Electronically FILED by Superior Court of California, County of Los Angeles on 12/07/2020 05:46 PM Sherri R.

Carter, Executive Officer/Clerk of Court, by R. Perez,Deputy Clerk

20STCV46671
Assigned for all purposes to: Stanley Mosk Courthouse, Judicial Officer: Robert Broadbelt

1
ANNETTE MORASCH, SBN 263797
2
LAW OFFICE OF ANNETTE MORASCH, APC
5701 W. SLAUSON AVE., SUITE 210
3 CULVER CITY, CA 90230
PHONE: (323) 791-6276
4 FAX: (323) 617-5523
[email protected]
5
Attorney for Plaintiffs
6 Annette Turner and Tammy Davis
7

9 LOS ANGELES SUPERIOR COURT

STATE OF CALIFORNIA
10
ANNETTE TURNER, and Case No.
11
TAMMY DAVIS
12 COMPLAINT FOR DAMAGES AND
INJUNCTIVE RELIEF, AND
13 PLAINTIFF DEMAND FOR JURY TRIAL
14
vs.
15 1. Gender Discrimination under
AIDS HEALTHCARE Unruh Civil Rights Act, Civil
16
FOUNDATION, a California Code §51
17 Corporation; 2. Gender Discrimination under
VICTOR’S SERVICES, LLC, a Fair Employment and Housing
18 California limited liability Act, Gov’t Code §12955(a)
19
company; 3. Assault and Battery
TONY ROSITAS, an individual;
20 and
DOES 1-10, inclusive
21

22 DEFENDANT(s)

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24

25

26

27

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1
COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
1 TO THE COURT, DEFENDANTS AND THEIR ATTORNEYS OF RECORD:
2
Plaintiffs, Annette Turner and Tammy Davis, hereby allege as follows against
3
the following defendants: AIDS HEALTHCARE FOUNDATION, a California
4

5 Corporation; VICTOR’S SERVICES, LLC, a California Limited Liability Company;

6 TONY ROSITAS, an individual, and DOES 1-10 inclusive the following:

7
JURISIDICTION AND VENUE
8
1. This Court has personal jurisdiction over the parties because Plaintiffs reside
9

10
in the City and County of Los Angeles and all Defendants conduct business within

11 the City and County of Los Angeles.

12
2. Venue is proper in this court based on the fact that the real property which is
13
where all damages occurred in this action is located, specifically 423 E. 7 th Street,
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15
Los Angeles.

16 THE PARTIES
17
The Plaintiffs
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3. At all relevant times herein, Plaintiffs have been tenants of Defendant AIDS
19
HEALTHCARE FOUNDATION. AIDS HEALTHCARE FOUNDATION owns and
20

21 manages The Madison Hotel, located at 423 E. 7 th Street, Los Angeles (“The

22 Madison”). Plaintiff is a “tenant” within the meaning of Cal. Civ. Code §1940, et seq.
23
and Los Angeles Municipal Code (“LAMC”) §47.73(U).
24
4. Plaintiff, Annette Turner, is a woman, lives at The Madison, and is 57 years
25

26 old.

27 5. Plaintiff, Tammy Davis, is a woman, lives at The Madison, and is 50 years old.
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2
COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
1 The Defendants
2
6. Since September 27, 2017, Defendant AIDS HEALTHCARE FOUNDATION, a
3
California Corporation has owned and operated The Madison. The Madison is
4

5 located at 423 E. 7th Street, Los Angeles. The Madison Hotel is a “housing

6 accommodation” as defined by Gov’t Code §12927(d. AIDS HEALTHCARE

7
FOUNDATION is an “owner” within the definition of Cal. Gov’t Code §12927(e), a
8
“person” within the meaning of Cal. Gov’t Code §12955 et seq., and a “business
9

10
establishment” as defined under Cal. Civ. Code §51 et seq.

