Excerpt: ...eters ("Peeters") and Money Tax Group, Inc., alleging causes of action for (1) Violation of the Tax Preparation Act (Bus. & Prof. Code SS 22250 et seq.), (2) Fraud, (3) Violation of Penal Code S 496, and (4) Unfair Competition. On December 30, 2022, Plaintiff served Peeters with a Notice of Deposition for January 19, 2023. The Notice did not include a request for documents. Peeters timely served a written objection to the deposition on the ground...

Excerpt: ...efendant, MFS Supply, LLC, for (1) breach of written contract, (2) breach of oral contract, (3) account stated, and (4) quantum meruit. As alleged, Plaintiff's business includes importing, freight forwarding and logistical services. Pursuant to a written and oral contract, Plaintiff provided such services to Defendant. The bill amounted to $80,290.70. Defendant did not pay the bill. On April 24, 2023, Plaintiff served Defendant with discovery req...

Excerpt: ...ars old and has been receiving medical care from Cedars-Sinai Medical Center (“Cedars Sinai”) from July 2021 to present. On June 16, 2022, Plaintiff was admitted to Cedars Sinai for in-patient neck surgery. She was transported on the Cedars Sinai campus from a personal vehicle to her patient room while seated in her personal transport chair. The chair did not have footrests. Plaintiff underwent neck surgery. On June 21, 2022, Plaintiff was di...

Excerpt: ...edical treatment. On June 16, 2023, Plaintiff, Elena Jahnke, filed a Complaint against Defendants, Blue Cross of California dba Anthem Blue Cross (“Anthem”) and Preferred IPA of California (“Preferred IPA”), asserting causes of action for (1) Breach of the Implied Covenant of Good Faith and Fair Dealing, (2) Breach of Contract, (3) Violations of Business & Professions Code section 17200, and (4) Negligence. The First, Second, and Third Ca...

Excerpt: ...ts, Quik Tow LLC (“Quik Tow”) and Ignacio Gonzalez, for wage and hour violations. On July 19, 2023, Plaintiff served Quik Tow with Form Interrogatories—General, Set One, Special Interrogatories, Set Two, and Request for Admissions Set, Two. To date, Quik Tow has not served responses. On September 28 and September 29, 2023, Plaintiff filed these motions to compel Quik Tow's responses to the Form Interrogatories—General, Set One, and Specia...

Excerpt: ...cessive force and infringements of federal rights. In response to the murder of George Floyd, protestors gathered near the intersection of Beverly Blvd. and The Grove Drive/Stanley Drive (the “Stanley Protest”), among other locations. On May 30, 2020, Plaintiff, Jonathan Rivera, participated in the Stanley Protest. Los Angeles Police Department (“LAPD”) and Los Angeles County Sheriff's Department (“LACSD”) deployed law enforcement to ...

Excerpt: ...alleges that between August 22, 2013 to February 6, 2020, she personally loaned the total sum of $65,945.00 to Defendants, Jennifer O. Oh and Younhee Cho, so that Defendants could purchase a house. In return, Defendants promised to repay Plaintiff with interest by October 30, 2020 without any intention to repay the loan. Defendants have not repaid the loan. On November 22, 2022, Plaintiff filed a Complaint in pro per against Defendants for (1) Fi...

Excerpt: ...d this action against Defendant Los Angeles Unified School District (“LAUSD”) for actions for (1) Negligence and (2) Negligent Failure to Warn, Train, or Educate. In relevant part, the Complaint alleges that Plaintiff was sexually abused by Vance Miller (“Miller”) from 1998 to 2002 while he was a student at Hamilton Music Academy. Miller was an employee of the Los Angeles Unified School District (“LAUSD”). The Complaint further allege...

Excerpt: ...mination and wrongful termination action. On September 26, 2023, Plaintiff, Emmanuel Akuamoah, filed a Complaint against Defendant, Kaiser Foundation Hospitals, alleging causes of action for (1) Retaliation in Violation of CFRA, (2) Violation of Labor Code §§ 233, 234, 246.5, (3) Disability and Associational Disability Discrimination (FEHA), (4) Violation of Labor Code §§ 1102.5-1105, (5) Retaliation (FEHA), (6) Wrongful Termination in Violat...

Excerpt: ... Angeles Unified School District (“LAUSD”) for injuries arising from a slip and fall while walking through the main hallway on Defendant's premises. Plaintiff alleges the floor of the hallway was in a dangerous condition, and Defendant had actual or constructive notice of the dangerous condition. On August 30, 2022, LAUSD filed this motion for summary judgment, or in the alternative, summary adjudication. Oral argument was heard on September ...

Excerpt: ...ndant Kia America, Inc. (“Kia”). Plaintiff filed a First Amended Complaint (FAC) on May 5, 2022, for (1) Violation of Song-Beverly Act, Breach of Express Warranty; (2) Violation of the Song- Beverly Act, Breach of Implied Warranty; (3) Fraudulent Inducement – Concealment; and (4) Fraudulent Inducement – Misrepresentation. Plaintiff purchased a new 2017 Kia Sportage from Allstar Kia on September 17, 2016. Plaintiff alleges the vehicle was ...

Excerpt: ...CTION This is a breach of contract case concerning real property. On September 28, 2021, Plaintiff, The Redeemed Christian Church of God-Jesus Embassy Los Angeles, filed a complaint against Defendants, Swift Petrochemicals, Inc. (“Swift”) and Mutiu Olatunji Durosinmi-Etti (“Etti”). On October 9, 2023, Plaintiff filed the operative Third Amended Complaint (TAC) alleging causes of action for: 1) Breach of Contract, 2) Promissory Estoppel, 3...

