Excerpt: ...”) and Tyler Patrick Whiteman (“Whiteman”) for damages arising from an automobile incident. Plaintiff alleges that on January 22, 2020, Whiteman lost con trol of his vehicle and collided with Plaintiff's vehicle. Plaintiff sets forth a cause of action for liability of public entities and public employees pursuant to Gov. Code section 815.2 and 820. Plaintiff moves to compel the City to produce medical employment records of Whiteman related ...

Excerpt: ...item Jesse Ronald Carrasco, (“Plaintiff Carrasco”) propounded set one of form interrogatories, special interrogatories, and request for production of documents on defendant Becky Radgowski (“Defendan t Becky”) on December 27, 2023. To date, Defendant Becky has not served responses. Plaintiff Carrasco therefore seeks an order compelling Defendant Becky to respond, without objections, to the outstanding discovery and to pay sanctions. Defen...

Excerpt: ...ndo Cazares (“Cazares”), Fidel Calderon, Cazares Services LLC (Doe 1), Thomas Franklin Henry (Doe 2), and Orchids de Oro, Inc. (Doe 3) for damages arising from a motor vehicle incident. On April 2, 2024, Cazares filed the instant motion for terminating sanctions to dismiss plaintiff Marina Ruiz's (“Plaintiff Ruiz”) complaint against them for failure to abide by the Court's January 26, 2024 Order that she serve verified responses to form i...

Excerpt: ...bry (“Plaintiff”) to appear for his deposition and to pay monetary sanctions. On June 14, 2023, Defendants noticed Plaintiff's deposition for September 22, 2023. The deposition was taken off -calendar in order for the parties to meet and confer regarding Plaintiff's written discovery responses. Defense counsel emailed to propose new dates to take Plaintiff's deposition, and after not hearing from Plaintiff's counsel, Defendants served a secon...

Excerpt: ...) ( collectively, “Plaintiffs”) filed this action against defendant Julien Brunet (“Defendant”) and Does 1 -15 for damages arising from a motor vehicle accident. Defendant now moves for terminating sanctions against Plaintiffs for failing to serve verified discovery responses in compliance with the Court's February 7, 2024 Order pertaining to Defendant's motions to compel discovery responses. Plaintiffs are in pro per. Defendant filed a c...

Excerpt: ...City of LA”), City of Calabasas, and Does 1 through 100 for injuries arising from a slip and fall. Plaintiff alleges she was riding her bicycle on July 22, 2020 on Valmar Road at or near the intersection with Brenford Street when her bicycle slid on the water and algae in the street, causing her to fall and sustain injury. (FAC at ¶ 11.) Plaintiff sets forth two causes of action for (1) dangerous co ndition of public property against all defen...

Excerpt: ...t defendants Raul Sanchez Ortiz, Maria Gonzalez de Sanchez, Raul Sanchez, Jr. (Doe 1), and Does 2 to 10 for injuries arising from a December 4, 2021 motor vehicle collision. On January 30, 2023, defendants Ortiz, Gonzalez de Sanchez, and Raul Sanchez, Jr. (Doe 1) (collectively, “Defendants”) filed their Answer to the complaint. Defendants simultaneously filed a cross -complaint against Plaintiff and Roes 1 -25 for (1) declarator y relief, (3)...

Excerpt: ...2) special interrogatories, set one, and (3) demand for identification and inspection of documents, set one, on plaintiff Martha Melgar ("Plaintiff Melgar") on October 25, 2023. After sending a meet and confer letter regarding the lack of responses, Plaintiff Melgar has failed to serve responses to date. Defendant therefore seeks an order compelling her to respond, without objections, to the outstanding discovery and to pay sanctions. Plaintiff M...

Excerpt: .... On January 31, 2024, Plaintiff filed a proof of service showing Defendant was served with the Summons and Complaint by substituted service on January 26, 2024. Plaintiff's registered process server served Defendant's co -occupant “Sara Lobos” mailbox at 18 718 Ambler Ave, Carson, CA 90746 - 2125 (the “Residence”) and mailed the Summons and Complaint to the same address. Defendant discovered the Summons and Complaint in his mailbox on Ja...

Excerpt: ...Jorge Giraffe and Does 1 to 50 for injuries arising from a motor vehicle collision. On March 23, 2022, Plaintiff filed an amendment to complaint naming George Graf (“Graf”) as Doe 1. On July 7, 2022, Graf filed his Answer to Plaintiff's complaint. On February 20, 2024, Plaintiff now seeks leave to file a First Amended Complaint (“FAC”) to correct a typographical error on the case caption. Plaintiff argues the Doe amendment to add Graf was...

