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Steven J. Eyre, CB# 119714
3550 Wilshire Boulevard, Suite 1440
Los Angeles, California 90010
(213)385-6926
fax (213) 385-3313
stevenjeyre@gmai1. com
Attorney for Plaintiff
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UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
321 North Spring Street, Los Angeles, CA 90012
IGNACIO OROZCO,
Plaintiff,
-vs.-
JUAN MANUEL NAVARRO, JOSE
DIOSDADO, DOES 1-10,
Defendants.
Orozco vs. Navarro
LACV14-8188?A(M\m^)
No.
COMPLAINT FOR:
2.
3.
5.
6.
FEDERAL TRADEMARK
INFRINGEMENT AND UNFAIR
COMPETITION;
COMMERCIAL DISPARAGEMENT;
STATE LAW AND STATUTORY
TRADE NAME INFRINGEMENT
AND DILUTION;
INTERFERENCE WITH
PROSPECTIVE BUSINESS
ADVANTAGE;
ACCOUNTING;
TEMPORARY, PRELIMINARY AND
PERMANENT INJUNCTIVE
RELIEF
JURY TRIAL DEMANDED
i
111
Qio i :- "" '< ;t Court
COIR;. ii..:2 _^
COMPLAINT
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B^3 Q
JURISDICTION AND VENUE
tfo; 1. These claims arise under
the federal Trademark Act, as amended, 15
17200 andCalifornia statutory andcommoiji
1331 and 1138(a). Jurisdiction is also proper
jurisdiction as provided in 28 U.S.C. 136
2. This Court has specific
each has purposefully committed, within
and/or has committed tortious acts outside
would cause injury within the state.
3. Venue is proper in the United
pursuant to 28 U.S. C. 1391(b) and 1391(
District, transact affairs in this District and
giving rise to the claims herein occurred wi
THE
4.
laws of the United States, particularly under
U.S.C. 1051 etseq., Cal. Bus. & Prof. Code
law. Jurisdiction is proper under 28 U.S.C.
pursuant to the Court's supplemental
pen onal jurisdiction over all of the defendants as
state, the acts from which these claims arise
California, knowing and intending that such acts
th;
Plaintiff Ignacio Orozco is
extensively throughout the United States
5. Defendant Juan Manuel
Defendant Navarro is a dance promoter and
6. Defendant Jose Diosdado is
7. The true names of the
presently unknown to plaintiff, who therefolre
Plaintiff will seek to amend this complaint
he has ascertained such information. Plaintiff
named herein as Does 1 through 10 has
alleged in this Complaint and is liable to
8. Plaintiff is informed and be
musicians who perform with the musical g:
States District Court for the Central District
c) in that some defendants reside in this
hat a substantial part of the events or omissions
hin this District.
PARTIES
resident and national of Mexico who performs
his musical group VIENTO Y SOL.
resides in Los Angeles County, California,
representative of one or more musical groups,
a resident of the state of Iowa.
named herein as Does 1 through 10 are
sues said defendants by such fictitious names,
allege the true names of said defendants when
is informed and believe that each defendant
in some or all of the acts or conduct
by reason thereof,
ieve that defendants DOES 1-5 are individual
of defendant Jose Diosdado.
with
Na /arro
defer dants
10
par icipated
Plaintiff
roup
Orozco vs. Navarro COMPLAINT
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GENERAL ALLEGATIONS
9. Plaintiff Ignacio Orozco
early 1980's in Irapuato, Mexico. In that
services under the name VIENTO Y SOL i
group, plaintiff has continuously used the
with the live performances of his musical g
group, on television and radio, and in sound
10. At least as early as 1992
group to the United States to perform. S
continuously used the name and mark
connection with the live performances of hjs
performances of the group, on television
11. Plaintiff is the owner of the
the United States Patent and Trademark
entertainment in the nature of live
with a registration date of May 6, 2014.
12. Defendant Jose Diosdado i
who left the group in or about 1999
his departure.
13. Plaintiff alleges on
recentlyformedhis own musical group usih
used for the past thirty (30) years.
