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Electronically Filed by Superior Court of California, County of f Orange, 06/: 12/2023 11:40:12 AM.
Vt Ht TAMASAI 4 tere
APIORADY.SR PARTY WAAOUT ATTORNET didmne, SoleAbr fuhoar BA ‘adaress): Hh 1 By KClimer, Deputy CleRLD-PI-001
FOR COURT
USE ONLY
;- WILLIAM K. GAMBLE, 43367
WILLIAM K. GAMBLE LAW FIRM
301 E. COOK STREET, SUITE E
SANTA MARIA, CA 93454
TeverHone
No: (805) 922-8308 FAXNo(Optiona): (805) 928-3514
E-MAIL ADDRESS (Optional): GETGAMBLEPATTY@GMAIL.COM
ATTORNEY FOR (Name): DEVON BINH VU
SUPERIOR COURT OF CALIFORNIA, COUNTY OF ORANGE COUNTY
streetappress: 700 CIVIC CENTER DRIVE
MAILING ADDRESS:
ciryanoziecoos: SANTA ANA, CA 92701
ranch Name: CENTRAL JUSTICE CENTER
PLAINTIFF: DEVON BINH VU
DEFENDANT: HANNA HUE NGUYEN
[K) does
1 To 25 INCLUSTVE.
COMPLAINT-Personal Injury, Property Damage, Wrongful Death
(2 AMENDED (Number):
Type (check all that apply):
CQ) MOTOR VEHICLE Cy OTHER (specify):
CC) Property Damage CC) Wrongful Death
(&) Personal Injury () Other Damages (specify):
Jurisdiction (check all that apply): ‘CASE NUMBER:
(CQ ACTION Is A LIMITED CIVIL CASE
Amount demanded [(] does not exceed $10,000 | 30-2023-01330355-CU-PA-CIC
CD exceeds $10,000, but does not exceed $25,000
(CQ) ACTION Is AN UNLIMITED CIVIL CASE (exceeds $25,000)
(2) ACTION Is RECLASSIFIED by this amended complaint Assigned for All Purposes
CC) from limited to unlimited Judge Theodore Howard
() from unlimited to limited
Plaintiff (na
orme
names): DEVON BINH VU
alleges causes of action against defendant (name ornames): HANNA HUE NGUYEN, AND DOES
1 THROUGH 25, INCLUSIVE.
This pleading, including attachments and exhibits, consists of the following number of
pages: 4
Each plaintiff named above is a competent adult
a. () except plaintiff (name):
(1) () a corporation qualified to do business in California
(2) CQ an unincorporated entity (describe):
(3) () a public entity (describe):
(4) CQ a minor () an aduit
(a) (2) for whom a guardian or conservator of the estate or a guardian ad litem has been appointed
(b) CQ} other (specify):
(5) C2) other (specify):
b. (C) except plaintiff (name):
(1) a corporation qualified to do business in California
(2) C) an unincorporated entity (describe):
(3) CQ a public entity (describe):
(4) CQ a minor CD anadutt
(@) (2) for whom a guardian or conservator of the estat ite or a guardian ad litem has been appointed
(b) CE) other (specify):
(8) CQ other (specify):
(C} Information about additional plaintiffs who are not competent adults is shown in Attachment
3.
Page 1 of 3
“ate Co incil{orof Optional
Californ
Use COMPLAINT-Personal Injury, Property Code of Givi Procedure, a4 5.12
PLD-PI-001 [Rev. January 1, "207 CEB {=Forms- Damage, Wrongful Death gov
VU, DEVON BINH
SE
PLD-PI-001
SHORT TITLE: CASE NUMBER:
vU_v. NGUYEN
4. [) Plaintiff (name):
is doing business under the fictitious name (specify):
and has complied with the fictitious business name laws.
