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10/07/2025 Regular & HA
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Correspondence - Non Agenda
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11/13/2025 5:28:21 PM
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City Clerk
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10/7/2025
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I Plaintiff JODI T14ORN was hurt and injured in her health, strength, and activity,sustaining injury to <br /> 2 her nervous system and person, all of which injuries have caused, and continue to cause, Plaintiff`great <br /> 3 naerrtl;physical, and nervous pain and suffering. As a result of such injuries} Plaintiff has suffered <br /> 4 general damages in an amount in excess of the jurisdictional miniaiuna of this Court. <br /> 29. As a legal result of defendants' tortious misconduct,as aforesaid,Plaintiff JODI THORN <br /> 6 <br /> has had to employ the services of hospitals, physicians, surgeons,.nurses, and other professional <br /> 7 <br /> services, and.said.Plaintiff was compelled to incur expenses for ambulance,medicines,x-rays and <br /> 9 other medical supplies and.services.Plaintiff is informed and believes and thereon alleges that further <br /> 10 services of that nature will be required by Plaintiff for an unpredictable period in the future, all to <br /> l 1 Plaintiffs damage,in a sutra.according;to proof at the time of trial, <br /> 12 30. As a further result of the tortious misconduct of defendants,Plaintiff JODI THORN'S <br /> 13 <br /> property was damaged and destroyed,and said Plaintiff lost the use of same, all to Plaintiff's damage, <br /> 14 <br /> in a sum.according to proof at the time of trial. <br /> 15 <br /> l 6 31,As a further legal result of the tortious misconduct of defendants; and each of them, <br /> 17 Plaintiff suffered loss of earnings and earning capacity, in the past,present and future, in an amount <br /> 18 that will be demonstrated at trial according to proof. <br /> 19 32, Upon compliance with Code of Civil Procedure section.998,Plaintiff will :seek.an award <br /> 20 of prejudgment interest and costs as to any non-governmental entities,pursuant to California.Civil <br /> 21. <br /> Code§ 3291,in a sum according.to proof. <br /> 22 <br /> 33. As a further legal result of the 'oiegoing,.Plaintiff suffered.and will continue to suffer <br /> 23 <br /> 24 pain, anxiety, emotional distress; and other general damages,in a sum within the jurisdiction of this <br /> 25 court and according to proof at the time of trial. <br /> 26 PLAINTIFF'S FOURTH CAUSE OF ACTION <br /> 27 <br /> -7- <br /> 28 <br /> Complaint for Darna.ges <br />
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