Excerpt: ...3, 2021 Effect of Amendment Adds affirmative defense of statute of limitations, correct typographical errors, respond more accurately to allegations in SAC based on present knowledge RELEVANT FACTS: Plaintiff Prapai Benjauthrit brings this action against her brother, defendant Boonsieng 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 pri...

Excerpt: ...essor Trustee, as to Yusuf's Cross-Complaint for partition by sale and as to plaintiffs' cause of action for partition by sale as alleged in plaintiffs' complaint SUMMARY OF FACTS: Plaintiffs John B. Jung and Ellen L. Jung, as trustees of a family trust, allege that plaintiffs and defendant Michael Yusuf, trustee of the Yusuf trust, are co-owners of real property and improvements located on East Orange Grove in Glendale. The complaint alleges tha...

Excerpt: ...d Mita Vaghashia to be tried after plaintiff Rakesh Kothari's claims alleged in the First Amended Complaint FACTUAL AND PROCEDURAL 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...

Excerpt: ...efendants 2) Negligence Per Se v. All Defendants* 3) Breach of the Warranty of Habitability v. LBM and Anoakia 4) Breach of Covenant of Quiet Enjoyment v. LBM and Anoakia 5) NIED v. LBM and Anoakia* 6) Breach of Contract v. LBM and Anoakia *Causes of action dismissed without prejudice on 12/27/21 SUMMARY OF FACTS: Plaintiff Nvart Krlian alleges that in January of 2009, plaintiff entered into a Residential Lease with G.M. Kefalas aka G.M. Kefalas ...

Excerpt: ...Canyon, Inc. 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 provide the leased premises in good order and satisfactory condition in violation of Article 10 of the Lease, and by failing to provide repairs to internal pipes of the facility housing the premises leading to a failure in structural repairs in violation o...

Excerpt: ...efendants 2) Negligence Per Se v. All Defendants* 3) Breach of the Warranty of Habitability v. LBM and Anoakia 4) Breach of Covenant of Quiet Enjoyment v. LBM and Anoakia 5) NIED v. LBM and Anoakia* 6) Breach of Contract v. LBM and Anoakia *Causes of action dismissed without prejudice on 12/27/21 SUMMARY OF FACTS: Plaintiff Nvart Krlian alleges that in January of 2009, plaintiff entered into a Residential Lease with G.M. Kefalas aka G.M. Kefalas ...

Excerpt: ...arty Electric Entertainment, Inc. RELIEF REQUESTED: Orders quashing subpoenas DECLARATION SUPPORTING MOTION: Reasonable and good faith attempt to resolve informally: Yes FACTUAL BACKGROUND: Plaintiff Candice Vega-Gershon alleges that she began employment with defendant The Walt Disney Company (“Disney”) in October of 2015 with the Residuals Team, and that during her interview process, she informed Disney that her husband was terminally ill wh...

Excerpt: ...d Amended Cross-Complaint 1) Complete Indemnity 2) Partial Indemnity 3) Declaratory Relief 4) Violations of BPC sections 7000, et seq. 5) Breach of Contract 6) Fraud 7) Negligence SUMMARY OF FACTS: Plaintiff Guillermo Ochoa alleges that on November 9, 2019, at or near Vernon Road in Glendale, defendants Jose Avalos and Jose Hulzar negligently operated, owned, entrusted, and employed the persons who operated a motor vehicle, causing injuries and d...

Excerpt: ...dical Center to file a record under seal in support of its motion for summary judgment, and all pleadings and other documents referencing thereto and disclosing the contents thereof. SUMMARY OF FACTS: Plaintiff Shake Rubyan alleges that in October of 2018, plaintiff arrived at the facilities of defendant Physician Surgery Center at Glendale Adventist, LLC (“Surgery Center”) for outpatient colonoscopy and endoscopy medical services. Plaintiff ...

