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Full title: Reply to (related document(s): 64 Response to motion for order to terminate, annul, modify or condition the automatic stay and declaration(s) in support filed by Creditor Virage SPV 1, LLC, 95 Reply filed by Creditor Frantz Law Group, APLC, 97 Notice to Filer of Error and/or Deficient Document) (with zoom hearing information) Filed by Creditor Frantz Law Group, APLC (Attachments: # 1 Evidentiary Objections) (Winston, Eric) (Entered: 01/19/2021)

Document posted on Jan 18, 2021 in the bankruptcy, 66 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

ANY, a California 19 Corporation, and SEMPRA ENERGY, a California Corporation, were acting for and on behalf 20 of each of the other defendants and DOES 1-100 as their agents, servants, representatives, 21 employees, joint venturers and/or co-conspirators; that all acts, conduct, and omissions herein 22 alleged were perpetrated while said Defendants and DOES 1-100 were acting within the 23 authorized course, scope, and purpose of said agency, employment, joint venture and/or 24 conspiracy; that all acts, conduct or omissions were subsequently ratified by the respective 25 principals and the benefits thereof accepted by said principals; and that each Defendant, as 26 aforesaid, while acting as a principal, was negligent (in respect to private defendants herein) or 27 created a dangerous condition (as to public entities) in respect to the ownership, operation, 28 control, management, supervision, and maintenance of the subject property, involved in the -8- 1 subject incident; said private entity defendants were further negligent in the selection, hiring, 2 training or supervision of each and every other Defendant and DOES 1-100 as its agent, servant, 3 employee, joint venture and/or co-conspirator.Defendants and DOES 1-100, respectively, are liable for punitive damages 20 pursuant to subdivision (a) of California Civil Code, section 3294, based upon their wrongful 21 conduct, including the conduct of their officers, directors and managing agents, and the 22 wrongful conduct of their respective employees whose names are unknown and are sued herein 23 as DOES 20-30. As a further direct and proximate cause of the conduct of Defendants, Plaintiffs 12 have hired and retained counsel to recover compensation for loss and damage and are entitled to 13 recover all attorney's fees, expert fees, consultant fees and litigation costs and expenses as 14 allowed under California Code of Civil Procedure section 1021.9. That further, under and pursuant to California Code of Civil Procedure section 7 1036, Plaintiffs are entitled to recover all litigation costs and expense with regard to the 8 compensation for damage of properties, including attorneys' fees, expert fees, consultant fees 9 and litigation costs.Defendants' actions, conduct, omissions, negligence, trespass and failure to act 24 resulted in an air and water pollution hazard and foreseeable obstruction to the free use of 25 Plaintiffs'' property, invaded the right to use the property, and interfered with the enjoyment of 26 Plaintiffs' property, causing the Plaintiffs unreasonable harm and substantial actual damages 27 constitution a nuisance, pursuant to California Civil Code section 3479.

List of Tables

Document Contents

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP Kenneth Chiate (Cal. Bar No. 39554) 2 kenchiate@quinnemanuel.com K. John Shaffer (Cal. Bar No. 153729) 3 johnshaffer@quinnemanuel.com Eric Winston (Cal. Bar No. 202407) 4 ericwinston@quinnemanuel.com Razmig Izakelian (Cal. Bar No. 292137) 5 razmigizakelian@quinnemanuel.com 865 South Figueroa Street, 10th Floor 6 Los Angeles, California 90017-2543 Telephone: (213) 443-3000 7 Facsimile: (213) 443-3100 8 Attorneys for Frantz Law Group, APLC 9 UNITED STATES BANKRUPTCY COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 LOS ANGELES DIVISION 12 In re Chapter 7 13 GIRARDI KEESE, dba, THOMAS VINCENT Case No. 2:20-bk-21022-BR 14 GIRARDI REPLY TO VIRAGE SPV1 LLC’S 15 Debtor. OPPOSITION TO MOTION FOR RELIEF FROM STAY AND DEMAND FOR 16 ADEQUATE PROTECTION 17 Date: January 26, 2021 Time: 10:00 a.m. 18 Place: Courtroom 1668 via ZoomGov Web Address: 19 https://cacb.zoomgov.com/j/1607815035 Meeting ID: 1607815035 20 Password: 123456 Telephone: (646) 828-7666 21 22 23 24 25 26 27

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1 Frantz Law Group, APLC hereby replies to the Opposition to Motion for Relief from Stay b 2 Frantz Law Group APLC; Demand for Adequate Protection [ECF 64] (“Opposition”) filed by Virag 3 SPV1, LLC (“Virage”). In support of this Reply, Frantz submits the concurrently filed Evidentiar 4 Objections to Declaration of Lewis R. Landau (“Evidentiary Objections”).1 5 I. REPLY 6 A. Virage’s Argument That Frantz Has Not Provided Sufficient Facts Is Wrong. 7 Frantz seeks an order (1) confirming that the automatic stay does not apply to clients choosin8 to terminate GK and to Frantz conferring with such clients, or (2) alternatively, granting relief fro9 stay. As set forth in Frantz’s opening Memorandum, clients are free to fire their attorney at any tim10 and Frantz has an ethical duty to provide information to its clients. Memo at 4-5. Moreover, althoug11 GK’s estate may have an interest in fees that is has earned to date, it has no property interest i12 unearned, prospective fees for future services under California law. Id. at 4-5. 13 Virage suggests (but does not clearly argue) that Frantz has provided insufficient informatio14 for the Court to find that the automatic stay does not apply. Opposition at 2. To the extent Virage i15 making that argument, it is wrong. 16 Frantz has submitted a declaration from its founder and Chief Executive Officer whic17 specifically states that Frantz is co-counsel with GK to over 8,000 clients in the Southern Californi18 Gas Leak Litigation. Frantz Decl. ¶¶ 8-9. Frantz also specifically states that it did not attach an19 written fee contracts because those are confidential communications that an attorney generally ma20 not disclose pursuant to California Business & Professions Code section 6149, but that Frantz woul21 request to file them under the seal if the Court believed it was necessary to review any of th22 contracts. Memo. at 2 n.2.2 The admissible evidence, to which Virage has not filed any objections,23 24 1 All terms not defined herein have the same meaning as in the Notice of Motion and Motion fo25 Relief from the Automatic Stay Under 11 U.S.C. § 362 (with supporting declarations) (Action i26 Nonbankruptcy Forum) [ECF 31] (“Motion”). 2 Virage apparently has copies of at least some documents relating to the contracts, given that 27 improperly filed one with its Opposition. Frantz immediately notified Virage of the document’confidentiality, which has since been sealed. See ECF 84. Although Virage has yet to explain how

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1 demonstrates that Frantz and GK agreed to work together on the Southern California Gas Lea 2 Litigation, and that all clients represented by either firm in any manner would be jointly represente3 by both firms for all purposes. Frantz Decl. ¶¶ 8-9. 4 To the extent that Virage actually questions whether Frantz and GK served as co-counse5 attached as Appendix “1” is a copy of a complaint filed in the Southern California Gas Leak Litigatio6 in 2016, naming dozens of plaintiffs, and represented by Frantz and GK.4 Both firms signed th7 complaint. If Virage actually had any interest in the Southern California Gas Leak Litigation, it woul8 have easily found this complaint, among many other similar ones. 9 B. Virage Does Not Dispute That A Client Always Has The Ability To Fire His OHer Lawyer And That The Estate Lacks A Property Interest In Unearned Fee10 And Its Arguments Concerning A Purported Joint Venture Are Both Wrong anIrrelevant To Stay Relief. 11 12 Virage does not dispute that a client is free to fire his or her attorney without violating th13 automatic stay, and that the estate has no property interest in unearned fees, nor does Virage eve14 comment on the authorities Frantz cited in the Motion. Virage also fails to acknowledge this Court’15 own statements at the January 5, 2021 hearing on whether to grant a motion to appoint an interi16 trustee. See Jan. 5, 2021 H’rg Tr. [In re Girardi, Case No. 2:20-bk-21020-BR, ECF No. 59] at 9:1317 16 (“the law is pretty clear that plaintiffs or defendants for that matter but in this case plaintiffs i18 lawsuits have an absolute right any time they want they can move to another attorney.”). The estate’19 lack of a property interest in prospective fees, and the client’s ability to unilaterally terminate th20 relationship at any time, means that the there is no interest in fees for future services protected by th21 automatic stay. 22 obtained the document, apparently GK provided it to Virage without the consent of the clients o23 Frantz. Frantz reserves all rights on behalf of itself and its clients. 24 3 See Local Bankruptcy Rule 9013-1(i)(2) (evidentiary objections may be deemed waived if nset forth in a separate document citing the specific Federal Rule of Evidence upon which the objectio25 is based). 26 4 Pursuant to Federal Rule of Evidence 201, the Court may take judicial notice of the fact that thicomplaint was filed. U.S. ex rel. Robinson Rancheria Citizens Council v. Borneo, Inc., 971 F.2d 2427 248 (9th Cir. 1992) (“[W]e may take notice of proceedings in other courts, both within and without thfederal judicial system, if those proceedings have a direct relation to matters at issue.”).

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1 Instead, Virage raises a specious argument there “may” be a joint venture relationship betwee 2 Frantz and GK “in which general partnership duties apply among the partners.” Opposition at 3. Th3 argument, however, is contrary to the sole case that Virage cites, Blatt v. Frantz Law Group, 2017 W4 655851, at *6-7 (Cal. Ct. App. Feb 17, 2017). In that case, the California Court of Appeal held that a5 agreement between firms to work together to represent plaintiffs in a case did not create a joi6 venture obligation to a client because the agreement was not executed in the name of joint venture o7 partnership, but rather, separately by each firm. Id. at *6-7 & n.13 (citing Cal. Corp. Code 8 16301(1)). Therefore, based on Virage’s own authorities, there is no joint venture relationship her 9 Moreover, even if there was a joint venture (which there is not), relief from stay would still b10 appropriate. Any joint venture that existed would be a personal services relationship that is n11 assumable or assignable by the trustee under Bankruptcy Code section 365(c). See In re Catapu12 Entertainment, Inc., 165 F.3d 747 (9th Cir. 1998). Thus, neither GK nor the trustee would be able t13 assume or assign those agreements, and they have no value to the bankruptcy estate. Because the14 have no value to the bankruptcy estate, and there is no possible way for GK to perform as co-counse15 the estate will suffer no prejudice if relief from stay is granted. See, e.g., In re Catron, 158 B.R. 6216 625 (Bankr. E.D. Va. 1992) (“I hold that the partnership agreement is an executory contract fo17 personal services not assumable by the debtor and that cause exists to grant plaintiff’s motion fo18 relief from stay.”). 19 C. Virage’s Request For Adequate Protection Must Be Denied Because It Has NoProvided Any Evidence That It Has A Security Interest In Fees From Th20 Southern California Gas Leak Litigation. 21 Virage asserts that it is entitled to adequate protection under section 363(e) because it is 22 secured creditor of GK that is owed over $10 million under a November 12, 2017 note and a Februar23 26, 2018 note. Opposition at 2, 3. It contends that the February 26, 2018 note, under which it i24 allegedly owed $4,990,572.40, is secured by an interest in the proceeds of the Southern California Ga25 Leak Litigation. Id. 26 As a threshold matter, Virage provides no admissible evidence that it holds a security intere27 in the proceeds. Virage attaches a Declaration of Lewis Landau (its bankruptcy counsel), in whic

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1 Southern California Gas Leak Litigation cases referenced in the Motion.” Landau Decl. ¶ 2. Virag2 however, does not attach any security agreement to that declaration.5 Nor does it lay any foundatio3 under Federal Rule of Evidence 803(6) to admit copies of the promissory notes as business record 4 Incredibly, the declaration does not even state that the declarant has personal knowledge of th5 contents of his declaration. See Federal Rule of Evidence 602. Again, Mr. Landau is just bankruptc6 counsel; he has not offered any basis to establish any personal knowledge of Visage’s allege7 documents. 8 Virage has the burden of demonstrating the validity, priority, or extent of any interest it has i9 the proceeds of the Southern California Gas Leak Litigation. See, e.g., 11 U.S.C. § 362(g)(2) (statin10 that the party opposing a motion for relief from stay has the burden of proof on all issues except th11 issue of the debtor’s equity in the property); 11 U.S.C. § 363(p)(2) (“the entity asserting an interest i12 property has the burden of proof on the issue of the validity, priority, or extent of such interest”); In r13 Hotel Sierra Vista Ltd. P’ship, 112 F.3d 429, 434 (9th Cir. 1997) (“[A]s a preliminary matter, th14 party must prove that it holds a perfected security interest ….”); In re Carlos, 215 B.R. 52, 59 (Bank15 C.D. Cal. 1997) (holding that the creditor has the “burden of proof to show that it has a valid securit16 interest”). Because Virage has not satisfied its burden of proof, it is not entitled to any adequat17 protection. 18 D. Even If Virage Had A Security Interest In Fees From The Southern CaliforniGas Leak Litigation, It Is Not Entitled To Adequate Protection. 19 Bizarrely, Visage requests adequate protection in response to the Motion, which asks the Cou20 to confirm either the automatic stay does not apply or, if it does, that Frantz be granted relief from th21 22 5 While Virage offers to provide the “voluminous loan agreements evidencing Virage’s securit23 interest … upon request and execution of an appropriate protective order stipulation to protect againdisclosure of confidential client information,” Landau Decl. ¶ 2, it has not even provided admissibl24 evidence in the form of a declaration to demonstrate that it has loaned money to GK or taken an25 security interest. It is also worth mentioning the irony of Virage withholding its loan agreemenbecause it may contain confidential client information, but at the same time (a) improperly criticizin26 Frantz for not revealing client confidential information to demonstrate a factual basis for the Motioand (b) attaching the “Porter Ranch Agreement,” which contains confidential client information, an27 which Virage has subsequently moved to redact after Frantz sent a letter advising Virage of its cleaviolations. See ECF 74, 84.

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1 automatic stay. Adequate protection can be required under section 362 because of the imposition o2 the automatic stay. But since Frantz is asking for relief from stay, Visage has no right to deman3 adequate protection if this Court grants relief from stay. 4 Even if it were correct for Visage to request adequate protection if this Court grants th 5 Motion, Visage is not entitled to any adequate protection in respect of the relief sought. Virage cann6 demonstrate that its interest in GK’s interest in any futures proceeds of the Southern California Ga 7 Leak Litigation lacks adequate protection. See In re Marques, 547 B.R. 841, 844 (Bankr. C.D. Ca8 2016) (holding that secured creditor seeking relief from stay must make prima facie showing that it9 interest lacks adequate protection). 10 The reason that Virage is not entitled to any additional protection is that clients are always fre11 to terminate their attorney(s) at any time, for any reason, General Dynamics Corp. v. Superior Cour12 7 Cal. 4th 1164, 1174 (1994), and any expectation of unearned or prospective fees is not a propert13 interest, Heller Ehrman LLP v. Davis Wright Tremaine LLP, 4 Cal. 5th 467, 471 (2018). Because G14 has no property interest in prospective, unearned fees, Virage likewise cannot have any interest in an15 fees that could be harmed by the imposition of the automatic stay. See In re Radden, 35. B.R. 8216 824 (Bankr. E.D. Va. 1983) (“[T]he estate should have an interest in the property for which a credito17 seeks adequate protection. … GMAC's allowed secured claim cannot be based on an interest i18 property in which the estate has no interest.”); see also In re Megan-Racine Assocs., Inc., 192 B. 19 321, 328 (Bankr. N.D.N.Y. 1995) (holding that parties holding only a “contingent interest” in propert20 are not entitled to adequate protection). Therefore, Virage’s request for adequate protection must b21 denied. 22 II. CONCLUSION 23 For the reasons stated above, Frantz respectfully requests that the Court overrule th24 Opposition and grant the relief requested in the Motion. 25 26 27

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1 DATED: January 19, 2021 Respectfully submitted, 2 QUINN EMANUEL URQUHART & SULLIVAN, LL 3 By: /s/ Eric Winston Kenneth Chiate 4 John Shaffer Eric Winston 5 Razmig Izakelian 6 Attorneys for Frantz Law Group, APLC 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27