Excerpt: ...dia + Entertainment, Inc., filed a Complaint against Defendant, Orange County Flight Center, Inc., for (1) Breach of Part Written/Part Oral Contract, (2) Quantum Meruit, and (3) Open Book Account. Plaintiff alleges Defendant asked Plaintiff to run radio advertisements. They agreed upon advertising schedules (orally and/or in writing) and a Media plan. Plaintiff issued an Order Confirmation.[1] Pursuant to the terms of the Agreement, Plaintiff was...

Excerpt: ...n 2020, Plaintiff, Jane Doe, was hired as a security guard with universal Protection Service, LP dba Allied universal Security Services ("Allied"). In 2021, she was hired by Scott Beveridge, the Emergency Operations Director of HRL Laboratories, LLC, ("HRL") for a guard position at HRL. HRL and Allied are joint employers. On April 7, 2023, Plaintiff, lane Doe, filed a complaint against Defendants, Allied, HRL, and Beveridge, for. (1) Sexual Haras...

Excerpt: ...this action against the City of Los Angeles (sued as the “Los Angeles Police Department”). On January 5, 2023, Plaintiff filed the operative First Amended Complaint (“FAC”). The FAC alleges the following causes of action: (1) Willful Perjuries, the Serious Violation of the Federal Laws; (2) Violation of the United States Constitution; (3) Theft and Robbery of Plaintiff's Property; and (4) Elder Abuse.¿ The FAC also adds Kenneth Bryant (�...

Excerpt: ...took place during her employment with MDRN Staffing Inc. (“MDRN”). On May 31, 2023, Plaintiff filed the operative First Amended Complaint (“FAC”) against Defendants, MDRN and David Mota, for the following causes of action: (1) Disability Discrimination in Violation of the California Family Rights Act (2) Failure to Provide Reasonable Accommodations in Violation of FEHA (3) Failure to Engage in a Good Faith Interactive Process in Violation...

Excerpt: ...�)[2], filed a Complaint against Defendants, Arthur L. Goldberg (“Goldberg”), Kurt E. Bier, Kenneth Skipper-Dotta, and Working People's Law Center (“WPLC”), arising from Goldberg's court-ordered appointment as Plaintiff's counsel during custody proceedings between Plaintiff's parents, Denise Thomas (“Denise”) and Gary Thomas (“Gary”). On June 10, 2021, Plaintiff filed the operative First Amended Complaint (“FAC”), alleging cau...

Excerpt: ...nst Defendant, L.A. Downtown Medical Center LLC (erroneously sued and served as L.A. Downton Medical Center), for injuries arising from a slip and fall on Defendant's premises at 1711 W. Temple St., Los Angeles, California 90026. Plaintiff alleges that he was lawfully on Defendant's premises as a patient when he slipped on a substance on the floor. The original Complaint alleged causes of action for medical negligence, negligence, and premises li...

Excerpt: ...”) and Ignacio Gonzalez, for wage and hour violations. On November 14, 2022, Plaintiff served Quik Tow with the first set of discovery, including Request for Production of Documents. Quik Tow did not serve responses. After meeting and conferring with defense counsel about the overdue responses, Plaintiff filed motions to compel on February 21, 2023. The motions were heard and granted on June 22, 2023. In particular, Quik Tow was ordered to serv...

Excerpt: ...elpit, and Charles S. Clark, for wrongful eviction. The Complaint was partially handwritten and included exhibits that were not clearly referenced in the allegations. Plaintiff was self-represented at the time of the filing of the Complaint. On September 5, 2023, Plaintiff filed this motion for leave to file the proposed First Amended Complaint (FAC). The motion was heard on November 28, 2023. Defendant B. Ruth Allen correctly pointed out that th...

Excerpt: ...de § 1790, et seq. Defendant filed an Answer to the Complaint on February 16, 2022. On May 19, 2023, Defendant served, and Plaintiff accepted, an Offer to Compromise and Acceptance Under Code of Civil Procedure section 998. Plaintiff filed a Notice of Settlement on May 22, 2023. On December 7, 2023, Plaintiff filed this Motion for Attorney's Fees. Defendant filed an opposition. Plaintiff replied. II. DISCUSSION Evidentiary Objections Defendant o...

Excerpt: ...fendant, California Physicians' Service d/b/a Blue Shield of California, alleging that Defendant intentionally cancelled Plaintiff's health insurance policy. As a result, Plaintiff suffered emotional and physical distress, as well as monetary damages. The operative First Amended Complaint (“FAC”) was filed on July 13, 2023. Plaintiff is self-represented. On September 8, 2023, Defendant filed this Demurrer and Motion to Strike portions of the ...

Excerpt: ...dants, First American Title Insurance Co. (“First American”) and Urbana Bonnie Footte (“Footte”), for taking a loan out on the residence at 1250 King Lake Dr., Diamond Bar, California 91765 (the “Subject Property”) without Plaintiff's consent. On July 25, 2023, Plaintiff filed the operative First Amended Complaint (“FAC”), alleging causes of action for (1) Negligence and (2) Intentional Tort. The FAC adds JP Morgan Chase Bank (“...

Excerpt: ...ers ("Peeters") and Money Tax Group, Inc., alleging causes of action for (1) Violation of the Tax Preparation Act (Bus. & Prof. Code SS 22250 et seq.), (2) Fraud, (3) Violation of Penal Code S 496, and (4) Unfair Competition. On December 30, 2022, Plaintiff served Peeters with a Notice of Deposition for January 19, 2023. The Notice did not include a request for documents. Peeters timely served a written objection to the deposition on the grounds ...

Excerpt: ...Villa, et al. RESPONDING PARTY: Defendant Los Angeles Dodgers, LLC I. INTRODUCTION On August 23, 2023, Plaintiffs, Adam Luna Villa, Monica Jasmine Villa, and Jasmin Estrella Villa, by and through her Guardian Ad Litem, Adam Luna Villa, filed these motions to compel Defendant, Los Angeles Dodgers LLC, to provide responses to Plaintiffs' Form Interrogatories, Set One, Special Interrogatories, Set One, and Request for Production of Documents, Sets O...

