Excerpt: ...mended 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. Alexandrov was driving a Toyota Ray 4 in the number two lane of travel. Mr. Alex...

Excerpt: ... 51 Eucalyptus trees that are actually attractive and desirable, and not really dangerous, diseased or unhealthy, as the Association claims. On 11/2/22, Plaintiff filed a request for dismissal of the entire action. MP Positions Moving party requests an order awarding $11,991.70 in attorneys' fees against Plaintiff, on grounds including the following: · The defense litigation objective here was to defeat the imposition of an injunction preventing...

Excerpt: ...ly touching, adverse employment actions, discrimination, harassment and retaliation, based on gender, Plaintiff was forced to resign. The causes of action are: 1. DISCRIMINATION IN VIOLATION OF FEHA 2. FAILURE TO PREVENT DISCRIMINATION (FEHA) 3. HARASSMENT IN VIOLATION OF FEHA 4. FAILURE TO PREVENT HARASSMENT IN VIOLATION OF FEHA 5. RETALIATION IN VIOLATION OF FEHA 6. FAILURE TO PREVENT RETALIATION (FEHA) 7. RETALIATION IN VIOLATION OF LABOR CODE...

Excerpt: ...nt, alleging: For years, defendants have been trying to drive Plaintiff out of her leased premises, including by fraud. Plaintiff successfully 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 assign...

Excerpt: ...ing him, or putting him in handcuffs, and pointing a gun at him. The causes of action are: 1. UNLAWFUL SEARCH AND SEIZURE IN VIOLATION OF CONSTITUTIONAL RIGHTS UNDER 42 U.S.C. § 1983 - FOURTH AMENDMENT 2. DENIAL OF EQUAL PROTECTION IN VIOLATION OF CONSTITUTIONAL RIGHTS UNDER 42 U.S.C. § 1983 - FOURTEENTH AMENDMENT 3. VIOLATION OF CIVIL RIGHTS UNDER 42 U.S.C. § 1983 - SUPERVISORY LIABILITY 4. VIOLATION OF CAL. CIVIL CODE § 52.1 (B) - BANE ACT ...

Excerpt: ...make Plaintiff angry, and some unknown people in the community engaged in terrorism. Plaintiff requests the complaint allegations be forwarded to the F.B.I. if this case is denied. No causes of action are stated. MP Positions Moving party requests an order sustaining the demurrer to the Complaint, on grounds including the following: · TELECARE CORPORATION is a California corporation that is a health care provider for mental health services for s...

Excerpt: ... GENERAL MOTORS (Defendant) regarding a 2018 Chevrolet Malibu, which had nonconformities remaining unrepaired after a reasonable number of attempts. MP Moving parties request an order compelling Defendant to provide further responses to and overrule Defendant's objections to Plaintiffs' First Set of Requests for Production of Documents (Requests), and awarding $2,685.00 sanctions, on grounds including the following: · Defendant provided inadequa...

Excerpt: ...cing 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 HARASSMENT (CAL. GOV. CODE § 12940(H)) 4) WRONGFUL CONSTRUCTIVE TERMINATION IN VIOLATION OF PUBLIC P...

Excerpt: ... in the amount of $27,290.00. The causes of action are: 1. FORECLOSURE OF MECHANIC'S LIEN; 2. BREACH OF WRITTEN CONTRACT; 3. COMMON COUNTS; 4. UNJUST ENRICHMENT; 5. STATUTORY PROMPT PAYMENT PENALTIES. On 6/30/20, defendants filed a Cross-Complaint. On 9/21/22, defendants filed a First Amended Cross-Complaint against plaintiffs and others, alleging that plaintiffs did substandard remodeling work on defendants' residence. Those Causes of Action are...

