cobain_v_gordon___holmes__doc_.pdf
DESCRIPTION
Courtney Love Cobain is suing her attorneys for malpractice, breach of fiduciary duty, and intentional interference with economic advantage. In a separate suit, the attorney is suing Love for defamation for tweets. The complaint alleges that the attorneys failed to pursue financial assets and personal property from Kurt Cobain's estate.TRANSCRIPT
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DONGELL LAWRENCE FINNEY LLPRichard A. Dongell (SBN 128083)([email protected])John A. Lawrence (SBN 073395)[email protected])707 Wilshire Boulevard, 45th FloorLos Angeles, CA 90017-3609Telephone: (213)943-6100Facsimile: (213)943-6101
Attorneys for Plaintiff Courtney Love Cobain
' FILEDLOS ANGELES SUPERIOR COURT
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JOHN M. ULAHttt, CUEftK
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$36 \^w^\Am*\SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT
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Case No.: ;COURTNEY LOVECOBAIN
Plaintiffs,
GORDON &HOLMES, Civil Trial Lawyers, aE^xr^P ofProfessional corporations:RHONDA J. HOLMES, a professionalcorporation; and RHONDA J. HOLMES, anindividual; and DOES 1through 10, inclusive,
Defendants.
BC525857
COURTNEYLOVE COBAIN'SCOMPLAINT FOR LEGALMALPRACTICE, BREACH OFFJ5S£iARY DUTY> INTENTIONALINTERFERENCE WITH APROSPECTIVE ECONOMIC^Y4£IAGE'AND NEGLIGENTINTERFERENCE WITH APROSPECTIVE ECONOMICADVANTAGE
COMES NOW Complainant COURTNEY LOVE COBAIN ("LOVE"), andalleges, complains, and avers, as follows: ' 33 -O O P7
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The Parties, Venue and .Tu'risdirrtnn _ „ 0 0 < S -v 5S 5 w m .. c «:1• LOVE is, and at all times herein mentioned was an inSivflMesid«| fft
Los Angeles County, California and/or New York State ' "' §§ §| g w o
2. Defendant GORDON &HOLMES ("G&H") is and at all times menSo|dwas alaw firm owned and operated as apartnership ofprofessional corporations, organized^!
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existing under the laws of the State of California. G&H has its principal place of business in SanDiego County, California at 223 West Dale Street, San Diego, CA 92101.
3. Defendant RHONDA J. HOLMES, APC ("Holmes, APC") is and at alltimes mentioned was aprofessional corporation authorized to practice law in the State ofCalifornia and authorized to form and did form apartnership with Frederic L. Gordon, APC("Gordon, APC"). Holmes, APC and Gordon, APC are the sole owners/partners in G&H and atall times relevant, Holmes, APC was in the business of practicing law with Gordon, APC in SanDiego County, at 223 West Dale Street, San Diego, CA 92101.
4. Defendant RHONDA J. HOLMES ("HOLMES") is and at all timesmentioned herein was an attorney licensed to practice in the States of California, Nevada, andUtah. HOLMES has her principal place ofbusiness in San Diego County, at 223 West DaleStreet, San Diego, CA 92101.
5. Complainant LOVE is informed and believes, and thereon alleges, that atall times herein mentioned, Defendants, and each of them, were the agents and/or employees ofeach of the remaining Defendants, and in doing the acts complained of, were acting within thescope ofsuch agency and/or employment and with the permission, authority and consent of eachof theremaining Defendants.
6. The acts and conduct of Defendants that are alleged in this Complaintoccurred in the Stateof California.
Factual Background
7. LOVE'S husband Kurt Cobain died in 1994 and an estate (the "CobainEstate") was set up to manage his assets on LOVE's behalfand on behalfof LOVE and theirdaughter, Frances Bean Cobain ("Frances").
8. In or around late 2008, LOVE was introduced to HOLMES through amutual acquaintance-a physician who had treated both LOVE and HOLMES. Defendants,through HOLMES, advised LOVE that she was correct in her belief that she had been misusedby her advisers in the management of the Cobain Estate, and that LOVE should place her trust inDefendants to seek redress for those claims. Defendants gained LOVE's trust and confidence
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and Defendants stated they would represent LOVE in her pursuit of the money and propertyLOVE believed to be stolen from the Cobain Estate. Moreover, HOLMES used her background,as well as her knowledge of LOVE's struggles, to forge aspecial relationship in which sheconvinced LOVE that she understood LOVE and had only LOVE's best interests in mind, andwas not entering the relationship solely for her own personal gain. Based on theserepresentations, LOVE relied on Defendants.
9. Between late 2008 and March 2009, LOVE met and communicated withDefendants on numerous occasions, and Defendants promised to prepare and circulate adraft ofacomplaint involving the money and property stolen from the Cobain Estate.
10. On April 7, 2009, Defendants went public with apress release stating thatthey would be bringing an impending civil case regarding the fraud perpetuated on the CobainEstate. By way of example, the press release quoted HOLMES stating, "I have never seen suchgreed and moral ttupitx.de. This case is going to make Bernard Madoff look warm and fuzzy."
11 • LOVE never received adraft of the complaint which Defendants had •claimed they were working on for months on her behalf. Among other excuses, Defendantsrepresented that they had prepared adraft of such acomplaint, but unknown agents has brokeninto her computer and erased the drafts. Later in 2009, LOVE reached out to Defendantsregarding the complaint and Defendants told LOVE that they were "too busy" to draft thecomplaint. To date, Defendants have failed to provide acopy of this alleged draft complaint.
Holmes' Letter to Frances
12. On April 27, 2009, HOLMES sent aletter (the "HOLMES LETTER") toFrances, who was then sixteen years old. (A true and correct copy of the HOLMES LETTER isattached hereto as Exhibit "A").
13. LOVE first saw the HOLMES LETTER in or about November 2012,when the HOLMES LETTER was produced in discovery by Defendants in arelated action'Defendants filed against LOVE on May 26, 2011 for libel, invasion ofprivacy - false light, andintentional interference with aprospective economic advantage (the "Related Action"). LOVE isnot an attorney or professional and none ofher prior counsel informed her of the significance of
ECONOMIC^^^D^^rrwr^^^^^PKObPhCIIVE ECONOMIC ADVANTAGE
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HOLMES' wrongful conduct in the HOLMES LETTER. LOVE officially retained currentcounsel, Dongell Lawrence Finney LLP ("DLF") on September 6,2013, to investigate andquantify the nature and extent ofher damages and to move forward with this Complaint.
