1 JASON W.

SCHAFF - SBN 244285

DAVID B. WITKIN -SBN 344145
2 SCHROEDER SCHAFF & LOW, INC.
2205 Plaza Drive, Suite 225
3 Rocklin, CA 95765
Telephone: (916) 672-6558
4 Facsimile: (916) 672-6602
5 Attorneys for Plaintiffs,
ADRIENNE SPOHR, THE ESTATE OF ROBERT G.
6 SPOHR, and THE ESTATE OF WENDY WOOD
7
8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 IN AND FOR THE COUNTY OF PLACER
10 ***
11 ADRIENNE SPOHR, an individual; THE CASE NO.
ESTATE OF ROBERT G. SPOHR; and THE Complaint filed:
12 ESTATE OF WENDY WOOD, Trial Date: not set
13 Plaintiffs,
14 vs. PLAINITFFS' COMPLAINT FOR
DAMAGES AND DEMAND FOR
15 ERIN R. SPOHR, an individual; DANIEL JURY TRIAL
SERAFINI, an individual; and DOES 1
16 through 10, inclusive, 1. WRONGFUL DEATH
2. SURVIVAL AND SURVIVAL
17 Defendants. DAMAGES
3. INTENTIONAL INFLICTION OF
18 EMOTIONAL DISTRESS
4. PUNITIVE DAMAGES
19
20 UNLIMITED CIVIL CASE
JURY TRIAL DEMANDED
21
22 Plaintiffs ADRIENNE SPOHR, THE ESTATE OF ROBERT G. SPOHR, and THE
23 ESTATE OF WENDY WOOD (collectively, "Plaintiffs"), by and through the undersigned
24 counsel, allege that at all pertinent times in this complaint, upon information and
25 belief, as follows:
26 INTRODUCTION
27 1. Plaintiffs bring this action for damages against Defendants ERIN R.
28 SPOHR, DANIEL SERAFINI, (collectively, "Defendants"}, and DOES 1 through 10,
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COMPLAINT FOR DAMAGES
1 inclusive, for damages Plaintiffs suffered arising out of the senseless murder of Plaintiff
2 ADRIENNE SPOHR and Defendant ERIN R. SPOHR's Father, Robert Gary Spohr and
3 the shooting of Plaintiff ADRIENNE SPOHR and Defendant ERIN R. SPOHR's Mother,
4 Wendy Wood, eventually resulting in the death of Wendy Wood.
5 2. On Saturday, June 5, 2021, a masked and hooded man ran up the driveway
6 toward the Homewood/West Lake Tahoe home of Robert Gary Spohr and Wendy Wood.
7 Hours later, Placer County authorities found Mr. Spohr dead from a point-blank gunshot
8 wound. Ms. Wood was clinging to life with two gunshot wounds to the brain. Ms. Wood
9 subsequently died because of the June 5, 2021, incident.
10 JURISDICTION AND VENUE
11 3. This Court has jurisdiction over this matter pursuant to Code of Civil
12 Procedure§§ 395(a) and 410.10 because the injury causing death occurred in Placer
13 County, California, rendering the exercise of jurisdiction over Defendants in California
14 Courts consistent with the notions of fair play and substantial justice. This Court
15 further has jurisdiction in rem over real property located in Placer County, California
16 and is at issue in this matter.
17 4. Venue is proper in Placer County pursuant to Code of Civil Procedure§ 395
18 because the injury causing death occurred in Placer County, California, and because
19 Plaintiffs suffered harm in Placer County, California.
20 PARTIES
21 5. Plaintiff ADRIENNE SPOHR is a resident of Sonoma County, California
22 and is the surviving daughter of decedents Robert Gary Spohr and Wendy Wood.
23 6. Plaintiff THE ESTATE OF ROBERT G. SPOHR is represented by and
24 through its Successor-in-interest ADRIENNE SPOHR pursuant to California Code of Civil
25 Procedure section 377 .60.
26 7. Plaintiff THE ESTATE OF WENDY WOOD is represented by and through its
27 Successor-in-interest ADRIENNE SPOHR pursuant to California Code of Civil Procedure
28 section 377.60.
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COMPLAINT FOR DAMAGES
1 8. Defendant ERIN R. SPOHR is a resident of Reno, Nevada.
2 9. Defendant DANIEL SERAFINI is a resident of Reno, Nevada.
3 10. The true names and capacities, whether individual, corporate, associate, or
