Excerpt: ...rst Amended Complaint, alleging that he is entitled to quiet title to 8943 Telfair Avenue, Los Angeles, because one of the abstracts-- the 2012 Abstract of Judgment-- did not create a lien against the subject real property, since the Judgment Debtor was deceased, and hence was not the owner on or after the date the 2012 Abstract was recorded. The causes of action are: 1. QUIET TITLE 2. CANCELLATION OF INSTRUMENTS 3. DECLARATORY RELIEF. On 11/1/21...

Excerpt: ...ed the lack of conversion permits, demanded excess rent in violation of the Los Angeles Rent Stabilization Ordinance (LARSO), and gave a Declaration of Intent to Evict for Landlord Occupancy, without paying required relocation assistance. The causes of action are: (1) VIOLATION OF STATUTE (CIVIL CODE, SECTION 1942.4) (2) RESTITUTION BASED ON UNJUST ENRICHMENT (3) VIOLATION OF BUSINESS AND PROFESSIONS CODE, SECTION 17200 (4) MONEY HAD AND RECEIVED...

Excerpt: ...yment as camera operator, including by allowing ongoing sexual harassment by a coworker, and reducing hours, in retaliation for Plaintiff's complaining about the harassment instead of putting up with it in order to get along with the other employee. The causes of action are: 1) SEXUAL HARASSMENT, HOSTILE WORK ENVIRONMENT (CAL. GOV. CODE § 12940(J)) 2) DISCRIMINATION (CAL. GOV. CODE § 12940(A)) 3) RETALIATION FOR OPPOSING DISCRIMINATION AND HARA...

Excerpt: ...arranty of habitability, and violations of Beverly Hills Municipal Code, alleging lessors' liability for residential water leaks, gas issues, electrical issues, and mold issues. On 9/23/19, plaintiffs filed a First Amended Complaint including retaliatory eviction against the DALLALS. On 10/30/19, defendants, HILDA DALLAL and MARK DALLAL, filed a Cross-Complaint against Cross-Defendant 1 OAK, for negligence, breach of contract, equitable indemnity...

Excerpt: ... Nathaniel Berhow walked onto the campus with a .45-caliber handgun, and began to shoot students before taking his own life with the same gun. Gracie and Dominic died from their gunshot wounds. On November 16, 2020, the Blackwell plaintiffs filed a complaint for general negligence— wrongful death, premises liability—wrongful death, negligence—survivor cause of action, and negligence—emotional distress. Plaintiffs allege William S. Hart Un...

Excerpt: ...ntified as defendant Charly Taylor. On May 7, 2022, Anderson alleges a co-tenant in the building, defendant Stanley Nathanson, committed a sexual assault and attempted within the apartment building laundry room common area. Plaintiffs submitted a complaint with property manager Taylor, but allege defendant landlords refused to conduct any independent investigation and/or seek eviction of Nathanson. Instead, on August 17, 2022, Plaintiffs were ser...

Excerpt: ... (“TRANSFORCE”) and Northern Refrigeratored Transportation. Inc. (“NRT”) as a truck driver. Transforce, a national truck driver staffing firm had placed Ahmed with NRT and Ahmed upon completion of training was to begin as a truck driver for NRT 17. Ahmed completed his requisite orientation spanning from June 22, 2021 to June 25, 2021 and thereafter being his training/field work on or about June 28, 2021 which was scheduled from 3am to 3pm...

Excerpt: ...d with leave to amend. On 3/24/23, Plaintiff filed a First Amended Complaint, alleging defendants leased residential property to Plaintiff, which had uninhabitable conditions including ongoing rainwater intrusion, faulty plumbing, mold, faulty weather protection, dropping ceiling debris, dangerous electrical wiring, and defendants breached promises to remediate these issues by long ignoring Plaintiff's maintenance requests. The Causes of Action a...

Excerpt: ... 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 CODE §§ 226.7 AND ...

