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Carl E. Kohlweck, Esq. (SBN 087139) 01
1 28437 Plainfield Dr. (:...
2 Rancho Palos Verdes, CA 90275-3147 \&
Tel: (310) 480-3423
OCT 05 2012
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By Offlcer/C rk
SHA ESlEY -, Oep ty 3 Email: ceklaw46@aol.com
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Attorney for Plaintiff
KAREN DE LA CARRIERE
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES, CENTRAL DISTRICT
KAREN DE LA CARRIERE,
Plaintiff,
vs.
WILLIAM N. GREENE,
individually and doing business
as CALIFORNIA CONSULTING
GROUP, a business entity of
unknown form, R & R TRUST, a
business entity of unknown form,
CALIFORNIA CONSULTING
GROUP INTERNATIONAL, a
business of unknown form; All
Persons Presently Unknown,
Claiming Any Legal Or Equitable
Right, Title, Estate,
Lien, Or Interest In The Property
Described In The Complaint
Adverse To Plaintiffs' Title, Or
Any Cloud On Plaintiffs' Title
Thereto; and DOES 1 through 25,
inclusive,
Defendants.
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Case No.: Be 4 9 3 3 9 3
COMPLAINT
1. Quiet Title (CCP 760.010, et
seq.);
2. Cancellation of Instrument
Pursuant to Civ. C. 3412;
3. Declaratory Relief (CCP
1060);
4. Slander of Title;
5. To Void Contract Pursuant to
Civ. C. 1670.5
6. Breach of Fiduciary Duty;
7. Unfair Business Practices;
and
8. Negligence.
Plaintiff, KAREN DE LA CARRIERE. alleges as follows:
COMPLAINT - 1
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1
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3 1. Plaintiff is, an individual, and at all times material herein was, a resident of Los
4 Angeles County, California.
5 2. Defendant WILLIAM N. GREENE is an individual doing business in Los
6 Angeles County individually as a certified public accountant and under the business
7 names CALIFORNIA CONSULTING GROUP, CALIFORNIA CONSULTING GROUP
8 INTERNATIONAL and R & R Trust, each of which is a business entity of unknown form
9 but which is named as a defendant herein to the extent that each is a jural entity subject
10 to suit in its own name.
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3. "All Persons Presently Unknown, Claiming Any Legal Or Equitable Right,
Title, Estate, Lien, Or Interest In The Property Described In The Complaint Adverse To
Plaintiffs' Title, Or Any Cloud On Plaintiffs' Title Thereto' are sued herein pursuant to
California Code of Civil Procedure Section 762.020(a).
4. The true names and capacities, whether individual, corporate, associate, or
otherwise, of Defendants DOES 1-25, inclusive, are unknown to Plaintiff, who therefore
sues them by the said fictitious names. When Plaintiff ascertains the true names and
capacities of DOES 1 through 25, she will amend her complaint accordingly. Plaintiff is
informed and believes and thereon alleges that some of these fictitious named
Defendants claim some right, title, estate, lien, or interest in the hereinafter-described
PROPERTY adverse to plaintiffs title and their claims, and each of them, constitute a
cloud on Plaintiffs title to that PROPERTY. Plaintiff is informed and believes and
thereupon alleges that others of these DOE defendants participated with or assisted
Defendant GREENE in perpetrating and committing the acts herein alleged. The
allegations of this complaint have evidentiary support or are likely to have evidentiary
support after a reasonable opportunity for further investigation or discovery.
COMPLAINT - 2 . . ~
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1 5. Each of the Defendants named herein are believed to, and are alleged to
2 have been acting in concert with, as employee, agent, co-conspirator or member of a
3 joint venture with, each of the other Defendants, and are therefore alleged to be jointly
4 and severally liable for the claims set forth herein, except as otherwise alleged.
5 (Hereafter, unless otherwise specified, defendants, including DOE 1 through DOE 25
6 will be referred to collectively as "Defendants").
7 GENERAL ALLEGATIONS
8 6. The real property that is the subject of this case is commonly known as 1935
9 N. Serrano Avenue, Los Angeles, CA 90027 and is described as Lot 45, Tract 3823 as
10 per map recorded in Book 41, Page 78 of maps in the Office of the County Recorder of
11 Los Angeles County. The property is designated as Assessor's parcel No. 5587-24-20
12 in the Assessor's Office of Los Angeles County, and is hereinafter referred to as the
13 'Subject Property:
14 7. Plaintiff acquired title in the Subject Property by grant deed on May 27, 1998,
15 a copy of which is attached as Exhibit 1.
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8. Plaintiff took possession of the Subject Property on the same date of the
closing in May 1988 and, as of the commencement of this action, is still now and has
been in continuous possession of the Subject Property.
9. At the time Plaintiff acquired the Subject Property, and continuing until April
2012, Defendant William N. Greene, as a Certified Public Accountant, provided
professional accountancy services to Plaintiff. Specifically, Defendant Greene prepared
her state and federal tax returns; and, after she began doing business selling Thomas
Kinkade artworks over the internet beginning in 2001, Defendant Greene also prepared,
filed and paid Plaintiff's California sales taxes, and provided Plaintiff with professional
financial advice and planning as her accountant and financial advisor.
10. Without Plaintiff's knowledge or consent, a 'Deed of Trust and Assignment 0
Rents" containing a 'Promissory Note - Straight - Secured By Deed of Trust" on the
COMPLAINT - 3
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1 Subject Property was recorded in the Los Angeles County Official Records on October
2 9, 2003, as Instrument No. 03 3025404, a copy of which is attached as Exhibit 2, and is
3 referred to hereinafter as "the 2003 Promissory Note and Trust Deed.' California
4 Consulting Group is listed as the Trustee and R & R Trusts is listed as the Beneficiary.
5 Plaintiffs name is listed as the Trustor and signatory on the note and purportedly
6 appeared and signed before a notary on February 26, 2003.
7 11. Plaintiffs purported notarized signature is a forgery. Plaintiff did not appear
8 before the notary and did not execute the 2003 Promissory Note and Trust Deed. Nor
9 did she have knowledge of or give her consent for anyone to sign on her behalf, or to
10 record the document.
11 12. Through the recorded trust deed, Defendants William N. Greene, R & R
12 Trust, and California Consulting Group claim an interest adverse to Plaintiffs in the
13 subject real property. Plaintiff further alleges on information and belief that some of the
14 unknown DOE defendants also claim an adverse interest to Plaintiffs real property
15 through the deed of trust.
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13. Plaintiff discovered the forged instrument on or about May 1, 2012, within a
few days of Defendant Greene making, under threat of foreclosure, a demand for full
payment of an amount in excess of $677,000. The amount purportedly represented: (1)
prinCiple in the amount of $175,000, plus compounded interest at the rate of 14% % and
(2) fees for unpaid accountancy services over the past eleven (11) years.
14. In the process of retaining a new certified public accountant, Plaintiff
requested from Defendant Greene copies of her California sales tax returns and proofs
of payment since she had always turned over her sales records to Defendant Greene
and gave a check made payable to Greene in an amount he told her was due the State.
Defendant Greene refused to provide the information to Plaintiff, claiming he was not
obligated to do so since, he claimed, she owed him accountancy fees. In so acting,
Defendant Greene breached his professional responsibility under California State Board
COMPLAINT - 4


