17-

Ronald Jason Palmieri. SBN 96953

Robert P. Wargo, SBN 175177
FILED
LOS ANGELES SUPERIOR COURT

MAR 242004
J./b

2 LAW OFFICES OF RONALD JASON PALMIERI

911 Linda Flora Drive
3 Los Angeles, California 90049
Tel: (310)471-188\
4 Fax: (310)471-3511

5 Attorneys for Plaintiffs ABC Escrow, Inc.,

and Alcohol Enterprises, Inc.
6 C.;fECT: .:,.;; . ::~~
....,... ~ 5L'::':;;;';:'.J ~.l'
,-, >"~ ". '
tJ.JU-;;<._H
J.... -.-.Il
J
C,'3,: ,

~(;r\ 4:::;; J
7
,l:..l'- ~,:,;~:';
8
SUPERIOR COURT FOR THE STATE OF CAffiIij?gWiiMINT OF THE DRIGINAL
9
FOR THE COUNTY OF LOS ANGELES
10

II
ABC ESCROW, TNC., a California
corporation; ALCOHOL ENTERPRISES,
)
)
CASE NO. 8 C3 12678
TNC., a California corporation ) COMPLATNT FOR:
12 )
Plaintiffs ) 1. Breach of Contract
13 ) 2. Intentional Interference with Prospective
v. ) Economic Advantage
14 MICHAEL STETNHAUER, an individual, ) 3. Slander
and Does 1 through 10, inclusive )
15 ) UNLIMITED CIVIL CASE
Defendants. )
16 )
Plaintiffs ABC Escrow, Inc., and Alcohol Enterprises, Inc., allege as follows:
17
GENERAL ALLEGATIONS
18
I. Plaintiff ABC Escrow, Inc., is a California corporation qualitied to transact business in
19
this state, with its principal place of business in Pacific Palisades, CA.
20
2. Plaintiff Alcohol Enterprises, Inc., is a California corporation qualitled to transact
21
business in this state, with its principal place of business in Pacitlc Palisades, CA.
22
3. Defendant Michael Steinhauer is an individual residing in Los Angeles, CA.
')'
-j

4. Plaintiff is informed and believes and thereon alleges that the true names and capacities
24
of Does I through 10, whether individual, corporate, partnership, associate, or otherwise,
25
:i are unknown to Plaintiff, who therefore sues said Defendants, and each of them, by such
26 ;,"
fictitious names. Plainti 1'1' will seek leave of Court to amend this Complaint to show their
27
true names and capacities when the same have been ascertained. Plaintiff is informed and
28
Page I
ij COMPLAINT
!:.

ORIGINAL

bel ieve and thereon alleges that each Defendant designated herein as a Doe was
")
~ responsible in some manner for the events and happenings referred to in this Complaint,

3 proximately causing the injuries and damages to Plaintiff:

4 FIRST CAUSE OF ACTION

(For Breach of Contract against all Defendants)
5
5. Plaintiffs incorporate by reference paragraphs 1 through 4 as though fully set forth hereat.
6
6. Plaintiffs are related companies engaged in the business of acting as a third party finder
7
and providing consulting and escrow services in connection with the sale, purchase and
8
transfer of alcoholic beverage licenses in California and throughout the United States.
9
7. On or about August 20. 200 l, Plaintiffs and Defendant Steinhauer entered into a written
10
Employment Agreement whereby Plaintiffs agreed to employ Defendant as an at will
11
employee in the position of Sales/Customer Service Representative, on the terms and
12
conditions set forth in the Agreement, a copy of which is attached hereto as Exhibit "A."
13
8. Paragraph 10.4 of the Employment Agreement states that "during his ... employment and
14
for a period of two (2) years following the discharge, resignation or temlination of
15
[Defendant] or the tennination of this Agreement, [Defendant] shall not directly or
16
indirectly use any [of Plaintiffs'] Confidential Information to call on, solicit, take away,
17
or attempt to call on. solicit or take away, either for [Defendant] or for any other person.
18
timl, corporation or entity the company's clients, customers and employees."
19
9. "Confidentiallnfonnation" is defined in Paragraph 10.1 of the Employment Agreement to
20
include: (I) the name, address or telephone number of clients or customers; (2)
21
infonnation obtained from customers or clients; (3) costs incurred by the Company in
22
acquiring licenses; (4) fees charged clients or customers for services; and (5) procedures
23
utilized by the Company in acquiring licenses on behalf of clients.
24
10. Paragraph 10.5 of the Employment Agreement states that "no adequate remedy at law
25
may exist for any violation of Sections 10.1-10.4 of this Agreement and that in the case of
26
any breach. a restraining order or injunction may be issued in addition to any other rights
27
or remedies, including damages, which may be appropriate."
28
Page 2.
':1
ii' COMPLAINT
.'.~
 11.

