Excerpt: ...t plaintiff on her entire operative Second Amended Complaint In the alternative, summary adjudication of plaintiff's fourth, fifth and/or sixth causes of action CAUSES OF ACTION: from Second Amended Complaint 1) Sexual Battery v. Flores 2) IIED v. Flores 3) Assault v. Flores 4) Public Entity Liability v. ELAC, LACCD 5) Title IX Violations v. ELAC, LACCD 6) 42 USC section 1983; Civil Rights Violations v. ELAC, LACCD SUMMARY OF FACTS: Plaintiff Zai...

Excerpt: ...murrer to Second Amended Complaint Strike punitive damages, attorney fees CAUSES OF ACTION: from Second Amended Complaint 1) Fraud—Intentional Misrepresentation 2) Fraud—Concealment 3) Negligence 4) Quiet Title 5) Declaratory Relief SUMMARY OF FACTS: Plaintiff Filaip Patatanian alleges that since 2001, plaintiff has owned a unit of real property on Liberty Avenue in Glendale. Plaintiff alleges that in 2018, defendants Athas Capital Group, Arm...

Excerpt: ...ark 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 and foreseeable risk of contact by tall vehicles passing below. Plaintiff alleges that as he was approaching the site of the overhanging ele...

Excerpt: ...the agreement by intentionally misrepresenting the nature of certain investments and has refused to repay funds due. The First Amended Complaint alleges causes of action for breach of contract, common counts, and fraud. The file shows that on February 2, 2020, defendant filed an answer to the complaint. On November 17, 2021, plaintiff filed a First Amended Complaint. On December 16, 2021, defendant filed an Amended Answer to Amended Complaint. Th...

Excerpt: ...sa Goodrich's response to and compliance with Defendants' demand for supplemental physical examinations and deposition FACTUAL BACKGROUND: Plaintiff Lisa Goodrich alleges that on June 19, 2017, while she was a passenger in a vehicle which was entering an intersection, defendant Guillermo Eduardo Padilla, Jr., driving a tractor-trailer, made an unsafe left-hand turn, causing a massive collision, which totaled the vehicle where plaintiff was a pass...

Excerpt: ...tiff's First Amended Complaint, and plaintiff's claim for punitive damage. CAUSES OF ACTION: from First Amended Complaint 1) Premises Liability 2) Negligence 3) Private Nuisance 4) Concealment 5) Breach of Implied Warranty of Habitability 6) Fraudulent Misrepresentation 7) IIED 8) Theft by False Pretense* 9) Breach of Contract *Demurrer by defendant Noho Commons and Polaris Property Management sustained without leave to amend on 11/05/22 SUMMARY ...

Excerpt: ...ts) Responding Party: Defendants/Cross Complainants Westco Petroleum Distributors Inc. and Westco Petroleum Inc. (Fees) Defendant/Cross-Complainant Kamal A. Bilal (Fees) Plaintiff and Cross-defendants MCW Fuels, LLC and Aleksandr Blyumkin (Tax Costs) RELIEF REQUESTED: Attorney Fees Award of attorneys' fees in the amount of $776, 917.50 and costs in the amount of $16,974.94, plus costs in the amount of $451.30 incurred in connection with the appea...

Excerpt: ... Amended Complaint CAUSES OF ACTION: from Second Amended Complaint 1) Harassment 2) Threats of Illegal Eviction 3) Extortion 4) IIED SUMMARY OF FACTS: Plaintiff Lucinda Sky alleges that plaintiff and her 16-year-old son have been residing at a condominium unit and that Armen Arutyunyan, their landlord, is also a defendant in a separate personal injury suit brought by plaintiff. The SAC alleges that starting in September of 2019, when plaintiff mo...

Excerpt: ...ARATION SUPPORTING MOTION: Reasonable and good faith attempt to resolve informally: Exs. B, C FACTUAL BACKGROUND: Plaintiff CAC Motors dba ZR Investment brings this action against defendants X3 AST Consulting, Inc. (“X3 AST Consulting”), Sleiman A. Timani, and Marques Johnson, alleging that plaintiff is engaged in the automobile export business, and entered into a business relationship with defendant X3 AST Consulting pursuant to which plaint...