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1 of Accountancy Rules of Professional Conduct, Article 9, 68, which requires a
2 licensee upon request by a client to release a client's records, which the sales tax
3 returns were, and speCifically states: 'Unpaid fees do not constitute justification for
4 retention of client records.'
5 15. Defendant Greene's claim of fees was specious and untrue and designed as
6 justification and pretense to avoid disclosure of self-dealing and conflicts of interest by
7 Greene. In fact, the parties had developed a barter system over the years. Plaintiff
8 provided counseling services in exchange for accountancy services and financial
9 advice. Further probing of Defendant Greene by Plaintiff elicited the admission from
10 Defendant Greene that he had treated her business as a subsidiary of his owned and
11 controlled California Consulting Group. Greene continues to fail and refuse, to provide
12 to Plaintiff copies of her sales tax returns and proofs of payments.
13 16. Plaintiff did not authorize or consent to have her personal business treated
14 as a subsidiary of California Consulting Group.
15 17. Plaintiff requested from Defendant Greene copies of their basic retainer
16 agreement and invoices he claimed were unpaid. She also requested any signed
17 documents that memorialized her authorization to treat her business as a subsidiary of
18 California Consulting Group. Defendant Greene failed and refused, and continues to
19 fail and refuse, to provide her the information.
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FIRST CAUSE OF ACTION FOR QUIET TITLE
(Against All Defendants)
18. Plaintiff incorporates the allegations of paragraphs 1 through 17 above as
23 though fully set forth hereat.
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19. Pursuant to CCP 760.010, et seq., Plaintiff seeks to quiet title against the
claims of defendants as follows: the claims of defendants are without any right whatever
and such defendants have no right, title, estate, lien, or interest whatsoever in the
above-described real property or any part thereof.
COMPLAINT - 5
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1 20. Plaintiff seeks to quiet title as of the date of the filing of this complaint with the
2 court.
3 SECOND CAUSE OF ACTION FOR CANCELLATION OF INSTRUMENT
4 PURSUANT TO CIVIL CODE 3412
5 (Against All Defendants)
6 21. Plaintiff incorporates the allegations of paragraphs 1 through 20 above as
7 though fully set forth hereat.
8 22. The 2003 Promissory Note and Trust Deed is void or voidable due to its
9 fraudulent nature and the forged signature of Plaintiff, in that it is violative of the usury
10 laws of the State of California and does not qualified for any exemption therefrom, and
11 for the reasons set forth in paragraphs 37 through 46, each of which is herein
12 incorporated by this reference.
13 23. If left outstanding, there is a reasonable apprehension that it may cause
14 serious injury to Plaintiff.
15 24. Plaintiff seeks an adjudication and order pursuant to Civil Code 3412 that
16 the 2003 Promissory Note and Trust Deed be delivered up and canceled.
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THIRD CAUSE OF ACTION FOR DECLARATORY RELIEF
(Against All Defendants)
25. Plaintiff incorporates the allegations of paragraphs 1 through 24 above as
20 though fully set forth hereat.
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26. An actual controversy has arisen and now exists between Plaintiff and
Defendants concerning their respective rights and duties under the 2003 Promissory
Note and Trust Deed and title in the Subject Property. Defendants contend that the
2003 Promissory Note and Trust Deed is valid and the note due and payable. Plaintiff
disputes these contentions and contends that the instrument is fraudulent and not
executed by her. Plaintiff further contends that: (a) the interest rate set forth in the 2003
Promissory Note and Trust Deed is usurious, unlawful, and uncollectible and, (b) she
COMPLAINT - 6
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1 has made zero payments on either the principle or interest which were, pursuant to the
2 terms of the note, due 5 years and 30 days from February 22, 2003, or by March 22,
3 2008, and therefore, pursuant to CCP 337, her obligation to pay, if it ever existed,
4 which she disputes, has been extinguished as beyond the 4-year statute of limitations
5 for an action based on "any contract, obligation or liability founded upon an instrument
6 in writing."
7 27. Plaintiff is harmed and continues to suffer by this unsettled state of affairs in
8 that a cloud exists on her title to the Subject Property, impairing her equity and free
9 enjoyment of the property. A judicial declaration pursuant to Cal. Civ. Proc. Code
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1060 is therefore necessary and appropriate at this time so that Plaintiff's rights and
duties under the 2003 Promissory Note and Trust Deed may be determined with
certainty.
28. Plaintiff requests a judicial determination of her rights and duties under the
2003 Promissory Note and Trust Deed and of her right to title in the Subject Property.
FOURTH CAUSE OF ACTION FOR SLANDER OF TITLE
_(Against All Defendants)
29. Plaintiff incorporates the allegations of paragraphs 1 through 24 above as
though fully set forth herea!.
30. The tort of Slander of Title involves the action of one who, without a privilege
20 or justification to do so, publishes matter which is untrue and disparaging to another's
21 property and results in pecuniary damage.
22 31. Defendants, without privilege or justification, forged or caused to be forged
23 Plaintiff's signature on the 2003 Promissory Note and Trust Deed, or in reckless
24 disregard for whether Plaintiff had actually signed the instrument, and then published
25 the 2003 PromiSSOry Note and Trust Deed by recording it in the official records of Los
26 Angeles County.
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COMPLAINT - 7
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1 32. The claim of an interest in title on the Subject Property by virtue of Plaintiffs
2 signature on the 2003 Promissory Note and Trust Deed is untrue; Plaintiff did not
3 execute the document, nor authorize anyone to do so on her behalf.
4 33. The published 2003 Promissory Note disparaged and continues to disparage
5 Plaintiffs property as a cloud to her title to the Subject Property, and has impaired and
6 continues to impair her equity in and free enjoyment of the property, and has resulted in
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actual economic damage to her in that she is unable to refinance the Subject Property
at the more advantageous interest rates which would otherwise be currently available to
her.
34. As a proximate cause of the slander of her title in the Subject Property,
Plaintiff has been damaged in an amount to be proven at trial and which includes, in
addition to the interest rate differential above alleged, the costs and attorney's fees
necessarily incurred in clearing the slandered title.
35. The conduct of Defendants, and each of them, is malicious, oppressive, and
fraudulent as those terms are defined in Civil Code 3294 and, therefore, justifies the
imposition of punitive damages. More specifically, (1) Defendant Greene, as Plaintiffs
certified public accountant and financial advisor engaged in self-dealing and
undisclosed conflicts of interests, and attempted to profit unlawfully by collecting
usurious interest; (2) Plaintiff is informed and believes and thereon alleges that
Defendant Greene forged or caused to be forged Plaintiffs signature by using copies of
Plaintiffs signature on financial documents obtained by virtue of his professional
relationship with Plaintiff; and (3) upon infomnation and belief, Defendants engaged in a
scheme to profit off Plaintiffs business by use of the 2003 Promissory Note and Trust
Deed in a manner not fully understood by Plaintiff at the time of the filing of this action,
and without her knowledge and consent.
COMPLAINT - 8
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1 FIFTH CAUSE OF ACTION TO VOID CONTRACT FOR
2 UNCONSCIONABLENESS PURSUANT TO CIVIL CODE 1670.5
3 (Against Defendant Greene)
4 36. Plaintiff incorporates the allegations of paragraphs 1 through 24 above as
5 though fully set forth hereat.
6 37. Defendant Greene is a California licensed Certified Public Accountant.
7 38. Under Article 9, Section 65 of the California Board of Accountancy
8 Regulations, all CPA licensees must comply with the American Institute of CPA's
9 ("AICPA's") Code of Professional Conduct.
10 39. The AICPA's Rule 101 states: "A member in public practice shall be
11 independent in the performance of professional services as required by standards
12 promulgated by bodies deSignated by Council."
13 40. AICPA's Rule 101 is interpreted by the AICPA to mean that Independence of
14 a CPA "Shall be considered to be impaired if: (A) During the period of professional
15 engagement a covered member (1) Had or was committed to acquire any direct or
16 material indirect financial interest in the client... [or) (4) Except as specifically permitted
17 in interpretation 101-5, had any loan to or from the client. . ." (The alleged loan to Plainti
18 is not covered as an exception.)
19 41. Additionally, California State Board of Accountancy Rules of Professional
20 Conduct, Article 9 , 57 provides: A licensee shall not concurrently engage in the
21 practice of public accountancy and in any other business or occupation which impairs
22 the licensee's independence, objectivity, or creates a conflict of interest in rendering
23 professional services."
24 42. Civil Code 1670.5(a) states
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If the court as a matter of law finds the contract or any clause of the contract to
have been unconscionable at the time it was made, the court may refuse to enforce the
contract, or it may enforce the remainder of the contract without the unconscionable
COMPLAINT - 9


1 clause, or it may so limit the application of any unconscionable clause as to avoid any
2 unconscionable result.
3 43. The 2003 Promissory Note and Trust Deed is unconscionable for the
4 following reasons: (a) Defendant Greene violated his professional responsibilities by
5 entering into a loan with Plaintiff during his professional engagement of Plaintiff; (b)
6 upon information and belief, Defendant Greene engaged in self-dealing with Plaintiff in
7 which the 2003 Promissory Note and Trust Deed was part of a scheme by Defendants
8 to personally profit or evade taxes; (c) Defendant Greene concealed from Plaintiff his
9 self-dealing; (d) Defendant Greene did not obtain the informed consent of Plaintiff to
10 participate in Defendants' scheme; (e) Plaintiff did not knowingly execute or consent to
11 the execution of the 2003 Promissory Note and Trust Deed, nor its recording, and (f) the
12 subject promissory note prepared by Defendant Greene includes a usurious rate of
13 interest, which in and of itself, is unconscionable.
14 44. Additionally, Defendant Green's conduct related to the 2003 Promissory
15 Note and Trust Deed, as alleged herein above, constitutes unprofessional conduct as
16 set forth in Business & Professions Code ('B & PC") 5100, to wit: 5100(c)
17 (diShonesty, fraud & gross negligence); 5100(i) (fiscal dishonesty or breach of
18 fiduciary responsibility of any kind); and 5100(k) (obtaining money, property or other
19 valuable consideration by fraudulent means or false pretenses).
20 45. Defendant Greene's conduct as alleged herein was willful and knowing
21 and/or with complete and reckless disregard of the emotional or financial ramifications
22 that would surely befall Plaintiff, and was in flagrant breach of his fiduciary duties owed
23 to Plaintiff.
24 46. Plaintiff therefore requests a finding that the 2003 PromiSSOry Note and Trust
25 Deed is unconscionable and VOid, and an order that Defendants reconvey the trust
26 deed.
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COMPLAINT - 10

