FILED JUL EZI except defendant (name): 0 except defendant (name): (5) 0 other (specify)

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1 AV:1 0/ : CARLE MACKIE POWER R PAGE 07/11 ATtORNtY Olt PARTY WITHOUT ATTORNEYNenic Sloe Blr, owneor. and liddiru Dawn M. Ross (SBN ) 1 John A. Loveman (SBN ) Carle, Mackie, Power & Ross LLP 100 B Street, Suite 400 Santa Rosa, CA ralcuortetio: (707) FAX /40 Monons4: (707) E man. ADORES (0Puone7. ATTORNEY f OR WarneZ Plaintiff SUPERIOR COURT OF CALIFORNIA, COUNTY OF 1EHAMA STREET ADDRESS: 633 Washington Street MAIUNC =CRESS: Room 21 ammo z, com Redbluff, CA MANCH NAME: PLAttiTIFF; DEFENDANT: CALIFORNIA SUPERIOR COURT COUNTY OF TEITAMA MARK D. MONTALVO PLD-C-001 FOR COURT USE ONLY FILED UPERIOR COURT OF CALIFORNIA JUL OF TEHAMA I. DMSION ' &k r' 0,. t lie OF THE COUFIT a.:iwa 1 rib z. DERRY 41. (Ell DOES 1 TO 50, Inclusive CONTRACT 110 COMPLAINT 0 AMENDED COMPLAINT plumber): 0 CROSS-COMPLAINT 0 AMENDED CROSS-COMPLAINT (Numbar): Jurisdiction (checkoff that apply): 0 ACTION IS A LIMITED CIVIL CASE Amount demanded 0 does not exceed 510,000 exceeds $10,000 but does not exceed 525,000 ACTION IS AN UNLIMITED CIVIL CASE (exceeds 525,000) Ca ACTION IS RECLASSIFIED by this amended complaint or cross-complaint 0 from limited to unlimited 0 from unlimited to limited _ Plaintiff" (name o alleges causes of action againstdefendant (name or names): CASZ NUMER MARK D. MONTALVO and DOES 1-50, Inclusive 2. This pleading, Including attachments and exhibits, consists of the following number of pages: 5 3. a. Each plaintiff named above is a competent adult al except plaintiff (name): CALIFORNIA SUPERIOR COURT COUNTY OF TETIAMA (1) 0 a corporation qualified to do business in California (2) 0 an unincorporated entity (describe): (3) an other (specify): Governmental Entity b. Q Plaintiff (name): a. (ZI has complied with the fictitious business name laws and is doing business under the fictitious name (specify): b. 0 has complied with all licensing requirements as a licensed(specify): c. Q Information about additional plaintiffs who are not competent adults is shown in Attachment 3c. 4. a. Each defendant named above is a natural person EZI except defendant (name): 0 except defendant (name): (1) 0 a business organization, form unknown (1) 0 a business organization, form unknown (2) 0 a corporation (2) a corporation (3) C3 an unincorporated entity (describe): (3) Lj an unincorporated entity (describe): (4) CI a public entity (describe): (5) 0 other (specify): (4) El a public entity (describe): (5) 0 other (specify) this form is used CrtiSCOntialrk platricri mars atita-cedviarttel ertt beard ant Imam tragycietondwit Fars /V prowl Ice oral Ga = i Count!: d Csirorrilm vin-c-001 OW. Januiwy 1, Z007) Ismiffmts- COMPLAINT Contract PEW I Ott Coda of CM PrOCeare. A

2 07/19/ : CARLE MACKIE POWER R PAGE 08/11 SHORT TM.E: CA. Superior Court Co oftetiatna v Montslvo, et al. CASE numseft PLO-C (Continued) b. The true names of defendants sued as Does are unknown to plaintiff. (1) ra Doe defendants (specify Doe numbers): 1-25 were the agents or employees of the named defendants and acted within the scope of that agency or employment. (2) al Doe defendants (specify Doe numbers): 1-5n are persons whose capacities are unknown to plaintiff. c. 0 Information about additional defendants who are not natural persons is contained In Attachment 4c. d. CI Defendants who are joined under Code of Civil Procedure section 382 are (names): 5. El Plaintiff is required to comply with a claims statute,and a. CI has complied with applicable claims statutes, or b. CI is excused from complying because (specify): 6. CI This action Is subject to CI Civil Code section D 0 Civil Code section This court is the proper court because a. a defendant entered Into the contract here. b. 0 a defendant lived here when the contract was entered into. c. Cia a defendant lives here now. d. 0 the contract was to be performed here. e. El a defendant Is a corporation or unincorporated association and Its principal place of business is here. f. 0 real property that Is the subject of this action is located here. g. 01 other (specity): 8. The following causes of action are attached and the statements above apply to each (each complaint must have one or more causes of action attached): CI Breach of Contract I:I Common Counts Other (specify): Intentional Tort, General Negligence 9. al Other allegations: Exemplary Damages 10. Plaintiff prays for judgment for costs of suit; for such relief as is fair, just. and equitable; and for a. El damages of: $ b. 1:1 interest on the damages (1) 1:=1 according to proof (2) El at the rate of (specify): percent per year from (date): c. I attomevs fees (1) 0 of: (2) 0 according to proof. d. other (specify): Damages according to proof and injunctive relief. 11. CJI The paragraphs of this pleading alleged on information and belief are as follows (specify paragraph numbers): Date: July 10, a3mM..Rng PUK.COURIKJEnueryUCCin MmIlbrent. ITYMORMINTNAMO MGNATURC. OF ruagit r OR ATTORN,y) (If you wish to verity this pleading, affix a verification.) COMPLAINT - Contract Pape 2 of 2

3 07/19/ : CARLE MACKIE POWER R PAGE B9/11 SHORT TIRE: CASE NUMBER PLD-P1-001 (31 vmst CAUSE OF ACTION- Intentional Tort Page _3 (number) ATTACHMENTTO Complaint Q Cross Complaint (Use a separate cause of action form for each cause of action.) IT-1. Plaintiff (name): CALIFORNIA SUPERIOR COURT COUNTY OF TEHAMA alleges that defendant (name) : MARK D. MONTALVO ara Does 1- to 50 was the legal (proximate) cause of damages to plaintiff. By the following acts or omissions to act, defendant Intentionally caused the damage to plaintiff on (dote): on or about July 3, 2015 and continuing at (place): Redbluff, California, Tehama Couiity (description of reasons for liability): Intentional Tort - Conversion: Defendant Montalvo was the Director of Information Technology for the Superior Court of the State of California, County of Tehama. His employment was terminated on June 26, As Director of IT, Defendant possessed critical passwords and had access to all of the Court's essential IT systems, including its , phone % calendaring, CMC, and jury systems. When Defendant left the Court's employ, he provided the Court with incorrect password information for critical passwords. When Defendant failed to provide the correct passwords, Plaintiff sent Defendant two letters demanding return of the critical IT codes, and explaining that California Penal Code section 502 prohibits computer crimes and various forms of unauthorized access to government entity computer systems. Defendant failed to return the critical passwords and, on information and belief, sabotaged the Court's computer system. On July 9, 2015, while investigating the source of its computer system problems, the Court determined that on July 3, 2015 at 1:58 p.m., someone had logged into the Administrator account, controlled by Defendant, and deleted two hard drives containing all of the Court's infrastructure for Tehama County, and bad emptied it from the trash bin. At this point, the Court's CMC system is non-operational, it'sphone, and website arc non-operational, along with its jury summons system and other critical court systems. The Court has already spent over one hundred thousand dollars ($100,000) hiring professionals to try to restore its system, but does not yet know if that is possible. Defendant's conduct has and will cause the Plaintiff damages in excess of the minimal jurisdiction of the Court. FormAtmrtmdfcrOolmdthe Judie's! Council / Col cefomle ALD-o1401(31 (Rev. J..%Aryl. 2037) SilAtir CAUSE of AdTION Intentional Tort Pogo 1 of 1 Code of CM:Noted" wow:await: alley

4 '07/19/ : CARLE MACKIE POWER R PAGE 10/11 SHORT TITLE: I SFCOND (number) ATTACHMENT TO EI Complaint El Cross-Complaint (Use a separate cause of action form for each cause of aeon.) CASE. rflimzer CAUSE OF ACTION- General Negligence Page A_ PL.D.P1 001(2) GN-1. Plaintiff (name): CALIFORNIA SUPERIOR COURT COUNTY OF TEHAMA alleges that defendant (name): MARK D. MONTALVO I Does to 50 was the legal (proximate) cause of damages to plaintiff. negligently caused the damage to plaintiff on (date): on or about July 3, 2015 at (place): Redbluff, California, Tehama County (description of reasons for : Disseminating the IT systems described herein. By the following acts or omissions to act, defendant Form Approved for Optional Usd.kodldfd Card Ce Ceelforria Ott)-P ) pay. January resniort CAUSE OF ACTION- General Negligence Cole at ChM Proc*aure

5 '07/10/ : CARLE MACKIE POWER R PAGE 11/11 SHORT TIRE: CASE NUMBER PLD P1-001(6) Exemplary Damages Attachment Page ATTACHMENT TO aa Complaint EZICross-Complaint EX-1. As additional damages against defendant (name): MARK D. MONTALVO Plaintiff alleges defendant was guilty of l malice Ca fraud an oppression as defined in Civil Code section 3294, and plaintiff should recover, In addition to actual damages, damages to make an example of and to punish defendant EX-2. The facts supporting plaintiffs claim are as follows: Defendant intentionally withheld critical passwords from Plaintiff and sabotaged its computer system as set forth above. EX-3. The amount of exemplary damages sought is a. CI not shown, pursuant to Code of Civil Procedure section b. S FJudlttraVoTteictallernitl ffie. Pt.D.PI-001(3) pow. arum./ Marto brew% EsTif rwilear Exemplary Damages Attachment Page l vt I Cock) of Ctvl ProceOure..covnr a