted extreme danger and

hazard to persons using or in the vicinity of the Subject Vehicle and/or Subject Gear

Selector, due to the latent defects in the Subject Vehicle and/or Subject Gear Selector.


belief, allege that, in reliance upon such warranties, Decedent ANTON YELCHIN

operated the Subject Vehicle with the Subject Gear Selector installed in it, in a manner

foreseeable and as intended by Defendants. Plaintiffs are informed and believe and,

based upon such information and belief, allege that, as a direct and substantial result of

the breach of such implied warranty by these Defendants, and each of them, the


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Subject Vehicle and/or Subject Gear Selector malfunctioned causing the Subject

Vehicle to roll away and strike ANTON YELCHIN, resulting in his untimely death.

51. As a result of said breaches of warranty, both express and implied,

Plaintiffs sustained injuries, death, and damages as herein alleged.


and due to the dangerous condition as alleged, Plaintiffs have incurred funeral and

burial expenses and will continue to incur other cost related expenses, the total amount

of such expenses are not known to Plaintiffs at this time and plaintiffs will move to

amend this complaint to state such amount when the same becomes known to them, or

on proof thereof.



YELCHIN’s consortium, love, companionship, guidance, comfort, society, solace, moral






otherwise approved in a deliberate, cold, callous, malicious, intentional, and/or



Plaintiffs’ and Decedent’s rights and safety, Plaintiffs request the assessment of



I ll

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FOURTH CAUSE OF ACTION BY PLAINTIFFS AGAINST DEFENDANTS FCA US



AND DOES 1 THROUGH 100. INCLUSIVE. FOR NEGLIGENCE (WRONGFUL

DEATH AND PERSONAL INJURIES)



56. Plaintiffs are informed and believe, and thereupon allege, that at said time

and place, Defendants FCA US LLC, ZF NORTH AMERICA, INC., AUTO COMPANY

XXIII, INC.,, dba AUTONATION CHRYSLER DODGE JEEP VALENCIA and CA

SUPERSTORES VALENCIA CJD, and DOES 1 THROUGH 100, inclusive, and each of

them negligently, recklessly and carelessly manufactured, designed, developed,

processed, produced, assembled, built, tested, inspected, installed, warned, equipped,

endorsed, exported, wholesaled, retailed, lessors, rented, sold, modified, serviced,

repaired, installed, provided, and/or otherwise distributed the Subject Vehicle and

Subject Gear Selector, which malfunctioned and caused the Subject Vehicle to roll

away and strike ANTON YELCHIN, resulting in his untimely death.

57. Defendants, and each of them, knew or should have known that it was

likely that a person such as Decedent ANTON YELCHIN would use the Subject Vehicle

in a reasonably foreseeable manner and would suffer serious injuries and even death

because of the defect(s) of the Subject Vehicle and Subject Gear Selector.

58. As a direct and proximate result of the conduct of Defendants, and each

of them, ANTON YELCHIN sustained severe injuries which resulted in his untimely

death.


and due to the dangerous condition as alleged, Plaintiffs have incurred funeral and

burial expenses and will continue to incur other cost related expenses, the total amount

of such expenses are not known to Plaintiffs at this time and plaintiffs will move to


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amend this complaint to state such amount when the same becomes known to them, or

on proof thereof.



YELCHIN's consortium, love, companionship, guidance, comfort, society, solace, moral






otherwise approved in a deliberate, cold, callous, malicious, reckless, intentional, and/or



Plaintiffs’ and Decedent’s rights and safety, Plaintiffs request the assessment of



62. Plaintiffs are the lawful heirs of Decedent ANTON YELCHIN, as defined

under California Code of Civil Procedure, sections 377.11 and 377.60.

DEMAND FOR JURY TRIAL

Plaintiffs VICTOR YELCHIN, individually and as Successor-In-Interest to

ANTON YELCHIN, and IRINA YELCHINA, individually and as Successor-in-interest to

ANTON YELCHIN hereby request a trial by jury

WHEREFORE, Plaintiffs VICTOR YELCHIN, individually and as Successor-In-

Interest to ANTON YELCHIN, and IRINA YELCHINA, individually and as Successor-in-

Interest to ANTON YELCHIN, pray for judgment against Defendants, and each of them,

as follows:

III


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DATED:

All general damages, including but not limited to loss of the Decedent’s

consortium, according to proof at time of trial;

All special damages, including all funeral/mortuary, consequential, and

incidental expenses incurred, and all additional economic losses,

according to proof at time of trial;

For prejudgment interest, as determined and accrued according to

applicable statutes;

For punitive damages against Defendants in an amount that is to be

ascertained;

Attorneys' fees;

Costs of bringing this suit; and

Such other and further relief as the Court deems just and proper.

August 2, 2016 GARY A. D O ^ ^ ^ ^ ^ ^ ^ R P O R A T IO N

0afyA ^B ord ick , E § q ^Diana S. Diskin, Esq.Attorneys for Plaintiffs


EXHIBIT 1

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Gary A. Dordick, Esq. S/B# 128008Diana S. Diskin, Esq. S/B#251366GARY A. DORDICK, A LAW CORPORATION509 South Beverly DriveBeverly Hills, California 90212-4514Tel: (310) 551-0949 • Fax: (855) 299-4444Email: [email protected]: [email protected]

Attorneys for Plaintiffs

SUPERIOR COURT FOR THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

VICTOR YELCHIN, an individual, IRINA YELCHINA, an individual: and the ESTATE OF ANTON YELCHIN, by and through his Successors-in-lnterest, VICTOR YELCHIN and IRINA YELCHINA,

Plaintiffs,

v.

