SUM-100

SUMMONS FOR COURT USE ONLY

(SOLO PARA USO DE LA CORTE)
(CITACJON JUDICIAL)
NOTICE TO DEFENDANT: ENDORSED
(A VISO AL DEMANDADO): FILED
ALAMEDA COUNTY
Oakland Redevelopment Group, a limited liabili ty corporation; Eugene
Gore li k, an indiv id ual; Jessica Sawczuk , an individ ual; and DOES 1-20 APR 2 8 2017
YOU ARE BEING SUED BY PLAINTIFF:
LO ESTA DEMANDANDO EL DEMANDANTE):
~~~~~~~~~~~~~~~~~~~~-----------------------sbr
~LERK ~ ~n:N9R COURT
- ~~
The People of the State of Cal ifornia, Pla intiff, and the C ity of Oakland, r-. :iAfHOMAS, ouputy
a municipal corporation, Pla intiff and Real Party in Interest
NOTICE! You have been sued. The court may decide against you without your being heard unless you respond within 30 days. Read the information
below.
You have 30 CALENDAR DAYS after this summons and legal papers are served on you to file a written response at this court and have a copy
served on the plaintiff. A letter or phone call will not protect you. Your written response must be in proper legal form if you want the court to hear your
case. There may be a court form that you can use for your response. You can find these court forms and more information at the California Courts
Online Self-Help Center (www.courtinfo.ca.govlselfhelp) . your county law library. or the courthouse nearest you. If you cannot pay the filing fee. ask
the court clerk for a fee waiver form . If you do not file your response on time. you may lose the case by default. and your wages. money. and property
may be taken without further warning from the court.
There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney. you may want to call an attorney
referral service. If you cannot afford an attorney, you may be eligible for free legal services from a nonprofit legal services program. You can locate
these nonprofit groups at the California Legal Services Web site (www.lawhelpcalifornia.org), the California Courts Online Self-Help Center
(www.courtinfo.ca.gov/selfhelp). or by contacting your local court or county bar association. NOTE: The court has a statutory lien for waived fees and
costs on any settlement or arbitration award of $10.000 or more in a civil case. The court's lien must be paid before the court will dismiss the case
;A VISO! Lo han demandado. Sino responde dentro de 30 dias. Ia corte puede decidir en su contra sin escuchar su version. Lea Ia informacion a
continuacion.
Tiene 30 DIAS DE CALENDAR/0 despues de que /e entreguen esta citacion y papeles legales para presentar una respuesta por escrito en esta
corte y hacer que se entregue una copia a/ demandante. Una carta o una 1/amada telefonica no to protegen. Su respuesta por escrito tiene que estar
en Formato legal correcto sidesea que procesen su caso en Ia corte. Es posible que haya un formu/ario que usted pueda usar para su respuesta
Puede encontrar estos formularios de Ia corte y mas informacion en el Centro de Ayuda de las Cortes de California (www.sucorte.ca.gov). en Ia
biblioteca de !eyes de su condado o en Ia corte que /e quede mas cerca. Sino puede pagar Ia cuota de presentaci6n. pida a/ secretario de Ia corte
que le de un formulario de exenci6n de pago de cuotas. Sino presenta su respuesta a tiempo. puede perder el caso por incumplimiento y Ia corte le
podra quitar su sue/do. dinero y bienes sin mas advertencia.
Hay otros requisitos legales. Es recomendable que /lame a un abogado inmediatamente. Sino conoce a un abogado. puede /lamar a un servicio de
remisi6n a abogados. Sino puede pagar a un abogado, es posible que cumpla con los requisitos para obtener servicios legales gratuitos de un
programa de servicios legales sin fines de lucro. Puede encontrar estos grupos sin fines de lucro en el sitio web de California Legal Services.
(www.lawhelpcalifornia.org), en el Centro de Ayuda de las Cortes de California, (www.sucorte.ca.gov) o poniendose en contacto con Ia corte o el
colegio de abogados locales. AVISO: Por ley, Ia corte tiene derecho a reclamar las cuotas y los costos exentos por imponer un gravamen sobre
cualquier recuperaci6n de $10,000 6 mas de valor recibida mediante un acuerdo o una concesi6n de arbitraje en un caso de derecho civil. Tiene que
pagar el gravamen de Ia corte antes de que Ia corte pueda desechar el caso.

The name and address of the court is: CASE NUMBER

Alameda County Superior Court
_R G17858 1 2 1
(Numero del Caso)
(EI nombre y direcci6n de Ia corte es):
1225 Fallon Street
Oakland, CA 946 12
The name. address. and telephone number of plaintiffs attorney , or plaintiff without an attorney, is:
(EI nombre, Ia direcci6n y el numero de telefono del abogado del demandante. o del demandante que no tiene abogado, es):
Oakland City Attorney, Kevin K ing, I Frank H. Ogawa Pl aza, 6th Fl., Oakland, CA 94612, (51 0)23S-3865

DATE:
(Fecha)
APR ~
~
MtJ
6 CV Chad F'nke
1 Clerk. by
(Secretario)
. Deputy
(Adjunto)
(For proof of service of this summons, use Proof of Service of Summons (form POS-01 0).)
(Para prueba de entrega de esta citation use el formulario Proo f of Service of Summons. (POS-010)).
NOTICE TO THE PERSON SERVED: You are served
!SEAl ! 1. D as a n individual defendant.
2. 0 as the person sued under the fictitious name of (specify)

3. D on behalf of (specify):

under: D CCP 416.10 (corporation)

D CCP 416.60 (minor)
D CCP 4 16.20 (defunct corporation) D CCP 416.70 (conservatee)
D CCP 4 16.40 (association or partnership)
D CCP 416.90 (authorized person)
D other (specify):
4. D by personal delivery on (date) :
Pa e 1 or 1
Form Adopled IO< Mandalory Use
Judetal CounCil of Caltfoma
SUMMONS CO<fe o l Cvl Proce<Jure 41 2 20 465
www courtmfo clJ gov
SUMIOO IRev July 1, 2009)
 BARBARA J. PARK ER. City Attorney- 8 #69722
OTIS MCGE E. Chief Assist. C ity Atty - SB # 71885
2 MA RIA BEE, S pec ia l Counsel - SB # 167716
KEVIN K ING, Neighbo rhood Law Corps Attorney - SB #3 09397
3 One Frank H . Ogawa Plaza, 6th Fl oor ENDORSED
Oakland , Cali forn ia. 946 12 FILED
4 Telepho ne: (51 0) 23 8-3865 ALAMEDA COUNTY
Fax: (51 0) 23 8-6 500 APR 2 6 2017
5 KK I G@ oaklandcityattorney.org
CE04368/2 11 37 19v I CLERK~ COURT
6
A ttorneys fo r Plaintiffs. By ~MA~
7 The People of the S tate of Ca li fo rn ia and
The City of Oakland
8
SU PERIOR CO URT OF TH E STATE OF CAL IFORNIA
9
CO UNTY OF ALAMEDA
10
UNLI MITED C IVIL CASE
II

12
THE PEO P LE OF T HE STAT E OF
CALIFORN IA,
Case No. RG1 7 8 5 8 1 2 1
13 Plaintiff, COMPLAINT FOR IN.JUNCTIVE RELIEF,
CIVIL PENALTIES, RESTITUTION,
14 THE C ITY OF OAKLAN D, a mun icipa l ATTORNEY'S FEES, COSTS, AND OT II ER
corporation. EQU ITABLE RELIEF BASED O N:
15 Pla intiffand Real Party in
Interest, (1) TENANT PROTECT ION ORJ)I NA NCF:
16 !Oakla nd Municipa l Cod e 8.22.600 et seq. I
\'.
