Excerpt: ...R RESPONDENT'S ATTORNEY OF RECORD, RON A. ROSEN JANFAZA; MOTION FOR ORDER COMPELLING RESPONDENT, VANESSA L. JACQUES, TO (1) ANSWER FORM INTERROGATORIES, SET NO. ONE; AND (2) PAY COSTS AND SANCTIONS IN THE AMOUNT OF $761.65 AGAINST RESPONDENT AND/OR RESPONDENT'S ATTORNEY OF RECORD, RON A. ROSEN JANFAZA; MOTION FOR ORDER COMPELLING RESPONDENT, VANESSA L. JACQUES, TO (1) ANSWER DEMANDS FOR PRODUCTION OF DOCUMENTS, SET NO. ONE; AND (2) PAY COSTS AND ...

Excerpt: ...mber 23, 2019 against a number of defendants, including Vidala Aaronoff, Gloria P. Martinez-Senftner, and the Martinez Law Group, P.C. Plaintiff filed the operative Second Amended Complaint (“SAC”) on November 17, 2020, alleging ten causes of action. On August 29, 2023, Jane Doe filed a Cross-Complaint in this action against, inter alia, Plaintiff. The Cross-Complaint alleges nine causes of action. On July 23, 2021, the Court issued an Order ...

Excerpt: ...t Defendants Charlie Cheng-Han Tsai (“Charlie Tsai”) and Che-Chin Tsai (“CC Tsai”) (jointly, “Defendants”). The Complaint alleges causes of action for (1) set aside voidable transaction –Civil Code § 3439.04, subd. (a)(1), (2) set aside voidable transaction – Civil Code § 3439.04, subd, (a)(2), (3) set aside voidable transaction – Civil Code § 3439.05, (4) civil conspiracy, and (5) declaratory relief. On July 5, 2022, CC Tsai...

Excerpt: ... against, inter alia, Defendant Leon Richard Mays, an individual (“Mays”) and as Trustee of the 402 Randolph Trust. The operative Fourth Amended Complaint (“FAC”) was filed by Plaintiffs on January 27, 2023. The FAC asserts causes of action for (1) intentional misrepresentation, (2) negligence, (3) fraudulent conveyance, (4) “withdrawn,” (5) violation of Business and Professions Code section 7160, (6) aiding and abetting unlicensed co...

Excerpt: ...ampshire BBL”) and Robert Lee, an individual dba Landpac Properties. On June 30, 2022, JC 2020 filed amendments to the Complaint naming Christine A. Lee AKA Soo Lee in place of Doe 3 and Timothy Lee in place of Doe 4. On July 27, 2022, JC 2020 filed an amendment to the Complaint naming Christopher Y Lee in place of Doe 5. JC 2020 filed the operative First Amended Complaint (“FAC”) on July 27, 2022, asserting causes of action for (1) breach ...

Excerpt: .... Robert J. Smyth, M.D. (“Plaintiff”) filed this action against a number of defendants. On September 26, 2023, a “Stipulation and Order for Leave to File First Amended Complaint and to Continue November 29 Trial Date and Other Dates” was filed. The Stipulation provides, inter alia, that “[t]he stipulated First Amended Complaint attached as Exhibit A is deemed filed and served as of the day the court signs this stipulation.” (September...

Excerpt: ...S Background On October 12, 2021, Plaintiff Alex Cotraviwat (“Plaintiff”) filed this action against Defendant Charlie Cheng-Han Tsai (“Defendant”). The Complaint alleges causes of action for (1) breach of contract and (2) unjust enrichment. On November 23, 2022, Defendant filed an answer to the Complaint. Defendant's answer alleges affirmative defenses of unconscionability and failure of consideration. Plaintiff now moves for summary judg...

Excerpt: ...aintiff Larry Link (“Plaintiff”) filed this action against Defendants Victoria Billings (“Billings”) and 5523 Harold Way, LLC (“Harold Way”) (jointly, “Defendants”). The Complaint alleges causes of action for (1) disability discrimination, (2) retaliation for request for accommodation, (3) failure to pay wages owed at termination, (4) failure to pay wages owed after termination, (5) harassment, and (6) “retaliation eviction.” ...

