WILLIAM MCGRANE [057761] MATTHEW SEPUYA [287947] … Amended Complaint for Pe… · 1. Plaintiff...

First Amended Complaint for Penal Fines for Misuse of Personally Identifiable Information

Sanket Vinod Thakur, et. al. v. Cofiroute USA, LLC

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WILLIAM MCGRANE [057761] MATTHEW SEPUYA [287947] MCGRANE PC Four Embarcadero Center, 14th Floor San Francisco, CA 94111 Telephone: (415) 292-4807 [email protected] [email protected]

Additional firms listed on the following page

Attorneys for Plaintiffs Sanket Vinod Thakur, an individual person, and Mathew Skogebo, an individual, on behalf of themselves and all other persons and entities similarly situated.

SUPERIOR COURT

IN AND FOR THE COUNTY OF SAN DIEGO

STATE OF CALIFORNIA

SANKET VINOD THAKUR, an individual person and MATHEW SKOGEBO, an individual person, on behalf of themselves and all other persons and entities similarly situated,

Plaintiffs, v.

COFIROUTE USA, LLC, a Delaware limited liability company, ORANGE COUNTY TRANSPORTATION AUTHORITY, a California governmental entity and RIVERSIDE COUNTY TRANSPORTATION COMMISSION, a California governmental entity

Defendants.

Case No. 37-2018-00059425-CU-MC-CTL

CLASS ACTION

FIRST AMENDED COMPLAINT FOR PENAL FINES FOR MISUSE OF PERSONALLY IDENTIFIABLE INFORMATION



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MICHAEL HASSEN [124823] REALLAW PC 1981 N. Broadway, Suite 280 Walnut Creek, CA 94596 Telephone: (925)-359-7500 [email protected]

MICHAEL WALSH [155401] The Walsh Firm, PC 38 Corporate Park Irvine, CA 92606 Telephone: (949)-724-1350 [email protected]

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Come now Plaintiffs and allege as follows:

Parties

1. Plaintiff Sanket Vinod Thakur (Thakur) is an individual person residing in San

Diego County, California, within the boundaries of San Diego County that are subject to the

jurisdiction of the Central Division of the San Diego Superior Court.

2. Plaintiff Mathew Skogebo (Skogebo) is an individual person.

3. Thakur and Skogebo are hereafter collectively referred to as Motorists.

4. Motorists bring this action as a putative class action on behalf of themselves and

all other persons and entities similarly situated.

5. Defendant Cofiroute USA, LLC (CUSA) is a Delaware limited liability company

with its principle place of business in Orange County, California.

6. Defendant Orange County Transportation Authority (OCTA) is a California

governmental entity with its principle place of business in Orange County, California.

7. Defendant Riverside County Transportation Commission (RCTC) is a California

governmental entity with its principle place of business in Riverside County, California.

8. CUSA, OCTA, and RCTC are sometimes hereafter collectively referred to as

Defendants.

Jurisdiction and Venue

9. This Court has jurisdiction over this case because the alleged violations of Streets

& Highway Code §§ 31490(a) and 31490 (k) (the PII Violations) as described, infra, all occurred

in California.

10. Venue is appropriate in San Diego County because San Diego County is where

the relevant cause of action for penal fines, or some part of that cause of action, first arose. See

Code of Civil Procedure § 393(a).



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Limitation of Actions

11. To the extent this putative class action is brought by Class Members (as that term

is defined, infra) who are non-individual business entities against CUSA only, the applicable

statute of limitations is Code of Civil Procedure section 343, which, absent tolling, runs four

years from occurrence.


is defined, infra) who are individual persons against CUSA only, the applicable statute of

limitations is Code of Civil Procedure section 340(a), which, absent tolling, runs one year from

discovery.


is defined, infra) against OCTA and RCTC, California Government Code section 912.4 provides

that a claim made against a California governmental entity is barred after one year from the date

of occurrence.

