Excerpt: ...les, failed to establish a special needs trust of structured annuity payments due monthly to Vista Points Inc., thereby creating financial difficulties for Plaintiff and his son. The causes of action are: 1. 42 USC § 1983 – EQUAL PROTECTION OF THE LAW, DUE PROCESS. 2. 42 USC § 1983 - BREACH OF CONTRACT. On 12/14/21, the Court sustained, without leave to amend, a similar demurrer of co- Defendant PACIFIC LIFE INSURANCE COMPANY, based on the de...

Excerpt: ... SMOKE INTERNATIONAL LLC; 4) REQUEST MONETARY SANCTIONS IN THE AMOUNT OF $3,535.00 AGAINST DEFENDANT VAPE & SMOKE INTERNATIONAL LLC AND THEIR COUNSEL OF RECORD, FADI K. RASHEKD. Notice: Okay Opposition MP: Plaintiff RP: Defendant VAPE & SMOKE INTERNATIONAL LLC. Summary On 1/8/21, Plaintiff JAMIL NAJI filed a Complaint alleging that Plaintiff, and defendants QUYS ARIKAT, and RAMI AL NATOUR, on behalf of Defendant VAPE & SMOKE INTERNATIONAL LLC, D/...

Excerpt: ...D THEIR COUNSEL OF RECORD FADI K. RASHEED. MOTION TO 1) COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES SECTIONS 15.1 AND 17.1 SET ONE PROPOUNDED TO DEFENDANT QUYS ARIKAT 2) COMPEL FURTHER RESPONSES TO REQUESTS FOR PRODUCTION SET ONE NUMBERS 1, 2, 3, 5, 9 PROPOUNDED TO DEFENDANT QUYS ARIKAT 3) REQUEST MONETARY SANCTIONS IN THE AMOUNT OF $4610.00 AGAINST DEFENDANT QUYS ARIKAT AND THEIR COUNSEL OF RECORD, FADI K. RASHEED. Notice: Okay Opposition M...

Excerpt: ...chased new Defendant's manufactured 2013 Chevrolet Silverado, having defects, including drive motor battery failure, and throttle system failure. On 2/23/21, the Court entered a specific and lengthy minute order compelling Defendant's further discovery responses. MP Positions Moving party requests an order again compelling further responses, and/or imposing issue and evidentiary sanctions, on grounds including the following:  GM has not produc...

Excerpt: ... in violation of public policy MP Positions Moving parties request an order compelling this action into arbitration, and dismissing or staying this action, on grounds including the following: · Plaintiffs' argument that the Arbitration Agreement requires employees to waive rights to redress sexual harassment or discrimination under FEHA, is false. The Arbitration Agreement expressly permits Plaintiffs to seek redress for sexual harassment or dis...

Excerpt: ...vement on Plaintiffs' property, including defendants' performing work without a license, failing to perform some work, performing some work negligently, abandoning the site, and keeping the sums paid. The causes of action are: 1. FRAUD 2. INTENTIONAL TORT 3. GENERAL NEGLIGENCE 4. BREACH OF CONTRACT 5. RECOVERY OF COMPENSATION PAID TO UNLICENSED CONTRACTOR UNDER BUSINESS & PROFESSIONS CODE § 7031(B). MP Positions Moving parties request an order a...

Excerpt: ...making a ceiling collapse, and a dilapidated structure. The causes of action are: 1. NEGLIGENCE 2. BREACH OF IMPLIED WARRANTY OF HABITABILTY. MP Positions Moving party requests an order sustaining the demurrer to the Complaint, on grounds including the following: · The Complaint is uncertain, including as to whether the Statute of Limitations applies, and the drafting that incorporates allegations by reference. · The Second Cause of Action is f...

Excerpt: ...On 10/20/20, defendants filed a Cross-Complaint against Plaintiff, for Breach of Contract and Constructive Eviction, alleging that the landlord breached paragraph 6.1.1 of the lease, by not repairing air conditioning that was 68 degrees cold. MP Positions Moving party requests an order granting summary judgment against defendants, on bases including the following: · Defendants breached the Lease, and failed to pay damages in an amount no less th...