14. DLF focused LOVE's attention on specific statements and disclosures
contained in the HOLMES LETTER. Further, DLF focused LOVE on the legal significance ofthe false representations (discussed below) HOLMES made as alawyer (retained only by LOVE)to Frances in the HOLMES LETTER.
15. The HOLMES LETTER contained numerous unprofessional, shocking,and outrageous sentiments and improper disclosures ofattorney-client privilegedcommunications, including but not limited to, the following:
a. HOLMES began the letter by stating that "I [Holmes] representyou [Frances]." At the time she made this representation, this statement was false as HOLMEShad never been hired to represent Frances. HOLMES further failed to disclose that sherepresented LOVE in the letter.
b. HOLMES included numerous allegations that she personally was avictim ofanebulous conspiracy. Specifically, she claimed that, as aresult ofher representationof LOVE, HOLMES had been avictim of"a very large and very scary conspiracy" and that"thieves" had "hacked into my PCS (on one such occasion, to make my legal brief in this verycase 'disappear'); used my credit cards all over the country; and accessed/drained my savingsaccount." HOLMES had no basis in fact to make such claims.
c HOLMES inexplicably included numerous personal and
inappropriate comments in the letter, including discussing her husband's and brother's suicide,and her own miscarriages and inability to have children. Such subjects were inappropriate for aletter by an attorney to aminor whom she does not represent.
d. HOLMES further disclosed client confidences, privileged asattorney-client communications, in the letter without receiving appropriate permission fromLOVE.
C0U|mUCIAR)Y n^^rlS^f^SM1^^ MALPRACTICE, BREACH OFi-iDUUARY DUTY, INTENTIONAL INTERFERENCE WITH A PRn<?PPrrrvpECONOMIC ADVANTAGE, AND NEGEiGENT^TERiFER^NlfWITH A
PROSPECTIVE ECONOMIC ADVANTAGE
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e. HOLMES knowingly and falsely represented that "[HOLMES]lost [her] own husband from suicide within afew months ofyour Father's suicide." Based onpublic records, HOLMES' statement is not true and was knowingly false when she made thisstatement.
f. HOLMES knowingly and falsely misrepresented the amount ofmoney that Frances should have received as of that time from her trust in the Letter. Based onpublic records, HOLMES' statement is not true and was knowingly false when she made thisstatement.
g. HOLMES knowingly and falsely misrepresented and completelyoverstated her accomplishments as an attorney in the Letter from HOLMES to Frances. Basedon public records, HOLMES' statement is not true and was knowingly false when she made thisstatement.
16. HOLMES has given contradictory statements regarding the authorship ofthe HOLMES LETTER in deposition testimony and aDeclaration in the Related Action, at onepoint stating that LOVE "drafted the entire letter" while at another point claiming it was basedon LOVE's "numerous comments" to HOLMES. Both statements are in fact false, as LOVEhad no hand at all in writing the HOLMES LETTER.
17. Had LOVE received the HOLMES LETTER when it was sent on April27, 2009, LOVE would have terminated HOLMES as her lawyer immediately.
18. LOVE incurred damages, including attorneys' fees and emotional distress,as adirect result of the HOLMES LETTER. ;
19. At the time the HOLMES LETTER was sent, Frances was sixteen yearsold, and her affairs were being handled by Trust representatives, who eventually received theHOLMES LETTER. Due to the false and unprofessional representations in the HOLMESLETTER, Frances and the Trust representatives concluded that LOVE had hired an unstable andparanoid person as Frances' lawyer.
HCONOM.C^^^^^^S^^T
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20. The HOLMES LETTER resulted in adeterioration in the relationship
between Frances and other Trust representatives, as this letter convinced them that LOVE couldnot be trusted with decision making capabilities.
21. This deterioration resulted in actual injury when Frances obtained a
Temporary Restraining Order against LOVE in December 2009.
22. Further injury was incurred when Frances and the other Trust
representatives forced LOVE's resignation in November 2010 as Manager ofEnd ofMusic, LLC("EOM"). EOM contained the valuable publishing and publicity rights of Kurt Cobain. LOVEandFrances are the only two members of EOM.
Holmes' July 2009 E-maiis
23. Holmes knowingly and falsely misrepresented and took sole and completecredit for single-handedly discovering several famous and valuable Kurt Cobain guitars andother highly valued personal property of Kurt Cobain to LOVE and LOVE's personal managersand assistants in aJuly 3, 2009 email. In this email, HOLMES took complete credit for
discovering this information, expressly representing this discovery was based on her active
investigation and her "TONS" ofcontacts in the Seattle/Washington State area. The truth is that
Mr. Phillip Gross and his lawyer contacted HOLMES, believing HOLMES was LOVE'S lawyerat the time, to request helpful information to assist Mr. Gross in his litigation. HOLMES never
reached out to or contacted Mr. Gross or his lawyer. Based on public records, HOLMES'statements are not true and were knowingly false when she made them
24. HOLMES additionally represented herself to be LOVE's attorney to Mr.Gross and bis attorney and other representatives on July 3, even though HOLMES claimed in theRelated Action that LOVE had terminated HOLMES from representing LOVE on May 4, 2009.
25. LOVE incurred damages, including attorneys' fees and emotional distress,as a direct result of these e-mails.
FIRST CAUSE OF ACTION
(Legal Malpractice - Professional Negligence)6
COURTNEY LOVE COBAIN'S COMPLAINT FOR LEGAL MALPRACTICE BREACH OFFIDUCIARY DUTY, INTENTIONAL INTERFERENCE\WTTHLA PROSPECTIVE
ECONOMIC ADVANTAGE, AND NEGLIGENT INTEREFERENCE WITH APROSPECTIVE ECONOMIC ADVANTAGE
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26. LOVE incorporates by reference each and every allegation contained in
paragraphs 1through 25, inclusive, ofthis Complaint as though fully set forth herein.
27. At all times relevant hereto, Defendants, by reason ofits attorney-client
relationship with LOVE, owed aduty of care to LOVE to provide adequate and reasonable legal
advice, services, communications, and guidance in accordance with relevant legal standards of
care within the practice oflaw, in matters concerning the fraud perpetuated against the CobainEstate.
28. Defendants breached the relevant duty of care by failing to adequately
represent LOVE in providing competent legal advice, full and accurate communications, and
withholding attorney-client privileged communications in accordance with relevant legal
standards within the practice of law, as detailed more fully below. Defendants were negligent byfailing to use the skill and care that a reasonably careful attorney would have used in similar
circumstances. Defendants also failed to live up to the standard ofprofessionalism in sendingout the HOLMES LETTER.