Excerpt: ...y Usselman (“Plaintiff”) filed this action against Defendant Los Angeles Unified School District (“Defendant”). The Complaint alleges causes of action for (1) religious discrimination in violation of FEHA, (2) disability discrimination in violation of FEHA, (3) failure to provide reasonable accommodations in violation of FEHA, (4) failure to engage in good faith interactive process in violation of FEHA, (5) retaliation in violation of FEH...

Excerpt: ...RESPONSES TO FORM INTERROGATORIES AND REQUEST FOR SANCTIONS Background On November 8, 2021, Plaintiff Maricela Torres (“Plaintiff”) filed this action against Defendant Basta, Inc. (“Defendant”). Plaintiff filed the operative First Amended Complaint on January 30, 2023, alleging causes of action for (1) wrongful termination in violation of public policy, (2) disability discrimination in violation of FEHA, (3) failure to prevent discriminat...

Excerpt: ...Depot, Inc. (jointly, “Plaintiffs”) filed this action on February 3, 2023 against Defendants The State of California, acting by and through the California Department of Transportation (“Caltrans”), as well as Malcolm Dougherty, Karla Sutiff, Carrie Bowen, Heriberto Salazar, James Marsella, Mark A. Lyles, Kelly Lin, John Njoroge, Glenn Mueller, and Scott Fridell (collectively, the “Individual Defendants”) [1] . The Complaint alleges ca...

Excerpt: ...r Unlawful Detainer” against Defendant Tomatera Gomez USA, Inc. (“Tomatera”). The Complaint alleges one cause of action for unlawful detainer. Tomatera now moves for an order granting it leave to file a cross-complaint in the instant action. The motion is unopposed. Discussion Pursuant to Code of Civil Procedure section 428.50, subdivision (a), “[a] party shall file a cross- complaint against any of the parties who filed the complaint or ...

Excerpt: ...O THE FIRST SET OF GENERAL FORM INTERROGATORIES TO DEFENDANT GLEN DOLLARHIDE; REQUEST FOR MONETARY SANCTIONS Background Plaintiffs Sherry Hennington (“Hennington”) and Lorrie Irving (jointly, “Plaintiffs”) filed this action on June 1, 2021 against Defendant Glen Dollarhide (“Defendant”). The Complaint alleges causes of action for (1) breach of fiduciary duty, (2) breach of undivided loyalty, (3) fraud, (4) conversion, (5) intentional ...

Excerpt: ...ion on April 25, 2023 against Defendants Masis Tamazyan (“Tamazyan”) and Elen Tahmasian (“Tahmasian”). The Complaint alleges causes of action for (1) declaratory relief re: real property resulting trust, and (2) “in the alternative,” declaratory relief re: deed of trust priority. On July 7, 2023, Tahmasian filed a Cross-Complaint against Cross-Defendants Siranush Akherdyan a.k.a. Siranush Akhverdyan, Tamazyan, and Soorage Tomasian (�...

Excerpt: ...inst defendant Joseph Daniel Davis. On August 31, 2023, Plaintiff submitted a Verified Second Amended Complaint (“SAC”) against defendants Joseph Daniel Davis, Hilary Davis, and Randi Desnoes. The Court notes that Plaintiff's SAC indicates that it was “electronically received” on “08/31/2023.” The SAC alleges causes of action for (1) “perjury by Defendants Joseph D. Davis and Hilary Davis Regarding the Transfer of Title of the Ketch...

Excerpt: ...ff”) filed this lemon law action on December 14, 2021, against Defendant Hyundai Motor America (“Defendant”). The operative First Amended Complaint was filed on July 14, 2022, asserting causes of action for (1) violation of subdivision (d) of Civil Code section 1793.2, (2) violation of subdivision (b) of Civil Code section 1793.2, (3) violation of subdivision (a)(3) of Civil Code section 1793.2, and (4) breach of the implied warranty of mer...

