··~-~---
/ 2
3
4
5
6
1
8
9
lO
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Dario de Ghetaldi - Bar No. 126782 Amanda L. Riddle - Bar No. 215221 Clare Capaceioli Velasquez - Bar No. 290466 COREY, LUZAICH, DE GHETALD!, NASTARJ & RIDDLE LLP 700 EI Camino Real
OCT 2 6Z015
CLERK OF THE COURy
P.O. Box 669 Millbrae, California 94030-0669 Telephone: (650) 871-5666 Facsunile: (650} 871-4144 [email protected] [email protected]
Michael S. Danko· Bar No. 1I1359 Kristine K. Meredith ·Bar No. 158243 DANKO MEREDITH 333 Twin Dolphin Drive, Suite 145 Redwood Shores, CA 94065 Telephone: (650) 453-3600 Facsimile: (650) 394-8672 [email protected] [email protected]
DY;_ BOWMAN t.IU ocpwy (.'Jerk -
Attorneys for Plaintiffs Stephanie Mathes and Karen Goldsmith
SUPERJOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
STEPHANIE MATHES and KAREN } GOLDSMITH, individually and as ) Successors-in-Interest to the Estate of OWEN ) GOLDSMITH, deceased, and STEPHANIE } MATHES, as representative of the Estate of } OWEN GOLDSMITH, deceased, )
Plaintiffs, l vs.
PG&E CORPORATION, a California Corporation, PACIFIC GAS & ELECTRIC COMPANY, a California Corporation, ACRT, Inc., a Corporation, TREES, INC., a Corporation, and DOES 1-50, inclusive,
Defendants.
~ }
~ ) ) ) } }
~~~~~~~~~~~~~}
CGC-15-548619 CASE NO.
COMPLAINT FOR:
1. NEGLIGENCE: WRONGFUL DEATH
2. STRICT LIABILITY: WRONGFUL DEATH
3. SURVIVAL ACTION
COMPLAINT
Scanned by CamScanner
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Plaintiffs STEPHANIE MATHES and KAREN GOLDSMITH, individually and as
Successors-in-Interest to the Estate of OWEN GOLDSMITH, deceased, and STEPHANIE
MATHES, as representative of the Estate of OWEN GOLDSMITII, deceased, bring this action
for damages against Defendants PG&E CORPORATION, a California Corporation, PACIFIC
GAS & ELECTRIC COMPANY, a California Corporation (collectively "PG&E"), a
Corporation, ACRT, INC., TREES, INC., a Corporation, and DOES 1-50, inclusive, as follows:
I. INTRODUCTION
1. PG&E has a long history of failing to maintain its infrastructure and making poor
decisions that result in safety lapses. These safety lapses have led to disasters that result in
wrongful death, personal injury, and destruction of property. In this case, PG&E failed to
properly inspect its electrical lines and maintain the surrounding vegetation, by its own acts or
through the acts of its agents. As a result, on the afternoon of September 9, 2015, a tree struck a
12,000-volt PG&E power line on Butte Mountain Road, in Jackson, California. Sparks flew and
ignited what has since been named "The Butte Fire."
2. Over the next week, the Butte Fire spread rapidly, causing extensive damage
within Amador and Calaveras Counties. Over 4,000 firefighters battled the blaze. The fire was
not reported contained until October 1, 2015. The Butte Fire burned more than 70,000 acres,
destroying and damaging 475 residences, 343 outbuildings, and 45 other structures. The fire also
left tens of thousands of dead or dying trees, and the risk of water pollution and erosion in its
wake. Two people lost their lives as a result of the Butte Fire and thousands of residents and
property owners were significantly burdened.
3. One of those residents was Owen Goldsmith. Owen Goldsmith was found in his
home by firefighters on September 15, 2015, having perished in the Butte Fire. At the time of his
death, Owen Goldsmith, 82, lived in the home he owned in Mountain Ranch, Calaveras County.