Excerpt: ...c., a California corporation), collectively (“Receiver”) Proof of Service Timely Filed (CRC Rule 3.1300): ok 16/21 Court Days Lapsed (CCP 1005(b)): ok Oppo and Reply submitted RELIEF REQUESTED: City of Duarte (“City”) moves for an order reimbursing City for $26,446.00 in attorneys' fees. This motion is made pursuant to this Court's December 16, 2021, Judgment for City pursuant to CCP §§578 and 579; CCP §435.16(c)(1); this Court's and t...

Excerpt: ...ed (CCP 1005(b)): ok Proper Address:ok Oppo and Reply submitted. Defendant notes that Plaintiff submitted its Opposition late; however, the Court notes that it will still consider Plaintiff's untimely filed Opposition. RELIEF REQUESTED: Defendant, Forest Lawn Memorial-Park Association (“Defendant”) demurs to all causes of action in Plaintiff's First Amended Complaint (“FAC”). Defendant demurs to Plaintiff's first cause of action for breac...

Excerpt: ...k account for money due, because an account was stated in writing between plaintiff and defendant in which it was agreed that defendant was indebted to plaintiff, for money lent by plaintiff to defendant at defendant's request, and for money paid, laid out, and expended to or for defendant at defendant's special instance and request. The complaint alleges that $51,282.02, which is the reasonable value, is due and unpaid despite plaintiff's demand...

Excerpt: ...rrer to second cause of action of First Amended Cross-Complaint CAUSES OF ACTION: from First Amended Cross-Complaint 1) Breach of Contract v. Golshan 2) Breach of Implied Contract v. Ataian 3) Fraud v. Ataian 4) Indemnity v. Ataian SUMMARY OF FACTS: 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 Ange...

Excerpt: ...ACTION: from Complaint (from body of pleading, not caption) 1) Breach of the Covenant of Quiet Enjoyment 2) Breach of Implied Warranty of Habitability 3) IIED 4) Negligence 5) Nuisance 6) Business & Professions Code section 17200 et seq. 7) Collection of Rent on Substandard Dwelling 8) Breach of Contract 9) NIED 10) Constructive Eviction SUMMARY OF FACTS: Plaintiffs Edgar Torosyan and Marina Kegeyan allege that they rented a dwelling unit located...

Excerpt: ...wo Order Deeming Requests for Admissions Admitted CHRONOLOGY Date Discovery served: October 19, 2021 Date Responses served: NO RESPONSES SERVED Date Motion served: January 18, 2022 Timely ANALYSIS: Document Demands Under CCP § 2031.300, “if a party to whom a demand for inspection, copying, testing or sampling is directed fails to serve a timely response to it,” that party “waives any objection to the demand, including one based on privileg...

Excerpt: ...endant A Cut Above Building & Developing Inc. RELIEF REQUESTED: A Cut Above Further Responses to Special Interrogatories (Set One) Stull Further Responses to Special Interrogatories Nos. 65 and 83 FACTUAL BACKGROUND Plaintiff A Cut Above Building & Development Inc. (“A Cut Above”) alleges that in August of 2018 plaintiff commenced construction work at property in Monrovia, title of which is held by the Rachelle K. Stull 2014 Revocable Trust, ...

Excerpt: ...aim for money based upon a contract, express or implied, where the total amount of the claim is a fixed or readily ascertainable amount not less than $500, exclusive of costs, interest and attorney's fees] Claim is for amount due under written Small Business Credit Agreement (“Agreement”) between plaintiff MUFG Union Bank, N.A. and defendant We Go Transport, Inc. pursuant to which defendant was provided an unsecured business line of credit, a...

Excerpt: ...ina 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 sexual assault, defendant knew or should have known that incidents ...

Excerpt: ... judgment against plaintiffs In the alternative, summary adjudication of first, second, third, fourth, fifth and seventh causes of action and/or claim for punitive damages. Causes of Action from Complaint 1) Breach of Contract v. All Defendants 2) Breach of Implied Covenant of Good Faith and Fair Dealing v. All Defendants 3) Fraud v. All Defendants 4) Declaratory Relief v. All Defendants 5) Violation of Business & Professions Code Section 17200 v...

