Taco Bell Lawsuit

Case 8:11-cv-00101-DOC -FFM Document 1 Filed 01/19/11 Page 1 of 18 Page ID #:6
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9 Q!NTRAL DISTRICT OF CALIFORNIA
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Situated and the General Pu: lie, CLASS ACI'ION
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b 14 ·v. 1. VIOLATIONS OF CONSUMERS
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BUSINESS & PROmSIONS
CODE 117200, ETSEQ.
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. 000255
1 Plaintiff Amanda Obney, by and through her attorneys, brings this action
2 on behalf of herself, all others similarly situated and the general public against
3 defendant Taco Bell Corporation ("Taco Bell" or "Defendant"). The Court has
4 jurisdiction over this action pursuant to 28 U.S.C. §l332(d)(2). Plaintiff alleges,
5 on information and belief, except for the information based on personal
6 knowledge, as follows:
7 NATURE OF THE ACTION
8 1. This is a consumer rights class action challenging Taco Bell's
9 practice of representing to consumers that the filling in many of its ''beef' food
10 items is "seasoned ground beef' or "seasoned beef," when in fact a substantial
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17 Bell to properly advertise and label these food items and to engage in a corrective
18 advertising campaign to educate the public about the true content of its food
19 Products (defined below).
20 2. Plaintiff brings this action pursuant to Federal Rules of Civil
21 Procedure 23(a) and (b)(2) on behalf of herself, all similarly situated consumers
22 of the menu items advertised and labeled by defendant as containing "seasoned
23 ground beef' or "seasoned beef' and the general public. Plaintiff seeks to halt
24 the dissemination of Taco Bell's false and misleading advertising message, and
25 correct the false and misleading perception it has created in the minds of
26 consumers.
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00025525
JURISDICTION AND VENUE