29. Defendant made completely false representations inthe HOLMES
LETTER, stating that HOLMES represented Frances, and further HOLMES failed to disclose
that she represented LOVE - both actions which fall below the relevant legal standard ofcare
within the practice oflaw. LOVE is informed and believes that the purpose ofthe HOLMES
LETTER was to secure representation of the Cobain Estate, and Defendants' false
representations and untrue statements made within the letter are a clear violation ofCalifornia
Rules ofProfessional Conduct ("RPC") Rule 1-400 (Advertising and Solicitation).
30. During the course ofthe parties' attorney-client relationship, Defendants
revealed confidential attorney-client communications without the knowledge or consent of
LOVE, and Defendants failed to communicate with LOVE regarding the HOLMES LETTER.
Defendants' disclosure ofLOVE's confidential communications to Frances in the HOLMES
LETTER is a clear and express violation ofRPC Rule 3-100 (Confidential Information ofa
Client), and California Business and Professions Code ("BPC") Section 6068(e)(1).
CQU£™fYLOVE COBAIN'S COMPLAINT FOR LEGAL MALPRACTICE, BREACH OFFIDUCIARY DUTY, INTENTIONAL INTERFERENCE WITH A PROSPECTIVE
ECONOMIC ADVANTAGE, AND NEGLIGENT INTERFERENCE WITH APROSPECTIVE ECONOMIC ADVANTAGE
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31. Defendants failed to inform LOVE regarding the content ofthe HOLMES
LETTER. Defendants' failure to keep LOVE informed about, and failure to discuss the contentsand substance ofthe HOLMES LETTER, is aclear violation ofRPC Rule 3-500(Communication).
32. LOVE was damaged as aresult of the above actions. As an example, as aresult ofthe HOLMES LETTER, the relationship between Frances and other Trust
representatives deteriorated, as this letter convinced them that LOVE could not be trusted with
decision making capabilities. This deterioration resulted in later legal proceedings to be takenagainst LOVE. LOVE incurred damages, including attorneys' fees and emotional distress, as adirect result of the HOLMES LETTER.
SECOND CAUSE OF ACTION
(Breach of FiduciaryDuty)
33. LOVE incorporates by reference each and every allegation contained in -paragraphs 1through 32, inclusive, of this Complaint as though fully set forth herein.
34. Defendants, as attorneys for LOVE at all times relevant herein, wereobligated and required to act as fiduciary ofLOVE, and Defendants owed afiduciary duty topreserve and protect LOVE's interests, rights, and opportunities.
35. Defendants, by virtue ofthe actions and failures to act described
hereinabove, breached said fiduciary duties.
36. Specifically, Defendants breached the duty ofan attorney to not makemisrepresentations and untrue statements on LOVE's behalf about Frances, in violation of RPCRule 1-400 (Advertising and Solicitation).
37. Defendants breached the duty ofan attorney to keep secrete confidentialinformation ofaclient, pursuant to RPC Rule 3-100 (Confidential Information ofaClient) andBPC Section 6068(e)(1), by disclosing LOVE's confidential information in the HOLMESLETTER.
COURTNEY LOVE COBAW'S^^FI£H£L^RY DUTY, INTENTIONAL INTERFERENCE WITH APROSPECTIVE
ECONOMIC ADVANTAGE, AND NEGLIGENT INTERFERENCE WITH APROSPECTIVE ECONOMIC ADVANTAGE
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38. Further, Defendants breached the duty ofan attorney to communicate with
its client pursuant to RPC 3-500 (Communication), by failing to communicate with LOVEregarding the contents and substance ofthe HOLMES LETTER.
39. As an actual and proximate result of Defendants' breach of fiduciaryduties described above, LOVE has suffered damages, including attorneys'fees and emotionaldistress damages, in an amount to be proven attrial.
40. Defendants' egregious breaches of duties, in disclosing LOVE's attorney-client confidential information, failing to inform LOVE about the contents and substance of theHOLMES LETTER, and falsely misrepresenting that HOLMES represented Frances in additionto other misrepresentations on LOVE's behalfabout Frances, were done intentionally andfraudulently, and with reckless disregard for the truth. LOVE therefore seeks an award ofexemplary and punitive damages in an amount to be proven at trial.
THIRD CAUSE OF ACTION
(Intentional Interference with aProspective Economic Advantage)41. LOVE incorporates by reference each and every allegation contained in
paragraphs 1through 40, inclusive, of this Complaint as though folly set forth herein.
42. LOVE had and continues to enjoy prospective and economic relationshipswith her daughter, Frances, and the Trust representatives, as LOVE is abeneficiary of the CobainEstate.
43. Defendants, as attorneys hired to bring an action based on the fraud
perpetuated on the Cobain Estate, were well aware of LOVE's interest in the Cobain Estate, aswell as LOVE's prospective and economic relationships with Frances and Trust representatives.
44. Defendants engaged in wrongful conduct by using LOVE's attorney-clientconfidential information in the HOLMES LETTER, by falsely misrepresenting that HOLMESrepresented Frances, and by including other inappropriate and unprofessional material in theletter.
45. Defendants' abovementioned wrongful conduct was designed to, and infact did, disrupt and adversely affected LOVE's prospective and economic relationship with
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'JSKSA?7 DUTY> INTENTIONAL INTERFERENCE WITH APROSPECTIVEECONOMIC ADVANTAGE, AND NEGLIGENT INTEREFERENCE WTTH A
PROSPECTIVE ECONOMIC ADVANTAGE
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Frances andTrust representatives of theCobain Estate. Asdiscussed above, as a result of
Defendants' wrongful conduct within the HOLMES LETTER, the relationship between Frances
and other Trust representatives deteriorated, as this letter convincedthem that LOVE could not
be trusted with decision making capabilities. This deterioration resulted in legal proceedings to
be taken against LOVE.
46. As a direct and proximate result ofDefendants' wrongful acts, LOVE has
suffered damages and disruption to her relationships with Frances and Trust representatives.
47. Defendants' aforementioned conduct was willful and oppressive, or
fraudulent, or malicious, and thus LOVE is entitled to an award ofexemplary or punitive
damages, in an amount to be proven at trial.
FOURTH CAUSE OF ACTION
(Negligent Interference with aProspective Economic Advantage)
48. LOVE incorporates by reference each and every allegation contained in
paragraphs 1through 47, inclusive, ofthis Complaint as though fully set herein.
