Excerpt: ...ional Elder Abuse 5) Fraud 6) Theft SUMMARY OF FACTS: Plaintiff Lorraine Rhone alleges that in January of 2022 plaintiff entered into an agreement with defendant Redondo Van and Storage, Inc. to move plaintiff's household goods from a two-bedroom upstairs apartment in Glendale to the city of San Pedro. Plaintiff was quoted a price of $2,400 to $3,200, with four men. Plaintiff alleges that instead of four men, five men arrived not prepared to crat...

Excerpt: ...ations, punitive damages, treble damages CAUSES OF ACTION: from Complaint 1) Fraud v. Hamadi, Minasyan 2) Conspiracy to Defraud v. Hamadi, Minasyan 3) Intentional Misrepresentation v. Hamadi, Minasyan 4) Breach of Fiduciary Duty v. Minasyan 5) Breach of Oral Contract v. Hamadi, Keshishyan 6) Unjust Enrichment v. Hamadi, Keshishyan 7) Conversion v. Hamadi, Keshishyan 8) Theft -Receipt of Stolen Property v. Hamadi 9) NIED v. Hamadi SUMMARY OF FACTS...

Excerpt: ...ction of Documents, Set One FACTUAL BACKGROUND Plaintiff Toni Lawson-Apana alleges that she leased a vehicle from defendant Sunrise Ford, which vehicle was manufactured by defendant Ford Motor Company, and which was equipped with a Power Liftgate System, an electrical opening and closing system. Plaintiff alleges that contrary to defendants' representations regarding the subject vehicle's safety and reliability, in April of 2015, while plaintiff ...

Excerpt: ...entative of the Estate of Jim Cox. SUMMARY OF FACTS: The complaint alleges that Ivy Fung, the mother of plaintiff Kurt Takashi Ando, created a Revocable Trust in 2016. Ivy Fung was the Trustee, with successor Trustees being plaintiff and/or Marie Bernardini. The Trust was created by Ivy Fung after she was diagnosed with terminal illness, and was revocable until her death, after which the Trust became irrevocable and all Trust property was to be h...

Excerpt: ...(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 4) Breach of the Implied Warranty of Merchantability 5) Fraudulent Inducement—Concealment SUMMARY OF FACTS: Plaintiff Grigor Golamirians alleges that in September of 2020 plaintiff entered into a warranty contract with defendant General Motors, LLC (GM) regarding a 2020 Chevrolet Bolt vehi...

Excerpt: ...m First Amended Complaint 1) Negligence 2) Conversion 3) Breach of Contract 4) NIED 5) IIED SUMMARY OF FACTS: Plaintiff Raya Torossian alleges that in March of 2020, plaintiff contracted with defendant Zippy Shell, Inc. (Zippy Shell) to have personal belongings moved, in a closed storage container, to North Carolina. In April of 2020, defendant Pack Rats Portable Mini Storage, LLC (Pack Rats), on behalf of Zippy Shell, met with plaintiff to pick ...

Excerpt: ...First Amended Complaint 1) Negligent Act or Omission of Public Entity or Public Employee 2) Dangerous Condition of Public Property SUMMARY OF FACTS: Plaintiffs Natasha Asatryan and Vartan Asatryan, the parents of decedent Liana Asatryan, allege that on December 2, 2021, defendants City of Glendale, Glendale Unified School District, and Balboa Elementary School negligently hired, retained, trained and supervised defendants' employees, and negligen...

Excerpt: ...of the plaintiff's claim and that entitled to possession? No declaration or documentary evidence submitted. If based on written instrument, copy attached? No. Showing that property wrongfully detained by defendant, manner in which came into possession and reason for detention? No showing Particular description of property and statement of its value? No showing, application Statement of location of the property No showing, application Property not...

