Excerpt: ...ked asphalt caused Plaintiff to trip, fall and strike her head, resulting in a traumatic brain injury and other injuries. The causes of action are: (1) NEGLIGENCE (Cal. Gov. Code § 815.2, 820(a)) (2) NEGLIGENT SUPERVISION (Cal. Education Code § 44807) (3) DANGEROUS CONDITION OF PUBLIC PROPERTY (Cal. Gov. Code § 835). Positions Defendant requests the Court to deem waived privileged documents, on bases including the following:  Plaintiff's ex...

Excerpt: ...is a convicted felon, (2) served 15 years in prison, (3) dealt crack cocaine, (4) possessed illegal guns and (5) threatened to kill a real estate agent. The causes of action are: 1. DEFAMATION; 2. RALPHS CIVIL RIGHTS ACT (VIOLATION OF CAL. CIV. CODE § 51.7); 3. BANE ACT (VIOLATION OF CAL. CIV. CODE § 52.1); 4. INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS; 5. INTENTIONAL INTERFERENCE WITH CONTRACTUAL RELATIONS; 6. INTENTIONAL INTERFERENCE WITH P...

Excerpt: ...er derivative action, as majority shareholder and President of The Palms Restaurant, Inc., arising from wrongful actions of defendants, as shareholders, JOEL FLORIAN and YADIRA FLORIAN. The causes of action are: (1) BREACH OF DUTY OF PRUDENCE & GOOD FAITH-GROSS MISMANAGEMENT-CORPORATE WASTE (2) BREACH OF FIDUCIARY DUTY OF LOYALTY — CONVERSION (3) REMOVAL OF DIRECTORS, CORP. CODE SECTION 304 (4) DECLARATORY RELIEF (5) FAILURE TO PRODUCE CORP., C...

Excerpt: ...deling of their owned home, but failed to pay for a significant portion of the construction work. The Plaintiff's causes of action are: 1. BREACH OF CONTRACT 2. REASONABLE VALUE OF WORK 3. FORECLOSURE OF MECHANICS LIEN. A Cross-Complaint was filed, on 8/3/20, by defendants RACHEL RABIZADEH and SHAWN RABIZADEH against Plaintiff, alleging Plaintiff did remodeling having numerous construction defects. Another Cross-Complaint was filed, on 4/27/21, b...

Excerpt: ...ality of its cultivating and selling marijuana. The elements of a claim for are: 1. BREACH OF CONTRACT 2. BREACH OF PERSONAL GUARANTEE 3. BREACH OF FIDUCIARY DUTY 4. FRAUD ' 5. CONVERSION 6. INTERFERENCE WITH CONTRACTUAL RELATIONS 7. CONSPIRACY/CONVERSION 8. REFORMATION ' 9. INTENTIONAL AND NEGLIGENT MISREPRESENTATION. MP Positions Moving party requests an order granting partial judgment on the pleadings, as to fraud and negligent misrepresentati...

Excerpt: ...e partitioned, because of disputes as to how best to administer the Property and lease it out, after defendants breached an oral agreement, they confirmed by letter, by not fully paying rent, while living there for years, MP Positions Moving party requests an order sustaining the demurrer, and granting the motion to strike, on bases including the following:  Statute of Limitations: Plaintiff's cited authorities for characterizing the October 2...

Excerpt: ... in flipping a condominium project, but instead converted the funds to their own use, thereby causing Plaintiff to lose $2,585,858.33, and other investors to lose tens of millions of dollars. The causes of action are: 1. FRAUD 2. BREACH OF FIDUCIARY DUTY 3. DISSOLUTION OF CORPORATION 4. ACCOUNTING. On 6/16/20, defaults were entered against defendants. MP Positions Moving party requests an order vacating default, under CCP Section 473.5, on ground...

Excerpt: ...rable reverse shifting. MP Positions Moving party requests an order compelling Defendant to serve further responses to form interrogatory 12.1, on grounds including the following:  The instructions on the first page of the official form interrogatories specifically identify the term "INCIDENT" is to be applied to the injury date or, the breach of contract, or the "set of circumstances" leading up to the dispute. This is a breach of warranty ca...

