Excerpt: ...ments is denied in part (as to document request numbers 16, 20, 27, and 29, and as to sanctions), and is otherwise granted. On or before 12/10/23, Plaintiff shall serve further responses, and produce documents, without unsupported objections, and in full compliance with the California Discovery Act, CCP §2016.010 et seq., as to the requests for documents served by Defendant. The motion to compel a deposition is granted, and sanctions in the amou...

Excerpt: ...mpliance with the California Discovery Act, CCP §2016.010 et seq., as to the interrogatories and requests for documents served by plaintiffs and addressed in their separate statements. On or before that same date, counsel Ongaro PC, shall pay discovery sanctions in the total sum of $5,070.00 to plaintiffs, the Court finding the absence of substantial justification. E.g., CCP § 2023.030. On 12/16/21, ESMERALDA RAMIREZ and GUSTAVO ORTIZ HERNANDEZ...

Excerpt: ...d terminated the employment in approximately March of 2020. The causes of action are (1) Wrongful Termination; (2) Retaliation (California Labor Code § 98.6 And 1102.5); (3) Violation Of California Labor Code §§ 510 And 1198 (Unpaid Overtime); (4) Violation Of California Labor Code §§ 1194, 1197 And 1197.1 (Unpaid Minimum Wages); (5) Violation Of California Labor Code § 226.7 (Unpaid Rest Period Premiums); (6) Violation Of California Labor ...

Excerpt: ...gave a Declaration of Intent to Evict for Landlord Occupancy, without paying required relocation assistance. On 3/11/20, Defendant filed a First Amended Cross-Complaint against Plaintiff, alleging that Cross-Defendant EMMONS unjustly retained the benefit of living in the Building's "Lower Unit" without paying rent required by the written lease, negligently caused a need to replace the unit's heating system, to pay for additional maintenance of th...

Excerpt: ... §2016.010 et seq., as to the form interrogatories and special interrogatories served by Defendant. On or before that same date, Plaintiff ELCHANAN BEISS and The Chang Firm shall pay discovery sanctions in the total sum of $4,600 to Defendant, the Court finding the absence of substantial justification. E.g., CCP § 2023.030. On 12/27/21, Plaintiff ELCHANAN BEISS (“Plaintiff”) filed a Complaint. On 7/27/22, Plaintiff filed a First Amended Com...

Excerpt: ...e Victims of Corporate Fraud Recovery Fund, denied petitioners' applications for payment through the fund. MP Positions Moving party requests an order transferring venue to Sacramento, on grounds including the following: · Under Corporations Code section 2287, subdivision (a), this Court is not the proper venue for this action. RP Positions Opposing parties advocate denying, for reasons including the following: · Venue for this petition is prop...

Excerpt: ...laintiff Doctor ALEXANDER GHATAN, and corporations owned by Defendant Doctor Shirazy, entered into a written Professional Services Agreement (“PSA”) for Plaintiff to provide medical services to defendants' patients, but defendants conversely contend that Plaintiff is entitled to the professional fee liens for just 11 of approximately 270 procedures, and that defendants have not had any duty to exclusively use Plaintiff for some of the listed ...

Excerpt: ..., Plaintiff filed a First Amended Complaint, alleging that Defendant's financial elder abuse of decedent WANDA SNEED also caused Plaintiff to be deprived of her expected inheritance, in that Defendant interfered with title to assets, personal properties, and interfered with obtaining the monies belonging to the estate of Wanda Sneed. The causes of action are: 1) INTENTIONAL INTERFERENCE WITH EXPECTED INHERITANCE; 2) DEPENDENT ADULT ABUSE; 3) FRAU...

Excerpt: ...d YU LIN filed a Complaint alleging: 10. In June 2015, Plaintiff Fang, on behalf of Plaintiffs, executed a Limited Partnership Agreement (“LPA,” Exhibit) with Defendant Group 48 LP. Defendant CMB Export and Defendant NK are general partners of the limited partnership, controlled by Defendant Hogan. 11. The purpose of the agreement under the LPA is “[T]he investor seeks to apply for a green card (permanent residenc[y]) under the EB-5 Immigra...

