FILED

&.mertor Court of Callfomla

, • County of Los Anaeles
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Daniel A. Reisman (SBN 250819)

Erin Reisman (SBN 248426) MAY 14 2018
2 REISMAN & REISMAN Sherri A. , uve OfficedClelt(
5900 Wilshire Blvd., Suite 2600 BY,. . Deputy
3 Los Angeles, CA 90036 en
Tel: (323) 330-0580
4 Fax: (323) 389-0694
Emai I: [email protected]
5 [email protected]
6
Attorneys for Plaintiff, LAUREN MORGAN
7

8 SUPERIOR COURT OF THE STATE OF CALIFORNIA

9 COUNTY OF LOS ANGELES

10

11 LAUREN MORGAN, an individual, Case No.: BC 7 o5 8 8 8

12 Plaintiff, COMPLAINT FOR:
13 (1) DISCRIMINATION BASED ON
V.
DISABILITY IN VIOLATION OF
14 AMBULNZ HOLDINGS, LLC., a limited FEHA;
liability company; AMBULNZ HEALTH,
15 (2) FAILURE TO ACCOMMODATE A
LLC, a limited liability company; and DOES
1 through 50, inclusive, DISABILITY IN VIOLATION OF
16
FEHA;
17 Defendants.
(3) FAILURE TO ENGAGE IN THE
18 INTERACTIVE PROCESS IN
VIOLATION OF FEHA;
19
(4) RETALIATION;
20

21 (5) WRONGFUL TERMINATION IN

VIOLATION OF PUBLIC POLICY;
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(6) FAILURE TO PAY WAGES;
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(7) WAITING TIME PENALTIES
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- - - - - - - - - - - - - - ~ DEMAND FOR JURY TRIAL BYFA
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28

COMPLAINT
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 1 Plaintiff Lauren Morgan alleges causes of action against Ambulnz Holdings LLC, Ambulnz

2 Health, LLC and Does 1 through 50, inclusive, as follows:

3 Parties
4 1. Defendant Ambulnz Holdings, LLC. is a limited liability company doing business in

5 Los Angeles County, California. Defendant is an entity subject to suit under the California Fair

6 Employment and Housing Act, Government Code section 12900, et seq. ("FEHA").

7 2. Defendant Ambulnz Health, LLC is a limited liability company doing business in

8 Los Angeles County, California. Defendant is an entity subject to suit under FEHA.

9 3. Plaintiff Lauren Morgan is, and at all times material to the allegations in this

10 complaint, was a resident of the State of California, County of Los Angeles.

II 4. Plaintiff is ignorant of the true names and capacities of the defendants sued as Does
12 I through 50, inclusive, and therefore sues these defendants by such fictitious names. Plaintiff will
13 amend this complaint to allege their true names and capacities when ascertained. On information
14 and belief, each of these fictitiously named defendants is responsible in some manner for the

15 occurrences alleged in the complaint, and said defendants proximately caused Plaintiff's injuries.
16 Venue
17 5. This court is the proper venue because the unlawful employment practices and other
18 tortious acts alleged in this complaint occurred in Los Angeles County, California.
19 Factual Allegations
20 6. Defendants employed Plaintiff for as the director of human resources until it
21 unlawfully terminated her employment on or about March 30, 2018. At all times relevant, Plaintiff
22 performed her job in a competent and satisfactory manner.
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27 8. Additionally, before she went out on leave, Plaintiff repeatedly refused to forge
28 documents or signatures on documents.
-2-
COMPLAINT
 1 9. Ultimately, Defendants terminated Plaintiffs employment for pretextual reasons.

2 10. Defendants maintain an unlimited paid time off policy. However, Defendants failed

3 and refused and continue to fail and refuse to pay Plaintiff her wages for the time period that she

4 was on leave and before she was terminated.

5 Exhaustion of Administrative Remedies

6 11. Plaintiff has exhausted her administrative remedies. Plaintiff filed a charge with the

7 Department of Fair Employment and Housing ("DFEH"). The DFEH immediately issued to

8 Plaintiff a right to sue letter. True and correct copies of the charge and the right to sue letter are

9 attached as Exhibit A.

10 First Cause of Action

Discrimination Based on Disability in Violation of FEHA
11 (Against All Defendants)
12 12. Plaintiff incorporates paragraphs 1 through 12 by this reference.

13 13. As detailed in the allegations above, during Plaintiffs employment, Defendants, and

14 each of them, engaged in conduct and continue to engage in conduct that resulted in and continues

15 to result in Plaintiff being treated less favorably because of his disability. Additionally, Plaintiff has

16 been subject to several adverse employment actions, including but not limited to (a) being

17 suspended, (b) being denied the opportunity for promotion or advancement, (c) being denied

18 reinstatement, and (d) being terminated.

19 14. As a direct and proximate result of the discrimination of Defendants, and each of

20 them, Plaintiff has been harmed in that Plaintiff has suffered the loss of wages, salary, benefits, and

21 additional amounts of money Plaintiff would have received if Plaintiff had not been subject to

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22 adverse employment actions. As a result, Plaintiff has suffered such damages in an amount
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24 15. As a further direct and proximate result of the discrimination of Defendants, and
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26 employment-related opportunities. As a result, Plaintiff has suffered such damages in an amount

27 according to proof.

28
-3-
COMPLAINT
 16. As a further direct and proximate result of the discrimination of Defendants, and

2 each of them, Plaintiff has been harmed in that Plaintiff has suffered humiliation, mental anguish,

3 and emotional distress, and has been harmed in mind and body. As a result, Plaintiff has suffered

4 such damages in an amount according to proof.

5 17. The above-recited actions of Defendants, and each of them, were done with malice,

6 fraud, oppression, and in reckless disregard of Plaintiffs rights under FEHA. Accordingly, Plaintiff

7 is entitled to an award of punitive damages.

8
Second Cause of Action
9 Failure to Accommodate Disability in Violation of FEHA
(Against All Defendants)
10

11 18. Plaintiff incorporates paragraphs 1 through 17 by this reference.