Excerpt: ...s this action against her former employer, defendant Systech Solutions, LLC, alleging that in July of 2020, plaintiff was hired as a Marketing and Corporate Communications Analyst, and was wrongly classified as an exempt employee and paid an annual salary, when her employment position did not fall under any exception to the non-exempt employee status. Plaintiff alleges that due to this misclassification, plaintiff was denied overtime that she was...

Excerpt: ... vehicle from Glendale Hyundai, and that upon the purchase defendant Hyundai Motor America issued an express warranty to plaintiff, pursuant to which defendant undertook to preserve or maintain the utility or performance of the vehicle. Plaintiff alleges that since purchasing the vehicle, plaintiff has delivered the vehicle for repair to defendant or its authorized repair facility not less than three times for repair of nonconformity to warranty,...

Excerpt: ...Plaintiff Nate Beltran alleges that while he was a resident or patient with defendant BHC Alhambra Hospital, Inc. (BHC Alhambra), he was a dependent adult. Plaintiff alleges that in September of 2021, plaintiff was brutally attacked by another patient while admitted at BHC Alhambra, when, while plaintiff was sound asleep in his hospital bed, another patient started punching and choking plaintiff. Plaintiff rolled out of bed and was on the ground ...

Excerpt: ...ants Wayne Hazle and Mary Ellen Hazle to occupy premises in Glendale, and has at all times satisfied her lease and has been in lawful possession of her apartment. Plaintiff alleges that the tenancy is subject to the Tenant Protection Act of 2019. Plaintiff alleges that plaintiff has been living in the back room/garage of defendants' property as specified in the Lease Agreement, but that the premises were not permitted to be safe, inhabitable, or ...

Excerpt: ...LA Auto Center, Inc. owes plaintiff money in the sum of $10,000 because defendant paid off plaintiff's loan amount of $5,700 and evaluated his Honda Civil for $9,800 as his trade in value, and in the same transaction defendant sold plaintiff a used Volkswagen GTI for $12,166. Plaintiff claims that when he drove the car off the lot the check engine light turned on, and there followed a six-month period of empty promises, excuses and run around ans...

Excerpt: ...leges that in February of 2023, plaintiff entered into a written Food Truck Lease Agreement with defendants Timofey Kravtsov, Elena Kravtsova, and Coffeegizer, LLC pursuant to which defendants agreed to lease a 2021 Mercedes Sprinter Food Truck for 12 months at $3,500 per month. The complaint alleges that the Lease required an initial $10,000 payment for first and last month's lease payments and a $3,000 security deposit, which defendants paid, b...

Excerpt: ...r Production of Documents, Set One DECLARATION SUPPORTING MOTION: Reasonable and good faith attempt to resolve informally: Yes, Sobati Decl., paras. 6, 7 Ex. E FACTUAL BACKGROUND Plaintiff and decedent Alberd Ishoo, through his successor in interest, his daughter, Sinla Ishoo, alleges that decedent passed away as a result of injuries caused by abuse and neglect while decedent was a patient at defendant Providence Saint Joseph Medical Center in Bu...

Excerpt: ...er to Proceed Using Pseudonyms and accompanying exhibits in the Court's public file. FACTUAL AND PROCEDURAL BACKGROUND: This action is brought by plaintiff Jane DOE K.C. 1 and plaintiff Jane Doe A.H. 2, who allege that they are survivors of childhood sexual abuse, sexual battery, assault, molestation and abuse at the hands of defendant (originally sued as defendant Doe 1) Gloria de Los Angeles Trevino Ruiz aka Gloria Trevi, and defendant (origina...

Excerpt: ...s been served) RELIEF REQUESTED: Order transferring this action from Los Angeles Superior Court to Fresno County Superior Court FACTUAL BACKGROUND: Plaintiffs David Montes and Consuelo Montes allege that in March of 2019 plaintiffs purchased a 2019 Ford F-150, for which defendant Ford Motor Company (Ford) issued a written warranty, pursuant to which Ford agreed to preserve or maintain the utility or performance of the vehicle or provide compensat...

