N00 SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO, Document Scanning Lead Sheet Jian-29-2015 2:39 pm Case Number: CGC-15-543877 Filing Date: Jan-29-2015 2:35 Filed by: DENNIS TOYAMA ia Juke Box: 001 Image: 04773494 COMPLAINT MARY FINLEY ET AL VS. UBER TECHNOLOGIES, INC. ET AL 001004773494 Instructions: Please place this sheet on top of the document to be scanned.@ e SUM-100 SUMMONS FOR COURT USE ONLY (CITACION JUDICIAL) (SOLO PARA USO DE LA CORTE) NOTICE TO DEFENDANT: (AVISO AL DEMANDADO): Uber Technologies, Inc.; Rasier LLC; Rasier-CA LLC; Ho Wan Pang; David Jonathan Waksberg; Does 1-40 YOU ARE BEING SUED BY PLAINTIFF: (LO ESTA DEMANDANDO EL DEMANDANTE): Mary Finley and Sean Finley NOTICE! 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 will not protect you, Your written response must be in proper legal form if you want the court to hear your case. There may 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 (www.courtinfo.ca.gov/selthelp} your county law library, or the courthouse nearest you. If you cannot pay the filing fee, ask the court clerk for a fee waiver form. if you do not file your response on time, you may lose 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 may want to call an attorney right away. If you do not know an attorney, you may want to call an attorney referral service. If you cannot afford an attorney, you may be eligible for free legal services from a nonprofit legal services program. You can locate these nonprofit groups at the California Legal Services Web site(www.lawhelpcalifomia.org), the California Courts Online Self-Help Center (www courtinfo.ca.gov/selfhelp), or by contacting your iocal court or county bar association NOTE: The court has a statutory lien for waived fees and costs on any settlement or arbitration award of $10,000 or more in a civil case. The courts lien must be paid before the court will dismiss the case. JAVISO! Lo han demandado. Si no responde dentro de 30 dias, la corte puede decidir en su contra sin escuchar su versién. Lea la informacion a continuacién. Tiene 30 DIAS DE CALENDARIO después de que le entreguen esta citacién y papeles legales para presenter una respuesta por escrito en esta corte y hacer que se entregue una copia al demandante. Una carta o una llamada telefénica no lo protegen. Su respuesta por escrito tiene que estar en formato legal correcto si desea que procesen su caso en la corte. Es posible que haya un formulario que usted pueda usar para su respuesta Puede encontrar estos formularios de la corte y més informacién en el Centro de Ayuda de las Cortes de Californiwww.sucorte.ca.gov), en la biblioteca de leyes de su condado o en la corte que le quede mas cerca. Sino puede pagar la cuota de presentacién, pida al secretario de la corte que le dé un formulario de exencién de pago de cuotas. Sino presenta su respuesta a tiempo, puede perder el caso por incumplimiento y la corte le podré quitar su sueldo, dinero y bienes sin mas advertencia. Hay otros requisitos legales. Es recomendable que llame a un abogado inmediatamente. Si no conoce a un abogado, puede llamar a un servicio de remisi6n 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 servicios legales sin fines de lucro. Puede encontrar estos grupos sin fines de lucro en el sitio web de California Legal Services, (wrw lawhelpcalifornia.org), en el Centro de Ayuda de las Cortes de California, (www. sucorte.ca.gov) 0 poniéndose en contacto con la corte o el colegio de abogados locales. AVISO: Por ley, la corte tiene derecho a reclamar las cuotas y los costos exentos por imponer un gravamen sobre cualquier recuperacién de $10,000 6 més de valor recibida mediante un acuerdo o una concesién de arbitraje en un caso de derecho civil. Tiene que pagar el gravamen de la corte antes de que la corte pueda desechar el caso. The name and address of the court is: ig Pyesy 43877 (El nombre y direcci6n de la corte es). San Francisco County Superior Court 400 McAllister Street San Francisco, CA 94102 The name, address, and telephone number