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: FILED Katrina Anne Foley, Bar No, 184921 Los Angeles Superior Court The Foley Group, PLC ; 1600 Dove Street, Suite 101 Abo SEP 23 2010 JOhD\n. Cuan, Cer ‘Newport Beach, California 92660 Oo; ‘Telephone: (949) 502-8800 vii Facsimile: (949) 502-8801 ‘Attorneys for Plaintift (Hon Micheal L. Steen KEVIN SCROGGINS , DEPUTY SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES 3 8 cong BESSA KEVIN SCROGGINS, COMPLAINT Plaintiff. 1, RACIAL DISCRIMINATION (GOVT CODE §§ 12940 ET SEQ); 2. RACE-BASED HARASSMENT (GOVT CODE §§ 12940 ET SEQ); 3, RETALIATION FOR MAKING PROTECTED COMPLAINTS (GOVT v. CITY OF PALOS VERDES ESTATES, a public entity; DAN DREILING, an aa CODE §§ 12940 ET SEQ); individual; MENJOU, an individual; and WS LURE 40 PREVENT DOES 1 though 50, inclusive, HARASSMENT AND/OR DISCRIMINATION (GOVT CODE §§ Defendants 12940 ET SEQ); . BREACH OF CONTRACT; 6. BREACH OF IMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING; 7. WRONGFUL TERMINATION IN VIOLATION OF PUBLIC POLICY; 8 MISREPRESENTATION OF MATERIAL FACTS; 9. VIOLATION OF THE POLICE. OFFICERS BILL OF RIGHTS (GOVT CODE §§ 3303 ET SEQ); 10. INVASION OF PRIVACY (CAL, 11. INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS 8 LAAN id 100 # LdT3024 DEMAND FOR JURYTRI on'sses HO ov/t2/60 srT0zarevHg9 SHARU/YTT BET9HHOE #39VO/LI9 ay at) we 1 ‘COMPLAINT FOR DAMAGES, 3 S GENERAL ALLEGATIONS 1, Atall times material to this Complaint, Plaintiff Kevin Scroggins (hereinafter “Plaintiff"), an ‘African-American male, was a resident of Los Angeles County, California. 2, Atal times material to this Complaint, Defendant Dan Dreiling (hereinafter “Dreiling”), is a Caucasian male, and a resident of Los Angeles County California. 3. Atall times material to this Complaint, Defendant Menjou (hereinafter “Menjou”), is a Caucasian male, and a resident of Los Angeles County Califomia, 4, Atall times material to this Complaint, Defendant City of Palos Verdes Estates is a California public entity (hereinafter “PVE”). 5. Plaintiff is informed and believes, and thereon alleges, that Defendants, and each of them, including} those designated herein as DOES | through 50, inclusive, are responsible in some manner for the occurrences and happenings, as well as such acts and omissions as are more fully alleged herein, and that Plaintiff's injuries, damages and losses, as alleged below, were and are the direct and proximate result of t actions or omissions of said Defendants. 6. Furthermore, each of the Defendants are sued as the principals, agents, partners, servants, employees, officers, directors, subsidi ies, corporate affiliates, alter egos, conspirators and co-conspirators, joint ventures of each of the rem ing Defendants. Each of the Defendants were acting within the course, scope and authority of such relationship, and with the knowledge, consent, approval or ratification of the remaining Defendants. 7. © Does I through 50 are sued under the fictitious names pursuant to the Code of Civil Procedure section 474, PlaintifVis informed and believes and on that basis alleges, that each Defendant sued under such fittious names isin some manner responsible for the wrongs and damages as alleged below, and in so acting was functioning as the agent, servant, partner and employee of the other Defendants and in doing, the acti 1s mentioned below was acting within the course and scope of his or her authority as such agent, servant, partner, and employee with the permission and consent of the other Defendants. 8. Plaintiff was hired by PVE as a Captain in its Police Department on or around March 18, 2008. Dreiling was PVE’s Chief of Police and was Plaintiff's direct supervisor. 9. Atornear the time Plaintiff was initially hired by PVE, Dreiling, a Caucasian male, began referring 2 ‘COMPLAINT FOR DAMAGES Bienes to Plaintiff, an African-American male, “Boy” and/or “Buddy Boy” both in one-on-one conversations and in group situations. Plaintiff complained to Dreiling that this was offensive to him, it humiliated and ‘embarrassed him, and that he felt that the use of these terms was discriminatory. Instead of ceasing to refer to Plaintiff as “Boy” or “Buddy Boy,” Dreiling told Plaintiff that he was on probation and could be terminated at any time. 10. Plaintiff then investigated a claim that another PVE police officer had stolen approximately $17,000} from the PVE Police Union. Plaintiff made a report to Dreiling regarding this alleged embezzlement of funds. Instead of seeking further investigation, Dreiling became critical of suspicious accounting, procedures by the PVE Police Union treasurer and stated that the Union should “never have had an ‘Armenian work as the treasurer.” Plaintiff complained to Dreiling that this was a racist and inflammatory statement. Dreiling simply stated, “I am not a racist Buddy Boy.” 11. Plaintiff was further subjected to racial discrimination when at a retirement party for a fellow officer, which he was required to attend, PVE through its employees and agents presented a slide show depicting a white officer wearing black makeup graphically simulating being hung by a rope. The white officer went so far as to tilt his head at an angle and hang his tongue out of his mouth. Plaintiff complained about this slide show that depicted the hanging of an blackened face man to Dreiling and was told to “get ‘over it” and to “not be so sensitive.” 12. AtaPVE Police Department retreat in La Quinta, California, Plaintiff was further subjected to racially discriminatory and harassing conduct as well as defamatory conduct by Dreiling and Menjou. At the retreat, Menjou accused Plaintiff of being iliterate and called him worthless in front of Dreiling and other police officers. Plaintiff complained about this conduct to Dreiling, but neither Dreiling nor PVE tod any type of corrective action against Menjou, Menjou’s racist and defamatory statements to Plaintiff came after Plaintiff had recommended Menjou's termination to Dreiling for engaging in vandalism, trespassing, and impersonating a police officer. Plaintiff had also complained to Dreiling that Menjou improperly wamed another police officer thatthe officer's daughter had complained about the officer violating a temporary restraining order. Again, neither PVE nor Dreiling took any type of corrective action against ‘Menjou and permitted him to continue espousing his racial hatred and defamatory statements against Plaintiff. 