23AHCV00379

Assigned for all purposes to: Alhambra Courthouse, Judicial Officer: William Crowfoot

1 || Estela S. Richeda (SBN 143917)

LAW OFFICES OF ESTELA S. RICHEDA
2 || 150 So. El Molino Avenue, Suite 100
Pasadena, California 91101 |
3 }} Tel. (626) 304-0648 Fax. (626) 304-0844
E-mail: estela@richedalaw.com
| 4
R. Brian Kramer (SBN 102371) |
5 | LAW OFFICE OF R. BRIAN KRAMER
1230 Rosecrans Ave., Suite 300
| 6 || Manhattan Beach, California 90266
Tel. (310) 536-9501 Fax. (310) 536-9503
7 | E-mail: briankramerlaw@aol.com

8 || Attorneys for Plaintiff, JOSE RIVERA

, 10 | SUPERIOR COURT OF THE STATE OF CALIFORNIA

: 11 FOR THE COUNTY OF LOS ANGELES (UNLIMITED) :

12 |
| JOSE RIVERA, an individual; ) CASE NO.
13 )
| Plaintiff, )
2 14 |} vs. ) COMPLAINT FOR DAMAGES:
)
15 || CALIFORNIA STATE LOTTERY ) 1. DECLARATORY RELIEF;
COMMISSION, a public entity, STATE OF ) 2. CONVERSION;
: 16 || CALIFORNIA, a public entity; “REGGIE”, ) 3. TRESPASS TO CHATTEL;
: an individual; EDWIN CASTRO, an ) 4. INTENTIONAL
17 || individual; and DOES 1 through 50, ) INTERFERENCE WITH .
inclusive, ) PROSPECTIVE ECONOMIC
18 Defendants. ) RELATIONS;
_ . ) 5. NEGLIGENT INTERFERENCE
19 WITH PROSPECTIVE
ECONOMIC RELATIONS;
20 |

214 COMES NOW plaintiff, JOSE RIVERA, and for causes of action against defendants, and

22 || each of them, complains and alleges as follows: :

23 | GENERAL ALLEGATIONS

24 1, At all times mentioned herein, plaintiff, JOSE RIVERA, was, and now is, a |

25 || resident of the County of Los Angeles, State of California.

26 2. Plaintiff is informed and believes and thereupon alleges defendant, CALIFORNIA

27 || STATE LOTTERY COMMISSION, is and has been a public entity organized under the

| 28 || Constitution of the State of California.

HEA SS al A ro lL ic ht nb te 1 “ini i i ar a deca ie tn ou ew nd Ta iii Keen

COMPLAINT FOR DAMAGES |

| 1) 3. Plaintiff is informed and believes and thereupon alleges defendant, STATE OF

2 | CALIFORNIA, is a public entity.

3 4. Plaintiff is informed and believes and thereupon alleges defendants,

| 4 || CALIFORNIA STATE LOTTERY COMMISSION and STATE OF CALIFORNIA, own,

5 || manage, operate, control and/or supervise the Powerball Lottery in California.

| 6 5. Plaintiff is informed and believes and thereupon alleges that at all times

| ' 7 || mentioned herein defendant “REGGIE” is an individual and was, and now is, a resident of the

8| County of Los Angeles, State of California. When the full legal name of “REGGIE” is obtained,

9 | plaintiff will seek leave of court to amend this Complaint to assert the true name and/or capacity
10 | of “REGGIE” as DOE 1.

11 6. Plaintiff is informed and believes and thereupon alleges that at all times

12 || mentioned herein defendant, EDWIN CASTRO, was, and now is, a resident of the County of Los

13 || Angeles, State of California.

14 7. The true names and/or capacities, whether individual, corporate, associate or

15 }| otherwise of defendants, DOES 1 through 50, inclusive, are unknown to plaintiff at this time and,

| 16 || therefore, plaintiff sues said defendants by said fictitious names, and when the true names and

17 | capacities of said defendants are ascertained, plaintiff will amend this complaint accordingly. |

18 | Plaintiff is informed and believes and thereupon alleges that each defendant designated herein as

19 || a DOE is legally responsible, negligently or in some other actionable manner, for the events and

20 || happenings hereinafter referred to and proximately thereby caused the injuries and damages to

21 || plaintiff as hereinafter alleged. Plaintiff will seek leave of court to amend this complaint to insert

22 || the true names and/or capacities of such fictitiously named defendants when the same have been

23 || ascertained.

