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I has had to employ the services of hospitals,physicians, surgeons, nurses, and other professional 2 services;and said Plaintiff was compelled to_incur expenses for ambulance,medicines, x-rays and 3 other medical supplies and services,Plaintiff is informed and believes and thereon alleges that further 4 services of that nature will be required by plaintiff for an unpredictable period in the future,all to S Plaintiff's damage,in a sum according to proof at the time of trial. 6 13. As a further result of the tortious misconduct of defendants, Plaintiff JODI THORN'S 7 8 property was damaged and destroyed, and said Plaintiff last the use of same, all,to Plaintiff's damage, 9 in a sum according;to proof at the time.of trial. 10 1.4. .A.s a further legal result of the lortious inisconduct of defendants, and each of them, 11 Plaintiff suffered loss of earnings and.earning capacity, in the past,present and future,in an amount 12 that will be demonstrated at trial according to proof, 13 15, Upon compliance with Cade of Civil Procedure section 998, Plaintiff will.seek an award 14 of prejudgment interest and casts.as to any non-governmental entities,pursuant to California Civil 15 16 Code § 3291,in a sum according to proof. 17 16..As a further legal result of the foregoing, Plaintiff suffered and will continue to suffer 18 pain, anxiety; emotionaI distress, and rather general damages, in a sum within the jurisd efion of this 19 court and according to proof at the time of trial. 20 PLAINTIFF JODI THORN's SECOND CAUSE OF ACTION AS TO DEFENDANTS 21 CRIS`I`A,L GUITERREZ,CITY OF .ANA [Government Cade §8 O (a)].AND DOE'S 1- 22 50 23 M Plaintiff incorporates by this reference.all allegations in Paragraphs 1 through 16 of'this 24 25 complaint,as though fully set forth herein. 26 18.. At the times, places,:and in the:manner as aforesaid,C12.ISTAL GUTIERRF7 27 ..4- 28 Complaint for Damages