2 3. This Court has original jurisdiction pursuant to 28 U.S.C.
3 § 1332(d)(2). The matter in controversy, exclusive of interest and costs, exceeds
4 the sum or value of $5,000,000 and is a class action in which members of the
5 Class of plaintiffs are citizens of states different from Taco Bell. Further, greater
6 than two-thirds of the Class members reside in states other than the state in
7 which Taco Bell is a citizen.
8 4. Venue is proper in this Court pursuant to 28 U.S.C. §1391 in that
9 many of the acts and transactions giving rise to this action occurred in this
10 district and because Taco Bell:
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18 5. Plaintiff is a resident of California. During the relevant time period
19 plaintiffwas exposed in California to defendant's advertising and labeling claims
20 that the subject "beef' food items were filled with "seasoned ground beef' or
21 "seasoned beef." Based on these representations, as well as the reasonable belief
22 that defendant would accurately and honestly describe its products, plaintiff
23 believed the taco meat filling was seasoned beef and, in reliance thereon,
24 purchased the food items, thereby suffering injury in fact and losing money as a
25 result of the alleged conduct. Plaintiff wanted to purchase beef-filled food items
26 from Taco Bell, but did not receive what she believed she was purchasing.
27 6. Defendant Taco Bell Corporation is a California company with its
28 principal place of business in Irvine, California. Taco Bell Corporation, a wholly
00025525 2
1 owned subsidiary ofYum! Brands, Inc., is the largest Mexican fast-food chain in
2 the United States. It operates, manages or franchises more than 5,600 locations
3 in the United States and had sales in 2009 in excess of $1.9 billion. More than
4 35 million consumers visit a Taco Bell restaurant each week and more than two
5 billion consumers are served annually. From its headquarters and Restaurant
6 Support Center in California, Taco Bell determines the content of its advertising
7 and labeling, including its menus.
8 DEFENDANT'S CONDUCT
9 7. Taco Bell operates, manages, markets, and franchises fast-food
10 restaurants in California and throughout the United States.
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18 "Products"). In reality, a substantial majority of the filling is comprised of
19 substances other than beef, and is required to be labeled and advertised as "taco
20 meat filling."
21 1O. Taco Bell also misrepresents certain of the Products' ingredients as
22 "seasonings." However, these ingredients are not added for flavor, but rather to
23 increase the volume of the product. These ingredients are binders and extenders
24 such as "isolated oat product."
25 11. Taco Bell uniformly misrepresents on its package labels, brochures,
26 website, menus, and in its television commercials that the "beef' Products
27 contain "seasoned ground beef," rather than "taco meat filling."
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00025525 3
1 12. For example, Taco Bell describes its diet product, "Fresco Soft
2 Taco," as "a warm, soft flour tortilla filled with seasoned ground beef, crisp
3 shredded lettuce, and fiesta salsa." It describes its Crunchy Taco as "a crunchy,
4 com taco shell filled with seasoned ground beef, crisp shredded lettuce, and real
5 cheddar cheese." It describes its spicy beef "Volcano® Burrito as "a warm, soft
6 flour tortilla that's packed with a double portion* of seasoned ground beef,
7 seasoned rice, crunchy red tortilla strips, real cheddar cheese, cool reduced fat
8 sour cream and cheesy molten hot lava sauce." In fact, for each of these food
9 items and its other Products, the "seasoned ground beef' is not ground beef with
10 seasoning but "taco meat filling."
D.. 13. On its website, www.tacobell.com. Taco Bell repeats these
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14. Taco Bell's television commercials, restaurant menus and print
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1 that the "beef' Products contain "seasoned ground beef," and not a product of
2 substantially lower quality that does not meet the definition for beef. For
3 example:
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18 15. Taco Bell's advertisement that it sells "beef' menu items containing
19 "seasoned ground beef," is unsubstantiated, false and misleading. The Products,
20 unbeknownst to consumers, are comprised substantially of meat filling and are
21 mislabeled. Taco Bell's "seasoned beef' actually contains among other
22 ingredients, water, "Isolated Oat Product," wheat oats, soy lecithin,
23 maltodrextrin, anti-dusting agent, autolyzed yeast extract, modified corn starch
24 and sodium phosphate, as well as beef and seasonings.
25 16. Taco Bell's definition of "seasoned beef' does not conform to
26 consumers' reasonable expectation or ordinary meaning of seasoned beef, which
27 is beef and seasonings. Merriam-Webster defines "beef' as "the flesh of an adult
28 domestic bovine (as steer or cow) used as food."
00025525 6
1 17. Taco Bell's use of the term "seasoned beef' also violates and is
2 otherwise inconsistent with the United States Department of Agriculture's
3 ("USDA") definition. The USDA defines "beef' as "flesh of cattle." 7 C.F.R.
4 §1260.l19. "Ground beef' "shall consist of chopped fresh and/or frozen beef
5 with or without seasoning and without the addition of beef fat as such, shall not
6 contain more than 30 percent fat, and shall not contain added water, phosphates,
7 binders, or extenders." 9 C.F.R. §319.15.
8 18. The USDA has developed the Food Standards and Labeling Policy
9 Book (the "Policy Book"). The Policy Book provides "guidance to help
10 manufacturers and prepare product labels that are truthful and not misleading."
0- The Policy Book requires food labeled as "Taco filling" to contain "at least 40
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a:a 17 CLASS ACTION ALLEGATIONS
18 20. Plaintiff brings this lawsuit on behalf of herself and the proposed
19 Class members under Federal Rules of Civil Procedure Rule 23(a) and (b)(2).
20 The proposed Class consists of:
21 All persons in the United States who purchased any food product
22 from Taco Bell that was advertised or labeled as a containing
23 "beef," "seasoned ground beef' or "seasoned beef."
24 21. The Class is comprised of many tens of thousands of consumers
25 throughout California and the United States. The Class is so numerous that
26 joinder of all members ofthe Class is impractical.
27 22. This action involves questions of law and fact common to the
28 plaintiff and the members of the Class which include:
00025525 8
1 (a) Whether Taco Bell has engaged in an unlawful, unfair,

2 misleading or deceptive business act or practice through their labeling and
3 advertising practices;
4 (b) Whether Taco Bell's labeling and advertising is misleading
5 and/or likely to deceive regarding the nature of the Products;
6 (c) Whether the Taco Bell Products contain beef with a seasoning
7 or taco meat filling;
8 (d) Whether Taco Bell's alleged conduct violates public policy;
9 and
10 (e) Whether plaintiff and Class members are entitled to
0.. declaratory and injunctive relief, including enjoining Taco Bell from continuing
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18 members of the Class. Plaintiff has engaged counsel who are experienced in the
19 prosecution of this type of action.
20 25. Unless a class-wide injunction is issued, Taco Bell will continue to
21 commit the violations alleged, and the members 9f the Class and the general
22 public will continue to be misled.
23 26. Taco Bell has acted or refused to act on grounds that apply generally
24 to the Class so that final injunctive relief and corresponding declaratory relief is
25 appropriate respecting the Class as a whole.
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00025525 9
1 FIRST CAUSE OF ACTION