14. On October 11, 2018, Thakur served OCTA with a class action administrative

claim consistent with the allegations made in this First Amended Complaint etc. against OCTA,

which claim was denied by OCTA on November 29, 2018. See Exhibit 1.

15. On October 15, 2018, Skogebo served RCTC with a class action administrative

claim consistent with the allegations made in this First Amended Complaint etc. against RCTC,

which claim was denied by RCTC on November 28, 2018. See Exhibit 2.

16. The various statutes of limitation applicable to CUSA (but not applicable to

OCTA and RCTC) in this case have been tolled since no later than July 16, 2018, at which time

an initial complaint in Chavez v. Cofiroute USA, LLC, Orange County Superior Court Case No.

30-2018-01005771-CU-MC-CXC (the Chavez Case) was first filed and served, thereby putting

CUSA on notice that it had potential liability in one or more class action proceedings on account

of its having sent out the 23302(b) Toll Evasion Notices (as that term is defined, infra) during the

Relevant Period (as that term is defined, infra).

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Charging Allegations

17. All during the Relevant Period, Defendants have each acted as the agents of the

others in doing and failing to do all of the things alleged in this First Amended Complaint, etc.

18. CUSA is a transportation agency operating an electronic toll collection system

with respect to a toll highway (91 Express Lanes) that is partially owned by OCTA and partially

owned by RCTC.

19. The terms transportation agency, electronic toll collection system and toll

highway, supra, as employed throughout this Complaint, are all otherwise defined in Streets &

Highway Code §§ 31490(l)-(m).

20. Motorists drove the 91 Express Lanes without a valid FasTrak® account during

the Relevant Period (as that term is defined, infra) in violation of Vehicle Code § 23302.5

(Motorists’ 23302.5 Violations).

21. Responding to Motorists’ 23302.5 Violations, CUSA sent Motorists and Class (as

that term is defined, infra) Notices of Toll Evasion Violation and/or Notices of Delinquent Toll

Evasion Violation (collectively 23302(b) Toll Evasion Notices). Copies of these 23302(b) Toll

Evasion Notices are attached hereto as Group Exhibit 3.

22. On their face, the 23302(b) Toll Evasion Notices advertised 91 Express Lanes-

related services to nonsubscribers of the 91 Express Lanes.

23. On their face, the 23302(b) Toll Evasion Notices constituted an ultra vires act by

CUSA in that the content of the 23302(b) Toll Evasion Notices disregarded (i) the requirements

of OCTA’s Ordinance No. 2010-1 at §§ 2(d) and 3(c)(2) and (ii) the parallel requirements of

RCTC’s Ordinance No. 16-001 § 3(d) (collectively, the 23302.5 OCTA/RCTC Ordinances) by

virtue of the 23302(b) Toll Evasion Notices’ misidentification of the section of the Vehicle Code

Motorists 23302.5 Violations had violated as if it was Vehicle Code § 23302(b) as opposed to its

correctly being Vehicle Code § 23302.5 and only Vehicle Code § 23302.5.

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24. The ultra vires nature of the 23302(b) Toll Evasion Notices has recently been

made the subject of a binding judicial admission on the part of CUSA’s two principles, OCTA

and RCTC, which two governmental agencies, in direct response to a writ petition Motorists had

previously filed against them (see, e.g., Thakur et. al. v. Orange County Transportation

Authority et. al., Orange County Superior Court Case No. 30-2018-01025555-CU-WM-CJC),

immediately required that CUSA correct the form of the 23302(b) Toll Evasion Notices by

substituting new toll evasion notices (the form of which new toll evasion notices was specifically

approved by OCTA and RCTC [23302.5 Toll Evasion Notices]) in the place and stead of the

23302(b) Toll Evasion Notices.

25. The 23302.5 Toll Evasion Notices first went into use on November 1, 2018.

Copies of the forms of these 23302.5 Toll Evasion Notices previously provided to Motorists’

counsel by OCTA and RCTC are attached as Group Exhibit 4.