24 | 8. Plaintiff is informed and believes and thereupon alleges that at all times
25 | mentioned herein defendants, and each of them, including DOES 1 through 50, inclusive, and

26 || each of them, were the agents, servants, employees and/or joint venturers of their co-defendants,
27 || and were, as such, acting within the course, scope permission, consent and authority of said |
28 || agency, employment and/or joint venture and that the acts of every defendant were ratified by

| 7 COMPLAINT FOR DAMAGES |

| |

1 || every other defendant. | :

2 9. On or about November 7, 2022, plaintiff, JOSE RIVERA, purchased a lottery |

3 | ticket for the $2.04 Billion Powerball Lottery draw that was scheduled for November 7, 2022 |

4 | (hereinafter “SUBJECT LOTTERY TICKET”). The draw for the $2.04 Billion Powerball |
5 | Lottery actually took place on November 8, 2022. | |
6 | 10. Plaintiff, JOSE RIVERA, was over the age of 18 years and lawfully purchased the |

7 | “SUBJECT LOTTERY TICKET” at Joe’s Service Center in Altadena, California, and plaintiff |

8 || was at all times mentioned herein the rightful and lawful owner of the “SUBJECT LOTTERY

9 || TICKET”. |
10 | 11. On or about November 7, 2022, defendant “REGGIE” stole the “SUBJECT |

11 | LOTTERY TICKET” from plaintiff, JOSE RIVERA. |

12 12. After defendant “REGGIE” stole the “SUBJECT LOTTERY TICKET” from
13 | plaintiff, JOSE RIVERA, numerous requests and demands were made by plaintiff to defendant |
14 | “REGGIE” to return the “SUBJECT LOTTERY TICKET” but defendant “REGGIE” refused to |

15 || return the “SUBJECT LOTTERY TICKET” to plaintiff. :

16 13. On November 8, 2022, the following winning numbers were picked for the $2.04
17 || Billion Powerball Lottery: 10, 33, 41, 47, 56 and 10. This was and remains the largest prize in .
18 | lottery history. Plaintiff contends the winning numbers are on the “SUBJECT LOTTERY |
19 | TICKET” which belongs to plaintiff. |
20 14. After the winning numbers were picked on November 8, 2022, plaintiff made |
21 | repeated requests that “REGGIE” return the “SUBJECT LOTTERY TICKET” to plaintiff. |
22 || “REGGIE’s responses included, but were not limited to, the ticket was a loser or if I find the |

23 || ticket we can split the winnings 50/50. Plaintiff refused to be blackmailed and repeatedly

24 |, requested the “SUBJECT LOTTERY TICKET” be returned to plaintiff. “REGGIE” refused to ,

25 || return the “SUBJECT LOTTERY TICKET” to plaintiff.
26 15. Plaintiff, JOSE RIVERA, reported the theft of the “SUBJECT LOTTERY

27 | TICKET” to the California Lottery and law enforcement.

28
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COMPLAINT FOR DAMAGES
 i
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1} 16. On February 14, 2023, defendants, CALIFORNIA STATE LOTTERY

2 | COMMISSION and STATE OF CALIFORNIA, announced EDWIN CASTRO was the winner |
3 || of the $2.04 Billion Lottery. Plaintiff is informed and believes and thereupon alleges defendant

4 || EDWIN CASTRO refused to attend the California Lottery press conference and failed to allow
| 5 | disclosure of his age, education, residence or occupation, among other things. |
| 6 17. Upon plaintiffs learning on February 14, 2023, that a certain EDWIN CASTRO

7 || was claimed to be the owner of the winning ticket, plaintiff, JOSE RIVERA, attempted on
8 || February 15, 2023, to present a Claim Form to the California Lottery in Chatsworth, California,

9 || but plaintiff was advised his Claim Form would not be accepted as the matter was closed.
10 18. On February 17, 2023, plaintiff, JOSE RIVERA, presented a Claim Form to the

11 || California Lottery in Santa Fe Springs, California, along with a Declaration that the “SUBJECT

12 | LOTTERY TICKET” was stolen, and the Claim Form was accepted by the Lottery office.

