OA SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Document Scanning Lead Sheet Sep-15-2018 2:37 pm Case Number: CGC-15-547949 Filing Date: Sep-15-2015 2:34 Filed by: DENNIS TOYAMA Juke Box: 001 Image: 05076007 COMPLAINT BOGDAN PETRESCU VS. UBER TECHNOLOGIES, INC. ET AL 001C05076007 Instructions: Please place this sheet on top of the document to be scanned.Ree eo el Christopher B. Dolan (SBN 165358) F [ L.ED Jeremy M. Jessup (SBN 208758) Syphon he THE DOLAN LAW FIRM ‘Sotmny San Panesea 1438 Market Street San Francisco, California 94102 SEP 15 2015 Telephone: (415) 421-2800 CLERK OF T} Ct Facsimile: (415) 421-2830 cc DENN SAMA, eM Attomeys for Plaintiff Bogdan Petrescu IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN FRANCISCO UNLIMITED JURISDICTION BOGDAN PETRESCU CaseNo. CGC+15 547949 Plaintiffs, COMPLAINT FOR DAMAGES. Vv. 1. NEGLIGENCE - MOTOR VEHICLE UBER TECHNOLOGIES, INC., RASIER 2, NEGLIGENT ENTRUSTMENT LLC, RASIER-CA LLC, NIMA RAI, and 3. NEGLIGENCE PER SE DOES 1-30, 4. NEGLIGENT HIRING RETENTION AND SUPERVISION Defendants. DEMAND FOR JURY TRIAL PARTIES 1. Plaintiff BOGDAN PETRESCU is an adult male who presently resides in San Francisco, California. 2. Defendant UBER TECHNOLOGIES, INC. (hereinafter “UBER”) is a Delaware (Corporation and or Does 1-10 are corporations and/or business entities of a form unknown, which run a Transportation Network Company (TNC) known as UBER which provide a number of transportation options and vehicles for users of their service, including a low cost ae COMPLAINT FOR DAMAGES AND DEMAND FOR TRIAL BY JURYES eo eo) option called Uber X, through an online-enabled application (hereinafter “APP”). UBER has its principal place of business in and conducts business in San Francisco, California. 3. Plaintiffs are informed and believe and on the basis of said information and belief allege ‘that RASIER LLC is a Delaware Limited Liability Company which is a wholly owned subsidiary of UBER and the parent company of RASIER-CA LLC, a Delaware Limited Liability Company. RASIER LLC & RASIER-CA LLC have their principal place of business in and conducts business in San Francisco, California, Defendants are in the business of| transporting passengers and are common carriers who owed Plaintiff PETRESCU the highest duty of care and vigilance of a very cautious person, 4. UBER and DOES 1-10, use RASIER LLC and/or RASIER-CA LLC and/or Does 21-30 to operate a TRANSPORTATION NETWORK COMPANY (TNC) known as Uber X, a division of UBER and/or Does 1-10 and 21-30’s commercial enterprise. Defendants are in the [business of transporting passengers and are common carriers who owed Plaintiff PETRESCU the highest duty of care and vigilance of a very cautious person. 5. Plaintiffs are informed and believe, and on the basis of information and belief allege that RASIER-CA LLC has been assigned Carrier ID PSG0032512 by the PUC and that UBER, RASIER LLC and/or RASIER-CA LLC and/or Does 1-10 and 21-30 use Carrier ID PSG0032512 to operate its TNC, Uber X in California. 6. Plaintiffs are informed and believe, and on the basis of information and belief allege that RASIER-CA LLC is the insurance certificate holder for the insurance that UBER is required to carry as a TNC by the PUC, which it uses for its Uber X operations. 7. Defendant NIMA RAI (hereinafter “Defendant RAI”) is an adult natural person who Plaintiff is informed and believes and thereby alleges is a resident of the state of California, and is therefore subject to the jurisdiction of this Court. 8. On April 15, 2015, Defendant RAI was the driver of the vehicle which injured BOGDAN PETRESCU. Defendant is in the business of transporting passengers and is a common carrier who owed Plaintiff PETRESCU the highest duty of care and vigilance of a very cautious person. oa ‘COMPLAINT FOR DAMAGES AND DEMAND FOR TRIAL BY JURYOro te) 9. Plaintiff is informed and believe, and the basis of said information and belief, allege, that on April 15, 2015, at the time of this collision, Defendant RAI was a driver/transportation provider who was operating his vehicle utilizing the UBER APP and as such was an agent and/or employee and/or partner of UBER, and/or RASIER LLC and/or RAISER-CA LLC and/or Does 1-10 and/or Does 21-30. 