of plaintiffs attorney, or plaintiff without an attorney, is: (Ef nombre, la direccién y el nimero de teléfono del abogado del demandante, o de! demandante que no tiene abogado, es): HASSARD BONNINGTON LLP Joanna L. Storey, Esq. SBN 214952 275 Battery Street, 16th Floor (415) 288-980 San Francisco, CA 94111 = COU : DATE: > OLERK OF Ht U' Fock by cone . Deputy (Fecha) JAN 2 8 2015 (Secretario) £ (Adjunto) Sane ST seriGe oF Hs SUTTONS, USE POST oT GERIGE ST SURO Toe PORTO] io} ‘of Service OF this summons, use Proof of Service of Summons (form POS-OT0)) (Para prueba de entrega de esta citacién use el formulario Proof of Service of Summons, (POS-010)). NOTICE TO THE PERSON SERVED: You are served 1 as an individual defendant. 2, as the person sued under the fictitious name of (specify). [SEAL 3. C2) on behalf of (specify): under: CCP 416.10 (corporation) CCP 416.60 (minor) CCP 416.20 (defunct corporation) CCP 416.70 (conservatee) CCP 416.40 (association or partnership) CCP 416.90 (authorized person) other (specify): 4. [(C) by personal delivery on (date): pei Fag iapeete eae card Gnas ato SAS I cae See eS eee ESSENTIAL FORMS™CM-010 "ATTORNEY OR PARTY WITHOUT ATTORNEY (Nam, State Bar number and asoress) FOR COURT USE ONLY | HASSARD BONNINGTON LLP Joanna L. Storey, Esq, SBN 214952 FE 275 Battery Street, 16th Floor ; a San Francisco, CA 94111 Superior Court of California tetepHoneno: (415) 288-9800 raxno: (415) 288-9801 vounty of San Francisco ATTORNEY FOR (Name) Plaintiffs Mary Finley and Sean Finley ‘SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Francisco JAN 29 2015 street aopress 400 McAllister Street manincaopress 400 McAllister Street CLERK OF THE COURT cmvanozecoveSan Francisco, CA 94102 BY: aoa ARK BRANCH NAME, ees Deputy Clerk | CASENAME: Finley v. Uber Technologies, Inc. CIVIL CASE COVER SHEET Complex Case Designation Aug es (QQ Unlimited = (CQ Limited Cicounter CQ voind ¢é e 1 5 5 4 5 8 a 7 (Amount (Amount meer demanded demanded is Filed with first appearance by defendant Seite exceeds $25,000) $25,000 or less) (Cal. Rules of Court, rule 3.402) veer Items 1-6 below must be completed (see instructions on page 2). T, Check one box below for the case type that best describes this case: Auto Tort Contract Provisionally Complex Civil Litigation 4 Auto (22) Breach of contractwarranty (06) (Cal. Rules of Court, rules 3.400-3.403) Uninsured motorist (46) Rule 3.740 collections (09) Antitrust/Trade regulation (03) Da cinchrel eieenel umenen: Otter collectors (08) Construction defect (10) Panegernongiar paste surance coverage (18) Mass tort (40) Other contract (37) Securities litigation (28) tests (08) EnvironmentaToxic tort (30) Product liability (24) Real Property Insurance coverage claims arising from the Medical malpractice (45) LY Eminent domain/inverse Hectolhnteebe et 9 Other P/PDAWD (23) condemnation (14) above listed provisionally complex case Wrongful eviction (33) types (41) Other real property (26) Enforcement of Judgment Enforcement of judgment (20) Non-PIPDIWD (Other) Tort Business tort/unfair business practice (07) Civil rights (08) Unlawful Detainer Defamation (13) Commercial (31) Miscellaneous Civil Complaint Fraud (16) Residential (32) 8 RICO (27) Intellectual property (19) Drugs (38) Other complaint (not specified above) (42) Professional negligence (25) Judicial Review Miscellaneous Civil Petition ee ee Ge) ‘Asset forfeiture (05) H Partnership and corporate governance (21) Employment Petition re: arbitration award (11) Other petition (not specified above) (43) Wrongful termination (36) Writ of mandate (02) Other employment (15) Other judicial review (39) 2. Thiscase [Bis CQ isnot complex under rule 3.400 of the California Rules of Court. If the case is complex, mark the factors requiring exceptional judicial management. a Large number of separately represented parties Large number of witnesses b. Extensive motion practice raising difficult or novel e 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 court c. (2) Substantial amount of documentary