17 (2) BANE ACT !Ca lifornia Civ il Code ~52 .11
Oakland Redeve lo pment Group, a lim ited
18 liabi li ty corporat ion; Eugene Go relik, an
individual: Jessica Sawczuk, an indi vidual;
19 and DOES ONE through T W ENTY
inclusive.
20
Defendants.
21

22
I. Jahahara A lkc bu lan-Ma'at, 64 years o ld and disabled, has li ved in Oakland at 369 MacArthur
23

24 Boulevard ('"the Property") since April I . 1995 .

25 2. Upon informati o n and belief. as ofApril 26, 20 16. Jahahara 1\ lkebulan -Ma'at and his minor

26 son were the onl y tenants at the 3-unit residence located at the Property.
27

28
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COM PLA INT FOR INJUNCTI VE RELI EF, C IVIL PENALTIES. REST ITUTION. ATTORNEY'S FEES.
COST S. AND OT II ER EQU ITI\IJLE RELIEI:
 .....
J. Upon information and belief, on April 26.2016. Defendants Jessica Sm czuk and Eugene
2 Gorelik cont acted .Jahahara Alkebu lan-Ma'at. in person, at his home nnd informed him they
3
intended to pu rchase the Property. That same afternoon, Defendant Jessica Sawczuk contacted
4
Jahahara Alkebulan-Ma'at. via e-mai l. stating she and her husband Defendant Eugene Gorclik
5
intended to '"restore the house to its ori ginal condition (this means turn ing it back into a single
6

7 fam il y) [.rand move in as [their] primary residence: (parenthetical in original). Defendant

8 Jessica Sawczuk further stated, ''this means yo u would need to relocate and offered to .. he lp

9 wi th movers. pay l] deposit and several month 's rent somewhere Ie ise I or other
10 compensation:
II
4. Upon informati on and belief. on May I 0. 2016. Oakland Redevelopment Group LLC. owned
12
in trust by Defendants Eugene Gorelik and Jessica Sawczuk. purchased the Property.
13
5. Upon information and beliet~ from Apri l 2016 to March 2017. Defendants Jessica Sawczuk
14

15 and Eugene Gore lik made multiple o rters (in person. by e-mail and by text message) to

16 facilitate moving Jahahara Alkebulan-Maat out of his home and provide compensation.

17 During that time and to date, Jahahara Alkebulan-Ma'at has continued to look for housing
18
through affordable housing and low-income. senior housing programs.
19
6. On September 2. 20 16, Defendant Jessica Sawczuk obtained a perm it tiom the City or Oakland
20
Planning and Building Department to .. remove fanl unpermitted I story rear structure attached
21
to lthe-12 story: Jahahara Alkebulan-Ma'at's bedroom and dining room were in the rear of the
22

23 two-story build ing and his bathroom and li ving room were in the one-story rear attached

24 structure.
25 7. On October 25, 20 16, Jahahara Alkebulan-Ma'at received a 60-day eviction notice from
26
Defend ant Jessica Sawc:wk. as an authori zed agent f()r Defendant Oak land Redevelopment
27
Group, LLC. and Daniel Bornstein, as the attorney and authorized agent for Defendant
28
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COMPLAI NT FOR INJ UNCTIV E RELIEF. CIVIL PENALTIES. RESTITUTION, ATTORNEY 'S 1-n :s.
COSTS. AND OTHER EQU ITABI.F. RELIEF
 Oakland Redeve lopment Group, LLC. The notice falsel y claimed that .. the City.. dete rmined
2
his home was exempt from the Just Cause Ordinance. Under the notice. Jahahara A lke hulan-
3
Ma'at was to move out on or before December 25, 2016. Ch ri stmas Day. or fac e an ev iction
4
lawsuit.
5
8. On January 12. 20 17. Defendants fil ed an Unlawful Detainer lawsuit against Jahahara
6
7 Alkebulan-Ma 'at.

8 9. Upon information and belief, on February 25. 2017. Defendants shut o iT the gas. leav ing

9 Jahahara J\ lkebulan-Ma'at with no heat and no hot water. Conseque ntl y. Jahahara J\lkehu lan-
10
Ma"at began using space heaters with ex tension cords. which short-circuited the electrical
II
outlets. On or about that day. Jahahara Alkebulan-Ma'at informed Dctcndant Eugene Uore lik
12
of these issues via text message. Defendant Eugene Gorelik told .lahahara Alkebulan-Ma'at
13
that hi s workers cut off the gas because they smelled a leak. Additionall y. Defendant Eugene
14

15 Gorelik told .Jahahara Alkebulan-Ma'at to hire someone to fix the issues and the costs wo uld

16 be accounted for in the Unlawful Detainer lawsuit.

17 10. Upon information and belief on March 15, 2017. Defendants and .lahahara Alkehulan-Ma 'at
18
attended a Mandatory Settlement Conference to try to resolve the Unlawful Detainer. The
19
parties were unsuccessful in reaching an agreement, and the case was continued lor Jury Trial
20
on March 20, 2017.
21
11. Upon inf01mation and belief, on March 16, 2017 (a day after the Mandatory Settlement
22

23 Conference), while Jahahara Alkebulan-Ma 'at was away from hi s home lor about two hours.

24 Defendants changed the exterior locks to the Property. Consequent ly. Jahahara Alkcbu lan-
25 Ma'at could not access hi s home or hi s belongings. including medicine to r his disabi lity.
26
Additionally. upon information and belie[ Defendants cut off.lahahara J\lkebulan-Ma'at's
27
access to electricity. water, cable and internet.
28 ~
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COM PLAINT FOR INJUNCTIVE RELI EF, C IVIL PENALTIES. RESTIT UTION , ATTORNEY 'S FEES.
COSTS. AND OTII ER EQU ITABLE RELIEF
 12. Upon information and belie[ after changing the exterior locks of .Jahahara Alkebulan-Ma 'at" s
2 home. on March 16. 20 I7. Gorelik sent .lahahara Alkebulan-Ma'at an e-ma il stating. in part.
