AK01

0
GIOVANNI RAMIREZ
4030 Clinton Street
2 Los Angeles, CA 90004
Telephone: (323) 338-9373
3
FILED
SUPERIORCOURTOfCALIFORNIA
COUNTYOFLOSANGELES
JUL 11 2012
1
COMES NOW Plaintiff GIOVANNI RAMIREZ, who alleges as follows:
live Officer/Clerk
Deputy
John
BY
COMPLAINT FOR DEFAMAnON;
DEMAND FOR JURY TRIAL
Unlimited Civil Case
Case No.:
CENTRAL DISTRICT
FOR THE COUNTY OF LOS ANGELES
MtUtVet?A S
SUPERIOR COURT FOR THE STATE OF
Plaintiffs,
Defendants.
I.
vs.
the City of Los Angeles, State of California.
THE PARTIES ;g g ;:::;
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Plaintiff GIOVANNI RAMIREZ ("Ramirez") is, and at all times :
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was, an individual residing in the County of Los Angeles, State of California. =' III ;:' 2- E", 2
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2. Ramirez is informed and believes and thereon alleges that Defendant CITY BF::: :
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LOS ANGELES ("the City"), a public entity, is and at all times material hereto was in" iE
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official capacity as Chief of the Los Angeles )
Police Department, and DOES I-50, inclusive,)
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CITY OF LOS ANGELES, a public entity;
CHARLIE BECK, individually and in his
GIOVANNI RAMIREZ, an individual,.
4 In ProPer
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COMPLAINT

3. Ramirez is informed and believes and thereon alleges that CHARLIE BECK
2 ("Beck"), in his official capacity as Chief of the Los Angeles Police Department is, and at all
3 times material hereto was, employed with the City, located in the County of Los Angeles, State
4 of California.
5 4.
Ramirez is informed and believes and thereon alleges that Beck is, and at all time
6 material hereto was, an individual located in the County of Los Angeles, State of California.
7 5.
The true names and capacities of those Defendants sued herein as Does I through
8 50, inclusive, are unknown to Ramirez, who therefore sues said Defendants by such fictitious
9 names. Ramirez will amend this Complaint to allege their true names and capacities when the
10 same have been ascertained.
II 6.
Ramirez is informed and believes, and thereon alleges, that at all times material
12 hereto, that the DOE Defendants, were the agents, representatives, servants and employees of the
13 other Defendants, and that all of the acts herein alleged were done in the course and scope of
14 such agency and employment.
IS
16 7.
FACTS COMMON TO ALL CAUSES OF ACTION
On or around March 31, 20II, Bryan Stow ("Stow"), a Giant's baseball fan, was
17 brutally beaten in a Los Angeles Dodgers Stadium parking lot after attending a Los Angeles
18 Dodgers' home opener against long time rivals, the San Francisco Giants.
19 8.
The beating was so horrific that news of the incident received worldwide media
20 coverage, and generated an immediate and sustained public outcry for the capture of the two
21 assailants.
22 9.
Ramirez is informed and believes that Stow sustained repeated blows to the face
23 causing him to fall to the ground and strike his head on the parking lot pavement. He is further
24 informed and believes that the assailants continued the brutal attack by kicking Stow several
25 times in the head causing him to lose consciousness. By the time the attack was over, Stow
26 failed to regain consciousness and was placed in a medically induced coma with reports of
27 serious concerns of whether he would even survive.
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After several weeks of the case going unsolved, there was increasing pressure
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COMPLAINT
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from the media and the general public for the Los Angeles Police Department ("LAPD") to bring
2 the responsible parties to justice.
3 II.
On or about the morning of May 22, 20II, LAPD served a search warrant on a
4 residence where, through their surveillance, they had observed Ramirez staying overnight.
5 Ramirez was taken into custody and initially placed on a parole hold and a $1 million bail as a
6 suspect in the Stow beating.
7 12.
However, Ramirez was not at the Los Angeles Dodgers' home opener on or
8 around March 31, 2011 nor had he ever attended a Los Angeles Dodgers' baseball game in his
9 entire life until a recent game opener in March 2012.
10 13.
Almost immediately, numerous alibi witnesses came forward on behalf of
11 Ramirez corroborating the fact that Ramirez was not at Dodgers Stadium on March 31, 20II.
12 14.
Ramirez is informed and believes that on or around May 24, 2011, the Los
I3 Angeles District Attorneys Office determined that no charges could be filed against him in the
14 Stow beating and that more investigation was required.
IS 15.
Within days of Ramirez' arrest, Ramirez cooperated with the police and
16 consented to a polygraph examination. Those results were never released, but upon information
17 and belief, authorities had concluded early in the investigation that Ramirez had been truthful in
18 his denials of any involvement in the Stow beating.
19 16.
In addition, early police reports indicated that palm prints of the principal
20 aggressor in the Stow beating case were retrieved from a vehicle in the Dodgers Stadium parking
21 lot. Ramirez had consented to LAPD's request to get prints of his fingers and palms. The results
22 of the analysis were never disclosed, but upon information and belief, authorities had concluded
23 early in the investigation that the prints on the vehicle were not from Ramirez.
24 17.
It was not until July 22, 2011, after two other suspects were arrested and actual
25 criminal charges had been filed, that Beck finally admitted publicly in a press conference that
26 same day that Ramirez was factually innocent of the Stow beating.
27 18.
Between May 22, 2011 and July 21, 2011, Beck made numerous false and
~ 8 defamatory statements to the media that Ramirez was the principal perpetrator of the Stow
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COMPLAINT
beating.