13 19. On February 17, 2023, plaintiff, JOSE RIVERA, by and through his counsel, sent

14 || a letter to the California Lottery, including to Director Johnson, Deputy Director Shergill-Chima

15 || and Chief Legal Counsel Aceves, and advised the California Lottery of plaintiff's claim the

16 | “SUBJECT LOTTERY TICKET” was stolen and plaintiff is the rightful owner of the |

17 || “SUBJECT LOTTERY TICKET”. The February 17, 2023, letter included a copy of the Claim |
18 || Form plaintiff presented earlier that day to the California Lottery in Santa Fe Springs, California.

19 | The February 17, 2023, letter stated, among many other things, the following: :
20 Attached is a signed Claim Form on behalf of Jose Rivera in connection with the
prize claim of $2.04 Billion. Mr. Rivera insists the California Lottery withhold
21] making any payment to Edwin Castro or any other individual until the facts and :
circumstances of the purchase, theft and submitting of the winning Powerball
22 ticket is fully investigated by the California Lottery and law enforcement. The
funds should be interplead so the rightful owner can be determined in a court of
23 law.
:
24 |
Mr, Rivera is willing to fully cooperate with your investigation, including meeting
25 with your investigators to give a detailed statement concerning the purchase and
theft of the ticket, along with threats of blackmail. We request an opportunity to
26 view the video depicting the date and time of the purchase of the winning lottery |
ticket at Joe's Service Centerin Altadena, California, where Mr. Rivera purchased
27 the ticket on November 7, 2022. We also look forward to viewing any video that
purports to depict Edwin Castro purchasing the winning ticket. :
28 |] |
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| COMPLAINT FOR DAMAGES

 1] It was recently reported in the news there is an extensive vetting process that is
performed when someone presents a winning ticket. We assume the California |
2 2 Lottery has taken or will take into consideration Mr. Rivera’s reported theft
| allegations. The following was recently reported in the news media concerning
3| the vetting process:
: 4 California Lottery spokesperson Russ Lopez explained that when
the winner shows up, an extensive vetting process takes place to
| 5 make sure they're the actual winner.

6 Officials will even check store surveillance video from the time
when the ticket was purchased.
7
"We look at the ticket, we make sure this is a valid ticket, this is
8 the right ticket, this is the right person, the signatures match, we
look at identities and we look at a lot of things. People shouldn't be
9 | intimidated. This is for their own safety," Lopez said. (Emphasis
7 added)

) Mr. Rivera claims he is the “right person”. Mr. Rivera acted promptly upon |
11 learning that.a certain Edwin Castro was claiming to be the winner. Up until the
| announcement on February 14, 2023, Mr. Rivera had been threatened that his
12 | winning ticket would be destroyed if he did not agree to split the winnings. Mr.
Rivera refused to accept that threat of blackmail. The disclosure of the alleged
13 winner on February 14, 2023, indicates the stolen ticket was not destroyed but is
now in the possession and safety of the California Lottery.
14
| 15 | 20. Plaintiff, JOSE RIVERA, by and through his counsel, further corresponded with

16 | the California Lottery on February 21, 2023, and requested the California Lottery preserve all |
| 17 | videos depicting the individual purchasing the “SUBJECT LOTTERY TICKET” at Joe’s Service | |
18 || Center and plaintiff made a Public Records Act Request to the California Lottery for the video

19 || depicting the purchase of the “SUBJECT LOTTERY TICKET”.

20} 21. Plaintiff, JOSE RIVERA, has not received a response from the California Lottery

21 | concerning plaintiff's assertion plaintiff is the rightful owner of the “SUBJECT LOTTERY

22 || TICKET” and plaintiff is entitled to the proceeds of the winning ticket.

23 22. Plaintiff, JOSE RIVERA, is informed and believes defendant, EDWIN CASTRO,

24 || elected to receive the lump sum payment of about $997.6 million. Plaintiff contends plaintiff is .
25 || the lawful and rightful owner of the “SUBJECT LOTTERY TICKET” and entitled to receipt of |
26 | the lump sum payment of about $997.6 million or the 30 annual payments. It is not known if any

27 payment has been made to EDWIN CASTRO.