12 19. Government Code section 12940 required Defendants, and each of them, to make

13 reasonable accommodations for Plaintiffs disability.

14 20. On information and belief, rather than accommodate Plaintiffs disability,

15 Defendants, and each of them, terminated Plaintiffs employment.

16 21. As a direct and proximate result of the conduct of Defendants, and each of them,

17 Plaintiff has been harmed in that Plaintiff has suffered the loss of wages, salary, benefits, and

18 additional amounts of money Plaintiff would have received. As a result, Plaintiff has suffered such

19 damages in an amount according to proof.

20 22. As a further direct and proximate result of the conduct of Defendants, and each of

21 them, Plaintiff has been harmed in that Plaintiff has suffered the intangible loss of employment-

22 related opportunities. As a result, Plaintiff has suffered such damages in an amount according to
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26 emotional distress, and has been harmed in mind and body. As a result, Plaintiff has suffered such

27 damages in an amount according to proof.

28
--4-
COMPLAINT
 1 24. The above-recited actions of Defendants, and each of them, were done with malice,

2 fraud, oppression, and in reckless disregard of Plaintiffs rights under FEHA. Accordingly, Plaintiff

3 is entitled to an award of punitive damages.

4 Third Cause of Action

Failure to Engage in the Interactive Process in Violation of FEHA
5 (Against All Defendants)
6 25. Plaintiff incorporates paragraphs 1 through 24 by this reference.

7 26. Government Code section 12940(n) makes it unlawful "[f]or an employer or other

8 entity covered by this part to fail to engage in a timely, good faith interactive process with the

9 employee or applicant to determine effective reasonable accommodations, if any, in response to a

10 request for reasonable accommodation by an employee or applicant with a known physical or

11 mental disability or known medical condition."

12 27. Government Code section 12926.1 (e) sates "The Legislature affirms the importance

13 of the interactive practice between the applicant or employee and the employer in determining a

14 reasonable accommodation, as the requirement has been articulated by the Equal Employment

15 Opportunity Commission in its interpretive guidance of the Americans with Disabilities Act."

16 28. As set forth in the allegations above, Defendants, and each of them, were aware of

17 Plaintiffs disability, as she had taken leave and requested accommodations pursuant to her doctor's

18 instructions.

19 29. Further, Defendants, and each of them, refused to engage in a timely good faith

20 process with Plaintiff to determine effective reasonable accommodations as required by California

21 Government Code sections 12940(n) and 12926.l(e).

22 30. Had Defendants, and each of them, engaged in a timely good faith interactive
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26 Plaintiff has been harmed in that Plaintiff has suffered the loss of wages, salary, benefits, and

27 additional amounts of money Plaintiff would have received if Plaintiff had been afforded a good

28

-5-
COMPLAINT
 faith interactive process. As a result, Plaintiff has suffered such damages in an amount according to

2 proof.

3 32. As a further direct and proximate result of the conduct of Defendants, and each of

4 them, Plaintiff has been harmed in that Plaintiff has suffered the intangible loss of employment-

5 related opportunities. As a result, Plaintiff has suffered such damages in an amount according to

6 proof.

7 33. As a further direct and proximate result of the conduct of Defendants, and each of

8 them, Plaintiff has been harmed in that Plaintiff has suffered humiliation, mental anguish, and

9 emotional distress, and has been harmed in mind and body. As a result, Plaintiff has suffered such

10 damages in an amount according to proof.

11 34. The above-recited actions of Defendants, and each of them, were done with malice,

12 fraud, oppression, and in reckless disregard of Plaintiffs rights under FEHA. Accordingly, Plaintiff

13 is entitled to an award of punitive damages.

14 Fourth Cause of Action

Retaliation in Violation of FEHA and Labor Code section 1102.5
15 (Against All Defendants)
16 35. Plaintiff incorporates paragraphs 1 through 34 by this reference.

17 36. As alleged above, Plaintiff requested an accommodation for a disability, which is

18 protected activity under FEHA, and refused to engage in illegal activity, which is

19 protected under Labor Code section 1102.5. Defendants retaliated against Plaintiff by

20 subjecting her to one or more adverse employment actions, including termination.

21 37. As a result, Plaintiff has suffered general and special damages in amounts according to

22 proof.
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26 Fifth Cause of Action

Wrongful Termination in Violation of Public Policy
27 (Against All Defendants)
28 39. Plaintiff incorporates paragraphs 1 through 38 by this reference.

-6-
COMPLAINT
 1 40. Defendants, and each of them, terminated Plaintiffs employment in violation of

2 important and well-established public policies, which are set forth, for example, in the Fair

3 Employment and Housing Act.

4 41. As a direct and proximate result of the conduct of Defendants, and each of them,

5 Plaintiff has suffered special and general damages in amounts to be proven at trial.

6 42. The above-recited actions of Defendants, and each of them, were done with malice,

7 fraud, oppression, and in reckless disregard of Plaintiffs rights. Accordingly, Plaintiff is entitled to

8 an award of punitive damages.

9 Sixth Cause of Action

Failure to Pay Wages
10 (Against All Defendants)
11 43. Plaintiff incorporates paragraphs 1 through 42 by this reference.

12 44. As alleged above, Defendants failed to compensate Plaintiff at her agreed upon wage in

13 violation of the Labor Code.

14 45. As a result, Plaintiff suffered damages. Additionally, Defendants are liable for penalties

15 and Plaintiffs attorneys' fees.

16 Seventh Cause of Action

Waiting time Penalties
17 (Against All Defendants)
18 46. Plaintiff incorporates paragraphs 1 through 45 by this reference. Labor Code section

19 201 requires an employer, who discharges an employee, to pay compensation due and

20 owing to said employee immediately upon discharge. Labor Code section 203 provides

21 that if an employer willfully fails to pay compensation promptly upon discharge in a

22 prompt and timely manner pursuant to Labor Code section 201, said employer is liable
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26 48. As a result, Plaintiff is entitled to damages in an amount to be proven at trial as well as

27 prejudgment interest, penalties, and attorneys' fees.

