Alameda County Court Watch

ALT HADDAD vs CIRCLE K STORES INC. (Page 1): COMPLAINT 1 Joseph Lavi, Esq. (SBN 209776) Vincent C. Granberry, Esq. (SBN 276483) Jeffrey D. Klein, Esq. (SBN 297296) Margaux K. Gundzik, Esq. (SBN 340116) LAVI & EBRAHIMIAN, LLP 8889 W. Olympic Boulevard, Suite 200 Beverly Hills, California 90211 Telephone: (310) 432-0000 Facsimile: (310) 432-0001 Email: [email protected] [email protected] [email protected] [email protected] Attorneys for Plaintiff NATALIE HADDAD, on behalf of herself and current and former aggrieved employees SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ALAMEDA NATALIE HADDAD, on behalf of herself and current and former aggrieved employees Plaintiff, vs. CIRCLE K STORES INC.; and DOES 1 to 100, inclusive, Defendants. Case No.: PAGA ACTION PLAINTIFF NATALIE HADDAD’S COMPLAINT FOR: 1. CIVIL PENALTIES PURSUANT TO THE PRIVATE ATTORNEYS GENERAL ACT OF 2004 (“PAGA”), LABOR CODE SECTIONS 2698, ET SEQ. COMES NOW Plaintiff NATALIE HADDAD (“Plaintiff

ALT HADDAD vs CIRCLE K STORES INC. (Page 2): COMPLAINT 2 Defendants’ violation of the Labor Code based on Defendants’ failure to pay wages for all hours worked at minimum wage and all overtime hours worked at the overtime rate of pay; failure to pay overtime wages at the proper overtime rate of pay; failure to authorize or permit all legally required and/or compliant meal periods or pay meal period premium wages; failure to authorize or permit all legally required and/or compliant rest periods or pay rest period premium wages; indemnification for all necessary expenditures or losses incurred by employees in direct consequence of discharging their duties; failure to pay wages for accrued paid sick time at the regular rate of pay; statutory penalties for failure to timely pay earned wages during employment; statutory penalties for failure to provide accurate wage statements; statutory waiting time penalties in the form of continuation wages for failure to timely pay employees all wages due

ALT HADDAD vs CIRCLE K STORES INC. (Page 3): COMPLAINT 3 filed include current, former and/or future employees of Defendants who work, worked, or will work for Defendants as direct employees as well as temporary employees employed through temp agencies as hourly non-exempt employees in California. At all times mentioned herein, the currently named Plaintiff is and was domiciled and a resident and citizen of California and was employed by Defendants in an hourly position at Defendants’ location in Alameda county from in or around December 13, 2022, until on or about August 11, 2025. 2. Plaintiff is informed and believes and thereon alleges that Defendant CIRCLE K STORES INC. is authorized to do business within the State of California and is doing business in the State of California and/or that Defendants DOES 1-50 are, and at all times relevant hereto were persons acting on behalf of Defendant CIRCLE K STORES INC. in the establishment of, or ratification of, the aforementioned illegal wa

ALT HADDAD vs CIRCLE K STORES INC. (Page 4): COMPLAINT 4 named defendants is in some manner responsible for the events and allegations set forth in this complaint. 6. Plaintiff makes the allegations in this complaint without any admission that, as to any particular allegation, Plaintiff bears the burden of pleading, proving, or persuading and Plaintiff reserves all of Plaintiff's right to plead in the alternative. FIRST CAUSE OF ACTION CIVIL PENALTIES PURSUANT TO THE PRIVATE ATTORNEYS GENERAL ACT OF 2004, LABOR CODE SECTIONS 2698, ET SEQ. (Against all Defendants by Plaintiff on behalf of Themselves, the State of California, and Other Current and Former Aggrieved Employees) 7. Plaintiff incorporates all paragraphs above as though fully set forth herein. 8. During Plaintiff’s employment and continuing through the present, Plaintiff alleges Defendants violated Labor Code sections 201, 202, 203, 204, 223, 226, 226.7, 246, 510, 512, 1194, 1197, 2802, and the applicable Wage Orders. 9. Specif

