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PACIFIC EMPLOYERS INSURANCE COMPANY v. ADVANCED CLINICAL EMPLOYMENT STAFFING LLC Complaint for Breach of Contract

ATTENTION: It is possible that this information may no longer be current and therefore may be inaccurate. The index contains both open and closed cases and is not a complete list of cases in which an ACE Insurance Group company is involved. This information is provided to give interested persons an idea of the issues disputed in the indexed cases. For a full understanding of a case, one should read the rest of the court file, including the response. For the most up-to-date and complete information on a case, visit www.pacer.gov or contact the clerk of the relevant court.

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1 2 3 4 5 6 7 8 9 10 11 12 Plaintiff, 13
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Timothy Carl Aires, Esq. (138169) AIRES LAW FIRM 180 Newport Center Drive, Suite 260 Newport Beach, California 92660 (949)718-2020 (949) 718-2021 FAX Attorneys for Plaintiff, PACIFIC EMPLOYERS INSURANCE COMPANY
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John A. Cuas, txwuuve Officei/Cierii
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SUPERIOR COURT (UNLIMITED) OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES, CENTRAL DISTRICT, STANLEY MOSK COURTHOUSE
PACIFIC EMPLOYERS INSURANCE COMPANY,
Case No.
BC4J058.8
COMPLAINT FOR BREACH OF CONTRACT ($89,234.00 DEMANDED) [C.C.P. §425.10] :
v. ADVANCED CLINICAL EMPLOYMENT STAFFING LLC; and DOES 1 through 50, inclusive, Defendants.
16 17 18 19 20 21 22 23 24 25 26 27
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Plaintiff Pacific Employers Insurance Company, by and through its undersigned attorneys, hereby alleges against Defendants, and each of them, as follows:
PRELIMINARY ALLEGATIONS
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Plaintiff Pacific Employers Insurance Company is now, and at all^ir^e^rSe^VantJ: hereto was, a corporation duly organized and existing under the laws of the Commonwealth !df? Pennsylvania. Ill III
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COMPLAINT
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18
2.
Plaintiff is informed and believes and based thereon alleges that Defendant Advanced
Clinical Employment Staffing LLC is now, and at all times relevant hereto was, a corporation organized under the laws of the State of California and doing business in the County of Los Angeles, State of California and within this judicial district at 1768 North Garey Avenue,.Pomona, California 91767. > ;
3.
Plaintiff is ignorant of the true names and capacities of the Defendants sued herein
as Does 1 through 50, inclusive, and therefore sues these Defendants by such fictitious names. Plaintiff will amend this Complaint to allege the true names and capacities of said Defendants when the same is ascertained. Plaintiff is informed and believes and based thereon alleges that each of these fictitiously-named Defendants is jointly responsible in some manner for the transactions and /or occurrences herein alleged, and that the Plaintiffs injuries as alleged were proximately caused by such Defendants. ' 4. <
Plaintiff is informed and believes and based thereon alleges that at all times herein
mentioned each of the Defendants was the agent of each of the remaining Defendants, and in doing the things hereinafter alleged, was acting in the course and scope of such agency with the permission and consent of its co-Defendants.
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20 21 22 23 24 25 26 27 28 o
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5. . Plaintiff is informed and believes and based thereon alleges that, at all times relevant
hereto, a unity of interest has existed between Defendants such that any separateness between the
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Defendants has ceased and that it would sanction a fraud or promote an injustice ifthe separateness of the Defendants were recognized. Plaintiff is informed and believes and based thereon alleges that, at all times relevant hereto, that the entity Defendants have been used by the individual Defendants as subterfuges for illegal, fraudulent and/or otherwise wrongful transactions. Plaintiff is informed and believes and based thereon alleges that Defendants are successors in interest to a party liable to Plaintiff. As a result, whether Defendants are the alter egos of one another or successors in interest, Defendants are responsible for the debts, obligations and duties of one another. Plaintiff is informed
COMPLAINT
1 2 3 4 5 6 7 8 9 10 11 12 13 14
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and believes and based thereon alleges that the damage claim of Plaintiff is separate and distinct from any damage claim of the entirety of the class of the entity Defendants' creditors in that Plaintiff was the specific and particularized target of Defendants' illegal, fraudulent and/or otherwise wrongful conduct. '
6.