3 ‘COMPLAINT FOR DAMAGES 13. After the La Quinta, California retreat, Plaintiff leamed that the PVE Police Department with, Dreiling’s approval and/or participation was issuing Carrying Concealed Weapons (“CCW”) permits to ‘members of the Reserve police force without ensuring that the applicants first completed required courses and obtained certification. Plaintiff confronted Dreiling about this situation because he understood that the cal ymia Commission on Peace Officer's Standards and Training (“POST”) was to conduct an inspection af or around the same time. Plaintiff attended a Reserves meeting near this time to enforce the requirements} ‘and demanded uncertified in luals with CCW permits to obtain certification. Instead of praising Plaintiff, Dreiling became angry and told Plaintiff to stay out of it. POST did conduct its inspection and. found that CCW permits had been improperly issued. 14. Only after making the complaints above, and enduring the race-based discrimination and harassment at the hands of Dreiling and the race-based discrimination, harassment, and defamation at the hands of Menjou, Plaintiff was then given a negative evaluation. 15, Onor about November 3, 2008, Plaintiff was informed that he was being terminated as Captain of the PVE police force. He was told that the reasons for his termin: \n were tardiness and performance issues. However, Plaintiff believes and thereon alleges that this was merely pretext for race-based discrimination, harassment, and retaliati for making protected complaints. Indeed, the termination was disproportionate to how PVE treated Caucasian officers for tardiness and performance issues. 16. Furthermore, PVE claimed that it could terminate Plaintiff at any time’ because he was on probation. However, that is inaccurate based on PVE’s own Civil Service Rules and Regulations, Rule VIII, Section 8, which states in pertinent part that “persons appointed to permanent positions shall be on probation for a period of six months before an appointment or promotion is made complete...Otherwise, his promotion or retention in the service shall be equivalent toa final and absolute promotion or appointment.” 17. Plaintiff was hired on March 18, 2008, as of September 18, 2008 he had worked more than the requited six months and thereafter his retention by the PVE Police Department made him a non- probationary employee of the Department and his retention in the service was the equivalent of a final and absolute appointment. 18. The PVE Police Department also to maintain Plaintiff's personne! file properly. Indeed, certain documents were removed from Plaintiff's personnel file and certain documents were never placed in! 4 COMPLAINT FOR DAMAGES sen SBomrau au 12 13 14 1s 16 17 18 19 20 2 2 23 24 25 26 27 28 Plaintiff's personnel file. 19. Over one (1) year after Plaintiff had been wrongfully terminated from the PVE Police Department, the PVE Police Department sent notice to Plaintiff that it was finally correcting the issue. 20. Plaintiff is also informed and believes and thereon alleges that the PVE Police Department sent his confidential personnel file and/or other private personnel information to third-parties without Plaintiff's consent and without an order for a court. EXHAUSTION OF ADMINISTRATIVE REMEDIES AND GOVERNMENT TORT CLAIM REQUIREMENTS. 21. Onor around May 1, 2009, Plaintiff filed a Govemment Claim with the PVE describing the events, above. PVE never responded to Plaintiff’ claim, including failing to send him any type of correspondence that PVE rejected Plaintiff's claim. On or around _, Plaintiff filed another Goverment Claim with the! PVE regarding invasion of his privacy and confidence in his personnel file. Again, PVE never responded t Plaintiff's claim, including failing to send him any type of correspondence that PVE rejected Plaintiff's claim. 22. Onor around September 23, 2009, Plaintiff filed a complaint against PVE and Dreiling with California's Department of Fair Employment and Housing (“DFEH") alleging multiple violations of California's Fair Employment and Housing Act (“FEHA”). Plaintiffimmediately received a Right To Sue letter from the DFEH. FIRST CAUSE OF ACTION RACIAL DISCRIMINATION (GOVT CODE §§ 12940 ET SEQ) (Against Defendants PVE and DOES 1-50) 23, Plaimtiffrrealleges and incorporates herein by reference each of the allegations set forth above as if fully set forth herein. 24, Atall times herein mentioned, the FEHA, embodied in Goverment Code section 12940 was in full force and effect. This act prohibits discrimination, harassment, and retaliation based on race, as well as on other grounds. 25. Plaintiff believes and thereon alleges that Defendant PVE is a qualified employer subject to the 5 ‘COMPLAINT FOR DAMAGES, Carn aue 10 W 12 13 14 15 16 | 7 18 19 20 a 22 23 24 25 26 28 requirements of FEHA. 26. Plaintiff further believes and thereon alleges that Defendant PVE, and each of them, discriminated against him on the basis of his race. The discrimination included verbal harassment; unequal application of PVE policies that benefitted non-A\tican-American employees and disadvantaged Plaintiff; and, threats of termination. Despite Plaintiff's numerous complaints to Defendant PVE and its agents about the discriminatory conduct, no investigation was conducted or appropriate corrective action taken. Ultimately, Defendant PVE terminated Plaintif’s employment and replaced him with a non-A frican-American employee. 27. Asaresult of the discriminatory acts, Plaintiff suffered from stress, humiliation, embarrassment, loss of confidence and professional reputation, and anxiety, which has negatively impacted his physical and ‘emotional condition. 28. Plaintiff believes and thereon alleges that any claims of misconduct or performance issues as Defendant PVE’s basis for any disciplinary actions against Plaintiff are pretextual and meant to disguise the| discriminatory reasons for his termination. 29, Asadirect and proximate cause of the discrimination, Plaintiff has suffered and continues to suffer general, compensatory, and special damages, including lost wages and benefits, future loss of wages and benefits, and emotional distress and physical illness in an amount unknown, but according to proof at trial. 