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

State Farm General Insurance Company vs City of Carmel-By-The-Sea: OPPOSITION TO DEMURRER TO THIRD AMENDED COMPLAINT

ABSTRACT: RE: SUPERIOR COURT OF CALIFORNIA COUNTY OF MONTEREY STATE FARM GENERAL INSURANCE COMPANY, Plaintiff, vs. CITY OF CARMEL-BY-THE-SEA; and DOES 1 through 10, inclusive, Defendants. Case No.: 16CV002381 OPPOSITION TO DEMURRER TO THIRD AMENDED COMPLAINT On March 7, 2017, Ashley Stander, Law Offices of Geordan Goebel, Attorneys for Plaintiff, submitted to the Superior Court of California, County of Monterey, OPPOSITION TO DEMURRER TO THIRD AMENDED COMPLAINT. 1. ANY VALIDLY PLED CLAIM DEFEATS A DEMURRER. 2. PLAINTIFFS' THIRD AMENDED COMPLAINT SETS FORTH SUFFICIENT FACTS TO STATE ALL THREE CAUSES OF ACTION. A. The City's Violation of its Own Code Section Proximately Caused the Damages as Allege Herein. B. The City's Exercise of Dominion and Control over Trees within its Limits Prevented Property Owners from Rectifying Dangerous Condition of Property. C. Inverse Condemnation
3. CONCLUSION. The TAC sets forth sufficient facts to establish causes of action against the City. The demurrer should be overrruled.
The OPPOSITION TO DEMURRER TO THIRD AMENDED COMPLAINT document copy is embedded.

16cv002381 Opposition to Demurrer to Third Amended Complaint 3-7-2017 by L. A. Paterson on Scribd

SUPERIOR COURT OF CALIFORNIA COUNTY OF MONTEREY
STATE FARM GENERAL INSURANCE COMPANY, Plaintiff, vs. CITY OF CARMEL-BY-THE-SEA; and DOES 1 through 10, inclusive, Defendants.
Case No.: 16CV002381
OPPOSITION TO DEMURRER TO THIRD AMENDED COMPLAINT

State Farm General Insurance Company vs City of Carmel-By-The-Sea: OPPOSITION TO MOTION FOR SANCTIONS

ABSTRACT: RE: SUPERIOR COURT OF CALIFORNIA COUNTY OF MONTEREY

STATE FARM GENERAL INSURANCE COMPANY, Plaintiff, vs. CITY OF CARMEL-BY-THE-SEA; and DOES 1 through I 0, inclusive, Defendants. Case No.: 16CV002381 OPPOSITION TO MOTION FOR SANCTIONS On March 7, 2017, Ashley Stander, Law Offices of Geordan Goebel, Attorneys for Plaintiff, submitted to the Superior Court of California, County of Monterey, OPPOSITION TO MOTION FOR SANCTIONS. 1. STATE FARM'S COMPLAINT IS BASED UPON THE CITY'S VIOLATION OF ITS OWN ORDINANCE. 2. THE CITY'S MOTION FOR SANCTIONS IS FRIVOLOUS AND IN BAD FAITH. 3. CONCLUSION. The City's frivolous sanctions motion should be denied. Plaintiff's complaint is brought in good faith, and is supported by the facts and the law. The OPPOSITION TO MOTION FOR SANCTIONS document copy is embedded.

16cv002381 Opposition to Motion for Sanctions 3-7-2017 by L. A. Paterson on Scribd

SUPERIOR COURT OF CALIFORNIA
COUNTY OF MONTEREY
STATE FARM GENERAL INSURANCE COMPANY, Plaintiff, vs. CITY OF CARMEL-BY-THE-SEA; and DOES I through I 0, inclusive, Defendants.
Case No.: 16CV002381
OPPOSITION TO MOTION FOR SANCTIONS