14. Defendant Jose Diosdado
DIOSDADO Y SU VIENTO Y SOL" in tl
services as plaintiff. As of August 4, 2014
USPTO.
15. In spite of the refusal by
mark, plaintiff is informed and believes
Orozco vs. Navarro
year,
n
name
foinded the musical group VIENTO Y SOL in the
, plaintiffs group began to perform artistic
Mexico. Since the inception of the musical
and mark VIENTO Y SOL in connection
;j-oup, inadvertising for the performances ofthe
recordings of the group.
p|aintiffIgnacio Orozco brought his musical
incfe that time, plaintiff Ignacio Orozco has
VIEKTO Y SOL in commerce in the United States in
musical group, in advertising for the
radio, and in sound recordings of the group,
registration of the VIENTO Y SOL mark with
Office ("USPTO") in International Class 41 for
performances by a musical band, Reg. No. 4,524,385,
ard
i$ a former member of plaintiff s musical group
Defendant Diosdado did not return to the group after
information and belief that defendant Jose Diosdado
g the "Viento y Sol" moniker that plaintiff has
Has applied to register the mark"JOSE
e same international class and for the same
defendant's application was refused by the
the
th.t
USPTO to register defendant Jose Diosdado's
defendant has used a printout of the
COMPLAINT
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informational page relating tohis application
to mislead others into believing that he has
and is thus entitled to use the mark VIENTp
advertising for its services.
16. Defendant Juan Manuel
musical groups, particularly inthe Regionajl
and elsewhere. Defendant Navarro has
with dubious or noright to the use of name|s
names of well-known groups, and passing
musical groups, promoters and members o
17. Defendant Juan Manuel
Grandes de America" ("The Seven Great
Auditorium in Wilmington, California on
musical groups being advertised are "pirat<|:
of the rightful owners of the actual group,
group" beingadvertised is "Diosdado y su
18. Plaintiff is informed and
owners to whom defendants Navarro,
pirate group arewell aware that defendant
"Viento y Sol," but have conspiredto
group as "Viento y Sol," using defendants
"Vientoy Sol" as justificationfor their
19. Plaintiff is informed and b
defendant Navarro, have caused print and
public in a calculated effort to mislead the
"no-name" pirate group by holdingthe pi
SOL. The only ones who profit from this
their cohorts as the sellers of the pirate grdup
, which shows that the application is still alive,
a registration for the mark in the United States
Y SOL in connection with his group and the
Navarro is a promoter and representative of
Mexican music market of Southern California
e a career of promotingpirate groups, i.e. those
that are confusingly similar or identical to the
hem off to the public, wreaking havoc amongst
the public.
is the promoter and owner of the "Los 7
of America") event at the Longshoreman
October 25, 2014, inwhich at least two of the
groups" that are usurping the registered marks
Withrespect to the instant lawsuit, the "pirate
VIENTO Y SOL."
ieve that the unscrupulous promoters and
and their cohorts sell the services of the
s pirategroup is not plaintiffs musical group
the public by advertising defendant's pirate
false claims of having "registered" the name
g and deceptive practices.
;lieves that nightclub owners, including
ather forms of advertising to be placed before the
public into attending the performances of the
group out as plaintiffs group VIENTO Y
deception are defendants Navarro, Diosdado and
Ni.varro
Ones
b:l
Dios dado
mislsad
misleading
pirate
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Orozco vs. Navarro
COMPLAINT
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^m
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irreparat 20. Meanwhile, plaintiff is i
their deceptions upon an unsuspecting
pay to see plaintiffs musical group are dis^]
VIENTO Y SOL but instead defendant's
as trusting next time a performance by
plaintiffs reputation, earning ability and
21. Defendants canbeexpecteji
order to benefit from the confusion they
activities.
FIRST CLA
bly harmedeach time defendants practice
customers who believe the advertising and
ppointed to find that the group performing is not
group. Suchcustomers are less likely to be
plaihtiff s group is advertised. The damage to
bottom line is incalculable; the harm is irreparable,
to continue the above deceptive practices in
causing unless enjoined from such deceptive
(FEDERAL
UNFAIR
22. Plaintiff realleges and incorporates
paragraphs of this complaint.
