Palmer Sues Rialto 1741246546 (1-22)

I THEIDA SALAZAR SBN: 2 9 5 5 4 7
LAW OFFICES OF THEIDA SALAZAR

2 2 1 4 0 North Hollywood Way # 7 1 9 2
Burbank, CA 9 1 5 1 0
3 Telephone: ( 8 1 8 ) 433-7290
FILED
Facsimile: ( 8 1 8 ) 436-4009
4
Superior Court of California
[email protected] Countv of Los Angeles
5
JUN 0 1 2018
Attorneys for Plaintiffs
6
Shem K.�erkof Court
3y, ,Deputy
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SUPERIOR COURT OF THE STATE OF CRTik&NA"

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COUNTY OF LOS ANGELES-CENTRAL

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10 EDWARD PALMER, E S Q . , an individual; Case No.:
ERIC WILSON, an individual; PATRICK

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1 1
SMITH, an individual; and TIMOTHY
LAINTIFF'S COMPLAINT FOR
ST ANSELL, an individual.
12
AMAGES
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Plaintiffs,
1. Negligence, Pursuant to Civil Code
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1 71 4 ;
2. Fraud/Intentional Misrepresentation;
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V. 3. Negligent Misrepresentation;
4. Tortious Interference with Economic

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Advantage;
5. Tortious Interference with Contract;

17 CITY OF RIALTO, a public entity. 6. Intentional Infliction of
Emotional Distress;
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7. Negligent Infliction of
Emotional Distress;
Defendant.
19 8. Unfair Business Practices in Violation
of the Business & Professions Code §
20 1 72 0 0 ; a n d
9. Discrimination on Basis of Race
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22
LAINTIFFS DEMAND JURY TRIAL

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Plaintiffs, Edward Palmer, Esq., Eric Wilson, Patrick Smith, and Timothy Stansell are filing
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their complaint against, Defendants City of Rialto.

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:
Identification of Parties
1. Plaintiff Edward Palmer, Esq. is a resident of San Bernardino County, California.
COMPLAINT FOR DAMAGES

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2. Plaintiff Eric Wilson is a resident of Los Angeles County, California.
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3. Plaintiff Patrick Smith is a resident of San Bernardino County, Califonia.
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4. Plaintiff Timothy Stansell is a resident of San Bernardino County, California.
5. Defendant City of Rialto is, and at all times mentioned herein was a government entity in
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Rialto California doing business in San Bernardino County and operating under the laws of
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the State of California.

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8 6. Gina Gibson-Williams is an employee of the City of Rialto, serving in City/ Planning and
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Licensing.
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7. Deborah Robertson is an employee of the City of Rialto serving as an elected official
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o 5 5 or employee, partner or officer, director or joint venturer of defendant herein, and doing the things
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joint venture, or association and under the direction of, and with the consent and permission,
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advance knowledge and/or ratification of the other defendants. At all times relevant, the named
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employees, including the Mayor, and Rialto Police Department, formed and operated under a
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22 common plan and agreement, with the resulting injuries and damages to Plaintiff arising from acts
23 done in furtherance of the common design.
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9. Further, at all times relevant, the named employee, Mayor, and Law Enforcement Officers,
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aided and abetted the commission of the torts alleged herein in that: (a) the defendant knew
its employees conduct constituted a breach of duty and gave substantial assistance or
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encouragement to the other defendants to so act, or, (b) Employee and Mayor gave
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substantial assistance to the Defendants in accomplishing a tortious result and that
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Defendant's own conduct, separately considered, constituted a breach of duty to Plaintiffs.
3
1 0 . The Defendants are liable for the acts of each other through principles of respondeat
superior, agency, ostensible agency, partnership, alter-ego and other forms of vicarious
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liability.
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8 C. Jurisdiction And Venue
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1 1 . This Court has jurisdiction over Defendants because they do business in and have extensive
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contacts with Los Angeles County.
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t 12. One or more Plaintiffs are in Los Angeles County, California Accordingly, venue of this
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1 3 . Plaintiff is a resident of Los Angeles County.
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jury should be empaneled in Los Angeles County to ensure an unbiased and impartial finder
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of fact.
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D. General Allegations
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1 5 . Raquel's Jazz Lounge was unfairly targeted for closure, and unfortunately suffered disparate
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22 treatment in its operation of the business located at 134 S . Riverside, Ave. Rialto, 92376.
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1 6 . On or about March 6, 2 0 1 7 , Raquel's Jazz Lounge received a Notice from Code
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Enforcement indicating it had not paid for a business license for the year 2 0 1 7 . Mr. Palmer
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was in South Carolina and contacted City Administrator, Mike Story by phone regarding
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1 7 . Mr. Story informed Mr. Palmer to email Ms. Gina Gibson-Williams (City
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Planning/Licensing) to give permission for business partner, Eric Wilson to go to City Hall
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to pay for the Business License for the year.
1 8 . Mr. Palmer did as Mr. Story requested, and Mr. Wilson.went to the Licensing Division that
day (with a blank check) and requested from Ms. Gibson-Williams the amount necessary to
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pay all licensing fees.

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8 1 9 . Mr. Wilson inquired of the amount required to bring Raquel's current on amounts owed to
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the City as well as the amount necessary to pay for the calendar year. Mr. Wilson paid
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approximately $ 1 , 5 0 0 . 0 0 for licensing and permits based on Ms. Gibson-William's
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s specification of fees owed for the year.
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5 ° 20. On or about March 1 6 , 2 0 1 7 , The Rialto Police Department (RPD) came to the lounge at
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approximately 10 : 3 0 p.m. and proceeded to close the business and informed management it
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M not the Business License. More importantly, because the City is closed every Friday, the
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business remained closed through Monday, March 20, 2 0 1 7 which included the very
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profitable St. Patrick's Day weekend.
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22. On Monday March 20, 2 0 1 7 , a meeting was held at the Licensing Division with the
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principals of Raquel's, Ms. Gibson-Williams, and RPD Lieutenant Smith. The business
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23 license fee was paid, and Raquel's was allowed to re-open March 2 1 , 2 0 1 7 .
24 2 3 . Unfortunately, Ra q uel's was again closed by RPD, this time the fact the caterer there for
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that night did not possess a City Business License, was cited as cause.
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not have a Business License , which was irrelevant because food was not being sold it was
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2 5 . Raquel's remained closed pursuant to the City of Rialto's demand for the next two months.
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More importantly, there were no ABC violations, Health Department violation, Fire
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Department Violations, or Building Code violations that warranted or necessitated closing.
26. However, RPD and the City chose to close them anyway and could not re-open until they
were told they could by the City.