2
3 19.
BECK'S DEFAMATORY STATEMENTS
On May 22, 2011, immediately following the arrest of Ramirez, Beck held a news
4 conference to announce the arrest of the "primary aggressor" in the Stow beating. Beck stated:
5 "I believe we have the right guy. I wouldn't be standing here in front of you, I certainly
6 wouldn't be booking him later on tonight." He added: "[t]o be a police department in this city,
7 it has to be effective. We have to be effective to put this thug in custody."
8 20. After Los Angeles County prosecutors had determined on May 24, 201 I that no
9 charges could be filed in the Stow beating case and more investigation was required, and after
10 numerous witnesses had already come forward to corroborate Ramirez's alibi that he was not at
11 Dodgers Stadium on March 31, 2011, Beck nonetheless continued to publicly accuse Ramirez of
12 committing the Stow beating, For example, on May 26,2011, when asked by the media whether
13 he remained as confident that police had the correct man, Beck stated "absolutely" and "I am as
14 sure as you need to be to make an arrest and pursue a prosecution." He further said, "Giovanni
15 Ramirez is, and was, and has been our primary suspect in the Stow beating."
16 21. Even after the investigation into the Stow beating was reassigned on June 8, 2011
17 to another division because the accusations against Ramirez remained unsubstantiated, Beck
18 made further public accusations that Ramirez was the perpetrator. For example, on June 12,
19 2011, Beck stated to the media that "[e]veryone mistakes an abundance of caution for a lack of
20 evidence," but "I am still confident we have the right guy."
21 22. As late as June 24, 2011 in a LAPD news release, Beck responded to questions
22 about Ramirez possibly being cleared of all charges: "[m]y comments today are in no way
23 indicative of any changes in the status of the Brian Stow case. The Department will continue to
24 pursue leads that may convict a suspect just as vigorously as we pursue those that may exonerate
25 a suspect. I still believe that the arrest of Giovanni Ramirez was appropriate and he is still the
26 primary suspect in this case."
27 23. Beck knew that each and every statement that he published to the worldwide
~ 8 media as set forth in Paragraphs 19 through 22 of this Complaint was false, or that he made them
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COMPLAINT

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with reckless disregard for the truth of the statements. For example, on May 22, 2011, Beck
2 referred to Ramirez as the "primary aggressor" in the Stow beating and called him a "thug."
3 These statements were all done prior to LAPD even conducting a live line-up and without any
4 forensic evidence to link Ramirez to the Stow beating.
5 24. Beck knew, at the time he published the statements to the worldwide media as set
6 forth in Paragraphs 19 through 22, that each and every statement was false or that he was acting
7 with reckless disregard for the truth. For instance, on May 26, 2011 with the Los Angeles
8 District Attorneys Office declining to prosecute, Beck told the worldwide media that he was
9 "absolutely" confident they had the right man and that "Giovanni Ramirez is, and was, and has
10 been our primary suspect in the Stow beating."
II 25. Beck knew, at the time he published the statements to the worldwide media as set
12 forth in Paragraphs 19 through 22, that each and every statement was false or that he made them
13 with reckless disregard for the truth. For instance, when, on or about June 8,20II, it was readily
14 apparent that there was no credible evidence linking Ramirez to the Stow beating and LAPD
IS reassigned the Stow investigation to one of their elite divisions, Beck continued to say to the
16 worldwide media that he was confident that Ramirez was the ..... right guy."
17 26. Beck knew, at the time he published the statements to the worldwide media as set
18 forth in Paragraph 19 through 22, that each and every statement was false or that he made them
19 with reckless disregard for the truth. For instance, on June 24, 2011 when there was no forensic
20 evidence linking Ramirez to the beating, questionable identifications, ample alibi witnesses, and
21 a non-deceptive polygraph test result, it had to be clear by that time that the suspects in the Stow
22 beating were still outstanding. However, Beck continued to say that Ramirez was ..... still the
23 primary suspect in [the Stow] case."
24 27. Each and every statement that Beck published to the worldwide media that is set
25 forth in Paragraphs 19 through 22, was false, defamatory, outrageous, and published with willful
26 or callous disregard for Ramirez's rights, with malice and oppression, and with the intent to
27 injure Ramirez's reputation and his character.
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COMPLAINT