Born in Borger, Texas, Owen Goldsmith served as a staff sergeant in the United States Air Force
from 1951 to 1955. He went on to graduate magna cum laude in music at then~San Francisco
State College and got his master's degree in music from the college in 1965. Owen Goldsmith
was a prolific music composer, having taught choir and orchestra to high school and college
2
COMPLAINT
students. Mr. Goldsmith had two beloved daughters: Plaintiffs Stephanie Mathes and Karen
2 Goidsmith.
3
4
5
6
7
8
9
10
1 1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
4. In this ease, PG&E and its agents ACRT, Inc., and Trees, Inc., negligently
maintained and operated its electrical infrastructure, and failed to maintain the surrounding
vegetation within the applicable regulations and law. As a result, hundreds of residents lost their
homes, Owen Goldsmith lost his life, and Plaintiffs Stephanie Mathes and Karen Goldsmith lost
their father.
II. JURISDICTION AND VENUE
5. This Court has personal jurisdiction over Defendants. PG&E Corporation and
Pacific Gas & Electric Company are incorporated in California and have and continue to do
significant business in California so as to render the exercise of jurisdiction over it by the
California courts consistent with traditional notions of fairness and substantial justice. Defendant
ACRT, Inc., is a privately owned corporation conducting business in California as a utility
vegetation management contractor. Defendant Trees, Inc., is a privately owned corporation
conducting business in California as a tree maintenance corporation for utility companies. In
addition, a substantial part of the events that caused Plaintiffs' injuries occurred in the County of
San Francisco, within the State of California.
6. The amount of controversy exceeds the jurisdictional minimum of this Court.
7. Venue is proper in this County as Defendants perform business in this County,
with at least two of them having their principal plaee of business in this County, and a substantial
part of the events, acts, omissions, and transactions complained of herein occurred in this
County.
III. THE PARTIES
8. Plaintiff Stephanie Mathes is the loving daughter of Owen Goldsmith. She brings
certain claims herein, specified below, as the natural daughter of Owen Goldsmith, pursuant to
Code of Civil Procedure§ 377.60. Additionally, on October 26, 2015, Plaintiff Stephanie
Mathes filed with the Superior Court of California, County of Calaveras, the Estate of Owen
Goldsmith. In the filing, Plaintiff Stephanie Mathes seeks to have the Court appoint her as the
3
COMPLAl:-.IT
administrator of the Estate of Owen Goldsmith. She is thus lawfully entitled to pursue all claims
2 and causes of action for damages, loss, or destruction of assets of the Estate pursuant to Code of
3 Civil Procedure § 377.30.
4 9. Plaintiff Karen Goldsmith is the loving daughter of Owen Goldsmith. She brings
5 certain claims herein, specified below, as the natural daughter of Owen Goldsmith, pursuant to
6 Code of Civil Procedure § 377.60.
7 I 0. Owen Goldsmith was the natural father of Plaintiffs Stephanie ~athes and Karen
8 Goldsmith. At the time of his death, he owned and occupied 6003 Eagle View Drive, Mountain
9 Ranch, California.'
10 IL Defendant PG&E Corporation, is incorporated in California and based in San
11 Francisco, California. At all times mentioned herein, it has acted to provide electrical services to
12 members of the public in California, including, Amador and Calaveras Counties.
13 12. Defendant Pacific Gas & Electric Company, a subsidiary corporation of PG&E
14 Corporation, is incorporated in California and based in San Francisco, California. It is one of the
15 largest combination natural gas and electric utilities in the United States. At all times herein
16 mentioned, Pacific Gas & Electric Company provided electric service to millions of customers in
17 Northern and Central California, including to the residents of Amador and Calaveras Counties,
18 through its electric transmission and distribution systems.
19 13. Defendant ACRT, Inc., is utility vegetation management company, doing business
20 all over the United States. Plaintiffs are informed and believe that at all times mentioned herein,
21 ACRT, Inc., was the agent of PG&E and acting within the course and scope of that agency.
22 14. Defendant Trees, Inc., is one of the largest utility vegetation management service
23 companies in the United States. Plaintiffs are informed and believe that at all times mentioned
24 herein, Trees, Inc., was the agent of PG&E and acting within the course and scope of that agency.
25 15. The true names and capacities, whether individual, corporate, associate or
26 otherwise of1he Defendants sued herein as DOES 1 through 50 are unknown to Plaintiffs who
27
28 1 As of September 9, 201 the property was held by Owen L. Goldsmith, Trustee of the Owen L. Goldsmith Trust, dated May 3, 1996.