3
"If you set foot on the premises again without my permission. J will not on ly call the police to
4
arrest you for trespass but I will defend my property.~ I repeat. DO NOT SF.T FOOT 0 TilE
5
PREM ISES AGAIN WITHOUT MY PERMISSION or there will be consequences ...
6

7 13. Upon information and belie[ on March 17. 20 17. while Jahahara Alkebulan-Ma at \\as at the

8 hospital getting emergency doses of medication that was locked in his home. Defendants

9 partially demolished his home. including portions of the roof and walls. That same day.
IO
Jahahara Alkebulan-Ma 'at reported the incident to the Oakland Pol ice Department who then
II
responded to the Property. A responding oflicer spoke to Defendant Eugene Gorelik by phone
I2
and asked him to provide .Jahahara Alkebulan-Ma 'at with a key to the new Jocks: hO\\Cver.
13
Defendant Eugene Gorel ik refused. The officers allowed .Jahahara 1\Jkebulan-Ma ut to enter
14
15 his home through an unlocked window.

I6 14. Upon information and belief, during the ni ghts of March 17 and March 18. 2017. Defendant

17 Eugene Gorelik. contacted .Jahahara Alkebulan-Ma'at at his home. unannounced. through a

18
demolished portion of the wall. and made multiple threats. including demands that .Jahahara
19
Alkebulan-Ma"at get otfhis property and that he 'better not be [t]hcre in the morning:
20
15. On March 20. 20 17. Defendant Eugene Gorelik posted a 24-hour notice of entry to "make
21
necessary repairs to Drywall and Electrical throughout rthe I apartmenr on March 11. 20 17.
22

23 On March 22.2017. Defendants demolished most of the rear-end addition. That same day. City

24 of Oakland Code Enforcement Inspector Wing Loo posted a restricted usc notice on the
25 remaining frame, which permitted debris clean up only. Consequen tly. Jahahara 1\lkchulan-
26
Ma'at was forced to seek emergency housing at hotels, while his minor son moved in with
27
relatives. Jahahara Alkcbulan-Maat remains homeless to dat~.:.
28
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COMPLA INT FOR INJUNCTIVE RELieF, CI VIL PENALTIES. RESTITUTION. ATTORNEY"S PEES.
COSTS. AND OTIIER EQUITABLE RELIEF
 16. On March 27.2017. days after demoli sh ing the !-story portion of.lahahara Alkebulan-Maats
2
home. forcing him to vacate. Defendants dismi ssed the Un lawful Detainer.
3
17. Defendants systematic campaign of harassment has violated - and continues to violate - state..:
4
and local laws designed to protect tenants from unjust conduct by abusi\e landlords.
5
Theretore, the People of the State of California and the Ci ty of Oak land intervene to hold
6

7 Defend ants accountable for their illegal actions. to delcnd the tenant's rights. and to secure the

8 reiicf the tenant is entitled to under law.

9 PARTI ES
10
18. The Ci ty of Oakland is a municipal corporation and a chartered city. organized and ex isting
II
under the laws of the State of California.
12
19. The People of the State of California and the City of Oakland (collecti vely .. Plaintiffs.. ) bring
13
these actions to protect the exercise and enjoyment of tenant rights from harassment. threats.
14

15 intimidation and coercion.

16 20. Defendant OAKLA D REDEVELOPMENT GROU P. LLC owns the Property located at 369

17 MacArthur Boulevard, Oakland, CA with Assessor Parcel Numhcr ("A PN'') 0 I 0-0785-021-02.
18
21. Upo n information and be li et: Defendants EUGENE GORELIK and .JESS ICA SA WC7.UK
19
hold OAKLAND REDEVELOPMENT GROUP. LLC in trust and manage the property.
20
22. Defendant EUGENE GORELIK is the registered agent of OAKLAND REDEVELOPMENT
21
GROUP. LLC.
22

23 23. Defendants DOES I through 20. whether individual. corporate, associate. represcntati\'c. alter

24 ego or otherwise of the named Defendants. are sued by lictitious names pursuant to California
25 Code of Civil Procedure 474. Plaintiffs will amend this Complaint to allege the true names
26
and capaci ties of DOES I through 20 when their true identities are ascer1ained.
27

28
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COMPLA INT FOR INJUNCTIVE RELIEF, CIVIL PENALTIES, RESTITUTION, /\lTORNEY"S FI~ ES,
COSTS. AND OTIIER EQU IT/\RL E RELIEF
 24. Plaintiffs are informed and believe. and therefore allege, that each of the Defendants was the
2
agent, servant, employee. subsidiary, aflili atc. partner. assignee. successor-in-interest. al ter
3
ego. or other representati ve of the remaining De fendants in comm itting the alleged acts. Each
4
Defend ant is li able, in who le or in part, to r the damages and injuri es.
5
JURISDI CTION
6

7 25. Thi s Court is the proper venue because the subject premises. the Oetendants' conduct. and the

8 Plainti ns injuries are all located or occu rred within the City of Oak land , Alameda Coun ty.

9 Californi a.
10
FACTS
II
Background
12
26. Upon information and beliet: Jahahara A.lkcbulan-Ma'at, a 64-ycar-o ld. disabled and low-
13
income individual. has li ved in Oakland at 369 MacArthur Bouleva rd since April I. 1995.
14

15 27. Upon informati on and belief. the residence on the Property consists or three un its: a front unit.

16 a back unit and an upstairs unit. The back unit was equipped "vith a bedroom. kitchen and

17 dining room. shower. toilet, and li ving room and a patio. The bedroom. kitchen and dining
18
room were in the two-story portion of the building, while the shower. toilet. and li ving room
19
were in the one-story add ition. The one-story addition was created prior to Jahahara
20
Alkcbulan-Ma'at's arri val.
21
28. Upon info rmation and belief, beginning in 1995, Jahahara Alkcbulan-Ma'at lived in the front
22

23 unit with hi s fo rmer wife, wh ile hi s fo rmer mother-i n-l aw lived in the back unit. In 2006.

24 follow ing hi s fo rmer wife and mother-in-law's departure. Jahahara Alkebulan-Ma'at moved to
25 the back unit. Jahahara Alkebulan-Ma'at 's minor son has li ved with him at the Property si nce
26
2000.
27

28
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COMPLAINT FOR INJ UNCTIVE RELIEF. CI VIL PENALTI ES, RESTITIJTION. ATTOR NEY'S FEES.
COSTS, AND OTIIER EQU ITABLE REI.II ~ F
 29. Upon information and belie( from 1995 to 2006, Jahahara Alkebulan-Ma'at paid rental

2 amounts ranging from $700 to $1,000 per month for the front unit. In 2006, .Jahahara
3
1\lkebulan-Ma'at began paying approximately $600 per month for the back unit alone. where
4
he lived with his minor son. Beginning in 20 15, Jahahara 1\lkebulan-Ma 'at's rent was raised to
s
$725 per month.