evidence f Substantial postjudgment judicial supervision 3. Remedies sought (check all that apply): a. (J monetary b. nonmonetary; declaratory or injunctive relief c. (L] punitive 4. Number of causes of action (specify): 5. Thiscase ([Jis is not a class action suit. 6. If there are any known related cases, file and serve a notice of related case. (You may use form CM-015.) Date: January 34 , 2015 Joanna I torey, Esq > (TYPE OR PRINT NAME) AJ OF PARTY OR ATTORNEY FOR PARTY) NOTICE Plaintiff must file this cover sheet with the first paper filed in the action or proceet cept small claims cases or cases filed under the Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.) Failure to file may result in sanctions. File this cover sheet in addition to any cover sheet required by local court rule. | If this case is complex under rule 3.400 et seq. of the 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. Pine ot Pe GWIL GASE COVER SHEET op SSeS Rea TP BHD TRCN NS T2007 Esc EWTHAL FORMS" wera COurno 3 govCe NY Aw BF Bw HN | = 5 12 HASSARD BONNINGTON LLP Philip S. Ward, Esq. (#51768) psw@hassard.com Marc Ni Zimmerman, Es 14 Sik [) wanzéhassard.com Joanna L. Storey, Esq. ( 52) jls@hassard.com 275 Battery Street, Suite 1600 JAN 29 2015 San Francisco, California 94111 CLERK OF THE COURT K Telephone: (415) 288-9800 EO Fax: (415) 288-9801 BY as eg TOYAMAy Deputy Cler Attorneys for Plaintiffs MARY FINLEY and SEAN FINLEY IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN FRANCISCO UNLIMITED JURISDICTION wo © 06 7 15-543877 MARY FINLEY; SEAN FINLEY, Plaintiffs, COMPLAINT FOR DAMAGES vs. 1. NEGLIGENCE - MOTOR VEHICLE UBER TECHNOLOGIES, INC.; RASIER 2. NEGLIGENCE LLC; RASIER-CA LLC; HO WAN 3. NEGLIGENT HIRING PANG; DAVID JONATHAN RETENTION AND WAKSBERG; and DOES 1-40, inclusive, SUPERVISION 4. LOSS OF CONSORTIUM Defendants. DEMAND FOR JURY TRIAL le Plaintiff MARY FINLEY is an adult female residing in the City and County of San Francisco. She is the spouse of SEAN FINLEY. 2. Plaintiff SEAN FINLEY is an adult male residing in the City and County of San Francisco. He is the spouse of MARY FINLEY. 3. Defendant UBER TECHNOLOGIES, INC. (hereinafter "UBER") is a Delaware Corporation, and Does 1-10 are corporations and/or business entities of a form unknown which run a TRANSPORTATION NETWORK COMPANY (“TNC”) known as UBER which provide a number of transportation options and vehicles for users of their service, including a low cost option called Uber X, through an online- enabled application (hereinafter "APP"). UBER has its principal place of business in “l COMPLAINT FOR DAMAGES AND DEMAND FOR TRIAL BY JURY PAWdocs\HBMAIN\03124\00000\00910600. DOCX-12815SC Oe IN DH WN u 12 13 4 15 16 17 18 19 20 21 22 23 24 25 26 27 28 and conducts business in San Francisco, California. 4. Plaintiffs are informed and believe and, on the basis of said information and belief, allege that RASIER LLC is a Delaware Limited Liability Company which is a wholly owned subsidiary of UBER and the parent company of RASIER-CA LLC, a Delaware Limited Liability Company. RASIER LLC and RASIER-CA LLC have their principal place of business in and conduct business in San Francisco, California. 5. UBER, and DOES 1-10, use RASIER LLC and/or RASIER-CA LLC and/or Does 21-30 to operate a TNC known as Uber X, a division of UBER and/or Does 1-10, and as a commercial enterprise of Does 21-30. 6. Plaintiffs are informed and believe and, on the basis of information and belief, allege that RASIER-CA LLC has been assigned Carrier ID No. PSG0032512 by the California Public Utilities Commission (“CPUC”) and further that UBER, RASIER LLC and/or RASIER-CA LLC and/or Does 1-10 and Does 21- 30 use Carrier ID No. PSG0032512 to operate its TNC, Uber X in California. Te Plaintiffs are informed and believe and, on the basis of information and belief, allege that RASIER-CA LLC is the insurance certificate holder for the insurance that UBER is required to carry as a TNC by the CPUC, which it uses for its Uber X operations. 