28 Prayer for Relief

-7-
COMPLAINT
 WHEREFORE Plaintiff prays for judgment against Defendants, and each of them, as follows:

2 (a) For back pay, front pay, and other monetary relief according to proof;

3 (b) For waiting time penalties pursuant to the applicable Labor Code sections;

4 (c) For unpaid wages

5 (d) For general and special damages according to proof;

6 (e) For prejudgment interest according to proof;

7 (t) For reinstatement;

8 (g) For declaratory relief;

9 (h)For injunctive relief;

10 (i) For restitution;

11 (j) For reasonable attorneys' fees and costs, including expert fees;

12 (k)For punitive damages in an amount appropriate to punish Defendants, and each of

13 them, and deter others from engaging in similar misconduct;

14 (I) For costs of suit incurred herein;

15 (m) For any other and further relief as the court deems just and proper.

16
DATED: April 30, 2018 REISMAN & REISMAN
17

18

19

20
By:!2£R
DaniefA. Reisman "-----'
Attorneys for Plaintiff,
21 LAUREN MORGAN
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COMPLAINT
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1 Demand for Jury Trial

2 Plaintiff Lauren Morgan hereby demands a jury trial on all issues so triable.

3
DATED: April 30, 2018 REISMAN & REISMAN
4

7
By: t2 g R
DaniefA. Re·isman '~-__,
Attorneys for Plaintiff,
8 LAUREN MORGAN
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COMPLAINT
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• EXHIBIT A
 STATE OE CALIFORNIA I Business Consumer Services and Housina Aoencv GOVERNOR EDMUND G BROWN JR
DIRECTOR KEVIN KISH
DEPARTMENT OF FAIR EMPLOYMENT & HOUSING
2218 Kausen Drive, Suite 100 I Elk Grove I CA I 95758
(800) 884-1684 I TDD (800) 700-2320
http://www.dfeh.ca.gov I email: [email protected]

May 14, 2018

Daniel Reisman
5900 Wilshire Blvd
Los Angeles, California 90036

RE: Notice to Complainant's Attorney

DFEH Matter Number: 201805-02240014
Right to Sue: Morgan/ AMBULNZ HEAL TH, LLC et al.

Dear Daniel Reisman:

Attached is a copy of your complaint of discrimination filed with the Department of Fair
Employment and Housing (DFEH) pursuant to the California Fair Employment and
Housing Act, Government Code section 12900 et seq. Also attached is a copy of your
Notice of Case Closure and Right to Sue.

Pursuant to Government Code section 12962, DFEH will not serve these
documents on the employer. You must serve the complaint separately, to all named
respondents. Please refer to the attached Notice of Case Closure and Right to Sue for
information regarding filing a private lawsuit in the State of California. A courtesy "Notice
of Filing of Discrimination Complaint" is attached for your convenience.

Be advised that the DFEH does not review or edit the complaint form to ensure that it
meets procedural or statutory requirements.

Sincerely,

Department of Fair Employment and Housing

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 STAIE OE CALIFORNIA I Business Consumer Services and Housing Aoencv GOVERNOR EDMUND G BROWN JR
DIRECTOR KEVIN KISH
DEPARTMENT OF FAIR EMPLOYMENT & HOUSING
2218 Kausen Drive, Suite 100 I Elk Grove I CA 195758
(800) 884-1684 I TDD (800) 700-2320
http://www.dfeh.ca.gov I email: [email protected]

May 14, 2018

RE: Notice of Filing of Discrimination Complaint

DFEH Matter Number: 201805-02240014
Right to Sue: Morgan/ AMBULNZ HEAL TH, LLC et al.

To All Respondent(s):

Enclosed is a copy of a complaint of discrimination that has been filed with the
Department of Fair Employment and Housing (DFEH) in accordance with Government
° Code section 12960. This constitutes service of the complaint pursuant to Government
Code section 12962. The complainant has requested an authorization to file a lawsuit.
This case is not being investigated by DFEH and is being closed immediately. A copy of
the Notice of Case Closure and Right to Sue is enclosed for your records.

Please refer to the attached complaint for a list of all respondent(s) and their contact
information.

No response to DFEH is requested or required.

Sincerely,

Department of Fair Employment and Housing

 STATE OF CALIFORNIA I Business Consumer Services and Housing Aaencv GOVERNOR EDMUND G BROWN JR
DIRECTOR KEVIN KISH
DEPARTMENT OF FAIR EMPLOYMENT & HOUSING
2218 Kausen Drive, Suite 100 I Elk Grove I CA 195758
(800) 884-1684 I TDD (800) 700-2320
http://www.dfeh.ca.gov I email: [email protected]

May 14, 2018

Lauren Morgan
110 W 6th St
Long Beach, California 90802

RE: Notice of Case Closure and Right to Sue

DFEH Matter Number: 201805-02240014
Right to Sue: Morgan/ AMBULNZ HEAL TH, LLC et al.

Dear Lauren Morgan,

This letter informs you that the above-referenced complaint was filed with the
Department of Fair Employment and Housing (DFEH) has been closed effective May
14, 2018 because an immediate Right to Sue notice was requested. DFEH will take no
further action on the complaint.

This letter is also your Right to Sue notice. According to Government Code section
12965, subdivision (b ), a civil action may be brought under the provisions of the Fair
Employment and Housing Act against the person, employer, labor organization or
employment agency named in the above-referenced complaint. The civil action must be
filed within one year from the date of this letter.

To obtain a federal Right to Sue notice, you must contact the U.S. Equal Employment
Opportunity Commission (EEOC) to file a complaint within 30 days of receipt of this
DFEH Notice of Case Closure or within 300 days of the alleged discriminatory act,
whichever is earlier.