ALT DURANT vs WINN MANAGEMENT GROUP, LLC, A MASSACHUSETTS LIMITED LIABILITY COMPANY (Page 1): 1 COMPLAINT Kane Moon (SBN 249834) E-mail: [email protected] Christopher L. Garcia (SBN 306082) E-mail: [email protected] Lindsey A. Gevorkian (SBN 364013) E-mail: [email protected] MOON LAW GROUP, PC 725 S. Figueroa Street, 31st Floor Los Angeles, California 90017 Telephone: (213) 232-3128 Facsimile: (213) 232-3125 Attorneys for Plaintiff CHARLES DURANT SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ALAMEDA CHARLES DURANT, an individual; Plaintiff, vs. WINN MANAGEMENT GROUP, LLC, a Massachusetts Limited Liability Company; and DOES 1 through 25, inclusive, Defendants. Case No.: _______________ COMPLAINT FOR DAMAGES FOR: 1. VIOLATION OF LABOR CODE §1102.5; 2. VIOLATION OF LABOR CODE §98.6; 3. WRONGFUL TERMINATION IN VIOLATION OF PUBLIC POLICY; 4. FAILURE TO PROVIDE MEAL PERIODS; 5. FAILURE TO PROVIDE RE

ALT DURANT vs WINN MANAGEMENT GROUP, LLC, A MASSACHUSETTS LIMITED LIABILITY COMPANY (Page 2): 2 COMPLAINT COMES NOW Plaintiff Charles Durant for his Complaint against Defendant WINN MANAGEMENT GROUP, LLC, and DOES 1 through 25 (herein collectively referred to as “Defendants”), and each of them, complains and alleges as follows: THE PARTIES 1. Plaintiff Charles Durant (“Plaintiff” or “Durant”) is, and at all relevant times herein was, an individual residing in the County of Alameda, State of California. 2. Plaintiff is informed and believes and thereon alleges that Defendant WINN MANAGEMENT GROUP, LLC (“Defendant” or “Winn”) is, and at all relevant times was, a Massachusetts Limited Liability Company that conducts business in the County of San Mateo, State of California. 3. Plaintiff is ignorant of the true names and capacities of those defendants sued as DOES 1 through 25, inclusive, and, therefore, sues them under the fictitious names pursuant to Code of Civil Procedure section 474. Pla

ALT DURANT vs WINN MANAGEMENT GROUP, LLC, A MASSACHUSETTS LIMITED LIABILITY COMPANY (Page 3): 3 COMPLAINT GENERAL ALLEGATIONS 6. On or about April 28, 2025, Durant was hired by Defendants. Durant was employed by Defendants until September 22, 2025, when he was terminated. 7. Throughout Durant’s employment with Defendant, Durant was required to use his personal vehicle to drive to different work sites and his personal cell phone for Defendant’s business which he was not reimbursed for. 8. During Durant’s employment for Defendants, Durant was also not provided with, or authorized to take, or was unable to take due to Durant’s schedule, all the requisite appropriate meal and rest breaks. Durant is entitled to an hour of wages for each day in which Plaintiff was not provided with such breaks, in an amount according to proof at trial. 9. From in or around July 2025, until the date Durant was terminated, Durant repeatedly expressed complaints to Defendants regarding his inability to timely tak

ALT DURANT vs WINN MANAGEMENT GROUP, LLC, A MASSACHUSETTS LIMITED LIABILITY COMPANY (Page 4): 4 COMPLAINT unlawful policies. Defendants’ violations, as alleged above, during all relevant times herein were willful and deliberate. 16. At all relevant times, Defendants were and are legally responsible for all of the unlawful conduct, policies, practices, acts and omissions as described in each and all of the foregoing paragraphs as the employer of Durant. Further, Defendants are responsible for each of the unlawful acts or omissions complained of herein under the doctrine of “respondeat superior”. FIRST CAUSE OF ACTION (Violation of California Labor Code § 1102.5 - Against All Defendants) 17. Plaintiff incorporates the allegations of the preceding paragraphs as though fully set forth herein. 18. At all times relevant herein, Plaintiff was an employee within the meaning of Labor Code Section 1102.5. 19. Plaintiff engaged in activity protected by Labor Code Section 1102.5 by, inter alia, disc

ALT INGERSOLL, vs BEVERAGES & MORE, INC.,, et al. (Page 1): PAGA COMPLAINT Robert Drexler (SBN 119119) [email protected] Jonathan Lee (SBN 267146) [email protected] Robert Myong (SBN 262097) [email protected] Capstone Law APC 1875 Century Park East, Suite 1860 Los Angeles, California 90067 Telephone: (310) 556-4811 Facsimile: (310) 943-0396 Attorneys for Plaintiff Leeanna Ingersoll SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ALAMEDA LEEANNA INGERSOLL, as an aggrieved employee pursuant to the Private Attorneys General Act (“PAGA”), on behalf of the State of California and other non-party Aggrieved Employees, Plaintiff, vs. BEVERAGES & MORE, INC., a Delaware corporation; GOBRANDS, INC., a Delaware corporation; and DOES 1 through 10, inclusive, Defendants. Case No.: COMPLAINT – PAGA ENFORCEMENT ACTION (1) Claim for Civil Penalties for Violations of California Labor Code, Pursuant to PAGA, §§ 2698, et seq.