8. Defendant HO WAN PANG is an adult male residing in Oakland, California. On September 10, 2014, he was the driver of a vehicle which injured MARY FINLEY. 9. Defendant DAVID JONATHAN WAKSBERG is an adult male residing in Palo Alto, California. On September 10, 2014, he was the driver of a vehicle which injured MARY FINLEY. M1 eon COMPLAINT FOR DAMAGES AND DEMAND FOR TRIAL BY JURY P:\Wdocs\HBMAIN\03 124\00000\009 10600. DOCX-12815SO em IND HB wD 10. Plaintiffs are informed and believe and, the basis of said information and belief, allege that on September 10, 2014, at the time of the subject collision, Defendant HO WAN PANG was a driver/transportation provider who was operating his vehicle utilizing the UBER APP and as such was an agent and/or employee and/or partner of UBER, and/or RASIER LLC and/or RAISER-CA LLC and/or Does 1-10 and/or Does 21-30. ll. Plaintiffs are informed and believe and, the basis of said information and belief, allege that at all times material to this complaint, UBER and/or RASIER LLC and/or RAISER-CA LLC and/or Does 1-10 and/or Does 21-30 were the employer(s) of Defendant HO WAN PANG, and/or his partner and/or an agency relationship existed between them. 12. Does 11-20 are believed to be the owners of the vehicle driven by HO WAN PANG at the time of the subject collision. 13. Does 31-35 are believed to be the owners of the vehicle driven DAVID JONATHAN WAKSBERG at the time of the subject collision. 14. Does 36-40 are believed to be the employer of DAVID JONATHAN WAKSBERG, and/or his partner and/or an agency relationship existed between them, and they are liable in the event DAVID JOANTHAN WAKSBERG was operating the motor vehicle within the course and scope of his employment at the time of the subject collision. 15. Plaintiffs are ignorant of the names of the Defendants sued herein as DOES | through 40, inclusive, and therefore sue these Defendants by such fictitious names. Plaintiffs will amend this complaint to allege their true names and capacities when ascertained. Plaintiffs are informed and believe and herein allege that each of said fictitiously named Defendants is responsible in some manner for the occurrences herein alleged, and that Plaintiffs’ injuries herein alleged were caused by the aforementioned Defendants. /// oa COMPLAINT FOR DAMAGES AND DEMAND FOR TRIAL BY JURY P.\Wdocs\HBMAIN\03124\00000\0091 0600. DOCX-12815Cem nN Dw BF WN = yoeNMN YN NYDN HK De B&B ew Be eB es Be ee eoD AHA BF BH KF SO wH AU A HA Fw WH = S 16. Plaintiffs are informed and believe and, on the basis of said information and belief, allege that at all times material to the matters alleged in this Complaint, each of the Defendants was the agent and/or employee and/or partner of each of the remaining Defendants and, in doing the things herein alleged, was acting within the course and scope of such agency and/or employment, and/or aided and/or abetted the others and/or ratified the acts of the others so as to make them liable for the Plaintiffs’ damages. 17. Plaintiffs are informed and believe and, on the basis of said information and belief, allege that there is a unity of interest and operation between UBER, RAISER LLC, RAISER-CA LLC and Does 1-10 and 21-30 such that their separate and independent classification is but a fiction and that each is the alter-ego of the other. 18. | Defendants are liable for the acts of each other through principles of respondeat superior, agency, ostensible agency, partnership, alter-ego and other forms of vicarious liability. YENUE AND JURISDICTION 19. Venue in this court is appropriate as the injuries to the Plaintiffs occurred within the City and County of San Francisco. 20. Jurisdiction is proper in this case in that the amount in controversy is in excess of the statutory minimum of this court. FA‘ MON TO A: TION 21. On September 10, 2014, at approximately 5:55 p.m., MARY FINLEY was a passenger in a motor vehicle operated by HO WAN PANG that collided with a motor vehicle operated by DAVID JONATHAN WAKSBERG at or near the intersection of 17" Avenue and Fulton Street in San Francisco, California. 