Excerpt: ... Ignacio Gonzalez, for wage and hour violations. On November 14, 2022, Plaintiff served Quik Tow with Form Interrogatories— Employment Law, Set One. On June 13, 2023, Quik Tow served responses. Plaintiff took issue with the responses and sent a meet and confer letter. Defendant provided Plaintiff with extensions to file a motion to compel further in exchange for an extension to respond to the meet and confer letter. On October 26, 2023, after s...

Excerpt: ...nd wrongful termination action against Defendant, Cedars-Sinai Medical Center. On December 5, 2022, Defendant served Plaintiff with a Notce of Deposition which also included requests for production of documents. Plaintiff timely served a written objection to the deposition stating that Plaintiff would not appear on the grounds the deposition date "was unilaterally selected and is inconvenient to Plaintiff's counsel." The objection was not interpo...

Excerpt: ...nt, against Defendants, First American Title Insurance Co. (“First American”) and Urbana Bonnie Footte (“Footte”), for taking a loan out on the residence at 1250 King Lake Dr., Diamond Bar, California 91765 (the “Subject Property”) without Plaintiff's consent. On July 25, 2023, Plaintiff filed the operative First Amended Complaint (“FAC”), alleging causes of action for (1) Negligence and (2) Intentional Tort. The FAC adds JP Morga...

Excerpt: ...una Villa, et al. RESPONDING PARTY: Defendant Los Angeles Dodgers, LLC I. INTRODUCTION On August 23, 2023, Plaintiffs, Adam Luna Villa, Monica Jasmine Villa, and Jasmin Estrella Villa, by and through her Guardian Ad Litem, Adam Luna Villa, filed these motions to compel Defendant, Los Angeles Dodgers LLC, to provide responses to Plaintiffs' Form Interrogatories, Set One, Special Interrogatories, Set One, and Request for Production of Documents, Se...

Excerpt: ...��Pham”) and Hollywood Investments, LLC filed a Complaint against Defendants, Jackson Leroy Underwood (“Underwood”), Gay Hilliard (“Hilliard”), Essa Rassool, Joe Boudre (“Boudre”), Keller Williams Realty Santa Barbara (“Keller Williams”), Mohammad Asraf Azdoi, and Elite REO Brokers, alleging five causes of action for: (1) breach of contract; (2) fraudulent concealment; (3) negligence; (4) negligent misrepresentation; and (5) dec...

Excerpt: ...ught by prospective tenants of various rental properties regarding alleged violations of the Investigative Consumer Reporting Agencies Act (ICRAA). On February 14, 2023, Plaintiffs[2], Or Vardi (“Vardi”), Joseph Schuetz (“Schuetz”), Chaninthon Thammasan (“Thammasan”), and Stephanie Steiner (“Steiner”), filed a Complaint, against Defendants, Equity Residential Management, LLC (“ERM”) and TransUnion Rental Screening Solutions, I...

Excerpt: ...ng that she purchased a defective 2017 Chevrolet Tahoe (the “Vehicle”) which Defendant's failed to conform to the Vehicle's express warranties. On July 20, 2023, Plaintiff filed the operative First Amended Complaint (“FAC”) asserting causes of action for: 1. Breach of Implied Warranty of Merchantability under the Song-Beverly Act 2. Breach of Express Warranty under the Song-Beverly Act 3. Breach of Express Warranty under California Commer...

Excerpt: ...this action against Defendants, Shahco, Inc. (“Shahco”) and Shahram Saba (“Saba”), alleging causes of action for (1) Public Nuisance, (2) Public Nuisance Per Se, (3) Abatement of Public Nuisance, (4) Private Nuisance, (5) Private Nuisance Per Se, and (6) Negligence. The Complaint alleges as follows: Plaintiffs are the owners and residents of real property at 1545 Cambria Street, Los Angeles, California 90017. Shahco, a corporation, is the...

Excerpt: ...021, Plaintiff, Veronica Yameleth Bonilla, filed a Complaint against Defendant, Numero Uno Acquisitions, LLC, alleging causes of action for: (1) Retaliation in Violation of the California Family Rights Act (CFRA) (2) Discrimination in Violation of the CFRA (3) Disability Discrimination in Violation of the Fair Employment and Housing Act (FEHA) (4) Failure to Engage in a Good Faith Interactive Process in Violation of the FEHA (5) Failure to Provid...

Excerpt: ...ages. On March 2, 2023, Plaintiff, Arami Cheyenne Walker, 1 filed a Complaint against Defendant, The Regents of the University of California (erroneously sued as Board of Regents, University of California), alleging causes of action for: (1) Appropriation (Civil Code section 3344); (2) Breach of Contract; and (3) Negligent Infliction of Emotional Distress.¿¿Plaintiff alleges that, on May 28, 2015, she was approached by a photographer at Univers...

Excerpt: ...fendants, Ronald S. MacDonald (“MacDonald”) and Monica K. Kramer (“Kramer”), asserting a cause of action for motor vehicle negligence. Kramer was dismissed from this action on May 11, 2021. On February 24, 2023, Plaintiff filed a motion for leave to file a First Amended Complaint (“FAC”) to add new defendants and causes of action. On October 2, 2023, after taking the matter under submission, the Court denied the motion for leave to am...

Excerpt: ... Ignacio Gonzalez, for wage and hour violations. ¿ On November 14, 2022, Plaintiff served Quik Tow with Special Interrogatories, Set One. ¿On June 13, 2023, Quik Tow served responses. Plaintiff took issue with the responses and sent a meet and confer letter. Defendant provided Plaintiff with extensions to file a motion to compel further in exchange for an extension to respond to the meet and confer letter. On October 26, 2023, after several ext...

