Excerpt: ... August 29, 2016, the floor inside, outside, around, and near said bathroom contained pooling water, which created a dangerous and unsafe condition. (Complaint, ¶10.) On August 29, 2016, as plaintiff Madahaqueel Cardoza Orozco (“Plaintiff”) walked into said bathroom she slipped on the pooling water left on the floor and fell to the ground, causing serious bodily injury and harm. (Complaint, ¶12.) Defendants carelessly and/or negligently use...

Excerpt: ...lays, corrective grinding and epoxy flooring for commercial, retail, governmental, and residential facilities. (First Amended Complaint (“FAC”), ¶1.) In connection with the construction of defendant Apple Inc.'s (“Apple”) new 175 acre signature campus and headquarters known as Apple Park (“Project”), Apple entered into a written prime contract with defendant Rudolph & Sletten, Inc. (“Rudolph”) in or around June 10, 2015 to act as...

Excerpt: ...f Verdugo received an initial offer letter on April 6, 2015 and was hired by defendant Cassidy/ DTZ for the full time position of Vice President, Project & Development Services. (Id.) Plaintiff Verdugo began working from his home in San Jose and attending meetings with defendant Cassidy/ DTZ and defendant Facebook representatives. (Complaint, ¶5.) Almost immediately after he began working, plaintiff Verdugo's superior and others began making age...

Excerpt: ... (“Lease”) for the Premises. (FAC, ¶7 and Exh. A.) The parties later entered into an addendum to the Lease. (Id.) Defendant PBRC vacated the Premises on or about December 19, 2017. (FAC, ¶9.) Defendant PBRC breached the Lease by failing to pay rent due. (FAC, ¶10.) Pursuant to the terms of the Lease, plaintiff BSJ is entitled to $57,892.83 for unpaid rent due under the holdover rate. (Id.) Defendant PBRC breached the lease by failing to de...

Excerpt: ..., B, and C were insureds of defendant Sheet Metal Workers Local 104 Health Plan (“Defendant”) either as subscribers to coverage or dependents of a subscriber to coverage under a policy or certificate of insurance issued and underwritten by Defendant. (Complaint, ¶7.) Prior to performing surgeries on Patients A, B, and C, CSNI employees obtained promises and information from Defendant's representatives to be assured that Defendant would pay f...

Excerpt: ...Project will provide necessary infrastructure for the City Place Project. (Id.) As relocated, Stars and Stripes Drive would cut through a City‐owned building located at 5131 Stars and Stripes Drive which is presently leased to defendant D.E. II Restaurants, Inc. (“Defendant”) pursuant to a Lease Agreement for the Santa Clara Banquet and Meeting Facility between City and Defendant, dated July 1999, as amended by that certain First Amendment ...

Excerpt: ...LLC (“VSM”), owners of real property known as the Vallco Fashion Mall located at 10123 North Wolfe Road in Cupertino (“Subject Property”), to exclusively represent VSM in connection with the sale of the Subject Property. (SAC, ¶¶7 – 8.) On or about August 2, 2011, VSM and plaintiff Nguyen entered into an exclusive right to sell agreement entitled “Owner‐Broker Agreement‐Vallco Shopping Center” (“Listing Agreement”). (SAC, ...

Excerpt: ...AC”] at ¶ 2.2 ) Plaintiff Stephanie Drewsen (“Plaintiff”) became a patient of defendant SHC in January 2013. (Id. at ¶ 7.) Dr. David W. Lowenberg (“Dr. Lowenberg”) was Plaintiff's physician and an employee of defendant SHC. (Id. at ¶ 2.) Eric Sundberg, M.D. and Varun Gajendran, M.D. (collectively, “the residents”) were employed by defendant SHC as assistant resident surgeons. (Ibid.) On April 29, 2013, Plaintiff was scheduled to ...

