Excerpt: ...7/21, Plaintiff filed a Complaint alleging that Defendants, as attorneys, represented Plaintiff in a number of cases, spanning a significant period of time, but as to one case, Defendants negligently advised her, resulting in the striking of her answer and entry of default and default judgment. The causes of action are: 1. PROFESSIONAL NEGLIGENCE 2. BREACH OF FIDUCIARY DUTY 3. BREACH OF CONTRACT 4. BREACH GOOD FAITH AND FAIR DEALING. On 7/26/21, ...

Excerpt: ...vera, which has habitability violations, including cockroach infestation, spider infestation, mold contamination, dysfunctional plumbing systems, disrupted utility access to plumbing and electrical, dysfunctional electrical system, improper weatherproofing, improper ventilation, structural deficiencies, and improper construction practices posing health and safety hazards. The causes of action are: 1. VIOLATION OF CALIFORNIA CIVIL CODE § 1942.4 2...

Excerpt: ...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 unlikely to receive any ...

Excerpt: ...ined a mortgage loan encumbering their owned residential property at 8744 Burnet Ave No. 2, North Hills, CA, and on or about April 10, 2018, a Notice of Default (NOD) was recorded by NATIONSTAR MORTGAGE, LLC, but Plaintiffs never were contacted about foreclosure alternatives as required under Civil Code Section §2923.5, and ultimately NATIONSTAR wrongfully foreclosed. MP Positions Moving party requests an order granting summary judgment against ...

Excerpt: ...g as a subsidiary of the City of Los Angeles, failed to establish a special needs trust of structured annuity payments due monthly to Vista Points Inc., thereby creating financial difficulties for Plaintiff and his son. The causes of action are: 1. 42 USC § 1983 – EQUAL PROTECTION OF THE LAW, DUE PROCESS. 2. 42 USC § 1983 - BREACH OF CONTRACT. On 12/14/21, the Court sustained, without leave to amend, a similar demurrer of co-Defendant PACIFIC...

Excerpt: ...7. Presumably due to the COVID pandemic, Plaintiff's start date at the LAFD academy was delayed. In or about January 2021, Plaintiff was informed that he was eligible to begin the LAFD academy class scheduled to begin in July 2021. In or about April 2021, LAFD confirmed that Plaintiff was accepted to the July 2021 Fire Academy class and informed him that he must appear in May 2021 to be fitted for personal protective gear and to conduct Live Scan...

Excerpt: ... Defendant GENERAL MOTORS regarding a 2018 Chevrolet Malibu, which had nonconformities remaining unrepaired after a reasonable number of attempts. MP Positions Moving parties request an order compelling deposition attendance of GENERAL MOTORS PMQ, and awarding $1,765.00 sanctions, on grounds including the following: · Plaintiffs' served a notice of deposition that lists reasonably particularized matters related to the request for repurchase of t...

Excerpt: ...aintiff filed a Complaint. On 11/24/20, Plaintiff filed a First Amended Complaint alleging: Defendants unlawfully discriminated in 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 updat...

Excerpt: ...er granting relief from default, on grounds including the following: · Defendant Kumar did not understand what was being served on her given her limited understanding of English. · She mistakenly believed her son was handling the matter, as it related to the LLC. As is Indian tradition, Mr. Kumar, Defendant's oldest son, handles all matters for Defendant. · She is elderly, age 67. · She is sued as a lease guarantor, not involved in business o...

Excerpt: ...defensible asbestos case-- Norris Morgan v. J-M Manufacturing 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 the action to recover damages allegedly resulting from Plaintiff's asbestos exposure, including Defendant's appalling lack of pre-trial preparation, leading to ...

Excerpt: ... judgment was filed 12/14/22 for $39,686.36. MP Positions Moving party requests an order vacating default judgment, on bases including the following: · Plaintiff improperly requested more than the amount set forth in the complaint, making the Judgment void. Rodriguez v. Cho (2015) 236 CA4th 742, 752-753. · Plaintiff cited distinguishable opinions. · Plaintiff's evidence is unsigned and incompetent. · Alternatively, the Court should modify the...

Excerpt: ...gainst the trucking defendants. On 1/13/21, this lead 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, prov...

Excerpt: ...d on workers compensation policy number 9241524-18. Plaintiff also alleges it was assigned the debt. The causes of action are: 1. BREACH OF CONTRACT 2. OPEN BOOK ACCOUNT 3. ACCOUNT STATED 4. REASONABLE VALUE. On 6/21/22, default judgment was entered against Defendant for damages of $186,144.97, attorney fees of $1,200.00, interest of $38,299.97, and costs of $650.13, for a total of $226,295.07. On 10/25/22, Defendant filed this motion to set asid...

Excerpt: ...ears, 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 assignment of a deed of t...