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27. On or about May 1 0 , 2 0 1 7 , Mayor Deborah Robertson, RPD Lieutenant Robert Smith, Gina
7
8 Gibson-Williams, and City Administrator, Mike Story met with Eric Wilson, Tim Stansell,
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Pat Smith, and A. Majadi.
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2 8 . During this meeting, Mayor Robertson informed them the City would not support Raquel's
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S' as long as it was in the present location and in association with Mr. Edward Palmer.
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which excluded Mr. Palmer and sought to have them relocated to an area away from the
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. ¢ s 16 3 0 . Plaintiff complied with GC § 945.6 and brought its claim within six months, which was
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t denied. Denial of the claim prompted Plaintiff to bring this timely complaint.
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19 FIRST CAUSE OF ACTION
(NEGLIGENCE, pursuant to Civil C o d e § 1714)

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3 1 . Plaintiffs refer to and incorporates the factual allegations set forth in paragraphs one ( 1 )
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through thirty (30) as though fully set forth hereafter.

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32. Defendants had a duty to use due care in advising the Plaintiffs on the full amount owed to
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satisfy their debts in association with its business.

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proper information to Plaintiffs. Among other things, Defendant failed to properly advise
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Plaintiffs of the business license fees required to remain open for business .
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3 4 . More importantly, since Defendant keeps reduced hours and does not operate on Friday,
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which is the last and busiest day of the week, their duty to Plaintiffs was heightened.
3 5 . Defendants knew Plaintiffs were present to pay ALL fees and Defendants knew these fees
had to be paid to remain open and service the community.

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36. Defendants' acts and omissions were a substantial factor in causing Plaintiffs injuries.
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3 7. Defendants breach of duty resulted in Plaintiffs being harmed and suffering economic
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8 damages and significant financial loss.
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3 8 . As a further proximate result of the Defendants' actions, Plaintiff has been required to
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expend money and incur obligations for additional marketing to attempt to reach the patrons
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& lost. medical services, MRI's, drugs, and sundries reasonably required in the treatment and
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3 9 . As a further proximate result of the dangerous condition on the Defendants' property,
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SECOND CAUSE OF ACTION
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(FRAUD/INTENTIONAL MISREPRESENTATION)
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40. Plaintiffs refer to and incorporates the factual allegations set forth in paragraphs one ( 1 )
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through thirty-nine (39) as though fully set forth hereafter.

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23 4 1 . Defendant willfully and intentionally engaged in fraud and misrepresentation as defined by
24 California Civil C o d e § 1 5 72 . Defendant, purposefully, recklessly, or intentionally or by
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some other actionable manner withheld the proper amount owed in fees.
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42. Defendant's fraudulent representation to Plaintiff of the amount required to stay open
occurred on the date of March 6, 2 0 1 8 but resulted in Plaintiffs business being closed over
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the St. Patrick's weekend.
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43. Defendant's fraudulent representations regarding the amount required to stay open for
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business based on Ms. Gibson- Wilsons assertions of facts were not true and Plaintiffs relief
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on those assertions and representations to be true and were damaged thereafter.
44. Defendant made such representations recklessly and without regard for the truth. Moreover,
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Defendants intentionally suppressed the true facts regarding the amounts owed and
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precluded the Plaintiffs from paying.

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8 4 5 . Defendants created an unlawful scheme, to effectuate a closure of Plaintiffs business and
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intentionally suppressing amounts owed was an intricate part of their scheme. This was the
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proximate cause of Plaintiffs harm and resulted in damages, an amount of which will be
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THIRD CAUSE OF ACTION
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through forty-five (45) as though fully set forth hereafter.

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4 7. Defendants owed a duty to Plaintiff to exercise reasonable care to ensure they did not
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20 misrepresent the amount of fees required to stay open. Defendant also had a duty not to
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create unreasonable risks of injury to others and failed to exercise that reasonable care and
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therefore breached their duty.
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48. The Defendants made the foregoing misrepresentations without any reasonable
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grounds for believing them to be true, and were, in fact, reckless.

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49. These misrepresentations were made directly by Defendants, by Ms. Gibson-

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Williams, their representative and authorized agent, with the intention of inducing reliance on the
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50. The representations by the Defendants were in fact false, in that Plaintiffs still
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required an amount to be paid and were subsequently closed as a result of Defendants breach
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causing serious injuries to Plaintiffs.
51. The foregoing representations by Defendants were made with the expectation and
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intention of inducing reliance upon them and Plaintiff reasonably relied on the misrepresentations
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made by the Defendant to their detriment.

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8 52. If Plaintiff had known of the true facts and the facts concealed by the Defendants,
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Plaintiff would have paid all its fees and remained open over the very busy and very profitable, St.
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Patrick's Day weekend.
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53. The reliance of Plaintiffs upon Defendants' misrepresentations was justified
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because such misrepresentations were made and conducted by individuals and entities that were in
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a position to know the true facts.

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54. As a direct, proximate, and foreseeable result of Defendants' negligent

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16 misrepresentations, Plaintiff suffered injuries and damages as alleged herein. The exact amount
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is currently not ascertained but will be shown according to proof at time of trial.
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FOURTH CAUSE OF ACTION
(TORTIOUS INTERFERENCE WITH ECONOMIC ADVANTAGE}

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55. Plaintiffs refer to and incorporates the factual allegations set forth in paragraphs one (1 )
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through Fifty-Four (54) as though fully set forth hereafter.

