eavet/eo ken dry He pur 10 u 1B 14 15 16 7 18, 19 20 22 23 24 26 27 28 DOUGLAS CAIAFA, ESQ. (State Bar No. 107747) “i DOUGLAS CAIAFA, A Professional Law Corporatigy 11845 West Olympic Boulevard, Suite 1245 FILED Los Angeles, California 90064 rior Court ot Califor Gl0) 444-5540 - phone wo! echt ‘Angelos B10) 312-8260 - fax AUG 12 2014 CHRISTOPHER J. MOROSOFF, ESQ, (State Bar No. 200465) gy, LAW OFFICE OF CHRISTOPHER J. MOROSOFF eee OficerCter 77-305 California Drive ao OY Palm Desert, California 92211 7 (Zed) 469-5986 - phone 760) 345-1581 - Attorneys for Plaintiffs SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES CASE NO. BC5 54512 CLASS ACTION : STEVEN PRICE, an individual; individually and on behalf of all others similarly situated, Plaintiff, COMPLAINT FOR DAMAGES vs 1 UNLAWFUL MISCLASSIFICATION OF EMPLOY! FAILURE TO PAY MINIMUM UBER TECHNOLOGIES, INC., a Delaware WAGE; Corporation, and DOES 1 through 100, inclusive, 3. FAILURE TO PAY OVERTIME COMPENSATION; FAILURE TO PAY FOR MISSED MEAL PERIODS; FAILURE TO PAY FOR MISSED REST PERIODS; FAILURE TO PAY FOR REPORTING TIME; 4, Defendants. 5. 6. 7. FAILURE TO REIMBURSE 8 9. x EMPLOYEE EXPENSES, FAILURE TO KEEP ACCURATE EMPLOYMENT RECORDS; FAILURE TO PROVIDE ACCURATE WAGE SRAPEMENTS; 10. UNLAWFUL BUSI ae mm 2 PRACTICES (CaliforniéeHsindss Professions oa SE7200) ata, aad ee 11. PENALTIES NTT THE” LABOR CODE BaVales 29 ATTORNEYS GENERALAC TE (California Labor Code §2698'e¥seq.) pacwqey59 ztepena DEMAND FOR JURY TRIALS ie need COMPLAINT FOR DAMAGES. ( 3G iNA Lwrere0 ee a ‘STEVEN PRICE (“Plaintiff”), individually and on behalf of all Comes now Plai others similarly situated (collectively referred to as “Class Members”), and for causes of action against Defendants and each of them, alleges as follows: INTRODUCTION 1, This complaint involves a representative action for damages and is brought by and on behalf of persons who are or have been at some time between August 12, 2010, and the present, employed as drivers for UBER TECHNOLOGIES, INC., a Delaware Corporation with its principal place of business in California (hereafter referred to as “UBER” or “Defendant”), a transportation network company (“TNC”) which provides prearranged transportation services to consumers in California for compensation using an online-enabled application or platform, 2. This is a California state-wide class action which challenges UBER’s uniform policy of willfully mis-classifying its drivers as independent contractors when, in fact, each such driver is and/or was an employee of UBER. 3, Asarresult of UBER’s unlawful mis-classification of its drivers as independent contractors, UBER has uniformly violated the requirements of the California Labor Code and California Industrial Welfare Commission (“IWC”) Wage Order No. 9-2001, as amended (“Wage Order No. 9"), by, among other things: a, Failing to pay its drivers at least the minimum wage required by California law for every hour worked; b. Failing to pay its drivers overtime compensation for hours worked in excess of 8 hours in-one-day and/or 40 hours in-one-week; c. Failing to pay its drivers premium wages for missed meal periods; 4, Failing to pay its drivers premium wages for missed rest periods; e. Failing to compensate its drivers for reporting-time premiums; {Failing to reimburse its drivers for employment related expenses. 2. Unlawfully taking gratuities from each of its drivers in California; h, Failing to keep accurate employment records for its drivers in California; and, 2 ‘COMPLAINT FOR DAMAGES:wrveTv00 Sow ao 10. i. Failing to provide its drivers in California with legally required wage statements. PARTIES Plaintiff STEVEN PRICE (hereinafter "Plaintift*) is, and at all times relevant hereto has been, an individual and a resident of Los Angeles County, California. At some time during the period from August 12, 2010, to the present, Plaintiff worked for Defendant UBER as a driver in Los Angeles, California, Plaintiff is informed and believes, and on that basis alleges, that Defendant UBER is a corporation, organized under the laws of the state of Delaware, which is licensed by the California Secretary of State to conduct business in the state of California, and which does conduct substantial business on a regular and continuous basis in the state of California. UBER’s principal place of business is in San Francisco, California The true names and capacities of the defendants named herein as DOES 1 through 100, inclusive, whether individual, corporate, associate