Excerpt: ...AXTON 9 CORPORATION. On 8/9/21, Plaintiff filed a First Amended Complaint, alleging that Defendant's financial elder abuse of decedent WANDA SNEED also caused Plaintiff to be deprived of her expected inheritance, in that Defendant interfered with title to assets, personal properties, and interfered with obtaining the monies belonging to the estate of Wanda Sneed. The causes of action are: 1) INTENTIONAL INTERFERENCE WITH EXPECTED INHERITANCE; 2) ...

Excerpt: ...plaintiffs. Summary On 4/13/17, plaintiffs filed a Complaint. On 12/11/17, plaintiffs filed a First Amended Complaint, alleging: This action for negligence and strict liability arises out of an incident that occurred on December 26, 2015. Oleg Alexandrov was driving east on the 10 Freeway approaching Crenshaw Blvd and downtown Los Angeles. Marianna Alexandrov was sitting in the passenger seat while their two young grandchildren were passengers in...

Excerpt: ...ff filed this action, including constructive employment termination, and alleging that Plaintiff worked as a maintenance worker, and employer Defendant City of Lawndale intentionally assigned Plaintiff to do work that violated his medical restrictions, and refused to offer available, reasonable work accommodations, based upon discrimination and retaliation. The causes of action of the Third Amended Complaint are: 1. VIOLATION OF THE FAIR EMPLOYME...

Excerpt: ...sentations made by the salesperson and the manufacturer through publications, that the vehicle's range on a charge was 259 miles. However, the vehicle had defects including with the EV battery module, insufficient distance on a charge, potential high voltage battery fire and front seatbelt pretensioner. After Plaintiff's repeated presentations of the vehicle authorized repair facilities, the manufacturer has been unable to conform the Vehicle to ...

Excerpt: ...nant residing at an apartment complex at 952 S Detroit Street, Los Angeles, until constructive eviction, after defendants, as landlords, failed to timely or fully address Plaintiff's complaints of uninhabitable conditions, including trash under the landlords' control in the common areas, loud music and noise at all hours, roach infestation; water leaks in Plaintiff's apartment under the lessors' control, unpermitted washer and dryer, lack of hot ...

Excerpt: ...ths before was "non-consensual" (i.e. criminal "rape"). The cause of action is INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS. On 7/28/23, Defendant filed a Cross-Complaint against Plaintiff alleging that, on or about 11/18/21, after drugging Cross-Complainant, Cross-Defendant raped her, notwithstanding that Cross-Complainant resisted him physically and verbally, and said “no” and “stop.” Cross-Complainant's Causes of Action are: 1. SEXUAL ...

Excerpt: ...eceptionist, then “staffing coordinator,” until their constructive, wrongful termination of employment on or about March 15, 2021, based upon work-related disability and sexual orientation. The causes of action are: 1. BREACH OF EXPRESS WRITTEN CONTRACT; 2. BREACH OF IMPLIED CONTRACT; 3. BREACH OF THE COVENANT OF GOOD FAITH AND FAIR DEALING; 4. WRONGFUL TERMINATION IN VIOLATION OF PUBLIC POLICY; 5. DISCRIMINATION; 6. RETALIATION; 7. HARASSMEN...

Excerpt: ...On 5/15/23, Plaintiff ALI MURHI, filed a Complaint alleging that employer defendants discriminated, harassed, retaliated and later terminated employment, because of Plaintiff's disability and ongoing requests for accommodations. The causes of action are: (1) DISCRIMINATION IN VIOLATION OF FEHA; (2) HOSTILE WORK ENVIRONMENT HARASSMENT UNDER FEHA; (3) RETALIATION UNDER FEHA; (4) FAILURE TO PROVIDE REASONABLE ACCOMMODATIONS IN VIOLATION OF FEHA; (5)...

Excerpt: ...t (“LPA,” Exhibit) with Defendant Group 48 LP. Defendant CMB Export and Defendant NK are general partners of the limited partnership, controlled by Defendant Hogan. 11. The purpose of the agreement under the LPA is “[T]he investor seeks to apply for a green card (permanent residenc[y]) under the EB-5 Immigrant Investor Program[,] and does not require an economic profit on his/her investment” (pg.1). Plaintiffs transmitted $550,000 to Defe...