Excerpt: ...hleen Wang, Xiao Rong Zhou, Ruo (Laura) Li, Zhengmao Zhu, LXRZ, Inc., Firetide, Inc. (“Firetide”), George Zhu (“Zhu”), Xin Liu (“Liu”), and Da Yong Guan (“Guan”) (collectively “Defendants”). As alleged in the Fourth Amended Complaint (“4AC”), Ampro and Consolitech are circuit board assembly and manufacturing companies owned by Elliot Wang (“Wang”) and located in Fremont, CA. (4AC, ¶¶ 1‐2, 23.) As Wang lived in Taiw...

Excerpt: ...dala”) made disparaging remarks to plaintiff Lobo regarding his age and subjected plaintiff Lobo to hostility due to his ancestry/national origin. (FAC, ¶¶18 – 19.) Plaintiff Lobo was denied opportunities and benefits of employment that were essential to his continued success at defendant Intel. (FAC, ¶20.) Plaintiff Lobo made several workplace complaints to defendants regarding Perumandala's actions. (FAC, ¶21.) Defendants retaliated aga...

Excerpt: ...s released to the custody of Lexington's agent, defendant Ed Mumbert (“Mumbert”). (Id.) Thereafter, Decedent did not appear in court. (Id.) Defendants Lexington and Mumbert located Decedent in Nevada and took Decedent into custody. (Id.) An arrangement had been made for Decedent to be represented by defendant Robert Drescher (“Drescher”) in the Santa Clara proceedings. (Id.) On September 11, 2016, defendant Drescher acquired an airplane o...

Excerpt: ...mber 22, 2016. (Complaint, ¶¶8 – 9.) Pursuant to the express language of the promissory note, the loan would be secured by all WTK company assets. (Complaint, ¶¶10 – 11.) Defendant Byron M. Phillips (“Phillips”) was president and secretary of defendant WTK. Plaintiffs discovered Phillips was draining the company funds and not paying the company's bills. (Complaint, ¶12.) On June 11, 2018, plaintiffs Patrick and Lewis filed a complain...

Excerpt: ...) Ma Labs is a global distributor of a full range of IT components and software with annual sales substantially in excess of $1 billion. (SAC, ¶43.) Ma Labs' principal place of business is located in an approximately 117,000 square foot facility located at 2075 N. Capitol Avenue in San Jose (“Capitol Property”). (SAC, ¶44.) Ma Labs currently employs approximately 460 persons in the United States including approximately 360 in California and...

Excerpt: ... the purchase of this restaurant (the “Business”) located at 1235 E. Calaveras Boulevard in Milpitas, California (the “Contract”). (First Amended Complaint [“FAC”] at ¶ 8.) Under the terms of the Contract, the close of escrow for the purchase and sale of the Business was scheduled to close forty‐five (45) days after the acceptance of the Contract by defendant Qiong. (Id. at ¶ 9.) The Contract was accepted by defendant Qiong on Jan...

Excerpt: ...ccasions, beginning in or around January 2017, defendant Kamarei touched plaintiff Jane Doe's sexual organs underneath her clothing. (Complaint, ¶6.) On March 29, 2018, plaintiff Jane Doe, through her guardian ad litem John Doe, filed a complaint against defendant Kamarei asserting causes of action for: (1) Sexual Battery (2) Intentional Infliction of Emotional Distress On June 11, 2018, defendant Kamarei filed a demurrer and motion to strike pl...

Excerpt: ... Catalina LLC and 574 Mariscal LLC unlawfully obtained $150,000 that belonged to plaintiff BHI through fraud, conversion, and conspiracy. The third parties then used the money to acquire real property in San Diego and in Palm Springs. The San Diego property was subsequently deeded to defendant 2006 Catalina Fund, LLC by the third party 2006 Catalina LLC for no consideration. The Palm Springs property was later deeded to defendant 574 Mariscal Fun...