Excerpt: ... action based on a complaint in intervention. Plaintiff alleges that plaintiff is a licensed escrow agent and is now in possession of $33,750.00 in disputed money, which funds represent the earnest money deposit of defendant Lusine Hakhverdyan (Buyer) submitted to Escrow during the purchase of real property in Van Nuys from defendants Karapet Kiramichyan and Tsonvinar Kiramittchian (Sellers). Plaintiff alleges that in June of 2018, the defendants...

Excerpt: ...that in February of 2021, plaintiff walked into a commercial building located on private property on Brand Boulevard owned, operated, maintained, and controlled by defendants Alta Construction and UBS Realty Investors LLC. Plaintiff alleges that while moving into the facility on surfaces and other points of passage intended for public use, plaintiff slipped and fell due to oil that was on the floor, and fell to the ground, sustaining injuries. Pl...

Excerpt: ...achs Bank USA and against defendant Viktoryia Antashkevich. In the alternative, summary adjudication in favor of plaintiff on the first cause of action for open book account. CAUSES OF ACTION: from (Form) Complaint 1) Common Counts Open Book Account Account Stated Money Lent Money Paid, Laid Out and Expended at Defendant's Special Instance and Request Other SUMMARY OF FACTS: Plaintiff Goldman Sachs Bank USA alleges that within the last four years...

Excerpt: ...amount of $3,826 for plaintiff's purported failure to comply with the March 11, 2022 Order. FACTUAL AND PROCEDURAL BACKGROUND: Plaintiff Mark Ellensohn alleges that on June 9, 2015, plaintiff was traveling on Interstate 5 southbound approximately 100 feet north of Alameda Avenue in the City of Burbank, where a low hanging live and uncovered electrical wire was stretched across the freeway, hanging at such a height that it posed an unreasonable an...

Excerpt: ...umyan for the sale of a motor vehicle. (Ex. 1). Under this Contract, upon a default of any provision, plaintiff has the right to immediate possession of the vehicle. [Wilber Decl., ¶ 6, Ex. 1, ¶ 3d]. Defendant has defaulted in payment on the agreement. [Wilber Decl., ¶¶10, 11]. Plaintiff is aware that defendant Shaumyan is no longer in possession of the vehicle, and that defendant Gad Auto Body Shop Inc. (Gad Auto) is currently in possession ...

Excerpt: ...ORTING MOTION: Reasonable and good faith attempt to resolve informally: Yes, Sobati Decl., paras. 6, 7 Ex. E FACTUAL BACKGROUND Plaintiff and decedent Alberd Ishoo, through his successor in interest, his daughter, Sinla Ishoo, alleges that decedent passed away as a result of injuries caused by abuse and neglect while decedent was a patient at defendant Providence Saint Joseph Medical Center in Burbank. The complaint alleges that decedent, a depen...

Excerpt: ...blic Nuisance v. Bedikian Defendants 4) Trespass v. Bedikian Defendants 5) Negligence v. Bedikian Defendants 6) Breach of Contract v. Hippo 7) Breach of Covenant of Good Faith and Fair Dealing v. Hippo 8) Violation of Fair Housing Act v. Hippo SUMMARY OF FACTS: Plaintiff Mae Abou-Chakra alleges that defendants Alice Bedikian and Hrant Bedikian are the owners of property which adjoins property owned and occupied by plaintiff in La Crescenta. Plain...

Excerpt: ...nd Substitute Plaintiff Jason Steger Responding Party: Motion for Reconsideration Defendant Olympus America Inc. Defendants John A. Kasher, M.D. and James Kao, M.D. Motions to Dismiss Plaintiff Jason Steger Motion to Augment and Substitute Defendant Olympus America, Inc. “Joinder” filed by Defendants John A. Kasher, M.D. and James Kao, M.D. RELIEF REQUESTED: Motion for Reconsideration Order reconsidering in part, the Court's minute order date...

