Excerpt: ...�Mena”), and Avis Budget Car Rental, LLC (“Avis”) (collectively, “Defendants”) for damages arising from a motor vehicle accident. The complaint alleges causes of action for motor vehicle and general negligence. Defendants now move for a protective order related to Plaintiff's deposition notice for the Person Most Knowledgeable (“PMK”) at Avis served on Defendants on August 27, 2021. Plaintiff opposes the motion. As of October 7, 202...

Excerpt: ...nt, Kenneth Douglas Kochakji (“Defendant”) for damages arising from a motor vehicle vs. pedestrian accident on November 23, 2019. Plaintiff, at this time, seeks to quash three deposition subpoenas issued by Defendant to T-Mobile USA, Inc. (“T-Mobile”), Meritain Health (“Meritain”), and the Cheesecake Factory (“Cheesecake”) on August 10, 2021. Defendant opposes the motion, and Plaintiff filed a reply. Plaintiff asserts the subpoena...

Excerpt: ...inistrative Services Cooperative, Inc. (collectively, “Defendants”) for damages arising from a pedestrian vs. motor vehicle accident. Defendants move for terminating sanctions against Plaintiff dismissing Plaintiff's complaint because of Plaintiff's misuse of the discovery process by failing to serve responses to initial discovery and failing to comply with the court's June 9, 2021, Order pertaining to Defendants' motion to compel initial res...

Excerpt: ...endant”), erroneously sued herein as Starbucks Coffee Company, alleging a single cause of action for negligence. The complaint alleges that on November 14, 2019, Plaintiff ordered a hot tea from Defendant's store, which was served to Plaintiff in two paper Starbucks cups stacked on top of one another with tea bags resting in hot water. A lid was then placed on top over the strings attached to the tea bags. When Plaintiff went to take a drink of...

Excerpt: ...llectively, the “Corella Plaintiffs”) filed Case No. 19STCV24638 against Defendant, Southern California Edison Company (“Defendant” or “SCE”) for injuries Corella sustained when an electricity panel box exploded. Plaintiffs, Edward Hano (“Hano”) and Denise Hano (collectively, the “Hano Plaintiffs”) filed Case No. 19STCV25002 against SCE for damages arising out of the same incident. On October 28, 2019, the court deemed the act...

Excerpt: ...d this action against Defendant, Thomas Ton (“Ton”) and Mercury Insurance Company (“Mercury”) (collectively, “Defendants”) for damages arising from a motor vehicle accident. On June 29, 2021, Plaintiff filed a First Amended Complaint (“FAC”) alleging causes of action for (1) personal injuries, (2) insurance fraud, and (3) manslaughter. Defendants now each demur to the FAC in its entirety. The demurrers are largely identical and wi...

Excerpt: ...tentional tort and (2) negligence. On June 8, 2021, Plaintiff filed his Amendment to Complaint naming Kaiser Foundation Hospitals as Doe 1. On July 7, 2021, Plaintiff filed another Amendment to Complaint providing the correct name of Kaiser Permanente is Kaiser Foundation Health Plan, Inc. The complaint alleges Plaintiff accompanied her husband to a colonoscopy of Kaiser's facility on September 1, 2020, and Plaintiff was barred from the building ...

Excerpt: ...Cruz”) and Daniel Guillen filed this action against Defendants, Beverly Hills Physicians, Tsung-Lin Roger Tsai, M.D., and Maher Anous, M.D. for medical malpractice and loss of consortium. Plaintiffs' First Amended Complaint alleges that on August 13, 2018, Cruz consulted and engaged Defendants to be her medical surgeons for cosmetic surgery procedures, but Defendants negligently treated and caused injury to Cruz. On January 26, 2021, Defendant ...

Excerpt: ...than”), a minor, by and through his guardian ad litem, Patricia Nathali, (collectively, “Plaintiffs”) filed this action against Defendants, Con-Way Freight Inc. (“Con-Way”), XPO Logistics Freight (“XPO”), and Jose Nunez Hernandez (“Hernandez”) for damages arising from a collision between a train and tractor trailer. On April 14, 2017, Plaintiffs filed the operative First Amended Complaint (“FAC”) alleging the crash occurred ...

Excerpt: ...nt”) for damages arising out of a trip and fall on the public sidewalk. The complaint alleges that Plaintiff tripped on a raised concrete slab of sidewalk, and that as Plaintiff was attempting to catch herself before she fell, Plaintiff subsequently tripped on a raised manhole cover. The complaint alleges causes of action for (1) negligence under Government Code § 815.2(a) and (2) dangerous condition of public property. At this time, Defendant...

Excerpt: ...ate Farm”) filed this petition to commence and enforce discovery against Respondent, Carlos Sajche (“Sajche”) in connection with an uninsured motorist claim. State Farm provides Sajche email served form interrogatories, special interrogatories, requests for admission, and request for production of documents, sets one, on State Farm on April 19, 2021. Following attempts to meet and confer concerning the waiver of objections, State Farm serve...

Excerpt: ...Wolff”), Lawrence A. Wolff, DDS, Inc., and Hospital Dental Surgery Center for (1) professional negligence, (2) lack of informed consent, and (3) medical battery arising out of surgical procedures performed by defendants on March 24, 2017, and August 11, 2017. Plaintiff alleges that on September 4, 2015, Plaintiff went to A to Z Dental (“A to Z”) for a consultation for getting dentures and was told the cost would be $2,000. Plaintiff was giv...