Excerpt: ...nsmission, control system, and inoperable reverse shifting. MP Positions Moving party requests an order compelling Defendant to serve further responses to requests for production of documents nos. 1-3, 9, 13-17, 34-48, on grounds including the following:  Defendant's responses are incomplete, evasive, and its effort to point to select documents in lieu of producing all responsive documents was ineffective.  Plaintiffs seek to evidence that ...

Excerpt: ...SURANCE CO.; and SURETEC INSURANCE COMPANY; and BRADLEY C. CHAPMAN. RP: Plaintiff Summary On 7/30/20, Plaintiff filed a Complaint. On 12/4/20, Plaintiff filed a First Amended Complaint, alleging that defendants refused to turn over to Plaintiff money due and owing as payment for work done installing equipment for William S. Hart Union High School District, and Inglewood Unified School District. The causes of action are: 1. BREACH OF CONTRACT; 2. ...

Excerpt: .../21/20, Plaintiff filed a First Amended Complaint alleging: In and around January 15, 2019, Kwon withdrew approximately $442,244.43 from the Lightspeed accounts, leaving a balance of $340,613 in the Lightspeed accounts. This was not Kwon's money, nor had Cho provided Kwon with any authority to remove these funds. Cho confronted Kwon about the withdrawals and he apologized to Cho by text, agreeing to return the money that he had withdrawn from the...

Excerpt: ...MP Positions Moving party requests an order compelling Defendant's further responses to Plaintiff's Request for Production of Documents numbers 30-33, and awarding $2,310 in sanctions, on bases including the following:  The requests seek documents and evidence describing or tracking repairs related to various consumer complaints from the same make, model, and year as Plaintiff's vehicle, which are relevant to prove a violation of the Song-Beve...

Excerpt: ...aintiff TRICOAST BUILDERS, INC. filed a Complaint alleging that it has not been fully paid for a work authorization agreement and home improvement agreement, after fire damage caused to the individual owner defendants' home. The causes of action are: 1. BREACH OF OBLIGATION TO PAY MONEY 2. BREACH OF WRITTEN CONTRACT 3. FORECLOSURE OF MECHANIC'S LIEN 4. REASONABLE VALUE OF LABOR AND MATERIALS FURNISHED. On 5/2/19, the Court entered judgment in fav...

Excerpt: ...home, but failed to pay for a significant portion of the construction work. The Plaintiff's causes of action are: 1. BREACH OF CONTRACT 2. REASONABLE VALUE OF WORK 3. FORECLOSURE OF MECHANICS LIEN. A Cross-Complaint was filed, on 8/3/20, by defendants RACHEL RABIZADEH and SHAWN RABIZADEH against Plaintiff, alleging Plaintiff did remodeling having numerous construction defects. Another Cross-Complaint was filed, on 4/27/21, by GMP ASSOCIATES, INC....

Excerpt: ... employment, on account of religion, age and disability. Plaintiff experienced an increasingly hostile and retaliatory work environment, which she believes was a result of discriminatory acts, resulting in threats to change accommodation of her work hours that had been established since her employ, and inadequate updates in training and notice of changes in work procedures. Defendants subjected Plaintiff to a deliberate course of harassment, deme...

Excerpt: ...CLAUDIA YUN KANG OH, FRANK OH, THOMAS OH. Summary On 5/28/20, Plaintiffs filed a Complaint alleging the following: After agreeing to a partnership agreement, Defendant J. SUH– an experienced real estate broker and manager of commercial properties– breached an agreement to perform the duties of managing, engaged in converting funds for personal use, and fraudulently induced plaintiffs to sell their ownership interests by communicating substant...

Excerpt: ...her separate property acquired outside of marriage, and Plaintiff relied on Defendant's representations as a knowledgeable law student, regarding filing a Joint Petition for Dissolution of Marriage based on having no community assets. Further, Defendant inflicted emotional distress when he falsely emailed to Plaintiff's employer that Plaintiff had faked practicing her employing entity's religion, and that Plaintiff hacked Defendant's email and wa...

