Excerpt: ...ion brought by plaintiff Herc Rentals to collect sums allegedly due under a written Herc Account agreement plaintiff entered with defendant 1 Stop Home Remodel. The file shows that on August 6, 2019, plaintiff filed a Request for Entry of Default of defendant, which was entered as requested on August 8, 2019. Default was entered based on a proof of service of summons filed on July 19, 2019, which shows service on 1 Stop Home Remodeling by substit...

Excerpt: ...tee Company of North America USA, and Continental Casualty Company (New Trial) Plaintiff Aris Construction, Inc. (Fees) RELIEF REQUESTED: New Trial Order vacating judgment granting summary judgment and an order granting a new trial. Fees Order allowing for the recovery from plaintiff of attorney's fees as costs of suit in the amount of $68,527.25 SUMMARY OF FACTS: Plaintiff Aris Construction Inc. alleges that in April of 2019, defendant the Nazer...

Excerpt: ...h Hough Pollock and Joan Crawley Pollock Trust Dated November 7, 2002, alleges that plaintiff entered into a written Residential Lease Agreement with defendants Romeo Gupilan, Alice Gupilan, Kyle Gupilan, Cyrus Gupilan, Albe Bersave, and Rizzy Vasalo, that defendants breached the agreement by failing to pay rent from June 1, 2012 through January 31, 2017, and that defendants now owe plaintiff a total of $27,400 for unpaid rent. The form complaint...

Excerpt: ...ogatories, Set One, Nos. 13, 30, 32 and 42 FACTUAL BACKGROUND Plaintiff Iwona Zolnierkiewicz alleges that she is the daughter of decedent Malgorzata Krolikowski, the next in kin with ownership and control of Krolikowski's human remains. The operative complaint, the First Amended Complaint, alleges that on September 19, 2018, plaintiff's mother Krolikowski passed away, with her remains being held by defendant Dignity Health dba Glendale Memorial H...

Excerpt: ...native, summary adjudication of each cause of action Causes of Action from First Amended Complaint 1) Violation of California Government Code section 12940 et seq. 2) Violation of Labor Code section 1102.5 et seq. 3) Defamation Per Se SUMMARY OF COMPLAINT: Plaintiff Allen Jay Hollis alleges that he was employed by defendant Alpha Security and Logistix, Inc. beginning in January of 2019, when plaintiff was hired as production staff, and that as pa...

Excerpt: ... action Causes of Action from Complaint 1) Breach of Contract 2) Fraud in the Inducement SUMMARY OF COMPLAINT: Plaintiff Hamed Golshan alleges that defendant Mike Kamali was a fifty percent shareholder of a business entity known as Saint Glen, Inc., which operates a restaurant known as Panini Grill in Los Angeles County (the “Company”), and in September of 2019 entered into a Stock Purchase Agreement wherein defendant agreed to sell his entir...

Excerpt: ... informally: Yes, Ukeje Decl., paras. 6-10, Exs. 3-6 FACTUAL BACKGROUND Plaintiff Rakesh Kothari alleges that in July of 2014 he entered a written agreement with defendants Govind Vaghashia dba Quality Inn and Suites, Sonal Vaghashia dba Travelodge Burbank, Prashant Vaghashia dba Quality Inn Burbank Airport, Mita Vaghashia and Vaghasia Family Partnership Limited, the owners of hotels/motels in Southern California, wherein it was agreed that plain...

Excerpt: ...ff Fedex Corporate Services, Inc. alleging that plaintiff is the holder of a debt for services provided by FedEx Express Corp. and FedEx Ground Package Systems to defendants Shippler and Eduard Sarkisyan, individually and dba Rapid Shippers aka Road to Green and B'Lit Chargers. The file shows that on July 27, 2021, the default of defendants was entered. The default of moving party Sarkisyan was entered based on a proof of service showing service ...