ALT INGERSOLL, vs BEVERAGES & MORE, INC.,, et al. (Page 2): Page 1 PAGA COMPLAINT Plaintiff Leeanna Ingersoll, as an aggrieved employee and on behalf of the State of California and all other non-party Aggrieved Employees, alleges as follows: JURISDICTION AND VENUE 1. This is an enforcement action under the Labor Code Private Attorneys General Act of 2004, California Labor Code sections 2698, et seq. (“PAGA”) to recover civil penalties and any other available relief on behalf of Plaintiff, the State of California, and other current and former employees who worked for Defendants in California as a non-exempt, hourly paid employee and received at least one wage statement and against whom one or more violations of any provision in Division 2 Part 2 Chapter 1 of the Labor Code or any provision regulating hours and days of work in the applicable Industrial Welfare Commission (“IWC”) Wage Order were committed, as set forth in this complaint, at any time between one year prior to the filing of t

ALT INGERSOLL, vs BEVERAGES & MORE, INC.,, et al. (Page 3): Page 2 PAGA COMPLAINT civil penalties attributable to violations personally suffered are less than $75,000. Id. at 1122. 4. Venue is proper in this Court because Defendants employ persons in this county, and employed Plaintiff in this county, and thus a substantial portion of the transactions and occurrences related to this action occurred in this county. 5. California Labor Code sections 2698, et seq., the “Labor Code Private Attorneys General Act of 2004,” authorize aggrieved employees to sue as private attorneys general their current or former employers for various civil penalties for violations of various provisions in the California Labor Code. THE PARTIES 6. Plaintiff Leeanna Ingersoll is a resident of Oakland, in Alameda County, California. Defendants employed Plaintiff as an hourly paid, non-exempt employee from approximately October 2024 to July 2025. Plaintiff worked for Defendants as a Retail Sales Associate at the

ALT INGERSOLL, vs BEVERAGES & MORE, INC.,, et al. (Page 4): Page 3 PAGA COMPLAINT. Plaintiff is informed and believes, and thereon alleges, that DOES 1 through 10 were the partners, agents, owners, or managers of BEVERAGES & MORE, INC. and GOBRANDS, INC., at all relevant times. 11. Plaintiff is informed and believes, and thereon alleges, that each and all of the acts and omissions alleged herein was performed by, or is attributable to, BEVERAGES & MORE, INC.; GOBRANDS, INC.; and/or DOES 1 through 10 (collectively, “Defendants” or “BEVMO”), each acting as the agent, employee, alter ego, and/or joint venturer of, or working in concert with, each of the other co-Defendants and was acting within the course and scope of such agency, employment, joint venture, or concerted activity with legal authority to act on the others’ behalf. The acts of any and all Defendants were in accordance with, and represent, the official policy of Defendants. 12. At all relevant times, Defendants, and each of th

ALT ZHANG, et al. vs INABEL (Page 1): PLD.PI.OOl ATTORNEY OR PARTY WTHOUT ATTORNEY NAME: Christopher C. Zhang, Esq. FIRM NAME: Frontal Law Group STREETADDRESS: 1871 The Alameda, Suite 425 oTY: San JOSe TELEPHoNE no.: (408)890-7925 EMArL ADDRESS: [email protected] STATE BAR NUMBER: 27 1179 STATE: CA ZIPCODE: 95126 FAX No.: 408-675-2258 ATToRNEY FoR(name): Plaintiffs LONGZHE ZHANG and JIALU WANG FOR COURT USE O'VLY SUPERIOR COURT OF CALIFORNIA, COUNTY OF STREET ADDRESS: 1 225 FAIION StrEEt MAILING ADDRESS: crrY AND ZrP CoDE: Oakland, CA 94612 BRANCH nrur Civil/Unlimited ALAMEDA PLAINTIFF: LONGZHE ZHANG and JIALU WANG DEFENDANT: HERRERA ESCAMILLA INABEL l-x-l DOES 1 TO 100 GOMPLAINT-Persona! lnjury, Property Damage, Wrongful Death Type (check all that apply): l-a MOTOR VEHIGLE [__l OTHER (specify): E Property Damage [__l Wrongful Death f Personal lnjury l-l Ottrer Damages (specify): CASE NUMBER: Jurisdiction (check all that apply): I-_l ncIoN ls A LIMITED CIVIL CASE (does not exceed $35,

