Excerpt: ...gatories, set one, and special interrogatories, set one, and request for production of documents (“RPDs”), set one, on Plaintiff Patricio Harris (“Harris”) on August 10, 2023. Responses were due on or before September 13, 2023. Uber's counsel granted Plaintiff Harris' request for an extension up to September 27, 2023 to provide discovery responses. Responses were not served. Uber avers it attempted to meet and confer with Plaintiff's coun...

Excerpt: ...C Madison Lomita LLC filed the instant motion to compel Plaintiff Eva Mayes (“Plaintiff”) to appear for her deposition thirty days from the hearing date. Preliminary, the Court notes that Plaintiff filed a request for dismissal of Regents on November 21, 2023, which was entered on November 22, 2023. Therefore, the motion as it pertains to Regents is moot, and the Court will only address arguments as it relates to CDC Madison Lomita LLC (“De...

Excerpt: ... set one, and (3) request for production of documents (“RPDs”), set one, on Plaintiff Eric Maldonado (“Plaintiff”) on June 8, 2022. On October 6, 2022, Plaintiff served unverified responses to the propounded discovery. On January 20, 2023, Defense counsel send a meet and confer correspondence to Plaintiff's counsel requesting verified and substantial responses by February 3, 2023. To date, Plaintiff has not served verified responses to th...

Excerpt: ...”) for injuries arising from a slip and fall on an unknown clear substance at Defendant's store on January 21, 2021. Defendant now moves the Court for an order compelling Plaintiff to provide further responses to Defendant's supplemental form interrogatories, supplemental special interrogatories, and supplemental demand for production of documents. II. Informal Discovery Conference (“IDC”) Per the Eight Amended Standing Order for Procedures...

Excerpt: ...) against defendants City of Los Angeles (“City”), Jacob Jahan and Simon Djahanbani for injuries arising from a trip and fall on the sidewalk. Trial in this matter is currently set for March 27, 2024. On September 26, 2023, Jacob Jahan and Simon Djahanbani (“Moving Party”) filed the instant motion for summary judgment against Plaintiff's Complaint and City's Cross-Complaint for indemnity. Plaintiff opposes the motion. II. Motion for Summa...

Excerpt: ...fendants Fernandez Perez Mulgado (“Mulgado”) and FM Perez Transport Inc. (“FM”), (collectively, “Defendants”) for damages arising from an automobile accident. The complaint alleges causes of action for (1) motor vehicle, (2) general negligence, (3) “Violation of Vehicle Code 20001(a) – Misdemeanor Hit and Run” against Mulgado only, and (4) Intentional Infliction of Emotional Distress against Mulgado only. The judicial form compl...

Excerpt: ...Rexdeo Properties LTD dba Rexdeo Apartments and Envoy Properties Inc. (“Defendants”) for damages arising from a slip and fall on a common area walkway of an apartment building owned and managed by Defendants. At this time, Plaintiff moves for an order of compelling Defendants to produce Eric S. Millstein, M.D.'s (“Dr. Millstein”) defense medical examination report concerning Plaintiff's physical examination that is code-compliant with Cod...

Excerpt: ...nt”) for damages arising from a motor vehicle incident. At this time, Defendant moves for an order compelling Plaintiff to appear for an examination with Paul E. Kaloostian, M.D., FAANS, FACS (“Dr. Kaloostian”) at 960 E Green St, Suite 320, Pasadena, CA 91106 on a date and time of Dr. Kaloostian's availability. Defendant additional requests monetary sanctions. Any opposition was due on or before November 30, 2023; none was filed. II. Motion...

Excerpt: ...ing, Inc. (“Automac”) for damages arising from a slip and fall on water near the hallway and/or stairwell area of 200 Pine Ave., Long Beach, CA 90802 on February 17, 2020. Plaintiff sets forth two causes of action for general negligence and premises liability. Plaintiff filed amendments to complaint naming Octopus Japanese Cuisine, Inc. as Doe 1, Octopus Restaurant Long Beach, Inc. (“Octopus Restaurant”) as Doe 2, and Riverrock Real Estat...

Excerpt: ...fendant Michael Evich Kirsanov (“Defendant”) for damages arising from a motor vehicle incident. Trial is currently set for March 4, 2024. At this time, Defendant seeks leave to file a First Amended Answer (“FAA”) to Plaintiff's complaint to include an affirmative defense based on prelitigation settlement of Plaintiff's claims. The motion is unopposed. II. Motion for Leave to File First Amended Complaint CCP § 473(a)(1) provides, in relev...