Excerpt: ... OF ACTION: from Second Amended Complaint 1) Elder Abuse and Neglect 2) Wrongful Death 3) Medical Malpractice 4) Violation of Resident's Bill of Rights SUMMARY OF FACTS: Plaintiff Margaret Shu, individually and as successor in interest to decedent Itzu Po, Shu's parent, alleges that plaintiffs' decedent was approximately 80 years old, and at all relevant times an elder, when she was sent from Kaiser to defendant San Gabriel Valley Medical Center ...

Excerpt: ...o the Estate of Cassandra Ivette Ventura (No Opposition) Relief Requested: Summary judgment in favor of defendant Farough Kerendi, M.D. CAUSES OF ACTION from Third Amended Complaint 1) Medical Malpractice—Wrongful Death v. Pacifica Defendants 2) Medical Malpractice—Wrongful Death (Survival Action) v. Pacifica Defendants 3) Medical Malpractice—Wrongful Death v. Kaiser Defendants 4) Medical Malpractice—Wrongful Death (Survival Action) v. Ka...

Excerpt: ...endant Paul Van Richter (Preliminary Injunction) Plaintiff Excelsior at the Americana at Brand Homeowners' Association (Demurrer and Special Motion to Strike) RELIEF REQUESTED: Preliminary Injunction Preliminary injunction Demurrer Sustain demurrer to Verified Complaint Special Motion to Strike Strike third and fourth causes of action of Verified Complaint CAUSES OF ACTION: From Complaint 1) Breach of Governing Documents—Civil Code 5975 2) Inju...

Excerpt: ...Motion to Strike Sustain demurrer to first cause of action of Fourth Amended Complaint Strike punitive damages Motion to Quash Quash service of summons and dismiss defendant Michael Gibson from this action CAUSES OF ACTION: from Fourth Amended Complaint 1) Dangerous Condition of Public Property (Negligence/Gross Negligence) 2) General Negligence and Gross Negligence as to Defendant HHS 3) Premises Liability 4) Motor Vehicle SUMMARY OF FACTS: Plai...

Excerpt: ...nlawful detainer action brought 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 statu...

Excerpt: ...c. dba Carrows Restaurant (No Opposition to Travelers' Motion) RELIEF REQUESTED: Mercury Insurance Motion Order granting summary judgment in favor of cross-defendant Mercury Insurance Company In the alternative summary adjudication for each cause of action, and/or claim for punitive damages. Travelers Property Casualty Company Motion Summary judgment against defendant/cross-complainant OM ABS, Inc. dba Carrows Restaurant. In the alternative, summ...

Excerpt: ...ition) Cross-complainant Pure Safety Group, Inc. dba Guardian Fall (No Opposition) RELIEF REQUESTED: Determination that settlements described below were made in good faith Order dismissing as against Hagopian and Icon Investments, LLC the cross-complaint of Pure Safety Group, Inc. dba Guardian Fall SUMMARY OF FACTS: Plaintiffs Erika Rodriguez, individually, and as conservator of the estate of Jose Angel Delgado-Gonzalez, allege that in August of ...

Excerpt: ... Motion to Compel Further Responses to Form Interrogatories, Set One Motion for Sanctions Issue sanctions FACTUAL BACKGROUND 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 th...

Excerpt: ...s the assignee of a written Lease Agreement with defendants Elite Trans World, Inc. and Vahan Margaryan, for the lease of a motor vehicle. [Ex. 1]. Under the Agreement, upon a default, plaintiff has the right to take possession of the vehicle. [Ex. 1 ¶ 23]. Defendant has defaulted in payment on the agreement. [Decl. ¶ 6]. Plaintiff has made demand for surrender and is entitled to return of the vehicle. [Decl. ¶ ¶12, 13, 15]. If based on writt...

Excerpt: ...and their minor children, Hovik Palamutian and K. Palamutian, allege that during their tenancy in a unit of leased premises which were negligently and improperly maintained by defendants, the premises became uninhabitable due to housing conditions including, but not limited to, bedbug infestation on the premises and in the subject unit. Plaintiffs allege that although defendants had actual notice and knowledge of the untenantable conditions, defe...