30. Moreover, Plaintiff is entitled to attomeys’ fees and costs for bringing suit alleging these violations. Plaintiff has incurred and continues to incur legal expenses and attorneys’ fees as a result of his FEHA claims against Defendants. Plaintiff is presently unaware of the precise amount of these expenses and fees, but seeks an award of attorneys’ fees and costs according to proof at trial. SECOND CAUSE OF ACTION RACE-BASED HARASSMENT (GOVT CODE §§ 12940 ET SEQ) (Against Defendants PVE, Dreiling, Menjou and DOES 1-50) 31. Plaintiff realleges and incorporates herein by reference each of the allegations set forth above as if fully set forth herein, 32. Atal times herein mentioned, the FEHA, embodied in Government Code section 12940 was in full 6 ‘COMPLAINT FOR DAMAGES ate force and effect. This act prohibits discrimination, harassment, and retaliation based on race, as well as on other grounds. 33. Plaintiff believes and thereon alleges that Defendant PVE, and each of them, are qualified ‘employers subject to the requirements of FEHA. 34. Plaintiff was consistently harassed based on his race by PVE, Dreiling and Menjou, and each of them, as described in detail above. 35, Asaresult of the harassment, Plaintiff suffered from stress, humiliation, embarrassment, loss of confidence and professional reputation, and anxiety, which has negatively impacted his physical and ‘emotional condition, 36. Plaintiff believes and thereon alleges that any claims of misconduct or performance issues as Defendants basis for any disciplinary actions against Plaintiff are pretextual and meant to disguise the discriminatory reasons for his termination and the harassment that he suffered. 37. Asadirect and proximate cause of the Defendants’, and each of them, racial harassment, Plaintiff has suffered and continues to suffer general, compensatory, and special damages, including lost wages and benefits, future loss of wages and benefits, and emotional distress and physical illness in an amount unknown, but according to proof at trial. ~ 38. Moreover, PlaintifTis entitled to attomeys’ fees and costs for bringing suit alleging these violations. Plaintiff. has incurred and continues to incur legal expenses and attomeys” fees as a result of his FEHA claims against Defendants. Plaintiffs presently unaware of the precise amount of these expenses and fees, but seeks an award of attomeys’ fees and costs according to proof at trial. ‘THIRD CAUSE OF ACTION RETALIATION FOR MAKING PROTECTED COMPLAINTS (GOVT CODE §§ 12940 ET SEQ) (Against Defendants PVE and DOES 1-50) 39, Plaintiffrealleges and incorporates herein by reference each of the allegations set forth above as if fully set forth herein, 40. Atall times herein mentioned, the FEHA, embodied in Goverment Code section 12940 was in full force and effect. This act prohibits discrimination, harassment, and retaliation based on race, as well as on 7 ‘COMPLAINT FOR DAMAGES a aun on other grounds. 41. Plaintiff believes and thereon alleges that Defendant PVE, and each of them, are qualified employers subject to the requirements of FEHA. 42, Atall times relevant, Plaintiff was able to and did perform the essential functions of his position. Plaintiff believes and thereon alleges that Defendant PVE, and each of them, retaliated against him because. he complained about Defendants’ discriminatory and harassing conduct regarding his race, the issuing of ‘CCW permits, and that certain employees of the PVE Police Department stole money from the Police Union. Despite Plaintiff's numerous complaints to Defendant PVE about the discriminatory and harassing conduct, the lack of oversight with the issuing of CCW permits, and the lack of oversight into the theft of Police Union monies, no investigation was conducted or appropriate corrective action taken. Ultimately, Defendant PVE terminated Plaintiff's employment. 43. Asa result of the retaliatory acts, Plaintiff suffered from stress, humiliation, embarrassment, loss of confidence and professional reputation, and anxiety, which has negatively impacted his physical and emotional condition. 44. Plaintiff believes and thereon alleges that any claims of misconduct or performance issues as Defendants basis for any disciplinary actions against Plaintiff are pretextual and meant to disguise the discriminatory reasons for his termination and the harassment that he suffered. 45. Asadirect and proximate cause of the Defendant PVE’s retaliatory conduct, Plaintiff has suffered and continues to suffer general, compensatory, and special damages, including lost wages and benefits, future loss of wages and benefits, and emotional distress and physical illness in an amount unknown, but according to proof at trial. 46. Moreover, Plaintiff is entitled to attorneys’ fees and costs for bringing suit alleging these violations. Plaintiff has incurred and continues to incur legal expenses and attorneys’ fees as a result of his FEHA claims against Defendants. Plaintiff is presently unaware of the precise amount of these expenses and fees, but secks an award of attomeys’ fees and costs according to proof at tral. we ut uy 8 ‘COMPLAINT FOR DAMAGES, Rw Nn Sweairanu u 1B 4 15 16 7 19 20 2 23 24 25 26 28 FOURTH CAUSE OF ACTION FAILURE TO PREVENT HARASSMENT AND/OR DISCRIMINATION (GOVT CODE §§ 12940 ET SEQ) (Against Defendants PVE and DOES 1-50) 47. Plaintiff realleges and incorporates herein by reference each of the allegations set forth above as if fully set forth herein. 48, Atal times herein mentioned, the FEHA, embodied in Government Code section 12940 was in full force and effect. This act requires that employers prevent discrimination and harassment in the workplace. 49, Plaintiff believes and thereon alleges that Defendant PVE, and each of them, are qualified employers subject to the requirements of FEHA. 50. _Atall times relevant, Plaintiff made a number complaints to his supervisors and other employees and agents of PVE that he was being discriminated against due to his race and that he was being harassed due to his race. Despite Plaintiff's numerous complaints to Defendant PVE, and each of them, about the discriminatory and harassing conduct, no invest on was conducted or appropriate corrective action taken, Ultimately, Defendant PVE terminated Plaintiff's employment. 51. Asa result of PVE’s failure to prevent racial discrimination and harassment, Plaintiff suffered from stress, humiliation, embarrassment, loss of confidence and professional reputation, and anxiety, which has negatively impacted his physical and emotional condition. 52, Plaintiff believes and thereon alleges that any claims of misconduct or performance issues as Defendants basis for any disciplinary actions against Plaintiff are pretextual and meant to disguise the discriminatory reasons for his termination and the harassment that he suffered. 