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To: THE POOL MANAGEMENT COMPANY, INC., A California Corporation and ROBERT TOLEDO, an individual, TAKE NOTICE OF THE FOLLOWING:
PLAINTIFFS STATEMENT OF
PURSUANT TO C.C.P §425.11
SUPERIOR COURT FOR THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN DIEGO
HALL OF JUSTICE
330 WEST BROADWAY
SAN DIEGO CA 92101
CASE NO. GIC 865897
Troy Wensel and Darlene Wensel,
The Pool Management Company Inc., a California Corporation, Robert Toledo, an individual, et al.
COME NOW Plaintiffs TROY WENSEL and DARLENE WENSEL and allege as follows: The following response is provided pursuant to the requirements of C.C.P. §425.11, and is provided at the outset of the case without the benefit of discovery or expert analysis. According, Plaintiff reserves the right to revise such figures as discovery and further information is obtained.
PLAINTIFF HEREBY NOTIFIES DEFENDANTS that Plaintiff is seeking to recover monetary damages in this case in the amounts set forth below: Special Damages
(Economic damages) in the amount of $300,000.00. This includes costs of consultants, engineers, demolition and reconstruction of the pool and adjacent areas. General Damages
(Non-economic damages) in the amount of $500,000.00. This amount includes loss of use and enjoyment, emotional distress, and associated non-economic damages.
The foregoing does not include damages for diminution in value, unanticipated reconstruction costs, attorneys fees, interest or court costs.
DATED: July 7, 2006
BROWNING & ASSOCIATES, APC
By: /s/ William K. Browning, Esq.
Attorneys for Plaintiffs TROY WENSEL and DARLENE WENSEL
402 W. Broadway, Suite 400
SAN DIEGO, CA 92101
Pub. Aug. 23, 30, Sept. 6,13-00011809