Excerpt: ...Inc. (“Drive” or “Plaintiff”). Defendant Pelletier allegedly began working for Drive as a Service Advisor on or about January 29, 2008. Compl. ¶ 21. As part of his employment, Plaintiff allegedly signed and executed non-disclosure Agreements (the “NDAs”) in 2008, 2017, and 2019, agreeing to keep all of Plaintiff's proprietary information in the strictest of confidences and not to use such information for his own benefit. Compl. ¶¶ ...

Excerpt: ... case arises in connection with Plaintiffs Sangjoon Jay Lee and Joongwha June Lee, as trustees of the Sangjoon and Joonghwa Lee Living Trust Dated April 24, 2008 (collectively “Plaintiffs” or the “Lees”)'s ownership of the real property located at 1209 Turquesa Lane, Pacific Palisades, CA (the “Subject Property”). Plaintiffs allegedly entered into a partially oral and written contract with Defendant Samara Engineering, Inc. (“SEI”...

Excerpt: ...ay in Plaintiff's medical examination and whether he or she will merely administer the tests and collect data at Dr. Djalilian's direction or whether he or she will engage in any analysis of the results or otherwise diagnose Plaintiff's physical condition and act as an independent examiner. The parties are to submit a joint statement by October 30, 2020, regarding their meet and confer efforts and any disputes that remain. All meet and confer ses...

Excerpt: ...tive information of Plaintiff including his full, unredacted social security number. See TAC Ex. A, at 7; Goldman Decl. Ex. 8, Ex. A at 7. Pursuant to California Rules of Court, rule 1.201(a)(1), such information must be redacted or excluded to protect personal privacy and other legitimate interests. The parties are instructed to withdraw these documents and to submit new versions that properly redact all sensitive information. Plaintiff to give ...

Excerpt: ... Guaranty, by which he guaranteed payment on the Agreement. Compl. ¶ 6, Ex. B. Pursuant to the terms of the Agreement, Churrascaria was allegedly required to make daily retrieval payments in the sum of $921.00, commencing March 27, 2018 and continuing until the entire repayment amount of $174,000 was paid in full. Compl. ¶ 8. Churrascaria allegedly failed to make the required payment on or about May 2, 2018 and defaulted. Compl. ¶ 9. According...

Excerpt: ... quash the subpoena to Open Bank. MOTION TO QUASH OPEN BANK SUBPOENA Defendants Jun Chow, Piper Er, and Lili Chen (“Defendants”) move for an order quashing Plaintiffs Shu Wu Chueh and Gloria Hsu's (“Plaintiffs”) subpoenas to Open Bank. The parties jointly invested in Caesar Global Alliance, Inc. (“Caesar Global”) for the purpose of buying and managing a car wash business. In 2019, Open Bank refinanced loans to Caesar Global. In obtain...

Excerpt: ...ect tenants and visitors from the danger posed by falling pieces of façade and accommodate Plaintiff while the repairs are being done. The Court continued the hearing again as the parties were engaging in settlement discussions. On September 18, 2020, the parties filed their joint statement. Plaintiff states that Defendants should hire a professional to conduct an evaluation of the building, install a sidewalk cover to prevent injury, give Plain...

Excerpt: ... request for monetary sanctions. Plaintiff to give notice. Background Plaintiff Lakeshore Investment LLC (“Lakeshore”) alleges Defendant Now Solutions Inc. (“Now”) executed a Promissory Note (the “Note”) on January 9, 2013 in favor of Plaintiff in the amount of $1,759,150.00 at 11% interest per annum, with the interest rate rising to 16% upon a default. Compl. ¶ 8. The Note was allegedly secured by a Security Agreement (the “Agreem...

Excerpt: ...notice. Background This case arises in connection with Defendants Downtown LA Law Group, LLP (“DTLA”), Farid Yaghoubtil (“Yaghoubtil”), Daniel Azizi (“Azizi”), and Salar Hendizadeh's (“Henzidadeh”) (collectively “Defendants”) alleged representation of Plaintiffs Sean O'Brien (“O'Brien”) and Ted Ragains (“Ragains”) (collectively “Plaintiffs”), in connection with a potential personal injury lawsuit against Uber Techn...

Excerpt: ...nc. (“Happy Gifts” or “HGI”). Happy Gifts is an online retailer doing business as Earfleek.com. Compl. ¶ 12. Happy Gifts was allegedly founded by defendants Sean Rimokh and Avi Zolty (“Zolty”), and its officers and directors allegedly included Sean Rimokh, Zolty, Jack Rimokh, Joe Combs (“Combs”), and the Rimokh Family Trust (the “Trust”). Id. at ¶ 13. Defendants Sean Rimokh, Zolty, Joe Combs, Jack Rimokh, and the Trust will ...

Excerpt: ...Peak”), Hongshi International USA Company (“Hongshi International”), Kaihou Liang (“Liang”), Yong Bai (“Bai”), and Chunshi Li (“Chunshi Li”) (collectively “Plaintiffs”) allege that Defendants AA Sunrise Inc. (“AA Sunrise”), Ji Li (“Ji Li”), and Holly Xiong (“Xiong”) (collectively “Defendants”) wrongfully assumed and exercised ostensible authority and actual power over Yorba's business and financial affairs, a...

Excerpt: ...alleges he leased a new 2017 Cadillac ATS (“the Subject Vehicle”) on or about February 1, 2018 from Defendant General Motors LLC (“GM” or “Defendant”). According to Plaintiff, the vehicle was delivered to him with serious defects and nonconformities to warranty and developed other defects and nonconformities in areas relating to the air intake sensor and check engine light. In the Complaint, Plaintiff alleges two causes of action for ...