This action is not subject to Civil Code S1812.10 or Civil Code §2984.4. Theproper
county for the trial of this action is the County of Los Angeles in that the Defendants, and each of them, contracted to perform the obligation sued upon and/or have their principalfplace of business in the County of Los Angeles and within this judicial district.
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FIRST CAUSE OF ACTION (Breach of Contract Against All Defendants) P 7. Plaintiff hereby incorporates by reference paragraphs 1 through 6, inclusive, of this j";
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Complaint as if set forth in full in this paragraph.
16 17 8. 18 19
On or about January 1, 2011, Plaintiff upon the request of Defendants for Workers
Compensation and Employers Liability Insurance coverage, provided Defendants with an Insurance Policy No. NWC C4639902A for the period of 1/1/2011 through 1/1/2012, in writing, which was 20 subject to an audit and recomputation of its premium (the "Policy"). Plaintiff is authorized under 21 the Policy to examine and audit all records that relate to the Policy during the policy period. The 22 23 24 25 26 27
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Policy provides that the final premium will be determined by using the actual premium basis and the proper classifications and rates as determined by an audit. The Policy further obligated Defendants to pay the difference between the estimated and actual premiums after the audit and final premium determined by Plaintiff. In this regard, the Policy, in part, provides:
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PART FIVE - PREMIUM [If] B. Classifications fl] Item 4 of the information page shows the rate and premium basis for certain
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COMPLAINT
1 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
1 3
business or work classifications. These classifications were assigned based on an estimate of the exposures you would have during the policy period. If your actual exposures are not properly described by those classifications, we will assign proper classifications, rates and premium basis by endorsement to this policy. [%] C. Remuneration
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[%\. Premium for each work classification is determined by multiplying a rate times a premium basis period. Remuneration is the most common premium basis. This premium basis includes payroll and all other remuneration paid or payable during the policy period for the services of: fl|] 1. All your officer and employees engaged'in
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work covered by this policy; and flj] 2. All other persons engaged'in work that would make us liable under Part One (Workers Compensation Insurance) of this policy period. If you do not have payroll records for these persons, the contract price for their services and materials may be used as the premium basis. This paragraph 2 will not apply if you give us proof that the employers of these perso'hs
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lawfully secured their workers compensation obligation, [f] E. Filial
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Premium. The premium shown on the Information Page, schedules and endorsements is an estimate. The final premium will be
determined after this policy ends by using the actual, and not the estimated, premium basis and the proper classifications and rates that
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lawfully apply to the business and work covered by this policy. If the final premium is more than the premium you paid us, you must pay
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us the balance. If it is less, we will refund the balance to you. The final premium will not be less than the highest minimum premium for the classifications covered by this policy.... [|] F. Records. You will
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keep records of information needed to compute premium. You will provide us with copies of those records when we ask for them. [%\ G.
COMPLAINT
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Audit. You will let us examine and audit all your records that relate 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
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to this policy. These records include ledgers, journals, registers, vouchers, contracts, tax reports, payroll and disbursement records, and programs for storing and retrieving data. We may conduct the
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audits during regular business hours during the policy period and within three years after the policy period ends. Information
developed by audit will be used to determine final premium. Insurance rate service organizations have the same rights we have under this provision.
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9.
An audit was subsequently performed on the effective policy period for the Policy.
The audit found the premium basis estimate provided by the Defendants to be inaccurate and found the actual audited total premium plus tax for the effective policy period for the Policy to be short.
10.