ALT ZHANG, et al. vs INABEL (Page 2): PLD.PI.OOl SHORT TITLE: Zhang & Wang v. lnabel CASE NUMBER: 4. [-l Plaintilf (name): is doing business under the fictitious name (specify) and has complied with the flctitious business name laws. 5. Each defendant named above is a natural person a. I x I exceptdefendanl(name): DOES 21-50 c. [-_-l exceptdefendant(name): (1) fal a business organization, form unknown. (1) T_l a business organization, form unknown. (2) l-l a corporation. (2) l-l a corporation. (3) E an unincorporated entity (describe): (3) fl an unincorporated entity (describe): (4) t-_l a public entity (describe): (4) l-l a public entity (describe): b. fI except defendanl(name):51-70 d. E except defe ndant(nane):7'l-'l11 (1) E a business organization, form unknown. (1) E a business organization, form unknown. (2)E a corporation. (2) E a corporation. (3) E an unincorporated entity (descrbe); (3) E an unincorporated entity (describe): UNKNOWN (4) E a public enlily (describe): (4) E a publi

ALT ZHANG, et al. vs INABEL (Page 3): PLD-PI.OO1 SHORT TITLE: Zhang & Wang v. lnabel CASE NUMBER: 10. The following causes of action are attached and the statements above apply to each (each complaint must have one or more causes of action attached): a. [Tl Motor Vehicle b. I x I General Negligence c. I-__l lntentional Tort d. [__l Products Liability e. l-l Premises Liability f. [-_-l Other (specify): 1 1. Plaintiff has suffered (check all that apply) a. J-E wage loss. b. [-__l loss of use of property. c. [E hospital and medical expenses. d. l- x I general damage. e. Ixl propertydamage. f. I-_l loss of earning capacity. 12.f1 The damages claimed for wrongful death and the relationships of plaintiff to the deceased are a. [__l listed in Attachment 12. b. [_-l as follows: 13. The relief sought in this complaint is within the jurisdiction of this court. 14. Plaintiff prays for judgment for costs of suit; for such relief as is fair, just, and equitable; and for a. (1) l-x I compensatory damag

ALT ZHANG, et al. vs INABEL (Page 4): PLD-P|-001(1) SHORT TITLE: Zhang& Wang v. Inabel CASE NUMBER: lst GAUSE OF ACTION-Motor Vehicle (number) ATTACHMENT TO lJ_l Complaint E Cross - Complaint (Use a separate cause of action form for each cause of action.) Plaintiff (name): LONGZHE ZHANG and JIALU WANG MV- 1, Plaintiff alleges the acts of defendants were negligent; the acts were the legal (proximate) cause of injuries and damages to plaintiff; the acts occurred on (date): 0212012024 at (place): Union City, CA MV- 2. DEFENDANTS a. [7] ffre defendants who operated a motor vehicle are (names): A Does I to 100 b. I I I fne defendants who employed the persons who operated a motor vehicle in the course of their employment are (names): A Does I to 100 c. I y I fne defendants who owned the motor vehicle which was operated with their permission are (names): A Does I to 100 d. I y I ffre defendants who entrusted the motor rehicle are (names): A Does I to 100 e. [7] tne defendants who were the agents

ALT HODGES, AN INDIVIDUAL vs THE PERMANENTE MEDICAL GROUP, INC., A CALIFORNIA CORPORATION, (Page 1): {HM00056378 } - 1 - HODGES V. THE PERMANENTE MEDICAL GROUP, INC. COMPLAINT EQUAL RIGHTS LAW GROUP 1900 Avenue of the Stars, Suite 900 Los Angeles, CA 90067 Telephone: (310) 526-7229 Mika Hilaire, Esq. (SBN: 212263) Chloe Banker, Esq. (SBN: 345710) Clavey Robertson, Esq. (SBN: 358764) EQUAL RIGHTS LAW GROUP 1900 Avenue of the Stars, Suite 900 Los Angeles, CA 90067 Telephone and Fax: (310) 526-7229 [email protected] [email protected] [email protected] Attorneys for Plaintiff, RAMONA HODGES SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ALAMEDA RAMONA HODGES, an individual, Plaintiff, v. THE PERMANENTE MEDICAL GROUP, INC., a California corporation, and DOES 1 through 25, inclusive, Defendants. CASE NO.: COMPLAINT FOR: 1. DISCRIMINATION ON THE BASIS OF RACE IN VIOLATION OF FEHA; 2. RETALIATION IN VIOLATION OF FEHA; 3. FAILURE TO PREVENT DISC