Excerpt: ...ainst defendants the Ci5r of Los Angeles ("the Ciöf') and Does 1 to 50 for damages arising from a trip and fall on a sidewalk Plaintiff filed amendments to complaint naming Letha Jones as Doe 2. Letha lones ("Jones") filed an Answer in pro per on July 5, 2023. Jones, now represented by counsel, seeks leave to file a First Amended Answer ("FAA") to Plaintiffs complaint to include affirmative defenses not previously pleaded due to the lack of assi...

Excerpt: ...es 1 to 50 for injuries arising from a motor vehicle incident On March 28, 2022, Alverson filed an Answer to Plaintiffs complaint and filed a cross-complaint agamst Roes 1 to 25 for (1) equitable indemnity, (2) contribution, (3) express indemnity, and (4) declaratoty relief. On Januaty 27, 2023, Alverson filed amendments to the cross-complaint naming the City of Los Angeles as Roe 1 and Roberto Sandoval ("Sandoval M) as Roe 2. Sandoval now demurs...

Excerpt: ...gh 100 for damages arising from an alleged dangerous condition of public property. Plaintiff filed amendments to complaint, naming Los Angeles Department of Wa ter & Power as Doe 1, Northwest Excavating, Inc. (“Northwest”) as Doe 2, Skansa, Inc. as Doe 3, Skansa USA, Inc. as Doe 4, and Regional Connector Constructors, Inc. (“RCC”) as Doe 5. RCC filed its Answer to Plaintiff's complaint on December 5, 2022. RCC now seeks leave to file a cr...

Excerpt: ...arising from an automobile collision. On October 9, 2023, Plaintiff filed a Notice of Settlement of Entire Case providing the parties entered into a conditional settlement upon receipt of settlement funds. Plaintiff now moves for an order to enforce settlement agreement pursuant to CCP § 664.6. Defendant opposes the motion, and Plaintiff filed a reply. 1. Moving Argument Plaintiff argues the parties participated in mediation, and after transmiss...

Excerpt: ... served as Trader Joe's East, Inc. and 10850 National Boulevard d.b.a. Trader Joe's) propounded form interrogatories, set two, and requests for admissions (“RFAs”), set one, on Plaintiff Mandana Mizrahi (“Plaintiff”) on November 3, 202 3. As of the date of Trader Joe's Company filing the instant motion, Plaintiff has not served responses. Trader Joe's Company therefore seeks an order to compel responses to the outstanding discovery, in ad...

Excerpt: ...efendants") for damages arising from an automobile accident Defendants now move to compel non-party Pacific MRI to produce its custodian of records for deposition, and to produce documents pursuant to a deposition subpoena sewed. Defendants further request monetary sanctions against Pacific MRI. Any opposition was due on or before April 16, 2024; the motion is unopposed. 11. MOTION TO COMPEL DEPOSITION (NON-PARTY) 1. Procedural Per CRC 3.1346, wh...

Excerpt: ... Manager, and Does 1 to 10 for injuries arising from a slip and fall on a wet floor because Doe Manager was pouring water onto the floor. Home Depot now moves for a Protective Order to prevent Plaintiff from taking the depositions of Julio Monzon (“Monzon”) and Michael Lewis (“Lewis”). Plaintiff opposes the motion, and Home Depot filed a reply. 1. Moving Argument Home Depot avers that its employees Monzon and Lewis were investigating mana...

Excerpt: ... damages arising from a motor vehicle incident. On July 28, 2023, this matter was called for non -jury trial. After no appearances or contact by either party, Plaintiff's complaint was dismissed without prejudice. (Min. Order, July 28, 2023.) On January 29, 2024, Plaintiff filed the instant motion to set aside the dismissal. II. MOTION TO SET ASIDE 1. Legal Standard Code Civ. Proc. (“CCP”) § 473 provides for both discretionary and mandatory ...

Excerpt: ...rtainment LLC, et al. for damages arising from a trip and fall at SoFi stadium. Defendants Kroenke Sports & Entertainment LLC; Stadco LA, LLC; Pincay RE, LLC; and Chargers Football Company, LLC filed their motion for summary judgment/adjudication as to Plaintiff's operative complaint. The hearing on the motion is set for April 26, 202 4. Defendant Contemporary Services Corporation filed its separate motion for summary judgment against Plaintiff's...