Paragraph 11.9 of the Employment Agreement states that "in the event of any litigation

2 between or among the parties hereto respecting or arising out of this Agreement, the

3 prevailing party or parties shall be entitled to recover reasonable attorneys' fees and costs,

4 whether or not such litigation proceeds to tinal judgment or determination."

5 12. PlaintitTs terminated Defendant's employment on March 5, 2004, due to company

6 reorganization.

7 13. As of that date, Defendant Steinhauer knew that Plaintiffs had recently brokered the sale

8 ofa liquor license to Safeway, one of Plaintiffs' longtime clients, for the sum of

9 $200,000.

10 [4. Plaintiffs are intornled and believe, and thereupon allege, that Defendant Steinhauer also

II knew that Plaintiffs were then in the midst of negotiations with Safeway for the potential

12 sale of another liquor license for the sum of$210,000.

13 15. On March 11,2004, Defendant Steinhauer twice telephoned Jan Martin, a vice president

14 of Safeway, who was Plaintiffs' principal contact with the company.

15 16. During the t1rst conversation, Steinhauer identitled himself only as "Mike" to Ms. Martin

16 and stated to her that he had a liquor license available for sale to Safeway for the sum of

17 $180,000.

18 17. Ms. Martin thereafter contacted Craig Block, an ofticer of both Plaintiffs, and infonned

19 that she had been contacted by someone named "Mike" calling from the 323 area code

20 and offering her the liquor license.

21 18. Mr. Block suspected that "Mike" was Plaintiffs recently ternlinated employee, Defendant

22 Steinhauer, and that the license he was attempting to sell her was a license he was

negotiating for from a potential seller when he was terminated from his employment by

24 Plaintiffs. Mr. Block requested that Ms. Martin contact "Mike" to make further inquiry

25 regarding his identity and the potential seller.

26 "':!19. Ms. Martin subsequently spoke with "Mike" and he confirmed to her that he was, in fact,

27 Defendant Steinhauer. He thereafter advised Ms. Martin that the reason that he was

28
Page 3
COMPLAINT

calling her was so that Safeway could avoid being "gouged" with respect to this

transaction because Plaintiffs always gouged their clients. Steinhauer also stated that he

3 would not be making any money from the transaction and that would have the seller of

4 the license contact Ms. Martin directly.

5 20. The potential seller contacted Ms. Martin directly, and Safeway and the seller tentatively

6 have entered into an agreement whereby Safeway has agreed to purchase the liquor

7 Iicense directly from the seller for approximately $180,000.00, or approximately $30,000

8 less than the amount which Safeway tentatively had agreed to pay to Plaintiffs for

9 acquiring the license.

10 21. Had Defendant Steinhauer not utilized Plaintiffs' confidential infonnation and interfered

II with Plaintifls' potential brokering of the sale of this liquor license to Safeway, Plaintiffs

12 would have earned approximately $90,000 from the sale.

13 Defendant's wrongful conduct. as set forth above, constituted a breach of his employment

14 contract in that he agreed not "to call on, solicit, take away, or attempt to call on, solicit

15 or take away, either for [Defendant] or for any other person, finn, corporation or entity

16 the company's clients, customers and employees."

17 23. Defendant's wrongful conduct, as set forth hereinabove, has caused Plaintiffs to sutTer

18 damages in the amount of $90,000.00, and unless and until enjoined by Order of this

19 Court, Defendant's conduct shall continue to cause irreparable injury to PlaintiftS,

20 including, but not limited to lost profits and damage to its customer goodwill.

21 24. Plaintiffs are further infonned and believe, and thereon allege, that Defendant intends to

22 continue his course of wrongful conduct by contacting other of Plaintiffs' clients and

23 customers. in retaliation for Plaintiffs' lawful tennination of Defendant Steinhauer's

24 employment.

25 25. Plaintiffs have no adequate remedy at law inasmuch as monetary damages cannot
j"j
,..
26 compensate for damage to its customer goodwill and damages for loss of profits may not
,.
27 be quantifiable.

28
Page 4
I:; COMPLAINT
:~ I
 26.

Based upon the foregoing, Plaintiffs are entitled to a Temporary Restraining Order, OSC

2 Re Preliminary Injunction, Preliminary Injunction and Permanent Injunction as prayed for

3 herein restraining Defendant Steinhauer from the following: Communicating with, calling

4 on, soliciting, taking away, or attempting to communicate, call on, solicit or take away,

5 either for Defendant, or for any other person, tirm, corporation or entity, any of PlaintilTs'

6 clients, customers and employees.