53. Asa direct and proximate cause of the Defendant PVE"s failure to prevent racial discrimination and harassment, Plaintiff has suffered and continues to suffer general, compensatory, and special damages, including lost wages and benefits, future loss of wages and benefits, and emotional distress and physical illness in an amount unknown, but according to proof a trial. 54. Moreover, Plaintiffs entitled to attomeys’ fees and costs for bringing suit alleging these violations. Plaintiff has incurred and continues to incur legal expenses and attorneys’ fees as a result of his FEHA. claims against Defendants. Plaintiff is presently unaware of the precise amount of these expenses and fees, 2 ‘COMPLAINT FOR DAMAGES awn Sew nau ul B 4 15 16 7 18 19 20 21 2 24 25 26 27 28 but seeks an award of attomeys” fees and costs according to proof at trial. FIFTH CAUSE OF ACTION BREACH OF CONTRACT (Against Defendant PVE and DOES 1-50) 55. Plaintiff realleges and incorporates herein by reference each of the allegations set forth above as if fully set forth herein. 56. Atall times herein mentioned, Defendant PVE, and each of them, had in effect its Civil Service Rules and Regulations, Rule VIII, Section 8, which states in pertinent part that “persons appointed to permanent positions shall be on probation for a period of six months before an appointment or promotion is made complete... Otherwise, his promotion or retention in the service shall be equivalent to a final and absolute promotion or appointment. 57. Plaintif began his employment with PVE on March 18, 2008. Accordingly, as of September 18, 2008 he was no longer a probationary employee and had attained permanent retention and an absolute promotion to the position of Police Captain. 58. Defendant PVE’s Civil Service Rules formed a contract with its employees. 59, On November 3, 2008, Defendant PVE terminated Plaintiff without providing him with an appeal or an explanation as to why he was being terminated in violation of Defendant PVE’s Civil Service Rules. 60. Plaintiff;performed all obligations on his part required to be performed in accordance with the terms and conditions of the contract. 61. Asadirect and proximate result of Defendants” breach of contract, Plaintiff has suffered compensatory, incidental and consequential damages, including lost income and benefits, all in a sum according to proof at time of trial. Plaintiffs further entitled to pre-judgment interest atthe legal prev: rate. itt we 7 10 COMPLAINT FOR DAMAGES Ben 10 u 12 B 4 15 16 7 18 19 21 2 23 24 25 26 27 28 SIXTH CAUSE OF ACTION BREACH OF THE IMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING (Against Defendants PVE and DOES 1-50) 62. Plaintiff realleges and incorporates herein by reference each of the allegations set forth above as if fully set forth herein. 63. The provisions of the California Labor Code are implied by law into all employment agreements, including the employment agreement entered into between Plaintiff'and Defendants. Atal times herein mentioned, there existed an implied covenant of good faith and fair dealing incident to the implied and express employment contract by and between Plaintiff and Defendants that: i, Each party would act in good faith and deal fairly toward the other conceming, all matters relating to employment; Neither party would do anything to deprive the other party of the benefits of t agreement; ii, Neither party would take any action that would unfaisly prevent the other from obiaining the benefit of employment; and iv. Defendants would treat Plaintiff equally to employees who are similarly situated t Plaintiff 64.» On orabout November 3, 2008, Defendants, and each of them, intentionally and purposefully breached the implied covenant of good faith and fair dealing by terminating Plaintiff's employment, 65. As discussed above and incorporated herein, the bad faith conduct ofthe Defendants, and each of them, was designed to prevent and in fact prevented Plaintiff from carrying out his par of the employment agreement and destroyed and/or impaired Plaintf’s right to receive the benefits to which he was entitled pursuant to the agreement. 66. By acting and filing to act s alleged herein the Defendants violated both state and federal laws and wrongfully terminated Plaintiff, The Defendants breached the implied covenant of good faith and fair dealing. 67. Asadirect and proximate result of the Defendants’ breach ofthe implied covenant of good faith and fair dealing, Plaintiff has suffered compensatory, incidental and consequential damages, including lost pay a ‘COMPLAINT FOR DAMAGES q 3 Cw rae and benefits all in a sum according to proof at time of tril. Plaintiffis further entitled to pre-judgment interest atthe legal prevailing rate. SEVENTH CAUSE OF ACTI WRONGFUL TERMINATION IN VIOLATION OF PUBLIC POLICY (GOVERNMENT CODE § 12940 ET SEQ) (Against Defendants PVE and DOES 1-50) 68, Plaintiff realleges and incorporates herein by reference cach of the allegations set forth above as if fully set forth herein. 69. Iti the public policy of the State of California to prohibit wrongful termination in the workplace. This public policy is embodied in and tethered to various State and Federal Constitutional provisions, statutes, regulations, policies, and case aw. 70. Atall times relevant to this matter, California Constitution Antcle I, Section & was in full force and effect and binding on Defendants, and each of them. This Constitutional provision embodies fundamental, substantial, and well-established public policies of the State of California that prohibit employers from ‘wrongfully terminating employees in violation of fundamental policies, beneficial tothe public, and embodied in a statute, administrative regulation, or constitutional provision, 71. Inaddition, the FEHA, embodied in Government Code § 12940 was in full force and effect, prohibiting retaliation based on race as well as on other grounds. 72. Asset forth in the factual summary above, Plaintiff believes and thereon alleges that the Defendants, and each of them, violated Govemment Code section! 