ALT HODGES, AN INDIVIDUAL vs THE PERMANENTE MEDICAL GROUP, INC., A CALIFORNIA CORPORATION, (Page 2): {HM00056378 } - 2 - HODGES V. THE PERMANENTE MEDICAL GROUP, INC. COMPLAINT EQUAL RIGHTS LAW GROUP 1900 Avenue of the Stars, Suite 900 Los Angeles, CA 90067 Telephone: (310) 526-7229 INTRODUCTION 1. Plaintiff began her employment as a “Specialist 2” at Defendant Kaiser in July 2002. For more than a decade, Plaintiff worked without incident. In or about 2015, Catherine Ghant became Plaintiff’s manager. Ghant increasingly assigned Black employees, including Plaintiff, extra work and more difficult tasks. Ghant also applied extreme scrutiny to Black employees, singling them out for dress code violations and writing them up for minor violations which non-Black employees were not written up for. Plaintiff complained regarding the increased workflow and made numerous informal complaints to Ghant about her discriminatory assignment practices, but ultimately was forced to transfer and accept a

ALT HODGES, AN INDIVIDUAL vs THE PERMANENTE MEDICAL GROUP, INC., A CALIFORNIA CORPORATION, (Page 3): {HM00056378 } - 3 - HODGES V. THE PERMANENTE MEDICAL GROUP, INC. COMPLAINT EQUAL RIGHTS LAW GROUP 1900 Avenue of the Stars, Suite 900 Los Angeles, CA 90067 Telephone: (310) 526-7229 suffered by Plaintiff and for damages proximately caused by the conduct of each such Defendants as herein alleged. 6. Plaintiff is informed, believes, and based thereon alleges, that at all times relevant for purposes of this Complaint, the Defendants designated herein as DOES 1 through 25 inclusive, acted as the agents, employees, directors, officers, joint venturers and/or partners of the named Defendants and such fictitiously-named Defendants. Each of them, while acting in the course and scope of their agency, employment, corporate capacities, and partnership, performed the acts and conduct herein alleged, and said acts and conduct were ratified and approved by each Defendant. 7. Plaintiff is informed,

ALT HODGES, AN INDIVIDUAL vs THE PERMANENTE MEDICAL GROUP, INC., A CALIFORNIA CORPORATION, (Page 4): {HM00056378 } - 4 - HODGES V. THE PERMANENTE MEDICAL GROUP, INC. COMPLAINT EQUAL RIGHTS LAW GROUP 1900 Avenue of the Stars, Suite 900 Los Angeles, CA 90067 Telephone: (310) 526-7229 this judicial district. 12. Venue is proper in ALAMEDA County because the alleged unlawful actions complained of herein occurred in ALAMEDA County. 13. As required by law, Plaintiff timely filed a charge of discrimination with the California Civil Rights Department (“CRD”), which issued a Notice of Case Closure and Right to Sue for all state law discrimination claims alleged herein. Attached hereto as Exhibit A is a copy of the Notice of Case Closure and Right to Sue. 14. This suit is brought within one year of Plaintiff’s “Right to Sue” letter. FACTUAL ALLEGATIONS 15. Plaintiff began her employment at Defendant on or about July 15, 2002 as a Batch Clerk in the Business Office. Plaintiff demonstrated excell

ALT TJAJA vs DEL ROSARIO (Page 1): Form Approved for Optional Use Judicial Council of California PLD-PI-001 [Rev. January 1, 2024] COMPLAINT—Personal Injury, Property Damage, Wrongful Death Code of Civil Procedure, § 425.12 www.courts.ca.gov PLD-PI-001 FOR COURT USE ONLY CASE NUMBER: SUPERIOR COURT OF CALIFORNIA, COUNTY OF STREET ADDRESS: MAILING ADDRESS: CITY AND ZIP CODE: BRANCH NAME: ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: NAME: FIRM NAME: STREET ADDRESS: CITY: STATE: ZIP CODE: TELEPHONE NO.: FAX NO.: EMAIL ADDRESS: ATTORNEY FOR (name): PLAINTIFF: DEFENDANT: DOES 1 TO COMPLAINT—Personal Injury, Property Damage, Wrongful Death AMENDED (Number): Type (check all that apply): MOTOR VEHICLE OTHER (specify): Property Damage Personal Injury Wrongful Death Other Damages (specify): Jurisdiction (check all that apply): ACTION IS A LIMITED CIVIL CASE (does not exceed $35,000) Amount demanded does not exceed $10,000 exceeds $10,000 ACTION IS AN UNLIMITED CIVIL CASE (exceeds $35,000)