4
COMPLAJNT
therefore sue said Defendants by such fictitious names. Plaintiffs will amend this complaint to
2 show their true names and capacities when the same are ascertained. Plaintiffs are informed and
3 believe and thereon allege that each of said fictitious Defendants is in some manner negligently
4 and/or legally responsible for the occurrences herein alleged, and that Plaintiffs' damages as
5 herein alleged were legally caused by such Defendants, and each of them.
6 16. Plaintiffs are informed and believe and thereon allege that at all times herein
7 mentioned, Defendants, and each of them, were the partners, principals, agents, employees,
8 servants and joint venturers of each other Co-defendants, and in doing the things hereinafter
9 mentioned were acting within the course and scope of their authority and relationship as such
10 partners, principals, agents, employees, servants and joint venturers with the permission,
11 knowledge, and consent of each other co-Defendants.
12 IV. THE FACTS
13 1 7. PG&E' s safety record is an abomination. PG&E has and continues to ~put its
14 own profits before the safety of the California residents whom it serves. The Butte Fire fell on
15 the fifth year anniversary of the rupture and explosion of PG&E' s 30-inch transmission
16 pipeline under a residential neighborhood in San Bruno, California. That explosion and ensuing
1 7 fire killed eight people, injured dozens of others, and destroyed and damaged I 00 homes. The
18 neighborhood still has not fully recovered from the horrifying experience. The CPUC fined
19 PG&E $1.6 billion for safety violations that lead to the San Bruno Explosion.
20 18. In the years prior to the San Bruno Explosion, PG&E had several other incidents
21 that caused injury and death to California residents, and destroyed properties:
22 a. 1981: A PG&E gas main in downtown San Francisco exploded, forcing
23 30,000 people to evacuate. It took workers nine hours to shut off the gas
24 main' s manual shut off valves and stop the flow of gas that continued to
25
26
27
28
b.
feed the flames in the interim.
1992: Two people were killed and three others were injured when a PG&E
gas line exploded in Santa Rosa. The pipeline was improperly marked,
failing to give proper notice to contractors working in the area. A
5
COMPLAINT
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
23
24
25
26
27
28
c.
d.
e.
f.
g.
h.
contractor hit the pipe with a backhoe, causing the pipe to leak several
months later.
1998: A CPUC report found that PG&E had misdirected $77.6 million that
was to be used to trim trees near power lines, which, as we know from the
instant case, is a necessary part of preventing wildfires, and redirected it
into corporate profits.
1997: A Nevada County jury found PG&E guilty of 739 misdemeanor
counts of criminal negligence for a pattern of tree-trimming violations that
sparked a devastating 1994 wildfire in the Sierras. The fire burned down a
schoolhouse and 12 homes near the scenic Gold Rush town of Rough and
Ready.
1999: A rotten pine, which the government said PG&E should have
removed, fell on a power line, starting the Pendola Fire. It burned for 11
days and scorched 11, 725 acres, mainly in the Tahoe and Plumas national
forests. PG&E paid a $14.75 million settlement to the U.S. Forest Service
in 2009. That year, the utility also reached a $22.7 million settlement with
the CPUC after regulators found PG&E had not spent money earmarked
for tree trimming and removal toward those purposes.
2003: One third of San Francisco lost power following a fire at PG&E's
Mission District Substation. The fire burned for nearly two hours before
PG&E workers arrived on the scene to discover the damage.
2005: A PG&E electrical transformer exploded beneath the San Francisco
financial district, severely burning a woman who had been walking by.
2008: An explosion and fire caused by a natural gas leak destroyed a
residence in Rancho Cordova, California, killing one person, injuring five
others and causing damage to several other nearby homes. The cause of
the explosion was the use of a section of unmarked and out-of-
6
COMPLA!NT
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
19.
specification pipe with inadequate wall thickness that allowed gas to leak
from a mechanical coupiing instalied approximately two years earlier.
Two years ago, PG&E and its contractors agreed to pay a $50.5 million to settle
claims over the Power Fire of2004 that burned 13,000 acres of Eldorado National Forest, and a
2008 blaze known as the Whiskey Fire that burned more than 5,000 acres of Mendocino National
Forest.