Excerpt: ...r clients to Bad Boys. (Id.) Bad Boys employed defendant Ashley Pilling‐Miller (“Miller”) from November 12, 2013 until her resignation on or about June 26, 2017. (Complaint, ¶7.) While employed at Bad Boys, defendant Miller had access to Bad Boys' proprietary information and trade secrets including, but not limited to, the confidential list of referring attorneys (“Confidential Information”). (Complaint, ¶¶7 – 8.) In recognition of...

Excerpt: ...��) which IEN delivered to defendants at defendants' request on an open book account whereby defendants became indebted to IEN in the net principal amount of $149,327.27. (Complaint, ¶9.) Although demand has been made, defendants have failed and neglected to pay said sum, and the entire sum is now due, owing and unpaid, together with interest thereon. IEN assigned and transferred to plaintiff National Commercial Recovery, Inc. doing business as ...

Excerpt: ...y, “Defendants”) arises from alleged employment discrimination and Labor Code violations. According to the Complaint, Plaintiff worked at Goodwill from March to June 2017, during which time it committed various wage and hour violations and discriminated against him. Regarding the wage and hour violations, Plaintiff was not provided full meal and rest breaks, accurate wage statements, his personnel file, or his final paycheck. Regarding the di...

Excerpt: ...LC is the owner of four units at the Project. (See Second Amended Cross‐Complaint (“SAXC”) at ¶ 3.) Defendant and cross‐complainant Sherry Chen (“Chen”) (self‐represented) is a member of C Cube Investment LLC. (Id. at ¶ 1.) On May 25, 2018, Lundy filed a Complaint against Chen alleging causes of action for injunctive relief, declaratory relief, nuisance, negligence, and money due. Lundy claims that defendant Chen failed to make pa...

Excerpt: ...e to distribute, among other things, a condominium in Santa Cruz, California, and most of its contents to Plaintiff upon her death, but she specifically devised a bedroom set and artwork at the condominium to her niece, Mary Blakemore. In the fifth amendment to the Trust, Settlor directed the trustee to transfer the condominium and all of its contents to Ms. Blakemore; Plaintiff remained entitled to other Trust assets. Plaintiff alleges Settlor d...

Excerpt: ...�). Plaintiffs allege the Subject Premises were not rentable, that defendants deprived them of full access to the garage, and defendants did not provide them with temporary suitable housing. On January 7, 2019, Plaintiffs filed the operative Complaint alleging causes of action for: (1) conspiracy; (2) fraud/deceit/intentional misrepresentation; (3) breach of contract; (4) elder abuse; and (5) substandard housing. Defendant Park West served each p...

Excerpt: ... warranty which covers the engine and transmission. (Id. at ¶ 2.) During the warranty period, the Subject Vehicle contained or developed defects which substantially impair the use, value, or safety of the Subject Vehicle. (Id. at ¶ 3.) Defendant Kia knew since 2009, if not earlier, that the 2011‐2019 Kia Optima, 2011‐ 2019 Kia Sportage, 2012‐2019 Kia Sorento, and other vehicles equipped with a 2.0 or 2.4L engine contained one or more desi...

Excerpt: ...the garage was being repaired. Plaintiffs purport to assert causes of action against themselves for: (1) conspiracy; (2) fraud; (3) intentional misrepresentation; (4) fraud in contract formation; (5) breach of contract; (6) elder abuse; and (7) substandard housing. It appears they actually attribute the conduct giving rise to these causes of action to defendants Richard Hanson, Leonard Ataide 3 , Park West Condominiums, and Common Interest Manage...

Excerpt: ...Decedent”), who died on October 26, 2016. (First Amended Complaint (“FAC”), ¶1.) Decedent was a resident of, among others, defendant Milpitas Care Center (“MCC”) from April 2016 to July 2016. (FAC, ¶¶2 and 5.) During their care and/or custody of Decedent, defendant MCC failed to develop and implement adequate skin integrity and infection control/ monitoring measures, which resulted in Decedent sustaining injuries requiring specialize...