5. Each defendant named above is a natural person
a. [X] except defendant (name): c. [] except defendant (name):
DOES 1 THROUGH 25
(1) (2) a business organization, form unknown (1) (QQ abusiness organization, form unknown
(2) [) acorporation (2) () acorporation
(3) (QQ an unincorporated entity (describe): (3) [CQ an unincorporated entity (describe):
(4) (CQ a public entity (describe): (4) (CQ a public entity (describe):
(8) [&) other (specify): (6) CQ other (specify):
FORM UNKNOWN
b. (2) except defendant (name): d. (2) except defendant (name):
(1) (2) a business organization, form unknown (1) () a business organization, form unknown
(2) CQ acorporation (2) [) acorporation
(3) (2) an unincorporated entity (describe): (3) CQ an unincorporated entity (describe):
(4) (2) a public entity (describe): 4) (Qa public entity (describe):
6) () other (specify): (©) C) other (specify):
() Information about additional defendants who are not natural persons is contained in Attachment 5.
The true names of defendants sued as Does are unknown to plaintiff.
a. [&] Doe defendants (specify Doe numbers): THR1_ OUG 25 were
H the agents or employees of other
named defendants and acted within the scope of that agency or employment.
b. [Q) Doe defendants (specify Doe numbers): are persons whose capacities are unknown to
plaintiff.
(C) Defendants who are joined under Code of Civil Procedure section 382 are (names):
This court is the proper court because
a. . [) at least one defendant now resides in its jurisdictional area.
b. . LL) the principal place of business of a defendant co poration or unincorporated association is in its jurisdiction
al area.
c. injury to person or damage to personal property occurred in its jurisdictional area.
d . [C} other (specify):
() Plaintiff is required to comply with a claims statute, and
a. (] has complied with applicable claims statutes, or
b. (L) is excused from complying because (specify):
PLD-PI-001 [Rev. January 1, 2007] COMPLAINT-Personal Injury, Property Page
2 of 3
GE | come Damage, Wrongful Death
VU, DEVON BINH
a ee
ee
PLD-PI-001
SHORT TITLE: CASE NUMBER:
VU v. NGUYEN
10. The following causes of action are attached and the statements above apply to each (each complaint must
have one or more
causes of action attached):
[Q Motor Vehicle
CQ General Negligence
C) Intentional Tort
CC) Products Liability
CC} Premises Liability
CL) Other (specify) :
11 Plaintiff has suffered
CQ) wage loss
[&} loss of use of property
[X) hospital and medical expenses
CQ general damage
() property damage
[X} loss of earning capacity
[&) other damage (specify) :
PRE-JUDGMENT INTEREST ACCORDING TO PROOF
12. (CC) The damages claimed for wrongful death and the relationships of plaintiff to the deceased are
a (CC) listed in Attachment 12.
b. (2) as follows:
13. The relief sought in this complaint is within the jurisdiction of this court.
14, Plaintiff prays for judgment for costs of suit; for such relief as is fair, just, and equitable; and for
a (1) QQ compensatory damages
(2) () punitive damages
The amount of damages is (in cases for personal injury or wrongful death, you must check (1)).
(1) GQ) according to proof
(2) C) in the amount of: $
15. (QQ The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers):
S(a), 5 (b)
Date: JUNE 12, 2023
ee
WILLIAM K. GAMBLE
(TYPE OR PRINT NAME) > (SIGNATURE OF PLAINTIFF OR ATTORNEY)
PLD-PL004 [Rev. January 1, 2007] COMPLAINT-Personal Injury, Property Page
3 of 3
Damage, Wrongful Death
GB | Eton VU, DEVON BINH
=
PLD-PI-001(1
SHORT TITLE: CASE NUMBER:
VU v. NGUYEN
ELRST ates CAUSE OF ACTION- Motor Vehicle
ATTACHMENT TO [XJ Complaint C2) Cross-Complaint
(Use a separate cause of action form for each cause of action.)
