Excerpt: ... Aid Funds, and (4) Discrimination. On February 17, 2023, defense counsel, Louis R. Dumont ("Dumont"), filed a declaration pursuant to Cal. Code Civ. Proc. S in which he stated that an attempt was made to reach Plaintiff, but was unsuccessful. Defendant provided a meet and confer letter to Plaintiff via mail and email on February 14, 2023. (See Exh.A.) Cal. Code Civ. Proc. S provides an automatic 30-day extension of time in which to file a respon...

Excerpt: ...ding Cruz. Plaintiffs present that Cruz was the second twin delivered by cesarean section by Defendant Dina Margherita Echevarria, M.D. (“Dr. Echevarria” and collectively “Defendants”). Plaintiff contends that Defendants each owed Plaintiffs a duty of care to perform the care and treatment of Plaintiffs in conformance with the then existing standards of care applicable to each Defendant and that Defendants were negligent and breached thei...

Excerpt: ...imited to the bumper-bumper warranty, powertrain warranty, and emission warranty. Plaintiff presents that the Subject Vehicle contained defects and nonconformities which manifested themselves within the applicable express warranty period including but not limited to, transmission defects, engine defects, and electrical system defects; that FMC failed to conform the Subject Vehicle to the terms of the express warranty after a reasonable number of ...

Excerpt: ...at the time of Vincent's admission and following, Defendant provided inadequate staffing levels; (2) in the process of discharge, Vincent was discharged against hospital protocol, policies, procedures, and the standard of care, and was left standing unaided and unassisted outside of Defendant's hospital building; (3) while alone outside, Vincent fell; and (4) Debbie arrived to Defendant's hospital building and found Vincent injured, incapacitated...

Excerpt: ... waste. However, after the purchase, Plaintiff presents that she would visit every weekend and, each time she visited, there was more yard waste. Plaintiff contends that she stopped visiting the property for a few months and, when she resumed her weekend visits in June 2021, an enormous amount of waste had been piled on her property. Plaintiff states she attempted to ask the city for help, but was told that she needed the names of the individuals...

Excerpt: ...juries and property damage. On December 22, 2021, Plaintiff filed her Complaint alleging Ävo causes of action for General Negligence and Motor Vehicle. On April 26, 2022, Yang filed her Answer. On August 30, 2022, Plaintiff filed an amendment to the Complaint, correcting the fictitious name of Doe 1 to Xueqiang Liu ("Liu"). On October 17, 2022, Yang was dismissed. On February 17, 2023, Liu filed this instant Motion to Quash Doe Amendment ("Motio...

Excerpt: ... one cause of action for Premises Liability.i On January 05, 2022, Defendant filed its Answer. On January 12, 2023, Plaintiff filed a notice for a Motion for Protective Order. On Februaty 01, 2023, the Court signed the corresponding Order for the Stipulation to Continue Trial, FSC [and Related Motion/Discovety Dates] signed by the parties. On February 23, 2023, Plaintiff filed this Motion for Protective Order. On March 15, 2023, Defendant filed i...

Excerpt: ...Plaintiffs stay at Defendants' hotel on November 3, 2019. Plamtiff checked in to the hotel on November 2, 2019. On November 3, 2019, Plaintiff states that she awoke at 2 a.m. with an "intense itching sensation." (Compl„ 15.) She alleges that when she pulled back the covers, she discovered bedbugs which she reported to hotel staff. Plaintiff contends that cleaning staff then came to inspect the room at which time she presented a dead bedbug to t...

Excerpt: ..."District'). The District has jurisdiction over air quality affected by the Citys water diversion. The Civ has been drawing water from the Owens River for over 100 years. The Owens Lake Bed is now dried, creating large volumes of dust, in particular, the pollutant PMIO, a particulate matter 10 microns or less in diameter. In 2012, the City initiated legal action against the District by filing a verified petition for writ of mandate, and while the...

Excerpt: ...lowing the incident on March 14, 2018, there were no altercations between Plaintiffs and there were no incidents in which SLD was reported to be in danger, imminent harm from abuse or neglect or in any situation where her physical or emotions; · On March 15, 2018, county social worker Serrano contacted Lopez and was told by Rodriguez that no Restraining Order was necessary, Lopez denied any physical altercation occurred and denied the allegation...

Excerpt: ...ld's life insurance proceeds that Plaintiff was to receive upon his death for Plaintiff so she could be financially secure until her death and (2) Derek was to pay Bill Proster $42,000.00 for the real property located at 11043 Ambrosio, Desert Hot Springs, California 92240 (“Ambrosio Property”), transfer title to Plaintiff, and Plaintiff would receive $1,266.00 monthly payments from Jose and Maria Trejo who the home was financed to with an op...

Excerpt: ... excessive amounts of Tetracaine and Lidocaine and failed to monitor, and (2) Decedent's vital signs were not appropriately monitored during the procedure or the recovery period. Decedent died on or about February 07, 2021.On May 05, 2022, Plaintiffs filed their Complaint alleging two causes of action for: (1) Wrongful Death Based on Medical Malpractice (Cal. Code Civ. Proc. § 377.60), and (2) Medical Malpractice Through a Survival Action (Cal. ...

Excerpt: ..., causing a Plaintiff, not specified, to fall and sustain physical injuries. On January 04, 2018, Plaintiffs filed their Complaint alleging three causes of action: (1) General Negligence, (2) Premises Liability, and (3) Loss of Consortium. On April 05, 2018, Defendant CEC Entertainment, Inc. dba Chuck E Cheese (“CEC”) filed its Answer. On April 27, 2018, CEC filed its Cross-Complaint against several cross-defendants, including Cross- Defendan...