Excerpt: ...er, and later appointed CEO, stole both plaintiffs' corporate assets and embezzled funds for personal use, and was fired on 9/13/22, upon discovery. The causes of action are: 1. BREACH OF CONTRACT; 2. FRAUD COUNT ONE; 3. VIOLATION OF CALIFORNIA PENAL CODE § 484; 4. CONVERSION-COUNT ONE; 5. BREACH OF FIDUCIARY DUTY; 6. CONSTRUCTIVE FRAUD; 7. EMBEZZLEMENT; 8. FRAUD-COUNT TWO; 9. CONVERSION-COUNT TWO; 10. FRAUD-COUNT THREE; 11. CONVERSION-COUNT THR...

Excerpt: ...ort 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 Defendant Group 48 LP in July 2015. 12. Defendants then made a loan for ...

Excerpt: ...action is INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS. MP Positions Moving party requests an order sustaining the demurrer to the Complaint, on grounds including the following: · The conduct relates to anticipated litigation and is privileged and protected conduct as a matter of law under Civil Code section 47(b). · The allegations, including “allegations of criminal conduct . . . to third parties” and “demands for money now claiming tha...

Excerpt: ...dant's authorized repair facility has not repaired various defects after numerous opportunities, and Defendant has failed to repurchase the vehicle. MP Positions Moving party requests an order compelling Defendant's further responses to document requests numbers 1, 2, 3, 5, 8, 9, 11, 12, 16, 17, 18, 19 and 20 through 35, on grounds including the following: · Plaintiff seeks documents directly related to her Song-Beverly Consumer Warranty Act cla...

Excerpt: ...s, minimum wages, provide meal and rest breaks, related wage and hour claims, sexual harassment, wrongful termination in violation of public policy, failure to accommodate, failure to engage in the interactive process, assault and battery, negligent and intentional infliction of emotional distress, PAGA claims, among others. MP Positions Moving and joining parties requests an order compelling arbitration of Plaintiff's complaint, and staying this...

Excerpt: ...or Negligence, alleging that defendants, as owners of an apartment building at 1616 North La Brea Ave, Los Angeles, received complaints from tenants regarding the uptick in violence in the area, but defendants ignored the concerns, and on or about 1/18/20, plaintiffs were visiting friends at the property, when an unknown individual shot both plaintiffs. MP Positions Moving parties request an order compelling deposition attendance of nonparty Raim...

Excerpt: ...g: 16. On or about June 22, 2021, Plaintiff Ahmed Wafa (“Ahmed”) a Middle Eastern was hired by Transforce, Inc. (“TRANSFORCE”) and Northern Refrigeratored Transportation. Inc. (“NRT”) as a truck driver. Transforce, a national truck driver staffing firm had placed Ahmed with NRT and Ahmed upon completion of training was to begin as a truck driver for NRT 17. Ahmed completed his requisite orientation spanning from June 22, 2021 to June ...

Excerpt: ...ended Complaint, alleging that plaintiffs are tenants at 625 S. Burlington Ave., Los Angeles, which has uninhabitable conditions, including cockroach infestations, widespread mold contamination, open exposure to raw sewage, plumbing issues, faulty and insufficient utilities, structural defects, and deficient security. The causes of action are: 1. BREACH OF THE WARRANTY OF HABITABILITY 2. NEGLIGENCE 3. BREACH OF QUIET ENJOYMENT 4. NUISANCE 5. VIOL...

Excerpt: ...Amended Complaint, alleging that he is entitled to quiet title to 8943 Telfair Avenue, Los Angeles, because one of the abstracts-- the 2012 Abstract of Judgment-- did not create a lien against the subject real property, since the Judgment Debtor was deceased, and hence was not the owner on or after the date the 2012 Abstract was recorded. The causes of action are: 1. QUIET TITLE 2. CANCELLATION OF INSTRUMENTS 3. DECLARATORY RELIEF. On 11/1/21, De...

Excerpt: ...a was married to and living with Plaintiff. Defendant Olha Kukshyn is Vitalina's mother. In January 2019, Vitalina and Kukshyn told Plaintiff that he should invest in property in the city of Kyiv, Ukraine. Kukshyn was a resident in Kyiv and she told Plaintiff that she knew were there were good deals to purchase real estate there. She also stated that Plaintiff would double his investment from making a real estate purchase in Kyiv (FAC ¶ 39). Vit...