49. Defendants, as herattorneys, owed a duty of care to LOVE.
50. As LOVE's attorneys, Defendants had extensive knowledge of the Cobain
Estate, and LOVE's prospective and economic relationships with Frances and Trust
representatives.
51. Because ofDefendants' attorney-client relationship with LOVE,
Defendants knew or should have known that Defendants' aforementioned wrongful conduct
regarding the HOLMES LETTER would harm and disrupt LOVE's prospective and economic
relationships withFrances and Trust representatives.
52. Defendants failed to act with reasonable care by wrongfully interfering
with LOVE's economic relationships with Frances and Trust representatives, and Defendants'
negligent conduct has infact disrupted LOVE's economic relationships with Frances and Trust
representatives.
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COURTNEY LOVE COBAIN'S COMPLAINT FOR LEGAL MALPRACTICE, BREACH OFFIDUCIARY DUTY, INTENTIONAL INTERFERENCE WITH A PROSPECTIVE
ECONOMIC ADVANTAGE, AND NEGLIGENT INTEREFERENCE WITH APROSPECTIVE ECONOMIC ADVANTAGE
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53. As adirect and proximate result of Defendant's wrongful conduct, LOVE
has suffered damages, including attorneys' fees and emotional distress damages, in an amount tobe proven at trial.
PRAYER FOR RELIEF
WHEREFORE, LOVE prays as follows:
1. Damages, including emotional distress damages and attorneys' fees, inexcess of the jurisdictional limits ofthis Court;
2. For interest, attorney's fees, and costs ofsuit incurred herein;
3. For punitive and exemplary damages in an amount to be proven at trial;4. For such further and other relief as this Court deems just and proper.
DATED: October 25, 2013 DONGELL LAWRENCE FINNEY LLP
By:Richard A. Donge
Attorneys for PlaintiffCOURTNEY LOVE COBAIN
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COURTNEY LOVE COBAIN'S COMPLAINT FOR LEGAL MALPRACTICE BREACH OFFISV£^YPUTY' RETENTIONAL INTERFERENCE WITHLA PROSPECTIVE
ECONOMIC ADVANTAGE, AND NEGLIGENT INTEREFERENCE WTTH APROSPECTIVE ECONOMIC ADVANTAGE
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BOROon*HOimes
CIVIl. T>UL LAWYBKt
April 27,2009
PERSONAL & CONFIDENTIAL:
ATTORNEY-CLIENT PRIVILEGED COMMUNICATION
VIA FACSIMILE & U.S. MAIL
Ms. Frances B. Cobain
9145 St. Ives Drive
Los Angeles, CA 90069
RE: Estate of Kurt Cobain. et al Fraud Litigation
Dear Ms. Frances Cobain:
By way of forma! introduction, my name is Rhonda Holmes, andI am an attorney. Irepresent you, along with yourGrandmother Wendy, and your AuntsKim and Brianne. Thework (am doing on all your behalfrelates to tracking down and prosecuting the peopleandentities who havebeenstealing from andpillaging yourlate Father's estatesince the day hepassedaway. I am keenlyaware ofthe sensitivity ofthismatter, as I lost my own husband fromsuicide within a few monthsofyour Father's suicide. So please understand I write this letternotin any way to bringup matters which areupsettingandpainful to you. But rather, I write younow because we all need yourhelp and yoursupport
Let me be clear attheoutset, it is beyonddisputeyou will not"need" the funds from yourlate Father's estateasyouembark on yourown career endeavors. No one doubts yourabilitytoearn vast amounts ofmoney independently of your parents. Your Mom assuresme you areadisciplinedand focused younglady. Your Mother boasts to me incessantly of yourgenius- Shehas described forme on countless occasions "My Frances with themost talentedeyes andvoiceand writing ability and sense of composition I have ever seen".1 Even if you want nothing todo
On thematter of yourcareer, if youwillkindlyindulge me forjustamomentof unsolicited adviceas,despiteyears of trying, t wan unable toetay pregnant and carry ababyto full-term. So,envying abovealtyourMother's gifts,her relotioiuihip with you, I'd be grateful ta you both forallowingme to overstep in thisone area: I understandDearFrances youarcNOT in school atthe moment. Whileyourother-warldy talents of therarest sort maywelt lead you to a career whichostensiblybears tittleon conventional education; you willnever regret thegifttoyourself-esteem andto yourchildren andyourchildren's children of simply allowing yourselfa full and proper education. Thiscruel world hasshown timeandagain it haslittletolerance forthe"scholastkally-impaired". White my LASTintent here isto lecture (my FIRSTIsto PROTECT), (Msbears saying asI would feci remiss, not gifted with children ofmyown towhom toimpart these lessons, had Inotshared this bitofwisdomwithyounow. What youdowithit is,of course, wellbeyond mycontrol.
A PjtBTNSatHtr OF KOfESSIOMAI. COafOMTIOKI
ftritik UConlon IWwKtt J. Katna | Hwihw T. Fty»i> j fttati*' N. Ocrutu' EnutL- b«*@fc(}fd<tMii4Minwu<*itn
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Ms. Frances B. Cobain
April 27,2009Page 2
with your late Father's, or later on this year, your Mother's sponsorships and clothing lines-evenif you do not want adime oftheir money-- that simply misses the point The point is, yourGrandmother should beliving in alarge, comfortable ranch, as should your Aunts.
You are ALL the unfortunate victims ofavery large and very scary conspiracy. Ihavepersonally experienced the reach and criminality ofthese thieves; They have hacked into my PCs(on one. such occasion, to make my legal brief in this very case "disappear"); used mycreditcards all over the country; and accessed/drained mysavings account. I am here toensure thesethieves do not mess with you anymore. Your Mom tells me the story ofwhat these people did toyou when you wereonly 11 years old. Theseeviland vileanimals hadnoconsciencewhatsoever when they caused your life to fall apart at such ayoung age when they took yourhorse and home and displaced your family. My God, Frances-you were ONLY ELEVEN yearsold!! I You were still healing the wounds (and Iimagine still are) ofyour Father's horriblypainful passing. These people are evil and deserve to pay. Not so much for the money for you orfor yourMother, butatleast for your Father's Mother and Sisters. You are all innocent victims inthis horrible mess. And INNOCENT you are. Here again, Iam not usually one to impart somuch unsolicited pedantic rambling, but Icannot help but say to you (myself surviving not onlymy Husband's suicide but mydear brother's suicide two months later), I pray not amoment isspent on this planet when you EVER blame yourself, child- EVER!!! People do what they do,Sweetheart. We no more have the power to cause others' behaviors than we do to stop them.You, an innocent little child did NOTHING but deserve to be loved, nurtured, and protected. Iam sosorry for what you went through. I pray to Ood, Buddha, and anyone else who will listen,you don't spend onemoment in guilt orremorse. You were and are anINNOCENT VICTIM inyour Father's passing. Neither you NOR your Mother EVER deserve to beblamed, accused, orotherwise. Enough said.