11 7. Defendant, VICTOR’S SERVICES, LLC is a California Limited Liability

12
Company. Upon information and belief, VICTOR’S SERVICES was, and remains, a
13
handyman service which did and does various repair and work assignments at the
14

15
direction of AIDS HEALTHCARE FOUNDATION at The Madison. Upon information

16 and belief, VICTOR’S SERVICES does not maintain a license as required by the
17
California Contractors State License Board. VICTOR’S SERVICES is a “business
18
establishment” as defined under Cal. Civ. Code §51 et seq.
19
8. Defendant, TONY ROSITAS, is, or was, an employee of VICTOR’S SERVICES,
20

21 and did various repairs and work assignments at the direction of AIDS

22 HEALTHCARE FOUNDATION at the Madison, including in the apartment unit of

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Plaintiff Tammy Davis.
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9. DOE 1 is a company or d/b/a of an unknown name and location, which has
25

26 provided “security guards” for the Madison. Upon information and belief, DOE 1 is a

27 “business establishment” as defined under Cal. Civ. Code §51 et seq.

28

3
COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
1 10. DOE 2 is a male individual “security guard” employed by either AIDS
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HEALTHCARE FOUNDATION, or DOE 1. DOE 2 works at the Madison.
3
11. Plaintiff Tammy Davis is informed and believes, that AIDS
4

5 HEALTHCARE FOUNDATION, VICTOR’S SERVICES, TONY ROSITAS, and DOES 3-

6 10, were, or are, the agent, ostensible agent, alter ego, representative, employer,
7
employee, joint venture, parent, subsidiary, affiliate, related entity, partner and/or
8
associate of each other, and were at all times acting and performing, or failing to act
9

10
or perform, within the course and scope of that agency and/or authorization and/or

11 ratification, and are therefore all responsible in some manner for the acts and
12
omissions of each other.
13
12. Plaintiff Annette Turner is informed and believes, that AIDS
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15
HEALTHCARE FOUNDATION, and DOES 1-10, were, or are, the agent, ostensible

16 agent, alter ego, representative, employer, employee, joint venture, parent,

17
subsidiary, affiliate, related entity, partner and/or associate of each other, and were
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at all times acting and performing, or failing to act or perform, within the course and
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scope of that agency and/or authorization and/or ratification, and are therefore all
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21 responsible in some manner for the acts and omissions of each other.

22 13. Plaintiffs are ignorant of the true names and capacities of defendants
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used herein as DOES 1 through 10, inclusive, and therefore sue these defendants by
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such fictitious names. Plaintiffs will amend this complaint to allege the defendants’
25

26 true names and capacities when ascertained.

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4
COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
1 14. As a direct and proximate result of the unlawful actions of Defendants
2 AIDS HEALTHCARE FOUNDATION, and DOES 1-10, Annette Turner has suffered,
3
and continues to suffer, monetary, and emotional damages.
4
15. As a direct and proximate result of the unlawful actions of Defendants
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AIDS HEALTHCARE FOUNDATION, VICTOR SERVICES, TONY ROSITAS, and DOES
6
3-10, Tammy Davis has suffered, and continues to suffer, monetary, physical and
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emotional damages.
8
STATEMENT OF FACTS
9
Facts Specific to Plaintiff Annette Turner
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11 16. Near the beginning of October 2020, security guards employed by either

12 AIDS Healthcare Foundation or DOES 1, 3-10, sexually harassed and discriminated

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against Plaintiff Annette Turner.
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17. As one example, DOE 2 is a male security guard is employed by DOE 1.
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DOE 2 said to Ms. Turner, “I don’t know if you’re a he, she, or what,” [and] “you’ve
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been here a long time, let me eat that pussy.” Ms. Turner reported this incident to
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AIDS HEALTHCARE FOUNDATION’S manager, and the company did nothing.
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18. Plaintiffs’ counsel also told inside legal counsel for AIDS HEALTHCARE
19

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FOUNDATION that this occurred. No one has spoken with Ms. Turner and the

21 security guard remains on duty.