7 SECOND CAUSE OF ACTION

(For Intentional Interference with Prospective Economic Advantage Against all Defendants)
8
27. Plaintiffs incorporate by reference paragraphs I through 26 as though fully set forth
9
hereat.
10
28. In engaging in the above-described conduct, Defendant Steinhauer intended to interfere
I1
with PlaintitTs' prospective economic advantage by depriving them of the profits they
12
would have earned from successfully brokering the sale of the liquor license to Safeway.
13
29. Defendant Steinhauer's conduct was wilful, wanton, and malicious, done with conscious
14
disregard for Plaintiffs' rights and with the intent to vex, annoy and harass Plaintiffs. As
15
such, an award of exemplary damages against Defendants, and each of them, is justified
16
and appropriate.
17
30. Defendant's wrongful conduct, as set forth hereinabove, has caused Plaintiffs to suffer
18
damages in the amount of $90,000.00, and unless and until enjoined by Order of this
19
Court, Defendant's conduct shall continue to cause irreparable injury to Plaintiffs,
20
including, but not limited to lost profits and damage to its customer goodwill.
21
31. Plaintiffs are further informed and believe, and thereon allege, that Defendant intends to
22
continue his course of wrongful conduct by contacting other of Plaintiffs' clients and
23
customers, in retaliation for Plaintiffs' lawful ternlination of Defendant Steinhauer's
24
employment.
25
32. Plainti ffs have no adequate remedy at law inasmuch as monetary damages cannot
26
compensate for damage to its customer goodwill and damages for loss of protits may not
27
be quantifiable.
28
Page 5
=;, COMPLAINT
:'
, ":;
 33.

Based upon the foregoing, Plaintiffs are entitled to a Temporary Restraining Order, OSC
'")
~ Re Preliminary Injunction, Preliminary Injunction and Pemlanent Injunction as prayed for

3 herein restraining Detendant Steinhauer from the following: Communicating with, calling

4 on, soliciting, taking away, or attempting to communicate, call on, solicit or take away,

5 either for Defendant, or for any other person, firm, corporation or entity, any of Plaintiffs'

6 dients, customers and employees.

7 THIRD CAUSE OF ACTION

(For Slander Against all Defendants)
8
34. Plaintiffs incorporate by reference paragraphs I through 26 as though fully set forth
9
hereat.
10
35. As set forth above, Delendant Steinhauer stated to Jan Martin of Safeway that Plaintiffs
II
always "gouged" their dients.
12
36. This statement was false, and known by Defendant to be false, and had a tendency to
13
injure Plaintiffs with respect to their trade or business because the statement imputes
14
dishonesty or a lack of ethics to Plaintiffs.
15
37. Defendant Steinhauer made this statement with actual malice towards Plaintiffs and in
16
retaliation for Plaintiffs' lawful termination of Defendant Steinhauer's employment. As
17
such, in addition to special and general damages, an award of exemplary damages against
18
Defendants, and each of them, is justified and appropriate.
19
Whereas, Plaintiffs prays for judgment against Defendants, as follows:
20
I. On the First Cause of Action
21
a. For general and compensatory damages in the minimum principal amount of
'")'")
~-

$90,000.00, according to proof at trial.

23
b. A Temporary Restraining Order, OSC Re Preliminary Injunction, Preliminary
24
Injunction and Permanent Injunction as prayed for herein restraining Defendant
25 .
Steinhauer from the following: Communicating with, calling on, soliciting, taking
26
away, or attempting to communicate, call on, solicit or take away, either for
27
Detendant, or for any other person, firm, corporation or entity, any of PlaintitTs'
28
Page 6
'i COMPLAINT
';1

clients, customers and employees.

2 2. On the Second Cause of Action

3 a. For general and compensatory damages in the minimum principal amount of

4 $90,000.00, according to proof at trial.

5 b. For punitive damages in an amount to be demonstrated at trial.

6 c. A Temporary Restraining Order, OSC Re Preliminary Injunction, Preliminary

7 Injunction and Pemlanent Injunction as prayed for herein restraining Defendant

8 Steinhauer trom the following: Communicating with, calling on, soliciting, taking

9 away, or attempting to communicate, call on, solicit or take away, either for

10 Defendant, or for any other person, lirnl, corporation or entity, any of Plaintiffs'

II clients, customers and employees.

12 3. On the Third Cause of Action

13 a. For general and compensatory damages in an amount to be demonstrated at trial.

14 b. For punitive damages in an amount to be demonstrated at trial.

15 4. On All Causes of Action:

16 a. For attorneys' fees and costs and for such other and further relief as the Court

17 deems just and proper.