1 SIXTH CAUSE OF ACTION FOR BREACH OF FIDUCIARY DUTIES
2 (Against Defendant Greene)
3 47. Plaintiff incorporates the allegations of paragraphs 1 through 46 above as
4 though fully set forth hereat.
5 48. At all times relevant, Defendant Greene created, accepted and acted in a
6 fiduciary relationship of great trust that required him to avoid self-dealing and conflicts 0
7 interests and to always act in the best interests of Plaintiff, including her property,
8 business, and financial interests, and which also included duties of honesty, loyalty and
9 full disclosure to his client.
10 49. In acting as alleged herein above, Defendant Greene breached his fiduciary
11 duties owed to Plaintiff as he has acted and continues to act for his own benefit and to
12 the detriment of Plaintiff. On information and belief, Plaintiff alleges that Defendant
13 Greene has conducted his accountancy practice with regard to Plaintiff's affairs in a
14 manner replete with self-dealing and schemes designed to evade taxes and otherwise
15 profit off his client.
16 50. As a proximate result of Defendant Greene's breach of fiduciary duties,
17 Plaintiff was damaged according to proof at trial.
18 51. The conduct of Defendant Greene was willful, intentional, purposeful, and
19 done with the sole intention to personally profit to the detriment of Plaintiff.
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52. The conduct of Defendant Greene, as alleged herein, is malicious,
oppressive, and fraudulent as those terms are defined in Civil Code 3294 and,
therefore, justifies the imposition of punitive damages.
SEVENTH CAUSE OF ACTION FOR UNFAIR BUSINESS PRACTICES
(Against All Defendants)
53. Plaintiff incorporates the allegations of paragraphs 1 through 24, and 26,
above, as though fully set forth hereat.
COMPLAINT - 11



1 54. Plaintiff brings this action pursuant to B & PC 17200, which prohibits any
2 unlawful, unfair or fraudulent business act or practice. In this cause of action only,
3 Plaintiff not only sues individually but sues on behalf of the general public.
4 55. On information and belief, Plaintiff alleges that Defendants are engaged in
5 tax schemes involving the placement of fraudulent promissory notes and trust deeds on
6 real property of their clients, with or without the knowledge and consent of their Clients,
7 and involving the false and fraudulent reporting of sales taxes of retail businesses
8 through California Consulting Group, with or without the knowledge and consent of their
9 clients.
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56. Plaintiff is further informed and believes and thereon alleges that Defendants
practices are unlawful, unfair and fraudulent as those terms are defined in cases
interpreting B & PC 17200.
57. On information and belief, Defendants practices are continuing and date
back at least to 1998, and extend to more persons than Plaintiff.
58. As a direct and proximate result of the unfair and deceptive acts and
practices committed against her personally, Plaintiff has been damaged in an amount to
be proven at trial.
59. Plaintiff also seeks an accounting of her sales tax returns and those of
California Consulting Group as they may relate to Plaintiffs retail art business, and the
actual returns filed on her behalf.
60. Plaintiff seeks disgorgement of any profits or benefits derived by Defendants
off the 1998 and 2003 promissory notes secured by trust deeds and off her retail art
business or other personal affairs.
61. Plaintiff further seeks an order that Defendants reconvey the 2003 trust
deed.
62. On behalf of the general public, Plaintiff seeks a preliminary and permanent
injunction against Defendants from further engaging in the unlawful, unfair and
COMPLAINT - 12
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1 fraudulent acts and practices and a disgorgement of profits derived by Defendants at
2 the expense of other clients.
3 63. Plaintiff is entitled to reasonable attorney's fees for bringing this action.
4 EIGHTH CAUSE OF ACTION FOR NEGLIGENCE
5 (Against Defendant William Greene)
6 64. Plaintiff incorporates the allegations of paragraphs 1 through 24, and 26,
7 above, as though fully set forth herea!.
8 65. At all times relevant, Defendant William Greene, acting as Plaintiff's
9 Certified Public Accountant, had a duty to exercise the reasonable care and skill of a
10 certified public account and to follow California's professional rules, regulations and
11 statutes regulating the practice of accountancy, which include, inter alia: refraining from
12 acts of dishonesty, fraud and gross negligence (B & PC 51 OO(c)); refraining from fiscal
13 dishonesty or breach of fiduciary duty of any kind (B & PC 5100(i)); refraining from
14 preparation offalse financial reports (B & PC 51000)); and releasing client records
15 when requested of the client, not engaging 'in any other business or occupation which
16 impairs the licensee's independence, objectivity or creates conflicts of interests:
17 (California State Board of Accountancy Rules of Professional Conduct, Article 9 68,
18 and 57, respectively.)
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66. In taking the actions alleged herein above, and in failing to take the actions
as alleged herein above, Defendant Greene breached his duty of care and skill to
Plaintiff by failing to obtain Plaintiff's notarized signature on the 2003 Promissory Note
and Trust Deed; by failing to obtain Plaintiff's informed consent to record the note; by
failing to apprise her of the usurious nature of the rate of interest that he proposed to
charge and by failing to apprise her that such a loan and interest rate could only be
processed through a licensed independent third party broker; by failing to obtain
Plaintiff's informed consent to record the note; by failing to obtain Plaintiff's informed
consent to treat her retail art business as a subsidiary of Defendant Greene's California
COMPLAINT - 13


1 Consulting Group regarding California sales taxes; and by failing to maintain separate
2 California sales tax filings for Plaintiff which created a conflict of interest with Defendant
3 Greene and led him to treat the portion of California Consulting Group's sales tax
4 returns relating to Plaintiffs business as not belonging to Plaintiff, thereby denying her
5 copies of her sales tax returns and proof of payment. Additionally, Defendant Greene
6 breached his duty of care and skill to Plaintiff by taking actions against her when he
7 demanded payment in full on the purported 2003 Promissory Note and Trust Deed that
8 he did not have the legal authority to do nor for which he could otherwise charge her at
9 a usurious interest rate; and by failing to immediately reconvey the note and trust deed
10 upon notice from Plaintiff that her signature was forged, that she did not know or
11 authorize the recording of the instrument, that the interest provision in the note was
12 usurious and unlawful, and that the principle was also time-barred by the terms of the
13 note, and her demand that he do so. Defendant Greene also breached his duty of care
14 and skill to Plaintiff by refusing to provide her copies of her sales tax returns and proof
15 of payment when requested by her.
16 67. As a direct and proximate cause of Defendant's negligence. Plaintiff, and her
17 propertY,were damaged according to proof at trial.
18 68. Further, the errors and omissions of Defendant Greene constitute negligence
19 per se pursuant to Evidence Code 669, thereby creating a presumption of negligence,
20 because: (a) his actions and failures to act as herein alleged violated a statute,
21 ordinance, or regulation of a public entity, as cited herein above; (b) the violation
22 proximately caused injury to Plaintiff and/or her property; (c) the injury resulted from an
23 occurrence of the nature which the statute, ordinance, or regulation was designed to
24 prevent; and (d) Plaintiff, the person suffering the injury to her person or property was
25 one of the class of persons for whose protection the statute, ordinance, or regulation
26 was adopted.
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COMPLAINT - 14
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PRAYER FOR RELIEF
WHEREFORE, Plaintiff prays for the following relief:
AS TO THE FIRST CAUSE OF ACTION:
1. For a judgment quieting title in Plaintiff as the owner of the Subject Property
by declaring that Defendants have no interest in the property adverse to the Plaintiff;
2. For costs of suit according to proof; and,
3. For other such relief that may be granted to Plaintiff as the Court deems just.
AS TO THE SECOND CAUSE OF ACTION:
1. For an order that the deed of trust recorded October 9, 2003 against the
Subject Property be delivered up and canceled;
2. For costs of suit according to proof; and,
3. For other such relief that may be granted to Plaintiff as the Court deems just.
AS TO THE THIRD CAUSE OF ACTION:
1. For a declaration that Plaintiff owes nothing under the 2003 Promissory Note
and Trust Deedand an order that Defendants remove the cloud to Plaintiffs title in the
Subject Property and reconvey the trust deed.
2. For costs of suit according to proof;
3. For reasonable attorney's fees under the contract or by statute; and
4. For other such relief that may be granted to Plaintiff as the Court deems just.
20 AS TO THE FOURTH CAUSE OF ACTION:
21 1. For an order that the deed of trust recorded October 9, 2003 against the
22 Subject Property be delivered up and canceled;
23 2. For damages, including attorney's fee necessarily incurred in clearing the
24 slandered title, according to proof;
25 3. For punitive damages according to proof;
26 4. For costs of suit according to proof; and,
27 5. For other such relief that may be granted to Plaintiff as the Court deems just.
28
COMPLAINT - 15


