1 Ronald 51. Rouda, Bsq, (SE #mw)
2 ROUDA, FfiDER, TI%T.EN & Z%NOBmI
44 Montgomery Street, Suite 4000
3 San Francisco, California 94104
= 415-398-5398; Fax: 415-398-8169
4
5 ATTORNEYS FOR PLAlNTfFF
6
7
8
9 IN THE SUPERIQR COURT OF THE STATE OF CALIFQRNIA
10 IN AND FOR THE COUNTY OF SAN FRANCISCO
11 EDYTHE PAMELA WHIPPLE-KELLY,
12 Plaintiff! COMPLAINT
73 V. b WRONGFUL
14 ROBERT E. NOEL, MARJ#RlE F. KNOLIER,
RUDOLPH G. KOPPL, ANNETTE PUCCI-
15 KOPPL, THE RUDOLOPH C. KOPPLTRUST, [C,C.P,
MARINA GREEN PROPERTIES, INC., and
16 ROE 1 through bOE $0, inclusive, DEMAND FOR
17 Defendants.
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18
19
20 Plaintiff, Edythe Pamela Whipple-Kelly, demands a jury
21 GENERAL ALLEGATIONS
22 1. Plaintiff, Edythe Pamela Whipple-Kelly, is the
23 deceased.
24 2. UnderCaliforniaCodeofCivil Procedure section
25 Code section 6402, plaintiff, Edythe Pamela Whipple-Kelly,
26 wrongful death of her daughter, Diane Whipple. Diane Whipple, deceased, was the only
SNIPPETS:
26 wrongful death of her daughter, Diane Whipple.
daughter of plaintiff, Edythe Pamela WhippIe-Kelly.
Francisco, California, was a 40-unit residential apartment building in San Francisco's Pacific
and a parking facility for the use of tenants and guests.
adult woman residing with Sharon Smith, as domestic partners and tenants, in apartment unit
and DOE ONE through DOE TWENTY, inclusive, and each of them, owned, possessed,
RUOOLPH C. KOPPL TRUST, is a legal entity created and existing under the laws of the State
KQPPL, THE RUDOLPH C. KOPPL TRUST, and DOE TWENTY ONE through DOE FORTY,
12 GREEN PROPERTIES, INC., is a California corporation with its principal place of business
occurred in the City and County of San Francisco.
11 otherwise, of defendants DOE ONE through DOE FIFTY, inclusive, are presently unknown to
12 plaintiff who therefore SW said defendants by such fictitious names.
13 believes and thereon alleges that each defendant designated herein as "DOE" is legally
living in fear of said dogs.
may be just compensation for the loss and damages plaintiff has suffered and will
Said defendants' violation of said statutes constitute a presumption that said
has sustained the losses and damages herein described.
13 THE RUOOLOPH G+ KOPPL TRUST, MARINA GREEN PROPERTIES, INC., and DOE
DOE FIFTY, inclusive, and each of them, breached their non-delegable duty of care owed to
13 the presence of said dangerous dogs on the premises.
19 possession of a rental unit if:
right to abate a nuisance, posing a threat to tenants in said apartment building, was
San Francisco Housing Code which requires a caretaker or other responsible person to reside
19 or other responsible person to reside upon the premises and have charge of the said
but required said person to have charge of both apartment houses in violation of the
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