FCA US LLC; ZF NORTH AMERICA, INC.; AUTO COMPANY XXIII, INC., dba AUTONATION CHRYSLER DODGE JEEP VALENCIA and CA SUPERSTORES VALENCIA CJD; and DOES 1 to 100, Inclusive,

Defendants.

CASE NO.:

DECLARATION OF VICTOR YELCHIN AND IRINA YELCHINA AS SUCCESSORS-IN-INTEREST PURSUANT TO CODE OF CIVIL PROCEDURE §377.32

JOINT DECLARATION OF PLAINTIFFS IRINA YELCHINA AND VICTOR YELCHIN.

AS SUCCESSORS-IN-INTEREST TO ANTON YELCHIN fC.C.P. 6377.32)

Plaintiffs IRINA YELCHINA and VICTOR YELCHIN make the following declaration

pursuant to Code of Civil Procedure section 377.32:

1. We are the Plaintiffs in this action and the successors-in-interest to Anton

Yelchin. If called upon as witnesses to testify, we could and would competently testify to

the following facts and information.

___________________________________________________________ 1 .____________________________________________________________

DECLARATION OFVICTOR YELCHIN AND IRINA YELCHINA AS SUCCESSORS-IN- INTEREST PURSUANT TO CODE OF CIVIL PROCEDURE §377.32



•

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2. We seek to commence an action or proceeding as the decedent's

Successors In Interest.

3 The name of the decedent is ANTON YELCHIN.

4. On or about June 19, 2016, ANTON YELCHIN died in Los Angeles,

California, as a result of Defendants’ negligence.

5. A true and correct copy of the decedent’s death certificate is attached hereto

as Exhibit A.

6. A proceeding is now pending in California for the administration of Anton’s

estate, by which we will be named as co-administrators of Anton’s estate.

7. We are the decedent’s parents and successors in interest, as defined in

section 377.11 of the California Code of Civil Procedure. We succeed equally to the

decedent’s interest in the action or proceeding.

8. Aside from us, no other person has a superior right to commence the action

pr proceeding or to be substituted for the decedent in the pending action or proceeding.

I declare under penalty of perjury under the laws of the State of California that the

foregoing is true and correct and that this declaration was executed on August 1,2016, at

Los Angeles, California.

IRINA YELCHINA

I declare under penalty of perjury under the laws of the State of California that the

foregoing is true and correct and that this declaration was executed on August 1,2016, at

Los Angeles, California.

VICTOR YELCHIN

__________________________________ 2___________________________________DECLARATION OFVICTOR YELCHIN AND IRINA YELCHINA AS SUCCESSORS-IN-

INTEREST PURSUANT TO CODE OF CIVIL PROCEDURE §377.32

EXHIBIT A

¿tu» ANY ALTERATION OR ERASURE VOIDS THIS CERTIFICATE»*

COUNTY OF LOS ANGELESDEPARTMENT OF PUBLIC HEALTH

CERTIFICATE OF DEATH5U*t 0* CAOKAWUl

uu tu£* mem. t im i msab M i m s* unw aa _____ vs-n«revvsi_____________

32016190275633052016122327

3 IA S I <F*T*y!

YELCHINI NAME. O» 0CCE0CN7-FW$T

ANTON*'JCTWQNT YT.A." ryw.yaras_1t sexAKA ALSO KNOWN AS - IncJ-jC* M AKA 9 IRST M-OCEi LAST)

03/11/19897 DATE OF DEATH ■«w-M.-ccr r

06/19/2016 FNDS ARUED FORCES’ TI MARITAL f A l A W 3 . ^

|X |« NEVER MARRIED« fa’flTM STATEDC^tGN COUNTRY

RUSSIAI I «CICC*IT-S MCIWHITEHS GRADUATE

11 K.NOOF & .'S *£$S O fl*< C A /3T*r|«c.9nx«> itt'a *0*3 co^U-jcto*

ENTERTAINMENT17 USUAL OCCuPaTCN - 7fp* e* » v« O OO NCT USE RETIRED

ACTORJ0 DECEDENT'S RESCENCE TS**H AM v *ec.4b>«)