Excerpt: ... structural, and transmission system defects, and co-Defendant PUENTE HILLS FORD breached its duty to Plaintiff to ordinary care and skill by failing to properly store, prepare, and repair the vehicle. The causes of action are: 1. VIOLATION OF SONG-BEVERLY ACT - BREACH OF EXPRESS WARRANTY 2. VIOLATION OF SONG-BEVERLY ACT - BREACH OF IMPLIED WARRANTY 3. VIOLATION OF THE SONGBEVERLY ACT SECTION 1793.2 4. NEGLIGENT REPAIR. MP Positions Moving partie...

Excerpt: ...f, after Plaintiff paid defendants $40,000 to purchase $49,600 in the Merchant Defendant's future accounts receivable, to fund the working capital needs of the Merchant Defendant's business operations, defendants failed to repay, and Stillwell personally guaranteed the obligations. The causes of action are: 1. BREACH OF WRITTEN CONTRACT 2. BREACH OF WRITTEN GUARANTY. MP Positions Moving party requests an order granting summary judgment or summary...

Excerpt: ...this is an action for Declaratory Relief, Breach of Contract and related claims, arising out of a written one-page partnership agreement entered into in 2011, between Plaintiff and the decedent DARLENE UPCHURCH-FRIEDMAN, providing Plaintiff with a 30% ownership and partnership interest in commercial real property at Jefferson and La Brea Boulevards. On 8/18/22, Defendant JEFFERSON LA BREA D&J PROPERTIES, LLC filed a notice of bankruptcy stay, but...

Excerpt: ...os Angeles, in preparation for occupancy, but Defendant abandoned the premises after about 7 months of possession and refuses to repay the loan or further rent. The causes of action are: 1) BREACH OF LEASE; 2) FAILURE TO REPAY LOAN; 3) COMMON COUNTS: MONEY OWED; and 4) UNJUST ENRICHMENT. On 5/22/23, Plaintiff filed a motion for leave to amend the operative complaint to add causes of action related to alter ego issues and false and defamatory stat...

Excerpt: ...nts Summary On 6/10/22, Plaintiff PAUL BUTAKOV, a self-represented litigant, filed a Complaint for Medical Negligence, alleging that, in June 2020, Plaintiff underwent vessel coronary artery bypass at HUNTINGTON HOSPITAL, and thereafter experienced a clicking noise in his chest, which thereafter was discovered to be an improperly closed chest plate by doctors at KECK MEDICAL CENTER OF USC. MP Positions Defendant Moving party requests an order gra...

Excerpt: ...action are: 1. WRONGFUL TERMINATION IN VIOLATION OF FEHA (GOV'T. CODE § 12940 ET SEQ.); 2. FEHA VIOLATIONS BASED UPON DISABILITY DISCRIMINATION; 3. FAILURE TO PROVIDE REASONABLE ACCOMMODATIONS IN VIOLATION OF GOV'T CODE §§12940 ET SEQ.; 4. FAILURE TO ENGAGE IN A GOOD FAITH INTERACTIVE PROCESS IN VIOLATION OF GOV'T CODE §§12940 ET SEQ.; 5. FEHA VIOLATIONS BASED UPON RETALIATION; 6. FAILURE TO REINSTATE IN VIOLATION OF THE CFRA; 7. INTERFERENC...

Excerpt: ... MURAL MEDIA, LLC and S.B.S. TRUST DEED NETWORK that entered into the original loan and deed of trust while incapable of legally doing business in the State of California, due to their filing LLC cancellations. Defendants BRUETSCH and CAPITALBENEFIT, INC., acted as agents for defendants. Other defendants represented themselves as being the lien holders, thereby fraudulently inducing Plaintiff to enter into loan modification agreements. The causes...