2 FIRST CAUSE OF ACTION
3 (DEFAMATION)
4 AS AND FOR A FIRST CAUSE OF ACTION FOR DEFAMATION AGAINST BECK IN
5 HIS CAPACITY AS CHIEF OF THE LOS ANGELES POLICE DEPARTMENT, AND
6 EACH OF THEM, RAMIREZ ALLEGES AS FOLLOWS:
7 28. Ramirez realleges and incorporates herein by reference Paragraphs 1 through 27,
8 inclusive of this Complaint with the same force and effect as though set forth in full.
9 29. Beck, in his official capacity as Chief of the LAPD, published the statements
10 regarding Ramirez to various media outlets as are set forth in Paragraphs 19 through 22 of this
II Complaint.
12 30. The statements that Beck published to various 'media outlets are set forth in
13 Paragraphs 19 through 22 are all false statements.
14 31. Beck published to various media outlets the false statements that are set forth in
15 Paragraphs 19 through 22 with constitutional malice in that Beck knew, at the time the
16 statements were published, that the statements were false, or acted with reckless disregard for the
17 truth of the statements.
18 32, Beck published to various media outlets the false and defamatory statements that
19 that are set forth in Paragraphs 19 through 22 with the expectation, and/or actual knowledge, that
20 the information would be re-publish in other widely disseminated public media.
21 33. The false statements that Beck published to various media outlets that are set fort
22 in Paragraphs 19 through 22 are defamatory per se, in that they accuse Ramirez ofoffenses of
23 moral turpitude, offenses which may be punishable by imprisonment, and accuse him of conduct
24 which would tend to directly injure him. Specifically, the statements falsely portray Ramirez as
25 a brutal and callous individual who has no respect for the sanctity of life.
26 34.
The false and defamatory statements that Beck pUblished to various media outlets
27 are set forth in Paragraphs 19 through 22 were not privileged.
35. The false and defamatory statements that Ramirez published to various media
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COMPLAINT
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outlets that are set forth in Paragraphs 19 through 22, by their natural consequence, may cause
2 and have caused Ramirez damages to his reputation and standing in the community, as he has
3 suffered public hatred, contempt and ridicule. The statements have also damaged Ramirez in
4 that they have impaired and may further impair his ability to obtain or maintain gainful
5 employment. The statements have also damaged Ramirez in that they have caused him to suffer
6 adverse physical consequences from stress, emotional distress, mental anguish, and mental pain
7 and suffering.
8 36. The false and defamatory statements that Beck published to various media outlets
9 that are set forth in Paragraphs 19 through 22 were published with willful or callous disregard for
10 the rights of Ramirez and others, and with malice, fraud and oppression toward Ramirez. Beck's
II conduct warrants an assessment of punitive damages in an amount appropriate to punish him and
12 deter others city employees from engaging in similar wrongful conduct in accordance with proof
13 allrial.
14 37. As a result of Beck's wrongful conduct that is set forth in this Complaint,
15 Ramirez has suffered substantial general and special damages, including emotional distress, in an
16 amount in accordance with proof at trial.
17 SECOND CAUSE OF ACTION
18 (DEFAMATION)
19 AS AND FOR A SECOND CAUSE OF ACTION FOR DEFAMATION AGAINST BECK,
20 INDIVIDUALLY, AND EACH OF THEM, RAMIREZ ALLEGES AS FOLLOWS:
21 38. Ramirez realleges and incorporates herein by reference Paragraphs I through 27,
22 inclusive of this Complaint with the same force and effect as though set forth in full.
23 39. Beck, an individual, engaged in conduct that went far beyond the scope of his
24 employment as Chief of the LAPD.
25 40. Beck stated in a July 30, 2011 opinion piece published in the L.A. Times that his
26 department has an obligation to release certain information after an arrest is made such as an
27 individual's description, age, sex, race or ethnicity, date and location of arrest, and limited
~ 1 2 8 information about the evidence and the basis of the arrest. However, his statements as set forth
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COMPLAINT

in Paragraphs 19 through 22, went well beyond those parameters.