Excerpt: ...rch 15, 2021 global Settlement Agreement between the parties in this matter, which incorporated a Stipulation for Entry of Judgment, and also pursuant to CCP section 664.6. SUMMARY OF FACTS: Plaintiff George Hsieh alleges that in 2018, he was referred to a purported opportunity to invest in defendant Wild Rabbit Technologies, LLC (“Wild Rabbit Technologies”), a purported technology company specializing in the area of artificial intelligence. ...

Excerpt: ...MMARY OF FACTS: Plaintiff American Express National Bank brings this action to collect sums allegedly due by defendant Jared T. Smith for money owed on an American Express Card account pursuant to which plaintiff lent money to defendant, in the sum of $31,936.84. The complaint alleges causes of action for Common Counts and Quantum Meruit. On May 19, 2020, plaintiff filed a Stipulation for Conditional Entry of Judgment, signed by the parties. Plai...

Excerpt: ...in 30 days?: No RELIEF REQUESTED: Order dismissing or striking cross-complainant Ireneusz Perzyna's Cross-Complaint CAUSES OF ACTION: from Cross-Complaint 1) Conversion 2) Adverse Possession SUMMARY OF FACTS: Plaintiff Iwona Zolnierkiewicz alleges that she is the daughter of decedent Malgorzata Krolikowski, the next in kin with ownership and control of Krolikowski's human remains. The FAC alleges that on September 19, 2018, plaintiff's mother Kro...

Excerpt: ...ion of Private Facts 2) Invasion of Privacy—False Light 3) IIED 4) NIED SUMMARY OF FACTS: Plaintiff Viola Dersahakian alleges that at the height of the pandemic, plaintiff and her family suffered water damage to their home which forced them to move in with plaintiff's mother-in-law at the residential complex operated by defendant Casa De Valley View Owner's Association. Plaintiff alleges that she is a legally blind individual and was also pregn...

Excerpt: ... OF ACTION FROM THE First Amended Complaint of Yolla Ghanem 1) Premises Liability 2) Gross Negligence CAUSES OF ACTION FROM THE Complaint of John Paul Ghanem 1) Premises Liability 2) Gross Negligence SUMMARY OF FACTS: Plaintiff Yolla Ghanem alleges that an unidentified man exposed himself while she was in a shower at a gym facility owned and operated by defendant 24 Hour Fitness USA, Inc. Plaintiff alleges that defendant was aware that criminals ...

Excerpt: ...uction Inc. alleges that in April of 2019, defendant the Nazerian Group entered into a prime contact with Glendale Community College District to construct a work of improvement to the college gymnasium. In June of 2019, defendant Nazerian Group contacted plaintiff and presented it with a subcontract agreement for completion of the project. The SAC alleges that plaintiff upon reviewing the subcontract was unable to sign it as drafted, as the deadl...

Excerpt: ...rnative, summary adjudication of each cause of action Causes of Action from First Amended Complaint 1) Violation of California Government Code section 12940 et seq. 2) Violation of Labor Code section 1102.5 et seq. 3) Defamation Per Se SUMMARY OF COMPLAINT: Plaintiff Allen Jay Hollis alleges that he was employed by defendant Alpha Security and Logistix, Inc. beginning in January of 2019, when plaintiff was hired as production staff, and that as p...

Excerpt: ...fendants Global Alarm Protection and Maritza Aguilar, alleging that defendants have breached a written agreement with plaintiff by failing to pay plaintiff amounts due under the agreement as invoiced. The complaint alleges causes of action for breach of contract, open book account, account stated, reasonable value and beach of personal guarantee. The file shows that on June 18, 2021, the court granted a motion brought by defendants Aguilar and Gl...

Excerpt: ...by plaintiff Ricardo Canales alleging that he is the landlord of premises in Glendale, and that defendant Ideal Kitchen Supply, Inc. entered into a written agreement with plaintiff to rent the premises for a fixed term, was served with a 3- day notice to pay rent or quit and failed to comply with the requirements of the notice by the required date. On May 28, 2019, the matter was called for a jury trial, final status conference and motion for sum...