Excerpt: ...on Carbide Corp. (2005) 128 Cal. App. 4th 333, 342; Carlton v. Quint (2000) 77 Cal.App.4th 690, 697.) Opposition MP: Plaintiff RP: Defendants Summary On 7/6/21, Plaintiff SONYA HOWARD, a self-represented litigant, filed a form Complaint, alleging that, after impersonating a doctor, defendants charge Plaintiff's insurer for delayed or unfilled prescriptions. The causes of action are: Fraud, Insurance Fraud. MP Positions Moving party requests an or...

Excerpt: ...rimination, by the employer, LA DWP, occurred, including the denial, on or about October 29, 2020, of another promotion to Supply Services Manager II. The causes of action are: 1. FEHA RETALIATION VIOLATIONS 2. FEHA DISABILITY DISCRIMINATION 3. FEHA AGE DISCRIMINATION 4. FEHA AGE DISCRIMINATION 5. LABOR CODE §1102.5 VIOLATIONS 6. HOSTILE WORK ENVIRONMENT 7. 18 U.S.C. §1983 CIVIL RIGHTS/EQUAL PROTECTION VIOLATIONS. MP Positions Moving party requ...

Excerpt: ...ten contracts to provide wound care services for patients at Defendant's hospital, and after a contract terminated on June 30, 2017, defendants acquired possession of all of plaintiffs' trade secrets and confidential information. The causes of action of the Second Amended Complaint are: 1) BREACH OF CONTRACT (NON-COMPETE AND CONFIDENTIALITY CLAUSES) 2) FRAUD AND DECEIT 3) UNJUST ENRICHMENT 4) DEFAMATION 5) UNFAIR BUSINESS ACTS AND PRACTICES 6) NE...

Excerpt: ... putting him in handcuffs, and pointing a gun at him. The causes of action are: 1. UNLAWFUL SEARCH AND SEIZURE IN VIOLATION OF CONSTITUTIONAL RIGHTS UNDER 42 U.S.C. § 1983 -FOURTH AMENDMENT 2. DENIAL OF EQUAL PROTECTION IN VIOLATION OF CONSTITUTIONAL RIGHTS UNDER 42 U.S.C. § 1983 - FOURTEENTH AMENDMENT 3. VIOLATION OF CIVIL RIGHTS UNDER 42 U.S.C. § 1983 - SUPERVISORY LIABILITY 4. VIOLATION OF CAL. CIVIL CODE § 52.1 (B) - BANE ACT 5. WARRANTLE...

Excerpt: ...ied good-faith interactive process, denied work environment free of discrimination and/or retaliation, denied medical leave, denied reasonable accommodation, denied reinstatement, and employment termination. The causes of action are: 1. DISCRIMINATION IN VIOLATION OF GOV'T CODE §§12940 ET SEQ.; 2. RETALIATION IN VIOLATION OF GOV'T CODE §§12940 ET SEQ.; 3. FAILURE TO PREVENT DISCRIMINATION AND RETALIATION IN VIOLATION OF GOV'T CODE §12940(k);...

Excerpt: ... On 1/7/21, Plaintiff filed a First Amended Complaint, Qui Tam action, alleging that defendants, as providers of psychiatric care and psychotherapy, submitted fraudulent claims to at least 11 medical health insurance companies, by claiming that CHANG, a physician, treated patients, when they were actually seen by a “non-credentialed,” out-of-network provider, who is not a physician, thereby enabling defendants to collect higher-than-permitted...

Excerpt: ...cturing Company, Inc., LASC Case No. BC695605, but Defendant grossly poorly represented Plaintiff, in the action to recover damages allegedly resulting from Plaintiff's indirect asbestos exposure, including Defendant's appalling lack of pre-trial preparation, leading to a large Judgment against Plaintiff, in the sums of $7,213,704.39 in compensatory damages, and $15 million punitive damages. The causes of action are: (1) LEGAL MALPRACTICE; (2) BR...

Excerpt: ...insurance companies, by claiming that CHANG, a physician, treated patients, when they were actually seen by a “non-credentialed,” out-of-network provider, who is not a physician, thereby enabling defendants to collect higher-than-permitted sums of benefits, in violation of Insurance Code § 1871.7 and Penal Code §§ 549, 550, and 496 (First Amended Complaint, ¶ 21). The causes of action are: 1) VIOLATIONS OF THE CALIFORNIA INSURANCE FRAUDS ...