So too, are you, your Grandmother, and your Aunts innocent victims in this fraud beingperpetrated on your late Father's estate. Frances-1 am atrial lawyer, specializing complexcommercial litigation matters. Ihave handled these types ofcases successfully throughout my21 -year career. Ihave recovered multiple milhons (ifnot billions) ofdollars for people inyourfamily's situation over the years. Iam afour-time recipient ofthe "Outstanding Trial LawyerAward" and recent "Trial Lawyer ofthe Year" (which is somewhat akin to aGrammy in thelegal world). Imention these accomplishments not to boast, but hopefully to give you asensethat you are in good hands, and to instill in you the confidence Iwouldn't behandling this matterif Iwere not abundantly confident the facts are on our side. Your Mother has been handling mismatter on her own now for so long. Even though Iam now on board, Ido not get the sense yourMom can 'let go'until the case if filed and begins running itscourse. I doubt I need toconvinceyou how much this matter has consumed your Mother and threatens to destroy her spirit. Thesooner I have your support and hence the support of your Trust Fund, thesooner I can ease thismatterout ofyour Mom's hands.
G&H000058
fv
Ms. Frances B. Cobain
April 27,2009Page 3
•
•
To reiterate, the purpose ofreaching out to you at this point is to enlist your support. Thelast thing any ofus want, least ofall your Mother (who is FIERCELY protective ofyou, bytheway) is for you to be dragged into along court battle. Your Mother's only goal is to finish therecord she iscurrently working on and get you bom aNew York homes. Ofparticular importancewill bethe support of your Trust when itcomes time for filing suit. Wewill need their support.We will ail need to unite to make this a successful endeavor.
On the subject oftrust funds, they are strange animals. They do not always pay all thefunds out when you are 18 like you would assume (unless aparticularly stupid parent ordered itor they are small). You do not have 1/1,000,000,000th ofwhat it appears you should have inmyview. My experience has shown me, the minute you turn 18 they will try and make you sign awaiver stating you will never sue them. They are likely saying meaniand terrible things aboutyour Mother even. Sadly, in 1998, they managed to get away wit, in myopinion, takingadvantage of your Mom's lack of scholastics and education (billing you millions ofdollars, whileyour Mother never, ever billed you apenny). They accused your Mother of"diverting money in*2003". YourMother had (has) absolute discretion inthat regard. I KNOW that musthurttohear. And, yes, ascrazy as it sounds, not ONE of your "protectors" (lawyers, bankers,accountants, managers, etc.) stood up tothis. They had too much of aninterest in keeping youand your Mom inthe dark, sadly. They do not seem tobeoperating any more "openly" today.For example, weare presently trying to find out how much you lost inthe huge economicdownturn inrecent months, and simply getting noresponses whatsoever to our inquiries.
You see,Frances-3 things are very important:
1. Iam here and I am NOT going toletthose who perpetrated fraud against yourlate Father's estate and your family get away withit. You have my word on that.1am here toprotect your interests, as well as your Grandmother Wendy'sandyour Aunts Kim's and Brianne's interests. They don't have topay meadime.
2. Your Mom - allshewants is for youto be secure andsafe. I am goingto makesure you and your family are safe and secure so you Mom does not have todo allof thiswork, I knowshewould muchprefer beinga Mother and anartist Pleasestand byusand continue being patient Your Mother has 100% faith inyourcapacity to make aliving and bean artist of greatness and succeed at whateveryou ultimately choose. That isnot the point, the point is;
G&H000059
Ms, Frances B. Cobain
Aprif 27, 2009Page 4
3. No onehas stopped these frauds from attacking yourFather's estateandpillaging it Andfor the sake of everyone, it needs to stop, and timeis of theessence.
Thank you for taking the time toread and consider this letter, Frances. Please call me ifand whenever you need. My office phone number is: 619-696-0444. My cell phone number is:619-572-2211. My email addressis: [email protected].
Withloveand warmest Regards,
GORDON & HOLMES
RJH:kam
G&H000060
~s
e^^mB./*TORNEY OR PARTY WITHOUT ATTORNEY (Name ."Richard A. Dongell (SBN 128083)
John A. Lawrence (SBN 073395)DONGELLLAWRENCE FINNEY LLP707 Wilshire Boulevard, 45thFloorLos Angeles, CA 90017
TELEPHONE NO: (213)943-6100attorney for (N«mej: Courtney Love Cohain
tarnumber, anaaddress):
faxno: (213)943-6101
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELESstreet address: 111 North Hill Streetmailing address: 111 North Hill Street
cityanozip code: Los Angeles. CA 90012ggANCHNAME: Stanley Mosk Courthouse
FOR COURT US£ ONLYCM-01Q
FILEDWS ANGELES SUPERIOR COURT
OCT 25M
JOrwiM.CLAHKfc.CLfcHK
case NAME: COURTNEY LOVE COBAIN v. GORDON &HOLMES, et al. BY
CIVIL CASE COVER SHEETLxJ Unlimited CD Limited
(Amount (Amountdemanded demanded isexceeds $25.000) $25,000 or less)
ComplexCase Designation• Counter CD JoinderFiled with first appearance by defendant
(Cal. Rules ofCourt, rule 3.402)
CASE NUMBER:
JUDGE:
OEPT:
Items 1-6 below must be completed (see instructions on page 2)1. Check one box below for the case type that best describes this case:
Auto Tort
• Auto (22)CD Uninsured motorist (46)Other PI/PD/WD (Personal Injury/PropertyDamage/Wrongful Death)Tort
I 1Asbestos (04)CD Product liability (24)I IMedical malpractice (45)CZZZI Other PI/PDArVD (23)Non-PI/PO/WD (Other) Tort
Contract
i IBreach of contract/warranty (06)CD Rule 3.740 collections (09)lZJ Other collections (09)i JInsurance coverage (18)CZ3 Other contract (37)Real Property
I IEminent domain/Inversecondemnation(14)
CD Wrongful eviction (33)L—i Business tort/unfair business practice (07) I IOther real property (26)Cj Civil rights (08)I IDefamation (13)• Fraud (16)CD Intellectual property (19)I x ...I Professional negligence (25)CZZ3 Other non-PI/PDA/VD tort (35)Employment
CD Wrongful termination (36)I IOther employment (15)This casefaclor^eouiSxceptS £& £%££? "** ^ °'̂ ^^""**̂ "the""*"-**<•mark mea CJ Large number of separately represented parties d. • Large number of witnesses
^Jl^S^T^^r^ e ^ Coordi"a«onwith-^-tionspendinginoneormorecourts, I 1c k? , , ^e-consuming to resolve in other counties, states, or countries or in afederal courtc. • Substanhal amount of documentaryeyidence f. • Substantial postjudgment judicial superb ion3. Remed.es sought (cnecK a// tnat apply): a. CD monetae b. CD nonmoneta^declaratory or SSlSTc. ED punitive
4V Number of causes of action (specify): Four (4)S^This case CD is CD is not a class action suit.
