Excerpt: ...leges that Foothill Plaza and Igdaloff owed a duv ofreasonable care towards her and others and that duty was breached as the Premises contained a large exposed height differential that was not properly filled in and/or covered, and lacked signage and warnings and/or had improperly placed signage and warnings, resulting in Plaintiffs injuries. On November 17, 2021, Plaintiff filed her Complaint alleging three causes of action for: (1) Negligence a...

Excerpt: ...n 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 Complaint alleging three (3) ...

Excerpt: ...owned by Iulia and Raymond Joseph Wallace ("Raymond" and collectively "Defendants"). On March 23, 2021, Plaintiffs filed a complaint against Defendants alleging tvvo causes of action for Motor Vehicle and Negligence, and seeking exemplary damages against Julia. On May 4, 2021, Petitioner John Paclib Reyes ("Petitioner) filed a petition to approve the compromise of pending action on behalf of minor claimant Kayleen Reyes ("Minor Claimant'). Analys...

Excerpt: ...es; • Plaintiff was one ofthe people invited to the Premises; • At approximately 5:00 pm, Defendant negligently and without due care created a situation at the Premises that caused people to uncontrollably rush to leave the premises, creating a defective, unsafe, and hazardous condition (i.e., a trap); and • Plamtiff was walking up to the Premises when the aforementioned incident occurred, causing her to be trampled by the people that were ...

Excerpt: ...rain warranty. Plaintiffs further allege that Defendant agreed to preserve or maintam the utility or performance of Plaintiffs' vehicle or to provide compensation If there was a failure in such utility or performance. Plaintiffs present that the Subject Vehicle was delivered to them with serious defects and developed other serious defects and nonconformities to warranty including, but not limited to, transmission, electrical, structural, and susp...

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: ...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: ... 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: ..."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: ..., 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: ... 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: ...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: ... 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...