4 otherwise of Defendants DOES 1 through 10, are unknown to Plaintiffs who, under Code
5 of Civil Procedure § 474, sue these DOE Defendants under fictitious names. Plaintiffs
6 will amend this complaint to show the true names and capacities of DOE Defendants
7 when they are ascertained. Each of the DOE Defendants is in some manner legally
8 responsible for the occurrences alleged in in this complaint, and Plaintiffs damages as
9 alleged were legally caused by each of those DOE Defendants.
10 11. At all relevant times, each of the Defendants were the partners, principals,
11 agents, employees, servants, and joint venturers of each other, and in doing the things
12 alleged in in this complaint were acting within the course and scope of their authority
13 and relationship as partners, principals, agents, employees, servants, and joint venturers
14 with the permission, knowledge, and consent of each other.
15 RELEVANT FACTUAL ALLEGATIONS
16 12. According to authorities, the June 5, 2021, heinous murder of Robert Gary
17 Spohr and attempted murder of Wendy Wood, eventually leading to Wood's death, were
18 premeditated and planned. Indeed, Robert Gary Spohr and Wendy Wood (collectively,
19 "Plaintiffs Decedents") were targeted by the masked, hooded assailant.
20 13. Wendy Wood spent a month in the Intensive Care Unit and several weeks
21 in rehab. Wood was forced to relearn basic skills, including how to walk, talk, and eat
22 again. She never regained memory of the June 5, 2021, incident. Eventually, her
23 injuries stemming from the June 5, 2021, incident led to her death.
24 14. Plaintiff ADRIENNE SPOHR and Defendant ERIN R. SPOHR share
25 property gifted to them by their Parents, Plaintiffs Decedents, including real property
26 located in Placer County, California.
27 ///
28 Ill
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COMPLAINT FOR DAMAGES
1 15. In April of 2023, the Placer County Sheriffs Office confirmed new
2 developments in the "cold case" regarding the shooting of Plaintiffs Decedents. In a
3 social media post, the office confirmed that the suspects may reside in the Reno area. 1
4 GENERAL ALLEGATIONS
5 FIRST CAUSE OF ACTION
6 Wrongful Death (Against all Defendants)
7 16. Plaintiffs incorporate by reference and reallege each and every allegation
8 and statement contained in the prior paragraphs.
9 17. Plaintiffs are informed and believe, and thereon allege, that Defendants,
10 and each of them, including DOES 1 through 10, inclusive, caused, conspired to cause, or
11 otherwise participated in causing, the premeditated and planned June 5, 2021, murder
12 of Robert Gary Spohr and attempted murder of Wendy Wood, eventually leading to
13 Wood's death.
14 18. The aforementioned subject incident giving rise to this wrongful death and
15 survival action proximately and legally caused Plaintiffs Decedents to suffer fatal
16 mJunes.
17 19. Plaintiffs are further informed and believe, and thereon allege, that
18 Defendants, and each of them, including DOES 1 through 10, inclusive, were agents,
19 servants, employees, successors, joint venturers, co-conspirators, and/or successors-in-
20 interest of their co-defendants, who were acting within the course, scope, and authority
21 of said agency, employment and or venture, and/or in furtherance of said conspiracy in
22 causing the aforementioned subject incident to occur.
23 20. As a legal, direct, and proximate result of the malicious, despicable, cruel,
24 and unjust conduct of Defendants, and each of them, including DOES 1 through 10,
25 inclusive, as described in this complaint, Plaintiffs have sustained damages resulting
26