Excerpt: ...d party Meghedy Bandary Third party Robert Ter-Oganesyan (Compel Compliance Deposition Subpoenas) (No Opposition) RELIEF REQUESTED: Responses to Specially Prepared Interrogatories, Set No. One from plaintiff Order Compelling Compliance with Subpoena for Attendance and Testimony by Robert Ter-Oganesyan FACTUAL AND PROCEDURAL BACKGROUND: Plaintiff Vehanoosh Grigorian brings this legal malpractice action against her former attorneys, defendants Alex...

Excerpt: ...WARD Written arbitration agreement attached or included verbatim (§1285.4(a)): Attach 4(b), paras. 27, 28 Arbitrator(s) name(s) (§1285.4(b)): Bruce Kahn (American Arbitration Association) Arbitration award and written opinion set forth (§1285.4(c)): Yes, Attach 8 (c) Petition served and filed not earlier than 10 days after service of the award (§1288.4) and no more than 4 years (§1288) after signed copy of award is served on petitioner: Yes ...

Excerpt: ...tive damages allegations and prayer RELEVANT FACTS: Plaintiffs Adelina M. and Salvador Alvizures allege that they are spouses, and that while plaintiffs were paying tenants at premises in Sun Valley which were owned and managed by defendant Minas Development, LLC, plaintiff Adelina M. was violently raped at knife point by an unknown male while doing laundry in the facility provided at the subject premises. The complaint alleges that prior to the ...

Excerpt: ...: Sustain demurrer to fourth and sixth causes of action of the First Amended Complaint (Redrock) Sustain demurrer to fourth, sixth and eighth causes of action of First Amended Complaint (Noho Commons) Strike Attorneys' Fees, Punitive Damages (Redrock) Strike Punitive Damages, Demand and collection of rent, statutory damages and penalties and attorney's fees (Noho Commons) CAUSES OF ACTION: from First Amended Complaint 1) Premises Liability 2) Neg...

Excerpt: ...et and Confer? Yes RELIEF REQUESTED: Dr. Kerendi Sustain demurrer to fifth through eighth causes of action of Second Amended Complaint Strike Punitive Damages Pacifica Hospital Sustain demurrer to fifth through fourteenth causes of action of Second Amended Complaint Strike punitive damages, attorney's fees CAUSES OF ACTION: from Second Amended Complaint 1) Medical Malpractice—Wrongful Death 2) Medical Malpractice—Wrongful Death (Survival Acti...

Excerpt: ...nc. dba Street Corner News alleges that it entered into a written lease agreement with defendant Glendale I Mall Associates, LP, and that defendant breached the agreement by failing to prevent the bathrooms in the Joint Use Areas from overflooding and affecting plaintiff's rented subject premises. The complaint alleges that flooding occurred multiple times from March of 2020 through February of 2021, and that as a result plaintiff has suffered mo...

Excerpt: ...Psychological Malpractice 2) IIED 3) NIED 4) Professional—Negligent Supervision SUMMARY OF FACTS: Plaintiff Yervan Saryan alleges that he is the father of a minor daughter who is eleven years old at the time of the filing of this action. Plaintiff alleges that the daughter's mother, from whom plaintiff is now divorced, unilaterally took the daughter for treatment at defendant Didi Hirsch Mental Health Services (“Didi Hirsch”) from the time ...

Excerpt: ... defendant Melody International Music School, Inc. from April through July of 2018, defendant Harmik Haghverdian, who was entrusted by defendant Melody with the supervision and care of plaintiff during the private music course, improperly and repeatedly touched, harassed, sexually assaulted, and battered plaintiff during his private classes. The complaint alleges that defendant Melody knew or should have known of this misconduct and failed to pre...

