Excerpt: ...ition Papers: No Oppo Reply: No Reply RELIEF REQUESTED¿ Defendant, Jay Uhm, makes a special appearance to move the court to Set Aside Default entered against Defendant on the ground that Plaintiffs failed to properly serve Summons on Defendant and Defendant had no actual knowledge in regard to Plaintiffs' Request for Default/Default Judgment. Moreover, as noted fully in the concurrently filed Motion to Quash Summons, Uhm claims there was no prop...

Excerpt: ...S 1-30 TENTATIVE RULING DEMURRER & MOTION TO STRIKE Moving Party: Defendants, Robert D. Heinrich, CPA, an individual (Robert); Robert D. Heinrich C.P.A., Inc., a California Corporation (CPA Inc.), and MMAP Services, Inc., a California corporation (MMAP) [All three Defendants collectively referred to as Defendants] Responding Party: Plaintiffs, GC-8; San Clemente Beach Country Club; Shorecliffs Golf Management; Sean Leong; Allison Lee Proof of Ser...

Excerpt: ...ice Timely Filed (CRC Rule 3.1300):Ok 16/21 Court Days Lapsed (CCP 1005(b)): Ok Proper Address: Ok Moving Papers: Motion; Decl. Mari F. Henderson; Proposed Order; Separate Statement; Notice of Lodging Under Seal; Joint Stipulation and Protective Order; Opposition Papers: Opposition; Separate Statement; Jane E. Reilly Declaration [ Only document not filed under seal ] Reply Papers: Reply; Supplemental Separate Statement; Notice of Lodging Under Se...

Excerpt: ...ted Moving Papers: Motion; Donahue Declaration; Chobanian's Notice of Lodging Exhibit F; Separate Statement; Proposed Order; Proof of Service; Proposed Judgment Opposition Papers: Opposition; Separate Statement; Declarations in Support of Opposition Reply Papers: Reply 75/80 Days Under 437c(2), notice of the motion and supporting papers shall be served on all other parties to the action at least 75 days before the time appointed for hearing. If t...

Excerpt: ...oposed Order Trial Date : 05/01/2023 – thus, the Discovery cutoff may moot this motion. CCP 2024.020. Court will hear argument. RELIEF REQUESTED Plaintiffs, Arman Yegiyants and 10415 Commerce LLC move for an order compelling Fares Salman Abassi, a non-party, to produce documents and to appear at his deposition. Plaintiffs move on the grounds that Abassi was served with (A) a subpoena to produce documents on February 7, 2023 (Records Subpoena) a...

Excerpt: ...Papers: Motion; Separate Statement; Proposed Order; Cronin Declaration Opposition Papers: Oprxisition; Pakbaz Declaration Reply Papers: Reply; Cronin Declaration RELIEF REQUESTED Defendant: Ford Motor Company, moves for an order comrrllmg åurther responses to Special Interrogatories: Set One: 2: 3: 4: 9: 11: 13: 14: 16: 17: 18: 23: 33: 34: 35: 36: 38: 48: 49, 51, 52, 54, 57, and 58 within 14 days of the Court's order. Defendant moves pursuant to...

Excerpt: ...ration; Supplemental Robinson Declaration Opposition Papers: No Opposition Reply Papers: No Reply Submitted RELIEF REQUESTED Plaintiffs move the Court for an order compelling Defendant, Anupam Patel, to åurther responses to Special Interrogatories, Set One, Nos. 1-4, 8, 11-15, 17, 18. Plaintiffs move under ccp Plaintiffs request monetary sanctions against Defendant Anupam Patel and counsel, Adli Law Group: P_C_, and in of Plaintiffs in the sum o...

Excerpt: ...ed cccp 10050)): 0k Proper Address: 0k RELIEF REOUESTED Plaintiffmoves for an order to strike Defendant' s objections and compel fi_lrther responses to Plaintiffs Request for Production of Documents, Set One, number 3, 5, g, 16, 17: 18: 22: 24: 29: 30: 31: 32: 33, 34, 35, 36, and 37. Plaintiffbrmgs this motion pursuant to CCP 52031.310 and 2031.320 on the grounds that Defendant failed to provide adequate responses. PROCEDURAL 45 Days Unless notic...