1 AS TO THE FIFTH CAUSE OF ACTION:
2 1. For a finding that the 2003 Promissory Note and Trust Deed is
3 unconscionable and void, and an order that Defendants reconvey the trust deed;
4 2. For costs of suit according to proof; and,
5 3. For other such relief be granted to Plaintiff as the Court deems just.
6 AS TO THE SIXTH CAUSE OF ACTION:
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1. For damages, according to proof;
2. For punitive damages according to proof;
3. For costs of suit according to proof; and,
4. For other such relief that may be granted to Plaintiff as the Court deems just.
AS TO THE SEVENTH CAUSE OF ACTION:
1. For damages, according to proof;
2. For an order that Defendants reconvey the 2003 trust deed.
3. For an Accounting of Plaintiff's sales tax returns and those of California
Consulting Group as they may relate to Plaintiff's retail art business, and the actual
returns filed on her behalf.
4. For disgorgement of any profits or benefits derived by Defendants off the
1998 and 2003 promissory notes secured by trust deeds and off her retail art business
19 or other personal affairs.
20 5. On behalf of the general public, Plaintiff seeks a preliminary and permanent
21 injunction against Defendants from further engaging in the unlawful, unfair and
22 fraudulent acts and practices and a disgorgement of profits derived by Defendants at
23 the expense of other clients.
24 6. For reasonable attorney's fees;
25 7. For costs of suit according to proof; and,
26 8. For other such relief that may be granted to Plaintiff as the Court deems just.
27
28
COMPLAINT - 16


1 AS TO THE EIGHTH CAUSE OF ACTION:
2 1. For damages, according to proof;
3 2. For costs of suit according to proof; and,
4 3. For other such relief that may be granted to Plaintiff as the Court deems just.
5
6 Date: October 4,2012
7
8
:W0(i;;;;;;:;Z
Carl E. Kohlweck, Attorney for Plaintiff
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18
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20
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24
25
26
27
28
COMPLAINT - 17
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1
2
3
4
5
6
7
8
9
10
11
12
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15
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17
18
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20
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28


III
UI
'>
"
>i


VERIFICATION
I, the undersigned, certify and declare that I have read the foregoing and know its
contents. I am a party to this action. The matters stated in the documents described
above are true of my own knowledge and belief except as to those matters stated on
information and belief, as to those matters I believe them to be true.
Executed on October 4, 2012, in Los Angeles, County of Los Angeles, California.
I declare under penalty of perjury under the laws of the State of California that
the foregoing is true and correct.

COMPLAINT - 18

Karen de la Carriere v. William N. Greene. et al. EXHIBIT 1
. ...... . ... < .... - .......... - ,,- _.......
RECORDING REQUESTED BY:
. QLD .... ICTITLI
,..,.,
When Recorded Mall Document
... d Tea Stat ....... , To:
Karen de 1a Carriere
98 1099967
RECORDEDIflLED IN OFFICIAL RECORDS
RECORDER'S OfFICE
LOS ANGELES COUNTY
CALIFORNIA .
JUN
30. 1998 ATlA. ... 1935 Nortb Serrano Avenue
Los Angeles, CA 90021
Escrow No.
Order No.
3l062-JJ
816512-44
APN: 5581-24-20
__ M, ___ ,. I
ORA, NT DEED :::
""-'-'- IFE$il
Documentary_Iartaalat 47s.lio ' Cltytaatl,957.50 .
I" I compute!! "" !ull value of property conveyed, or D
,
..k
I I computed on lull value less value 01 liens or eneumbtancBS remaining at tima of sata, ..
I I Unincorporeted Area City of Loe Anseles
FOR A VALUABLE CONSIDERAnoN. r!!!*ptaf whld'lla hereIIv 1IClnawIIIdaIId. Abel L. Nosce a married
man as his sale ana sepsrate property Nosce, a sing1e msn and
Haria Hideliza P Nosce, a single womao and Hsria Aurora P Nasce, a Hingle woman
hereby GRANTISI 10
Karen de 1a Carriere. an unmarried woman
the foUowIng dascrlbed reel property lit the CIty of Los Angeles
County of Lo s Ange Ie s S_ of CaIIfGmIa:
Lot 45 of Tract No. 3823. as per map recorded in Book 41 Page 78 of maps.
in tbe office of the County Recorder of said County.
DATED: May 27 1998
JAti ;/-/Pn-
COUNTY F 1...
i
' . belore me. . I
f3 f:: BP(H'ared
ft1J.!tHi:!(u, ... Nllf<el
"- Maria
personallv known 10 me lor proved to me on the basis
of satisfectory evidence) to be Ihe parsonlsl whose J ;!>==-.jfc.:.,. ______ _
narnels) is/ere subscribed to the within instrument and :: - -
Keria Aurora P. Nosee
acknowledged to me thet helshelthey executed the
same In hlsihsrlthelr authorized capeeityCiesl. 'end thet
by hlsiher/lheir slgnaturelsl on the instrument the
personis), or the emlty upon behalf of which the
personCsi acted. executed the instrument.
Witness m1i'f!!'mal seal.
Signature
MAlt. TAX STATEMENT AS DIRECTED ABOVE.
UII-131"",, GIWfI'DEED


Karen de la Carriere v. William N. Greene, et al. EXHIBIT 2
-------- -------
I
This page la part of your document - DO NOT DISCARD
03 3025404. \
4:21 PM OCT 09 2003
TITLE(S) :
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Assessor's Identification Number (AIN)
To be completed by Examiner OR Title Company In black Ink. Number of AIN'a Shown
THIS FORM NOT TO BE DUPLICATED
AND WKBI RECORDED MAIL nas t&D AMJ. UNt..Us
DTMERWISE SNDWN aaow, MAll TAX ST1TEMDm1 1'0:

=. 1031 /II. {IlJtfJO Art sre '1'1
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03 3025404
THIS DEED OF TRUST. mode this day !',
between K'&ReN pg. lIL (AOpp .eye .
-:..-------=-: __ herein called Trustor.
whose _I II I 'US N. S f.6?At,to L,s AN (U:u s cA q ()021
Ale) &tMI1l (CItY) rS'.T(] D'I
_ ... C .... 4I",.,UII<2.N""-""':w.LV''-''O .... ''''"'-'-'S ... ____________ . he,.,in celled Trust , end
..... ________________________ ,. herein c.lled Beneficiary.
Trustor grents. trena'", end assigns to Trustoo. in trust. with power of solo. all that roal pr_ in the City of
Las tir!! GeI2c. . County of k2$ Affeetl S. Stet. 01 CA . described as:
l(t35 N. SWVrtro ) CA ((r;tJ27
itS T>A er 3g t.3 '601( lf3 P%e
G>utnj cJr: Los fw.q-tLts
TOGETHER with al1 rightB, privileges, title and interest which Trustor now has or may hereafte, acquire in or to aetd property.
inctuding. without limitation. the renta. issues and profits thereof. and with the appurtenances and all buildings and
improvements now or hereafter placed thereon, It being understood and agreed that all clBllsea of property, attached 01
. unattached, used in connection therewith shall be deemed fixtures and subject to the property above described;
SUBJECT, HOWEVER. 10 tho rlghl. power and authority given to end conlerred uponB.neliciary hereinbelow 10 collo<:1 end
appty .uch rents. i uos and profits:
tFor purpose. of thi. instrument au oi the foregoing described property. property rights ancllnterests shall be referred to as .. the
property . )
MAil TAX STATEMENT TO: .... Le::il __
RECORD PAGO 1. ,z.J QllLY ....... 1 fill

." ."
ThIs Deed of Trust Ie fOf the purpose of securing: 1. Payment of the indebtedness in the principal Bum of
evidenced by that certain promissory note of even date herewith made by Trulltor; or anyone of them. payable to Beneficiary or :;
order, and any extension or renewal thereof. which promissory note is in the following form: 2. Performance of
oach agreement of Trustor contained or incorporated herein by reference; 3. Payment of suchsums as may be adVanced by
Beneficiary or Trustee to protact the sacurity in accordance with the tarms of this Deed of TrUll, plus interesl t_ at the
rate se1 forth in said promissory note; and 4. Payment of such further aurne 88 may be advanced by Beneficiary when evidenced
by another promissory note lor promissDry notes, it is aD aecured.
PROMISSORY NOTE - STRAIGHT - SECURED BY DEED OF TRUST
,OM