Excerpt: ...nt State of California and Does 1 through 50 for the death of Asherey Shatonia Ryan (“Decedent”) in an automobile collision. The First Amended Complaint (“FAC”) asserts a single cause of action for negligence. The FAC provides that Plaintiff is the successor-in-interest to Decedent, who was killed in a traffic collision caused by Nicole Lorraine Linton. (“Linton”). Defendant State of California (“Defendant”) now demurs to the FAC,...

Excerpt: ...s and Recreation, County of Los Angeles, and State of California for damages arising from a trip and fall on an alleged defective stair while walking on the steps of a jungle gym. Plaintiff alleges defendants negligently owned and maintained the subject jungle gym located at or near Live Oak Park, 10144 Bogue St., Temple City, CA 91780. Temple City filed a cross-complaint against Roes 1 to 20 for equitable indemnity/contribution (against Roes 1 t...

Excerpt: ... Castellanos (collectively, “Plaintiffs”) filed this action against Defendants, Tamir Benyun (“Benyun”), Oz Pilo, and 911 Attic Remodeling, Inc. for damages arising from a motor vehicle accident. On August 18, 2023, Plaintiffs filed proof of service of the summons and complaint showing substitute service on Benyun alleging the documents were left with a co-occupant “Jane Doe”, at 5274 Campo Rd., Woodland Hills, CA 91364 (“Campo Addr...

Excerpt: ...) filed this action against VCA Inc. (“VCA”), erroneously sued herein as VCA West Los Angeles Animal Hospital, and Selena Inouye (“Inouye”) for damages relating to a dog bite incident.¿Plaintiff brings two causes of action for negligence and for strict liability. On September 6, 2023, Inouye filed the instant motion for an order requiring Plaintiff to post an undertaking in the sum of $58,000 pursuant to CCP § 1030. Plaintiff opposes th...

Excerpt: ...araat Moller and Curtis Dailey (“Defendants”) for damages arising from an automobile accident. At this time, Defendants move to compel non-party Heights Surgical Institute (“Heights Surgical”) to produce its billing person most knowledgeable (“PMK”) and produce documents pursuant to a deposition subpoena served on Heights Surgical, and for monetary sanctions. The motion is unopposed. II. Legal Standard 1. Procedural Per CRC 3.1346, wh...

Excerpt: ...Plaintiff”) attorney of record, Steven Ross / Downtown LA Law Group, LLP (“Counsel”), moves to be relieved as counsel contending relief is necessary because the attorney- client relationship has broken down. Counsel has attached a proof of service demonstrating service of the motion, declaration, and proposed order on Plaintiff and on Defendant California Department of Transportation. (Cal. Rules of Court, rule 3.1362(d).) However, Californ...

Excerpt: ...dants Teresa Montes De Oca and Robert Martinez for damages arising from a fall over an alleged dangerous condition. Trial is currently set for November 18, 2024. At this time, Plaintiff seeks leave to file a First Amended Complaint (“FAC”) to assert causes of action for Breach of Statutory Obligation, Negligent Exercise of Retained Control, Negligence, and Premises Liability. The motion is unopposed. II. Motion for Leave to File FAC CCP § 47...

Excerpt: ...oa (“Figueroa”) propounded form interrogatories, set one, and request for production of documents (“RPDs”), set one, on Cross-Defendant Artem Kazaryan (“Kazaryan”) on March 13, 2023. Additionally, Figueroa propounded interrogatories, set two, on Kazaryan on July 5, 2023. On July 24, 2023, Kazaryan served unverified responses to the propounded discovery. After sending meet and confer correspondence to Kazaryan's counsel, there has been...

Excerpt: ...ainst Defendants Miguel A. Lopez (“Lopez”), Lucia Aguiluz (“Aguiluz”), Uriel Morales Villanueva, Antonio Villanueva, and Does 1 to 50 for damages arising from a motor vehicle accident. Defendant Aguiluz is the owner of the vehicle involved in the incident. On June 30, 2022, Plaintiff dismissed all defendants except for Lopez and Aguiluz (collectively, “Defendants”). Plaintiff seeks a default judgment against Lopez and Aguiluz in the t...

Excerpt: ...liability, negligence, breach of warranty (expressed and implied), negligence, and wrongful death arising from a vehicle collision with a pole that took place on November 19, 2018, and resulted in the death of Decedent Paula Bianca Udiong (“Decedent”). Plaintiffs' First Amended Complaint (“FAC”) alleges that Plaintiffs Angelo Udiong (“Angelo”), and Amada Udiong (“Amada”), Joshua Ancheta (“Ancheta”), were passengers in a Toyota...