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1 APPENDIX

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Table 1 on page 9. Back to List of Tables
~nQRN~ PR T'.f!J'ITV Wl'!110UT llHQRNEV /NRIM, ·~·"' ear number, • nd addrc#sj:
James P. Frantz, Esq. SBN: 87.49.2
Frantz; Law Group, APLC
555 West Fifth St, 31 '1 Floor, LA, CA 900)°3
. i'ElJPHONE N0:!323 .425.8138 FI\)( N0.:619.52$~7~72
.ATTOAfiEV FOJ\ (Name):·Plairitiffs ,
$YPl;i.RIOR CQURT' OF CAL1FORNIA, COUNTY OF LOS ANG)3LES
~EIITAOOAEj;s: 111 North mu Street I
I
:MAii.iNG AoollE!>S: 1i1 North Hnl Stree~
ClTl'ANDZIP'oPOE:Los Angeles, CA ~Ob.12 J!
:fiRmoH NAMe: Stanle'v Mosk Courthouse
i
CIVIL. CASE COVER SHEET C9mplEiJI case Des!'11:'11!(ion CASE NUMBER: , [X] Unlfmitecl D· Llml~ed rh D l1f' " "' (Amount (Amount T. Cot1nter . Jolnder i-JU-. -oo'""IE:_wt:_:r-t~r-ivH"_, .f----"'-:-""""2-~--i (j~m~ndec,f d~manded Is Fll~d wlth.flrst appearance by defe.!Jqant u ~ exceeds $25,00Q} $25,000 or l~ss) . . I (Qal, AU~$ of·Oourt, rule 3.402) oePr: Items 1--6 below-m~! bG comp~t(fq (seE) lnstrµotlons on page 2) .. · 1. Check on~ )Jex t;ielPW fQr t.he c:Me type that best tlescribes this case; Auto Ton Con}r.,ct' Provlsl(inally· C:Omp.lex CIVIi Litigation EJ Auto (22)' D B(each of conlr.Eiol/warr~nty (OS} (CaL Rules~ of Court. rules ·a.400-3.40~) 0 D Uninsured motorist (46) Rule S.740 eollections (09) AnWustJTr~de r!.'!gula!km (03j D D Other Pl/PP/Wtl (~11rsonal Injury/Property Olher collec1ions (09) Consfrucllon defect '{10) D D 011mag~rorig~µl pl!~t~}\l:ll't Insurance coverage (16} Me,s't tonXilD) D · 0 D Asbeslot; (04) 'Olher contract (37) Sectlrltles litlgafion {26J D P.rodue1 liability (~4} aRea l Property !JD Envfronme111avroxio tort (30) DD Medical malpractice (45) Eminent domalt'.111i'1Vers~ W Insurance coverage .claims arisinQ fi:om the Olher PllPD/WD (23) 1 cont1emnaUon (~4) above llsted pro11lslonally complex case ~on-Pl/PD/WD (Other) 'Tort qD Wrori.i;lftll eviolion (33) types (41} DD aus1ness tor11unta1r business practice. to71 other re~ property (26} DEnt o~ement.of Judgment Civil. righ1s (08) Unlawful Detainer Enforcement of jlldgment (20)-D D Oela:rtia:lion (13) Commercial (31) Mlseellaneous Clv11 Compl11lnt D D D Fraud (16) Residentlal (32} BICO (27) D .lnie!lec;tual property mn §D Druas {g8), D Ol~er ¢Qii\pla1tit (not speoifiedabove) {!42) D Ptofesslonat negligence (25) JudlCiel ·Review Nllscel~neous clv.11 Petltloi:i D Other·non·PllPDi'WD iM (35) Ass!!l fOrfE!~µfe (OS) D Parlnership and corporale gove~n1111oe (2~) D ~loyrnent · Pelilion re: arbitration award (11 l Olh~r petHton· (n1'V>peoified abov{J) (43) · L.J Yl/rOflgful termina11on (36) 1 Writ 'of mandats (02): · . D n Other employment (.15) Olher Judicial rev(ew (391 / 2. This case ~ Is LJ ls not eornp1ex ubt;ter rui~ ~.400 ~f the Cai1fomla Rules· o.f Court If the case ls jmplex, mE1* the. factors requiring exceptional judicial manageme~t:P:rovisit>nally complex 1i. DO Large number pf sepata:tely .represe:nte~:partles d. ~ Large number of witnesses / :b. CR] Extensive motion practice raising dlfflc~lt or novel e. [fil Coordlnmlon·wlJ:h related actions pcyIEY FOi'! PAR1Y) • Plalritlff must file th ls cover sheet.with the flrst paper flied In the action Qr pr9ce13dln.g (ex s <'!ii c_laims cases.or cases.illed under the Probate Cbde, Family Code, or Wells.re and Institutions .Code). (Cal. Rules of urt, rute·s.2.20.) fallure to file may result In sarictlons. t • Fite this ¢oVf3r sheeJ In ai;ldltloh td ariy cover sh~et required oy Joo~I Qoui:t rule~ • It this case ls complex under rule '3-40.0 et seq. ·bf the California ·Rules ·of'Court, you ·must ser\le·a copy of this cover .sheet on· all other parties to the action or. proceeding. l • Unless th ls is a coll®tlons case under rule ~.74b era.complex case, 1hl$ ¢ever S.heetWfll b.e \Js'Eld for stat!Stlcal purposes onlv.

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SHORT TITLE: CASE NUMBER Toni Adelan, et al. v. Southern Callfomla Gas Company, et al. CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION (CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION) This form is required pursuant to Local Rule 2.3 in all new civil case filings in the Los Angeles Superior Court. Item I. Check the types of hearing and fill In the estimated length of hearing expected for this case: JURY TRIAL?yfYES CLASS ACTION? YES LIMITED CASE? YES TIME ESTIMATED FOR TRIAL_3_o-_ao_ __" "'H"'"O"""U'-"RS-./._.tD=A_...Y_.S Item II. Indicate the correct district and courthouse location (4 steps -If you checked •Limited Case•, skip to Item II\, Pg, 4): Step 1: After first completing the Civil Case Cover Sheet form, find the main Civil Case Cover Sheet heading for your case in the left margin below, and, to the right in Column A, the Civil Case Cover Sheet case type you selected. Step 2: Check l21lil Superior Court type of action In Column B below which best describes the nature of this case. Step 3: In Column C, circle the reason for the court location choice that applies to the type of action you have checked. For any exception to the court location, see Local Rule 2.3. Applicable Reasons for Choosing Courthouse Location (see Column C below) 1. Class actions must be med In the Stanley Mosk Courthouse, central district. 6. Location of property or permanently garaged vehlcle. 2. May be filed In central (other county, or no bodily Injury/property damage). 7. Location where peUUoner resides. 3. Location where cause of action arose. 6. Location Wherein defendanUrespondent functions wholly. 4. Location wtiere bodily lnjury, death or damage occurred. 9. Location where one or more of the 1>arties reside. 5. Locatlon where performance required or defendant resides. 10. Location of Labor Commissioner Office 11. Mandatory Flllng Lotatlon (Hub Case) Step 4: Fill in the information requested on page 4 in Item Ill; complete Item IV. Sign the declaration. Auto(22) O A7100 Motor Vehicle-Personal lnjury/PropertyDamageiWrongful Death 1., 2., 4.
Table 1 on page 10. Back to List of Tables
Uninsured Motorist (46) D A711 O Personal Injury/Property DamageiWrongful Death-Uninsured Motorlst 1., 2., 4. None
CJ A6070 Asbestos Property Damage
Asbestos (04)
O A7221 Asbestos· Personal ln]uryM/rongful Death
2.
2.
Product Llablllty (24) O A7260 Producl Llabllity (not asbestos or toxlc/envlronmental) 1., 2 .• 3., 4., 8,
D A7210 Medical Malpractice· Physicians & Surgeons
Medical Malpractlce (45)
IJ A7240 Other Professional Health Care Malpractice
1., 4.
1. . 4.
D A7250 Premises IJability (e.g., slip and fall)
Other Personal
Injury Property D A7230 Intentional Bodily Injury/Property DamageM/rongfu! Dealh (e.g.,
Damage Wrongful assault, vandalism, etc.)
oeath(23) D A7270 Intentional lnfilctlon o! Emotional Distress
O A722.0 Other Personal Injury/Property Damage/Wrongful Death
1., 4.
1.,4.
1., 3.
1., 4.

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Toni Adelan, et al. v. Southern California Gas Company, et al. A B C Applicable Civil Case Cover Sheet Type of Action Reasons ~ See Step 3Category No. (Check only one) Above ·. · .. Business Tort (07) D A6029 Other Commercial/Business Tort (not fraud/breach of contract) 1., 3. Civil Rights (08) D A6005 Civil Rights/Discrimination 1., 2., 3. Defamation (13) D A6010 Defamation (slander/libel) 1., 2., 3. Fraud (16) D A6013 Fraud (no contract) 1., 2., 3. D A6017 Legal Malpractice 1., 2., 3. Professional Negligence (25) D A6050 Other Professional Malpractice (not medical or legal) 1., 2., 3. Other (35) D A6025 Other Non-Personal Injury/Property Damage tort 2.,3. - c Wrongful Termination (36) D A6037 Wrongful Termination 1., 2., 3. Cl) ~ D A6024 Other Employment Complaint Case 1., 2., 3. Ci. Other Employment (15) E D A6109 Labor Commissioner Appeals 10. w D A6004 Breach of Rental/Lease Contract (not unlawful detainer or wrongful 2., 5. eviction) Breach of Contract/ Warranty 2., 5. (06) D A6008 Contract/Warranty Breach -Seller Plaintiff (no fraud/negligence) (not insurance) D A6019 Negligent Breach of Contract/Warranty (no fraud) 1., 2., 5. 1., 2., 5. D A6028 Other Breach of Contract/Warranty (not fraud or negligence) ~ D A6002 Collections Case-Seller Plaintiff 2., 5., 6, 11 Collections (09) c D A6012 Other Promissory Note/Collections Case 2., 5, 11 0 (.) D A6034 Collections Case-Purchased Debt (Charged Off Consumer Debt 5,6, 11 Purchased on or after Januarv 1, 2014\ Insurance Coverage (18) D A6015 Insurance Coverage (not complex) 1., 2., 5., 8. D A6009 Contractual Fraud 1., 2., 3., 5. Other Contract (37) D A6031 Tortious Interference 1., 2., 3., 5. D A6027 Other Contract Dispute(not breach/insurance/fraud/negligence) 1., 2., 3., 8. Eminent Domain/Inverse D A7300 Eminent Domain/Condemnation Number of parcels ___ 2. Condemnation (14) Wrongful Eviction (33) D A6023 Wrongful Eviction Case 2., 6. D A6018 Mortgage Foreclosure 2., 6. Other Real Property (26) D A6032 Quiet Title 2., 6. D A6060 Other Real Property (not eminent domain, landlord/tenant, foreclosure) 2., 6. Unlawful Detainer-Commercial D A6021 Unlawful Detainer-Commercial (not drugs or wrongful eviction) 2., 6. (31) Unlawful Detainer-Residential D A6020 Unlawful Detainer-Residential (not drugs or wrongful eviction) 2., 6. (32) Unlawful Detainer- D A6020F Unlawful Detainer-Post-Foreclosure 2., 6. Post-Foreclosure (34) Unlawful Detainer-Drugs (38) D A6022 Unlawful Detainer-Drugs 2., 6.

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Toni Adelan, et al. v. Southern California Gas Company, et al. A B C Applicable Civil Case Cover Sheet Type of Action Reasons -See Step 3 Category No. (Check only one) Above Asset Forfeiture (05) D A6108 Asset Forfeiture Case 2., 6. Petition re Arbitration ( 11) D A6115 Petition to Compel/ConfirmNacate Arbitration 2., 5. D A6151 Writ -Administrative Mandamus 2., 8. Writ of Mandate (02) D A6152 Writ -Mandamus on Limited Court Case Matter 2. D A6153 Writ -Other Limited Court Case Review 2. Other Judicial Review (39) D A6150 Other Writ /Judicial Review 2., 8. Antitrust/Trade Regulation (03) D A6003 Antitrust/Trade Regulation 1., 2., 8. c 0 ~ Construction Defect (10) D A6007 Construction Defect 1., 2., 3. :Ce ) -I Claims Involving Mass Tort ~ D A6006 Claims Involving Mass Tort 1., 2., 8. c.. (40) E 00 Securities Litigation (28) D A6035 Securities Litigation Case 1., 2., 8. ~ Iii c Toxic Tort Iii A6036 Toxic Tort/Environmental 1., 2., 3., 8. ·u0; Environmental (30) -~ Insurance Coverage Claims D A6014 Insurance Coverage/Subrogation (complex case only) 1., 2., 5., 8. ll.. from Complex Case (4 1) D A6141 Sister State Judgment 2., 9. - - D A6160 Abstract of Judgment 2., 6. c c QE) QE) Enforcement D A6107 Confession of Judgment (non-domestic relations) 2., 9. ~Q) "CC) of Judgment (20) D A6140 Administrative Agency Award (not unpaid taxes) 2., 8. .E ~ wc D A6114 Petition/Certificate for Entry of Judgment on Unpaid Tax 2., 8. 0 D A6112 Other Enforcement of Judgment Case 2., 8., 9. RICO (27) D A6033 Racketeering (RICO) Case 1., 2., 8. ~~ g "iii D A6030 Declaratory Relief Only 1., 2., 8. c c.. .C.!i!)! 0E Other Complaints D A6040 Injunctive Relief Only (not domestic/harassment) 2., 8. uII) O (Not Specified Above) (42) D A6011 Other Commercial Complaint Case (non-tort/non-complex) 1., 2., 8. ::§ :~ 0 D A6000 Other Civil Complaint (non-tort/non-complex) 1., 2., 8. Partnership Corporation D A6113 Partnership and Corporate Governance Case 2., 8. Governance (21) D A6121 Civil Harassment 2., 3., 9. D A6123 Workplace Harassment 2., 3., 9. D A6124 Elder/Dependent Adult Abuse Case 2., 3., 9. Other Petitions (Not Specified Above) (43) D A6190 Election Contest 2. D A6110 Petition for Change of Name 2., 7. D A6170 Petition for Relief from Late Claim Law 2., 3., 4., 8. D A6100 Other Civil Petition 2., 9.

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Toni Adelan, et al. v. Southern California Gas Company, et al. Item Ill. Statement of Location: Enter the address of the accident, party's residence or place of business, performance, or other circumstance indicated in Item II., Step 3 on Page 1, as the proper reason for filing in the court location you selected.
Table 1 on page 13. Back to List of Tables
CITY: STATE: ZIP CODE: Porter Ranch CA 91326 Item IV. Declaration of Assignment: I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that the above-entitled matter is properly filed for assignment to the Stanley Mask courthouse in the Central Judicial District of the Superior Court of California, County of Los Angeles [Code Civ. Proc., § 392 et seq., and Local Rule 2.3, subd.(a). Dated: January '2016 (SIGNATURE OF ATTORNEY/FILING PARTY) PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY COMMENCE YOUR NEW COURT CASE: 1. Original Complaint or Petition. 2. If filing a Complaint, a completed Summons form for issuance by the Clerk. 3. Civil Case Cover Sheet, Judicial Council form CM-010. 4. Civil Case Cover Sheet Addendum and Statement of Location form, LACIV 109, LASC Approved 03-04 (Rev. 03/15). 5. Payment in full of the filing fee, unless fees have been waived. 6. A signed order appointing the Guardian ad Litem, Judicial Council form CIV-010, if the plaintiff or petitioner is a minor under 18 years of age will be required by Court in order to issue a summons. 7. Additional copies of documents to be conformed by the Clerk. Copies of the cover sheet and this addendum must be served along with the summons and complaint, or other initiating pleading in the case.

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SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES NOTICE OF CASE ASSIGNMENT -UNLIMITED CIVIL CASE (NON-CLASS ACTION) o Case Number~~~~~~~~~~~~~~~~~- BC 6 7 5 4 2 THIS FORM IS TO BE SERVED WITH THE SUMMONS AND COMPLAINT \'our case is assigned for all purposes to the judge indicated below. There is more information on the reverse side of this form.
Table 1 on page 14. Back to List of Tables
ASSIGNED JUDGE DEPT ROOM ASSIGNED JUDGE DEPT ROOM
Hon. Kevin C. Brazile 1 534 None Hon. Elizabeth Allen White 48 506
Hon. Barbara A. Meiers 12 636 None Hon. Deirdre Hill 49 509
Hon. Terry A. Green 14 300 None Hon. Teresa A. Beaudet 50 508
Hon. Richard Fruin 15 307 None Hon. Michael J. Raphael 51 511
Hon. Rita Miller 16 306 None Hon. Susan Bryant-Deason 52 510
Hon. Richard E. Rico 17 309 None Hon. Steven J. Kleifield 53 513
Hon. Stephanie Bowick 19 311 None Hon. Ernest M. Hiroshige 54 512
Hon. Dalila Corral Lyons 20 310 None Hon. Malcolm H. Mackey 55 515
Hon. Robert L. Hess 24 314 None Hon. Michael Johnson 56 514
Hon. Yvette M. Palazuelos 28 318 None Hon. Rolf M. Treu 58 516
Hon. Barbara Scheper 30 400 None Hon. Gregory Keosian 61 732
Hon. Samantha Jessner 31 407 None Hon, Michael L. Stern 62 600
Hon. Daniel S. Murphy 32 406 None Hon. Mark Mooney 68 617
Hon. Michael P. Linfield 34 408 None Hon. William F. Fahey 69 621
Hon. Gregory Alarcon 36 410 None Hon. Suzanne G. Bruguera 71 729
Hon. Marc Marmaro 37 413 None Hon. Ruth Ann Kwan 72 731
Hon. Maureen Duffy-Lewis 38 412 None Hon. Rafael Ongkeko 73 733
Hon. Elizabeth Feffer 39 415 None Hon. Teresa Sanchez-Gordon 74 735
Hon. Michelle R. Rosenblatt 40 414 None Hon. Gall Ruderman Feuer 78 730
Hon. Holly E. Kendig 42 None 416 None
Hon. Mel Red Recana 45 None 529 None Hon. Emile H. Elias 324 ccw
Hon. Frederick C. Shaller 46 500 None "Provisionally Complex
Non-class Action Cases
Assignment is Pending
Complex Determination
r<
....__....
D
ccw
v
None Hon. Debre K. Weintraub 47 507 None None None None None
*Com PIH All non-class action cases designated as provisionally complex are forwarded to the Supervising Judge of the Complex Litigation Program located in the Central Civil West Courthouse (600 S. Commonwealth Ave., Los Angeles 90005), for complex/non-complex determination pursuant to Local Rule 3.J(k). This procedure is for the purpose of assessing whether or not the case is complex within the meaning of California Rules of Court, rule 3.400. Depending on the outcome of that assessment, the case may be reassigned to one of the judges of the Complex Litigation Program or reassigned randomly to a court in the Central District. Given to the Plaintiff/Cross-Complainant/Attorney of Record on----- tive Officer/Clerk

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INSTRUCTIONS FOR HANDLING UNLIMITED CIVIL CASES The following critical provisions of the Chapter Three Rules, as applicable in the Central District, are summarized for your assistance. APPLICATION The Chapter Three Rules were effective January l, 1994. They apply to all general civil cases. PRIORITY OVER OTHER RULES The Chapter Three Rules shall have priority over all other Local Rules to the extent the others are inconsistent. CHALLENGE TO ASSIGNED JUDGE A challenge under Code of Civil Procedure section 170.6 must be made within 15 days after notice of assignment for all purposes to ajudge, or if a party has not yet appeared, within 15 days of the first appearance. TIME STANDARDS Cases assigned to the Individual Calendaring Court will be subject to processing under the following time standards: COMPLAINTS: All complaints shall be served within 60 days of filing and proof of service shall be filed within 90 days of filing. CROSS.COMPLAINTS: Without leave of court first being obtained, no cross-complaint may be filed by any party after their answer isfiled. Cross-complaints shall be served within 30 days of the filing date and a proof of service filed within 60 days of the filing date. A Status Conference will be scheduled by the assigned Independent Calendar Judge no later than 270 days after the filing of the complaint. Counsel must be fully prepared to discuss the following issues: alternative dispute resolution, bifurcation, settlement, trial date, and experwitnesses. FINAL STATUS CONFERENCE The Court will require the parties at a status conference not more than I 0 days before the trial to have timely filed and served all motionsin limine, bifurcation motions, statements of major evidentiary issues, dispositive motions, requested jury instructions, and special jurinstructions and special jury verdicts. These matters may be heard and resolved at this conference. At least 5 days before this conference,counsel must also have exchanged lists of exhibits and witnesses and have submitted to the court a brief statement of the case to be read tothe jury panel as required by Chapter Eight of the Los Angeles Superior Court Rules. SANCTIONS The court will impose appropriate sanctions for the failure or refusal to comply with Chapter Three Rules, orders made by the Court, andtime standards or deadlines established by the Court or by the Chapter Three Rules. Such sanctions may be on a party or if appropriate ocounsel for the party. This is not a complete delineation of the Chapter Three Rules, and adherence only to the above provisions is therefore not aguarantee against the imposition of sanctions under Trial Court Delay Reduction. Careful reading and compliance with thactual Chapter Rules is absolutely imperative.