18
19 DATE: March 23, 2004

20
21
22
23

24
25
26
27

28
:" I Page 7
'I,J
:i=1 COMPLAINT
"1
.03/23/2004 TL~ 14:23 FAX 3~59 3688 ABC ESCROW \ LLS .
~002/002

1 ~~cm~

2 I have read the furegoing Complaint and know its controts.

J I am 11 pllIty to this action. The matters stated in the foregoing document are true of my

4 own knowledge except as to those matters which are stated on information and belief, and as 10
5 those: matters I believe them to be true.
6 I declare under penalty of perjury under the laws of the State of California that the
7 foregoing is true and oorrect.
8 Executed on March 23, 2004, at Los Angdes. C
9

10
11 C Escrow, Inc., and Alcohol
c.
12
13
14

15
16

17
18
19

20
21
22
23
24
25
26
:(;
.';'27
'I,
.J

.:28
./ PageS
!~ :j. COMPLAINT
i
~\:!
(

60/60 39\1d

CM-010
ATTORNEY OR PARTY WITHOUT ATIORNEY (Name. s rnumbe~andaddres~: FOR COURT USE ONLY
Ronald Jason Palmieri, SBN 96953
-Robert P. Wargo, SBN 175177
LAW OFFICES OF RONALD JASON PALMIERI
911 Linda Flora Drive
Los Angeles, CA
TELEPHONE NO.:
90049
310-471-1881 FAX NO.: 310-471-3511
LO
FlIt!1? C~lm
ANGELES
ATTORNEY FOR !Name): ABC Escrow Inc. and Alcohol Enternrises MAR 2 4: 'lOO4
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Los Angeles
STREET ADDRESS: I I I N. Hill Street CLARKE CLE\-\I<
MAILING ADDRESS: 111 N. Hill Street JOHN A, '
CITY ANOZIP CODE: Los Angeles,
BRANCH NAME:
CASE NAME:
Central
CA 90012-3117

ABC Escrow, et al. , v. Steinhauer

BY . 'G~:~UTY
Complex Case Designation CASE NUMBER:
CIVIL CASE COVER SHEET
[K] Unlimited o Limited 0 Counter o
Joinder BC31267B
(Amount (Amount Filed with first appearance by defendant JUDGE:
demanded demanded IS
exceeds $25,000\$25 000 or less' (Cal. Rules of Court, rule 1811) DEPT.:
All five (5) items be/ow must be completed (see instructions on page 2).
1. Check one box below for the case type that best describes this case:
Auto Tort Contract Provisionally Complex Civil litigation
OAuto(22) [K] Breach of contracVwarranty (06) (Cal. Rules of Court, rules 1800-1812)
o Uninsured motorist (46) o
Collections (09) o
AntitrusVTrade regulation (03)
Other PIIPDIWD (Personal Injury/Property o
Insurance coverage (18) o
Construction defect (10)
DamagelWrongful Death) Tort
o o Other contract (37) o Mass tort (40)

o
Asbestos (04)
Real Property o Securities litigation (28)

o
Product liability (24)
~ Eminent domain/Inverse o EnvironmentalfToxic tort (30)
Medical malpractice (45) condemnation (14) CJ Insurance coverage claims arising from the
o Other PIIPDIWD (23)
o Wrongful eviction (33)
above listed provisionally complex case
types (41)
Non-PI/PDIWD (Other) Tort
o Business tort/unfair business practice (07)
o Other real property (26)
Enforcement of Judgment
o Civil rights (08) Unlawful Detainer o Enforcement of judgment (20)
o Defamation (13) o Commercial (31)
o Fraud (16) o Residential (32) Miscellaneous Civil Complaint
o
o Intellectual property (19) o Drugs (38) o
RICO (27)
Otller complaint (not speciffed above) (42)
Judicial Review
D Professional negligence (25)
o Olher non-PI/PDIWD tort (35)
o Asset forfeiture (05) Miscellaneous Civil Petition
CJ Petition re: arbitration award (11) CJ Partnership and corporate governance (21)
Employment
CJ Wrongful termination (36) o Writ of mandate (02) o Other petition (not speciffed above) (43)

o Other employment (15) o Other judicial review (39)

2. ThiS case is 0 [K] is not complex under rule 1800 of the California Rules of Court. If case is complex, mark the factors
requiring exceptional judicial management:
a. 0Large number of separately represented parties d. o Large number of witnesses
b. 0Extensive motion practice raising difficult or novel e. o Coordination with related actions pending in one or more courts
issues that will be time-consuming to resolve in other counties, states or countries, or in a federal court
c. 0Substantial amount of documentary evidence f. 0 Substantial post-judgment judicial supervision
3. Type of remedies sought (check all that apply):
a. I x I monetary b. [K] nonmonetary; deciaratory or injunctive relief c. [K] punitive
4. Number of causes of action (specify): 3
5. This case 0 is I x I is not a ciass action suit.
Date:
Robert P. Wargo, SBN 175177

" NOTICE
Plai~tiff must file this cover sheet with the first paper filed in the action or proceeding (except smali claims cases or cases filed
undllr the Probate, Family, or Welfare and Institutions Code). (Cal. Rules of Court. rule 201.8.) Failure to file may result in
sant;:tions.
Fih"',lhis cover sheet in addition to any cover sheet required by local court ruie.
If thi~ case is complex under rule 1800 et seq. of the California Rules of Court, you must serve a copy of this cover sheet on all
othe~ parties to the action or proceeding.
Un!"" s this is a com lex case this cover sheet shall be used for statistical ur oses ani . Page 1 of 2