2 Consumers Legal Remedies Act
Civil Code §1750 et seq.
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4 27. Plaintiff realleges and incorporates by reference the allegations
5 contained in the paragraphs above as if fully set forth herein.
6 28. This cause of action is brought pursuant to the Consumers Legal
7 Remedies Act, Civil Code §1750, et seq. (the "Act"). Plaintiff is a consumer as
8 defined by Civil Code §1761(d). The Products are goods within the meaning of
9 the Act.
10 29. Taco Bell violated and continues to violate the Act by engaging in
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18 particular standard, quality or grade if [they are] of another.
19 (c) Advertising goods with intent not to sell
20 them as advertised.
21 30. Taco Bell violated the Act by making the representations described
22 above when it knew, or should have known, that the representations were
23 unsubstantiated, false and misleading.
24 31. Pursuant to §1782(d) of the Act, plaintiff and the Class seek a Court
25 order enjoining the above-described wrongful acts and practices of Taco Bell,
26 and for corrective advertising.
27 32. Pursuant to §1780(d) of the Act, attached hereto as Exhibit A is the
28 affidavit showing that this action has been commenced in the proper forum.
00025525 ]0
1 SECOND CAUSE OF ACTION

2
Unlawful Business Acts and Practices,
3 Business & Professions Code §17200, et seq.
4 33. Plaintiff repeats and realleges the allegations contained In the
5 paragraphs above, as if fully set forth herein.
6 34. Business & Professions Code §17200 prohibits any "unlawful,
7 unfair or fraudulent business act or practice and unfair, deceptive, untrue or
8 misleading advertising." For the reasons discussed above, Taco Bell has violated
9 each of these provisions of Business & Professions Code §17200.
10 35. Taco Bell has violated §17200's prohibition against engaging in
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18 36. Plaintiff and the Class reserve the right to allege other violations of
19 law which constitute other unlawful business acts or practices. Such conduct is
20 ongoing and continues to this date.
21 37. Taco Bell's acts, omissions, misrepresentations, practices and non-
22 disclosures that the Products contained "seasoned ground beef' or "seasoned
23 beef' rather than "taco meat filling," as alleged herein, also constitute "unfair"
24 business acts and practices within the meaning of Business & Professions Code
25 § 17200, et seq., in that its conduct is substantially injurious to consumers,
26 offends public policy, and is immoral, unethical, oppressive, and unscrupulous as
27 the gravity of the conduct outweighs any alleged benefits attributable to such
28 conduct.
00025525 11
1 38. As stated in this Complaint, plaintiff alleges violations of consumer

2 protection, unfair competition and truth in advertising laws. Plaintiff asserts
3 violations of the public policy of engaging in false and misleading advertising,
4 unfair competition and deceptive conduct towards consumers. This conduct
5 constitutes violations of the unfair prong of Business & Professions Code
6 §17200, et seq.
7 39. There were reasonably available alternatives to further Taco Bell's
8 legitimate business interests, other than the conduct described herein.
9 40. The foregoing conduct also violates Business & Professions Code
10 §l7200's prohibition against "fraudulent" or deceptive business practices.
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18 42. Taco Bell's conduct caused and continues to cause substantial injury
19 to plaintiff and the other Class members. Plaintiff has suffered injury in fact and
20 has lost money or property as a result of Taco Bell's unfair conduct.
21 43. As a result of Taco Bell's violations of the DCL, and similar laws in
22 effect in other states, plaintiff and Class members are entitled to the relief against
23 defendant, as set forth in the Prayer for Relief.
24 44. Additionally, pursuant to Business & Professions Code § 17203,
25 plaintiff seeks an order requiring Taco Bell to immediately cease such acts of
26 unlawful, unfair and fraudulent business practices, and requiring Taco Bell to
27 engage in a corrective advertising campaign, including notification of the true
28 content and ingredients of Taco Bell's Products.
00025525 ]2
1 PRAYER FOR RELIEF