Excerpt: ...ross-Complaint Sever cross-suit filed against Travelers by defendant/cross-complainant OM ABS, Inc. dba Carrows Restaurant CAUSES OF ACTION: from Cross-Complaint 1) Breach of Contract 2) Conversion 3) Implied Covenant of Good Faith and Fair Dealing 4) Quantum Meruit 5) Unjust Enrichment 6) Contribution and Equitable Indemnity 7) Exemplary and Punitive Damages SUMMARY OF FACTS: Plaintiff Nextgen Associates, Inc. dba Servicemaster Restoration by EM...

Excerpt: ...itled to possession? Plaintiff Financial Pacific Leasing, Inc. is the assignee of a written Equipment Financing Agreement entered into by Ascentium Capital LLC with defendant H.D. Transportation, Inc. for the financing of certain equipment, a 2019 BMW. [Decl., paras. 4, 5, Exs. 1, 2]. In February of 2021, defendant failed to make the monthly payment, and has failed to make any further payments. [Decl., para. 7]. Plaintiff is entitled to immediate...

Excerpt: ...OF FACTS: Plaintiffs Lawrence Coates Agdigos and Lerma Candaza Agdigos allege that in June of 2018, they purchased residential real property in Glendale from defendant Manuel Lucero, for the purchase price of $700,000, and that defendant transferred the subject property to plaintiffs via a Grant Deed recorded on July 16, 2018. The complaint alleges that years earlier, in July of 2003, defendant Manuel Lucero executed a deed of trust in favor of d...

Excerpt: ...t entitled to possession? Plaintiff Ally Bank is an assignee of a Contract with defendant Robert Manukyan for the purchase of a motor vehicle. (Ex. A). Under this contract, upon a default of any provision, plaintiff has the right to immediate possession of the vehicle. [Bolduc Decl., ¶ 7, Ex. A, ¶ 3d]. Defendant has defaulted in payment on the agreement. [Decl., ¶ 8]. Defendant is further in default in that he has transferred the subject vehic...

Excerpt: ...ntered) CAUSES OF ACTION: from Complaint 1) Negligence Per Se; 2) Conversion; 3) Breach of Contract; 4) Fraud; 5) False Promise; 6) Restitution, Unjust Enrichment; 7) Breach of Implied Warranty of Fitness for a Particular Purpose; 8) Negligent Hiring, Retention, and Supervision; and 9) Negligence-Vicarious Liability SUMMARY OF FACTS: Plaintiff CAC Motors dba ZR Investment (“Plaintiff”) filed this action against Defendants X3 AST Consulting, I...

Excerpt: ... Services NA, LLC Responding Party: Defendants H&S Collision and Auto Repair, Inc., Samuel Petikyan, and Mkrtich Papazyan RELIEF REQUESTED: Summary judgment/adjudication in favor of Plaintiff Financial Services Vehicle Trust, by and through its servicer, BMW Financial Services NA, LLC as to the First Amended Complaint against Defendants H&S Collision and Auto Repair Inc., Samuel Petikyan, Mkrtich Papazyan, and the California DMV (third, fourth, s...

Excerpt: ... has been and may continue to be exchanged in this case FACTUAL BACKGROUND: Plaintiffs Akop Sogomonyan and Tsovinar Sogomonyan bring this action for malicious prosecution, alleging that their neighbors, defendants Anait Orudzhyan and Hamazasp Kiramijyan filed a previous action against plaintiffs, in which they were represented by defendant Karapet Zakaryan, who was employed by defendant KAASS PC, which was overseen and directed by its principal, ...

Excerpt: ... BACKGROUND: Plaintiff Deshnok Overseas Co. alleges that between June of 2017 and April of 2018 it entered into a written contract with defendants KL Global International Corp. and Kevin Liao for the purchase of goods, consisting of textiles. Plaintiff alleges that the contract consists of invoices, packing lists, and related shipping documents, and that the terms include full payment within thirty days of delivery with an inspection period of th...

