Excerpt: ...s Defendant Antelope Valley Hospital Foundation (“AVHF”), through Defendant Michael A. Gertz, M.D. (“Dr. Gertz”) misrepresented that the doctor performing the medical procedure was “World Class”, that AVHF was ranked as one of the top hospitals in California, and that Plaintiff would not find better care at some other hospital than he would receive at AVHF. On September 21, 2020, Plaintiff filed a complaint against Defendants AVHF, Dr...

Excerpt: ...ant Antelope Valley Hospital Foundation (“AVHF”), through Defendant Michael A. Gertz, M.D. (“Dr. Gertz”) misrepresented that the doctor performing the medical procedure was “World Class”, that AVHF was ranked as one of the top hospitals in California, and that Plaintiff would not find better care at some other hospital than he would receive at AVHF. On September 21, 2020, Plaintiff filed a complaint against Defendants AVHF, Dr. Eddin,...

Excerpt: ...790 E Avenue K, Lancaster, California 93535 (the “Premises”). Plaintiff alleges that Defendants did not obtain a permit for the work, that Defendants knew or should have known that Plaintiff did not hold a license to perform roofing work, and that Mr. Sabalboro failed to properly set-up, lock and/or secure the ladder that Plaintiff used. Plaintiff contends that at Mr. Sabalboro's request, proceeded to the back patio to install boards undernea...

Excerpt: ... travelling westbound on Avenue F when she entered the intersection without stopping at her stop sign due to a dangerous condition on the roadway, causing the Subject Vehicle to broadside Houghton's vehicle. (Complaint, at ¶ 1.) The Subject Vehicle overturned and collided with a wooden electrical pole, causing the pole to collapse, on the northwest corner, before coming to rest on the adjacent dirt field. On May 19, 2020, Plaintiff filed her Com...

Excerpt: ... performed the surgery. Plaintiff alleges that Dr. Misra performed surgery on the areas of his cervical spine where a prior surgery had already been done and that the surgery led to rehospitalization for sepsis, abscess of the neck, and a MRSA infection. Plaintiff further alleges that it was discovered after rehospitalization that Dr, Misra utilized surgical hardware, cervical cages, in a manner that was not recommended by the manufacturer or con...

Excerpt: ...sociated medical bills and mental anguish, shock, and trauma. On July 06, 2021, Plaintiff filed her Complaint alleging Negligence, Failure to Warn, Strict Liability, Breach of Express Warranty, and Breach of Implied Warranty against all defendants. On June 03, 2021, Defendant Walmart, Inc. (“Walmart”) filed its Answer. On June 07, 2021, Plaintiff filed her First Amended Complaint (“FAC”). The FAC alleges the same five causes of action aga...

Excerpt: ...te was passenger. Plaintiffs contend that the accident caused severe injuries and damages to themselves and their property. On March 24, 2020, Plaintiffs filed their Complaint. On April 02, 2021, Defendant filed his Answer. On July 09, 2021, Del Angel brought this instant Motion to Quash. On August 25, 2021, Defendant filed his Opposition. Analysis Standard for Motion to Quash – Cal. Code Civ. Proc. §1987.1(a) provides, as follows: “If a sub...

Excerpt: ...ociated medical bills and mental anguish, shock, and trauma. On July 06, 2021, Plaintiff filed her Complaint alleging Negligence, Failure to Warn, Strict Liability, Breach of Express Warranty, and Breach of Implied Warranty against all defendants. On June 03, 2021, Defendant Walmart, Inc. (“Walmart”) filed its Answer. On June 07, 2021, Plaintiff filed her First Amended Complaint (“FAC”). The FAC alleges the same five causes of action agai...

Excerpt: ...ndant's property, and that the salt water discharge damaged Plaintiff's vegetation and topsoil. On March 12, 2019, Plaintiff filed his Complaint alleging two causes of action Trespass and Private Nuisance. On August 05, 2019, Plaintiff amended his Complaint (First Amended Complaint, “FAC”), adding new facts, but not new causes of actions. On August 12, 2021, Plaintiff filed this instant Motion for Leave to File a Second Amended Complaint. On ...

Excerpt: ... (“Palmdale Regional”); High Desert Medical Corporation, erroneously sued as High Desert Medical Group (“High Desert”); Quartz Hill Walk-In Medical Group, Inc. (“Quartz Hill”); and individuals Joel Herriott Thayer, M.D. (“Dr. Thayer”); Eric Carney Denley, M.D. (“Dr. Denley”); and Carlos A. Guerrero, FNP (“Mr. Guerrero” and collectively, “Defendants”) negligently and recklessly failed to diagnose Decedent's lung cancer....

Excerpt: ...f was inebriated during a Saturday class. Plaintiff claims that Faaborg introduced her to marijuana, sent sexually explicit text messages and emails, and continued the sexual assault until the close of the school year in 2019 both on and off school campus. Plaintiff further alleges that Antelope Valley Union High School District (AVUHSD) through its employees, including Vice-Principal Michael Ybarra (“Ybarra,” or with AVUHSD, “Defendants”...

Excerpt: ...alph Steven Leon (“Leon”) was driving his vehicle in a negligent manner, striking Plaintiffs' vehicle; 2. Defendant/Cross-Defendant/Cross-Complainant Hong Zhou (“Zhou”) was driving a vehicle owned by Qian Bai (“Bai”), erroneously sued as Quian Bai, while in a negligent manner, causing it to be hit by Plaintiffs' vehicle; 3. Defendant/Cross-Defendant/Cross-Complainant Jose Enrique Rodriquez Franco (“Franco”) was driving his vehicle...