Excerpt: ...y On 1/7/21, Plaintiff filed a First Amended Complaint, Qui Tam action, alleging that defendants, as providers of psychiatric care and psychotherapy, submitted fraudulent claims to at least 11 medical health insurance companies, by claiming that CHANG, a physician, treated patients, when they were actually seen by a “non-credentialed,” out-of-network provider, who is not a physician, thereby enabling defendants to collect higher-than-permitte...

Excerpt: ... as holder, and assignee, of a construction-related deed of trust, on 5055 Mount Helena Ave, Los Angeles, wrongfully foreclosed, during when Plaintiff genuinely disputed a grossly inflated pay-off amount, thereby interfering with Plaintiff's attempted sale of its property, to co- Defendant REBECCA DARNELL, who has taken possession of the property without paying rent. The causes of action are: 1) QUIET TITLE TO REAL PROPERTY 2) WRONGFUL FORECLOSUR...

Excerpt: ...ns, including electrical deficiencies; plumbing deficiencies; lack of hot water; water leaks; floors and walls containing mold and mildew; insect infestations; pest infestations; security and safety deficiencies; storage deficiencies; and loss of use of the premises. The causes of action are: 1) BREACH OF IMPLIED WARRANTY OF HABITABILITY 2) BREACH OF STATUTORY WARRANTY OF HABITABILITY 3) BREACH OF THE COVENANT OF QUIET ENJOYMENT 4) NEGLIGENCE 5) ...

Excerpt: ...lleging that Defendants, lessees, and unauthorized resident Gabriela Borchardt, contend that Plaintiff is in breach of the warranty of habitability, whereas defendants have done the pattern of obstructing repairs and remediation, and damaging property, and so caused any uninhabitable conditions. The causes of action are: 1) BREACH OF CONTRACT 2) DECLARATORY RELIEF 3) NEGLIGENCE 4) UNJUST ENRICHMENT. On 12/28/20, defendants, as self-represented li...

Excerpt: ... 25% Plaintiff NORA SUSANA ARELLANO, and 25% to Defendant NORA MORAN ARELLANO), in exchange for plaintiffs obtaining funds and orchestrating all repairs for rehab of the property, and then placing it for sale. The causes of action are: 1) PARTITION OF REAL PROPERTY 2) BREACH OF CONTRACT 3) BREACH OF COVENANT OF GOOD FAITH AND FAIR DEALINGS 4) DECLARATORY RELIEF 5) PROMISSORY ESTOPPEL 6) NEGLIGENT MISREPRESENTATION 7) FRAUDULENT MISREPRESENTATION ...

Excerpt: ...that, when Defendant CRAIG CORNWELL became the Chief Deputy City Attorney in 2006, Plaintiff's performance while working as a Deputy City Attorney became falsely and unfairly handled based on the pretext of poor work performance, leading to years of retaliation for Plaintiff's complaints, harassment (e.g., yelling, defamation, ridicule, bias against Plaintiff, and profanity), criticisms of Plaintiff's childcare needs, disproportionate assignments...

Excerpt: ...essful entrepreneurs that if they invested $100,000, then they would (i) receive a level of mentorship and coaching that had “literally never been done before,” including access to exclusive in-person events held at various high-end venues throughout the country, (ii) be “guaranteed” to receive a significant return on the $100,000 investment, and (iii) have the right to receive a refund. The causes of action are: (1) BREACH OF CONTRACT (2...

Excerpt: ...ses under the Elder and Dependent Adult Civil Protection Act, based upon the healthcare Defendants' neglect and deliberate withholding of treatments, including for chronic kidney disease, and Covid, of decedent WALLACE DORSEY, a 68-year-old, frail, dependent adult. The causes of action are: 1. VIOLATIONS OF THE ELDER AND DEPENDENT ADULT CIVIL PROTECTION ACT [Welf. & Inst. C. § 15600 et seq.] 2. NEGLIGENCE 3. WRONGFUL DEATH. MP Positions Moving p...

Excerpt: ... a First Amended Complaint, alleging that defendants ERIC MICHAEL PONY and LIFETIME FINANCIAL, INC. engaged in a predatory lending scheme to cheat homeowners like Plaintiff out of substantial home equity, by enticing homeowners to refinance their current mortgages with new mortgage loans. Defendants falsely represented that the mortgage loans that they would make or arrange were at lower fixed interest rates and required lower monthly payments th...