Excerpt: ...s in the Hollywood Hills, and Defendants continue 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...

Excerpt: ... for New Force International Education, and Plaintiff paid a total of $39,950.00. Defendant Weng deliberately used different business entities in the Service Contract, and on her business card, to confuse Plaintiff, and to create the false impression that she was a successful businesswoman with great resources and capabilities. The causes of action are: 1. INTENTIONAL MISREPRESENTATION 2. NEGLIGENT MISREPRESENTATION 3. RESCISSION OF CONTRACT 4. B...

Excerpt: ...iled the lead action, Lorenzo v. Los Morales (19STCV23612) against the trucking defendants. On 3/30/20, plaintiffs filed the Complaint, Lorenzo v. LAUSD (20STCV12415), against LAUSD and others. On 1/13/21, this lead case was ordered consolidated for all purposes with 20STCV23961 and 20STCV12415. On 2/3/21, plaintiffs filed the Second Amended Complaint, regarding separately filed wrongful death lawsuits that arise out of the same double fatal pede...

Excerpt: ... this action, including constructive employment termination, and.alleging that Plaintiff worked as a maintenance worker, and employer Defendant City of Lawndale intentionally assigned Plaintiff to do work that violated his medical restrictions, and refused to offer available, reasonable work accommodations, based upon discrimination and retaliations. The causes of action of the Third Amended Complaint are: 1. VIOLATION OF THE FAIR EMPLOYMENT AND ...

Excerpt: ...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, and supervise, management, staff and medical care work...

Excerpt: ... handcuffed and arrested him, and said they were looking for a robbery suspect who was an African American male, but it was not Plaintiff. The counts are: I. UNRUH CIVIL RIGHTS ACT, CIVIL CODE §§ 51 et seq. II. TOM BANE CIVIL RIGHTS ACT, CIVIL CODE § 52.1. III. BATTERY. IV. NEGLIGENCE. MP Positions Moving party requests an order directing Plaintiff to remove deputy video from you tube and other social media of Plaintiff, and imposing monetary ...

Excerpt: ...r compelling arbitration and staying this action, on grounds including the following: · Plaintiff entered into a Retail Installment Sales Contract containing a broad arbitration provision covering all claims arising out of the purchase or condition of his purchased Altima. · Nissan may enforce the Arbitration Provision pursuant to the doctrine of equitable estoppel. Felisilda v. FCA US LLC (2020) 53 Cal.App.5th 486, 496–99. · Nissan may enfo...

Excerpt: ... engage in a good-faith interactive process or reasonably accommodate Plaintiff's disability and discriminated and retaliated against Plaintiff based on her disability and whistleblowing. MP Positions Moving party requests an order sustaining the demurrer to the Fourth Cause of action for Whistleblower Retaliation of the Second Amended Complaint, and granting the motion to strike, on grounds including the following: · Plaintiff failed to present...

Excerpt: ...red engine and brake defects, which vehicle was manufactured by Defendant General Motors, LLC. MP Positions Moving parties request an order compelling Defendant's further document responses, and imposing monetary sanctions ($2,685.00), on grounds including the following: · Aside from asserting inappropriate objections, Defendant has failed to provide any substantive response to many of Plaintiffs' requests. · Requests for Production Numbers 19 ...

Excerpt: ...ase was ordered consolidated for all purposes with 20STCV23961 and 20STCV12415. On 2/3/21, plaintiffs filed the Second Amended Complaint, regarding separately filed wrongful death lawsuits that arise out of the same double fatal pedestrian accident. Allegedly, plaintiffs are the parents of two sisters who died in April 2019, after being run over by a dump truck, while they were pedestrians in a crosswalk, on route to middle school, due to the fai...

Excerpt: ...filed a First Amended Petition, requesting declaratory 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 striking damages allegations barred by the two-year St...

Excerpt: ... RP: Plaintiff Defendant Summary On 10/16/20, Plaintiff MIKISHA CURRY filed a representative PAGA Complaint alleging that Defendant as employer at a nursing home committed various wage-and-hour violations. MP Positions Moving party requests an order compelling arbitration, and striking, dismissing or staying the non-individual PAGA claims, on grounds including the following: · Plaintiff had upon hire signed an agreement committing such claims to...

Excerpt: ...intiff to provide medical services to defendants' patients, but defendants conversely contend that Plaintiff is entitled to the professional fee liens for just 11 of approximately 270 procedures, and that defendants have not had any duty to exclusively use Plaintiff for some of the listed exclusive procedures. Additionally, defendants used Plaintiff's likeness on marketing material without Plaintiff's consent. MP Positions Moving party requests a...