Excerpt: ...7-4907 ½ Wadsworth Avenue, Los Angeles, because it acquired title to the Property from Defendant RAFAEL GUTIERREZ AYALA via Grant Deed, on or about January 21, 2021, as a bona fide purchaser without knowledge of AYALA's allegations. The causes of action are: 1. QUIET TITLE 2. EQUITABLE SUBROGATION (TO IMPRESS EQUITABLE LIEN) 3. PARTITION BY SALE OF REAL PROPERTY 4. BREACH OF WARRANTY UNDER CAL. CIVIL CODE § 1113. On 7/19/22, RAMIRO AYALA and RA...

Excerpt: ...hat Plaintiff was wrongfully terminated from her employment with Defendants DCC Staffing Services Inc. (“DCC”), Ancestral Home Health Care Providers Inc. (“Ancestral”), Ana Lingao (“Lingao”), and Evelyn Borromeo-Cruz (“Borromeo-Cruz”) (collectively, “Defendants”) on approximately March 15, 2021. Plaintiff alleges causes of action for breach of express written contract, breach of implied contract, breach of the covenant of good...

Excerpt: ...iff filed a Third Amended Complaint, alleging: Before and during Plaintiff's dental treatments, each defendant misrepresented, in a marketing scheme, to Plaintiff and others, that Defendant EDWARD MORANDO was licensed, authorized and qualified to perform tooth extractions and other dental services. Defendants ST. JOHN'S WELL CHILD & FAMILY MEDICAL CENTER and KOUROSH MICHAEL BERAL, D.D.S. and DR. DEHGHAN- SHIRAZI failed to properly train, screen, ...

Excerpt: ...OUNDATION. RP: 1. Plaintiff. 2. Defendant NANCY BARGMANN. Defendant HARBOR DEVELOPMENTAL DISABILITIES FOUNDATION. Summary On 11/8/21, Plaintiff filed a Complaint. On 3/15/22, Plaintiff filed a First Amended Complaint alleging: Plaintiff is an association of Hispanic/Latinx families having developmentally disabled children entitled to state-funded services, under the Lanterman Developmental Disabilities Services Act. Welf. & Inst. Code §§ 4500 e...

Excerpt: ...al property for rent and claimed that it was equipped with central air and heating, and Defendant MOLLY WAGGONER verbally stated similarly, but there actually were a myriad of habitability issues, including inadequate heat. The causes of action are: 1. NEGLIGENCE; 2. BREACH OF CONTRACT; 3. TENANT HARASSMENT (L.A.M.C.1145.32, et seq); 4. UNLAWFUL EVICTION (LA.M.C. 1149.99, et seq); and 5. FRAUDULENT MISREPRESENTATION. MP Positions Moving party req...

Excerpt: ... Hart Union High School District, and Inglewood Unified School District. The causes of action are: 1. BREACH OF CONTRACT; 2. OPEN BOOK ACCOUNT; 3. VIOLATION OF CAL. PUB. CON. CODE § 7107, ET.SEQ.; 4. BREACH OF CONSTRUCTIVE TRUST; 5. CONVERSION OF PERSONAL PROPERTY; 6. TO RECOVER MONEY DUE ON PAYMENT BOND ON PUBLIC WORK. MP Positions Moving parties requests an order allowing leave to file a proposed cross-complaint, and to amend answers to add af...

Excerpt: ...t. On 1/8/16, plaintiffs filed a First Amended Complaint, alleging acts of corporate looting and disloyalty, done by TENG HUANG, against MAGNUS SUNHILLGROUP, LLC, and its minority members. The causes of action are: (1) BREACH OF FIDUCIARY DUTY; (2) RESCISSION; (3) QUIET TITLE; (4) SLANDER OF TITLE; (5) DECLARATORY RELIEF; (6) ABUSE OF CONTROL; (7) CORPORATE WASTE; (8) CONVERSION; (9) TRESPASS TO CHATTEL; (10) FRAUD / INTENTIONAL MISREPRESENTATION...