23. This claim for relief arises
against all defendants.
24. Plaintiff is the senior user
VIENTO Y SOL and is owner of the regis
above. Continuously since the introductioh
early as 1992, plaintiffhas usedthe mark'
the services of his musical group as perfoifnm
inherently distinctive.
25. None of the defendants nafaed
utilize the name VIENTO Y SOL. Defendant
ago, thus abandoning the group and any
sought to rejoin the group since that time
26. Defendants are using plaintiff
confusion as to plaintiffs association wit!
Orozco vs. Navarro
public
p rate
are
M FOR RELIEF
TRADEMARK INFRINGEMENT AND
COMPETITION)
in this cause of action all previous
under 15U.S.C. 1125(a)(1)(A) and is alleged
ind owner of the trade name and service mark
ration of the mark with the USPTO, as alleged
of the group in the United States at least as
/IENTO Y SOL in commerce in connection with
g andrecording artists. Plaintiffs mark is
claim
herein have any claim or colorable right to
Jose Diosdado left the group some 15 years
to use of the group's name, and has never
s mark in a way that is likely to cause
, affiliation with, or sponsorship of the
COMPLAINT
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0
performance of defendants' musical group
actual confusion by promoters and consumers
27. Defendants' actions
43(a) of the Lanham Act, 15 U.S.C. 1125|(
28. The actions of defendants,
damage to plaintiffs reputation and mark.
29. The actions of defendants
intended to cause confusion, have caused
unless enjoined.
30. For eachact of unfair competition
damages as well as defendants' profits from
31. Plaintiff is entitled to treble
U.S.C. 11117.
32. Plaintiff is informed and bejlieves
of herein were undertaken willfully and
or deception.
33. Monetary relief alone is no
injury that defendants' illegal actions have
defendants' actions are not enjoined
permanent injunctive relief to stopdefendants
SECOND CLAIM
9
Defendants' actions have led to instances of
constitute unfair competition in violation of section
a).
;is alleged herein, have cause substantial
a|nd each of them as herein alleged were and are
cpnfusion, and will continue to cause confusion
ition, plaintiff is entitled to recover actual
such infringement,
damages and prejudgment interest under 15
wih
that the acts of defendants complained
the intention of causing confusion, mistake
t adequate to address fully the irreparable
caused and will continue to cause plaintiff if
Plairjtiff therefore is also entitled topreliminary and
' ongoing acts of unfair competition.
FOR RELIEF
(COMMERCIAL
34. Plaintiff realleges and incc
paragraphs of this complaint.
35. This claim for reliefarises |under 15 U.S.C. 1125(a)(1)(B) andis alleged
against all defendants.
DISPARAGEMENT)
otporates in this cause of actionall previous
Orozco vs. Navarro
COMPLAINT
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36. Defendants and their cohorts
others, have misrepresented the nature,
manner that has caused, and is likely to
37. In engaging in the actions
them willfully intended and continue to i
38. In engaging in the actions
them have willfully intended to cause dilut
39. For each act of unfair
damages as well as defendants' profits frorh
40. Plaintiff is entitled to trebk
U.S.C. H1117.
41. Plaintiff is informed and
of herein were undertaken willfully and intlen
42. Monetary relief alone is nc
injurythat defendants' illegal actions have
not enjoined. Plaintiff therefore is also
relief to stop defendants' ongoing unfair
THIRD CLAIM
;s, in connection with nightclub owners and
characteristics and qualities of the pirate group in a
continue to cause, damage to plaintiff.
complained of above, defendants and each of
intend totrade on plaintiffs reputation,
complained of above, defendants and each of
on of plaintiff s famous mark,
competition, plaintiff is entitled to recover actual
such infringement,
damages and prejudgment interest under 15
believes that the acts of defendants complained
tionally by defendants,
adequate to address fully the irreparable
caused and will continue to cause plaintiff if
entitled to preliminary and permanent injunctive
competition.