20. As part of its system of providing electricity to members of the public in Amador
and Calaveras Counties, PG&E owned, installed, constructed, operated and maintained overhead
power lines, together with supporting poles and appwienances, throughout Amador and
Calaveras Counties, for the purpose of conducting electricity for delivery to the members of the
general public. Such lines existed near Butte Mountain Road, east of Jackson, California.
21. Electrical infrastructure is inherently dangerous and hazardous. The transmission
and distribution of electricity requires an increased level of care in line with the increased risk of
danger. Defendants, and each of them, had a duty to properly maintain and repair the electric
transmission lines and to keep vegetation properly trimmed and maintained so as to prevent it
coming in contact with power lines. In the construction, repair, maintenance and operation of the
power lines, Defendants, and each of them, had an obligation to comply with legal standards,
statutes and regulations, including, but not limited to Public Resource Code 4292, Public
Resource Code 4293, CPUC General Order No. 95, and CPUC General Order No. 165.
Defendants, and each of them, were aware that these requirements were the minimum standards
to be followed, and that they were required to consider the surrounding circumstances when
determining how to keep the lines safe. Defendants, and each of them, were further aware that a
failure to do so constituted negligence and would expose members of the general public to risk of
death or injury.
22. At all times herein mentioned, Defendants, and each of them, were aware that
California continues to face one of the most severe droughts in history. In January 2015,
Governor Jerry Brown declared a State of Emergency and directed state officials to take all
necessary actions to prepare for water shortages. In addition, 2015 brought record temperatures.
7
COMPLAINT
As a result, the danger of wildfires in the state became increasingly known. Such conditions,
2 along with above-cited regulations and guidelines regarding management of power lines and
3 vegetation in the vicinity of overhead electrical lines, put Defendants on notice that they needed
4 to properly maintain both PG&E's electrical infrastructure and the surrounding vegetation that
5 could impact it. In fact, the CPUC called on utilities to step up their vegetation management
6 efforts last year as the drought worsened.
7 23. Defendants failed to heed these obvious warnings and foreseeable risks, and meet
8 their obligations to properly maintain, repair, and inspect their power lines, and properly maintain
9 in accordance with regulations and the circumstances - the trees and other vegetation
10 surroundings PG&E's power lines.
11 24. Plaintiffs are informed and believe that on September 9, 2015, a tree that had been
12 negligently maintained by PG&E and/or ACRT, Inc., and/or Trees, Inc., struck a 12,000-volt
13 overhead power line that was owned and operated by PG&E. The resulting fire spread rapidly,
14 ultimately burning over 70,000 acres, destroying and damaging 4 7 5 residences, 343 outbuildings,
15 and 45 other structures. The fire also left tens of thousands of dead or dying trees, and the risk of
16 water pollution and erosion, in its wake. Two people lost their lives and thousands of residents
17 and property owners were significantly burdened.
18 25. Plaintiffs' father, Owen Goldsmith, lost his life to the Butte Fire. In addition,
19 Owen Goldsmith's real and personal property, including five acres of heavily vegetated land,
20 were destroyed.
21 26. As firefighters battled the blaze, PG&E acknowledged that it was likely that a tree
had made contact with the PG&E line in the vicinity of the ignition point. The CPlJC followed
23 up PG&E's release with a statement that Cal Fire had narrowed the Butte Fire investigation to a
24 single tree, and that Cal Fire had taken custody of the tree and the power line conductor.
25 27. Defendants' failures showed a conscious disregard for human life and were a
26 substantial factor in the fire and the death of Owen Goldsmith. Plaintiffs are informed and
believe that Defendants, and each of them, knew of the dangerous condition of PG&E's electrical
28 infrastructure, the condition of the property, including the surrounding circumstances such as the
8
COMPLAfNT
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
23
24
25
26
28
drought, high temperatures, and flammable vegetation surrounding PG&E's electrical
infrastructure, ali of which resulted in the ignition and spread of the Butte Fire, and acted
recklessly and with careless and conscious disregard to human life and safety, ignoring the
obvious risks present, including warnings related to the specific tree at issue and the 12,000 volt
power-line in its vicinity. As a result, and to ensure that Defendants make public safety a priority
in the future, this action seeks punitive and exemplary damages against Defendants.