Excerpt: ...Angeles and Richard Curry (collectively, “Defendants”) for damages arising from a motor vehicle accident. Plaintiff, at this time, moves to quash Defendants' deposition subpoenas served on USAA General Indemnity (“USAA”) and Hertz Claim Management Corporation (“Hertz”) seeking Plaintiff's insurance and employment records, respectively. Defendants oppose the motion. As of September 30, 2021, no reply has been filed. Plaintiff contends ...

Excerpt: ... Delgado (“Delgado”), Jorge Ortiz-Perez (“Perez”), and Allied Trade Group for damages arising from a motor vehicle accident. The operative First Amended Complaint (“FAC”) alleges causes of action for (1) negligence and (2), motor vehicle negligence. Delgado was allegedly operating the vehicle that collided with Plaintiff's vehicle and was working in the course and scope of his employment with Perez at the time of the accident. The com...

Excerpt: ...rshidi (“Defendant”) for damages relating to an alleged physical altercation between Plaintiff and Defendant that occurred at the Santa Monica Courthouse on May 26, 2016. On June 4, 2021, Plaintiff filed the Second Amended Complaint (“SAC”) alleging causes of action for (1) assault and battery, (2) intentional infliction of emotional distress, (3) negligent hiring, training, supervision and retention of employee, (4) negligence, (5) false...

Excerpt: ...alifornia Pizza Kitchen, Inc. for damages relating to Plaintiff's alleged trip and fall over an improperly secured storm drain. The complaint alleges a single cause of action for premises liability. On March 9, 2021, Plaintiff filed an Amendment to Complaint naming Doe 2 as Evergreen Cleaning Systems, Inc. (“Evergreen”). Evergreen, at this time, moves to strike the Doe amendment. Plaintiff opposes the motion, and Defendant filed a reply. Ever...

Excerpt: ...amdar MD Inc., Lawrence DeLasotta MD, and United Medical Imaging Inc. (collectively, “Defendants”) for medical malpractice. Plaintiff alleges Defendants delayed in diagnosing Plaintiff with thyroid cancer, and as a result of that delay, Plaintiff lost her voice. Defendants Bina Kamdar, MD and Bina Kamdar MD Inc. (the “Kamdar Defendants” or “Moving Defendants”) now move for summary judgment. Plaintiff opposes the motion, and Moving Def...

Excerpt: ...ion against Defendants, Kaiser Foundation Hospitals doing business as Kaiser Foundation Hospital – Downey, Kaiser Foundation Health Plan, Inc., Southern California Permanente Medical Group, and Joseph Fisch, M.D. (collectively, “Defendants”) for damages related to the alleged wrongful death of Plaintiffs' child, Quincy Vaughn, arising from the June 10, 2020, birth of Plaintiffs' child. The complaint alleges causes of action for (1) wrongful...

Excerpt: ...dant”) alleging causes of action for motor vehicle and general negligence. At this time, Defendant moves to strike the entire complaint. The motion is unopposed. Defendant moves to strike the complaint on the ground it does not comply with CCP §§ 128.7 and 446 because while the complaint was purportedly filed by Plaintiff in pro per, the complaint was not actually signed by Plaintiff or an attorney retained by Plaintiff. Defendant contends Pl...

Excerpt: ...Inglewood (“Defendants”) for damages relating to Plaintiff's alleged trip and fall on a public sidewalk. On April 15, 2021, the court held an Order to Show Cause re: Dismissal for Failure to File Proof of Service (the “OSC”). There were no appearances by or for either side. The court ordered the complaint dismissed without prejudice pursuant to CCP § 581(b). On August 26, 2021, Plaintiff filed the instant motion to set aside dismissal. P...

Excerpt: ...ery Company dba Food 4 Less for damages arising out of a slip and fall on Defendant's property. Plaintiff alleges she slipped on a liquid substance left on the floor by a cashier, and that rather than calling for medical assistance, Defendant negligently called a taxicab for Plaintiff to take her home. Plaintiff allegedly fell again while exiting the taxicab because she could not walk. The complaint alleges causes of action for negligence and pre...

Excerpt: ...Recycling, and Albert Perez for damages arising from a three-vehicle accident. The complaint alleges claims for (1) negligence, including claims for motor vehicle negligence, negligent entrustment, negligent training, negligent undertaking, negligent supervision and negligent retention, and (2) negligence per se. Defendants Perez Paper Recycling (“PPR) and Albert Perez (“Perez”) (collectively, “Perez Defendants”) now move for summary ju...

Excerpt: ... of Los Angeles (“Defendant”) for damages relating to Plaintiff's alleged trip and fall on a sidewalk. On August 19, 2021, Plaintiff filed a First Amended Complaint (“FAC”) asserting causes of action for (1) governmental liability and (2) premises liability. Defendant demurs to the FAC on the ground Plaintiff did not comply with the Government Claims Act's (the “Act”) statute of limitations. Defendant asserts the FAC alleges Plaintiff...

Excerpt: ...nd Yang Keun Yu (“Yu”) (collectively, “Defendants”) for damages arising from a motor vehicle accident At this time, Plaintiff moves to quash business records subpoenas served on five of Plaintiff healthcare providers. The subpoenas were issued on June 11, 2021, with a production date of July 9, 2021. Plaintiff contends the subpoenas are overbroad and violate Plaintiff's right to privacy because the subpoenas seek all medical records and d...

Excerpt: ...ndants, Luisa M. Betancourt (“Luisa”) and Eduardo Molina Betancourt (“Eduardo”) for subrogation. On January 22, 2021, Plaintiff filed a Request for Dismissal as to Luisa only dismissing Luisa with prejudice. On April 28, 2021, the court signed and filed a Stipulation for Settlement and Order signed by Eduardo, Plaintiff, and their counsel. On August 18, 2021, Plaintiff filed the instant motion to enforce settlement agreement against Eduar...