or otherwise, are unknown to Plaintiff who therefore sues such defendants under fictitious names pursuant to California Code of Civil Procedure §474, Plaintiff is informed and believes, and on that basis alleges, that these defendants, DOES | through 100, are in some manner or capacity, and to some degree, legally responsible and liable for the damages of which Plaintiff complains. Plaintiff will seek leave of Court to amend this Complaint to set forth the true names and capacities of all fictitiously-named defendants within a reasonable time after they become known. Plaintiff is informed and believes and on that basis alleges, that at all times relevant hereto, defendants UBER and DOES 1 through 100, and each of them, acted as employers of Plaintiff, and all others similarly situated. JURISDICTION AND VENUE This is a civil action brought under and pursuant to the California Labor Code and the California Business & Professions Code. : This Court has jurisdiction over this action pursuant to Code of Civil Procedure §410.10. ‘The monetary relief which Plaintiff seeks is in excess of the jurisdictional minimum eae ‘COMPLAINT FOR DAMAGESeT/e1/90 Ce aa we i 12. 14. 16. 17. 18 required by this Court and will be established according to proof at trial. Venue is proper in this Court pursuant to Code of Civil Procedure §§395 and 395.5 because the employment agreements at issue, whether real or implied, were made and/or performed in the county of Los Angeles, California. Furthermore, Defendant’s liability arises, by virtue of the employment of Plaintiff, in the county of Los Angeles, California. Plaintiff is informed and believes, and on that basis alleges, that Defendant UBER and DOES | through 100, and each of them, have had sufficient contacts with the state of California for this Court to exercise jurisdiction over them. FACTUAL ALLEGATIONS UBER is a California-based transportation business referred to by the California Public Utilities Commission as a TNC. Through a mobile phone software application, UBER connects local travelers who seek transportation via automobile with local drivers (“Class Members”) who are and have been screened, trained, controlled, and are paid by UBER. All UBER drivers are subject to and must abide by all of UBER’s uniform rules, regulations and policies. UBER operates much like a taxi cab service. UBER customers who wish to pay for local transportation via automobile must log on to a mobile phone application and enter information regarding, among other things, where they wish to be picked up from and where they wish to be dropped off. Then, through its software application, UBER sends each customer’s information to a local UBER driver. ‘The UBER driver then picks up the customer and transports the customer to the desired destination. Each UBER customer pays for the service by paying UBER directly via credit card based on an amount calculated solely by UBER and based on the miles driven and the amount of time it took to reach the destination. UBER deceptively and falsely advises all customers that a gratuity is included in the cost of the transportation service that UBER charges. However, UBER drivers do not receive the total proceeds from any such gratuity. Rather, UBER drivers receive at most only a 4. ‘COMPLAINT FOR DAMAGESwiyer/eo Sew aan 19, 20. 2. portion of any additional gratuity amount added by UBER to the customer's charge. Al payments from the customer, including any such gratuities, must be paid by the customer directly to UBER. UBER rules do not permit its drivers to accept any type of payment from its customers. Instead, UBER, pays each of its drivers a portion of the amount received from the customer (i.e., a portion of the charge for the service and a portion of any gratuity), as determined solely by UBER. In an effort to avoid providing its drivers with the minimum benefits and protections afforded employees in California, UBER has willfully, uniformly, and unilaterally classified each and every one of its drivers as “independent contractors,” rather than “employees,” despite the fact that the factual circumstances of the relationship between UBER and its drivers clearly demonstrate that UBER drivers are in fact “employees” of the company under California law. Under California law, UBER drivers should be considered employees for, among others, the following reasons: a. UBER retains the right to control, and in fact does control, the manner and means by which all UBER drivers accomplish