26. On their face, the 23302.5 Toll Evasion Notices now properly identify Vehicle

Code § 23302.5 as the sole and only provision of the Vehicle Code which any motorists driving

the 91 Express Lanes without a valid FasTrak® account may correctly be charged with violating.

27. On their face, the 23302.5 Toll Evasion Notices do not advertise 91 Express

Lanes-related services to nonsubscribers of the 91 Express Lanes.

28. However, and between January 1, 2011, and October 31, 2018 (the Relevant

Period), the 23302(b) Toll Evasion Notices all advertised 91 Express Lanes-related services to

nonsubscribers of the 91 Express Lanes using such nonsubscribers personally identifiable

information—as that term is defined by Streets & Highway Code § 31490(o)—which personally

identifiable information had initially been collected by CUSA acting in its capacity as the

transportation agency that operated an electronic toll collection system for OCTA and RCTC

with respect to the 91 Express Lanes (PII).

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29. Defendants conduct respecting the 23302(b) Toll Evasion Notices was punishable

in every instance by the imposition of mandatory penal fines ranging from $2,500 to $4,000 (the

PII Penal Fines) as is otherwise set forth in Streets & Highway Code § 31490(q)(1)-(2), in that,

inter alia, CUSA, acting in its capacity as the transportation agency that operated an electronic

toll collection system for OCTA and RCTC with respect to the 91 Express Lanes, knowingly

provided PII to third parties, to wit and inter alia, the United States Post Office, in order to

facilitate such third parties’ delivery of the 23302(b) Toll Evasion Notices to the Class Members

(as that term is defined, infra).

30. Defendants may not rely on the sole exception (the § 23302 Exception) to Streets

& Highway Code § 31490(k) which permits “advertising of toll-related products or services

contained in a notice of toll evasion issued pursuant to Section 23302 of the Vehicle Code” for

the following reasons:

a. As a matter of law, the 23302(b) Toll Evasion Notices were not and could

not have been “issued pursuant to Section 23302 of the Vehicle Code” because the

23302(b) Toll Evasion Notices were directly contrary to the mandate of the 23302.5

OCTA/RCTC Ordinances, which 23302.5 OCTA/RCTC Ordinances had been passed by

the boards of both OCTA and RCTC in the exercise of their broad legislative

discretion to make Vehicle Code § 23302.5 the sole and only provision of the Vehicle

Code that CUSA had any right to charge motorists with violating by virtue of their

driving the 91 Express Lanes without a valid FasTrak® account during the Relevant

Period.

b. Put another way, CUSA was implicitly forbidden by the 23302.5

OCTA/RCTC Ordinances from charging motorists with violating the criminal Vehicle

Code § 23302 (as opposed to the civil Vehicle Code § 23302.5) because such motorists

had driven the 91 Express Lanes without a valid FasTrak® account during the Relevant

Period.

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c. Treating Vehicle Code § 23302 and Vehicle Code § 23302.5 as being in any

manner equivalent statutes for purposes of construing the extent of the § 23302 Exception

would ignore the plain meaning of the § 23302 Exception in violation of well-established

rules of statutory construction. See, e.g., San Diego Union v. City Council, 146 Cal. App.3d

947, 954 (1983) (citing 58 Cal.Jur.3d, Statutes, § 116, p. 505 for the twin propositions (i)

that express exceptions to any general statutory rule should always be strictly and narrowly

construed and (ii) that such express exceptions should never be extended to include things

other than those which were clearly contemplated by the actual language of such express

exceptions).

d. Treating Vehicle Code § 23302 and Vehicle Code § 23302.5 as being in any

manner equivalent statutes for purposes of construing the extent of the § 23302 Exception

would also violate strong public policy by arbitrarily denying motorists the full protection

of their PII as is specifically contemplated by Streets & Highway Code

§ 31490(k).

e. CUSA must and should be deemed equitably estopped from claiming the

benefit of the § 23302 Exception by virtue of its having either intentionally or recklessly

misrepresented to the Class Members (as that term is defined, infra) that they were being

charged with the commission of a criminal infraction under Vehicle Code section

23302(b) when, in truth and in fact, CUSA had no right to make such an accusation of

criminal behavior and instead only had the right to charge Class Members (as that term

is defined, infra) with the civil offense of having violated Vehicle Code section

23302.5 as per the mandate of the 23302.5 OCTA/RCTC Ordinances.