Excerpt: ...25 Century Park East Company, et al. for damages related to premises liability. On March 15, 2023, Plaintiff filed proof of service of the summons and complaint on defendant Pocrass & De Los Reyes, LLP (“P&D”), alleging P&D was personally served via its authorized agent for service of process James Pocrass (“Pocrass”) on May 7, 2022, at the address 1880 Century Park East, Suite 1415, Los Angeles, California 90067. On March 15, 2023, Plain...

Excerpt: ...ollectively, “Defendants”) for injuries arising from a motor vehicle collision. The trial date is currently set for October 24, 2024. Defendants now move to continue the current trial date and all related dates to June 24, 2025 to allow their motion for summary judgment (“MSJ”), currently reserved for December 10, 2024, to be heard prior to trial. The motion is unopposed. II. LEGAL STANDARD Although continuances of trials are disfavored, ...

Excerpt: ...County of Los Angeles, State of California, Cherry Street Garage, Los Angeles Convention Center, Staples Center for a slip and fall incident. At this time, the City moves for an order compelling Plaintiff to appear for a mental examination with neuropsychologist Earl C. Thorndyke, Ph.D., (“Dr. Thorndyke”) at 11835 W. Olympic Blvd., Ste. 1270E, Los Angeles, CA 90064. The City argues Plaintiff testified at deposition that she attributes PTSD, a...

Excerpt: ...nd Romaine Kirlew for injuries arising from an automobile collision. On February 26, 2024, the Court granted Plaintiff's motion to compel further, and ordered Hertz to serve further responses to Plaintiff's request for production of documents, set one, as to request nos. 5 and 7. (Min. Order, Feb. 26, 2024.) Further, the Co urt granted Plaintiff's request for sanctions and ordered Hertz and/or its counsel, jointly and severally, to pay Plaintiff ...

Excerpt: ... Burbank Senior Villa West ("LBC"), Burbank Senior Villa West, Trion Solutions Inc. Orion"), Kornland Building, and Paul Lawrence Dunbar Haney IV ("Haney") for wrongful death (Labor Code 53601) and premises liability. Plaintiffs, the parents of decedent Moncerrat Vargas ("Decedent'), allege Decedent was an employee of LBC/Trion/ Burbank Senior Villa West. After Haney was terminated from his employment with defendants, Haney stabbed Decedent when ...

Excerpt: ...h his guardian ad litem Nicholas Vinovich, (“Plaintiff”) filed this action against defendants, Thirty – First District PTSA – Creative Kids (“Creative Kids”), Los Angeles Unified School District (“LAUSD”) and Does 1 to 50 for injuries arising from allegations of negligent supervision. The complaint alleges that Plaintiff was participating in a sponsored school activity at Chatsworth Park when Plaintiff wandered off alone outside t...

Excerpt: ...Burbank Senior Villa West ("LBC"), Burbank Senior Villa West, Trion Solutions Inc. Orion"), Kornland Building, and Paul Lawrence Dunbar Haney IV ("Haney") for wrongful death (Labor Code 53601) and premises liability. Plaintiffs, the parents of decedent Moncerrat Vargas ("Decedent'), allege Decedent was an employee of LBC/Trion/ Burbank Senior Villa West. After Haney was terminated from his employment with defendants, Haney stabbed Decedent when D...

Excerpt: ...efendants") for damages arising from an automobile accident Defendants now move to compel non-party SoCal Imaging to produce its custodian of records for deposition, and to produce documents pursuant to a deposition subpoena served. Defendants further request monetary sanctions against SoCal Imaging. Any opposition was due on or before April 11, 2024; the motion is unopposed. 11. MOTION TO COMPEL DEPOSITION (NON-PARTY) 1. Procedural Per CRC 3.134...

Excerpt: ...ely, “Plaintiffs”) filed this action against defendants Dr. Robert Khorramian, Dr. Ellie Goldstein, and The Rehabilitation Centre of Beverly Hills (“the Centre”) for wrongful death ari sing from allegations of medical malpractice. On February 26, 2024, the Centre filed an application for good faith settlement, in addition to the instant motion for determination of good faith settlement between it and Plaintiffs. As of April 11, 2024, the ...

Excerpt: ...ogatories, and request for production of documents, set one, on plaintiffs Monica Garcia and Genaro Santillian (collectively, "Plaintiffs") on November 21, 2023. The responses were due on December 26, 2023. However, as of the motion filing date, Plaintiffs have not served responses. Defendant therefore seeks an order compelling Plaintiffs to respond, without objections, to the outstandmg discovery and to pay sanctions. In opposition, Plaintiffs c...