V. FIRST CAUSE OF ACTION
(Negligence - Wrongful Death Pursuant to C.C.P. § 377.60, et seq.)
28. Plaintiffs hereby reallege and incorporate by reference each and every allegation
contained above as though the same were set forth herein in full.
29. Defendants, and each of them, breached their duties and obligations and (1) failed
to comply with all applicable standards, statutes and regulations; (2) failed to timely and properly
maintain the subject overhead power line; (3) failed to properly maintain, including, but not
limited to, trimming and pruning, all surrounding vegetation so as to prevent it from making
contact with the subject power line; (4) failed to take in to account all surrounding circumstances
when maintaining the subject overhead power line and the surrounding vegetation.
30. As a direct, proximate, and legal result of the negligence of Defendants, and each
of them, and the resulting Butte Fire, Decedent Owen Goldsmith suffered burns and injuries,
which resulted in his death.
31. As a direct, legal and proximate result of the incident described above, and the
death of her father, Decedent Owen Goldsmith, Plaintiff Stephanie Mathes has sustained a loss of
love, companionship, comfort, affection, society, solace, training and/or moral support.
32. As a direct, legal and proximate result of the incident described above, and the
death of her father, Decedent Owen Goldsmith, Plaintiff Karen Goldsmith has sustained a loss of
love, companionship, comfort, affection, society, solace, training and/or moral support.
I I I
I I I
I I I
9
COMPLAIN1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
VII. SECOND CAUSE OF ACTION
(Strict Liability- Wrongful Death Pursuant to C.C.P. § 377.60, et seq.)
33. Plaintiffs hereby reallege and incorporate by reference each and every allegation
contained above as though the same were set forth herein in full.
34. Plaintiffs are informed and believe that the electrical line that is the subject of this
action was a 12,000-volt electrical transmission line. The electrical lines were located in and ran
through populated and highly vegetated areas. The area was also subject to and affected by the
California drought, high temperature, and flammable timber and vegetation. As such, Plaintiffs
are informed and believe that Defendants, and each of them, knew that the operation of the
electrical transmission line was an ultra hazardous activity because any failure would result in
serious injury and death.
35. Defendants, and each of them, are strictly liable for damage, injury and/or death
resulting from a failure of the subject line.
36. As alleged herein, Decedent Owen Goldsmith lost his life, and Plaintiffs suffered
injury and damage as a result of Defendants' ultra-hazardous activity.
37. The ultra-hazardous activity of Defendants, and each of them, was a substantial
factor in causing the injury and damage suffered by Plaintiffs.
3 8. As a direct, legal and proximate result of the incident described in the preceding
paragraphs, and the death of Decedent Owen Goldsmith, Plaintiffs have sustained a loss of love,
companionship, comfort, affection, society, solace, training and/or moral support. The injury and
damage suffered by Plaintiffs is of a kind to be expected as a result of ultra-hazardous activity.
VIII. THIRD CAUSE OF ACTION
(Survival Action Pursuant to C.C.P. § 377.20, et seq. & Punitive Damages)
39. Plaintiffs hereby reallege and incorporate by reference each and every allegation
contained above as though the same were set forth herein in full.
40. As a direct result of the above-described incident and the failures of Defendants,
and each of them, Decedent Owen Goldsmith suffered damage to his real and personal property.
Additionally, Mr. Goldsmith lived for a period of time after being initially injured and he
10
COMPLAINT
suffered injury and damages prior to his death. The Decedent sustained said damages in an
2 amount according to proof. Plaintiffs Stephanie Mathes and Karen Goldsmith are Decedent's
3 children and the successors in interest to Decedent, and Plaintiff Stephanie Mathes seeks to have
4 the court appoint her as representative of the Estate of Owen Goldsmith, for the purposes of
5 bringing an action under C.C.P. § 377.30 for any and all damages suffered by Owen Goldsmith
6 prior to his death for, including but not limited to, damage to his real and personal property, and
7 his land and vegetation, as well as punitive damages. Decedent Owen Goldsmith would have
8 been entitled to recover any such damages under the causes of action for, inter alia, inverse
9 condemnation, negligence, negligence per se, and violations of statute and regulations.
IO 41. The actions of these Defendants did in fact result in the death of Owen Goldsmith.