Sincerely,

Department of Fair Employment and Housing

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 1 COMPLAINT OF EMPLOYMENT DISCRIMINATION
BEFORE THE STATE OF CALIFORNIA
2 DEPARTMENT OF FAIR EMPLOYMENT AND HOUSING
Under the California Fair Employment and Housing Act
3
(Gov. Code,§ 12900 et seq.)
4
In the Matter of the Complaint of
5 Lauren Morgan DFEH No. 201805-02240014
6 Complainant,
7 vs.

8 AMBULNZ HEAL TH, LLC

35 W 35TH STREET, 5TH FLOOR
9 NEW YORK, New York 10001
10
AMBULNZ HOLDINGS LLC
11 35 W 35TH STREET, 5TH FLOOR
NEW YORK, New York 10001
12
Respondents.
13
1. Respondent AMBULNZ HEALTH, LLC is an employer subject to suit under the
14
California Fair Employment and Housing Act (FEHA) (Gov. Code,§ 12900 et seq.).
15
2. Complainant Lauren Morgan, resides in the City of Long Beach State of
16 California.
17 3. Complainant alleges that on or about March 30, 2018, respondent took the
18 following adverse actions:

19 Complainant was discriminated against because of complainant's disability

(physical or mental) and as a result of the discrimination was terminated, laid off,
20 denied hire or promotion, reprimanded, denied equal pay, suspended, denied or
forced transfer, demoted, asked impermissible non-job-related questions, denied a
21
work environment free of discrimination and/or retaliation, denied any employment
22 benefit or privilege, denied reasonable accommodation for a disability, denied family
care or medical leave (cfra) (employers of 50 or more people), denied work
;:;;23 opportunities or assignments.

:r"?4 Complainant experienced retaliation because complainant requested or used a

-- disability-related accommodation and as a result was terminated, laid off, denied

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27 11------------------------------------I
-1-
Complaint- DFEH No. 201805-02240014
28
Date Filed: May 14, 2018
 1 equal pay, denied family care or medical leave (cfra) (employers of 50 or more
people).
2

3
Additional Complaint Details: Defendants employed Plaintiff for as the director of
4 human resources until it unlawfully terminated her employment on or about March
30, 2018. At all times relevant, Plaintiff performed her job in a competent and
5 satisfactory manner. Plaintiff also suffered from one or more disabilities as defined
under FEHA. Specifically, suffers from a chronic gastrointestinal disorder and acute
6 flareups of the related symptoms. While suffering from a flareup, Plaintiff required
7 and requested reasonable leave to recover beginning on or about November 29,
2017. Additionally, before she went out on leave, Plaintiff repeatedly refused to forge
8 documents or signatures on documents.
Ultimately, Defendants terminated Plaintiff's employment for pretextual reasons.
9 Defendants maintain an unlimited paid time off policy. However, Defendants failed
and refused and continue to fail and refuse to pay Plaintiff her wages for the time
10
period that she was on leave and before she was terminated.
11

12

13

14

15

16

17

18

19

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Complaint- DFEH No. 201805-02240014
28 Date Filed: May 14, 2018
 1 VERIFICATION

2 I, Daniel Reisman, am the Attorney in the above-entitled complaint. I have read the
foregoing complaint and know the contents thereof. The matters alleged are based
3
on information and belief, which I believe to be true.
4
On May 14, 2018, I declare under penalty of perjury under the laws of the State of
5 California that the foregoing is true and correct.
6 Los Angeles, California
7

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Complaint - DFEH No. 201805-02240014
28 Date Filed: May 14, 2018
.,.
CM-010
ATTORNEY OR PARTY WITHOUT ATTORNEY {Nam,,, "''"'"oar number, andaddn;ss): FOR COURT USE ONJ.Y
Daniel A. Reisman (SBN 250819
REISMAN & REISMAN
5900 Wilshire Blvd., Ste 2600
Los Angeles, CA 90036
FILED
9'JP&r1or Court of Callfomla
(323) 330-0580
TELEPHONE NO. FAX NO. (323) 389-0694 County of Los Anqeles
ATTORNEY FOR (Name): Plaintiff, Lauren Mor an
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
STREET ADDRESS: 111 N. Hill St
MAY 14 2018
MAILING ADDRESS: same

c1rv AND z1P coDE: Los Angeles 90012

BRANCH NAME Central (Stan le Mosk Courthouse
CASE NAME:
LAUREN MORGAN v. AMBULNZ HOLDINGS, LLC, et al.

IZI
CIVIL CASE COVER SHEET
Unlimited D Limited
Complex Case Designation CASE NUMBBC
7o
(Amount (Amount D Counter D Joinder
JUDGE:
demanded demanded is Filed with first appearance by defendant
exceeds $25,000) $25,000 or less) (Cal. Rules of Court, rule 3.402) DEPT:

Items 1-6 below must be completed (see 1ns/ructions on page 2).

1. Check one box below for the case type that best describes this case:
Auto Tort Contract Provisionally Complex Clvll Litigation
D Auto(22) D Breach of contracVwarranty (06) (Cal. Rules of Court, rules 3.400-3.403)
D Uninsured motorist (46) D Rule 3.740 collections (09) D AntitrusVTrade regulation (03)
Other Pl/PD/WO (Personal Injury/Property D Other collections (09) D Construction defect (10)
Damage/Wrongful Death) Tort D Insurance coverage (18) D Mass tort (40)
D Asbestos (04)
D Other contract (37) D Securities litigation (28)
D Product liability (24) Real Property D Environmental/Toxic tort (30)
D Medical malpractice (45) D condemnation
Eminent domain/Inverse D Insurance coverage claims arising from the
D Other Pl/PD/WO (23) (14) above listed provisionally complex case
Non-Pl/PD/WO (Other) Tort D Wrongful eviction (33) types (41)