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24 5 6 . Mayor of Rialto knew that Plaintiffs enjoyed a harmonious economic relationship
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that was likely to benefit Plaintiff Palmer as well;
5 7 . The Mayor's knowledge of this relationship and personal and political motives
caused her to attempt to break up the Plaintiffs business relationship.
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5 8 . Ultimately, Mayor Robertson informed Plaintiff Wilson and others that if they
2
continued to stay in the location owned by Mr. Palmer, the city would continue to
harass and disrupt their business.

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5 9 . Mayor Robertson suggested that the Plaintiffs relocate to another venue for their Jazz
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6 Lounge and that she could put them in touch with the project manager.
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60. Defendants conduct was wrongful and unethical. Moreover, Defendant intended to
disrupt the economic relationship, and had knowledge that disruption was likely
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because of their conduct.

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11 6 1 . Defendants sought to disrupt the relationship of Plaintiffs and cause them harm.
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62. The harm is evident from the economic damages suffered by Plaintiffs which is a
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64. The exact amount of financial loss as a result of the Defendants misrepresentation is
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currently not ascertained but will be shown according to proof at time of trial.
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FIFTH CAUSE OF ACTION
21 (TORTIOUS INTERFERENCE WITH CONTRACT)
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65. Plaintiffs refer to and incorporates the factual allegations set forth in paragraphs one (1 )
23
24 through Sixty - Four (64) as though fully set forth hereafter.
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66. Mayor of Rialto knew that Plaintiffs had a contract and enjoyed a harmonious
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? economic relationship that was likely to benefit Plaintiff Palmer as well;
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6 7 . The Mayor's knowledge of this relationship and personal and political motives
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caused her to attempt to break up the Plaintiffs business relationship.
6 8 . Ultimately, Mayor Robertson informed Plaintiff Wilson and others that if they
4
continued to stay in the location owned by Mr. Palmer, the city would continue to
5
6 harass and disrupt their business.
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69. Mayor Robertson suggested that the Plaintiffs relocate to another venue for their Jazz
Lounge and that she could put them in touch with the project manager.
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70. Defendants conduct was wrongful and unethical. Moreover, Defendant intended to
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agreements with its vendors, suppliers, and lienholders.
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agreement regarding the location for Raquel's Jazz Lounge and cause them harm.
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7 3 . The harm is evident from the economic damages suffered by Plaintiffs which is a
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causal connection between the wrongful act and the harm. The exact amount is
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21 currently not ascertained but will be shown according to proof at the time of trial.
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23 SIXTH CAUSE OF ACTION
{INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS)

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74.Plaintiffrestates and incorporates by reference each and every allegation contained i

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the paragraphs one ( 1 ) through Seventy-Three (73), as fully set forth herein.
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7 5 . The conduct of Defendants, herein alleged, was outrageous, negligent, reckless or in
2 some other actionable way.
4 7 6 . As soon as Plaintiff was allowed to open, the City implemented its scheme to
wrongfully, fraudulently, and maliciously close Raquel's so as to harm its

5
relationship with its vendors, patrons, suppliers and lienholders. Defendants were
6
determined to get rid of Plaintiffs and their motive was clear; Defendants did not
7
want an African-American owned business in that location and did not want Plaintiff
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in the location owned by Plaintiff Palmer.

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7 7 . Ultimately, Plaintiffs establishment became the subject of harassment and ridicule as

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more fully set forth in the facts. Nevertheless, the fraudulent scheme of the
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& Defendant is illegal, unethical, immoral, and outrageous.
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7 8 . Especially, considering the Mayor is an elected official and public servant, makes he
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behavior so extreme that it goes beyond the bounds of decency and could be
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regarded as intolerable in a civilized society.
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i 4 79. In acting as they did, Defendants intended to cause, or acted with reckless disregards
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17 80. As a direct and proximate result of the conduct of Defendants, Plaintiffs have
18 suffered and continues to suffer severe emotional distress including but not limited
to, anxiety, depression, humiliation, vulnerability, sleeplessness, impact on appetite,

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and self-doubt in an amount which exceeds the minimum jurisdictional requirements

20
of this Court. The exact amount is currently not ascertained but will be shown
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according to proof at the time of trial.

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23
SEVENTH CAUSE OF ACTION

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(NEGLIGENT INFLICTION OF EMPOTIONAL DISTRESS)
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: 8 1 . Plaintiff restates and incorporates by reference each and every allegation contained i
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the previous paragraphs one (1 ) through Eighty (80), as fully set forth herein.
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82. The conduct of Defendants, herein alleged, was outrageous, intentional, and
2 malicious. As soon as Plaintiff was allowed to open, the City implemented its
3 scheme to wrongfully, fraudulently, and maliciously close Raquel's so as to harm its
4 relationship with its vendors, patrons, suppliers and lienholders. Defendants were
determined to get rid of Plaintiffs and their 'motive was clear; Defendants did not
5
want an African-American owned business in that location and did not want Plaintiff
6
in the location owned by Plaintiff Palmer.

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8 3 . Ultimately, Plaintiffs establishment became the subject of harassment and ridicule as

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more fully set forth in the facts. Nevertheless, the fraudulent scheme of the
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Defendant is illegal, unethical, immoral, and outrageous.

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84. Especially, considering the Mayor is an elected official and public servant, makes he
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behavior so extreme that it goes beyond the bounds of decency and could be
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regarded as intolerable in a civilized society.
13
8 5 . In acting as they did, Defendants intended to cause, or acted with reckless disregards
14
as to whether their actions would cause Plaintiff to suffer severe emotional distress.
15
8 6 . As a direct and proximate result of the conduct of Defendants, Plaintiffs have
16 suffered and continues to suffer severe emotional distress including but not limited
17 to, anxiety, depression, humiliation, vulnerability, sleeplessness, impact on appetite,
18 and self-doubt in an amount which exceeds the minimum jurisdictional requirements
of this Court. The exact amount is currently not ascertained but will be shown
19
according to proof at the time of trial.