2940 by discriminating, harassing, and retaliating against him on the basis of his complaints and hs race. 73, Asa direct and proximate cause of the wrongful termination, Plaintiff has suffered and continues to suffer general, compensatory, and special damages, including lost wages and benefits, future loss of wages and benefits, and emotional and physica distress, stress, humiliation, embarrassment, loss of confidence and professional reputation, and anxiety in an amount unknown, but according to proof at tral 74, Moreover, Plaintiff is entitled to attomeys' fees and eosts for bringing suit alleging these viotations. Plaintiff has incurred and continues to incur legal expenses and attorneys” fees as a result of his claims 12 ‘COMPLAINT FOR DAMAGES: against the Defendants. Plaintiff is presently unaware of the precise amount of these expenses and fees, but secks an award of attorneys’ fees and costs according to proof at trial STH CAUSE OF AC MISREPRESENTATION OF MATERIAL FACTS, (Against Defendants PVE and DOES 1-50) 75, Plaintiff realleges and incorporates herein by reference each of the allegations set forth above as if fully set forth herein, 76, _Atall times herein mentioned, Defendant PVE, and each of them, had in effect its Civil Service Rules and Regulations, Rule VIII, Section 8 which states in pertinent part that “persons appointed to permanent positions shall be on probation for a period of six months before an appointment or promotion is made complete... Otherwise, his promotion or retention in the service shall be equivalent to a final and absolute promotion or appointment. 77. Plaintiff began his employment with Defendant PVE on March 18, 2008. Accordingly, as of September 18, 2008 he was no longer a probationary employee and had attained permanent retention and ar] absolute promotion to the position of Police Captain. 78. Plaintiff relied on the representations made in Defendant PVE’s Civil Service Rules. 79. Plaintiff performed all obligations on his part required to be performed in accordance with the terms and conditions of Defendant PVE’s Civil Service Rules. 80, The representations made by Defendant PVE were in fact false. Defendant PVE terminated Plaintiff on November 3, 2008 in violation of its own Civil Service Rules. 81. When Defendant PVE made these representations, they knew them to be false and made these representations with the intention to deceive and defraud Plaintiff and to induce Plaintiff to act in reliance ‘on these representations in the manner heretofore alleged, or with the expectation that the Plai iff would so| act. 82. Plaintiff, at the time these representations were made by Defendant PVE, and each of them, and at the time Plaintiff took the actions herein alleged, was ignorant of the falsity of Defendant PVE’s representations and believed them to be true. In reliance on these representations, Plaintiff was induced to 33, COMPLAINT FOR DAMAGES and did take the job of Police Captain with Defendant PVE. Had Plaintiff known the actual facts, he would not have taken such action, Plaintiff's reliance on Defendant PVE’s representations was justified because Defendant PVE is a municipality and must follow the civil service rules proscribed. 83. Asa proximate result of the fraudulent conduct of Defendant PVE as herein alleged, Plaintiff was deprived of other opportunities in the police officer profession. 84, Asadirect and proximate cause of the fraudulent conduct of Defendant PVE, Plaintiff suffered and continues to suffer general, compensatory, and special damages, including lost wages and benefits, future lost wages and benefits, humiliation, and damage to his professional reputation in an amount unknown, but according to proof at trial. NINTH CAUSE OF ACTION VIOLATION OF THE POLICE OFFICERS BILL OF RIGHTS (GOVT CODE §§ 3303 ET SEQ) (Against Defendants PVE and DOES 1-50) 85. Plaintiff realleges and incorporates herein by reference each of the allegations set forth above as if fully set forth herein. 86, Atal times herein mentioned, the California Police Officer’s Bill of Rights (“POBRA”), embodied in Government Code seetion 3303 was in full foree and effect. This act requires that municipalities and ‘governmental agencies employing police officers properly maintain the personnel files of its police officers 87, Plaintiff believes and thereon alleges that Defendant PVE, and each of them, are qualified employers subject to the requirements of POBRA. 88. Defendant PVE, and each of them, failed to properly maintain Plaintiff's personnel file by removing! certain documents and failing to insert certain documents into Plaintif?’s personnel file in a timely manner. Plaintiff's also informed and believes that in or about the Spring of 2010 Defendant PVE provided information about Plaintiff's private personnel matters to Attomey Nancy Mahan-Lamb and Gibeaut, Mahan & Briscoe, and their agents or representatives, in violation of Plaintiff's rights. 89. Asa proximate result of the fraudulent conduct of Defendant PVE as herein alleged, Plaintiff was deprived of other opportunities in the police officer profession. 1s ‘COMPLAINT FOR DAMAGES Bivens sie ities tet atten ul 12 13 14 16 7 18 19, 20 21 22 23 24 26 27 28 90. Asa direct and proximate cause of the fraudulent conduct of Defendant PVE, Plaintiff suffered and continues to suffer general, compensatory, and special damages, including lost wages and benefits, future lost wages and benefits, humiliation, and damage to his professional reputation in an amount unknown, but according to proof at trial. TENTH CAUSE OF ACTION INVASION OF PRIVACY ((CAL. CONSTITUTION AR (Against All Defendants and DOES 1-50) 91. Plaintiff realleges and incorporates herein by reference cach of the allegations set forth above as if fully set forth herein. 92. California Constitution Article I, Section I states: “All people are by nature free and independent and have inalienable rights. Among these are enjoying and defending life and liberty, acquiring, possessing, and protecting property, and pursuing and obtaining safety, happiness, and privacy.” 93. One of the principal mischiefs at which the privacy amendment is directed is the improper use of information properly obtained fora specific purpose, for example, the use ot for another purpose or the disclosure of it to some third party. 94. Defendant PVE, and each of them, engaged in such mischief by disseminating Plaintif?’s personnel file andlor private information in Plaintiff's personnel file to third partis without Plaintiff"s consent and ‘without an order from a court of law. 95, Asa proximate result ofthe publication of said information by Defendant PVE, and each of them, Plaintiff suffered a loss of reputation, shame, mortification, embarrassment, and humiliation, all to Plaintiff's damage in a sum within the jurisdiction of this Court and to be shown according to proof at the time of trial. uw is 1 15 ‘COMPLAINT FOR DAMAGES Bireeree ELEVENTH CAUSE OF ACTION INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS (Against All Defendants and DOES 1-50) 96. Plaintiff realleges and incorporates herein by reference each of the allegations set forth above as if fully set forth herein. 