Plaintiff has performed all conditions, covenants and promises required of it on its
part in accordance with the terms and conditions of the Policy, except those which are excused by Defendants' breach. 4 11. Subsequent to the audit, Defendants refused to make any further payments toward the
policy premium as audited for the Policy. Thus, within the past four years, ^Defendants have breached the terms of the Policy by failing and refusing to satisfy the amount outstanding on the Policy of $89,234.00, which became fixed or readily ascertainable on June 28, 2012.
12.
As a direct and proximate result of Defendants' breach of the Policy, Plaintiff has
been damaged in the amount of $89,234.00, together with prejudgment interest of $24.44 per day from January 2, 2012 using the legal rate of 10% per annum.
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COMPLAINT
1 2 3 4 5 6 7 8 9 10 11
12
WHEREFORE, Plaintiff prays for judgment against Defendants, and each of them, as follows:
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1.
For the sum of $89,234.00, together with prejudgment interest of $24.44 per day from { •
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January 2, 2012 using the legal rate of 10% per annum;
2.
For costs of suit, including attorney's fees, if available; and
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3.
For such other and further relief as the Court deems just and proper.
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DATED: August 14, 2012
AIRES LAW FIRM
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Attoffre^for Plaintiff, PACIFIC
SURANCE COMPANY
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COMPLAINT
J j ORIGINAL
CM-010
ATTCfiNEY OR PARTY WITHOUT ATTORNEY (Name, StateWr m tatter number, and addmss): FOR COURT USE ONLY
"Timothy Carl Aires, Esq. (138169) Timothy Carl Aires, Esq. (138169) AIRES LAW FIRM 180 Newport Center Drive, S u i t e 260 Newport Beach, C A 92 660
FAX NO.: 9 4 9 / 7 1 8 - 2 0 2 1 TELEPHONED.: 949/718-2020 A T R E F R (Nairn): P L A I N T I F F TONY O SUPERIOR COURT OF CALIFORNIA, COUNTY OF L O S ANGELES STREET ADDRESS: 1 1 1 NORTH H I L L STREET MAILING ADDRESS: 1 1 1 NORTH H I L L S T R E E T CITY AND ZIP CODE: LOS A N G E L E S , CA 9 0 0 1 2 BRANCH NAME: CENTRAL D I S T R I C T , STANLEY MOSK COURTHOU
FILED
SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES
AUG 1 7 2012
J ihn A. UBTjte, cxecium Otficer/Cierk i A. Clarice, cxecuave EY dL/iJDtDulv
CASE NAME: PACIFIC EMPLOYERS INSURANCE COMPANY v. ADVANCED CLINICAL EMPLOYMENT STAFFING LLC; and DOE
CIVIL CASE COVER SHEET Q D Unlimited • Limited (Amount (Amount demanded demanded is exceeds $25,000) $25.000 or less) Complex Case Designation I I Counter I I Joinder Filed with first appearance by defendant (Cal. Rules of Court, rule 3.402)
CASE NUMBER:.
BC490586
JUDGE: DEPT:
Items 1-6 below must be completed (see instructiom on page 2). 1. Check one box below for the case type that best describes this case: Contract Auto Tort Provisionally Complex Civil Litigation (Cal. Rules of Court, rules 3.400-3.403) I I | I [ | Antitrust/Trade regulation (03) | Construction defect (10) I Mass tort (40) | Securities litigation (28) D Environmental/Toxic tort (30) ~] Insurance coverage claims arising from the above listedrprovisionally complex case types (41) ...