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21
EIGHTH CAUSE OF ACTION

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(UNFAIR BUSINESS PRACTICES,

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PURSUANT TO BUSINESS AND PROFESSIONS §17200)

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8 7 . Plaintiff restates and incorporates by reference each and every allegation contained i
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gr: the paragraphs one (1 ) through Eighty-Six (86) as fully set forth herein.
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8 8 . Defendants, without limitation, consciously, deliberately, and in bad faith
2 discriminated against, and retaliated against Plaintiffs, and harassed them, as more
3 fully alleged herein.
4 89. Defendants, without limitation, consciously, deliberately, and in bad faith withheld
the amounts required for Plaintiff to pay to remain open, even after Plaintiff made a
5
request for the full amount owed. Defendants actions are in violation of California
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Business and Professions Code § 1 2 0 2 4 . 1 .
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90. This conduct is "unlawful, unfair and fraudulent," within the meaning of Business
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and Professions Code § 1 7 2 0 0 .

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9 1. The wrongful conduct of Defendants, unless enjoined by court order, will cause great
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and irreparable harm to Plaintiff, and businesses similarly situated, as Defendant will
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continue to engage in conduct prohibited by Government Code § § 1 2 9 4 0 and
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12940.2, Business and Professions Code § 1 7 2 0 0 et seq. There is no adequate remedy
13
at law to prevent this abuse. Plaintiff therefore seeks an order requiring that the
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Defendant () pay for a consultant to provide anti-discrimination, anti-harassment,
15
and anti-retaliation training to each of the Defendants Departments for as long as the
16 Defendants are in business with minority-based businesses.
17 92. Training should be required of each of Defendants employees, at the time of hire and
18 annually thereafter, to attend one full day discrimination and anti-harassment, and
anti-retaliation seminars; and (iii) publicly apologize to Plaintiffs in any medium the
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court approved; and (iv) any other injunctive relief deemed appropriate by the Court.
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9 3 . The wrongful conduct of Defendants caused an extensive period of closure because

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they are a minority owned business frequented by African -American Patrons.

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94. Plaintiffs suffered damages legally caused by the Defendants' unfair business
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practices, which is incorporated here to the extent pertinent as set forth here in full.
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9 5 . The exact amount is currently not ascertained but will be shown according to proof
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at the time of trial herein.
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NINTH CAUSE OF ACTION
2 (RACIAL DISCRIMINATION)
4 96. Plaintiff restates and incorporates by reference each and every allegation contained i
the paragraphs one (1 ) through Ninety-Five (95) as fully set forth herein.
5
97. Defendant is a government entity and should be held to higher standard as a public
6
entity in the State of California.

7
9 8 . Defendants discrimination against Plaintiff is obvious, prevalent, and transparent that

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it is based on race. There are not many minority businesses in Rialto and one thing is
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apparent, is that Raquel's is not welcomed at its present location because Plaintiffs
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business primary demographic is African-Americans.
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99. Moreover, facts will show that Mayor Robertson made the suggestion to a location
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that is more "minority-friendly" and not in the heart of the city where it is clear a
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1 0 0 . Ultimately, Defendants are uncomfortable with Raquel's Jazz Lounge being at its
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18 10 1. Finally, Mayor Robertson believed Defendants could intimidate Plaintiffs and
force them to leave and take their business to another location, city, or another
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county.
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1 0 2 . Had Defendant's relocated the Defendants scheme would have continued in

21
additional issues with the Plaintiffs business and we are confident Defendant would
22
not have allowed the new location to open and Defendants were confident they
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would be able to discourage Plaintiffs and preclude them from re-opening.

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1 0 3 . Plaintiff has stood through numerous trials and tribulations at its current location
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which has been its home for the last three years. Plaintiffs have been treated
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differently from all other businesses repeatedly, because the Mayor has a personal
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grudge against Plaintiff Palmer and Defendants do not like the African-American
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presence at the location the business is currently located.
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104. Therefore, Defendants will continue to thwart the Plaintiffs business goals and
2 discourage and harass them as they have continuously done in the past.
3 10 5 . The exact amount Plaintiffs have lost is currently not ascertained but will be shown
4 according to proof at the time of trial.
WHEREFORE, Plaintiffs pray for judgment against Defendants as follows:

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1. For general damages according to proof;

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2. For special damages and related expenses according to proof;

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9 3. For loss of earnings according to proof;
10 4. For costs of suit herein incurred;
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5. For prejudgment interest;
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6. For post judgment interest; and
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7 5 5 7. For such other and further relief as the court may deem just and property.
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DATED: June 1 , 2018. Respectfully Submitted,
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a} 17 LAW OFFICES OF THEIDA SALAZAR
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18
19 By:
--------------
THE ID A SALAZAR
20
Attorney for Plaintiffs
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CM-010
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):
Theida Salazar, Esq. (SBN 295547)
2 1 4 0 North Hollywood Way, #7192

R'CED•
r Court of California
Burbank, CA 9 1 5 1 0 upertot j
Ce tw of Los A n g el e s
oun ·
TELEPHONE NO.: 8 1 8 . 4 3 3 . 7290 FAXNO.: 8 1 8 . 4 3 6 .4 0 0 9
ATTORNEY FOR (Name): Plaintiff JUN 0 1 2018

SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
·. «uuve oncer&erk of Court
STREET ADDRESS: 1 1 1 North Hill St.
t
r r 1 rt. . � , D e p u ty
MAILING ADDRESS:
c
cTY AND zIP cope: Los Angeles, 9 0 0 1 2 Y. -....%.%a.
BRANCH NAME: Central
CASE NAME:
Palmer, et al v. City of Rialto

--
CIVIL CASE COVER SHEET Complex Case Designation g C 7 0 8 4 8 0
( Unlimited c Limited
[l counter [l Joiner
(Amount (Amount
JUDGE:
demanded demanded is Filed with first appearance by defendant
exceeds $25,000) $25,000 or less) (Cal. Rules of Court, rule 3.402) DEPT:
Items 1-6 below must be completed (see instructions on page 2).
1. Check one box below for the case type that best describes this case:
Auto Tort Contract Provisionally Complex Clvll Litigation
D Auto (22) D Breach of contract/warranty (06)