Excerpt: ... from Complaint 1) Negligence 2) Negligence Per Se 3) Negligence SUMMARY OF COMPLAINT: Plaintiff Amira Strugano alleges that on December 17, 2017, plaintiff was lawfully traveling on Laurel Canyon Boulevard in plaintiff's motor vehicle when the vehicle was involved in a collision caused by a vehicle operated by defendant Elizabeth Rose Quinn, who drove defendant's vehicle into oncoming traffic, as a result of which plaintiff was hurt and physical...

Excerpt: ... motion, whichever is later. SUMMARY OF FACTS: Plaintiff Dennis P. Block, individually and dba as Dennis Block and Associates, as well as his associate attorneys plaintiffs Paul Eric Gold and Hasti Rahsepar , and his office manager, plaintiff Azam Riesen allege that plaintiff Block is regarded as one of the pre-eminent attorneys handling landlord-tenant matters, and that defendant BASTA, Inc. and Daniel Bramzon previously defended defendant Brett...

Excerpt: ...ond, third and tenth and eleventh causes of action of Second Amended Complaint CAUSES OF ACTION: from Second Amended Complaint 1) General Negligence 2) Negligent Hiring, Supervision or Retention of Employee 3) Premises Liability 4) Gross Negligence 5) Product Liability/Failure to Warn 6) Negligence/Product Liability 7) Strict Products Liability 8) Breach of Warranty of Merchantability 9) Breach of Implied Warranty of Fitness for a Particular Purp...

Excerpt: ...F REQUESTED: Sustain demurrer to Second Amended Complaint CAUSES OF ACTION: from Second Amended Complaint Various SUMMARY OF FACTS: Plaintiff Dehui Zeng filed a complaint in this action on February 17, 2021, which was over 180 pages long, and then, on February 22, 2021, filed a First Amended Form Complaint, superseding the initial complaint, which was six pages long, and checked the box that “The following causes of action are attached,” and ...

Excerpt: ... 1) Misappropriation of Trade Secrets 2) Conversion 3) Breach of Fiduciary Duty and or the Duty of Loyalty 4) Intentional Interference with Prospective Economic Advantage 5) Violation of Business & Professions Code section 17200 6) Invasion of Privacy SUMMARY OF FACTS: Plaintiff J & J Freight Solutions, LLC alleges that it is a successful trucking business, and that plaintiff Golden J Group, Inc. is a sister business of J & J, providing backup se...

Excerpt: ...ain demurrer to Complaint CAUSES OF ACTION: from Complaint 1) Violations of the Unruh Civil Rights Act, California Civil Code section 51 et seq. SUMMARY OF FACTS: Plaintiff Perla Mageno alleges that plaintiff is a visually impaired and legally blind person who requires screen-reading software to read website content using a computer, and that she has visited the website offered by defendant Insert Name Here, LLC, www.inhhair .com, and that during...

Excerpt: ...nant of Good Faith and Fair Dealing SUMMARY OF FACTS: Plaintiff Michelle Moore, LLC dba Bober Tea alleges that plaintiff operates a business called “Bober Tea,” a restaurant that primarily serves boba milk tea. Plaintiff alleges that in October of 2019, plaintiff entered into a contract with defendant Wikicart, LLC with Wikicart working in conjunction with defendant Aigens, Inc., pursuant to which defendants would develop and integrate softwa...

Excerpt: ...TION: from Second Amended Complaint 1) Breach of CC&Rs 2) Abatement of Nuisance and Nuisance Per Se 3) Declaratory Relief SUMMARY OF FACTS: Plaintiff The Arlington Green Homeowners Association alleges that it operates and manages a common interest development project in Pasadena and brings this action as an authorized representative of its member pursuant to Civil Code section 5980 and the Declaration of Covenants, Conditions and Restrictions (�...