2 41. Beck also mentioned in the same opinion piece that it was his intention to do
3 "constitutional policing" when he took the position as Chief of the LAPD. He further clarified
4 his point by stating, "[ilt is embracing not just the words but also the spirit of the Constitution."
5 However, Beck obliterated the spirit of the Constitution by making the statements as referenced
6 in Paragraphs 19 through 22 because his conduct jeopardized any presumption of innocence that
7 Ramirez was entitled too and therefore impacted his due process rights.
8 42. The statements that Beck published to various media outlets are set forth in
9 Paragraphs 19 through 22 are all false statements.
10
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43. Beck published to various media outlets the false statements that are set forth in
Paragraphs 19 through 22 with constitutional malice in that Beck knew, at the time the
12 statements were published, that the statements were false, or acted with reckless disregard for the
13 truth of the statements.
14 44. Beck published to various media outlets the false and defamatory statements that
15 are set forth in Paragraphs 19 through 22 with the expectation, and/or actual knowledge, that the
16 information would be re-published in other widely disseminated public media.
17 45. The false statements that Beck published to various media outlets that are set fort
18 in Paragraphs 19 through 22 are defamatory per se, in that they accuse Ramirez ofoffenses of
19 moral turpitude, offenses punishable by imprisonment, and accuse him of conduct which would
20 tend to directly injure him. Specifically, the statements falsely portray Ramirez as a brutal and
2I callous individual who has no respect for the sanctity of life.
22 46. The false and defamatory statements that Beck published to various media outlets
23 are set forth in Paragraphs 19 through 22 were not privileged.
24 47. The false and defamatory statements that Ramirez published to various media
25 outlets that are set forth in Paragraphs 19 through 22, by their natural consequence, may cause
26 and have caused Ramirez damages to his reputation and standing in the community, as he has
27 suffered public hatred, contempt and ridicule. The statements have also damaged Ramirez in
~ 28 that they have impaired and may further impair his ability to obtain or maintain gainful
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COMPLAINT

employment. The statements have also damaged Ramirez in that they have caused him to suffer
2 adverse physical consequences from stress, emotional distress, mental anguish, and mental pain
3 and suffering.
4 48. The false and defamatory statements that Beck published to various media outlets
5 that are set forth in Paragraphs 19 through 22 were published with willful or callous disregard for
6 the rights of Ramirez and others, and with malice, fraud and oppression toward Ramirez. Beck's
7 conduct warrants an assessment of punitive damages in an amount appropriate to punish him and
8 deter others from engaging in similar wrongful conduct in accordance with proof at trial.
9 49. As a result of Beck's wrongful conduct that is set forth in this Complaint,
\ 0 Ramirez has suffered substantial general and special damages, including emotional distress, in a
II amount in accordance with proof at trial.
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COMPLAINT
07/11/2012 11:48 FAX

1i!I0002/0003
PRAYER FOR RELIEF
2 WHEREFORE, Ramirez prays for judgment against lhe City of Los Angeles and Beck,
3 individually and in his official capacity as Chiefof LAPD, and DOES 1!hrough 50, and each of
4 them, for as follows:
5 FOR THEFIRST AND SECOND CAUSES OF ACTION BY RAMIREZ FOR
6 DEFAMATION AGAINST DEFENDANTS, AND EACH OF THEM:
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2.
3.
4.
5.
6.
For general damages in an amount to be proven at time of trial;
For specific damages in an amount to be proven at time of trial;
For punitive and exemplary damages;
For reasonable attorneys' fees !hereon;
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For costs ofsuit and
For such other and further reliefas this Honorable Court deems just and
13 proper.
14 DATED: JUlyJ..L., 2012
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COMPLAINT
DEMAND FORJURy TRIAL
Plaintiff, movANNI RAMIREZ hereby demands a trial byjury.
DATED: July..J..l-, 2012 GIOVANN! RAMIREZ
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Plaintiff, IN PRO PER
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07/11/2012 11:47 FAX

