On July 07, 2020 a
Complaint,Petition
was filed
involving a dispute between
Estate Of Moises Hernandez, Sr., By And Through Its Successor In Interest Justine,
Guillen, Yadira,
Hernandez Jr., Moises,
Hernandez, Justine,
Hernandez Moreno, Jesus Alberto,
Hernandez Moreno, Mayra Candelaria,
and
Apostolic Assembly Of The Faith In Christ Jesus, A California Corporation,
San Diego Gas & Electric Company A California Corporation,
Sempra Energy A California Corporation,
for PI personal injury not MV
in the District Court of San Bernardino County.
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GREENE BROILLET WHEELER LLP SPACE BELOW FOR FILING STAMP ONLY
1
LAWYERS
100 WILSHIRE BOULEVARD SUITE 2100
2 P O BOX 2131
SANTA MONICA CALIFORNIA 90407 2131
TEL 310 5 s izoo
SUPCa lO t2C UR i CS C ALI
3 FAX 310 576 1220 r s da
OUrJTY C7F SAf F ERN RL l SO
ROBERT D JARCHI State Bar No 204168 sAN z e7 nEo t s o
4 CHRISTIAN T F NICKERSON State Bar No 281084
JUL 0 7 2020
5 Attorneys for Plaintiffs
Y
m
6
se
r er 1r OV i
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF SAN BERNARDINO
10
ESTATE OF MOISES HERNANDEZ SR CASE NO C g bZ
11 by
and through its successor in interest JUSTINE
12 HERNANDEZ JUSTINE HERNANDEZ an COMPLAINT FOR WRONGFUL
individual MOISES HERNANDEZ JR an DEATH
13 individual YADIRA GUILLEN an individual
MAYRA CANDELARIA HERNANDEZ 1 Negligence
14 MORENO an individual JESUS ALBERTO 2 Negligence
HERNANDEZ MORENO an individual 3 Negligence Premises
15 4 Survival Action
Plaintiffs
16 DEMAND FOR JURY TRIAL
vs
17
SAN DIEGO GAS ELECTRIC COMPANY
18 a California Corporation SEMPRA ENERGY
a California Corporation and APOSTOLIC
19 ASSEMBLY OF THE FAITH IN CHRIST
JESUS a California Corporation dba North
20 Coast Fellowship and DOES 1 through 100
inclusive
21
Defendants
22
23
COME NOW the plaintiffs ESTATE OF MOISES HERNANDEZ SR by and through
24
its Successor in Interest JLJSTINE HERNANDEZ JUSTINE HERNANDEZ individually
25
MOISES HERNANDEZ JR individually YADIRA GUILLEN individually MAYRA
26
CANDELARIA HERNANDEZ MORENO individually JESUS ALBERTO HERNANDEZ
27
MORENO individually and for causes of action against defendants SAN DIEGO GAS
28
1
920855 COMPLAINT FOR DAMAGES
1 ELECTRIC COMPANY a California Corporation SEMPRA ENERGY a California
2 Corporation and APOSTOLIC ASSEMBLY OF THE FAITH IN CHRIST JESUS a California
3 Corporation dba North Coast Fellowship and DOES 1 through 100 inclusive and each of them
4 allege
5
6 GENERAL ALLEGATIONS
7 1 Plaintiffs JUSTINE HERNANDEZ MOISES HERNANDEZ JR YADIRA
8 GUILLEN MAYRA CANDELARIA HERNANDEZ MORENO JESUS ALBERTO
9 HERNANDEZ MORENO are the surviving children of Moises Hernandez Sr Plaintiffs
10 decedent JiJSTINE HERNANDEZ is successor in interest to decedent Moises Hernandez Sr
11 pursuant to California Code of Civil Procedure 377 10 377 11 and she has declared herself as
a
M 12 such as required
by California Code of Civil Procedure 377 32 See attached Declaration of
W N
W 13 Justine Hernandez
N Q 14 2 The true names and capacities whether individual corporate associate or otherwise
X
m U
o z 15 of defendants DOES 1 through l 00 inclusive and each of them are unknown to plaintiffs who
a
m a 16 therefore sue said defendants by such fictitious names Plaintiffs are informed and believe and
w Q
17 thereupon allege that each of the defendants fictitiously named herein as a DOE is legally
c
18 responsible negligently or in some other actionable manner for the events and happenings
19 referred to and thereby proximately caused the injuries to Plaintiffs as hereinafter alleged
20 Plaintiffs will seek leave of court to amend this Complaint and state the true names and or
21 capacities of said fictitiously named defendants when the same have been ascertained
22 3 Plaintiffs are informed and believe and thereupon allege that at all times mentioned
23 herein defendants and each of them including DOES 1 through 100 inclusive and each of them
24 were the agents servants employees and or joint venturers of their co defendants and each was
25 as such acting within the course scope and authority of said agency employment and or venture