Class Allegations

31. Motorists bring this action on behalf of themselves and all other individual

persons and non-individual business entities similarly situated (the Class).

32. Motorists are informed and believe and on that basis allege that—while Class

Members (as that term is defined, infra) are citizens of many different states of the United States



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and foreign countries (such that minimal diversity does exist in this case for purposes of the

federal Class Action Fairness Act of 2005 [28 U.S.C. Sections 1332(d)])—substantially more

than two-thirds of the Class Members (as that term is defined, infra) are California citizens.

33. The Class is defined as follows: “All individual persons and non-individual

business entities (i) who were nonsubscribers to the 91 Express Lanes; (ii) who drove the 91

Express Lanes without a valid FasTrak® account; (iii) who received 23302(b) Toll Evasion

Notices with respect to the 91 Express Lanes; (iv) which 23302(b) Toll Evasion Notices were

sent to such individual persons and non-individual business entities by a third party utilizing

PII, which PII said third party had earlier knowingly been sent by or on behalf of the

Defendants during the Relevant Period.”

34. The Class has four Sub-classes.

35. The first Sub-class is defined as follows: “All non-individual business entities (i)

who were nonsubscribers to the 91 Express Lanes; (ii) who drove the 91 Express Lanes without a

valid FasTrak® account (iii) who received 23302(b) Toll Evasion Notices with respect to the 91

Express Lanes (iv) which 23302(b) Toll Evasion Notices were sent to such persons and entities

by a third party utilizing PII, which PII said third party had earlier knowingly been sent by or on

behalf of any of the Defendants during the Relevant Period” (the C.C.P. § 343 Sub-class).

36. The second Sub-class is defined as follows: “All individual persons (i) who were

nonsubscribers to the 91 Express Lanes; (ii) who drove the 91 Express Lanes without a valid

FasTrak® account; (iii) who received 23302(b) Toll Evasion Notices with respect to the 91

Express Lanes; (iv) which 23302(b) Toll Evasion Notices were sent to such persons and entities

by a third party utilizing PII, which PII said third party had earlier knowingly been sent by or on

behalf of any of the Defendants during the Relevant Period” (the C.C.P. § 340(a) Sub-class).

37. The third Sub-class is defined as follows: “All individual persons and non-

individual business entities (i) who were nonsubscribers to the 91 Express Lanes; (ii) who drove

the OCTA-owned portion of the 91 Express Lanes without a valid FasTrak® account; (iii) who

received 23302(b) Toll Evasion Notices with respect to the 91 Express Lanes; (iv) which

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23302(b) Toll Evasion Notices were sent to such persons and entities by a third party utilizing

PII, which PII said third party had earlier knowingly been sent by CUSA on behalf of OCTA on

and after October 11, 2017” (the OCTA Sub-class).

38. The fourth Sub-class is defined as follows: “All individual persons and non-

individual business entities (i) who were nonsubscribers to the 91 Express Lanes; (ii) who drove

the RCTC-owned portion of the 91 Express Lanes without a valid FasTrak® account; (iii) who

received 23302(b) Toll Evasion Notices with respect to the 91 Express Lanes; (iv) which

23302(b) Toll Evasion Notices were sent to such persons and entities by a third party utilizing

PII which PII said third party had earlier knowingly been sent by CUSA on behalf of RCTC on

and after October 15, 2017” (the RCTC Sub-class).

39. Members of the Class, including but not limited to members of any of the C.C.P.

§ 343 Sub-class; the C.C.P. § 340(a) Sub-class; the OCTA Sub-class and/or the RCTC Sub-class

are hereafter sometimes collectively referred to as Class Members.

40. Motorists are members of both the Class and the C.C.P. § 340(a) Sub-class.

41. Motorists are not members of the C.C.P. § 343 Sub-class, which is limited to non-

individual business entities and does not include any individual persons.

