SUPERIOR COURT OF CALIFORNIA ons Seaaeenrt COUNTY OF LOS ANGELES | COURTHOUSE ADORESS: Norwalk Courthouse een 12720 Norwalk Blvd., Norwalk, CA 90650 iyof Los Angeles: | 06/30/2022 | NOTICE OF CASE ASSIGNMENT ‘Shes Cate, Erte Oem / Get Cou by E.Chanes —_ paputy UNLIMITED CIVIL CASE aaa SE ROBER Your case is assigned for all purposes to the judicial officer indicated below. | 22NWCV00539 iS FORM IS TO BE SERVED WITH TI ASSIGNED JUDGE DEPT | ROOM ___ASSIGNED JUDGE DEPT [ROOM Y | Margaret Miller Bernal F Given to the PlaintiffiCross-Complainant/Attomey of Record Sherri R. Carter, Executive Officer / Clerk of Court on, 07/01/2022 ‘Daisy LACIY 190 (Rev 6/18) NOTICE OF CASE ASSIGNMENT ~ UNLIMITED CIVIL CASE ASC Approved 05/08 By E. Chanes » Deputy ClerkING UNI TED CIVIL CASES ‘The following critical provisions of the California Rules of Court, Title 3, Division 7, as applicable in the Superior Court, are summarized for your assistance. APPLICATION ‘The Division 7 Rules were effective January 1, 2007. They apply to all general civil cases. V ‘The Division 7 Rules shall have priority over all other Local Rules to the extent the others are inconsistent, CHALLENGE TO ASSIGNED JUDGE ‘A challenge under Code of Civil Procedure Section 170.6 must be made within 15 days after notice of assignment for all purposes to a judge, or if a party has not yet appeared, within 15 days of the first appearance, ‘TIME STANDARDS ‘Cases assigned to the Independent Calendaring Courts will be subject to processing under the following time standards: COMPLAINTS Al complaints shall be served within 60 days of filing and proof of service shall be filed within 90 days. CROSS-COMPLAINTS Without leave of court first being obtained, no cross-complaint may be filed by any party after their answer is filed. Cross- ‘complaints shall be served within 30 days of the filing date and a proof of service filed within 60 days of the filing date. STATUS CONFERENCE A status conference will be scheduled by the assigned Independent Calendar Judge no later than 270 days after the filing of the complaint. Counsel must be fully prepared to discuss the following issues: alternative dispute resolution, bifurcation, settlement, trial date, and expert witnesses, EINAL STATUS CONFERENCE ‘The Court will require the parties to attend a final status conference not more than 10 days before the scheduled trial date. All partes shall have motions in limine, bifurcation motions, statements of major evidentiary issues, dispositive motions, requested form jury instructions, special jury instructions, and special jury verdicts timely filed and served prior to the conference. These matters may be heard and resolved at this conference. At least five days before this conference, counsel must also have exchanged lists of exhibits and witnesses, and have submitted tothe court a bref statement ofthe case to be read tothe jury panel as required by Chapter Three of the Los Angeles Superior Court Rules. SANCTIONS ‘The court will impose appropriate sanctions for the failure or refusal to comply with Chapter Three Rules, orders made by the Court, and time standards or deadlines established by the Court or by the Chapter Three Rules. Such sanctions may be on a party, cr if appropriate, on counsel for a party. ‘This is not a complete delineation of the Division 7 or Chapter Three Rules, and adherence only to the above provisions is therefore not a guarantee against the imposition of sanctions under Trial Court Delay Reduction, Careful reading and ‘compliance with the actual Chapter Rules is imperative. Class Actions Pursuant to Local Rule 2.3, all class actions shall be filed at the Stanley Mosk Courthouse and are randomly assigned to complex Jjudge at the designated complex courthouse. If the case is found not to be a class action it will be returned to an Independent Calendar Courtroom for all purposes. *Provisionally Complex Cases Cases filed as provisionally complex are initially assigned to the Supervising Judge of complex litigation for determination of complex status. If the case is deemed to be complex within the meaning of California Rules of Court 3.400 et seq., it will be randomly assigned to a complex judge at the designated complex courthouse. If the case is found not to be complex, it will be returned to an Independent Calendar Courtroom forall purposes. Lacty 190 (Rev 6118) NOTICE OF CASE ASSIGNMENT - UNLIMITED CIVIL CASE LASC Approved 05/06‘22NWCVO0539 SUMMONS (CITACION JUDICIAL) NOTICE TO DEFENDANT: (AVISO AL DEMANDADO) CENTRO MUNDIAL; An Unknown Entity; PAULO ORTEGA aka PABLO ORTEGA; An individual; and DOES 1 through 50, inclusive. YOU ARE BEING SUED BY PLAINTIFF: (LO ESTA DEMANDANDO EL DEMANDANTE): RUFINO LAUREANO, An individual HIOTIGET You have been sued. The court may decide against you without your boing heard unless yOu respond witin GO Gays, Read the Ffonnation below. You have 30 CALENDAR DAYS after this summons and legal papers are served on yout flea written response at his court and have @ copy ‘served on the paint. Alter or phone cal wil not protect you. Your writen response must be In proper egal form if you wart he cout t hear your ‘ase. There may be a court form that you can use for your response. You can tnd these court forms and more information atthe Calfomia Ci Online Se-Help Center (www. courtnfo.ca. goviselele), your count law Ibray, or te courthouse nearest you If you cannot pay te ng fe ‘he court clerk fora fee waiver form. you do nc fle Your responee on tine, you ray le the case by default, and your wages, money, and property ‘maybe taken without further warming fom the court. “There are ther legal requizements. You may want o call an atomey right away. you de not know sn attomey, you may want to call an atomey ‘feral service. if you canna afford an atime, you may be elige or ree logal services from a nongvoft legal sera program. You ca locale ‘these nonprofit groupe atthe Calforia Logal Services Web eta (www awhelpealfori. or), ia Caltomnia Cours Online Sel alp Center (enn courtnfe.c3.gourslMelp), or by contacting your lees cout or county bar association, NOTE: The court has a statutory lon for waived feos and Costs on any setferert or arbivation award of $10,000 or more ina Givi case. The courts len must be paid belore the cour wil dsmiss the case, FAVISO! Le han demandada. Sino respande dentro de 30 clas, i