1i10001l0003

FILED
UPERtORCOURTO' CALIFORNIA
FLOSANGELES
d. 0 Larga number otwltnesoas
e. 0 CoonIlnation willi _ actions pending in one or mOlll c:ourta
in _ c:ounIies, -.or caunlries. or in a _rat court
I. 0 s.-ntial ""Il"I"isio
boD '''.'BAelai,. dedarlltory ... injunctive mIIaf c.IZlPlJ'll1M>
I8qUIrIng """"IllIclI I _
a. 0 I.aIge number of saparataly AlJ)IeS8ntacI par1las
b. 0 eXllln5fve motion pr.Idice raising difticull or IlO\I9l
Issuas tIiilt wII be time-eonsuming to _
c. 0 ofdocumentaryerridenca
3. Rai'_-.ghI(_.. fJnrIlIPP!Y): a.rn__,
4. NumDerofcausesolaolion (specIIJ): 2
5. ThIs case 0.. IZl "not a _ -.suIl.
8. IllIlenl any ........ n!Ialed CIISl!S. file and ..... a nolioo of- case. OIXSUSBItlmI, CM-015.J
8iOVANNI RAMIREZ '. -
fTYPe ORPRllIITlWIfllilEbF
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COUNTY0
I A11<lOHE'tFOR_; In Pro Per
Isu__01' "'" _lIlA, COUII1YOF Los Angeles
JUL 11 2012
.,..., 111 N. Hill Street
........ A<lORl!SS: 111 N. Hill Street
E>l4)tive Officer/Clerk
=''''In'<XlOE' Los CA 90012
......,....." SIan1e Courthouse
fRy . ,r - ,Deputy
CASE NAME;
S\mber LI.FJdr-Clayton
Ramirez v. City of Los An2eles. el. al.
CML CASE COVER SHEET com_c.. DoIIgnaIlon
CAS&1rI\NttR:
8C48819
1
ill UnIlmllod
Du_
Oeuu_ o Joinder
(Amount (Amount
.lIJl:lGl'
demanrl8l1 demanded is Filed wi\Il51St _ll'I...-anl
_$25,000) $25.000 or ....) '[Cal. RulesolCvurt, """3.402)
""".
//oms 1-61101_must be
_ on Da08 Zl.
1. Chect< 0.. bux belowlor tho """" typo tl1at _ describes this case:
AY1oTOd
Conlrod _CVlnpIHClvIIlJdgollon
BAulO(22)
o 8nI.cll 01"""'"CIIWaITanlY(06)
(CoL - 01 CaurI, rules
Un;n$ut<d mclOll&t (<&) o RUI03.7""_.. (09) o _rode.-ID3)
0llltI< PUl'IIJWD<--IlnJ..,/PI_1r o Otber_(O!I) o Cvnslrudion -.:I (11ll
oa....gaIWrortgtUl DIeIh) Toft
o Insurance_(IB)
o __.... (.el)
0-(04)
o O\her -(37)
o _liIigalion('28)
o _ !IMIy(24)
-PnoJIII1r
o En.;..
o _ii."".'-(4O)
o ErriftonI __
o ___aJlsIngmnthl
o 0lIler I'IIl'ONm(23)
...idei.._. (14)
___ooqJlej case
-(OlIIaI)TotI 0
Ijpes (41)
o -_.....__(01) 0 0III0t __(28)
E"bcwMdof Judgm8nI:
o CMI!W1SlO5J -'_r
o EiifOt....... oIjudgmenl (20)
[] Dotom8lIon (13) 0 c..""..cIal (31) MIIc:JIIIai .. ClvU CvnIpIIdnl
o FIBUlI (16) D Rultlential (32)
o RICO(21)
0 __(19) 0 Drugs(38)
o Otbercomplainl (not __abo...! (42)
o PluftsSlOilai negligence (25) JUdIeIal RvvIcM
m 2 Ill" CMl.-.alon
o Otber.....PllPDIWD Iorl (35) 0 AsseI_105J
0_........... _<>1)
0 _ra: __llI(ll)
o OtherpellUon(not"""""_)(43)
o WcolgIuIIe",i.-.(3ll) R_ollllllfll"'(II2)
o Other (IS) Otber 1udIdaI_l39l
2. This case U is lLJ is not complex under rule 3.400 01tho Califomia Rules 01 CoUlllf1lla case is CllIlIp!ex, Rl8l1< tho
--
l1li .udicial mil ment

