SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF VENTURA, UNLIMITED CIVIL JURISDICTION ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

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1 ROB HENNIG (STATE BAR NO. LAW OFFICES OF ROB HENNIG CENTURY PARK EAST, SUITE 0 LOS ANGELES, CA 00- TELEPHONE: (0-000 FAX: (0-0 Attorneys for Plaintiff Don Hanks SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF VENTURA, UNLIMITED CIVIL JURISDICTION 0 0 DON HANKS, an individual, vs. Plaintiff, AMGEN USA, INC., a California corporation; and DOES through 0, inclusive; Defendants. CASE NO.: CU-WT-VTA FIRST AMENDED COMPLAINT FOR:. RETALIATION IN VIOLATION OF LABOR CODE SECTION 0.;. WRONGFUL TERMINATION IN VIOLATION OF PUBLIC POLICY;. UNFAIR COMPETITION IN VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTION 00 FOR RESTITUTION AND INJUNCTIVE RELIEF; AND DEMAND FOR JURY TRIAL DATE FILED: April 0, 00 DEPT.: JUDGE: Hon. Henry J. Walsh GENERAL ALLEGATIONS Introduction. This is a whistleblower lawsuit. Plaintiff Don Hanks (hereinafter Plaintiff or Hanks files this Complaint for Damages related to Plaintiff s former employment with Defendant Amgen USA, Inc. (hereinafter Defendant Amgen or Amgen. Plaintiff Hanks was an eighteen year employee of Amgen who merely did a computer search concerning the False Claims Act and was then terminated within weeks of doing so. Plaintiff Hanks brings causes of --

2 action for violation of Labor Code section 0., wrongful termination in violation of public policy, and Business and Professions Code section 00 et seq., against Defendant Amgen and Does through Parties and jurisdiction. At all times material to this complaint, Plaintiff is informed and believes Defendant Amgen was and is a California corporation doing business in the County of Ventura and, in fact, headquartered in the County of Ventura.. Defendant Does One through Forty are sued under fictitious names pursuant to California Code of Civil Procedure section. Plaintiff is informed and believes, and on that basis alleges, that each defendant sued under such fictitious names is in some manner responsible for the wrongs and damages as alleged below, and in so acting was functioning as the agent, servant, manager, supervisor, and/or employee of Amgen, and in doing the actions mentioned below was acting within the course and scope of his or her authority as such agent, servant, manager, supervisor, and/or employee with the permission and consent of the Defendant Amgen.. This Court is the proper court and this action is properly filed in Ventura County and in this judicial district because (a Defendant Amgen transacts business in Ventura County; (b contracts of employment between Plaintiff and Amgen were made and terminated in Ventura County; (c the termination of Plaintiff occurred by and through Amgen s actions in Ventura County; (d records including records relating to Plaintiff s employment were and are maintained by Amgen in Ventura County; and (e material transactions between Plaintiff and Defendants took place within Ventura County.. Plaintiff is a former employee of Defendant Amgen and a resident of the State of Florida. Plaintiff voluntarily submits to the jurisdiction of Ventura County Superior Court in the State of California.. Plaintiff Hanks sues under California law. California law is the applicable law for this lawsuit because at the beginning of Mr. Hanks employment with Amgen, Inc. (later succeeded by Defendant Amgen USA, Inc., Amgen imposed California law on the employment --

3 0 relationship between Amgen and Hanks by and through its use of California law in the Proprietary Information and Inventions Agreement contract between Amgen and Mr. Hanks. Defendant Amgen specifically chose California law in a choice of law provision (see, p. to the Agreement at paragraph.: Governing Law. This Agreement will be governed by and construed according to the laws of the State of California. Defendant Amgen then reaffirmed the choice of California law when, after it terminated Mr. Hanks, it sent him a letter by and through Stephanie Murray, Human Resource Operations of Defendant Amgen, on or about May, 00 reminding him [Your] obligations are described more fully in the enclosed Proprietary Information and Inventions Agreement and enclosing a copy of this agreement. A true and correct copy of this agreement and a true and correct copy of the Amgen letter to Mr. Hanks of May, 00 (without the attachment are attached hereto and incorporated herein as Exhibit A.. At all relevant times alleged herein Plaintiff was employed by Defendant Amgen under an employment agreement that was partly written, partly oral, and partly implied.. As a direct and proximate result of the unlawful acts of Defendants, Plaintiff has suffered and continues to suffer from loss of earnings and other damages in amounts not yet ascertained, but subject to proof at trial.. Plaintiff is informed and believes, and thereon alleges, that Defendant Amgen engaged in malice, fraud, and/or oppression in its actions against Plaintiff. 0 Facts 0. When Plaintiff Hanks first began working for Amgen as a sales representative in, Amgen and its employees were committed to the best traditions of medicine and saving lives. Amgen was seeking Food and Drug Administration (hereinafter FDA approval of Epogen for dialysis patients to save these patients from needing risky transfusions. At the time, blood borne pathogens, including the HIV virus, created a serious risk for transfusion patients receiving tainted blood with potentially deadly consequences.. Over time, the tremendous profits obtained from blockbuster drugs altered Amgen. In search of ever greater profits, Amgen began seeking alternate markets and new --

4 0 0 patients for several of its drugs. In particular, Amgen began to promote overfill. Overfill was a concept where a drug would be filled in an amount significantly greater than its recommended dose. That way, a provider could use the extra amount on a new patient still billing the new patient and Medicare for the dosing but not having to pay for the additional drug provided.. Amgen also began to use other marketing techniques to boost sales including rebates, off invoice discounts, volume discounts, free goods, extravagant dinners and lavish retreats for doctors. Amgen began payments to physicians ($,000, pharmacists ($0, nurses ($00, and office billing staff ($0 that were characterized as honorariums or for roundtable discussions.. Amgen also promoted and sold its drugs on spread or margin using elaborate spread sheets provided to doctors including the potential monthly income per patient for the prescription of Amgen drugs. Amgen knew or should have know that to sell on spread or margin is unethical and illegal. Amgen counseled its sales representatives to hide these activities by reporting them as business reviews or economics in Orion and in Gelco expense reports.. Amgen also began to promote off-label marketing of its drugs to doctors. Off-label marketing is a strategy of deliberately selling a drug for purposes other than the FDA approved use. While a doctor can prescribe a drug for an off-label use, it is illegal for a pharmaceutical company to market a drug for an off-label use. Amgen promoted off-label marketing of its drugs in patient populations including myelodysplastic syndromes ( MDS, HIV/AIDS, and peri-surgery.. Amgen also began aggressively promoting the use of higher doses of its drugs. Higher doses meant greater sales and larger profits. Unfortunately, these higher dosing promotions would often lead to significantly higher side-effects for the patient. An influential study that Amgen delayed releasing showed that these higher dosing levels actually resulted in a higher mortality rate. In short, Amgen began to seek greater profits at the expense of patient care and safety. /// --

5 0 0. In October 00, Amgen launched Aranesp for chronic renal failure. Sales of Aranesp were modest and below expectations. In July 00, Amgen received FDA approval of Aranesp in chemotherapy induced anemia patients. Aranesp was approved by the FDA for once a week dosing for chemotherapy induced anemia patients. Amgen aggressively marketed Aranesp to be used for every other week dosing an illegal off-label marketing of non-approved dosing.. Amgen developed a very sophisticated contract tier system for marketing Aranesp and Neulasta. In short, these marketing contracts created an enormous incentive to sell more product in the form of ever larger rebates and off-invoice discounts for greater use of these drugs by physicians and hospitals. These tiers created a strong incentive to sell more and more of Amgen s products.. Although Amgen sold its pharmaceutical products to doctors and hospitals, the United States Government is the single largest payer in the form of Medicare reimbursements for the drugs that Plaintiff Hanks marketed on Amgen s behalf. Indeed, these off-label marketing tactics and other illegal actions of Amgen had a significant and fraudulent impact upon Medicare reimbursement of these drug costs.. Plaintiff Hanks resisted many of Amgen s illegal marketing tactics. Plaintiff Hanks complained that his customer were unfairly locked in to rigid contracts with Amgen. Plaintiff Hanks brought his concerns directly to Amgen management located in its Thousand Oaks headquarters such as Mr. Joe Turgeon, Amgen s national Marketing Sales Director. 0. On or about March, 00, Plaintiff Hanks had his annual performance evaluation. His review was outstanding, as usual, with recognition for his great sales year.. Around this time, medical data had now become public that Erythropoetic Stimulating Agents such as Amgen s Epogen and Aranesp as well as its competitor, Johnson & Johnson s Procrit, had significant safety issues including increased mortality at higher, off-label dosing.. At this point, Plaintiff Hanks began to seek information regarding Amgen s practices via his an Amgen internet connection. Plaintiff Hanks began to seek news releases concerning Amgen, other whistleblowers and whistleblower claims, and False Claims Act claims --

6 0 0 in the pharmaceutical business. Indeed, Plaintiff Hanks filled out a qui tam case evaluation with the law firms Phillips and Cohen, LLP on or about April, 00.. On or about May, 00, Plaintiff Hanks was told to come to Thousand Oaks, California to Amgen s corporate headquarters, for a meeting. In a meeting on or about May, 00, an Amgen Human Resources Manager, Ms. Elizabeth Egel, informed Plaintiff that he had done nothing wrong, but that Amgen had pulled some of his expenses in the past six months and had some questions to ask him. Plaintiff Hanks was actually verbally reprimanded for having too much detail on his expense reports. Since Plaintiff Hanks often detailed in his expense reports the illegal marketing tactics of Amgen such as off-label marketing. Plaintiff Hanks was told by Ms. Egel that he was a compliance risk if the Office of Inspector General or the Internal Revenue Service ever saw his expense reports.. Plaintiff Hanks was then subsequently terminated by Ms. Egel on or about May, 00. Ms. Egel called Mr. Hanks, firing him on the telephone from, presumably, her office at Defendant Amgen s headquarters in Thousand Oaks, CA. The pre-textual reasons offered by Ms. Egel was that Plaintiff Hanks represented a risk.. Plaintiff Hanks brings this complaint based upon his attempts to counter and prevent illegal actions on the part of Amgen.. The actions of Amgen described herein constitute unfair business practices in violation of Business and Professions Code section 00 et seq. In particular, Amgen s policy and practice of terminating any whistleblower indeed anyone who does not toe the line in fully and unquestionably participating in Amgen s illegal off-label marketing practices constitutes a violation of Business and Professions Code section 00 et seq.. Plaintiff Hanks resisted many of Amgen s illegal and unfair practices. As a result, despite Hanks s laudatory employment record, he began to experience retaliation involving adverse employment actions, specifically his termination. Indeed, Hanks was ultimately terminated in retaliation for his refusal to engage in illegal and unfair practices and/or for his complaints of fraud, inefficiency, and waste involving federal government contracts. /// --

7 . Plaintiff Hanks alleges that his termination by Defendant Amgen was motivated by his whistleblower activities and/or his refusal to engage in illegal and unfair practices, his termination was in violation of public policy. 0 0 FIRST CAUSE OF ACTION RETALIATION IN VIOLATION OF LABOR CODE SECTION 0.. As a separate and distinct cause of action, Plaintiff complains and realleges all the allegations contained in this complaint, and incorporates each by reference into this cause of action as though fully set forth herein, excepting those allegations which are inconsistent with this cause of action. Plaintiff Hanks brings this cause of action against Defendants Amgen and Does through Plaintiff was subjected to retaliation in violation of Labor Code section 0.(b by Defendants for his disclosing what Plaintiff in good faith believed to be violations by Amgen of state or federal statutes or regulations.. Plaintiff was subjected to retaliation in violation of Labor Code section 0.(c by Defendants for his refusal to participate in activity that he believed, in good-faith, would be a violation of federal and state laws and regulations. Plaintiff was subjected to retaliation in violation of Labor Code section 0. by Defendants for his refusal to participate in activity that was, in fact, in violation of federal and state laws and regulations.. Plaintiff did in fact suffer adverse employment actions up to and including his termination by Defendants in retaliation for Plaintiff s disclosure and refusal to participate as stated herein.. Defendants intentionally created or knowingly permitted these working conditions wherein Plaintiff was directed to commit actions in violation of federal and state laws and regulations and retaliated against for the reporting of actions in violation of federal and state laws and regulations of others. /// /// --

8 0. As a proximate result of the retaliation against Plaintiff by Defendants in violation of Labor Code section 0., Plaintiff has sustained and continues to sustain substantial losses in earnings and other employment benefits.. As a proximate result of the retaliation against Plaintiff by Defendants in violation of Labor Code section 0., Plaintiff has suffered and continues to general damages including mental pain and anguish, all of the character that Plaintiff might normally suffer given the circumstances Plaintiff has encountered and in a sum according to proof.. Plaintiff is entitled, per Labor Code section 0.(f for a civil penalty against Defendants not exceeding $0,000 for each instance of violation of Labor Code section 0.(b and (c.. Plaintiff is informed and believes and therein alleges that the aforesaid acts directed toward him were carried out with a conscious disregard of Plaintiff s right to be free from such illegal behavior, such as to constitute oppression, fraud, or malice pursuant to California Civil Code section entitling Plaintiff to punitive damages in an amount appropriate to punish and set an example of Defendants. WHEREFORE, Plaintiff Hanks requests relief as hereafter provided. 0 SECOND CAUSE OF ACTION WRONGFUL TERMINATION IN VIOLATION OF PUBLIC POLICY. As a separate and distinct cause of action, Plaintiff complains and realleges all the allegations contained in this complaint, and incorporates each by reference into this cause of action as though fully set forth herein, excepting those allegations which are inconsistent with this cause of action. Plaintiff Hanks brings this cause of action against Defendants Amgen and Does through 0.. ///. Plaintiff was employed by Amgen for approximately years beginning in 0. Plaintiff was terminated by Defendants on or about May,

9 0 0. Plaintiff s attempting to report and document what Plaintiff reasonably believed to be ethical, legal, and regulatory violations of others and/or his resistance to directions to commit what Plaintiff reasonably believed to be ethical, legal, and regulatory violations himself and that these were motivating reasons for Plaintiff s termination.. Plaintiff further alleges that each of these ethical, legal, and regulatory violations by Defendants involved claims of fraud against the United States Government and actions against the federal False Claims Act and California False Claims Act (California Government Code section et seq.. More specifically, the Federal False Claims Act at U.S.C. 0(h( made it illegal to terminate Plaintiff because of the actions described herein which were in furtherance of efforts to stop violations of this Federal False Claims Act.. As a proximate result of Defendants wrongful termination of him, Plaintiff has sustained and continues to sustain substantial losses in earnings and other employment benefits.. As a proximate result of Defendants wrongful termination of him, Plaintiff has suffered and continues to general damages including mental and physical pain and anguish, all of the character that Plaintiff might normally suffer given the circumstances Plaintiff has encountered and in a sum according to proof.. Plaintiff has incurred and continues to incur legal expenses and attorney fees. Plaintiff is presently unaware of the precise amount of these expenses and fees and prays leave of court to amend this complaint when the amounts are more fully known.. Plaintiff is informed and believes and therein alleges that the aforesaid acts directed toward him were carried out with a conscious disregard of Plaintiff s right to be free from such illegal behavior, such as to constitute oppression, fraud, or malice pursuant to California Civil Code section entitling Plaintiff to punitive damages in an amount appropriate to punish and set an example of Defendants. /// WHEREFORE, Plaintiff Hanks requests relief as hereafter provided. --

10 0 0 THIRD CAUSE OF ACTION VIOLATION OF CALIFORNIA S UNFAIR COMPETITION LAW BUSINESS AND PROFESSIONS CODE SECTION 00 ET SEQ.. As a separate and distinct cause of action, Plaintiff complains and realleges all the allegations contained in this complaint, and incorporates each by reference into this cause of action as though fully set forth herein, excepting those allegations which are inconsistent with this cause of action. This cause of action is brought against Defendants Amgen and Does through 0.. Business and Professions Code section 00 et seq. defines unfair competition to include any unfair, unlawful or deceptive business practice. California s Unfair Competition Law also provides for injunctive relief and restitution for violations.. Defendant Amgen and Does through 0 have committed numerous unfair, unlawful, or deceptive business practices described herein and these practices have worked to the detriment of Plaintiff and others. Defendants have benefitted financially from these unlawful and unfair practices. Among other things, Defendants have engaged in the unlawful or unfair business practice of retaliating against Plaintiff and others who refused to engage in the illegal and unethical conduct of Amgen. 0. Plaintiff is informed and believes and thereon alleges that Defendants continue to engage in the practices described herein and is continuing and will continue to benefit financially from these unlawful and unfair practices unless enjoined by this court from doing so.. As a proximate result of Defendants actions, Plaintiff has suffered injury in fact and lost money or property. This injury in fact includes the loss of wage, salary, benefits, and other moneys. In particular, because of Mr. Hanks termination when he was in the process of exposing the illegal and unethical practices of Amgen, he was denied salary, bonuses, contest prizes, and other forms of wages that would have been provided to him and that were provided to others.. During all relevant times, Plaintiff held Amgen stock and options. During the time of his employment, Plaintiff held Amgen stock as part of his retirement savings. Plaintiff -0-

11 0 0 was also provided options for Amgen stock that could be exercised by him. During the relevant time period, Plaintiff lost money in that as Amgen s stock price declined, Plaintiff s options became far less valuable, even worthless. During the relevant time period, Plaintiff lost money in that his Amgen stock declined in value.. Plaintiff asserts that a motivating factor for the decline in Amgen s stock price was the unfair, unlawful, and deceptive business practices described herein. Plaintiff further asserts that the Amgen s unfair, unlawful, and deceptive business practices and the exposure of these practices caused actual injury to Plaintiff in the form of significant financial losses both in his Amgen stock and his options to purchase Amgen stock at specified share prices.. The actions of Defendants detailed herein against Plaintiff constitutes unfair, unlawful and deceptive business practices, and further, constitute actions for which injunctive relief and restitutionary disgorgement are available.. Under Business and Professions Code section 00 et seq., Plaintiff is entitled to restitutionary disgorgement of all funds, which lawfully should have been paid as wages, civil penalties, or other penalties, as well as the actual losses in stock value and other actual monetary losses of Claimant, for the last four years, together with interest thereon, as well as costs and reasonable attorneys fees pursuant to Code of Civil Procedure section 0... Under Business and Professions Code section 00 et seq., Defendants may be compelled to disgorge any and all ill-gotten profits and benefits received from the conduct described herein together with payment of civil penalties, or other penalties, for the last four years, together with interest thereon, as well as costs and reasonable attorneys fees pursuant to statute.. This action, in particular its claim for injunctive relief under Business and Professions Code section 0, has been brought and may properly be maintained as a representative action under the procedures described in Code of Civil Procedure section because there is a well-defined community of interest in the litigation and the proposed class is easily ascertainable: a. Numerosity: The potential number of persons injured as a result of the --

12 0 unfair, unlawful, and deceptive business practices of Defendants as described herein are so numerous that joinder of all the members of the such a class is impracticable. While the precise number of persons affect has not yet been determined, Plaintiff is informed and believes that Amgen has employed literally thousands of persons who had Amgen stock in their retirement plans and/or options for Amgen stock, that Amgen has thousands of shareholders, and that Amgen furthermore had competing corporations that were marketing similar drugs in different types of markets all of whom would qualify as potential class members during the affected period. Given this large number, it is highly likely that there is a sufficient number of potential class members. As a result, joinder of all such persons is not practicable; b. Commonality: There are questions of law and fact common to the Plaintiff and other affected persons that predominate over any questions affecting only individuals or the individuals that would constitute any potential class. These common questions of law and fact include without limitation: 0 (i. (ii Whether Defendants violated federal laws and regulations through its hundreds of sales and marketing employees by engaging in off-label marketing practices for many of its drugs; Whether Defendants violated California Labor Code section 0. in the way described herein by retaliating against its employees who either refused to engage in its illegal conduct, or retaliating against those employees who attempted to expose Amgen s illegal conduct in a manner protected under Labor Code section 0.; and --

13 (iii Whether Defendants violated Business and Professions Code section 00 by violating the labor laws and regulations noted herein and otherwise engaged in unfair competition in violation of California s Unfair Competition Law. 0 0 c. Typicality: Plaintiffs claims are typical of the claims of any potential class. Plaintiffs and all potential class members sustained injuries arising out of actions or inactions of Defendants common course of conduct of engaging in unfair, unlawful, and deceptive business practices alleged herein; d. Adequacy of Representation: Plaintiff is qualified to, and will fairly and adequately protect the interests of all potential class members as a representative of these persons, with whom Plaintiff has a well-defined community of interest and typicality of claims, as demonstrated herein. Plaintiff has no interest that is adverse to the interests of any of the other potential class members in general or of any potential class members specifically. Plaintiff acknowledges that he has an obligation to make known any relationship, conflicts or differences with any potential class member. Plaintiffs attorneys and proposed representative action counsel are versed in the rules governing class action discovery, certification, and settlement and in filing 00 actions. Plaintiff has incurred, and during the pendency of this action, will continue to incur, costs and attorney fees, that have been, are and will be necessarily expended for the prosecution of this action for the substantial benefit of each potential class member; e. Superiority of Class Action: A class or representative action is superior to other available means for the fair and efficient adjudication of this controversy. Individual joinder of all potential class members --

14 0 0 is not practicable, and common questions of law and fact affecting the affected potential class members predominate over any questions affecting only individual members of the potential class. Each potential class member has been damaged and is entitled to recover by reason of Defendants illegal policies and/or practices. Class or representative action treatment will allow those similarly situated persons to litigate their claims in the manner that is most efficient and economical for the parties and the judicial system; and f. Public Policy Consideration: California corporations violate California laws and engage in unfair competition everyday. Current employees are often afraid to assert their rights out of fear of direct or indirect retaliation. Former employees are fearful of bringing actions because they believe their former employers can damage their future endeavors through negative references and other means. Class and representative actions provide the potential class members who are not named in the complaint with a type of anonymity that allows for the vindication of their rights.. Under Business and Professions Code section 0, Defendants should be enjoined from any and all unfair, unlawful and deceptive business practices as described herein in the future. Indeed, this enjoinment should include any and all of the unfair, unlawful, or deceptive business practices described herein. WHEREFORE, Plaintiff Hanks on behalf of himself and as a representative of other aggrieved persons requests relief as hereafter provided. PRAYER FOR RELIEF WHEREFORE, Plaintiff Hanks prays for relief and judgment against all Defendants, as follows: /// --

15 0 As to the First Cause of Action: a. For restitution of all monies due Plaintiff including back pay, front pay, lost employment benefits and other compensation, and other special damages according to proof; b. For general damages to compensate Plaintiff for his past, present, and future emotional distress, pain and suffering, and loss of pleasure and enjoyment of life; c. For all civil penalties as specified in Labor Code section 0.(f of up to $0,000 for each violation; d. For punitive damages as allowed by law; e. For an award of interest, including prejudgment interest, at the legal rate; f. For an award of attorney fees as allowed by law; g. For costs of suit incurred; and h. For such other and further relief as this Court deems appropriate. 0 As to the Second Cause of Action: /// a. For restitution of all monies due Plaintiff including back pay, front pay, lost employment benefits and other compensation, and other special damages according to proof; b. For general damages to compensate Plaintiff for his past, present, and future emotional distress, pain and suffering, and loss of pleasure and enjoyment of life; c. For punitive damages as allowed by law; d. For an award of interest, including prejudgment interest, at the legal rate; e. For an award of attorney fees as allowed by law; f. For costs of suit incurred; and g. For such other and further relief as this Court deems appropriate. --

16 0 0 As to the Third Cause of Action: a. That Respondent Amgen be found to have violated Business and Professions Code section 00 et seq. by engaging in unfair and unlawful business practices; b. For Respondent to be ordered to pay restitution to Claimant for his damages and all others similarly situated who were damaged from Respondent s unfair and unlawful business practices; c. For Respondent to be ordered to disgorge all profits obtained or tainted by its unlawful and/or unfair activities pursuant to Business and Professions Code section 00 et seq.; d. For Respondent to be permanently enjoined from engaging in unlawful and unfair competition and that they be further be permanently enjoined from the specific business practices mentioned and described herein; e. For Claimant and all others similarly situated to be reinstated to comparable positions as each previously had before Respondent engaged in it unlawful and unfair competition and that Respondent be permanently enjoined from engaging in unlawful and unfair competition as it applies to Claimant and others similarly situated; f. That Claimant s injunctive claims for himself, others similarly situated, and on behalf of the general public, be ordered to be heard in Superior Court for the County of Orange; g. For attorney s fees pursuant to Code of Civil Procedure section 0.; h. For costs of suit incurred; and i. For such other and further relief as may be appropriate. Dated: June, 00 LAW OFFICES OF ROB HENNIG Rob Hennig Attorneys for Plaintiff Don Hanks --

17 DEMAND FOR JURY TRIAL Plaintiff demands trial by jury in this matter. 0 0 Dated: June, 00 LAW OFFICES OF ROB HENNIG Rob Hennig Attorneys for Plaintiff Don Hanks --

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