3866 BERRY DR.: i Z.» CODE

9160423. COUNT V/PRCV-NCE

LOS ANGELES34 YEARS IN COUNTY 3S STATE/fCRE'-ON COUNTRYJ1 D IY

STUDIO CITY*7 AFCFMASrS U A L M O IO O N S ID IM M -W N » > >--r» >OlU »•*4203 COLFAX AVE. #F, STUDIO CITY. CA 91604

31 FUCRVIANT S NAWL.RtLATXJNSxF

VICTOR YELCHIN. FATHER

11. LAST

YELCHIN11. NAME Oí FATH£RRaF«£N7-4 Í15T

VICTOR RUSSIA31 BRIM STATE

RUSSIA36 MOOLI IT. LAST (TÍ.RTH NAMtl

KORINA3». NAVE Of MOTm£IL1>AAENT.».HST

IRINAM a o E m o m iN MOUNT SINA, MEMORIAL PARK

5950 FOREST LAWN DR.. LOS ANGELES. CA 900683> OilROSiTON DATE "ytvIMííy»

06/24/201643. MFiATUMC OF EMBALJyCR

► NOT EMBALMED4S LCENSE NwM8E«

FD1010U SSNATUHe O» LOCAL NEC STFEAR

► JEFFREY GUNZENHAUSER. MD¡17. DATE nrv& ve rry

06/21/2016t« NAME C* FUÑERA. ESTAfiUSHUfMMOUNT SINAI MORTUARY

ICO 'F OTHEn THAN HOSPITAL. SPECfY ONE

□ — n s s r e □ £DRIVEWAY5 TACVilY ACC**ESS OR EOCAT ON WHIRL F ÜUNO (So-MI *rOW. freer orlocMON104 COUNTY

LOS ANGELEStc« CJT>

STUDIO CITY3866 BERRY DRIVE

a BLUNT TRAUMATIC ASPHYXIARAPID B016-04493

»»M J 10 CáíAé on U r* A Er*e* UNCiRLYtNO CAUSE | ) »»*»« or rvMry inai

110 AUTCPiYrtWORMEOT

116 l ICENSE NUMBER

11* TYPE ATTEND NO FHYS.CAN S NAME. MAUNJ AilOMt S3 /»'• EÓU

131 NA3N0ATE *»tk<MKcrvj 132 K X '« C4 mom*

06/18/2016 IUNKMVi.cn CA DEATH

123 IVACI CA INA.AT ,« ; W / . W » '*

DRIVEWAY134 Of SCR'HF K>.V INJURY OCCURRED U »•-*% rtiJ -.M in i\v#yPINNED BETWEEN BACK OF HIS VEHICLE AND GATE OF RESIDENCE DRIVEWAY121 LOCATION C* INJURY (V.<*h «v i tv me Alien, v d t*y. »rvj rp i

3866 BERRY DRIVE. STUDIO CITY. CA 9160412» DATE mTVatlceyy

06/21/20161J* TYPE NAVI TITLE o*- CORONER /CCFNJTV CO*WNCR

REGINA AUGUSTINE. DEP CORONER124 r..GNA*UHEC*CORONÍR/DtPUTYCC*<CNtR

.REGINA AUGUSTINECENSUS TRACTinnfflHHnnnaiiiitMfflii

________ O X>0100327>:2«3,________STATE

FIEClSTRAR

CERTIFIED COPY OF VITAL RECORDSTATE OF CALIFORNIA. COUNTY OF LOS ANGELES

This is a true certified conjfW the recced filed in the County of Los Angeles Department of PutíLfójHer/thlüt tiforsfhe Registrar's signature in purple ink. 000984324

E ISSUED

Health Of)

This copy is noi valid unless preparod on on ongravod border, displaying the dai«. soal and signature o f the Registrar.

■ isSSiS a il i ^ a s s i /■.

SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES NOTICE OF CASE ASSIGNMENT - UNLIMITED CIVIL PERSONAL INJURY CASE

Case Number

THIS FORM IS TO BF. SERVED WITH THE

Your case is assigned for all purposes to the jud ic ia l officer indicated below (Local Rule 3.3(c).

SUMMONS AND COMPLAINT BO 8 9 n ~ — --------------------------------

ASSIGNED JUDGE DEPT ROOM ASSIGNED JUDGE DEPT ROOM

Hon. Patricia Nieto/

632

/ Hon. Michelle Williams Court( V

633

Hon. Randolph Hammock 93 631

Hon. Benny C. Osorio 97 630

Hon. Holly J. Eujie 98 635

r , \ V '' A y

__6.

3y

— r A —

Given to the PlaintifT/Cross-Complainant/Attomey o f Record onai

SM AR TER , Executive Officcr/Clerk

. Deputy Clerk

LACIV PI 190 (Rev06/16) LASC Approved 05-06

NOTICE OF CASE ASSIGN

UNLIMITED CIVIL CASE

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FILEDLOS ANGELES SUPERIOR COURT

FEB 2 52016SHERRI R. CARTER, EXECUTIVE OFFICER' CLERK

ABY C. CASAREZ, DEP10J

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES

s e e 2 $) Case No.:In re Personal Injury Cases Assigned to the ) ~ * * 0 $ gPersonal Injury Courts; ) SIXTH AMENDED GENERAL(CENTRAL DISTRICT) ) ORDER RE PERSONAL INJURY

) COURT (“PI Court”) PROCEDURES,) CENTRAL DISTRICT

______________________________________) (Effective as of February 22, 2016)

$

DEPARTMENT: 91 92 93 ^¡f ^ 98

FINAL STATUS CONFERENCE (“ F s c y

Date:o \

at 10:00 a.m.

TRIAL:

• Date: ' \ ^

'Vs

at 8:30 a.m.. \

OSC re DISMISSAL (Code Civ. Proc.. S 583.210):

• Date: at 8:30 a.m.