10, Plaintiff is informed and believe, and the basis of said information and belief, allege, at all times material to this complaint, UBER and/or RASIER LLC and/or RAISER-CA LLC and/or Does 1-10 and/or Does 21-30 were the employer of Defendant RAI, and/or his partner and/or an agency relationship existed between them. 11. Does 11-20 are believed to be the owners of the vehicle driven by RAI at the time of the collision. 12. Plaintiff is ignorant of the names of the Defendants sued herein as DOES 1 through 30, inclusive, and therefore sues these Defendants by such fictitious names. Plaintiff will amend this complaint to allege their true names and capacities when ascertained. Plaintiff is informed and believes and thereon alleges that each of said fictitiously named Defendants is responsible in some manner for the occurrences herein alleged, and that Plaintiff's injuries herein alleged were caused by the aforementioned Defendants. 13. Plaintiff is informed and believes, and on the basis of said information and belief alleges, that at all times herein material to this matters alleged in this Complaint, each of the Defendants was the agent and/or employee and/or partner of each of the remaining Defendants and, in doing the things herein alleged, was acting within the course and scope of such agency and/or employment, and/or aided and/or abetted the others and/or ratified the acts of the others 0 as to make them liable for the Plaintiff's damages. 14, Plaintiff is informed and believes, and on the basis of said information and belief alleges, that there is a unity of interest and operation between UBER, RAISER LLC, RAISER- CA LLC and Does 1-10 and 21-30 such that their separate and independent classification is but a fiction and that each is the alter-ego of the other. 3s ‘COMPLAINT FOR DAMAGES AND DEMAND FOR TRIAL BY JURYScwmrxrsuneun 15, Defendants are liable for the acts of each other through principals of respondeat superior, agency, ostensible agency, partnership, alter-ego and other forms of vicarious liability. VENUE AND JURISDICTION, 16. Venue in this court is appropriate as at least one Defendant is a resident and/or has its principal place of business in and conducts business in San Francisco County. 17. Jurisdiction is proper in this case in that the amount in controversy is in excess of the statutory requirements of this court. FACTS COMMON TO ALL CAUSES OF ACTION 18. On April 15, 2015, at around 5:30pm, BOGDAN PETRESCU, an Uber X patron, was picked up in a 4 door Nissan sedan, license plate number 7ESS218, driven by Defendant NIMA RAL, California Driver's License number D9048270, which he summoned through the use of his Uber App. 19. BOGDAN PETRESCU and a colleague of his were being taken to the SFO by NIMA RAL, 20. As they traveled southbound on 101, near Grand Avenue the vehicle began drifting across the lanes of traffic. At that point BOGDAN PETRESCU looked to Defendant NIMA. RAI and saw that his hands were off the wheel and he was slumped backwards in his seat with his eyes fixed and gazing nowhere. The driver was unresponsive to the men’s attempts to get his attention as the car drove into the back of a large moving truck. 21. The collision caused serious and significant physical and mental injuries to Plaintiff. 22, Following the subject accident, Defendant NIMA RAI admitted to Plaintiff that he had blacked out and had a “head problem”. Defendant NIMA RAI also communicated that he had a seizure disorder. 23. UBER, RAISER LLC, RAISER-CA LLC and Does 1-10 and 21-30 and their Uber X service have been classified by the California Public Utilities Commission (hereinafter “PUC”) asa TNC. 24. Defendants, and each of them, are common carriers who owed Plaintiff PETRESCU the highest duty of care and vigilance of a very cautious person. The PUC has found that, “clearly, 74 ‘COMPLAINT FOR DAMAGES AND DEMAND FOR TRIAL BY JURYBee fo oy el each TNC is receiving either an economic benefit or a business benefit. At a minimum, they are receiving increased patronage with the growth of their businesses.” 