2 Wherefore, plaintiffprays for a judgment:
3 A. Certifying the Class as a class action;
4 B. Awarding declaratory and injunctive relief, including enJommg
5 defendant from continuing the unlawful practices as set forth herein, and
6 continuing to misrepresent the true contents and ingredients of their Products;
7 C. Directing defendant to engage in a corrective advertising campaign;
8 D. Awarding plaintiff attorneys' fees and costs; and
9 E. Awarding such further relief as may be just and proper.
10 JURY DEMAND
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...J 11 Plaintiff demands a trial by jury on all issues so triable.
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z- Dated: January 19,2011 BLOOD HURST & O'REARDON, LLP
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~ 13 LESLIE E. HURST
a:: THOMAS J. O'REARDON II
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9 17 600 B Stree~ Suite 1550
m San Diego, cA 92101
18 Telephone: (619) 338-1100
FaCSImile: (619) 338-1101
19 tblood~bholaw.com
lhurst holaw.com
20 torear on@bholaw.com
21 BEASLEYrl ALLEN, CROW, MEHVIN,
PORTIS & MILE~ P.C.
22 W. DANIELMILE~, ITI
WILLIAM E. HOPKINS, JR.
23 218 Commerce Street
Post Office Box 4160
24 Montgomery, AL 36104
Telepnone: 334/269-2343
25 334/954-7555 (fax)
Dee.Miles~easley' Allen.com
26 Bill.Hopkiiis@BeasleyAllen.com
27 Attorneys for Plaintiff
28
00025525 13
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c" O. Blood (tblood@bholaw.com)
Address:
BI Hurst & O'Rcardon. LLP

.600 Stre~ Suite lSSO
San iego, CA 92101
619 38·1100 6191338·IlOI (fax)
l1NlTED STATES DISTRICT COURT
CENTRAL DISTRICf Oll' CALIFORNIA
A' NDA OBNEY. On BehalfofHmel£. AD OthOl'S CASSNUMBER
subi arly Situated and the General Public SACVU-GOI0i nn,.
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TA BELL CORPORATION
SUMMONS'
DEPBNDAN'I'(S).
TO:· DEFENDANT(S): _ _~~-=--;"";;,:;;;=-...:-...,,...-:.._ _

;. "';';" _
A lawsuit has been :filed against you.

. Within 21 days after service ofthis ~ .on you (not countins the day you received it), you
must erve aD the plaintiff an answer to the attached IJI complaint 0 . amended complaint
D~ laim 0 ClOS8--c1aim or a motion under awe 12 of-the Federal R11Ies ofCivil Procedure. The answer
or Iri tion must be served on tho plaintiff's attorney, Timothy G. Blood •whose address is
·810' Hurst & OIRcardonLLP 600 a.Street Suite 1550. SanDie ,CA 92101 . If you fail to do so,
j cm.t by default will be entered against you for the ~Jicf demanded mthe complaint. You also must file
your. wer or motion with the court.
Clerk, ~.S. District Court
By: -----~---...;;--I
{U8e dayaVtM tkfend.!mt t, lb. Unltlll StrdR or Q United $t4Iu. apu:y, or;' till oJlioo or employft oftlu! U"itsd &tata. Allow"
. 60 . u,Rule12(rl)(3)).
CV~1 (12m) SUMMONS

UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
CIVIL COVER SHEET
I (a) PLAINTn'fo'S (Check box if you are representing yourself D) DEFENDANTS