Excerpt: ...ants, First American Title Insurance Co. and Urbana Bonnie Footte, for taking a loan out on the residence at 1250 King Lake Dr., Diamond Bar, California 91765 (the “Subject Property”) without Plaintiff's consent. On July 25, 2023, Plaintiff filed the operative First Amended Complaint (“FAC”), alleging causes of action for (1) Negligence and (2) Intentional Tort. The FAC adds JP Morgan Chase Bank (“Chase”) as a defendant. On October 13...

Excerpt: ...iff, John Cadusale, filed these motions to compel Defendants, Alameda Restaurant LLC, Noypitz Bar & Grill LLC, Lauro Calonzo, and Wokcano Cerritos, LLC, to provide responses to Plaintiff's Request for Production of Documents, Set One. Plaintiff seeks sanctions against Defendants. Defendants filed Oppositions.[1] Plaintiff filed Replies. II. LEGAL STANDARD TO COMPEL DISCOVERY RESPONSES If a party to whom inspection demands were directed fails to s...

Excerpt: ...legal malpractice action against Defendants, Arthur Goldberg, Kurt E. Bier, Kenneth Skipper- Dotta, an Working People's Law Center. On September 21, 2023, Plaintiff served Defendant Goldberg with a Notice of Deposition which also included requests for production of documents. The deposition was noticed for October 6, 2023. Defendant Goldberg agreed to appear. On September 27, 2023, defense counsel notified Plaintiff that Defendant Goldberg had be...

Excerpt: ...ruary 26, 2021, Plaintiff, Dawn Marie Fisher, initiated this action against Defendants, Adam F. Goldberg Productions, Inc.[1], Sony Pictures Entertainment, Inc (“SP Entertainment”), and Does 1-25, for injuries and damages arising from a trip and fall on the property of SP Entertainment. Plaintiff later amended the Complaint to name Sony Pictures Television, Inc. (“SP Television”) as Doe 1, Lot, Inc. as Doe 2, and Sony Pictures Studios, In...

Excerpt: .... On July 28, 2022, Plaintiff filed the first amended complaint (FAC) against Defendants Alameda Restaurant LLC, Noypitz Bar & Grill LLC, Lauro Calonzo, and Wokcano Cerritos, LLC, alleging seven causes of action for: (1) failure to provide meal breaks; (2) failure to provide rest breaks; (3) failure to pay wages; (4) failure to pay overtime; (5) failure to provide accurate itemized wage statements; (6) violation of Business and Professions Code s...

Excerpt: ...res screen reading software to read website content and access the content. Defendant, Johnny Was, LLC, owns and operates clothing store locations in California, including a store in Manhattan Beach, California. Defendant has a public website which provides access to Defendant's array of services, including a location locator, description of its products, and amenities, among other things. Plaintiff claims the website is maintained in such a way ...

Excerpt: ...rsement for the renovation of two properties on 49th Street and Roy Street in Highland Park, California. The parties are in the business of flipping houses. On June 5, 2022, Plaintiff, Kendall Key dba A Paper Street, filed a Complaint against Defendants, Robert Pereira and Vista Park Properties, LLC. On September 13, 2023, Plaintiff filed the First Amended Complaint (“FAC”) against Defendants alleging causes of action for (1) Breach of Contra...

Excerpt: ...oration, initiated this action against Defendants, Aquatherm, L.P., AENA NA, L.C., and Aquatherm GMBH, for (1) Breach of Express Warranty, (2) Strict Products Liability – Manufacturing Defect, and (3) Strict Products Liability – Design Defect. The Complaint alleges that Aquatherm Green Piping leaked. On August 25, 2023, Plaintiffs filed this motion for leave to file the First Amended Complaint. On December 5, 2023, Plaintiffs filed a Notice o...

Excerpt: ...020, Plaintiffs Romelia Leon de Garcia; Belisario Garcia; Jesus Alexander Garcia by and through his guardian ad litem Romelia Leon De Garcia, et al. filed a Complaint against Bruce A. Roden and Susan M. Roden, as individuals and trustees of the Living Trust of Bruce A. Roden and Susan M. Roden 1995 Dated July 20, 1995 (“Settling Defendants”), Gordon Cole, LLC, AQP Management, Inc., and Joel Estrada. On August 24, 2023, Gordon Cole, LLC, AQP M...

Excerpt: ... wrongful termination action against Defendant, Cedars-Sinai Medical Center. On December 5, 2022, Defendant served Plaintiff with a Notce of Deposition which also included requests for production of documents. Plaintiff timely served a written objection to the deposition stating that Plaintiff would not appear on the grounds the deposition date "was unilaterally selected and is inconvenient to Plaintiff's counsel." The objection was not interpose...

Excerpt: ...en an application for an order has been made to a judge, or to a court, and refused in whole or in part, or granted, or granted conditonally, or on terms, any party affected by the order may, within 10 days after service upon the party of written notce of entry of the order . . . [may] make application to the same judge or court that made the order, to reconsider the matter and modify, amend, or revoke the prior order. The party making the applic...

Excerpt: ...lan, alleging seven causes of action for: (1) wrongful termination in violation of public policy; (2) disability discrimination: failure to accommodate in violation of Government Code section 12940(m); (3) disability discrimination: retaliation — failure to accommodate in violation of Government Code section (4) disability discrimination - failure to engage in interactive process — Government Code section 12940(n); (5) retaliation in molation...