25. UBER, RAISER LLC, RAISER-CA LLC and Does 1-10 and 21-30, through its services, including Uber X, provides prearranged transportation services for compensation using its APP or platform to connect persons wanting to procure transportation (hereinafter “USERS"), with those who, utilizing their own personal vehicles, want to provide transportation ion exchange for compensation (hereinafter “DRIVERS”). 26. Plaintiffs are informed and believe, and on the basis of said information and belief allege, that Defendant NIMA RAI was logged on to the UBER APP at the time that the collision occurred and was appearing as a UBER and/or Uber X DRIVER available for providing ‘transportation services to USERS and/or was viewing, monitoring and/or interacting with his wireless communications device/smartphone/GPS at or near the time of the collision. 27. Before USERS can utilize the APP, USERS must become “partners” of UBER, UBER, RAISER LLC, RAISER-CA LLC and Does 1-10 and 21-30 by logging into UBER’s APP or ‘web based portal and provide information about themselves to UBER including their name, e- ‘mail, credit card number, mobile telephone number, etc. Only registered USERS can use UBER’s APP to prearrange transportation service. 28. Before DRIVERS can participate in UBER’S, RASIER LLC’S, RAISER-CA LLC’S and Does 1-10 and 21-30’s prearranged transportation service, including but not limited to Uber X, they must apply to be a DRIVER by logging into UBER’s APP or web based portal and providing information including but not limited to their name, phone number, address, e-mail, ‘banking information, vehicle registration, insurance, vehicle description, and have their vehicle inspected. UBER, RASIER LLC and RAISER-CA LLC and Does 1-10 and 21-30 are required to conduct a background investigation of their DRIVERS including but not limited to theit driving and criminal history (and thereafter conduct periodic reviews of their driving history). UBER, RASIER LLC and RAISER-CA LLC and Does 1-10 and 21-30 then evaluate the driver and only permit those drivers it finds suitable to become registered DRIVERS on its APP. UBER, RASIER LLC and RAISER-CA LLC and Does 1-10 and 21-30 reserve the right to ar COMPLAINT FOR DAMAGES AND DEMAND FOR TRIAL BY JURYSiocon at remove or delete DRIVERS from their system at their discretion. Therefore UBER, RASIER LLC and RAISER-CA LLC and Does 1-10 and 21-30 are entirely in control of who can use their system as either a DRIVER or USER. They represent that they fully screen their employees and they are the safest in the industry, 29. Defendants UBER, RASIER LLC and RAISER-CA LLC and Does 1-10 and 21-30, represent to the public, such as Plaintiff PETRESCU that they fully screen their employees and conduct background check into medical conditions, and based upon information and belief, failed to check to determine if Defendant RAI was medically sound to operate a motor vehicle 30. Only after USERS and DRIVERS have provided the information required by UBER, RASIER LLC and RAISER-CA LLC and Does 1-10 and 21-30 can they participate in the pre~ arranged transportation service. 31. USERS secking transportation services provided by UBER, RASIER LLC and RAISER-CA LLC and Does 1-10 and 21-30, such as Uber x and its DRIVERS, log on to the APP which is under the URL, www-uber.com, and arrive at a main screen that says UBER. From that main screen they can navigate among different types of transportation services (generally distinguished by type of vehicle) including Uber X which is touted as “the low cost UBER.” 32. DRIVERS, in order to be available to provide USERS transportation services in exchange for compensation, must log on to the UBER and/or Uber X APP and indicate their availability. Their location and information is then visible to USERS and DRIVERS can access a screen on their electronic communication device/smart phone/GPS called a “God View” which shows them a map of where others using the system are located. 