Excerpt: ...L CITY COMMUNITY HEALTH CENTER, INC. (e.g., theft of public funds), and issued an incorrect audit opinion in September 2017, as to which plaintiffs, as corporate officers and whistleblowers, had provided plentiful contrary proof to Defendant, which caused the corporate bad actors to remain in power, to fire plaintiffs in March 2017, and plaintiffs not to be later reinstated. The causes of action are: 1. INTENTIONAL INTERFERENCE WITH PROSPECTIVE E...

Excerpt: ...that if they invested $100,000, then they would (i) receive a level of mentorship and coaching that had “literally never been done before,” including access to exclusive in-person events held at various high-end venues throughout the country, (ii) be “guaranteed” to receive a significant return on the $100,000 investment, and (iii) have the right to receive a refund. The causes of action are: (1) BREACH OF CONTRACT (2) UNJUST ENRICHMENT (...

Excerpt: ...iled a First Amended Complaint. On 2/25/20, plaintiffs filed a motion for leave to file a Second Amended Complaint, alleging that plaintiffs entered into written contracts to provide wound care services for patients at Defendant's hospital, and after a contract terminated on June 30, 2017, defendants acquired possession of all of plaintiffs' trade secrets and confidential information. The causes of action of the Second Amended Complaint are: 1) B...

Excerpt: ...otal from bank accounts that Defendant orally agreed were her separate property acquired outside of marriage, and Plaintiff relied on Defendant's representations as a knowledgeable law student, regarding filing a Joint Petition for Dissolution of Marriage based on having no community assets. Further, Defendant inflicted emotional distress when he falsely emailed to Plaintiff's employer that Plaintiff had faked practicing her employing entity's re...

Excerpt: ...employment, after he requested owed wages. The causes of action are: 1. FAILURE TO PAY OVERTIME; 2. FAILURE TO PAY FOR REST PERIODS NOT PROVIDED; 3. FAILURE TO PAY FOR MEAL PERIODS NOT PROVIDED; 4. FAILURE TO PAY MINIMUM WAGE; 5. WAITING TIME PENALTIES; 6. WRONGFUL TERMINATION IN VIOLATION OF PUBLIC POLICY; 7. HOSTILE WORK ENVIORNMENT IN VIOLATION OF GOVT. CODE §12940 ET SEQ. 8. INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS; 9. NEGLIGENT INFLICTI...

Excerpt: ...nting Plaintiff exclusive rights to proprietary custom spice blends, formulations and recipes, in growing the business called “San Pedro Fish Market,” including by interfering with Plaintiff's business arrangements, and reneging on compensation agreements. The causes of action are: 1. BREACH OF ORAL CONTRACT 2. TORTIOUS INTERFERENCE WITH WRITTEN CONTRACT OR PROSPECTIVE BUSINESS ADVANTAGE 3. NEGLIGENT INTERFERENCE WITH PROSPECTIVE BUSINESS ADV...

Excerpt: ...er, including based on Plaintiff's medical conditions related to pregnancy justifying reasonable accommodations. The causes of action are: (1) DISCRIMINATION ON THE BASES OF SEX, PREGNANCY, DISABILITY, ASSOCIATIONAL DISABILITY, CFRA LEAVE, REQUEST FOR ACCOMMODATION IN VIOLATION OF FEHA (GOV. CODE § 12900, ET SEQ.); (2) RETALIATION IN VIOLATION OF FEHA (GOV. CODE § 12900, ET SEQ.); (3) HOSTILE WORK ENVIRONMENT HARASSMENT IN VIOLATION OF THE FEHA...

Excerpt: ...n investing member, but, in a conspiracy with other defendants, concealed self- dealing in buying and selling real properties, and in assigning membership interests and misrepresenting profits and amounts due for distributing. The causes of action are: 1. INTENTIONAL CONCEALMENT 2. CONSPIRACY 3. BREACH OF CONTRACT 4. BREACH OF FIDUCIARY DUTY 5. ACCOUNTING. MP Positions Moving party requests an order sustaining the demurrer to the First Amended Co...