Excerpt: ...soz, reached out to Chris Furie (“Furie”), a real estate broker, for assistance in purchasing a property located at 943 N. Laurel Avenue in Los Angeles, California. Instead of assisting Plaintiff with the purchase of 943 N. Laurel Avenue, Furie proposed the purchase of 944 N. Laurel Avenue in Los Angeles, California (“Subject Property”). Furie represented that he and his company, 944 Laurel, LLC (“944 Laurel”), were in the process of ...

Excerpt: ...th America, Inc., Ajinomoto Frozen Foods, U.S.A, Inc., and Trader Joe's Company, alleging causes of action for (1) breach of written contract, (2) intentional interference with prospective economic advantage, (3) fraud, (4) negligent misrepresentation, (5) unfair competition, (6) breach of fiduciary duty, (7) aiding and abetting breach of fiduciary duty, (8) violation of California Uniform Trade Secrets Act, and (9) misappropriation of confidenti...

Excerpt: ...lication to the same judge or court that made the order, to reconsider the matter and modify, amend, or revoke the prior order. The party making the application shall state by affidavit what application was made before, when and to what judge, what order or decisions were made, and what new or different facts, circumstances, or law are claimed to be shown.” (Code Civ. Proc., § 1008(a).) A trial court has discretion with respect to granting a m...

Excerpt: ...at Defendant intentionally cancelled Plaintiff's health insurance policy. As a result, Plaintiff suffered emotional and physical distress, as well as monetary damages. The operative First Amended Complaint (“FAC”) was filed on July 13, 2023. Plaintiff is self-represented. On September 8, 2023, Defendant filed a Demurrer and Motion to Strike the FAC. Plaintiff filed Opposition documents on September 26 and September 28, 2023. Defendant filed a...

Excerpt: ...the Fair Employment and Housing Act (“FEHA”). Plaintiff, Randi Winter, was employed at El Camino Community College District (“El Camino”) as a journeyman plumber from September 2002 to November 2018. Commencing in the Fall of 2010 through 2018, Plaintiff alleges that Thomas Brown (“Brown”), Director of the Facilities, Planning and Services Department at El Camino, and Robert Brobst (“Brobst”), the Assistant Director, discriminated...

Excerpt: ...laim for excessive force. In response to the murder of George Floyd, protestors gathered along Beverly Blvd. near The Grove Drive shopping center. On May 30, 2023, Plaintiff, Jonathan Rivera, participated in the protest near the intersection of Beverly Blvd. and N. Fairfax Ave. (“Fairfax Protest”). Los Angeles Police Department (“LAPD”) and Los Angeles County Sheriff's Department (“LACSD”) deployed law enforcement to provide crowd con...

Excerpt: ...ach, California (the “Subject Property”). 910 Torrance Blvd., LLC (“910 Torrance”), owns a one-third (1/3) interest as a tenant in common of the Subject Property. London Towne Center, LLC (“LTC”) owns a two- thirds (2/3) interest in the Subject Property. Thomas Norris (“Norris”) is the sole member and manager of LTC. On March 12, 2021, Plaintiffs, 910 Torrance, Leslie H. Winner, and Lynda Winner, individually and as trustees of th...

Excerpt: ...F. Delpit, and Charles S. Clark, for wrongful eviction. The Complaint was partially handwritten and included exhibits that were not clearly referenced in the allegations. Plaintiff was self-represented at the time of the filing of the Complaint. On September 6, 2023, Plaintiff filed a Substitution of Attorney, indicating that Plaintiff is represented by counsel. Plaintiff now moves for an order granting leave to file the proposed First Amended Co...

Excerpt: ... of Los Angeles.” On July 24, 2023, Defendant County of Los Angeles (County) filed a demurrer the Complaint. No opposition was filed. The demurrer was sustained with leave to amend. On October 4, 2023, Plaintiff filed a 108-page “Complaint Statement Amended.” On October 6, 2023, the County filed a demurrer. That demurrer is the matter before the Court, set for hearing on November 14, 2023. But on October 9, 2023, Plaintiff filed a 61-page �...

Excerpt: ...fendant State National Insurance Company, Inc. and others. On March 30, 2023, Defendant filed a demurrer to the eighth cause of action. A demurrer for sufficiency tests whether the complaint states a cause of action. (Hahn v. Mirda (2007) 147 Cal.App.4th 740, 747.) When considering demurrers, courts read the allegations liberally and in context, accepting the alleged facts as true. (Nolte v. Cedars-Sinai Medical Center (2015) 236 Cal.App.4th 1401...

Excerpt: ...ined with 20 days leave to amend, in part, and overruled, in part. Jayi Chiang, et al.'s Motion to Strike Portions of First Amended Cross-complaint is moot, in part, and granted with 20 days leave to amend, in part. Background Plaintiff's Complaint was filed on June 16, 2021. Plaintiff alleges the following facts. Plaintiff entered into a contract with Defendants. Defendants agreed to build Plaintiff a restaurant in exchange for Plaintiff paying ...

Excerpt: ...ined with 20 days leave to amend, in part, and overruled, in part. Jayi Chiang, et al.'s Motion to Strike Portions of First Amended Cross-complaint is moot, in part, and granted with 20 days leave to amend, in part. Background Plaintiff's Complaint was filed on June 16, 2021. Plaintiff alleges the following facts. Plaintiff entered into a contract with Defendants. Defendants agreed to build Plaintiff a restaurant in exchange for Plaintiff paying ...

Excerpt: ...ss transactions. On May 7, 2021, Jason Aryeh, 1568 Blue Jay Way LLC, 6097 West Winding Way LLC, and 5849 Murphy Way LLC (“the Aryeh Parties”) filed their Cross-Complaint (“the Aryeh Cross-Complaint”) against Oliver Damavandi, Bar Design and Construction, Inc., Asher Joseph Alfasi, Archive Design Group, LLC, and Zoran Pevec. On August 27, 2021, Oliver Damavandi amended his Complaint to substitute Doe 1 with Sarah Emmi Tibstra, Doe 4 with M...

