Excerpt: ...ition subpoena DECLARATION SUPPORTING MOTION: Reasonable and good faith attempt to resolve informally: Exhibit 4 FACTUAL BACKGROUND: Plaintiff 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,...

Excerpt: ... causes of action of Cross-Complaint CAUSES OF ACTION: from Cross-Complaint 1) Breach of Fiduciary Duty 2) Breach of Written Contract 3) Interference with Prospective Economic Relations 4) Declaratory Relief 5) Negligent Interference with Prospective Economic Relations 6) Breach of Implied Covenant of Good Faith and Fair Dealing 7) Breach of Oral Contract SUMMARY OF FACTS: Plaintiff Gewo Khachadoorian alleges that in March of 2020 plaintiff comme...

Excerpt: ... Death 3) Negligence—Wrongful Death 4) Negligence—Survivor Action SUMMARY OF FACTS: Plaintiff Jasmine Diaz alleges that she is the daughter of decedent Arturo Diaz Enriquez, and a person entitled to bring a wrongful death action under CCP section 377.60. Plaintiff alleges that in March of 2020, in response to the COVID-19 pandemic, the City of Los Angeles declared a local emergency that included prohibited enforcement for certain parking viol...

Excerpt: ...use of action for intentional interference with contractual relations against cross-defendant Ataian RELEVANT 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 Angeles County (the Company), and in September of 2019 entered into a Stock Purchase Agreement wherein defendant agreed to sell his entir...

Excerpt: ... DECLARATION SUPPORTING MOTION: Reasonable and good faith attempt to resolve informally: Yes, Ex. 6 FACTUAL BACKGROUND: Plaintiff Lupita Vazquez alleges that in January of 2022 plaintiff purchased a 2022 Ford Explorer, for which defendant Ford Motor Company issued a written warranty, by which defendant agreed to preserve or maintain the utility or performance of the vehicle or provide compensation if there was a failure in such utility or perform...

Excerpt: ...rmen Abolian and Talin Shahbazian, a married couple, allege that they are trustees of a family trust, and as trustees own real property on Dunsmere Road in Glendale. Defendant Suzanne Bloom, as trustee of Bloom Trust, owns property on Linda Vista Road in Glendale, which adjoins plaintiffs' property. The complaint alleges that in April of 2021, plaintiffs received a recorded survey which revealed a series of encroachments over a portion of the Dun...

Excerpt: ...each of Implied Covenant of Good Faith and Fair Dealing 4) Breach of Implied Contract 5) Violation of Business & Professions Code section 17200 SUMMARY OF FACTS: Plaintiff Odet Ayvazyan alleges that she has an ownership interest in property on Chestnut Street in Glendale and has used the property as her primary residence. Plaintiff alleges that in 2011 plaintiff took out a loan mortgage against the property from PMC Bankcorp, and a Deed of Trust ...

Excerpt: ...) Negligence SUMMARY OF FACTS: Plaintiff Ann Grigoryan alleges that plaintiff's family desired to use Crescenta Valley Community Regional Park, a public park owned, possessed, managed, maintained and controlled by defendant County of Los Angeles, to celebrate plaintiff's granddaughter's birthday and obtained a permit from defendant for a public gathering at the park, including use of the picnic area. Plaintiff alleges that defendant was thereby p...

Excerpt: ... 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 breached their duty of care by failing to properly supervise, care for, or provide the proper medical aid to Liana Asatryan while she was a st...

Excerpt: ...lternative, summary adjudication of each cause of action, and/or plaintiff's request for punitive damages CAUSES OF ACTION: from Second Amended Complaint (from body of pleading, not caption) 1) Medical Malpractice v. All defendants except Olympus 2) Negligence v. Olympus 3) Strict Products Liability—Failure to Warn v. Olympus 4) Negligence—Failure to Warn v. Olympus 5) Fraud—Intentional Misrepresentation v. Olympus 6) Fraud—Negligent Misr...

Excerpt: ... from Complaint 1) Violation of Song Beverly Act—Breach of Express Warranty 2) Violation of Song Beverly Act—Breach of Implied Warranty 3) Violation of Business & Professions Code section 17200 4) Negligent Repair SUMMARY OF FACTS: Plaintiffs Lourdes Isabel Aguilar and Jose R. Aguilar allege that in January of 2020, they purchased a 2017 Subaru Impreza pursuant to which defendant Subaru of America, Inc. (Subaru) was a warrantor of the vehicle...

Excerpt: ...Beverly Act—Breach of Implied Warranty 3) Violation of the Song-Beverly Act Section 1793.2 SUMMARY OF FACTS: Plaintiff Edgardo Pinto alleges that in March of 2021 plaintiff purchased a 2020 Ford EcoSport vehicle 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 compensation if there was a failure in such utility or p...

Excerpt: ...BACKGROUND: Plaintiffs Richard Vartanian and Elvira Vartanian allege that they are an elderly couple and that in December of 2019 defendant Lazaros Georgiadis (Lazaros), on behalf of defendant Lending Star Capital, offered plaintiffs an attractive reverse mortgage on their real property located in Altadena. At the time plaintiffs were in active Chapter 13 bankruptcy due to the fact that the subject property was under foreclosure by the second lie...