97. . Inperpetuating the discrimination, harassment, and retaliation against Plaintiff and other offensive conduct described herein, Defendants, and each of them, abused the special positions they held in relation t Plaintiff, Defendants acted with the knowledge that they could manipulate and damage Plainti?’s interest and well-being. 98. Atall times relevant, Plaintiff was able to and did perform the essential functions of his position. Plaintiff believes and thereon alleges that Defendants, and each of them, intended to and did cause Plaintiff to suffer from emotional distress because he made protected complaints that were never investigated, he ‘was discriminated against, harassed, defamed, retaliated against and ultimately wrongfully terminated 99. Asaresult of these acts, Plaintiff suffered from stress, humi ion, embarrassment, loss of confidence and professional reputation, and anxiety, whi negatively impacted his physical and emotional condition. 100. Through Defendants outrageous and unprivileged conduct as described herein and above, Defendants acted with the intent to cause, or with a reckless disregard for the probability of causing, Plaintiff to suffer humiliation, isolation, mental anguish, loss of job opportunities and reputation, and severe| physical and emotional distress. 101. To the extent that said certain agent(s) of the Defendants perpetrated retaliatory conduct, the Defendants authorized and ratified the conduct with the knowledge that Plaintiff's emotional and physical distress would thereby inerease, and with a wanton and reckless disregard of the deleterious consequences to Plaintiff. 102. Asa direct and proximate result of Defendants’ acts, Plaintiff suffered and continues to suffer general, compensatory, and special damages, including lost wages and benefits, future loss of wages and benefits, loss of career opportunities, prejudgment interest, consequential and incidental damages, plus tort damages including humiliation, isolation, emotional distress and physical injuries in an amount unknown, 16 ‘COMPLAINT FOR DAMAGES. awaw but according to proof at tral. 103. The above-recited actions of Defendant Dreiling and Menjou were done with intent, malice, fraud, or oppression, and in reckless disregard of the Plaintiff's rights under public policies of the State of California and anti-retaliation statutes embodied in California Government Code section 12940 et seq. and defamation statutes embodied in California Civil Code section 46 et seq. Plaintiff is thus entitled to and seeks punitive and exemplary damages from Defendants Dreiling and Menjou in an amount according to proof at trial. Plaintiffs further entitled to prejudgment interest atthe legal prevailing rate. WHEREFORE, Plaintiff prays for judgment as follows: 1. General and compensatory damages including all lost wages, in a sum according to proof at time of trial; 2. Consequential and incidental damages in a sum according to proof at time of trial; 3. Damages for mental and emotional distress in a sum according to proof at time of trial; 4, General and special damages in a sum according to proof at time of trial; 5. Penalties in a sum according to proof at time of trial; 6. Payment of Plaintiff's reasonable and actual attomey fees in a sum according to proof at time of trial; 7. For costs of suit herein incurred; 8. Pre-judgment interest at the legal prevailing rate; 9. Punitive and exemplary damages in a sum according to proof at time of trial; 10, Statutory penalties; and For such other and further relief as the Court deems just and proper. DEMAND FOR JURY Plaintiff hereby demands trial by jury in this action. Dated: A] 23 [40 FOLEY GROUP, PLC K] : ;CROGGINS for Plaintiff 7 COMPLAINT FOR DAMAGES a The Foley Group, PLC [Los Angeles Su Court 1600 Dove Street, Suite 101 Newnort Beach, CA 92660 reersone xo: 949-502-8800 rxsve: 949-502-8801 SEP 23 2010 vom fos’ PlantiT KEVIN SCROGGINS. [SUPERIOR COURT OF caLFoswA.counTr oF Los Angeles URI Canine, Vue srmeer aooress: 1] North Hill Street rau ness ev 2. oepury corravoze cove: Los Angeles 90012 snmensane: Stanley Mosk Courthouse - Central District CASE nas: SCROGGINS v. CITY OF PALOS VERDES ESTATES, etal. CIV CASE COVER SHEET Conplexcase Desinaion "GC AG GL IS Untimited Limited ine et TA eounter I soincer — L— (curt emandedis | Fied wih fest appearnco by detendat Guowece $25,000) _S25000or'ess)| (Cal Russ of Cour, 3.402) _|_ or Tems 1-5 below Must be comoleted (see nsirwcions on page 2) F Enack one Gox beiow the case type that best describes tis case: ‘auto Tor contact Protons Complex Ci Ligon Maas Cana a cfcntacnernty 06) (xs Rao eu rae 340060) Cred ma 6) (ses 0 caecion03) La] ating eution 8 ner PUPDIUD (PerecnjryPropery — [} Otereecions 0m) Consrcindte 1) Samagetarongi est Tor toc ove 981) sss tn sanesion 9 (I oerewesa on (E) secizsingason ce TE) Prove iota fsa Propery 1 mtormeraV ot (0) CE) ecies mapraciee (ts) EI tmnertcomainiverse ———) smarance coverage ears tsa tome TS oer preow a coders) Sa eet area se Non-PIPOMWD (Other) Ter [Emmons eviction (29) ‘types (41) (Ey pesness torn iness acca or) L_] Otero pone 28) Enorement ol Jusgnent CE cranes oy ntl Deter CT enters evga 20 SS petaraion 2) EW conmescale scatlaneous Civ Coma I reuse 1 resen2) Ly ecoen inetecul ope 9) DB doce. TI oer conti nsec above) 2) (Protest neience 5) Sk Review ee 1 omer eon rion a 29 TEP ase ree (05) [oT armen an norte overanee (21) Eager [oy Pewonte: rivaton enact) =} ore ptton nt apt abe) 3) erg etn 8) B winermanse 02) EZ omer emptoyment its) (Sores jcc eview 20) This case Lolis LZ] isnot complex under rule 3.400 of the California Rules of Cowt the case is complex, mark the factors requiring exceplonal judicial management a. Lc] Large numberof separately represented parties. [_] Large number of witnesses Lo] extensive maton practice raising aitfcut or novel e. [Coordination wth rated aeions pending in one oF more ‘courts issues that willbe time-consuming to resolve in other counties, sales, of counties, or ina federal court c. [J Substantial amount of documentary evidence 1. (J substantial postudgment judicial supervision Remedios sought (ck a that poy: aL ZI monetary &{—] renmenetary, declaratory ornunctve eet ¢ [Z]puntve 3 4, Number of causes of action (speciy) 5, Thiscase [Jis isnot _aclass action suit 6. If there are any known related cases, file and serve a notice of related case. fYo