33. Plaintiff is informed and believe, and on the basis of said information and belief alleges that the status of Defendant NIMA RAI as an UBER and/or Uber X DRIVER, including but not limited to the failure properly screen for health issues, was a proximate cause of this collision including but not limited to its causing Defendant NIMA RAI to drive for UBER, despite not being medically cleared to. MW Tes (COMPLAINT FOR DAMAGES AND DEMAND FOR TRIAL BY JURYFIRST CAUSE OF ACTION ‘Negligence ~Motor Vehicle By Plaintiff Against All Defendants 34, Plaintiffs incorporate by reference, as though fully set forth herein, the contents of Paragraphs 1 through 33. 35. Defendants and each of them owed Plaintiff a duty of reasonable/due care as well as statutory duties established in California Vehicle Codes, 21703, 22350, and/or 22107. 36. Defendant NIMA RAI, on April 15, 2015, while operating his vehicle in the scope and course of his employment/agency/partnership with UBER, and/or RASIER LLC and/or RAISER-CA LLC and/or Does 1-10 and 21-30, was negligent and did breach one or more of those duties and said breach was the proximate cause of personal injuries to Plaintiff BOGDAN PETRESCU. 37. As a proximate result the negligence of Defendants, and each of them, Plaintiff has suffered significant general and special damages in amounts to be determined at trial, 38. The conduct of the Defendants and each of them was engaged in with fraud, oppression and/or malice, and was in conscious disregard of the rights and safety of others, including but ‘not limited to the Plaintiffs herein so as to warrant the imposition of punitive damages pursuant to California Civil Code Section 3294 SECOND CAUSE OF ACTION Negligent Entrustment By Plaintiff Defendants UBER, RASIER LLC and RAISER-CA LLC and Does 1-10 and 21-30 39. Plaintiffs incorporate by reference, as though fully set forth herein, the contents of Paragraphs 1 through 38. 40. Defendants UBER, RASIER LLC and RAISER-CA LLC and Does 1-10 and 21-30, and ‘each of them, had a duty to exercise reasonable care for the safety of others, such as Plaintiff, a Passenger in their employee's vehicle, when entrusting Defendants’ vehicles to employees. 41. Plaintiff is informed and believes, and thereupon alleges, that Defendants knew, or should have known, that Defendant RAI was unfit to be driving a vehicle due to, but not limited TT COMPLAINT FOR DAMAGES AND DEMAND FOR TRIAL BY JURYa 3 4 5 6 7 8 9 0 to, Defendant RAI’s then existing head injury and/or seizure disorder on or around the time of the accident. 42. Plaintiff is informed and believes, and thereupon alleges, that Defendants knew, or should have known, that, given Defendant RAI’s medical condition, Defendant RAI was unfit to be driving a vehicle. 43. Plaintiff is informed and believes, and thereupon alleges, that Defendant RAI, in the course and scope of his employment with Defendants UBER, RASIER LLC and RAISER-CA LLC and Does 1-10 and 21-30, negligently operated a vehicle, losing consciousness and control of the vehicle, striking at least one other vehicle causing Plaintiff's injuries and damages. 44, Defendants UBER, RASIER LLC and RAISER-CA LLC and Does 1-10 and 21-30 breached this duty of care by providing and entrusting a vehicle to Defendant RAI. 45. As a direct and proximate result of Defendants negligent acts and/or omissions, Plaintiff suffered injuries and damages. THIRD CAUSE OF ACTION Negligence Per Se By Plaintiff Against ALL DEFENDANTS 46. Plaintiffs hereby incorporate by reference, as though fully set forth herein, the contents of Paragraphs 1-45. 