Excerpt: ...s Fees and Tax Costs) Plaintiff Nick Nichols (Tax Costs) RELIEF REQUESTED: Attorneys' Fees Attorney's fees in the amount of $885,000.00 Tax Costs City's Motion—Strike or tax costs claimed in Memorandum of Costs filed by plaintiff Nichol's Motion—Strike or tax costs claimed in Memorandum of Costs filed by defendants SUMMARY OF FACTS: Plaintiff Nick Nichols commenced this proceeding on October 30, 2015. The verified First Amended Complaint alle...

Excerpt: ...laintiff Golden Canyon, Inc. 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 provide the leased premises in good order and satisfactory condition in violation of Article 10 of the Lease, and by failing to provide repairs to internal pipes of the facility housing the premises leading to a failure in structural repair...

Excerpt: ...ha House of Prayer, Inc. Status of Deponent: Defendants (parties) DEPO ATTENDANCE REQUIRED BY: Formal Notices [Exhibits A]. RELIEF REQUESTED BY MOVING PARTY: Order compelling defendants to produce documents at deposition. DECLARATION SUPPORTING MOTION: Reasonable and good faith attempt to resolve informally: Yes, Decl., paras. 13-16, Exs. D, E, F CHRONOLOGY Date NOTICE OF DEPOSITION served: August 24, 2021 Date of Deposition (10 day lapse): Septe...

Excerpt: ...RC separate statement, etc.: Yes DECLARATION SUPPORTING MOTION: Reasonable and good faith attempt to resolve informally: Ok, Decl., paras. 28-34, Exs. 12-18 FACTUAL BACKGROUND: Plaintiff Efrain Lopez alleges that in March of 2019, plaintiff purchased a 2019 Subaru Impreza, which was manufactured or distributed by defendant Subaru of America, Inc. Plaintiff alleges that in connection with the purchase, plaintiff received an express written warrant...

Excerpt: ...aint filed: June 2, 2021 Effect of Amendment Adds cause of action for quiet title in response to defendant's cross-complaint claiming a permanent equitable easement over plaintiff's commercial property. RELEVANT FACTS: Plaintiff 77 Del Mar, LLC alleges that it owns real property in Pasadena, and that in June of 2019 it obtained a boundary survey of the subject property and became aware that defendant Sixty-Four West Valley, LLC, the owner of a pa...

Excerpt: ... on East Acacia Avenue in Glendale, along with their three minor children, pursuant to a written lease agreement. Plaintiffs allege that defendant Rudy Covarubus was the owner or manager of the subject property and defendant Acacia Riverdale Property Management, LLC was the manager of the subject property. Plaintiffs allege that during the tenancy, from October to 2014 to May of 2020, defendants failed to provide habitable living conditions, and ...

Excerpt: ...e Company, Ltd. (U.S. Branch) summary judgment on the complaint filed by plaintiffs In the alternative, summary adjudication of cause of action for tortious breach of the implied covenant of good faith and fair dealing and/or claim for punitive damages. Causes of Action from Complaint 1) Breach of Contract v. All Defendants 2) Breach of Implied Covenant of Good Faith and Fair Dealing v. All Defendants 3) Fraud v. All Defendants 4) Declaratory Rel...

Excerpt: ...nit of real property on Liberty Avenue in Glendale. Plaintiff alleges that in 2018, defendants Athas Corporation Group, MTC Financial, Inc., and Shellpoint Mortgaging Servicing took part in a mortgage transaction involving the subject property. The FAC alleges that the mortgagee, Doe 1, falsely assumed the identity of plaintiff, and forged plaintiff's signature on the documents in the transaction, including the property deed and mortgage contract...

Excerpt: ...ng Party: Plaintiff Lisa O'rrell Relief Requested: Summary judgment in favor of defendants Wilmington Savings Funds Society, FSB dba Christiana Trust, as Trustee for Pretium Mortgage Acquisition Trust and Clear Recon Corp. In the alternative, summary adjudication of the first, second and/or third causes of action. Causes of Action from Second Amended Complaint 1) Declaratory Relief/Judgment v. All Defendants 2) Breach of Contract/Estoppel v. PMAT...