Excerpt: ...e was born in March of 1981, and while a minor, was a victim of childhood sexual molestation and assault done by defendants' employed teacher, at South Bay Junior Academy, caused by defendants' failures and refusals, including with regard to hiring, retention, training and supervision, by defendants SOUTHERN CALIFORNIA CONFERENCE OF SEVENTH-DAY ADVENTISTS (SCC) and NORTH AMERICAN DIVISION OF SEVENTH DAY ADVENTISTS (NAD). The causes of action are:...

Excerpt: ...nt alleging that Plaintiff purchased a new 2020 Chevrolet Silverado having and developing serious defects and nonconformities to warranty, and Defendant GM was unable to conform Plaintiff's vehicle to the applicable express warranty, after a reasonable number of repair attempts. The causes of action are: 1. VIOLATION OF SONG-BEVERLY ACT- BREACH OF EXPRESS WARRANTY COMPLAINT 2. VIOLATION OF SONG-BEVERLY ACT - BREACH OF IMPLIED WARRANTY 3. VIOLATIO...

Excerpt: ...lly obtained summary judgment in an unlawful detainer action, based upon having a lease with an option to purchase, at 2115 N. Upper Krest St., Los Angeles, CA 90046. Defendant DEWITTE MORTGAGE INVESTORS FUND, LLC (DMIF) had foreclosed on a second deed of trust. Also, Defendant PETER DEWITTE recorded an assignment of a deed of trust to himself, and seeks to foreclose on the extinguished first deed of trust, using CLE CAPITAL PARTNERS LLC (CLE) as...

Excerpt: ... with 20STCV23961 and 20STCV12415. The Complaint in consolidated case number 20STCV23961 alleges that GLOBAL CENTURY, as insurance broker, was used by THANDI as a device to broker insurance policies between California trucking insureds, like LOS MORALES, a small trucking company, and the non-California-admitted, insolvent insurer, Global Hawk, provided a policy for indemnity in the event of catastrophic loss, but now the Lorenzo plaintiffs are un...

Excerpt: ...king plumbing causing mold, and there were other uninhabitable conditions. The causes of action are: 1. BREACH OF CONTRACT 2. BREACH OF IMPLIED WARRANTY OF HABITABILITY 3. BREACH OF COVENANT FOR QUIET ENJOYMENT 4. BREACH OF COVENANT OF GOOD FAITH AND FAIR DEALING 5. NEGLIGENCE 6. PREMISES LIABILITY 7. NEGLIGENT MISREPRESENTATION 8. INI'ENTIONAL MISREPRESENTATION 9. NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS 10. INTENTIONAL INFLICTION OF EMOTIONAL...

Excerpt: ...es, and backed-up sewage that constantly seeped into the premises. The causes of action are: 1. BREACH OF WRITTEN CONTRACT 2. BREACH OF COVENANT OF QUIET ENJOYMENT 3. NEGLIGENT MISREPRESENTATIONS 4. NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS. MP Positions Moving party requests an order sustaining the demurrer to the Complaint, on grounds including the following: 1. Plaintiffs' Complaint fails to state facts sufficient to constitute a cause of act...

Excerpt: ...HEN FANG and YU LIN filed a Complaint alleging: 10. In June 2015, Plaintiff Fang, on behalf of Plaintiffs, executed a Limited Partnership Agreement (“LPA,” Exhibit) with Defendant Group 48 LP. Defendant CMB Export and Defendant NK are general partners of the limited partnership, controlled by Defendant Hogan. 11. The purpose of the agreement under the LPA is “[T]he investor seeks to apply for a green card (permanent residenc[y]) under the E...

Excerpt: ...iser, on the basis of his sexual orientation and age, and in retaliation for Plaintiff's complaints. The causes of action are: 1. SEXUAL ORIENTATION DISCRIMINATION (FEHA) 2. DISCRIMINATION BASED ON AGE 3. RETALIATION FOR CONDUCT THAT IS PROTECTED BY THE FAIR EMPLOYMENT AND HOUSING ACT IN VIOLATION OF CALIFORNIA GOVERNMENT CODE §§ 12940 ET SEQ. 4. WHISTLEBLOWER RETALIATION [Lab. Code, § 1102.5] 5. FAILURE TO TAKE ALL REASONABLE STEPS TO PREVENT...