their work; b. UBER retains the right to hire and fire drivers in its sole discretion; ¢. UBER retains the right to terminate the UBER “Platform” and the UBER application, and/or to block drivers from using the Platform and/or application, which effectively gives UBER the ability and right to prevent its drivers from picking up customers, working, and earning an income; d. UBER drivers do not engage in a business distinct from that of UBER; e. UBER sets all rates of pay for its drivers and prohibits its drivers from setting rates of pay for their services; f. UBER requires its drivers to consent to receiving emails and texts from UBER, all of which drivers are required to pay for re« ing such emails and texts at the rate(s) charged by their mobile phone service providers, including without limitation, notification emails, emails or text messages informing drivers about “Se ‘COMPLAINT FOR DAMAGES:“yrr21700, ee a 22. potential available customers, and emails or text messages regarding UBER promotions by which drivers are required'to abide; UBER unilaterally and in its sole discretion requires cach driver to accept any and all promotional discounts offered by UBER to customers; UBER requires each driver to engage in training before being permitted to work as an UBER driver, which, inter alia, instructs drivers regarding UBER's requirements for how they are to interact with customers; UBER requires that each driver ensure that his or her vehicle comply with UBER’s requirements for appearance and cleanliness; UBER retains the right to discipline its drivers in its sole discretion; UBER limits the geographical locations in which its drivers are permitted to work, and restricts its drivers” ability to transport customers more than a certain number of miles, as determined solely by UBER; UBER restricts its drivers ability to work.and eam income by only permitting them to work certain hours each day; UBER prohibits its drivers from hiring other employees to assist them; and, UBER requites its drivers to respond to and accept all customer ride requests unless they are transporting another customer at the time. UBER has not, and will not be able to overcome the legal presumption under California law that each Class Member is in fact an employee. As a result of UBER’s uniform mis-classification of its drivers as independent contractors, UBER does not pay its drivers a wage for each hour, or portion thereof, that they work, Instead, UBER pays its drivers using a formula, derived and determined solely by UBER, based on and related in some way to the amount UBER receives from its customers, The consequenees of this practice are, without limitation, that UBER drivers throughout Califomia are: not paid for all of the hours that they actually work; not paid at least the minimum wage required by California law for each hour worked; not paid overtime compensation for hours that they actually work in excess of 8 hours in-a-day be ‘COMPLAINT FOR DAMAGES:wietrao a aw een 24. 27. 28. 29. 30. 31 e eo : and/or 40 hours in-a-week; and, have had portions of their gratuities unlawfully taken from them by UBER. In addition, this unlawful employment praetice has also resulted in Defendant’s failure to keep accurate time records for its driver employees, and failure to provide its driver employees with proper wage statements showing the actual number of hours each such employee has worked, In addition to Defendant's unlawful wage payment practices, UBER has uniformly failed to provide its drivers throughout California with meal and rest periods as required by the California Labor Code and Wage Order No. 9 UBER has also uniformly required its drivers to periodically report for work on days during which no work was available, and/or days during which the drivers were not put to ‘work, and on which the driver received no pay. On such days, UBER has failed to pay its drivers the reporting time pay required by Wage Order No. 9 UBER also has a uniform policy of failing to reimburse its drivers for necessary expenditures incurred in the course of their duties as UBER drivers. CLASS ACTION A IN Plaintiff brings this action on behalf of himself and on behalf of all other persons similarly situated (the Class”), namely each and every person who, at any time during the period from August 12, 2010, to the present (hereafter referred to as the “Class Period”), has worked, or currently works, as a driver for UBER in California (“Class Members”). Plaintiff is and has been a member of the proposed Class described herein. The number of persons in the proposed Class herein is so numerous that joinder of all such persons would be impracti¢able. While the exact number and identities of all such persons are unknown to Plaintiff at this time and can only be obtained through appropriate discovery, Plaintiff is informed and believes, and on that basis alleges, that the proposed Class herein includes over 1,000 persons. Disposition of Plaintiff's claims in a class action will benefit all parties and the Court, oe ‘COMPLAINT FOR DAMAGES.wiret/e0 ul 12 4 15 16 7 18 19 20 21 2 B 24 25 26 28 32, 34. 