C H Auto (22)
I I Uninsured motorist (46) Other PI/PD/WD (Personal Injury/Property Damage/Wrongful Death) Tort I I I I I I | Asbestos (04) | Product liability (24) [ ] Medical malpractice (45) I Other PI/PD/WD (23) I Business tort/unfair business practice (07) | Civil rights (08) I Defamation (13) I Intellectual property (19) I | | Professional negligence (25) | Other non-PI/PD/WD tort (35) | Non-Pl/PD/WD (Other) Tort . I
H Breach of contract/warranty (06) I Rule 3.740 collections (09) X 1 Other collections (09) I | Insurance coverage (18) • f I Other contract (37) Real Property I Eminent domain/Inverse condemnation (14) J Wrongful eviction (33) | Other real property (26)
Enforcement of Judgment I | Enforcement of judgment (20) Miscellaneous Civil Complaint I I I | I RICO (27) I Other complaint (nor specified above) (42) I Partnership and corporate governance (21) | Other petition (not specified above) (43) !i 1
Unlawful Detainer d H Commercial (31) | I H Residential (32) I I I Drugs (38) | Asset forfeiture (05) I Petition re: arbitration award (11) Z ] Writ of mandate (02) Zl Other judicial review (39) Judicial Review
l _ J Fraud (16)
Miscellaneous Civil Petition
Employment I | Wrongful termination (36) I I Other employment (15)
2. This case 1 i is I X 1 is not complex under rule 3.400 ofthe California Rules of Court. If the case is complex, mark the factors requiring exceptional judicial management: ; a. L_J Large number of separately represented parties d. I I Large number of witnesses b. I I Extensive motion practice raising difficult or novel e. I I Coordination with related actions(pending in one or more courts issues that will be time-consuming to resolve in other counties, states, or countries, or in a federal court c. I I Substantial amount of documentary evidence f. 1 I Substantial postjudgment judicial supervision 3. Remedies sought (check all that apply): a. I X i monetary b. I I nonmonetary; declaratory or injunctive relief c. I | punitive 4. Number of causes of action (specify): ONE jj 5. This case I 1 is I X I is not a class action suit. 6. If there are any known related cases, file and serve a notice of related case. (You may use form CM-015.) Date: 8 / 1 4 / 2 0 1 2 k *-— V T i m o t h y C a r l A i r e s , E s q . (1381691
(TYPE OR PRINT NAME)
NOTICE • Plaintiff must file this cover sheet with the first paper filed in the action or proceeding {eJreeptsmall claims casee*6r cases filed under the Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of CourCrtrle-373aG^aiiure to file may result in sanctions. •) File this cover sheet in addition to any cover sheet required by local court rule. i • If this case is complex under rule 3.400 et seq. of the California Rules of Court, you must serve a copy of this cover sheet on all i; i other parties to the action or proceeding. \ ? Unless this is a collections case under rule 3.740 or a complex case, this cover sheet will be used for'statistical purposes only.
I; Form Adopted for Mandatory Use Judicial Council of California CM-010 [Rev. July 1,2007] Paflt 1 o( 2
CIVIL CASE COVER SHEET
,s
Cal. Rules of Court, rules 2.30.3.220, 3 400-3.403. 3.740; Cal. Standards of Judicial Administrator!, sld. 3.10
INSTRUCTIONS ON HOW TO COMPLETE THE COVER SHEET
CM-010
To Plaintiffs and Others Filing First Papers. If you are filing a first paper (for example, a complaint) in a civil case, you must complete and file, along with your first paper, the Civil Case Cover Sheet contained on page 1. This information will be used to compile statistics about the types and numbers of cases filed. You must complete items 1 through 6 on the sheet. In item 1, you must check one box for the case type that best describes the case. If the case fits both a general and a more specific type of case listed in item 1. check the more specific one. If the case has multiple causes of action, check the box that best indicates' the primary cause of action. To assist you in completing the sheet, examples of the cases that belong under each case type in item 1;are provided below. A cover sheet must be filed only with your initial