ALT TJAJA vs DEL ROSARIO (Page 2): PLD-PI-001 [Rev. January 1, 2024] COMPLAINT—Personal Injury, Property Damage, Wrongful Death Page 2 of 3 PLD-PI-001 SHORT TITLE: CASE NUMBER: Plaintiff (name): is doing business under the fictitious name (specify): and has complied with the fictitious business name laws. 4. 5. Each defendant named above is a natural person a. except defendant (name): (1) a business organization, form unknown. (2) a corporation. (3) an unincorporated entity (describe): (4) a public entity (describe): (5) other (specify): b. except defendant (name): (1) a business organization, form unknown. (2) a corporation. (3) an unincorporated entity (describe): (4) a public entity (describe): (5) other (specify): c. except defendant (name): (1) a business organization, form unknown. (2) a corporation. (3) an unincorporated entity

ALT TJAJA vs DEL ROSARIO (Page 3): PLD-PI-001 [Rev. January 1, 2024] COMPLAINT—Personal Injury, Property Damage, Wrongful Death Page 3 of 3 PLD-PI-001 SHORT TITLE: CASE NUMBER: 10. The following causes of action are attached and the statements above apply to each (each complaint must have one or more causes of action attached): a. Motor Vehicle b. General Negligence c. Intentional Tort d. Products Liability e. Premises Liability f. Other (specify): 11. Plaintiff has suffered (check all that apply) a. wage loss. b. loss of use of property. c. hospital and medical expenses. d. general damage. e. property damage. f. loss of earning capacity. g. other damage (specify): 12. The damages claimed for wrongful death and the relationships of plaintiff to the deceased are a. listed in Attachment 12. b. as follows: 13. The relief sought in this complaint is within the jurisdiction of this court. 14. Plaintiff prays for judgment for costs of suit; for such relief as is

ALT TJAJA vs DEL ROSARIO (Page 4): www.courts.ca.gov Form Approved for Optional Use Judicial Council of California PLD-PI-001(1) [Rev. January 1, 2007] CAUSE OF ACTION—Motor Vehicle Code of Civil Procedure 425.12 PLD-PI-001(1) SHORT TITLE: CASE NUMBER: CAUSE OF ACTION—Motor Vehicle (number) Complaint Cross - Complaint ATTACHMENT TO (Use a separate cause of action form for each cause of action.) Plaintiff (name): MV- 1.Plaintiff alleges the acts of defendants were negligent; the acts were the legal (proximate) cause of injuries and damages to plaintiff; the acts occurred on (date): at (place): MV- 2.DEFENDANTS a. The defendants who operated a motor vehicle are (names): Does to b. The defendants who employed the persons who operated a motor vehicle in the course of their employment are (names): Does to c. The defendants who owned the motor vehicle which was operated with their permission are

ALT SIERRA ROOFING AND SOLAR, INC., vs YATES,, et al. (Page 1): PLAINTIFF SIERRA ROOFNG’S COMPLAINT Gerald K. Carroll, State Bar No. 142054 CARROLL LAW OFFICES 11007 Caloden St. Oakland, CA 94605 415-407-1290 [email protected] Attorneys for Plaintiff Sierra Roofing and Solar, Inc. SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ALAMEDA UNLIMITED JURISDICTION SIERRA ROOFING AND SOLAR, INC., a California corporation, Plaintiff, vs. LOLITA YATES, an individual, EYES ON YOU DAYCARE CENTER, LLC, a California corporation, and DOES 1-10, inclusive, Defendants. CASE NO. PLAINTIFF’S COMPLAINT FOR DAMAGES AGAINST DEFENDANTS (1) BREACH OF CONTRACT; (2) FORECLOSURE OF MECHANICS’ LIEN; (3) COMMON COUNT—FOR WORK, LABOR & SERVICES; (4) COMMON COUNT—FOR MONEY/QUANTUM MERUIT; AND (5) COMMON COUNT—FOR RESTITUTION/UNJUST ENRICHMENT Plaintiff SIERRA ROOFING AND SOLAR, INC. (identified herein as “Sierra” or “Plaintiff”), alleges as follows: THE PARTIES 1. Plaintiff is a corporation, organized an

ALT SIERRA ROOFING AND SOLAR, INC., vs YATES,, et al. (Page 2): PLAINTIFF SIERRA ROOFING’S COMPLAINT 3. Lolita Yates (referred to herein as “Yates” or “Defendant”) is, and at all times relevant to this Complaint was, an individual residing in Hayward, Alameda County. 4. Plaintiff is informed, believes and on that basis alleges that Yates has an ownership interest in the real property located at 21753 Vallejo Street, Hayward, California, 94541 (the “Property”). 5. Eyes on You Daycare Center, LLC (“Daycare”) is a California corporation with its principal place of business at the Property. Plaintiff is informed, believes and on that basis alleges that Daycare has an ownership interest in the Property. 6. Defendants DOES 1-10, inclusive, are sued herein under fictitious names. Their true names and capacities are unknown to Plaintiff. When their true name and capacities are ascertained, Plaintiff will amend this Complaint by inserting their names and capacities herein. Plaintiff is informed