22 19. In addition, a female security guard called Ms. Turner a “bitch” and “ho”

23 for absolutely no reason. Ms. Turner also reported this incident to AIDS Healthcare
24 Foundation. Plaintiffs’ counsel also reported this incident to AIDS Healthcare
25 Foundation’s inside legal counsel. No one has spoken to Ms. Turner and the female
26 security guard remains employed.
27 20. No one from AIDS HEALTHCARE FOUNDATION, DOE 1, or DOES 3-10
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ever contacted Ms. Turner concerning DOE 2 and these other female guards’

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COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
1 actions. Upon information and belief, none of these defendants took any action to
2 notify other residents of DOE 2, and the other security guards’ actions, nor did any
3
defendant take any steps to prevent additional sexual harassment occurring again at
4
The Madison
5
Facts Pertaining to Plaintiff Tammy Davis
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21. Ms. Davis uses a wheelchair.
7

8 22. In or around January 2020, Defendant TONY ROSITAS, employee of

9 VICTOR’S SERVICES, LLC, came to Tammy Davis’ (“Ms. Davis”) unit to do some
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maintenance work. When inside Ms. Davis’ unit, ROSITAS made inappropriate,
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sexual comments to Ms. Davis, and he purposefully brushed his arm against Ms.
12

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Davis’s breasts while working on her sink.

14 23. Ms. Davis and another tenant turned in a written complaint about Mr.
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Rositas to an AIDS Healthcare Foundation employee manning the front desk of The
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Madison. The written complaint stated words to the effect that Tony Rositas was
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sexually harassing Ms. Davis, and Ms. Davis did not feel comfortable with Mr.
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19 Rositas doing any future work in her unit.

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24. Defendants AIDS HEALTHCARE FOUNDATION, VICTOR’S SERVICES,
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and DOES 3-10 did not speak with Ms. Davis after she filed her complaint about Mr.
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Rositas, took no actions to investigate Ms. Davis’s complaint, and took no actions to
23

24 prevent sex discrimination and sexual assault at The Madison.

25 25. On June 8, 2020, Mr. Rositas returned to Ms. Davis’s unit to,
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supposedly, touch up the paint on Ms. Davis’s walls. While in her unit, Mr. Rositas
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COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
1 sexually assaulted Ms. Davis and made disgusting and sexually inappropriate
2
comments.
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26. Mr. Rositas asked Ms. Davis when she lost her virginity. Mr. Rositas
4

5 motioned to her bed and said, “This bed doesn’t make a lot of noise. Unless you’re a

6 screamer of course.” Mr. Rositas said, “I would really love to see your breasts one
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day,” or words to that effect. Mr. Rositas pulled down the neck of Ms. Davis’s shirt,
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exposing her breast, then caressing her breast with the back of his hand. Mr.
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Rositas then pulled up Ms. Davis’s skirt and slid his hand up her leg until he was

11 rubbing her vagina. Ms. Davis was frozen with fear and could not do anything to
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defend herself. Mr. Rositas looked at Ms. Davis’s pet cat and said to it, “Don’t worry,
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I’m not going to hurt your mommy.” When Mr. Rositas was finished sexually
14

15
assaulting Ms. Davis, he walked out of the unit saying, “You have a good evening. I

16 hope to get to see more of your tits later on.”

17
27. Ms. Davis called the police. Los Angeles Police Department came and
18
took a report. Ms. Davis told an AIDS HEALTHCARE FOUNDATION security guard,
19
named Carmel, (who may be employed by DOE 1), about Mr. Rositas sexually
20

21 assaulting Ms. Davis. Carmel wrote notes down on a post-it note while Ms. Davis

22 was speaking.
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28. Ms. Davis’s attorney immediately contacted inside counsel for the AIDS
24
HEALTHCARE FOUNDATION to inform them that Mr. Rositas had sexually
25

26 assaulted and harassed Ms. Davis.

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COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
1 29. Yet the next morning at approximately 8:30-9:00 a.m., Ms. Davis saw
2
Mr. Rositas inside The Madison, reporting for work as if nothing had happened. Ms.
3
Davis’s attorney immediately contacted counsel for AIDS HEALTHCARE
4

5 FOUNDATION, again requesting that Mr. Rositas be excluded from The Madison. At

6 11:50 a.m., Ms. Davis heard a loud pound on the wall, like someone had punched it.
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A few minutes later, Ms. Davis witnessed Mr. Rositas in his vehicle, about to leave
8
The Madison.
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30. Ms. Davis obtained a Temporary, and then a Permanent, Restraining

11 Order against Mr. Rositas. At the permanent restraining order hearing, Mr. Rositas
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was not credible in his denial of sexual harassment and sexual assault.
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31. No one from AIDS HEALTHCARE FOUNDATION, or VICTOR’S
14