?tJo3,
.......
after da .. , for value received, theundarsigned makerla' proml.elsl to pay t.
DAn. NIDIDIt v;:;;"f
C8/,(;:{,(h,)iir JiTnfiuU(Wc. . 0taUD
- i
the sum of M UUtJllE't,.D fJ@
with intereat from vt Fef3 7B
_--II:::9w*"" __ percent per annum. payable
Should interest not be paid when due. it shall thereafter bear like interest 81 the U"ICipaI, but such unpaid . 8t 80
compounded shall not exceed an amount equal to simple interest on the unpaid principal at the maximwn rate permitted by law.
Should defautt be made in payment of intentSt when due. the whole sum of principal and accrued interest ahllli become
immediately due. without notice. at the option of the holder of this note. Interest after matwity will accrue at the rete indicated
above. Princlpel and inlere.1 are payable in lewful money of the United Stete.. Eacih maker will be jointly and severally Bable,
and consents to the acceptance of security or. substituted security for this note. and waives presentment, demand and proteSt
and the right co a8sart any staMe of limitations. A married person who ligns this nota agraa8 that recoursa may be had against
hislher ,8eparate property for any obligation contained herein. If any ection be instituted on this nota. the undersigned
prom; C_I '0 pay ouch sum as the Court may fix as attomey'. feel. This Note is secured by a Deed of TNSt of aven
date herewith.
To protoct ...... curlty 01 this Deed of Trust, Trua.or agrees:
(1 I To keep the property in good condition and repair; not to remove, substantially attar or any building thereon; to
completa or restore promptly and in good and workmanlika manner any building which may be constructed. damaged Or destroyed
thereon and to pay when due an claims for lebor performed end msterials furnished therefor; to comply with aD laws affecting the
property or requiring any alt8fations or improvements to be made thereon; not to commit or permit waste. thereof; not to commit.
suffer or permit any act upon the property in viofation of faw: to cultivate. irrigate. fertJlize, fumigate, prune 'and do all other acta
which 'rom the charactei or use of the property mey be rS8Ionabty necessary, the spscific enumeration. herem not exduding the
general. .
(2) To provide. maintain and deliver to 8eneficlary tite and, jf required by Beneficiary. other Insurance satisfactory to and with
loss payabiB to Beneficiary. The amount collected under any fire or other insurance policy. may be applied by BenefiCiary upon any Q
indebtedness secured hereby and in such order as Beneficiary mey determine. Of at option of Beneficiary the entire amount so C:)
collected or any part thereof may be released to Trustor, Such aPPlication or rmease shall not cure or waive eny default or notice
of defauft hereunder or invalidate any ect done pursuant to. such notice. eo
(3) To appear in and defend action or proceedinQ purporting to effect the security hereof 'the or powers oP
Beneficiary or Trustee; and to ehe extent permitted by law, to pay aU costs and expenses. including the cost of evidence of title and
anomey's tees. in any such action or proceeding in which 8enefM:iary or Trustee may appear. and in any suit 'brought by Beneficiary
to fo,eclose this Oeed of Trust or enforce the rights of Beneficiary or TNStee her8\.Wlder.
(4) To pay: at least ten days before delinquency all tueland aueslments affecting the ptopeny. including assessments on
appurtenant water stock; when due, allanctlfT1brances. charges and liens. with Interest. on the property or any part theraot, which
appear to be prior or superior hereto; and all costs. fees and expenaes of this Trust to the.exeent permitted by law.
(5) Should Trustor fail to make any payment or to do any act as herein provided. then Beneficiary or Trustae. but withoUt
obligation to do flO. and without notice to or demand upon Trustor; and without releaSing Trus,or from any obligation hereof. may:
make or do the 8ame in such manner end to such extent as either may deem necessary to protect the security hereoi. BeneficiarY
RECORD PAGES 1, 2. 3 6. 4 ONlY, P.ge 2 of 6
.
i
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========a=1
or Trustee being aythorized to enter upon the prOperty for such purposes; appear in and defend any action or proceeding
to affect the secUrity hereof or the rights or powers of Beneficiary or Trustee; pay. purchase. contest or compromise any
encumbrance, charge or lien which in the judgment of either appears to be prior or superior hereto; and. in exercising any such l t
powers. pay necessary expenses. emJ)loy counsel and pay his reasonable fees. 1"
16) To pay immediately and without demand alilums expended bV Beneficiary or Trustee pursuant to the terms of this Deed
of Trust. wnh interest from date of expenditure at the rate aet forth in the aforesaid promissory note.
q) That any award of damages in connection with any condemnation for public use or injury to said property or any part
thereof ;s hereby assigned and shall be paid to beneficiary who may apply or release such moneys received by him in the same
maMer and with the same effect as above provided for disposition of proceeds of fire or other insl.D'ance .
(8) That by accepting' P6Vmem of any sum secured hereby after its due date. Beneficiarv does not waive his right either to
reQuire prompt payment when due of all other sums so secured or to declare default for failure so to pay.
(91 That at any time. or from time to time: without liability there'or and without notice, upon wrinen request of Beneficiary
end presentation of this Deed of Trust Bnd said promissory note for endorsement. and without affecting the pcrsonaillability of any"
person for payment of the indebtedness secured hereby, Trustee may: reconvey any part of the property; consent to the making
of any map or plat thereof; join in granting any easement thereon; or join in Bny extension agreement or Bny agreement subordinating
the lien or charge hereof.
j t 01 That upon written request of Beneficiary stating that aU sums secured hereby havs been paid, and upon surrender of this
Deed of Trust and said promissory note to Trustee for cancellation and reterition and upon repayment of its fees, Trustee shall
reconvey. without warranty. the property then hald hereunder. The recitals in such reconveyance of any matters or facts shall be
conclusive proof of the truthfulness thereof. The grantee in such reconveyance may be described as -the person or persons legally
entitled thereto."
j1 1 I That as additional security. Trustor hereby gives to and confers upon Beneficiary the right, power and authority. during
continuance of these Trusts, to colfect the rents, issues and profits of the property. reserving unto Trustor the right, prior to any
de1ault by Trustor in payment of any indebtedness secured hereby or in performance 01 any agreement hereunder, to collect end
retain such rents, issues and pro1its as they become due end payable. Upon any such default, Beneficiary may at any time without
notice, either in person. by agent. or by 8 receiver to be appointed by a court, and without regard to the adequacy of any security
for the indebtedneu hereby secured, enter upon and take possession 01 the propeny or any part thereof. in his own name lue for
or otherwise collect such rents issues and profits, including those past due and unpaid, and apply the same, le88 costs and expenses
01 operation and collection, including reasonable attorney's 1ees. upon any indebtedness secured hereby, and in such order as
Beneficiary may determine. The entering upon Bnd taking possession of the property. the collection of such rents, issues lind profits
and the application tnereo' as aforesaid. shall not cure or waive any default or notice of default hereunder or invalidate any act dona
pursuant to such notice. "
(12) That upon default by Trustor in payment of any indebtedness secured hereby or' in performance of any agreement
hereunder. Beneficiary may declare all sums secured hereby immediately due and payable by delivery to Trustee 01 written
declaration of default and demand 10r sale and of written notice of delault and of election to cause to be sold the property, which
notice Trustee shall cause to be filed for record. Beneficiary shall also deposit with Trustee thia Deed of Trust. said promissory note
and all documents evidencing expenditures secured hereby.
After the lapse of such time as may then be required by law following the recordation 01 said notice of default. and notice
of sale having been given as then required by law, Trustee. without demand on Trustor, ahaUsellaaid property at the time and place
fixed by it in said notice of sale. either as 8 whole or in separate parcels, and in such order as it may determine. at public auction
to the highest bidder for cash in lawful money of the United States. payable at time of sale. Trustee may postpone sale of all or
any portion of said property by public announcement at such time and place of sale. and from time to time thereafter may postpone
such sale by public announcement at the time fixed by the preceding postponement. Truslee shall deliver to such purchaser its deed
conveying the property so sold. but without any covenant or warranty. expressed or implied. The recitals in such deed of any
matters or facts ehall be conclusive proof of the truthfulness thereof. Any person, including Trustor. Trustee, or Beneficiary a8
hereinafter defined. may purchase at such sale.
After deducting all costs. fees and expenses of Trustee and of this Trust to the extont permitted by law, including the cost
of evidence of title in connection with such 88le, Trustee shall apply the proceeds of 881e to payment of: all sums expended under
the terms hereof. not then 'repaid, with accrued interest at the rate set forth in the aforesaid promissory note;" all other syms then
SDCured hereby; and the remainder. if any. to the person or persons legally entitled thereto".
Immediately after such sale. Trustor shall surrender possession of the property to the purchaser. in the event poss88sion
has not previousty been surrendered by Tr.ustor, and upon failure to vacate the propeny, Trustor shall pay to the purchaser the
reasonable rental value of the property. andlor 8t purchaser's option. may be dispossessed in accordance with the law applicable
to tenant's holding over. .
1131 That Trustor. or if the property shall have been transferred. the then record owner. together with Beneffciarv. may from
time to time, by instrument in writing, substitute a successor or successors to any Trustee named herein or acting hereunder, wtlich
instrument, executed and acknowledged by each and recorded In the oUice of the recorder of the county or counties where the
property is situated. shall be conclusive proof of proper substitution of such successor Trustee or Trustees, wl'lo shall, without
conveyance from the Trustee predecessor. succeed to all its title. estate. rights. powers and duties. Said instrument must contain
Ihe name of the original Trustor. Trustee and Beneficiary hereunder, the book and page where this Deed is recorded, the name and
address of new Trustee. and such other matters as may be required bV law. If notice of default shall have been recorded. this
RECORD PAGES 1. 2. 3 &. 4 ONLY. Page 3 01 6
03' a,()254 04