D Business tort/unfair business practice (07) D Other real property (26) Enforcement of Judgment
D Civil rights (08) Unlawful Detainer D Enforcement of judgment (20)
D Defamation (13) D Commercial (31) Miscellaneous Civil Complaint
D Fraud (16) D Residential (32) D RIC0(27)
D Intellectual property (19) D Drugs (38) D Other complaint (not specified above) (42)
D Professional negligence (25) Judicial Review Miscellaneous Civil Petition
D Other non-Pl/PD/WO tort (35) D Asset forfeiture (05) D Partnership and corporate governance (21)
Employment D Petition re: arbitration award (11) D Other petition (not specified above) (43)
IZ] Wrongful termination (36) D Writ of mandate (02)
•D Other employment (15) D Other judicial review (39)
2. This case LJ is LLJ
is not complex under rule 3.400 of the California Rules of Court. If the case is complex, mark the
factors requiring exceptional judicial management:
a. D Large number of separately represented parties d. D Large number of witnesses
b. D Extensive motion practice raising difficult or novel e. D Coordination with related actions pending in one or more courts
issues that will be time-consuming to resolve in other counties, states, or countries, or in a federal court
c. D Substantial amount of documentary evidence f. D Substantial postjudgment judicial supervision

3. Remedies sought (check all /ha/ apply): a.[ZJ monetary b. [ZJ nonmonetary; declaratory or injunctive relief c. lZ] punitive
4,.:D Number of causes of action (specify): 7
5 ..nThis case D
is IZI
is not a class action suit.
6;::_ If there are any known related cases, file and serve a notice of related case. (You may use form CM-015)
Ofile: April30,2018
Q~iel A. Reisman
(TYPE OR PRINT NAME)
•
eL -::
{SIGNATURE OF P'·eR·-AflORNEY FOR PARTY)
,_,.. NOTICE
•'.;l':lPlaintiff must file this cover sheet with the first paper filed in the action or proceeding (except small claims cases or cases filed
under the Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.) Failure to file may result
in sanctions.
• File this cover sheet in addition to any cover sheet required by local court rule.
• If this case is complex under rule 3.400 et seq. of the California Rules of Court, you must serve a copy of this cover sheet on all
other parties to the action or proceeding.
• Unless this is a collections case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes onlv.
flage 1 of 2
Fenn Adopted for Mandatory Use Cal. Rules of Court, rules 2.30, 3.220, 3.400-3.403, 3. 740:
Judicial Council of California CIVIL CASE COVER SHEET Cal. Standards of Judicial Administration, std. 3.1 0
CM-01 o [Rev. July 1, 2007] www.couttinfo.ca.gov
 ...
j

CM-010
INSTRUCTIONS ON HOW TO COMPLETE THE COVER SHEET
To Plaintiffs and Others Filing First Papers. If you are filing a first paper (for example, a complaint) in a civil case, you must
complete and file, along with your first paper, the Civil Case Cover Sheet contained on page 1. This information will be used to compile
statistics about the types and numbers of cases filed. You must complete items 1 through 6 on the sheet. In item 1, you must check
one box for the case type that best describes the case. If the case fits both a general and a more specific type of case listed in item 1,
check the more specific one. If the case has multiple causes of action, check the box that best indicates the primary cause of action.
To assist you in completing the sheet, examples of the cases that belong under each case type in item 1 are provided below. A cover
sheet must be filed only with your initial paper. Failure to file a cover sheet with the first paper filed in a civil case may subject a party,
its counsel, or both to sanctions under rules 2.30 and 3.220 of the California Rules of Court.
To Parties in Rule 3.740 Collections Cases. A "collections case" under rule 3.740 is defined as an action for recovery of money
owed in a sum stated to be certain that is not more than $25,000, exclusive of interest and attorney's fees, arising from a transaction in
which property, services, or money was acquired on credit. A collections case does not include an action seeking the following: (1) tort
damages, (2) punitive damages, (3) recovery of real property, (4) recovery of personal property, or (5) a prejudgment writ of
attachment. The identification of a case as a rule 3.740 collections case on this form means that it will be exempt from the general
time-for-service requirements and case management rules, unless a defendant files a responsive pleading. A rule 3.740 collections
case will be subject to the requirements for service and obtaining a judgment in rule 3.740.
To Parties in Complex Cases. In complex cases only, parties must also use the Civil Case Cover Sheet to designate whether the
case is complex. If a ·plaintiff believes the case is complex under rule 3.400 of the California Rules of Court, this must be indicated by
completing the appropriate boxes in items 1 and 2. If a plaintiff designates a case as complex, the cover sheet must be served with the
complaint on all parties to the action. A defendant may file and serve no later than the time of its first appearance a joinder in the
plaintiffs designation, a counter-designation that the case is not complex, or, if the plaintiff has made no designation, a designation that
the case is complex.
CASE TYPES AND EXAMPLES
Auto Tort Contract Provlslonally Complex Clvll Litigation (Cal.
Auto (22)-Personal Injury/Property Breach of Contract/Warranty (06) Rules of Court Rules 3.40D-3.403)
Damage/Wrongful Death Breach of Rental/Lease AntitrusUTrade Regulation (03)
Uninsured Motorist (46) (tithe Contract (not unlawful detainer Construction Defect (10)
case involves an uninsured or wrongful eviction) Claims Involving Mass Tort (40)
moton'st claim subject to Contract/Warranty Breach-Seller Securities Litigation (28)
arbitration, check this item Plaintiff (not fraud or negligence) Environmental/Toxic Tort (30)
instead ofAuto) Negligent Breach of Contra cu Insurance Coverage Claims
Other Pl/PD/WO (Personal Injury/ Warranty (arising from provt'sional/y complex
Property Damage/Wrongful Death) Other Breach of Contract/Warranty case type listed above) (41)
Tort Collections (e.g., money owed, open Enforcement of Judgment
Asbestos (04) book accounts) (09) Enforcement of Judgment (20)
Asbestos Property Damage Collection Case-Seller Plaintiff Abstract of Judgment (Out of
Asbestos Personal Injury/ Other Promissory Note/Collections County)
Wrongful Death Case Confession of Judgment (non-
Product Liability (not asbestos or Insurance Coverage (not provt'sional/y domestic relations)
toxic/environmental) (24) complex) (18) Sister State Judgment
Medical Malpractice (45) Auto Subrogation Administrative Agency Award
Medical Malpractice- Other Coverage (not unpaid taxes)
Physicians & Surgeons Other Contract (37) Petition/Certification of Entry of
Other Professional Health Care Contractual Fraud Judgment on Unpaid Taxes
Malpractice Other Contract Dispute Other Enforcement of Judgment
Real Property Case
Other Pl/PD/WO (23)
Premises Liability (e.g., slip Eminent Domain/Inverse Mlscellaneous Clvll Complalnt
and fall) Condemnation (14) RICO(27)
Intentional Bodily Injury/PD/WO Wrongful Eviction (33) Other Complaint (not specified
above)(42)
(e.g., assault, vandalism) Other Real Property (e.g., quiet title) (26)
Intentional Infliction of Declaratory Relief Only
Writ of Possession of Real Property Injunctive Relief Only (non-
Emotional Distress Mortgage Foreclosure
Negligent Infliction of harassment)
Quiet Title
Emotional Distress Mechanics Lien
Other Real Property (not eminent
Other Pl/PD/WO Other Commercial Complaint
domain, landlorcvfenant, or
Case (non-tort/non-complex)
Non-Pl/PD/WO (Other) Tort foreclosure)
Other Civil Complaint
Business Tort/Unfair Business Unlawful Detainer (non-tort/non-complex)
Practice (07) Commercial (31)
Mlscellaneous Clvll Petition
,8 Civil Rights (e.g., discrimination, Residential (32) Partnership and Corporate
u, false arrest) (not civil Drugs (38) (if the case involves illegal Governance (21)
.,.,_ harassment) (08) drugs, check this item; othetwise, Other Petition (not specified
~- Defamation (e.g., slander, libel) report as Commercial or Residential) above)(43)
IJ7 (13) Judlclal Review Civil Harassment
...._ Fraud (16) Asset Forfeiture (05) Workplace Violence
i,...) Intellectual Property (19) Petition Re: Arbitration Award (11) Elder/Dependent Adult
0 Professional Negligence (25) Writ of Mandate (02) Abuse
r-" Legal Malpractice Writ-Administrative Mandamus Election Contest
,:;,o Other Professional Malpractice Writ-Mandamus on Limited Court Petition for Name Change
(not medical or legal) Case Matter Petition for Relief From Late
Other Non-Pl/PD/WO Tort (35) Writ-Other Limited Court Case Claim
Employment Review Other Civil Petition
Wrongful Termination (36) Other Judicial Review (39)
Other Employment (15) Review of Health Officer Order
Notice of Appeal-Labor
Commissioner Appeals
CM-010 (Rev. July 1, 2007] Page 2of2
CIVIL CASE COVER SHEET
 SHORT·.TITLE·
,., • • ···' ··MORGAN v. AMBULNZ HOLDINGS, LLC, et al.