6

7 30. Upon information and belieC s ince Defendants purchased the Property, Jahahara Alkcbu lan-

8 Ma 'at paid his rent in full to Defendants every month by personal check. The December 20 16

9 check was returned to Jahahara Alkebu lan-Ma'at by mail. The January 2017 check was not

10 cashed. Jahahara Alkebulan-Ma'at has not paid rent from February 20 17 to the present because
I1
Unlawful Detainer proceed ings were pending.
12
Oakland Redevelopment Group LLC's Purchase of the Property and Move Out
13 Negotiations
14
31. Upon information and belief, on April 26, 2016. Defendants Jessica Sawczuk and Eugene
15
Gorelik contacted Jahahara Alkebulan-Ma'at at his home and informed him they intended to
16
purchase the Property. That same afternoon. Defendant Jessica Sawczuk contacted .Jahahara
17
Alkebulan-Ma'aL via e-mail , stating she and her husband Defendant Eugene Gorclik intended
18

19 to "restore the house to its original condition (this means turning it back into a s ingle l~unily)

20 [,)"and 'move in as [their] primary residence." Defendant Jessica Sawczuk further stated ,

21 'this means you would need to relocate" and offered to ''help with movers. pay II deposit and
22
several month's rent somewhere [else) or other compensation."
23
32. Upon information and be li el~ on April 28, 2016, Defendant Jessica Sawczuk sent Jahahara
24
A lkebulan-Ma'at a text message ask ing him to make a decision on her proposal by tht; end or
25
the clay because escrow was closing on the Property. Jahahara Alkehulan-Ma'at responded, via
26

27 e-maiL that he d id not fe el comfortable responding by the deadline. He needed more time to

28
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COMPLAINT FOR INJUN CTIVE RELIEF. CIV IL PENALTIES. RESTITUTION. ATrORNEY'S FEES.
COSTS. AND OTHER EQUITABLE RF.I.IEF
 look for new housing for both himself and hi s minor son through affordable housing and low-
2 income. senior housing programs.
3
33. On May I 0. 20 16. Defendant Oakland Redevelopment Group LL.C with Defendant Eugene
4
Gorelik as its registered agent, purchased the Property.
5
34. On June 5. 20 16, Jahahara Alkcbulan-Ma 'at and Defendants Jessica Sawczuk and Eugene
6
7 Gorelik met to discuss finding Jahahara Alkebulan-Ma"at new living arrangements. That

8 afternoon, Gorel ik e-mail ed Jahahara Alkebulan-Ma"at offering to help move him up various

9 afford able housing and sen ior, low-income housing li sts he applied lor. On .June 20. 2016.
10
Jahahara Alkebu lan-Maat declined this offer citing ethi cal concerns.
II
35. On July 26.20 16. Defendant Eugene Gorelik e-mail ed Jahahara Alkebulan- Ma"at asking lor
12
an update on his housing search and his attorney"s information.
13
Unlawful Detainer Lawsuit, Harassment, and l)isplaccm ent
14

IS 36. On cptember 2. 20 16. Defendant Jessica Sawcr.uk obtained a permit from the City or Oakland

16 Planning and Building Department (""Pl anning"') to ""remove fan] unpermitted I story rear

17 structure altached to fthe] 2 story.'

18
37. On October 25, 20 16, Jahahara Alkebulan-Ma'at received a 60-day ev iction notice from
19
Defendant Jessica Sawczuk. as an authorized agent for Defendant Oak land Redevelopmen t
20
Group. L LC. and Daniel Bornstein. as the attorney and authorized agent for Defendant
21
Oakland Redevelopment Group. L LC. In the notice. based on the September 2. 2016 permit.
22

23 Defendants misrepresented that Jahahara Alkebulan-Ma ats home was not covered under the

24 .lust Cause Ordinance stating .. [t]he city [l determined that the premises you occupy is illegal
25 and there fo re exempt because of its status ofbeing an illegal unit." This is untrue. /\t that
26
point, .. the City' never determined that Jahahara Alkcbulan-Ma 'at 's home was illegal. Code
27
Enforcement never inspected the premises, issued a Notice or Violation or issued any restricted
28
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COMPLAINT FOR INJ UNCT IV E RELI EF, CIVIL PENALT IES, RESTITUTION. ATTORNEY'S FEES.
COSTS, AND OTHER EQUITABLE RELIEF
 use noti ces. Nor did " the City" make the legal determination that Jahahara Alkebulan-Ma'ats
2 home was exempt from the Just Cause Ordinance.
3
38. Under the eviction notice. Jahahara Alkebulan-Ma at was to move out on or before December
4
25, 20 16. Christmas Day, or face an eviction lawsuit.
5
39. Based on the eviction notice, Defendants tiled an unlawful detainer lawsuit against Jahahara
6

7 /\l kebulan-Ma'at on January 12,20 17.

8 40. On December 23, 2016, Defendant Eugene Gorelik submitted a pre-appli cation to Planning to

9 develop the residence into 7 units with 7 park ing spaces. However. on February 17. 2017.
10
during his deposition for the Unlawful Detainer. when Defendant Eugene Gorelik was asked if
II
he planned to move into the Property as hi s primary residence. he responded ... If that's what it
12
takes to get him out:
13
41. Upon intormation and belief~ on february 25. 2017. Derendants shut otT the gas. leaving
14

15 Jahahara Alkebulan-Ma'at with no heat and no hot water. Consequently. Jahahara Alkebu lan-

16 Ma'at began using space heaters with ex tension cords. which short-circuited the electrical

17 outl ets. On or about that day. Jahahara /\lkebulan-Ma'at informed Defendant Eugene Gorelik
18
of these issues via text message. Defend ant Eugene Gorcli k told .Jahahara Alkebulan-Ma'at
19
that hi s workers cut off the gas because they sme lled a leak. Addi ti onall y, Defendant Eugene
20
Gorelik told Jahahara Alkebulan-Ma 'at to hire someone to lix the issues and the costs would
21
be accounted for in the Unlawful Detainer lawsuit.
22

23 42. Upon infom1ation and belief. on March 8. 2017. Defendant Eugene Gorelik sent Jahahara

24 /\ Jkebulan-Ma at a ..demand letter,' via e-mail. requesting .. reimbursement of $43.190.-D tor

25 excess holding costs covering loan interest payments. utilities. and legal tees 1Delendantsl
26
incurTed on [the Property.)" Defendant Eugene Goreli k alleged. these costs were .. related to
27

28
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COMPLAINT FOR INJ UNCTIVE RELIEF, CIVIL PENALT IES, RESTITUTION, ATTORNEYs FEES,
COSTS, AND OTIIER EQU ITABLE RELIEF
 your refusa l to leave the property in contradiction to promises and agreements you made to us
2 prior to our purchase of the property."