Excerpt: ...ts SUMMARY OF FACTS: 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, defendant Armen Kiramijyan, Esq., the son of defendants...

Excerpt: ... NO RESPONSES SERVED Date Motion served: July 28, 2022 Timely OPPOSITION: No opposition ANALYSIS: Plaintiff Dennis P. Block seeks to compel defendant Daniel Bramzon to respond to interrogatories which were propounded to defendant pursuant to CCP section 708.020, which permits written interrogatories to be propounded to a “judgment debtor.” Such interrogatories are permitted which request “information to aid in enforcement of the money judgm...

Excerpt: ...hew Perez bring this action for declaratory relief against plaintiff Jennifer Perez's mother, defendant Eveline J. Siracuse, trustee of the Eveline J. Siracuse 2003 Trust. Plaintiffs allege that they have resided at real property on Santa Barbara Avenue in Glendale, and that in May of 2019, defendant filed a complaint for partition of the subject property against plaintiffs as defendants, which defendant Siracuse voluntarily dismissed shortly bef...

Excerpt: ...essions Code section 17200 et seq. 5) Negligence 6) Breach of Contract 7) Constructive Eviction 8) Violation of LARSO 9) Civil Code 1950.5 SUMMARY OF FACTS: Plaintiff Ahmed Dehal alleges that plaintiff is a tenant of residential property in Glendale which plaintiff took possession of by a written lease. Plaintiff alleges that defendant Suzanna Abovyan, and un-named Avetik Karapetyan, is the legal owner of the subject property, and at all material...

Excerpt: ...ach of Contract v. USB and Dixieline 3) Breach of Contract v. Dixieline 4) Breach of Contract v. USB, Dixieline 5) Breach of Contract v. Dixieline, Pro Build 6) Unfair Business Practices v. All Defendants* *Request for Dismissal with prejudice of this cause of action only filed and Dismissal entered as requested 08/29/2022 SUMMARY OF FACTS: The complaint which is the subject of these demurrers was consolidated with this case, the lead case, in wh...

Excerpt: ...2, pers. within 30 days?: No Meet and Confer? Yes RELIEF REQUESTED: Sustain demurrer to complaint Strike prayers for general and special damages. CAUSES OF ACTION: from Complaint 1) Intentional Trespass to Real Property 2) Negligent Trespass to Real Property 3) Quiet Title 4) Declaratory Relief 5) Nuisance SUMMARY OF FACTS: Plaintiffs Sarmen Abolian and Talin Shahbazian, a married couple, allege that they are trustees of a family trust, and as tr...

Excerpt: ...ve Fraudulent Transfer 5) Constructive Fraudulent Transfer 6) Actual Fraudulent Transfer 7) Constructive Fraudulent Transfer 8) Constructive Fraudulent Transfer 9) Constructive Fraudulent Transfer 10) Actual Fraudulent Transfer SUMMARY OF FACTS: Plaintiff Cathay Bank alleges that in June of 2021 it entered into a business loan agreement with Borrower Cherry Man Industries, along with a promissory note, and in August of 2016 entered into a term lo...

Excerpt: ...lawful detainer. Causes of Action from Complaint 1) Unlawful Detainer 2) Unlawful Detainer SUMMARY OF COMPLAINT: This is an unlawful detainer action brought by plaintiff Glendale I Mall Associates, LP, alleging that it is the landlord under a lease of certain real commercial property which is part of the Glendale Galleria. The complaint alleges that in October of 2017, plaintiff conveyed to tenant, defendant Golden Canyon, Inc. doing business as ...

Excerpt: ...int for negligence per se CAUSES OF ACTION FROM THE Complaint 1) Negligence Per Se (Vehicle Code section 5753) 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 9) Negligence—Vicarious Liability SUMMARY OF FACTS: Plaintiff CAC Motors dba ZR Investment brings this action against defendants...