(Cal. Rules of Court, rules 3.400--3.403)
D Uninsured motorist (46) D Rule 3.740 collections (09) c Antitrust/Trade regulation (03)
Other PI/PD/WD (Personal Injury/Property D Other collections (09) c Construction defect (10)
Damage/Wrongful Death) Tort D Insurance coverage (18) c Mass tort (40)
D Asbestos (04) D Other contract (37) D Securities litigation (28)

D Product liability (24)
Real Property D Environmental/Toxic tort (30)
D Medical malpractice (45) D Eminent domain/Inverse
D Insurance coverage claims arising from the
[ ouer PvPowo (2s) condemnation (14) above listed provisionally complex case
types (41)
Non-PI/PD/WD (Other) Tort
D Wrongful eviction (33)
[@ omer real property (26) Enforcement of Judgment

D Business tort/unfair business practice (07)
[Z crones «oe) Unlawful Detainer [l entorcement of judgment (20)
[l oetamaton (13) D Commercial ( 3 1 ) Miscellaneous Civil Complaint
[Z] rau@ (e El Resdental (32) [l aco @7
D Intellectual property ( 1 9 ) D Drugs (38) [v ouer complaint (not specified above) (42)
D Professional negligence (25) Judicial Review

Miscellaneous Civil Petition
D Other non-Pl/PD/WO tort (35) D Asset forfeiture (05)

D Partnership and corporate gove rnance ( 2 1 )
Employment D Petition re: arbitration award ( 1 1 )
D Other petition (not specified above) (43)
D Wrongful termination (36) D Writ of mandate (02)
D Other employment (15) D Other judicial review (39)
2. This case LJ is W is not complex under rule 3.400 of the California Rules of Court. If the case is complex, mark the
factors requiring exceptional judicial management:
a. D Large number of separately represented parties d. D Large number of witnesses
»L Extensive motion practice raising difficult or novel e. [l 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. D Substantial amount of documentary evidence f. D Substantial postjudgment judicial supervision
3. Remedies sought (check all that apply): a . CZ] monetary b. [l nonmonetary; declaratory or injunctive relief c. D punitive
4. Number of causes of action (specify): 1
5. This case D is 0 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: 06/01/2018 ��
7 / ..,/ _
Theida Salazar, Esg. ) [
@PF oR RiNf NAME)j Aro#Rev

servo#
Foamy
rs@Nr'la~or
e
s NOTICE
�-· Plaintiff must file this cover sheet with the first paper filed in the action or proceeding (except small claims cases or cases filed
2; under the Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.) Failure to file may result
,
i in sanctions.
• File this cover sheet in addition to any cover sheet required by local court rule.
• If this case is complex under rule 3.400 et seq. of the California Rules of Court, you must serve a copy of this cover sheet on all
= 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.
' aae1of2
Form Adopted tor Mandatory use CIVIL CASE COVER SHEET cat. mutes of count, rules 2.30, 3.220, 3.400-3.403, 3.740;
Judicial Council of California Cal. Standards of Judicial Administration, std. 3.10
CM-O10 [Rev. July 1 , 2007] www.courtinto.ca.gov

CM-010
INSTRUCTIONS ON HOW TO COMPLETE THE COVER S H E E T
To Plaintiffs and Others Filing First Papers. If you are fi l i n g a first paper (for example, a complaint) in a civil case, you must
complete and fi l e , 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 n u m b e rs 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 i n i ti a l paper. Failure to fi l e a cover sheet with the first paper filed in a civil case may subject a p a rty ,
its counsel, or both to sanctions under rules 2.30 and 3.220 of the C a l i fo rn i a Rules of Court.
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 w i ll 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 will 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 Sheet to designate whether the
case is complex. If a p l a i n t i ff believes the case is complex under rule 3.400 of the C a l i fo rn i a Rules of C o u rt , this must be indicated by
completing the appropriate boxes in items 1 and 2. If a p l a i n ti ff designates a case as complex, the cover sheet must be served with the
complaint on all parties to the action. A defendant may file and serve no later than the time of its first appearance a joinder in the
p l a i n ti ff s 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 Contract Provisionally Complex Civil Litigation (Cal.
Auto (22)-Personal Injury/Property Breach of Contract/Warranty (06) Rules of Court Rules 3.400-3.403)
Damage/Wrongful Death Breach of Rental/Lease Antitrust/Trade Regulation (03)
Contract (not unlawful detainer Construction Defect (10)

Uninsured Motorist (46) (if the
or wrongful eviction) Claims Involving Mass Tort (40)
case involves an uninsured
Contract/Warranty Breach-Seller Securities Litigation (28)
motorist claim subject to
Plaintiff (not fraud or negligence) Environmental/Toxic Tort (30)

arbitration, check this item
instead of Auto) Negligent Breach of Contract/ Insurance Coverage Claims
Warranty (arising from provisionally complex

Other PI/PD/WD (Personal Injury/
Other Breach of Contract/Warranty case type listed above) (41)
Property Damage/Wrongful Death)
Collections (e.g., money owed, open Enforcement of Judgment
Tort
book accounts) (09) Enforcement of Judgment (20)
Asbestos (04)
Collection Case-8eller Plaintiff Abstract of Judgment (Out of
Asbestos Property Damage
County)
Asbestos Personal Injury/ Other Promissory Note/Collections
Case Confession of Judgment (non