28 | |
|p te 5 neem
COMPLAINT FOR DAMAGES
: 1 23. Plaintiff, JOSE RIVERA, contends an actual controversy has arisen between the |

| 2 || parties and their respective rights and obligations as to whether plaintiff must be awarded the :

3 || $2.04 Billion Powerball lottery prize for the draw on November 8, 2022. To the extent |

| 4 || defendants, CALIFORNIA STATE LOTTERY COMMISSION, STATE OF CALIFORNIA, ;

| 5 || have made or make any payment to any individual other than the actual and lawful owner of the

6 || “SUBJECT LOTTERY TICKET”, plaintiff, JOSE RIVERA, will seek the amount of those |

| 7 || payments as damages against defendants.

8
9 FIRST CAUSE OF ACTION |

10 | (DECLARATORY RELIEF - by plaintiff, JOSE RIVERA, against defendants, |

11 CALIFORNIA STATE LOTTERY COMMISSION, STATE OF CALIFORNIA, |

12 EDWIN CASTRO and DOES 1 through 50, inclusive)

13 | 24. ‘Plaintiff, JOSE RIVERA, realleges as though fully set forth at length and

14 || incorporates herein by reference all of the allegations and statements contained in Paragraphs |
| 15 || through 23, inclusive, of the GENERAL ALLEGATIONS above.

| 16 25. Plaintiff, JOSE RIVERA, is informed and believes and thereupon alleges an

| 17 | actual controversy has arisen between the parties and their respective rights and obligations as to :
18 || the ownership of the “SUBJECT LOTTERY TICKET” and whether plaintiff must be awarded
19 | the $2.04 Billion Powerball lottery prize for the draw on November 8, 2022.

20 26. Plaintiff, JOSE RIVERA, is informed and believes and thereupon alleges: |
21. a. Plaintiff is the rightful and lawful owner of the “SUBJECT LOTTERY :

22 TICKET” and entitled to the payout of the $2.04 Billion;

23 b. The “SUBJECT LOTTERY TICKET” was stolen from plaintiff by

24 “REGGIE” who thereafter provided the “SUBJECT LOTTERY TICKET”

25. to others;

26 c. The “SUBJECT LOTTERY TICKET” was presented to the California |

27 Lottery without the consent, permission or knowledge of plaintiff; |
28 |
sinning ani i |
COMPLAINT FOR DAMAGES |
| | ,

| 1 d. Plaintiff notified the California Lottery by submitting a Claim Form that

2 plaintiff is the lawful and rightful owner of the “SUBJECT LOTTERY |

| 3 | TICKET”;
| 4 e. Plaintiff has presented substantial proof plaintiff is the winner of the $2.04

: 5 Billion Superball Lottery and defendants have the video from Joe’s

| 6 Service Center that depicts the individual who purchased the “SUBJECT

: 7 LOTTERY TICKET”;

| 8 f. Defendants, CALIFORNIA STATE LOTTERY COMMISSION and |

9 STATE OF CALIFORNIA, have failed to pay plaintiff.

| 10 27. Plaintiff, JOSE RIVERA, is informed and believes and thereupon alleges |

11 || defendants, and each of them, apparently dispute plaintiffs contentions plaintiff is the lawful and |

12 || rightful owner of the “SUBJECT LOTTERY TICKET” and entitled to the payout of the $2.04
13 || Billion. ,

14 28. Plaintiff, JOSE RIVERA, requests a judicial determination of plaintiff's rights

15 || and obligations as they relate to plaintiff as the lawful and rightful owner of the “SUBJECT

| 16 | LOTTERY TICKET” and entitlement to the payout of the $2.04 Billion Powerball Lottery.

| 17 |
| 18 | SECOND CAUSE OF ACTION
19 | (CONVERSION - By Plaintiff, JOSE RIVERA, Against Defendants, “REGGIE”

20 and DOES 1 through 50, inclusive)

21 29. Plaintiff, JOSE RIVERA, realleges as though fully set forth herein at length and = |

22 | incorporate herein by reference all of the allegations and statements contained in Paragraphs 1

23 | through 23, inclusive, of the GENERAL ALLEGATIONS above.

24 30. That at all times mentioned herein plaintiff, JOSE RIVERA, owned, possessed,

25 || and was the lawful and rightful owner of the “SUBJECT LOTTERY TICKET” and defendant |

26 || “REGGIE” wrongfully exercised control over and stole the “SUBJECT LOTTERY TICKET” :

27 || without the consent of plaintiff.