3
43. Upon information and belief. on March 15. 20 17. Defendants and Jahahara Alkebulan-Ma at
4
attended a Mandatory Settlement Conference to try to resolve the Unlawful Detainer. The
5
parties were unsuccessful in reachin g an agreement, and the case was continued tor .Jury Trial
6

7 on March 20, 20 17.

8 44. Upon information and beliet~ on March 16, 20 17 (a day after the Mandatory Settlement

9 Conference). whil e Jahahara 1\lkebulan-Ma 'at was away from his home for about two hours.
10 Defendants changed the exterior locks to the Property. Consequently . .lahahara 1\lkebulan-
II
Ma'at could not access hi s home or his belongings, including medic ine lor his disability.
12
Add iti onally. upon information and belief, Defendants cut off Jahahara Alkebulan-Ma'ats
13
access to electricity. water. cable and internet.
14

15 45. Upon information and belief, after changing the ex terior locks of Jahahara Alkchulan-Ma'at's

16 home, on March 16, 20 17, Gorelik sent Jahahara 1\lkebulan-Ma at an e-mail stating. in part,

17 " If you set toot on the prem ises again without my permission, I wi ll not only ca ll the police to
18
arrest you for trespass but I will defend my property. ,I I repeat. DO NOT SET FOOT ON TilE
19
PREM ISES AGAlN WIT HOUT MY PERM ISS ION or there wi ll be consequences ...
20
46. Upon inlonnation and be lief, on March 17. 20 17. wh ile .lahahara Alkebul an-Ma'at was at the
21
hospital getting emergency doses of medication that was locked in his home. Defendants
22
23 partially demolished his home, including portions of the roof and walls. That same day.

24 .Jahahara Alkebulan-Maat reported the incident to the Oakland Police Department who then

25 responded to the Property. A responding offi cer spoke to Defendant Eugene Gorelik hy phone
26
and asked him to provide Jahahara Alkebulan-M a'at with a key to the ne\v locks: however,
27

28
- I 0-
------------------------------~~-------------------------------
COMPLAINT J70R INJUNCTIVE RELIEF. CIVIL PENALTIES. RESTITUTION. A"ITORNEY"S FEES.
COSTS, AND OTHER EQUITAI3LE RELIEF
 Defendant Eugene Gorelik refused. The offi cers all owed Jahahara Alkebulan-Ma'at to en ter

2 hi s home through an unlocked window.

3
47. Upon information and beli eL during the nights of March 17 and March IS, 2017. Defendant
4
Eugene Goreli k, contacted Jahahara Alkebulan- Ma'at at his home, unannounced. through a
5
demoli shed portion of the wall , and made mul tiple threats. includ ing demands that Jahahara
6

7 Alke bul an-Ma'at get otT his property and that he "better not be [t] here in the morning ...

8 48. On March 20, 201 7, Defendant Eugene Goreli k posted a 24-hour noti ce of entry to "make

9 necessary repairs to Drywall and Electrical throughout !the] apartment'' on March 22. 2017.
10 49. On March 2 L 2017, in an e-mail to Defendants, Jahahara Alkebulan-Ma 'at's unl avvf"ul deta iner
11
defense attorney, Anne Omura, requested the keys to the changed locks. resto ration of uti li ties,
12
and repair of the partially demolished roof
13
50. On March 22, 20 17, rather than make the "repairs" set forth in the 24-hour notice. Defendants
14

15 demoli shed most of the rear-end addition. That same day, City of Oak land Code Ent()rcement

16 Inspector Wing Loo posted a restricted use notice on the remaining frame. which permitted

17 debris clean up onl y. Consequently, Jahahara Alkebul an-Ma'at was forced to seck emergency
I8 housing at hotels, while his minor son moved in with relatives. Jahahara Alkebulan-Ma at
19
remains home less to date.
20
51. Upon info rmation and beliet: to date, Jahahara Alkebulan- Ma'at's personal property remains
21
on the premises in a storage container. Several items have gone missing or are damaged.
22
23 including hi s wedding ring, famil y photos, artifacts, and a video recorder.

24 52. On March 27, 20 17. days after demoli shing the one-story portion of Jahahara Alkcbulan-

25 Ma'at's home, forcing him to vacate, Defendants dismissed the Un lawful Detainer.
26
II
27
II
28
- II-
COMPLA INT fO R INJ UNCTIV E RELI Ef. CI VIL PENALTIES. RESTITUTION. ATTORNEY'S FEES.
COST S. AN D OTH ER EQUITABLE RELIEF
 Jahahara Alkebulan-Ma'at Fears for the Safety of His Person and Property
2
53. Upon infom1ation and belief, Defendants' continued harassment has exacted a significant
3
emotional toll on Jahahara Alkebu lan-Ma'at. Due to Defendant Eugene Gorelik"s multiple
4
threats, Jahahara A lkebulan-Ma 'at fears fo r his physical safety and that of his minor son. Due
5
to Defenda nt Eugene Gorelik' s threats and Defendants' actions, Jahahara Alkebulan-Ma'at
6

7 also fears for the safety of hi s personal property, which remains on the premises in a storage

8 conta iner.

9 FIRST CAUSE OF ACTION FOR TENANT PROTECTION ORDINANCE

BY CITY OF OAKLAND AGAINST ALL DEFEN DANTS
10
!Oakla nd Municipal C ode 8.22.600 et seq. I
11
54. Plaintiffs incorporate by reference each preceding paragraph.
12
55. Plaintiffs bring this action pursuant to Oakland Municipal Code ("OMC ") ~8.22.600 et seq.
13
(the " T e na nt Protection Ordinance") in the name of the City of Oak land.
14

15 56. The Tenant Protection Ord inance finds that "the rising market demand for rental housing in

16 Oakland c reates an ince ntive for some land lords to engage in harassing behavior.'' OMC

17 8.22 .6 1O(E). T he purpose of the Tenant Protection Ordinance is "to deter harassing behavior
18
by landl ords. to e ncourage landlords to follow the law and uphold their responsibility to
19
provide habitable rental properties, and to give tenants legal recourse in in stances where they
20
a re s ubjected to harassing behavior by landlords.'' OMC 8.22.61 O(M).
21
57. Defendants v iolated OM C 8.22.640(A)( I) or the Tenant Protection Ord inance by
22

23 ''[ i]nterrupting, terminat[ing] and fa il [ing] to provide housing serv ices req uired'' by state a nd

24 local law.