, 4030 Clinton S_
I Los A/lj!e1es. CA 90004
I 323 338 9373
PIaintitl muslliIe1his...aIeeI with the finst _ 8led In lhe 8CIion 01 (except omaII c1ail!lS filed
under 1llaProIlatBCode. Family Code. or WoIIaJ8 and In!ltilulians Codal. (Cal RnIIls of Court. """3Jl:lIl,)oflloOn10file may
in sanctions.
Fila tIils """'" _Inaddition to any """'.-""IllinIiIll'I- COUil rule.
I1I1l1a c;ase "complex under """ 3.400 etseq. oftho CIIIIIomIa _ otCvurt, "'" rnust_a copyoflhis """""sheeton all
oIIIar paJ1ie&to tho action or pIOClI!I!dng.
V_lIlis ia a co-"case under rule 3.740or a complex _1IlIa__.... be _ tOr_cal p_
CML CASE COVER SHEET
SHORT TITLE:
RAMIREZ V. CITY OF LOS ANGELES, ET AL
CASE NUMBER
CIVIL CASE COVER SHEET ADDENDUM AND
STATEMENT OF LOCATION
(CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION)
This fonn is required pursuant to Local Rule 2.0 In all new civil case filings In the Los Angeles Superior Court.
Item I. Check the types of hearing and fill in the estimated length of hearing expected for this case:
JURY TRIAL? IlZ1 YES CLASS ACTION? DYES LIMITED CASE? DYES TIME ESTIMATED FOR TRIAL 14 0 HOURS/0 DAYS
Item II. Indicate the correct dislrict and courthouse location (4 steps -If you checked "Limited Case". skip to Item III, Pg. 4):
Step 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 A, the Civil Case Cover Sheet case type you selected.
Step 2: Check Q!!! Superior Court type of action in Column B below which best describes the nature of this case.
Step 3: In Column C, circle the reason for the court location choice that applies to the type of action you have
checked. For any exception to the court location, see Local Rule 2.0.
Applicable Reasons for Choosing Courthouse Location (see Column C below)
1. Class actions must be filed in the Stanley Mcsk Courthouse, central district.
2. May be flIed 1n central (other county, or no bodily Injury/property damage).
3. Location where cause of action arose.
4. Location where bodily injury, death or damage occurred.
5. Location where pel10rmance required or defendant resides.
6. location of or permanently garaged vehicle.
7. Location where petitioner resides.
8. location wherein defendantJrespOndent functions wholly,
9, Location where one or more of the parties reside,
10. Location of Labor Commissioner Office
Step 4: Fill in the informalion requested on page 4 in Item III; complete Item IV. Sign the declaration.
A B C
Civil Case Cover Sheet Type of Action Applicable Reasons
Category No, (Check only one) See Step 3 Above
Auto (22) lJ A7100 Motor Vehicle - Personallnjury/Property DamagelWrongful Death 1.. 2.. 4.
Uninsured Motorist (46) lJ A7110 Personallnjury/Property DamageIWrongfUl Death - Uninsured Motorist 1.. 2.. 4.
lJ AS070 Asbestos Property Damage 2.
Asbestos (04)
lJ A7221 Asbestos - PersonallnjurylWrongful Death 2.
Product liability (24) 0 A7260 Product Liability (not asbestos or toxic/environmenlal) 1.. 2.. 3. 4., B
0 A7210 Medical Malpractice - PhyslCians & Surgeons 1.,4.
Medical Malpractice (45)
0 A7240 Other Professional Health Care Malpractice 1.. 4.
0 A7250 Premises Liability (e.g., slip and fall)
1.. 4.
Other
Personal Injury
0 A7230 Intentional Bodily Injury/Property DamagelVVrongful Death (e.g.,
1.,4.
Property Damage
assault. vandalism. etc.)
Wrongful Death
0 A7270 Intentionallnftiction of EmotIonal Distress
1. 3.
(23)
1.,4.
0 A7220 Other Personal Injury/Property DamageNlJrongful Death

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109 (Rev. 03/11) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.0
LAse Approved 03-ll4 AND STATEMENT OF LOCATION Page 1 of 4