carte puede decir an su conte sn escuchar Su version. Lea la informacian Contnacion Tiane 30 DIAS DE CALENDARIO después 60 quo le entroguen esta ctclén y papeles legales pare presentar una respuesta por escito en esta corte y hacer que 6e enregue una copie a! demandante. Una carta 0 una larnade felfonica noo protegen. Su resouesta por eget tare que estar fn formato logo correcto s desea que procesen su caso an la corte. Es posble que haya un formutaro que usted puede usar para su respuesta. Buade encontrar estes lormularoe 3 la corey mas informacion onal Conta de Ayuda 3 1 Corts do Calla naw scare. gov), 6” la eiblotecs de lees de su condedo 0 an lo corte que lo quade mas cerca. Sino puede pagar le cvsta de presentocén, pide al secretar do la cote |9u8 le da un formulorie de exencisn de pogo de cuolas. Sino presenta su respuesta a Lemp, puede perder el caso por houmplmients la core le oer gutter su sueldo,ainaro y bianes sin mas advertencia, ‘Hay ous requis logates. Es recomendable que lame a un sbogado inmediatements, Sino conoce sun abogade, puede lamar a un servicio de remisisn a sbogedos. Sino puede pagar 2 un abogadb, es posible que cumpla con los requisites para obtener servicios legals gratulos de un de servos legals sin thes de luca. Puade encontrar esios grupos si fines de uso en a! silo web do Calflomia Legal Services, ‘how lawhelpeatomia.org), en el Centro de Ayuda de las Corlos de Calfomia, (ww.cusare.ca,90¥) 0 poniandaee an contacto con a cote oe! ‘Galop do abogados locales. AVISO: Por ey, Io corte Lene derecho a relemsr le cuoias los costae exenfos por Impaner un gravemen sobre (aguir recuseracn de $10,000 0 mas de valor recibse mediante un severdo 0 una concesion de arblrae en un caso de derecho ou. Tene qUe ‘Eagar el gravamen dela corte ates de que la corte pueda desachar ol caso. ‘The name and address ofthe courts senaeee (Einombre aren conto; Cououse “S2Nivwcy 00539 12720 Norwalk Blvd, Norwalk, CA. 90650, ‘The name, address, and telephone number of plaintiff's attomey. or plant without an attorney, is (Elnombre, la dreccién y el nimero de leléfono del abogado dei demendante, © del demandante que no tiane abogedo, 2s): Law Office of, Walter P, Saavedra, 6443 Florence Ave, Suite A, Bell Gardens CA 90201, Tel. 562-746-0208 DATE:DG!30/2022 shen, carer Execute Ofer ut Clark, by po red Sher Cater Eectve oer CaotCout CME DY E. Chanes ee [For proof of service of this summons, use Proof of Service of Summons (form POS-010).) (Para prusbe de onto de est cation use ol ornare Proat of Service of Summons, (POS-010)) NOTICE TO THE PERSON SERVED: Vou ae seved 1 La] os an incu detercare 2. [] 8s the person sued under the fictitious name of (specify): 3, [1 onbehatt of (speci): under: I ccP 416.10 (corporation) cP 41660 (minor) cer 416.20 (etunet corporation) ECP 416.70 (conserva) ) ccP 416.40 (association or partnership) [=] CCP 416,90 (euthorized person) otter (spect: 4. [1 by personal delivery on (date): ae "Satan cates ‘SUMMONS aon i 088 Sis Sy, er:ee ee Ty SND enOE NOUEE OF Mainomnia. Mounly of S08 Angeles on OG S0Z0 RR ANOE HIRE" R. Carter, Executive OfficeriClerk of Court, by 6. Chanes.De [aT TORREY oR PARTY vaTNOUT ATTORNEY ann Sa Barman and aoa Walter P. Saavedra Es., SBN: 311571 LAW OFFICE OF WALTER SAAVEDRA £489 Florence Ave. Suite A, Bol Gardens CA 90201 ‘TELEPHONE Nos $62-746-0208 axno: 562-746-0206 srromey Fon um Plaintiff _RUFINO LAUREANO, An individual SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES STREETACORESS:- 12720 Norwalk Blvd, wane AooRese: Some peeryeped Norwalk CA 90680 sencuas_ Norval Courhouse (CASE NAME: RUFINO LAUREANO VS. CENTRO MUNDIAL. ETAL pai CASE COVER SHEET ‘Complex Case Designation SE NOMBER United Limited eee oe Leia counter 2 Joinder demanded demanded is Filed with first appearance by defendant | “° exceeds $25,000) _ $25,000 or less) (Cal. Rules of Cour, rule 3.402) err. ‘tems 7-6 below must be completed (eee instructions on page 2). [i- Check one box below forthe case type that best describes ths case: Auto Tort Sontract ‘Auto (22) ‘Breach of corractwarrenty (06) Uninsured motorist 8) Rue 3.70 cotectons (08) Provisionaly Complex CWI Litigation (Gal. Rules of Court, rules 3.400-3.403) AniinstTrade regulation (03) ‘Other PLPOIWD (Personal Injury/Property ‘Other collections (09) TE) construction detect (10) DamagelWrongful Death) Tort Insurance coverage (18) TJ] Mass tort 40) ‘Asbasios (4) (Other contract (37) EJ securities itigation (28) Pry pero ( emvronmentaTaxc tr (30) Medical mapracoe (8) Eminent domanivese insurance psec tom Cie Pips Sraenceaeas 1 pemecrsereecaestte sam -PUPOIWD (Other) Tort ‘Wrongful eviction (33) types (41) Busnes ora business pracice (07) L_] Other eal property (28) Enforcement of Judament TE) cine eights (08) lawful Detainer Enforcement of judgment (20) Defamation (13) ‘Commerc 31) Miscellaneous Civil Complaint Fraud (16) Residential (32) FJ rico a7 Inxetectut propery (18) Drags (38) Other complaint (ot specified above) (42) Protessions negigence (25) {udiciat Review Miscellaneous Civil Petition (ther non-PUPDNVD to (35) ‘Asst froture (05) Partnership and carporate governance (21) Employment 7) otter petition (not speciied above) (42) ‘Wrongful termination (36) Peto re: erraton award (11) 1 wt of mandate (02) TE) otter empoyment (15) TI otra jc revi (9) Z Triscase [Tis LxTisnot — complex under rule 3.400 of the California Rules of Court. I the case Is complex, mark the factors requiring exceptional judicial management: 2. C2) Large number of separately represented parties d.[[_] Large number of witnesses ». [1] Extensive motion practice raising difficult or novel @.[_] Coordination with related actions pending in one or more courts ‘saves that willbe time-coneuming o resdve in other counties, states, or counties, or in a federal court c. [2] Substantial amount of documentary evidence 1. 21 substantia! postiudgment judicial supervision Remedies sought (check all that apply): a.[X] monetary b.