My use form CM-015,) Katrina Anne Foley. (Wie OFM ETAT OR ATORETIORPAANT NOTICE « Plainlitf must le this cover sheet with the fist paper fled in the action or prog Linder the Probate Code, Family Code, or Welfare and institutions Code). (Ca in sanctions. + File this cover sheet n addition to any cover sheet requited by local cout re. Trig case's complexunder rue 3400 et seq, ofthe Calforia Rules of Court, you must serve a copy ofthis cover sheet on all ‘other partes tothe acton or proceeding, « Unless this fe a ollectons case under rule 3.740 or @ complex case, tis cover sheet willbe used for statistical purposes ony, [cept smal cisims cases of cases filed ‘of Gourt, ue 3.220) Faiure to fle may result aes CIVIL CASE COVER SHEET SRE Sae eens ees en : INSTRUCTIONS ON HOW TO COMPLETE THE COVER SHEET apae To Plaintits and’ Others Filing First Papers. ti you are fling a fst paper (for example, a complain in a cv case, you must Te Pits ard ae along with your fst paper, tho Civl Case Cover Shoet contained on page 1. This information wil be used o compile Siegtos about the ypes and numbers of cases fied. You must compete ems 1 trough 6 onthe sheet. tn em 1, you must check Sea Doctor me cave ype iat best describes the case. the case fis both e general and a more speci ype of case listed in tom 3, crear he mace pec one Ite case has multiple causes cf acon, check the box Dat bet iceates te primary cause of action. Sree oun completing the shoot examples of ho cases tht elong under each case type in tem 1 are provided below, A cover Theat met be ted oy wih your il pape, Failure to fea cover sheet nth the fst paper fled a ci case may subject party. Wecaunsel or tote soncsons under rues 250 and 3.220 of the Calfomia Rules of Court. To Parties in Rule 3740 Collections Cases. A “colectons case" under culo 3.740 ia defined as an action for recovery af monoy Tearin'a sun Sted toe certain thts nol more than $25,000 exclisive of inierest and attomey's fees, arising from a transaction in cee aout. senfees, of money was acquired on Ged. Acolecione case does nl inde an action seeing the folowing: (1) ort Ynmages” 2) puntve damages, (2) recovery of res! propery, (8) recovery of personal property, 0” (5) @ projudgmert wit of sere teein "he ertiteation of a case 2s a fle 3740 colectons case on thie form moans that wil Be exempt fom the goneal are cuivice requrements and cage manegoment rules, uiess a delensant flee responive pleading, A rule 3.740 colectons {ase wi bo aubject to tne roguoments fo service and abaiing a judgment in ule 3740 ‘Jo Parties in Complex Cases. In complex cases only, parties must as use the Ci! Case Covor Shoot to designate whether the se.e ie Sonplon a olan booves ths cace fs complox under rule 3400 ofthe Calforva Rules of Coun this must be indicat by CER pleang to appropriate boxes in emns 1 and 2 Ifa pani designates a case a8 comple, the cover sheet must be served withthe Sere an al partes te re acon. A defendant may fle and serve no later than the time offs frst appearance a joiner in the Sirois ces gnaton a counter cesigation that the case isnot complex, o,f the paint has made no desgnaton, a designation tat ‘the case is complex. CASE TYPES AND EXAMPLES stort Contact, Frovslonay Comoe Cv Ligation (at "ASS 2)-Pexoal iyuyPrepey Tr of oruotvrety (6 Roc of Cour en 340040) arogetvorhs exh ‘Suachaitentone seated Regan ©) eaten gs Sacto et el eer Concon Bat (1) Mat Oe ews te) leery loss To (40 Sonat camn beste contacienahy Seat eter sae etn 3) cet eee em ‘tl ro oreo) Storer tte te 3 resese ay velgteanen Co veo rege a cnn ruPOMD (Personal iar! eg rm povisonay complex ono (rene citer 80d ct Conracitaary se tpeteee cco Prope coment eat carga 5, sony one. pen enorcanseaaserenn asses (09 craig nna 20 bees Popa Oxmage cen Coe Ste Pare "Sie a sgran Outot ‘Asbestos Personal uy ther Promssory NoterCotedtons Cou) ‘Wrongful Death Case Confession of Judgment (non Pree ay tases Imran vege (rt proioaly eerete aon) dc Ly rt ses oma 0 sits Sat Suapret osc apres fs Scan Sansa ue Avara Wea ops Gites Coveaae inturpasad ‘Ghyicare Sageors oer caniecean velianCeatclaret yo one oes etn ore uch aud ‘haps Capea Tote ‘lara Sher Coned Depue ote ecard Other FifPOMWD (23) Roal Property Case scr bay 09-lb Papel Sonatanerse acaapeoes vt Compt woh orsoeranont een inert! oa un POMO worgenelon Oe Sars ee pcres ‘opr enn sn) Cine Rea Povey fea, que te 6 oor nena niin Naot oresoan ited tapry can ele ry ete Dates werreeen irene Reset Oy on ogg eon Monae! osunern Emotional Distress: Other Real Property (not eminent eee cover iPOD as Rol ee eo Ot Comers Conlin: on-puPonND (thon Tort Sots omen fontatracampen ness Tei Busnes Unintt Onto calgon sh Conner) ieniothorcoms com (of ran, reno (2 Mcatanous Ci Patton fae ae notch rg (8 case ioe ena eee conn oa cee tom ohare, Seer cwutaten (ese tb) ‘eas Comme ocr) (Fete (ot encod vm suc Roe wo) Ft 8 ay fever 09 Gerace feel zy (8) Petter ton Aware) ue Professional Negigence 25) Wi ot Mandate 02) See toon hagas i ae Marsares eee er Sie Pec apace Vicente on Ued Caot Secon ‘ro necea eh ‘ave watt Ce eee eet NamPHPOMO Tet 8) \Wi-Other Limited Court Case ten fr rombat mocyecnt newer ne it Petien ite Teminaton (6) oa ete ‘ner Employment 18) Tava ct Heath er Order oso Aopea- abo Cena Ses eee CIVIL CASE COVER SHEET vane Sorte cma CEE FESS SCROGGINS v. CITY OF PALOS VERDES ESTATES, et al. CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION {CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION) ‘This form is required pursuant to LASC Local Rule 2.0 in all new civil case filings in the Los Angeles Superior Court. TemT, Check the fypes of hearing and fil in the estimated length of hearing expected for this case: auav tri [7] ves ciassaction? Ives umrreo case? Clves tive estimareo For TRIAL7-20_O HOURS/@) DAYS Item Il. Select the correct district and courthouse location (4 steps — If you checked ‘Limited Case", skip to item Ill, Pg. 4): Step 1: After frst 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 cout location choice that applies tothe type of action you have checked. For any exception tothe court location, see Los Angeles Superior Court Local Rule 2.0. Applicable Reasons for Choosing Courthouse Location (see Column C below) 1. Gass Actions mabe Rafe County Comraure, Coal Dara. Losatan of prope orpamaneny garage venice. PERE Ea Gccm memo, | te eee ta & toes oe exces, & CBeaton were ang o'mere a spares resse 5 Gencsnt esdes Yo. E8EBtSn ot aborCommasoner Ohisn ‘Step 4: Fillin the information requested on page 4 in tem Il; complete Item IV._ Sign the dectaration. A B c Civ case Cover Shot | Type of Action ‘Appizabi Reasons - eo etgon We (hock oaty one) Boe Stop 3 Above : ‘Ato @2) 11 A7100. Motor Vehicle - Persona InjuryProperty DamagetWrongtilDeeth | s_24, & Tussurea trate) | 97110 Personal nixyPropeny amapenirongt Dea Unrsuea oto! | 1.2. 