Excerpt: ...on of Hratchia Bardakjian; Separate Statement; Declaration of Clay Wilkinson; Opposition Papers: Opposition; Declaration of Arman Yeglyants; Declaration of Bart Baggett; Declaration of Sylvie Merzian; Separate Statement; Declaration of Henry S. David; Request for Judicial Notice Reply Papers: Reply; Objections to Merman Declaration; Hratchia Request for Judicial Notice; Objections to Yegiyants Declaration; Hratchia's Response to Plaintiffs Separa...

Excerpt: ...d (CCP 1005(b)) 0k Proper Address: 0k Moving Papers: Motion; Proposed Order; Gallagher Declaration; Request for Judicial Notice Opposition Papers: Opposition; Jacobson Declaration Reply Papers: Reply RELIEF REQUESTED Defendant moves the Court for judgment on the pleadings as to Plaintiff s first, second, and third causes of action. BACKGROUND Plaintiff filed a Complaint on 07/26/2022 alleging three causes of action: (1) Violation of Song- Beverly...

Excerpt: ... 16/21 Court Days Lapsed (CCP 10050): 0k Proper Address: 0k Opposition submitted. No reply submitted Moving Papers: Motion; Proposed Order Opposition Papers: Opposition RELIEF REQUESTED Defendant: NILS moves the Court to sustain a demurrer to all causes of action as stated on Plaintiffs First Amended Complaint (FAC)_ The demurrer is based on CCP 5430.40 and 430.10 as follows: 1 _ Plaintiffs First Amended Complaint in its entirety on the grounds t...

Excerpt: ...o the first amended complaints second cause of action for medical battery. BACKGROUND: The operative pleading is the first amended complaint ("FAC") filed on January 5, 2023 by Plaintiffs Marta Santos Tobar, etal. ("Plaintiffs") against Defendants Rodolfo Quintero, et al. ("Defendants"). The FAC alleges three causes of action: (1) medical negligence; (2) medical battery; and (3) loss of consortium. Plamtiff Tobar's second cause of action for batt...

Excerpt: ...ed (CCP Proper Address: 0k Oppo and reply submitted. RELIEF REOUESTED Defendant: Los Angeles County Metropolitan Transportation Authority, filed the instant demurrer pursuant to CCP 5430.10 et seq. on the following grounds Plaintiffs First Cause of Action fails to state facts sufficient to constitute a cause of action against Defendant: is uncenain, and is duplicative of Plaintiff s Second Cause of Action. Plaintiff s second cause of action fails...

Excerpt: ...ts stated they do not think it would be unduly burdensome on the Court to address the matters together. Therefore, this Court will address both motions in a singular ruling.] Moving Party: Defendants, Karim Boumajdi aka Kevin Boumajdi and Tesla Reseller Group, Inc. a Call forma corporation Responding Party: Plaintiff Peter Oliver Opposition and Reply submitted. Moving Papers: Karim Boumajdi's motion; Boumajdi s proposed order; Tesla Reseller Grou...

Excerpt: ...tion; Plaintiffs Request for Judicial Notice; Plaintiffs Separate Statement; Anum Arshad Declaration Opposition Papers: Opposition; Michael R. Carey Declaration; Objection to Separate Statement; Ryan A. McCarthy Declaration Reply Papers: Reply; Arshad Declaration RELIEF REOUESTEDa-c Plaintiff Justine Hsu: moves this Coun for (1) For issue sanctions against Tesla, establishing that prior to the subject incident: July 6, 2019, Tesla was on notice o...

Excerpt: ...wing orders: (1) Compelling Defendant and Cross-Complainant MS Electrical Distribution: Inc. DBA Bees Lighting ("Bees Lighting") to serve verified answers: without objection, to Fonn Interrogatories (Set Number One), within five (5) days of the hearing of this Motion; (2) Compelling Bees Lighting to serve verified answers, uithout objection: to Special Interrogatories (Set Number One), within five (5) days of the hearing of this Motion; (3) Compe...

Excerpt: ...ct Address (CCP SS 1013, 1013(a)): 0k 16/+5-day lapse (CCP 51005): 0k RELIEF REQUESTED: An order to compel Defendant Shiraz Rental to provide amended responses to the Requests for Production, Set 4. An order imposing monetary sanctions against Defendant Shiraz Rental and its counsel of record in the amount of $1,410.00 for Requests for Production. An order to compel Defendant Shiraz Rental to provide amended responses to Special Interrogatories, ...

