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`Sandra Hefner
`355 Serrano Drive
`San Francisco, California 94132
`415-374-1502
`sandradhefner@gmail.com
`
`
`
`
`ELECTRONICALLY
`F I L E D
`
`Superior Court of California,
`County of San Francisco
`03/21/2022
`Clerk of the Court
`BY: KAREN VALDES
`SUPERIOR COURT FOR THE STATE OF CALIFORNIA
`Deputy Clerk
`COUNTY OF SAN FRANCISCO – UNLIMITED
`CGC-22-598796
`
`
`
`Sandra Hefner
`Personal Representative for the Estate of
`Christopher Hefner,
`Plaintiff,
`vs.
`Linda Steinholff-Holmes,
`Defendant.
`
`Case No.
`
`
`
`Plaintiff’s Complaint for Damages and
`Demand for Jury Trial
` Wrongful Death
` Survival
`
`
`
`1. The Plaintiff is the Personal Representative of the Estate of Christopher Hefner and the
`
`mother and next of kin of Christopher Hefner. Both the Plaintiff and Christopher Hefner were
`
`at all times relevant herein citizens and residents of San Francisco, California and over the
`
`age of eighteen.
`
`2. The Defendant is a citizen and resident of San Francisco, California, is over the age of
`
`eighteen and was conducting business in the City and County of San Francisco.
`
`3. The Defendant is the owner of real property located at 884-886 14th Street San Francisco,
`
`California.
`
`4. The Court has personal jurisdiction over the parties and subject matter jurisdiction over the
`
`claims asserted herein. Venue is proper in San Francisco County because the Defendant
`
`transacts business in San Francisco.
`
`5. Christopher Hefner (“Decedent”), resided at apartment 884 14th Street San Francisco,
`
`California, as a subtenant under the lease of Daniel J. Feldman, Ph.D.
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`Sandra Hefner
`355 Serrano Drive
`San Francisco, California 94132
`415-374-1502
`sandradhefner@gmail.com
`
`
`
`
`ELECTRONICALLY
`F I L E D
`
`Superior Court of California,
`County of San Francisco
`03/21/2022
`Clerk of the Court
`BY: KAREN VALDES
`SUPERIOR COURT FOR THE STATE OF CALIFORNIA
`Deputy Clerk
`COUNTY OF SAN FRANCISCO – UNLIMITED
`CGC-22-598796
`
`
`
`Sandra Hefner
`Personal Representative for the Estate of
`Christopher Hefner,
`Plaintiff,
`vs.
`Linda Steinholff-Holmes,
`Defendant.
`
`Case No.
`
`
`
`Plaintiff’s Complaint for Damages and
`Demand for Jury Trial
` Wrongful Death
` Survival
`
`
`
`1. The Plaintiff is the Personal Representative of the Estate of Christopher Hefner and the
`
`mother and next of kin of Christopher Hefner. Both the Plaintiff and Christopher Hefner were
`
`at all times relevant herein citizens and residents of San Francisco, California and over the
`
`age of eighteen.
`
`2. The Defendant is a citizen and resident of San Francisco, California, is over the age of
`
`eighteen and was conducting business in the City and County of San Francisco.
`
`3. The Defendant is the owner of real property located at 884-886 14th Street San Francisco,
`
`California.
`
`4. The Court has personal jurisdiction over the parties and subject matter jurisdiction over the
`
`claims asserted herein. Venue is proper in San Francisco County because the Defendant
`
`transacts business in San Francisco.
`
`5. Christopher Hefner (“Decedent”), resided at apartment 884 14th Street San Francisco,
`
`California, as a subtenant under the lease of Daniel J. Feldman, Ph.D.
`
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`6. By reason of the landlord-tenant and subtenant relationship the Defendant owed various
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`statutory and non-statutory duties to the Decedent, including but not limited to, a duty of care
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`to provide a habitable apartment, free from mold and providing potable water.
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`7. The apartment was not habitable and was defective and dangerous.
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`8. The water was not potable but was contaminated, and the concentration of mold particles in
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`the air far exceeded safety guidelines for habitability.
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`9. The Defendant was provided with written notice of the problems that made the apartment
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`uninhabitable and dangerous, and that it threatened the life of the Decedent.
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`10. The contaminated water and mold caused an infection that prevented the Decedent from
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`receiving chemotherapy for Non-Hodgkin’s Lymphoma which would have provided 50%
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`survival rate at 5 years.
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`11. The inability to receive chemotherapy due to the infection caused by the contaminated water
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`was the actual, direct and proximate cause of his death within 3 months of notifying
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`Defendant of the risk of the uninhabitable conditions in the residence at 884 14th St.
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`12. The Decedent experienced physical pain and suffering. The Decedent’s awareness that the
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`failure to receive chemotherapy treatment, due to the infection caused by the conditions in the
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`apartment, would result in death caused severe emotional distress for several months.
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`13. The Defendant also had a duty to warn the Decedent of any non-obvious hazards, including
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`contaminants being released into the apartment and through the water.
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`14. The Defendant’s breach of her duty to provide potable water, her negligence to address
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`serious issues with mold, and her breach of her statutory duties and her warranty of
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`habitability and to warn of non-obvious hazards was the direct and proximate cause of the
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`Decedent’s death.
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`
`
`For A First Cause of Action
`(Wrongful Death)
`California Code of Civil Procedure Section 377.60
`
`15.
`
`The Plaintiff realleges and incorporates all prior allegations as though fully set forth
`
`herein.
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`16.
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`By reason of the landlord/tenant relationship the Defendant owed the duties set forth
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`above.
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`17.
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`The Defendant breached those duties by failing to warn of non-obvious hazards including
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`but not limited to contaminants in the water the Plaintiff provided to the apartment.
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`18.
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`The Defendant further breached her duties to provide a habitable apartment suitable for
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`human habitation including the duty to provide potable water.
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`19.
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`The Defendant’s breach of these duties caused the Decedent to develop an infection that
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`prevented the Decedent from obtaining medical treatment for non-Hodgkin’s lymphoma resulting
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`in his death.
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`20.
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`The Defendant’s breach of her duties was the direct and proximate cause of the death of
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`Christopher Hefner and corresponding damages in an amount to be proved at trial.
`
`For A Second Cause of Action
`(Survival)
`California Code of Civil Procedure 377.30
`
`The Plaintiff realleges and incorporates all prior allegations as though fully set forth
`
`
`
`
`
`21.
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`herein.
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`22.
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`The Decedent experienced physical pain and suffering and severe emotional distress for
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`several months after becoming infected from the contaminated water the Defendant provided to
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`the apartment.
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`23.
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`The Decedent was aware that without the chemotherapy the non-Hodgkin’s lymphoma
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`would go untreated and hasten his death.
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`24.
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`The Defendant owed the duties set forth above.
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`25. The Defendant’s breach of those duties, including but not limited to failing to warn of
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`non-obvious hazards and to provide potable water was the direct and proximate cause of
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`damage to the Decedent in an amount to be proved at trial.
`
`26.
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`The Defendant’s conduct, as set forth herein, was grossly negligent.
`
`The Plaintiff seeks judgment against the Defendant as follows:
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`1. For general damages
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`2. For special damages
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`3. For punitive damages
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`4. For the costs of this litigation
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`5. For attorney’s fees
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`6. For all other relief the Court deems just and proper.
`
`Respectfully submitted,
`
`
`
`
`
`
`
`
`
`
`
`
`
`Sandi Hefner
`355 Serrano Drive APT 1L
`San Francisco, California 94132
`Phone 415-374-1502
`
`4
`
`
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