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LOS ANGELES SUPERIOR COURT

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LAW

OFFICES OF

PICCO

& PRESLEY

GREGORY L.
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PICCO

(SLale Bar #87235)

JAN 2 6 2012

2121 Cloverfield Blvd., Suite 110

Santa Monica, CA 90404 (310) 829-5414

Attorney for Plaintiff, NUBIA DEL CARMEN PREZA

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SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

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John H. Reld
NUBIA DEL CARMEN PREZA,

CASE NO. : SCll58^3

COMPLAINT FOR DAMAGES FOR PERSONAL INJURIES

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Plaintiff,
vs.

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LINDSAY LOHAN,

BLACK & WHITE

CASE MANAGEMENT CONFERENCE

CAR RENTAL,

and DOES 1

through 10, inclusive,

Defendants.

MAYU2(Ji2 S'^P F"

Data
DEL CARMEN PREZA, for a cause of action

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Plaintiff,

NUBIA

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against the defendants, and each of them, complains and alleges as

follows:

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1.

The tortious conduct giving rise to this lawsuit

the City of West Hollywood, County of Los Angeles,

occurred in

State of California.

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2. corporate, 50,

The

true

names or

or

capacities, of are

whether

individual, 1 through who

associate

otherwise, of them,

defendants unknown to

DOES

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inclusive,

and each

plaintiff,

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therefore sues said defendants by such 1

COMPLAINT

fictitious names and will _

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ask

leave

of the

Court

to amend this

complaint

to

insert their

true names or capacities when the same have been ascertained.

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3.

Plaintiff is informed and believes and thereon alleges

that each of the defendants designated as a DOE is negligently,

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consciously,

willfully,

intentionally,

knowingly,

recklessly,

otherwise tortiously,

or legally responsible in some manner for

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the events and happenings herein referred to,

consciously, willfully, intentionally,

and negligently,
recklessly, or

knowingly,

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otherwise tortiously caused the injuries and damages proximately

thereby to plaintiffs as hereinafter alleged, through said

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defendants' own conduct, or through the conduct of their agents,

servants or employees, and each of them, or due to said

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defendants' ownership,

importation, possession,

operation, supervision,

design, servicing,

distribution, maintenance,

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inspection,

repair,

control,

entrustment,

use,

furnishing,

manufacturing, or sale of the premises or instrumentalities which

caused the injuries and damages herein alleged.
4. At all times herein relevant, each of the defendants was

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an agent, servant or employee of each of the remaining defendants, and was at ail times acting within the time, purpose or scope of

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said agency or employment, and acting with the express or implied

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knowledge, permission or consent of the remaining defendants, and

each of them.

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5.

Plaintiff is informed and believes and thereon alleges

times herein mentioned, defendants LINDSAY LOHAN,

at all

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BLACK & WHITE CAR RENTAL,

and DOES 1 through 10,

inclusive, and

each of them, were the owners of a motor vehicle referred to in

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this complaint and generally described as a Maserati Granturism.

2 COMPLAINT

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6.
that at

Plaintiff is informed and believes and thereon alleges

all times herein mentioned, defendant LINDSAY LOHAN was

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the driver of the aforementioned vehicle.

7.

Defendant LINDSAY LOHAN was

driving said motor vehicle

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with the

express or

implied consent,

permission

or

knowledge of

the remaining defendants, and each of them.

8. At all times herein mentioned, Alta Loma Road at or

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near Holloway Drive

was and is a public

roadway in the City of

West Hollywood, County of L03 Angeles, State of California.

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9.
p.m.,

On

or

about

September

1,

2010 at

approximately
Loma

4:00

plaintiff was

a pedestrian

crossing Alta

Road at or

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near

its

intersection

with

Holloway

Drive

in

West

Hollywood,

walking north. 10. At said time and place, defendant; LINDSAY LOHAN was

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driving the aforementioned Maserati automobile South on Alta Loma

Road at or near Holloway Drive in West Hollywood. 11. At said time and place, defendants, and each of them,

did, among other things, so negligently entrust, manage, maintain,

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drive or operate their said motor vehicle as to proximately cause

their vehicle to collide with plaintiff, and as a proximate result

thereof, caused the hereinafter described injuries and damages to
plaintiff.
12. omissions, As a direct and proximate result of said tortious acts, or conduct of the defendants, and each of Ihem,

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plaintiff has sustained and incurred, and is certain in the future

to

sustain and

incur

losses,

injuries,

and

damages

itemized as

follows:

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COMPLAINT

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(a)

Disabling

and

serious

personal

injuries,

pain,

suffering and anguish in connection therewith, all to plaintiff's

general damage in a sum in excess of the minimum jurisdictional
amount of this Court;

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(b)

Expenditures

for

past,

present

and

future

medical

services and other curative items in connection with the treatment

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of plaintiff's said injuries, all to plaintiff's damage in a sum

to be determined according to proof at the time of trial; and (c) Inability to perform plaintiff's regular and usual

occupation,
earning

with resulting loss and impairment of earnings and

all to plaintiff's damage in a sum to be

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capacity,

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determined according to proof at the time of trial.

REQUEST FOR JURY TRIAL

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Plaintiff hereby requests a trial by jury.

PRAYER FOR RELIEF

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WHEREFORE,

plaintiff

prays

for

judgment

against

the

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defendants, and each of them, as follows:

1.

General

damages

in

sum

in

excess

of

the

minimum

jurisdictional amount of this Court;

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2.

All medical and incidental expenses according to proof;

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3.

Loss and impairment of earnings and earning capacity

according to proof;
4. For costs of suit incurred herein;

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to law;

For post-judgment and pre-judgment interest according

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COMPLAINT

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6.

For such other and further relief as to this Court may

deem just and proper.

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DATE: l/2H/<20\3^ GREGORY L. PICCO

Attorney for Plaintiff

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COMPLAINT