Excerpt: ..., 2023 Date Responses served: NO RESPONSES SERVED Date Motion served: October 5, 2023 Timely OPPOSITION: No opposition ANALYSIS: Under CCP § 2033.280, a party who fails to serve a timely response to requests for admissions “waives any objection to the requests.” In addition, the requesting party may move for an order that “the truth of any matters specified in the requests be deemed admitted, as well as for a monetary sanction....” CCP S...

Excerpt: ... damages to plaintiff. The form complaint alleges causes of action for Motor Vehicle and General Negligence. ANALYSIS: CCP § 418.10 permits a defendant, on or before the last day of his time to plead, to serve and file a motion to quash service of summons “on the ground of lack of jurisdiction of the court over him...” § 418.10(a)(1). With respect to a motion to quash for lack of jurisdiction, the burden is on plaintiff to demonstrate by a ...

Excerpt: ...laintiff Goldman Sachs Bank USA and against defendant Viktoryia Antashkevich. In the alternative, summary adjudication in favor of plaintiff on the first cause of action for open book account. CAUSES OF ACTION: from (Form) Complaint 1) Common Counts Open Book Account Account Stated Money Lent Money Paid, Laid Out and Expended at Defendant's Special Instance and Request Other SUMMARY OF FACTS: Plaintiff Goldman Sachs Bank USA alleges that within t...

Excerpt: ...ntract stemming from alleged false claim made to plaintiff's bonding company request for punitive damages CAUSES OF ACTION: from (Form) Complaint 1) Breach of Contract 2) Fraud 3) General Negligence SUMMARY OF FACTS: Plaintiff HR General Construction, Inc. (HR General Construction) alleges that in December of 2021 plaintiff entered into a written contract with defendants Scott Sakamoto and Jamie Sakamoto, and that defendants breached the agreemen...

Excerpt: ...es to Request for Documents Further Responses to Requests for Admissions, Nos. 6-8, 12-17, 19-24 and 35-37. FACTUAL BACKGROUND Plaintiff Korea Trade Insurance Corporation alleges that it is assignee to Mido Trade Co., Ltd, and brings this action for common counts, alleging that defendant Mix & Match Apparel, Inc. has become indebted to plaintiff in the sum of $152,244.49. The complaint alleges causes of action for open book account, account state...

Excerpt: ...ta alleges that in January of 2022, plaintiff purchased a 2022 Kia Telluride vehicle manufactured by defendant Kia America, Inc. (Kia) and in connection with the purchase of the vehicle plaintiff received an express written warranty in which defendant undertook to maintain the utility or performance of the vehicle or to provide compensation if there was a failure in utility or performance for a specified period of time. After plaintiff took posse...

Excerpt: ...tiffs at all relevant times have resided in an illegally built structure located at 12223 Wick Street in Sun Valley, Unit A, since February 2009 to the present, pursuant to a written lease agreement with the former landlord. Plaintiffs allege that defendant Karen Baca is the true owner of the subject property and unit, and that defendant Ana Moreno has acted as property manager since September of 2015. Plaintiffs allege that during their tenancie...

Excerpt: ...ion 3) Negligent Misrepresentation 4) Quantum Meruit SUMMARY OF FACTS: Plaintiff A&T Advisors dba Anchor Bookkeeping (Anchor Bookkeeping) alleges that in October of 2022, plaintiff and defendant Cahit Soykat dba Roma Pizza (Soykat) entered into an Agreement for Limited Consulting Services whereby plaintiff agreed to assist, advise, consult, prepare and help defendant to apply for and become eligible for the Employee Retention Credit (ERC) program...