22. The collision caused serious and significant physical and mental injuries to MARY FINLEY. //} 4- COMPLAINT FOR DAMAGES AND DEMAND FOR TRIAL BY JURY P:\Wdoes\HBMAIN\03 1241000001009 10600.DOCX-12815Cm nr DAW FF WN = SS ee Rede ee DESeee a HeTe Eee NOTH eve bapeecte asec sec ee eee cetera see eee ec eee egSee Reape ean oPe-- eRe mete AG peace Me MC 23. UBER, RAISER LLC, RAISER-CA LLC and Does 1-10 and 21- 30 and their Uber X service have been classified by the CPUC as a TNC. 24. UBER, RAISER LLC, RAISER-CA LLC and Does 1-10 and 21- 30, through their services, including Uber X, provide prearranged transportation services for compensation using the APP or platform to connect persons wanting to procure transportation (hereinafter USERS"), with those who, utilizing their own personal vehicles, want to provide transportation on exchange for compensation (hereinafter "DRIVERS"). 25. Plaintiffs are informed and believe and, on the basis of said information and belief, allege that HO WAN PANG was logged on to the UBER APP at the time the subject collision occurred, was appearing as a UBER and/or Uber X DRIVER providing transportation services to USERS and/or was viewing, monitoring and/or interacting with his wireless communications device/smartphone/GPS at or near the time of the subject collision. FI A Negligence - Motor Vehicle By Plaintiff MARY FINLEY against All Defendants 26. _ Plaintiffs incorporate by reference, as though fully set forth herein, the contents of Paragraphs 1 through 25. 27. Defendants and each of them owed Plaintiff Mary Finley a duty of reasonable/due care as well as statutory duties established in Vehicle Code sections 21950, 23123, 23123.5 and/or 26708. 28. On September 10, 2014, Defendant HO WAN PANG, while operating his vehicle in the scope and course of his employment/agency/partnership with UBER, and/or RASIER LLC and/or RAISER-CA LLC and/or Does 1-10 and 21- 30, was negligent and did breach one or more of the aforesaid duties, which breach was the proximate cause of personal injuries to Plaintiff MARY FINLEY. “5. COMPLAINT FOR DAMAGES AND DEMAND FOR TRIAL BY JURY P\Wdoes\HBMAIN\03 124\00000\009 10600. DOCX-12815po) oe ° CoN DW WN YN YN YN NNN Se ee ee ee Be Be ot AAW BF ON FS Owe ADA BR WY = SO 29. On September 10, 2014, Defendant DAVID JONATHAN WAKSBERG, while operating his vehicle in the scope and course of his employment/agency/partnership with Does 36-40, was negligent and did breach one or more of the aforesaid duties, which breach was the proximate cause of personal injuries to Plaintiff MARY FINLEY. 30. Onsaid date, Defendants Does 11-20 were negligent in their entrustment of the vehicle being driven by HO WAN PANG. 31. | Onsaid date, Defendants Does 31-35 were negligent in their entrustment of the vehicle being driven by DAVID JONATHAN WAKSBERG. 32. Asa proximate result the negligence of Defendants, and each of them, Plaintiff MARY FINLEY has suffered significant general and special damages in amounts to be determined at trial. 33. WHEREFORE, Plaintiff MARY FINLEY prays for judgment against Defendants as set forth below. SECOND CAUSE OF ACTION Negligence By Plaintiff MARY FINLEY against Defendants UBER, and/or RASIER LLC and/or RAISER-CA LLC and/or Does 1-10 and 21-30 34. Plaintiffs hereby incorporate by reference, as though fully set forth herein, the contents of Paragraphs 1-33. 35. | Defendants UBER, and/or RASIER LLC and/or RAISER-CA LLC and/or Does 1-10 and 21-30 and DOES 1-10 were negligent in their development, implementation, and use of the APP in the provision of prearranged transportation services in such a manner so as to lead to DRIVERS, including HO WAN PANG, to be distracted and/or inattentive, while driving. Mf -6- COMPLAINT FOR DAMAGES AND DEMAND FOR TRIAL BY JURY P:\Wdocs\HBMAIN\03 124\00000\009 10600.DOCX-12815,Cm YN Dw FF wBWN = 5 12 36. Defendants UBER, and/or RASIER LLC and/or RAISER-CA LLC and/or Does 1-10 and 21-30 required its DRIVERS to use a smartphone APP and/or GPS that causes, and did cause, driver distraction and inattention to the roadway, such that it was the proximate cause of the subject accident and resulting personal injuries to Plaintiff MARY FINLEY. 