Excerpt: ...BY: Formal Notice [Amended Notice, Exhibit A]. RELIEF REQUESTED BY MOVING PARTY: Order compelling defendant Rosemead Hwang, LLC to produce documents and supplemental deposition testimony to plaintiff Chao Hsin Chuan's First Amended Notice of Taking Deposition of Gemma Hwang. DECLARATION SUPPORTING MOTION: Reasonable and good faith attempt to resolve informally: Ok, Ex. C CHRONOLOGY Date NOTICE OF DEPOSITION served: March 18, 2021 Date of Depositi...

Excerpt: ...any and Sempra Energy as to the Second Cause of Action in plaintiffs' First Amended Complaint Causes of Action from First Amended Complaint 1) Negligence (Count I) v. Design Build, Kanounji, Hunter, Sapphire 2) Negligence (Count II) v. Southern California Gas, Sempra Energy 3) Breach of Contract (Count I) v. Design Build, Kanounji 4) Breach of Contract (Count II) v. Design Build, Kanounji 5) Breach of Implied Covenant v Design Build, Kanounji, Hu...

Excerpt: ... in her complaint. King Street Productions Motion Summary adjudication as to plaintiff's allegations of punitive damages in her complaint Causes of Action from Complaint 1) Negligence 2) Negligence Per Se SUMMARY OF COMPLAINT: Plaintiff Amira Strugano alleges that on December 17, 2017, plaintiff was lawfully traveling on Laurel Canyon Boulevard in plaintiff's motor vehicle when the vehicle was involved in a collision caused by a vehicle operated ...

Excerpt: ...021 SUMMARY OF FACTS: Plaintiff F. Glenn Nichols alleges that an actual controversy has arisen between plaintiff and defendants Pickard & Butters Construction, Inc. (“PBC”) and North American Specialty Insurance Company (“NASIC”) with respect to the parties' rights, duties, obligations and liabilities under a written retainer agreement executed by plaintiff and defendant PBC for legal services and representation in January of 2012. Plaint...

Excerpt: ...nt at South Pasadena Middle School, under the care of defendant South Pasadena Unified School District, plaintiff was sexually harassed, molested and abused by defendant Deguzman, whom the District had hired to serve as a basketball coach, mentor, supervisor and to counsel minor students, including plaintiff. ANALYSIS: Under CCP § 2017.010, “any party may obtain discovery regarding any matter, not privileged, that is relevant to the subject ma...

Excerpt: ...a paying tenant of defendant Sarkis Khachmanian at premises in Glendale, and that plaintiff was attacked and beaten by other tenants at the property, defendants Minasova, Artur, and a trespasser illegally housing with them, defendant Guillermo, as a result of which plaintiff suffered severe and disabling injuries. Plaintiff alleges that defendant Khachamanian, and his employee and building manager, defendant Cago Cherchyan, were aware of dangerou...

Excerpt: ...ms of the settlement agreement reached between the parties SUMMARY OF FACTS: Plaintiffs allege that decedent John A. McGinnis was an elder as that term is defined in Welfare & Institutions Code section 15610.27, and that on February 20, 2018, decedent was admitted to defendant USC Verdugo Hills Hospital (“USC”) for a possible infection. At the time, decedent was on steroid medications, which are known to elevate blood sugar levels. The compla...

Excerpt: ... proceedings SUMMARY OF FACTS: Plaintiff Esperanza Bagwell alleges that she is the owner of property on Primrose Avenue in Monrovia based on plaintiff's actual, open, notorious, exclusive, hostile and adverse possession of the subject property for five years preceding the commencement of this action and has paid all taxes assessed against the property for the same five years. Plaintiff alleges that plaintiff and defendants JP Morgan Chase Bank (�...

Excerpt: ...e production of documents ordered to be produced by the court at deposition Leave to file Second Amended Complaint FACTUAL BACKGROUND: Plaintiff Prapai Benjauthrit brings this action against her brother, defendant Boonseing Benjauthrit, alleging that the parties took title to four properties on Marion Drive in Glendale in 1977 as joint tenants, with the subject property to be the principal place of residence of plaintiff. Plaintiff alleges that d...