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VOLUNTARY EFFICIENT LITIGATION STIPULATIONS The Early Organizational Meeting Stipulation, Discovery Resolution Stipulation, and Motions in Limine Stipulation are voluntary stipulations entered into by the parties. The parties superlorcourtotcantornla County of Los Angeles may enter into one, two, or all three of the stipulations; LAC BA however, they may not alter the stipulations as written, because the Court wants to ensure uniformity of application. Los Angeles County These stipulations are meant to encourage cooperation Bar Association Litigation Section between the parties and to assist in resolving issues in a Los Angeles County Bar Association Labor and manner that promotes economic case resolution and judicial Employment Law Section efficiency. """''<•·~,, ... ,. . ~Ill ,! ; ~ • • I • ; . ,' ' ;!\1.1! \n·.•:: The following organizations endorse the goal of Consumer Attorneys Association of Los Angelea promoting efficiency in litigation and ask that counsel consider using these stipulations as a voluntary way to promote communications and procedures among counsel and with the court to fairly resolve issues in their cases. +Los Angeles County Bar Association Litigation Section+ Southern Callfomla Defense Counsel + Los Angeles County Bar Association Labor and Employment Law Section+ Association of Bualnesa Trial Lawyers +consumer Attorneys Association of Los Angeles+ +southern California Defense Counsel+ +Association of Business Trial Lawyers+ California Employment Lawyers Association +ca1ifornia Employment Lawyers Association+

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NAME ,>,ND ADDRESll OF ATTORNeV OR PAATY WITHOUT A'T'TORNEY: $TATEIWI NUMllEA lloHrvodfTable 1 on page 17. Back to List of Tables
SUAPTIOERRNEIOY FROR C (NOamUe\R: T OF CALIFORNIA. COUNTY OF LOS ANGELES
COURTHOUSE ADDRESS:
PLAINTIFF:
DEFENDANT:
CASE NUMtll!R: STIPULATION - DISCOVERY RESOLUTION This stipulation Is intended to provide a fast and informal resolution of discovery issues through limited paperwork and an informal conference with the Court to aid in the resolution of the issues. The parties agree that: 1. Prior to the discovery cut-off in this action, no discovery motion shall be filed or heard unless the moving party first makes a written request for an Informal Discovery Conference pursuant to the terms of this stipulation. 2. At the Informal Discovery Conference the Court will consider the dispute presented by parties and determine whether it can be resolved informally. Nothing set forth herein will preclude a party from making a record at the conclusion of an Informal Discovery Conference, either orally or in writing. 3. Following a reasonable and good faith attempt at an informal resolution of each issue to be presented, a party may request an Informal Discovery Conference pursuant to the following procedures: a. The party requesting the Informal Discovery Conference will: i. File a Request for Informal Discovery Conference with the clerk's office on the approved form (copy attached) and deliver a courtesy, conformed copy to the assigned department; ii. Include a brief summary of the dispute and specify the relief requested; and iii. Serve the opposing party pursuant to any authorized or agreed method of service that ensures that the opposing party receives the Request for Informal Discovery Conference no later than the next court day following the filing. b. Any Answer to a Request for Informal Discovery Conference must: i. Also be filed on the approved form (copy attached); ii. Include a brief summary of why the requested relief should be denied;

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iii. Be filed within two (2) court days of receipt of the Request; and iv. Be served on the opposing party pursuant to any authorized or agreed upon method of service that ensures that the opposing party receives the Answer no later than the next court day following the filing. c. No other pleadings, including but not limited to exhibits, declarations, or attachments, will be accepted. d. If the Court has not granted or denied the Request for Informal Discovery Conference within ten (10) days following the filing of the Request, then it shall be deemed to have been denied. If the Court acts on the Request, the parties will be notified whether the Request for Informal Discovery Conference has been granted or denied and, if granted, the date and time of the Informal Discovery Conference, which must be within twenty (20) days of the filing of the Request for Informal Discovery Conference. e. If the conference is not held within twenty (20) days of the filing of the Request for Informal Discovery Conference, unless extended by agreement of the parties and the Court, then the Request for the Informal Discovery Conference shall be deemed to have been denied at that time. 4. If (a) the Court has denied a conference or (b) one of the time deadlines above has expired without the Court having acted or (c) the Informal Discovery Conference is concluded without resolving the dispute, then a party may file a discovery motion to address unresolved issues. 5. The parties hereby further agree that the time for making a motion to compel or other discovery motion is tolled from the date of filing of the Request for Informal Discovery Conference until (a) the request is denied or deemed denied or (b) twenty (20) days after the filing of the Request for Informal Discovery Conference, whichever is earlier, unless extended by Order of the Court. It is the understanding and intent of the parties that this stipulation shall, for each discovery dispute to which it applies, constitute a writing memorializing a "specific later date to which the propounding [or demanding or requesting] party and the responding party have agreed in writing," within the meaning of Code Civil Procedure sections 2030.300(c), 2031.320(c), and 2033.290(c). 6. Nothing herein will preclude any party from applying ex parte for appropriate relief, including an order shortening time for a motion to be heard concerning discovery. 7. Any party may terminate this stipulation by giving twenty-one (21) days notice of intent to terminate the stipulation. 8. References to "days" mean calendar days, unless otherwise noted. If the date for performing any act pursuant to this stipulation falls on a Saturday, Sunday or Court holiday, then the time for performing that act shall be extended to the next Court day.

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The following parties stipulate: Date: (TYPE OR PRINT NAME) {ATIORNEV FOR PLAINTIFF) Date: (TYPE OR PRINT NAME) (ATTORNEY FOR DEFENDANT) Date: (TYPE OR PRINT NAME) {ATTORNEY FOR DEFENDANT) Date: (TYPE OR PRINT NAME) (ATTORNEY FOR DEFENDANT) Date: (TYPE OR PRINT NAME) (ATTORNEY FOR----------' Date: (TYPE OR PRINT NAME) (AlTORNEV FOR _________ _, Date: (TYPE OR PRINT NAME) (ATTORNEY FOR _________ _,

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Table 1 on page 20. Back to List of Tables
NAME ANO/.OORESS OF ATTORNEY OR PARTY WITHOUT ATTORNEY: $TATE BAR NUMl!Ell
TELEPHONE NO.: FAX NO. (Optional):
E·MAIL ADDRESS (Optional):
ATTORNEY FOR !Name}:
R1aen1M for Qttk't Flt Stamp
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES None
COURTHOUSE ADDRESS: None
This stipulation Is Intended to encourage cooperation among the parties at an early stage in the litigation and to assist the parties In efficient case resolution. The parties agree that: 1. The parties commit to conduct an initial conference (in-person or via teleconference or via videoconference) within 15 days from the date this stipulation is signed, to discuss and consider whether there can be agreement on the following: a. Are motions to challenge the pleadings necessary? If the issue can be resolved by amendment as of right, or if the Court would allow leave to amend, could an amended complaint resolve most or all of the issues a demurrer might otherwise raise? If so, the parties agree to work through pleading issues so that a demurrer need only raise issues they cannot resolve. Is the issue that the defendant seeks to raise amenable to resolution on demurrer, or would some other type of motion be preferable? Could a voluntary targeted exchange of documents or Information by any party cure an uncertainty in the pleadings? b. Initial mutual exchanges of documents at the "core" of the litigation. (For example, in an employment case, the employment records, personnel file and documents relating to the conduct in question could be considered "core." In a personal injury case, an incident or police report, medical records, and repair or maintenance records could be considered "core."); c. Exchange of names and contact information of witnesses; d. Any insurance agreement that may be available to satisfy part or all of a judgment, or to indemnify or reimburse for payments made to satisfy a judgment; e. Exchange of any other information that might be helpful to facilitate understanding, handling, or resolution of the case in a manner that preserves objections or privileges by agreement; f. Controlling issues of law that, if resolved early, will promote efficiency and economy Jn other phases of the case. Also, when and how such issues can be presented to the Court; g. Whether or when the case should be scheduled with a settlement officer, what discovery or court ruling on legal issues is reasonably required to make settlement discussions meaningful, and whether the parties wish to use a sitting judge or a private mediator or other options as

20

discussed in the "Alternative Dispute Resolution (ADR) Information Package" served with the complaint; h. Computation of damages, including documents, not priVileged or protected from disclosure, on which such computation is based; i. Whether the case is suitable for the Expedited Jury Trial procedures (see information at www.lacourt.org under "Civir and then under "General Information"). 2. The time for a defending party to respond to a complaint or cross-complaint will be extended to for the complaint, and for the cross- (INSERT DA TE) (INSERT DATE) complaint, which is comprised of the 30 days to respond under Government Code§ 68616(b), and the 30 days permitted by Code of Civil Procedure section 1054(a), good cause having been found by the Civil Supervising Judge due to the case management benefits provided by this Stipulation. A copy of the General Order can be found at www.lacourt.om under "Civif', click on "General Information", then click on "Voluntary Efficient Litigation Stfpulations". 3. The parties will prepare a joint report titled "Joint Status Report Pursuant to Initial Conference and Early Organizational Meeting Stipulation, and if desired, a proposed order summarizing results of their meet and confer and advising the Court of any way it may assist the parties' efficient conduct or resolution of the case. The parties shall attach the Joint Status Report to the Case Management Conference statement, and file the documents when the CMG statement is due. 4. References to "daysn mean calendar days, unless otherwise noted. If the date for performing any act pursuant to this stlpulation falls on a Saturday, Sunday or Court holiday, then the time for performing that act shall be extended to the next Court day · The following parties stipulate: Date: (TYPE OR PRINT NAME) (ATTORNEY FOR PLAINTIFF) Date: (TYPE OR PRINT NAME) (ATTORNEY FOR DEFENDANT) Date: )> {TYPE OR PRINT NAME) (ATTORNEY FOR DEFENDANT) Date: )> (TYPE OR PRINT NAME) (ATTORNEY FOR DEFENDANT) Date: )> (TYPE OR PRINT NAME) (ATIORNEY FOR Date: > (TYPE OR PRINT NAME) (ATTORNEY FOR Date: > (TYPE OR PRINT NAME) (ATTORNEY FOR

21

Table 1 on page 22. Back to List of Tables
NllME ANO AOOREllS OF l.TTORNEY OF! PAATY IMTHOUT l.TTORNEY: BfATEllARNUMllEA.
TELEPHONE NO.: FAX NO, (Optional):
E-MAIL ADDRESS (Optional):
ATTORNEY FOR CNamel:
l'l ... ..,.dfoteltrt'•Fllt 8"""'1
SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES
1
None
COURTHOUSE ADDRESS: None
PLAINTIFF: None
DEFENDANT: None
INFORMAL DISCOVERY CONFERENCE
(pursuant to the Discovery Resolution Stipulation of the parties)
CME NUMBER:
1. This document relates to: D Request for Informal Discovery Conference D Answer to Request for Informal Discovery Conference 2. Deadline for Court to decide on Request: (insert date 10 calendar days following filing of the Request). 3. Deadline for Court to hold Informal Discovery Conference: (Insert date 20 calendar days following filing of the Request). 4. For a Request for lnfonnal Discovery Conference, briefly describe the nature of the discovery dispute, Including the facts and legal arguments at Issue. For an Answer to Request for lnfonnal Discovery Conference, briefly describe why the Court should deny the requested discovery, Including the facts and legal arguments at issue.

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Table 1 on page 23. Back to List of Tables
NllME/oNtl,tJlORESS Of ATTOl\N~ ORPl\RTYW!TliOUT ATTORNEY: STATE BAA NUMflER
TELEPHONE NO.: FAX NO. (Optional):
E·MAIL ADDRESS (Optional):
ATTORNEY FOR (Namel:
RllMIVod lo< Clorlc'o Fl11 St-
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES None
COURTHOUSE ADDRESS: None
PLAINTIFF: None
OEFENOANT: None
STIPULATION AND ORDER - MOTIONS IN LIMINE None
This stipulation is intended to provide fast and informal resolution of evidentlary issues through diligent efforts to define and discuss such issues and limit paperwork. The parties agree that: 1. At least _ days before the final status conference, each party will provide all other parties with a list containing a one paragraph explanation of each proposed motion in \imine. Each one paragraph explanation must identify the substance of a single proposed motion in limine and the grounds for the proposed motion. 2. The parties thereafter will meet and confer, either in person or via teleconference or videoconference, concerning all proposed motions in limine. In that meet and confer, the parties will determine: a. Whether the parties can stipulate to any of the proposed motions. If the parties so stipulate, they may file a stipulation and proposed order with the Court. b. Whether any of the proposed motions can be briefed and submitted by means of a short joint statement of issues. For each motion which can be addressed by a short joint statement of issues, a short joint statement of issues must be filed with the Court 10 days prior to the final status conference. Each side's portion of the short joint statement of issues may not exceed three pages. The parties will meet and confer to agree on a date and manner for exchanging the parties' respective portions of the short joint statement of issues and the process for filing the short joint statement of issues. 3. All proposed motions in limine that are not either the subject of a stipulation or briefed via a short joint statement of issues will be briefed and filed in accordance with the California Rules of Court and the Los Angeles Superior Court Rules.

