Case regarding the demolition of trailers
Case No. BC 473905
First Amended Complaint for Damages 1st AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE AND DECLARATORY RELIEF AND ATTORNEYS’ FEES FOR: (1) PERSONAL INJURY;(2) VIOLATION OF CALIFORNIA ENVIRONMENTAL AIR QUALITY ACT (CEQA) AND U. S. ENVIRONMENTAL PROTECTION ACT (EPA); (3) BUYING AND DISPOSING OF UNREGISTERED MOBILEHOMES IN VIOLATION OF B & P CODE §10131.6(A), RESULTING IN REMOVAL AND DESTRUCTION OF MOBILE HOMES CONTAINING ASBESTOS, LEAD PAINT,MOLD, AND/OR FORMALDEHYDE WITHOUT PERMITS, NOTICE TO AFFECTED PERSONS, AND AN ENVIRONMENTAL IMPACT REPORT, AND IN CONTRADICTION TO CLAIMS MADE IN EXISTING DRAFT EIR FOR SUBJECT PROPERTY; (4) ELDER ABUSE; 5) INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS; (6) RETALIATORY EVICTION FOR REPORTING ABOVE VIOLATIONS TO GOVERNMENTAL AGENCIES; (7) FRAUDULENT UNFAIR COMPETITION; (8) VIOLATION OF CIVIL RIGHTS AND (9) CONSPIRACY TO COMMIT EACH
Defendants are: Marc. L. Luzzatto, an Individual; James Muramatsu, an Individual; Village Trailer Park, Inc., a California Corporation; J&H Asset Property Mgmt. Co.,Inc a California Corporation; James George Joffe, an Individual, Jill Arteaga, an Individual; Dennis Shay, an Individual; June Willis, an Individual; James Brewster, an Individual; and DOES 1 through 20, Inclusive
Plaintiff is:Brenda Barnes, an Individual
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DISCOVERY-VTP responds to interrogatories on 8/10/12
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Temporary Restraining Order against Demolishing Trailers EX PARTE APPLICATION FOR TEMPORARY RESTRAINING ORDER AND OSC AGAINST DEMOLISHING TRAILERS AT SITE OCCUPIED BY ELDER RESIDENTS INCLUDING PLAINTIFF, UNTIL THE COURT FINDS 26 TRAILERS DEFENDANTS REMOVED WITHOUT INSPECTION AND/ OR PERMITS DID NOT CONTAIN ASBESTOS, LEAD, MOLD, AND/OR FORMALDEHYDE AND ANY TRAILERS DEFENDANTS PROPOSE TO DEMOLISH OR REMOVE IN THE FUTURE ALSO DO NOT CONTAIN SAID HAZARDOUS MATERIAL , OR IN THE ALTERNATIVE, UNTIL AN ENVIRONMENTAL IMPACT REPORT IS PREPARED SHOWING NO IMPACT OF SUCH DEMOLITION OR IT IS DONE WITH PROPER MITIGATION; ) MEMORANDUM OF POINTS AND AUTHORITIES
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Opposition to Motion to Transfer: PLAINTIFF’S NOTICE OF OPPOSITION AND OPPOSITION TO DEFENDANTS LUZZATTO ET AL.’S MOTION TO TRANSFER TO WEST DISTRICT; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF BRENDA BARNES IN SUPPORT THEREOF
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First Amended Complaint for Damages 1st AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE AND DECLARATORY RELIEF AND ATTORNEYS’ FEES FOR: (1) PERSONAL INJURY;(2) VIOLATION OF CALIFORNIA ENVIRONMENTAL AIR QUALITY ACT (CEQA) AND U. S. ENVIRONMENTAL PROTECTION ACT (EPA); (3) BUYING AND DISPOSING OF UNREGISTERED MOBILEHOMES IN VIOLATION OF B & P CODE §10131.6(A), RESULTING IN REMOVAL AND DESTRUCTION OF MOBILE HOMES CONTAINING ASBESTOS, LEAD PAINT,MOLD, AND/OR FORMALDEHYDE WITHOUT PERMITS, NOTICE TO AFFECTED PERSONS, AND AN ENVIRONMENTAL IMPACT REPORT, AND IN CONTRADICTION TO CLAIMS MADE IN EXISTING DRAFT EIR FOR SUBJECT PROPERTY; (4) ELDER ABUSE; 5) INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS; (6) RETALIATORY EVICTION FOR REPORTING ABOVE VIOLATIONS TO GOVERNMENTAL AGENCIES; (7) FRAUDULENT UNFAIR COMPETITION; (8) VIOLATION OF CIVIL RIGHTS AND (9) CONSPIRACY TO COMMIT EACH
Defendants are: Marc. L. Luzzatto, an Individual; James Muramatsu, an Individual; Village Trailer Park, Inc., a California Corporation; J&H Asset Property Mgmt. Co.,Inc a California Corporation; James George Joffe, an Individual, Jill Arteaga, an Individual; Dennis Shay, an Individual; June Willis, an Individual; James Brewster, an Individual; and DOES 1 through 20, Inclusive
Plaintiff is:Brenda Barnes, an Individual
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DISCOVERY-VTP responds to interrogatories on 8/10/12
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Temporary Restraining Order against Demolishing Trailers EX PARTE APPLICATION FOR TEMPORARY RESTRAINING ORDER AND OSC AGAINST DEMOLISHING TRAILERS AT SITE OCCUPIED BY ELDER RESIDENTS INCLUDING PLAINTIFF, UNTIL THE COURT FINDS 26 TRAILERS DEFENDANTS REMOVED WITHOUT INSPECTION AND/ OR PERMITS DID NOT CONTAIN ASBESTOS, LEAD, MOLD, AND/OR FORMALDEHYDE AND ANY TRAILERS DEFENDANTS PROPOSE TO DEMOLISH OR REMOVE IN THE FUTURE ALSO DO NOT CONTAIN SAID HAZARDOUS MATERIAL , OR IN THE ALTERNATIVE, UNTIL AN ENVIRONMENTAL IMPACT REPORT IS PREPARED SHOWING NO IMPACT OF SUCH DEMOLITION OR IT IS DONE WITH PROPER MITIGATION; ) MEMORANDUM OF POINTS AND AUTHORITIES
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Opposition to Motion to Transfer: PLAINTIFF’S NOTICE OF OPPOSITION AND OPPOSITION TO DEFENDANTS LUZZATTO ET AL.’S MOTION TO TRANSFER TO WEST DISTRICT; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF BRENDA BARNES IN SUPPORT THEREOF
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