Wrongful Death
Insurance Coverage (not provisionally domestic relations)
Product Liability (not asbestos or
complex) (18) Sister State Judgment
toxic/environmental) (24)
Auto Subrogation Administrative Agency Award
Medical Malpractice (45)
Other Coverage (not unpaid taxes)
Medical Malpractice-
Petition/Certification of Entry of
Physicians & Surgeons Other Contract (37)
Judgment on Unpaid Taxes
Other Professional Health Care Contractual Fraud
Other Enforcement of Judgment
Malpractice Other Contract Dispute
Case
Other PIIPDWD (23) Real Property
Miscellaneous Civil Complaint
Premises Liability (e.g., slip Eminent Domain/Inverse
RICO (27)
and fall) Condemnation (14)
Other Complaint (not specified
Intentional Bodily Injury/PD/WO Wrongful Eviction (33)
above) (42)
(e.g., assault, vandalism) Other Real Property (e.g., quiet title) (26)
Declaratory Relief Only
Intentional Infliction of Writ of Possession of Real Property
Injunctive Relief Only (non-
Emotional Distress Mortgage Foreclosure
harassment)
Negligent Infliction of Quiet Title
Mechanics Lien
Emotional Distress Other Real Property (not eminent
Other Commercial Complaint
Other Pl/PD/WO domain, landlord/tenant, or
Case (non-tort/non-complex)
Non-Pl/PD/WO (Other) Tort foreclosure)
Other Civil Complaint
Business Tort/Unfair Business Unlawful Detainer
(non-tort/non-complex)
Practice (07) Commercial ( 3 1 )
Miscellaneous Civil Petition
Civil Rights (e.g., discrimination, Residential (32)
Partnership and Corporate
false arrest) (not civil Drugs (38) (if the case involves illegal
Governance ( 2 1 )
harassment) (08) drugs, check this item; otherwise,
Other Petition (not specified
Defamation (e.g., slander, libel) report as Commercial or Residential)
above) (43)
(13) Judicial Review
Civil Harassment
Fraud ( 1 6 ) Asset Forfeiture (05)
Workplace Violence
Intellectual Property (19) Petition Re: Arbitration Award ( 1 1 )
Elder/Dependent Adult
Professional Negligence (25) Writ of Mandate (02)
Abuse
_, Legal Malpractice Writ-Administrative Mandamus
Election Contest
' Other Professional Malpractice Writ-Mandamus on Limited Court
Petition for Name Change
a. (not medical or legal) Case Matter
Petition for Relief From Late
Other Non-PI/PDWD Tort (35) Writ-Other Limited Court Case Claim
Employment
Review Other Civil Petition
Wrongful Termination (36)
Other Judicial Review (39)
Other Employment ( 1 5 )
Review of Health Officer Order
Notice of Appeal-Labor
Commissioner Appeals
cw-of[Re. Juy 1. 2zoo7 Page 2 of 2
CIVIL CASE COVER SHEET

SH~RT TITLE; .. • CASE NUMBER
Palmer, et al. v City of Rialto
CIVIL CASE COVER SHEET A D D E N D U M AND
STATEMENT OF LOCATION
(CERTIFICATE OF G R O U N D S FOR A S S I G N M E N T TO C O U R T H O U S E LOCATION)
This form is required pursuant to Local Rule 2.3 in all new civil case fi l i n g s in the Los Angeles Superior Court.
Step 1 : After c o m p l e t i n g the Civil Case Cover Sheet ( J u d i ci a l C o u n ci l form CM-010), fi n d t h e exact case type in
C o l u m n A that c o r r e s p o n d s to the case type i n d i c a t e d in the Civil Case Cover Sheet.
Step 2: I n C o l u m n B, check the box for the type of action that best describes the nature of t h e case.
Step 3: I n C o l u m n C, circle the n u m b e r w h i c h e x p l a i n s the reason for t h e court fi l i n g location you have
chosen.
Applicable Reasons for Choosing Court Filing Location (Column C)
1 . Class actions must be filed in the Stanley Mosk Courthouse, Central District. 7. Location where petitioner resides.
2. Permissive filing in central district. 8. Location wherein defendant/respondent functions wholly.
3. Location where cause of action arose. 9. Location where one or more of the parties reside.
4. Mandatory personal injury filing in North District. 1 0 . Location of Labor Commissioner Office.
11. Mandatory filing location ( H u b Cases - unlawful detainer, limited

5. Location where performance required or defendant resides.
non-collection, limited collection, or personal injury).
6. Location of property or permanently garaged vehicle.
A B C
C i Case
v i Cover
l Sheet Type of Action Applicable Reasons
Category No. (Check only one) See Step 3 Above
Auto (22) D A7100 Motor Vehicle - Personal Injury/Property Damage/Wrongful Death 1 , 4 , 11
o t
5
«t Uninsured Motorist (46) D A 7 1 10 Personal Injury/Property Damage/Wrongful Death -- Uninsured Motorist 1,4 , 1 1
D A6 070 Asbestos Prope rty Damage 1 , 1 1
Asbestos (04 )
D A7221 Asbestos - Personal Injury/Wrongful Death 1 , 1 1
F e
o
f.
Product ability (24) D A72 0 Product abili not asbestos or to ic/environmental)
e Li 6 Li ty ( x 1 , 4 , 1 1
£
a. «
- QI
z o 1 , 4 , 1 1
D A 72 10 Medical Malpractice - Physicians & Surgeons
=
£ %
5 Medical Malpractice (45)
1 , 4 , 1 1
D A7 240 Other Professional Health Care Malpractice

«
9
g = D A7 25 0 Premises Liability ( e. g. , slip and fa ll)
a 1 , 4 , 1 1
Other P ersonal
¢ E - D A72 3 0 Int e ntional B odily Injury/Prope rty Dama g e/Wrongful Death (e.g.
Injury Prope
d E rty
1 , 4 , 1 1
.c c assault , vandalism , etc.)