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The following parties stipulate: Date: (TYPE OR PRINT NAME) (ATTORNEY FOR PLAINTIFF) Date: (TYPE OR PRINT NAME) (ATTORNEY FOR DEFENDANT) Date: (TYPE OR PRINT NAME) (ATTORNEY FOR DEFENDANT) Date: (TYPE OR PRINT NAME) (A TIORNEY FOR DEFENDANT) Date: (TYPE OR PRINT NAME) (ATTORNEY FOR _______ _, Date: (TYPE OR PRINT NAME) (ATTORNEY FOR _______ _, Date: (TYPE OR PRINT NAME) (ATTORNEY FOR _______ _, THE COURT SO ORDERS. Date: JUDICIAL OFFICER

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Table 1 on page 25. Back to List of Tables
None SUM-100
FOR COURT IJSE ONLY
(SOLO PARA USO OE LA CORTEJ
CONFORMED COPY
ORIGINAL FILED
Superior Court ot Catlfomia
County of Los Angeles
JAN 2 0 20\6
nerri R. Carter, Executive Officer/Clerk
By Cristina Grijalva, Deputy
NOTICE! You have been sued. The court may decide against you without your being heard unless you respond within 30 days. Read lhe information
below.
You have 30 CALENDAR DAYS after this summons and legal papers are served on you lo file a written response at \his court and have a copy
served on the plaintiff. A letter or phone call wlll not protect you. Your written response must be In proper legal form lfyou want the court to hear your
case. There may be a court form that you can use for your response. You can find these court forms and more lnformallon at lhe California Courts
Online Self-Help Center (www.courlfnfo.ca.gov/selfhelp), your county law library, or the courthouse nearest you. If you cannot pay the filing fee, ask
the court clerk for a fee waiver ronn. lfyou do not file your response on time, you may lose the case by default, and your wages, money, and property
may be taken without further warning from the court.
There are other legal requirements. You may want to call an attorney right away. If you do nol know an attorney, you may want to call an attorney
referral service. If you cannot afford an attorney, you may be eligible for free legal services from a nonprofit legal services program. You can locate
these nonprofit groups at the California Legal Services Web site (www./awhefpcal/fornla.org), the California Courts Online Self-Help Center
(www.courtfnfo.ca.gov/selfh$lp), or by contacting your local court or county bar association. NOTE: The court has a statutory lien for waived fees and
costs on any settlement or arbitration award of$10,000 or more In a olvll case. The court's lien must be paid before the court will dismiss the case.
1AVJSO! Lohan demandado. SI no responde dentro de 30 d!as, la corte pU$de decld/r en su contra sin escucher su versl6n. Lea /a lnformacl6n a
continua c/6n.
Tiena 30 DIAS DE CALENDARIO daspu6s de que la entreguen esta oftadon y papeles laga/as para presenter uns r11spuests por escrito en este
corte y hacar que se entragua una cop/a al demandante. Una carla o una lfamada ta/ef6nlca no lo protegen. Su respuesta por esctito tlene qua ester
en formato legal co"ecto s/ desea que procesen su caso en la corle. Es pos/b/e que ha ya un fonnulalfo qua usted pueda user para su respuesta.
Puede ancontrsrestosformularios de la corte y mlfs lnformac/6n an el Centro de Ayuda de las Cortes de California (WWw.sucorte.ca.gov), en /a
blbl/oteca de /eyes de su condado o en fa corla que le queda mils cerca. SI no puede pager la cuota de presentaci6n, p/da al secretarlo de la corle
que le di§ un formu/arlo de $Xencf6n de pago d" cuotas. SI no presents su respuesta a tiempo, puede perder "I caso por /ncumplimlento y Is corts le
podr4 quftar su sue/do, dlnero y bienes sin mas advertencla.
Hay otros requisltos Jega/es. Es recomendable qua llama a un abogado lnmed/atamente. Si no conoca a un abogado, puede Ila mar a un servlc/o de
rem/si6n a sbogados. SI no puede pager 11 un ab og ado, es poslb/e que cump/a con /os requ/s/tos para obtener ssrvlcios legales gratultos de un
programs de servlclos /i~ga/es sin fines de /ucro. Pueda encontrar estos gropes sin nnes d11 lucro en ol sitlo web de Callfom/a Legal Services,
(Www.1awhelpcallfomla.org), en el Centro da Ayuda de las Cortes de Califomla, (WWw.sucorte.ca.gov) o pon/endose en contacto con la corte o el
coleglo de abogados locales. AV/SO: Por lay, la corte t/ene derec:ho a rec/a mar las cuotas y los costos exentos por lmponer un gravamen sobre
cua/qu/er recuperacl6n de $10,0DO 6 mas de valor rec/bide med/ante un acu(lrdo o una conces/6n de srb/tra}e en un caso de derecho civil. Tlene que
pagan~/ gravamen da Is corte antes de qua la corta pueda desecharel caso.
None
The name and addrtlss of the court is: CASE NUMaER: (El nombre y dlrecc/6n de la corte es): (Numewdel~): Superior Court ofCalifomia, County of Los Angeles Stanley Mosk Courthouse, 111 North Hill Street Los Angeles, CA 90012 The name, address, and telephone number of plaintiff's attorney, or plaintiff without an attorney, is: James P. Frantz, Esq. (El nombre, fa direcci6n y el numero de te/9fono de/ abogado de/ demandante, ode/ demandante qua no tiene abogado, es): FRANTZ LAW GROUP APLC 555 West Fifth St, 31'1 Floor, Los Angeles, C~.9_0.0J3.~ ;;,i;;:i?. 323.425.8138 DATE: 5\~>.;.',-.;,,.'\.'-'1' Clerk, by , Deputy (Fecha) (Secretario) \(Adjunto) (For proof of service of this summons, use Proof of Service of Summons (form POS..010).) oJ<.:~! \ F. -1 (Para prueba de entrega de esla citati6n use el formu/ario Proof of Service of Summons, (PQ~f4)): · NOTICE TO THE PERSON SERVED: You are served lSE'AL] 1. D as an individual defendant. D 2. as the person sued under the fictitious name of (specify): CJ JAN 2 0 2016 3. on behalf of (specify): D O under: CCP 416.1 O( corporation) CCP 416.60 (minor) 0 O CCP 416.20 (defunct corporation) CCP 416.70 (conservatee) CJ CCP 416.40 (association or partnership) CJ CCP 416.90 (authorized person) other (specify):

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SHORT TITLE: CASE NUMBER: _Toni Adelan, et al. v. Southern California Gas Company, et al. INSTRUCTIONS FOR USE _., This form may be used as an attachment to any summons if space does not permit the listing of all parties on the summons. _., If this attachment is used, insert the following statement in the plaintiff or defendant box on the summons: "Additional Parties Attachment form is attached." List additional parties (Check only one box. Use a separate page for each type of party.): [X] Plaintiff D Defendant D Cross-Complainant D Cross-Defendant LEVI ADELAN; EVELYN ADI; MARGARET ANN AFDAHL; FERNANDO AGUIRRE; MATITZA AGUIRRE; PAOLA AGUIRRE; SARAH AGUIRRE; AFZAL AHMAD; AZEEM AHMAD; ZAHRAH AHMAD; ZAHHDA AHMAD; ISMAEL ALCANTARA; CHARMAINE ALEXANDER; EDWARD ANDERSON; ARNULFO ANDRADE; JAMES ANGOLE; JOE ARELLANO; CLAUDIA ASCENCIO; OBAID ASIF; ASMA ASIF; OSAMA ASIF; OMIAR ASIF; SHAMIM ASIFI; AHTESHAW M ASIFI; SIMON AVUNJIAN; RUZANNA AVUNJIAN; ELIZABETH AVUNJIAN; ARSEN AYDINYAN; LALITA YSOLA; BRIAN BABAY ANS; PARSHOTAM BADRESHIA; SONIA BADRESHIA; AMANI BADRESHIA, a minor by and through his guardian ad litem, SONIA BADRESHIA; SAMAYA BADRESHIa minor by and through her guardian ad litem, SONIA BADRESHIA; HECTOR BAEZ; ALAN BAILEY; WILFREDO BALITON; ANGUSTIA BALITON; BERYL BATTY; BONNIER.BECKER; ARLENE BELFEY; PATRICIA BELLOVIN; LILIAN BENATAR; GEORGE BIJU; MEGAN BOOIMAD; SHOMO BRANDEL; GUENDA BRANDEL; PAMELA BRODSKY; TED MARC BRODSKY; MARION OLIVIA BRONOWICKI; REBECCA BURKHARDT; SALVADOR CARO; HENRY CHANDRA; HANNYARTI CHANDRA; PEIPEI CHANG; HOWARD CHARNEY; ASHWANI CHAWLA; ROGER CHLOWITZ; BONNIE CHLOWITZ; LINDA IN CHO; LEONARD CILENTI; FRED COHEN; HEIDI COHEN; MICHACOHILL; CRAIG COHN; SCOTT COHN; LINDA COHN; MICHAEL COURTNEY, III ; NEYSON CRUZ; JERONA CUETO; SHEILA CUETO; GEORGETTE DABBAH; DAN DABBAH; KAREN E. DALDINE; DAVID DAV IS; ROBERT LAMONT DeBOSE; NICOLE DeBOSE; STELLA DEKEL; YITZCHAK DEKEL and KRISTINA, K. DELEVIE Page 2___ of 2._

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1 James P. Frantz, Esq., SBN 87492 porterranch@frantzlawgroup.com 2 George T. Stiefel Ill, Esq., SBN 297611 William P. Harris III, Esq., SBN 123575 3 . CONFORMED CO v Jodi L. Frantz, Esq., SBN, SBN 131711 Su O~fGINAL Filer! . rpenor Court of c II' 4 M. Regina Bagdasarian, Esq., SBN 296219 County of Lo s An ga e•leOsrn la Kira C. Guisto, Esq., SBN 292544 JAN 2 0 2016 5 FRANTZ LAW GROUP, APLC 6 555 West Fifth St, 31st Floor Sherri R. Carter, Executiv& Officer/Clerk Los Angeles, CA 90013 By Cristina Grijalva, Deputy 7 Tel: (323) 425-8138 Fax: (619) 525-7672 8 9 Thomas V. Girardi, SBN 36603 tgirardi@girardikeese.com 10 Robert William Finnerty, SBN 119775 John Kelley Courtney, SBN 136720 l l Keith David Griffin, SBN 204388 12 GIRARDI I KEESE 1126 Wilshire Boulevard 13 Los Angeles, CA 90017 Tel: (213) 262-6777 14 Fax: (213) 481-1554 15 Attorneys for Plaintiffs 16 SUPERIOR COURT OF THE STATE OF CALIFORNIA 17 IN AND FOR THE COUNTY OF LOS ANGELES STANLEY MOSK COURTHOUSE 18 BC 6 O7 5 4 2 19 TONI ADELAN; LEVI ADELAN; EVELYN CASE NO: ADI; MARGARET ANN AFDAHL; COMPLAINT FOR 20 FERNANDO AGUIRRE; MATITZA 1. NEGLIGENCE Zl AGUIRRE; PAOLA AGUrR.RE; SARAH 2. TRESPASS AGUIRRE; AFZAL AHMAD; AZEEM 3. NUISANCE 22 AHMAD; ZAHRAH AHMAD; ZAHHDA 4. INTENTIONAL INFLICTION OF AHMAD; ISMAEL ALCANTARA; EMOTIONAL DISTRESS 23 CHARMAINE ALEXANDER; EDWARD 5. NEGLIGENT INFLICTION OF 24 ANDERSON; ARNULFO ANDRADE; EMOTIONAL DISTRESS JAMES ANGOLE; JOE ARELLANO; 6. INVERSE CONDEMNATION 25 CLAUDIA ASCENCIO; OBAID ASIF; 7. STRICT LIABILITY ASMA ASIF; OSAMA ASIF; OMIAR ASIF; 8. PUBLIC NUISANCE 26 SHAMIM ASIF!; AHTESHA WM ASIF!; DEMAND FOR JURY TRIAL 27 SIMON AVUNJIAN; RUZANNA AVUNJIAN; ELIZABETH AV UNJIAN; 28 ARSEN AYDINYAN; LALITHA AYSOLA; BRIAN BABA YA NS; PARSHOTAM - I -

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l BADRESHIA; SONIA BADRESHIA;l) 2 AMANI BADRESHIA, a minor by and through his guardian ad litem, SONIA ) 3 BADRESHIA; SAMAYA BADRESHIA, a ) minor by and through her guardian ad litem, ~) 4 SONIA BADRESHIA; HECTOR BAEZ; 5 ALAN BAILEY; WILFREDO BALITON; ) ANGUSTIA BALITON; BERYL BATTY; ) 6 BONNIE R.BECKER; ARLENE BELFEY; ) PATRICIA BELLOVIN; LILIAN ) 7 BENATAR; GEORGE BIJU; MEGAN ) ~ 8 BOOIMAD; SHOMO BRANDEL; GUENDA BRANDEL; PAMELA BRODSKY; TED ) 9 MARC BRODSKY; MARION OLIVIA ) BRONOWICKI; REBECCA BURKHARDT; ) 10 SALVADOR CARO; HENRY CHANDRA; ) CHANG;~ 11 HANNYA RTI CHANDRA; PEIPEI HOWARD CHARNEY; ASHWANI ) 12 CHAWLA; ROGER CHLOW ITZ; ) 13 BONNIE CHLOWITZ; LINDA IN CHO; ~ LEONARD CILENTI; FRED COHEN; ) 14 HEIDI COHEN; MICHAEL COHILL; ) CRAIG COHN; SCOTT COHN; LINDA ) 15 COHN; MICHAEL COURTNEY, III ) 16 NEYSON CRUZ; JERONA CUETO; ) ~ SHEILA CUETO; GEORGETTE DABBAH; 17 DAN DABBAH; KAREN E. DALDINE; ) DAVIDDAVIS;ROBERTLAMONT ) 18 DeBOSE; NICOLE DeBOSE; STELLA ~ 19 DEKEL; YITZCHAK DEKEL; and ) KRISTINA K. DELEVIE, ) 20 ) ) Plaintiffs, 21 ) ) 22 vs. ) ) 23 SOUTHERN CALIFORNIA GAS ) COMPANY; a California Corporation ) 24 SEMPRA ENERGY, a California Corporation;~ 25 and DOES 1through100, inclusive, ) ~ 26 Defendants. ) 27 ~~~~~~~~~~~~~-) 28 -2-

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1 Plaintiffs TONI ADELAN; LEVI ADELAN; EVELYN ADI; MARGARET ANN 2 AFDAHL; FERNANDO AGUIRRE; MATITZA AGUIRRE; PAOLA AGUIRRE; SARAH 3 AGUIRRE; AFZAL AHMAD; AZEEM AHMAD; ZAHRAH AHMAD; ZAHHDA AHMAD; 4 ISMAEL ALCANTARA; CHARMAINE ALEXANDER; EDWARD ANDERSON; ARNULFO 5 ANDRADE; JAMES ANG O LE; JOE ARELLANO; CLAUDIA ASCENCIO; OBAID ASIF; 6 ASMA ASIF; OSAMA ASIF; OMIAR ASIF; SHAMIM ASIFI; AHTESHAW M ASIFI; 7 SIMON AVUNJIAN; RUZANNA A VUNJIAN; ELIZABETH AVUNJIAN; ARSEN 8 A YDINYAN; LALITHA A YSOLA; BRIAN BABAY ANS; PARSHOTAM BADRESHIA; 9 SONIA BADRESHIA; AMANI BADRESHIA, a minor by and through his guardian ad litem, 10 SONIA BADRESHIA; SAMAYA BADRESHIA, a minor by and through her guardian ad litem, 11 SONIA BADRESHIA; HECTOR BAEZ; ALAN BAILEY; WILFREDO BALITON; 12 ANGUSTIA BALITON; BERYL BATTY; BONNIER.BECKER; ARLENE BELFEY; 13 PATRICIA BELLOVIN; LILIAN BENATAR; GEORGE BIJU; MEGAN BOOIMAD; SHOMO 14 BRANDEL; GUENDA BRANDEL; PAMELA BRODSKY; TED MARC BRODSKY; 15 MARION OLIVIA BRONOWICKI; REBECCA BURKHARDT; SALVADOR CARO; 16 HENRY CHANDRA; HANNYARTI CHANDRA; PEIPEI CHANG; HOWARD CHARNEY; 17 ASHWA NI CHAWLA; ROGER CHLO WITZ; BONNIE CHLO WITZ; LINDA IN CHO; 18 LEONARD CILENTI; FRED COHEN; HEIDI COHEN; MICHAEL COHILL; CRAIG COHN; 19 SCOTT COHN; LINDA COHN; MICHAEL COURTNEY, III; NEYSON CRUZ; JERONA 20 CUETO; SHEILA CUETO; GEORGETTE DABBAH; DAN DABBAH; KAREN E. 21 DALDINE; DAVID DAVIS; ROBERT LAMONT DeBOSE; NICOLE DeBOSE; STELLA 22 DEKEL; YITZCHAK DEKEL and KRISTINA K. DELEVIE, bring this Complaint for causes of 23 action against the Defendants, SOUTHERN CALIFORNIA GAS COMP ANY, SEMPRA 24 ENERGY, and DOES 1-100, and each of them, and complain and allege upon information as 25 follows: 26 SUMMARY OF CASE 27 1. Defendants have caused the release of natural gas and other chemicals and 28 chemical compounds (including chemicals known to cause cancer, serious respiratory, genetic, -3 -

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1 cardiac and central nervous system diseases, illnesses and defects) in and around the Porter 2 Ranch, N orthridge, Chatsworth and Granada Hills neighborhoods in the County of Los Angeles, 3 State of California and the surrounding areas. Defendants injected natural gas into underground 4 storage wells in the Aliso Canyon Oil Field which is adjacent to Plaintiffs' homes and places of 5 business. Defendants negligently, carelessly, and in other tortious manners constructed, 6 controlled, inspected, oversaw, maintained, and operated natural gas storage wells and injected 7 and withdrew natural gas into and from its underground wells causing leaks, including a recent 8 catastrophic gas leak. Defendants were aware as early as the late 1970s that the underground 9 storage wells were corroded and otherwise in disrepair. For example, in or about the 1970s, a 10 safety valve was reportedly eliminated from Standard Sesnon 25 API No. 037-00776 11 (hereinafter "Standard Sesnon 25") because the valve was leaking. In November 2014, many of 12 Defendants' wells were 60 to 70 years old and Defendants knew of existing leaks and corrosion 13 in its wells. SEMPRA ENERGY foresaw "major failures and service interruptions from 14 potential hazards that currently remain undetected." On or about October 23, 2015, SEMPRA 15 ENERGY's prediction came true when it was performing operations at Standard Sesnon 25 and 16 caused a massive leak of natural gas and other chemicals. The leak of this one well single-17 handedly increased California's greenhouse gas emissions by approximately twenty-five percent 18 (25%). In response to the Standard Sesnon 25 leak, Defendants were not properly prepared to 19 address, abate, stop and otherwise mitigate the leak. Defendants failed to immediately report 20 the leaking well, misrepresented the levels of benzene being released, did not have proper 21 equipment to handle the leak, and its abatement efforts exacerbated the leak and injuries to 22 Plaintiffs. Defendants' conduct has resulted in natural gas, methane, mercaptans, hydrogen 23 sulfide, sulfur dioxide, benzene, toluene, ethylbenzenes, xylenes, and an oily mist being 24 released into the air, along with noxious odors emanating therefrom. For example, the Standard 25 Sesnon 25 has continued for approximately two and a half months prior to the filing of the 26 instant Complaint with no immediate end in sight. Plaintiffs have suffered and/or continue to 27 suffer from nausea, dizziness, discomfort, headaches and nosebleeds, irritation and dermatitis to 28 their skin and eyes, respiratory and breathing problems, and fatigue, along with other potential -4-