Excerpt: ...from First Amended Complaint 1) Breach of Implied Warranty of Habitability 2) Breach of Implied Warranty of Habitability 3) Negligent Premises Liability 4) Nuisance 5) IIED 6) Breach of Contract 7) Breach of Covenant of Quiet Enjoyment 8) Breach of the Covenant of Good Faith and Fair Dealing 9) Fraud/Deceit/Intentional Misrepresentation of Fact 10) Negligent Misrepresentation SUMMARY OF FACTS: Plaintiff Rebecca Garcia alleges that in October of 2...

Excerpt: ...om Cross-Complaint 1) Express Indemnity 2) Implied Indemnity 3) Contribution 4) Declaratory Relief SUMMARY OF FACTS: Plaintiff Julieta Paez has filed this action alleging that in February of 2021, plaintiff walked into a commercial building located on private property on Brand Boulevard owned, operated, maintained, and controlled by defendants Alta Construction and UBS Realty Investors LLC. Plaintiff alleges that while moving into the facility on...

Excerpt: ...ave resided in an illegally built structure located at 12223 Wick Street in Sun Valley, Unit B, since April 2012 to the present, pursuant to a written lease agreement with the former landlord. Plaintiffs allege that defendant Karen Baca is the true owner of the subject property and unit, and that defendant Ana Moreno has acted as property manager since September of 2015. Plaintiffs allege that during their tenancies at the unit and defendants' ow...

Excerpt: ...tative of the Estate of Jim Cox. SUMMARY OF FACTS: The complaint alleges that Ivy Fung, the mother of plaintiff Kurt Takashi Ando, created a Revocable Trust in 2016. Ivy Fung was the Trustee, with successor Trustees being plaintiff and/or Marie Bernardini. The Trust was created by Ivy Fung after she was diagnosed with terminal illness, and was revocable until her death, after which the Trust became irrevocable and all Trust property was to be han...

Excerpt: ...e Martello, M.D. In the alternative, summary adjudication in favor of each moving defendant 75/80 Day Lapse: Yes Separate Statements: Yes Causes of Action from Complaint 1) Medical Malpractice SUMMARY OF COMPLAINT: Plaintiff John Peter Robinson alleges that on June 25, 2020, plaintiff presented to defendant Urgent Med dba Glendale Urgent Care (Glendale Urgent Care) with a chief complaint of lacerations to the right hand secondary to a dog bite in...

Excerpt: ...gust of 2021 plaintiff leased a new 2021 BMW M5 vehicle from Pacific BMW in Glendale, and that the subject vehicle was delivered to plaintiff with serious defects and nonconformities to warranty, including transmission issues, center console screen issues, and repeat driver seat motor defects. Plaintiff alleges that plaintiff presented the vehicle on numerous occasions to defendant BMW of North America, LLC's authorized repair facilities for repa...

Excerpt: ...at in March of 2022 plaintiff entered into a warranty contract with Kia America, Inc. regarding a 2018 Kia Nero. Plaintiff alleges that under the Song-Beverly Act, defendant had an affirmative duty to promptly offer to repurchase or replace the vehicle at the time defendant failed to conform the vehicle to the terms of the express warranty after a reasonable number of attempts. Plaintiff alleges that defects and nonconformities to warranty manife...

Excerpt: ...tiff Jason Steger Motion to Augment and Substitute Defendant Olympus America, Inc. “Joinder” filed by Defendants John A. Kasher, M.D. and James Kao, M.D. RELIEF REQUESTED: Motions to Dismiss Order dismissing action pursuant to CCP sections 583.310 and 583.360. Motion to Augment and Substitute Order permitting plaintiff to augment and substitute list of designated experts and extend date to complete expert deposition of Dr. Tawhid Gazi pending...

Excerpt: ...tories (Set One), Interrogatories Nos. 1, 4, and 19, from each plaintiff FACTUAL BACKGROUND Plaintiffs Neuro Diagnostic Center, Inc. and Shushanik Devine allege that they were in possession of premises in Glendale and that defendants A & D Fire Sprinklers, Inc. and National Community Renaissance of California, while conducting construction work installing a new fire sprinkler system and plumbing at property directly behind the subject premises, w...