CIVIL CASE COVER SHEET ADDENDUM AND

STATEMENT OF LOCATION BY FAX
(CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION)

This fonn is required pursuant to Local Rule 2.3 in all new civil case filings in the Los Angeles Superior Court.

Step 1: After completing the Civil Case Cover Sheet (Judicial Council form CM-010), find the exact case type in
Column A that corresponds to the case type indicated in the Civil Case Cover Sheet.

Step 2: In Column B'. check the box for the type of action that best describes the nature of the case.

Step 3: In Column C, circle the number which explains the reason for the court filing location you have
chosen.

Applicable Reasons for Choosing Court Filing Location (Column C)

1,:G!ass;a_ctiql')s .!li1Jst;b:e'tfiJe.(tJr\J!Jef~lc!iJl¢y.;M.~1Ssi:;purt1:i9iJs1t,G.eJ1trat Ptstnc;t: 7,:,Eoc:atiqnwtfete\i1~t[t[9_1')er.te!ii(!e~.

2..P,el'rli!$!iiyeJi.lifig·in:~-~n.tr~!:dtstii¢.t, &:i.Lcitjiti¢i1·W~~t~tr:(d~fe.ff~arj!lresp:(irjd~iit;fl!_i1Cti!)i')S'W~:011y,
~,. L¢c:att9n w~er~ .cau~e~'<>f~ct,90:alo$¢, ~/l:'.O:c:atiqfiWhere;o_i'.1¢°:,orJno.(~(!>fttie:P.~i'.M$'~$i.~ef:
ti.-.Mar\:di3ti'rWpersciiiaJ•JriiiiiY.~li_ng,irjN6rtl:i-:DJ~tt!ct,. tQ}LO!:,?ljori'.qfJ..'.~!:>cirQcirriCTi[~jpri¢JQffi¢~,
11. Mandatory filing location (Hub Cases - unlawful detainer, limited
5, ~o:caUon.'tJl,ere,Cpe_rtgtm?[i~:rl;!qilit~d'.0(<1.ef~M~.ijtfe~i~es; non-collection, limited collection, or personal injury).
9,,toc:~ticin 01·t1r.°Qpertfofii~_nnalieiiW,gar~gEf~Ne,~i.tJ.f

Auto(22) □ A71:00 MR!9rV,ehicle_.~·Rersq11ar!iiji:/ry/Property.D.amagll/Wr9ng(urpec1th 1,'4.-J1

.B
::I t:
0
< I- U(linsi.JreclMotqfist-(46) □ A7no Pers.orial lnjury/Property-QamageNVrongfutoeath -,-.Uninsured l'v1otorist 1, 4, 11

□ A607Q Asbe.sto~ Property Damc19E;) 1, 11

}\spestot (94 l
□ A7221. Asbestci~~ P_er~o.nal lrij!Jry/VVrcingful Dealt, 1; 11

Product Liability (24) □ A7;rno Product Liability (not asbestos· or toxic/environmental) 1, 4, 11