FOR RELIEF
(STATE LAW COMMON LAW
INFRINGEMENT
43. Plaintiff realleges and in
paragraphs of this complaint.
44. This claim for relief arises
alleged against all defendants.
45. Bytheir acts alleged hereiiji
infringement and dilution, California Bus
seq.
AND STATUTORY TRADE NAME
AND DILUTION)
corporate in this cause of action all previous
under the laws of the State of California and is
, defendants have engaged in trade name
& Prof. Code 14330 et seq., and 14402 et
Orozco vs. Navarro
COMPLAINT
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|ft
46. Defendants have
their services are connected with plaintiff
47. Plaintiff is informed and
herein were undertaken willfully and with
deception.
48. Monetary relief alone is
injury that defendants' illegal actions have
defendants' conduct is not enjoined,
permanent injunctiverelief to stop
FOURTH
(INTERFERENCE WITH
49. Plaintiff realleges and inc
paragraphs of this complaint.
50. This claim for relief arises
and is alleged against all defendants.
51. Defendants and each of thim
prospective business advantage of plaintif
exploit andbenefit commercially from the
goodwill of the business of plaintiffs
52. Plaintiff has been damage
each of them with plaintiffs economic
to this complaint.
53. The aforementioned acts
malicious. Plaintiff therefore should be
alleged by amendment to this complaint
Orozco vs. Navarro
o
intentionally deceived the public by misrepresenting that
musical group,
bdlieves that the acts of defendants described
ihe intention of causing confusion, mistake or
no|t adequate to address fully the irreparable
caused and will continue to cause plaintiff if
Plaintiff therefore is also entitled to preliminary and
defendants' ongoing acts of unfair competition.
CLAIM FOR RELIEF
PROSPECTIVE BUSINESS ADVANTAGE)
orporates in this cause of actionall previous
under the common law of the State of California
through their actions, have interfered withthe
by interfering withthe right of plaintiffto
trade name and mark VIENTO Y SOL and the
musical group,
bythe tortious interference bydefendants and
relations in an amount to be alleged by amendment
led
o|f defendants were and are willful, oppressive and
awarded punitive damages in an amount to be
COMPLAINT
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FIFTH CLAIM FDR RELIEF
(ACCOUNTING)
54. Plaintiffreallegesandin
paragraphs of this complaint.
55. This claim for relief arises
and is alleged against all defendants.
56. Defendants are in possession
defendants from their misleading and
represents a misappropriation of monies
ledgers, etc. which will provide this inforrr
eachofthem. The amount of damages
defendants cannot be ascertained without
57. Defendants and each of
usurpation of the trade name andservice
plaintiff for the income and profits realized
such activities.
58. Plaintiff hereby demands,
received by defendants and eachof themf
VIENTO Y SOL and any other confusing
SEVENTH
co:porates in this cause of action all previous
ander the common law of the State of California
of information relating to monies paid to
practices described herein, which
plaintiff. Thebooks, accounts, records,
ationare in the possession of defendants and
and interest owing to plaintiff from
accountingby defendants and each of them,
have also benefited economically from the
VIENTO Y SOL without accounting to
bydefendants and each of them as a result of
deceptive
from
profits
En
'them
nark
md is entitled to, an accounting of all monies
om their use of the mark and trade name
similar terms.
CLAIM FOR RELIEF
iy
AMD (TEMPORARY, PRELIMINARY
59. Plaintiff realleges and in
paragraphs of this complaint.
60. The continuing wrongful
continue to harm the interest of plaintiff i
SOL. Ifthis court does not issue atempoijary
against defendants and each of them prohjbitin
other confusingly similar terms, in connecjtion
PERMANENT INJUNCTIVE RELIEF)
ccfrporates inthis cause ofaction all previous
Orozco vs. Navarro
Acts ofdefendants herein have harmed and
the use of the name and mark VIENTO Y
, preliminary andpermanent injunction
ingthe use of the name VIENTO YSOL, and
withthe goods and services of defendants'
lr l
COMPLAINT
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musical group, plaintiff will suffer irreparable harm for which there is no adequate remedy
at law.