[—] nonmonetary; declaratory or injunctive Number of causes of action (specify): See atach document Form MC.025 (a) triscase lis isnot a class action sult. . If there are any known related cases, fle and serve a notice of rotated case. (You Date: Oo 94-22, > NOTICE «+ Plaintif must fle this cover sheet withthe fist paper fled in the action or proceeding (except small clsims cases or cases filed Lunger the Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Ruse of Court. rule 3.220.) Failure to fe 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 @ copy of this cover sheet on all ‘other pares fo the action or proceeding * Unless this isa collections case under rule 3.740 or a complex case, this cover sheet willbe used for statistical purposes ont rehet ¢ [KIpunitive (SOT ASTER a Civil CASE COVER SHEET Se aaINSTRUCTIONS ON HOW TO COMPLETE THE COVER SHEET Sees. To Plaintfts and Others Fling First Papers. If you are fing a frst paper (for example, @ complaint in a civl case, you must Completa and fle, eong with yout frst paper, the Chl Case Cover Sheet contsined on page 1: This Information willbe Used io comple Statstes sbout the ypes and numbers of cases fled. You must complet tems 1 through & onthe sheet. In em 1, you must check tone box for the cabo ype tal best descrbes the case. Ifthe case Mls both a general and » more specif type of case ated in Rem 1, hack the more specie one. Ifthe case has mufiple causes of acton, check the box that best incleates the primary cause of action ‘To assist you In completing the sheet, examples ofthe cases tnt belong under each case type In em 7 are provided Below. A cover sheet must be fled only with your iil paper. Falure to flee cover sheet wih the firs paper Med in a cil case may subject party, is couneel or both to sanctions under rdee 2-30 and 3.220 of he Cebforia Rules of Court To Parties in Rule 3.740 Collections Cases. A “callecions case" under rule 3740 is defined as en action for recovery of money owed ina sum slated 1 be certain tat isnot more than $25,000, exclusive of interest and attorney's fees, arising from a transaction in which propery, seraoes, or money was acqued on cred collectons case does not include en action seeking the folowing: (1) tor Gameges, (2) punitive. damages” (2) recovery of real propery, (4) recovery of personal propery, or (6) a preludgment writ of attactmrent The dentifcaion ofa case es a rule 3.740 callectons case on this form means that i will be exempt from the general {imerforcervce requirements and case management rues, unless @ defendent flee a responsive pleading. A rule 3.740 collections ‘case wil be subject to te requtements for service and obtaining judgment in rule 3.740, To Parties in Complex Cases. In complex cases only parties must also use the Ci! Case Cover Sheet to designate whether the ase is complex. If paint believes the case Is complex under rule 3.400 of the Calfomia Rules of Cour, ths must be indicated by Completing the appropriate boxes in tems 1 and 2 Ia plain designates a case as comple, the cover sheet must be served wit the omplaint‘on all parties tothe action. A defendant may fle and serve no later than the ime of is fret eppearance a oinder in the fiat sokgafe's cour angneion Sat a Gace eek soe Wa at hos nase Wo esto Geognaon fa Rew (CASE TYPES AND EXAMPLES Auto Tort Contract Provisionally Complex Civil Litigation (Cal. ‘Auto (22)}-Personal Injury/Property_ ‘Breach of ContractWarranty (06) Rules of Court Rules 3.400-3.403) Caregen al elcome ce naan ears a ened Salma eta So magnon ee Sicashaatine oxen coun cece eons an ape siete can mee Paro Peta yey! ng fs Sova crein een Pepe eee ha netic a yspoen eeren port See co) es eee See a at Se eet ‘epenes Povey ooo She Rocce Nee caghoren oa reer Se eee trots LSE enon tnipent Renee blame scat ne ei fs ns pet ae eee ee, ee see Sade ene Oe: eag rman Physicians & Surgeons Other Contract (37) Petition/Cartification of Entry of ote Professional Health Care ‘Contractual Froud Judgment on Unpaid Taxes ‘ora naan ong a tore ona mae ety Premee Lasty (0. sp eter borainrverse Miacalaneous Chil Complaint woes ores ra Intentional Bodily Inury/PDWD- ‘Wrongful Evietion (33) Other connie (not specified ‘epy eee elon Seathea rove 0, comes oe) a ered Peearenass Emotional Distress: Mortgage Foreclosure co ty (none Negligent Infiction of ‘Quiet Tile facpermenen ea Sn Bie Rt peace Sed cra Non-PUPDAD (Other) Tort foreclosure) Other: ‘Complaint i ‘Business ce Business: ee per ae x) se ee rire CoRR Be dectraten, ae acaaracs CPt, ‘aot toad See cas mcnes tap! poy sens ma i sce ce cannes oe a an oo eee eee somes 7 Rae seals mally ete oataern PaCS pesevcin Sieh eee ee Seer reer iachicnmey oe cos ae reece eae rapes es eedorBe cree tr ee Pein Rae rane mo RESHE a ve eta can cae a et nae acer eet nin in ee an Srarthame te ae ete ape to mmissioner Appeals. Bava aay a CIVIL CASE COVER SHEET aeMc-025 SHORT TITLE: case NONE |” RUFINO LAUREANO VS. CENTRO MUNDIAL..ET.AL ATTACHMENT (Numbeq: _4(@) (This Attachment may be used with any Judicial Couneil form.) COMPLAINT FOR DAMAGES: 1, FRAUD: 2, CONVERSION; 3, INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS; 4. BREACH OF CONTRACT; AND 5. BREACH OF IMPLIED GOVENANT OF GOOD FAITH AND FAIR DEALING. {ifthe item that this Attachment cancers is made under penalty of perjury, all statements in this Page 3 of _3 ‘Attachment are made under penalty of perjury.) (Ada pages as required) eae ATTACHMENT Sehr. tessa, at to Judicial Council Form‘SORTTTEE RUFINO LAUREANO VS. CENTRO MUNDIAL, ET.AL CAEN CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION (CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION) This form is required pursuant to Local Rule 2:3 in all new civil case filings in the Los Angeles Superior Court. Step 1: After completing the Civil Case Cover Sheet (Judicial Council form CM-010), find the exact case type in Column A that corresponds to the case type indicated in the Civil Case Cover Sheet. Step 2: in Column 8, check the box for the type of action that best describes the nature of the case. Step 3: In Column C, circle the number which explains the reason for the court filing location you have chosen. Applicable Reasons for Choosing Court Filing Location (Column C) 4. Class actone must be fied in the Stanley Mosk Courthouse, Centra District. 7. Location where peitioner resis. 2, Permiesve fling in central csi 6. Location wherein detendantresponcentfuncions whol. 3. Location where cause of acon arose. 8. Location where one or mera of the partes resi. 4. Mandatory personal injury fing in North Distt 10, Location af Labor Commissioner Ofc. ee eo accent raion 11, Mandatory fling location (Hub Cases ~ uniawful detainer, limites ron-cllection, limited collection, or personal injury). 