Plaintiff (name): DEVON BINH VU
MV-1. Plaintiff alleges the acts of defendants were negligent; the acts were the legal (proximate) cause of injuries
and damages to plaintiff; the acts occurred
‘on (date): SEPTEMBER 27, 2022
at (place): CITY OF WESTMINSTER, COUNTY OF ORANGE, STATE OF CALIFORNIA, ON BEACH
BLVD. AT THE INTERSECTION OF MCFADDEN AVENUE, PLAINTIFF WAS STOPPED
FOR THE RED LIGHT IN THE NUMBER 1 LANE OF BEACH BLVD. AT MCFADDEN
AVE. THE LIGHT FOR NORTHBOUND TRAFFIC TURNED GREEN AND NORTHBOUND
TRAFFIC STARTED MOVING. AS MR. VU ENTERED INTO THE INTERSECTION, HE
COLLIDED WITH DEFENDANT, HANNA EUE NGUYEN'S VEHICLE AFTER SHE RAN THE
LIGHT, DEFENDANT THEN COLLIDED WITH A THIRD VEHICLE.
MV-2. DEFENDANTS
a. (XJ) The defendants who operated a motor vehicle are (names):
HANNA HUE NGUYEN, AND
[EQ Does Pneiarnt to 25,
tc
b. EX] The defendants who employed the persons who operated a motor vehicle in the course of their employment
are (names): HANNA HUE NGUYEN, AND
(K) Does J to 1ncL.
25,
c. [QJ The defendants who owned the motor vehicle which was operated with their permission are(names):
HANNA HUE NGUYEN, AND
4
() Does to tNcL.
25,
d. [X] The defendants who entrusted the motor vehicle are (names):
HANNA HUE NGUYEN, AND
[XQ] Does fo 25,1NcL
e. (XQ The defendants who were the agents and employees of the other defendants and acted within the scope
of the agency were (names):
HANNA HUE NGUYEN, AND
[D Does it __ to tcl 25,
f. (QQ The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are
(2) listed in Attachment MV-2f [XJ as follows:
HANNA HUE NGUYEN, AND DOES 1 THROUGH 25, ACCORDING TO
PROOF.
CC) Does to
Page 4___
Page 1 of 1
Form Approved for Optional Use Code of Civil Procedure § 425.12
ludicial Council of California CAUSE OF ACTION - Motor Vehicle
PLD-PI-001(1) [Rev. January 1, www, courtinfo.ca.gov
VU, DEVON BINH
CB | penne
Preview
oe Electronically Filed by Superior Court of California, County of f Orange, 06/: 12/2023 11:40:12 AM. Vt Ht TAMASAI 4 tere APIORADY.SR PARTY WAAOUT ATTORNET didmne, SoleAbr fuhoar BA ‘adaress): Hh 1 By KClimer, Deputy CleRLD-PI-001 FOR COURT USE ONLY ;- WILLIAM K. GAMBLE, 43367 WILLIAM K. GAMBLE LAW FIRM 301 E. COOK STREET, SUITE E SANTA MARIA, CA 93454 TeverHone No: (805) 922-8308 FAXNo(Optiona): (805) 928-3514 E-MAIL ADDRESS (Optional): GETGAMBLEPATTY@GMAIL.COM ATTORNEY FOR (Name): DEVON BINH VU SUPERIOR COURT OF CALIFORNIA, COUNTY OF ORANGE COUNTY streetappress: 700 CIVIC CENTER DRIVE MAILING ADDRESS: ciryanoziecoos: SANTA ANA, CA 92701 ranch Name: CENTRAL JUSTICE CENTER PLAINTIFF: DEVON BINH VU DEFENDANT: HANNA HUE NGUYEN [K) does 1 To 25 INCLUSTVE. COMPLAINT-Personal Injury, Property Damage, Wrongful Death (2 AMENDED (Number): Type (check all that apply): CQ) MOTOR VEHICLE Cy OTHER (specify): CC) Property Damage CC) Wrongful Death (&) Personal Injury () Other Damages (specify): Jurisdiction (check all that apply): ‘CASE NUMBER: (CQ ACTION Is A LIMITED CIVIL CASE Amount demanded [(] does not exceed $10,000 | 30-2023-01330355-CU-PA-CIC CD exceeds $10,000, but does not exceed $25,000 (CQ) ACTION Is AN UNLIMITED CIVIL CASE (exceeds $25,000) (2) ACTION Is RECLASSIFIED by this amended complaint Assigned for All Purposes CC) from limited to unlimited Judge Theodore Howard () from unlimited to limited Plaintiff (na orme names): DEVON BINH VU alleges causes of action against defendant (name ornames): HANNA HUE NGUYEN, AND DOES 1 THROUGH 