Excerpt: ...roduction of documents on plaintiff Dwayne Flowers (“Plaintiff”) on May 2, 2023 1. To date, Plaintiff has not served responses. Defendant therefore seeks an order compelling defendant Plaintiff to respond, without objections, to the outstanding discovery and to pay sanctions. In opposition, Plaintiff's counsel submits a request for a continuance on the motions to compel on the grounds that Plaintiff's counsel is unable to ascertain the status...

Excerpt: ...on against defendant Manfield and Associates ("Defendant') for injuries arising from a slip and fall on allegedly defective stairs covered in foreign debris and dust Plaintiff now seeks to strike Defendants orthopedic experts on the grounds that it is cumulative. Defendant opposes the motion, and Plaintiff filed a reply. Defendant also filed a motion for leave to amend/augment its expert witness designation. The Court had advanced the hearing to ...

Excerpt: ...o pay monetary sanctions. On January 19, 2024, Garcia noticed Plaintiff's deposition for February 1, 2024. Garcia's counsel enclosed in the letter that Plaintiff is to provide alternative dates if Plaintiff is not available, and that the deposition will not be taken off -calendar ab sent notification of alternative dates for February 2024. On January 31, 2024, Garcia's counsel sought to confirm the deposition date, and Plaintiff's counsel respond...

Excerpt: ...��Plaintiffs”) filed a First Amended Complaint (“FAC”) against defendants Vista General Engineering Company Inc. (“Vista”), Arturo Orozco Torres (“Torres”), and Does 1 to 10 for damages arising from a motor vehicle accident that occurred on August 24, 2018. The FAC sets forth four causes of action for (1) motor vehicle negligence, (2) general negligence, and (3) negligence per se, and (4) loss of consortium against all defendants. V...

Excerpt: ...ffs") each a separate set of (1) form interrogatories, set one, (2) special interrogatories, set one, and (3) request for production of documents ("RPDs"), set one, on November 2, 2023. Responses were initially due on December 5, 2023. After receiving no responses, defense counsel sent email correspondence to Plaintiffs counsel requesting status of the discovety. Defendant granted Plaintiffs an extension to respond to discovery by December 21, 20...

Excerpt: ...ey Occupational Center and Does 1 through 100 for injuries arising from a slip and fall on slippery yellow traction plates. The operative Second Amended Complaint (“SAC”) sets forth three causes of action for (1) negligence – against Does 1 through 100, (2) premises liability ag ainst Does 1-100, and (3) dangerous condition of public property pursuant to Gov. Code § 835 against West Valley Occupational Center – Los Angeles Unified School...

Excerpt: ...havez (collectively, “Plaintiffs”) filed this action against defendants, Daniel Chan (“Chan”), Chanchenda Hou, Chanvachana Hou, Doe Attacker, and Does 1 to 20 for injuries arising from a shooting by Doe Attacker. Plaintiffs set collectively set forth three causes of action for: (1) general negligence against Chan, Chanchenda Hou and Chanvachana Hou, Doe Attacker, and Does 1 to 20, (2) intentional tort against Doe Attacker and Does 1 to 20...

Excerpt: ...is action against defendant George Anderson and Does 1 to 50 for damages arising from a motor vehicle collision. Plaintiff filed an amendment to complaint naming Karo Vartanian as Doe 1. George Anderson and Karo Vartanian (“Defendants”) now move for evidentiary and issue sanctions against Plaintiff for failing to appear for neurological examination in violation of the Court's October 26, 2023 Order. On October 26, 2023, the Court ordered P la...

Excerpt: ... for injuries arising from Plamtifffalling off a ladder. Plamtiff filed an amendment to complaint naming Shahe Terjimanian as Doe 1, At this time, Plaintiff seek leave to file a First Amended Complaint ("PAC") to add a third cause of action for Uninsured Employer & Negligence Pursuant to California labor Code 3700 & 3706, and fourth cause of action for negligence per se, in addition to seeking damages. Anahid Terjlmanian and Shahe Terjimanian ("D...

Excerpt: ...ng from an automobile collision. Defendant Cody Yaraghchi, erroneously sued and served as Cody Araghachi, (“Yaraghchi”) now moves for terminating sanctions against Plaintiff Grey to dismiss her action on the grounds that she failed to abide by the Court's September 19, 2023 Order to appea r for her deposition. Defendants Uber Technologies, Inc., Rasier, LLC and Rasier -CA, LLC (“Uber Defendants”) join the motion. Plaintiff Grey opposes Ya...

Excerpt: ...y Lee Smithers ("Defendants") for damages arising from a motor vehicle collision. Defendants now move to compel the deposition of non-party Gagandeep Singh ("Singh"), who is the person most knowledgeable ("PMC) at Diamond Sea, Inc. Defendants asserts they served Singh with a valid deposition subpoena that required Singh to appear for his deposition on November 29, 2023, but Singh did not appear for his deposition. The motion is unopposed. 11. MOT...