35. 36, 37. 38, There is a well-defined community of interest presented by the proposed Class herein in that, among other things, each member of the proposed Class has an interest in receiving the minimum compensation required by California law for the hours they have worked for Defendant, obtaining other appropriate legal relief for the harm of which Plaintiff complains, and obtaining other adequate compensation for the common damages which Plaintiff and all other persons similarly situated have suffered as a result of Defendant's actions. Each Class Member herein has performed labor for Defendant at some time during the Class Period for which they have not been properly compensated, in that they have not received the minimum compensation required by the California Labor Code and Wage Order No. 9. Defendants have also deprived Plaintiff and all other Class Members of other statutory rights guaranteed to them by the California Labor Code and/or Wage Order No. 9, as described more fully herein A class action in this case is superior to any other available method for the fair and efficient adjudication of the claims presented herein. ‘The prosecution of separate actions by individual members of the proposed Class herein would create a risk of inconsistent and/or varying adjudications with respect to individual ‘members of the proposed Class which would or may establish incompatible standards of conduct for Defendants and which would also create a risk of adjudications with respect to individual members of the proposed Class herein which would, as a practical matter, be dispositive of the interests of other members of the proposed Class not parties to the particular individual adjudications, and/or would or may substantially impede or impair the ability of those other members to protect their interests. Common questions of law and fact exist in this case with respect to the proposed Class which predominate over any questions affecting only individual members of the Class and which do not vary between members thereof. At some time during the Class Period, all of the individuals in the proposed Class herein 8. ‘COMPLAINT FOR DAMAGES.wret/eo Ce nae 10 u 12 14 1S 16 7 18 19 20 21 22 23 24 25 26 28 39. 40. 4l. 42. 43. have been employed by Defendant as drivers in one or more city within California and have been unlawfully subjected to a uniform and consistent set of unfair employment practices, as described more fully herein. All members of the proposed Class herein have been deprived of their legal rights, guaranteed by the California Labor Code and Wage Order No. 9, to be properly compensated for the hours that they have worked for Defendant throughout the Class, Period. All members of the proposed Class herein have been deprived of their legal rights, guaranteed by the California Labor Codé and Wage Order No. 9, to be properly ‘compensated for one or more meal and/or rest periods which such employees did not receive on one or more days during the Class Period in which such employees worked for Defendant All members of the proposed Class herein have been deprived of their legal rights, guaranteed by the California Labor Code and Wage Order No. 9, to be properly compensated for reporting to work on one or more occasions during the Class Period on days that such employees were not put to work The common questions of fact involved in this case include, without limitation: (1) whether UBER has retained the right to control the manner and means by which Class Members accomplish their work; (2) whether UBER has retained the right to discharge Class Members without cause; (3) whether Class Members have been engaged in business or occupation distinct from that of UBER while performing services as UBER drivers; (4) whether performing services as an UBER driver requires any unique or specialized skill indicative of that of an independent contractor; (5) whether Class Members have been engaged to perform services for UBER as UBER drivers for a short specified period of time, or for an unspecified length of time; and, (6) whether the work performed by UBER drivers is part of UBER’s regular business. Other common questions of fact involved in this case include, without limitation, whether (1) UBER has guaranteed that cach Class Member received at least the applicable 9. ‘COMPLAINT FOR DAMAGES-pxver90 Ce aa ® 10 i 12 3 4 15 16 7 18 19 20 al 2 2B 4 26 27 28 44. 