Excerpt: ...f and against defendants Artak Daldumyan, an individual, Goar Nersesyan, an individual, and World Financial Group, Inc., a California corporation In the alternative, summary adjudication of each cause of action. CAUSES OF ACTION: from Complaint 1) Breach of Contract 2) Breach of the Covenant of Good Faith and Fair Dealing SUMMARY OF FACTS: Plaintiff S & N Properties alleges that it is a real estate limited partnership, and that in October 2018 it...

Excerpt: ...rit of possession FACTUAL AND PROCEDURAL BACKGROUND: Plaintiff Broadway Vestalia, LLC brings this complaint for unlawful detainer, alleging that plaintiff is the owner of premises in Glendale, and that in October of 2020, defendants Rimond Asadoryan and Lernik Khajehsari agreed pursuant to a written agreement with plaintiff's agent to pay monthly rent for the residential property. The complaint alleges that the tenancy was terminated pursuant to ...

Excerpt: ...tion served: July 12, 2022 Timely 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 Section 2033.280(b). The code specifies that “The court shall make this order, unle...

Excerpt: ...payment for services performed by unlicensed subcontractors on the construction project at issue herein SUMMARY OF FACTS: 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, of which defendant Rachelle K. Stull is the trustee. Plaintiff alleges that the subject proper...

Excerpt: ...plaintiff on her entire operative Second Amended Complaint In the alternative, summary adjudication of plaintiff's fourth, fifth and/or sixth causes of action CAUSES OF ACTION: from Second Amended Complaint 1) Sexual Battery v. Flores 2) IIED v. Flores 3) Assault v. Flores 4) Public Entity Liability v. ELAC, LACCD 5) Title IX Violations v. ELAC, LACCD 6) 42 USC section 1983; Civil Rights Violations v. ELAC, LACCD SUMMARY OF FACTS: Plaintiff Zaida...

Excerpt: ...t for Admissions, and Third Set of Requests for Production of Documents. SUMMARY OF FACTS: Plaintiff Prapai Benjauthrit brings this action against her brother, defendant Boonsieng Benjauthrit, alleging that the parties took title to properties in Glendale in 1977 as joint tenants, with one of the subject properties to be the principal place of residence of plaintiff. Plaintiff alleges that defendant wrongfully induced plaintiff to sign away her i...

Excerpt: ...hat 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 and foreseeable risk of contact by tall vehicles passing below. Plaintiff alleges that as he was approaching the site of the overhanging electrical wire, a tall tr...

Excerpt: ...aintiff UHG I LLC brings this action to collect a sum allegedly due on a credit account. Plaintiff alleges that it is the successor in interest to the original creditor, WebBank, and that plaintiff is a debt buyer, the sole owner of the debt at issue, which purchased the debt after charge-off. Plaintiff alleges that the charge-off creditor at the time of charge-off is Upgrade, Inc., and the name of the debtor as it appeared in the charge-off cred...

Excerpt: ...ff UHG I LLC brings this action to collect a sum allegedly due on a credit account. Plaintiff alleges that it is the successor in interest to the original creditor, WebBank, and that plaintiff is a debt buyer, the sole owner of the debt at issue, which purchased the debt after charge-off. Plaintiff alleges that the charge-off creditor at the time of charge-off is Upgrade, Inc., and the name of the debtor as it appeared in the charge-off creditor'...

Excerpt: ... ACTION: from First Amended Complaint 1) Elder Abuse and Neglect 2) Wrongful Death 3) Medical Malpractice 4) Violation of Resident's Bill of Rights SUMMARY OF FACTS: Plaintiff Margaret Shu, individually and as successor in interest to decedent Itzu Po, Shu's parent, alleges that plaintiffs' decedent was approximately 80 years old, and at all relevant times an elder, when she was sent from Kaiser to defendant San Gabriel Valley Medical Center on A...

Excerpt: ...ligence v. All Defendants 2) Breach of Contract v. USB and Dixieline 3) Breach of Contract v. Dixieline 4) Breach of Contract v. USB, Dixieline 5) Breach of Contract v. Dixieline, Pro Build 6) Unfair Business Practices v. All Defendants SUMMARY OF FACTS: The complaint which is the subject of this demurrer and motion to strike was consolidated with this case, the lead case, in which plaintiff King Cobra Construction, P.C. (“King Cobra”) allege...