Excerpt: ...ez (“Plaintiff”) filed this action against defendants Housing Authority of The City of Los Angeles and Does 1 to 50 for damages arising from a workplace injury. Plaintiff alleges he was employed by defendants as a third-party contractor to perform soldering work on an elevator in building 2 of the Jordan Downs Housing Project. While the elevator was positioned at the 6 th floor, Plaintiff alleges he fell six stories in free fall when the elev...

Excerpt: ...st for default judgment submitted on October 24, 2023 is GRANTED in the following amounts for the following reasons: This is an action wherein Plaintiff Rose Ramos (“Plaintiff”) alleges Josiah Dawson (“Dawson”) fired three or four gunshots into Plaintiff's vehicle, hitting Plaintiff on the left side of her chest with a bullet through her abdomen and liver. Sally Sanchez (“Sanchez”) is alleged to be Dawson's parent and or legal guardia...

Excerpt: ...ones, Heinrich Fernandez (collectively, “Plaintiffs”) filed this action against Defendants Roya Shookofy and Seyed Shayan Javaherian (“Defendants”) asserting negligence arising from an automobile incident which allegedly occurred on August 31, 2018 at El Toro Rd. in the County of Los Angeles. (Compl. at ¶ 8.) At this time, Defendants move to transfer venue to Orange County, arguing that the incident occurred in Orange County and that Def...

Excerpt: ...d Complaint (“FAC”) against Michelle Proyect (“Defendant”) and Does 1 to 10, wherein Plaintiff alleges she fell after her left foot slipped between the space of concrete pavers on Defendant's property. On July 21, 2023, Defendant filed her Answer to the FAC. Defendant now moves for terminating sanctions against Plaintiff to dismiss Plaintiff's action by failing to serve verified discovery responses in compliance with the Court's August 16...

Excerpt: ... Beginnings Christian Discipleship (“New Beginnings”), GM Service & Management, and Does 1 to 25 for injuries Plaintiff sustained after falling from the second story of a building. At this time, Plaintiff moves again for terminating sanctions against New Beginnings for disobeying the Court's September 2, 2022 order compelling New Beginnings to serve verified responses to Plaintiff's set one of form interrogatories, special interrogatories, an...

Excerpt: ...ly Cline and Chad Allen Margolin (“Defendants”) for damages arising from a motor vehicle accident. On December 13, 2022, Defendants filed their Answer to Plaintiff's complaint, and filed a cross-complaint against Ursula Crovelto (“Crovelto”) and Roes 1 to 50 for indemnification, apportionment of fault, and declaratory relief. At this time, Defendants seek to file a first amended cross-complaint (“FACC”) to add American Honda Motor Com...

Excerpt: ... special interrogatories, set one, and (3) request for production of documents (“RPDs”), set one, on Plaintiff Nico Quiros (“Plaintiff”) on August 17, 2022. Plaintiff's responses were due on or before September 20, 2022. After granting Plaintiff two 30-day extensions on October 19, 2022, and then on November 4, 2022, Plaintiff's counsel filed a motion to be relieved as counsel, which was heard and granted on January 18, 2023. On March 2, ...

Excerpt: ...u Barr (“Plaintiffs”) filed this action against Defendants Lyft, Inc. (“Lyft”), Ayalnesh Tessema, Raquel Rosasarmijo for damages arising from an automobile incident. At this time, Plaintiffs move to compel the deposition of Lyft's employee, Katye Coombs (“Coombs”). Lyft opposes the motion, and Plaintiffs filed a reply. 1. Moving Argument Coombs is an employee of Lyft, and signed the verification to Lyft's discovery responses as an aut...

Excerpt: ...) for damages arising from a motor vehicle incident. At this time, Defendant moves for an order compelling Plaintiff to appear for an examination with neurologist Dr. Jeffrey Bounds (“Dr. Bounds”) at 11370 Anderson St., Suite B100, Loma Linda, CA 92354 on December 19, 2023 at 11:00 a.m. Defendant contends a neurological examination is necessary because Plaintiff claims traumatic brain injury from the incident. Any opposition was due on or bef...

Excerpt: ...Defendants City of Los Angeles, County of Los Angeles, Kingsley Project, LLC, SAC-MM Properties LLC for damages arising from a trip and fall on a sidewalk. Trial is currently set for September 24, 2024. At this time, Plaintiff seeks leave to file a First Amended Complaint (“FAC”) to correct the alleged location of the incident. The motion is unopposed. II. Motion for Leave to File FAC CCP § 473(a)(1) provides, in relevant part: “The court ...