28
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COMPLAINT FOR DAMAGES |
| 1 31. That at all times mentioned herein defendant “REGGIE” and DOES 1 through 50,

2 || inclusive, intentionally took possession of the “SUBJECT LOTTERY TICKET” without the |

3 || consent or permission of plaintiff and deprived and prevented plaintiff from having access to or |

4 | possession of the “SUBJECT LOTTERY TICKET” so as to be able to present the “SUBJECT

5 || LOTTERY TICKET” with a Claim Form to California Lottery to collect on the winning numbers |

7 6 | on the “SUBJECT LOTTERY TICKET” thereby causing harm to plaintiff in the amount of the |

| 7 | $2.04 Billion Lottery prize which plaintiff claims he won with the numbers on the “SUBJECT |

| 8 || LOTTERY TICKET”.

9 32. That as a direct and proximate result of the wrongful conduct of defendant

10 | “REGGIE” and DOES 1 through 50, inclusive, plaintiff was harmed as said defendants later |

11 || presented the “SUBJECT LOTTERY TICKET” to the California Lottery as if defendants and |

12 || others were the rightful and lawful purchasers and owners of the “SUBJECT LOTTERY

13 | TICKET”.

14 | 33. Plaintiffis informed and believes and thereupon alleges defendants’ conduct was

15 || willful, intentional and designed to deprive plaintiff of the proceeds of the “SUBJECT

16 | LOTTERY TICKET” and plaintiff seeks damages in the amount of the $2.04 Billion Lottery

17 || prize, damages for emotional distress, along with punitive damages, according to proof. ,
18

19 THIRD CAUSE OF ACTION

20 | (TRESPASS TO CHATTELS - By Plaintiff, JOSE RIVERA, Against Defendants, |

21 “REGGIE” and DOES 1 through 50, inclusive) |

22 34. Plaintiff, JOSE RIVERA, realleges as though fully set forth herein at length and |

23 || incorporate herein by reference all of the allegations and statements contained in Paragraphs 1 |

24 | through 23, inclusive, of the GENERAL ALLEGATIONS above. |

25 | 35. That at all times mentioned herein plaintiff, JOSE RIVERA, owned, possessed,

26 || and was the was the lawful owner of the “SUBJECT LOTTERY TICKET” and defendant |

27 | “REGGIE” wrongfully exercised control over and stole the “SUBJECT LOTTERY TICKET” |

28 | without the consent of plaintiff. |

rey eial a |
 1 36. That at all times mentioned herein defendant “REGGIE” and DOES 1 through 50,
2 |, inclusive, intentionally interfered with plaintiff's use and possession of the “SUBJECT | :

3 | LOTTERY TICKET” and defendants took possession of the “SUBJECT LOTTERY TICKET” |

4 || without the consent of plaintiff and deprived and prevented plaintiff from having access to or

5 || possession of the “SUBJECT LOTTERY TICKET” so as to be able to present the “SUBJECT

6 | LOTTERY TICKET” with a Claim Form to California Lottery to collect on the winning numbers

7 j| on the “SUBJECT LOTTERY TICKET” thereby causing harm to plaintiff in the amount of the

8 | $2.04 Billion Lottery prize which plaintiff claims he won with the numbers on the “SUBJECT

9 || LOTTERY TICKET”. | |

10 37. That as a direct and proximate result of the wrongful conduct of defendant :

11 || “REGGIE” and DOES 1 through 50, inclusive, plaintiff was harmed as said defendants later |

12 || presented the “SUBJECT LOTTERY TICKET” to the California Lottery as if defendants and

13 || others were the rightful and lawful purchasers and owners of the “SUBJECT LOTTERY . |

14 | TICKET”.

15 38 Plaintiff is informed and believes and thereupon alleges defendants’ conduct was

16 || willful, intentional and designed to deprive plaintiff of the proceeds of the “SUBJECT

17 | LOTTERY TICKET” and plaintiff seeks damages in the amount of the $2.04 Billion Lottery |

| 18 || prize, damages for emotional distress, along with punitive damages, according to proof.