47. California Vehicle Codes, 21703, 22350, and/or 22107, were laws implemented by the State of California to protect individuals from injury or death due to inattentive or distracted drivers. Plaintiffs and each of them were of the class of persons intended to be protected by these laws. 48. Defendants and each of them therefore owed Plaintiffs a duty to conduct their affairs in accordance with California Vehicle Codes, 21703, 22350, and/or 22107. 49. Defendants and each of them breached one or more of the duties established by California Vehicle Codes, 21703, 22350, and/or 22107. Such conduct constitutes negligence per se. Tee ‘COMPLAINT FOR DAMAGES AND DEMAND FOR TRIAL BY JURY50. Asa direct and proximate result, Plaintiffs, and each of them, suffered significant ‘general and special damages in an amount to be determined at trial 51. The conduct of the Defendants and each of them was engaged in with fraud, oppression. and/or malice, and was in conscious disregard of the rights and safety of others, including but not limited to the Plaintiffs herein so as to warrant the imposition of punitive damages pursuant to California Civil Code Section 3294. FOURTH CAUSE OF ACTION Negligent Hiring, Retention, Training and Supervision By all Plaintiff Against UBER, and/or RASIER LLC and/or RAISER-CA LLC and/or Does 1-10 and 21-30 52. Plaintiffs incorporate by reference as if fully set forth herein Paragraphs 1-51. 53. UBER, and/or RASIER LLC and/or RAISER-CA LLC and/or Does 1-10 and 21-30 jowed the general public a duty of reasonable care in the hiring, training and supervision of its DRIVERS. 54. UBER, and/or RASIER LLC and/or RAISER-CA LLC and/or Does 1-10 and 21-30 did breach that duty of care in the hiring, retention, training and/or supervision of Defendant NIMA RAI who was unfit to be a provider of transportation, and who was not adequately trained or supervised in his driving and/or use of the APP and the dangers inherent therein. UBER, and/or RASIER LLC and/or RAISER-CA LLC and/or Does 1-10 and 21-30 knew or should have known that Defendant NIMA RAI was not medically fit to be driving a vehicle and lead toa risk of the very type of danger and harm that occurred on April 15, 2015. 58. The breach of that duty was the proximate cause of harm to the Plaintiff causing him to suffer significant special and general damages in an amount to be proven at the time of trial. 56. The conduct of the Defendants and each of them was engaged in with fraud, oppression and/or malice, and was in conscious disregard of the rights and safety of others, including but not limited to the Plaintiff herein so as to warrant the imposition of punitive damages pursuant to California Civil Code Section 3294. dit <9 ‘COMPLAINT FOR DAMAGES AND DEMAND FOR TRIAL BY JURYeo PRAYER FOR RELIEF WHEREFORE, Plaintiff prays for judgment against Defendants, and each of them, asl follows: 1, All General Damages shown according to proof, 2. All Special Damages shown according to proof; 3. Attomey’s fees as the prescribed rate as available under the law; 4, For costs of suit herein incurred; and 5. All other relief as the Court may deem proper. Dated: September_I!_, 2015 Plaintiff hereby demands trial by jury. Dated: September_jj__, 2015 THE DOLAN LAW FIRM By: = Christepftef B Bolan Esq Attorney for Plaintiff BOGDAN PETRESCU By: = ee olati, Esq. Attorney fof Plaintiff BOGDAN PETRESCU, T0- (COMPLAINT FOR DAMAGES AND DEMAND FOR TRIAL BY JURYsuiffons e ‘SUM-100 (CITACION JUDICIAL) FoR COURT Use On.” (solo Pana USO Be LA CORTE) NOTICE TO DEFENDANT: UBER TECHNOLOGIES, INC., RASTER (AVISO AL DEMANDADO): LLC, RASIER-CA LLC, NIMA RAI and DOES 1-30 YOU ARE BEING SUED BY PLAINTIFF: BOGDAN PETRESCU (LO ESTA DEMANDANDO EL DEMANDANTE): ‘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 wtten response at this court and have @ copy ‘served on the plant. letter or phone cal wil not protect you. Your written response must bein proper legal frm if you want the cout to Rear your ‘case. There may be a court form that you can use for your response. You can find these court forms and more information atthe Calfomia Courts Gnline Sel Help Center (www. courtnlo.ca.gov/selelp), your count lw ibeary. or the courthouse nearest you. Ifyou cannot