Date:' Oc'torir 25K^l3relate<1 ^^ *'* "" ^ "n°tiCe °f related eWl^ "*° tomfiftois.)Richard A. Donee'll CSBN mnai) ^
{TYPE OR PRINT NAM6)
Unlawful Detainer
CD Commercial (31)CD Residential (32)CD Drugs (38)Judicial Review
CD Asset forfeiture (05)CD Petition re: arbitration award (11)CD Writ of mandate (02)I IOther judicial review (39)
JS«rYV
*• File this cover sheet in addition to any cover sheet required by local court rule*"JZ^SfSS^SSl^^"^°f^ Ca,if0m,a RU|SS °f C0Urt' V" ™* *™ *̂ **•» cover sheet on a«.WUnless this „acollections case under rule 3.740 or acomplex case, this cover sheet will be used for statistical purposes only.
" —————.. Pag« t of 2Form Adoptedfor Mandatory UseJudicial Council of CaliforniaCM-010[Rov. July t, 2007|
CIVIL CASE COVER SHEET
Provisionally Complex Civil Litigation{Cal. Rules ofCourt, rules 3.400-3.403)CD Antitrust/Trade regulation (03)CD Construction defect (10)CD Mass tort (40)I I Securities litigation (28)I I Environmental/Toxic tort (30)I; ...J Insurance coverage claims arising from the
above listed provisionally complex casetypes (41)
Enforcementof Judgment
CD Enforcement of judgment (20)MiscellaneousCivil ComplaintCD RICO (27)CD Other complaint rnof specified above) (42)Miscellaneous Civil Petition
I _ „.l Partnership and corporate governance (21)CD Other petition (not specified above) (43)
Soluahns-
ATTORNEY FORPARTY)
Cal. Rules ofCourt, rules 2.30, 3.220, 3 400-3.403, 3.740;Cal. Standards of Judicial Administration, std.3.10
i INSTRUj|ONS ON HOW TO COMPLETE THE COM SHEET
statistics about the types and numbers o^ses filed ^^J^fT*™?!? m* i' ThiS information wiH be used to compileone box for the case type that beTt*1SSZS S£22i2Sh?2n1 T? 6°" the •"•* ,n item 1- you must checkcheck the more specific one. If the case has• rStSTca<£?5SS k t^T*' 8ud am0re Spedfic *"* of case ,is,ed in item LTo assist you in completing the sheJ examptes of heTSeS Itt£^2 h* ** ?* ^J"**88 the P™3* cause of acti°n-sheet must be filed only with your tnrtial oTeV FaS,,»l^1 ~ k 9. unlerueach Case *"* in i,em 1are Provided Mow. Acoveroounsel, or both to m^S^SSS'SS!?iaSK!!ria^^P^^ '" **" —^ "**a»"*• «S2^^^ Undfr I"'6 374°iS defi"ed aS a" action for «»«Y of money owedproperty, services, or money^ Su^iT^T«5^^12|,^andr^T/* ^ ^ fr°m atransacti0n in whichdamages, (2) punitive damages (3) recovery of real nmrirtJ ST, casefdoes not ,ndude af1 action seeking the following: (1) tortThe identification ofacase a's aSe37^ °r (5) a™^™* writ of attachmentrequirements and case management rulesunless^a defendan?fi« IT f' 'l""' be exempt from the 9eneral «me-for-serviceto the requirements for service' and obta,n!n|̂ ^i2f2^fi3^~«Pon«« •*"*»*• *rule 3.740 collections case «h be subject
P«aintiffsdesignation,acounter-de8ignati^S
CM-010
the case is complex.
Auto Tort
Auto (22)—Personal Injury/PropertyDamage/Wrongful Death
Uninsured Motorist (46) (ifthecase involves an uninsuredmotorist claimsubjecttoarbitration, check this iteminstead of Auto)
Other PI/PD/WD (Personal Injury/Property Damage/Wrongful Oeath)Tort
Asbestos (04)Asbestos Property DamageAsbestos Personal Injury/
Wrongful DeathProductLiability (notasbestos or
toxic/environmental) (24)Medical Malpractice (45)
Medical Malpractice-Physicians &Surgeons
Other ProfessionalHealthCareMalpractice
Other PI/PDAA/D (23)Premises Liability (e.g., slip
and fall)Intentional Bodily (njury/PD/WO
(e.g., assault,vandalism)Intentional Infliction of
Emotional DistressNegligent Infliction of
Emotional DistressOther PI/PD/WD
Non-PI/PDAVD (Other) Tort^Business Tort/Unfair Business., Practice (07)'Civil Rights (e.g., discrimination,-., false arrest) (notcivil\ harassment) (08)
'Defamation (e.g., slander, libel)f> d3)Fraud (16)Intellectual Property (19)(Professional Negligence (25)
Legal Malpractice!-V Other Professional Malpractice!~.> fnofmedical orlegal)Other Non-PI/PD/WD Tort (35)
EmploymentWrongful Termination (36)Other Employment (15)
CM-O10(Rev. July 1,2007| ~ '—
CASETYPES AND EXAMPLESContract
Breach ofContract/Warranty (06)Breach of Rental/Lease
Contract (notunlawful detaineror wrongful eviction)
Contract/Warranty Breach—SellerPlaintiff (not fraud or negligence)
NegligentBreach of Contract/Warranty
Other Breach ofContract/WarrantyCollections (eg., money owed, open
bookaccounts)(09)Collection Case—Seller PlaintiffOtherPromissory Note/Collections
Case
Insurance Coverage (not provisionallycomplex) (18)Auto SubrogationOtherCoverage
Other Contract (37)Contractual FraudOtherContract Dispute
Real PropertyEminent Domain/Inverse
Condemnation (14)Wrongful Eviction (33)Other Real Property (e.g., quiet title) (26)
Writ ofPossession ofReal PropertyMortgage ForeclosureQuiet TitleOther Real Property (noteminentdomain, landlord/tenant, orforeclosure)
Unlawful DetainerCommercial (31)Residential(32)Drugs (38) (if the case involves illegal