TO EACH PARTY AND TO THE ATTORNEY OF RECORD FOR EACH PARTY:

Pursuant to the California Code of Civil Procedure (“C.C.P.”), the California

Rules of Court, and the Los Angeles County Court Rules (“Local Rules”), the Los

Angeles Superior Court (“LASC” or “Court”) HEREBY AMENDS AND SUPERSEDES

THE September 18, 2015 AMENDED GENERAL ORDER AND GENERALLY

1 Central D istrict 2/22/2106

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O R D E R S A S F O L L O W S IN T H IS A N D A L L O T H E R G E N E R A L JU R IS D IC T IO N

P E R S O N A L IN JU R Y A C T IO N S :

E ffec tive M arch 18, 2013 , the C ourt responded to system ic budget reductions by

centralizing the m an ag em en t o f m ore than 18,000 general ju risd ic tio n personal in jury cases in

the Stanley M osk C ourthouse . L A SC initially o p en ed th ree P erso n al In ju ry C ourts (“PI

C ourts” - D ep artm en ts 91 , 92 and 93), on January 6 ,2 0 1 4 , a fo u rth (D ep artm en t 97), and on

Septem ber 28, 2015 a fifth (D epartm ent 98) to ad judicate all p re tria l m atte rs fo r these cases.

It also estab lished a M as te r C alendar C ourt (D epartm ent O ne), to m an ag e th e assignm ent ol

trials to d ed icated T ria l C o u rts located countyw ide. P rio r A m ended G eneral O rders la id out

the basic p rocedures fo r th e P I C ourts’ m anagem ent o f pretrial m atters. T h e p arties w ill find

additional in fo rm ation ab o u t the PI C ourts on the co u rt’s w ebsite , www.lacourt.org.

1. T o ensu re p ro p er assignm ent to a PI C ourt, P la in tif f s ) m u st care fu lly fill ou t the Civil

Case C over Sheet A d d en d u m (form L A C IV 109). T h e C ourt defin es “ p ersonal in jury” as:

“an unlim ited civil case described on the Civil Case C over Sheet Addendum and

Statem ent o f Location (LACIV 109) as M otor V ehicle-Personal Injury/Property

D am age/W rongful Death; Personal Injury/Property D am age/W rongful Death-

U ninsured M otorist; Product Liability (o ther than asbestos or

toxic/environm ental); M edical M alpractice-Physicians & Surgeons; O ther

Professional Health Care M alpractice; Premises Liability; Intentional Bodily

Injury/Property Damage/W rongful Death; or O ther Personal Injury/Property

D am age/W rongful Death. An action for intentional infliction o f em otional

distress, defam ation, civil rights/discrim ination, or m alpractice (other than

m edical m alpractice), is not included in this definition. An action for injury to

real property is not included in this definition.” L ocal R ule 2 .3(a)(1)(A ).

2 Central District 2/22/2106

http://www.lacourt.org

The C ourt w ill ass ig n a case to the PI C ourts i f p la in t i f f s ) ch ec k any o f the follow ing

boxes in th e C iv il C ase C over Sheet A ddendum :

D A 7 100 M o to r V eh icle - Personal In ju ry /P roperty D am age/W rongfu l

D eath

U A 7 110 P ersonal Injury/Property D am age/W rongfu l D eath - U ninsured

M oto rist

□ A 7260 P ro d u c t L iab ility (no t asbestos o r tox ic /env ironm en tal)

□ A 7 2 10 M ed ica l M alpractice - Physicians & S urg eo n s

□ A 7240 M edica l M alpractice - O ther P rofessional H ealth C are M alpractice

□ A 72S0 P rem ises L iability (e.g., s lip and fall)

□ A 7230 In ten tional B odily In jury /Property D am age/W rongfu l D eath (e.g .,

assau lt, vandalism etc .)

U A 7220 O th er Personal In jury/Property D am age /W rongfu l D eath

T he C o u rt w ill no t assign cases to the PI C ourts i f p la in ti f f s ) ch eck an y boxes

elsew here in th e C iv il C ase C over Sheet A ddendum (any b o x es o n pages tw o and

th ree o f th a t form ).

T he C ourt se ts th e above d ates in this action in the PI C ourt c ircled ab o v e (D epartm ent 9 1 ,9 2 ,

9 3 ,9 7 , o r 98) at th e S tan ley M osk C ourthouse, 111 N orth H ill S treet, L os A ngeles, C A 90012.

Cal. R ules o f C ourt, R u les 3 .714(b)(3), 3.729.

F IL IN G O F D O C U M E N T S

2. P arties m ay file d o cu m en ts in person at the filing w indow , v ia U S M ail, o r as o f March

1,2106, th ro u g h e-D elivery , w hich is available online a t w w w .lacourt.o rg (link on hom epage).

P lease no te th a t filings a re no longer accepted v ia facsim ile and m ust be filed e ither in person



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via e-D elivery. C la im s invo lv ing an atto rney-clien t fee d ispu te , docu m en ts in w hich the

ling party is a m inor, lega lly incom peten t person, o r person fo r w h o m a conservato r has been

>pointed, R equests to W aiv e C ourt Fees (FW -001) and R equests fo r A ccom m odations by

arsons w ith D isab ilities (M C -410), m ay n o t be filed v ia e-D elivery .