25 58. Detendants violated OMC 8.22.640(A)(2) of the Tenant Protection Ordinance by "failli ng] to
26
perfo rm repairs and maintenance required [ ... ]"by s tate and local law.
27

28
- 12-
COMPLA INT FOR INJUNCTI VE RELI EF, CI VIL PENALTIES, RESTITUTION. ATTORNEY' S FEES,
COSTS, AND OTHER EQU ITABLE RELIEf-
 59. Defend ants vio lated OM C 8.22.640(A)(3) of the Tenant Protection Ordinance through

2 "fail[ing] to exercise due dili gence in completing repairs and maintenance 1... I."
3
60. Defendants vio lated OMC ~8 . 22 . 640(A)(4) of the Tenant Protection Ordinance by "abuslingl
4
l the ir] right of access into a rental housing unit as that right is prov ided by law.fl"'
5
61 . Defendants violated OMC ~8.22.640(A)(5) of the Tenant Protection Ordinance by
6
"fr]emov[ing] from the Rental Unit personal property, furnishings, or any other items without
7
8 the prior written consent of the Tenant [ . .. ].''

9 62. Defendants violated OMC 8.22.640(/\)(6) of the Tenant Protection Ord inance by

10 .. [i]nfluenc[ing] or attempt[ing] to influence a Tenant to vacate a Renta l Un it through fraud.

II
intimidation or coercion[.]"
12
63. Defendants v io lated OMC 8.22.640(A)(8) of the Tenant Protection O rd inance by
13
[a]ttempt[ing] to coerce a Tenant to vacate w ith offer(s) of payments to vacate which are
14

15 accompani ed w ith threats or intimidation ...

16 64. Defendants vio lated OMC 8.22.640(A)(9) of the Tenant Protection Ordinance by

17 '[t]hreatenfing] the tenant, by word or gesture. with physical harmf .J"

18
65. Defendants v iolated OMC 8.22.640(A)( I 0) of the Tenant Protection Ordinance by
19
"substantia ll y and directly interfer[ing] with a Tenants' ri ght to quiet enjoyment or a rental
20
housing unit[ ... ].''
21
66. Defendants violated OMC 8.22.640(A)(11) of the Tenant Protection Ordinance by
22
23 "Ir]efus[ing] to accept or acknowledge receipt of a Tenant's lawful rent payment, except as

24 such refusal may be perm itted by state law after a notice to quit has been served on the Tenant

25 and the time period tor performance pursuant to the notice has expi red!.!"
26
67. Defendants violated OMC 8. 22.640(A)( l2) of the Tenant Protection Ordinance by
27
"[ r]efus[i ng] to cash a re nt check for over thi rty (30) days f ... 1. except as such rerusal may be
28
- 13 -
COM PLAINT FOR INJUNCTIV E RELIEF. CI VIL PENALTIES, RESTITUTION, ATTORNEY'S FEES.
COSTS, A ND OTHER EQUITABLE RELIEF
 permitted by state law after a notice to quit has been served on the Tenant and the time period
2 for performance pursuant to the notice has expired[.]"
3
68. Defendants violated OMC 8.22.640(A) ( 13) of the Tenan t Protection Ordinance by
4
.. interfcrfingj with a Tenant's right to privacyl.r
5
69. Defendants violated OMC 8.22.640(A)( 15) of the Tenant Protection Ordinance through
6

7 ..other repeated acts or om issions of such significance as to substanti ally intertcrc '' ith or

8 disturb the comfort, repose, peace or qui et of any person lawfully entitl ed to occupancy of such

9 dwelling unit and that cause. arc likely to cause, or arc intended to cause any person lawfully
10 entitled to occupancy of a dwelling unit to vacate such dwelling unit or to surrender or waive
II
any rights in relation to such occupancy."
12
70. Defendants violated OMC 8.22.640(A) ( 16) of the Tenant Protection Ordinance by
13
'remov[ing] a housing serv ice for the purpose of causing the Tenant to vacate the Rental
14
IS
Un it. ..

16 71. Detendants acted in bad faith against thei r tenant as required by OMC ~L22.640(/\).

17 72. Defendants have engaged in a pattern and practice of harassment, and therefore the City
18 Attorney is exercising her authori ty pursuant to OMC ~8.22.670(A)(2).
19
SECOND CAUSE OF ACTION FOR THE BANE ACT
20 BY ALL PLAINTIFFS AGA INST ALL DEFENDANTS
!California Civil Code 52.1 et seq. I
21
73. Plaintiffs incorporate by reference each preceding paragraph.
22
23 74. Plaintiffs bring this action pursuant to California Civil Code 52.1 (a). in the name of the

24 People of the State of Ca li fornia and the Ci ty or Oakland, in order to protect the exerc ise and

25 enjoyment of tenant rights under state and local law from interterencc by Defendants through
26
threats, intimidation and coercion.
27

28
- 14 -
COMPLA INT FOR INJ UNCTIV E RELIEF, CIVIL PENALTI ES, RESTITUTION, ATTORNEY'S FEES.
COSTS, AND OTHER EQUITABLE RELIEF
 75. Defendants interfered with Jahahara Alkebulan-Maars tenant rights under state and loca l law
2 by threatenin g or committing violent acts.
3
76. Jahahara Alkebulan-Ma'at reasonably believed that if he exercised hi s tenant rights under state
4
and local law. Defendants would commi t violence against him or his property.
5
PRAYER FO R I~ E LI EF
6

7 Plainti ffs pray that the Court:

8 First Cause of /\ction

9 77. Order all injuncti ve relief deemed necessary, which may include but is not li mited to the

10 fo llowing: cease any construction on add itional un its until all required perm its arc obtai ned:
II
prior to re-renting any unit(s). schedule and pass req ui red inspections by City Building offic ial:
12
one r Jahahara Alkebulan-Ma ' at a rental uni t at the Propet1y at hi s most recent rate:
I~
compensate Jahahara Alkebul an-Ma' at for hi s relocation tees; for the next two years. notify the
14

15 City one week in advance be fore any un lawful detainer lawsuits are filed in volving units at the

16 property; lo r the next two years. certify each month that Defendants arc in compliance wit h the

17 Tenant Protection Ord inance and Just Cause lo r Eviction Ordinance: req uire DciCmlunts to
18
attend anger management counseling; require Defendants to refrain fro m verba l and written
19
threats: mandate that Defendants stay away from the Property: and hi re a separate property
20
ma nager and submit the proposed candidate fo r review and approval by the City. pursuant to
21
Oakland Municipal Code 8.22.670(C).
22
23 78. Award Plaintiffs any costs and ex penses incurred by the City in abatement and

24 prosec ution o f the violations pursuant to Oakland Muni cipal Code ~8 . 22 . 650(C) and

25 8.22.670( 0 )(3).