Excerpt: ...; Proposed Order Opposing Papers: Opposition; Hamblin Declaration Reply Papers: Reply Proof of Service Timely Filed (CRC Rule 3.1300): 0k 16/21 Court Days Lapsed (CCP 10050) 0k Proper Address: 0k ccp S12904 ' 'A copy of the petition and a written notice of the time and place ofthe hearing thereof and any other papers upon which the petition is based shall be served in the manner provided in the arbitration agreement for the service of such petiti...

Excerpt: ...16/21 Court Days Lapsed cccp 1005(b)) 0k Proper Address:Ok CCP S12904 ' 'A copy of the petition and a written notice of the time and place ofthe hearing thereof and any other papers upon which the petition is based shall be served in the manner provided in the arbitration agreement for the service of such petition and notice." (CCP "If the arbitration agreement does not provide the manner in which such service shall be made and the person on whom...

Excerpt: ...e; Declaration of Camran Pakbaz Reply Papers: Reply Proof of Service Timely Filed (CRC Rule 3.1300): 0k 16/21 Court Days Lapsed cccp 1005(b)) 0k Proper Address: 0k CCP S12904 ' 'A copy of the petition and a written notice of the time and place ofthe hearing thereof and any other papers upon which the petition is based shall be served in the manner provided in the arbitration agreement for the service of such petition and notice." (CCP "If the arb...

Excerpt: ...Oppo and Reply Submitted) Moving Papers: Demurrer; Dailey Declaration; Request for Judicial Notice Opposition Papers: Opposition Reply Papers: Reply Proof ofService Timely Filed (CRC Rule 3.1300): 0k 16/21 Court Days Lapsed (CCP 10050): 0k Proper Address: 0k RELIEF REQUESTED Defendants: HSBC Bank USA National Association, as Trustee for the Cenificate Holders of Deutsche Alt-A Securities Mortgage Loan Trust: Series 2007-0A3 and National Default S...

Excerpt: ...Motion/Motion; Separate Statement; Carey Declaration; Proposed Order Opposition Papers: Opposition; Separate Statement; Slavik Declaration; Notice of Errata Reply Papers: Reply; Separate Statement; Tesla's Objections to Slavik Declaration 75/80 Days Under 437c(2), notice of the motion and supporting papers shall be served on all other parties to the action at least 75 days before the time appointed for hearing. If the notice is served by mail, th...

Excerpt: ...er awarding her attorney fees, costs, and expenses, in the total amount of: $162,432.31, including: (1) $94,148.00 in incurred attorney's fees with a 1.5 time multiplier (for a total of $148,722.00); (2) an additional $5,000.00 for Plaintiff counsel's to review Defendant's Opposition, draft the Reply brief, attend the hearing on this Motion, draft an opposition to Defendant's anticipated motion to tax costs, and attend the hearing thereto (though...

Excerpt: ...005(b)): Ok Proper Address: Ok Moving Papers: Notice of Motion/Motion; Proposed Order; Opposition Papers: Opposition; Amarkarian Declaration Reply Papers: Reply; Objection to Amarkarian's Declaration RELIEF REQUESTED Defendant, Ford Motor Company, moves for an order for judgment on the pleadings as to Plaintiff's action. Defendant moves under CCP §438. BACKGROUND Plaintiff filed a complaint on 06/16/2022 alleging three causes of action: (1) Viol...

Excerpt: ...ia Declaration; Proof of Service; Request for Judicial Notice; Proposed Order Opposing Papers: Opposition; Pakbaz Declaration Reply Papers: Reply Proof of Service Timely Filed (CRC Rule 3.1300): Ok 16/21 Court Days Lapsed (CCP 1005(b)): Ok Proper Address: Ok The Reply points out that the Opposition was untimely; however, the Court will still consider the untimely Opposition. CCP §1290.4 “A copy of the petition and a written notice of the time ...