Excerpt: ...arcia” or “Plaintiff”) alleges he entered into a residential purchase agreement (the “RSA”) as the buyer, on or around February 7, 2017, with nonparty Melvin Silas, as successor trustee of the Kathy Melvin Family Trust (“the Seller”), as the seller, for the purchase of the real property located at 729 W. 123rd St., Los Angeles, CA 90044 (“the Subject Property”). First Am. Compl. (“FAC”) ¶ 14. Defendants Inland Empire Real E...

Excerpt: ...¶ 2-3, 19. According to Plaintiff, Defendant improperly implemented a plan to wrongfully increase its business profits at the expense of residents by staffing Glen Park with an insufficient number of care personnel and by not providing sufficient training for its staff. Compl. ¶¶ 10- 11. Plaintiff alleges she was likely the victim of rape and that she suffered other injuries due to the understaffing, including acute primary and secondary syphi...

Excerpt: ...et and confer letter, as well as information on when those complaints or repair requests were made. The parties are further ORDERED to meet and confer regarding the documents that would be necessary to apprise Plaintiffs of the number of repurchase requests Ford received and granted for vehicles of the same year, make, and model based on the same defects at issue in Plaintiffs' claims, as well as when the requests were made. In meeting and confer...

Excerpt: ... Toyota”) (collectively “Defendants”), on or about February 23, 2017. First Amended Complaint (“FAC”) ¶ 9. Plaintiff alleges he has been unable to obtain hydrogen fuel for the vehicle from Defendant TMS or its affiliates and that this constitutes a defect or nonconformity to warranty. FAC ¶¶ 10, 19. Plaintiff filed the initial Complaint on January 25, 2019, alleging six causes of action for: (1) violation of the Song-Beverly Consumer...

Excerpt: ...imely filed and served by electronic mail on April 7, 2020 OPPOSITION: Timely filed and served by electronic mail on June 9, 2020 REPLY: Timely filed and served by electronic mail on June 18, 2020 [Tentative] Ruling: The court GRANTS Defendants White Arrow, LLC and White Arrow, Inc.'s motion for summary adjudication as to Plaintiff's demand for punitive damages. The motion is otherwise DENIED. Defendants to give notice. NB: Plaintiff lodged copie...

Excerpt: ...cles of the same year, make, and model as the Subject Vehicle, and (3) Defendant's policies and practices in California. Plaintiff is ordered to give notice. Background Plaintiff Shane Reichow (“Reichow” or “Plaintiff”) alleges he purchased a used 2015 Chevrolet Corvette (the “Subject Vehicle”) on or about January 14, 2017, which was manufactured and distributed by Defendant General Motors LLC (“GM” or “Defendant”). Compl. ¶�...

Excerpt: ...rs LLC (hereinafter “GM” or “Defendant”). Id. In connection with the purchase, Plaintiffs claim they received an express written warranty that included a 3-year/36,000-mile express bumper-to-bumper warranty, a 5-year/60,000- mile powertrain warranty, and a 10-year/120,000-mile extended coverage plan which covered the engine. Compl. ¶ 7. According to Plaintiffs, the Subject Vehicle contained or developed defects during the warranty period...

Excerpt: ...ely the “Programs”) of the David Geffen School of Medicine at the University of California, Los Angeles Health System (“UCLA”). Compl. ¶ 6. Plaintiff entered into a one-year contract with UCLA, beginning in June 2017, which was to renew each year of the Programs. Compl. ¶¶ 6, 9. Defendant the Regents of the University of California (“Defendant” or “the Regents”) govern the University of California, including UCLA. Compl. ¶ 7. ...

Excerpt: ...a complaint against a demurrer, a court will treat the demurrer as admitting all material facts properly pleaded, but not contentions, deductions or conclusions of law. (Blank v. Kirwan (1985) 39 Cal.3d 311, 318 (Blank); C & H Foods Co. v. Hartford Ins. Co. (1984) 163 Cal.App.3d 1055, 1062.) It is well settled that a “demurrer lies only for defects appearing on the face of the complaint[.]” (Stevens v. Superior Court (1999) 75 Cal.App.4th 594...

Excerpt: ...e) and Rihua Li (hereinafter Li) (collectively Plaintiffs) allege that defendant Guozhong Chen (hereinafter Chen) presented Plaintiffs with an opportunity to acquire stock in a Chinese corporation known as Beijing TOEIC (hereinafter TOEIC) that was owned by Chen. (First Am. Compl. (FAC) ¶ 9.) Defendant Chen allegedly represented that the Company was very healthy financially and that it was taking steps to be listed on a recognized Chinese stock ...

Excerpt: ... property located at 5134 Gaynor Avenue, Encino, CA 91436 (the Gaynor Property). Plaintiff Lorena Alvarado (hereinafter Alvarado or Plaintiff) alleges that she entered into a written Agent Open House Agreement (the Open House Agreement) with defendant Adi Livyatan (hereinafter Livyatan) regarding certain real property located at 4952 Noeline Avenue in Encino, California (the Noeline Property), which was allegedly listed by Livyatan through defend...

Excerpt: ...g specific search terms and a limited group of individual document custodians who are reasonably likely to have discoverable information. This list of individuals should be narrowly tailored to individuals who would be likely to have discussed the alleged defect and FCA's response to the alleged defect. If a search of those custodians reveals correspondence with other individuals who are likely to have discoverable information, then Plaintiff is ...

Excerpt: ...bello Unified School District (hereinafter the District or Defendant) to perform certain public contract work on the project, commonly described as the “Districtwide Network Cable Project” (the Project). (Compl. ¶ 5, Ex. A.) According to Plaintiff Telenet, it has performed its scope of work, without limitation, at 7 schools. (Compl. ¶ 6.) Plaintiff allegedly submitted pay application no. 10 to Defendant on or about February 25, 2019, in the...