PLAYER
WHEREFORE, plaintiff prays for
1. For an order requiringdefendants
should not be enjoined as set forth below,
2. For a temporary restraining orqer.
injunction, all enjoining defendants and
employees and co-venturers, and all persor
who receive actual notice of the order by
or performing any of the following acts:
(a) Using the name VIENTp
colorable imitation of the name, in connectlion
connection with the goods or services of
(b) Using the name VIENTp
colorable imitation of the name, in any
commercial value of the goods or services
(c) Otherwise infringing or
service mark and trade name VIENTO Y
(d) Causing a likelihood of
makeup, source, nature or quality ofplaintiff
(e) Contacting promoters,
offering the services of defendants as
colorable imitation of the name.
3. For an order requiring defendants
literature, advertising, goods and other
injurious designations.
4. For actual damages in an
relief;as follows:
to show cause, if they have any, why they
4uring the pendency of this action.
, a preliminary injunction, and a permanent
of them and their agents, servants,
s in active concert or participation with them
pbrsonal service or otherwise, from engaging in
Orozco vs. Navarro
Y SOL or any confusingly similar or
with advertising in any form, or in
defendants or anyof them;
Y SOL or any confusingly similar or
for the purpose of enhancing the
of defendants;
diluting the distinctive quality of plaintiff s
SOL;
confusion, deception or mistake as to the
s or defendants' services;
Advertisers or other businesses for the purpose of
VIENTO Y SOL or any confusingly similar or
to deliver up and destroy all promotional
material bearing the infringing, diluting or
amoiint not less than $100,000.
ma iner
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COMPLAINT
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plaintiffs actual damages suffered by reason of
and trade name.
4efendants' profits derived from infringement
5. For three times the amount of
defendants' infringement of plaintiff s mark
6. For three times the amount of
of plaintiff s mark and trade name.
7. For punitive damages in an am|ount to be proved at trial
8. For prejudgment interest.
9. For an accountingof all moniels
connection with the use of the name VIENITO
10. For costs of suit.
11. For reasonable attorneys fees.
12. For suchotherrelief as the coijrt maydeem appropriate
Dated: October 22, 2014
/stevenievre/
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Orozco vs. Navarro
received by defendants from their activities in
YSOL.
Steven J. Eyre
Attorney for plaintiff
COMPLAINT
A
o
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1
DEMAND FC)R JURY TRIAL
2
Plaintiff demands a trial of this action by a jury.
3
Dated: October 24, 2014
4
<
/stevenjevre/
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>teven J. Eyre
Attorney for plaintiff
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-12-
Orozco vs. Navarro COMPLAINT
UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
CIVIL COVER! HEET
I. (a) PLAINTIFFS ( Check box ifyou arerepresenting yourself fj )
IGNACIO RODRIGUEZ
DEFENDANTS {Check box ifyou arerepresenting yourself Q
JUAItl MANUEL NAVARRO, JOSE DIOSDADO, DOES1-10
(b) County of Residence of First Listed Plaintiff
(EXCEPTINU.S. PLAINTIFF CASES)
Cou ity of Residence of First Listed Defendant LOS ANGELES
(IN ujs. PLAINTIFF CASES ONLY)
(c) Attorneys (Firm Name,Address and Telephone Number) Ifyou are
representing yourself, provide the same information.
STEVENJ. EYRE, ATTORNEYAT LAW
3550 WILSHIREBLVDSTE 1440
LOS ANGELES, CA 90010
213.385.6926
II. BASIS OF JURISDICTION (Place an Xin one box only.)
| 11.U.S. Government
Plaintiff
I 1 2. U.S. Government
Defendant
| 3. Federal Question (U.S.
Government Not a Party)
| 14. Diversity (Indicate Citizenship
of Parties in Item III)
IV. ORIGIN (Place an Xin one box only.
1. Original ii 2. Removed from
Attc rneys (Firm Name, Address and Telephone Number) Ifyou are
repr renting yourself, provide the same information.