Excerpt: ...): Ok 16/21 Court Days Lapsed (CCP 1005(b)): Ok Proper Address: Ok Moving Papers: Notice of Motion; Motion; Separate Statement; Nina Hirsch Declaration Opposition Papers: Defendant's joint Opposition; Separate Statement; Gary K. Brucker Jr. Declaration Reply Papers: No Reply Submitted RELIEF REQUESTED Plaintiff, Felicitas Debt Fund, LP, moves the Court for an order compelling Defendant, Opus Fund Services (USA) LLC (Opus) to provide further Form ...

Excerpt: ...C., a California corporation; GAIL COOPER, individually and Trustee of the G.S. Cooper Living Trust; and ROES 1-50 TENTATIVE RULING ON MOTION TO STRIKE Moving Party: Defendants, Kathco Inc. dba KSM Construction; Kevin Holczer (Kevin), and Tracy (Tracy) Holczer Responding Party: Plaintiff, Gail Cooper Opposition Submitted, No Reply submitted. Moving Papers: Notice of Motion/Memo; Proposed Order Opposition Papers: Opposition Reply Papers: No Reply ...

Excerpt: ...mbined opposition was submitted to oppose both moving party's motions.] RELIEF REQUESTED¿ Defendant/Cross-Complainant, JCP, moves this Court to enforce the business records subpoena to Citibank, N.A. (Citibank) over the objections of Hakob Galadjian The motion is made pursuant to the provisions of Code of Civil Procedure sections 1985.3, 1987.1 and upon the grounds that Citibank was duly served with a deposition subpoena for business records, bu...

Excerpt: ...Authority (Metro) moves the Court for an order compelling Plaintiff, Orlando Price, to attend a subsequent deposition. Defendant alleges as follows in its notice of motion, “This motion is brought pursuant to Code of Civil Procedure section 2025.610, on the ground that good causes exist for the subsequent deposition. The initial deposition of Plaintiff occurred on September 1, 2021. On October 1, 2021, Plaintiff served Metro's counsel his first...

Excerpt: ...urt Days Lapsed (CCP 1005(b)): Ok Proper Address: Yes/No – The email address on the proof of service for the motion differs from the email address on file with the Court. However, it appears as if Plaintiffs received this motion because Plaintiffs filed an Opposition. Moving Papers: Notice of motion/motion; Declaration of Abigail White; Proposed Order Opposition Papers: Opposition; Declaration of Sarah E. Pfeffer Reply Papers: Reply; Declaratio...

Excerpt: ...Notice of Demurrer/Memo; Declaration of Sasha Bassi Proof of Service Timely Filed (CRC Rule 3.1300): Ok 16/21 Court Days Lapsed (CCP 1005(b)): Ok Proper Address: No – The proof of service of the instant motion alleges service by electronic transmission. The email address on the proof of service that Defendant served Plaintiff at was “e- [email protected]”. However, on eCourt, Plaintiff's counsel's email address is listed as “kjaco...

Excerpt: ...N TO STRIKE Moving Party: Defendants, Loma Vista Investment LLC, a Limited Liability Company, and Albert Ahdoot, an indiv. Responding Party: Plaintiff, CJ Prime Investment, LLC (Oppo and Reply Submitted) Moving Papers: Notice of demurrer/memo; Request for Judicial Notice Opposing Papers: Opposition Reply Papers: Reply Proof of Service Timely Filed (CRC Rule 3.1300): Ok 16/21 Court Days Lapsed (CCP 1005(b)): Ok Proper Address: Ok RELIEF REQUESTED ...

Excerpt: ...Ok 16/21 Court Days Lapsed (CCP 1005(b)): Ok Proper Address: Uncertain The notice of this motion was allegedly served on Plaintiff's counsel and the non-party, Badalyan Group, Inc. As to service of this motion on Plaintiff's counsel it is uncertain if it was served on the proper address for two reasons. As to alleged service by email, the instant motion was served on Arsine Grun at “[email protected]” and a copy to “[email protected]” ; h...

Excerpt: ...ted. Moving Papers: Motion Opposition Papers: Opposition Reply Papers: Reply RELIEF REQUESTED Defendant requests as follows, “Defendant, Robert Yepremian, will, and does hereby, move for an order granting Defendant his reasonable attorney's fees in the sums set forth in the attached Declaration of Raymond Hovsepian or as reasonably fixed by the court, and for an order vacating and setting aside Plaintiff's voluntary dismissal of this action. Th...