pay the fling feo, ask {he court clerk for 8 fee waiver form. I you do not fle your response on time, you may lose the case by default, and your wages, money, and property ‘may be taken without furthor warning from the court “There ae other legal requirements. You may want to call an atfomey right away. f you do not know an attomey, you may want to allan attomey foferal sevice. you cannot afford an attorney, you may be ebigble fr free legal services from a nonprofit legal services program. You can locale these nonprofit groups atthe California Legal Services Web site (wor Jewhelpcaliorna.org), the Calfornia Courts Online SeltHelp Center (jem courtinfe.ca. govisthelp, or by contacting you local cout or county bar association. NOTE: The cour has a statutory len for waived fees and ‘Costs on any settlement or arbivation award of $10,000 or more ina cv case. The court's lien must be paid before the count wil demise the case. JAVISO! Lo han demandado. Sino responde dentro de 30 des, la corte puede decidir en su contra sn escuchar su version. Lea fa informacion @ ontincacion Tlene 30 DIAS DE CALENDARIO después de que le entraguen esta citscién y papeleslegales para presentar una respuesta por escrito en esta corte y hacer que se entregue una copia al demandante. Una cara o una lamads (elefonica nolo protegen. Su respuesta por escrito ane que estar fen formato lega corecto si desea que procesen su caso en la carte. Es posible que haya un formulara que usted pueda Usar para su respuesto, Puede encontrar estos formularos de fe corte y més informacion en el Cento de Ayuda de las Cortes de Calfomia (www sucorte.ca.g0¥), en a bofeca de leyes de su condado 0 en la corte que le quede mas cerca. Si no puede pagar la cuota de presentecion, pid al secretorode fa corte ‘que fe dé un formulario de exencion de pago de cuotas. Sino presenta su respuesta a fempo, puede perder el caso por Incumplimlent Ta corte fe ‘Bosra qultar su sueide, dno y bienes sin mas advertneta, Hay atos requstos legales. Es recomendable que lame a un abogado inmediatamente. Sino conoce a un abogado, puede lamar @ un servicio de ‘emision a abogados. Sino puede pagar a un abogado, es posible que cumple con los requisites para obtaner servicios legates gratultos de un programa de servicios legals si fnes de lucre. Puede encontrar estes grupos sin fines de luco on a sito web de Callfomia Legal Services, (town lawhelpcalfomia.org), en of Centro de Ayuda de as Cortes de Caiforla, (www. sucorte.ca.gov) 0 poniéndose on contacto con la corte o @! Colegio de abogados locales. AVISO: Por ley, la corte tiene derecho a reciamar las cuotas y los Costas exentos por imponer un gravemen sobre ‘cualquier recuperacisn de $10,000 6 mas de valor recibida mediante un acuerdo o una concesion de arbiraje en un caso de derecho cil Tene que| agar el gravamen dela corte antes de quo la corte pueda desechar a caso. je name and address of the cour fs: sen (El nombre y creccion de fa corte): i Superior Court CGE-15 547949 400 McAllister San Francisco, CA 94102 ‘The name, address, and telephone number of plainti’s attorney, or plaintif without an attomey, is: (Ei nombre, la dreccién y el numero de teléfono del abogado de! demandante, o del demandante que no tiene abogado, 0s): Christopher B. Dolan (SBN_165358) Jeremy M. Jessup (SBN 208758) San Feanciseo, CA" 94102 CLERK OF THE COURT dy a “ (ocha) SEP 15 2015 es Deputy (Agjunto) (For proof of service ofthis summons, use Proof of Senvice of Summons (form POS-010)) (Para prueba de entroga de osta citation use o! formulario Proof of Service of Summons, (POS-010)). NOTICE TO THE PERSON SERVED: You are served 1. [_] as an individual defendant. 