45. minimum wage for each hour worked; (2) UBER has guaranteed that each Class Member received at least the applicable premium overtime compensation for each overtime hour worked; (3) UBER has provided Class Members with premium pay for each meal period that Class Members have been unable to take during the Class Period; (4) UBER has provided Class Members with premium pay for each rest period that Class Members have been unable to take during the Class Period; (5) UBER has paid the required reporting time compensation to Class Members who have been required to report to work on one or more days during the Class Period on a day in which they were not put to work; (6) Class Members have been subject to the same companywide policies and practices while working as a driver for UBER, including without limitation, policies and practices related to the manner and means by which they accomplish their work, their compensation, time keeping, record keeping, and wage statements; (7) Class Members have had some amount of gratuities from customers taken from them by UBER; and, (8) Class Members have incurred expenses related to their jobs as drivers for UBER which were not reimbursed by UBER. “The common questions of law in this case applicable to each Class Member's claim against Defendants include, without limitation, application of: (1) the common law test for employment articulated by the California Supreme Court in Ayala v. Antelope Valley Newspapers (2014) case no. $206874; (2) Wage Order No. 9; (3) Labor Code §§226, 226.7, 226.8, 351, $10, 512, 1174, 1197, 1198, and 2802. Common questions of law and fact involved in this case include, thout limitation: (1) whether Class Members worked as UBER drivers in California as employees of Defendant(s) or as independent contractors; (2) whether Defendants uniform policies and practices have violated Labor Code §1197, and Wage Order No. 9, by virtue of Defendant’s failure to pay its driver employees at least the legally required minimum wage for each and every hour worked; (3) whether Defendant's uniform policies and practices have violated California's overtime compensation requirements codified at Labor Code §§510 and 1198, and Wage Order No. 9, by virtue of Defendant's failure to =10- ‘COMPLAINT FOR DAMAGESvierse0 Sc wrai)a " 13 14 15 16 7 18 19 20 2 23 24 25 26 a7 28 46, e : ® pay its driver employees premium overtime compensation for hours worked in excess of 8-in-a-day and/or 40-in-a-week; (4) whether Defendant's uniform policies and practices, have violated California’s meal period requirements codified at Labor Code §§226.7 and 512, and Wage Order No. 9, by virtue of its failure to provide its driver employees with meal periods as required therein; (5) whether Defendant's uniform policies and practices have violated California's rest period requirements codified at Labor Code §226.7, and Wage Order No. 9, by virtue of its failure to provide its driver employees with rest periods as required therein; (6) whether Defendant has violated Wage Order No. 9 by uniformly failing to pay its driver employees a reporting time premium for days during the Class Period on which such employees reported to work but were not provided any paid work; (7) whether Defendant violated Labor Code §351 by uniformly and unlawfully withholding portions of gratuities left for Class Members by customers; (8) whether Defendant violated Labor Code §2802 by uniformly failing to reimburse Class Members for work related expenses; (9) whether Defendant violated Labor Code §1174 and Wage Order No. 9 by uniformly failing to keep adequate time and employment records for Class Members; (10) whether Defendant violated Labor Code §226 and Wage Order No, 9 by uniformly failing to provide Class Members with accurate wage statements; (11) whether Defendant’s uniform policies and practices related to the relationship between UBER and its drivers are unlawful, unfair and/or fraudulent business practices in violation of