6. Location of property cr pemanenty garsged vehicle. ‘to (22) 'D AT100 Motor Vehicle Personal luryProperty DamageMrongfDesth | 14,11 Auto Tort Uninsured Motorist (46) |. A7110. Persona InjuryProperty Damage/Wrongf Death — Uninsured Motor} 4,4, 11 sy) [2 A070 Aten Provo Conare aa z 5 bg (D_AT221 Asbestos - Personal InjuryWrongful Death: 11 e i Prostumoay Ge) | AT2S0 Preaict Laniy (rt sbero or itndomert) vant ef . A720 wade pace: Prec Saanre van = i Mesealaeacs(t8) | 249 ote Protestion Heath Cae alate hast 23 Seerpenere! | a7200 inrtenl oat yPronary Oanagutrongh Oe she yn | hee nocertnesy io ‘Death (23) C_A7270 Intentional infliction af Emotional Distress nr D._A7220 Other Personal InjuryiProperty Damage/Wrongful Death nan CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.3 as civ 100 av. 1278 AND STATEMENT OF LOCATION Page 1 of 4 For Mandatory UseSHORTTTLE RUFINO LAUREANO VS. CENTRO MUNDIAL.,ET.AL CASE BER Other Employment (18) Employment See [san oaeeaaernerneaceny Sarr gz Covi Rignis (08) | A8005 civ ghtDisrninaton 1.23 Ef eee oes a a Fraud (16) HL A6013 Fraud (no contrac) 1.2.3 BS | eioana negigoce 2s) [2 MEO" Leal talrcice 128 i ? 1 A6050 Cie Professors (nt maa or epa) has £ (Other (35) C_A8025 Other Non-Personal Injury/Property Damage tort 123 [wergtrTernsion gs) [G) AS007 Wrongs Tominatan 1.23 oe Ti : ‘AB109 Labor Commissioner Appeals [_—— 10 AsO GnaciptRonsaaneGrvaiaten! aareremman Tre cosy 6071 Other Commercial Complaint Case (nom-torvinon-complex) 128 73 8000 Otner Civil Complaint (non-tortinon-complex) 1.28 ——| ariorship Corporation eae aarcne mp Comaaton To apt Parnerhp and Caporale Govemance Cas 28 1 AB121 Ch Harassment wth Damages 2.39 a8 © A6123 Workstace Harseement Wih Damages 2.3.9 3 124 Deven Jul Abuse | it i omerredtore:nig | ASY24 EkerDevendentAdut Abuse Case With Oamoges 2.30 3 Spaced above) as) | AB190 Election Contest a 3 A810 Patton fr Change of NamalChange of Gander ae © ABI70 Pelton tor Reet rom Late Clim Law aaa © A8100 Other Civ Petition a CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.3 arena ote ef AND STATEMENT OF LOCATION Page 3 0f 4 For Mandatory Use‘FORT THLE RUFINO LAUREANO VS. CENTRO MUNDIAL, ET-AL Ss ‘Step 4: Statement of Reason and Address: Check the appropriate boxes for the numbers shown under Column C for the type of action that you have selected. Enter the address which is the basis for the filing location, including zip code. {No address required for class action cases). 14520 1/2 ROSEMEAD BLVD 09.210311 PICO RIVERA ca__[s0869 Step 5: Certification of Assignment: | certify that this case is properiy filed in the Norwalk Courthouse District of the Superior Court of California, County of Los Angeles [Code Civ. Proc., §392 et seq., and Local Rule 2.3(a)(2)(E)) Dated: __tle-94- 29. __ [BanarCor ATTORNEVLNG PART) PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY COMMENCE YOUR NEW COURT CASE: 1. Original Complaint or Petition 2. If fling a Complaint, « completed Summons form for issuance by the Clerk. 3. Civil Case Cover Sheet, Judicial Council form CM-010. 4 Civil Case Gover Sheet Addendum and Statement of Location form, LACIV 109, LASC Approved 03-04 (Rev. 02/6), Paymentin full ofthe filing fee, unless there is court order for waiver, partial or scheduled payments. 6. Asigned order appointing the Guardian ad Litem, Judicial Council form C1V-010, ifthe plaintiff or petitioner minor under 18 years of age will be required by Court in order to issue a summons. 7. Additional 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. CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.3 Lase crv 100 Rew. 128 AND STATEMENT OF LOCATION Page 4 of4 For Mandatory UseElectronically FLED 10 re 12 u 18 16 18 19 20 22 23 24 25 26 27 28 22NWCV00539 Assigned for all purposes to: Norwalk Courthouse, Judicial Officer: Margaret Bernal jpeior Court of Calor, County of Los Angele on 06/30/2022 11:01 AM Sher R, Carer, Executve OfierClrk of Cour, by E. Cans, Deputy Clerk Walter P. Saavedra Esq., Bar No. 311571 LAW OFFICE OF WALTER SAAVEDRA 6443 Florence Ave, Suite A Bell Gardens, CA 90201 Attomey for Plaintiff RUFINO LAUREANO SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES RUFINO LAUREANO, an individual; Case No.: | | Plaintiff | COMPLAINT FOR DAMAGES FOR: ‘ | | 1) FRAUD; 2) CONVERSION; 3) INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS; 4) BREACH OF CONTRACT; 5) BREACH OF IMPLIED COVENANT vs. i | | I | | l I 1 OF GOOD FAITH AND FAIR, | | | | i | CENTRO MUNDIAL; An Unknown Entity; PAULO ORTEGA aka PABLO ORTEGA, An Individual; and DOES | through 50, Inclusive. (Defendants.) DEALING; COMES NOW, PLAINTIFF RUFINO LAUREANO, and for causes of action against the Defendants and each of them, alleged as follows: JURISDICTION 1. This is the proper court and this action is properly filed in Los Angeles County because Defendant's obligations and liability arise therein. 2. Jurisdiction is premised upon the fact that the damages suffered by Plaintiffs are in excess of the minimum sum required for jurisdiction in the Superior Court of the State of California. COMPLAINT10 a a2 3 15 16 a a9 20 a 22 23 24 25 26 27 2e 3. Further, this Court has personal jurisdiction over Defendants on the grounds that all Defendants live and/or conduct or transact business and contract to supply goods or services in this State, and Defendants have purposefully availed themselves of the jurisdiction of this Court by transacting business in this State. 4, Defendants were to perform their contractual obligations owed to Plaintiffs in County of Los Angeles, California. 5. Venue and jurisdiction are also proper in this County as upon information and belief, Defendants reside and/or transacts business in this County. THE PARTIES 6. Plaintiff, RUFINO LAUREANO, (hereinafter referred to as “Plaintiff"), at all times relevant to this action, resided in the County of Los Angeles, State of California. 7. On information and belief, Defendant, CENTRO MUNDIAL, (hereinafter referred to as “COMPANY”, and DOES 1-50 are, and at all times relevant to this action, a California Corporation, with its principal place of business located in 4520 % Rosemead Blvd., Pico Rivera CA 90660. 8 On information and belief, Defendant PAULO ORTEGA aka PABLO ORTEGA (hereinafter referred to as “ORTEGA”) is an individual located at 4520 '% Rosemead Blvd., Pico Rivera CA 90660, was and is an owner, director, officer, or managing agent of Defendant COMPANY. 