Excerpt: ...IV's, in a conspiracy with other defendants, inducing her to make payments on a loan to him, based upon misrepresentations of being an experienced real estate attorney. Also, that pleading alleges post-judgment aiding and abetting of sale of the subject property to Lanker Partnership, to hinder Plaintiff as judgment creditor, after prevailing at trial on those underlying facts. Before reversal and remand in appellate proceedings (opinion, filed 1...

Excerpt: ...action are: 1. DISCRIMINATION; 2. WRONGFUL TERMINATION/ADVERSE TREATMENT IN VIOLATION OF LABOR CODE § 1102.5; 3. INTERFERENCE WITH PROTECTED AND PAID LEAVE IN VIOLATION OF THE EMERGENCY FAMILY AND MEDICAL LEAVE EXPANSION ACT; 4. WRONGFUL TERMINATION/ADVERSE ACTIONS IN VIOLATION OF PUBLIC POLICY; 5. BREACH OF CONTRACT; 6. BREACH OF THE IMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING; 7. RECOVERY OF WAGES; 8. FAILURE TO PAY STATUTORILY MANDATED OV...

Excerpt: ..., Plaintiff ARMANDO MEJIA filed a Complaint against defendants as allegedly his former employers, and further alleging the following: 15. On or about October 12, 2018, Plaintiff was approved for and went on medical leave due to emotional distress, mental anguish, and other psychological conditions and injuries he was experiencing. 16. During Plaintiff's medical leave, Plaintiff treated with medical providers including a psychiatrist. 17. After be...

Excerpt: ...n Rescue Act. Allegedly, the EDD Appeals Board awarded Plaintiff nothing even though Plaintiff is unemployed. MP Positions Moving party requests an order sustaining the demurrer to the operative pleading, on grounds including the following: · The pleading fails to allege any statutory violation as the Government Claims Act requires for claims against government agencies. · Mr. Stoppelman failed to present his claim before filing his lawsuit as ...

Excerpt: ...tion for being disabled, and for taking time off of work because of Morales' injuries/disability/medical condition. The causes of action are: 1. DISABILITY DISCRIMINATION IN VIOLATION OF FEHA; 2. FAILURE TO ENGAGE IN A GOOD FAITH INTERACTIVE PROCESS IN VIOLATION OF FEHA; 3. FAILURE TO ACCOMMODATE IN VIOLATION OF FEHA; 4. RETALIATION IN VIOLATION OF FEHA; 5. FAILURE TO TAKE ALL REASONABLE STEPS TO PREVENT DISCRIMINATION, AND/OR RETALIATION; 6. VIO...

Excerpt: ...C. Summary On 5/4/22, Plaintiff WEI LI filed a Complaint. On 7/13/22, Plaintiff filed a First Amended Complaint, alleging: To help his son with college entry and attendance, Plaintiff signed a Service Contract with Defendant Weng, who signed her name as the “representative for New Force International Education, and Plaintiff paid a total of $39,950.00. Defendant Weng deliberately used different business entities in the Service Contract, and on ...

Excerpt: ...d case was ordered consolidated for all purposes with 20STCV23961 and 20STCV12415. The Complaint in consolidated case number 20STCV23961 alleges that GLOBAL CENTURY, as insurance broker, was used by THANDI as a device to broker insurance policies between California trucking insureds, like LOS MORALES, a small trucking company, and the non-California-admitted, insolvent insurer, Global Hawk, provided a policy for indemnity in the event of catastro...

Excerpt: ...2021. On 9/23/21, Defendant AZIZBEK KURBANOV filed the Cross-Complaint. On 5/2/22, Defendant AZIZBEK KURBANOV filed a First Amended Cross- Complaint against STATE FARM and three other alleged insurers, for breach of contract, bad faith and unfair business practices, alleging there was insurance coverage as to the rental of a TURO vehicle, and an automobile accident driving it, on 2/12/19. MP Positions Moving party requests an order granting summa...