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1 long-term effects. Moreover, Plaintiffs herein, have or will be forced to relocate, permanently 2 and/or temporarily, and their real and personal property has been greatly diminished in value 3 and/or destroyed. Plaintiffs seek general and special damages for, among other things alleged 4 herein: personal injuries; damage to their real and personal properties; diminution in value of 5 their properties; lost wages; loss of the enjoyment of their properties; emotional distress; 6 annoyance and discomfort; relocation expenses; attorneys' fees and costs, appointment of court-7 ordered monitor over Defendants and the Aliso Canyon Oil and Gas Field to ensure that the 8 causes of the leak are fully investigated and repaired as quickly as possible, to ensure action 9 plans are put in place to prevent a reoccurrence of this type of event and to address the 10 consequences of the emission of massive volumes of greenhouse gases into the environment; 11 and punitive damages. 12 GENERAL ALLEGATIONS 13 2. SOUTHERN CALIFORNIA GAS COMP ANY and its parent company, 14 SEMPRA ENERGY, (hereinafter collectively "SEMPRA ENERGY") have controlled, owned 15 and/or operated a natural gas storage facility in the Aliso Canyon Oil and Gas Field. The Aliso 16 Canyon Oil and Gas Field is adjacent to the Porter Ranch neighborhood in the County of Los 17 Angeles, and was once an active drilling spot for oil but has more recently been utilized for 18 storage of natural gas. 19 3. SEMPRA ENGERGY imports natural gas and injects the natural gas into storage 20 reservoirs, underground storage wells, in the Aliso Canyon Oil and Gas Field. 21 4. Many of the storage wells and reservoirs were originally drilled in or about the 22 1950s for the purpose of extracting oil. The natural gas placed in these reservoirs contain 23 dangerous and deleterious chemicals and compounds such as benzene, toluene, ethylbenzenes, 24 xylenes. 25 5. In or about 2008, SEMPRA ENERGY observed that at least one well in the Aliso 26 Canyon Field was in disrepair and its condition was "indicative of production casing leaks from 27 either internal or external corrosion where high pressure gas can migrate to the surface in a 28 matter of hours. In the following years, SEMPRA ENERGY observed corrosion on several of -5-

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1 its 60 to 70-year-old (or older) wells. 2 6. On October 23, 2015 SEMPRA ENERGY claims to have first detected an 3 uncontrolled flow of fluids and gas from a storage well in the Aliso Canyon Oil Field 4 (hereinafter the "Standard Sesnon 25 leak"). It has not been determined when the Standard 5 Sesnon 25 leak began and/or whether other wells leaked in the past, are leaking or about to leak 6 (SEMPRA ENERGY operates approximately 100 storage wells in the Aliso Canyon Oil and 7 Gas Field). 8 7. In the weeks and month prior to reporting the leak, SEMPRA ENERGY injected 9 billions of cubic feet of gas into subject reservoir area. 10 8. Prior to the October 23, 2015 reported Standard Sesnon 25 leak, SEMPRA 11 ENERGY aclmowledged that based on observations at the Aliso Canyon Field between 2008 12 and 2013, "well integrity may have already been severely compromised requiring immediate 13 attention to maintain safety, integrity and reliability." 14 9. In fact, in 1979 a safety valve on Standard Sesnon 25 was reportedly defective 15 and leaking for the then 26-year-old well. SEMPRA ENERGY reportedly eliminated that valve 16 from the system and continued its operations. 17 10. In or about 2014 and thereafter, SEMPRA ENERGY reported that the old wells in 18 the Aliso Canyon were "not able to meet the deliverability levels expected." As a result, 19 SEMPRA ENERGY was likely over-injecting other wells to compensate for the losses. 20 11. By November 2014, SEMPRA ENERGY predicted "major failures and service 21 interruptions from potential hazards that currently remain undetected." 22 12. SEMPRA ENERGY had knowledge of the risks and hazards of its operations but 23 failed to take appropriate action, failed to warn adjacent residents and business owners, and 24 failed to cease its dangerous activities. 25 13. SEMPRA ENERGY failed to timely detect and fully warn Plaintiffs and others of 26 the leak and the hazards associated therewith and/or SEMPRA ENERGY misinformed Plaintiffs 27 and others of the dangers of the leak and the chemicals being released, including the number of 28 times peak levels of benzene were detected in the air. -6-

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1 14. SEMPRA ENERGY has failed in its attempts to abate the leaking of fluids and 2 gas. In fact, SEMPRA ENERGY has exacerbated the leak and release of toxic chemicals and a 3 foul odor into the area. SEMPRA ENERGY SEMPRA ENERGY has caused and continues to 4 allow natural gas to be released into the air, impacting residents, including the named Plaintiffs, 5 and their land, homes and property. 6 15. The Standard Sesnon 25 leak as of October 23, 2015 is and remains enormous, 7 massive amounts of methane and other chemicals have been released into the air, significantly 8 increasing statewide emissions of greenhouse gases. The release of the methane will have 9 deleterious impacts on the environment. 10 16. In addition to the release of methane, the gas leak includes the release of 11 mercaptans, toluene and benzene, among other chemicals, pollutants and contaminants. 12 17. Mercaptans, which are highly flammable, are added to natural gas to give it a 13 distinctive odor so that it is noticeable in the event of a leak. Mercaptans have a repulsive, foul 14 rotten egg smell and can cause eye and skin irritation, respiratory problems (including breathing 15 issues), nausea, dizziness, and headaches. 16 18. Benzene is categorized by the Environmental Protection Agency as a human 17 cancer causing agent and exposure can cause drowsiness, dizziness, and headaches as well as 18 eye, skin and respiratory tract irritation with acute exposure, and blood disorders can be caused 19 by long term exposure. 20 19. Plaintiffs are individuals and/or business entities, residents, domiciliaries and 21 property owners who, at all relevant times, resided in or conducted business in Los Angeles 22 County in or about the neighborhoods of Porter Ranch, Granada Hills, Northridge, and 23 Chatsworth. All of their claims arise from events or occurrences within the County of Los 24 Angeles which resulted in damages, losses and injuries within the County of Los Angeles, State 25 of California, as more particularly alleged herein. 26 20. Defendant SOUTHERN CALIFORNIA GAS COMPA NY is, and at all relevant 27 times herein mentioned was, a California Corporation licensed to do business in the State of 28 California with its principal place of business in the City of Los Angeles, State of California. -7-

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1 21. Defendant SEMPRA ENERGY is, and at all relevant times herein mentioned was, 2 a California Corporation licensed to do business in the State of California. Upon information 3 and belief, Defendant SEMPRA ENERGY regularly transacts business in the County of Los 4 Angeles, State of California and its principal place of business is located in the City of San 5 Diego, State of California. 6 22. The acts alleged herein took place in the County of Los Angeles, State of 7 California and will have a direct effect on Plaintiffs within the County of Los Angeles. 8 23. The true names and/or capacities, whether individual, corporate, associate or 9 otherwise of Defendants DOES 1through100, inclusive, and each of them, are unknown to 10 Plaintiffs, who therefore sue said Defendants by such fictitious names. 11 24. Plaintiffs are informed and believe, and thereupon allege, that each of the 12 defendants fictitiously named herein as a DOE is legally responsible, negligently or in some 13 other actionable manner, for the events and happenings hereinafter referred to, and proximately 14 caused the injuries as hereinafter alleged. Plaintiffs will amend this Complaint to assert the true 15 names and/ or capacities of such fictitiously named defendants when the same have been 16 ascertained. 17 25. Plaintiffs are informed and believe, and thereupon allege, that at all relevant times 18 mentioned herein, Defendants SOUTHERN CALIFORNIA GAS COMP ANY, a California 19 Corporation, and SEMPRA ENERGY, a California Corporation, were acting for and on behalf 20 of each of the other defendants and DOES 1-100 as their agents, servants, representatives, 21 employees, joint venturers and/or co-conspirators; that all acts, conduct, and omissions herein 22 alleged were perpetrated while said Defendants and DOES 1-100 were acting within the 23 authorized course, scope, and purpose of said agency, employment, joint venture and/or 24 conspiracy; that all acts, conduct or omissions were subsequently ratified by the respective 25 principals and the benefits thereof accepted by said principals; and that each Defendant, as 26 aforesaid, while acting as a principal, was negligent (in respect to private defendants herein) or 27 created a dangerous condition (as to public entities) in respect to the ownership, operation, 28 control, management, supervision, and maintenance of the subject property, involved in the -8-

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1 subject incident; said private entity defendants were further negligent in the selection, hiring, 2 training or supervision of each and every other Defendant and DOES 1-100 as its agent, servant, 3 employee, joint venture and/or co-conspirator. 4 FIRST CAUSE OF ACTION 5 NEGLIGENCE 6 (Against SOUTHERN CALIFORNIA GAS COMPA NY, SEMPRA ENERGY and 7 DOES 1-100) 8 26. Plaintiffs re-allege and incorporate herein by reference, as though fully set forth at 9 length, all of the preceding allegations and statements contained herein. 10 27. Defendants SOUTHERN CALIFORNIA GAS COMP ANY, SEMPRA ENERGY 11 and DOES 1-100 own, operate, oversee, inspect, control, and/or maintain the subject gas storage 12 wells and gas storage operations, including reservoirs in or about the Aliso Canyon area by the 13 communities of Porter Ranch, Granada Hills, Northridge, and Chatsworth. A reasonable person 14 in the position of Defendants knew, or should have recognized, the necessity of taking special 15 precautions to protect adjoining residents and business owners against the risk of harm created 16 by the work to be performed. Defendants have special knowledge and expertise far above that 17 of a layperson that they were required to apply to the design, engineering, construction, use, 18 operation, inspection, repair and maintenance of the gas storage wells. 19 28. Defendants, and each of them, knew or should have known that the gas storage 20 wells and activities created a foreseeable risk of harm to Plaintiffs including the risk of leaks 21 and/or other migrations of methane, mercaptan, and other chemicals and pollutants and that 22 such pollutants would contaminate Plaintiffs and their property. 23 29. Defendants have a duty to use reasonable care in the construction, operation, and 24 maintenance of its gas storage activities and wells. 25 30. The failure of the wells and the gas leaks, including the Standard Sesnon 25 leak, 26 would not have occurred but for the negligence or other tortious conduct of SEMPRA 27 ENERGY. The duration of the still ongoing Standard Sesnon 25 leak should have been avoided 28 and would have been avoided had SEMPRA ENERGY acted as a reasonable prudent entity in -9-

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1 maintaining, operating, designing and otherwise utilizing the storage wells and reservoirs and in 2 in enacting procedures in advance and promptly enacting appropriate contingency plans for 3 such an event. 4 31. Defendants breached their duties by negligently and carelessly designing, 5 inspecting, engineering, constructing, using, operating, repairing and/o r maintaining the gas 6 storage wells and activities. Defendants' conduct directly caused the leaks, releases, emissions, 7 and/or migration of noxious odors, hazardous gases, chemicals, pollutants, and contaminants 8 into the air and Plaintiffs' persons and property. 9 32. Defendants breached their duties by, among other things: 10 a. failing to conduct reasonably prompt, proper and frequent inspections of the 11 wells, activities, and equipment; 12 b. failing to design, construct, monitor, and maintain wells in a manner that avoids a 13 breach and leak; 14 c. failing to design, construct, monitor and maintain wells in a manner to withstand 15 foreseeable conditions; 16 d. failing to install, maintain, and possess the equipment necessary to detect, inspect 17 and/or repair a breached well; 18 e. failing to exercise competence, oversight and caution in the injection of natural 19 gas into an underground storage well; 20 f. failing to timely, adequately and properly warn Plaintiffs of the risk of a potential 21 gas leak, the ensuing gas leak/well breach, and the dangers and hazards of the gas 22 leak; and 23 g. negligently and carelessly responding to the gas leak, including failing to timely 24 build relief wells. 25 33. The negligence of Defendants was a substantial factor in causing Plaintiffs' 26 damages. 27 34. Defendants' failure to comply with their duty of care proximately caused damages 28 to Plaintiffs. Defendants' conduct resulted in noxious odors, the release of methane and - 10-

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1 mercaptan, and other pollutants, and an oily mist causing personal injury (including respiratory 2 problems, nosebleeds, headaches and nausea), property damage (including diminution of value), 3 and emotional distress to Plaintiffs. The noxious odors and gases are also causing Plaintiffs to 4 relocate and abandon their homes. 5 35. Plaintiffs were hurt and injured in their health, strength, and activity, all of which 6 said injuries caused and continue to cause Plaintiffs great mental, physical and nervous pain and 7 suffering, all to Plaintiffs' damage in an amount according to proof at trial. Plaintiffs are 8 informed and believes and thereon alleges that said injuries will result in some permanent 9 disability to Plaintiffs. Plaintiffs have suffered and will suffer in the future severe mental and 10 emotional pain and suffering resulting from their injuries. Leave of court will be sought to 11 amend this complaint to set forth the exact amount of said general damages. 12 36. As a further result Defendants' failure to comply with their duty of care, Plaintiffs 13 suffered, and will continue to suffer, the loss of use and quite enjoyment of their property in 14 addition to all of their general damages in an amount to be set forth according to proof at trial. 15 37. As a further, direct and proximate result of said carelessness and negligence of 16 defendants, and each of them, Plaintiffs will employ physicians and surgeons to examine, treat 17 and care for them and will incur medical expenses. 18 38. As a further direct and proximate result of said carelessness and negligence of the 19 defendants, and each of them, Plaintiffs will be prevented from attending to their usual 20 occupations, sustaining a loss of earnings thereby. 21 39. In addition, Plaintiffs should be awarded attorney's fees under Code of Civil 22 Procedure section 1021.5 because the successful prosecution of this action will confer a 23 significant benefit both pecuniary and non-pecuniary on the general public and a large class of 24 persons by abating environmental harm and preventing future harm to residents of Porter 25 Ranch. Further, the necessity and financial burden of private enforcement makes such an award 26 appropriate as the litigation is not economically feasible or viable for Plaintiffs to pursue on 27 their own at their own expense, and such fees should not in the interest of justice be paid out of 28 the recovery, if any. -11-

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1 40. At all relevant times herein Defendants and DOES 1-100 acted with malice, 2 oppression and fraud. California Civil Code section 3294 defines "malice" as despicable 3 conduct which is carried on by the defendant with a willful and conscious disregard of the rights 4 and safety of others; "oppression" as despicable conduct that subjects a person to cruel and 5 unjust hardship in conscious disregard of the persons' rights; and "fraud" as an intentional 6 misrepresentation, deceit, or concealment of a material fact known to the defendant with the 7 intention on the part of the defendant of thereby depriving a person of their property or legal 8 rights or otherwise causing injury, and as such are therefore liable to Plaintiffs for punitive 9 damages pursuant to Cal. Civ. Code section 3294(a). All allegations of malice, oppression or 10 fraud are directed at Defendants SOUTHERN CALIFORNIA GAS COMP ANY, SEMPRA 11 ENERGY and DOES 1-100 and their employees, officers, directors and managing agents sued 12 herein as DOES. 13 41. Defendants' actions alleged herein were malicious, oppressive and fraudulent 14 actions that caused the injuries alleged herein to Plaintiffs, were despicable in nature, were 15 done wilfully and consciously, or were caused by intentional misrepresentation, deceit, or 16 concealment of a material fact known to the Defendants and DO ES 1-100 with the intention on 17 the part of the Defendants and DOES 1-100 of thereby consciously depriving a person of their 18 property or legal rights or otherwise causing injury. 19 42. Defendants and DOES 1-100, respectively, are liable for punitive damages 20 pursuant to subdivision (a) of California Civil Code, section 3294, based upon their wrongful 21 conduct, including the conduct of their officers, directors and managing agents, and the 22 wrongful conduct of their respective employees whose names are unknown and are sued herein 23 as DOES 20-30. Defendants and DOES 1-100, had advance knowledge of the unfitness of said 24 employees (DOES 20-30) and employed such employees with conscious disregard of the rights 25 and safety of others or ratified their wrongful conduct with respect to maintaining dangerous 26 conditions of the premises as set forth in the above allegations that are incorporated herein by 27 this reference. Said wrongful conduct was done with conscious disregard of the rights and 28 safety of Plaintiffs. Defendants and DOES 1-100 authorized or ratified the wrongful conduct of - 12-