27

28 https://www.facebook.com/photo/?fbicl=61G019527226G01&set=a.217808103714414
4
COMPLAINT FOR DAMAGES
1 from the loss of love, affection, society, service, comfort, support, right of support,
2 expectations of future support and counseling, companionship, solace, and mental
3 support, as well as other benefits and assistance of Plaintiffs Decedents, all to their
4 general damages in a sum in excess of the jurisdictional limits of this Court, which will
5 be stated according to proof, pursuant to Section 425.10 of the California Code of Civil
6 Procedure.
7 21. As a legal, direct, and proximate result of the malicious, despicable, cruel,
8 and unjust conduct of Defendants, and each of them, including DOES 1 through 10,
9 inclusive, as described in this complaint, Plaintiffs will be deprived of the financial
10 support and assistance of Plaintiffs Decedents, the exact amount of such losses to be
11 stated according to proof, pursuant to Section 425.10 of the California Code of Civil
12 Procedure.
13 22. As a legal, direct, and proximate result of the malicious, despicable, cruel,
14 and unjust conduct of Defendants, and each of them, including DOES 1 through 10,
15 inclusive, as described in this complaint, Plaintiffs have incurred property, medical,
16 funeral and burial expenses in an amount to be stated according to proof, pursuant to
17 Section 425.10 of the California Code of Civil Procedure.
18 23. As a legal, direct, and proximate result of the malicious, despicable, cruel,
19 and unjust conduct of Defendants, and each of them, including DOES 1 through 10,
20 inclusive, as described in this complaint, Plaintiffs Decedents have suffered lost
21 earnings, the exact amount of such losses to be stated according to proof, pursuant to
22 Section 425.10 of the California Code of Civil Procedure.
23 24. Because the malicious, despicable, cruel, and unjust conduct of Defendants,
24 and each of them, including DOES 1 through 10, inclusive, as described in this
25 complaint, was committed in a deliberate, cold, callous, calculating, premeditated,
26 intentional and/or unreasonable manner, causing fatal injuries to Plaintiffs Decedents,
27 and done with conscious disregard of Plaintiffs Decedents rights and safety, Plaintiff
28 THE ESTATE OF ROBERT G. SPOHR by and through its Successor-in-interest
5
COMPLAINT FOR DAMAGES
1 ADRIENNE SPOHR, and Plaintiff THE ESTATE OF WENDY WOOD by and through its
2 Successor-in-interest ADRIENNE SPOHR, request the assessment of punitive damages
3 against Defendants, and each of them, including DOES 1 through 10, inclusive, in an
4 amount appropriate to punish and/or set an example of them.
5 SECOND CAUSE OF ACTION
6 Survival and Survival Damages (Against all Defendants)
7 25. Plaintiffs incorporate by reference and reallege each and every allegation
8 and statement contained in the prior paragraphs.
9 26. Plaintiffs are informed and believe, and thereon allege, that Defendants,
10 and each of them, including DOES 1 through 10, inclusive, caused, conspired to cause, or
11 otherwise participated in causing, the premeditated and planned June 5, 2021, murder
12 of Robert Gary Spohr and attempted murder of Wendy Wood, eventually leading to
13 Wood's death.
14 27. The aforementioned subject incident giving rise to this wrongful death and
15 survival action proximately and legally caused Plaintiffs Decedents to suffer fatal
16 mJuries.
17 28. Plaintiffs are further informed and believe, and thereon allege, that
18 Defendants, and each of them, including DOES 1 through 10, inclusive, were agents,
19 servants, employees, successors, joint venturers, co-conspirators, and/or successors-in-
20 interest of their co-defendants, who were acting within the course, scope, and authority
21 of said agency, employment and or venture, and/or in furtherance of said conspiracy in
22 causing the aforementioned subject incident to occur.
23 29. As a legal, direct, and proximate result of the malicious, despicable, cruel,
24 and unjust conduct of Defendants, and each of them, including DOES 1 through 10,
25 inclusive, as described in this complaint, Plaintiffs have sustained damages resulting
26 from the loss oflove, affection, society, service, comfort, support, right of support,
27 expectations of future support and counseling, companionship, solace, and mental
28 support, as well as other benefits and assistance of Plaintiffs Decedents, all to their
6
COMPLAINT FOR DAMAGES
1 general damages in a sum in excess of the jurisdictional limits of this Court, which will
2 be stated according to proof, pursuant to Section 425.10 of the California Code of Civil
3 Procedure.
4 30. As a legal, direct, and proximate result of the malicious, despicable, cruel,
5 and unjust conduct of Defendants, and each of them, including DOES 1 through 10,
6 inclusive, as described in this complaint, Plaintiffs will be deprived of the financial
7 support and assistance of Plaintiffs Decedents, the exact amount of such losses to be
8 stated according to proof, pursuant to Section 425.10 of the California Code of Civil
9 Procedure.
10 31. As a legal, direct, and proximate result of the malicious, despicable, cruel,
11 and unjust conduct of Defendants, and each of them, including DOES 1 through 10,
12 inclusive, as described in this complaint, Plaintiffs have incurred property, medical,
13 funeral and burial expenses in an amount to be stated according to proof, pursuant to
14 Section 425.10 of the California Code of Civil Procedure.
15 32. As a legal, direct, and proximate result of the malicious, despicable, cruel,
16 and unjust conduct of Defendants, and each of them, including DOES 1 through 10,
17 inclusive, as described in this complaint, Plaintiffs Decedents have suffered lost
18 earnings, the exact amount of such losses to be stated according to proof, pursuant to
19 Section 425.10 of the California Code of Civil Procedure.
20 33. Because the malicious, despicable, cruel, and unjust conduct of Defendants,
21 and each of them, including DOES 1 through 10, inclusive, as described in this