9. The true names and capacities, whether individual, corporate, associate or otherwise, of Defendants named herein as DOES 1 through 50, inclusive, are unknown to Plaintiff at this time and therefore said Defendants are sued by such fictitious names. Plaintiff will seek to leave to amend this Complaint to insert the true names and capacities of said Defendants when the same become known to Plaintiff. Plaintiff is informed and believes, and based thereupon alleges, that each of the fictitiously named Defends is responsible for the wrongful acts alleged herein and is therefore liable to Plaintiff as alleged hereinafter. 10. Plaintiff is informed and believes, and based thereupon alleges, that at all times relevant hereto, Defendants, and each of them, were the agents, employees, managing agents, COMPLAINT Baea2 13 u 15 20 a 22 23 24 25 26 27 26 supervisors, coconspirators, parent corporation, joint employers, alter ego, and/or joint ventures of the other Defendants, and each of them, and in doing the things alleged herein, were acting at least in part within the course and scope of said agency, employment conspiracy, joint employer, alter ego status, and/or joint venture and with the permission and consent of each of the other Defendants 11, On information and belief, Plaintiff alleges, that at all times relevant to this claim, Defendants, and each of them, including those Defendants named as DOES 1 through 50, acted in concert with one another to commit the wrongful acts alleged herein, and aided, abetted, incited, compelled and/or coerced one another in the wrongful acts alleged herein, and/or attempted to do so. On information and belief, Plaintiff further alleges, that Defendants, and each of them, including those Defendants named as DOES 1 through 50, formed and executed a conspiracy or common plan pursuant to which they would commit the unlawful acts alleged herein, with all such acts alleged herein done as part ofand pursuant to said conspiracy, intended to cause and actually causing Plaintiff harm. 12, Whenever and wherever reference is made in this Complaint to any act or failure to act by a Defendant or co-Defendant, such allegations and references shall also be deemed to mean the acts and/or failure to act by each Defendant acting individually, jointly and severally. FACTUAL ALLEGATIO! 13, PLAINTIFF is a 68-year-old man with deteriorating heaith. Throughout his life Plaintiff has visited many doctors about his health condition. Eventually, Plaintiff's health worsened and was informed by his many doctors that there was nothing else modern medicine could do to alleviate his pain and suffering. 14. Onor around May 2022, Plaintiff saw a television commercial of DEFENDANT PAULO ORTEGA aka PABLO ORTE! 5A (“ORTEGA”). The commercial depicted Defendant Ortega as a spiritual minister and curer of health problems. Defendant's commercial provided Ortega’s contact information which included the telephone number 323-350-6299. 15. Plaintiff, who was in severe pain and desperate to alleviate them, called the number 323-350-6299, Defendant Ortega picked up the phone and after a few minutes, Defendant COMPLAINT =a10 n 12 13 14 15 16 re 19 20 a 23 24 25 2 28 Ortega made Plaintiff an appointment to meet in person. The appointment was set at DEFENDANT CENTRO MUNDIAL (“COMPANY”) located at 4520 %4 Rosemead Blvd., Pico Rivera CA 90660. 16. On or around April 2022, Plaintiff met with Defendant Ortega at Company. Defendant Ortega was a light skinned Hispanic man, about 6"7”, with black short hair. Defendant Ortega charged Plaintiff $40.00 for the consultation, which Plaintiff paid in cash, and Defendant began reading Plaintiff's cards. Defendant asked Plaintiff a series of questions about his visit to which Plaintiff told him about his deteriorating health problems and what his doctors had told him, Defendant proceeding with the card reading and then upon its conclusion, told Plaintiff that the reason he was in such physical pain with no remedy was due to Plaintiff being “hexed” by an unknown person who wanted to do him harm, 17. Defendant Ortega told Plaintiff that the reason Plaintiff was unable to be cured by a licensed doctor was because it was a spiritual issue that could not be treated with modern medicine, Defendant Ortega told Plaintiff that he was being cursed with black magic and needed a cleansing in order for Plaintiff to feel better. Defendant Ortega claimed he was able to make the pain go away with a cleansing of Plaintiff's person. Defendant Ortega than told Plaintiff that in order to initiate the process to cleanse Plaintiff, he required $1,400.00 to begin the job. Defendant Ortega saw that Plaintiff was in so much pain and desperation that Defendant Ortega took advantage of Plaintiff's weakened state. 18. Plaintiff, being desperate to alleviate his pain and suffering, agreed to have the cleansing done and entered into an oral contract with Defendant Ortega. Plaintiff paid Defendant Ortega $1,400.00 in cash. Defendant Ortega told Plaintiff to go home and return the following day to begin the cleansing. Plaintiff retuned the next day for the cleansing where Defendant Ortega told him to think of a special deceased person's spirit. Plaintiff gave his late brother's name to Defendant Ortega to which he wrote in a piece of paper and threw it in fire. The paper caused black smoke to which Defendant Ortega saw as an opportunity to “interpret” it a message from Plaintiff's deceased brother than Plaintiff required eight (8) black mases; each worth $250.00, Plaintiff being vulnerable and desperate paid Defendant $2,000.00 in cash. COMPLAINT Sa10 uu a2 13 uu as 16 19, Ina lapse of six days, Defendant Ortega called Plaintiff to inform him that he had already done all eight (8) black mases required. However, Plaintiff's physical condition did not improve. Defendant Ortega told Plaintiff that the black mases revealed another message from Plaintiff's deceased bother. According to “Plaintiff's deceased brother's spirit”, the evil that was causing Plaintiff harm was coming from Plaintiff's home. Defendant Ortega said that the grand spirit of San Sabastian De Valcazar chose Plaintiff's brother as a messenger to inform Plaintiff of a buried treasure. Defendant Ortega told Plaintiff that the spirit of San Sabastian De Valcazar said the treasure was hidden for more than 190 years and was valued roughly around $2,500.00 which included golden and silver coins and 19 diamonds. 