Excerpt: ...lectrical defects, manufactured and warranted by Defendant JAGUAR LAND ROVER NORTH AMERICA, LLC MP Positions Moving party requests an order compelling Defendant to serve further responses to document requests including numbers: 18, 20, 21, 25-29, and 31-34, and imposing $2125 in monetary sanctions, on grounds including the following: · Aside from asserting meritless objections, Defendant has failed to provide any substantive response to many of ...

Excerpt: ... accurate wage statements. The causes of action are: 1. FAILURE TO PAY WAGES [VIOLATION OF LABOR CODE §1194] 2. FAILURE TO PAY WAGES AT TIME OF TERMINATION/SEPARATION [VIOLATION OF LABOR CODE §§201-203] 3. FAILURE TO PAY OVERTIME WAGES [VIOLATION OF LABOR CODE §510] 4. FAILURE TO PROVIDE MEAL AND REST PERIODS [VIOLATION OF LABOR CODE §226.7] 5. FAILURE TO PROVIDE ACCURATE AND COMPLETE WAGE STATEMENTS [VIOLATION OF LABOR CODE §226] 6. UNFAIR...

Excerpt: ...nded Complaint. On 1/27/23, Plaintiff filed a Third Amended Complaint, alleging: Before and during Plaintiff's dental treatments, each defendant misrepresented, in a marketing scheme, to Plaintiff and others, that Defendant EDWARD MORANDO was licensed, authorized and qualified to perform tooth extractions and other dental services. Defendants ST. JOHN'S WELL CHILD & FAMILY MEDICAL CENTER and KOUROSH MICHAEL BERAL, D.D.S. and DR. DEHGHAN- SHIRAZI ...

Excerpt: ...with Defendant Weng, who signed her name as the "representative for New Force Intemational Education, and Plaintiff paid a total of S39,950 00 Defendant Weng deliberately used different business entities in the Sen-ice Contract, and on her business card, to confuse Plaintiff and to create the false impression that she was a successåLl businesswoman with great resources and capabilities. The causes of action are: 1 INTENTIONAL MISREPRESENTATION 2...

Excerpt: ...s-Defendant SHASHA ZHENG filed a Complaint. On 11/4/22, Plaintiff filed a motion for leave to file a proposed First Amended Complaint: adding a Cause of Action for THEFT PURSUANT TO PENAL CODE $96: and 7th Cause of Action for BREACH OF FIDUCIARY DUTY - DUTY OF LOYALTY On 12/9/22, Plaintiff filed a First Amended Complaint, alleging- Starting August 2, 2017, the day after the parties stated date of marriage separation: Defendant/Cross-Complainant X...

Excerpt: ... Brea Ave, Los Angeles, received complaints from tenants regarding the uptick in violence in the area: but defendants ignored the concerns: and on or about 1 / 18/20, plaintiffs were visiting friends at the property: when an unknown individual shot both plaintiffs. The cause of action is Negligence. MP Positions Moving parties request an order comrrlling frit-ther responses to special interrogatories 7, 8, 10, and 26: and document requests 2, 4-8...

Excerpt: ...nded Complaint: alleging: This action for negligence and strict liability arises out of an incident that occulTed on December 26, 2015 _ Oleg Alexandrov was driving east on the 10 Freeway approaching Crenshaw Blvd and dountown Los Angeles. Marianna Alexandrov was sitting in the passenger seat while their two young grandchildren were passengers in the rear seats. Mr. Alexandrov was driving a Toyota Ray 4 in the number two lane Mr. Alexandrov was d...

Excerpt: ...NTRALIA G P_: LLC; INAMERICA HOLDINGS, LLC; DEBRA L. DUGGAN; and PROLAND IVLQNAGENIENT CONIPANY LLC Defendants . Kevin Singer, Superior Coun Receiver Plaintiffs MICHAEL N. KOENIG: LAUREN M. KOENIG; and Kevin Singer, Superior Court Plaintiffs _ Defendants Summary On 8/10/18, plaintiffs MICHAEL N. KOENIG: LAUREN M. KOENIG, individually and derivatively on behalf of CENTRALIA LIMITED INVESTORS, LP: filed a Complaint. On 12/12/22, plaintiffs filed a ...