drugs, check this item: otherwise,report as Commercial or Residential)
Judicial ReviewAsset Forfeiture (05)Petition Re: Arbitration Award (11)Writ of Mandate (02)
Writ-Administrative MandamusWrit-Mandamus on Limited Court
Case MatterWrit-Other Limited Court Case
Review
Other Judicial Review (39)Review of Health OfficerOrderNoticeofAppeaMLabor
Commissioner Appeals
CIVIL CASE COVERSHEET
Provisionally Complex Civil Litigation (Cai.Rules ofCourt Rules 3.400-3.403)
Antitrust/Trade Regulation (03)Construction Defect(10)Claims Involving Mass Tort (40)Securities Litigation (28)Environmental/Toxic Tort (30)Insurance CoverageClaims
(arising from provisionally complexcase type listedabove) (41)
Enforcement of JudgmentEnforcement ofJudgment (20)
Abstract of Judgment(OutofCounty)
Confession ofJudgment (non-domestic relations)
Sister State JudgmentAdministrative Agency Award
(notunpaidtaxes)Petition/Certification ofEntry of
Judgmenton Unpaid TaxesOther Enforcement ofJudgment
Case
Miscellaneous Civil ComplaintRICO (27)OtherComplaint (not specified
above) (42)Declaratory Relief OnlyInjunctive Relief Only (non-
harassment)Mechanics Lien
OtherCommercial ComplaintCase (non-tort/non-complex)
Other Civil Complaint(non-tort/non-complex)
Miscellaneous Civil PetitionPartnershipand Corporate
Governance(21)Other Petition (notspecified
above) (43)Civil HarassmentWorkplace ViolenceElder/Dependent Adult
Abuse
Election ContestPetition for Name ChangePetition for Relief from Late
Claim
Other Civil Petition
Page 2 of 2
^^OURTNEYLOVE COBAIN v. GORDON &mLME^^TJ^^ ^m^WSTCIVIL CASE COVER SHEET ADDENDUM AND
/rcDT.^ATrrtr. STATEMENT OF LOCATION(CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO CQURTHOUSE LOCATION)
Item I. Check the types of hearing and fill in the estimated length of hearing expected for this caseJURVTRIAL7 [T] VES CLASS ACTION? • YES LIM.TED CASE? Q VES TIME ESTIMATED FOR TR.AL 5 n^^n,.
Item II. .ndlcate the correct district and courthouse .ocation (4 steps -„you checked "Limited Case", skip to Item 1.1, Pg. 4):
Step 2: Check« Superior Court type of action in Column BWow which best describes the nature of this case.
Applicable Reasons for Choosing Courthouse Location (iee Column Cbeto»7
i' i«S!SH WKere bod«ily if|Jur*deatn or damage occurred q iLSS!r0n wDerein defendant/respondent functions whollv5. Location where performance required or defendant reskies 1n r2Sl0" w«h,er? onS or more of the parties reside *'1U Location of Labor Commissioner Orficffice
Step 4: Fill in the information requested on page 4in Item III; complete Item L Sign the declaration.
Auto (22)
to»~
o
5<
Uninsured Motorist (46)
• A7100 Motor Vehicle -Personal Injury/Property Damage/Wrongful DeathCD A711Q Personal Injury/Property Damage/Wrongful Death -Uninsured Motorist
1,2.4.
1..2..4.
Asbestos (04)
ProductLiability (24)
CD A6070 Asbestos Property DamageI 1A7221 Asbestos -Personal Injury/Wrongful Death
CD A7260 Product Liability (not asbestos or toxic/environmental)tr is
f "ifS e
* 5a> £.^ CD
Medical Malpractice (45) • A7210 Medical Malpractice -Physicians &SurgeonsCjA7240 Other Professional Health Care Malpractice
K*
OtherPersonal Injury
Property DamageWrongful Death
(23)
LAClV 109(Rev. 03/11)LASCApproved 03-04
I 1A7250 Premises Liability (e.g., slip and fall) <
1=1 A723° St^i^I 1A7270 Intentional Infliction of Emotional DistressI 1A7220 Other Personal Injury/Property Damage/Wrongful Death
CIVIL CASE COVER SHEET ADDENDUMAND STATEMENT OF LOCATION
1,2., 3., 4., 8.
1., 4.
1.,4.
1..4.
1,4.
1,3.
1..4.
Local Rule 2.0
Page 1 of 4LA-CV109
*"~* COURTNEY LOVE COBAIN v. GORDONTmLms,
if
3 3
C(0 P
§£
= EO CO
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41
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Q.
£UJ
BusinessTort (07)
Civil Rights (08)
Defamation (13)
Fraud (16)
Professional Negligence (25)
Other (35)
Wrongful Termination (36)
Other Employment (15)
CD A6029 Other Commercial/Business Tort (not friud/breach of contract)CD A6005 Civil Rights/Discrimination
CD A6010 Defamation (slander/libel)
CD A6013 Fraud (no contract)
CD A6017 Legal Malpractice fCD A6050 Other Professional Malpractice (not medical or legal)CD A6025 Other Non-Personal Injury/Property Damage tort
I 1A6037 Wrongful Termination
CD A6024 Other Employment Complaint CaseI 1A6109 Labor Commissioner Appeals
1., 3.
1., 2., 3.
1-, 2„ 3.
1,2., 3.
$P1..2..3.
2,3.
1,2., 3.
1., 2., 3.
10.
Breach ofContract/ Warranty(06)
(not insurance)
CD A6004 Breach of Rental/Lease Contract (not unlawful detainer or wrongful• A6008 Contract/Warranty Breach -Seller Plaintiff (no fraud/negligence)CD A6019 Negligent Breach of Contract/Warranty (no fraud)CD A6028 Other Breach of Contract/Warranty (not fraud or negligence)
2., 5.
2., 5.
1..2..5.'
1..2., 5.
Q
eo
o
c41a.
2a.