O~~(jiClaICou:~il or~::~~ro7niil5e CIVIL CASE COVER SHEET Legal a\l~n~~~Sof"'J~d~i:~Ad~n;Slra!lO~, 1L~

eM-Ol0 [Rev. July 1, 200'3J Solutigns'
lGl,P1us
ORIGil\JhL
 INSTRUCTIOtit ON HOW TO COMPLETE THE
To Plaintiffs and Others Filing First Papers
AER SHEET

If you are filing a first paper (for example, a complaint) in a civil case, you must complete and file, along with your first paper, the Civil
Case Cover Sheet contained on page 1, This information will be used to compile statistics about the types and numbers of cases filed,
You must check all five items on the sheet. In item 1, you must check one box for the case type that best describes the case, If the
case fils both a general and a more specific type of case listed in Item 1, check the more specific one. If the case has mUltiple causes
of action, check the box that best indicates the primary cause of action. To assist you In completing the sheet, examples of the cases
that belong under each case type in item 1 are provided below. A cover sheet must be filed only with your initiai paper. You do not
need to submit a cover sheet with amended papers. Failure to file a cover sheet with the first paper filed in a civil case may subject a
party, its counsel, or both to sanctions under rules 201.8(c) and 227 of the California Rules of Court.
To Parties in Complex Cases
in complex cases only, parties must also use the Civil Case Cover Sheet to designate whether the case is complex. If a plaintiff
believes the case is complex under rule 1800 of the California Rules of Court, this must be indicated by completing the appropriate
boxes in items 1 and 2. If a plaintiff designates a case as complex, the cover sheet must be served with the complaint on all parties to
the action. A defendant may file and serve no later than the time of its first appearance a joinder in the plaintiff's designation, a
counter-designation that the case is not complex, or, if the plaintiff has made no designation, a designation that the case is complex.
CASE TYPES AND EXAMPLES
Auto Tort Contract Provisionally Complex Civil
Auto (22)-Personal Injury/Property Breach of Contracl/Warranty (06) Litigation (Cal. Rules of Court Rule
DamagelWrongful Death Breach of Rental/Lease 1800-1812)
Uninsured Motorist (46) (if the Contract (not unlawful detainer Antitrust/Trade Regulation (03)
case involves an uninsured or wrongful eviction) Construction Defect (10)
motorist claim subject to Contracl/Warranty Breach-Seller Claims Involving Mass Tort (40)
Plaintiff (not fraud or negligence)
arbitration, check this item Securities Litigation (28)
Negligent Breach of Contract/
instead of Auto) Warranty Toxic Tort/Environmental (30)
Other Breach of Contracl/Warranty Insurance Coverage Claims
Other PI/PDIWD (Personal Injury/ Collections (e.g., money owed, open (arising from provisionally
Property DamagelWrongful Death) book accounts) (09) complex case type listed above)
Tort Collection Case-Seller Plaintiff (41)
Asbestos (04) Other Promissory Note/Collections
Asbestos Property Damage Case Enforcement of Judgment
Asbestos Personal injury/ Insurance Coverage (not provisionally Enforcement of JUdgment (20)
Wrongful Death camp/ex) (18) Abstract of Judgment (Out of
Product liability (not asbestos or Auto Subrogation County)
toxic/environmental) (24) Other Coverage Confession of Judgment (non-
Other Contract (37) domestic relations)
Medical Malpractice (45)
Contractual Fraud Sister State Judgment
Medical Malpractice-
Other Contract Dispute Administrative Agency Award
Physicians & Surgeons
(not unpaid taxes)
Other Professional Health Care Real Property Petition/Certification of Entry of
Malpractice Eminent Domainllnverse JUdgment on Unpaid Tax
Other PI/PDIWD (23) Condemnation (14) Other Enforcement of Judgment
Premises Liability (e.g .. slip WrongfUl Eviction (33)
Case
and fall) Other Real Property (e.g., quiet tille) (26)
Intentional Bodily Injury/PDIWD Writ of Possession of Real Property Miscellaneous Civil Complaint
(e.g., assault, vandalism) Mortgage Foreclosure RiCO (27)
Intentionai Infliction of Quiet Tille Other Complaint (not specified
Emotional Distress Other Real Property (not eminent above) (42)
Negligent Infliction of domain, landlordltenant, or Declaratory Relief Only
foreclosure) Injunctive Relief Only (non-
Emotional Distress
Other PI/PDIWD harassment)
Unlawful Detainer Mechanics Lien
Commercial (31) Other Commercial Complaint
NonPI/PDIWD (Other) Tort Residential (32)
Business Tort/Unfair Business Case (fJOn-torVnon-complex)
Drugs (38) (if the case involves illegal Other Civil Complaint
Practice (07)
drugs, check this item; otherwise, (non-tort/non-complex)
Civil Rights (e.g.. discrimination,
report as Commercial or
false arrest) (not civil
Residential) Miscellaneous Civil Petition
harassment) (08) Partnership and Corporate
Defamation (e.g .. slander, libel) Governance (21)
Judicial Review
(13) Other Petition (not specified above)
Asset Forfeiture (05)
Fraud (16) Petition Re: Arbitration Award (11) (43)
in!~lIectual Property (19) Writ of Mandate (02) Civil Harassment
P"lfessional Negiigence (25) Writ-Administrative Mandamus Workplace Vioience
"': Legal Malpractice Writ-Mandamus on Limited Court Elder/Dependent Adult
." Other Professional Malpractice Case Maller Abuse
';'. (not medical or legal) Writ-Other Limited Court Case Election Contest
Ot~er Non-PI/PDIWD Tort (35) Review Petition for Name Change
Other Judicial Review (39) Petition for Relief from Late
Empldyment Review of Health Officer Order Claim
W,pngful Termination (36) Notice of Appeal-Labor Other Civil Petition
Oiher Employment (15) Commissioner Appeals
eM-OlD [Rev. July 1. 20031 Page 2 of 2
CIVIL CASE COVER SHEET
 SHORT"rITlE: ABC Escrow v. Stei auer
BC3!2678
CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION
(CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION)
This form is required in all new civil case filings in the Los Angeles Superior Court
I. Check the types of hearing and fill in the estimated length of hearing expected for this case:
JURY TRIAL? W YES CLASS ACTION? D YES LIMITED CASE? D YES TIME ESTIMATED FOR TRIAL _2_
D
HOURS/WDAYS,
II. Select the correct district and courthouse location (4 steps - If you checked "Limited Case", skip to No. III, Pg. 4):
1 After first 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 1, the Civil Case Cover Sheet case type you selected.
2 Check one Superior Court type of action in Column 2 below which best describes the nature of this case.
3 In Column 3, circle the reason for the court location choice that applies to the type of action you have checked.