20. After two days, Defendant Ortega came over to Plaintiff's home to begin excavating the ground in the hops of finding the buried treasure promised by the spirit of San Sabastian. Defendant Ortega told Plaintiff to unplug all electronic devices and appliances in the house and then and only then they begin to dig. The digging began at the side of the house of Plaintiff, Defendant Ortega initiated the digging and then stopped told Plaintiff to continue digging at least four feet deep and wide and left. Plaintiff continued the digging with the help of his son. The next day, Defendant Ortega returned with a man who he referred to Minister ‘Thomas. 21, With the help of Minister Thomas, Defendant Ortega and Thomas filled the hole in the ground with 24 lit candles and they started to pray. After the prayer, Defendant Ortega and ‘Thomas covered the hole with a white sheet. As expected, with no ventilation, the sheet rose up a bit and shortly caught on fire. Defendant Ortega with the help of Thomas threw 5 gallons of water in the hole. The dirt soon turned to mud. Defendant Ortega told Plaintiff to dig and find “the keys”. Plaintiff removed the sheet and found 3 golden coins and a diamond. Defendant Ortega told Plaintiff that the 3 gold coins and diamond were valued at $13 million dollars. Defendant Ortega began to dig and found a crow. Inside the crow was a statute of Death and a letter attached to it. Plaintiff never saw the contents of the note since Defendant took the note, the coins, and the diamond with them. COMPLAINT oS10 Ft a2 13 14 a5 16 rt] ae 19 20 aa 23 24 26 2 28 22, Two days passed and Defendant Ortega called Plaintiff and told Plaintiff that he needed to make 66 black mases, however this time they were $1,000.00 each. Plaintiff was torn and Defendant Ortega told him that since Defendant Ortega was such a good person, he would cover half the cost of the 66 black mases. The next day, Plaintiff went to Company to which he was greeted by Defendant Ortega and Thomas. Plaintiff gave Defendant Ortega $11,000 in cash. ‘After three to four days, Plaintiff then took Defendant Ortega an additional $15,000.00 in cash. About a day passed and, Defendant Ortega called Plaintiff for an additional $14,000.00 to begin the 66 mases. Plaintiff told Defendant Ortega that he had no more money and that he was spending too much money on this remedy when his body felt the same or worse. Defendant Ortega told Plaintiff that instead of $14,000.00 he could bring $7,000.00, however Plaintiff told Defendant Ortega that he had no more money. 23. Defendant Ortega and Defendant Company are in the business to hustle those who find themselves in a very vulnerable state in their lives in order to exploit those vulnerabilities to gain access to their money. To this date, Defendants request more money from Plaintiff knowing he is in physical pain and susceptible due to his age. Nothing Defendants have done has improve Plaintiff's physical health or mental health. FIRST CAUSE OF ACTION FOR FRAUD (By Plaintiff Against All Defendants and DOES 1-50) 24, Plaintifi’s incorporate, by reference, all the foregoing paragraphs of this complaint, as though fully set herein. 25. In California, the general elements of a cause of action for fraudulent misrepresentation are (1) misrepresentation (false representation, concealment, or nondisclosure); (2) knowledge of falsity (scienter); (3) intent to induce reliance; (4) justifiable reliance; and (5) resulting damage. 26. Here, the first element is met because Defendants misrepresented the fact that they could cure Plaintiff of his physical pain and that Defendant could make Plaintiff feel better physically with a cleansing. This was a misrepresentation since the cleanses that Defendants COMPLAINT aes18 19 20 au 22 2a 25 26 28 performed did nothing to improve Plaintiff's physical health or mental health. Thus, Defendants misrepresented these facts 27. The second element is met because Defendants knew that all the black mases and the cleanse process would not improve Plaintiff's physical condition at all. Defendants knew that the things being told to Plaintiff about their “ability” to improve or “cure” Plaintiff's physical condition were untrue as it was all a ruse to obtain money from Plaintiff. Nothing Defendants have done has improve Plaintiff's physical health or mental health, thus Defendants had knowledge of the falsity. 28, The third element is met because Defendants told Plaintiff they could cure his physical pain with the intent to induce reliance on Plaintiff's part. Defendants also used Plaintiff's deceased family member’s name in order for Plaintiff to trust him and to obtain money from Plaintiff. Defendant Ortega saw that Plaintiff was in so much pain and desperation that Defendant Ortega took advantage of Plaintiff's weakened state and began to hustle him for money. Thus, Defendants intended to induce reliance. 29. The fourth element is met because PLAINTIFF was a 68-year-old man with deteriorating health. Throughout his life Plaintiff has visited many doctors about his health condition. Eventually, Plaintiff's health worsened and was informed by his many doctors that there was nothing else modern medicine could do to alleviate his pain and suffering, Plaintiff, being desperate to alleviate his pain and suffering, agreed to have the cleansing done and entered into an oral contract with Defendant Ortega. However, Defendants are in the business to hustle those who find themselves in a very vulnerable state in their lives in order to exploit those vulnerabilities to gain access to their money. To this date, Defendants request more money from Plaintiff knowing he is in physical pain and susceptible due to his age. Nothing Defendants have done has improve Plaintiff's physical health or mental health. Thus, due to Plaintiff's vulnerable state he justifiably relied on Defendants misrepresentation. 30. The fifth element is met because Plaintiffs has suffered damages in the amount of $29,440.00; $40.00 for the consultation, $1,400.00 to begin the cleansing, $2,000.00 for the first 8 COMPLAINT10 a 12 13 a4 45 16 7 18 19 20 2 22 23 24 25 26 21 28 black mases, $26,000.00 for the 66 black mases. Thus, Plaintiff suffered damages due to Defendants acts and/or omission. 