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9 20 21 2 2 24 2s 26 27 28 John C. Taylor, State Bar No. 78389 Louanne Masry, State Bar No. 190559 TAYLOR & RING, LLP 1230 Rosecrans Avenue, Suite 360 ‘Manhattan Beach, California 90266 Telephone: (310) 209-4100 Facsimile: (310) 208-5052 Ronald D. Rosengarten, State Bar No. 128859 ROSENGARTEN & ASSOCIATES 28632 Roadside Drive, Suite 212 ‘Agoura Hills, California 91301 Telephone: (618) 225-5070 Facsimile: (818) 225-5077 ‘Attorneys for Plaintiffs SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT SALVADOR ALBERT CORADO, individually) CASE NO. ) and as Successor-in-Interest to MELYDA. } CORADO; and ALBERT J. CORADO, an individual, } ) COMPLAINT FOR DAMAGES Plaintifts, ) vs. ) j ) (Demand for Jury Trial) ) ) ) ) 2 CITY OF LOS ANGELES, a public entity; SINLEN TSE, an individual; SARAH WINANS, an individual; and DOES 1 through 100, inclusive. _ Defendants ) Plaintiffs, SALVADOR ALBERT CORADO, individually and as Successor-in-Interest to MELYDA CORRADO, and ALBERT J. CORADO, hereby allege and complain against Defendants, and each of them, as follows: ul i i COMPLAINT FOR DAMAGES 10 n 2 3 “4 1s 16 20 2 2 2 mM 2s 26 7 28 GENERAL ALLEGATIONS 1. At all relevant times herein, Plaintiff SALVADOR ALBERT CORADO, individually and as Successor-in-Interest to MELYDA CORADO was a resident of the State of California, County of Los Angeles. Plaintiff SALVADOR ALBERT CORADO, individually and as Successor-in-Interest to MELYDA CORADO, has complied with the provisions of Code of Civil Procedure §377.32, herewith, attached as Exhibit “A”, an affidavit as required by this Section, Plaintiffs SALVADOR ALBERT CORADO and ALBERT J. CORADO are the father and brother, respectively, of decedent MELYDA CORADO, who was unmarried and had no children at the time of her death, Prior to her iting death, decedent MELYDA CORADO, helped financially support her brother, Plaintiff ALBERT J. CORADO. 2. Plaintiffs are informed and believe, and thereon allege, that at all relevant times herein, Defendants CITY OF LOS ANGELES (hereinafter sometimes referred to as “CITY” or “LOS ANGELES ), and DOES I through 10, inclusive, are and at all times herein mentioned were, public entities and/or municipal corporations, duly organized and existing under and by virtue of the laws of the State of California. 3, Plaintiffs are informed and believe, and thereon allege, that at all relevant times herein, Defendants SINLEN TSE, SARAH WINANS, and DOES 11 through 70, inclusive, are and at all times herein mentioned were, officers, ranking officers, and/or other employees of Defendant LOS ANGELES and/or DOES 1 through 10, inclusive, and at all times mentioned herein were acting in the course and scope or their employment with Defendant LOS ANGELES and/or DOES | through 10 and are liable under the doctrine of respondent superior pursuant to Section 815.2 of the California Government Code. 4, PlaintiffS are informed and believe, and thereon allege, that at all relevant times herein, Defendants DOES 71 through 100, inclusive, are and at all times herein mentioned were, employees of Defendants LOS ANGELES and/or DOES 1 through 10, inclusive, and were responsible for implementing, promulgating, maintaining, sanctioning, condoning, and/or ratifying policies, procedures, practice, and/or customs, under which the other Defendants committed the wrongful acts hereinafter complained of. Plaintiffs are also informed and believe, and thereon allege, that at all times 2 COMPLAINT FOR DAMAGES 20 2 2 2 24 2s 26 7 28 herein mentioned, Defendants DOES 71 through 100, inclusive, were responsible for the administration of the Los Angeles Police Department and for selecting, hiring, training, and supervising persons jworking for and within the Los Angeles Police Department including, but not limited to, Defendants SINLEN TSE, SARAH WINANS, and DOES 11 through 70, inclus ve. 5. Defendants LOS ANGELES and DOES 1 through 10, inclusive, are liable for any and all wrongful acts hereinafter committed by any of the individual DOES 71 through 100, inclusive, pursuant to Section 815.2 of the California Government Code. 6. The true names, identities or capacities, whether individual, associate, corporate or otherwise, of Defendants DOES | through 100, inclusive, and each of them, are unknown to Plaintiffs who therefore sue said Defendants by such fictitious names. When the true names, identities or capacities of such fictitiously designated Defendants are ascertained, Plaintiffs will ask leave of Court to amend the complaint to assert the true names, identities, and capacities, together with the proper charging allegations. 7. Plaintiffs are informed and believe, and thereon allege, that each of the Defendants designated herein as a DOE is responsible, in some manner, for the events and happenings herein referred to, thereby proximately causing the injuries and damages to Plaintifi’ as hereinafter alleged. 8. Plaintiffs are informed and believe, and thereon allege, that at all times herein mentioned, Defendants, and each of them, were the agents, servants, employees, and joint venturers of cach other and of their co-Defendants, and were acting within the course and scope of their employment, agency or joint venture, and that all acts, conduct or omissions were subsequently ratified by the respective principals and the benefits thereof accepted by said principals. 9. Plaintiffs name Defendants herein, and each of them, because Plaintiffs are in doubt and do not know exactly from which of said Defendants Plaintiffs are entitled to redress and whether the injuries and damages to Plaintiffs herein alleged were caused by the combined negligence of all Defendants or by the concurrent or successive and separate negligence of Defendants, and/or one or more of them. For that reason, Plaintiffs name all of said Defendants and will ask for the determination of the liability of each and all of said Defendants in this action and to what extent and what 3 ‘COMPLAINT FOR DAMAGES