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: ...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...