power ot substitution cannot exercised until after the fees, and expenses of the then acting Trustee shall, ha,ltB been
to such Trustee. who shall endorse receipt thereof upon such instrument of substitution. The procedure herein provided for
substitution of rrustees shall be exclusive of all other provisions for substitution, statutory or otherwise. to the extent permitted by I
law.
(141 That this Oeed of Trust applies to. inures to the benefit 0', and binds all panies hereto. thei, heirs, legatees, devisees.
administrators, executors, successors and assigns. The term Beneficiary shall mean the owner and holder, including pledgees, of
the promissory note secured hereby. whether Of' not named as Beneficiary herein. In this Deed of Trust, whenever the context so
requirel, the mascutine gender includes the feminine and/Of neuter. and the sinQu:lar number includes the plural. and all obligations
of each Trustor hereunder are joint and several.
115) That Trustee accepts this trust when this Deed of Trust, duly executed and acknowledged. is made a public record as
provided by law. TrUSlee i. nOI ol!ligaled 10 norlly any party herelo 01 pending sale under, any olher Deed 01 Trusl or 01 any aClion
or proceeding In which TrustOt. Beneficiary. or Trustee shall be party unless brought by Trust .
(16) Without affecting the liability of Trustee or of any other party now or hereafter bound by the terms hereof for any obligation
secured hereby. Beneficiary may. from time to time and with Dr without notice 8S he ahall determine. rel88s8 Bny person now or
hereafter liable for the performance of such obligation. extend the time for payment 01 performance, accept additional security. and
alter, substitute or release any security.
(17) Trustee or Beneficiary may enter upon and inspect the premises at any reasonable time.
{18} No remedy hereby given to Beneficiary or Trustee is exclusive of any other remedy hereunder or under any present or future
law. No delay on the part of Trustee or Beneficiary in enforcing their respective rights or remedies hereunder shall constitute a
waiver thereof. .
(19) Trustor waives tho right to assert at time any statute of limitations a8 a bar to any action brought to enforce any
obligation hereby secured.
(20, Should Trustor. without Beneficiary's written consent. voluntarily sell; transfer or convey his interest in the property or any
pan thereof, 01 if by operation of law. it be sold. transferred or conveyed. then Beneficiary may. at its option. declare all sums
secured hereby immediatety due and payable. Consent to one such transaction shall not be deemed 10 be a waiver of the right to
require such consent of future or successive transactions.
(21) The invalidity or unenforceabilily of any provision herein shall not affect the validity and enforceability of any other
provision.
Each undersigned Trustor requests that a copy of any Notice of Default and of any Notice ot Sale hereunder shaD be mailed to him
8t the addreSs hereinabove set _ ... '-

__ __
COUNTY OF."'-.....
RIGHT THUMBPRINT {()plio".I'
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!
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personstly appeared


pro 10 me on t Sla a 511 .ctary
evidenceJ to be the peflon)a1 whose neme(N, to
thewithin t and acknowledged to me lhal y uted
the IIJntli". his e their authorized capacilYlldJ. and t y his their
on instrument the personOiC" 01 the entity upon ....... ... ........... "
which It\e PI!so"'?( Dcted. executed tho instrumem, e . CATERNlA SOLOMON
WITNESS my hand and oftlciel .cal. i Commission 81247905
2' NoIay I'I.CIIc: - CoJIIanIa f
J los Angeles Cauntr -
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RIGHT THUMBPRINT IOp1ion8l1
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8

CLAIMED BY SIGNERIS,
INDIVIDUAl,SI
CORPORATE ______ _
OFfiCERS -----rrmtiiT---
(Imli,1
o PARTNER,S) 0 LIMITED
o GENERAL
o ATTORNEY IN FACT
o TRUSTEEIS)
8
SIGNER IS AEPRESfNTINO:
(NoW( Of PlRSONCs' 011 ENTm'hESU:
ORO PAGES 1. 2. 3 & 4 ONLY. Page 4 016
03 3025404


,/

CM 010
'-"'" -
OR PARlY YJlTHOUT ATTORNEY (Na"., Slata Bar nurrilef, and 1Jda8ss):

Carl E- Kohlweck, SBN 087139
Los Angeles Superior Coun
Law Offices of Carl E- Kohlweck
28437 Plainfield Drive, Rancho Palos Verdes, CA 90275
OCT 05 2012 TELEPHOHENO,310-480-3423 FA''''''.' 310-377-8572
ATTORNEY FOR (NomoI' Plaintiff Karen de la Carrierel
SUPERIOR COURT OF CAUFORNIA, COUNTY OF Los Angeles
John A. CI=utIve Officer/CI
smeET AOORESS, III North Hope Street
MAlUNGAIlCOESS, III North Hope Street
By SHA ESLEY ' Depl
ClTYANOZIPCOOE, Los Angeles, CA 90012
SRANCH NAME, Central - Stanley Mosk Courthous
CASE NAME:
CIVIL CASE COVER SHEET
Complex Case Designation
CASE NlNBER;
BC49339
[ZJ Unlimited
0
Umited
o Counter o Joinder
(Amount (Amount
demanded demanded is Filed with first appearance by defendant
JUDGE:
exceeds $25,000) $25,000 or less) (Cal. Rules of Court, rule 3.402)
DEPT:
ems 1-6 be/ow must be completed (see instructions onpage 2).
I. Check one box below for the case type that best describes this case:
Auto Tort
Contract Provisionally Complex Civil Utlgation
B Auto(22)
0
Breach of contractlwarranty (06)
(Cal. Rules 01 Court, rut ..
Uninsured motorist (46) 0
Rule 3.740 collections (09) 0
Antitrust.frrade regulation (03)
Other PUPDIWD (Personat Injury/Property 0
other collections (09) 0 Construction defect (10)
Damage/Wrongtut Death) Tort
0
Insurance coverage (18) 0
Mass tort (40)
o Asbestos (04)
0
other contract (37) 0 Securities litigation (28)
o Product liability (24)
Real Pr_rty 0
Environmentalrr oxic tort (30)
o Medical malpractice (45)
0
Eminent domain/Inverse
0 Insurance coverage daims arising from the
o other PIIPOIWD (23)
condemnation (14)
above listed provisklnally oomplex case
Non-l'llPDIWD (Other) Tort
o Wrongful evidion (33)
types (41)
o Business tort/unfair business practice (07)
[ZJ other real property (26) Enforcement of Judgment
o Civil rights (OB) Unlawful Detainer
o Enforcement of judgment (20)
0
Defamation (13)
o Commercial (31)
Miscellaneous Civil Complaint
0
Fraud (16)
o Residential (32)
o RICO(27)
0
Intellectual property (19)
o Orugs(38)
o Other complaint (not 5pecified above) (42)
0
Professional negligence (25) Judicial Review
Miscellaneous Civil Petition
0
other non-PIIPOIWD tort (35)
o Asset lorteiture (05)
D Partnership and corporate govemance (21)
Ooyment
o Petition re: arbitration 3Ylard (11)
D Other petition (not specified above) (43)
WrongfUl termination (36) o Writ 01 mandate (02)
E5 othet'employment(15) El othet' judicial review (39)
2. This case L.J is lZJ is not complex under rule 3.400 of the Califomia Rules of Court. If the case is complex, marl< the
factors requiring exceptiona1ludicial management:
a. 0 Large number of separately represented parties d. 0 Large number of INitnesses
rk
ty
3
bO Extensive motion practice raising difficult or novel
issues that will be time-consuming to resolve
Substantial amount of documentary evidence
e. 0 Coordination with related actions pending in one or more courts
in other counties, states, or countries, or in a federal court
C.O I. 0 Substantial posljudgment judicial supervision
3. Remedies sought (check all that apply): a.0 monetary b.[ZJ nonmonetary; declaratory or injunctive relief c.
4. Number 01 causes of action (specify): 8
5. This case 0 is [l] is not a class action suit.
6. If there are any known related cases, file and serve a notice of related case.
Date: October 4, 2012
Carl E. Kohlweck
Plaintiff must file this cover sheet with the first paper filed in the action or proceeding (except small claims cases or cases filed
under the Probate Code, Famity Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.) Failure to file may result
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 Vlilt be used for statistical purposes
CIVIL CASE COVER SHEET