26 and that each and every defendant as aforesaid when acting as a principal was negligent in the
27 selection and hiring each and every other defendant as an agent employee and or joint venture
28
2
920855 COMPLAINT FOR DAMAGES
Document Filed Date
July 07, 2020
Case Filing Date
July 07, 2020
Category
PI personal injury not MV
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GREENE BROILLET WHEELER LLP SPACE BELOW FOR FILING STAMP ONLY 1 LAWYERS 100 WILSHIRE BOULEVARD SUITE 2100 2 P O BOX 2131 SANTA MONICA CALIFORNIA 90407 2131 TEL 310 5 s izoo SUPCa lO t2C UR i CS C ALI 3 FAX 310 576 1220 r s da OUrJTY C7F SAf F ERN RL l SO ROBERT D JARCHI State Bar No 204168 sAN z e7 nEo t s o 4 CHRISTIAN T F NICKERSON State Bar No 281084 JUL 0 7 2020 5 Attorneys for Plaintiffs Y m 6 se r er 1r OV i 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF SAN BERNARDINO 10 ESTATE OF MOISES HERNANDEZ SR CASE NO C g bZ 11 by and through its successor in interest JUSTINE 12 HERNANDEZ JUSTINE HERNANDEZ an COMPLAINT FOR WRONGFUL individual MOISES HERNANDEZ JR an DEATH 13 individual YADIRA GUILLEN an individual MAYRA CANDELARIA HERNANDEZ 1 Negligence 14 MORENO an individual JESUS ALBERTO 2 Negligence HERNANDEZ MORENO an individual 3 Negligence Premises 15 4 Survival Action Plaintiffs 16 DEMAND FOR JURY TRIAL vs 17 SAN DIEGO GAS ELECTRIC COMPANY 18 a California Corporation SEMPRA ENERGY a California Corporation and APOSTOLIC 19 ASSEMBLY OF THE FAITH IN CHRIST JESUS a California Corporation dba North 20 Coast Fellowship and DOES 1 through 100 inclusive 21 Defendants 22 23 COME NOW the plaintiffs ESTATE OF MOISES HERNANDEZ SR by and through 24 its Successor in Interest JLJSTINE HERNANDEZ JUSTINE HERNANDEZ individually 25 MOISES HERNANDEZ JR individually YADIRA GUILLEN individually MAYRA 26 CANDELARIA HERNANDEZ MORENO individually JESUS ALBERTO HERNANDEZ 27 MORENO individually and for causes of action against defendants SAN DIEGO GAS 28 1 920855 COMPLAINT FOR DAMAGES 1 ELECTRIC COMPANY a California Corporation SEMPRA ENERGY a California 2 Corporation and APOSTOLIC ASSEMBLY OF THE FAITH IN CHRIST JESUS a California 3 Corporation dba North Coast Fellowship and DOES 1 through 100 inclusive and each of them 4 allege 5 6 GENERAL ALLEGATIONS 7 1 Plaintiffs JUSTINE HERNANDEZ MOISES HERNANDEZ JR YADIRA 8 GUILLEN MAYRA CANDELARIA HERNANDEZ MORENO JESUS ALBERTO 9 HERNANDEZ MORENO are the surviving children of Moises Hernandez Sr Plaintiffs 10 decedent JiJSTINE HERNANDEZ is successor in interest to decedent Moises Hernandez Sr 11 pursuant to California Code of Civil Procedure 377 10 377 11 and she has declared herself as a M 12 such as required by California Code of Civil Procedure 377 32 See attached Declaration of W N W 13 Justine Hernandez N Q 14 2 The true names and capacities whether individual corporate associate or otherwise X m U o z 15 of defendants DOES 1 through l 00 inclusive and each of them are unknown to plaintiffs who a m a 16 therefore sue said defendants by such fictitious names Plaintiffs are informed and believe and w Q 17 thereupon allege that each of the defendants fictitiously named herein as a DOE is legally c 18 responsible negligently or in some other actionable manner for the events and happenings 19 referred to and thereby proximately caused the injuries to Plaintiffs as hereinafter alleged 20 Plaintiffs will seek leave of court to amend this Complaint and state the true names and or 21 capacities of said fictitiously named defendants when the same have been ascertained 22 3 Plaintiffs are informed and believe and thereupon allege that at all times mentioned 23 herein defendants and each of them including DOES 1 through 100 inclusive and each of them 24 were the agents servants employees and or joint venturers of their co defendants and each was 25 as such acting within the course scope and authority of said agency employment and or venture 26 and that each and every defendant as aforesaid when acting as a principal was negligent in the 27 selection and hiring each and every other defendant as an agent employee and or joint venture 28 2 920855 COMPLAINT FOR DAMAGES