25, INCLUSIVE. This pleading, including attachments and exhibits, consists of the following number of pages: 4 Each plaintiff named above is a competent adult a. () except plaintiff (name): (1) () a corporation qualified to do business in California (2) CQ an unincorporated entity (describe): (3) () a public entity (describe): (4) CQ a minor () an aduit (a) (2) for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b) CQ} other (specify): (5) C2) other (specify): b. (C) except plaintiff (name): (1) a corporation qualified to do business in California (2) C) an unincorporated entity (describe): (3) CQ a public entity (describe): (4) CQ a minor CD anadutt (@) (2) for whom a guardian or conservator of the estat ite or a guardian ad litem has been appointed (b) CE) other (specify): (8) CQ other (specify): (C} Information about additional plaintiffs who are not competent adults is shown in Attachment 3. Page 1 of 3 “ate Co incil{orof Optional Californ Use COMPLAINT-Personal Injury, Property Code of Givi Procedure, a4 5.12 PLD-PI-001 [Rev. January 1, "207 CEB {=Forms- Damage, Wrongful Death gov VU, DEVON BINH SE PLD-PI-001 SHORT TITLE: CASE NUMBER: vU_v. NGUYEN 4. [) Plaintiff (name): is doing business under the fictitious name (specify): and has complied with the fictitious business name laws. 5. Each defendant named above is a natural person a. [X] except defendant (name): c. [] except defendant (name): DOES 1 THROUGH 25 (1) (2) a business organization, form unknown (1) (QQ abusiness organization, form unknown (2) [) acorporation (2) () acorporation (3) (QQ an unincorporated entity (describe): (3) [CQ an unincorporated entity (describe): (4) (CQ a public entity (describe): (4) (CQ a public entity (describe): (8) [&) other (specify): (6) CQ other (specify): FORM UNKNOWN b. (2) except defendant (name): d. (2) except defendant (name): (1) (2) a business organization, form unknown (1) () a business organization, form unknown (2) CQ acorporation (2) [) acorporation (3) (2) an unincorporated entity (describe): (3) CQ an unincorporated entity (describe): (4) (2) a public entity (describe): 4) (Qa public entity (describe): 6) () other (specify): (©) C) other (specify): () Information about additional defendants who are not natural persons is contained in Attachment 5. The true names of defendants sued as Does are unknown to plaintiff. a. [&] Doe defendants (specify Doe numbers): THR1_ OUG 25 were H the agents or employees of other named defendants and acted within the scope of that agency or employment. b. [Q) Doe defendants (specify Doe numbers): are persons whose capacities are unknown to plaintiff. (C) Defendants who are joined under Code of Civil Procedure section 382 are (names): This court is the proper court because a. . [) at least one defendant now resides in its jurisdictional area. b. . LL) the principal place of business of a defendant co poration or unincorporated association is in its jurisdiction al area. c. injury to person or damage to personal property occurred in its jurisdictional area. d . [C} other (specify): () Plaintiff is required to comply with a claims statute, and a. (] has complied with applicable claims statutes, or b. (L) is excused from complying because (specify): PLD-PI-001 [Rev. January 1, 2007] COMPLAINT-Personal Injury, Property Page 2 of 3 GE | come Damage, Wrongful Death VU, DEVON BINH a ee ee PLD-PI-001 SHORT TITLE: CASE NUMBER: VU v. NGUYEN 10. The