. -
/
,
,--



INSTRUCTIONS ON HOW TO COMPLETE THE COVER SHEET
CM010
To Plaintiffs and Others Filing First Papers. If you are filing a first paper (for example. a complaint) in a civil case, you must
complete and file, along IMth your first paper, the Civil Case Cover Sheet contained on page 1. This inlonmation IMII be used to compile
statistics aboul the types and numbers of cases filed. You must complete items 1 through 6 on the sheet. In Hem I, 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 Hem I,
check the more specific one, If the case has multiple causes 01 action, check the box that best indicales the primary cause 01 action.
To assist you in completing the sheet, examples 01 the cases that belong under each case type in Hem 1 are provided below. A cover
sheet must be filed only wHh your initial paper. Failure to file a cover sheet IMth the first paper filed in a civil case may subject a party,
its counsel, or both to sanctions under rules 2.30 and 3.220 01 the Califomia 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 01 money
owed in a sum stated to be certain that is not more than $25,000, exdusive 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 10liolMng: (1) tort
damages, (2) punitive demages, (3) recovery 01 real property, (4) recovery 01 personal property, or (5) a prejudgment writ 01
attachment. The identification 01 a case as a rule 3.740 collections case on this lonn means that it IMII be exempt from the general
time-for-service requirements and case management rules, unless a defendant files 8 responsive pleading. A rule 3.740 collections
case IMII be subject to the requirements for service and obtaining a judgmenl in rule 3.740.
To Parties In Complex Cases. In complex cases only, parties musl also use the Civil Case Cover Sheet to designate whether the
case is complex. If a plaintiff believes the case is complex under rule 3.400 01 the Califomia Rules 01 Court, this must be indicated by
completing Ihe appropriale boxes in Hems 1 and 2. If a plaintiff designales a case as complex, the cover sheet must be served IMth 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
plaintiffs deSignation. a counter-designation that the case is not complex, or, if the plaintiff has made no deSignation, a designation that
the case is complex. CASE TYPES AND EXAMPLES
Auto Tort Contract
Auto (22)-personallnjurylProperty Breach of ContractNVarranty (06)
DamageAlVrongful Death Breach of RentallLease
Uninsured Motorist (46) (if the Contract (not unlawful detainer
caS8 involves en uninsured or wrongful eviction)
motorist claim subject to COntract/VVarranty Breach-Seller
arbitration. chedc this item Plaintiff (not fraud or negligence)
instead of Auto) Neg\gent Breach of ContractJ
Other PIIPOIWO (PersonallnjuryJ Warranty
Property OamagehVrongful Death) Othet' Breach of ContractlWarranty
Tort Collections (e.g., money owed, open
Asbestos (04) book accounts) (09)
Asbestos Property Damage COllection Case-Seller Plaintiff
Asbestos Personal Injury/ other Promissory Note/Collections
Wrongful Death Case
Product Uability (not asbestos Of Insurance Coverage (not provislonsJly
foxic!envirOllmental) (24) complex) (18)
Medical Malpractice (45) Auto SUbrogation
Medical Malpraclice- Other Coverage
Physicians & Surgeons other COntract (37)
other Professional Health Care Contractual Fraud
Malpractice other Contract Dispute
Other PUPOIWD (23) Real Property
Premises Liability (e.g., slip Eminent Domain/Inverse
and fall) Condemnation (14)
Intentional Bodily Injury/PDMlD Wrongful Eviction (33)
(e.g., assault, vandalism) other Real Property (e.g., quiet title) (26)
Intentional Infliction of Writ of Possession of Real Property
Emotional Distress Mortgage Foreclosure
Negligent Infliction of Quiet Tit1e
Emotional Distress other Real Property (not eminent
other PVPDIWD domain. landlordltenant, or
Non.pI/PIlIWD (Otherl Tort foreclosure)
Business TortlUnfair Business Unlawful Detainer
Practice (07) COmmercial (31)
CMI Rights (e.g., discrimina1ion, Residential (32)
false arrest) (not civil Drugs (38) (If the case involves illegal
harassment) (DB) drugs. check this item; otherwise,
Defamation (e.g., slander,libel) repott as Commeldal or Residential)
(13) Joolcial Review
Fraud (16) Asset Forfetture (OS)
Intellectual Property (19) Petition Re: Artlttration Award (11)
Professional Negligence (25) Writ of Mandate (02)
Legal Malpractice Mandamus
other Professional Malpractice Writ-Mandamus on Umited COurt
(not medical or legal) Case Matter
Other Non--PIIPDM'O Tort (35) Writ-Other Umited Court Case
Employment
Wrongful Termination (36)
Other Employment (15)
C010 (Rev . .kI1r " 20(7)
Review
other Judicial Review (39)
Review 01 Health Officer Order
Notice of Appeal-Labor
Commissioner Appeals
CIVIL CASE COVER SHEET
Provisionally Complex Civil Litigation (Cal.
Rutes 01 Court Rules 3.4O(hJ.403)
AntitrustITrade Regulation (03)
Construction Deled (10)
Claims Involving Mass Tort (40)
Securities Litigation (2B)
Environmental/Toxic Tort (30)
Insurance COverage Claims
(arising from provisionally complex
case type lis/ed above) (41)
Enforcement of Judgment
Enforcement of Judgment (20)
Atstract of Judgment (Out of
County)
Confession of Judgment (non-
domestic relatfons)
Sister State Judgment
Administrative Agency Award
(not unpaid taxes)
PetitionICertification of Entry of
Judgment on Unpaid Taxes
other Enforcement of Judgment
Case
Miscellaneous Civil Complaint
RICO (27)
Other Complaint (not spec;t;ed
above) (42)
Dedaratory Relief Only
Injunctive Only
hBrassment)
Mechanics Lien
other Commercial Complaint
Case (non4otf1non-complex)
Other Civil Complaint
(non-torllnon-complex)
Miscellaneous Civil Petition
Partnership and Corporate
Govemance (21)
Other Petition (not specified
above)(43)
Civil Harassment
Workplace Violence
ElderlDependent Adun
Abuse
Election Contest
Petition for Name Change
Petition for Relief From Late
Claim
other Civil Petition
Page2of2

'f

SHORT nllE;

CASE NUMBER
Karen de la Carriere v. William N. Greene
CIVIL CASE COVER SHEET ADDENDUM AND
STATEMENT OF LOCATION
(CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION)
This fonn Is required pursuant to Local Rule 2.0 in all new civil case filings in the Los Angeles Superior Court.
Item I. Check the Iypes of hearing and fill in the estimated length of hearing expected for this case:
JURY TRIAL? III YES CLASS ACTION? D YES LIMITED CASE? DYES TIME ESTIMATED FOR TRIAL ..
Item II. Indicate the correct district and courthouse location (4 steps -If you checked "Limited Case", skip to Item III, Pg. 4):
Step 1: After first completing the Civil Case Cover Sheet form, find the main Civil Case Cover Sheet heading for your
cese in the left margin below, and, to the right in Column A, the Civil Case Cover Sheet case type you selected.
Step 2: Check 2!!! Superior Court type of action in Column B below which best describes the nature of this case.
Step 3: In Column C, circle the reason for the court locetion choice that applies to the type of action you have
checked. For any exception to the court location, see Local Rule 2.0.
Applicable Reasons for Choosing Courthouse Location (see Column C below)
1. Class actions must be filed in the Stanley Mosk Courthouse, central distriCt.
2. May be filed in central (other,oounty, or no bodily injury/property damage).
6. Location of property or pennanently garaged vehicle.
7. Location 'Nhere petitioner resides.
3. LoCation wtlere cause of action arose. 8. Location wherein defendant/respondent functions wholly.
4. location INhere bodily injury, death or damage occurred.
5. Location where performance required or defendant reskies.
9. Location where one or more of the parties reside.
10. Location of Laoor Commissioner Office
Step 4: Fill in the information requested on page 4 in Item III; complete Item IV. Sign the declaration.
A
Civil case cover Sheet
Category No.
Auto (22)
Uninsured Motorist (46)
Asbestos (04)
Product Uability (24)
Medical Matpradice (45)
other
Personal Injury
Property Damage
wrongful Death
LACIV 109 (Rev. 03(11)
LASC Approved 03-04
(23)
B C
Typo of Action Applicable Reasons -'
tCheck only one) See Step 3 Pbt:Ne
0 A7100 Motor Vehicle - Personallnjury/Property OamageNlrongfu\ Death 1.,2.,4.
0 A7110 PersonallnjurylProperty OamageM'rongful Death - Uninsured Motorist 1 .. 2 . 4.
0 AB070 Asbestos Property Damage
0 A7221 Asbestos - PersonallnjurylWrongful Death
0 A7260 Product Liability (not asbestos or tOXic/environmental)
0 A7210 Medical Malpractice - Physicians & Surgeons
0 A7240 other Professional Health Care Malpradice
0 A72Sa Premises Uability (e.g .. Slip and fall)
0 A7230 Intentional Bodily InjurylProperty OamageM'rongfu\ Death (e.g. 1
assault, vandalism, etc.)
0 A7270 Intentional Infliction of Emotional Distress
0 A7220 Other PersonallnjurylProperty DamageiWrongful Death
CIVIL CASE COVER SHEET ADDENDUM
AND STATEMENT OF LOCATION
2.
2.
1 . 2 . 3.,4.,8.
1 . 4.
1.,4.
1 . 4.
1.,4.
1 . 3.
1.,4,
Local Rule 2.0
Page 1 of 4
'f



I SHORT llTLE:
Karen de fa Carriere v. William N. Greene
I CASE .........
A
CMI C .... Cover Sheet .
Category No.
Business Tort (07)

Civil Rights (08)


Defamation (13)
.C' "el
=15
Fraud (16)
..
15;:

a.""
Professional Negligence (25)
C E1
0"
ze
Other (35)
C! Wrongful Termination (36)

i
E
Other Employment (15)
....
Breach of Contractl Warranty
(06)
(not insurance)
1:)
..