Excerpt: ...d due to Plaintiff's not refunding payments or paying damages for nonperformance of a solar panel contract, and Bartok offered to withdraw the liens regarding Defendant's dispute regarding Plaintiff's failure to sell solar panels to the homeowner, but never did withdraw the lien. MP Positions Moving parties request an order to set aside the default and default judgment in this matter, allowing moving party to defend this action on its merits, on ...

Excerpt: ...3/17, plaintiffs filed a Complaint. On 12/11/17, plaintiffs filed a First Amended Complaint, alleging: This action for negligence and strict liability arises out of an incident that occurred on December 26, 2015. Oleg Alexandrov was driving east on the 10 Freeway approaching Crenshaw Blvd and downtown Los Angeles. Marianna Alexandrov was sitting in the passenger seat while their two young grandchildren were passengers in the rear seats. Mr. Alexa...

Excerpt: ... done by defendants' employed teacher, at South Bay Junior Academy, caused by defendants' failures and refusals, including with regard to hiring, retention, training and supervision, by defendants SOUTHERN CALIFORNIA CONFERENCE OF SEVENTH-DAY ADVENTISTS (SCC) and NORTH AMERICAN DIVISION OF SEVENTH DAY ADVENTISTS (NAD). The causes of action are: (1) NEGLIGENCE; (2) NEGLIGENT SUPERVISION; (3) NEGLIGENT HIRING/RETENTION; (4) NEGLIGENT FAILURE TO WAR...

Excerpt: ...ry employees, including for compliance with State and Federal laws for employment eligibility, before being placed at Plaintiff BEEMAK PLASTICS, LLC. On 6/24/21, default Judgment was filed in the total sum of $1,426,093.43 against Defendant SOUTH BAY. MP Positions Moving party requests an order setting aside or vacating default entry and judgment and allowing a proposed answer, via a motion filed 6/23/23, on grounds including the following: · De...

Excerpt: ...Bella Street, Pacoima, having various uninhabitable conditions, and the Los Angeles Housing Department repeatedly instructed Defendant to cease tenant harassment such as attempted evictions without paying relocation assistance, which was done in apparent retaliation for tenants' complaints, The causes of action are: 1. VIOLATION OF LOS ANGELES MUNICIPAL CODE (“LAMC”) CHAPTER XV, ARTICLE 1, § 151.05.A; 2. VIOLATION OF BUSINESS AND PROFESSIONS...

Excerpt: ...CTS, LLC and MICHAEL'S COOKIES LLC were required to submit payment to HUNTINGTON CAPITAL in the amount of $356,924 pursuant to a succession of written Warrant Agreements, Defendant J. DON COOKSEY, JR., on his own behalf and on behalf of MICHAEL'S BAKERY, misrepresented the true financial condition of MICHAEL'S BAKERY while failing to disclose the true working capital needs of it, and the amounts distributed to equity holders left it with insuffic...

Excerpt: ... work, as to employment at Lexus of Cerritos as a diagnostic specialist and mechanic shop foreman, and Defendant wrongfully terminated Plaintiff's employment, based on the pretext of “unprofessional and disrespectful behavior towards other technicians,” after false accusations made because Plaintiff had reported an employee's unlawful conversion of a customer's vehicle. The causes of action are: 1. FAILURE TO PROVIDE REASONABLE ACCOMMODATION ...

Excerpt: ...filed this action, including constructive employment termination, and alleging that Plaintiff worked as a maintenance worker, and employer Defendant City of Lawndale intentionally assigned Plaintiff to do work that violated his medical restrictions, and refused to offer available, reasonable work accommodations, based upon discrimination and retaliation. The causes of action of the Third Amended Complaint are: 1. VIOLATION OF THE FAIR EMPLOYMENT ...

Excerpt: ..., service upon contemnors have been authorized. In re Abrams (1980) 108 Cal. App. 3d 685, 691.). No Opposition MP: Plaintiff RP: Summary On 02/07/19, Plaintiff Tatsu Ramen, LLC filed the instant action against Defendants Juan Carlos Rivas, Ryutaro Isobe, B&B International, LLC, Wakou USA, Inc., and Mutual Trading Company, Inc. Plaintiff alleges that defendants conspired to grossly overcharge plaintiff for sauces it purchased from defendants. Plai...