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ORIGINAL
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Amar Shergill, SBN 219385 mi
SHERGILL LAW FIRM TAPR IT py
1104 Corporate Way Ros 3
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Sacramento, CA 95831 NQUE,
Telephone: (916) 564-5781 2 yoo Fe
Facsimile: (916) 564-2764 ia
E-mail: amar@shergilllawfirm.com
Attomey for Plaintiffs
4YOR532
5.02
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN JOAQUIN
PREET KAMAL, SABREEN KAUR, CaseNo Sano 149
KANWAR SINGH WALIA, and
SATVIR KAUR ATWAL, COMPLAINT FOR
PERSONAL INJURIES
Plaintiff,
vs. : (Damages exceed $25,000.00)
NEVIN SLEDGE and DOES 1 through THIS CASE HAS BEEN ASSIG
25, inclusive, sUDGE BARBARA A. KR ONLUND on
Defendants. PARTMENT 10D FOR ALL Pi 4
: INCLUDING TRIAL URPOSES,
Plaintiffs PREET KAMAL, SABREEN KAUR, KANWAR SINGH WALIA, and
SATVIR KAUR ATWAL allege against defendants NEVIN SLEDGE and DOES | through 25,
inclusive, as follows that:
FIRST CAUSE OF ACTION
(Negligence)
1. The true names or capacities, whether individual, corporate, associate or otherwise
of defendants, DOES 1 through 25, inclusive, are unknown to plaintiff who therefore sues said
defendants by such fictitious names. Plaintiff is informed and believes, and thereon alleges that
each of the defendants, designated herein as a DOE is legally responsible in some manner for the
EES
COMPLAINT FOR PERSONAL INJURIES - 1
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events and happenings herein referred to, and legally caused injury and damage proximately
thereby to plaintiff, as herein alleged.
2, Plaintiff is further informed and believes and thereon alleges that defendants, and
cach of them, are and were at all times herein mentioned the agent, servant or employee of each
of the other defendants and were at all times herein mentioned acting within the course and scope
of said agency, service and employment and acting with the consent and knowledge of each other
defendant.
3, Atall times herein mentioned, defendants, NEVIN SLEDGE and DOES 1 through
25 inclusive, and each of them, were the owners of a 2005 Toyota Tundra, California license
number 7827405.
4, At all times herein mentioned, defendants, NEVIN SLEDGE and DOES 1 through 25
inclusive, and each of them, were operating the 2005 Toyota Tundra, California license number
7827405 with the consent, permission and knowledge of each of the remaining defendants.
5. At all times herein mentioned northbound I-5 one mile south of Tumer Road was
in the County of San Joaquin, State of California.
6. On or about April 16, 2017, plaintiff SABREEN KAUR was operating a motor
vehicle which was traveling northbound on I-5, south of Turner Road in the County of San
Joaquin, State of California.
7. At said time and place, defendants and each of them, so negligently and carelessly
entrusted, managed, maintained, controlled, owned, and operated their afore described motor
vehicle traveling along and upon northbound I-5, south of Turner Road, County of San Joaquin,
so as to proximately cause said vehicle to collide with the vehicle in which plaintiffs were riding
and so proximately caused the hereinafter described damages and injuries to plaintiffs.
——eeee
COMPLAINT FOR PERSONAL INJURIES - 2ood AR PR Ww PY
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8. As a direct and proximate result of the aforesaid conduct of the defendants, and
each of them, plaintiffs were hurt and injured in health, strength, and activity, sustaining injuries
to body, and shock and injury to nervous system and person, all of which have caused and
continue to cause great mental and physical pain, suffering, and nervousness. Plaintiffs are
informed and believe and thercon allege, that the injuries will result in some permanent disability
to the plaintiffs, all to their general damage in an amount in excess of the jurisdictional limits of
this court, which wil! be shown according to proof at the time of trial.
9. As a further proximate result of the acts of the defendants, and each of them,
plaintiffs were required to employ, and continue to employ, physicians and surgeons to examine,
treat and care for them and did and continue to incur medical and incidental expenses which will
be shown according to proof at time of trial.
10. Asa further proximate result of the said acts of the defendants, and each of them,
plaintiffs were prevented from attending to their usual occupations for a period, sustaining loss
of earnings in an amount unknown to them at this time, but which will be shown according to
proof, Plaintiffs are informed and believe and thereon allege that they will be prevented from
attending to said usual occupations for a period in the future and will sustain further Joss of
earnings, all in an amount unknown to plaintiffs at this time, but which will be shown according
to proof at the time of trial.
11, Prejudgment interest on the damages alleged herein should be awarded should
judgment for Plaintiffs be rendered; that said sum should be calculated from the time the cause off
action arose or as provided in the California Civil Code.
