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Sloat Lawsuit

Sloat Lawsuit

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Published by jeremybwhite
Lawsuit alleging illegal gifts, donations from Sacramento firm Sloat Higgins Jensen & Associates
Lawsuit alleging illegal gifts, donations from Sacramento firm Sloat Higgins Jensen & Associates

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Published by: jeremybwhite on Dec 27, 2013
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03/28/2014

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is
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Jesse
Ortiz
(CA
Bar Assn.
No.
176450)
,
 
\
Ben
Williams
(CA
Bar Assn.
No.
284884)
Jesse
Ortiz
Law
917
7th
Street
Sacramento,
CA
95814
Telephone:
(916)
443-9500
Facsimile:
(916)
443-9501
Attorneys
for
Plaintiff
.
RHONDASMIRA
and
ORLEANS
CONSLUTING
GROUP,
LLC
SUPERIOR
COURT OF THE
STATE
OF
CALIFORNIA
OUN~Y
OF
SACRAMENTO
)
Case
No.
)
)
COMPLAINT
FOR
DAMAGES:
RHONDA
S~ IKA,
an
indi
viduc:.J.;
)
ORI.:ENJS
CONSLULTING
GRO'JP
 
LLC
}
1 Violation
of
Business
a
California
Limited
Liabilit'i'
}
Professions
Code
17200;
Company,
) )
2 Declaratory
Relief;
3
Violation
of
the
Political
Plaintiff,
Reform
Act;
vs,
4
Wrongful
Termination
in Violation
of
Public
"
KEVIN SLOAT,
an
individuQl;
Policy;
and
SLOAT HIGGENS
JENSEN
&
S.
Defamation
ASSOCIATES,
LLC
r
A
ifornia
Limited
Liability
Company,
and
DOES
1
through
50,
inclusive,
Defendan:.s.
I
I
I
Plaintiffs,
RHONDA
SMIRA
and
ORLEANS
CONSULTING
GROUP, LLC
r
hereby
complain and
allege
as
follows:
PARTIES
1.
Plaintiff,
RHONDA
SMIRA
(hereinafter
Plaintiff
and/or
"SMIRA")
is,
and
at
all
times
herein
mentioned
was,
an
individual
residing in
Sacramento
County,
California.
2.
Plaintiff,
ORLEANS
CONSULTING GROUP,
LLC
(hereinafter
"ORLEANS"
and/or
collectively
referred to
as
Plaintiffs )
is,
Complaint
for
Damages-1
 
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B
9
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.
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22 23
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and
at
all
herein
mentioned
was,
a
California
Limited
Liability
Company.
3. Defendant,
KEVIN
SLOAT
(hereinafter
"Defendant"
and/or
SLOAT )
is,
and
at
all
times
herein
mentioned
was,
an
individual residing in
Sacramento
County,
California.
SLOAT
is
a
registered
lobbyist
and
is
bound
by
the
laws
and
regulations
of the
California
Political
Reform
Act
of
1974
("PRA").
SLOAT
is
the
principal
and
founder
of
SLOAT
HIGGINS JENSEN
&
ASSOCIATES, LLC.
4.
As
a
registered'lobbyist
and
the
'owner
of
a
registered
lobbying firm,
SLOAT
attended
regular
Ethics Training courses
on
the
laws and
regulations. of
the
PEA. The
Ethics
Training courses
cover
the
laws and
regul.ations·
of
lobbyists
making
and
arranging
gifts
and
the
illegality
of
lobbyists
and
lobbying firms
making
campaign
contributions.
5.
SLOAT
is
one
of the
most
connected
and
powerful
political
figures
in
California
and
has been ranked
as
one
of the
100
most
powerful people
in
California
politics.
6. Defendant,
SI,OAT
HIGGINS
JENSEN
ASSOCIATES,
LLC,
(hereinafter
SHJ
and/or
collectively
referred to
as
"Defendants")
is,
and
at
all
times
herein
mentioned
was,
a
California
Limited
Liability
Company.
7.
SHJ
is
a
registered
lobbying firm
headquartered
in
Sacramento,
California
and
is
bound
by
the
laws
and
regulations
of
the
PRA.
Plaintiff
is
informed
and
believes
and
thereon
alleges
that
all
directors,
officers
and
shareholders
of
SHJ
reside in
Sacramento
County,
California
and
that
all
of
its
substantive operational decisions are
made
in
Sacramento County.
8.
SHJ
is
one
of the
largest
lobbying
firms
in California.
SHJ
is
consistently
one
of
the top
five
lobbying
firms
in
California
as
measured
by
annual
billings.
The
firm
is
Complaint
for
Damages-2
 
1
2
3
4
5
6 7 8
9
10
11
.
12
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27
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paid
millions
of
dollars
by
Fortune
500,
energy/utility,
and
insurance
companies.
SHJ
clients
have
contributed
millions
of
dollars
of
campaign
contributions
to
candidates
and
elected
officials.
9. There
exists,
and
at
all
times
herein
mentioned
there
existed,
a
unity
of
interest
and ownership between
defendants
SHJ
and
SLOAT
such
that
any
individuality
and
separateness
between
them
have
ceased,
and
defendants
SHJ
is
the
alter
ego
of
defendant
SLOAT
in that
Plaintiff
is
informed
and
believes
and
thereon
alleges
SLOAT:
(a)
commingles
and
uses
assets
and
funds
of
SHJ
for his
personal
use.
without
adequate
consideration
and/or
recordkeeping;
(b)
uses.
·SHJ.·
as
a
mere
shell,
instrumentality
and
conduit
to
carryon
his
personal business
and
exercises
complete
control
.and.dominance
over
SHJ
to
such·an
extent
that
any
individuality
and
separateness
between
SHJ
and
SLOAT
does
not,
and.
at
all·
relevant
times
herein
mentioned
did
not,
exist;
and
(c)
fails
to
adhere
to
and
disregards
corporate
governance,
recordkeeping
and
.
formalities
obligations.
10.
Plaintiffs
are ignorant
of
the
true
names
and
capacities
of
the
defendants
sued
herein
as
DOES
1-50,
inclusive,
and
therefore
sues
these
defendants
by
such
fictitious
names.
Plaintiffs
will
amend
the
complaint
to allege
their
true
names
and
capacities
when
ascertained.
Plaintiffs
are
informed
and
believes
and
thereon
alleges
that
each
of the
fictitious
named
defendants
are
responsible
in
some
manner
for the
occurrences
herein
alleged
and
that
Plaintiffs
losses are herein
alleged
were
proximately
caused
by
such
negligent
and/or
wrongful
conduct.
F CTU L
LLEG TIONS
11.
On
or
about
January
1,
2000,
SMlRA
became
an
employee
of
SHJ.
As
an employee,
Plaintiff s
responsibilities
included
Complaint
for
Damages-3

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