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23. As a further legal result of the tortuous misconduct of defendants,and each of them, <br /> 2 Plaintiff suffered loss of earnings and earning capacity, in the past,present and future, in an amount <br /> 3 that.wil l be demonstrated.at trial according to proof. <br /> 4 24.Upon compliance with Code of Civil Procedure section 998, Plaintiff will seek art award <br /> S <br /> of prejudgmeiat interest and costs as to any non-governmental entities,pursuant to California Civil <br /> 6 <br /> Code§ 3291,in a sum according;to.proof, <br /> 7 <br /> 25. As a further legal result of theforegoirtg,,Plaintiff suffered and will continue to suffer <br /> pain, anxiety,emotional distress, and other general damages,in a sum within the jurisdiction:of this <br /> 10 court and according to proof at time.of trial.. <br /> 11 PLMNTIFF�S THIRD CAusrs,OF ACTION AGAINST THE MY OF SANTA ANA <br /> 12 ONLY {Veh, C. §17001.) <br /> 13 <br /> 26. Plaintiff incorporates by this reforence all allegations.in Paragraphs I through 25 of this <br /> 14 <br /> complaint,as though fully set forth herein. <br /> 1 <br /> 16 27. At the tines,places and iz the.manner as aforesaid,CR;ISTAL GUTIERREZ <br /> 17 operated the motor vehicle entrusted to her 6y the CITY OF SANTA AMA in a manner that <br /> 18 was negligent or wrongful iurd while DRIVER was aching within the course and.scope of her <br /> 1) <br /> 20 employment with a public entity. Asa result of CRI.STAL GUTII RRF7's negligent or wrongful acts, <br /> 21 as aforesaid,Plaintiff was caused to suffer severe and serious personal injuries and related damages, as <br /> 22. <br /> 23 aforesaid. <br /> 24 28. As a direct and proximate result of the negligence of defendants,and each of them, <br /> 25 <br /> 26 <br /> 27 <br /> -6 <br /> 28 C.omplaint for Damages <br />