ISHORT TITl.E: ICASE NUMBER
GIOVANNI RAMIREZ V. CITY OF LOS ANGELES, ET AL
A B C
Civil Case Cover Sheet Type of Action Applicable Reasons -
Category No. (Check only one) See Step 3 AbOve
BUsln.s. Tort (07) 0 A6029 Other Commercial/Business Tort (not fraudlbreach of contrac1) 1.,3.
~ " ., 0
Civil Ri9hts (08) 0 A6005 Civil Rights/Discrimination 1.. 2,3.
"' ....
0'"
.t:
Defamation (13) 1.. 2.@
~ ~
III A6010 Defamation (slanderltibel)
' ~ i
=g
Fraud (16) 0 A6013 Fraud (no contract) 1.. 2.. 3
.. ~
g;=
l!!"
0 A6017 Legal Malpractice 1.. 2.. 3.
., ...
ProfessIonal Negligence (25)
0. ..
C E 0 A6050 Other Professional Malpractice (not medical or legal) 1.. 2., 3.
o ..
zc
Other (35) 0 A6025 Other NonPersonal Injury/Property Damage tort 2.. 3.
;:
Wrongful Termination (36) 0 A6037 Wrongful Termination 1.,2.. 3.
.,
!
0 A6024 Other Employment Complaint Case 1.,2.,3.
E
Other Employment (15)
w
0 A6109 Labor Commissioner Appeals 10.
0 A6004 Breach of Rentalllease Contract (not unlawful detainer or wrongful
2.. 5.
eviction)
Breach of ContracU Warranty
0 A6006 Contractfv\larranty Breach -Seller Plaintiff (no fraud/negligence)
2., 5.
(06)
(not insurance)
0 A6019 Negligent Breach of ConlractlWarranty (no fraud)
1.,2.. 5.
0 A6028 Other Breach of ContractIWarranty (not fraud or negligence)
1.. 2., 5.
tl
0 A6002 Collections Case-5eller Plaintiff
l!!
2.. 5.. 6.
-
Collections (09)
c
0 0 A6012 Other Promissory Note/Collections Case 2.,5.
0
Insurance Coverage (18) 0 A6015 Insurance Coverage (not complex) 1.,2.,5., e.
0 A6009 Contractual Fraud 1" 2.. 3.. 5.
other Contract (37) 0 A6031 Tortious Interference 1.,2.,3.,5.
0 A6027 Other Contract Dispute(not breachlinsurance/fralK1lnegligence) 1.,2,3.. e.
Eminent Domain/Inverse
[J
A7300 Eminent DomainlCondemnation
Number of parcels__ 2.
Condemnation (14)
~
Wrongful Eviction (33) 0 A6023 Wrongful Evidion Case 2.. 6.
.,
a.
l!
0.
0 A601e Mortgage Foreclosure 2.. 6.
..
.,
ll<
Other Real Property (26) 0 A6032 Quiet Tiue 2.. 6.
0 A6060 Other Real Property (not eminent domain, landlord/tenant, foreclosure) 2.. 6.
Unlawful Detainer-Commercial
0 A6021 Unlawful Detainer-Commercial (not drugs or wrongful eviction) 2.. 6.
0;
(31)
c
'..
Unlawful Detainer-Residential
1l
(32)
0 A6020 Unlawful Detainer-Residential (not drugs or wrongful eviction) 2.,6.
C
~
Unlawful Detainer-
[J
A6020FUnlawful Detainer-Posi-Foreclosure 2.,6.
.!! Post-Foreclosure (34)
c
=>
~
Unlawful Detainer-Drugs (38) 0 A6022 Unlawful Detainer-Drugs 2.. 6.
\
...
\'-.--------------:;;==--::;:-:-=::-c===::-c===::-c=-====:-:-:=--------------
,olACIV 109 (Rev. 03111) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.0
"
LASe Approved 0304 AND STATEMENT OF LOCATION Page 2 of 4

1
5t1ORT TITLE:
GIOVANNI RAMIREZ V. CITY OF LOS ANGELES, ET AL
ICASE NUMBER
AntitrustfTrade Regulation (03) 0 A6003 AntltrustfTrade Regulation
.. ..
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o 0

Jgl.
..
u :=
.!! .::
,",0
A
Civil Case Cover Sheet
Category No.
Asset Forfeiture (05)
Petition ra Arbitratlon (11)
Wril of Manoale (02)
Other Judicial Review (39)
Construction Defect (10)
Claims Involving Mass Tort
(40)
Securities litigation (28)
Toxic Tort
Environmental (30)
Insurance Coverage Claims
from Complex Case (41)
Enforcement
of Judgment (20)
RICO (27)
Other Complaints
(NOI SpecifieO Above) (42)
Partnership Corporation
Governance (21)
Other Petitions
(Not Specified Above)
(43)
B
Type of Action
(Cheek only one)
o A6108 Asset Forfeiture Case
o A6115 Petition to CompellConfirrnNacate Arbitration
o A6151 Writ- Administrative Mandamus
o A6152 Wril- Mandamus on LImited Court Case Matter
o A6153 Writ -Other Limited Court. Case Review
o A6150 Other WrillJudic:ial Review
o A6007 Construction Defect
o AGOOe Claims Involving Mass Tort
o A6035 Securities Utigation Case
o A6036 Toxic TorVEnvironmental
o A6014 Insurance CoveragelSubrogation (complex case only)
o A6141 Sister State Judgment
o A6160 Abstract of Judgment
I:l A6107 Confession of Judgment (non-<lomeslic relations)
o A6140 Administrative Agency Award (not unpaid taxes)
o A6114 Petition/Certificate for EntJy of Judgment on Unpaid Tax
o A6112 Other Enforcement of Judgment Case
o A6033 Racketeering (RICO) Case
o A6030 Dedaratory Relief Only
o A6040 Injunctive Relief Only (not
o AG011 Other Commercial Complaint Case (non-tortlnon-complex)
o AGOOO Other Civil Complaint (non-torttnon-complex)
o A6113 Partnership and Corporate Governance Case
o A6121 Civil Harassment
o A6123 Workplace Harassment
o A6124 ElderlDependent Adult Abuse Case
o A6190 Election Contest
o A6110 Petition for Change of Name
a A6170 Petition for Relief from Late Claim Law
o A8100 Other Civil Petition
C
Applicable Reasons -
See Step 3 Above
2.,6.
2.,5.
2.. 8.
2.
2.
2.. 8.
1.. 2.. 8.
1.. 2., 3.
1.. 2.. 8.
1.. 2.. 8.
1.. 2.. 3.. 8.
1.. 2.. 5., 8.
2.. 9.
2.. 6.
2.,9.
2.. 8.
2.. 8.
2.. 8.. 9.
1.,2.,8.
1.,2.,8.
2.. 8.
1.,2.. 8
1.. 2.. 8.
2.. 8
2.. 3.. 9.
2.. 3., 9.
2.. 3.. 9.
2.
2" 7.
2.,3.. 4.. 8.
2.. 9.
Local Rule 2.0
Page 3 of 4