Collections (09)
..,
Insurance COverage (18)
Other Contract (37)
Eminent Domainllnverse
Condemnation (14)
i
Wrongful Eviction (33)
a.
..
.,
""
Other Real Property (26)
Unlawful Oetainer-Commercia\
ill
(31)

Unlawful Detainer-Residential
(32)

Unlawful Detainer.

Post-Foreclosure (34)

Unlawful Detainer-Orugs (38)
LACIV 109 (Rev. 03111)
LASC Approved 03-(14
B
. Type of Action
(Check only one)
0 A6029 Other ComrnerciallBusiness Tort (not fraud/bfeach of contract)
0 Moo5 Civil Rights/Discrimination
0 AB010 Defamation (s1anderllibel)
0 AB013 Fraud (no contract)
0 AB017 Legal Malpractice
0 A6060 Other Professional Malpractice (not medical or legal)
0 AB025 Other Noo-PersonallnjurylProperty Damage tort
0 A6037 Wrongful Termination
0 A6024 Other Employment Complaint Case
0 AB109 Labor Commissioner Appeals
0 A6OO4 Breach of RentalJLease Contract (not unlawful detainer or wrongful
eviction)
0 ABOD8 Contrac:tJWarranty Breach -Seller Plaintiff (no fraud/negligence)
0 AB019 Negligent Breach of Contrac:tJWarranty (no fraud)
0 AB028 Other Breach of ContractlWarranty (not fraud or negligence)
0 A6OO2 Collections Case-5eUer Plaintiff
0 A6012 Other Promissory NoteJCollections Case
0 AB015 Insurance Coverage (not complex)
0 ABOO9 Contractual Fraud
0 AB031 Tortious Interference
0 A6027 other Contract Dispute(not breachlinsurancelfraudlnegtigence)
0 A7300 Eminent DomairJCondemnation Number of parcels __
0 AS023 Wrongful EViction Case
0 AB018 Mortgage Foreclosure

Quiet Title
0 AB060 Other Real Property (not eminent domain, landlordltenant, foreclosure)
0 A6021 Unlawful Detainer-Commerclal (not drugs or wrongful eviction)
0 AB020 Unlawful Detainer-Resijential (not drugs or wrongful evidion)
0 A602OFUnlawfuIDetainer-Post-Foreaosure
0 A6022 Unlawful Detainer-Drugs
CIVIL CASE COVER SHEET ADDENDUM
AND STATEMENT OF LOCATION
C
Applicable Reasons-.

1 . 3.
1.,2.,3.
1 . 2.,3.
1 .. 2 .. 3.
1 .. 2 . 3.
1.,2 .. 3.
2 . 3.
1 .. 2 . 3.
1.,2 .. 3.
10.
2 .. 5.
2 .. 5.
1.,2 .. 5.
1.,2.,5.
2 . 5 .. 6.
2 .. 5 .
1 .. 2., 5 .. 8.
1 .. 2., 3 .. 5.
1 . 2 .. 3 . 5.
1.,2 . 3.,8.
2.
2.,6.
2.,6.
W
2.,6.
2 .. 6.
2.,6.
2.,6.
2.,6.
Local Ru)e 2.0
Page 2 of 4

.,
,


I SHORT TIM:
Karen de la Carriere v. William N. Greene
I CASE NUMBER
A
CMI Case Cover Sheet
Category No.
Asset (05)
iI Petition re Arbitration (11)
'"
'5
'"
'"
:a
of Mandate (02)
'C
"
...,
Other Judicial Review (39)
a
AntitrusVTrede Regulation (03)
i
'"
Construction Defect (10)
.'"
::;
..
Claims Involving Mass Tort
-a (40)
E
8
Serurities utigatlon (28)
Z.
0;
a
Toxic Tort
...
Environmental (30)
.
Insurance Coverage Claims
Q.
from Complex Case (41)
III
Enforcement
ui
5 "
of Judgment (20)
- ...,
c-
'" 0
on
RICO (27)


Other Complaints
"'u

(Not Specified i'b<Ne) (42)
:ED
Partnership Corporation
Governance (21)
on on
.g
. '"
Other Petitions

(Not Specified i'b<Ne)
:iU
(-43)
LACIV,09 (Rev. 0311')
LASe Approved 0341
.
B
Type of Action
(Checl< only one)
0 ASl0B Asset Forfeiture Case
0 AS115 Petition to CompeVConfirmNacate Arbitration
0 AS151 Writ - Administrative Mandamus
0 AS152 Writ - Mandamus on Umited Court Case Matter
0 A6153 Writ - Other Umited Court Case Review
0 A6150 Other Writ IJudicial Review
0 A6003 AntitrusVTrade Regulation
0 ASoo7 Construction Defect
0 A6OO6 Claims Involving Mass Tort
0 AS035 Seculitles Utigatlon Case
0 AG036 Toxic T ortIEnvironmental
0 AS014 Insurance Coverage/Subrogation (complex case only)
0 AS14' Sister State Judgment
0 AS160 Abstract: of Judgment
0 ASl07 Confession of Judgment (non-domestic retations)
0 AS'40 Administrative Agency Award (not unpaid taxes)
D A6114 Petition/Certificate for Entry of Judgment on Unpaid Tax
0 AS112 Other Enforcement of Judgment Case
0 AS033 Racketeering (RICO) Case
0 A6030 Oedaratory Relief Only
0 A6040 Injunctive Relief Only (not domestirJharassment)
0 AS011 Other Commercial Complaint Case (non-tortlnolH:Omplex)
0 ASooO Other Civil Complaint (non-tortlnon-complex)
0 AS113 Partnership and Corporate Governance Case
0 A6121 Civil Harassment
0 A6123 Workplace Harassment
0 A6124 Elder/Dependent Adult Abuse Case
0 A6190 Election Contest
0 A6110 Petition for Change of Name
0 A6HO Petition for Relief from Late Claim Law
0 A6100 Other Civil Petition
CIVIL CASE COVER SHEET ADDENDUM
AND STATEMENT OF LOCATION
C
Applicable Reasons -
See Step 3 i'b<Ne
2.,6.
2.,5.
2., B.
2.
2.
2.,8.
1.,2., B.
1.,2.,3.
1 .. 2, B.
1.,2.,8.
1.,2.,3., B.
1.,2.,5 .. B.
2.,9.
2.,6.
2 .. 9.
2., B.
2., B.
2.,8.,9.
' .. 2., 8.
1.,2., B.
2" 8.
'.,2 .. 8.
'.,2., B.
2 .. B.
2.,3.,9.
2.,3 .. 9 .
2.,3 .. 9.
2.
2 .. 7.
2.,3.,4., B.
2.,9.
Local Rule 2.0
Page 3 of 4
I
. -
, ,
...


SHORTnn..E: CASE NUMBER
Karen de la Carriere v. William N. Greene
Item III. Statement of Location: Enter the address of the accident. party's residence or place of business, performance, or other
circumstance indicated in Item II., Step 3 on Page 1, as the proper reason for filing in the court location you selected.
ADORESS:
REASON: Check the appropriate boxes for the numbers shown
1935 North Serrano Avenue
under Column C for the type of action that you have selected for
Los Angeles, CA 90021
tIIis case.
01.02.03.04.05.06.07. DB. 09.010.
CITY: 5TAT: ZlPCOOf:
Los Angeles CA 90021
Item IV. Declaration of Assignment: I declare under penalty of under the laws of the State of california that the foregoing is true
and correct and that the above-entitled mailer is properly filed for assignment to the Stanley Mosk courthouse in the
_____ District of the Superior Court of Catifornia, County of Los Angeles [Code Civ. Proc .. 392 etseq., and Local
Rule 2.0, subds. (b), (c) and (d)J.
Dated: October 4, 2012
PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY
COMMENCE YOUR NEW COURT CASE:
1. Original Complaint or Petition.
2. If filing a Complaint, a completed Summons form for issuance by the Clerl<.
3. Civil Case Cover Sheet Judicial Council form CM.Q1 O.
4. Civil Case Cover Sheet Addendum and Statement of Location form, LACIV 109, LASC Approved 03-04 (Rev.
03/11).
5. Payment in full of the filing fee, unless fees have been waived.
6. A signed order appointing the Guardian ad Litem, Judicial Council form CIV.Q10, if the plaintiff or petitioner is a
minor under 1B years of age will be required by Court in order to issue a summons.
7. Additional copies of documents to be conformed by the Clerl<. Copies of the cover sheet and this addendum
must be served along with the summons and complaint, or other initiating pleading in the case .

51 LACIV 109 (Rev. 03111) CIVIL CASE COVER SHEET ADDENDUM
AND STATEMENT OF LOCATION
Local Rule 2.0
Page 4 of4
, LASC Approved 03-04
to
"I