42. Thakur is a member of the OCTA Sub-class.

43. Skogebo is a member of the RCTC Sub-class.

44. The Class Period is the same as the Relevant Period.

45. The identities of the Class Members can be readily ascertained from Defendants’

business records.

46. Questions of law and fact common to the Class predominate over questions

affecting only its separate Class Members, including, inter alia:

a. Whether the 23302(b) Toll Evasion Notices were all PII Violations by

Defendants and thus subject to the PII Penal Fines.

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b. Whether Defendants may rely on the § 23302 Exception to avoid being held

liable to the Class Members for the PII Penal Fines arising out of the PII Violations.

c. Whether the various applicable statutes of limitation have been tolled for

the benefit of the Class by the filing and service of the Chavez Case on July 16, 2018.

d. Whether, and if so, when Class Members belonging to the C.C.P. § 340(a)

Sub-class were themselves ever put on inquiry notice of CUSA’s potential liability for the

PII Penal Fines prior to the filing of the Chavez Case and/or the initial filing date for this

case given the fact that the 23302(b) Toll Evasion Notices sent to them by Defendants

indisputably ignored the existence of the 23302.5 OCTA/RCTC Ordinances, thereby

depriving the Class Members belonging to the C.C.P. § 340(a) Sub-class of any reason to

even suspect that their PII was not being protected as is otherwise provided for by Streets

& Highway Code § 31490(k) during the Class Period.

47. The claims of the Motorists are typical of the claims of the Class.

48. Treating this dispute as a class action is a superior method of adjudication in that

Motorists are informed and believe and on that basis allege that there are at least one million

Class Members, thus making the joinder of all absent Class Members impractical.

49. Additionally, the amount of each payment would be modest on an individual

basis, although significant in the aggregate.

50. It would be impractical for most of the Class Members individually to address

CUSA’s wrongdoings.

51. There should be no significant difficulties in managing this case as a class action.

52. Motorists can and will fairly and adequately represent the interests of the Class.

53. A class action would serve the best interests of the Class.

54. Motorists have retained competent and experienced counsel, all of whom will

vigorously represent the interests of the Class.

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Sole Cause of Action

(Violation of the Streets & Highway Code by CUSA)

55. Motorists reallege ¶¶ 1-54.

56. Defendants’ conduct as described, supra, makes Defendants liable to the Class

Members for the PII Penal Fines in a sum of not less than five million dollars ($5,000,000) each

and according to proof at trial.

WHEREFORE Motorists prays judgment as set forth below:

1. That the Class described herein be certified;

2. That Motorists be appointed the class representatives and Motorists’ counsel be

appointed counsel for the Class (Class Counsel);

3. That the Court order that Defendants pay the PII Penal Fines to the Class in a sum

of not less than five million dollars ($5,000,000) and according to proof at trial;

4. For an award of attorney’s fees and costs to Class Counsel on either or both a

common fund or statutory basis;

5. For such other and further relief as to the Court may seem just and proper.

Dated: December 6, 2018 THE WALSH FIRM, PC REALLAW PC MCGRANE PC

By: William McGrane Attorneys for Plaintiffs Mathew Skogebo, an individual person, and Sanket Vinod Thakur, an individual person, on behalf of themselves and all other persons and entities similarly situated

EXHIBIT 1

EXHIBIT 2

---

Riverside County TronsporlatiOII Commission

November 28, 2018

Mathew Skogebo

4080 Lemon Street, 3rd Floor • Riverside, CA 92501 Moiling Address: P. 0. Box 12008 • Riverside, CA 92502-2208

(951) 787-7141 • Fox (951) 787-7920 • www.rdc.org

2432 Little Creek Circle

Newbury Park, CA 91320

Dear Mr. Skogebo:

Thank you for your recently submitted claim in the matter of utilizing the 91 Express Lanes without a FasTrakaccount or transponder.