Excerpt: ...age-and hour violations. The causes of action are: 1. FAILURE TO PAY MINIMUM WAGE (Cal. Lab. Code S 1197), 2 FAILURE TO CONIPENSATE FOR ALL HOURS WORKED (Cal. Lab. Code S 1198); 3. FAILURE TO PAY OVERTIME CONIPENSATION (Cal. Lab Code 1198); 4. FAILURE TO PAY NEAL PERIOD COMPENSATION (Cal. Lab. Code S 226.7), FAILURE TO PAY REST PERIOD COMPENSATION (Cal. Lab. Code 226.7); 6. FAILURE TO FURNISH ACCURATE WAGE AND HOUR STATEMENTS (Cal. Lab. Code S 22...

Excerpt: ...uted a frivolous lawsuit against her: a former employee of defendants: for purposes of retaliating and preventing her from exercising her rights to freedom of speech and to petition the Court with a case for wrongåul employment termination, and defendants ultimately dismissed their case. The causes of action are: 1 _ WRONGFUL USE OF CIVIL PROCEEDINGS/ WLALICIOUS PROSECUTION 2 ABUSE OF PROCESS MP Positions Moving party requests an order compellin...

Excerpt: ...position MP: Plaintiff RP: Defendant Summary On 10/18/21, PlaintiffLMARCENE IRIGOYEN filed a Lemon Law Complaint alleging that Plaintiffs purchased 2020 Cadillac XTS vehicle has knoun defects involving the infotainment and backup camera systems, which Defendant has been unable to repair within a reasonable time, but Defendant failed to repurchase it: in Ivillftl violation of Song-Beverly Consumer Warranty Act. MP Positions Moving party requests a...

Excerpt: ...of providing reasonable accommodations, like part-time work from home, and Defendant assened the pretext of needing a frill-time employee. The causes of action are: WRONGFUL TERMINATION IN VIOLATION OF PUBLIC POLICIES. MEDICAL LEAVE RETALIATION. MEDICAL LEAVE DISCRIMINATION RETALIATION FOR REQUESTING AND USING ACCOMMODATIONS 4. FOR DISABILITIES. . FAILURE TO ENGAGE IN A TINIELY, GOOD FAITH, INTERACTIVE PROCESS TO DETERMINE REASONABLE ACCOMMODATIO...

Excerpt: ...nts BECKMAN, BURRELL HYNES: NATIONAL and EVENTUS: including as managers and membership interest owners of plaintiffs, through their mutual and continuing scheme, including under- reporting residual income of plaintiffs and over-reporting operating expenses, stole all assets of plaintiffs: and 50% of Plaintiff LAW's ownership interest therein, in violation of operating agreements and in breach of related covenants of good faith and fair dealing. T...

Excerpt: ...de Carport Number 1 : or Plaintiff wants at least S 1 Cuco to cover losses, instead of the $20,000.00 Defendant attempted to provide. The causes of action are: BREACH OF CONTRACT _ . NEGLIGENCE MP Positions Moving parties request an order sustaining the demurrer to the Complaint: and granting the motion to strike allegations regarding attorneys fees, on grounds including the following: The contract claim is uncertain. It is impossible for these d...

Excerpt: ...inimum wages, and failed to maintain records. MP Positions Moving parties request an order compelling Plaintiff into arbitration staying or dismissing the proceedings, on grounds including the following: Plaintiff signed a completely optional arbitration agreement, February 7: 2022: which requires him to submit any disputes related to his employment to individual arbitration. Plaintiff voluntarily agreed to pursue any claims on an individual basi...

Excerpt: ...nt: as insurer, asserted boilerplate exclusionary language related to workers compensation benefits, only as to Plaintiff MORALES, yet policy proceeds were not timely paid to SULAHIAN, nor was there any explanation as to why policy limits were not tendered to him. Defendants have not provided any analysis, investigation: or legal and/or factual analysis as to the preliminary determination of the required employee/employer relationship required un...