Excerpt: ... Contract with defendant Fred Hakopian for financing of the purchase 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. [Kirsling Decl., ¶ 7, Ex. 1, ¶ 3d]. Defendant has defaulted in payment on the agreement. [Decl., ¶ 8]. Plaintiff has made demand for surrender and is entitled to return of the automobile. [Decl., ¶¶ 10,11]. If based on written in...

Excerpt: ...k Marin alleges that in October of 2019, defendants Fernando Gudino and Gudino's Construction (collectively “Gudino”) presented a proposal to plaintiff for the renovation of plaintiff's residence in Pasadena. Plaintiff alleges that in reliance on defendants' false representation that defendant was a duly licensed contractor, plaintiff agreed to the proposal and entered into an agreement and an additional agreement for the construction of the ...

Excerpt: ...fendant 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 preven...

Excerpt: ... through eighth causes of action of Second Amended Complaint Strike Punitive Damages, allegations of neglect, fraud CAUSES OF ACTION: from Second Amended Complaint 1) Medical Malpractice—Wrongful Death 2) Medical Malpractice—Wrongful Death (Survival Action) 3) Medical Malpractice—Wrongful Death 4) Medical Malpractice—Wrongful Death (Survival Action) 5) General Negligence 6) General Negligence (Survival Action) 7) Dependent Adult Abuse—N...

Excerpt: ...Fraud SUMMARY OF FACTS: Plaintiffs Daryoush Kavian and Said Fallaahi allege that they entered into a written contract with defendants, and that defendants breached the agreement by never obtaining financing as promised, and then failing to return money to plaintiffs as agreed, resulting in plaintiffs suffering damages, including the loss of a business opportunity to purchase a franchise and associated income, and loss of funds given to defendant ...

Excerpt: ...UESTED: Sustain demurrer to first, sixth, tenth, eleventh and twelfth causes of action of Complaint Strike punitive damages, request for injunction, “slum-conditions.” CAUSES OF ACTION: from Complaint 1) Private Nuisance 2) Breach of Warranty of Habitability 3) Negligence 4) Breach of Covenant of Good Faith and Fair Dealing 5) Breach of Implied Covenant of Quiet Enjoyment 6) IIED 7) Violation of Civil Code section 1942.4 8) Violation of Civil...

Excerpt: ...itle to Express Easement 2) Private Nuisance 3) Permanent Injunction and Damages (Interference with Easement) 4) Declaratory Relief 5) Permanent Injunction and Damages—Violation of CC&Rs 6) Declaratory Relief Re CC&Rs SUMMARY OF FACTS: Plaintiffs Birgit Haas and Scott Haas allege that they are the owners of real property located in Sierra Madre, and that defendants Terri Murphy and Michael Murphy are the owners of real property adjacent to plai...

Excerpt: ...wned and operated by defendants City of Los Angeles and Los Angeles Unified School District. The complaint alleges that on March 5, 2019, plaintiff's mother, Amber Otte, picked up plaintiff from school and noticed that plaintiff had bruises and hand marks on his arm. Otte asked plaintiff where the bruises had come from, to which plaintiff replied to Otte, “The big teacher was mean to me.” Otte took this description to mean that plaintiff's te...

Excerpt: ...RY 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 o...

Excerpt: ...regarding mechanic's lien foreclosure to reflect the August 10, 2021 recording of a mechanic's lien release bond, and to make a claim on the mechanic's release bond and add the surety and principal on the release bond as parties, deletes causes of action and parties no longer part of this matter, and adds more specific factual allegations based on discovery conducted. RELEVANT FACTS: Plaintiff A Cut Above Building & Development alleges that in Au...

Excerpt: ...ng Party: Defendants H&S Collision and Auto Repair, Inc., Samuel Petikyan, and Mkrtich Papazyan (No Opposition to Motion to Bifurcate) 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 (thi...