Excerpt: ... as a result, Plaintiffs suffered damage. On April 15, 2021, Plaintiffs filed their Complaint alleging two causes of action for: (1) Motor Vehicle and (2) General Negligence. On January 05, 2023, Plaintiffs filed their FAC, alleging the same causes of action. The FAC differed from the Complaint in one aspect: location. While the Complaint stated the accident occurred in Palmdale, the FAC states that it occurred in Pinon Hills, CA 92372. On Januar...

Excerpt: ...but not limited to, physical disabilities. Plaintiffs allege that Decedent was admitted as an inpatient to a Defendant Premiere Rehabilitation & Wellness Center dba The Ellison John Transitional Center (“Premiere”)'s 24-hour health facility on or about October 16, 2020 due to minor chest pain and abnormal labs. Plaintiffs concede that Decedent had other health issues, such as a minor stroke, kidney disease, diabetes, and that such issues requ...

Excerpt: ...n, making the surface of the floor wet and slippery. Plaintiff further alleges that the school aide and Doe Defendants 52-75 failed to stop the game and another student, labelled as Doe Defendants 76-95, persisted in playing tag and struck and pushed Plaintiff, causing her to fall to the ground. Plaintiff believes that (1) after it started raining and the surface became slippery and dangerous persisted for such a period of time, presented such an...

Excerpt: ...equently, defaulted on each. CBB further alleges that on or about October 04, 2018, Sandhu executed and delivered to CBB a commercial guaranty (“Guaranty”) where he agreed to guarantee all indebtedness of Arabians due to CBB, including but not limited to the amounts owed under the 076 Note, then existing, or thereafter arising on a continuing basis. The Guaranty is alleged to include the debt under the 419 and 541 notes. The alleged outstandi...

Excerpt: ... at the time of Vincent's admission and following, Defendant provided inadequate staffing levels; (2) in the process of discharge, Vincent was discharged against hospital protocol, policies, procedures, and the standard of care, and was left standing unaided and unassisted outside of Defendant's hospital building; (3) while alone outside, Vincent fell; and (4) Debbie arrived to Defendant's hospital building and found Vincent injured, incapacitate...

Excerpt: ...“Gonzalez, Jr.” and collectively “Defendants”) negligently owned, operated, cleaned, maintained, managed, supervised and/or monitored the floor and premise and had actual and/or constructive notice of the dangerous condition. On May 25, 2021, Plaintiff filed her Complaint, alleging two causes of action for General Negligence and Premises Liability. On July 15, 2021, Vallarta filed its Answer. On November 03, 2022, Vallarta filed this Moti...

Excerpt: ... the “District”). The District has jurisdiction over air quality affected by the City's water diversion. The City has been drawing water from the Owens River for over 100 years. The Owens Lake Bed is now dried, creating large volumes of dust, in particular, the pollutant PM 10, a particulate matter 10 microns or less in diameter. In 2012, the City initiated legal action against the District by filing a verified petition for writ of mandate, a...

Excerpt: ...e to Defendants' lack of ordinary care, Plaintiff sustained injuries as well as pain and suffering. On January 06, 2022, Plaintiff filed his Complaint alleging two causes of action for General Negligence and Premises Liability. On May 10, 2022, Plaintiff amended the fictitious name of Doe 1 to MHC Property Management, L.P. and amended the incorrect name of Thousand Trails to MCH TT, L.P. On May 31, 2022, Plaintiff dismissed Equity Lifestyle and M...

Excerpt: ...ndant”). On August 03, 2022, Plaintiffs filed their Complaint alleging four causes of action for: (1) Violation of Song- Beverly Act – Breach of Express Warranty, (2) Violation of Song-Beverly Act – Breach of Implied Warranty; (3) Violation of the Song-Beverly Act § 1793.2(b), and (4) Violation of the Song-Beverly Act § 1973.22 – Tanner Consumer Protection Act. On September 09, 2022, Defendant filed its Answer. On November 03, 2022, Def...

Excerpt: ...de a left turn near the entrance/exit of Brierwood Estates, located at 45800 Challenger Way (“Subject Roadway”), Lancaster California 93535, crashing head-on into Plaintiffs' vehicle. Plaintiffs further allege that Defendants City of Lancaster (“Lancaster”), County of Los Angeles (“COLA”), and the State of California, acting by and through the Department of Transportation, erroneously sued as “State of California, a governmental ent...

Excerpt: ...10, 2022, Defendant filed its Demurrer. On December 19, 2022, Plaintiff filed her Motion for Order to Amend Filing Date pursuant to CRC 8.77 (“Motion for Order to Amend”). On December 19, 2022, Plaintiff filed her Opposition to the Demurrer. On December 20, 2022, a hearing on the Demurrer was held. The Court continued the matter to January 31, 2022 as the Motion for Order to Amend impacts the Demurrer. On December 19, 2022, Plaintiff filed he...

Excerpt: ...rehired by Defendants in or around February 2019. Plaintiff presents that at all relevant times he was performing his job duties in a satisfactory manner. Plaintiff also presents that he lost the use of his right eye due to a retinal detachment in or around May and August 2019 and was then transferred from Defendants' Granada Hills office to the Palmdale office as well as required Plaintiff to move from location to location, including Defendant's...