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1 their employees (DOES 20-30) as set forth herein by and through their officers, directors and 2 managing agents who are personally guilty of malice, oppression and/or fraud, all of whom are 3 sued herein as DOES. 4 43. Defendants and DOES 1-100, are corporate employers pursuant to California 5 Civil Code §3294(b) and had advance knowledge of the unfitness of their employees whose 6 identities are unknown and are sued as DOES 20-30. Defendants and DOES 1-100 employed 7 said DOES 20-30 employees in conscious disregard of the rights and safety of others and 8 authorized or ratified the wrongful conduct as set forth herein for which damages are claimed or 9 are personally guilty of malice and oppression. 10 44. Defendants and DOES 1-100 had actual knowledge in advance of the subject 11 incident and allowed said conduct of employees DOES 20-30 and said dangerous conditions as 12 herein alleged to exist for a substantial time in conscious disregard of the rights and safety of 13 Plaintiffs, and through Defendants' officers, directors and/or managing agents authorized 14 conduct of employees to continue and the afore-described conditions to exist. All said acts of 15 oppression, fraud and malice were undertaken by or on the part of Defendants and DOES 1-100 16 by and through the officers, directors or managing agents of Defendants and DO ES 1-100 and 17 DOE employees. 18 45. Accordingly, Defendants, DOES 1-100 and DOES 20-30 employees, respectively, 19 are liable for punitive damages pursuant to subdivision 3294(a) of the California Civil Code, 20 and Plaintiffs pray for judgment for punitive and exemplary damages against Defendants 21 SOUTHERN CALIFORNIA GAS COMPANY, SEMPRA ENERGY and DOES 1-100. 22 SECOND CAUSE OF ACTION 23 TRESPASS 24 (Against SOUTHERN CALIFORNIA GAS COMP ANY, SEMPRA ENERGY and DOES 1-25 100) 26 46. Plaintiffs re-allege and incorporate herein by reference, as though fully set forth at 27 length, all of the preceding allegations and statements contained herein. 28 47. At all times relevant herein, Plaintiffs were the owners, tenants, and/or lawful -13-

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1 occupiers of property impacted by the gas leak(s) alleged herein. 2 48. Defendants SOUTHERN CALIFORNIA GAS COMPANY, SEMPRA ENERGY 3 and DOES 1-100 intentionally, recklessly, negligently or some other actionable manner allowed 4 the gas leak(s) alleged herein to occur and/or continue, causing damage to Plaintiffs. 5 49. Plaintiffs did not grant permission for Defendants to cause the gas leak or noxious 6 odors to enter their properties. 7 50. As a direct, proximate and substantial cause of the trespass, Plaintiffs have 8 suffered and will continue to suffer damages, including but not limited to damage to property, 9 inability to live in and enjoy their homes and/or property, discomfort, annoyance, and emotional 10 distress in an amount to be proven at trial. 11 51. As a further direct and proximate cause of the conduct of Defendants, Plaintiffs 12 have hired and retained counsel to recover compensation for loss and damage and are entitled to 13 recover all attorney's fees, expert fees, consultant fees and litigation costs and expenses as 14 allowed under California Code of Civil Procedure section 1021.9. In addition, Plaintiffs should 15 be awarded attorney's fees under Code of Civil Procedure section 1021.5 because the successful 16 prosecution of this action will confer a significant benefit both pecuniary and non-pecuniary on 17 the general public and a large class of persons by abating environmental harm and preventing 18 future harm to residents of Porter Ranch. Further, the necessity and financial burden of private 19 enforcement makes such an award appropriate as the litigation is not economically feasible or 20 viable for Plaintiffs to pursue on their own at their own expense, and such fees should not in the 21 interest of justice be paid out of the recovery, if any. 22 52. At all relevant times herein Defendants and DOES 1-100 acted with malice, 23 oppression and fraud. California Civil Code section 3294 defines "malice" as despicable 24 conduct which is carried on by the defendant with a willful and conscious disregard of the rights 25 and safety of others; "oppression" as despicable conduct that subjects a person to cruel and 26 unjust hardship in conscious disregard of the persons' rights; and "fraud" as an intentional 27 misrepresentation, deceit, or concealment of a material fact known to the defendant with the 28 intention on the part of the defendant of thereby depriving a person of their property or legal - 14-

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1 rights or otherwise causing injury, and as such are therefore liable to Plaintiffs for punitive 2 damages pursuant to Cal. Civ. Code section 3294(a). All allegations of malice, oppression or 3 fraud are directed at Defendants SOUTHERN CALIFORNIA GAS COMP ANY, SEMPRA 4 ENERGY and DOES 1-100 and their employees, officers, directors and managing agents sued 5 herein as DOES. 6 53. Defendants' actions alleged herein were malicious, oppressive and fraudulent 7 actions that caused the injuries alleged herein to Plaintiffs, were despicable in nature, were 8 done wilfully and consciously, or were caused by intentional misrepresentation, deceit, or 9 concealment of a material fact known to the Defendants and DOES 1-100 with the 10 intention on the part of the Defendants and DOES 1-100 of thereby consciously depriving a 11 person of their property or legal rights or otherwise causing injury. 12 54. Defendants and DOES 1-100, respectively, are liable for punitive damages 13 pursuant to subdivision (a) of California Civil Code, section 3294, based upon their wrongful 14 conduct, including the conduct of their officers, directors and managing agents, and the 15 wrongful conduct of their respective employees whose names are unknown and are sued herein 16 as DOES 20-30. Defendants and DOES 1-100, had advance knowledge of the unfitness of said 17 employees (DOES 20-30) and employed such employees with conscious disregard of the rights 18 and safety of others or ratified their wrongful conduct with respect to maintaining dangerous 19 conditions of the premises as set forth in the above allegations that are incorporated herein by 20 this reference. Said wrongful conduct was done with conscious disregard of the rights and 21 safety of Plaintiffs. Defendants and DOES 1-100 authorized or ratified the wrongful conduct of 22 their employees (DOES 20-30) as set forth herein by and through their officers, directors and 23 managing agents who are personally guilty of malice, oppression and/or fraud, all of whom are 24 sued herein as DOES. 25 55. Defendants and DOES 1-100, are corporate employers pursuant to California 26 Civil Code §3294(b) and had advance knowledge of the unfitness of their employees whose 27 identities are unknown and are sued as DOES 20-30. Defendants and DOES 1-100 employed 28 said DOES 20-30 employees in conscious disregard of the rights and safety of others and - 15 -

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1 authorized or ratified the wrongful conduct as set forth herein for which damages are claimed or 2 are personally guilty of malice and oppression. 3 56. Defendants and DOES 1-100 had actual knowledge in advance of the subject 4 incident and allowed said conduct of employees DOES 20-30 and said dangerous conditions as 5 herein alleged to exist for a substantial time in conscious disregard of the rights and safety of 6 Plaintiffs, and through Defendants' officers, directors and/or managing agents authorized 7 conduct of employees to continue and the afore-described conditions to exist. All said acts of 8 oppression, fraud and malice were undertaken by or on the part of Defendants and DOES 1-100 9 by and through the officers, directors or managing agents of Defendants and DOES 1-100 and 10 DOE employees. 11 57. Accordingly, Defendants, DOES 1-100 and DOES 20-30 employees, respectively, 12 are liable for punitive damages pursuant to subdivision 3294(a) of the California Civil Code, 13 and Plaintiffs pray for judgment for punitive and exemplary damages against Defendants 14 SOUTHERN CALIFORNIA GAS COMPANY, SEMPRA ENERGY and DOES 1-100. 15 THIRD CAUSE OF ACTION 16 PRIVATE NUISANCE 17 (Against SOUTHERN CALIFORNIA GAS COMPA NY, SEMPRA ENERGY and DOES 1-18 100) 19 58. Plaintiffs re-allege and incorporate herein by reference, as though fully set forth at 20 length, all of the preceding allegations and statements contained herein. 21 59. Defendants' actions, conduct, omissions, negligence, trespass and failure to act 22 resulted in an air and water pollution hazard and foreseeable obstruction to the free use of 23 Plaintiffs' property, invaded the right to use the property, and interfered with the enjoyment of 24 Plaintiffs' property, causing the Plaintiffs unreasonable harm and substantial actual damages 25 constituting a nuisance, pursuant to California Civil Code section 3479. 26 60. As a direct, proximate and substantial cause of the trespass, Plaintiffs have 27 suffered and will continue to suffer damages, including but not limited to damage to property, 28 inability to live in and enjoy their homes and/or property, discomfort, annoyance, and emotional - 16-

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1 distress in an amount to be proven at trial. 2 61. Plaintiffs suffer from the ongoing contamination of the air surrounding their 3 properties. This harm includes, but is not limited to, polluted land and air in and around 4 Plaintiffs' properties and adverse health effects due to exposure. 5 62. Plaintiffs did not consent to Defendants' conduct. 6 63. An ordinary person of reasonable sensibility would reasonably be annoyed and/or 7 disturbed by the conditions created by Defendants. 8 64. The seriousness of Defendants' conduct referenced above outweighs the public 9 benefits of the Defendants' conduct. 10 65. Plaintiffs have no speedy, plain, or adequate remedy of law for the injuries 11 presently being suffered or for the aggravation of such injuries. Unless the nuisance created by 12 Defendants is restrained by a preliminary and permanent injunction, Plaintiffs will suffer great 13 and irreparable injury in that dangerous levels of noxious odors, methane, mercaptan, and other 14 chemicals will continue to pollute Plaintiffs' properties, air and water table and continue to 15 damage the right of Plaintiffs and their families to live in their homes without harmful exposure. 16 66. Defendants' actions resulted in the pollution of air and deprived residents of 17 Porter Ranch of their ability to live in their homes free of health problems. 18 67. As a further result of this wrongful conduct, Plaintiffs suffered, and will continue 19 to suffer, the loss of the quiet use and enjoyment of their property in addition to all of their 20 general damages in an amount to be set forth according to proof at trial. 21 68. In addition, Plaintiffs should be awarded attorney's fees under Code of Civil 22 Procedure section 1021.5 because the successful prosecution of this action will confer a 23 significant benefit both pecuniary and non-pecuniary on the general public and a large class of 24 persons by abating environmental harm and preventing future harm to residents of Porter 25 Ranch. 26 69. Further, the necessity and financial burden of private enforcement makes such an 27 award appropriate as the litigation is not economically feasible or viable for Plaintiffs to pursue 28 on their own at their own expense, and such fees should not in the interest of justice be paid out - 17 -

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1 of the recovery, if any. 2 70. At all relevant times herein Defendants and DOES 1-100 acted with malice, 3 oppression and fraud. California Civil Code section 3294 defines "malice" as despicable 4 conduct which is carried on by the defendant with a willful and conscious disregard of the rights 5 and safety of others; "oppression" as despicable conduct that subjects a person to cruel and 6 unjust hardship in conscious disregard of the persons' rights; and "fraud" as an intentional 7 misrepresentation, deceit, or concealment of a material fact known to the defendant-with the 8 intention on the part of the defendant of thereby depriving a person of their property or legal 9 rights or otherwise causing injury, and as such are therefore liable to Plaintiffs for punitive 10 damages pursuant to Cal. Civ. Code section 3294(a). All allegations of malice, oppression or 11 fraud are directed at Defendants SOUTHERN CALIFORNIA GAS COMPA NY, SEMPRA 12 ENERGY and DOES 1-100 and their employees, officers, directors and managing agents sued 13 herein as DOES. 14 71. Defendants' actions alleged herein were malicious, oppressive and fraudulent 15 actions that caused the injuries alleged herein to Plaintiffs, were despicable in nature, were 16 done wilfully and consciously, or were caused by intentional misrepresentation, 17 deceit, or concealment of a material fact known to the Defendants and DOES 1-100 with the 18 intention on the part of the Defendants and DOES 1-100 of thereby consciously depriving a 19 person of their property or legal rights or otherwise causing injury. 20 72. Defendants and DOES 1-100, respectively, are liable for punitive damages 21 pursuant to subdivision (a) of California Civil Code, section 3294, based upon their wrongful 22 conduct, including the conduct of their officers, directors and managing agents, and the 23 wrongful conduct of their respective employees whose names are unknown and are sued herein 24 as DOES 20-30. Defendants and DOES 1-100, had advance knowledge of the unfitness of said 25 employees (DOES 20-30) and employed such employees with conscious disregard of the rights 26 and safety of others or ratified their wrongful conduct with respect to maintaining dangerous 27 conditions of the premises as set forth in the above allegations that are incorporated herein by 28 this reference. Said wrongful conduct was done with conscious disregard of the rights and -18-

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1 safety of Plaintiffs. Defendants and DOES 1-100 authorized or ratified the wrongful conduct of 2 their employees (DOES 20-30) as set forth herein by and through their officers, directors and 3 managing agents who are personally guilty of malice, oppression and/or fraud, all of whom are 4 sued herein as DOES. 5 73. Defendants and DOES 1-100, are corporate employers pursuant to California 6 Civil Code §3294(b) and had advance knowledge of the unfitness of their employees whose 7 identities are unknown and are sued as DOES 20-30. Defendants and DOES 1-100 employed 8 said DOES 20-30 employees in conscious disregard of the rights and safety of others and 9 authorized or ratified the wrongful conduct as set forth herein for which damages are claimed or 10 are personally guilty of malice and oppression. 11 74. Defendants and DOES 1-100 had actual knowledge in advance of the subject 12 incident and allowed said conduct of employees DOES 20-30 and said dangerous conditions as 13 herein alleged to exist for a substantial time in conscious disregard of the rights and safety of 14 Plaintiffs, and through Defendants' officers, directors and/or managing agents authorized 15 conduct of employees to continue and the afore-described conditions to exist. All said acts of 16 oppression, fraud and malice were undertaken by or on the part of Defendants and DOES 1-100 17 by and through the officers, directors or managing agents of Defendants and DOES 1-100 and 18 DOE employees. 19 75. Accordingly, Defendants, DOES 1-100 and DOES 20-30 employees, respectively, 20 are liable for punitive damages pursuant to subdivision 3294(a) of the California Civil Code, 21 and Plaintiffs pray for judgment for punitive and exemplary damages against Defendants 22 SOUTHERN CALIFORNIA GAS COMPA NY, SEMPRA ENERGY and DOES 1-100. 23 FOURTH CAUSE OF ACTION 24 INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS 25 (Against SOUTHERN CALIFORNIA GAS COMP ANY, SEMPRA ENERGY 26 and DOES 1-100) 27 76. Plaintiffs re-allege and incorporate herein by reference, as though fully set forth at 28 length, all of the preceding allegations and statements contained herein. - 19-

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1 77. Defendant SOUTHERN CALIFORNIA GAS COMP ANY, SEMPRA ENERGY 2 and DOES 1-lOO's conduct as alleged herein was outrageous, being so extreme that it goes 3 beyond all possible bounds of decency intolerable in a civilized community, by, and not limited 4 to, ignoring a high risk of serious injury to the habitants of Porter Ranch, Granada Hills, 5 Northridge, Chatsworth and neighboring communities and their property from a underground 6 gas well breach. 7 78. Defendant SOUTHERN CALIFORNIA GAS COMPANY, SEMPRA ENERGY 8 and DOES 1-100 acted with reckless disregard of the probability that Plaintiffs would suffer 9 emotional distress. Defendants knew that emotional distress would probably result from their 10 conduct or gave little or no thought to the probable effects of their conduct. 11 79. Defendants acted with reckless disregard for the high probability that Plaintiffs 12 would suffer emotional distress, knowing that Plaintiffs would likely be present when their 13 outrageous conduct occurred. 14 80. Plaintiffs suffered severe emotional distress as alleged herein and Defendants' 15 conduct was the substantial factor in causing the severe emotional distress. 16 81. As a direct and proximate result of the outrageous conduct of Defendants and 17 DOES 1-100, and each of them, Plaintiffs were hurt and injured in their health, strength, and 18 activity, sustaining serious emotional distress, all of which said injuries caused and continue to 19 cause Plaintiffs great mental, physical and nervous pain and suffering. Plaintiffs are informed 20 and believes and thereon alleges that said serious emotional distress will result in some 21 permanent disability to Plaintiffs. Plaintiffs have suffered and will suffer in the future severe 22 mental and emotional pain and suffering resulting from their injuries. 23 82. At all relevant times herein Defendants and DOES 1-100 acted with malice, 24 oppression and fraud. California Civil Code section 3294 defines "malice" as despicable 25 conduct which is carried on by the defendant with a willful and conscious disregard of the rights 26 and safety of others; "oppression" as despicable conduct that subjects a person to cruel and 27 unjust hardship in conscious disregard of the persons' rights; and "fraud" as an intentional 28 misrepresentation, deceit, or concealment of a material fact known to the defendant with the -20-

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1 intention on the part of the defendant of thereby depriving a person of their property or legal 2 rights or otherwise causing injury, and as such are therefore liable to Plaintiffs for punitive 3 damages pursuant to Cal. Civ. Code section 3294(a). All allegations of malice, oppression or 4 fraud are directed at Defendants SOUTHERN CALIFORNIA GAS COMP ANY, SEMPRA 5 ENERGY and DOES 1-100 and their employees, officers, directors and managing agents sued 6 herein as DOES. 7 83. Defendants' actions alleged herein were malicious, oppressive and fraudulent 8 actions that caused the injuries alleged herein to Plaintiffs , were despicable in nature, were 9 done wilfully and consciously, or were caused by intentional misrepresentation, 10 deceit, or concealment of a material fact known to the Defendants and DOES 1-100 with the 11 intention on the part of the Defendants and DOES 1-100 of thereby consciously depriving a 12 person of their property or legal rights or otherwise causing injury. 13 84. Defendants and DOES 1-100, respectively, are liable for punitive damages 14 pursuant to subdivision (a) of California Civil Code, section 3294, based upon their wrongful 15 conduct, including the conduct of their officers, directors and managing agents, and the 16 wrongful conduct of their respective employees whose names are unknown and are sued herein 17 as DOES 20-30. Defendants and DOES 1-100, had advance knowledge of the unfitness of said 18 employees (DOES 20-30) and employed such employees with conscious disregard of the rights 19 and safety of others or ratified their 'wrongful conduct with respect to maintaining dangerous 20 conditions of the premises as set forth in the above allegations that are incorporated herein by 21 this reference. Said wrongful conduct was done with conscious disregard of the rights and 22 safety of Plaintiffs. Defendants and DOES 1-100 authorized or ratified the wrongful conduct of 23 their employees (DOES 20-30) as set forth herein by and through their officers, directors and 24 managing agents who are personally guilty of malice, oppression and/or fraud, all of whom are 25 sued herein as DOES. 26 85. Defendants and DOES 1-100, are corporate employers pursuant to California 27 Civil Code §3294(b) and had advance knowledge of the unfitness of their employees whose 28 identities are unknown and are sued as DOES 20-30. Defendants and DOES 1-100 employed -21-