Applicable Reasons for Choosing Courthouse Location (See Column 3 below)

1. Class Actions must be filed in the County Courthouse, Central District 6. Location of property or permanently garaged vehicle.
2. May be filed in Central (Other county, or no Bodily Inj/Prop,Damage) 7. Location where petitioner resides.
3. Location where cause of action arose 8. Location wherein defendant/respondent functions wholly.
4. Location where bodily injury, death or damage occurred. 9. Location where one or more of the parties reside.
5. Location where performance required or defendant resides. 10. Location of Labor Commissioner Office.
4 Fill in the information requested on page 4 in item III; complete item IV. Sign the certificate.

-1- -2- -3-

Civil Case Cover Sheet Type of Action Applicable Reasons
Category No, (Check only one) See Step 3 Above

Auto (22) D A7100 Motor Veh. - Pers. Injury/Prop, Dam./Wrongful Death 1.,2.,4.
Uninsured Motorist (46) D A7110 Pers. Inj/Prop. Dam.lWrongful Death Unins. Motorist 1,,2.,4.

Asbestos (04) D A6070 Asbestos Property Damage 2.

D A7221 Asbestosis - Personal InjurylWrongful Death 2.

Product Liability (24) D A7260 Product Liability (not asbestos or toxic/environmental) 1.. 2" 3., 4.. 8.

Medical Malpractice D A7210 Medical Malpractice - Physicians & Surgeons 1.. 2.,4,
(45) D A7240 Other Professional Health Care Malpractice 1.,2.,4,

Other PI/PDIWD (23) D A7250 Premises Liability (e.g., slip and fall) 1.. 2., 4.

D A7230 Intentional Bodily Injury/PDIWD (e.g., assault, vandalism, etc.) 1.,2.. 4.

D A7270 Intentional Infliction of Emotional Distress 1.,2.,3.

D A7271 Negligent Infliction of Emotional Distress 1.,2.. 3.

D A7220 Other Personal Injury/Property Dam.lWrongful Death 1.. 2., 4.

Business Tort (07) D A6029 Other Commercial/Business Tort (not fraud/breach of contract) 1.,2.. 3.

'~" Civil Rights (08) D AS005 Civil RightslDiscrimination 1,,2.,3.

~
Do
Oefamation
,. (13) D A6010 Defamation (slander/libel) 1.,2.,3,
iii: .,
co ".;: Fraud (16) D A6013 Fraud (no contract) 1,,2.,3.
z
..
Intell~tual Property (191 D A6016 Intellectual Property 2.,3.

"'".

': CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION \ H~Cf-.'1U~)\2t
CIV 109 09-03 l:1~el'J''l''\ 0R LA-481
SHORT TITLE: ABC Escrow v. Steinhauer CASE NUMBER

-1- -2- -3-

Civil Case Cover Sheet Type of Action Applicable Reasons
Calegory No. (Check only ono) See Step 3 Above

Prof. Negligence (25) 0 A6017 Legal Malpractice 1.,2.,3.

0 A6050 Other Professional Malpractice (not medical or legal) 1.,2.. 3.

Oth Non-PI/PDIWD Tort 0 A6025 Other Non-PI/PDIVVD Tort -Intentional 2.,3.

(35)
0 A6026 Other NonPI/PDIWD Tort - Negligence 2.,3.

Wrongful Termination
(36) 0 A6037 Wrongful Termination 1.. 2., 3.
Other Employment 0 A6024 Other Employment Complaint Case 1.,2.. 3.
(15)
0 A6109 Labor Commissioner Appeals 10.

Breach of Contract! 0 A6004 Breach of Rental/Lease Contract (not UD or wrongful eviction) 2.,5.
Warranty
(06)
0 A600B ContractlWarranty Breach-Seller Plaintiff (no fraud/negligence) 2.,5.

(not insurance) 0 A6019 Negligent Breach of ContractlWarranty (no fraud) 1.,2.,5.

0 A602B Other Breach of ContractlWarranty (not fraud or negligence) 1.@5.

Collections 0 A6002 Collections Case-Seller Plaintiff 2.. 5.,6.

(09) 0 A6012 Other Promissory Note/Collections Case 2.,5,

Insurance Coverage
(18) 0 A6015 Insurance Coverage (not complex) 1.,2.. 5.. 8.

Other Contract 0 A6009 Contractural Fraud 1.,2.,3.,5.

(37) 0 A6031 Tortious Interference 1.,2.. 3.. 5.
0 A6027 Other Contract Dispute (not breach/insurance/fraud/negligence) 1.,2.. 3., B.

Emnt Dom/lnv. Condo

(14) 0 A7300 Eminent Domain/Condemnation Number of parcels _ _ _ 2.

Wrongful Eviction
(33) 0 A6023 Wrongful Eviction Case 2.. 6.

Other Real Property

0 A601B Mortgage Foreclosure 2.,6.

(26) 0 A6032 Quiet Title 2. ,6.

0 A6060 Other Real Property (not em. domain, landlord/tenant, foreclosure) 2.,6.

Unlawful Detainer -
Commercial (31) 0 A6021 Unlawful Detainer-Commercial (not drugs or wrongful eviction) 2.. 6.

Unlawful Detainer -
Residential (32) 0 A6020 Unlawful Detainer-Residential (not drugs or wrongful eviction) 2.. 6.

Unlawful Detainer -
Drugs (38) 0 A6022 Unlawful Detainer-Drugs 2.,6.

":,
&set Forfeiture (05) 0 A6108 Asset Forfeiture Case 2.. 6.
.'
.'.
Pel~tion re Arbitration (11)
.. 0 A6115 Petition to Compel/Confirm Arbitration 2.,5.

CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION LAse Rule 2.0
CIV 109 09-03 Page 2 of 4
 SHORT TITLE' ABC Escrow v. einhauer I CASE NUMBER

-1- -2- -3-

Civil Case Cover Sheet Type of Action Applicable Reasons
Category No. (Check only one) See Step 3 Above

0 A6151 Writ - Administrative Mandamus 2.,8.

Writ of Mandate
0 A8152 Writ - Mandamus on Limited Court Case Matter 2.
(02)
0 A6153 Writ - Other Limited Court Case Review 2.

Oth. Jud. Review (39) 0 A6150 Other Writ I Judicial Review 2.. 8.

.~
AntitrustfTrade Reg. (03) 0 A6003 AntitrustfTrade Regulation 1.. 2.. 8.

:5
:ll Construction Defect (10) 0 A6007 Construction defect 1.,2. 3.
Q.
E
o Claims Inv. Mass Tort (40 0 A6006 Claims Involving Mass Tort 1.. 2.. 8.
u
~
;;
c 0
...
Securities Litig. (28) A6035 Securities Litigation Case 1.. 2., 8.
.2
;;
e
0..
Tox. TortlEnvronm (3D) 0 A6036 Toxic Tort/Environmental 1. 2.. 3.. 8.

Ins Clms - Complex Case 0 A6014 Insurance Coverage/Subrogation (complex case only) 1.. 2.. 5., 8.
(41)

~
"-"'". 0 A6141 Sister State Judgment 2.. 9.

'5 Enforcement 0 A6160 Abstract of Judgment 2.,6.

..
C
of Judgment
0 A6107 Confession of Judgment (non-domestic relations) 2.,9.

..
E
~
(20)
0 A6140 Administrative Agency Award (not unpaid taxes) 2.,8.
.!2
c 0 A6114 Petition/Certificate for Entry of Judgment on Unpaid Tax 2.. 8.
w
0 A6112 Other Enforcement of Judgment Case 2.. 8., 9.