E R V IC E O F S U M M O N S A N D C O M P L A IN T

P la in tif f s ) shall se rv e the sum m ons and com plain t in th is ac tio n u p o n d e fe n d a n ts ) as

>on as possib le b u t no la te r than th ree years from the date w h en th e co m p la in t is filed. C . C

§ 583.210, subd. (a). O n the O SC re D ism issal date no ted above, th e P I C o u rt w ill dism iss

lie ac tio n a n d /o r all u nserved parties unless the p la in tif fs ) sh o w cau se w hy th e action o r the

nserved p arties sh o u ld no t b e dism issed. C .C .P. §§ 583.250; 581 , subd . (b)(4).

T he C ourt sets the ab o v e trial and FSC dates on cond ition th a t p la in t i f f s ) effectuate

ervice on defendan t(s) o f th e sum m ons and com plain t w ith in six m onths o f filing the

om plaint.

T he P I C o u rt w ill d ism iss th e case w ithout p rejud ice pu rsu an t to C .C .P . § 581 w hen

io party appears fo r trial.

S T IP U L A T IO N S T O C O N T IN U E T R IA L

>. P rov ided th a t all parties agree (and there is no v io lation o f the “ five-year ru le,” C .C.P

J 583.310), th e p arties m ay advance o r continue any tria l da te in the P I C ourts w ithout

showing go o d cau se o r articu la ting any reason o r ju stifica tio n fo r th e change . T o continue or

advance a tria l d a te , the p arties (o r th e ir counsel o f record) shou ld jo in tly execu te and file (in

Hoorn 102 o f the S tan ley M o sk C ourthouse; fee required) a S tipu la tion to C ontinue Trial,

4 Centra] District 2/22/2106

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FSC and R elated M o tion /D iscovery D ates (form LA C IV C T R L -242 , ava ilab le on the co u rt’s

w ebsite. P ersonal In ju ry C o u rt link). The PI C ourts schedule F S C s fo r 10:00 a.m ., e igh t (8)

court days befo re the tria l date . P arties seek ing to continue th e tria l an d F S C d ates shall file

the S tipu lation at least e igh t cou rt days before the FSC date. P arties seek in g to advance the

trial and FSC d ates shall ti le the S tipu lation a t least e igh t cou rt d ay s befo re th e proposed

advanced F S C date. C ode C iv . P roc., § 595.2; G ovt. C ode § 706 1 7 , subd . (c)(2 ). In

selecting a n ew tr ia l date , p a rties should av o id setting o n any M o n d ay , o r the T uesday

follow ing a co u rt ho liday . P arties m ay subm it a m axim um o f tw o s tip u la tio n s to continue

trial, the firs t fo r a m ax im u m o f four m onths, the second fo r a m ax im u m o f tw o m onths. A

th ird request to co n tin u e tria l w ill on ly b e granted up o n a sh ow ing o f g o o d cause, by ex parte

application o r no ticed m otion . T his ru le is retroactive so that any p rev io u sly granted

stipulation to con tin u e trial w ill count tow ard the m axim um n u m b er o f a llo w ed continuances.

N O C A S E M A N A G E M E N T C O N F E R E N C E S

17. T he PI C o u rts do n o t conduct C ase M anagem ent C onferences. T he parties need not

I file a Case M an ag em en t S tatem ent.

L A W A N D M O T IO N

A N Y D O C U M E N T S W IT H D E C L A R A T IO N S A N D /O R E X H IB IT S M U S T B E T A B B E D . C R C §3 .1110(f)

A L L D E P O S IT IO N E X C E R P T S R E F E R E N C E D IN B R IE F S M U S T B E M A R K E D I O N T H E T R A N S C R IP T S A T T A C H E D A S E X H IB IT S . C R C §3 .1116(c)

I f vour filing is not tabbed or depositions are not marked, do not file without the tabs or marked depositions unless today is the tost dav for fitina. I f so. vou must file a tabbed/marked copy with the clerk in the department where vour motion will be heard within 2 court davs.


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C h a m b e rs C o p ie s R e q u ire d

8. In add itio n to filing original m otion papers in R oom 102 o f the S tanley Mosk

C ourthouse, the parties m u st deliver, d irectly to the PI C ourt cou rtroom s, an ex tra copy

(m arked “C ham bers C opy” ) o f rep ly briefs and a ll o ther m otion pap ers filed less than seven

(7) court days befo re a h earin g calendared in the P I C ourts. T h e P I C o u rts also strongly

encourage the p arties filin g and opposing lengthy m otions, such a s m o tio n s fo r sum m ary

judgm ent/ad jud ication , to su b m it one o r m ore th ree-ring b inders o rg an iz in g the C ham bers

C opies behind tabs.

R ese rv a tio n o f H e a r in g D a te

9. Parties a re d irec ted to reserve hearin g dates fo r m o tions in the P I C o u rts using th e Court

R eservation S ystem (C R S ) availab le on line at www.lacourt.ore ( lin k o n hom epage). A ftei

reserving a m o tio n hearing date, the reservation requesto r m u st su b m it th e papers fo r tiling

w ith the reservation rece ip t (C R S ) num ber printed on the face page o f th e do cu m en t under the

cap tion and a ttach the reserva tion receip t as the last page. P arties o r co u n se l w ho a re unable

to u tilize the o n lin e C R S m ay reserve a m otion hearing date b y ca lling th e P I C o u rt courtroom ,

M onday th rough F riday , betw een 3:00 p.m . and 4 :00 p.m .