Excerpt: ...IM, indiv; DHS CONSTRUCTION GROUP, INC., a California corporation dba REVAMP v. BYUNGJAE KWON, indiv; AHYOUNG KIM, indiv; TK CONSTRUCTION & DESIGN, INC. a California Corporation, and DOES 1-50 TENTATIVE RULING ON DEFENDANTS' DEMURRER & MOTION TO STRIKE Moving Party: Defendants, Yong Cheoll Kim (Kim) and Newgen Homedeco, Inc. (Newgen) (collectively Defendants.) Responding Party: Plaintiffs, Terry Kim and Hyunhee Choi (Plaintiffs) Proof of Service ...

Excerpt: ...ENTATIVE RULING ON MOTION TO COMPEL FURTHER RESPONSES TO REQUESTS FOR PRODUCTION Moving Party: Defendant/Cross-Complainant, Automated Systems America, Inc. (ASAI) Responding Party: No Opposition submitte d Moving Papers: Notice of Motion/Motion; Separate Statement; Proposed Order; Vescera Declaration No Opposition papers submitted. Notice of Non-Opposition submitted by ASAI. Proof of Service Timely Filed (CRC Rule 3.1300): Ok 16/21 Court Days Lap...

Excerpt: ...urt Days Lapsed (CCP 1005(b)): Ok Proper Address: Ok Moving Papers: Motion; Proposed Order; Linhardt Declaration; Separate Statement; Request for Judicial Notice Opposition: Opposition of Non-Party Kevin Kelley Reply: Request to Strike Untimely Opposition; Supplemental Linhardt Declaration The Court considers all moving, opposing, and reply papers. RELIEF REQUESTED Intervenor, Empire Fire and Marine Insurance Company will and herby does move for ...

Excerpt: ...tement; Proposed Order; Sogoyan Declaration Opposition Papers: Memo; Separate Statement Reply: Reply Proof of Service Timely Filed (CRC Rule 3.1300): Ok 16/21 Court Days Lapsed (CCP 1005(b)): Ok Proper Address: Ok RELIEF REQUESTED Plaintiff, Mark W. Ossola, moves for an order to strike Defendant's objections and compel further responses to Plaintiff's Request for Production of Documents (RPD), Set One, numbers 5, 6, 10, 11, 13, 14, 17, and 19-37....

Excerpt: ...x Linhardt Declaration; Request for Judicial Notice; Proposed Order [Notice of Joinder filed 1/20/23 by Defendant, The Estate of Izat Murataliev, to join in the motion of Intervenor.] Opposition Papers: Opposition. Reply Papers: Reply; Supplemental Declaration of Alex Linhardt Preliminary Procedural Matters Proof of Service Timely Filed (CRC Rule 3.1300): Ok 16/21 Court Days Lapsed (CCP 1005(b)): Ok Opposition argues that the instant motion was u...

Excerpt: ... Alehverdian, indiv; Travis Alehverdian, a minor by and through his guardian, Serjik Alehverdian (collectively Plaintiffs) Opposition submitted; Reply submitted late, and the Court will still consider the Reply, Notice of untimely Reply submitted Proof of Service Timely Filed (CRC Rule 3.1300): Ok 16/21 Court Days Lapsed (CCP 1005(b)): Ok Proper Address: Ok RELIEF REQUESTED Defendants move to compel further responses from all Plaintiffs to Form I...

Excerpt: ...s: Motion; Vanessa J. Oliva Declaration; Proposed Order Opposition Papers: Memo; Cameron Major Declaration Reply Papers: Reply RELIEF REQUESTED Plaintiff moves to compel Defendant to designate and produce for deposition, its Person(s) Most Qualified (PMQ) on all categories identified in Plaintiff's Amended Notice of Deposition of the Person Most Qualified for General Motors, LLC and Demand to Produce Documents at Deposition (Deposition Notice) an...

Excerpt: ... No Reply. Proof of Service Timely Filed (CRC Rule 3.1300): Ok 16/21 Court Days Lapsed (CCP 1005(b)): Ok Proper Address: Ok Moving Papers: Motion; Declaration of Katherine J. Vescera; Proposed Order; Declaration of John T. Steely Reply Papers: Notice of Non-Receipt of Opposition RELIEF REQUESTED Defendant/Cross-Complainant, Automated Systems America, Inc. (Defendant or ASAI) moves this Court for an order granting ASAI leave to take subsequent dep...