RICO (27) 0 A6033 Racketeering (RICO) Case 1.,2.,8.

Other Complaints
0 A6030 Declaratory Relief Only 1.,2.,8.

(Not Specified Above) 0 A6040 Injunctive Relief Only (not domestic/harassment) 2.. 8.

0 A6011 Other Commercial Complaint Case (non-tort/non-complex) 1.,2.. 8.

(42)
0 A6000 Other Civil Complaint (non-tort/non-complex) 1.. 2.. 8.

Partnership/Corp.
Governance (21) 0 A6113 Partnership and Corporate Governance Case 2.. 8.

0 A6121 Civil Harassment 2.,3.. 9.

.;; 0 A6123 Workplace Harassment 2.. 3.,9

.' . Other Petitions
<3 :L'
(Nbt Specified Above)
0 A6124 ElderlDependent Adult Abuse Case 2.. 3.. 9
.,
(43)
0 A6190 Election Contest 2.

,. , 0 A6110 Petition for Change of Name 2.,7.

"
:i: 0 A6170 Petition for Relief from Late Claim Law 2.,3.,4.,8.

"
0 A6100 Other Civil Petition 2.,9.

CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION LAse Rule 2.0
CIV 10909-03 Page 3 of 4
...
SHORT TITLE: ABC Escrow v. Steinhauer

111. Statement of Location: Enter the address of the accident, party residence or place of business, performance, or other
circumstance indicated in No. II., item 3 on Page 1 as the proper reason for filing in the court location you selected.
REASON: CHECK THE NUMBER UNDER ITEM -3. WHICH APPLIES IN THIS CASE ADDRESS:

01. [X] 2. 03.04.05.06.07. 08.09. 010. 1641 Poinsettia #15

CITY: STATE: ZIP CODE:

Los Angeles CA 90046

IV. Certificate/Declaration of Assignment: The undersigned hereby certifies and declares that the above entitled matter
is properly filed for assignment to the Central courthouse in the Central District
of the Los Angeles Superior Court under Section 392 et seq., Code of Civil Procedure and Rule 2(b), (c) and (d) of
this court for the reason checked above. I declare under penalty of perjury under the laws of the State of California that
the foregoing is true and correct and this declaration was executed on March 22, 2004 at,
Los Angeles California. ,,,,,)
{city}

Robert

New Civil Case Filing Instructions

This addendum form is required so that the court can assign your case to the correct courthouse location in the proper
district for filing and hearing. It satisfies the requirement for a certificate as to reasons for authorizing filing in the courthouse
location, as set forth in Los Angeies Superior Court Local Rule 2.0. It must be completed and submitted to the court along
with the Civil Case Cover Sheet and the original Complaint or Petition in ALL civil cases filed in any district (including the
Central District) of the Los Angeles County Superior Court. Copies of the cover sheet and this addendum must be served
along with the summons and complaint, or other initiating pleading in the case.

PLEASE HAVE THE FOLLOWING DOCUMENTS COMPLETED AND READY TO BE FILED IN ORDER TO
PROPERLY COMMENCE YOUR NEW COURT CASE:
1. Original Complaint or Petition.
2. If filing a Complaint, a completed Summons form for issuance by the Clerk (Summons forrns available at the Forms
Counter).
3. Civil Case Cover Sheet form required by California Rule of Court 982.2(b)(1), completely filled out (Cover Sheet
forms available at the Forms Counter).
4. This "Addendum to Civil Case Cover Sheet" form [Superior Court Form Number CIV 109, revised 09-03],
completely filled out (Item II. does not apply in limited civil cases) and submitted with the Civil Case Cover Sheet."
5. Payment in full of the filing fee (unless filing on behalf of state or local government or no fee is due for the type
of case being filed) or an Order of the Court waiving payment of filing fees in forma pauperis (fee waiver
application forms available at the Fiiing Window)

6. In case of a plaintiff or petitioner who is a minor under 18 years of age, an Order of the Court appointing an adult as
a guardian ad litem to act on behalf of the minor (Guardian ad Litem Appiication and Order forms available at the
Forms Counter).

7. Mditional copies of documents presented for endorsement by the Clerk and return to you .

Wil~ the exception of unlimited civil cases concerning property damage, bodily injury or wrongful death occurring in
this pounty, Labor Commissioner Appeals, and those types of actions required to be filed in the Central District by
Local:: Court Rule 2(b), all unlimited jurisdiction civil actions may be optionally filed either in the Central District or in
whic~ever other court location the rule would allow them to be filed. When a party elects to file an unlimited jurisdiction
civil ;~ction in Central District that would also be eligible for filing in one or more of the other court locations, this form
must.still be submitted with location and assignment information completed.
If:!
CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION LAse Rule 2.0
CIV 109 09-03 Page 4 of4