following causes of action are attached and the statements above apply to each (each complaint must have one or more causes of action attached): [Q Motor Vehicle CQ General Negligence C) Intentional Tort CC) Products Liability CC} Premises Liability CL) Other (specify) : 11 Plaintiff has suffered CQ) wage loss [&} loss of use of property [X) hospital and medical expenses CQ general damage () property damage [X} loss of earning capacity [&) other damage (specify) : PRE-JUDGMENT INTEREST ACCORDING TO PROOF 12. (CC) The damages claimed for wrongful death and the relationships of plaintiff to the deceased are a (CC) listed in Attachment 12. b. (2) as follows: 13. The relief sought in this complaint is within the jurisdiction of this court. 14, Plaintiff prays for judgment for costs of suit; for such relief as is fair, just, and equitable; and for a (1) QQ compensatory damages (2) () punitive damages The amount of damages is (in cases for personal injury or wrongful death, you must check (1)). (1) GQ) according to proof (2) C) in the amount of: $ 15. (QQ The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers): S(a), 5 (b) Date: JUNE 12, 2023 ee WILLIAM K. GAMBLE (TYPE OR PRINT NAME) > (SIGNATURE OF PLAINTIFF OR ATTORNEY) PLD-PL004 [Rev. January 1, 2007] COMPLAINT-Personal Injury, Property Page 3 of 3 Damage, Wrongful Death GB | Eton VU, DEVON BINH = PLD-PI-001(1 SHORT TITLE: CASE NUMBER: VU v. NGUYEN ELRST ates CAUSE OF ACTION- Motor Vehicle ATTACHMENT TO [XJ Complaint C2) Cross-Complaint (Use a separate cause of action form for each cause of action.) Plaintiff (name): DEVON BINH VU MV-1. Plaintiff alleges the acts of defendants were negligent; the acts were the legal (proximate) cause of injuries and damages to plaintiff; the acts occurred ‘on (date): SEPTEMBER 27, 2022 at (place): CITY OF WESTMINSTER, COUNTY OF ORANGE, STATE OF CALIFORNIA, ON BEACH BLVD. AT THE INTERSECTION OF MCFADDEN AVENUE, PLAINTIFF WAS STOPPED FOR THE RED LIGHT IN THE NUMBER 1 LANE OF BEACH BLVD. AT MCFADDEN AVE. THE LIGHT FOR NORTHBOUND TRAFFIC TURNED GREEN AND NORTHBOUND TRAFFIC STARTED MOVING. AS MR. VU ENTERED INTO THE INTERSECTION, HE COLLIDED WITH DEFENDANT, HANNA EUE NGUYEN'S VEHICLE AFTER SHE RAN THE LIGHT, DEFENDANT THEN COLLIDED WITH A THIRD VEHICLE. MV-2. DEFENDANTS a. (XJ) The defendants who operated a motor vehicle are (names): HANNA HUE NGUYEN, AND [EQ Does Pneiarnt to 25, tc b. EX] The defendants who employed the persons who operated a motor vehicle in the course of their employment are (names): HANNA HUE NGUYEN, AND (K) Does J to 1ncL. 25, c. [QJ The defendants who owned the motor vehicle which was operated with their permission are(names): HANNA HUE NGUYEN, AND 4 () Does to tNcL. 25, d. [X] The defendants who entrusted the motor vehicle are (names): HANNA HUE NGUYEN, AND [XQ] Does fo 25,1NcL e. (XQ The defendants who were the agents and employees of the other defendants and acted within the scope of the agency were (names): HANNA HUE NGUYEN, AND [D Does it __ to tcl 25, f. (QQ The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are (2) listed in Attachment MV-2f [XJ as follows: HANNA HUE NGUYEN, AND DOES 1 THROUGH 25, ACCORDING TO PROOF. CC) Does to Page 4___ Page 1 of 1 Form Approved for Optional Use Code of Civil Procedure § 425.12 ludicial Council of California CAUSE OF ACTION - Motor Vehicle PLD-PI-001(1) [Rev. January 1, www, courtinfo.ca.gov VU, DEVON BINH CB | penne