Willis

BACKGROUND

The General Setting On August 13, 2016, 22-year-old Raeshon Williams, an employee of Zip, Inc. and Berkeley Executives, traveled to South Lake Tahoe for a work trip with fellow employees Thomas Smith and Kai Petrich. That evening, as part of a team-building activity, Smith and Williams went riding together in Lake Tahoe on a wave runner, which had been rented from WSR. Smith was operating the wave runner, with Williams sitting behind him, and rode the wave runner at high speed into an oncoming wake, throwing Smith and Williams overboard and into the water. Williams drowned as a result of the impact. As will be seen, Williams’s mother, Marian Latasha Willis, filed a complaint in July 2017 in Alameda County Superior Court for wrongful death and survival damages.2 However, the first formal pleading was that filed by

2 As would later be revealed at the April 22, 2021 hearing on the subject motion to transfer venue, “Smith is nowhere to be found. And Petrick [sic] has left the country or he lives outside the country.” 2 WSR in the federal district court, and we begin by discussion of that proceeding. The Federal Court Proceedings In March 2017, after receiving a demand…