22 complaint, was committed in a deliberate, cold, callous, calculating, premeditated,
23 intentional and/or unreasonable manner, causing fatal injuries to Plaintiffs Decedents,
24 and done with conscious disregard of Plaintiffs Decedents rights and safety, Plaintiff
25 THE ESTATE OF ROBERT G. SPOHR by and through its Successor-in-interest
26 ADRIENNE SPOHR, and Plaintiff THE ESTATE OF WENDY WOOD by and through its
27 Successor-in-interest ADRIENNE SPOHR, request the assessment of punitive damages
28
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COMPLAINT FOR DAMAGES
1 against Defendants, and each of them, including DOES 1 through 10, inclusive, in an
2 amount appropriate to punish and/or set an example of them.
3 THIRD CAUSE OF ACTION
4 Intentional Infliction of Emotional Distress (Against all Defendants)
5 34. Plaintiffs incorporate by reference and reallege each and every allegation
6 and statement contained in the prior paragraphs.
7 35. This complaint alleges actions for damages pursuant to the common law of
8 the State of California as determinable from the face of the complaint.
9 36. The malicious, despicable, cruel, and unjust conduct of Defendants, and
10 each of them, including DOES 1 through 10, inclusive, as described in this complaint,
11 was extreme and outrageous and committed with wanton and reckless disregard of the
12 probability of causing Plaintiff ADRIENNE SPOHR to suffer severe emotional distress.
13 37. The malicious, despicable, cruel, and unjust conduct of Defendants, and
14 each of them, including DOES 1 through 10, inclusive, as described in this complaint,
15 caused Plaintiff ADRIENNE SPOHR to suffer the loss of her father by first degree
16 murder and to endure watching her mother suffer for a month in Intensive Care Unit
17 and several weeks in rehab, relearn basic skills, including how to walk, talk, and eat
18 again, and memory loss.
19 38. As a proximate result of the malicious, despicable, cruel, and unjust conduct
20 of Defendants, and each of them, including DOES 1 through 10, inclusive, as described in
21 this complaint, Plaintiff ADRIENNE SPOHR suffered shame, humiliation, mental
22 anguish, and extreme emotional and physical distress all to her general damage, which
23 will be stated according to proof, pursuant to Section 425.10 of the California Code of
24 Civil Procedure.
25 39. As a direct, foreseeable, and legal result of the malicious, despicable, cruel,
26 and unjust conduct of Defendants, and each of them, including DOES 1 through 10,
27 inclusive, as described in this complaint, Plaintiff ADRIENNE SPOHR has suffered and
28 continues to suffer substantial losses in earnings, bonuses and other employment
8
COMPLAINT FOR DAMAGES
1 benefits, in addition to expenses incurred in obtaining alternative employment, and has
2 suffered and continues to suffer shame, humiliation, mental anguish, and extreme
3 emotional and physical distress all to her general damage, which will be stated according
4 to proof, pursuant to Section 425.10 of the California Code of Civil Procedure.
5 40. Because the malicious, despicable, cruel, and unjust conduct of Defendants,
6 and each of them, including DOES 1 through 10, inclusive, as described in this
7 complaint, was committed in a deliberate, cold, callous, calculating, premeditated,
8 intentional and/or unreasonable manner, causing fatal injuries to Plaintiffs Decedents,
9 and done with conscious disregard of Plaintiff ADRIENNE SPOHR's rights and safety,
10 Plaintiff ADRIENNE SPOHR, requests the assessment of punitive damages against
11 Defendants, and each of them, including DOES 1 through 10, inclusive, in an amount
12 appropriate to punish and/or set an example of them.
13 FOURTH CAUSE OF ACTION
14 Punitive Damages (Against all Defendants)
15 41. Plaintiffs incorporate by reference and reallege each and every allegation
16 and statement contained in the prior paragraphs.
17 42. The conduct of Defendants, and each of them, including DOES 1 through
18 10, inclusive, as described in this complaint, was committed in a deliberate, cold, callous,
19 calculating, premeditated, intentional and/or unreasonable manner, causing fatal
20 injuries to Plaintiffs Decedents, and done with conscious disregard of Plaintiffs', and
21 each of them, rights and safety.
22 43. Because the malicious, despicable, cruel, and unjust conduct of Defendants,
23 and each of them, including DOES 1 through 10, inclusive, as described in this
24 complaint, was committed in a deliberate, cold, callous, calculating, premeditated,
25 intentional and/or unreasonable manner, causing fatal injuries to Plaintiffs Decedents,
26 and done with conscious disregard of Plaintiffs', and each of them, rights and safety,
27 Plaintiffs request the assessment of punitive damages against Defendants, and each of
28 them, including DOES 1 through 10, inclusive, in an amount appropriate to punish
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COMPLAINT FOR DAMAGES
1 and/or set an example of them pursuant to California Code of Civil Procedure section
2 3294.
3 DEMAND FOR JURY TRIAL
4 44. Plaintiffs hereby demand a jury trial.
5 PRAYER FOR RELIEF
6 Plaintiffs seek the following damages in an amount according to proof at trial:
7 For Wrongful Death and Survival:
8 (1) For non-economic damages suffered by Plaintiff ADRIENNE SPOHR
9 including, but not limited to the loss oflove, affection, society, service,
10 comfort, support, right of support, expectations of future support and
11 counseling, companionship, solace, and mental support, as well as other
12 benefits and assistance of Plaintiffs Decedents, in a sum in excess of the
13 jurisdictional minimum, according to proof;
14 (2) For economic damages suffered by Plaintiff THE ESTATE OF ROBERT
15 G. SPOHR by and through its Successor-in-interest ADRIENNE SPOHR, and
16 Plaintiff THE ESTATE OF WENDY WOOD by and through its Successor-in-
17 interest ADRIENNE SPOHR, related to the loss of earnings according to
18 proof;
19 (3) For funeral and burial expenses suffered by Plaintiffs, according to