III. CITIZEIJSHIP OF PRINCIPAL PARTIES-For DiversityCases Only
:inX in one box for plaintiff and one for defendant)
PTF DEF I J D I Dl PTF
State D'DlS^r'PlaCe D4
(Place
Citizen of Thi
Citizen of Ambther
Citizen or
Foreign Courjtry
State
Subject of a
of Business in this State
Incorporated and Principal Place
of Business in Another State
2 2
n 3 n 3 Frei9n Nation
5
6
H
Proceeding
State Court
3. Remanded from
Appellate Court

4. Reinstate dor
Reopene i

5. Transferred from Another
District (Specify)
6. Multi-
I I District
Litigation
V. REQUESTED IN COMPLAINT: JURY DEMAND: (x] Yes No
CLASS ACTION under F.R.Cv.P. 23: [J Yes [x] No [>
(qheck "Yes" only ifdemanded in complaint.)
MONEY DEMANDED IN COMPLAINT: $ UNSPECIFIED
DEF
4
5
6
VI. CAUSE OF ACTION (Citethe U.S. Civil Statute under whichyouare filing and write
15 U.S.C. sec. 1051, TRADEMARK INFRINGEMENT
a brief statement of cause. Do not cite jurisdictional statutes unless diversity.)
VII. NATURE OF SUIT (Place an Xin one box only).
OTHERSTATyTESi
375 False Claims Act
ii 400 State
I' Reapportionment
410 Antitrust
Q 430 Banks and Banking
450 Commerce/ICC
Rates/Etc.
Q 460 Deportation
470 Racketeer Influ
enced &Corrupt Org.
fj 480 Consumer Credit
490 Cable/Sat TV
850 Securities/Com-

modities/Exchange
890 Other Statutory
Actions
891 Agricultural Acts
893 Environmental
Matters
895 Freedom of Info.
Act
896 Arbitration
899 Admin. Procedures
| | Act/Review of Appeal of
Agency Decision
950 Constitutionality of
State Statutes
FOR OFFICE USE ONLY:
CV-71 (06/14)
CONTRACT REAL PROPERTYCONT. IMM GRATION PRISONER PETITIONS
Q 110Insurance
120Marine
130Miller Act
140 Negotiable
Instrument
150 Recovery of
| | Overpayments
Enforcement of
Judgment
151 Medicare Act
152 Recovery of
Defaulted Student
Loan (Excl. Vet.)
153 Recovery of
| | Overpayment of
Vet. Benefits
160 Stockholders'
Suits
rI 190 Other
Contract
195 Contract
Product Liability
196Franchise
WEAL PROPERTY
[J 210Land
Condemnation
| | 220 Foreclosure
230 Rent Lease &

Ejectment

Case Number:
240 Torts to Land
245 Tort Product
Liability
290 All Other Real
Property

462 Naturalization
Application
465 0 tier
Immic ration Actions
'~"~'A
m w*
Habeas Corpus:
I | 463 Alien Detainee
ii 510 Motions to Vacate
!I Sentence
530General
535DeathPenalty
310 Airplane
315 Airplane
Product Liability
320 Assault, Libel &
Slander
330 Fed. Employers'
Liability
340 Marine
345 Marine Product
Liability
350 Motor Vehicle
355 Motor Vehicle
Product Liability
360 Other Personal
Injury
362 Personal Injury-
Med Malpratice
365 Personal Injury-
Product Liability
367 Health Care/
Pharmaceutical
Personal Injury
Product Liability
368 Asbestos
Personal Injury
Product Liability
370
371 Tfuth
D380
Other Fraud
in Lending
Ctheer Personal
Propejrty Damage
385 Pi operty Damage
Product Liability

.BANKRUPTCY

422 Appeal 28
USC 1558
ithdrawal 28
57
r-i 423 V\
u USC1
WiMCCIVIL RIGHtS-j5j|%
440 Cjther Civil Rights
441V
442 El
443 H
jting
ployment
musing/

Acconmodations
445Afnerica
Disab
Em ' pl< yme
u Disab
n with
ities-
ent
Afnerican with
lities-Other
448Education
t;tilV.|.)'iMb.;1r>-i!'!