12. At all times relevant herein, defendants and each of them negligently hired,
supervised and trained each of the other defendants so as to proximately cause the hereinafter
described damages and injuries to plaintiffs.
——e SS
COMPLAINT FOR PERSONAL INJURIES - 3m
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13. As a further proximate result of the said acts of the Defendants, and each of them,
Plaintiffs were prevented from completing their usual household activities sustaining a loss of
household services in an amount unknown to them at this time, but which will be shown
according to proof. Plaintiffs are informed and believe and thereon allege that they will be
prevented from completing their usual household activities for a period in the future and will
sustain further loss of household services, all in an amount unknown to Plaintiffs at this time, but
which will be shown according to proof at the time of trial.
SECOND CAUSE OF ACTION
(Property Damage)
Plaintiffs PREET KAMAL, SABREEN KAUR, KANWAR SINGH WALIA, and
SATVIR KAUR ATWAL hereby incorporate by reference paragraphs 1 through 13 of the First
Cause of Action as though fully set forth herein, and alleges against defendants NEVIN SLEDGE
and DOES 1 through 25, inclusive, as follows that:
14. Asa further, direct and proximate result of said carelessness and negligence of the
defendants, and each of them, said vehicle owned by plaintiff KAMAL PREET was damaged and
plaintiff was denied the use of plaintiff's vehicle and other property, to plaintiff's further damage,
all in an amount which will be shown according to proof.
WHEREFORE, plaintiffs pray judgment against defendants, and each of them, as
hereinafter follows:
1, For general damages in excess of the jurisdictional limits of this court according
to proof,
2. For loss of earnings, loss of earning capacity, medical expenses, al! incidental
expenses and special damages according to proof;
3. For property damage and loss of use of property according to proof;
4. For loss of household services;
5. For prejudgment interest on the award for damages rendered in favor of plaintiff,
calculated from the time the cause of action arose, or as provided in the California Civil Code;
a ce
COMPLAINT FOR PERSONAL INJURIES - 4Oo om IY DH RF Ww Ye
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6. For costs of suit; and
patep: Y-//— 79
COMPLAINT FOR PERSONAL INJURIES - 5
7. For such other and further relief as the court deems proper.
AMAR SHERGILL
Attomey for Plaintiff(s)
Preview
_ om ND HA Bw Rey Py YPN — BSeRRRBBRRBESRERRRRSERHKS ORIGINAL SUPE Amar Shergill, SBN 219385 mi SHERGILL LAW FIRM TAPR IT py 1104 Corporate Way Ros 3 ao Sacramento, CA 95831 NQUE, Telephone: (916) 564-5781 2 yoo Fe Facsimile: (916) 564-2764 ia E-mail: amar@shergilllawfirm.com Attomey for Plaintiffs 4YOR532 5.02 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN JOAQUIN PREET KAMAL, SABREEN KAUR, CaseNo Sano 149 KANWAR SINGH WALIA, and SATVIR KAUR ATWAL, COMPLAINT FOR PERSONAL INJURIES Plaintiff, vs. : (Damages exceed $25,000.00) NEVIN SLEDGE and DOES 1 through THIS CASE HAS BEEN ASSIG 25, inclusive, sUDGE BARBARA A. KR ONLUND on Defendants. PARTMENT 10D FOR ALL Pi 4 : INCLUDING TRIAL URPOSES, Plaintiffs PREET KAMAL, SABREEN KAUR, KANWAR SINGH WALIA, and SATVIR KAUR ATWAL allege against defendants NEVIN SLEDGE and DOES | through 25, inclusive, as follows that: FIRST CAUSE OF ACTION (Negligence) 1. The true names or capacities, whether individual, corporate, associate or otherwise of defendants, DOES 1 through 25, inclusive, are unknown to plaintiff who therefore sues said defendants by such fictitious names. Plaintiff is informed and believes, and thereon alleges that each of the defendants, designated herein as a DOE is legally responsible in some manner for the EES COMPLAINT FOR PERSONAL INJURIES - 1 File RIOR Cour XV4 Ad© oY A UW RB WwW HD a SU ae AAA ROP HS 21 events and happenings herein referred to, and legally caused injury and damage proximately thereby to plaintiff, as herein alleged. 2, Plaintiff is further informed and believes and thereon alleges that defendants, and cach of them, are and were at all times herein mentioned the agent, servant or employee of each of the other defendants and were at all times herein mentioned acting within the course and scope of said agency, service and employment and acting with the consent and knowledge of each other defendant. 3, Atall times herein mentioned, defendants, NEVIN SLEDGE and DOES 1 through 25 inclusive, and each of them, were the owners of a 2005 Toyota Tundra, California license number 7827405. 4, At all times herein mentioned, defendants, NEVIN SLEDGE and DOES 1 through 25 inclusive, and each of them, were operating the 2005 Toyota Tundra, California license number 7827405 with the consent, permission and knowledge of each of the remaining defendants. 5. At all times herein mentioned northbound I-5 one mile south of Tumer Road was in the County of San Joaquin, State of California. 