□ A72:1.0 fyledjcal Malpractice~ Physici~ns & Stirgecihs J; 4, 11

Medic<1IM<1lpraclice (45) 1.,-4,:11
□ A724Q Qtlierf'rpfes:;iprial Hec1lth Cc!r.e Malpractice

D A725Q Pr.emi~El-~Liabi!ily(e.:g.,:slip!ahclif~!I)
.1,4,11_
.Qthei'.Personal
lnjur:y Property □ A7230 lntentiom,11 B_cidily Injury/Property Darnage/Vl/rongfuEDeath (e:g,,
• c1s~au1t, vanµalisrt etc.)
1,4,:11
Da_rii;1ge VVrongful
De,i!lh (23) 1, ~t;ft.
□ '/t.7:.21.0 li,terjti¢°f!~J lhflic\itjn qf~Mdtiq~al Distt~s~
□ A7:2?0 .QU'J~r P_et.!?i;>.@!iii~:ry1prpP.¢rty Q13magll/VYto.i:,gtu.1 .Pea.t~ 1,a~.+J

t;:~QIVJ0.9..(~e02/Hi) CIVIL CASE COVER SHEET ADDENDUM Local ROle;e:3

LA§>C;Appr,ov_e(fQ,3±94 AND STATEMENT OF LOCATION Pcigeifof4
SHORT,TITLE:
'• •••• ••• •• •• •• MORGAN v. AMBULNZ HOLDINGS, LLC, et al.

BusinessJ:or:t (07)

~~
a, l - CiVil~ights (08)
a. .c:
e,u
Cl.. a,
□ A6Q1 Q (J.efatr))3lion'(s.lan:c1~r/litJ:el) 0

~-
-o
-~- :::, :::,
c: C>
Fraud;(16J
- C:
rue
"'-
a s:
... a, □ }\6()17 L~galiM~!P~¢µqe; 1,:2;4
~ .C> Profe$siqilaJ,Negligehc;i!.(25)'
□
C
o
E
ns
A6.Q50 QtfierPrpfe$siorial M~IPt!=lctice.;(not-r,n~di¢~I qrJega!) 1,.:2;3
zo
Qther(35) □ A6.Q25 Qtti:efNon-:P.er~o.rial !rijliry/Property Delmage· tort 1,.2;,3

'E
a,
E
>,
0 □ A6024 qhe.r Emplciymerit .c:ompla,int .Case, 1,2,3
C. Ottier (;rilpldyment (15)'
E □ A6 l09 labor Commissiori,e~ Appe_als • 10
w

□ A6.0Q;4 Bre.!ii=ll.otRental/~ea$~,cc;ii,)rac:t (not \Jnll!WfuJ d~tciiile(p( wrongf1JI • 2;".5

e.vit;~6.i1):
ete.a,thofCorit@WWarranty ;2,5
(06) □ A.690!! §cirjl(agJ\J\/cirt.c1nty Bi$!.c:t:,';;::,eIIe.tPlaintiff.(r:1p ~uclfn1,1gl)ge!'ric:~)'.
{llOl:insurance) □ Af>ClJ9 Ne.gligentBJ~i!C:h:Ot~nJ~C:1/YYarr:.ai)ty (llci fraliq); Ji:2,.5.
1-;,':2,:5
□ A6C>28 QttfefB~cii;h<>f: contract/YI 13rtanty (notfraua otri~gugeri¢~):

ti D A60Q:2 §plli3qi6H~Qasj3,$~!!e.H'l,ciiriliff ~;,f3,+t

~
'E
0 □ ~60.12 -g1~:erPtOi1Jis$~lY·NQtetcoIt~c:~p,r1s case.: 5,'1l:
u
□ A.6934 C.6.lli!¢!icir\'s:qfs'~R~fc:t1a.sefd'.Q~pt.'(G,hr1i'g~cl.'.Q.ff,C6r:i~~:m.~f:,Qe!5\'. !>/?:'1:1'.
Purchased'oif'or:attetJanua ..' t .2014 :

□ A60Q9 GonJta,qµ~lfraud; 1,,:Zi~;,';~

□ Jl,6.o:n Tortipu!l)r:i~erteren9~ 1,,2;3;,5
□ A6027 QtfierQontt~¢J D/$p_ute(ricit'tire..~¢Mi:\su,raQce1ftiiud/r(egligenc.E! ). ,l;.':2,.3;,alk•~:.

Eh:liiii!rjtDomain/lnverse □ A7300 Eminent Domain/Condemnation Number of parcels_ _ 2,,6.

Gonctem_ilcltio.n .( 14)

wrongful E\iiclio11 (33 ). □ A6.Q23 Wro,ngful. Ev_iction Cai;e

□ A6Q18 M9rtgage. fc;,r.eclqsure

□ :,W032 qui(;!tTitle
□ A606_0 Ot~e(Real Property (not!:lmil)entdomain',landlord/tenant,Jore.closµre) ~. _6
..... llnlawtul·Detainer-Commercial
□ A6021 Unlawful Detainer:commercial (not drugs cir wrongful .eviction) 6, 11
(31)
.Unlawf~I Detainer-Residential
32 □ A602Cl Unla~ulDetaii:,er-Re~iclential (not dru.gs or wrongful evictiqn) 6, 11

Ui:il.awflJI t;)eJclin!:Jr- □ A6020F Unlawt°ulpetair:ieH~os,t,For.eclbsure 2,6,'H

Post-Foreclbsure 34. •
llnlawful Detainer-Drugs (38) □ A6022 Unlawful Detainei~Drugs 2,6, .11

LAGIVW!:!(Rev'2!1f3) . CIVIL CASE COVER SHEET ADDENDUM Local. RiJle:2.3.

L:A;,c;; f..PPra:v.ect 9.~, AND STATEMENT OF LOCATION Page::2,of4
SHORT TITLE: CASE NUMBER
• MORGAN v. AMBULNZ HOLDINGS, LLC, et al.