The commission is guided by state law and obligated to pay claims where there is liability on Its part. Weh,v. reviewed all of the information submitted to us relating to your claim, and have endeavored to be absolutelyfair in considering your case

Your claim presented to the Riverside County Transportation Commission was rejected on November 28, 2018.

WARNING Subject to certain exceptions, you have only six months from the date this notice was personally delivered or moiled to file a court action on this claim. Please refer to Government Code Section 945.6. You may, of cour.se, seek an attorney's advice on this matter. If you plan to consult an attorney, you should do so immediately. If you have questions about the claim or this denial of liability please contact Lisa Mobley Clerk of the Soardat (951) 787•7141. ,

I I

Sincerely,

Afk(!lr Executive Director

GROUP

EXHIBIT 3

GROUP

EXHIBIT 4

Notice of Delinquent Toll Evasion Violation Notice Mailing Date:

NTEV1103C1342674V575084

Registered Owner Name Address 1 Address 2 AddrCity,

Violation Number Vehicle License Plate Year and Make Entry Date and Time Toll Point Date and Time Location

In a Notice of Toll Evasion Violation letter dated 00/00/0000you were informed that the vehicle identified above was traveling on the 91 Express Lanes without payment of required toll(s) in violation of California Vehicle Code Section 23302.5. This violation is being enforced as a civil penalty pursuant to California Vehicle Codes Sections 23302.5 and 40250, et. seq. Please be advised that all vehicles must have a FasTrak® transponder registered to an account with a balance sufficient to pay the toll amount. Failure to pay the amount due or properly respond before the due date will result in additional penalties, fees and collection action as provided by law.

RESOLVE BEFORE THE FIRST DUE DATE TO AVOID ADDITIONAL PENALTIES

Pay the amount due. Payments can be made online at www.91expresslanes.com or by mail to the 91 Express Lanes, P.O. Box 68039, Anaheim, California 92817.

91 Express Lanes account holders with a valid account at the time of the violation, add the vehicle to your account. Complete and return the certificate below or call the customer service center at (800) 600-9191 to update your account.

Account holders with a valid account with another California Toll Agency, contact your account holding agency to add the vehicle to your account with a date prior to the violation date. If the account was not valid at the time of the violation, please call us at (800) 600-9191.

Complete an Affidavit of Non-Liability or Request an Administrative Investigation. Complete and return Section A (Affidavit of Non-Liability) or Section B (Request for Administrative Investigation) located on the back of this form within 60 days from the Notice Mailing Date.

Description Due After After

Toll

Penalty

Total Due

Due Date * *If not paid by this due date, the penalty will escalate up to $100 for the first violation, $150 for the second violation, and up to $200 for each additional violation within one year. You may also be responsible for court costs if these penalties are collected through the courts.

PAYMENT CERTIFICATE Violation #: Vehicle License:

Total Due Before: MM/DD/YY Total Due After:

MM/DD/YY

(Make check or money order payable to 91 Express Lanes. DO NOT MAIL CASH.)

Pay online at www.91expresslanes.com. Please charge $___________ to my credit card below: (Check One) American Express Visa MasterCard Discover My card was lost, stolen, expired, or cancelled. Please update as follows: Add as my primary default card Add as an additional card

Credit Card Number: Expiration (Month/Year): /

I have a valid 91 Express Lanes account. Add this vehicle to my account. Account Holder’s signature and Account Number are required. If your

account was not in good standing, the toll will not be eligible for payment from your account. Printed Name of Account Holder Account Holder Signature Required Account Number Date

a e Address 2 s City, State Zip1+4 (Please correct name and address if necessary)

NDTEVC7638373V250671364

09/04/2018

91E 55-Co. Line L#2

$3.85 $3.85 $3.85$25.00 $55.00 $80.00$28.85 $58.85 $83.85

11/16/2018 12/31/2018*

$28.85

J N

I

November 01 2018

11/16/2018 12/31/2018

09/11/2018,

11/16/2018 11/16/2018$58.85

- - -----------------------------------------------------------------------------------------------------------------------------