37. Asa proximate result of the negligence of Defendant UBER, and/or RASIER LLC and/or RAISER-CA LLC and/or Does 1-10 and 21-30, and each of them, MARY FINLEY has suffered significant special and general damages in amounts to be determined at trial. 38. WHEREFORE, Plaintiff MARY FINLEY prays for judgment against Defendants as set forth below. THIRD CAUSE OF ACTION Negligent Hiring, Retention, Training and Supervision By Plaintiff MARY FINLEY against UBER, and/or RASIER LLC and/or RAISER-CA LLC and/or Does 1-10, Does21-30 and Does 36-40 39. Plaintiffs incorporate by reference as if fully set forth herein Paragraphs 1-38. 40. UBER, and/or RASIER LLC and/or RAISER-CA LLC and/or Does 1-10 and 21-30 owed the general public a duty of reasonable care in the hiring, training and supervision of its DRIVERS. 41. UBER, and/or RASIER LLC and/or RAISER-CA LLC and/or Does 1-10 and Does 21-30 did breach that duty of care in the hiring, retention, training and/or supervision of Defendant HO WAN PANG who was unfit to be a provider of transportation, and who was not adequately trained or supervised in his driving and/or use of the APP and the dangers inherent therein. UBER, and/or RASIER LLC and/or RAISER-CA LLC and/or Does 1-10 and Does 21-30 knew or should have known that Defendant HO WAN PANG would be using the APP in a manner which would distract -7- COMPLAINT FOR DAMAGES AND DEMAND FOR TRIAL BY JURY P.\Wdoes\HBMAIN\03 124\00000100910600.DOCX-12815Ce ND Hw F&F wBWN RNR YN NNN NK Ye Be ee eB ew ee ee eI nn KR ON =F SF Ce ARADAA BR HH = SF him and lead to a risk of the very type of danger and harm that occurred on September 10, 2014. 42. Does 36-40 owe the general public a duty of reasonable care in the hiring, training and supervision of their employees who drive on the public roads. 43. Does 36-40 did breach that duty of care in the hiring, retention, training and/or supervision of Defendant DAVID JOANTHAN WAKSBERG who was not adequately trained or supervised in his driving. Does 36-40 knew or should have known that Defendant DAVID JOANTHAN WAKSBERG would be negligently driving the motor vehicle in a way that could lead to a risk of the very type of danger and harm that occurred on September 10, 2014. 44. The breach of those duties was the proximate cause of harm to Plaintiff MARY FINLEY, causing her to suffer significant special and general damages in an amount to be proven at the time of trial. 45. WHEREFORE, Plaintiff MARY FINLEY prays for judgment against Defendants as set forth below. EOURTH CAUSE OF ACTION Loss of Consortium By Plaintiff SEAN FINLEY Against all Defendants 46. Plaintiffs hereby incorporate by reference, as though fully set forth herein, the contents of Paragraphs 1-45. 47. Because of the wrongful acts of Defendants, and each of them, Plaintiff SEAN FINLEY suffered a loss of consortium with his wife MARY FINLEY. 48. Asa proximate result of the acts of Defendants, and each of them, Plaintiff SEAN FINLEY suffered significant special and general damages in an amount to be determined at trial. 49. WHEREFORE, Plaintiff SEAN FINLEY prays for judgment against Defendants as set forth below. -8- COMPLAINT FOR DAMAGES AND DEMAND FOR TRIAL BY JURY P.AWdocs\HBMAIN\03 124\00000\0091 0600. DOCX-12815Cm YN Dm F&F WN So 11 PRAYER FOR RELIEF WHEREFORE, Plaintiffs pray for judgment against Defendants as follows: 1. For special and general damages as allowed by law; 2. For Prejudgment interest; 3. For costs of suit herein incurred; and 4. For such other and further relief as the court may deem proper. Dated: January a°ho1s HASSARD BONNINGTON LLP HASSARD BONNINGTON LLP 275 Battery Street, Suite 1600 San Francisco, California 94111 Telephone: (415) 288-9800 E-mail: jls@hassard.com -9- COMPLAINT FOR DAMAGES AND DEMAND FOR TRIAL BY JURY P:\Wdocs\HBMAIN\03 1241000001009 10600. DOCX-12815