Excerpt: ...ole Foods Market California, Inc.", ("Defendant”) propounded (1) form interrogatories, set one, (2) special interrogatories, set one, and (3) request for production of documents (“RPDs”), set one, on Plaintiff Nico Quiros (“Plaintiff”) on August 17, 2022. Plaintiff's responses were due on or before September 20, 2022. After granting Plaintiff two 30-day extensions on October 19, 2022, and then on November 4, 2022, Plaintiff's counsel fi...

Excerpt: ...for damages arising from a motor vehicle incident. At this time, Defendant moves for an order compelling Plaintiff to appear for a mental examination with Charles Hinkin, Ph.D., (“Dr. Hinkin”) at 921 Westwood Blvd., Ste. 208, Los Angeles, CA 90024 at 9:00 a.m. Plaintiff opposes the motion, and Defendant filed a reply. Plaintiff does not dispute the necessity of a mental examination and has agreed to submit to a neuropsychological examination ...

Excerpt: ...Garcia”), a minor by and through his guardian ad litem Gabriela Garcia, (collectively, “Plaintiffs”), filed this action against Defendants Dhoor Gurpreet Singh and Triple Eight Transport Inc. (“Defendants”) for damages arising from a motor vehicle incident. Defendants now move for summary judgment, or alternatively, summary adjudication, against Plaintiff Elizarraras arguing that Plaintiff Elizarraras is now deceased and lacks standing ...

Excerpt: ...City of Los Angeles (“Defendant”) for injuries related to Plaintiff's scooter striking a large pothole, causing Plaintiff to fall. Plaintiff sets forth two causes of action for premises liability and general negligence. At this time, Plaintiff seeks leave to file a First Amended Complaint (“FAC”) to set forth an applicable cause of action against Defendant pursuant to Government Code § 835, since Plaintiff's cause of action for general n...

Excerpt: ...(“Julie”), and Does 1-25 for damages arising from an automobile incident. Trial is currently set for March 6, 2024. On August 9, 2023, Plaintiff filed an Amendment to Complaint naming Rachel Anne Miranda (“Miranda”) as Doe 1. Miranda now moves for an order dismissing the Amendment to Complaint pursuant to CCP § 474 and 581(m). Plaintiff opposes the motion. II. Motion for an Order Dismissing Amendment to Complaint CCP §474 provides: “W...

Excerpt: ...ron Terrace, LLC, and Does 1 to 25 for damages arising from a battery, wherein Plaintiff alleges he was ascending a stairway in the common area of the apartment complex when Does 1 to 5 punched Plaintiff in the head and robbed Plaintiff before fleeing the scene. On March 6, 2023, Defendants Calitex, LLC and Chadron Terrace, LLC (“Defendants”) filed the instant motion to compel three independent medical examinations (“IME”) of Plaintiff wi...

Excerpt: ... one, (2) special interrogatories, set one, and (3) request for production of documents (“RPDs”), set one, separately on Christine Muriel Roldzak and Melissa Hernandez (“Plaintiffs”) on April 18, 2023. After granting Plaintiffs an extension up and until July 21, 2023 to serve responses, Plaintiffs have not served any responses to date. Defendant therefore seeks an order compelling Plaintiffs to respond, without objections, to the outstand...

Excerpt: ...or damages arising from an automobile incident. At this time, Defendant Christian Jonathan Mejia (“Mejia”) moves for a Protective Order from having to provide responses to propounded written discovery on the grounds that Mejia is homeless and has not had an opportunity to meet with his counsel of record. The motion is unopposed. II. Motion for Protective Order 1. Meet and Confer CCP § 2030.090(a) provides, “When interrogatories have been p...

Excerpt: ...CA Inc., erroneously sued as VCA West Los Angeles Animal Hospital, (“VCA) (collectively, “Defendants”) for damages arising from a dog bite. The complaint alleges two causes of action for negligence and strict liability per California Civil Code Section 3342. Pertinent to VCA, the complaint alleges VCA failed to act reasonably in the care, handling, custody, and control of Inouye's dog, named “Theodor,” and that “Theodor” had an unus...

Excerpt: ...fendants TingTing You (“You”), The Cheng Living Trust Dated April 16, 1991, and EAN Holdings, LLC d/b/a Enterprise Rent-A-Car Company (“Enterprise”) for wrongful death involving a motor vehicle v. pedestrian incident. On September 13, 2023, Defendant You filed the instant motion for determination of good faith settlement between Plaintiffs and Defendants You and Enterprise. The motion is unopposed. Previously, this matter was heard on Oct...