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1 said DOES 20-30 employees in conscious disregard of the rights and safety of others and 2 authorized or ratified the wrongful conduct as set forth herein for which damages are claimed or 3 are personally guilty of malice and oppression. 4 86. Defendants and DOES 1-100 had actual knowledge in advance of the subject 5 incident and allowed said conduct of employees DOES 20-30 and said dangerous conditions as 6 herein alleged to exist for a substantial time in conscious disregard of the rights and safety of 7 Plaintiffs, and through Defendants' officers, directors and/or managing agents authorized 8 conduct of employees to continue and the afore-described conditions to exist. All said acts of 9 oppression, fraud and malice were undertaken by or on the part of Defendants and DOES 1-100 10 by and through the officers, directors or managing agents of Defendants and DOES 1-100 and 11 DOE employees. 12 87. Accordingly, Defendants, DOES 1-100 and DOES 20-30 employees, respectively, 13 are liable for punitive damages pursuant to subdivision 3294(a) of the California Civil Code, 14 and Plaintiffs pray for judgment for punitive and exemplary damages against Defendants 15 SOUTHERN CALIFORNIA GAS COMPANY, SEMPRA ENERGY and DOES 1-100. 16 FIFTH CAUSE OF ACTION 17 NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS 18 (Against SOUTHERN CALIFORNIA GAS COMP ANY, SEMPRA ENERGY and DOES 1-19 100) 20 88. Plaintiffs re-allege and incorporate herein by reference, as though fully set forth at 21 length, all of the preceding allegations and statements contained herein. 22 89. Defendants and DOES 1-100 were negligent as set forth above. 23 90. Plaintiffs were direct victims of the negligence of Defendants and suffered direct 24 injury and damages as a result of the incident the subject of this suit. 25 91. As a substantial factor of the negligence of Defendants and DOES 1-100 as fully 26 set forth herein, Plaintiffs suffered serious emotional distress, including but not limited to 27 suffering, anguish, fright, horror, nervousness, grief, anxiety, worry, shock, humiliation, and 28 shame that an ordinary reasonable person would be unable to cope with. -22-

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1 92. As a direct and proximate result of the said carelessness and negligence of the 2 Defendants and DOES 1-100, and each of them, Plaintiffs were hurt and injured in their health, 3 strength, and activity, sustaining serious emotional distress, all of which said injuries caused and 4 continue to cause Plaintiffs great mental, physical and nervous pain and suffering, all to 5 Plaintiffs' damages. Plaintiffs are informed and believe and thereon allege that said serious 6 emotional distress will result in some permanent disability to Plaintiffs. 7 93. Plaintiffs have suffered and will suffer in the future severe mental and emotional 8 pain and suffering resulting from their injuries. 9 SIXTH CAUSE OF ACTION 10 INVERSE CONDEMNATION 11 (Against SOUTHERN CALIFORNIA GAS COMPA NY, SEMPRA ENERGY, and 12 DOES 1-100) 13 94. Plaintiffs re-allege and incorporate herein by reference, as though fully set forth at 14 length, all of the preceding allegations and statements contained herein. 15 95. SOUTHERN CALIFORNIA GAS COMPANY, SEMPRA ENERGY and DOES 16 1-100, as alleged herein, acted and failed to act in attempting to work on a public property and 17 provide a public benefit. 18 96. Defendants' activities and wells present an inherent danger and risk of air and 19 water pollution to private property and the communities. In acting in the furtherance of the 20 public objective of supplying natural gas, Defendants took and did take on a known calculated 21 risk that private property would be damaged and destroyed. 22 97. The inherent risk became a reality on or about October 23, 2015 or earlier which 23 directly and legally resulted in the taking of property of Plaintiffs. 24 98. Plaintiffs in this action must now move from their homes - temporarily and 25 perhaps permanently. The acts and/or omissions of Defendants, collectively and each of them 26 individually, as alleged herein, have resulted in water and air pollution onto Plaintiffs' properties 27 as alleged herein and to be further determined. In addition, the continued acts and/or omissions 28 of Defendants, collectively and each of them individually, as alleged herein, have resulted in -23-

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1 ongoing pollution onto Plaintiffs' properties. 2 99. The conduct described herein was a substantial factor in causing damage to a 3 property interest protected by the U.S. Constitution, Fifth Amendment and Article I Section 19 4 of the California Constitution which entitles Plaintiffs to just compensation according to proof 5 at trial for all damages incurred. 6 100. That further, under and pursuant to California Code of Civil Procedure section 7 1036, Plaintiffs are entitled to recover all litigation costs and expense with regard to the 8 compensation for damage of properties, including attorneys' fees, expert fees, consultant fees 9 and litigation costs. 10 SEVENTH CAUSE OF ACTION 11 STRICT LIABILITY 12 (Against SOUTHERN CALIFORNIA GAS COMP ANY, SEMPRA ENERGY and DOES 1-13 100) 14 101. Plaintiffs re-allege and incorporate herein by reference, as though fully set forth at 15 length, all of the preceding allegations and statements contained herein. 16 102. Defendants' engaged in an ultrahazardous activity in the storage of large 17 quantities of natural gas, including methane and other chemicals in underground wells under 18 high pressure. 19 103. The gas leak alleged herein and ensuing injuries to Plaintiffs was the kind of harm 20 that would be anticipated as a result of the risk created by the storage of large quantities of 21 natural gas, including methane and other chemicals in underground wells under high pressure. 22 104. Defendants' activities were the legal and proximate cause of the injuries and 23 damages suffered by Plaintiffs. Plaintiffs were hurt and injured in their health, strength, and 24 activity, all of which said injuries caused and continue to cause plaintiff great mental, physical 25 and nervous pain and suffering, all to Plaintiffs' damage in an amount according to proof at 26 trial. Plaintiffs are informed and believes and thereon alleges that said injuries will result in 27 some permanent disability to the plaintiff, the exact amount of which is unknown. Plaintiffs 28 have suffered and will suffer in the future severe mental and emotional pain and suffering -24

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1 resulting from their injuries. Leave of court will be sought to amend this complaint to set forth 2 the exact amount of said general damages at such time as they are ascertained. The damages 3 caused by the breach included polluted land and air in and around Plaintiffs' properties and 4 adverse health effects suffered by Plaintiffs due to exposure. Due to Defendants' activities, 5 actions, and/or inactions, Plaintiffs experienced serious health effects including, but not limited 6 to: dizziness, nausea, drowsiness, headaches, and nose bleeding. 7 105. As a further result of this wrongful conduct, Plaintiffs suffered, and will continue 8 to suffer, the loss of the quiet use and enjoyment of their property and diminution in value of 9 their property, in addition to all of their general damages in an amount to be set forth according 10 to proof at trial. 11 106. As a further, direct and proximate result of said carelessness and negligence of 12 defendants, and each of them, Plaintiffs will employ physicians and surgeons to examine, treat 13 and care for them and will incur medical expenses. 14 107. As a further direct and proximate result of said carelessness and negligence of the 15 defendants, and each of them, Plaintiffs will be prevented from attending to their usual 16 occupations, sustaining a loss of earnings thereby. 17 108. In addition, Plaintiffs should be awarded attorney's fees under Code of Civil 18 Procedure section 1021. 5 because the successful prosecution of this action will confer a 19 significant benefit both pecuniary and non-pecuniary on the general public and a large class of 20 persons by abating environmental harm and preventing future harm to residents of Porter 21 Ranch. Further, the necessity and financial burden of private enforcement makes such an award 22 appropriate as the litigation is not economically feasible or viable for Plaintiffs to pursue on 23 their own at their own expense, and such fees should not in the interest of justice be paid out of 24 the recovery, if any. 25 109. At all relevant times herein Defendants and DOES 1-100 acted with malice, 26 oppression and fraud. California Civil Code section 3294 defines "malice" as despicable 27 conduct which is carried on by the defendant with a willful and conscious disregard of the rights 28 and safety of others; "oppression" as despicable conduct that subjects a person to cruel and unjust hardship in conscious disregard of the persons' rights; and "fraud" as an intentional -25-

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1 misrepresentation, deceit, or concealment of a material fact known to the defendant with the 2 intention on the part of the defendant of thereby depriving a person of their property or legal 3 rights or otherwise causing injury, and as such are therefore liable to Plaintiffs for punitive 4 damages pursuant to Cal. Civ. Code section 3294(a). All allegations of malice, oppression or 5 fraud are directed at Defendants SOUTHERN CALIFORNIA GAS COMP ANY, SEMPRA 6 ENERGY and DOES 1-100 and their employees, officers, directors and managing agents sued 7 herein as DOES. 8 110. Defendants' actions alleged herein were malicious, oppressive and fraudulent 9 actions that caused the injuries alleged herein to Plaintiffs, were despicable in nature, were 10 done wilfully and consciously, or were caused by intentional misrepresentation, deceit, or 11 concealment of a material fact known to the Defendants and DOES 1-100 with the intention on 12 the part of the Defendants and DOES 1-100 of thereby consciously depriving a person of their 13 property or legal rights or otherwise causing injury. 14 111. Defendants and DOES 1-100, respectively, are liable for punitive damages 15 pursuant to subdivision (a) of California Civil Code, section 3294, based upon their wrongful 16 conduct, including the conduct of their officers, directors and managing agents, and the 17 wrongful conduct of their respective employees whose names are unknown and are sued herein 18 as DOES 20-30. Defendants and DOES 1-100, had advance knowledge of the unfitness of said 19 employees (DOES 20-30) and employed such employees with conscious disregard of the rights 20 and safety of others or ratified their wrongful conduct with respect to maintaining dangerous 21 conditions of the premises as set forth in the above allegations that are incorporated herein by 22 this reference. Said wrongful conduct was done with conscious disregard of the rights and 23 safety of Plaintiffs. Defendants and DOES 1-100 authorized or ratified the wrongful conduct of 24 their employees (DOES 20-30) as set forth herein by and through their officers, directors and 25 managing agents who are personally guilty of malice, oppression and/or fraud, all of whom are 26 sued herein as DOES. 27 112. Defendants and DOES 1-100, are corporate employers pursuant to California 28 Civil Code §3294(b) and had advance knowledge of the unfitness of their employees whose -26-

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1 identities are unknown and are sued as DOES 20-30. Defendants and DOES 1-100 employed 2 said DOES 20-30 employees in conscious disregard of the rights and safety of others and 3 authorized or ratified the wrongful conduct as set forth herein for which damages are claimed or 4 are personally guilty of malice and oppression. 5 113. Defendants and DOES 1-100 had actual knowledge in advance of the subject 6 incident and allowed said conduct of employees DOES 20-30 and said dangerous conditions as 7 herein alleged to exist for a substantial time in conscious disregard of the rights and safety of 8 Plaintiffs, and through Defendants' officers, directors and/or managing agents authorized 9 conduct of employees to continue and the afore-described conditions to exist. All said acts of 10 oppression, fraud and malice were undertaken by or on the part of Defendants and DOES 1-100 11 by and through the officers, directors or managing agents of Defendants and DOES 1-100 and 12 DOE employees. 13 114. Accordingly, Defendants, DOES 1-100 and DOES 20-30 employees, respectively, 14 are liable for punitive damages pursuant to subdivision 3294(a) of the California Civil Code, 15 and Plaintiffs pray for judgment for punitive and exemplary damages against Defendants 16 SOUTHERN CALIFORNIA GAS COMP ANY, SEMPRA ENERGY and DOES 1-100. 17 EIGHTH CAUSE OF ACTION 18 PUBLIC NUISANCE 19 (Against SOUTHERN CALIFORNIA GAS COMP ANY, SEMPRA ENERGY and DOES 1-20 100) 21 115. Plaintiffs re-allege and incorporate herein by reference, as though fully set forth at 22 length, all of the preceding allegations and statements contained herein. 23 116. Defendants' actions, conduct, omissions, negligence, trespass and failure to act 24 resulted in an air and water pollution hazard and foreseeable obstruction to the free use of 25 Plaintiffs'' property, invaded the right to use the property, and interfered with the enjoyment of 26 Plaintiffs' property, causing the Plaintiffs unreasonable harm and substantial actual damages 27 constitution a nuisance, pursuant to California Civil Code section 3479. Defendants created a 28 continuing condition that is harmful to Plaintiffs' health and free use of their homes so as to -27-

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1 seriously interfere with comfortable enjoyment of their life and property. 2 117. As a direct, proximate and substantial cause of the trespass, Plaintiffs have 3 suffered and will continue to suffer damages, including but not limited to damage to property, 4 inability to live in and enjoy their homes and/or property, discomfort, annoyance, and emotional 5 distress in an amount to be proven at trial. 6 118. Plaintiffs suffer from the ongoing contamination of the air and water surrounding 7 their properties. This harm includes, but is not limited to, polluted land and air in and around 8 Plaintiffs' properties and adverse health effects due to exposure. 9 119. The continuing conditions created by the Defendants harmed residents in Porter 10 Ranch and the surrounding neighborhoods, and a substantial number of people at the same time. 11 The harmful condition includes pollution of the Plaintiffs' land, homes, and persons from 12 noxious odors, hazardous gases, chemicals, pollutants, and contaminants emanating and/or 13 migrating from Defendants' Aliso Canyon storage facility and injection wells. 14 120. Plaintiffs did not consent to the Defendants conduct. 15 121. As a result of Defendants' conduct, Plaintiffs suffered a type of harm that is 16 different from the type of harm suffered by the general public. Specifically, Plaintiffs have lost 17 the use and enjoyment of their land, including, but not limited to exposure to an array of 18 pollutants in their persons and on their land, and the continuing threat of leaks, releases, 19 emissions, and/or migration of dangerous levels of noxious odors, hazardous gases, chemicals, 20 pollutants, and contaminants. 21 122. An ordinary person of reasonable sensibilities would be reasonably annoyed 22 and/or disturbed by the condition created by Defendants. 23 123. The seriousness of Defendants' conduct referenced above outweighs the public 24 benefits of the Defendants' Aliso Canyon storage facility operations because gas leaks seriously 25 deprive Plaintiffs of peaceful enjoyment of their homes and pollute the air of the surrounding 26 properties and neighborhoods. In comparison, the social value and primary purpose of such 27 activity is the maximization of profit for corporations with no incentive to take precautions to 28 ensure the safety and environmental integrity of the storage facility. -28-

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1 124. Defendants' conduct, including constructing, operating, and/or maintaining the 2 Aliso Canyon storage facility and its injection wells was a substantial factor, and likely the only 3 cognizable factor, in causing the harm. Further, continuing harm remains due to the current and 4 ongoing contamination of Plaintiffs' properties. 5 125. Plaintiffs further allege that as a consequence of Defendants' acts and/or failures 6 to act, this public nuisance must be abated. 7 126. Plaintiffs have no speedy, plain, or adequate remedy of law for the injuries 8 presently being suffered or for the aggravation of such injuries. Unless the nuisance created by 9 Defendants is restrained by a preliminary and permanent injunction, Plaintiffs will suffer great 10 and irreparable injury in that dangerous levels of noxious odors, hazardous gases, chemicals, 11 pollutants, and contaminants will continue to emanate from Defendants' Aliso Canyon storage 12 facility, pollute the air, Plaintiffs' properties, and continue to damage the right of Plaintiffs and 13 their families to live in their homes without harmful exposure. 14 127. Defendants' actions resulted in the pollution of air and deprived residents of 15 Porter Ranch of their ability to live in their homes free of health problems. Defendants took 16 these actions with a willful and knowing disregard of the rights and safety of the community. 17 128. As a further result of this wrongful conduct, Plaintiffs suffered, and will continue 18 to suffer, the loss of the quiet use and enjoyment of their property in addition to all of their 19 general damages in an amount to be set forth according to proof at trial. 20 129. In addition, Plaintiffs should be awarded attorney's fees under Code of Civil 21 Procedure section 1021.5 because the successful prosecution of this action will confer a 22 significant benefit both pecuniary and non-pecuniary on the general public and a large class of 23 persons by abating environmental harm and preventing future harm to residents of Porter 24 Ranch. Further, the necessity and financial burden of private enforcement makes such an award 25 appropriate as the litigation is not economically feasible or viable for Plaintiffs to pursue on 26 their own at their own expense, and such fees should not in the interest of justice be paid out of 27 the recovery, if any. 28 -29-