Excerpt: ...ale or attempting to evict plaintiff or attempting to sell the subject property or otherwise transfer title. FACTUAL AND PROCEDURAL BACKGROUND: Plaintiff Ayman M. Salem alleges that plaintiff is the owner of real property in La Canada, and that plaintiff refinanced the original loan used to purchase the subject property when plaintiff borrowed funds from defendant BOFI Federal Bank, with the promissory note regarding the loan secured by a deed of...

Excerpt: ...and entities as defendants RELEVANT FACTS: Plaintiff Filaip Patatanian alleges that since 2001, plaintiff has owned a unit 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, ...

Excerpt: ...uary 28, 2022. SUMMARY OF FACTS: Plaintiff CAC Motors dba ZR Investment brings this action against defendants X3 AST Consulting, Inc. (“X3 AST Consulting”), Sleiman A. Timani, and Marques Johnson, alleging that plaintiff is engaged in the automobile export business, and entered into a business relationship with defendant X3 AST Consulting pursuant to which plaintiff would request specific vehicles and X3 AST Consulting would locate, purchase ...

Excerpt: ... 1, 2022 in the amount of $4,400 Order compliance and production of documents (Set One) ANALYSIS: Interrogatories and Documents (2 Motions) Defendant Brookfield Property Retail has filed oppositions to the motions, indicating that further verified responses to each of the discovery requests were served on July 25, 2022, since the filing of the motions on May 26, 2022. Defendant's counsel's declaration indicates that, “I provided Plaintiff's cou...

Excerpt: ...ract 2) Tortious Breach of the Covenant of Quiet Enjoyment 3) Tortious Breach of the Warranty of Habitability 4) Statutory Breach of the Warranty of Habitability 5) Nuisance 6) IIED 7) Negligence 8) Violation of California Civil Code section 789.3 9) Conversion 10) Constructive Eviction 11) Violation of California Civil Code 1940.2 12) Violation of Business & Professions Code section 17200 et seq. 13) Violation of Civil Code section 1950.5 14) Ma...

Excerpt: ...SES OF ACTION FROM THE Complaint 1) Breach of Contract 2) Breach of the Covenant of Good Faith and Fair Dealing SUMMARY OF FACTS: Plaintiff S & N Properties alleges that it is a real estate limited partnership, and that in October 2018 it entered into a Lease Agreement, as owner, with defendant World Financial Group, Inc. as tenant for commercial property in Glendale. The complaint alleges that defendants Artak Daldumyan and Goar Nersesyan are pr...

Excerpt: ...action was originally brought as an unlawful detainer action brought 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...

Excerpt: ...f action of First Amended Complaint Strike punitive damages, elder abuse, references to public health department CAUSES OF ACTION: from First Amended Complaint 1) Elder Abuse/Neglect 2) Wrongful Death 3) Statutory Violations/Breach of Resident Rights 4) NIED SUMMARY OF FACTS: Plaintiffs Loris Yadegarian and Gilda Yadegarian bring this action individually and as the surviving heirs of their father, decedent John Yadegarian, alleging that decedent ...

Excerpt: ...aling 2) Breach of Contract 3) Unfair Business Practices SUMMARY OF FACTS: Plaintiffs William Stepanyan alleges that defendant Topa Insurance Company issued plaintiff a homeowner's insurance policy for plaintiff's home in Glendale, which was in full force and effect when, in April of 2021, a water loss occurred at the property. The complaint alleges that plaintiff discovered the water leak, which had penetrated the majority of the interior of the...

Excerpt: ... Flanders Road in La Canada, digging holes and pouring concrete on the property, erecting a fence on the property, leaving construction debris and detritus on the property and trespassing in any form on the property. FACTUAL AND PROCEDURAL BACKGROUND: Plaintiff Jean Kechichian alleges that plaintiff owns a parcel of residential property located at 945 Flanders Road in La Canada, and that defendant Linda K. Lee owns an adjacent parcel of property ...

Excerpt: ...Plaintiff Maroot Sahakian alleges that he was 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, de...