"3
... o
c
K. ': '5
I Y:
Collections (09)
Insurance Coverage (18)
OtherContract (37)
Eminent Domain/InverseCondemnation (14)
Wrongful Eviction (33)
Other Real Property (26)
Unlawful Detainer-Commercial(31)
Unlawful Detainer-Residential(32)
Unlawful Detainer-Post-Foreclosure (34)
Unlawful Detainer-Drugs (33)
CD A6002 Collections Case-Seller PlaintiffCD A6012 Other Promissory Note/Collections Case
CD A6015 Insurance Coverage (not complex)
L__l A6009 Contractual Fraud {I 1A6031 Tortious Interference j• A6027 Other Contract Dispute(not breach/insurance/fraud/negligence)
CD A7300 Eminent Domain/Condemnation Number of parcelsCD A6023 Wrongful Eviction Case
CD A6018 Mortgage Foreclosure (CD A6032 Quiet Title
CD A606Q OtherRealProperty(noteminentdomain,landlord/tenant,foreclosure)• A6021 Unlawful Detainer-Commercial (not drugs or wrongful eviction)CD A6020 Unlawful Detainer-Residential (not drugs or wrongful eviction)CD A6020F Unlawful Detainer-Post-Foreclosure
CD A6022 Unlawful Detainer-Drugs
2„ 5., 6.
2., 5.
1..2..5., 8.
1,2., 3., 5.
1., 2., 3., 5.
1..2..3..8.
2„6.
2„6.
2., 6.
2., 6.
2„6.
2., 6.
2., 6.
2., 6.
LACiy 109(Rev. 03/11)LASCApproved 03-04
"CIVIL CASE COVER SHEET ADDENDUMAND STATEMENT OF LOCATION
Local Rule 2.0
Page 2 of 4
ST"* C0UI™Y1^VEC0BA1N v. GORDON &HOLMES"
a.
£o
o
A*"5co
o
C C
E B
a %c ._
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8a
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H>
f-"?
<»3
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•<o <u
~<oa.
o<a >
s u
tType;of(Actidn(Checleonly<dh§)
CD A6108 Asset Forfeiture Case
CDA6115 Petition to Compel/ConfirmA/acate Arbitration
CD A6151 Writ -Administrative Mandamus •CD A6152 Writ -Mandamus on Limited Court Case MatterLd A6153 Writ -Other Limited Court Case Review'
CD A6150 Other Writ/Judicial Review
Antitrust/Trade Regulation (03) t 1A6003 Antitrust/Trade RegulationConstruction Defect (10)
Claims Involving MassTort(40)
Securities Litigation (28)
Toxic TortEnvironmental (30)
Insurance Coverage Claimsfrom Complex Case(41)
Enforcementof Judgment(20)
RICO (27)
Other Complaints(Not Specified Above) (42)
Partnership CorporationGovernance (21)
Other Petitions(Not Specified Above)
(43)
CD A6007 Construction Defect
CD A6006 Claims Involving Mass Tort
I 1A6035 Securities Litigation Case
CD A6036 Toxic Tort/Environmental
CD A6014 Insurance Coverage/Subrogation (complex case only)I 1A6141 Sister State Judgment !( )A6160 Abstract of Judgment <CD A6107 Confession of Judgment (non-domesticTelations)CD A6140 Administrative Agency Award (not unpaid taxes)CD A6114 Petition/Certificate for Entry of Judgment on Unpaid TaxLCI A61I2 Other Enforcement of Judgment Case i
CD A6033 Racketeering (RICO) Case
I 1A6030 Declaratory Relief Only ,CD A6040 Injunctive Relief Only (not domestic/harassment)CD A6011 Other Commercial Complaint Case (non-tort/non-complex)CD A6000 Other Civil Complaint (non-tort/non-complex)
CD A6113 Partnership and Corporate Governance'Case
CD A6121 Civil Harassment jCD A6123 Workplace Harassment JCD A6124 Elder/Dependent Adult Abuse Case 'CD A6190 Election Contest ICD A6110 Petition for Change of NameCD A6170 Petition for Relief from Late Claim LawCD A6100 Other Civil Petition
LACIV 109 (Rev. 03/11)LASCApproved 03-04 C'VIL CASE COVER SHEET ADDENDUM
AND STATEMENT OF LOCATION;
2., 6.
2,5
2,8.
2.
2.
2., 8.
1,2., 8.
1,2., 3.
1., 2., 8.
1,2,8.
1,2,3., 8.
•1..2..5.. 8.
2,9.
2., 6.
2., 9.
2„8.
2., 8.
2., 8, 9.
1,2,8
1..2., 8.
2., 8.
1,2., 8.
1., 2,8.
2., 8.
2,3,9.
2., 3„9.
2., 3., 9.
2.
2., 7.
2., 3., 4., 8.
2., 9.
Local Rule 2.0
Page 3 of 4
I
} I
short title: COURTNFA LO VbCOBAIN v. GORDON &HOLMES, et al!CASE NUMBER
H rdge '•as me Pr°Per reas°n for filing in the court location you selected.
u^rN:. Che«k,tne appropriate boxes for the numbers shownthis case f°r the *** °f aCtion that *ou fave se^ecteSZ
• UJO 2. E 3.D 4.• 5.da.• 7. C38. • 9. CH 0.CITY:
Los Angeles
STATE:
CA
2IP CODE:
90069
address 9145 St. Ives Drive
SSn^STi^c, «££)] ' °Unty °f L°S An9e,eS [C°de CiV' Pr0C" §392 et «*- ™« Local
Dated: October 25. 2013
(SIGNATURE OF ATTO$*4y/FIUNG PARTY)Richard A. Dongell
COMMENHCAEVYOUR NEW CoKr? CASE: C0MPLETED AND ^ADY TO BE F.LED .N ORDER TO PROPERLY1.
2.
3.
4.
Original Complaint or Petition.
If filing aComplaint, acompleted Summons form for issuance by the Clerk.Civil Case Cover Sheet, Judicial Council form CM-010.
Civil Case Cover Sheet Addendum and Statement of Location form, LACIV109, LASC Approved 03-04 (Rev.5. Payment in full of the filing fee, unless fees have been waived.
0-1
0J-.V
LACIV 109(Rev. 03/11)LASC Approved 03-04
CIVIL CASE COVER SHEET ADDENDUMAND STATEMENTOF LOCATION
Local Rule 2.0
Page 4 of 4
General Information
Status Open
Court Superior Court of California,County of Los Angeles
Date Filed 2013-10-25 00:00:00
Cobain v. Gordon & Holmes, Docket No. BC525857 (Cal. Super. Ct. Oct. 25, 2013), Court Docket
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