Excerpt: ...ng failures to pay minimum wages, pay overtime wages, provide meal and rest breaks or compensation in lieu thereof: produce Plaintiffs' employee file and payroll records upon request, provide itemized employee wage statements: and pay wages upon tennination_ The jury rendered the verdict for plaintiffs: on 2/17/22 Judgment was filed 9/9/22. Notice of judgment Ivas filed 10/25/22 The motion for attorneys' fees was filed 12/23/22 MP Positions Movin...

Excerpt: ...S COMPLIANCE TO RFPD2: AND REQUEST FOR MONTEARY SANCTIONS AGAINST DEFENDANT IN THE suvl OF S7:951 01. MOTION COMPEL DEFENDANT/CROSS-COMPLAINANT TO PROVIDE FURTHER SUPPLENIENTAL RESPONSES TO REQUEST FOR ADMISSIONS: SET TWO: AND REQUEST FOR MONETARY SANCTIONS AGAINST DEFENDANT IN THE suvl OF 01. Notice. Okay Opposition MP: Plaintiff/Cross-Defendant SHASHAZHENG_ RP: XIIJWAN HU Summary On 8/3/20, Plaintiff/Cross-Defendant SHASHA ZHENG filed a Complai...

Excerpt: ...d to filing this motion: on grounds including the following: On 10/13/22, Plaintiff executed Defendant MERCEDES-BENZ USA: LLC's Offer to Compromise. The motion is brought to determine reasonably incurred costs: expenses, and attomey' s fees (Civ. Code 1794(d)) that Defendant obligated itself to pay Plaintiff submitted detailed time records for all persons who have worked on this matter, and receipts for all costs and expenses incurred (motion, ex...

Excerpt: ...ed after a reasonable number of attempts MP Positions Moving party requests an order compelling Defendant to finther document responses, and imposing monetary sanctions, on grounds including the following: Defendant's responses contain indiscriminate and improper boilerplate objections. W'hile FCA usually says it ' 'ivill comply in frill," that is inaccurate because FCA does not state that it has produced all responsive documents, cherry picks wh...

Excerpt: ...s Paul Mander ('Mander"), Sergio Venegas Venegas"), and Jaime Venegas C 'J. Venegas") (collectively: 'Defendants') for: (1) failure to pay minimum wages; (2) failure to pay overtime wages; (3) failure to provide rest periods or compensation in lieu thereof; (4) failure to provide meal periods or comrrnsation in lieu thereof; (5) failure to provide employment records upon request; (6) knowing and intentional failure to comply with itemized employe...

Excerpt: ...eging that, on or about Nowember 17, 2016, Plaintiff purchased a used 2015 Rolls Royce Ghost, under express written warranty: but the vehicle kept experiencing unrepaired defects, and/or nonconformities: and defendants conspired to secretly place tamper seal material on the vehicle, without Plaintiffs knowledge or consent, to to,' to catch Plaintiff tampering with the vehicle, which never happened, and which reduced the vehicle' s value. Further,...

Excerpt: ...etic surgeon who worked for Defendants' medical spa: and Ivas promised by LIU to be paid a yearly salary of S3CH3,CH30, 30% of the business 's profits: and an option for equity in the business: but Plaintiff Ivas only paid a total of S 150,000 The causes of action are: 1 _ BREACH OF WRITTEN CONTRACT; 2 BREACH OF ORAL AND OR IMPLIED-IN-FACT CONTRACT; 3 _ PROMISSORY ESTOPPEL: 4. BREACH OF THE IWLIED CO\ÆNANTS OF GOOD FAITH AND FAIR DEALING; UNJUST...

Excerpt: ...URLNG COMPANY, mc. filed a Complaint On 8/25/21, Plaintiff filed a First Amended Complaint: alleging: Defendant WFBM, LLP provided legal representation as to a defensible asbestos case-- Norris Morgan v. J-M Man4facturing Company, Inc.: LASC Case No. BC695605: in which the underlying case plaintiffs were represented by Simmons Hanly Conroy, LLC (SHC), with lead trial associate Scott Peebles_ But Defendant grossly poorly represented Plaintiff, in ...