11 Defendants, and each of them, failed to properly inspect, operate, and maintain the subject
12 overhead power line. Defendants, and each of them, knew that in light of the surrounding
13 drought conditions, including, but not limited to, tinder~like vegetation, that in the event that the
14 vegetation came in contact with the power lines a fire was the likely result. Defendants, and each
15 of them, further knew that a resulting fire was likely to pose a risk of serious injury or death to
16 the general public, including the Decedent.
17 42. As detailed in§ IV, supra, PG&E's safety record is inexcusably dire. PG&E has
18 had several other incidents that caused injury and death to California residents, and destroyed
19 properties, and has been subject to numerous penalties, including, but not limited to record fines
20 following the San Bruno Explosion, as a result of their failure to comply with safety standards,
21 rules and regulations. Despite these fines and punishments, Defendants have failed to modify
22 their behavior, continuing their practice of placing their own profits over safety and conducting
23 their business with a conscious disregard for the safety and well-being of the public and property.
24 As a result, in August of this year, the California Public Utilities Commission voted unanimously
25 for an investigation into the corporate culture of PG&E to determine if PG&E's representations
26 that safety was its priority matches PG&E's long-term practices.
27 43. Plaintiffa are informed and believe that the Butte Fire was the result of PG&E's
28 continued practice of prioritizing profits over safety, wherein they failed to properly maintain and
11
COMPLAlNT
inspect their power lines, and the surrounding vegetation, knowing that the likely result was a fire
2 that would pose risk of serious injury and/or death, and damage to property. Even following the
3 fire, PG&E continues to fail in its obligations to the victims of the Butte Fire, cutting down trees
4 that it claims are fire damaged and letting those trees fall and remain in the toxic ash from the
5 fire, entering residents' property without permission, leaving trunks and trimmings on residents'
6 property, closing roads to perform work without any notice, and failing and refusing to
7 coordinate with the governmental agencies responsible for the clean up of the disaster.
8 44. At all times prior to the subject incident, the conduct of Defendants, by act and/or
9 omission, demonstrated a wanton and/or reckless indifference for the required maintenance of
10 PG&E' s electrical infrastructure and the surrounding vegetation, as well as a conscious disregard
11 for and a foreseeable risk of serious injury and death of others, including Owen Goldsmith. The
12 wrongful conduct of Defendants was more than just inadvertence, error of judgment or
13 negligence. Rather, Defendants conduct was despicable and showed malice as defined by Civil
14 Code§ 3294. The state has an extremely strong interest in imposing sufficiently high punitive
15 damages in actions where the malicious conduct of the defendants leads to the wrongful death of
16 one of its citizens. As a result, Plaintiffs request that the trier of fact, in the exercise of sound
17 discretion of the rights and safety of others, such that additional damages for the sake of example
18 and sufficient to punish said Defendants for their despicable conduct, in an amount reasonably
19 related to Plaintiffs' actual damages and Defendants' wealth, yet sufficiently large enough to be
20 an example to others and to deter Defendants and others from engaging in similar conduct in the
21 future.
22 IX. PRAYER FOR RELIEF
23 WHEREFORE, Plaintiffs pray judgment against Defendants, and each of them, as
24 follows:
25
26
27
28
a.
b.
c.
For general damages in an amount according to proof;
For special damages in an amount according to proof;
For the pecuniary value of the loss of companionship, comfort, affection, society,
care, solace and/or moral support;
12
COMPLAJNT
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
28
d.
e.
f.
g.
h.
For treble or double damages for wrongful injuries to timber, trees, or underwood,
as aliowed under California Civil Code 3346;
For punitive and exemplary damages in an amount according to proof under
California Public Utilities Code § 2106, and as otherwise allowed by law;
For prejudgment interest;
For attorneys fees, expert fees, and consultant fees as allowed by law and Code of
Civil Procedure 1021.9, and costs of suit herein incurred; and
For such other and further relief as the Court may deem appropriate.
Dated: October 26, 2015
COREY, LUZAICtl.z DE GHETALDI, NAST ARI & RIDDLE LLP /
/
I
By:~---A AN.. LE, ESQ., Attorneys for Plaintiffs Stephanie Mathes and Karen Goldsmith
13
COMPLAINT