540Mandamus/Other
550Civil Rights
II 555 Prison Condition
560 Civil Detainee
LJ Conditionsof
Confinement
FORFEITURE/PENALTY
_ 625 Drug Related
I I Seizure ofProperty 21
USC 881
690Other
BIS^ff-gtABOR"

710 Fair Labor Standards


Act
rI 720 Labor/Mgmt.
L-' Relations
740Railway Labor Act
751 Family and Medical
Leave Act
790 Other Labor
Litigation
791 Employee Ret. Inc.
Security Act
LACVI4-8188
CIVIL COVER SHEET
-JMgamUOfP
820Copyrights
830Patent
[x] 840Trademark
.*,'>,'
861 HIA(1395ff)
862Black Lung (923)
863DIWC/DIWW (405 (g))
864SSID Title XVI
865RSI (405 (g
fEDER^LTAXSlJI^
ii 870 Taxes (U.S. Plaintiff or
L-J Defendant)
r-i 871 IRS-ThirdParty 26 USC
L-l 7609
Page 1 of 3
UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
CIVIL COVER 5 HEET
VIII. VENUE: Your answers tothequestions below will determine thedivision oftheCo|urt
to change, inaccordance with the Court's General Orders, uponreview bythe Court ofyour
., 5T^tECASEWAS>JiNDINaJN
to which thiscase will be initially assigned. This initial assignment issubject
iomplaint or Notice of Removal.
k.
'^tp'9^, <ffi
,' /^VlT)*llD"IV|^kl^iD'lslF; i~4&
QUESTION A: Was this case removed
from state court?
Yes \x\ No
If"no," skipto Question B. If"yes," check the
box to the right that applies, enter the
corresponding division in response to
Question E, below, and continue from there.
1
Los Angeles, Ventura, Santa Barbara, orS< nLuis Obispo
Western
Orange
Riverside or SanBernardino
g'l^II-^'' :r*i-
QUESTION B: Is the United States, or
one of its agencies or employees, a
PLAINTIFF in this action?
Yes [x] No
If"no," skip to Question C. If"yes,"answer
Question B.I, at right.
W&'MAl&iMa&'&r*ii-i4 ,vm- i v
QUESTION C: Is the United States, or
one of its agencies or employees, a
DEFENDANT in this action?
Yes [x] No
B.I. Do50%or more of the defendants who reside in
the district reside in Orange Co.?
check oneof theboxestotheright ""t
B.2. Do 50% or more of the defendants who r ;side in
the district reside in Riverside and/or San Bern srdino
Counties? (Consider thetwo counties togethejr.)
checkone of theboxes to theright
__
C.I. Do 50%or more of the plaintiffs who reside in the
district reside in Orange Co.?
check one ofthe boxes to the right "^
C.2. Do 50% or more of the plaintiffs who resi
district reside in Riverside and/or San Bernardi
Counties? (Consider the two counties togeth
Southern
>'' w~
' it
Eastern
YES. Your case will initially be assigned to the Southern Division.
Enter "Southern" inresponseto Question E, below, and continue
from there.
NO. Continueto QuestionB.2.
YES. Your case will initially be assigned to the Eastern Division.
Enter "Eastern" inresponseto Question E, below, and continue
from there.
NO. Your case will initially be assigned to the Western Division.
Enter "Western" inresponseto Question E, below, and continue
from there.
YES. Your case will initially be assigned to the Southern Division.
Enter "Southern" inresponseto Question E, below, and continue
from there.
NO. Continueto QuestionC.2.
If"no," skip to Question D. If"yes,"answer
Question C.1, at right.
ie in the
10
.)
YES. Your case will initially be assigned to the Eastern Division.
I I Enter "Eastern" in response to Question E, below, and continue
from there.
' '.-t(
checkone of the boxes to theright
'SX i
; -,- . , Sww"
*<-= ' .Aft*
er,
NO. Your case will initially be assigned to the Western Division,
fj Enter "Western" inresponseto Question E, below, and continue
from there.