Excerpt: ...s Fund Society D/B/A Christina Trust as Trustee for PNPMS Trust Iam Ventures (“Wilmington Savings”). Plaintiff claims no notice was given to him. On November 05, 2019, Cam Ventures Holdings LLC (Cam Venture), claiming to be an administrator for Wilmington Savings, allegedly created a second Deed of Trust (“ADOT-2”). On July 8, 2019, ZBS Law, LLP FKA Zieve, Brodnax, & Steele (“ZBS Law”) allegedly created a Notice of Default (“NOD”)...

Excerpt: ...dant Super Center Concepts, Inc. dba Superior Grocers (“Defendant”) filed their answer. On March 11, 2019 and July 05, 2019, both parties stipulated to continue trial. On November 05, 2019, Plaintiff filed an Ex-Parte Application for Continuance of Trial, granted November 07, 2019. On June 15, 2021, Defendant an Ex-Parte Application for Continuance of Trial, granted June 16, 2021. On August 23, 2021, Defendant filed a new Ex-Parte Application...

Excerpt: ...ista Corp. (“EDVCORP”). Plaintiff alleges the claims of EDVCORP are:  Defendant Timothy James Kiger (“Defendant”) asserted to prospective buyer Sanchez and to EDVCORP agent Alvarez that he was the true owner of the Parcel and 80 acres surrounding it. Defendant's assertions cost EDVCORP the sale of the Parcel.  Defendant asserted to prospective buyer Buenrostro that she and her mother were trespassing on his property and threatening ...

Excerpt: ... physical injuries, medical bills, loss of earnings/earnings capacity, pain and suffering, and more. On March 26, 2020, Plaintiffs filed their Complaint alleging three causes of action: (1) Negligence, (2) Negligence Per Se, and (3) Statutory Liability. On May 04, 2020, Defendants filed their Answer. On September 29, 2020, Defendants filed their Cross-Complaint alleging that Cross-Defendant Jonathan Jungjae Kim was responsible, in whole or in par...

Excerpt: ...in her left hip joint and underwent revision surgery on January 08, 2019. Plaintiff alleges that, during this second surgery, Dr. Minkowitz discovered that Defendant Smith & Nephew, Inc.'s R3 Acetabular System failed, shifted out of place, and that the femoral head showed wear. Plaintiff further alleges that on or about May 7, 2020, Dr. Minkowitz informed Plaintiff that he had received notice from Smith & Nephew Inc. that the hardware installed i...

Excerpt: ... could not own real property in California without being deported as he is an illegal immigrant. So, Defendants agreed that Plaintiff would use the money that he had won from the California Lottery to purchase the Property under one of their names and transfer the Property to Plaintiff after a short duration. In consideration for Defendants' assistance with this matter, Plaintiff would purchase small undisclosed gifts for Defendants, and allow De...

Excerpt: ...intained their premises to allow the slippery floor, a dangerous condition, to exist. Plaintiff filed her Complaint on July 27, 2020 with two causes of action, General Negligence and Premises Liability. On October 16, 2020, Defendant filed its answer. On May 28, 2021, Defendant filed this instant motion for summary judgement, or in the alternative summary adjudication. On August 02, 2021, Plaintiff filed their Opposition. On August 13, 2021, Defe...

Excerpt: ...ntiff alleges Defendant Antelope Valley Hospital Foundation (“AVH”), through Defendant Michael A. Gertz, M.D. (“Dr. Gertz”) misrepresented that the doctor performing the medical procedure was “World Class”, that AVH was ranked as one of the top hospitals in California, and that Plaintiff would not find better care at some other hospital than he would receive at AVH. On September 21, 2020, Plaintiff filed a complaint against Defendants...

Excerpt: ...ishment by keeping it clean and safe for invitees, cause liquid to be left on the floor of the premises without any proper “Caution Wet Floor” signs which created a dangerous condition and foreseeable risk of harm. Plaintiff contends that this dangerous condition and foreseeable risk of harm was the actual and proximate cause of Plaintiff's injuries and damages. On September August 07, 2019, Plaintiff filed her Complaint, alleging General Neg...

Excerpt: ...at the aforementioned dangerous condition existed due to Defendants' negligence in maintaining, managing, controlling, or operating of the location of incident and that the dangerous condition is the proximate cause of her injuries. On March 19, 2021, Plaintiff filed her Complaint alleging Negligence and Dangerous Condition of Public Property pursuant to Gov. Code §835 et seq. On June 25, 2021, Plaintiff filed a Substitution of Attorney releasin...

Excerpt: ...from owners Defendants Juana Carranza (“Carranza”) and Guillermo Farias (“Farias” and collectively, “Defendants”). (FAC, Exh. 1.) By the terms of the agreement, Plaintiffs allegedly agreed to pay a deposit of $10,000, and make monthly payments of $2,200 until the sixth month, wherein rent would increase to $2,800 until January 01, 2019. (FAC, Exh. 1.) The agreement includes two options, set to expire on January 01, 2019. (Id.) For the...

Excerpt: ...ng and sales business out of his property which is a residential property. Plaintiff alleges that, due to the business, there is loud noise from log splitters, big trucks that drop off “very loud and large boulders of wood,” extra traffic due to buyers, and a street sign pointing to Defendant's Property. (Motion for Injunctive Relief, Page 3 ¶2 and Complaint, Page 2 ¶8.) On April 26, 2021, Plaintiff filed her Complaint alleging two causes o...

Excerpt: ... payments to Shorter. On or about October 22, 2018, Shorter allegedly took out a second mortgage on the Property, for approximately $200,000. Plaintiff claims that shorter “unilaterally” obtained this loan without Plaintiff's consent and that Plaintiff had paid $125,000 toward the initial mortgage over the previous nine (9) years prior to the Shorter taking out the second mortgage and “pocketing” $75,000. Plaintiff states that Shorter is ...