Eric Calderon vs Smile Care

Complaint Information

PLD-PI-001

ATBI;NaEI‘; %?&gm&gggg {!#Vaniaeo.ga(f)e 88’87rj'lumbe!, and address): FOR COURTUSECONLY Attorney at Law . 516 W. Shaw Avenue, Suite 200 Fresno, CA 93704

TELEPHONE NO: (559) 230-0696 FAX NO. (Optional): (559) 221-2660

E-MAIL ADDRESS (Optional): attorNeY For (vame): Plaintiff ERIC CALDERON

SUPERIOR COURT OF CALIFORNIA, COUNTY OF FRESNQO sTREETADDRESS: 1130 "O" Street maiLnG ApDRess: 1130 "O" Street

cITY ANDZIPcoDE: Fresno 93724 BRANCH NAME:

PLAINTIFF: ERIC CALDERON

SMILE CARE; COAST DENTAL SERVICES, INC.; NAVNEET ARORA,

DEFENDANT: D-D-S:; NAVNEET ARORA PROFESSIONAL DENTAL CORPORATION,; F fi fi:I E i)

" MELISSA A. DEMPSEY, D.D.S.; GIZEL TABIBNIA, DM.D., M.S.; GIZEL . TABIBNIA, DM.D. M.S,, INC.; YORAM KOHANZADEH, D.D.S.; YORAM

DOES 1 TO 100 KOHANZADEH, INC.;| 6

COMPLAINT—Personal Injury, Property Damage, Wrongful Death

AMENDED (Number): FIRST Type (check all that apply): SEEBNO COUNTY SUPERIOR COURT [ ] MOTOR VEHICLE OTHER (specify}: Dental Malpractice DEPUTY [_] Property Damage [ __ ] Wrongful Death Personal Injury [___] Other Damages (specify): Jurisdiction (check all that apply):

[] ACTIONIS A LIMITED CIVIL CASE

Amount demanded [ | does notexceed $10,000 [_] exceeds $10,000, but does not exceed $25,000 ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000) 13CECG02814 [ ] ACTION{S RECLASSIFIED by this amended complaint 1 from limited to unlimited [ ] from unlimited to limited 1. Plaintiff (name or names): ERIC CALDERON SMILE CARE; COAST DENTAL SERVICES, INC.; NAVNEET ARORA,D.D.S,;

_ . NAVNEET ARORA PROFESSIONAL DENTAL CORPORATION; MELISSA A. alleges causes of action against defendant (name or names): DEMPSEY, D.D.S.; GIZEL TABIBNIA, DM.D., M.S.; GIZEL TABIBNIA, DM.D.,M.S.,

INC.; YORAM KOHANZADEH, D.D.S,; YORAM KOHANZADEH, INC.; and DOES 1 to 2. This pleading, including attachments and exhibits, consists of tll1%0following number of pages: 6 3. Each plaintiff named above is a competent adult a. [_] except plaintiff (name): (1) [__] a corporation qualified to do business in California (2) ] an unincorporated entity (describe): (3) [__] a public entity (describe): (4) (] aminor {__] an adult (a) [__] for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b) [_] other (specify): (5) [___] other (specify): b. [_] except plaintiff (name): (1) [_] a corporation qualified to do business in California (2) [__] an unincorporated entity (describe): (3) [__] a public entity (describe): (4) [_] aminor [_] an adult (@) [___] for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b) [_] other (specify): (6) [_] other (specify):

CASE NUMBER:

[__] Information about additional plaintiffs who are not competent adults is shown in Attachment 3.

- | PLD-PI-001

SHORT TITLE: ‘ CASE NUMBER:

CALDERON v. SMILE CARE, et al.

4. [_] Plaintiff (name): is doing business under the fictitious name (specify):

and has-complied with the fictitious business name laws.

5. Each defendant named above is a natural person NAVNEET ARORA PROFESSIONAL

a. except defendant (name): SMILE CARE c. except defendant (name): DENTAL CORPORATION (1) a business organization, form unknown (1) [_] a business organization, form unknown (2) [__] a corporation (2) a corporation - (3) [_] an unincorporated entity (describe): (3) [__] an unincorporated entity (describe): (4) [_] a public entity (describe): (4) [__] a public entity (describe): (6) [_] other (specify): (5) [__] other (specify):

COAST DENTAL

b. except defendant (name): SERVICES, INC. d. except defendant (name): GIZEL TABIBNIA, DM.D., M.S., INC. (1) {1 a business organization, form unknown (1) {__] a business organization, form unknown (2) a corporation (2) [(X]. a corporation (3) [__] an unincorporated entity (describe): (3) [_] an unincorporated entity (describe): (4) [_1 a public entity (describe): (4) [ ] a public entity (describe): (6) [__1 other (specify): (5) (] other (specify):

Information about additional defendants who are not natural persons is contained in Attachment 5.

6. The true names of defendants sued as Does are unknown to plaintiff. a. [_] Doe defendants (specify Doe numbers): were the agents or employees of other named defendants and acted within the scope of that agency or employment. b. Doe defendants (specify Doe numbers): 1 to 100 are persons whose capacities are unknown to plaintiff. 7. [] Defendants who are joined under Code of Civil Procedure section 382 are (names):

8. This.court is the proper court because a. [_] atleast one defendant now resides in its jurisdictional area. b. the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area. C. injury to person or damage to personat property occurred in its jurisdictional area.

d. [_] other (specify):

9. [_] Plaintiff is required to comply with a claims statute, and a. [__] has complied with applicable claims statutes, or b. [_] is excused from complying because (specify):