15
SERVICES or DOES 3-10 ever contacted Ms. Davis concerning Mr. Rositas’ actions.

16 Upon information and belief, none of these defendants took any action to notify
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other residents of Mr. Rosita’s actions, nor did any defendant take any steps to
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prevent another sexual assault or sexual harassment occurring again at The
19
Madison.
20

21 32. Although Ms. Davis requested a deadbolt on her door, defendant AIDS

22 HEALTHCARE FOUNDATION, and DOES 2-10 failed to install a deadbolt for over a
23
week after the sexual assault.
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33. Upon information and belief, defendant AIDS HEALTHCARE
25

26 FOUNDATION continues to do business with VICTOR’S SERVICES at The Madison.

27 Upon information and belief, defendant AIDS HEALTHCARE FOUNDATION

28

8
COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
1 continues to do business with TONY ROSITAS at AIDS HEALTHCARE
2
FOUNDATION’S other residential rental properties within Los Angeles.
3

5 Concerning the Claims of both Ms. Davis and Ms. Turner

6 34. The actions of AIDS Healthcare Foundation, VICTOR’S SERVICES,

7 TONY ROSITAS, and DOES 1-10 as described herein were committed maliciously,
8 oppressively with the intent to injure Plaintiffs Ms. Davis and Ms. Turner, and/or
9 were done with a willful and conscious disregard of the Plaintiffs’ rights to be to be
10 free of unlawful gender harassment and discrimination.
11
35. The despicable actions of these defendants were deliberate and
12
intentional, and therefore entitle Plaintiffs to recover punitive damages in a sum
13
sufficient to punish and deter these defendants from future similar conduct.
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36. Pursuant to Cal. Civil Code §51 et seq. and Gov’t Code 12955 et seq, Ms.
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Davis and Ms. Turner seek, compensatory damages, punitive damages, attorneys’
16
fees and costs.
17

18 FIRST CAUSE OF ACTION

19
Violation of Unruh Civil Rights Act, Civil Code §51
20
(Tammy Davis against Defendants AIDS Healthcare Foundation, Victor’s Services,
21 LLC, and DOES 3-10)
(Annette Turner against Defendants AIDS Healthcare Foundation, DOE 1, DOE 3-10)
22

23 37. At all times relevant herein, the Unruh Civil Rights Act, Civil Code §51
24
has provided that “all persons…are free and equal and no matter what their sex…are
25
entitled to the full and equal accommodations, advantages, facilities, privileges, or
26
services in all business establishments of every kind whatsoever.”
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COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
1 38. The AIDS Healthcare Foundation’s executive and director level
2
employees knew, or should have known, that Victor’s Services and/or Tony Rositas,
3
and DOES 3-10, were not qualified to conduct repairs in the Madison. Upon
4

5 information and belief, AIDS Healthcare Foundation took absolutely no steps to

6 ensure Victor’s Services and Tony Rositas were competent and safe contractors to be
7
granted access into womens’ units.
8
39. The AIDS Healthcare Foundation’s executive and director level
9

10
employees knew, or should have known, that DOES 1-10 were not qualified to

11 provide “security” services at the Madison. Upon information and belief, AIDS
12
Healthcare Foundation took absolutely no steps to ensure DOES 1-10 were
13
competent and safe contractors to be granted access to womens’ units.
14

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40. Upon information and belief, AIDS HEALTHCARE FOUNDATION has

16 never provided any of its employees or contractors who work at the Madison,
17
training in sexual harassment, or gender discrimination.
18
41. AIDS HEALTHCARE FOUNDATION knew, or should have known,
19
especially after the verbal and written reports of sexual harassment at the hands of
20

21 contractors or employees at the Madison, that female tenants were unsafe. AIDS

22 HEALTHCARE FOUNDATION took no reasonable steps to protect its female tenants

23
from sexual predators.
24
42. VICTOR’S SERVICES owner knew, or should have known, that TONY
25

26 ROSITAS was not qualified, and could not be trusted, to be inside of females’ units.

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10
COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
1 VICTOR’S SERVICES took absolutely no steps to ensure its employees were
2
competent and safe contractors to be granted access into womens’ units.
3
43. Upon information and belief, VICTOR’S SERVICES has never provided
4

5 any of its employees or contractors who work at the Madison, training in sexual

6 harassment, or sex discrimination.