2. [] as the person sued under the fictitious name of (specify): 3. [J onbehat of (specity): under: [—] CCP 416.10 (corporation) (ce 416.60 (minor) [5 cep 416.20 (defunct corporation) [= cop 416.70 (conservates) [) CCP 416.40 (association or partnership) [—] CCP 416.90 (authorized person) [J other (specity): 4. (1) by personal delivery on (date): Page tot "faa Canale cater ‘SUMMONS odie Coie oa Pate 4427045 SUMO ew ay 2008)@ cM-o19 TATTORNEY OR PARTY WITHOUT ATTORNEY Wan, Sal Brea a, [christopher B. Dolan (SBN 165358) Jeremy M. Jessup (SBN 208758) The Dolan Law Firm 1438 Market Street San Francisco, CA 94102 FIL, ED inly Gt San Francisco sromeveonaen:_PLAintit “re SEP 15 2016 seen sounes 400 Manistee rancisco CLERK OF THE COURT, cmvmozecooe San Francisco, CA 94102 * Deputy Ge seweunuwe Civil Unlimited CASENAME: Petrescu v. Uber CIVIL CASE COVER SHEET Complex Case Designation ‘CASE NUMBER: (X] Untimited— [_]Limited (1 Counter [| Joinder = 47949 (amount, (Armount with frst appearance by defendant | ce emeneS 5,000) $52°800 Sr less) (Cal. Rules of Cour, rule 3.402) err, ‘lems 1-6 below must be completed (see instructions on page 2) [1 Check one box below for he case type that best describes this case: Other PUPDIWD (Personal InjuryProperty Damage/Wrongful Death) Tort Asbestos (04) Product abity 24) fedical malpractice (45) (3 other PuPOAWD (23) Non-PUPDAWD (Other) Tort (Jew rights (08) SJoctamaton 3) (J Fraud (16) [1 intettectual property (19) [J Protessional negligence (25) ther non PUPOMND to (25) Employment [La] Wrong termination (3) other empoyment (8) business tonvnfsr business pracce (07) ‘Auto Tort Contract Provisionally Complex Civil Litigation (to 22) [Breach ofcontractwarranty (06) (Cal. Rules of Court, rules 3400-2409) [J Uninsured motorist (46) [| Rule 3.740 collections (08) {5 Antitrust Trade regutation (03) [other collections (09) Insurance coverage (18) (Other contract (37) Real Property [J Eminent domainiinverse ‘condemnation (14) [1 Wrongful eviction (33) [J other real property (26) Uniawtu Detainee (commercial (31) [7 Residential (32) [| mugs (38) Judicial Review (| Asset forte (05) [= Petition re: arivation award (11) [| wait of mandate (02) [other judi rviw (29) (Construction defect (10) [= Mass tort (40) securities tigation (26) [= EnmvronmentaToxc tort (30) [insurance coverage claims arising from the above listed provisonaly complex case types (41) Enforcement of Judgment ]ntorcement of judgment (20) Miscellaneous Civil Complaint (J rtcoer [J other complaint (not specified above) (42) Miscellaneous Civil Pattion = Parmership and comorate governance (21) [J other petition (not specitied above) (43) 2. Thiscase [_] is [J isnot “complex under rule 3.400 of the Califomia Rules of Court. If the case is complex, mark the factors requiring exceptional judicial management Ce Large numberof separately represented parties _d, [—] Large numberof winesses », [— Edensive motion practice raising cffcu or novel_e, (Coordination with related actions pending in one or more courts issues that wl be Ume-consuming to resolve in other counties, states, or counties, rin a federal court «. (7) Substantial amount of documentary evidence. ("~] Substalal posjudgment jul supervision Remedies sought (check all that apply): a. [X_] monetary b. [__] nonmonetary; declaratory or injunctive relief c. [__) punitive ‘Number of causes of action (specify): See attachment . Thiscase [—) is [X] isnot aclass action suit. If there are any known related cases, fle and serve a notice of or case. (You may use form CM-015,) NOTICE Jeremy M, Jessup TRPEORPNT RARE + Plaintif 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 Cour, rule 3.220.) Failure to flo may result in sanctions. * File this cover sheet in addition to any cover sheet required by local court rule. «+ If this case is complex under rule 3.400 et seq. ofthe California Rules of Court, you must serve a copy of this cover sheet on all ‘other parties to the action or proceeding * Unless ths is a collections case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes only fem coves carena ‘Batotten he 38o a CIVIL CASE COVER SHEET, Gat Res art ls 8 TO RAtR 978PETITIONERPLANTIFE, Bogdan Petrescu RESPONDENTIDEFENDANT: Uber Technologies, Inc., Rasier LLC, 1.NEGLIGENCE - MOTOR VEHICLE 2.NEGLIGENT ENTRUSTMENT 3.NEGLIGENCE PER SE 4.NEGLIGENT HIRING RETENTION AND SUPERVISION