paper. Failure to file a cover sheet with the first paper filed in a civil case may subject a party, its counsel, or both to sanctions under rules 2.30 and 3.220 of the California Rules of Court. i To Parties in Rule 3.740 Collections Cases. A "collections case" under rule 3.740 is defined as an action for recovery of money owed in a sum stated to be certain that is not more than $25,000, exclusive of interest and attorney's fees, arising from a transaction in which property, services, or money was acquired on credit. A collections case does not include an action seeking the following: (1) tort damages, (2) punitive damages, (3) recovery of real property, (4) recovery of personal property, or (5) a prejudgment writ of attachment. The identification of a case as a rule 3.740 collections case on this form means that it will be exempt from the general time-for-service requirements and case management rules, unless a defendant files a responsive pleading. A rule 3.740 collections case wilt be subject to the requirements for service and obtaining a judgment in rule 3.740. -, To Parties in Complex Cases. In complex cases only, parties must also use the Civil Case Cover Sfjee/ to designate whether the case is complex, if a plaintiff believes the case is complex under rule 3.400 of the California Rules of Court, this must be indicated by completing the appropriate boxes in items 1 and 2. If a plaintiff designates a case as complex, the cover sheet must be served with the complaint on all parties to the action. A defendant may fife and serve no later than the time of its first appearance a joinder in the plaintiffs designation, a counter-designation that the case is not complex, or, if the plaintiff has made no designation, a designation that the case is complex. CASE TYPES AND EXAMPLES Auto Tort Auto (22)—Personal Injury/Property Damage/Wrongful Death Uninsured Motorist (46) {if the case involves an uninsured motorist claim subject to arbitration, check this item instead of Auto) Other PI/PD/WD (Personal Injury/ Property Damage/Wrongful Death) Tort Asbestos (04) Asbestos Property Damage Asbestos Personal Injury/ Wrongful Death Product Liability (not asbestos or toxic/environmental) (24) Medical Malpractice (45) Medical MalpracticePhysicians & Surgeons Other Professional Health Care Malpractice Other PI/PD/WD (23) Premises Liability (e.g., slip and fall) Intentional Bodily Injury/PD/WD (e.g., assault, vandalism) Intentional Infliction of Emotional Distress Negligent Infliction of Emotional Distress Other PI/PDA/VD Non-PI/PD/WD (Other) Tort Business Tort/Unfair Business Practice (07) Civil Rights (e.g., discrimination, false arrest) (not civil harassment) (08) Defamation (e.g., slander, libel) (13) Fraud (16) Intellectual Property (19) ' Professional Negligence (25) Legal Malpractice Other Professional Malpractice (not medical or legal) Other Non-PI/PD/WD Tort (35) Employment Wrongful Termination (36) Other Employment (15)
CM-01O |R«v. July 1.2007|
Contract Breach of Contract/Warranty (06) Breach of Rental/Lease Contract (not unlawful detainer or wrongful eviction) Contract/Warranty Breach—Seller Plaintiff (not fraud or negligence) Negligent Breach of Contract/ Warranty Other Breach of Contract/Warranty Collections (e.g., money owed, open book accounts) (09) Collection Case—Seller Plaintiff Other Promissory Note/Collections Case Insurance Coverage (nor provisionally complex) (18) Auto Subrogation Other Coverage Other Contract (37) Contractual Fraud Other Contract Dispute Real Property Eminent Domain/Inverse Condemnation (14) Wrongful Eviction (33) Other Real Property (e.g., quiet title) (26) Writ of Possession of Real Property Mortgage Foreclosure Quiet Title Other Real Property (not eminent domain, lendlordAenant, or foreclosure) Unlawful Detainer Commercial (31) Residential (32) Drugs (38) (if the case involves illegal drugs, check this item; otherwise, report as Commercial or Residential) Judicial Review Asset Forfeiture (05) Petition Re: Arbitration Award (11) Writ of Mandate (02) Writ-Administrative Mandamus Writ-Mandamus on Limited Court Case Matter Writ-Other Limited Court Case Review Other Judicial Review (39) Review of Health Officer Order Notice of Appeal-Labor Commissioner Appeals