W ith d ra w a l o f M o tio n

10. C aliforn ia R u les o f C ourt, R u le 3 .1304(b) requires a m oving party to notify the court

im m ediately i f a m a tte r w ill no t be heard on the scheduled date . In k eep in g w ith that rule, the

PI C ourts urge p arties w ho am end p leadings in response to d em urrers to tile amended

pleadings befo re the date w hen opposition to the dem urrer is due so tha t th e P I C ourts do not

6 Central Districi2/22/2106

http://www.lacourt.ore

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needlessly prepare tentative rulings on demurrers.

D iscovery M o tio n s

11. T h e p u rp o se o f an In fo rm al D iscovery C onference (“ ID C ”) is to ass is t the parties to

resolve and /o r n a rro w th e sco p e o f d iscovery disputes. L ead tria l co u n se l o n each side, oi

another a tto rney w ith full au tho rity to m ake b inding agreem ents, m u st attend in person. The

P I ju dges have fo u n d th a t, in nearly every case , the parties am icab ly re so lv e d ispu tes w ith the

assistance o f the C ourt.

12. P arties m u s t p artic ip a te in an IDC b e fo re a M otion to C om pel F u rther R esponses to

D iscovery w ill be heard , un less, the m oving party subm its ev idence, by w ay o f declaration,

that the o p p o sin g p arty h as failed o r refused to partic ipa te in an ID C . Scheduling oi

participating in an ID C d o es no t ex tend any deadlines im posed by the C ode o f C ivil Procedure

for noticing and filing d isco v ery m otions. Ideally , the p arties sho u ld partic ipa te in an IDC

before a m o tion is filed because the IDC m ay avo id the n ecessity o f a m o tio n o r reduce it:

scope. B ecause o f th a t possib ility , attorneys are encouraged to stipu la te to ex tend the 45 (oi

60) day dead line fo r filing a m otion to com pel further d iscovery responses in o rder to allow

tim e to p artic ipa te in an ID C . I f parties do not stipu late to ex tend the dead lines, the moving

party m ay file the m otion to avoid it being deem ed untim ely . H ow ever, the ID C m ust take

place before the m otio n is heard so it is suggested that the m ov ing party reserve a date fo r the

m otion hearing th a t is a t least 60 days after the date w hen the ID C reserva tion is m ade. M otion:

to Com pel F u rther D isco v ery R esponses are heard at 10:00 a.m . I f the ID C is no t productive,

the m oving p arty m ay ad v an ce the hearing on a M otion to C om pel F urther D iscovery


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R esponses on an y ava ilab le hearing date that com plies w ith the n o tice requirem ents o f the

C ode o f C ivil P rocedure.

13. Parties are d irec ted to reserve ID C dates in the P I C ourts u sing C R S availab le online at

w w w .lacourt.org (link on hom epage). P arties are to m eet an d co n fe r regard ing the available

dates in C R S p rio r to accessing the system . A fter reserv in g th e ID C date, the reservation

requestor m ust file in the app ropria te departm ent and serve an In fo rm al D iscovery C onference

Form for P ersonal In jury C ourts , from LA C IV 239 (rev ised 12/14 o r la ter), at least 15 court

days p rio r to th e con ference and attach the CRS reservation rece ip t as the last page. The

opposing party m ay file and serve a responsive ID C Form , briefly se ttin g forth tha t party ’s

response, at least 10 co u rt days p rio r to the IDC.

14. T im e perm itting ; th e PI H ub ju dges m ay be availab le to p artic ip a te in ID C s to try to

resolve o ther types o f d iscovery disputes.

E x P a r te A p p lic a tio n s

15. U nder the C a lifo rn ia R ules o f C ourt, courts m ay o n ly g ran t ex parte re lie f upon a

show ing, by ad m issib le ev idence , that the m oving p arty w ill su ffe r “ irreparab le harm ,’

“ im m ediate danger,” o r w h ere the m oving party iden tifies “a sta tu to ry b as is fo r g ran ting relief

ex parte.” C al. R u le s o f C o u rt, R u le 3 .1202(c). T he P I C ourts hav e n o cap ac ity to hear multiple

ex parte ap p lica tions o r to sho rten tim e to add hearings to the ir fu lly b o o k ed m otion calendars.

T he PI C ourts d o n o t regard the C ourt’s unavailability fo r tim ely m otion hearings as an

“im m ediate d an g er” o r th rea t o f “ irreparable harm ” ju s tify in g ex parte re lief. Instead of

seeking ex parte re lie f, counsel shou ld reserve the earliest ava ilab le m o tio n hearing date, and

stipulate w ith a ll p a rties to con tinue the tria l to a da te the reafte r u s in g th e S tipulation to

C ontinue T ria l, F S C and R elated M otion/D iscovery D ates (fo rm L A C IV C T R L -242, available



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n the co u rt’s w ebsite , P I C o u rt Tab). C ounsel sh o u ld a lso ch eck th e C o u rt R eservation

ystem from tim e to tim e becau se earlier hearing d ates m ay becom e av ailab le as cases settle

r counsel o th e rw ise take h earin g s o f f calendar.