31. Inconclusion, Defendants are liable for fraud. SECOND CAUSE OF ACTION FOR CONVERSI (By Plaintiff Against All Defendants and DOES 1-50) 32. Plaintiffs incorporate, by reference, all the foregoing paragraphs of this complaint, as though fully set herein. 33. Conversion is the wrongful exercise of dominion over the property of another. The elements of a conversion claim are: (1) the Plaintiff’s ownership or right to possession of the property; (2) the defendant’s conversion by a wrongful act or disposition of property rights; and (3) damages. 34, The first element is met because Plaintiff was the owner of the $29,440.00, he paid in cash to Defendants; $40.00 for the consultation, $1,400.00 to begin the cleansing, $2,000.00 for the first 8 black mases, $26,000.00 for the 66 black mases. 35. The second element is met because Defendants have completely failed and/or refused to account for the use of Plaintiffs funds and have completely failed and/or refused to retum any of Plaintiffs’ funds. Nothing Defendants have done has improve Plaintiff's physical health or mental health. Instead, to satisfy their personal debts and/or living expenses, Defendants wrongfully and unlawfully intentionally converted Plaintiffs’ funds for Defendants’ personal use in their entirety. PlaintiffS in no manner consented to Defendants’ misappropriation of their funds. 36. The third element is met because Plaintiffs has suffered damages in the amount of $29,440.00; $40.00 for the consultation, $1,400.00 to begin the cleansing, $2,000.00 for the first 8 black mases, $26,000.00 for the 66 black mases. Thus, Plaintiff suffered damages due to Defendants acts and/or omission. 37. Inconelusion, Defendants have committed conversion. THIRD CAUSE OF ACT) NAL INFLICTIO! ONAL DISTRESS (By Plaintiff Against All Defendants and DOES 1-50) COMPLAINT Bier10 u 12 13 v 18 19 20 22 23 24 38. Plaintiffs incorporate, by reference, all the foregoing paragraphs of this complaint, as though fully set herein. 39. To establish this claim Plaintiff must prove: 1) that Defendants conduct was outrageous; 2) that Defendant acted with a reckless disregard of the probability that Plaintiff would suffer emotional distress, knowing that Plaintiff was present when the conduct occurred; 3) that Plaintiff suffered emotional distress; and 4) that Defendant's conduct was a substantial factor causing Plaintiff's severe emotional distress. 40. The first element is met because Defendants conduct was outrageous because it goes beyond all possible bounds of decency. Defendant Ortega told Plaintiff that the reason Plaintiff was unable to be cured by a licensed doctor was because it was a spiritual issue that could not be treated with modern medicine. Defendant Ortega claimed he was able to make Plaintiff's physical pain go away with a cleansing priced at $29,440.00. Defendant Ortega and Defendant Company are in the business to hustle those who find themselves in a very vulnerable state in their lives in order to exploit those vulnerabilities to gain access to their money. Defendants used Plaintiff's deceased family member's name in order for Plaintiff to trust him and to obi money from Plaintiff. Defendants even went to Plaintiff's home and told Plaintiff to unplug all electronic devices and appliances in the house and then and only then they begin to dig for a hidden “treasure” his deceased brother promised him. Defendants conduct was outrageous because a reasonable person would regard the conduct as intolerable in a civilized community. 41. The second element is met because Defendant intended to cause Plaintiff's, emotional distress, or Defendants acted with reckless disregard of the probability that Plaintiff would suffer emotional distress, knowing that Plaintiff was present when the conduct occurred, Defendant knew PLAINTIFF was a 68-year-old man with deteriorating health. Throughout his life Plaintiff has visited many doctors about his health condition. Defendant Ortega saw that Plaintiff was in so much pain and desperation that Defendant Ortega took advantage of Plaintiff's weakened state and began to hustle him for money. Defendants then created a ruse to deprive Plaintiff of $29,440.00. Defendants knew that emotional distress would probably result from Defendants conduct or Defendants gave little or no thought to the probable effects of his conduct. COMPLAINT ar20 an 2 13 14 15 16 18 19 20 a 23 2 2s 26 21 28 42. The third element is met because Plaintiff suffered severe emotional distress including suffering, anguish, fright, horror, nervousness, grief, anxiety, worry, shock, humiliation, and shame. After any meeting with Defendants, Plaintiff was given a little bit of hope that his physical pain would go away, however it was all a ruse by Defendants to obtain his money, and when Plaintiff found out it was all a lie, Plaintiff dealt with severe anguish, fright, horror, nervousness, grief, anxiety, worry, shock, humiliation, and shame. 43. The fourth element is met because Defendants conduct was a substantial factor in causing PLAINTIFF'S severe emotional distress. 44. The acts and/or omissions of DEFENDANTS, and each of them, caused PLAINTIFF to suffer harm and economic damages, for the cost of medical, psychological and/or psychiatric treatment, and PLAINTIFF is informed and believes that he may incur damages in the future for the cost of future care, in amounts according to proof at trial. 48. Incommi them, have been guilty of malice, fraud, or oppression and, therefore, PLAINTIFF seeks an award ing the acts and/or omissions alleged, DEFENDANTS, and each of of punitive damages against DEFENDANTS, and each of them, according to proof at trial. The damages caused by Defendants will be demonstrated according to proof. FOURTH CAUSE OF ACTION FOR BREACH OF CONTRACT (By Plaintiff Against All Defendants and DOES 1-50) 46. Plaintiff hereby incorporate by reference each and every one of the preceding paragraphs as if the same were fully set forth herein. 47. The following elements are required for a breach of contract: 1) the existence of a contract; 2) performance by the plaintiff or some justification for nonperformance; 3) failure to perform the contract by the defendant; and 4) resulting damages to Plaintiff. 