Excerpt: ...acy—Publication 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 (the “Association”). Plaintiff alleges that she is a legal...

Excerpt: ...for Production of Documents, Set One, from each plaintiff 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: ...o Gold CAUSES OF ACTION FROM THE From the First Amended Complaint 1) Invasion of Privacy 2) Libel 3) Libel Per Se 4) IIED 5) NIED 6) Intentional Interference with Prospective Economic Advantage 7) Unfair Business Practices 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 a...

Excerpt: ... for legal fees and costs accumulated in connection with the entry of default and related motion for relief from default. SUMMARY OF FACTS: Plaintiff CAC Motors dba ZR Investment (“CAC Motors”) brings this action against defendants X3 AST Consulting, Inc. (“X3 AST Consulting”), Sleiman A. Timani, and Marques Johnson on June 17, 2021, alleging that plaintiff is engaged in the automobile export business, and entered into a business relation...

Excerpt: ...ded Cross-Complaint 1) Complete Indemnity 2) Partial Indemnity 3) Declaratory Relief 4) Violations of BPC sections 7000, et seq. 5) Breach of Contract 6) Fraud 7) Negligence SUMMARY OF FACTS: Plaintiff Guillermo Ochoa alleges that on November 9, 2019, at or near Vernon Road in Glendale, defendants Jose Avalos and Jose Hulzar negligently operated, owned, entrusted, and employed the persons who operated a motor vehicle, causing injuries and damages...

Excerpt: ...nt of Good Faith and Fair Dealing 5) Breach of Implied Covenant of Quiet Enjoyment 6) IIED 7) NIED 8) Violation of California Civil Code section 1942.4 9) Violation of California Civil Code section 1942.5 SUMMARY OF FACTS: Plaintiffs Karine Grigoryan and Marat Agabekian allege that they leased residential premises on South Belmont Street in Glendale from defendants Xep Huu Nguyen, individually and as trustee of the Nguyen Living Trust Dated Septe...

Excerpt: ... that 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 v...

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: ...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: ...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: ...om each plaintiff Further Responses to Special Interrogatories, Set One, from each plaintiff Further Responses to Request for Production of Documents, Set One, from each plaintiff FACTUAL BACKGROUND Plaintiff Colby Calvert alleges that he was injured when defendant Hung Luong, working for defendant Beckman Coulter, Inc. (“Beckman Coulter”), serviced a piece of laboratory equipment at a laboratory located at the California Institute of Technol...

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: ...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: ...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: ...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: ...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: ...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: ...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: ...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: ...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: ...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: ...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: ...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: ...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: ...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...

Excerpt: ...(“DTL”), and its members, plaintiffs Walter Davis and Cameron Davis, as members and successor trustees of the Bruce A. Davis Revocable Trust and personal representatives of the Estate of Bruce A. Davis, bring this action against defendant Christine Davis, the sister of plaintiff Walter Davis, and the mother of Cameron Davis, alleging that in August of 2008, plaintiff DTL was formed, with Walter Davis and Bruce Davis the signatories on the DTL...

Excerpt: ....2): Not mentioned No waiver of right to compel arbitration (CCP §§1281.2(a); 1281.5): Not mentioned No grounds for rescission of agreement to arbitrate (CCP §1281.2(b)): Not mentioned Parties to the agreement are not parties to an action with a third party arising out of the same transaction, occurrence, or event with the possibility of conflicting rulings on a common issue of law or fact (CCP §1281.2(c))* [but does not apply to arbitration ...

Excerpt: ...asadena Hasting Center alleges that it owns property in Pasadena improved with a commercial retail center and accompanying parking lots and landscaping, which is adjacent to property owned by defendant Sapphos Environmental, Inc. of which defendant Marie Campbell is the Chief Executive Officer. Plaintiff alleges that in November 2016 defendants contacted the City of Pasadena requesting that the City inspect Podocarpus trees located on plaintiff's...