",
.'

.LACIV 109 (Rev. 03111) CIVIL CASE COVER SHEET ADDENDUM
N
LASC Approved 03-04 AND STATEMENT OF LOCATION
07/11/2012 11:49 FAX


1L..- __IlM: __GlOIl __"N_N1_RAMlREZV_.ClTY __OF_LOS __ANG __E_L.ES_,-_ET_A1. _
Il8ln RI. Stal8nlenl Ofl..acaliotl: Enter lheaddmsoftlleaccldent, pany's .esidenceorplaceofbuslne8s, peifOImance, or alher
.ce b.. Step 3on Page 1, aslheproper I\llIllOIIIgrIilnll in tile court location you & '0180.
-
__.........._rvr..__
1lle 77 _, _"__IlrQllelQl8l?ie_"'DIeLos
__Crvr.._of __"", __rvr
AIVlIos - 04 bi.'"cIIr _ """"roiLos AogoIoo.
--
Sptc, j fi c A
01.02. 03. 04. 05. 06. 07. 08. 09. 010.
\/Nt<:NONr-J 7.
ttIY,
ST''''
........
Los ......... CA
""'" IV. 000IBf_ofAaslQibll&t.ldscla'" .ndorPllilllllYofpetjury lnIertl8_0I1he ..1tl8tngoing is true
0J1d correct InlI tIllll tl8 allcNe e:rtitIocI ..- is _ rvr 66SIgi""'d LD Ihe Sllney Mask COU_ in Ihe
Cen1nJ7 D_oIlhe Superior CCIurt 01 County of los Angoles (Code CiII. P...... 392 et _. and Local
Rille 2.0. __(b), (e) and (ll)J.
.,_.,
.----.
PLEASE HAVE THEFOUOWING ITEIIS COMPLETEDAND READYTO BE FILED IN ORDERTO PROPERLY
COIIIIIENCEYOUR NEWCOURT CASE:
1. Original Coiijllllint or Petition.
2. II filing II CamplelnI, II campIBled Summons loRn fer Issuance by the Clerk.
3. Civil Cese Cover Sheet, Judicial Council form CM-010.
4. Civil C8S8Cover Sh8aI Addendum8IId Sl8IIRTleId of Loc8Iion form, lACIV 109.lASCApproved (Rev.
03111).
5. Peyment In full of the fiIlng fee. unI8aI fees IIlMlII8en WIIIVed.
6. Aslgned 0RI8r IIPpointi"u tile Guerdillnlid UI8m, Council fcrmCIV.o10, if the pIeIntiffor pelitio"e, is II
minor 18 years of age will be i8qIlIIed by Cc:urt in DRI8t to tssu8 II summons.
7. AddilIanlII copIea Of cIoc:unIenla to be ca"..""ed bylhe CIaIlc. Copies Of the cover ah8et 8IlCI this eddendum
must Il8 seN8d 8Iong _ the summons end co'"pl.1I, or ClIh8t inliatlng pla8dIng in the C8S8.
l.ACl\I109 (RoY. OII'l)
!l
-,
...
...
,-
I'
III
CML CASE COVERSHEET ADDENDUM
ANDSTATEMENTOF LOCATION
Local Rule2.0
Page4D14