REQUEST F O R T R A N S F E R T O IN D E P E N D E N T C A L E N D A R D E P A R T M E N T

6. Parties seek in g to tran sfe r a case from a P I C o u rt to an In d ep en d en t C alendar (“ I/C ”)

lourt shall file ( in R oom 102 o f th e S tanley M osk C ourthouse) and se rv e th e C ourt’s

M otion to T ran sfe r C o m p lica ted P ersonal In jury C ase to In d ependen t C alen d ar C ourt”

form L A C IV 238, ava ilab le o n the C ourt’s w ebsite u n d er th e P I C o u rts link). T h e P I

Courts w ill tran sfer a m a tte r to an I/C C ourt i f the case is no t a “P erso n a l In ju ry” case as

lefined in th e G en era l O rd e r re G eneral Ju risd ic tion PI C ases, o r i f it is “com plica ted .” In

leterm ining w h eth er a p e rso n a l in ju ry case is “com plicated” th e P I C o u rts w ill consider,

m ong o th e r th ings, th e n u m b er o f pretrial hearings o r the co m p lex ity o f issu es presented.

7. Parties o p p osing a m o tion to transfer have five co u rt days to file (in R o o m 102) an

Opposition (using th e sam e L A C IV 238 M otion to T ransfer form ).

,8. The PI C ourts w ill n o t conduct a hearing on any M otion to T ransfer to I/C C ourt

Although the parties m ay stipu la te to transfer a case to an Independen t C a len d ar D epartm ent,

he PI C ourts w ill m ake an independent determ ination w hether to tran sfe r the case o r not.

G E N E R A L O R D E R - F I N A L S T A T U S C O N F E R E N C E

19. Parties shall com ply w ith the requirem ents o f the P I C o u rts ’ “A m en d ed G eneral Ordei

-F in a l S tatus C onference,” w hich shall be served w ith the sum m ons an d com plaint.

IU R Y F E E S

20. Parties m u s t pay ju ry fees no later than 365 calendar days a fte r the filin g o f the initial

complaint. (C ode C iv . P roc., § 631, subds. (b) and (c))

9 Central Districl 2/22/2106

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JU R Y T R IA L S

21. T he PI C ourts d o no t co nduct ju ry trials. O n the tria l date, a P I C ourt w ill transfer the

case to the M aster C alen d ar C o u rt in D epartm ent O ne in th e S tan ley M osk Courthouse.

D epartm ent O ne a ss ig n s cases o u t fo r trial to ded icated T rial C ourts.

S A N C T IO N S

21. T he C ourt h as d iscre tion to im pose sanctions for any v io la tio n o f th is general order.

(C .C .P . §§ 128.7, 187 an d G ov. C ode, § 68608, subd . (b))

K ev in C. B raz ile ^S uperv ising Ju d g e , C ivil L os A ngeles S u p erio r C ourt


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FILEDLOS ANGELES SUPERIOR COURT

M 1 02016

SHERRI R. CAHim EXECUTIVE OFFtCERI 0£RK

SUPERIOR COURT O F THE STATE O F CALIFORNIA

FOR T H E COUNTY O F LOS ANGELES - CENTRAL DISTRICT

In re Personal Injury Cases Assigned ) FOURTH AMENDED GENERAL ORDER - To the Personal Injury Courts ) FINAL STATUS CONFERENCE,(Departments 9 1 ,9 2 ,9 3 ,9 7 and 98) ) PERSONAL INJURY ("PI") COURTS

) (Effective as o f June 10,2016))))

The dates for Trial and Final Status Conference ("FSC") having been set in this matter, the

Court HEREBY AMENDS AND SUPERSEDES ITS J a n u a ry 26, 2015, AMENDED

GENERAL O R D E R -F IN A L STATUS CONFERENCE AND GENERALLY

ORDERS AS FOLLOWS IN THIS AND ALL OTHER GENERAL JURISDICTION

PERSONAL INJURY ACTIONS:

1. PURPOSE OF THE FSC

The purpose of the FSC is to verify that the parties counsel are completely ready to

proceed with trial continuously and efficiently, from day to day, until verdict. The PI Courts

will verify at the FSC that all parties counsel have (I) prepared the Exhibit binders and Trial

Document binders and (2) met and conferred in an effort to stipulate to ultimate facts, legal

issues, motions in limine. and the authentication and admissibility o f exhibits.

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2. TRIAL DOCUMENTS TO BE FILED

At least five calendar days prior to the Final Status Conference, the parties counsel shull serve

and lile (in Room 102 o f the Stanley Mask Courthouse) the following Trial Readiness

Documents:

A. TRIAL BRIEFS (OPTIONAL)

Each party counsel may file, but is not required to file, a trial brief succinctly identifying:

(1) (he claims and defenses subject to litigation;

(2) the major legal issues (with supporting points and authorities);

(3) the relief claimed and calculation o f damages sought; and

(4) any other information that may assist the court at trial.