Damage W ron g ful
5 o
1 , 4 , 1 1
Death (23)
£ A7270 Intentional In fl iction of E motional Distress
1 , 4 , 1 1
..
D A7220 Other Personal Injury Property Damage/Wrongful Death
/
LAci09 (Rev 2/16) CIVIL CASE COVER S H E E T A D D E N D U M Local Rule 2.3
LA SC Approved 03-04 AND STATEMENT OF LOCATION Page 1 f

o 4
SHORT TITLE: • • CASE NUMBER
A B C Applicable
Civil Case Cover Sheet Type of Action Reasons - See Step 3
Category No. (Check only one) Above
Business Tort (07) A6029 Other Commercial/Business Tort (not fraud/breach of contract) 1 , 2, 3
□
t'
t: 6
p Civil Rights (08) .2 A6005 Civil Rights/Discrimination 1 , 2, 3
£ c
e =
23 Defamation ( 1 3 ) A6010 Defamation (slander/libel) 1 , 2, 3
- £
□
?
2 =
·£
--o
Fraud ( 1 6 ) A6013 Fraud (no contract) 1 , 2, 3
L □
% 9
8 5
(/}
...
. Cl) □ A6017 Legal Malpractice 1 , 2, 3
g Professional Negligence (25)
a. ¢d
[ A6050 Other Professional Malpractice (not medical or legal) 1 , 2 , 3
± E
o t
z c
Other (35) A6025 Other Non-Personal Injury/Property Damage tort 1 , 2, 3
□
Wrongful Termination (36) A6037 Wrongful Termination 1 , 2, 3

z □
0
E
>.
0 □ · A6024 Other Employment Complaint Case 1 , 2 , 3
a Other Employment ( 1 5 )
A6109 Labor Commissioner Appeals 10

£ □
w
A6004 Breach of Rental/Lease Contract (not unlawful detainer or wrongful

□ 2,5
eviction)
Breach of Contract/ Warranty 2,5

A6008 Contract/Warranty Breach -Seller Plaintiff (no fraud/negligence)
(06) □
1 , 2 , 5
(not insurance)
A6019 Negligent Breach of ContracUWarranty (no fraud)
□
1 , 2, 5
A6028 Other Breach of Contract/Warranty (not fraud or negligence)
□
t A6002 Collections Case-Seller Plaintiff 5,6, 11

□
� Collections (09)
- c
0 □ A6012 Other Promissory Note/Collections Case 5, 1 1
€
A6034 Collections Case-Purchased Debt (Charged Off Consumer Debt 5, 6, 1 1
□
Purchased on or after Januarv 1 , 2014)
Insurance Coverage ( 1 8 ) A6015 Insurance Coverage (not complex) 1,2,5,8

□
A6009 Contractual Fraud 1 , 2, 3, 5

□
Other Contract (37) A6031 Tortious Interference 1 , 2, 3 , 5
□
A6027 Other Contract Dispute(not breach/insurance/fraud/negligence) 1 , 2 , 3 , 8 , 9
□
Eminent Domain/Inverse
A7300 Eminent Domain/Condemnation Number of parcels_ 2, 6
Condemnation ( 1 4 )
□
Wrongful Eviction (33) A6023 Wrongful Eviction Case 2,6

□
A6018 Mortgage Foreclosure 2, 6

□
Other Real Property (26) A6032 Quiet Title 2,6
□
A6060 Other Real Property (not eminent domain, landlord/tenant, foreclosure) 2,6
□
Unlawful Detainer-Commercial
A6021 Unlawful Detainer-Commercial (not drugs or wrongful eviction) 6, 1 1
(31)
□
Unlawful Detainer-Residential
A6020 Unlawful Detainer-Residential (not drugs or wrongful eviction) 6 , 1 1
(32) □
Unlawful Detainer-
A6020F Unlawful Detainer-Post-Foreclosure 2, 6, 1 1
Post-Foreclosure (34)
□
Unlawful Detainer-Drugs (38) A6022 Unlawful Detainer-Drugs 2, 6, 1 1

□
.,.,,_
LACIV 109 (Rev 2/16) CIVIL CASE COVER S H E E T A D D E N D U M Local Rule 2 . 3
LASC Approved 03-04 AND STATEMENT OF LOCATION Page 2 of 4

SHORT TITLE: CASE NUMBER
A B C Applicable
Civil Case Cover Sheet Type of Action Reasons - See Step 3
Category No. (Check only one) Above
Asset Forfeiture (05) A6108 Asset Forfeiture Case 2, 3, 6

□
Petition re Arbitration ( 1 1 ) A6115 Petition to Compel/ConfirmNacate Arbitration 2,5

□
A6151 Writ - Administrative Mandamus 2,8

□
Writ of Mandate (02) A6152 Writ - Mandamus on Limited Court Case Matter 2
□
A6153 W ri t - Other Limited Court Case Review 2
□
Other Judicial Review (39) A6150 Other Writ /Judicial Review 2, 8

□
Antitrust/Trade Regulation (03) A6003 Antitrust/Trade Regulation 1 , 2 , 8

c
□
9
cu
Construction Defect ( 1 0 ) A6007 Construction Defect 1 , 2, 3
□
9
::i
K Claims Involving Mass Tort
A6006 Claims Involving Mass Tort 1 , 2 , 8
G)
(40)
□
a
E
0
Securities Litigation (28) A6035 Securities Litigation Case 1 , 2 , 8
C □

«
c
0
Toxic Tort
Environmental (30)
□ A6036 Toxic Tort/Environmental 1 , 2, 3, 8
V
5
e Insurance Coverage Claims
A6014 Insurance Coverage/Subrogation (complex case only) 1 , 2, 5, 8
a. from Complex Case ( 4 1 )
□
A6141 Sister State Judgment 2, 5, 1 1

□
A6160 Abstract of Judgment 2,6
□
- -
c
0
£
c
A6107 Confession of Judgment (non-domestic relations) 2,9
E E Enforcement □
a 0
9 g of Judgment (20)
A6140 Administrative Agency Award (not unpaid taxes) 2,8
□
$
5
=
s □ A6114 Petition/Certificate for Entry of Judgment on Unpaid Tax 2, 8
A6112 Other Enforcement of Judgment Case 2,8,9

□
RICO (27) A6033 Racketeering (RICO) Case 1 , 2, 8

□
A6030 Declaratory Relief Only 1 , 2, 8

□
A6040 Injunctive Relief Only (not domestic/harassment) 2,8
Other Complaints □
(Not Specified Above) (42)
A6011 Other Commercial Complaint Case (non-tort/non-complex) 1 , 2 , 8
□
A6000 Other Civil Complaint (non-tort/non-complex) 1 , 2, 8
□
Partnership Corporation
A6113 Partnership and Corporate Governance Case 2, 8
Governance ( 2 1 )
□
, A6121 Civil Harassment 2, 3, 9
A6123 Workplace Harassment 2, 3, 9