AMANDA OBNEV, On Behalfof Herself, All Others Similarly Situated and the TACO BELL CORPORATION
General Public
Plaintiff Defendant
(b) Attorneys (Finn Name, Address and Telephone Number. Ifyou are representing Attorneys (If Known)
yourself, provide same.)
Timothy G. Blood (149343), Blood Hurst & O'Reardon, LLP
600 B Street, Suite 1550, San Diego, CA 92101
619/338-1100 619/338-1101 (fax) tblood@bholaw.rom
U. BASIS OF JURISDICTION (Place an X in one box only.) W. CITIZENSHIP OF PRINOPAL PARTIES - For Diversity Cases Only
(Place an X in one box for plaintiffand one for defendant.)
o 1 U.S. Government Plaintiff 03 Federal Question (U.S.
~
DEF PTF
GovernmllntNot a Party) Citizen ofl"his State 01 Incorporated or Principal Place 04
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of Business in this State
02 U.S. Government Defendant rY4 Diversity (Indicate Citizenship Citizen ofAnother State 02 02 Incorporated and Principal Place 05 05
of Parties in Item III) ofBnsiness in Another State
Citizen or Subject ofa Foreign Country 0 3 0 3 Foreign Nation 06 06
IV, ORIGIN (Place an X in one box only.)
MI Original 0 2 Removed from 0 3 Remanded from o4 Reinstated or 0 5 Transferred from another district (specify): 0 6 Multi- o 7 Appeal to District
Proceeding State Court Appellate Court Reopened District Judge from
Litigation Magistrate Judge
V. REQUESTED IN COMPLAINT: JURY DEMAND: 0 Ves 0 No (Check 'Yes' only ifdemanded in complaint.)
CLASS ACTION UDder F.R.C.P. Z3: riVes 0 No 0 MONEY DEMANDED IN COMPLAINT: S
VI. CAUSE OF ACTION (Cite the U.S. Civil Statute under which you are filing and write a briefstatement of cause. Do not cite jurisdictional statutes unless diversity.)
Violations ofCal. Civil Code section 1750, et sq. and Cal. Business & Professions Code, section 17200, et seq.
VII. NATURE OF SUIT (Place aa X ia one box only.)
OTHER STATUT£:S COll/TMC,. TORTS TORTS

- 1-
PRISONER LABOR
o 400 State Reapportionment 0110 Insurance PERSONAL INJURY PERSONAL PETlnqNs 0710 Fair Labor Standards
0410 Antitrust 0120 Marine 0310 Airplane PROPERTV o 510 Motions to Act
o 430 Banks and Banking 0130 Miller Act o 315 Airplane Product rl370 Other Fraud Vacate Sentence o 720 LaborlMgml
o 450 CommercelICC 0140 Negotiable Instrument Liability o 371 Truth in Lending Habeas Corpus Relations
Rates!etc. 0150 Recovery of 0320 Assault, Libel & 0380 Other Personal o 530 General o 730 Labor/Mgml
0460 Deportation Overpayment & Slander Property Damage o 535 Death Penalty Reporting &
0470 Racketeer Influenced Enforcement of 0330 Fed. Employers' 0385 Property Damage o 540 Mandamus! Disclosure Act
Judgment Liability Product Liability Other
and Corrupt 0740 Railway Labor Act
0340 Marine
Organizations 0151 Medicare Act
0345 Marine Product
BA~KRllPTCY o 550 Civil Rights 0790 Other Labor
0480 Consumer Credit 0152 Recovery of Defaulted Liability
o 422 Appeal 28 USC o 555 Prison Condition Litigation
o 490 Cable/Sat TV Student Loan (Excl. 0350 Motor Vehicle 158 FORFEITURE/ 0791 Empl. Reline.
0810 Selective Service Veterans) 0355 Motor Vehicle o 423 Withdrawal 28 f'ENN,n' Security Act
o 850 Securities/Commodities! 0153 Recovery of Product Liability USC 157 0610 Agriculture PROpERTYJUGI:ITS
Exchange Overpayment of 0360 Other Personal CIVIL RIGHTS o 620 Other Food & o 820 Copyrights
0875 Customer Challenge 12 Veteran's Benefits InjUJ)' 0441 Voting Drug 0830 Patent
USC 3410 0160 Stockholders' Suits 0362 Personal InjUJ)'- o 442 Employment 0625 Drug Related o 840 Trademark
0890 Other Statutory Actions 0190 Other Contract Med Malpractice o 443 Housing/AceD- Seizure of Soc.iAL SECURITY
0891 Agricultural Act 0195 Contract Product 0365 PersonallnjUJ)'- mmodations Property 21 USC 0861 HIA (l395ft)
0892 Economic Stabilization Liability Product Liability o 444 Welfare 881 o 862 Black Lung (923)
Act o 196 Franchise 0368 Asbestos Personal o 44S American with 0630 Liquor Laws o 863 D1WCIDIWW
0893 Environmental Matters REAL PR()PERTY lnjUJ)' Product Disabilities • o 640 R.R. & Truck (405(g»
0894 Energy Allocation Act o 210 Land Condemnation Liability Employment o 650 Airline Regs o 864 SSID Title XVI
0895 Freedom oflnfo. Act 0220 Foreclosure IMMIGRAIlON o 446 American with o 660 Occupational .0865 RSI (405(g))
0900 Appeal of Fee Determi· o 230 Rent Lease & Ejectment 0462 Naturalization Disabilities· Safety /Health FEDERAL TAX SUITS
nation Under Equal o 240 Torts to Land Application Other 0690 Other 0870 Taxes (U.S. Plaintiff
Access to Justice 0245 Tort Product Liability 0463 Habeas Corpus- 0440 Other Civil or Defendant)
0950 Constitutionality of o 290 All Other Real Property Alien Detainee Rights 0871 IRS-Third Party 26
State Statutes 0465 Other Immigration USC 7609
Actions
FOR OFFICE USE ONLY: Case Number: _