19

20 | FOURTH CAUSE OF ACTION

21 (INTENTIONAL INTERFERENCE WITH PROSPECTIVE ECONOMIC

22) RELATIONS - By Plaintiff, JOSE RIVERA, Against Defendants, “REGGIE”

234 and DOES 1 through 50, inclusive)

24 | 39. Plaintiff, JOSE RIVERA, realleges as though fully set forth herein at length and |

25 || incorporate herein by reference all of the allegations and statements contained in Paragraphs 1 |

26 || through 23, inclusive, of the GENERAL ALLEGATIONS above.

27 40. Plaintiff is informed and believes and thereupon alleges plaintiff and the |

28 | California Lottery were in an economic relationship that probably would have resulted in an

| COMPLAINT YORDAMAGES SS |
: 1 | economic benefit to plaintiff.

2| Al. Plaintiff is informed and believes and thereupon alleges defendants, and each of |

| 3 || them, knew of the economic relationship between plaintiff and the California Lottery. |

| 4 42. Plaintiff is informed and believes and thereupon alleges defendants, and each of | ;

| 5 |; them, intended to disrupt the economic relationship between plaintiff and the California Lottery

6 | by depriving plaintiff of the “SUBJECT LOTTERY TICKET” and benefits provided by the |

7 | winning ticket.

8 43. Plaintiff is informed and believes and thereupon alleges defendants, and each of

9 || them, engaged in wrongful conduct by taking the “SUBJECT LOTTERY TICKET” from

10 || plaintiff and thereafter presenting the “SUBJECT LOTTERY TICKET” to the California Lottery |

11 |] and representing the “SUBJECT LOTTERY TICKET” belonged to someone other than plaintiff. |

12 44. Plaintiffis informed and believes and thereupon alleges the economic relationship

13 || between plaintiff and the California Lottery was disrupted by defendants, and each of them.

14 45. That at all times mentioned herein defendant “REGGIE” and DOES 1 through 50,

15 | inclusive, intentionally deprived and prevented plaintiff from having access to or possession of |

16 || the “SUBJECT LOTTERY TICKET” so as to be able to present the “SUBJECT LOTTERY

17 || TICKET” with a Claim Form to California Lottery to collect on the winning numbers on the |

18 || “SUBJECT LOTTERY TICKET” thereby causing harm to plaintiff in the amount of the $2.04

19 | Billion Lottery prize which plaintiff claims he won with the numbers on the “SUBJECT

20 | LOTTERY TICKET”.

21) 46. That as a direct and proximate result of the wrongful conduct of defendant :

22 || “REGGIE” and DOES 1 through 50, inclusive, plaintiff was harmed as said defendants later

23 || presented the “SUBJECT LOTTERY TICKET” to the California Lottery as if defendants and :

24 || others were the rightful and lawful purchasers and/or owners of the “SUBJECT LOTTERY

25 | TICKET”.

26 47, Plaintiff is informed and believes and thereupon alleges defendants’ conduct was |
27 || willful, intentional and designed to deprive plaintiff of the proceeds of the “SUBJECT |

28 || LOTTERY TICKET” and plaintiff seeks damages in the amount of the $2.04 Billion Lottery |
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COMPLAINT FOR DAMAGES
 | |

1 || prize, damages for emotional distress resulting from defendants’ intentional conduct, along with

2 | punitive damages, according to proof. |

3

4 FIFTH
CAUSEOF ACTION
5 (NEGLIGENT INTERFERENCE WITH PROSPECTIVE ECONOMIC

6 RELATIONS - By Plaintiff, JOSE RIVERA, Against Defendants, “REGGIE”

7 and DOES 1 through 50, inclusive)

8 48. Plaintiff, JOSE RIVERA, realleges as though fully set forth herein at length and

9 | incorporate herein by reference all of the allegations and statements contained in Paragraphs 1 |

: 10 || through 23, inclusive, of the GENERAL ALLEGATIONS above. | |

11 49. Plaintiff is informed and believes and thereupon alleges plaintiff and the |
| 12 || California Lottery were in an economic relationship that probably would have resulted in an |
13 | economic benefit to plaintiff. |
14 50. Plaintiff is informed and believes and thereupon alleges defendants, and each of

15 | them, knew or should have known of the economic relationship between plaintiff and the |

16 || California Lottery.