Excerpt: ...en served. Proper Address: No, no proof of service RELIEF REQUESTED Defendant, Grigor Vardanyan moves for the Court to vacate the default judgment entered in this case. BACKGROUND The 08/26/2022 Minute Order of the hearing herein on Defendant Vardanyan's previous motion to set aside/vacate the default judgement states as follows: “The matter is called for hearing. The Court provides the following tentative ruling: Tentative ruling on Defendant'...

Excerpt: ...s: Notice of Motion; Memo; Request for Judicial Notice; Brucker Jr. Declaration Opposition Papers: Opposition Reply Papers: Reply RELIEF REQUESTED Defendant, Opus, moves for judgment on the pleadings and requests the Court dismiss Plaintiffs' SAC in its entirety. Opus' Motion is made pursuant to California Code of Civil Procedure §§ 438(b)(1), 438(c)(1), and 389 because Plaintiffs failed to join indispensable party Kroll, LLC (F/K/A Duff & Phel...

Excerpt: ...y: Chase Fire Protection, Inc. – No Opposition No Reply submitted Proof of Service Timely Filed (CRC Rule 3.1300): Ok 16/21 Court Days Lapsed (CCP 1005(b)):Ok Proper Address: Ok. The instant motion seeking an order compelling further responses to RPD's to Chase Fire Protection was served by U.S. Mail to Daniel J. Goularte, Chase Fire Protection, Inc., Yeny Carillo-Padeh, and Nadav Padeh. On 9/8/2022, three “Substitution of Attorney” documen...

Excerpt: ...endants”) Responding Party: Cross-Complainant, Stockpile Property Ventures, LLC (Stockpile) Proof of service timely filed (CRC 3.1300(c)): Ok Correct Address (CCP §§ 1013, 1013(a)): Ok Moving Papers: Notice of Motion/Memo; Separate Statement; Declaration of Jeremy T. Katz; Index of Evidence in Support of MSJ; Request for Judicial Notice Opposition Papers: Memorandum in Opposition; Separate Statement of Disputed and Undisputed Material Facts; ...

Excerpt: ...155,955.00. [Such amount consists of a) $60,382.00 in attorney fees for Consumer Law Experts, P.C.) a 1.50 multiplier enhancement (or $90,573.00) on the total attorneys' fees; and c) an additional $5,000.00 for Plaintiff's counsel to review Defendant's Opposition, draft the Reply brief, and attend the hearing on this Motion (though Plaintiff's counsel expects to spend well over ten hours on these).] This Motion is made on the grounds that Plainti...

Excerpt: ...Service Timely Filed (CRC Rule 3.1300): Ok 16/21 Court Days Lapsed (CCP 1005(b)): Ok Proper Address: Ok RELIEF REQUESTED Defendant, Los Angeles County Metropolitan Transportation Authority, a Public Entity, demurs to Plaintiff's First Amended Complaint (FAC) pursuant to CCP §430.10, et seq. on the following grounds: 1. The filing of Plaintiff s FAC was procedurally defective as Plaintiff failed to serve Metro and attach a proof of service at the...

Excerpt: ...arkis Tchakian Proof of Service Timely Filed (CRC Rule 3.1300): Ok 16/21 Court Days Lapsed (CCP 1005(b)): Ok Proper Address: Ok Opposition (untimely ), and Reply Submitted. Reply accurately points out that the Opposition is untimely. The Court will still consider the Opposition. RELIEF REQUESTED Plaintiff moves the Court for an order (1) compelling third-party witness Sarkis Tchakian to appear for deposition pursuant to a subpoena served on Novem...

Excerpt: ...s- Defendant/Plaintiff.] Moving Party: Cross-Defendant/Plaintiff, So Moon Kim Responding Party: No Opposition submitted Proof of service timely filed (CRC 3.1300(c)): Ok Correct Address (CCP §§ 1013, 1013(a)): Ok Moving Papers: Notice of motion; Memo of points and authorities; separate statement; Wilson H. Park Decl.; Clark Anthony Braunstein Decl./Exhibits (380 pages); Clark Anthony Braunstein Decl./Exhibits (3 pages); Elizabeth Wells Decl./Ex...