6. On or about April 16, 2017, plaintiff SABREEN KAUR was operating a motor vehicle which was traveling northbound on I-5, south of Turner Road in the County of San Joaquin, State of California. 7. At said time and place, defendants and each of them, so negligently and carelessly entrusted, managed, maintained, controlled, owned, and operated their afore described motor vehicle traveling along and upon northbound I-5, south of Turner Road, County of San Joaquin, so as to proximately cause said vehicle to collide with the vehicle in which plaintiffs were riding and so proximately caused the hereinafter described damages and injuries to plaintiffs. ——eeee COMPLAINT FOR PERSONAL INJURIES - 2ood AR PR Ww PY YPN Y NM YP NY RK NF Be Be eB ee Be ee any AA RYH F FB DMA AH BF BW BK SD 8. As a direct and proximate result of the aforesaid conduct of the defendants, and each of them, plaintiffs were hurt and injured in health, strength, and activity, sustaining injuries to body, and shock and injury to nervous system and person, all of which have caused and continue to cause great mental and physical pain, suffering, and nervousness. Plaintiffs are informed and believe and thercon allege, that the injuries will result in some permanent disability to the plaintiffs, all to their general damage in an amount in excess of the jurisdictional limits of this court, which wil! be shown according to proof at the time of trial. 9. As a further proximate result of the acts of the defendants, and each of them, plaintiffs were required to employ, and continue to employ, physicians and surgeons to examine, treat and care for them and did and continue to incur medical and incidental expenses which will be shown according to proof at time of trial. 10. Asa further proximate result of the said acts of the defendants, and each of them, plaintiffs were prevented from attending to their usual occupations for a period, sustaining loss of earnings in an amount unknown to them at this time, but which will be shown according to proof, Plaintiffs are informed and believe and thereon allege that they will be prevented from attending to said usual occupations for a period in the future and will sustain further Joss of earnings, all in an amount unknown to plaintiffs at this time, but which will be shown according to proof at the time of trial. 11, Prejudgment interest on the damages alleged herein should be awarded should judgment for Plaintiffs be rendered; that said sum should be calculated from the time the cause off action arose or as provided in the California Civil Code. 12. At all times relevant herein, defendants and each of them negligently hired, supervised and trained each of the other defendants so as to proximately cause the hereinafter described damages and injuries to plaintiffs. ——e SS COMPLAINT FOR PERSONAL INJURIES - 3m eC oN A HW Pw DN BRRSRRERBBEEBETVCERVRAREBEES 13. As a further proximate result of the said acts of the Defendants, and each of them, Plaintiffs were prevented from completing their usual household activities sustaining a loss of household services in an amount unknown to them at this time, but which will be shown according to proof. Plaintiffs are informed and believe and thereon allege that they will be prevented from completing their usual household activities for a period in the future and will sustain further loss of household services, all in an amount unknown to Plaintiffs at this time, but which will be shown according to proof at the time of trial. SECOND CAUSE OF ACTION (Property Damage) Plaintiffs PREET KAMAL, SABREEN KAUR, KANWAR SINGH WALIA, and SATVIR KAUR ATWAL hereby incorporate by reference paragraphs 1 through 13 of the First Cause of Action as though fully set forth herein, and alleges against defendants NEVIN SLEDGE and DOES 1 through 25, inclusive, as follows that: 14. Asa further, direct and proximate result of said carelessness and negligence of the defendants, and each of them, said vehicle owned by plaintiff KAMAL PREET was damaged and plaintiff was denied the use of plaintiff's vehicle and other property, to plaintiff's further damage, all in an amount which will be shown according to proof. WHEREFORE, plaintiffs pray judgment against defendants, and each of them, as hereinafter follows: 1, For general damages in excess of the jurisdictional limits of this court according to proof, 2. For loss of earnings, loss of earning capacity, medical expenses, al! incidental expenses and special damages according to proof; 3. For property damage and loss of use of property according to proof; 4. For loss of household services; 5. For prejudgment interest on the award for damages rendered in favor of plaintiff, calculated from the time the cause of action arose, or as provided in the California Civil Code; a ce COMPLAINT FOR PERSONAL INJURIES - 4Oo om IY DH RF Ww Ye PP NN RYN SF Be we Be ee Be Se BNRRRPEBBEEREBEBURABDEBERE S 6. For costs of suit; and patep: Y-//— 79 COMPLAINT FOR PERSONAL INJURIES - 5 7. For such other and further relief as the court deems proper. AMAR SHERGILL Attomey for Plaintiff(s)