ALT SIERRA ROOFING AND SOLAR, INC., vs YATES,, et al. (Page 3): PLAINTIFF SIERRA ROOFING’S COMPLAINT FIRST CAUSE OF ACTION (Breach of Contract) 10. Plaintiff re-alleges and reincorporates by this reference each and every allegation contained in all preceding paragraphs as though such allegations are fully set forth herein. 11. Plaintiff contracted with Defendants for roof repairs and the installation of solar at the Property. Under those contracts, Plaintiff was to furnish all necessary labor, services, materials and equipment to be used for the project. Defendants agreed to pay Plaintiff for the cost to furnish and install new gutters. 12. Although Plaintiff has completed its work at the Property, and demand has been made since the work was performed and all necessary services, materials and equipment were furnished, Defendant has not paid any of the amount owed. 13. Defendants have asserted no offsets. The contract between Plaintiff and Defendants contains an attorney’s fees provis

ALT SIERRA ROOFING AND SOLAR, INC., vs YATES,, et al. (Page 4): PLAINTIFF SIERRA ROOFING’S COMPLAINT of lien, to be established according to proof. THIRD CAUSE OF ACTION (Common Count—For Work, Labor and Services) 18. Plaintiff re-alleges and reincorporates by this reference each and every allegation contained in all preceding paragraphs as though such allegations are fully set forth herein. 19. After Plaintiff completed its work at the Property, Defendants became indebted to Plaintiff in an agreed-upon sum for work, labor, services and/or equipment provided or performed by Plaintiff at the Property on behalf of Defendants according to their contract. 20. Since the completion of its work, Plaintiff has demanded payment of the agreed- upon sums from Defendants, but Defendants have failed and refused to pay the sum owed. FOURTH CAUSE OF ACTION (Common Count -- For Money; Quantum Meruit) 21. Plaintiff re-alleges and reincorporates by this reference each and every allegation contained in all

ALT JACOBS, AN INDIVIDUAL vs ALTA BATES SUMMIT MEDICAL CENTER, AN UNKNOWN ENTITY, et al. (Page 1): X X X X ALTA BATES SUMMIT MEDICAL CENTER, an unknown entity; (Additional Parties Attachment form is attached) DOWNTOWN LA LAW GROUP Anthony Werbin, Esq. 285684 (877) 389-2775 (213) 389-3765 [email protected] TAMARA JACOBS ALAMEDA General Negligence Premises Liability TAMARA JACOBS, an individual. TAMARA JACOBS, an individual. 90013 CA Los Angeles 540 S Santa Fe Ave. ALTA BATES SUMMIT MEDICAL CENTER, an unknown entity; (Additional Parties Attachment form is attached) 2233 Shore Line Drive 2233 Shore Line Drive Alameda, CA 94501 Alameda - George E. McDonald Hall of Justice

ALT JACOBS, AN INDIVIDUAL vs ALTA BATES SUMMIT MEDICAL CENTER, AN UNKNOWN ENTITY, et al. (Page 2): COMPLAINT - ATTACHMENT PAGE (Additional Parties Attachment form is attached) DEFENDANT: SUTTER BAY HOSPITALS, a California corporation; and DOES 1-50, inclusive. TAMARA JACOBS vs. ALTA BATES SUMMIT MEDICAL CENTER, et. al. COMPLAINT - ATTACHMENT PAGE (Additional Parties Attachment form is attached)

ALT JACOBS, AN INDIVIDUAL vs ALTA BATES SUMMIT MEDICAL CENTER, AN UNKNOWN ENTITY, et al. (Page 3): X X X X X X X TAMARA JACOBS vs. ALTA BATES SUMMIT MEDICAL CENTER, et. al. 1-50 1-50 ALTA BATES SUMMIT MEDICAL CENTER SUTTER BAY HOSPITALS

ALT JACOBS, AN INDIVIDUAL vs ALTA BATES SUMMIT MEDICAL CENTER, AN UNKNOWN ENTITY, et al. (Page 4): X X X X X X X X X X X TAMARA JACOBS vs. ALTA BATES SUMMIT MEDICAL CENTER, et. al. Prejudgment interest and interest on damages including but not limited to under Civil Code Sections 3287, 3288, 3291 and/or as allowed by law, common law or otherwise. Other damages, including loss of profits and special damages, unknown at this time which Plaintiff will prove at time of trial. Anthony Werbin, Esq. 2/13/2026