4 CAsoro Asbesos Property Damage 2 ge | Asbestos 0 A724 Asbestos -Persona inkeytongh Death qi é & | Prom uscity(2) | Cy arz0 erat Labily (rt asbestos once) $.2,9.408 a os 3 otpacice 4s) | 2 -A7210. Mecic! Mapraten- Prysicans & Sugeors 12 = G_A7240 Cover Professions Heath Care Nabracoe 12d £ TI A260 Prenises Listy (9 pond fat ees 8 one D_A7220_ tntenionet Body triuryPreperty DamageMitonatl Death (0. ee | Pesaran astaut vandarsm, ec) & roperty Damege 124 & | Woreurocan | © ar270 terion ntcon of Enotona Daves: es (a) 7220 citer Persona nur Property OamageWronghd Death aaa 1 |_Busness Ton (7) 8029 Other CommerciaBusiness Tox (not raufreach of contract) 1.2.3 B | cmon | c atoos cnt eonadecrmnain 1.2.9, 3 preety C_AB010 Defamation (standesibes) 1.2.3. z Fraud (16) D A6013 Fraud {no contract) 1.2.3. z 8 av 108 (Rev ove CIVIL CASE COVER SHEET ADDENDUM WASC, rie 20 LASC Approves 03-04 AND STATEMENT OF LOCATION Page 1 of 4 ares, Nos Personal Injury/Property Damage! Wrongful Death Tort (Cont'd) Employment Contract & z 5 5 [ronrme EEN SCROGGINS v. CITY OP PALOS VERDES ESTATES, et al ch ome B c Ne ee oe ‘Typo of Action Applicable Reasons ‘Sheet Catogory No. (Cheek only one) “S00 Stop 3 Above sional 1.2.3 Pres Cl 6017 Lege Malpractice ci 1D A6050 Cther Professions! Malpractice (not mecical ortega ah otner 28) 1B _Asc25 cine: Nom Personal riuryiProperty Damage tot 23 \roratemiaton | C).pa087 wong Terinton 4.2.8 ter Empevment |g) aecz4 oer eployet Compt Cate 1.208 _Ast09 Labor Commissioner Appeats Ft | ‘reach of Contry | C2. AS004 Breech of RentatLease Contact (ot Unlowil Detainer or wrong eviction) | 2,5, worery D A6008 ContaciWaranty Breach Seles Paint (no fraudnegigence) 26 (notinsurance) C6018 Negtgent Breach of ContraczWarany (no raud) Heit 48028 Other Breach of ContractNarraty (nt rau or negligence) qi rina Asoc cotectons Case-Seter Paint 2.5.6 oy D As012 oer Promissory Nee/Callectons Case Fy rnswance Gowerpe | Cl ago1s eran Coverage ot comsien) 1.2.5.8 ‘ner Contact 5000 Conractuat Fraud aaaie @ GAb031 Torus tneterence 12.208 1D A6027 omer Conract Dipute(not breaetinsrancefaudinesigence) 442.308 Hashemi C1 A7300 Eminent DomeivCendemnation Number of parce 2 conderrnation (14) east Cl Asoz3. Wrongtu Evicton Case 2.6. comer Rea Prepeny | 0 M018 Mongage Fredeexe 2.6. (23) CI Asos2 ovat Tite a 1D AG060 oter Real Propey (ot eminent domain, landordterat, reiosure) ae aunts oesnes | Cy gec21 Unnkd Deane Commer (a sor wrong vos) 2.6 ‘nda Deter rer Residential er wrongh ev rtp Dees 86020 Unawl Detar Resdentl (at hugs or wrongh evion) 2.6. ‘Uniantl Detaine- Tay eee ay Dea Gas Detsrer On 2.6. "asset Foretue (05) | Cl AS106 Asset Fri Case ae Potton re oivaton | C1 S115. Petitonte CompelConfrmvvacate Abiveton 2.8. ew 709 Re. 07107) CIVIL CASE COVER SHEET ADDENDUM (ASG, rie 20 LASC Approved 03.04 AND STATEMENT OF LOCATION Page 201 4 SCROGGINS v. CITY OF PALOS VERDES ESTATES, et al 3 A 8 c |_| crease cover shoot “Typ0 of Action ‘Appleablo Roasons é atogory No. {Cheek only no) 300 Stop 3 Above 3 TE ABIGY Wit. Admausvathe Mandamus a 3 Wt of Mandate i Asts2 wht- Mandamus on Liited Court Case Matter - 2 7 1 ABiS3_Wt-Cter iio Cour Cate Review : | Onetaicarrevew | psiso. ner kt ii Revow 2.8 Ans Trade i aa 1 een A600 AntirusTrade Regu 2.8 3 Construction Defect (10) G 88007 Construction defect 1.2.3. 3 és 1 Astos. Cine tg Mase Trt nae a B | secures usigation 26) Cl A605 Secunties Litgation Case ae 55 Toxie Tor a a 1 3 Environmental (30) 2 ete Geaoaee a Insurance Coverage insurance Cover tion (complex case Claims fom Complex G Aa014 ‘Insurance CoverageSubrogation ont) 1.2.5.8 ‘case 1 ABtAY Sister Stata Judgment 2.9. ee Enforcement (1D As160 anstrat of dudgment 2.6 He of dont 1 6107 onfesson of wsgment roncamesse rao) a gS a 1D As140 Adminstratve Agency Award (nl unpadtaxes) ae 33 I 0116: Pettion'Certicate fr Enty of Judgment on Unpaid Tax ae as D As112 Otner Enforcement of Judgment Case a RICO. D A6088.Racksteoing (RICO) Case 1.2.8 £ 1 A030 Declaratory Relief Onty 1.2.8 S| omercompiains 1 8040 injunctive Retief Only (nt domestioharassmert) 2.8 Bi | oes reeree 1 sors Omer Commercial Complaint Case (nor trdnon-compies) 4.208 eI 2) 1 Aa0c0 ore civ Complaint (nortrtinon complex) aia Poegatie Cmperaton |” () ABI9 Pattern are Cate Govan ate 208 (Governanent T Asi24 Cia Harassment 2.8.8 G A0125. worplace Harassment sia 1 size eiderDependent Aout Abuse Case sas other Petions ieee naa) 1 6190 Election Contest - fi 0 Asi10 Petton for Change of Name oe i 1D 6170 Petton or Rete fom Late Clim Low cae 1 As100 Otter Gil Peon el Rew 108 (Rev. ov07) CIVIL CASE COVER SHEET ADDENDUM LASG, rule 20 LASC Approved 08-04 AND STATEMENT OF LOCATION Page 3 of 4 aT TALE CASE MBER SCROGGTNS v. CITY OF PALOS VERDES ESTATES, et al. Item Ill, Statement of Location: Enter the address of the accident, party's residence or place of business, performance, or ther circumstance indicated in tem, Step 3.0n Page 1, asthe proper reason for filing in the cour location you selected, TREASON: GHECK THE NUMBER UNDER COLUMN G 5 WHICH APPLIES IN THIS CASE Keingeagins 1.02. 83,04. O8. 06. 07. 08. C9. O10. Los Argeles, A Gz “los Andes |A | qo Item IV. Declaration of Assignmant: | declare under penaly of perjury under the laws ofthe State of California thatthe foregoing is true gpd correct and that he above-entitled mattor is property fled for assignment tothe courthouse in the ¢ entra District of the Los Angeles Superior Court (Code Civ. Proc., § 392 et seq, and LASC Local Rule 2.0, subs, (0) (¢) and (4), vated: “Y> Zo PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY COMMENCE YOUR NEW COURT CASE: Original Complaint or Petition, If fling a Complaint, a completed Summons form for issuance by the Clerk Civil Case Cover Sheet form CM-010. : Complete Addendum to Civil Case Cover Sheet form LACIV 109 (Rev. 01/07), LASC Approved 03-04. ing fee, unless fees have been waived. Payment in full of the ‘Signed order appointing the Guardian ad Litem, JC form FL-935, ifthe plaintiff or petitioner is a minor “under 18 years of age, orf required by Cour. 7. Additionai 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. 01707) CIVIL CASE COVER SHEET ADDENDUM TASC, rule 20 LASC Approved 08-04 AND STATEMENT OF LOCATION Page 4 of 4