Excerpt: ...tom .... The page numbering must begin with the first page and use only Arabic numerals (e.g., 1, 2, 3)….” Plaintiff shall comply with the page numbering requirement or the pleading and briefs may be stricken by the Court on its own motion. A. Factual In her Third Amended Complaint (TAC), Plaintiff alleges seven causes of action involving her employment at and termination from Defendant's company. The causes of action are harassment, retaliat...

Excerpt: ...2023, Plaintiff filed her Judicial Council Form CM-200, Notice of Settlement of Entire Case. On October 20, 2023, Plaintiff filed her Unopposed Motion for Approval of PAGA Settlement. In support of her Motion, Plaintiff concurrently filed: (1) Declaration of Lisa Mullins; (2) Declaration of Harout Messrelian; and (3) Proposed Order. No opposition or other response has been filed to the Motion. ANALYSIS: I. Legal Standard “This part shall be kno...

Excerpt: ...ent was entered against J-M. Walsworth filed a Cross-Complaint against J-M, Outside GC, LLC (“Outside”), counsel Frank Fletcher (“Fletcher”) and others, alleging they are responsible for the unfavorable judgment in the underlying asbestos case. Outside has now filed a motion seeking an order from the Court for a determination that the settlement between Outside, Fletcher and J-M was entered into good faith pursuant to CCP § 877.6. (Fletc...

Excerpt: ...note secured by a deed of trust on his real property located in Redlands, California. The promissory note provided Shetty would receive a principal sum of $125,000, on which he would pay interest at 12 percent per annum. However, Defendants allegedly only lent him the principal sum of $108,000, rather than the $125,000 indicated on the note itself. When a notice of default was recorded against the property, Shetty tendered the full and correct am...

Excerpt: ...uction (Set One) is DENIED. The request for sanctions is denied. Moving party to provide notice. FACTUAL BACKGROUND This is an action for violations of the Song Beverly Consumer Warranty Act. Plaintiff alleges that she purchased a certified pre-owned 2016 Land Rover Discovery from Hornburg Jaguar Land Rover in Santa Monica, California. The purchase came with the remaining time/mileage balances of Jaguar Land Rover's warranties along with addition...

Excerpt: ...uction (Set One) is DENIED. The request for sanctions is denied. Moving party to provide notice. FACTUAL BACKGROUND This is an action for violations of the Song Beverly Consumer Warranty Act. Plaintiff alleges that she purchased a certified pre-owned 2016 Land Rover Discovery from Hornburg Jaguar Land Rover in Santa Monica, California. The purchase came with the remaining time/mileage balances of Jaguar Land Rover's warranties along with addition...

Excerpt: ...of over $400,000 in attorneys' fees, costs and interest owed by ELIOT CARMI (“Defendant”) for legal services undertaken on his behalf. Plaintiffs filed two motions to compel further discovery responses, both with monetary sanctions requests. The first motion is to compel further responses to form interrogatory number 15.1 regarding support for certain affirmative defenses. The second motion is to compel production of documents as agreed. Defe...

Excerpt: ...) for damages arising from a trip and fall over a hole on the sidewalk. On September 9, 2022, the City filed a cross-complaint against Compton Commercial Redevelopment Company (“CCRC”). On November 8, 2022, CCRC filed its Answer to the City's cross- complaint. On November 10, 2022, CCRC filed its cross-complaint against Roes 1 to 20, and later filed an amendment to cross-complaint naming the City as Roe 1 on January 17, 2023. The City filed i...

Excerpt: ... Complaint was filed on December 29, 2022. Plaintiff alleges the following facts. Plaintiff alleges that he was sexually assaulted when he was a minor at Saint Bernard High School. Meet and Confer Defendant filed a meet and confer declaration in sufficient compliance with CCP S 435.5. Lee W. Potts.) Motion to Strike The court may, upon a motion, or at any time in its discretion, and upon terms it deems proper, strike any irrelevant, false, or imp...

Excerpt: ...) and Saeed Bholat (“Bholat”) (jointly, “Defendants”). The Complaint asserts causes of action for (1) FEHA retaliation, (2) FEHA retaliation, (3) failure to prevent discrimination, (4) “prevention of employee's Weingarten rights – FEHA discrimination,” (5) “civil rights violation – use of video camera – FEHA discrimination,” (6) “failure to provide progressive discipline – FEHA discrimination,” (7) “failure to provid...

Excerpt: ...e “Vehicle”). On August 19, 2021, Plaintiff, Yuriria Cerezo Torres, filed a Complaint against Defendant, General Motors LLC, after Defendant failed to repair the Vehicle pursuant to written expressed warranty for the Vehicle and did not honor its obligations under the Song-Beverly Consumer Warranty Act. On May 18, 2023, the Court granted in part Plaintiff's motion to compel Defendant's further verified responses and documents to Request for P...

Excerpt: ...alleges that between August 22, 2013 to February 6, 2020, she personally loaned the total sum of $65,945.00 to Defendants, Jennifer O. Oh and Younhee Cho, so that Defendants could purchase a house. In return, Defendants promised to repay Plaintiff with interest by October 30, 2020 without any intention to repay the loan. Defendants have not repaid the loan. Promissory notes, written in Korean and English, as well as personal checks issued by Defe...

Excerpt: ...s, United Realty & Management, Inc. (“URMI”) and 7-Eleven, Inc. (“7-Eleven”), arising from a trip and fall on uneven pavement in the parking area in front of Defendants' 7-Eleven store. On August 31, 2020, 7-Eleven filed a Cross-Complaint against URMI, Paul Paik, and Lae Oh Paik for indemnity, apportionment of fault, and declaratory relief. Paul Paik and Lae Oh Pail (collectively, the “Paiks”), are the owners of the shopping center wh...