Excerpt: ...er sustaining the demurrer to the Complaint, on grounds including the following: · Plaintiff is seeking damages for unpaid rent for during, before and after the pandemic moratorium period. · County of Los Angeles' COVID-19 Resolution 1.25.2022 (1) bars commencement and litigation of a commercial unlawful detainer action until January 31, 2023, and (2) bars all actions on commercial lease guarantees until the same time. Also, the Resolution bars...

Excerpt: ...al 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 § 17200, ET SEQ. 6. VIOLATION OF...

Excerpt: ...equest an order awarding attorneys' fees and costs, in the sum of $43,725.01, on grounds including the following: · GM merely contends that "Plaintiffs' counsels' fees are unreasonable and exaggerated" with the only evidence in support being the personal opinion of its counsel, which is not the standard upon which this Court must use in determining whether Plaintiffs are entitled to their fees and costs. Attorney fee awards should be "fully comp...

Excerpt: ...ent 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 HARASS...

Excerpt: ...er Plaintiffs' purchase of the majority shares of Defendant California Medical Imaging, Inc. (CMI), Defendants foreclosed Plaintiff from all control and access to Defendant CMI's and associated Defendant Sanaths' operations, along with all other aspects of the business, and Defendants refuse to acknowledge Plaintiffs' majority shareholder status, and ousted Plaintiffs. The causes of action are: 1) BREACH OF CONTRACT - WRITTEN 2) BREACH OF CONTRAC...

Excerpt: ...04. Allegedly, Plaintiff, and represented, aggrieved employees, experienced defendants' violations in Los Angeles, including failure to properly pay wages for all overtime and regular hours work, failure to properly calculate overtime compensation, unlawful meal and rest period policies, failure to pay all wages due to discharged or quitting employees, failure to maintain required records, failure to provide accurate itemized wage statements, fai...

Excerpt: ...l services to defendants' patients, but defendants conversely contend that Plaintiff is entitled to the professional fee liens for just 11 of approximately 270 procedures, and that defendants have not had any duty to exclusively use Plaintiff for some of the listed exclusive procedures. Additionally, defendants used Plaintiff's likeness on marketing material without Plaintiff's consent. MP Positions Moving party requests an order summarily adjudi...

Excerpt: ...14.16 total 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 enti...

Excerpt: ...ANCARLO INCALZA filed a Complaint. On 3/22/21, Plaintiff filed a First Amended Complaint, alleging that defendants wrongfully terminated his employment, based on age discrimination, and fraudulently induced Plaintiff to 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 th...

Excerpt: ... The causes of action are: (1) DISCRIMINATION IN VIOLATION OF THE FEHA; (2) HOSTILE WORK ENVIRONMENT HARASSMENT IN VIOLATION OF THE FEHA; (3) RETALIATION IN VIOLATION OF THE FEHA; (4) FAILURE TO PREVENT DISCRIMINATION, HARASSMENT, OR RETALIATION IN VIOLATION OF FEHA; (5) BREACH OF EXPRESS ORAL CONTRACT NOT TO TERMINATE EMPLOYMENT WITHOUT GOODCAUSE; (6) BREACH OF IMPLIED-IN-FACT CONTRACT NOT TO TERMINATE EMPLOYMENT WITHOUT GOOD CAUSE. MP Positions...

Excerpt: ...cking noise in his chest, which thereafter was discovered to be an improperly closed chest plate by doctors at KECK MEDICAL CENTER OF USC. MP Positions Moving party requests an order sustaining the demurrer to the Complaint, on grounds including the following: · The applicable one-year Statute of Limitations expired. · Plaintiff's Complaint states that plaintiff underwent a three-vessel coronary artery bypass graft surgery performed by DR. MAUE...

Excerpt: ...IOLATION OF THE FEHA; (2) HOSTILE WORK ENVIRONMENT HARASSMENT IN VIOLATION OF THE FEHA; (3) RETALIATION IN VIOLATION OF THE FEHA; (4) FAILURE TO PREVENT DISCRIMINATION, HARASSMENT, OR RETALIATION IN VIOLATION OF FEHA; (5) BREACH OF EXPRESS ORAL CONTRACT NOT TO TERMINATE EMPLOYMENT WITHOUT GOODCAUSE; (6) BREACH OF IMPLIED-IN-FACT CONTRACT NOT TO TERMINATE EMPLOYMENT WITHOUT GOOD CAUSE. MP Positions Moving party requests an order compelling arbitra...