ALT BOYNTON vs GUILLEN, et al. (Page 1): PLD-PI-001 ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER 265069 NAME: Jon-Paul Moorehead, Esq. FIRM NAME: Law Offices of Richard W. Meier STREET ADDRESS. 11 Embarcadero West, Suite 133 CITY Oakland STATE CA ZIP CODE 94607 TELEPHONE NO.: (510) 834-3600 FAX NO.. 510-834-2648 EMAIL ADDRESS. [email protected] ATTORNEY FOR (name) Plaintiff Arielle Boynton FOR COURT USE ONLY SUPERIOR COURT OF CALIFORNIA, COUNTY OF ALAMEDA STREET ADDRESS: 1225 Fallon Street MAILING ADDRESS: CITY AND ZIP CODE: Oakland 94612 BRANCH NAME Rene C. Davidson Courthouse PLAINTIFF: DEFENDANT: Arielle Boynton Oralia Gaytan Guillen; Fernando Gaytan Magana; and DOES 1 TO 50 , inclusive x COMPLAINT—Personal (Number): all that apply): VEHICLE Property Damage Personal Injury Injury, Property Damage, Wrongful Death CASE NUMBER: AMENDED Type (check MOTOR x OTHER (specify): Wrongful Death x x Other Damages (specify): See # 11 below Jurisdiction (check all that ACTION IS A LI

ALT BOYNTON vs GUILLEN, et al. (Page 2): PLD-PI-001 SHORT TITLE: Boynton v. Guillen, et al. CASE NUMBER. 4. Plaintiff (name): c. except defendant (name): is doing business under the fictitious name (specify): and has complied with the fictitious business name laws. 5. Each defendant named above is a natural person a. except defendant (name): (1) a business organization, form unknown. (1) a business organization, form unknown. (2) (2) a corporation. a corporation. (3) (3) an unincorporated entity (describe): an unincorporated entity (describe): (4) (4) a public entity (describe): a public entity (describe): (5) (5) other (specify): other (specify): d. except defendant (name): b. except defendant (name): (1) (1) a business organization, form unknown. a business organization, form unknown. (2) (2) a corporation. a corporation. (3) an unincorporated entity (describe): (3) an unincorporated entity (describe): (4) (4) a public entity (describe): a public entity (describe): (5) (5) other (specif

ALT BOYNTON vs GUILLEN, et al. (Page 3): PLD-PI-001 SHORT TITLE: Boynton v. Guillen, et al. CASE NUMBER: 10. The following causes of action are attached and the statements above apply to each (each complaint must have one or more causes of action attached): a. b. c. d. e. f. x Motor Vehicle General Negligence Intentional Tort Products Liability Premises Liability Other (specify): 11. Plaintiff has suffered (check all that apply) 12. a. b. c. d. e. f. g. a. b. x x x x x x x wage loss, loss of use of property. hospital and medical expenses. general damage. property damage. loss of earning capacity. other damage (specify): Economic Damages; Pain and Suffering; Loss/Diminishment of Life Activities; Interest; Costs The damages claimed for wrongful death and the relationships of plaintiff to the deceased are listed in Attachment 12. as follows: 13. The relief sought in this complaint is within the jurisdiction of this court. 14. Plaintiff prays for judgment for costs of suit; for such relief

ALT BOYNTON vs GUILLEN, et al. (Page 4): PLD-PI-001 (1 ) SHORT TITLE: Boynton v. Guillen, et al. CASE NUMBER: FIRST CAUSE OF ACTION—Motor Vehicle (number) ATTACHMENT TO x Complaint Cross - Complaint (Use a separate cause of action form for each cause of action.) Plaintiff (name): Arielle Boynton MV- 1. Plaintiff alleges the acts of defendants were negligent; the acts were the legal (proximate) cause of injuries and damages to plaintiff; the acts occurred on (date): February 16, 2024 at (place): or about 21236 Garden Avenue, in Hayward, CA 94541. MV- 2. DEFENDANTS a. b. x The defendants who operated a motor vehicle are (names): Oralia Gaytan Guillen; Fernando Gaytan Magana; and x Does 1 to 50 The defendants who employed the persons who operated a motor vehicle in the course of their employment are (names): Does 1 to 50 c. I x I The defendants who owned the motor vehicle which was operated with their permission are (names): Oralia Gaytan Guillen; Fernando Gaytan Magana; and rirl Does 1 t