A B'. C Applicable
Civil Case·cover Sheet Type qi Action Reasons - See Step 3
• Category No. (Check only one) Above

Asset Forfeiture (05) D A6108 Asset Forfeiture Case 2, 3, 6

Petition re Arbitration ( 11) D A6.115 Petition to Conipel/ConfirmNacate Arbitration 2,5

D A6151 Writ - Administrative Mandamus 2,8

Writ of !\'landate (02) D A6152 Writ - Mandamus on Limited Court case Matter 2
D A6153 Writ - OtlJer Limited court c.ase Review 2

Othei Judicial ~eview t39) □ A6150 Other Writ /Judicial Review 2,8

Antitrust/Trade Regulation (03) □ A6003 Antitrust/Trade Regulation 1, 2, 8

C:
0
~ Construction Defect ( 1O) □ A6007 Construction Defect 1,2,3
C>
.::.
::i
>< <;;!aims Involving MassTort 1, 2,.8
Cl) □ A6.006 C.laiins thvolvj!"lg Mas~ Tort
C. (40)
E
0
u Secu_rities Litigation (28) □ A6035 Secur!ties Litig;!ltion C.asl! 1, 2,.a
.a::,
iii TqxiCTort
C:
0 □ A6036 Toxi,c Tort/Environmental 1, 2,3,:8
"iii Environment~I (30)
·;;:
0 lnsLiran~ ColiE!r.igE! <;;laimf □ A6014 Insurance coverage/Subrogation (complex case only) 1, 2,5,-8
r£. from Complex Case (41)

□ A6141 Sjster State Judgment 2, !?; 11

□ A6160 AbStractofJu<:Jgment 2,6
cc
Cl) Cl)
E E Enforcement □ A6107 Confession of Judgment (nbn,domestic relations) 2,9

-
Cl) C)
~ ,:i of Judgment (20) □ A6140 Administrative Agency Award (not unpaid taxes) 2,8
0 :::,
-,
C:
W -0 □ A6114 P.etitioh/Certificate forEhtry of Judgment on Unpaic!Tax 2,8
□ A6112 Other Enforcement of Judgment Case ~.8,9

RIC,O(27) □ A6Q33 Racketeering (RICO) Gase 1, 2, 8

UI
:::,
.l!J
C:
0 "' □ A6030 Declaratory Relief Only 1, 2, 8
~ C.
..!2 E Other.Complaints □ A6040 Injunctive Relief Only (not domestic/harassment) 2,8
cii 0
u u (Not Specified Above) (42)
UI □ A6011 Qther Commercial Complaint c.ase {non-tort/non-complex) 1, 2,.8
:i§ ·;;:
u □ A6.000 Qther·Ci\lil.Corhplaint·(non°tortJ.non-complexJ 1, 2,8

Partnership Corporation 2,8

□ A6113 Partnership and Corporate Governance Case
GOVE!rnahc~ (21)

□ A6121 Civil Harassment 2,3,9

□ A612~ •Workpla.ce. Harc3ssri)ent 2,·3, 9
□ A6124 Elder/Dependent Adult Abuse case 2,3,9
Other PetiHons (Not
SpecjfiedAboveJ(:43) □ A6190 Election Contest 2
□ A!1110 PetitionforChahge of Name/Change of Gender ~. 7
□ A6.170 Peti.ti.ori torRefief troo- Ll:lte Claim Law ?,3,:8
□ A61:0Q Qth'er Ci\lilP~t[(ion 2,9

LACIV 10Q (Rev 2/19) CIVIL CASE COVER SHEET ADDENDUM 1-ocal Rule.2.3
LASC Approved .03-04 AND STATEMENT OF LOCATION Page 3of4
 ,SHORT T,ITLE: G,\SENl,Jfylf:!ER
MORGAN v. AMBULNZ HOLDINGS, LLC, et al.

Step 4: Statement of Reason and Address: Check the appropriate boxes for the numbers shown under Column C for the
type of action that you have selected. Enter the address which is the basis for the filing location, including zip code.
(No address required for class action cases).

ADORE~~:
REASON: 1059 E Bed mar St
D 1. fl 2. D 3.. J ~: □ 5, 0 6, 0 T; 08.;0 9. D 10.. J '11.

CITY: STATE; ZIPCO0E;

Carson CA 90746

Step 5: Certification of Assignment: I certify that this case is properly filed in the Central District of
the Superior Court of California, County of Los Angeles [Code Civ. Proc., §392 et seq., and Local Rule 2.3(a)(l)(E)].

Dated: 4/30/18
(SIGNATURE OF ATTORNEY/FILING PARTY)

PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY
COMMENCE YOUR NEW COURT CASE:

1. Original Cotnplaintor Petition.

2. a complaint, acompleted summoristorm for.issuance by the Clerk.
If filing
3~ Civil Case Cover Sheet, Judicial Council form CIV-01 o.

4. Civil CaseCoverSheet-AddendUm and Statementot:Lotation'form, LACIV109, LASCApproved:03-04 (Rev.

~~ • •

5. Payment in>tull:of thefilih£! ,fee; unless there is courtorderJor waiver! partiarorsciieduled payments.
6: A signed ordet:app'aintingthe G.uardianad Liteni, J1Rlic:iateouncif forrri GIV,010, if the plairitiff.orpetitioneris a
mindr'Undet 1ayears ot:a~e will oe ·required qy Court in order'to issue a summons, • •

7. Additionalcopies,of do~uments,to be conformed.by th~!fCletk. copies·onhe .cover sh'¢etandthis:addeiidum

mustb'e served alon~;fwiththe summons and complaint,.oro.ther initiating pleading in.the case.

~
l,,J'l

LACIV 1.09 (Rev 2/1p) CIVIL CASE COVER SHEET ADDENDUM .Local Rule 2.3
LASC Approved 03'-04, AND STATEMENT OF LOCATION Page4 of4