20 Proof;
21 (4) For hospital, medical, professional, and incidental expenses suffered by
22 Plaintiffs, according to proof;

23 (5) For punitive and exemplary damages against Defendants in an amount

24 according to proof under Code of Civil Procedure § 3294 and/or any and all
25 other statutory or legal bases that may apply;
26 (6) For prejudgment and post judgment interest according to proof; and,
27 (7) For such other and further relief as the Court shall deem proper, all
28 according to proof.
10
COMPLAINT FOR DAMAGES
1 For Intentional Infliction of Emotional Distress (Plaintiff ADRIENNE
2 SPOHR only):
3 (1) For a money judgment representing compensatory damages including
4 lost wages, earnings, all other sums of money, together with interest on
5 these amounts according to proof;
6 (2) For an award of money judgment for mental pain and anguish and
7 severe emotional distress, including medical special damages, according to
8 proof;
9 (3) Attorneys' fees, expert fees, consultant fees and litigation costs and
10 expenses, as allowed under any statute, including under the tort of another
11 doctrine;
12 (4) For punitive and exemplary damages against Defendants in an amount

13 according to proof under Public Utilities Code§ 2106, Code of Civil

14 Procedure§ 3294 and/or any and all other statutory or legal bases that may
15 apply;
16 (5) Costs of suit;
17 (6) For prejudgment and post judgment interest according to proof; and,
18 (7) For such other and further relief as the Court shall deem proper.
19 DATED: June 2. 2023
20
21
By _ _ _ _ _ _ _ _ _ _ _ __
JASON W. SCHAFF
22 DAVID B. WITKIN
Attorneys for Plaintiffs,
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COMPLAINT FOR DAMAGES