^fe
octroy
Wotfrainfffs an* tefwdints1?>", #i &fr
*Vf IISfc!&#
tOrange Coulfty j $Bbfadimpa!w;
Indicate the location(s) in which 50% or more of plaintiffs who resideinthisdistrict
reside. (Check up to two boxes, or leave blank if none of these choices apply.)
Indicate the location(s) in which 50% or more of defendants who reside in this
district reside. (Check up to two boxes, or leave blank ifnone of these choices
apply
wrtmiw^^ii)m?w*-*r
i" i i" ,
D.1. Is there at least one answer in Column A?
Yes [X] No
If"yes,"your case will initiallybe assigned to the
SOUTHERN DIVISION.
Enter "Southern" in response to Question E, below, and continue from there.
If "no," goto question D2 to the right. ""^
;jaj Division?
Enterthe initial division determined by Question A, B, C, or Dabove
'iiiu ^"'"nn

s
^t *,< st'^r> ' $*
llh
^MMA^kWU^-
D.2. Is there at least one answer in Column B?
Yes [x] No
If"yes," your case will initially be assigned to the
EASTERN DIVISION.
Enter "Eastern" in response to Question E, below.
If"no," your case will be assigned to the WESTERN DIVISION.
Enter "Western" in response to Question E, below.
iNrriAL DIVISIONJNCACD
WESTERN
*
Do 50%ormore ofplaintiffs ordefendants in this district reside in Ventura, Santa Barbara, orSan Luis Obispo counties? Q Yes [x] No
CV-71 (06/14) CIVIL COVER SHEET Page 2 of3
UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
CIVIL COVER?SHEET
IX(a). IDENTICAL CASES: Has this action beenpreviously filed inthis court?
Ifyes, list case number(s):
IX(b). RELATED CASES: Is this case related (as defined below) to any cases previously filed in this court?
Ifyes, list case number(s):
Civil cases are related when they:
A. Arise from the same orclosely related transactions, happening,
B. Call for determination ofthe same orsubstantially related orsim
C. For otherreasons would entail substantial duplication of labor
Check all boxes that apply. That cases may involve the same patent, trademark, or copyright is not, in itself, sufficient to deem cases
related.
X. SIGNATURE OF ATTORNEY
(OR SELF-REPRESENTED LITIGANT):
/ftffir-
or event;
ilar questions of law and fact; or
if heard by different judges.
fx] NO YES
NO [X] YES
DATE: October 22 2014
Notice to Counsel/Parties: Thesubmission ofthis Civil Cover Sheet isrequired b
neither replaces norsupplements the filing and service of pleadings or other
more detailed instructions,see separate instruction sheet (CV-071 A).
i Local Rule 3-1. This Form CV-71 and the information contained herein
papers as required by law, except as provided by local rules ofcourt. For
Key to Statistical codes relating to Social Security Cases:
Nature of Suit Code Abbreviation
Substantive Statement of Caui e of Action
Allclaims for health insurance benefits (Me ii
include claims by hospitals, skilled nursing
(42 U.S.C. 1935FF(b))
861
862
863
863
864
865
CV-71 (06/14)
HIA
BL
DIWC
DIWW
SSID
RSI
All claims for "BlackLung" benefits under Ti
923)
All claims filed by insured workers for disab
all claims filed for child's insurance benefits
care) under Title18, Part A, of the SocialSecurityAct,as amended. Also,
1acilities, etc., forcertification as providers of services underthe program.
le4, Part B, of the FederalCoalMineHealthand SafetyActof 1969.(30U.S.C.
lity insurance benefitsunder Title 2ofthe Social Security Act, as amended;plus
based on disability. (42U.S.C. 405 (g))
All claims filed for widows or widowers in
amended. (42 U.S.C. 405 (g))
nsu-ance benefitsbasedon disability under Title 2of the Social Security Act, as
All claimsfor supplemental securityincome
amended.
All claims for retirement (old age) and survi\
(42 U.S.C. 405 (g))
paymentsbasedupon disability filed under Title 16ofthe Social Security Act, as
ors benefits under Title2 of the SocialSecurityAct,as amended.
CIVIL COVER SH EET
Page 3 of 3