Business & Professions Code §17200 et seq.; (12) whether Plaintiff and those other persons similarly situated are entitled to general and/or special damages as a result of any of the legal vioiations complained of herein, and the nature of such damages. The claims of the named Plaintiff in this case are typical of those of the other Class Members which he seeks to represent, in that, among other things, Plaintiff and each other Class Member have sustained damages and are facing irreparable harm because of, and arising out of, a common course of conduct engaged in by Defendant as complained of herein +H ‘COMPLAINT FOR DAMAGESexvetreo a) 6 10 i 12 1B 4 16 17 18 19 20 21 2 2B 24 26 a 28 4. 48. 49. 50. SI. 52, 53. 55, The claims of the named Plaintiff herein are coincident with, and not antagonistic to, the claims of the other Class Members which the named Plaintiff seeks to represent. The named Plaintiff herein will fairly and adequately represent and protect the interests of the members of the proposed Class which he seeks to represent. Plaintiff does not have any interests which are antagonistic to the interests of the proposed Class herein. Counsel for Plaintiff herein are experienced, qualified and generally able to conduct complex class action litigation. By virtue of Defendant’s unlawful failure to pay Class Members the minimum compensation required by California law, Defendant has received substantial sums of money, and has realized profits from the unpaid labor of literally thousands of employees since August 2010. Atall times relevant hereto, Labor Code §§200, 201, 202, 203, 204, 226, 226.7, 226.8, 351, 510, 12, 1174, 1194, 1198, and 2802 were, and continue to be, in full force and effect, and each and every defendant herein was, and continues to be, bound thereby. Atal times relevant hereto, Title 8 of the California Code of Regulations, §§11040 through 11015, have been, and continue to be, in full force and effect, and each and every defendant herein was, and continues to be, bound thereby. The relief sought in this action is necessary to restore to members of the proposed Class the money and property which Defendant has illegally acquired through the unlawful treatment of each Class Member as described herein. FIRST CAUSE OF ACTION UNLAWFUL MISCLASSIFICATION OF EMPLOYEE (California Labor Code §226.8) (By Plaintiff on behalf of himself and all others similarly situated) Plaintiff re-alleges and incorporates by reference, as though fully set forth herein, paragraphs | through 53 of this Complaint, Labor Code §226.8 provides, “It is unlawful for any person or employer to engage in any of the following activities: (1) Willful misclassification of an individual as an “12. ‘COMPLAINT FOR DAMAGESvrver/e0 ce ao 10 12 13 4 15 16 7 18 19 20 a 2 23 24 25 26 27 2B 56. 58. 59, 60. 61 2. 63. independent contractor. (2) Charging an individual who has been willfully misclassified as an independent contractor a fee, or making any deductions from compensation, for any purpose, including for goods, materials, space renal, services, government licenses, repairs, equipment maintenance, or fines arising from the individual's employment where any of the acts described in this paragraph would have violated the law if the individual had not been misclassified.” Atall relevant times during the Class Period, Labor Code §226.8 has been in full force and effect Defendant has violated Labor Code §226.8 by uniformly, willfully and unlawfully miselassifying Plaintiff and all other Class Members as independent contractors and by charging Plaintiff and all other Class Members fees and making unlawful deductions from such Class Members’ compensation. By virtue of Defendant’s violation of Labor Code §226.8, Plaintiff and all other Class Members have suffered, and continue to suffer, damages in amounts which are presently unknown to Plaintiff but which will be ascertained according to proof at trial. Plaintiff and each other Class Member are entitled to, and seek, payment from Defendant of civil penalties pursuant to Labor Code §§226.8(b) and (). SECOND CAUSE OF ACTION FAILURE TO PAY MINIMUM WAGE (California Labor Code §§1182.12, 1194, 1194.2, 1197, and 1197.1) B himself and all others similarly situated) Plaintiff re-alleges and incorporates by reference, as though fully set forth herein, parageaphs 1 through 59 of this Complaint. Defendant is the employer of Plaintiff and all other Class Members. Defendant willfully and uniformly mis-classified Plaintiff and all other Class Members as independent contractors when in fact each such Class Member was and/or is an employee of UBER : Labor Code §1194 provides that any employee who receives less than the legal minimum -13- ‘COMPLAINT FOR DAMAGES.wrrerveo ee a 64. 