7
44. VICTOR’S SERVICES knew, or should have known, especially after the
8
verbal and written reports of sexual harassment at the hands of Tony Rositas, that
9

10
female tenants were unsafe. VICTOR’S SERVICES took no reasonable steps to

11 protect its female customers from Tony Rositas.

12
45. DOE 1, the company or d/b/a which employs or employed the male
13
“security guard” who sexually harassed Annette Turner, knew, or should have
14

15
known that DOE 2, and the other guards mentioned herein, were not qualified to

16 provide security in the Madison. Upon information and belief, DOE 1 took no steps
17
to ensure its employees are competent and safe contractors to be granted access into
18
womens’ living units.
19
46. Upon information and belief, DOE 1 has never provided any of its
20

21 employees or contractors training in sexual harassment, or sex discrimination.

22 47. DOE 1 knew, or should have known, especially after the verbal and
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written reports of sexual harassment about DOE 1’s employees, that female tenants
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were unsafe. DOE 1 took no reasonable steps to protect its female customers from
25

26 DOE 2.

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COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
1 SECOND CAUSE OF ACTION
2
DISCRIMINATION BASED ON GENDER, GOV’T CODE §12955(a)
3
(Both Plaintiffs against AIDS HEALTHCARE FOUNDATION and DOES 3-10)
4

5 48. Plaintiffs Tammy Davis and Annette Turner repeat all above facts, as

6 though fully set forth herein.

7
49. At all times relevant herein, Cal. Gov’t Code §12940a has prohibited
8
discrimination against a tenant based on gender.
9

10
50. Defendant, AIDS HEALTHCARE FOUNDATION, and DOES 3-10 have

11 discriminated against Plaintiffs on the basis of their gender.

12
51. The unlawful actions and inactions of these defendants as described
13
above were intended to cause injury, were taken with a conscious disregard to the
14

15
rights of the plaintiffs, and/or were an extreme departure from what a reasonable

16 person would do in the same situation.

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52. As a result of the above-described actions of AIDS HEALTHCARE
18
FOUNDATION, and DOES 3-10, Plaintiff Tammy Davis has suffered, and continues
19
to suffer, and will continue to suffer, irreparable loss and injury, including but not
20

21 limited to: violation of civil rights; physical assault; embarrassment; fear; anxiety;

22 severe emotional distress; humiliation; and, other general and special damages
23
according to proof at trial.
24
53. As a result of the above-described actions of AIDS HEALTHCARE
25

26 FOUNDATION, and DOES 3-10, Ms. Turner has suffered, and continues to suffer,

27 and will continue to suffer, irreparable loss and injury, including but not limited to:
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12
COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
1 violation of her civil rights; embarrassment; fear; anxiety; severe emotional distress;
2
humiliation; and, other general and special damages according to proof at trial.
3
54. Pursuant to Cal. Gov’t Code §12989.2, Plaintiffs are entitled to
4

5 compensatory damages, attorneys’ fees and costs.

6 55. Ms. Davis and Ms. Turner seek punitive damages against AIDS
7
HEALTHCARE FOUNDATION and DOES 3-10 as the sexual harassment, sex
8
discrimination, and sexual assault, were known by these defendants’ executive level
9

10
employees, yet defendants took no reasonable steps to prevent, remedy, or

11 investigate these unlawful actions.

12
THIRD CAUES OF ACTION
13
ASSAULT AND BATTERY
14

15
(Plaintiff Tammy Davis against Defendant Tony Rositas)

16 56. Plaintiff Tammy Davis repeats the facts she personally alleged above as
17
though fully incorporated herein.
18
57. Tony Rositas acted with intent to cause harmful and offensive contact of
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Tammy Davis. Mr. Rositas touched Ms. Davis in a harmful, offensive, and non-
20

21 consensual way. Mr. Rositas also implied he was going to touch Ms. Davis in the

22 future through his parting comment when leaving her room.

23
58. Because Mr. Rositas was and/or is an employee and/or agent of AIDS
24
HEALTHCARE FOUNDATION and/or VICTOR SERVICES, all of whom had access to
25

26 her room, Ms. Davis is reasonably fearful of Mr. Rositas.