17 51. Plaintiff is informed and believes and thereupon alleges defendants, and each of 7
18 || them, knew or should have known this economic relationship between plaintiff and the

19 || California Lottery would be disrupted if defendants failed to act with reasonable care and
20 || deprived plaintiff of the “SUBJECT LOTTERY TICKET”.

21 | 52. Plaintiff is informed and believes and thereupon alleges defendants, and each of
22 | them, failed to act with reasonable care and deprived plaintiff of the “SUBJECT LOTTERY |
23 || TICKET”.

24 53. Plaintiff is informed and believes and thereupon alleges the economic relationship 2 ,

25 || between plaintiff and the California Lottery was disrupted by defendants, and each of them, as a |

26 | result of defendant’s negligent, careless and reckless conduct.

27 54. That at all times mentioned herein defendant “REGGIE” and DOES 1 through 50,

28 | inclusive, negligently and carelessly deprived and prevented plaintiff from having access to or

| } COMPLAINT FOR DAMAGES © | :

| 1| possession of the “SUBJECT LOTTERY TICKET” so as to plaintiff to be able to present the

2 || “SUBJECT LOTTERY TICKET” with a Claim Form to California Lottery to collect on the :

3 winning numbers on the “SUBJECT LOTTERY TICKET” thereby causing harm to plaintiff in |

4 || the amount of the $2.04 Billion Lottery prize which plaintiff claims he won with the numbers on :
| 5 | the “SUBJECT LOTTERY TICKET”.

| 6 55. That as a direct and proximate result of the wrongful conduct of defendant |

| 7 || “REGGIE” and DOES 1 through 50, inclusive, plaintiff was harmed as said defendants later

8 || presented the “SUBJECT LOTTERY TICKET” to the California Lottery as if defendants and

9 || others were the rightful and lawful purchasers and/or owners of the “SUBJECT LOTTERY

10 || TICKET”. |
11 56. Plaintiff is informed and believes and thereupon alleges defendants negligently |

12 | interfered with a relationship between plaintiff and the California Lottery that probably would

13 | have resulted in an economic benefit to plaintiff.

14 | 57. Plaintiff is informed and believes and thereupon alleges defendants’ conduct was

15 | negligent and careless and deprived plaintiff of the proceeds of the “SUBJECT LOTTERY

16 || TICKET” and plaintiff seeks damages in the amount of the $2.04 Billion Lottery prize and

17 || damages for emotional distress resulting from defendants’ negligent conduct, according to proof. |

18 WHEREFORE, plaintiff, JOSE RIVERA, prays for judgment against defendants, and

19 | each of them, as follows:

20 (1) That the Court declare the rights and obligations of each party with respect to this

21 | dispute; |

22 (2) That the Court declare plaintiff, JOSE RIVERA, is the lawful and rightful owner

23 || of the “SUBJECT LOTTERY TICKET” and the winner of the November 7 (8), 2022, $2.04

24 || Billion Powerball Lottery and entitled to the payout of the $2.04 Billion;

25 (3) That the Court declare plaintiff, JOSE RIVERA, has presented substantial proof |

26 | that plaintiff is the rightful owner of the “SUBJECT LOTTERY TICKET” and plaintiff is the |

27 | winner of the November 7 (8), 2022, $2.04 Billion Powerball Lottery and entitled to the payout =| |

28 || of the $2.04 Billion; |

| ee tre: |, seeenetene ne mnmcennrnsenteanenmmnemeennmatnatntnne |
COMPLAINT FOR DAMAGES |
 1 (4) That the Court award and enter judgment in favor of plaintiff, JOSE RIVERA,

2 || and against defendants in the amount of the grand prize for the $2.04 Billion Powerball Lottery
3 | draw on November 8, 2022;

: 4 (5) For all economic and non-economic damages, according to proof;

| 5 (6) For punitive damages, according to proof;

: 6 (7) For costs of suit incurred herein; and, :

| 7 (8) For such other and further relief as the Court deems just and proper.

8 | DATED: February 22, 2023 LAW OFFICE OF ESTELA RICHEDA

, Oo} and ,

: 10 LAW OFFICE OF R. BRIAN KRAMER

11 /s/_ Estela S. Richeda

BY:
| 12 ESTELA RICHEDA, Esq.
R. BRIAN KRAMER, Esq.
13 Attorneys for Plaintiff, JOSE RIVERA

| 14} |
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COMPLAINT FOR DAMAGES