□
A6124 Elder/Dependent Adult Abuse Case 2, 3, 9
□
Other Petitions (Not
Specified Above) (43) A6190 Election Contest

□ 2
A6110 Petition for Change of Name/Change of Gender

□ 2,7
A6170 Petition for Relief from Late Claim Law

□ 2, 3, 8
• □ A6100 Other Civil Petition

2,9
-�-
LACIV 109 (Rev 2/16) C I V I L CASE COVER S H E E T A D D E N D U M Local Rule 2.3

SHORT TITLE: CASE NUMBER
Step 4: Statement of Reason and Address: Check the appropriate boxes for the n u m b e r s shown u n d e r C o l u m n C for the
type of action that you have selected. Enter the address w h ic h is t h e basis for the fi l i n g location, i n c l u d i n g z i p code.
{ N o address r e q u i r e d for class a c t i o n cases).
ADDRESS:
REASON: 26424 Misty Ridge Pl
1 . 2 2 . 3 . 4 . 0 5 . 0 6 . 0 7 . 07 8 . 0 9.010.1 1 .
CITY: STATE: ZIP CODE:
Canyon Country CA 91387

:
Step 5: Certification of Assignment: I certify that this case is properly filed in the CENTRAL District of
the Superior Court of C a l i fo rn i a , County of Los Angeles [Code Civ. Proc., §392 et seq., a n d Local R u l e 2 . 3 { a )( l )( E ) ] .
Dated: 06/01/2018
(SIGNATURE OF ATTORNEY/FILING PARTY)
PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE F I L E D I N ORDER TO PROPERLY
C O M M E N C E Y O U R 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, J u d i c i a l Council form C M - 0 1 0 .
4. Civil Case Cover Sheet Addendum and Statement of Location form, LACIV 1 0 9 , LASC Approved 03-04 (Rev.
02/16).
5. Payment in full of the filing fee, unless there is court order for waiver, partial or scheduled payments.
6. A signed order appointing the Guardian ad Litem, J u d i ci a l Council form C I V - 0 1 0 , if the plaintiff or petitioner is a
minor under 1 8 years of age will be required by Court in order to issue a s u m m o n s .
7. Additional copies of documents to be conformed by the Clerk. Copies of the cover sheet and this a d d e n d u m
must be served along with the summons and complaint, or other initiating pleading in the case.
°
LACIV 109 (Rev 2/16) C I V I L CASE COVER S H E E T A D D E N D U M Local Rule 2.3

Palmer Sues Rialto 1741246546 (1-22)

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I THEIDA SALAZAR SBN: 2 9 5 5 4 7

LAW OFFICES OF THEIDA SALAZAR

[email protected] Countv of Los Angeles

SUPERIOR COURT OF THE STATE OF CRTik&NA"

COUNTY OF LOS ANGELES-CENTRAL

10 EDWARD PALMER, E S Q . , an individual; Case No.:

ERIC WILSON, an individual; PATRICK

4. Tortious Interference with Economic

5. Tortious Interference with Contract;

of the Business & Professions Code §

9. Discrimination on Basis of Race

LAINTIFFS DEMAND JURY TRIAL

their complaint against, Defendants City of Rialto.

1. Plaintiff Edward Palmer, Esq. is a resident of San Bernardino County, California.

COMPLAINT FOR DAMAGES

the State of California.

23 done in furtherance of the common design.

COMPLAINT FOR DAMAGES

8 C. Jurisdiction And Venue

contacts with Los Angeles County.

: ; ° action is proper pursuant to California Code of Civil Procedure § 3 9 3 .

COMPLAINT FOR DAMAGES

pay all licensing fees.

profitable St. Patrick's Day weekend.

COMPLAINT FOR DAMAGES

were told they could by the City.

19 FIRST CAUSE OF ACTION

(NEGLIGENCE, pursuant to Civil C o d e § 1714)

through thirty (30) as though fully set forth hereafter.

satisfy their debts in association with its business.

COMPLAINT FOR DAMAGES

had to be paid to remain open and service the community.

8 damages and significant financial loss.

through thirty-nine (39) as though fully set forth hereafter.

23 4 1 . Defendant willfully and intentionally engaged in fraud and misrepresentation as defined by

24 California Civil C o d e § 1 5 72 . Defendant, purposefully, recklessly, or intentionally or by

the St. Patrick's weekend.

COMPLAINT FOR DAMAGES

precluded the Plaintiffs from paying.

8 4 5 . Defendants created an unlawful scheme, to effectuate a closure of Plaintiffs business and

through forty-five (45) as though fully set forth hereafter.

grounds for believing them to be true, and were, in fact, reckless.

49. These misrepresentations were made directly by Defendants, by Ms. Gibson-

,28 amount ordered to pay .

COMPLAINT FOR DAMAGES

made by the Defendant to their detriment.

53. The reliance of Plaintiffs upon Defendants' misrepresentations was justified

a position to know the true facts.

54. As a direct, proximate, and foreseeable result of Defendants' negligent

(TORTIOUS INTERFERENCE WITH ECONOMIC ADVANTAGE}

through Fifty-Four (54) as though fully set forth hereafter.

24 5 6 . Mayor of Rialto knew that Plaintiffs enjoyed a harmonious economic relationship

caused her to attempt to break up the Plaintiffs business relationship.

COMPLAINT FOR DAMAGES

harass and disrupt their business.

because of their conduct.

21 (TORTIOUS INTERFERENCE WITH CONTRACT)

24 through Sixty - Four (64) as though fully set forth hereafter.

COMPLAINT FOR DAMAGES

6 harass and disrupt their business.

23 SIXTH CAUSE OF ACTION

{INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS)

74.Plaintiffrestates and incorporates by reference each and every allegation contained i