Excerpt: ...a Corporation dba El Super for injuries arising from a slip and fall incident. Relevant Procedural Background  On July 7, 2023, Plaintiff filed motions to compel Defendant's further discovery responses to Plaintiff's Special Interrogatories, Set Two, and Requests for Production of Documents, Set Two. Defendant served untimely further responses prior to the hearing. The Court found Defendant's responses to be code-compliant. As such, the Court ...

Excerpt: ... for injuries arising from a motor vehicle collision. On September 29, 2023, Defendant filed these motions to compel Plaintiff's further responses to Special Interrogatories, Set Two, and Request for Production of Documents, Set Two. Defendant seeks sanctions against Plaintiff and his counsel. Plaintiff filed an opposition. Defendant replied. II. LEGAL STANDARD TO COMPEL FURTHER RESPONSES TO DISCOVERY Under Code of Civil Procedure sections 2030.3...

Excerpt: ...bility action against Defendants, City of Los Angeles, County of Los Angeles, and Los Angeles County Metropolitan Transportation Authority (“MTA”), arising from a trip and fall on an uneven sidewalk at or near an MTA bus stop. Plaintiff noticed MTA's person(s) most qualified deposition on three occasions. LACMTA objected to all three deposition notices. On October 3, 2023, Plaintiff filed this motion to compel the deposition of MTA's person m...

Excerpt: ...ette Lee, for injuries arising from an attack by Defendant's two dogs. Plaintiff alleges Defendant owned, kept, possessed, harbored, and controlled two violent canines with a history of attacks of other individuals in the neighborhood. Plaintiff seeks punitive damages. On September 21, 2023, Defendant filed this motion to strike punitive damages from the Complaint. Plaintiff filed an opposition and Defendant replied. II. LEGAL STANDARD FOR MOTION...

Excerpt: ... PARTY: Plaintiff Galina Kopelev; Defendant Churchill Condominium Association I. INTRODUCTION On June 4, 2021, Plaintiff, Galina Kopelev, initiated this action against Defendant, Churchill Condominium Association, for injuries arising from a slip and fall in the sauna of Defendant's premises. On September 15, 2023, the following motions were filed:  Defendant's motion to compel Plaintiff's responses to Form Interrogatories, Set Two.  Defend...

Excerpt: ...ainst Defendant, The Vons Companies, Inc., for injuries arising from a slip and fall in a Vons' grocery store in Montrose, California. The trial date was initially set for March 2, 2023, and continued by stipulation of the parties to June 8, 2023. Discovery was set to the new trial date. On April 17, 2023, after Plaintiff did not appear for a properly noticed medical examination, Defendant reserved the first available hearing date for this motion...

Excerpt: ...plaint against Defendants, Ford Apartments, L.P. (“Ford Apartments”) and SRO Housing Corporation (“SRO Housing”), for negligence, premises liability, and negligent hiring, retention and supervision. Plaintiff was a tenant at Defendants' property. Plaintiff alleges he was attacked at the property and sustained injuries, including a traumatic brain injury and erectile dysfunction. Plaintiff later filed amendments to the complaint to name Kn...

Excerpt: ...laintiff, Juan Carlos Rosas Hernandez, filed this action against Defendants, Law Offices of Steven R. Espinoza, APC (“Espinoza Law Offices”) and SAE & JGE, LLC (“SAE & JGE”), asserting causes of action for (1) general negligence and (2) premises liability. Trial was set for May 17, 2023. Pursuant to that trial date, the discovery cutoff was set for April 17, 2023; the discovery motion cutoff was set for May 2, 2023. On March 12, 2023, Pla...

Excerpt: ...ity of Los Angeles, for injuries Plaintiff sustained while walking on an uplifted public sidewalk. On January 30, 2023, Plaintiff noticed the Defendant's deposition. Pursuant to Defendant's request, Plaintiff took the deposition off-calendar so that the parties could participate in mediation and possibly resolve the matter. The matter was not resolved at mediation. Plaintiff then re-noticed the deposition for Defendant for September 13, 2023. Def...

Excerpt: ...surance Company, for (1) Breach of Insurance Contract, (2) Bad Faith Breach of Implied Covenant of Good Faith and Fair Dealing, and (3) Declaratory relief. Plaintiff alleges that he retained an insurance policy from Defendant with Policy Number 4223-60-93-65 (the “Policy”) which provided uninsured motorist coverage for bodily injury claims. On August 12, 2020, Plaintiff was driving his vehicle on the freeway when Plaintiff's vehicle was struc...

Excerpt: ...ndant seeks to add three affirmative defenses. The motion is unopposed.[1] II. LEGAL STANDARD The court may, in its discretion and after notice to the adverse party, allow, upon any terms as may be just, an amendment to any pleading, including adding or striking out the name of any party, or correcting a mistake in the name of a party, or a mistake in any other respect.¿ (Code Civ. Proc., § 473, subd. (a)(1).)¿ “Public policy dictates that l...

Excerpt: ...ction against Defendant, Newmark Merrill Companies, Inc., arising from a slip and fall on a speed bump in the parking lot of Defendant's premises. Plaintiff asserts causes of action for (1) Premises Liability and (2) Negligence. On August 3, 2023, Defendant filed this motion for summary judgment, or in the alternative, summary adjudication. The motion is unopposed.[1] II. LEGAL STANDARD FOR SUMMARY JUDGMENT In reviewing a motion for summary judgm...

Excerpt: ...nd Victor Hugo Cardona, filed this motion to compel Plaintiff, Bertha Lidia Rapalo Rivera, to provide responses to Request for Production of Documents, Set One. Defendant seeks sanctions against Plaintiff and her counsel of record. The motion is unopposed. II. LEGAL STANDARD TO COMPEL DISCOVERY RESPONSES If a party to whom demands for inspection, copying, testing, or sampling is directed fails to serve a timely response, the propounding party may...