AFTER COMPLETING THE FRONT SIDE OF FORM CV-71 , COMPLETE THE INFORMAnON REQUESTED BELOW.
CV-71 (05/08) CIVIL COVER SHEET Page I of2

UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
CIVIL COVER SHEET
V111(a). IDENTICAL CASES: Has this action been previously filed in this coun and dismissed, remanded or closed? rJlND 0 Yes
If yes, list case number(s): _
VIII(b). RELATED CASES: Have any cases been previously filed in this counthat are related to the present case? rlNo 0 Yes
Ifyes, list case number(s): _
Civil cases are deemed related If a previously rued ease and the present case:
(Check all boxes that apply) 0 A. Arise from the same or closcly related transactions, happenings, Dr cvcnts; or
DB. Call for determinatiDn Dfthe sanlC or substantially related or similar questions Df law and fact; or
o C. For other reasons would entail substantial duplication oflabor if heard by different judgcs; Dr
o D. Involve the same patent, trademark Dr copyright, and onc ofthe factors identified abon in a, b Dr c alsD is present.
IX. VENUE: (When completing the following infonnation, use an additional sheet ifneeessary.)
(a) List the County in this District; California County outside of this District; State if other than CalifDrnia; or Foreign Country, in which EACH named plaintiff resides.
0 Check here ifthc l!ovemment. its aRCDcies or cmnlovees is il named nlaintiff'. If this box is checked. 20 to item {b).
County in this District:· California County outside Df this District; Slate. if olher than California; or Foreign Country
San Diego
(b) List the County in this District; California County outside of this District; State if othcr than California; or Foreign Country, in which EACH named defendant resides.
0 Check here ifthe I!.ovemment. its al!.cncies or cmDlovees is a named defendant. If this box is checked.llo to item let
County in this District:· California County outside of this District; State. if other than California; or Foreign Country
Irvine
(c) List the County in this District; California County outside of this District; State ifotherthan CalifDrnia; or Foreign Country, in which EACII claim arose.
.
Note' In land cOJldemnatioD cases, use the 10000tion of the tract of IaDd involved
County in this District:· California County outside of this District; State, ifother than California; or Foreign Counlry
Irvine
• Los ABgelcs, Orange, San Bernardino, Riverside, Ventura, Santa Barbara, or San Luis Obispo Counties
Note: In land condemnalion cases use the locatiDn of the tract oflan' ed
X. SIGNATURE OF ATTORNEY (OR PRO PER):..::...·...j..J~~£.:!:~~----IQ::::::======~_ Date 1119/20J I
Notice to CounsellParties: The CV-71 (JS-44) Civil Cover Sheet and the infomlation contained herein neither replace nor supplement the filing and service ofpleadings
or other papers as required by law. This fonn, approved by the Judicial Conference ofthe United States in September 1974, is required pursuant to Local Rule 3-1 is not filed
but is used by the Clerk of the Court for the purpose ofstatistics, venue and initiating the civil dDcket sheet. (For more detailed instructions, see separate instructions shcet.)
Key to Statistical codes relating to Social Security Cases:

Nature of Suit Code Abbreviation Substantin Statement of Cause of Actio.
861 HIA All claims for health insurance benefits (Medicare) under Title 18, Part A, of the SDcial Security Act, as amended.
AlsD, include claims by hospitals, skilled nursing facilities, etc., for certification as providers of services under the
program. (42 U.S.C. 1935FF(b»
862 BL All claims for "Black Lung" benefits IUlderTitle 4, Part B, of the Federal Coal Mine Health and Safety Act of 1969.
(30 U.S.C. 923)
863 D1WC All claims filed by insured workers for disability insurance benefits under Title 2 of the Social Security Act, as
amended; plus all claims filed for child's insurance benefits based on disability. (42 U.S.C. 405(g»
863 D1WW All claims filed for widows or widowers insurance benefits based on disability under Title 2 oflhe Social Security
Act, as amended. (42 U.S.C. 405(g»
864 ssm All claims for supplemental security income payments based upon disability filed under Title 16 ofthe Social Security
Act, as amended.
865 RSI All claims for retirement (old age) and survivors benefits under Title 2 of the Social Security Act, as amended. (42
U.S.C. (g»
CV-71 (05108) CIVIL COVER SHEET Page 2 of2

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA
NOTICE OF ASSIGNMENT TO UNITED STATES MAGISTRATE JUDGE FOR DISCOVERY
This case has been assigned to District Judge David O. Carter and the assigned
discovery Magistrate Judge is Frederick F. MllDlm.
The case number on all documents tiled with the Court should read 88 follows:
SACV11- 101 DOC (r~)
Pursuant to GeIleral Order 05-07 of the United States District Court for the Central
District of Califomia, the Magistrate Judge has been designated to hear discovery related
motions.
All discovery related motions should be noticed on the calendar ofthe Magistrate Judge
----------------------------------------_.
--------------------------------------_.
NOnCE TO COUNSEl
A copy of thltI notice muat be S81V8CI with the SUmmonB end OOI1fJ/aInt on eN defend8ntr (If a f8trICJV8IBCIIon 18
filed, 8 copy of thIa notice must be SfJMId on all pIaJntJff8).
Subsequent documents must be filed at the following loc81Ion:
L.J Western DM.lon lXI Southem D1v1.1on U Eatem DIvision

312 N. SprIng St.. Rm. G-8 411 Wul Fourth It., RIft. 1-GS3 3470 Twelfth st., Rm. 134
Lot Angel... CA 10012 88nta Ana, CA 8270104118 RIvwIIcIe. CA 82501
Failure to file at Ihe proper-Iocellon will resuilin your doeumlntll being relLmed to you.
CV·18 (03ttI8) NOTICE OF ASSIGNMENT TO UNITED STATES MAGISTRATE JUDGE FOR DISCOVERY

Taco Bell Lawsuit

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Taco Bell Lawsuit

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Case 8:11-cv-00101-DOC -FFM Document 1 Filed 01/19/11 Page 1 of 18 Page ID #:6

RLED • SOUTHEfU~ OMfil9,N

JURISDICTION AND VENUE

0 12 misrepresentations and omissions and the contents of its advertisements:

1 (a) Whether Taco Bell has engaged in an unlawful, unfair,

1 FIRST CAUSE OF ACTION

1 SECOND CAUSE OF ACTION

1 38. As stated in this Complaint, plaintiff alleges violations of consumer

1 PRAYER FOR RELIEF

BI Hurst & O'Rcardon. LLP

TO:· DEFENDANT(S): _ _~~-=--;"";;,:;;;=-...:-...,,...-:.._ _

A lawsuit has been :filed against you.

Clerk, ~.S. District Court

CV~1 (12m) SUMMONS

I (a) PLAINTn'fo'S (Check box if you are representing yourself D) DEFENDANTS

OTHER STATUT£:S COll/TMC,. TORTS TORTS

FOR OFFICE USE ONLY: Case Number: _

CV-71 (05/08) CIVIL COVER SHEET Page I of2

X. SIGNATURE OF ATTORNEY (OR PRO PER):..::...·...j..J~~£.:!:~~----IQ::::::======~_ Date 1119/20J I

Key to Statistical codes relating to Social Security Cases:

CV-71 (05108) CIVIL COVER SHEET Page 2 of2

UNITED STATES DISTRICT COURT

NOTICE OF ASSIGNMENT TO UNITED STATES MAGISTRATE JUDGE FOR DISCOVERY

L.J Western DM.lon lXI Southem D1v1.1on U Eatem DIvision

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X. SIGNATURE OF ATTORNEY (OR PRO PER):..::...·...j..J£.:!:----IQ::::::======~_ Date 1119/20J I