Friday, November 17, 2017

State Farm General Insurance Company vs City of Carmel-By-The-Sea THIRD AMENDED COMPLAINT FOR DAMAGES 1) Negligence 2) Dangerous Condition of Public Property 3) Inverse Condemnation

ABSTRACT: RE; SUPERIOR COURT OF CALIFORNIA, COUNTY OF MONTEREY UNLIMITED CIVIL CASE STATE FARM GENERAL INSURANCE COMPANY, Plaintiff, vs. CITY OF CARMEL-BY-THE-SEA; and DOES 1 through 10, inclusive, Defendants. Case No.:16CV002381 THIRD AMENDED COMPLAINT FOR DAMAGES 1) Negligence 2) Dangerous Condition of Public Property 3) Inverse Condemnation On January 4, 2017, Ashley Stander, Law Offices of Geordan Goebel, Attorneys for Plaintiff, submitted to the Superior Court of California, County of Monterey, THIRD AMENDED COMPLAINT FOR DAMAGES 1) Negligence 2) Dangerous Condition of Public Property 3) Inverse Condemnation. A fourth Conference Case Management and Conference: Trail Setting are scheduled for December 12, 2017, Department 15, according to the SUPERIOR COURT OF CALIFORNIA, COUNTY OF MONTEREY website. The THIRD AMENDED COMPLAINT FOR DAMAGES 1) Negligence 2) Dangerous Condition of Public Property 3) Inverse Condemnation document copy is embedded; named, including "City Forester." FIRST CAUSE OF ACTION, NEGLIGENCE [Cal. Gov. Code§§ 815.2, 815.6, 818.6. Municipal Code §17.481 SECOND CAUSE OF ACTION, DANGEROUS CONDITION OF PUBLIC PROPERTY [Cal. Gov. Code§ 835} THIRD CAUSE OF ACTION, INVERSE CONDEMNATION [Cal. Const, art. I,§ 19)
WHEREFORE, plaintiff prays for judgment against the defendants, and each of them as follows:
  1. For the sum of $64,792.40 and for interest thereon at the maximum legal rate from and after November, 2015;
  2. For costs of suit, expert fees and attorneys’ fees incurred therein;
  3. For such other and further relief as this Court may deem just and proper.
16cv002381 Third Amended Complaint for Damages 1-4-2017 by L. A. Paterson on Scribd
SUPERIOR COURT OF CALIFORNIA, COUNTY OF MONTEREY
UNLIMITED CIVIL CASE
STATE FARM GENERAL INSURANCE COMPANY, Plaintiff, vs. CITY OF CARMEL-BY-THE-SEA; and DOES 1 through 10, inclusive, Defendants.
Case No.:16CV002381
THIRD AMENDED COMPLAINT FOR DAMAGES
1) Negligence
2) Dangerous Condition of Public Property
3) Inverse Condemnation

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