Excerpt: ... pretext of employees ' sexual harassment complaints: whereas it was actually because he reported to a Human Resources manager that his supervisor was smoking marijuana during work hours at work _ The causes of action are: 1. RETALIATION IN VIOLATION OF LABOR CODE 1102.5 2 WRONGFUL TERMINATION IN VIOLATION OF PUBLIC POLICY 3 _ UNLAWFUL DENIAL OF REASONABLE ACCOLWv10DATION OF A DISABILITY 4. FAILURE TO ENGAGE IN TIIMELY: GOOD FAITH, INTERACTIVE PR...

Excerpt: ...AY REGULAR WAGES AND MINIMUM WAGES IN VIOLATION OF LABOR CODE 1194, 201, 218.5 (2) FAILURE TO PAY PAID TILME OFF ("PTOS") IN VIOLATION OF LABOR CODE S 227.3 (3) FAILURE TO REIMBURSE BUSINESS EXPENDITURES IN VIOLATION OF LABOR CODE 2802 (4) FAILURE TO PROVIDE ACCURATE WAGE STATEMENTS IN VIOLATION OF LABOR CODE 226 (5) LIQUIDATED DAMAGES IN VIOLATION OF LABOR CODE S 1194.2 (6) WAITING TILME PENALTIES IN VIOLATION OF LABOR CODE 201 AND 203 (7) RETAL...

Excerpt: ... a 2015 Dodge Journey which has unrepaired issues, including engine, HVAC and electrical. MP Positions Moving party requests an order compelling Defendant's ftlther document responses and production, on grounds including the following: Service of some supplemental responses after the motion was filed, does not fully resolve the motion. Plaintiff would still entitled to an order. Defendant FCA failed to fflther verified, Code-compliant responses: ...

Excerpt: ...laintiff filed a First Amended Complaint: alleging that defendants wrongftlly terminated his employment, based on age discrimination: and fraudulently induced Plaintiffto sign a severance agreement: release: and illegal noncompetition agreement prohibiting work for Porsche: which he did not fully understand due to limited fluency in English, because of high- level management' s repeatedly stating that the agreement Ivas drafted to mean that Plain...

Excerpt: ...ract: (2) Breach of Implied Warranty of Habitability/Tenantability: (3) Breach of Implied Warranty of Quiet Enjoyment: (4) Negligence, (5) Nuisance (Private), and (6) Retaliatory Acts (Violation of Califomia Civil Code 1942_5)_ On 11/15/22, Defendants filed the instant motion to strike punitive damages from Plaintiffs Complaint. On 12/14/22, Plaintiff filed an opposition and on 3/9/23 Defendants replied. MP Positions Plaintiff moves the Coun to s...

Excerpt: ...TS AND DEFENDANTS' COUNSEL IN THE AMOUNT OF S: 225 OO Notice. Okay Opposition MP: Plaintiff RP: Defendant Summary On 2/24/21, Plaintiff EILEEN TAHNLAZIAN filed a Complaint On 5/24/21 Plaintiff filed a First Amended Complaint: alleging that defendants caused adverse employment actions and urongful employment termination, based on Plaintiff s age, race, disability, color, and/or national origin The causes of action are: (1) DISCRIMINATION (AGE: RAC...

Excerpt: ...rate wage statements. MP Positions Moving party requests an order compelling Plaintiff s Complaint into arbitration, staying this action, and dismissing the representative claims: on grounds including the following: Individual PAGA claims can be compelled to arbitration and once compelled, PAGA claims brought on behalf of other individuals must be dismissed. Viking River Cmises, Inc. v. Moriana (2022) 142 S_Ct_ 1906. Plaintiff, a former employee ...

Excerpt: ...staining the demurrer to the Complaint, on grounds including the following Without a copy of any evidence of the property transfer to Plaintiff the Complaint fails on the grounds it is ambiguous whether Plaintiff actually has standing to sue. Plaintiff attached a lease agreement to the Complaint which names another Lessor than Plaintiff Though Plaintiff asserts they are the successor in interest to the at-issue lease agreement, Plaintiffhas faile...