66. 67. 68. 69. ‘wage applicable to the employee is entitled to recover in a civil action the unpaid balance of the full amount of the applicable minimum wage, plus interest thereon, attorney's fees, and costs of suit. Labor Code §1197 provides that the minimum wage is the minimum wage set by the Industrial Welfare Commission in the applicable wage order, in this case Wage Order No 9 applicable to transportation workers. Wage Order No. 9 incorporates by reference the minimum wage currently set by statute, which pursuant to Labor Code §1182.12 is $9.00 per hour, Defendant has failed to pay Plaintiff, and all other Class Members similarly situated, at least the legally required minimum wage for some portion of the hours that each such person worked as a driver for UBER during the Class Period. Defendant's failire to pay Plaintiff, and such other Class Members, at least the minimum wage as required by law, violates the provisions of Labor Code §§1182.12 and 1197, and Wage Order No. 9. By virtue of Defendant's unlawful failure to pay minimum wages to Plaintiff and all other Class Members when due, all such persons have suffered, and continue to suffer, damages in amounts which are presently unknown to Plaintiff but which will be ascertained according to proof at trial. Pursuant to Labor Code §§1194 and 1194.2, Plaintiff and all other similarly situated Class Members are entitled to recover from Defendant the full balance of any and all unpaid minimum wages, interest thereon, liquidated damages equal to the full amount of unpaid minimum wages and interest thereon, attorney’s fees, costs of suit, and penalties pursuant to Labor Code §1197.1 THIRD CAUSE OF ACTION FAILURE TO PAY OVERTIME COMPENSATION (California Labor Code §§1194 and 1198) (By Plaintiff on behalf of himself and all others similarly situate Plaintiff re-alleges and incorporates by reference, as though fully set forth herein, samo mots oer reners ot rags or wronghl eviction) 2,0 |] [7 Geeitios,, |e asoruninaromarerronsrsonve 28 Tanta oeanerbage G0) [SABE Uvevts Deer Ons ze ‘LACIV 108 (Rev. 03/11) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.0 LASC Approves 05-06 AND STATEMENT OF LOCATION Page 2of4 PERCE EEE iE kala alaewrrctreo PRICE V. 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AS190 Election Contest 2 = ca 1 AS110 Pein for Change of Name 2.7 10 A6170 Petion fr Rete! tom Late Cakm Law 2.9.4.6 1D Ast00 cer Civi Patton 2.8. ‘cw 109 (Rew car) CIVIL CASE COVER SHEET ADDENDUM Local Rule 20 LASC Approved 03.08 AND STATEMENT OF LOCATION Page 30! 4vivereo Soar SENDER PRICE V, UBER TECHNOLOGIES Item Il. Statement of Location: Enter the address of the accident, party's residence or place of business, performance, or other circumstance indicated in item lI., Step 3 on Page 1, as the proper reason for filing in the court location you selected. REASON: Check the appropriate boxes forthe nurmbars shown | 2012 Marne Ave. ‘under Colum G for tha type of action that you have selected for ‘his ease. G1. C2. 03. 04, 05.06. 07. 08. Oe. O10. or sme | arcooe: Gardena ca |soaee Item IV. Declaration of Assignment: | declare under paraly of perury under the laws ofthe State of California that the foregoing i true and correct and that the above-entiled matter is properly fled for assignment to the Los Angsles Superior courthouse in the Central Distiet of the Superior Court of Califomia, County of Los Angeles [Code Civ. Proc.,§ 392 et seq , and Local Rule 2.0, subds. (), (e) and (a) Dated: August 12, 2014 PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY COMMENCE YOUR NEW COURT CASE: 1. Original Compizint or Petition. 2. I fling a Complaint, a completed Summons form for issuance by the Clerk. 3. Civil Case Cover Sheet, Judicial Council form CM-010, 4 ht Case Cover Sheet Addendum and Statement of Location fam, LACIV 108, LASG Approved 03-04 (Rev ost), Payment in full of the filing fee, unless fees have been waived. 6. A signed order appointing the Guardian ad Liter, Judicial Council form CIV-010, ifthe plaintif or petitioner is a ‘minor under 18 years of age will be required by Court in order to issue a summons. LACIV 109 Rev. 0371) CIVIL CASE COVER SHEET ADDENDUM ‘Local Rule 20 LASC Approved 03-04 AND STATEMENT OF LOCATION Page 4 of ¢