Excerpt: ...tiff leased 4646 Los Feliz Boulevard, apartment 312, Los Angeles, owned by Defendant LOS FELIZ BLISS LLC, and initially managed by Defendant SUREN SINGH doing business as MONDIAL PROPERTIES, including Addendum #3 providing for $8,220.00 rent paid through January 31, 2021. In or about May 2020, the owner, and successor manager APARTMENT MANAGEMENT CONSULTANTS LLC (AMC) changed the locks on the apartment, to prevent Plaintiff's reentry, and also di...

Excerpt: ...ion are: 1. FORCIBLE ENTRY 2. FORCIBLE DETAINER. MP Positions Moving party requests the Court to order Plaintiff to submit to an independent mental examination, for reasons as follows: · Plaintiff claims emotional distress damages. · Plaintiff concedes that she needs to sit for an IME. · Plaintiff unreasonably is conditioning her IME on unrelated matters pertaining to a different action. · Without the results of this examination, defendant ca...

Excerpt: ... On 4/26/22, Plaintiff filed a First Amended Complaint, alleging that it is the owner of 4907-4907 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 P...

Excerpt: ...inue to interfere with Plaintiff's recorded easement for the sole use of a brick patio situated on Defendants' property, and built several structures on Plaintiff's Property. The causes of action are: 1. TRESPASS 2. PRIVATE NUISANCE 3. NEGLIGENCE 4. INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS 5. QUIET TITLE (EASEMENT) 6. PUBLIC NUISANCE 7. TRESPASS 8. PRIVATE NUISANCE 9. TRESPASS 10. PRIVATE NUSINANCE. On 2/19/19, defendants filed a First Amende...

Excerpt: ...GMC Sierra, in poor mechanical condition, and not really adequately inspected as part of its certification process, as advertised on its website. The causes of action are: 1. VIOLATION OF THE CONSUMERS LEGAL REMEDIES ACT, CIVIL CODE § 1750, ET SEQ; 2. FRAUDULENT MISREPRESENTATION; 3. NEGLIGENT MISREPRESENTATION; 4, VIOLATION OF THE SONG-BEVERLY CONSUMER WARRANTY ACT, CIVIL CODE § 1790, ET SEQ; 5. VIOLATION OF BUSINESS AND PROFESSIONS CODE § 17...

Excerpt: ...a Complaint. On 5/19/22, Plaintiff filed a First Amended Complaint, alleging that plaintiffs contracted with Defendant UTOPIA DEVELOPMENT, INC. to remove a residential structure, at 549 Westminster Ave., Los Angeles, and to replace it with a new structure, but water staining, mold, delamination, plaster separation, and other damages resulted from defendants' contractor negligence and construction defects, including an improperly waterproofed home...

Excerpt: ...d costs, on bases including the following: · Plaintiff moves for an order awarding attorneys' fees under the “lodestar” method, in the amount of $54,338.00. · Plaintiffs also request a modest “lodestar” enhancement of 0.5, in the amount of $27,169.00, for a total of $81,507.00 as the attorneys' fees actually and reasonably incurred. · Plaintiff also moves for reimbursement of verifiable costs and expenses in the amount of $18,228.23. �...

Excerpt: ... Second Amended Complaint, alleging: Defendant SARGEANT MARK BAILEY subjected Plaintiff to a hostile working environment and discrimination. Other defendants, having a gang-like mentality of conspiring against those outside the inner group, did not respond to Plaintiff's complaints. Plaintiff complained of discrimination based on disability, sexual orientation, race, and retaliation for filing a worker's compensation claim. Also, the employer fai...

Excerpt: ...atory relief regarding insurance benefits, after petitioners allegedly sustained property damage and personal injury in a multi-vehicle accident in August 2019, involving a car owned or driven by the Lunas respondents, added as DOE amendments on 8/16/21, after the petitioners' depositions were taken. MP Positions Moving parties request an order sustaining the demurrer to the First Amended Complaint, on grounds including the following: · The Firs...

Excerpt: ...ERMINATION IN VIOLATION OF PUBLIC POLICY; 2. PREGNANCY DISCRIMINATION IN VIOLATION OF CAL. GOV. CODE § 12940 et seq.; 3. RETALIATION IN VIOLATION OF CAL. GOV. CODE § 129040 et seq.; 4. FAILURE TO PREVENT PREGNANCY DISCRIMINATION IN VIOLATION OF CAL. GOV. CODE § 129040 et seq.; 5. HOSTILE WORK ENVIRONMENT; 6. INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS; 7. SEX DISCRIMINATION IN VIOLATION OF CAL. GOV. CODE § 129040 et seq.; and 8. DECLARATORY ...

Excerpt: ... in February 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 g...