48. The first element is met because Plaintiff and Defendant entered into an oral agreement. On or around April 2022, Plaintiff met with Defendant Ortega at Company. Defendant asked Plaintiff a series of questions about his visit to which Plaintiff told him about his deteriorating health problems and what his doctors had told him. Defendant proceeding with the card reading and then upon its conclusion, told Plaintiff that the reason he was in such physical ‘COMPLAINT wo10 aa 13 1 as 16 a ae as 20 a 22 23 24 25 26 27 28 pain with no remedy was due to a “hex”, Defendant Ortega told Plaintiff that he was being cursed with black magic and needed a cleansing in order for Plaintiff to feel better. Defendant Ortega claimed he was able to make the pain go away with a cleansing of Plaintiff's person. Plaintiff agreed to pay Defendant a total of $29,440.00 to improve his overall healthy. Thus, a contract was formed. 49. The second clement is met because Plaintiff has fully performed the terms and conditions of the oral agreement; except for those terms and conditions which were excused by the acts and/or omissions of Defendant. Here, Plaintiff rendered a total of $29,440.00 in cash to Defendant Ortega. Thus, Plaintiff fully performed under the contract, 50. The third element is met because Defendant Ortega and Defendant Company did not uphold their contractual duties on the oral agreement between Plaintiff. PLAINTIFF is a 68- year-old man with deteriorating health. Throughout his life Plaintiff has visited many doctors about his health condition. Eventually, Plaintiff's health worsened and was informed by his many doctors that there was nothing else modern medicine could do to alleviate his pain and suffering. Defendants saw that Plaintiff was in so much pain and desperation that Defendants took advantage of Plaintiff's weakened state. Defendant Ortega and Defendant Company are in the business to hustle those who find themselves in a very vulnerable state in their lives in order to exploit those vulnerabilities to gain access to their money. To this date, Defendants request more money from Plaintiff knowing he is in physical pain and susceptible due to his age and medical conditions. Nothing Defendants have done has improve Plaintiff's physical health or mental health. Thus, Defendants have breached the oral contract. 51. The fourth element is met because Plaintiffs has suffered damages in the amount of $29,440.00; $40.00 for the consultation, $1,400.00 to begin the cleansing, $2,000.00 for the first 8 black mases, $26,000.00 for the 66 black mases. Thus, Plaintiff suffered damages due to Defendants acts and/or omission. 52, _ In conclusion, Defendants have breached the oral contract with Plaintiff. EIFTH CAUSE OF ACTION FOR BI \CH OF IMPLIED OF GOOD FAITH AN DEALING ‘COMPLAINT: mae10 u a2 13 u 16 uv 18 19 20 22 23 24 (By Plaintiff Against All Defendants and DOES 1-50) 53. Plaintiffs incorporate, by reference, all the foregoing paragraphs of this complaint, as though fully set herein. 54, In general, every contract contains an implied duty of good faith and fair dealing. This duty requires that neither party will do anything that will destroy or injure the right of the other party to receive the benefits of the contract. Any relation existing between parties to a transaction wherein one of the parties is in duty bound to act with the utmost good faith for the benefit of the other party. Such a relation ordinarily arises where one person reposes confidence in the integrity of another, and in such a relation, the party in whom the confidence is reposed, if he voluntarily accepts or assumes to accept the confidence, can take no advantage from his acts relating to the interest of the other party without the latter's knowledge or consent. 58. Here, by entering into and forming an oral agreement with Plaintiff pursuant to the laws of the State of California, a contractual relationship existed between Defendants and Plaintiff. Inherent in and arising from this contract are the duties of loyalty, tegrity, candor, and good faith. 56. Defendant ORTEGA and COMPANY breached the implied covenant of good faith and fair dealing by unfairly interfering with Plaintiff's right to receive the benefits of the oral agreement; having his health improve. Furthermore, Defendants breached the covenant of good faith and fair dealing by actively attempting to take advantage of Plaintiff due to his age and medical condition by putting on a show to convince Plaintiff they were doing something to improve his health when in reality it was all a ruse. Defendants saw that Plaintiff was in so much pain and desperation that Defendants took advantage of Plaintiff's weakened state. Defendant Ortega and Defendant Company are in the business to hustle those who find themselves in a very vulnerable state in their lives in order to exploit those vulnerat ies to gain access to their money. To this date, Defendants request more money from Plaintiff knowing he is in physical pain and susceptible due to his age and medical conditions. Nothing Defendants have done has improve Plaintiff's physical health or mental health. compLAINT Enie20 a 22 23 24 25 26 27 28 57. The acts alleged above constitute violations of the implied covenant of good faith and fair dealing. 58. Asa direct, foreseeable, and proximate result of Defendants’ breach of the implied covenant of good faith and fair dealing, Plaintiffs have suffered damages, including overcharged attorneys’ fees, costs, and expenses. The amount of these damages has not been precisely determined and the damages are continuing to accrue. Plaintiff is thereby entitled to damages in amounts to be proven at trial. PRAYER FOR RELIEF Wherefore, PLAINTIFF prays for judgment, against DEFENDANTS, and each of them, as follows: 1. For special damages according to proof but no less than: a, $40.00 for the consultation; b. $1,400.00 to begin the cleansing; ¢. $2,000.00 for the first 8 black mases; 4d. $26,000.00 for the 66 black mases; 2. For general damages according to proof; 3. For punitive damages in the amount appropriate to punish the DEFENDANT(S) and deter other from engaging in similar misconduct on appropriate legal causes of action; 4. For costs of suit, including attorney's fees; 5. For such other relief’ as the Court deems appropriate. DATED: June_29_ 2022 LAW OFFICE OF WALTER P. SAAVEDRA ace WALTER P. SAAVEDRA ATTORNEY FOR PLAINTIFF RUFINO LAUREANO. COMPLAINT rae