6:08:49 PM09/04/2018 6:14:19 PM

Pay online at www.91expresslanes.com

GRONEMEYER JENS

1542 ALBA CT

RIVERSIDE CA 92507

795654613445099

7956546.PDF

BREFALSE

NDTEV

10/31/2018

58359

46

7956546

13445099NDTEV_58359_11012018_125313

*************AUTO**ALL FOR AADC 923 5 000001153

____

1355855.1

Notice of Toll Evasion Violation Notice Mailing Date:

NTEV1103C1342674V575084

Registered Owner Name Address 1 Address 2 Address 3 City,

Our records indicate that on the date, time and location listed above, the vehicle identified was traveling on the 91 Express Lanes without payment of required toll(s) in violation of California Vehicle Code Section 23302.5. This violation is being enforced as a civil penalty pursuant to California Vehicle Code Sections 23302.5 and 40250, et. seq. Please be advised that all vehicles must have a FasTrak® transponder registered to an account with a balance sufficient to pay the toll amount. Failure to pay the amount due or properly respond before the due date will result in additional penalties, fees and collection action as provided by law.

RESOLVE BEFORE THE FIRST DUE DATE TO AVOID ADDITIONAL PENALTIES

Pay the amount due. Payments can be made online at www.91expresslanes.com or by mail to the 91 Express Lanes, P.O. Box 68039, Anaheim, California 92817.

91 Express Lanes account holders with a valid account at the time of the violation, add the vehicle to your account. Complete and return the certificate below or call the customer service center at (800) 600-9191 to update your account.

Account holders with a valid account with another California Toll Agency, contact your account holding agency to add the vehicle to your account with a date prior to the violation date. If the account was not valid at the time of the violation, please call us at (800) 600-9191.

Complete an Affidavit of Non-Liability or Request an Administrative Investigation. Complete and return Section A (Affidavit of Non-Liability) or Section B (Request for Administrative Investigation) located on the back of this form within 30 days from the Notice Mailing Date.

Description Due After

Toll

Penalty

Total Due Due Date *

*If not paid by this due date, the penalty will escalate up to $100 for the first violation, $150 for the second violation, and up to $200 for each additional violation within one year. You may also be responsible for court costs if these penalties are collected through the courts. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

PAYMENT CERTIFICATE

Violation #: Vehicle License:

Total Due Before: MM/DD/YY Year / Model:

Pay online at www.91expresslanes.com Please charge $___________ to my credit card below: (Check One) American Express Visa MasterCard Discover My card was lost, stolen, expired, or cancelled. Please update as follows: Add as my primary default card Add as an additional card

Credit Card Number: Expiration (Month/Year): /

I have a valid 91 Express Lanes account. Add this vehicle to my account. Account Holder’s signature and Account Number are required. If your account was not in good standing, the toll will not be eligible for payment from your account.

Printed Name of Account Holder Account Holder Signature Required Account Number Date

Violation Number Vehicle License Plate

Year and Make

Entry Date and Time

Toll Point Date and Time

Location

November 01 2018

NTEVC7818862V257109540

10/29/2018 5:23:31 PM91E Co. Line-McKinley L#3

12/17/2018

$4.05 $4.05$25.00 $55.00

$29.05 $59.0512/01/2018 01/30/2019*

12/01/2018$29.05

----------------------------------------------------------------------------------------------------------------------------------------------------------

Pay online at www.91expresslanes.com

Notice Mailing Date:

5:10:49 PM10/29/2018

(Please correct name and address if necessary)

TORRES ELIGIO

OF FIGUEROA VANIREY

2059 S RENE DR

SANTA ANA CA 92704

795916913198009

7959169.PDF

BREFALSE

NTEV

10/31/2018

58360

2200

7959169

13198009NTEV_58360_11012018_065535

*************AUTO**ALL FOR AADC 923 3 000000505

____

WILLIAM MCGRANE [057761] MATTHEW SEPUYA [287947] … Amended Complaint for Pe… · 1. Plaintiff...

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