Excerpt: ...“Defendant”) for injuries arising from an automobile incident. After the Court granted Defendant's motion to strike punitive damages with leave to amend on September 13, 2023, Plaintiff filed a First Amended Complaint (“FAC”) on October 3, 2023. Defendant moves to strike the FAC on the same grounds that the allegations are insufficient to support a claim for punitive damages. Plaintiff opposes the motion, and Defendant filed a reply. II. ...

Excerpt: ...ogies, Inc. (“Uber”) for damages arising from a motor vehicle accident, which occurred on October 27, 2019. At this time, Uber moves to compel arbitration and stay the action pending completion of arbitration. As of November 14, 2023, no opposition was filed. The motion is unopposed. II. Motion to Compel Arbitration In deciding a petition to compel arbitration, trial courts must decide first whether an enforceable arbitration agreement exists...

Excerpt: ...ries Plaintiff allegedly sustained when she slipped and fell on water near the door of the restroom on June 9, 2019. On July 5, 2022, Plaintiff filed an amendment to complaint naming Nationwide Janitorial Services, Inc. as Doe 1. On August 16, 2023, Defendants Culver City Mall, LLC, erroneously sued as Westfield, LLC, and Nationwide Janitorial Services, Inc. (“Defendants”) filed the instant motion moving the Court for an order compelling Plai...

Excerpt: ...(“Defendant”) for injuries Plaintiff sustained when she slipped on a pool of liquid in Defendant's store and fell. Plaintiff moves the Court for an order compelling Defendant to provide further responses to Request for Production of Documents (“RPDs”), set two. Plaintiff requests further disclosures to request nos. 19-23, 25-26, and 28-31, and further verified responses to 32-33, and 35-37. Defendant opposes the motion, and Plaintiff file...

Excerpt: ...s, Inc. (“Uber”) and Sergio Doe (“Sergio”) for damages arising from an assault and battery. The complaint alleges that on February 4, 2020, Plaintiff was a passenger in Sergio's vehicle when Sergio became aggravated at Plaintiff's request for an additional drop-off, wherein Doe slammed the vehicle door on Plaintiff's leg, grabbed Plaintiff, and pushed her to the ground. Plaintiff alleges Sergio was acting within the course and scope of hi...

Excerpt: ...alifornia, Inc., Food 4 Less of Southern California, Inc., and The Kroger Co. for damages arising from a slip and fall. The complaint alleges defendants allowed a dangerous condition to exist, specifically a dirty, wet and slippery floor with spilled merchandise. The complaint alleges causes of action for premises liability and general negligence against defendants. At this time, Defendant Alpha Beta Company dba Food 4 Less, erroneously sued as F...

Excerpt: ...s default judgment against Alexis Jesus Romero in the total amount of $117,643.50, comprised of $7,140 for past medical specials, $10,000 for future medical expenses, and $100,000 in general damages for pain, suffering, mental anguish, residual complaints, and emotional distress. (Azizi Decl. ¶ 8.) Additionally, Plaintiff seeks $503.50 for reimbursement of clerk's filing fees and process server's fees, as costs. This action arises out of a motor...

Excerpt: ...o (“Plaintiff”) filed this action against Defendant Los Angeles County Metropolitan Transportation Authority (“Defendant”) for damages arising from a fall on Defendant's bus when the bus accelerated. Plaintiff alleges she struck her head as a result of the incident.¿ Defendant now moves for an order compelling Plaintiff to appear for a mental examination with James E. Rosenberg, M.D. (“Dr. Rosenberg”) and Ari Kalechstein, Ph.D. (“D...

Excerpt: ...bbie Lee French (“French”), Michael Candler (“Candler”), and Candler Trucking (collectively, “Defendants”) for damages arising from a motor vehicle accident. On May 13, 2022, Defendants filed a cross-complaint against Plaintiff for breach of contract, declaratory relief, and indemnification. Defendants now move for summary judgment on the grounds that Plaintiff entered into a binding and enforceable settlement agreement with Defendant...

Excerpt: ...dants, Restaurant Depot, LLC (“Restaurant Depot”) and Does 1 to 25 for damages arising from an alleged inadequately maintained portion of a raised curb located in front of one of the refrigerators on Restaurant Depot's property. On July 28, 2023, Plaintiff filed an amendment to complaint naming RD America, LLC (“RDA”) as Doe 1. On August 30, 2023, RDA filed its Answer to Plaintiff's complaint. On October 27, 2023, RDA filed the instant mo...