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1 130. At all relevant times herein Defendants and DOES 1-100 acted with malice, 2 oppression and fraud. California Civil Code section 3294 defines "malice" as despicable 3 conduct which is carried on by the defendant with a willful and conscious disregard of the rights 4 and safety of others; "oppression" as despicable conduct that subjects a person to cruel and 5 unjust hardship in conscious disregard of the persons' rights; and "fraud" as an intentional 6 misrepresentation, deceit, or concealment of a material fact lmown to the defendant with the 7 intention on the part of the defendant of thereby depriving a person of their property or legal 8 rights or otherwise causing injury, and as such are therefore liable to Plaintiffs for punitive 9 damages pursuant to Cal. Civ. Code section 3294(a). All allegations of malice, oppression or 10 fraud are directed at Defendants SOUTHERN CALIFORNIA GAS COMPANY, SEMPRA 11 ENERGY and DOES 1-100 and their employees, officers, directors and managing agents sued 12 herein as DOES. 13 131. Defendants' actions alleged herein were malicious, oppressive and fraudulent 14 actions that caused the injuries alleged herein to Plaintiffs, were despicable in nature, were 15 done wilfully and consciously, or were caused by intentional misrepresentation, deceit, or 16 concealment of a material fact lmown to the Defendants and DO ES 1-100 with the intention on 17 the part of the Defendants and DOES 1-100 of thereby consciously depriving a person of their 18 property or legal rights or otherwise causing injury. 19 132. Defendants and DOES 1-100, respectively, are liable for punitive damages 20 pursuant to subdivision (a) of California Civil Code, section 3294, based upon their wrongful 21 conduct, including the conduct of their officers, directors and managing agents, and the 22 wrongful conduct of their respective employees whose names are unlmown and are sued herein 23 as DOES 20-30. Defendants and DOES 1-100, had advance lmowledge of the unfitness of said 24 employees (DOES 20-30) and employed such employees with conscious disregard of the rights 25 and safety of others or ratified their wrongful conduct with respect to maintaining dangerous 26 conditions of the premises as set forth in the above allegations that are incorporated herein by 27 this reference. Said wrongful conduct was done with conscious disregard of the rights and 28 safety of Plaintiffs. Defendants and DOES 1-100 authorized or ratified the wrongful conduct of -30-

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1 their employees (DOES 20-30) as set forth herein by and through their officers, directors and 2 managing agents who are personally guilty of malice, oppression and/or fraud, all of whom are 3 sued herein as DOES. 4 13 3. Defendants and DO ES 1-100, are corporate employers pursuant to California 5 Civil Code §3294(b) and had advance knowledge of the unfitness of their employees whose 6 identities are unknown and are sued as DOES 20-30. Defendants and DOES 1-100 employed 7 said DOES 20-30 employees in conscious disregard of the rights and safety of others and 8 authorized or ratified the wrongful conduct as set forth herein for which damages are claimed or 9 are personally guilty of malice and oppression. 10 134. Defendants and DOES 1-100 had actual knowledge in advance of the subject 11 incident and allowed said conduct of employees DOES 20-30 and said dangerous conditions as 12 herein alleged to exist for a substantial time in conscious disregard of the rights and safety of 13 Plaintiffs, and through Defendants' officers, directors and/or managing agents authorized 14 conduct of employees to continue and the afore-described conditions to exist. All said acts of 15 oppression, fraud and malice were undertaken by or on the part of Defendants and DOES 1-100 16 by and through the officers, directors or managing agents of Defendants and 17 DOES 1-100 and DOE employees. 18 135. Accordingly, Defendants, DOES 1-100 and DOES 20-30 employees, respectively, 19 are liable for punitive damages pursuant to subdivision 3294(a) of the California Civil Code, and 20 Plaintiffs pray for judgment for punitive and exemplary damages against Defendants 21 SOUTHERN CALIFORNIA GAS COMPANY, SEMPRA ENERGY and DOES 1-100. 22 Ill 23 Ill 24 Ill 25 Ill 26 Ill 27 Ill 28 /// -31-

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1 2 PRAYER FOR RELIEF 3 WHEREFORE, Plaintiffs pray for judgment against all Defendants as follows: 4 1. An immediate and extended order placing a licensed medical doctor to manage and 5 monitor the health effects of exposure to the chemicals being released and that have been 6 released and to implement a treatment program therefore at the expense of Defendants; 7 2. An immediate and extended injunction and/or other court order placing a site 8 monitor/manager at the Aliso Canyon Oil and Gas Field to ensure that the causes of the 9 leak are fully investigated and repaired as quickly as possible, to ensure action plans are 10 put in place to prevent a reoccurrence of this type of event, and to address the 11 consequences of the emission of a massive volume of greenhouse gases into the 12 environment. 13 3. An immediate injunction against Defendants to prevent further harm to Plaintiffs to 14 include provisions for further ongoing monitoring of Plaintiffs' property and potential 15 remediation by Defendants; 16 4. Damages for cost of repair, depreciation, and/or replacement of destroyed, and/or lost 17 personal and/or real property; 18 5. Loss of use, benefit, goodwill and enjoyment of Plaintiffs' real and/or personal property; 19 6. Lost wages, earning capacity and/or business profits or proceeds and/or any related 20 displacement expenses; 21 7. Past and future medical expenses and incidental expenses according to proof at trial; 22 8. General damages for mental and emotional stress, fear, worry, and anxiety; 23 9. Annoyance and discomfort 24 10. For prejudgment interest; 25 11. For post-judgment interest; 26 12. An award to Plaintiffs for punitive damages; 27 13. For attorneys' fees and costs of suit pursuant to Code of Civil Procedure sections 1021.5, 28 1021.9, 1036 and any other provision oflaw; and 14. For such other and further relief as the court may deem proper. -32-

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es . F Geor T. 1efel III, Esq. William P. Harris III, Esq. Jodi L. Frantz, Esq. M. Regina Bagdasarian, Esq. Attorneys for Plaintiffs Complaint

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1 James P. Frantz, Esq., SBN 87492 jpf@frantzlawgroup.com 2 George T. Stiefel Ill, Esq., SBN 297611 CONFORMED COPY William P. Harris III, Esq., SBN 123575 O~IGINAL FILED 3 Superior Court of California Jodi L. Frantz, Esq., SBN, SBN 131711 Countv of Los Ann..,les 4 M. Regina Bagdasarian, Esq., SBN 296219 JAN 2 0 2016 Kira C. Guisto, Esq., SBN 292544 5 FRANTZ LAW GROUP, APLC 6 555 West Fifth St, 31st Floor Sherri R. Carter, Executive Officer/Cle k By: Julli Lara, Deputy Los Angeles, CA 90013 7 Tel: (323) 425-8138 Fax: (619) 525-7672 8 9 Thomas V. Girardi, SBN 36603 tgirardi@girardikeese.com 10 Robert William Finnerty, SBN 119775 Jolm Kelley Courtney, SBN 136720 11 Keith David Griffin, SBN 204388 12 GIRARDI I KEESE 1126 Wilshire Boulevard 13 Los Angeles, CA 90017 Tel: (213) 262-6777 14 Fax: (213) 481-1554 15 Attorneys for Plaintiffs 16 SUPERIOR COURT OF THE STATE OF CALIFORNIA 17 IN AND FOR THE COUNTY OF LOS ANGELES STANLEY MOSK COURTHOUSE 18 d \\ -"'· \ \':::. 19 TONIADELAN;LEVIADELAN;EVELYN ) ADI; MARGARET ANN AFDAHL; \\\\J 1~.:> ·Mo,",,' ·· ~ f .....)\J r'( -'1:"4·\,, 20 FERNANDO AGUIRRE; MA TITZA 21 AGUIRRE; PAOLA AGUIRRE; SARAH AGUIRRE; AFZAL AHMAD; AZEEM 22 AHMAD; ZAHRAH AHMAD; ZAHHDA AHMAD; ISMAEL ALCANTARA; 23 CHARMAINE ALEXANDER; EDWARD 24 ANDERSON; ARNULFO ANDRADE; JAMES ANGOLE; JOE ARELLANO; 25 CLAUDIA ASCENCIO; OBAID ASIF; ASMA ASIF; OSAMA ASIF; OMIAR ASIF; 26 SHAMIM ASIFI; AHTESHA WM ASIFI; 27 SIMON AV UNJIAN; RUZANNA AV UNJIAN; ELIZABETH AV UNJIAN; 28 ARSEN AYDINYAN; LALITHAAYSOLA; -34-

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BRIAN BABAY ANS; PARSHOTAM ) 1 ) BADRESHIA; SONIA BADRESHIA; ) 2 AMANI BADRESHIA, a minor by and ) through his guardian ad litem, SONIA ) 3 BADRESHIA; SAMAYA BADRESHIA, a ) minor by and through her guardian ad litem, ) 4 ) SONIA BADRESHIA; HECTOR BAEZ; ) 5 ALAN BAILEY; WILFREDO BALITON; ) ANGUSTIA BALITON; BERYL BATTY; ) 6 BONNIE R.BECKER; ARLENE BELFEY; ) ) PATRICIA BELLOVIN; LILIAN 7 ) BENATAR; GEORGE BIJU; MEGAN ) 8 BOOIMAD; SHOMO BRANDEL; GUENDA ) BRANDEL; PAMELA BRODSKY; TED ) 9 MARC BRODSKY; MARION OLIVIA ) ) BRONOWICKI; REBECCA BURKHARDT; 10 ) SALVADOR CARO; HENRY CHANDRA; ) 11 HANNYARTI CHANDRA; PEIPEI CHANG; ) HOWARD CHARNEY; ASHWANI ) 12 CHAWLA; ROGER CHLO WITZ; ) ) BONNIE CHLOWITZ; LINDA IN CHO; 13 ) LEONARD CILENTI; FRED COHEN; ) 14 HEIDI COHEN; MICHAEL COHILL; ) CRAIG COHN; SCOTT COHN; LINDA ) 15 ) COHN; MICHAEL COURTNEY, III ) NEYSON CRUZ; JERONA CUETO; 16 ) SHEILA CUETO; GEORGETTE DABBAH; ) 17 DAN DABBAH; KAREN E. DALDINE; ) DAVID DAV IS; ROBERT LAMONT ) 18 ) DeBOSE; NICOLE DeBOSE; STELLA ) DEKEL; YITZCHAK DEKEL and 19 ) KRISTINA K. DELEVIE, ) 20 ) Plaintiffs, ) 21 ) ) 22 vs. ) ) 23 SOUTHERN CALIFORNIA GAS ) ) COMPANY; a California Corporation; 24 ) SEMPRA ENERGY, a California Corporation; ) 25 and DOES 1through100, inclusive, ) ) 26 Defendants. ) ) 27 ) 28 -35-

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1 DEMAND FOR JURY TRIAL 2 Plaintiffs, for causes of action against the Defendants, hereby demands a trial of all 3 . actions by a jury. 4 5 DATED: January 19, 2016 6 7 GIRARDI l KEESE FRANTZ LAI - / 8 ·4 ~ 9 Tho~di, / SBN36603 10 Robert William Finnerty, SBN 119775 John Kelley Courtney, SBN 136720 11 Keith David Griffin, SBN 204388 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DEMAND FOR JURY TRIAL

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PROOF OF SERVICE OF DOCUMENT am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business address is: 65 S. Figueroa Street, 10th Floor, Los Angeles, CA 90017 true and correct copy of the foregoing document entitled: Reply to Virage SPV1 LLC’s Opposition to Motion for Reliom Stay and Demand for Adequate Protection ill be served or was served (a) on the judge in chambers in the form and manner required by LBR 5005-2(d); and (b) in e manner stated below: . TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF): Pursuant to controlling General rders and LBR, the foregoing document will be served by the court via NEF and hyperlink to the document. On January 9, 2021, I checked the CM/ECF docket for this bankruptcy case or adversary proceeding and determined that the llowing persons are on the Electronic Mail Notice List to receive NEF transmission at the email addresses stated below: Service information continued on attached page . SERVED BY UNITED STATES MAIL: n January 19, 2021, I served the following persons and/or entities at the last known addresses in this bankruptcy case odversary proceeding by placing a true and correct copy thereof in a sealed envelope in the United States mail, first classostage prepaid, and addressed as follows. Listing the judge here constitutes a declaration that mailing to the judge will e completed no later than 24 hours after the document is filed. ewis R. Landau, 22287 Mulholland Hwy., #318, Calabasas, CA 91302 Service information continued on attached page . SERVED BY PERSONAL DELIVERY, OVERNIGHT MAIL, FACSIMILE TRANSMISSION OR EMAIL (state method r each person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling LBR, on January 19, 2021 I served the llowing persons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing to uch service method), by facsimile transmission and/or email as follows. Listing the judge here constitutes a declaration at personal delivery on, or overnight mail to, the judge will be completed no later than 24 hours after the document is led. ewis R. Landau, Lew@Landaunet.com Service information continued on attached page declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. 1/19/21 Razmig Izakelian /s/ Razmig Izakelian Date Printed Name Signature

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. TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF): ichard D Buckley on behalf of Interested Party L.A. Arena Funding, LLC chard.buckley@arentfox.com arie E Christiansen on behalf of Creditor KCC Class Action Services, LLC christiansen@vedderprice.com, ecfladocket@vedderprice.com,marie-christiansen-4166@ecf.pacerpro.com ennifer Witherell Crastz on behalf of Creditor Wells Fargo Vendor Financial Services, Inc. rastz@hrhlaw.com shleigh A Danker on behalf of Interested Party Courtesy NEF shleigh.danker@dinsmore.com, SDCMLFiles@DINSMORE.COM;Katrice.ortiz@dinsmore.com lifford S Davidson on behalf of Creditor California Attorney Lending II, Inc. sdavidson@swlaw.com, jlanglois@swlaw.com;cliff-davidson-7586@ecf.pacerpro.com ei Lei Wang Ekvall on behalf of Interested Party Courtesy NEF kvall@swelawfirm.com, lgarrett@swelawfirm.com;gcruz@swelawfirm.com;jchung@swelawfirm.com ei Lei Wang Ekvall on behalf of Trustee Elissa Miller (TR) kvall@swelawfirm.com, lgarrett@swelawfirm.com;gcruz@swelawfirm.com;jchung@swelawfirm.com ichard W Esterkin on behalf of Interested Party Courtesy NEF chard.esterkin@morganlewis.com imothy W Evanston on behalf of Interested Party Courtesy NEF vanston@swelawfirm.com, gcruz@swelawfirm.com;lgarrett@swelawfirm.com;jchung@swelawfirm.com ric D Goldberg on behalf of Creditor Stillwell Madison, LLC ric.goldberg@dlapiper.com, eric-goldberg-1103@ecf.pacerpro.com ndrew Goodman on behalf of Attorney William F Savino goodman@andyglaw.com, Goodman.AndrewR102467@notify.bestcase.com ndrew Goodman on behalf of Petitioning Creditor Erika Saldana goodman@andyglaw.com, Goodman.AndrewR102467@notify.bestcase.com ndrew Goodman on behalf of Petitioning Creditor Jill O'Callahan goodman@andyglaw.com, Goodman.AndrewR102467@notify.bestcase.com ndrew Goodman on behalf of Petitioning Creditor John Abassian goodman@andyglaw.com, Goodman.AndrewR102467@notify.bestcase.com ndrew Goodman on behalf of Petitioning Creditor Kimberly Archie goodman@andyglaw.com, Goodman.AndrewR102467@notify.bestcase.com

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ndrew Goodman on behalf of Petitioning Creditor Robert M. Keese goodman@andyglaw.com, Goodman.AndrewR102467@notify.bestcase.com ndrew Goodman on behalf of Petitioning Creditor Virginia Antonio goodman@andyglaw.com, Goodman.AndrewR102467@notify.bestcase.com teven T Gubner on behalf of Interested Party Courtesy NEF gubner@bg.law, ecf@bg.law arshall J Hogan on behalf of Creditor California Attorney Lending II, Inc. hogan@swlaw.com, knestuk@swlaw.com azmig Izakelian on behalf of Creditor Frantz Law Group, APLC zmigizakelian@quinnemanuel.com ewis R Landau on behalf of Creditor Virage SPV 1, LLC ew@Landaunet.com ewis R Landau on behalf of Interested Party Courtesy NEF ew@Landaunet.com aniel A Lev on behalf of Interested Party Courtesy NEF lev@sulmeyerlaw.com, ccaldwell@sulmeyerlaw.com;dlev@ecf.inforuptcy.com eter J Mastan on behalf of Interested Party Courtesy NEF eter.mastan@dinsmore.com, SDCMLFiles@dinsmore.com;Katrice.ortiz@dinsmore.com dith R Matthai on behalf of Interested Party Courtesy NEF matthai@romalaw.com enneth Miller on behalf of Interested Party Courtesy NEF miller@pmcos.com, efilings@pmcos.com lissa Miller (TR) A71@ecfcbis.com, MillerTrustee@Sulmeyerlaw.com;C124@ecfcbis.com;ccaldwell@sulmeyerlaw.com ric A Mitnick on behalf of Interested Party Courtesy NEF itnickLaw@aol.com, mitnicklaw@gmail.com cott H Olson on behalf of Creditor KCC Class Action Services, LLC olson@vedderprice.com, scott-olson- 161@ecf.pacerpro.com,ecfsfdocket@vedderprice.com,nortega@vedderprice.com eonard Pena on behalf of Interested Party Robert Girardi ena@penalaw.com, penasomaecf@gmail.com;penalr72746@notify.bestcase.com ichael J Quinn on behalf of Creditor KCC Class Action Services, LLC

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quinn@vedderprice.com, ecfladocket@vedderprice.com,michael-quinn-2870@ecf.pacerpro.com onald N Richards on behalf of Interested Party Courtesy NEF n@ronaldrichards.com, morani@ronaldrichards.com,justin@ronaldrichards.com hilip E Strok on behalf of Interested Party Courtesy NEF strok@swelawfirm.com, gcruz@swelawfirm.com;1garrett@swelawfirm.com;jchung@swelawfirm.com nited States Trustee (LA) stpregion16.la.ecf@usdoj.gov ric D Winston on behalf of Creditor Frantz Law Group, APLC ricwinston@quinnemanuel.com hristopher K.S. Wong on behalf of Interested Party L.A. Arena Funding, LLC hristopher.wong@arentfox.com, yvonne.li@arentfox.com imothy J Yoo on behalf of Interested Party Courtesy NEF y@lnbyb.com

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