Provisionally Complex Civil Litigation (Cal. Rules of Court Rules 3.400-3.403) Antitrust/Trade Regulation (03) Construction Defect (10) Claims Involving Mass Tort (40) Securities Litigation (28) Environmental/Toxic Tort (30) Insurance Coverage Claims (arising from provisionally complex case-type listed above) (41) Enforcement pf Judgment Enforcement of Judgment (20) Abstract of Judgment (Out of County) Confession of Judgment (nondomestic relations) Sister. State Judgment Administrative Agency Award (not unpaid taxes) Petition/Certification of Entry of Judgment on Unpaid Taxes Othe^. Enforcement of Judgment Case Miscellaneous Civil Complaint RICO (2f) Other Cojnplaint (not specified above) (42) Declaratory Relief Only Injunctive Relief Only (nonharassment) Mechanics Lien Other! Commercial Complaint Case (non-tort/hon-complex) Othef Civil Complaint (non-tort/non-complex) Miscellaneous Civil Petition Partnership and Corporate , Governance (21) . - "Other Petition (hot specified • ' _ afcovej (43). . v '•'* Civil Harassment Workplace Violence ' 'Elder/Dependent Adult Abuse / Election Contest >: • " Petition for Narrie'Change Ret'rtipn(for Relief from Late Claim Other Civil Petition
Pags2 of 2
CIVIL CASE COVER SHEET
SHORT TITLE: P A C I F I C
EMPLOYERS
INSURANCE
COMPANY
V.
CASE NUMBER
ADVANCED CLINICAL EMPLOYMENT STAFFING LLC; a n d
BC
*9Q58
CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION (CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION)
This form is required pursuant to Local Rule 2.0 in all new civil case filings in the Los Angeles Superior Court.
Item I. Check the types of hearing and fill in the estimated length of hearing expected for this case:
JURY TRIAL? Q O YES CLASS ACTION? C O YES LIMITED CASE? C O YES TIME ESTIMATED FOR TRIAL4_ H O U R S / m DAYS
Item II. Indicate the correct district and courthouse location (4 steps - If you checked "Limited Case", skip to Item III, Pg. 4): Step 1 : After first completing the Civil Case Cover Sheet form, find the main Civil Case Cover Sheet heading for your case in the left margin below, and, to the right in Column A , the Civil Case Cover Sheet case}type you selected.
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% Step 2: Check one Superior Court type of action in Column B below which best describes tie nature of this case. Step 3: In Column C, circle the reason for the court location choice that applies to the type pf action you have checked. For any exception to the court location, see Local Rule 2.0. Applicable Reasons for Choosing Courthouse Location (see Column O below)
1. 2. 3. 4. 5. Class actions must be filed in the Stanley Mosk Courthouse, central district. May be filed in central (other county, or no bodily injury/property damage). Location where cause of action arose. Location where bodily injury, death or damage occurred. Location where performance required or defendant resides. 6. 7. 8. 9. 10. Location Location Location Location Location of property or permanently garaged vehicle. where petitionerresides. wherein defendant/respondent functions wholly. where one or more of the parties reside. of Labor Commissioner Office
Step 4: Fill in the information requested on page 4 in Item III; complete Item IV. Sign the declaration.
kpplicabletReasbnsJ
o o Auto (22)
Uninsured Motorist (46) i I I A7100 Motor Vehicle - Personal Injury/Property Damage/Wrongful Death I A7110 Personal Injury/Property Damage/Wrongful Death - Uninsured Motorist
1., 2., 4.
1., 2., 4.
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Asbestos (04)
I i I I I I
I A6070 Asbestos Property Damage I A7221 Asbestos - Personal Injury/Wrongful Death I A7260 Product Liability (not asbestos or toxic/environmental) I A7210 Medical Malpractice - Physicians & Surgeons I A7240 Other Professional Health Care Malpractice I A7250 Premises Liability (e.g., slip and fall)
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Product Liability (24)
1 „ 2 , 3., 4., 8.
