Excerpt: ...request for production of documents ("RPDs"), set one, on November 9, 2023. Responses were due on December 11, 2023. Denshaz's counsel sent correspondence to MJH's counsel on several occasions, which did not yield any responses. Denshaz avers that MJH has not provided any responses to date. Denshaz therefore seeks an order compelling MJH to respond, without objections, to the outstanding discovery and to pay sanctions. In opposition, MJH's counse...

Excerpt: ..."Plaintiff') filed this action against defendants County of Los Angeles ("the County"), City of Los Angeles ("the City"), Richard Ho ("Ho"), and Does 1 to 50 for damages arising from a trip and fall over an uneven and raised sidewalk. Plaintiff alleges that on December 20, 2020, he was riding his bicycle on the sidewalk of Tulsa Street when he tripped and fell on a part ofthe sidewalk located at 16854 Tulsa Street, Granada Hills, CA 91344. Plaint...

Excerpt: ...ogatories, set one, and (3) request for production of documents ("RPDs"), set one, on February 5, 2023. (Cook Decl. 2-4; Exhs. A-C.) Responses were due on January 8, 2024. (Ibid.) After receiving no responses, defense counsel sent email correspondence to Plaintiffs counsel regarding the outstanding discovery. (ld. at 5.) To date, Plaintiff did not respond to defense counsel's letter nor has Plaintiff served responses to the written discovery. (ld...

Excerpt: ... and Does 1 to 20 for injuries arising from a motor vehicle collision. Trial is currently set for May 28, 2024. On April 9, 2024, the City of Los Angeles (“Defendant”) filed the instant motion to continue the trial date and all related dates by 90 days. As of April 25, 2024, no opposition has been filed. II. MOTION TO CONTINUE TRIAL 1. Legal Standard Although continuances of trials are disfavored, each request for a continuance must be consid...

Excerpt: ...plaintiff Matthew Davenport ("Plaintiff). Uang Decl. 4; Exh. A.) Responses were due on or before January 10, 2023. (Ibid.) To date, Plamtiffhas not sewed responses. (ld. at 7.) Defendant now moves the Court for an order compelling Plaintiff to provide responses to the outstanding discovery and to pay sanctions. As of April 25, 2024, no opposition has been filed. 11. MOTION TO COMPEL SUPPLEMENTAL DISCOVERY A party may propound a supplemental inter...

Excerpt: ...mages arising from a motor vehicle incident. Defendant seeks the production of business records from VA Long Beach Healthcare System (“VA Long Beach”). Plaintiff testified he received treatment at VA Long Beach for injuries arising from the incident. Defendant served VA Long Beach through Defendant's subpoena vendor, seeking: “[Any and all documents and medical records pertaining to the examination, care, diagnosis, and treatment of the pat...

Excerpt: ...("Defendant") propounded on plaintiff Katherine Brown ("Plaintiff') request for production of documents ("RPDs), set tv.ro, on September 26, 2023. (Grannis Decl. 6.) After having granted an extension, and receiving no response, Plaintiff then sewed unverified responses. Plaintiff agreed to comply and produce documents in response to Requests Nos. 2 7 to 30 contained in RPDs, set tv.ro, but no documents have yet to be produced. Defense counsel wro...

Excerpt: ...usan Sherayko, and Caravan West Productions, LLC (collectively, “Defendants”) for injuries Plaintiff sustained while working as a hired actor and riding a horse for the filming of a movie. Defendants seek leave to file a First Amended Answer (“FAA”) to Plaintiff's complaint to include a tenth affirmative defense of workers' compensation exclusive remedy. Defendants argue Plaintiff's complaint raises the issue of the worker's compensation ...

Excerpt: ...e City”) for damages arising out of a trip and fall over a displaced section of a concrete walkway. The initial complaint alleged a single cause of action for prem ises liability. On March 7, 2024, the Court granted the City's motion for judgment on the pleadings with leave to amend to provide Plaintiff the opportunity to allege statutory authority for her claims against a public entity. (Min. Order, March 7, 2024.) Plaintiff was ordered to fil...

Excerpt: ...16, 2024, Plaintiff sewed responses to Defendants other first set of propounded discovety, but did not serve responses to the demand for production of documents. (ld. at 4.) On Februaty 9, 2024, defense counsel requested responses, without objection, no later than February 23, 2024. (ld. at 7.) To date, no responses to Defendant's demand for production of documents, set one, have been sewed. (ld. at 8.) Defendant therefore seeks an order compelli...

Excerpt: ...r damages arising from a fall from a defective ladder. On March 18, 2024, defendant Hawthorn Regency Apartments, LLC (sued as Hawthorne Regency) (“Defendant”) filed the instant motion for terminating sanctions to dismiss Plaintiff's complaint against it for failure to abide by the Court's February 22, 2024 Ord er that he serve verified responses to its set one of form interrogatories, special interrogatories, and request for production of doc...

Excerpt: ...Jose Jesus Sierra III, and Jessica Sierra (collectively, “Plaintiffs”) filed this action against defendants City of Los Angeles, County of Los Angeles, State of California, Savannah Lee Johnson, Elecnor Belco Electric, Inc., Elecnor, Inc., The Roman Catholic Archbishop of Los Angeles, and Does 1 to 50 for injuries arising from a motor vehicle collision. The trial date is currently set for September 10, 2024. On October 23, 2023, Plaintiffs fi...

Excerpt: ...ts William Randolph Fry (“Fry”), Gitibin & Associates, Inc., and Does 1 to 50 for damages arising from an automobile collision. Trial is currently set for November 12, 2024. Defendant Fry now moves to reopen discovery for the limited purpose of conducting Plaintiff's physical examination, which had been noticed prior to the discovery cut- off date. Plaintiff opposes the motion, and Fry filed a reply. II. MOTION TO REOPEN DISCOVERY CCP § 2024...

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: ...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: ...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: .... 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: ...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: ...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...