Excerpt: ...HE SUM OF $12,496.19 Background Plaintiffs Mehdi Saidane and Mimi Saidane (jointly, “Plaintiffs”) brought this action on June 30, 2017 against Defendants Patrick Khalafian, Dertad Teddy Bedjakian (“Bedjakian”), and 168 Entertainment, LLC (“168 Entertainment”). Plaintiffs filed the operative Second Amended Complaint on July 3, 2018, asserting causes of action for (1) fraud, (2) breach of contract, and (3) breach of the covenant of good...

Excerpt: ...6. The Complaint asserts causes of action for (1) breach of written contract, (2) open book account, (3) money had and received, (4) unjust enrichment, (5) conversion, (6) fraud in the inducement, and (7) equitable relief. On October 25, 2018, the Court entered a Judgment in this action indicating that “judgment is entered in favor of Plaintiff Daniel Perez (“Plaintiff”) and against defendants Joseph Safran, an individual (“Safran”) and...

Excerpt: ...AMENDED COMPLAINT Background On May 19, 2023, Plaintiff Caroline Ruddy (“Plaintiff”) filed the instant action against Defendants RQ Media Group, Inc. (“RQ Media”) and Brian Salzman (“Salzman”) (jointly, “Defendants”). On September 7, 2023, Plaintiff filed the operative Verified First Amended Complaint (“FAC”). The FAC alleges twelve causes of action, including causes of action for breach of contract and breach of implied coven...

Excerpt: ...against Defendant Tia Geddie (“Defendant”). The Complaint alleges causes of action for (1) intentional interference with performance of a contract, and (2) slander. In the Complaint, Plaintiffs allege that Defendant “emailed the personal email addresses of known vendors of THECRM CORPORATION to inform them of pending litigation involving Plaintiffs THECRM CORPORATION and RICHARD KEITH LATMAN, CEO of the THECRM CORPORATION, in an effort to d...

Excerpt: ...tiff”) filed this action against Defendants Giuliano-Pagano Corporation dba Giuliano's Bakery (“Giuliano's Bakery”) and NG Trucking LLC (“NG Trucking”) (jointly, “Defendants”). The Complaint alleges causes of action for (1) breach of written contract, (2) breach of oral contract, (3) open book account, and (4) open book account. The first and third causes of action of the Complaint are alleged against Giuliano's Bakery, and the seco...

Excerpt: ...tion (“Defendant”). The Complaint asserts causes of action for (1) violation of Civil Code section 2923.55 and (2) violation of Business and Professions Code section 17200 et seq. In the Complaint, Plaintiff alleges that at all relevant times, she owned the property located at 637 E 29th Street, Los Angeles CA 90011. (Compl., ¶ 7.) Plaintiff alleges that “[i]n mid-2015, a fire virtually destroyed most of the Property and left it in severe ...

Excerpt: ...kground Plaintiffs Brent Evans (“Evans”) and Style Squared, LLC (“Style Squared”) (jointly, “Plaintiffs”) filed this action on May 9, 2022 against Defendants Sophia Jin and Colorish, LLC dba Indigo Rose. Plaintiffs filed the operative First Amended Complaint on April 3, 2023, alleging causes of action for (1) breach of contract, (2) breach of implied covenant of good faith and fair dealing, (3) breach of contract, and (4) breach of im...

Excerpt: ...Nancy Klosowski (“Plaintiff”) filed this instant action against Defendants Manhattan Beach Unified School District (the “District”) and Tom Stekol (“Stekol”) (jointly, “Defendants”). On September 27, 2023, Plaintiff submitted a Second Amended Complaint (“SAC”) alleging causes of action for (1) age discrimination, (2) hostile work environment, (3) failure to prevent discrimination and harassment, (4) intentional infliction of e...

Excerpt: ...Plaintiff seeks judgment in the total amount of $40,084.80, comprising $14,914.37 in damages, $3,535.43 in interest, $635.00 in costs, and $21,000.00 in attorney's fees. The Court notes a number of defects with the submitted default judgment package. First, Item 6(a)(6) of the proposed judgment (Form JUD-100) is blank. Thus, the total amount requested is not listed on the proposed judgment. Second, Plaintiff indicates that “Plaintiff's attorney...