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CO O
Medical Malpractice (45)
1.,4. 1..4.
' 1..4. 1„4. 1..3. 1..4.
Other Personal Injury Property Damage Wrongful Death (23)
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I A7230 Intentional Bodily Injury/Property Damage/Wrongful Death (e.g. assault, vandalism, etc.) ; ] A7270 Intentional Infliction of Emotional Distress I A7220 Other Personal Injury/Property Damage/Wrongful Death X
LACIV 109 (Rev. 03/11) LASC*Approved 03-04
CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION
Local Rule 2.0 Page 1 of 4
LA-CV109
SHORTTITLE: P A C I F I C EMPLOYERS INSURANCE COMPANY v .
ADVANCED r.T,TNTTAT, KMPT.OYMF.NT S T A F F I N G T.T.P: pn
CASE NUMBER
SeivilteaserCo^rSfieeti'
Business Tort (07)
I I I I \ I
I A6029 Other Commercial/Business Tort (not fraud/breach of contract) I A6005 Civil Rights/Discrimination I A6010 Defamation (slander/libel) I A6013 Fraud (no contract) I A6017 Legal Malpractice _J A6050 Other Professional Malpractice (not medical or legal) I A6025 Other Non-Personal Injury/Property Damage tort I A6037 Wrongful Termination I A6024 Other Employment Complaint Case I A6109 Labor Commissioner Appeals
1.,3.
1..2., 3. 1..2., 3. 1.,2.,3. 1..2..3. 1., 2., 3. 2.,3.
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Civil Rights (08) Defamation (13) Fraud (16) Professional Negligence (25) Other (35)
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O CO
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Wrongful Termination (36)
1., 2., 3.
1., 2 , 3.
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Other Employment (15)
10.
2., 5. 2., 5. 1., 2., 5. 1.. 2., 5. 2., 5., 6.
Breach of Contract/ Warranty (06) (not insurance)
I H ] A6004 Breach of Rental/Lease Contract (not unlawful detainer or wrongful eviction) j I I I I A6008 Contract/Warranty Breach -Seller Plaintiff (no fraud/negligence) I A6019 Negligent Breach of Contract/Warranty (no fraud) I A6028 Other Breach of Contract/Warranty (not fraud or negligence) I A6002 Collections Case-Seller Plaintiff
" G 2 o o
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I Collections (09)
I X I A6012 Other Promissory Note/Collections Case I I I A6015 Insurance Coverage (not complex) I A6009 Contractual Fraud I A6031 Tortious Interference I A6027 Other Contract Dispute(not breach/insurance/fraud/negligence)
g)5.
1., 2., 5., 8. 2., 3.. 5. . 2., 3., 5. ,2., 3., 8.
Insurance Coverage (18)
Other Contract (37)
I I
Eminent Domain/Inverse Condemnation (14)
I I I
I A7300 Eminent Domain/Condemnation I A6023 Wrongful Eviction Case I A6018 Mortgage Foreclosure I A6032 Quiet Title
Number of parcels Ji_
8.
2
o.
CD
Wrongful Eviction (33)
2., 6.
2., 6. 2., 6.
a.
Other Real Property (26)
I [
I A6060OtherRealProperty(noteminentdomain,landlord/tenant,foreclosure) 2., 6. I A6021 Unlawful Detainer-Commercial (not drugs or wrongful eviction) I A6020 Unlawful Detainer-Residential (not drugs or wrongful eviction) I A6020F Unlawful Detainer-Post-Foreclosure I A6022 Unlawful Detainer-Drugs
Unlawful Detainer-Commercial (31)
CO
I I I I
2., 6. 2., 6. 2., 6. 2., 6.