Excerpt: ... and issue a case management order FACTUAL AND PROCEDURAL BACKGROUND: Plaintiff Pointe Assets, LLC, the successor in interest to Catalina Media Development, LLC (CMD), alleges that CMD owns real property in Burbank, commonly referred to as “The Pointe,” an office building and parking garage. Plaintiff alleges that in early 2006, plaintiff entered into an agreement with Krismar Construction Co. concerning construction of the Pointe, which, in ...

Excerpt: .... 85. FACTUAL BACKGROUND: Plaintiff Nate Beltran alleges that while he was a resident or patient with defendant BHC Alhambra Hospital, Inc. (BHC Alhambra), he was a dependent adult. Plaintiff alleges that in September of 2021, plaintiff was brutally attacked by another patient while admitted at BHC Alhambra, when, while plaintiff was sound asleep in his hospital bed, another patient started punching and choking plaintiff. Plaintiff rolled out of ...

Excerpt: ...stitute list of designated experts and extend date to complete expert deposition of Dr. Tawhid Gazi pending this application and de-designation of Dr. Tawhid Gazi FACTUAL and PROCEDURAL BACKGROUND: Plaintiff Jason Steger alleges that in October of 2016, plaintiff was admitted to defendant CSJ Providence St. Joseph Medical Center with abdominal pain, and that defendants, various medical providers, negligently performed a colonoscopy procedure on p...

Excerpt: ...AUSES OF ACTION: from Complaint 1) Violation of the California Homeowners Bill of Rights 2) Wrongful Foreclosure 3) Promissory Estoppel 4) Injunctive Relief * *Cause of action dismissed pursuant to a Request for Dismissal with prejudice filed by plaintiff on 07/31/2023 and entered as requested the same date. FACTUAL AND PROCEDURAL BACKGROUND: Plaintiff Ayman M. Salem alleges that plaintiff is the owner of real property in La Canada, and that plai...

Excerpt: ...aintiff Goldman Sachs Bank USA and against defendant Viktoryia Antashkevich. In the alternative, summary adjudication in favor of plaintiff on the first cause of action for open book account. CAUSES OF ACTION: from (Form) Complaint 1) Common Counts Open Book Account Account Stated Money Lent Money Paid, Laid Out and Expended at Defendant's Special Instance and Request Other SUMMARY OF FACTS: Plaintiff Goldman Sachs Bank USA alleges that within th...

Excerpt: ... not take place. SUMMARY OF FACTS: Plaintiff GPR Properties, LLC alleges that in June of 2014, it leased a storage space it owns in Glendale to defendants Shiraz Rental, Inc. (Shiraz Rental), Goorgen Mirzakhanian, and Soren Shabazian for five years. In 2019, plaintiff and defendants signed a new Lease for another five-year period for the premises. Plaintiff alleges that the individual defendants signed the Lease, and plaintiff believes they signe...

Excerpt: ... ACTION: from Third Amended Complaint 1) Medical Malpractice/Wrongful Death 2) Medical Malpractice/Negligence/Survival Action 3) Elder Neglect SUMMARY OF FACTS: Plaintiff Victor Tsai, the surviving spouse of decedent Mimi Kuo, and plaintiffs Alice Tsai and Rose Tsai, the surviving children of decedent, allege that from May through June of 2018, decedent received treatment at different defendants' health care facilities, and that defendants, and t...

Excerpt: ...t for Production of Documents, Set One CHRONOLOGY Date Discovery served: April 19, 2023 Extensions to Respond to: July 27, 2023 (Ex. F) Date Responses served: NO RESPONSES SERVED Date Motion served: August 17, 2023 Timely OPPOSITION: No opposition. ANALYSIS: Under CCP § 2030.290, “If a party to whom interrogatories are directed fails to serve a timely response,” that party “waives any legal right to exercise the option to produce writings....