B. MOTIONS IN LIM INE

Before filing motions in limine, the parties counsel shall comply with the statutory

notice provisions o f Code of Civil Procedure ("C.C.P.") Section 1005 and the

requirements o f Los Angeles County Court Rule ("Local Rule") 3.57(a). The caption

of each motion in limine shall concisely identify the evidence that the moving party

seeks to preclude. Parties filing more than one motion in limine shall number them

consecutively. Parties filing opposition and reply papers shall identify the

corresponding motion number in the caption of their papers.

C. JOIN T STATEMENT TO BE READ TO THE JURY

For jury trials, the parties/counse! shall work together to prepare and file a joint written

statement o f the case for the court to read to the jury. Local Rule 3.25(i)(4).

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D. JOINT WITNESS LIST

The parties counsel shall work together to prepare and file a joint list of all witnesses that

each party intends to call (excluding impeachment and rebuttal witnesses). Local Rule

3.25(i)(5). The joint witness list shall identify each witness by name, specify which

witnesses are experts, and estimate the length of the direct, cross examination rc-direct

examination (if any) of each witness. The parties/counsel shall identify and all potential

witness scheduling issues and special requirements. Any party/counsei who seeks to elicit

testimony from a witness not identified on the witness list must first make a showing of

good cause.

E. LIST OF PROPOSED JURY INSTRUCTIONS

(JOINT AND CONTESTED)

The parties/counsel shall jointly prepare and file a list o f proposed jury instructions, organized

in numerical order, specifying the instructions upon which all sides agree and the contested

instructions, if any. The Joint List of Jury Instructions must include a space by each instruction

for the judge to indicate whether the instruction was given.

F. JURY INSTRUCTIONS

(JOINT AND CONTESTED)

The purties/counsel shall prepare a complete set of full-text proposed juiy instructions, editing

all proposed California Civil Jury Instructions for Judges and Attorneys ("CACI") instructions

to insert party names and eliminate blanks and irrelevant material. The panics shall prepare

special instructions in a format ready for submission to the jury with the instruction number,

title and text only (i.e., there should be no boxes or other indication on the printed instruction

itself as to the requesting patty.)

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G. JO IN T VERDICT FORM(S)

The parties counsel shall prepare and jointly file a proposed general verdict fonn or special

verdict fonn (with interrogatories) acceptable to all sides. If the parties counsel cannot agree

on a joint verdict form,, each party must separately file a proposed verdict fonn Local Rule

3.25(i)(7) and (8).

H. JO IN T EXHIBIT LIST

The parties counsel shall prepare and file a joint exhibit list organized with columns

identifying each exhibit and specifying each party’s evidentiary objections, if any, to

admission of each exhibit. To comply with Local Rules 3.52(i)(5) and 3.53, the parties shall

meet and confer in an effort to resolve objections to the admissibility of each exhibit.

3. EVIDENTIARY EXHIBITS

The parties counsel shall jointly prepare (and be ready to temporarily lodge for inspection at

the FSC), three sets of tabbed, internally paginated and properly-marked exhibits, organized

numerically in three-ring binders (a set for the Court, the Judicial Assistant and the witnesses).

The parties counsel shall mark all non-documentary exhibits and insert a simple written

description of the exhibit behind the corresponding numerical tab in the exhibit binder. If the

parties have a joint signed exhibit list and electronic copies o f their respective exhibits, then

the parties will not be required to produce exhibit binders at the Final Status Conference

(FSC). However, the exhibit binders may be required by the assigned trial judge when the

trial commences. In the absence o f either a joint signed exhibit list or electronic copies,

exhibit binders will be required by all parties at the Final Status Conference.

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4. TRIAL BINDERS REQUIRED IN THE PI COURTS

The parties/counsel shall jointly prepare (and be ready to temporarily lodge for inspection at

the FSC) the Trial Documents, tabbed and organized into three-ring binders as follows:

Tab A: Trial Briefs

Tab B: Motions in limine

Tab C: Joint Statement to Be Read to the Juiy

Tab D: Joint Witness List

Tab E: Joint List of Jury Instructions (identifying the agreed upon and contested instructions)

Tab F: Joint and Contested Jury Instructions

Tab G: Joint and/or Contested Verdict Forms

The parties shull organize motions in limine (tabbed in numerical older) behind tab B

with the opposition papers and reply papers for each motion placed directly behind the moving

papers. The parlies shall organize proposed jury instructions behind tab F, with the agreed

upon instructions first in order followed by die contested instructions (including special

instructions) submitted by each side.

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5. FAILURE TO COMPLY WITH FSC OBLIGATIONS

rhe court has discretion to require any parry counsel who fails or refuses to comply with this

jeneral Order to Show Cause why the court should not impose monetary, evidentiary and or

ssue sanctions (including the entry of a default or the striking of an answer).

Dated this 10th day of June, 2016

tvini C. Brazile Supervising Judge, Civil Los Angeles Superior Court

Documents

^*co¡*TÜ5eo¡¡£7- - American Bar · PDF fileBreach of contract/warranty (06) ... Judicial Council of California ... a prejudgment writ of attachment

^co¡TÜ5eo¡¡£7- - American Bar · PDF fileBreach of contract/warranty (06) ... Judicial Council of California ... a prejudgment writ of attachment