Excerpt: ..., 2023. After granting Plaintiff Brown an extension to provide responses by January 15, 2024, Plaintiff has failed to serve responses to date despite several follow-up correspondences by defense counsel. Defendant therefore seeks an order compelling Plaintiff Brown to respond, without objections, to the outstanding discovery and to pay sanctions. Any opposition was due on or before April 5, 2024; the motion is unopposed. 11. MOTION TO COMPEL For ...

Excerpt: ...g Plaintiff Brown an extension to provide responses by January 15, 2024, Plaintiff has failed to sewe responses to date despite defense counsel sending several follow-up correspondences. Defendant therefore seeks an order compelling Plaintiff Brown to respond, without objections, to the outstanding discovety and to pay sanctions. Any opposition was due on or before April 4, 2024; the motion is unopposed. 11. MOTION TO COMPEL For a motion to compe...

Excerpt: ...d Daniel Ramirez (“Ramirez”) for damages arising from a dog bite incident. The complaint sets forth two causes of action for general negligence and strict liability. The complaint includes a prayer for punitive damages. Defendant Mehrdad Azizi, erroneously sued as Michael Azizi, (“Azizi”) moves to strike the prayer for punitive damages. Plaintiff opposes the motion, and Azizi filed a reply. II. MOTION TO STRIKE 1. Procedural Standard Befo...

Excerpt: ...d Haghighat Family Trust, and Does 1 to 50 for injuries arising from a metal gate coming off the rail, which caused Plaintiff to fall backwards on concrete. On September 6, 2022, Plaintiff filed amendments to complaint correcting the name of defendants Daria Trs to Daria Haghighat, Trustee of The Haghighat Family Trust, and correcting the name Hooshang Haghighat to Hooshang Haghighat, Trustee of the Haghighat Family Trust. F urther, dismissal was...

Excerpt: ...BS Group, and Radford Studio Center, Inc. for injuries arising from the delivery and unloading of steel beams to the premises located at 4024 Radford Avenue, Studio City, wherein the steel beams fell on Plaintiff. (Compl. at 14.) The complaint sets forth against all defendants two causes of action for (1) negligence and (2) premises liability. Defendant Norman Industrial Materials dba Industrial Metal Supply, Inc. ("IMS") now moves for summary ju...

Excerpt: ...tiffs”) filed this action against defendant Anthony Dwain Stanford (“Defendant”) for damages arising out of a motor vehicle accident. Defendant now moves for an order for leave to conduct a neuropsychological examination of Plaintiff Marena with George K. Henry, Ph.D./ABPP -CN (“Dr. Henry”) at 11601 Wilshire Blvd., 5th floor, Los Angeles, California 90025. Defendant avers that the parties do not dispute that Plaintiff Marena has placed ...

Excerpt: ...t one, on plaintiff Saeid Saghian (“Plaintiff”) on December 18, 2023. After receiving no responses, defense counsel sent email correspondence request ing responses on or before January 31, 2024. Plaintiff has failed to serve responses to date. Defendant therefore seeks an order compelling Plaintiff to respond, without objections, to the outstanding discovery and to pay sanctions. Any opposition was due on or before April 2, 2024; the motion i...

Excerpt: ... Grocery ("Mini Maro for damages arising from a motor vehicle accident that occurred on February 21, 2020. The complaint sets forth two causes of action for general negligence and motor vehicle negligence against all defendants. Mmi Mart now moves for judgment on the pleadings on the grounds that Plaintiffs complaint does not state sufficient facts to constitute a cause of action against it Plaintiff opposes the motion. Any reply was due on or be...

Excerpt: ...“Dang”), State of California, California State University, California State University of Northridge, CSU- Northridge, and Does 1 to 50 for damages arising from an automobile collision. Trial is currently set for May 23, 2024. Plaintiff now moves to reopen discovery for the limited purpose of conducting defendant Dang's deposition. Defendants Board of Trustees of the California State University (erroneously sued as “State of California, Cal...

Excerpt: ... against defendants Allied Universal Security Services Universal Protection Services LPP and White Memorial Medical Center (“WMMC”) for damages arising from security removing Plaintiff from the premises. The complaint sets forth four causes of action for (1) assault, (2) batt ery, (3) negligence, and (4) negligent hiring, retention, supervision and training. Defendant Allied Protection Service, LP dba Allied Universal Security Services Univer...