Excerpt: ... response to Request for Production No. 7 MONETARY SANCTION: None sought FACTUAL BACKGROUND: Plaintiff Paul Abramson, also known as Paul Van Richter, brings this action against defendant Spinnaker Insurance Company (Spinnaker) and Spinnaker's claims administrator, defendant Hippo Analytics, Inc. (Hippo), alleging that defendants engaged in unlawful claims handling practices, and breached their duty to defend, and also breached the implied covenan...

Excerpt: ...lready appeared in Superior Court: Plaintiff filed action) Copy of agreement included and referenced: Decl., Ex. 1 Demand and refusal to arbitrate: “Redundant” No waiver of right to compel arbitration: None mentioned No grounds for rescission of agreement to arbitrate: None 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 confli...

Excerpt: ...D PROCEDURAL BACKGROUND Plaintiff Fira Zefa Akyan alleges that in October of 2020, defendant Jaojong Kim negligently owned, operated, used, drove, maintained, loaned or entrusted a motor vehicle so that the motor vehicle collided with a vehicle driven by plaintiff, thereby proximately causing plaintiff injuries and damages. The Form Complaint alleges causes of action for General Negligence, Motor Vehicle, and Negligent Entrustment. ANALYSIS: Unde...

Excerpt: ...sed a 2021 Jeep Wrangler vehicle, and express warranties accompanied the sale of the vehicle, by which defendant FCA US LLC undertook to preserve or maintain the utility or performance of the vehicle or provide compensation if there was a failure in such utility or performance. Plaintiff alleges that the vehicle was delivered to plaintiff with serious defects and nonconformities to warranty, including the vehicle's engine, electrical, emission an...

Excerpt: ...d January 26, 2023) FACTUAL AND PROCEDURAL BACKGROUND: Plaintiff Richard Levy alleges that in December of 2020 plaintiff was injured when defendant Renato Abolencia negligently operated a motor vehicle owned by defendant Perla Salvador. The file shows that moving defendant Abolencia was served with the summons, complaint, and plaintiff's statement of damages by personal service on November 20, 2022, by a registered California process server. On J...

Excerpt: ...ntiffs Sarmen Abolian and Talin Shahbazian, a married couple, allege that they are trustees of a family trust, and as trustees own real property on Dunsmere Road in Glendale. Defendant Suzanne Bloom, as trustee of Bloom Trust, owns property on Linda Vista Road in Glendale, which adjoins plaintiffs' property. The complaint alleges that in April of 2021, plaintiffs received a recorded survey which revealed a series of encroachments over a portion o...

Excerpt: ...enter, Inc. [No Opposition] Name of Deponent: PMK of Neuro Diagnostic Center, Inc. Status of Deponent: Plaintiff's PMK (party or party affiliate) DEPO ATTENDANCE REQUIRED BY: Formal Notice [Kelleher Decl., Ex. K, Second Amended Notice]. RELIEF REQUESTED BY MOVING PARTY: Order compelling plaintiffs to produce additional documents in response to the requests for production contained within the Second Amended Notice of Part Two of Plaintiff's Deposi...

Excerpt: ...xhibit 3]. RELIEF REQUESTED BY MOVING PARTY: Order compelling the deposition of the Person Most Knowledgeable of defendant Porsche Cars North America, Inc., and responses and production of documents, and order striking objections DECLARATION SUPPORTING MOTION: Reasonable and good faith attempt to resolve informally: Ok, Ex. 5 MONETARY SANCTION: None sought FACTUAL BACKGROUND: Plaintiff Kian Shamim alleges that in August of 2020 plaintiff leased a...

Excerpt: ...onal Property* 2) Goods and Services Rendered 3) Promissory Estoppel *Cause of action dismissed pursuant to Request for Dismissal without prejudice on April 11, 2023. SUMMARY OF FACTS: Plaintiff Keshishyan Group, Inc. dba Concierge Auto Group alleges that it entered into an agreement with defendant Chad Cunningham, individually, and/or doing business as Give Me the Vin, and defendant Give Me the Vin, regarding the sale of a 2021 Lamborghini Urus ...

Excerpt: ...oversy alleged in the complaint to binding arbitration SUMMARY OF FACTS: Plaintiffs Mana Zalazar, Raul Zalazar, and Julio Cesar Zalazar bring this action individually and as heirs and successors in interest to their father, decedent Julio Zalazar, alleging that defendant Glendale Post Acute Center was a skilled nursing facility or intermediate care facility operating in Glendale, and licensed and/or operated by defendants LAC Verdugo Operation, L...

Excerpt: ...bitration SUMMARY OF FACTS: Plaintiff Jose Guadalupe Quezada alleges that in September of 2020, plaintiff purchased a 2020 Ford F-350 vehicle. Plaintiff alleges that defendant Ford Motor Company (Ford) warranted the vehicle and agreed preserve or mamtain the utility or performance of the vehicle or provide compensation if there was a failure in such utiliV or performance. Plamtiff alleges that defects and nonconformities to warranty manifested th...

Excerpt: ...Owners Association: Beven & Brock, and all persons acting in concert with them: cease operating or arranging to operate the condominium's water heater at a sound level that is the permitted levels allowed by the Glendale Municipal Code of 35 dBA_ FACTUAL BACKGROUND: Plaintiffs Meher Der Ohanessian: Ari Der Ohanessian and Lusya Der Ohanessian allege that plaintiffs Ali Der Ohanessian and Lusya Der Ohanessian are tenants of a condominium ou•ned b...