Khan

FACTS

In an amended complaint filed March 12, 2021, plaintiff sued defendant, checking the boxes on Judicial Council Form PLD-PI-001 indicating she was asserting claims for general negligence, and intentional tort. She also wrote that she had causes of action for “gross breach of duty, undue influence & conflict of interest, right to life, false imprisonment and isolation, assault and battery, intentional affliction [sic] of emotional distress, invasion of privacy, [and] violation of civil rights.” The complaint did not have substantive allegations to support these claims, though it does mention that plaintiff “fear[s]” for her life “from Kamala Harris and her allies like Nancy….” The complaint acknowledge that plaintiff was required to comply with a claims statute and alleges she did so. On April 12, 2021, defendant filed a demurrer on the grounds that plaintiff had failed to file a government claim before initiating the civil lawsuit. Defendant sought and obtained judicial notice of a government claim filed by plaintiff, and a responsive letter from the Department of General Services (DGS) dated November 18, 2020. The letter from DGS notified plaintiff that her claim was not…