Q
Unlawful Detainer-Residential (32) Unlawful Detainer' Post-Foreclosure (34) Unlawful Detainer-Drugs (38)
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LACIV 109 (Rev. 03/11) LASC Approved 03-04
CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION
Local Rule 2.0 Page 2 of 4
SHORTTITLE:
PACIFIC EMPLOYERS INSURANCE COMPANY v. ADVANCED CLINICAL EMPLOYMENT STAFFING LLC; an
CASE NUMBER
Asset Forfeiture (05)
I I I
I A6108 Asset Forfeiture Case i A6115 Petition to Compel/Confirm/Vacate Arbitration I A6151 Writ - Administrative Mandamus I A6152 Writ • Mandamus on Limited Court Case Matter Z) A6153 Writ - Other Limited Court Case Review I A6150 Other Writ/Judicial Review I A6003 Antitrust/Trade Regulation I A6007 Construction Defect I A6006 Claims Involving Mass Tort I A6035 Securities Litigation Case I A6036 Toxic Tort/Environmental I A6014 Insurance Coverage/Subrogation (complex case only)
2., 6. 2., 5. 2., 8. 2. 2. 2., B. 1., 2., 8.
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Petition re Arbitration (11)
Writ of Mandate (02)
I I
Other Judicial Review (39) Antitrust/Trade Regulation (03) Construction Defect (10)
Q.
i I I I I I I
1.. 2., 3.
1..2.. 8. 1..2., 8. 1.,2., 3.. 8. 1.. 2., 5., 8. 2., 9. 2„6. 2., 9. 2., 8. 2., 8. 2., 8., 9. 1.,2.,8. 1..2., 8. 2., 8. 1.,2.,8. 1., 2.,8. 2., 8.
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Claims Involving Mass Tort (40) Securities Litigation (28)
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LAOIV 109 (Rev. 03/11) LASC Approved 03-04
CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION
Local Rule 2.0 Page 3 of 4
SHORT-TITLE PACIFIC EMPLOYERS INSURANCE COMPANY v. ADVANCED CLINICAL EMPLOYMENT STAFFING LLC; and
CASE NUMBER
Item III. Statement of Location: Enter the address of the accident, party's residence or place of business, performance, or other circumstance indicated in Item II., Step 3 on Page 1, as the proper reason for filing in the court-location you selected.
ADDRESS: 17 68
REASON: Check the appropriate boxes for the numbers shown under Column C for the type of action that you have selected for this case.
NORTH GAREY AVENUE
•i.LS2.n3.n405.a6.a7.izB.n9.nio.
CITY: STATE: ZIP CODE:
POMONA
CA
91767
Item IV. Declaration of Assignment. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that the above-entitled matter is properly filed for assignment to the STANLEY MOSK " courthouse in the CENTRAL District of the Superior Court of California, County of Los Angeles [Code Civ. Proa, § 392 et seq., and Local Rule 2.0, subds. (b). (c) and (d)].
Dated: 8 / 1 4 / 2 0 1 2
PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY COMMENCE YOUR NEW COURT CASE: 1. Original Complaint or Petition. 2. If filing a Complaint, a completed Summons form for issuance by the Clerk. 3. Civil Case Cover Sheet, Judicial Council form CM-010. 4. Civil Case Cover Sheet Addendum and Statement of Location form, LACIV109, LASC Approved 03-04 (Rev. 03/11). 5. Payment in full of the filing fee, unless fees have been waived. • '•>
6. A signed order appointing the Guardian ad Litem, Judicial Council form CIV-010, if the plaintiff or petitioner is a minor under 18 years of age will be required by Court in order to issue a summons. 7. Additional copies of documents to be conformed by the Clerk. Copies of the cover sheefand this addendum must be served along with the summons and complaint, or other initiating pleading in the case.
LACIV 109 (Rev. 03/11) LASC Approved JD3-04
CIVIL CASE COVER SHEET ADDENDUM mp STATEMENT OF LOCATION 4 |
Local Rule 2.0 Page 4 of 4

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