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COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
1 59. Any reasonable woman in Ms. Davis’s position would be offended by the
2
touching, sexual comments, and threatening and ominous comments.
3
60. Ms. Davis seeks compensatory damages and punitive damages against
4

5 defendant Tony Rositas.

6 REQUEST FOR RELIEF

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PLAINTIFFS ask for relief as set forth below:
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A. Compensatory damages;
9

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B. Punitive and exemplary damages;

11 C. Statutory damages;
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D. For the first cause of action, Tammy Davis seeks from AIDS Healthcare
13
Foundation, Victor’s Services, and DOES 3-10, attorneys’ fees and costs for
14

15
prosecuting this action under Civil Code §51 et seq.;

16 E. For the first cause of action, Annette Turner seeks from AIDS Healthcare
17
Foundation, DOE 1 and DOES 3-10, attorneys’ fees and costs for
18
prosecuting this action under Civil Code §51 et seq.;
19
F. For the second cause of action, from AIDS Healthcare Foundation and
20

21 DOES 3-10, attorneys’ fees and costs for prosecuting this action, pursuant

22 to: Gov’t Code §12955 et seq., and §12989.2;

23
G. For prejudgment interest at the legal rate;
24
H. Such further relief as the Court deems just and proper.
25

26 I. Preliminary and permanent injunction causing the AIDS HEALTHCARE

27 FOUNDATION and DOES 3-10, their officers, agents and employees to:
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COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
1 a. Develop, implement, distribute to tenants, and post policies
2
concerning gender discrimination and how to make a complaint of
3
gender discrimination, in a public place at The Madison, the policies
4

5 to be consistent with FEHA (see, Dep’t Fair Empl. & Hous. V. O’Neill,

6 (Sep. 16, 2008) No. 08-08 FEHC Precedential Dec., 2008 WL

7
5869851, *12 (Cal. F.E.H.C.));
8
b. Provide, pay for, and attend anti-discrimination training, with a focus
9

10
on gender discrimination, how to handle gender discrimination

11 complaints, how to prevent discrimination, and how to investigate

12
claims of gender discrimination, and requirements of changing locks
13
after a sexual assault in one of AIDS HEALTHCARE FOUNDATION’S
14

15
units. (Id.) This requirement shall apply to Michael Weinstein, Mark

16 Dyer, and any other individual with supervisory and/or decision-

17
making duties at The Madison, including but not limited to property
18
managers, desk clerks and security guards;
19
c. Maintain rental records, including all gender discrimination or sexual
20

21 assault claims, for a duration of four (4) years, to allow monitoring of

22 Defendants’ rental practices, (See, Dept. of Fair Empl. & Hous. v.

23
Merribrook Apartments (1988) No. 88-19, FEHC Precedential Decs.,
24
1988 CEB 7, p 23, 1988 WL 242651, *17 (Cal. F.E.H.C.));
25

26 d. Post in a common area at The Madison, a notice of Defendants’

27 wrongdoing, and remedies granted therefor (See, Dept. of Fair Empl. &
28

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COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
1 Hous. v. Davis Realty Co., Inc. (Jan 23, 1987) No. 87-02 FEHC
2
Precedential Decs. 1986-87, CEB 5, pp. 27-28, 1987 WL 114850, *20
3
(Cal. F.E.H.C));
4

5 J. A judicial declaration that the AIDS HEALTHCARE FOUNDATION and

6 DOES 3-10 are engaging in conduct violative of the law;

7
K. For prejudgment interest at the legal rate;
8
L. Such further relief as the Court deems just and proper.
9

10
Plaintiff Tammy Davis against Defendant Tony Rositas

11 A. Compensatory damages according to proof;

12
B. Punitive damages to be determined at trial.
13
Dated: December 7, 2020 LAW OFFICE OF ANNETTE MORASCH
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__________________________________
17 Attorney for Plaintiffs
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COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
1 DEMAND FOR JURY TRIAL
2
Plaintiffs hereby request a jury trial on all cause of actions raised in this
3
complaint.
4

5 Dated: December 7, 2020 LAW OFFICE OF ANNETTE MORASCH

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__________________________________
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Attorney for Plaintiffs
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COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF