Rose Hills Complaint

7/31/2019 Rose Hills Complaint

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COMPLAINT1

ERIC J. DUBIN, ESQ., SBN: 160563DUBIN LAW FIRM19200 Von Karman Ave., Sixth FloorIrvine, California 92612Telephone: (949) 477-8040

JESSICA B. CHA, ESQ., SBN: 248071LAW OFFICES OF J.CHA & ASSOCIATES310 West 4TH StreetSanta Ana, California 92701Telephone: (714) 361-1421

Attorneys for PlaintiffsALBERTO PERNUDI, MARIELENA COVARRUBIAS, and PATRICIA KHAZRAEI

ALBERTO PERNUDI, MARIELENACOVARRUBIAS, and PATRICIAKHAZRAEI

Plaintiffs,

v.

ROSE HILLS MEMORIAL PARK,SERVICE CORPORATIONINTERNATIONAL, DIGNITYMEMORIAL NETWORKS, SCICALIFORNIA FUNERALSERVICES, INC, and DOES 1-100

Defendants.

CASE NO:

COMPLAINT FOR:

1. INTENTIONAL INFLICTION OF

EMOTIONAL DISTRESS;

2. NEGLIGENCE;

3. BREACH OF FIDUCIARY DUTY;

4. NEGLIGENT INFLICTION OF

EMOTIONAL DISTRESS;

5. TORTIOUS INTERFERENCE WITH RIGHT

TO DISPOSE OF REMAINS;

6. TORTIOUS INTERFERENCE WITH DEAD

BODIES;

7. EQUITABLE/INJUNCTIVE RELIEF;

8. VIOLATIONS OF BUSINESS &

PROFESSIONS CODE SECTION 17200;

9. VIOLATIONS OF BUSINESS &

PROFESSIONS CODE SECTIOM 17500;

10. FRAUD/CONCEALMENT/NEGLIGENT

MISREPRESENTATION

11. FRAUD/CONCEALMENT/INTENTIONAL

MISREPRESENTATION; AND

12.BREACH OF CONTRACT

SUPERIOR COURT OF THE STATE OF CALIFORNIAFOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT


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DEMAND FOR JURY TRIAL

JUDGE:

DEPT:

NATURE OF ACTION

1.This lawsuit challenges the morally despicable, fraudulent, unlawful and unfair businesspractices at Rose Hills Memorial Park, Service Corporation International, Dignity Memorial

Networks, and SCI California Funeral Services, Inc. (Defendants) who are the owners,

operators and managers of Rose Hills. Unfortunately, this is not the first time Defendant

Service Corporation International has been charged with engaging in horrific funeral practices.

2.The actions of Defendants are despicable and morally reprehensible and have causedsevere compensatory damages to Plaintiffs.

3.At all relevant times, Plaintiff, Alberto Pernudi was and is an individual residing inCalifornia is in the City of Pasadena, County of Los Angeles.

4.At all relevant times, Plaintiff, Marielena Covarrubias, was and is an individual residing inCalifornia is in the City of Whittier, County of Los Angeles.

5.At all relevant times, Plaintiff, Patricia Khazraei, was and is an individual residing inCalifornia is in the City of Temple City, County of Los Angeles.

6.Defendant Service Corporation International (SCI) is a Texas corporation. SCI is apublically traded company listed on the New York Stock Exchange under the symbol SCI.

SCI individually participated, ratified, approved and/or directed the improper or illegal acts and

omissions described herein. SCI provides death care services and products under the Dignity

Memorial brand name. At all times relevant hereto, Defendants owned, operated, managed and

were responsible for all business decisions of and at Rose Hills Memorial Park.7.Defendant SCI California Funeral Services, Inc, (SCI California) is a California

corporation authorized to do business and is engaged in business in Los Angeles County. SCI

California individually participated, ratified, approved and/or directed the improper or illegal

acts and omissions described herein. Defendant SCI California maintains its principal place of

business in Los Angeles County, California.


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28 COMPLAINT3

8.Defendant Rose Hills Memorial Park (Rose Hills) is a California Corporation authorizedto do business and is engaged in business in Los Angeles County. Rose Hills individually

participated, ratified, approved and/or directed the improper or illegal acts and omissions

described herein.

9.The true names and capacities of Defendants DOES 1 through 100, inclusive, whetherindividual, plural, corporate, partnership, associate or otherwise, are not known to Plaintiffs,

who therefore sues said Defendants by such fictitious names. Plaintiffs are informed and

believe and thereon allege that each of the Defendants designated herein as DOE are in some

manner responsible for the acts and occurrences set forth herein. Plaintiffs will ask leave of

court to amend this Complaint to show the true names and capacities of Defendants DOES 1

through 100, inclusive, as well as the manner in which each DOE defendant is responsible,

when the same have been ascertained.

10.Plaintiffs are informed and believe, and upon such basis allege, that at all times hereinmentioned, each of the Defendants herein were an agent, servant, employee, co-conspirator,

partner, joint venturer, wholly owned and controlled subsidiary and/or alter ego of each of the

remaining Defendants, and were at all times acting within the course and scope of said agency,

service, employment, conspiracy, partnership and/or joint venture.

11.Defendants, and each of them, aided and abetted, encouraged and rendered substantialassistance in accomplishing the wrongful conduct, wrongful goals and other wrongdoings

complained of herein. In taking action, as particularized herein, to aid and abet and

substantially assist the commission of the wrongful acts and other wrongdoings complained of,

each of the Defendants acted with an awareness of its primary wrongdoing and realized that its

conduct would substantially assist the accomplishment of the wrongful conduct, wrongful goals,

and other wrongdoing.

JURISDICTION AND VENUE

12.Pursuant to Los Angeles Superior Court Rule 2.3(a)(1)(B) venue is appropriate in theCounty of Los Angeles Central District. This Court has personal jurisdiction over the

Defendants and each of them by reason of the facts that: 1) Defendants have transacted and

conducted substantial business in the State of California, the County of Los Angeles, and the

Central District; 2) Plaintiffs injury occurred in the State of California and the County of Los


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Angeles; and 3) the events giving rise to the claims at issue in this lawsuit arose in California,

including within the County of Los Angeles and the Central District.

FACTUAL BACKGROUND

13.This lawsuit is brought by the children of Mercedes Adilia Rodriguez, in what has to bethe most horrific funeral home case in American history. The admitted unlawful conduct of

Rose Hills Memorial Park (Rose Hills), the Nations largest cemetery, is almost

unimaginable- shamefully desecrating two loving Mothers dignity, cultural traditions, and

religious beliefs leaving behind permanent pain and emotional trauma.

14.Mercedes Adilia Rodriguez was born on September 24, 1922 in the colonial city ofGranada, Nicaragua, which was founded by the Spaniards in 1620. People born in Granada are

very traditional and notorious for European idiosyncrasies - one being that Granadinians always

go back to Granada, alive or dead. If you are born in Granada you die in Granada or are laid to

rest in Granada. Underground burial is not permitted by tradition.

15.On September 30, 2010, Plaintiffs loving and warm-hearted Mother, MercedesRodriguez, died after devoting a lifetime to her three children, 11 grandchildren, and 2 great

grandchildren. Plaintiffs contracted Rose Hills to prepare their mother for burial at the familys

sacred above ground burial site at her birth place of Granada, Nicaragua to join her Mother and

Sister in eternal peace. The entire family was to travel to Nicaragua to greet her body at the

airport, and conduct the closed casket services and funeral their Mother had always requested

upon her passing. Underground burial is not permitted by tradition.

16.For this simple yet devastatingly important responsibility of ensuring their Mother safelyarrive in Nicaragua, Plaintiffs chose Rose Hills based on their proclaimed understanding and

compassion for the vast ethnic cultures and traditions in Southern California.

Rose Hills Memorial Park & Mortuaries provides comprehensivememorial care to Los Angeles County and Orange County families. We

have expertise in the funeral and burial traditions of many cultures,

and our team is proud to offer assistance in English, Spanish, Mandarin,

Cantonese, Korean and Vietnamese. - Rose Hills Website


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17.Like many culturally diverse and loving families in the areas of Rose Hills targetedmarkets, Plaintiffs trusted Rose Hills to understand and respect the critical importance of deep

rooted burial traditions, religions, and superstitious beliefs that so many Southern California

residents value to their core.

18.Instead, Rose Hills did the unthinkable; they lost track of Plaintiffs mother, placedher in the wrong casket, prepared and dressed her in a complete strangers clothes, and

horrifically presented her to the wrong family in an open casket funeral service, to be

mourned, touched, grieved, and then sacreligiously buried underground - violating her

lifelong cultural beliefs, superstitions, dying wishes, and personal convictions. Any and all

quality checks and procedures totally failed, and Rose Hills inexplicably presented the

Plaintiffs Mother to another family inexplicably ignorant of their catastrophic failure to

check body identifications on either women.

19.Plaintiffs are forever haunted by the vision of how a complete strangers family andfriends mourned, touched, kissed, and cried with Plaintiffs Mother, before sacrilegiously

burying her in a strangers plot. Like Plaintiffs, in the midst of their grief this strangers family

unconditionally trusted Rose Hills unfathomable misrepresentation that the woman placed in

their Mothers open casket was their Mother, and not a total stranger dressed up in her clothes

and accessories. The fact not a single Defendant employee ever checked, verified, or even

questioned that strangers were morning and burying Plaintiffs Mother warrants punitive

damages.

20.Plaintiffs Mother was buried underground in a strangers grave under a strangerstombstone for an appalling three rainy day and nights, sacrilegiously being violated of her

cultural beliefs and dying wish to never be buried underground. Plaintiffs were aware their

entire lives how their Mother feared to the bone being buried underground, often saying:

Debe de ser muy frio y yo soy muy friolenta (it must be very cold and I

am always cold). -Mercedes Adilia Rodriguez (1922-2010)

21.Three days after the wrongful burial, Rose Hills dug up Plaintiffs Mother in the middleof a rainy night, stripped the strangers clothes and accessories from her cold naked body, and

gave the other family a do-over funeral all concealed from Plaintiffs until after the fact.


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22.Plaintiffs were in the midst of preparing to travel to Nicaragua to meet their Mothersbody at the airport, to deliver her to her final place at the sacred, above ground cemetery in

Granada, Nicaragua, when a Rose Hills salesperson telephoned them with this crippling

revelation despite having first been advised by the husband of Marielena Covarrubias not to

communicate the revelation over the phone.

23.Rose Hills salesperson, Carmen Blue, engaged in even further intentional infliction ofemotional distress during the course and scope of her employment with Rose Hills, with her

outrageous response to this unlawful incompetence by telling the Plaintiffs:

Rose Hills had no obligation to notify the family as to what

happened, but they felt it was the right thing to do.

24.This statement of optional disclosure further adds to the Plaintiffs painful andreoccurring visions and nightmares - realizing how shockingly close their Mothers soul was

from being trapped underground in a strangers grave for eternity, never to be reunited to rest in

peace with her loved ones in Nicaragua.

25.The Plaintiffs were forced to view and identify their Mothers remains after she wascallously dug up in the middle of the night three (3) days post burial and eight (8) days post

mortem, adding a horrifying layer of trauma (a trauma that follows them to this day) that no

family should ever go through.

26.Rose Hills has since admitted full liability to the Department of Consumer AffairsCemetery and Funeral Bureau following its investigation into both occurrences.

27.The two elderly Hispanic women involved had the common last name Rodriguez, andRose Hills carelessly ignored all procedural safety checks, and treated these distinct and loving

Mothers interchangeably. The safety check system of Rose Hills was so reckless and flawed,

the same common last name of Rodriguez was all it took for this tragedy to occur; which, callsinto question Rose Hills prior and/or ongoing recklessness with the sacred remains of countless

of other deceased love ones.

28.Rose Hills unfathomable and unlawful conduct robbed Plaintiffs of the opportunity togrieve the passage of their Mother, replacing grief with anger and horror, and forever destroying


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the familys ability to lovingly remember their Mother, Grandmother, and Great Grandmother

without also remembering the nightmare inflicted by Rose Hills.

29.The entire family has been permanently traumatized. For example, Daughter Marielenahas been forever traumatized by nightmares that were unexplainable until Rose Hills admitted

their horrific conduct. In her nightmares, her Mother was screaming, scratching, and calling out

to her to get me out of here, not knowing the unspeakable truth that her premonitions were

devastatingly real - coinciding with the three nights her Mother was buried underground. Over

one year after her Mothers passing, Daughter Marielena is still devastatingly haunted by her

premonitions.

30.Rose Hills is owned by Service Corporation International (SCI). Unfortunately, thisis not the first time Defendant SCI has been charged with engaging in horrific funeral practices

bordering on the criminal. Recently at the National Funeral Home facility in Fairfax County,

Virginia, approximately 200 bodies were reported stored naked in various stages of

decomposition in conditions described as "disgusting, degrading and humiliating," including "at

least half a dozen veterans destined for the hallowed ground at Arlington National Cemetery.

SCI has also been subject to a $200 million dollar class action lawsuit in Florida, and another

class action in California.

31.SCIs ownership was concealed in all the Rose Hills documents, which the Plaintiffssigned unaware of SCIs extensive history of devastating families across the nation. Had

Plaintiffs known Rose Hills was owned and operated by a company such as SCI, they would not

have used any of Defendants services.

32.Rose Hills express and appalling admission that they made the optional decision toinform Plaintiffs of their unlawful conduct (even though they could have exercised their right

not to) begs the question of how many mistakes of this magnitude Rose Hills has made and then

made the decision to conceal - further warranting punitive damages. How many other

Rodriguezes, Smiths, Lees, or Wongs are buried in the wrong grave, in the wrong casket, theirsouls trapped eternally by Rose Hills obviously flawed verification system of alleged care and

competence?

///

///


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FIRST CAUSE OF ACTION

FOR INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

(AGAINST ALL DEFENDANTS AND DOES 1-100)

33.Plaintiffs restate and re-allege each and every allegation in the paragraphs 1 through 32as if fully set forth herein.

34.Defendants conduct as described herein was extreme and outrageous, and was soextreme as to exceed all bounds of that usually tolerated in a civilized society. Defendants

conduct as described herein was committed with the intent to cause, or with reckless disregard

of causing, emotional distress to Plaintiffs. Like many culturally diverse and loving families in

the areas of Rose Hills targeted markets, Plaintiffs trusted Rose Hills to understand and respect

the critical importance of deep rooted burial traditions, religions, and superstitious beliefs that

so many Southern California residents value to their core.

35.Rose Hills extreme and outrageous conduct is very clear: they lost track of Plaintiffsmother, placed her in the wrong casket, prepared and dressed her in a complete strangers

clothes, and horrifically presented her to the wrong family in an open casket funeral

service, to be mourned, touched, grieved, and then sacreligiously buried underground -

violating her lifelong cultural beliefs, superstitions, dying wishes, and personal convictions.

Any and all quality checks and procedures totally failed, and Rose Hills inexplicably

presented the Plaintiffs Mother to another family inexplicably ignorant of their

catastrophic failure to check body identifications on either woman.



unconditionally trusted Rose Hills unfathomable misrepresentation that the woman placed intheir Mothers open casket was their Mother, and not a total stranger dressed up in her clothes



damages.


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37.Plaintiffs Mother was buried underground in a strangers grave under a strangers tombstone for an appalling three rainy day and nights, sacrilegiously being violated of her

cultural beliefs and dying wish to never be buried underground. Plaintiffs were aware their






39.Rose Hills salesperson Carmen Blue intentionally further caused emotional distressunder course and scope of her employment with Rose Hills, when she intentionally disregarded

the plea from the husband of Daughter Marielena not to communicate the revelation to the

family over the phone. Carmen Blue caused even further emotional distress when she met with

the Plaintiffs and offered her outrageous response to this unlawful incompetence by telling the

Plaintiffs:






41.Furthermore, Plaintiffs repeated requests to speak with a manager or director ofoperations was ignored, only to later receive a letter from management self-proclaiming client

satisfaction for not charging Plaintiffs for the permanent devastation caused.

42.The emotional devastation the Defendants caused Plaintiffs is undeniable. Wordsused by the family to describe their pain, over a year later, include trauma, horror, anger,

humiliation, disrespect, emotional devastation, constant nightmares, ongoing feelings of


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being violated, anxiety attacks, trouble sleeping, difficulty concentrating, unbearable

mental anguish and pain, failure to grieve or recover, a sense of failure to their mother, and

so much stress that even divorce was contemplated by one.

43.Plaintiffs suffered and continue to suffer from severe or extreme emotional distress,which was actually and proximately caused by the Defendants outrageous conduct as set for

herein. Defendants undertook the aforesaid illegal acts intentionally or with conscious

disregard of the rights of Plaintiffs, and did so with fraud, oppression and/or malice.

44.Therefore, Plaintiffs are also entitled to punitive damages against Defendants in anamount to be determined at trial.

SECOND CAUSE OF ACTION

FOR NEGLIGENCE



46.By accepting the care, custody and control of the remains of Plaintiffs Mother, MercedesAdilia Rodriguez, Defendants undertook a duty of care to Plaintiffs. Defendants duty to

Plaintiffs included but were not limited to the following:

Not to ignore the family and loved ones express religious, cultural, traditional, andpersonal dying wishes;

Not to ignore contract and obligations; Not to ignore the individual life of all persons, regardless of ethnic, culture, or

appearances;

Not to ignore reasonable and required identification numbers and bracelets purportedsafety checks, merely because a deceased shared a common ethnic last name, and

appearance, even before displaying in an open casket and permanent burial;

Not to inter human remains in locations other than the plot in which the remains wereintended to be properly interred;

Not to lose the human remains of individuals;


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Not to intentionally, recklessly, and/or negligently publish, disseminate, circulateand/or place before the public, either directly or indirectly, statements that were

untrue; deceptive and/or misleading regarding the business patterns and practices at

Rose Hills.

To use reasonable care in all aspects of their cemetery, mortuary and funeral business; To handle and inter human remains in a proper and dignified manner; To hire and retain persons qualified and capable of providing proper cemetery,

mortuary and funeral related services;

To properly supervise their employees and make sure they were using reasonable carein providing the Plaintiffs with appropriate cemetery and funeral services;

To inspect, audit and correct body identification procedures and other relatedprocedures at Rose Hills.

To correct the numerous problems discussed in this complaint after Defendants knewor should have known of the problems without causing further trauma.

47.Defendants breached each of the above duties, and were negligent by failing to usereasonable care in virtually all aspects of their cemetery business, including but not limited to

those set forth below:

Ignoring the family and loved ones express religious, cultural, traditional, andpersonal dying wishes

Ignoring the contract and obligations; Ignoring the individual life Plaintiffs Mother (and stranger), regardless of ethnicity,

culture, or appearances;

Ignoring reasonable and required identification numbers, tags/bracelets and otherpurported safety checks, because the deceased shared a common ethnic last name and

similar appearances, even before displaying in an open casket and permanent burial.

Temporarily concealing the grotesque mishandling of remains, sand stating thatcorporate policy renders it optional for Defendants to disclose such egregious conduct

to the loved ones to whom they owed a duty of care;


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Interring decedents in locations other than the plot in which the remains wereintended to be properly interred;

Losing the human remains of individuals; Interring Plaintiffs Mother against express religious, cultural, traditional, and last

dying wishes;

Intentionally, recklessly, and/or negligently misinforming Plaintiffs as to the state andcondition of interment plots, services, interments, and human remains;

Intentionally, recklessly, and/or negligently publishing, disseminating, circulatingand/or placing before the public, either directly or indirectly, statements that were

untrue, deceptive and/or misleading regarding the business patterns and practices at

Rose Hills, Dignity, and SCI; Handling and interring human remains in an improper and undignified manner; Hiring and retaining persons not qualified and not capable of providing proper funeral

cemetery related services;

Not properly supervising their employees and making sure they were usingreasonable care in providing the Plaintiffs with appropriate interment services;

Failure to inspect, audit and/or correct ineffective body identification procedures andother related procedures as Rose Hills; and

Not correcting the numerous problems identified in this complaint after Defendantsknew or should have known of the problem.

48.Defendants knew, should have known or could reasonably foresee that their wrongfulacts and omissions would injure the Plaintiffs.

49.Defendants conduct as described herein was extreme and outrageous, and was so extremeas to exceed all bounds of that usually tolerated in a civilized society.

50.Plaintiffs are suffering from severe or extreme emotional distress, and Defendantsnegligence was a substantial factor in causing Plaintiffs severe or extreme emotional distress.

51.As a direct and proximate result of the negligence of Defendants, Plaintiffs suffered andcontinue to suffer the economic and non-economic damages.

52.Defendants failure to use reasonable care and their negligence in this case amount tooutrageous behavior that is not tolerated in our civilized society and community.


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53.Defendants acts and omissions amount to gross negligence tantamount to willful,wanton, and reckless conduct against the interests of the Plaintiffs.

54.Defendants knew or should have known that their serious failure to use reasonable areherein would results in damage to Plaintiffs.

THIRD CAUSE OF ACTION

FOR BREACH OF FIDUCIARY DUTY


55.Plaintiffs restate and re-allege each and every allegation contained in paragraphs 1through 54 above as if fully set forth herein.

56.By reason of the trust and confidence Plaintiffs placed in Defendants, and based on thefacts set forth above, Defendants owed Plaintiffs a fiduciary duty of loyalty and a duty to act in

the utmost good faith in all aspects of their ownership, operation, and management of Rose

Hills.

57.Defendants breached their duties to Plaintiffs by committing the acts set forth above. As adirect and proximate cause of the breach of fiduciary duties owed to Plaintiffs, Plaintiffs have

suffered damages in an amount to be proven at trial.

58.Defendants undertook the aforesaid illegal acts intentionally or with conscious disregardof the rights of Plaintiffs, and did so with fraud, oppression and/or malice. This despicable

conduct subjected Plaintiffs to cruel and unjust hardship so as to justify an award of punitive

damages in an amount sufficient to deter such wrongful conduct in the future. Accordingly,

Plaintiffs are entitled to punitive damages against Defendants in an amount to be determined at

trial.

FOURTH CAUSE OF ACTION

FOR NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS




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60.Defendants had a special duty to the Plaintiffs to care for the remains of the decedent bythe very nature of the services they provide. Defendants breach of this duty caused severe

emotional distress to Plaintiffs.

61.Defendants assumed a duty to the Plaintiffs thereby creating a special relationshipobligating them to perform those services in the dignified and respectful manner the Plaintiffs

expected from Defendants. Plaintiffs suffered severe emotional distress when Defendants

grossly mishandled and mistreated the remains of Plaintiffs Mother in ways unauthorized by

Plaintiffs, which were contrary to the wishes of the decedent, Plaintiffs, and their cultural

beliefs and traditions. Specifically, Defendants lost track of Plaintiffs mother, placed her in

the wrong casket, prepared and dressed her in a complete strangers clothes, and

horrifically presented her to the wrong family in an open casket funeral service, to be

mourned, touched, grieved, and then sacreligiously buried underground - violating her

lifelong cultural beliefs, superstitions, dying wishes, and personal convictions. Any and all

quality checks and procedures totally failed, and Rose Hills inexplicably presented the

Plaintiffs Mother to another family inexplicably ignorant of their catastrophic failure to

check body identifications on either woman.



unconditionally trusted Rose Hills unfathomable misrepresentation that the woman placed in

their Mothers open casket was their Mother, and not a total stranger dressed up in her clothes



damages.

63.Plaintiffs Mother was buried underground in a strangers grave under a strangerstombstone for an appalling three rainy day and nights, sacrilegiously being violated of hercultural beliefs and dying wish to never be buried underground. Plaintiffs were aware their





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65.Rose Hills salesperson Carmen Blue intentionally further caused emotional distressunder course and scope of her employment with Rose Hills, when she intentionally disregarded

the plea from the husband of Daughter Marielena not to communicate the revelation to the

family over the phone. Carmen Blue caused even further emotional distress when she met with

the Plaintiffs and offered her outrageous response to this unlawful incompetence by telling the

Plaintiffs:






67.Furthermore, Plaintiffs repeated requests to speak with a manager or director ofoperations were ignored, only to later receive a letter from management self-proclaiming client

satisfaction for not charging Plaintiffs for the permanent devastation caused.

68.Defendants actions were not only a substantial factor in causing the severe emotionaldistress suffered by Plaintiffs, they were the only factor causing the severe emotional distress

suffered by Plaintiffs resulting from egregious mistreatment of their Mothers remains.

69.The emotional devastation suffered by Plaintiffs is undeniable. Plaintiffs havedescribe their pain as feelings of horror, anger, humiliation, disrespect, emotional

devastation, constant nightmares, ongoing feelings of being violated, anxiety attacks,

trouble sleeping, difficulty concentrating, unbearable mental anguish and pain, failure to

grieve or recover, a sense of failure to their mother, and so much turmoil that even divorce

was contemplated by one of the plaintiffs.

70.No reasonable person, normally constituted, would be able to cope with the type ofmental stress and anguish caused by the present actions of the Defendants. Defendants conduct


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as described herein was extreme and outrageous, and was so extreme as to exceed all bounds of

that usually tolerated in a civilized society.

71.Plaintiffs suffered and continue to suffer from severe or extreme emotional distress,which was actually and proximately caused by the Defendants outrageous conduct as set for

herein.

72.Accordingly, Plaintiffs are entitled to punitive damages against Defendants in an amountto be determined at trial.

FIFTH CAUSE OF ACTION

FOR TORTIOUS INTERFERENCE WITH RIGHT TO DISPOSE OF REMAINS


73.Plaintiffs restate and re-alleges each and every allegation in the paragraphs 1 through 72as if fully set forth herein.

74.By reason of the relationship between Plaintiffs and the decedent, Plaintiffs were at alltimes herein mentioned entitled to control their deceased Mothers remains.

75.Defendants have intentionally, willfully, recklessly and/or negligently interfered withPlaintiffs rights to control the remains of their deceased Mothers remains, contrary to the

wishes and beliefs of Plaintiffs and decedent, by committing the acts described herein. This

interference was intentional, willful, reckless and/or negligent in that Defendants actions herein

are illegal, improper, and immoral in that Defendants failed to inform Plaintiffs of the acts

described herein prior to or immediately after committing the tortious activity.

76.Defendants disposition of human remains is and was repugnant, offensive, and insultingto Plaintiffs, their beliefs, and a civilized society. Learning of Defendants conduct described

herein caused and continues to cause the Plaintiffs extreme mental anguish and disgust,

disturbing their peace of mind causing them to become permanently sick in the mind and body.77.As a direct and proximate cause of the intentional, willful, reckless, and/or negligent acts

of Defendants, Plaintiffs suffered and continue to suffer the economic and non-economic

damages.

78.Defendants undertook the aforesaid illegal acts intentionally or with conscious disregardof the rights of Plaintiffs, and did so with fraud, oppression and/or malice. This despicable


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trial.

SIXTH CAUSE OF ACTION

FOR TORTIOUS INTERERENCE WITH DEAD BODIES



80.Defendants owed Plaintiffs a duty to exercise reasonable and proper care when handlingthe remains of Plaintiffs Mother. The duties include, but are not limited to, those set forth in

paragraph 46 above.

81.Defendants conduct of maliciously, intentionally, recklessly, or negligently removing,withholding, mutilating, or operating upon the Plaintiffs Mother or preventing the proper burial

or cremation of the Plaintiffs Mother, in addition to the conduct described in the paragraphs

above, demonstrates a wanton disregard for care of or attention to their duties, and a callous

indifference to the remains, property and property rights of others. Defendants conduct is

outrageous and goes beyond all bounds of decency in a civilized society.

82.Defendants conduct has directly and proximately caused and continues to causeeconomic and non-economic damages to Plaintiffs. Plaintiffs have and will continue to suffer

extreme mental anguish, distress and suffering.

83.Defendants could reasonably foresee that their wrongful acts and omissions woulddamage the Plaintiffs in the manner set forth above.

84.Defendants undertook the aforesaid illegal acts intentionally or with conscious disregardof the rights of the Plaintiffs, and did so with fraud, oppression and/or malice. This despicable




trial.


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28 COMPLAINT18

SEVENTH CAUSE OF ACTION

FOR EQUITABLE/INJUNCTIVE RELIEF


85.Plaintiff restates and re-alleges each and every allegation contained in paragraphs 1through 84 above as if fully set forth herein.

86.Plaintiffs request equitable and injunctive relief to ensure Defendants body identificationprocedures and processes and related services are overhauled, employees are properly trained to

prevent the type of egregious errors committed by Defendants above, and to prevent further

immoral and/or unlawful practices akin to those described the paragraphs above.

87.Injunctive relief is in the public interest. The proper disposition of human remains issacred and is last moment for the decedents family and loved ones to pay their respects and lay

the decedent to rest in their final resting place. These matters are of the utmost importance once

a loved one has passed and the public has a strong interest in insuring that these matters are

conducted properly.

88.The foregoing injunction is appropriate because, among other reasons, it is necessary toinsure that other decedents, with similar ethnic names, are properly laid to rest. Equity supports

the requested injunctive relief because Defendants committed the egregious acts described

above.

89.As a direct and proximate cause of the aforementioned wrongful acts and omissions bythe Defendants, many other families will be uncertain as to the location and disposition of their

family members remains and/or the remains of other decedents. Defendants conduct cannot

and will not be abated without the requested injunction. There is no other adequate remedy at

law for this objective.

90.Plaintiffs request a permanent injunction that requires, among others, that Defendantsfund a court supervised program that provides for the inspection of records, evaluation of bodyidentification processing and procedures, and monitoring of Defendants business practices to

ascertain whether the decedents interred at Defendants properties are interred in their intended

locations and under the correct name.

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28 COMPLAINT19

EIGHTH CAUSE OF ACTION

FOR VIOLATION OF BUSINESS AND PROFESSIONS CODE 17200 ET. SEQ.


91.Plaintiffs restate and re-allege each and every allegation in paragraphs 1 through 90 as iffully set forth herein.

92.Defendants aforementioned conduct constitutes an unlawful business practice withinthe meaning of the California Unfair Competition Law, and violates numerous other California

statutes, including but not limited to:

a) Health & Safety Code 7051, by removing parts of human remains from places where

they have been interred, and doing so with malice and wantonness.

b) Health & Safety Code 7500 et seq., by removing the remains of a deceased person

from a cemetery without the requisite legal authorization and consent.

c) Business & Professions Code 7735.5, by not clearly stating in preneed funeral

contracts that competent services were unavailable or limited by the patterns and

practices of Defendants described above.

d) Business & Professions Code 9725.1, for violating or attempting to violate, directly or

indirectly, or assisting in or abetting the violation of laws governing the disposition of

human remains, operation of cemeteries, and/or the sale of cemetery property, and for

negligence in performing acts related to the operation of a cemetery.

e) California Civil Code 1709-1710 for misrepresenting, or failing to disclose, the

patterns and practices of Defendants described above.

93.Defendants conduct in failing to disclose the above-described problems to Plaintiffsdescribed above also constitutes a fraudulent business practice within the meaning of the

California Unfair Competition Law.

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28 COMPLAINT20

NINETH CAUSE OF ACTION

FOR VIOLATIONS OF BUSINESS AND PROFESSIONS CODE 17500, ET. SEQ.


94.Plaintiffs restate and re-allege each and every allegation contained in paragraphs 1through 1 and 93 above as if fully set forth herein.

95.Defendants made representations to Plaintiffs, including but not limited to, that theremains of loved ones would be handled in a dignified and respectful manner. These

representations were made as part of a concerted and comprehensive effort by Defendants to

solicit the Plaintiffs and other unsuspecting families, to patronize the products and/or services

provided by Defendants.

96.The representations appear habitually in written documents, which were, on informationand belief, provided to Plaintiffs. These representations can also be found on the websites of

Defendants and other written forms. In making representations to Plaintiffs, Defendants

concealed and failed to disclose their true practices as described above. The representations

and/or failures by Defendants to disclose such information were part of a continuing scheme

and ongoing campaign to falsify, mislead, or otherwise unlawfully advertise the products or

services of

97.Plaintiffs are informed and believe the affirmative representations made by Defendantswere false when made as Defendants did not believe them to be true when they were made

and/or the representations were made with reckless disregard to truthfulness. As alleged above,

it was also the policy, practice, and intended program of Defendants to mishandle human

remains. Defendants SCI and Dignity were already engaging in undignified and disrespectful

acts around the nation, and were instructing their employees to exercise their options to conceal

those practices.

98.In addition to the representations of Defendants being false, the representations were alsomisleading as they failed to disclose the described practices of Defendants in mistreating

families and human remains. Defendants failed to disclose their gross misconduct conduct to the

Plaintiffs until after the fact, after more gross mishandling of their Mother occurred.

99.Defendants fraudulently failed to disclose that because they had a common last name,Rodriguez, representations of a secure check and verification system were not applicable to the


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28 COMPLAINT21

family. Defendants further fraudulently concealed, and failed to disclose, that Plaintiffs mother

was displayed at the wrong familys open casket funeral, buried underground in a strangers plot,

and then dug up in the middle of a rainy night. Defendants fraudulently failed to disclose this

information to the Plaintiffs until Defendants took independent, unauthorized, and illegal action

and after a third party was informed. All the actions taken by the Defendants were in

diametrical opposition to the representations made by Defendants that they handled remains in a

dignified and respectful manner.

100.The fiduciary relationship and the relationship of trust and confidence betweenPlaintiffs, on the one hand, and the Defendants, on the other, placed a higher standard on

Defendants to provide candid, honest, and forthright immediate communications to Plaintiffs,

including problems or inhumane conduct, disturbances, false services, religious violations,

breaches in the contract, within, and the overall practices and procedures engaged in by

Defendants to maintain the loved one in question. Without the Defendants upholding their duty,

the Plaintiffs would never be able to ascertain the materiality of the information. The material

facts of the egregious error as well as the business information (including the various licenses

they were required to hold) were solely within Defendants knowledge and could not have been

independently discovered by Plaintiffs.

101.Defendants consistently failed to make the material disclosures described above. Rather,the only disclosures made by Defendants were the inaccurate representations that they were

committed to maintaining a beautiful and peaceful environment for [Plaintiffs] loved ones

final resting place that will last for many generations to come and that Defendants Dignity

Memorial brand comes with an assurance of quality, value, caring service and exceptional

customer satisfaction. Service Corporation International is dedicated to compassionately

serving families at difficult times, celebrating the significance of lives that have been lived, and

preserving memories that transcend generations, with dignity and honor.

102.The most egregious and abhorrent of false representations is made by Rose Hills, whichmarkets aggressively to the very ethnic communities that appear to subjected to the most harm,

Rose Hills Memorial Park & Mortuaries provides comprehensive memorial care to Los

Angeles County and Orange County families. We have expertise in the funeral and burial

traditions of many cultures, and our team is proud to offer assistance in English, Spanish,

Mandarin, Cantonese, Korean and Vietnamese. - Rose Hills


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28 COMPLAINT22

103.Like many culturally diverse and loving families in the areas of Rose Hills targetedmarkets, Plaintiffs trusted Rose Hills to understand and respect the critical importance of the

individuality of their loved one even after passing, deep rooted burial traditions, religions, and

superstitious beliefs that so many Southern California residents value to their core.

104.Nonetheless, in defiance of these duties, Defendants engaged in repeated acts of falseadvertising and wrongful conduct, as described above, to the material detriment of Plaintiffs,

which were contrary to the very representations and the impressions Rose Hills marketed

aggressively to portray to the public.

105.Defendants alleged advertising scheme of marketing selective representations describedherein was propagated with the intent to directly or indirectly mislead Plaintiffs and the general

public. These representations were in fact untrue and/or misleading and likely to deceive

Plaintiffs and the general public. In making and disseminating the statement(s) herein alleged,

Defendants knew, or by the exercise of reasonable care should have known, that the

statement(s) was/were untrue or misleading and so acted in violation of Business and

Professions Code Section 17500.

106.Plaintiffs have no adequate remedy at law, and unless the Defendants are restrained,Defendants will continue to engage in untrue and misleading advertising, as alleged above, in

violation of Business and Professions Code Section 17500.

107.Plaintiffs material payment of money was a direct result of the aggressive falseadvertising campaign engaged in by Defendants. Plaintiffs would not have paid had they known

of the false advertising engaged in by Defendants.

108.Plaintiffs have also suffered material emotional distress and other damage due to thefalse advertising conduct by Defendants. The material loss was caused directly by the acts of

Defendants in falsely advertising their products/services in question. Plaintiffs would never

have patronized the business of Defendants had they not been misled by Defendants false and

misleading advertising.///

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28 COMPLAINT23

TENTH CAUSE OF ACTION

FRAUD/CONCEALMENT/ NEGLIGENT MISREPRESENTATION



110.Defendants recklessly, and/or negligently represented, concealed and/or failed todisclose the material facts. Defendants representations described above were in fact false.

Defendants do not provide dignified and respectful service to the decedent and Defendants do

not compassionately serve decedents families in their most difficult time of trying to celebrate

the significance of lives that have been lived, and preserving memories that transcend

generations, with dignity and honor. Defendants do not value or have expertise in the types

of sacred cultural burial traditions they purport to value and proudly claim on their websites.

Defendants accept the sacred responsibility of honoring cultural customs and traditions with

false promises of competence, compassion, and care. Defendants services lack quality, value

and caring for the reasons set forth above. Defendants statements were made with the intent to

deceive Plaintiffs.

111.Defendants made similar representations to Plaintiffs at the time Plaintiffs engagedDefendants services. Plaintiffs were entirely ignorant of the falsity of the Defendants

representations and believed them to be true. Plaintiffs relied on Defendants representations

and had Plaintiffs known of the known the actual facts, Plaintiffs would not have taken the

actions they did, including but not limited to entering a contract with Rose Hills, and entrusting

Defendants with the remains of their beloved Mother.

112.Defendants concealment and non-disclosure of material facts as set forth above weremade with the intent to induce the Plaintiffs to act in the manner herein alleged in reliance

thereon. Defendant Rose Hills concealed all ties with SCI, a company known for horrificpractices nationwide.

113.Plaintiffs reliance was justified and reasonable as they had no basis to doubt therepresentations made to them, nor did they have reason to believe they were being misled or

that material facts were being concealed from them, including the history of horrific conduct by

SCI.


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28 COMPLAINT24

114.Plaintiffs reliance on Defendants representations were justified. Defendantsconcealments and non-disclosure of material facts as set forth above were made with the intent

to induce the Plaintiffs to act in the manner herein alleged in reliance thereon. Defendant Rose

Hills concealed all ties with SCI, a company known for horrific national conduct

115.Plaintiffs, at the time these failures to disclose the suppressions of facts occurred and atthe time the Plaintiffs took the actions herein alleged, were ignorant of the existence of the facts

that the Defendants suppressed and failed to disclose. If the Plaintiffs had known of

Defendants concealments and failures to disclose material facts, they would not have taken the

actions they did, including hiring Rose Hills and entrusting Defendants with the remains of

their Mother.

116.As a direct and proximate cause of the above, Plaintiffs have suffered economic andnon-economic damages in an amount to be proven at trial.

ELEVENTH CAUSE OF ACTION

FOR FRAUD/CONCEALMENT/ INTENTIONAL MISREPRESENTATION



118.Defendants intentionally concealed and/or failed to disclose the material facts.Defendants representations described above were in fact false. Defendants do not provide

dignified and respectful service to the decedent and Defendants do not compassionately serve

decedents families in their most difficult time when they are trying to celebrate the significance

of lives that have been lived, and preserving memories that transcend generations, with

dignity and honor. Defendants do not value or have expertise in the types of sacred cultural

burial traditions they purport to value and proudly claim on their websites. Defendants acceptthe sacred responsibility of honoring cultural customs and traditions with false promises of

competence, compassion, and care. Defendants services lack quality, value and caring for the

reasons set forth above. Defendants statements were made with the intent to deceive Plaintiffs.

119.Defendants made similar representations to Plaintiffs at the time Plaintiffs engagedDefendants services. Plaintiffs were entirely ignorant of the falsity of Defendants


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28 COMPLAINT25

representations and believed them to be true. Plaintiffs relied on Defendants representations

and had Plaintiffs known of the known the actual facts, Plaintiffs would not have taken the

actions they did, including but not limited to entering a contract with Rose Hills, and entrusting

Defendants with the remains of their beloved Mother.

120.Defendants concealment and non-disclosure of material facts as set forth above weremade with the intent to induce the Plaintiffs to act in the manner herein alleged in reliance

thereon. Defendant Rose Hills concealed all ties with SCI, a company known for horrific

practices nationwide.

121.Plaintiffs reliance was justified and reasonable as they had no basis to doubt therepresentations made to them, nor did they have reason to believe they were being misled or

that material facts were being concealed from them, including the history of horrific conduct by

SCI. Plaintiffs reliance on the Defendants representations was justified.

122.Plaintiffs, at the time these failures to disclose the suppressions of facts occurred and atthe time the Plaintiffs took the actions herein alleged, were ignorant of the existence of the facts

that the Defendants suppressed and failed to disclose. If the Plaintiffs had known of

Defendants concealments and failures to disclose material facts, they would not have taken the

actions they did, including hiring Rose Hills and entrusting Defendants with the remains of

their Mother.

123.As a direct and proximate cause of the above, Plaintiffs have suffered economic andnon-economic damages in an amount to be proven at trial.

124.Defendants undertook the aforesaid illegal acts intentionally or with conscious disregardof the rights of Plaintiffs and did so with fraud, oppression and/or malice. This despicable




trial.///

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28 COMPLAINT26

TWELFTH CAUSE OF ACTION

FOR BREACH OF CONTRACT

(AGAINST ROSE HILLS ONLY AND DOES 1-100)


126.The contract upon which this action is based was made and was to be performed in theCounty of Los Angeles, State of California.

127.Plaintiffs entered into contract #440974 with Rose Hills on September 30, 2010 for thepreparation their Mothers remains for shipment to and burial in Granada, Nicaragua pursuant to

the last wishes of the decedent and the surviving family members. Plaintiffs agreed to a total

contract price of $8,120.26 for the casket, preparation services, transportation and other

necessary services to be performed by Rose Hills.

128.Plaintiffs performed all of the conditions, covenants and promises required by them tobe performed in accordance with the terms and conditions of the contract, by providing payment

to Rose Hills for any and all balances owed under the contract.

129.Rose Hills breached the contract when they lost track of Plaintiffs mother, placed her inthe wrong casket, prepared and dressed her in a complete strangers clothes, and horrifically

presented her to the wrong family in an open casket funeral service, to be mourned, touched,

grieved, and then sacrilegiously buried underground - violating her lifelong cultural beliefs,

superstitions, dying wishes, and personal convictions. Any and all quality checks and

procedures totally failed, and Rose Hills inexplicably presented the Plaintiffs Mother to another

family inexplicably ignorant of their catastrophic failure to check body identifications on either

woman.

130.Rose Hills breached their contract with Plaintiffs, who have been damaged thereby inthe sum of $8,120.26 plus interest at the legal rate from and after the date due according toproof.

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28 COMPLAINT27

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs pray for judgment against Defendants, and each of them, as

follows:

ON THE FIRST CAUSE OF ACTION FOR INTENTIONAL INFLICTION OF

EMOTIONAL DISTRESS

a. For damages with the exact amount to be proven at trial;

b. For punitive damages in an amount sufficient to punish the Defendants and to deter

them from engaging in wrongful conduct in the future;

c. An award of suitable equitable, injunctive and/or declaratory relief;

d. For costs of suit incurred herein;

e. For attorneys fees incurred herein; and

f. For such other and further relief as the Court may deem just and proper.

ON THE SECOND CAUSE OF ACTION FOR NEGLIGENCE


b. For interest and costs of suit incurred herein;

c. For attorneys fees incurred herein; and

d. For such other and further equitable relief as the Court may deem just and proper.

ON THE THIRD CAUSE OF ACTION FOR BREACH OF FIDUCIARY DUTY




c. An award of suitable equitable, injunctive and/or declaratory relief;d. For costs of suit incurred herein;




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28 COMPLAINT28

ON THE FOURTH CAUSE OF ACTION NEGLIGENT INFLICTION OF EMOTIONAL

DISTRESS








ON THE FIFTH CAUSE OF ACTION FOR TORTIOUS INTERERENCE WITH RIGHT

TO DISPOSE OF REMAINS








ON THE SIXTH CAUSE OF ACTION FOR TORTIOUS INTERFERENCE WITH DEAD

BODIES




c. An award of suitable equitable, injunctive and/or declaratory relief;d. For costs of suit incurred herein;



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28 COMPLAINT29

ON THE SEVENTH CAUSE OF ACTION FOR EQUITABLE/INJUNCTIVE RELIEF

a. For damages and/or restitution, with the exact amount to be proven at trial;

b. An award of suitable equitable, injunctive and declaratory relief;

c. For interest and costs of suit incurred herein;

d. For attorneys fees incurred herein; and

e. For such other and further equitable relief as the Court may deem just and proper.

ON EIGHTH CAUSE OF ACTION FOR VIOLATIONS OF BUSINESS & PROFESSIONS

CODE SECTION 17200








ON NINTH CAUSE OF ACTIONFOR VIOLATIONS OF BUSINESS & PROFESSIONS

CODE SECTIOM 17500







f. For such other and further relief as the Court may deem just and proper.///

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28 COMPLAINT30

ON TENTH CAUSE OF ACTION FOR FRAUD/CONCEALMENT/NEGLIGENT

MISREPRESENTATION








ON ELEVENTH CAUSE OF ACTION FOR FRAUD/CONCEALMENT/ INTENTIONAL

MISREPRESENTATION








ON TWELFTH CAUSE OF ACTION FOR BREACH OF CONTRACT




c. For costs of suit incurred herein;

d. For attorneys fees incurred herein; ande. For such other and further relief as the Court may deem just and proper.


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Rose Hills Complaint

Documents

Transcript of Rose Hills Complaint