Excerpt: ...endant Jerry Childs RESPONDING PARTY: No opposition I. BACKGROUND On August 14, 2023, Defendant, Jerry Childs, filed these motions to compel Plaintiff, Dennis Cacho Villa Jr., to provide responses to Defendant's First Set of Form Interrogatories, Special Interrogatories, and Request for Identification and Production of Documents, and to deem the Request for Admissions, Set One, admitted against Plaintiff. Defendant seeks sanctions against Plainti...

Excerpt: ...continuance. The motion is unopposed.[1] II. LEGAL STANDARD FOR MOTION TO CONTINUE TRIAL California Rules of Court, rule 3.1332, subdivision (b) outlines that “a party seeking a continuance of the date set for trial, whether contested or uncontested or stipulated to by the parties, must make the request for a continuance by a noticed motion or an ex parte application under the rules in chapter 4 of this division, with supporting declarations. T...

Excerpt: ... complaint against Defendants, Lyft, Inc., and Hamdi Sameer Abu-Mayyaleh (“Abu-Mayyaleh”), arising from a motor vehicle collision between Plaintiff and Lyft driver Abu-Mayyaleh. As a result of the incident, Plaintiff asserts a claim for loss of earnings. Plaintiff further alleges her injuries from the accident caused her to rely on others to care for her young daughter. On May 2, 2023, Plaintiff testified at her deposition that the incident c...

Excerpt: ... against Defendant, Bodega Latina Corporation dba El Super, arising from two July 18, 2020 slip and fall incidents. On May 3, 2021, Defendant filed motions to compel Ms. Castro's responses to the First Set of Defendant's Form Interrogatories, Special Interrogatories, and Request for Production. The Court granted the motions. Thereafter, Ms. Castro served responses to the Form and Special Interrogatories only. Having not received Ms. Castro's resp...

Excerpt: ...efendant, Barbara Dybnis, arising from an October 22, 2018 motor vehicle accident involving a motorcycle. On July 23, 2021, Defendant served a deposition subpoena for the production of business records (the “Subpoena”) on nonparty Christensen Hsu Sipes, LLP and/or Elizabeth Trent Schaus (hereafter, “CHS”). The Subpoena seeks documents regarding a 2015 motor vehicle accident involving Plaintiff and which resulted in a lawsuit captioned Han...

Excerpt: ..., initiated this action[l] against Defendant, Los Angeles Unified School District ("LAUSD") for injuries arising from a slip and fall while walking through the main hallway on Defendants premises. Plaintiff alleges the floor of the hallway was in a dangerous condition, and Defendant had actual or constructive notice of the dangerous condition. On August 30, 2022, LAUSD filed this motion for summary judgment, or in the alternative, summary adjudic...

Excerpt: ...deh Yaghoubian (“Yaghoubian”), Nancy Gaignard (“Gaignard”), and Lyft, Inc. (“Lyft”), for injuries Plaintiff sustained in an August 8, 2019 motor vehicle accident. Plaintiff alleges she was a passenger in a Lyft vehicle driven by Gaignard when Yaghoubian weaved through traffic in his vehicle and side swiped Gaignard's vehicle. Plaintiff asserts causes of action for General Negligence and Motor Vehicle against all defendants. At the tim...

Excerpt: ...: Plaintiffs Roberto Miranda, et al. RESPONDING PARTY: Defendants Marilin Ruiz, et al. I. INTRODUCTION On August 14, 2023, Plaintiffs, Roberto Miranda and Anabel Bautista, filed these motions[1] to compel Defendants, Marilin Ruiz and Mancia Hipolito, to provide responses to Plaintiff's First Set of Form Interrogatories, Special Interrogatories, and Request for Production of Documents, and to deem Requests for Admission, Set One, admitted against ...

Excerpt: ...anco, filed this action against Defendant, City of Los Angeles (“City”), for injuries and damages arising from a trip and fall on an uneven portion of a sidewalk. The subject sidewalk was controlled by Los Angeles Unified School District (“LAUSD”). Relevant Procedural Background The alleged accident took place on December 19, 2021. Plaintiff presented the City, a governmental entity, with a claim for the incident on May 19, 2022. The clai...

Excerpt: ...d fall on Defendant's premises. Plaintiff filed the operative First Amended Complaint (“FAC”) on July 5, 2023. Plaintiff seeks punitive damages and attorney's fees. On August 25, 2023, Defendant filed this motion to strike punitive damages and attorney's fees from the FAC. The motion is unopposed. II. LEGAL STANDARD FOR MOTION TO STRIKE Any party, within the time allowed to respond to a pleading, may serve and file a motion to strike the whol...

Excerpt: ...d Litem for minor, Darlene Ramirez, and Cesar Ramirez, initiated this medical malpractice action against Defendants, Margaret Juarez, M.D., San Gabriel Women's Health, Inc., and AHMC San Gabriel Valley Medical Center LP (“Settling Defendant”). Plaintiffs allege negligence for a failure to timely deliver Ms. Torres' twins, Darlene and Jayleen, resulting in significant injuries to Darlene and ultimately the death of Jayleen. On July 18, 2023, S...

Excerpt: ...G PARTY: Defendant Los Angeles Metropolitan Transportation Authority RESPONDING PARTY: Plaintiff Donyea Richardson I. BACKGROUND On March 13, 2023, Defendant, Los Angeles Metropolitan Transportation Authority, filed these motions to compel Plaintiff, Donyea Richardson, to provide responses to Defendant's first set of Form Interrogatories, Special Interrogatories, and Demand for Identification and Production and Inspection of Documents. Defendant ...