26
79. Award Plai ntifTs attorney's fees as authori zed by OMC 8.22.670(D)( I).
27
80. Order any restitu tion that the Court deems proper.
28
- 15 -
COM PLA INT FOR INJUNCT IV E RELI EF, CI VIL PENALTIES. RESTITUTION, ATTORNEY"S fEES.
COSTS. AND OTHER EQU ITABLE RELIEF
 Second Cause of Action
2 8 1. Order each Defendant to pay civil penalties in an amount up to $25.000 to each tenant whose
3
rights were violated pursuant to Cal. Civ. Code ~52 .1 (a).
4
82. Order all preliminary and permanent injuncti ve relief deemed necessary. which may inc lude
5
but is not limited to the follow ing: requiring Defendants to attend anger management
6

7 counseling: requiring Defendants to refrain from verbal and written threats: mandating that

8 Defendants stay away from the Property; and hiring a separate property manager and

9 submitting the proposed candidate for review and approval by the City, as authorized hy Cal.
10 Civ. Code 52.1 (a).
II
83. Award Plaintiffs attorney's fees as authorized by Cal. Civ. Code 52.1 (h).
12
All Causes of Action
13
84. Enter j udgment in favor of Plaintiffs and against Defendants
14

15 85. Order all other relief as the interests ofjusti ce may require.

16
Dated: April 26, 2017
17
BARBARA J. PARKER, City Attorney
18 OT IS MCGEE, Chief Assistant City Attorney
MARIA BEE, Special Counse l
19 KEV IN KING , Neighborhood Law Corps Attorney

20

21
By:
22 Attorneys for Plaintiffs.
The People ofthe State of Californi a and the City ofOakland

24
25

26
27
28
- 16 -
COMPLA INT FOR INJUNCTIVE RELIEF. CIVI L PENA LT I ES. RESTITUTION . ATTORNEYs FEES.
COSTS, AND OTHER EQU JTAI3LE RELIEF
 CM-010
~HORNE Y OR PARTY WITHO~T ATTORNEY (Nam~ Stale Bornumber. an(Ja<k/ress)
Barbara J. Parker. C1ty Attorney (Sd#69722)
FOR COURT USE ONLY

Kevin King ($8#.109.197)

One Frank II. Ogawa Plaz<J. 6th Floor
Oakland. CA 94612 ENDORSED
TELEPHONE NO(5){)) 238-3865 FAXNO
FILED
ATl ORNEv FORtNameJ l'he People of the State of Californ ia and City of Oakland
SUPERIOR COURT OF CALIFORNIA, COUNTY OF AJamecla
ALAMEDA COUNTY
srR~er ADDRess 1225 r:'allon Street
MAILING ADDRESS
APR 2 8 2017
CITY AND ZIP CODE Oak land, CA 94612
C ERK ~;pp,ERJOR COURT
r-----~BAA~NC~H~NA~M~E~--------------------------------------------------~ ll~
CASE NAME "' :-"" ;.;irl;"'-'a~Pit111f
People of California, et al. v. Oakland Redevelopment Group, LLC, ct al. n (' 1 .., n ,.- n .. ,.., ..
CIVIL CAS E COVER S H EET Complex Case Desig nation CASE~{\MB(R .L 1 0 :; 0 J. C. l
0 Unlimited
(Amount
0
Limited
(Amount
D
Counter 0
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 mstruct10ns on page 2).

Check one box below for the case type that best describes this case:
Auto Tort Contract Provisionally Complex Civil Litigation
0 Aulo (22) D Breach of contracUwarranty (06) (Cal. Rules of Court, ru les 3.40Q-3.403)
0 Uninsured motorist (46) D Rule 3.740 collections (09) 0 Antitrust/Trade regulation (03)
Other PI/PDIWD (Personal Injury/Property 0 Other collections (09) D Construction defect (10)
Damage/Wrongful Death) Tort D D
D
Insurance coverage (18) Mass tort (40)
Asbestos (04)
D Other contract (37) D Securities litigation (28)
D
D
Product liability (24) Real Property D Enwonmentat!Toxic tort (30)

D
Medical malpractice (45)
D Eminent domain/Inverse
condemnation (1 4)
D Insurance coverage claims arising from the

D
Other PI/PDNVD (23) above listed provisionally complex case
Non-PI/PDIWD (Other) Tort Wrongful eviction (33) types (41)
D [Z] Other real property (26) Enforcement of Judgment
D D
Bus1ness tort/unfair business practice (07)
Civil rights (08) Unlawful Detainer Enforcement or judgment (20)
D Defamation (13) D Commercial (31) Miscellaneous Civil Complaint
D Fraud (16) D Residential (32) D RIC0(27)
0 Intellectual property (19) D Drugs(38) D Other complaint (not specified above) (42)
0 Profess1onal negligence (25) Judicial Review
D Other non-PIIPDNVD tort (35) D Asset forfeiture (05)
Miscellaneous Civil Petition
D Partnership and corporate governance (21)

D
Employment
Wrongful termination (36)
D
D
Petition re : arbitration award (11)
Writ of mandate (02)
D Other petition (not specified above) (43)

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 reqwmg excepttonal JUdicial management.
a. D Large number of separately represented parties d. D
Large number of witnesses
b.D Extens1ve motion practice ra1sing 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 that apply): a[{] monetary b. [{] nonmonetary: declaratory or injunctive relief c. O punitive
4. Number of causes of action (specify):
5 This case D 1s 0 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.)
Date 4/26g) 7 -~/
!Kevin Kin_
(TYPE OR PRIN1 NAME)
NOTICE
Plaintiff 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 th1s 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 a ll
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.
.Sa e 1 of 2
Form AOOpiOd for Mandatory Use Cal R ~eso1 Court. rules 2 30. 3 220. 3 400-3 403 3 740,
JudiCial Cooool o f Cal1forma
C IVIL CASE COVER SH EET Cal Slandards of JudiCial Admtnlslra!lon. sld 3 10
CM.010 I Rev July I 20071 www ccumnro ca gov
 CM-010
INSTRUCTIONS ON HOW TO COMPLETE THE COVER SHEET
To P laintiffs and Others Filing First Papers. If you are filing a first paper (for example, a complaint) m a civ11 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 spec1fic one. If the case has multiple causes of action, check the box that best indicates the primary cause of action.
To assist you m comple ting 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 fi le a cover sheet with the first paper fi led 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 certam that is not more than $25,000. exclusive of interest and attorney's fees. ansing 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-serv1ce requirements and case management rules. unless a defendant files a responsive pleading. A rule 3.740 collections
case will be subject to the requ irements 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 fi le and serve no later than the time of its fi rst 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 Provisionally Complex Civil Litigation (Cal.