Excerpt: ...ntiffs Dr. Payam Vahedifar ("Mr. Vahedlfar%) and Shadi Vahedifar ('Ms. Vahedifar") (collectively, "Plaintiffs") The Coun has considered the moving, opposition and reply pape:rs_ BACKGROUND This action arises out ofa landlord/tenant relationship. Plaintiffs' complaint (the ' 'Complaint") alleges: (1) violation of Civil Code section 1950 5; (2) statutory fraud or deceit and common law fraud; (3) intentional misrepresentation; (4) negligent misrepre...

Excerpt: ...alleging that plaintiffs are tenants at 625 S _ Burlington Ave.. Los Angeles, which has uninhabitable conditions, including cockroach infestations: widespread mold contamination, open exposure to raw sewage, plumbing issues, faulty and insufficient utilities, structural defects, and deficient security The causes of action are: 1 BREACH OF THE WARRANTY OF HABITABILITY 2 NEGLIGENCE 3 BREACH OF QUIET ENJOYVIENT 4 NUISANCE VIOLATION OF CALIFORNIA CIV...

Excerpt: ...nto a uritten subcontract providing for Plaintiff to forming, concrete, shotcrete: rebar, and masonry work at the real property commonly known as 6933 Santa Monica Blvd, Los Angeles, but defendants interfered u.ith the subcontract performance and caused a delay in the construction schedule _ The causes of action are: 1 _ BREACH OF WRITTEN CONTRACT; 2 GOODS: WARES AND SOLD AND DELIVERED; 3 _ OPEN BOOK ACCOUNT; 4. ACCOUNT STATED On 2," 18/22, Defen...

Excerpt: ...east nine coun days before the hearing under Califomia Code of Civil Procedure ("CCP") section 1005, subdivision (b) BACKGROUND This action arises out of an employment relationship. Plaintiff s complaint (the ' 'Complaint") alleging: (1) retaliation pursuant to &xle section 1102.5; (2) retaliation pursuant in violation of Labor Code section 6310; (3) common law assault; (4) common law battery; (5) negligent hiring, supervision, or retention of em...

Excerpt: ...t of an alleged breach of an agreement (the "Agreement') to purchase real properV (the "Property') entered into by Moving Defendant as the seller of the Property and Plamtiffs predecessor in interest, HSK Properties, LLC. On December 15, 2022, the Court granted a motion to expunge lis pendens (the "Lis Pendens Motion") filed by Defendant and ordered that the lis pendens placed on the Property by Plaintiff be expunged on the grounds that Plaintiff...

Excerpt: ...iled a Complaint. On 12/12/22, plaintiffs filed a Fourth Amended Complaint: alleging: Plaintiffs are limited partners and co-owners of a interest in CENTRALIA LIMITED INVESTORS: LP_ Defendant, DONALD E. HOLLINGSHEAD was, before his passing and ensuing Probate proceedings, an individual who was the shareholder member: President and a director of the General Partner or acting General Partner of CENTRALIA APARTNIENTS: CENTRALIA LIMITED and PIONEER 2...

Excerpt: ...endant Nissan North America: Inc. and shortly thereafter experienced unrepaired problems, such as with air conditioning system failure, display issues: and squeaking brakes. MP Positions Moving party requests an order appomtmg arbitrators other than with the AAA, and requiring Defendant to timely pay arbitration fees, on grounds including the following: Can Defendant turn the "Ord "may" into "must: " and render the clause illusory when Defendant ...

Excerpt: ...e: Media Screen, Brakes, Active Distance Assist, Engine Coolant System, Tire Pressure Monitor, Driver: s Window, Left Head Lamp Control Unit, Adaptive High Beam System, Camera System, Parktronic Sensors: Brake Lamp Switch, Active Brake Assist System, Active Distance Assist System, Cigarette Lighter: and Rear Parking Sensor. MP Positions Moving party requests an order granting summary adjudication of the First, Second, Fourth, Fifth and Sixth caus...