Auto (22)- Personal Injury/Property Breach or Contract/Warranty (06) Rules of Court Rules 3.400-3.403)
Damage/Wrongful Death Breach of Rental/Lease AntitrusVTrade Regulation {03)
Un1nsured Motorist (46) (1f the Contract (not unlawful detainer Construction Defect (10)
case mvolves an uninsured or wrongful evict1on) Claims Involving Mass Tort (40)
motorist claim subject to Contraci/Warranty Breach-Seller Securities Litigation (28)
arbitration, check this item Plaintiff (not fraud or negligence) Environmentalffoxic Tort (30)
instead of Auto) Negligent Breach of Conlracv Insurance Coverage Claims
Other PI/PDIWD (Personallnjuryl Warranty (arising from provisionally 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 provisionally domestic relations)
toxic/enVIronmental) (24) complex) (18) Sister State Judgment
Medical Malpractice (45) Auto Subrogation Administrative Agency Award
Med1cal 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 PIIPDIWO (23)
Premises Liability (e.g .. slip Eminent Domain/Inverse Miscellaneous Civil Complaint
and fall) Condemnation (14) RICO (27)
Intentional Bodily lnjury/PDIWD Wrongful Eviction (33) Other Complaint (not specified
above) (42)
(e.g .. assault. vandalism) Other Real Property {e.g.. quiet title) (26)
Intentional Infliction or Declaratory Relief Only
Writ of Possession of Real Property Injunctive Relief Only (non-
Emot1onal Distress Mortgage Foreclosure harassment)
Negligent Infliction of Quiet Title
Emotional Distress Mechanics Lien
Other Real Property (not eminent Other Commercial Complaint
Other PIIPDIWO domain. Jandlord!Tenant. or Case (non-tort/non-complex)
Non-PI/POIWD (Other) Tort foreclosure)
Other Civil Complam t
Business TorVUnfair Business Unlawful Detainer (non-tort/non-complex)
Practice (07) Commercial (31) Miscellaneous Civil Petition
Civil Rights (e.g .. discrimination, Residential {32) Partnership and Corporate
false arrest) (not c1vil Drugs (38) (if the case involves illegal Governance (21)
harassment) (08) drugs, check this item; otherwise. Other Petition (not spectfied
Defamahon (e.g., slander. libel) report as Commercial or Residential) above) (43)
(13) Judicial Review Civil Harassment
Fraud (16) Asset Forfeiture (05) Workplace Violence
Intellectual Property (19) Petition Re: Arbitration Award (11) Elder/Dependent Adult
Professional Negligence (25) Writ of Mandate (02) Abuse
Legal Malpractice Writ- Administrative Mandamus Election Contest
Other Professional Malpractice Writ-Mandamus on Limited Court Petition for Name Change
(not medical or legal) Case Malter Petition for Relief From Lale
Other Non-PIIPDIWO Tort (35) Writ-Other Lim1ted Court Case Cia1m
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 2 ol2
CIVIL CASE COVER SHEET
 Unifierl Uules of the Sttpc>rior Court of Cn/ifomin, C01111ty of Alaml'rln

Case Number:

C IVIL CASE COVER SHEET ADDENDUM

THIS FORM IS REQUIRED IN ALL NEW UNLIMITED CIVIL CASE FILINGS IN THE
SUPERIOR COURT OF CALIFORNIA, COUNTY OF ALAMEDA
[ l Hayward Hall of Justice (447)
[ l Oakland, Rene C . Davidson Alameda County Courthouse (446) [ ] Pleasanton, Gale-Schenone Hall of Justice (448)
Civil Case Cover ~;

Sheet Category Civil Case Cover Sheet Case Type' ... , . Alameda County cat e Type (check only one) ;':

Auto Tort Auto tort (22) I I 34 Auto tort (G)

Is this an uninsured motorist case? [ 1 yes [ 1 no
Other PI/PD I Asbestos (04) I I 75 Asbestos (D)
WD Tort Product liability (24) I I 89 Product liability (nQ! asbestos or toxic tort/environmental ) (G)
Medical malpractice (45) I I 97 Medical malpractice (G)
Other PIIPD/WD tort (23) I l 33 Other PIIPDIWD tort (G)
Non- PI/PD I Bus tort/ unfair bus. practice (07) I I 79 Bus tort I unfair bus. practice (G)
WDTort Civil rights (08) I I 80 Civil rights (G)
Defamation (13) I I 84 Defamation (G)
Fraud (16) I I 24 Fraud (G)
Intellectual property (19) I I 87 Intellectual property (G)
Professional negligence (25) [ I 59 Professional negligence - non-medical (G)
Other non-PIIPDIWD tort (35) [ 1 03 Other non-PIIPDIWD tort (G)
Employment Wrongful termination (36) [ I 38 Wrongful termination (G)
Other employment (15) I I 85 Other employment (G)
I I 53 Labor comm award confirmation
I I 54 Notice of appeal- L.C.A.
Contract Breach contract / Wrnty (06) [ I 04 Breach contract I Wmty (G)
Collections (09) [ I 81 Collections (G)
Insurance coverage (18) I I 86 Ins. coverage - non-complex (G)
Other contract (37) I l 98 Other contract (G)
Real Property Eminent domain / lnv Cdm (14) [ I 18 Eminen t domain /lnv Cdm (G)
Wrong ful eviction (33) I I 17 Wrongful eviction (G)
Other real property (26) rJr' 36 Other real property (G)
Unlawful Detainer Commercial (31) [ I 94 Unlawful Detainer - commercia l Is the deft. in possession
Residential (32) [ 1 47 Unlawful Detainer - residential of the property?
Drugs (38) I J 21 Unlawful detainer - drugs [ ] Yes [ 1 No
Judicial Review Asset forfeiture (05) [ I 41 Asset forfeiture
Peti tion re: arbitration award (11) [ I 62 Pet. re: arbitration award
Writ of Mandate (02) [ I 49 Writ of mandate
Is this a CEQA action (Pubi.Res.Code section 21000 et seq) [ ) Yes [ ) No
Other judicial review (39) LI 64 Other judicial review
Provisionally Antitrust/ Trade regulation (03) I I 77 Antitrust/ Trade regulation
Complex Construction defect (10) [ J 82 Construction defect
Claims involving mass tort (40) I I 78 Claims involving mass tort
Securities litigation (28) I I 91 Securities litigation
Toxic tort I Environmental (30) [ I 93 Toxic tort I Environmental
Ins covrg from cmplx case type (4 1) r 1 95 Ins covrg from complex case type
Enforcement of Enforcement of judgment (20) I I 19 Enforcement of judgment
Judgment I I 08 Confession of judgment
Mise Complaint RICO (27) [ I 90 RICO (G)
Partnership I Corp. governance (21) [ I 88 Partnership I Corp. governance (G)
Other complaint (42) I I 68 All other complaints (G)
Misc. Civil Petition Other petition (43) [ I 06 Change of name
I I 69 Other petition
202-19 (5/1/00) A-13