Excerpt: ...feway Inc.), Kehe Distributors, Inc. (Doe 1), and Jyve Corporation (Doe 2) for damages arising from a boxes falling on Plaintiff while in a grocery store. The Vons Companies, Inc. (“Vons”) and Kehe Distributors, Inc. (“Kehe”) each filed a separate motion for terminating sanctions to dismiss plaintiff Patrick Rayfield's (“Plaintiff”) complaint against them for failure to abide by the Court's March 6, 2024 and March 7, 2024 Orders that ...

Excerpt: ...ources, LLC, and Does 1 to 50 for injuries arising from a motor vehicle collision. Trial is currently set for July 8, 2024. In July 2023, Plaintiff served Tyler Kelleher and Horizon Production Resources, LLC (collectively, “Defendants”). (Proofs of Service, July 12, 2023.). On October 11, 2023, Defendants filed their Answer to Plaintiff's complaint. On March 13, 2024, Plaintiff filed an amendment to complaint naming Foxburg Productions, LLC (...

Excerpt: ...nd Does 1 to 25 for injuries arising from a motor vehicle collision. On August 30, 2023, Plaintiff filed proof of service of the summons and complaint on Defendant, alleging Defendant was served by substituted service on June 26, 2023 at a business address located at 5840 Benner St Apt 208, Los Angeles, CA 90042, by serving “John Doe” described as a 50 year old Caucasian male. On February 13, 2024, Defendant filed the instant motion to quash ...

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: ...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: ...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: ...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: ...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: ...”) 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: ...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: .... 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: ...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...

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: ... 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: ... 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: ...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: ... 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: ...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: ...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: ...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: ...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: ...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: ...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: ...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: ...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: ... 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: ...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: ..., 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: ...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: ...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: ... 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: ...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: ...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: ...“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: ...g from a trip and fall at SoFi stadium. On March 18, 2024, Plaintiff filed the instant motion seeking an order compelling defendant Stadco LA, LLC ("Defendant') to provide further responses to Plaintiffs request for production of documents ("RPDs), sets one and fivo, as to requests nos. 2, 8, 16, 17, 18, 19, and 23. In opposition, Defendant contends Plaintiff received all relevant documents requested at IDC and that Plaintiff did not meet and con...

Excerpt: ...to 50 for damages arising from a motor vehicle accident. Plaintiff filed amendments to complaint naming Raiser LLC as Doe 1, Raiser-CA LLC as Doe 2, and Raiser – DC LLC as Doe 3. Raiser LLC and Raiser -CA LLC (collectively, “Raiser”) now move for terminating sanctions against Plaintiff for failing to serve verified discovery responses in compliance with the Court's February 21, 2024 Order compelling responses to Raiser's Request for Admissi...

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...

Excerpt: ...Defendant”) for damages arising from an automobile incident. The complaint sets forth a single cause of action for negligence. The complaint includes a prayer for punitive damages. Defendant now moves to strike the following from the complaint: (1) Page 2, paragraph 10, lines 21 through 23; (2) page 2, paragraph 11, line 23; and (3) page 4, Prayer for punitive damages, Paragraph 6, line 17. Any opposition was due on or before March 27, 2024; th...

Excerpt: ...Plaintiff”) filed this action against Defendant Kathryn Alverson (“Defendant”) for injuries arising from a motor vehicle incident. Trial is currently set for September 11, 2024. The Court previously granted Defendant's motion to compel Plaintiff's physical examination with neurosurgeon Luke Macyszyn, M.D. (“Dr. Macyszyn”). (Min. Order, March 28, 2024.) Defendant now seeks Plaintiff to submit to a second physical examination with neurolo...

Excerpt: ...y and through his Guardian Ad Litem, Anita Gonzalez (“Plaintiff”) filed this action against defendant Alexander Escalante (“Defendant”) for injuries arising from a motor vehicle v. bicycle incident. Defendant now moves for an order compelling Plaintiff to appear for a second physical examination (“IME”) with neurologist Lorne Label, M.D. (“Dr. Label”) Plaintiff opposes the motion, and Defendant filed a reply. 1. Moving Argument De...

Excerpt: ...nd through his guardian ad litem, Bertha Ramirez, ("Plaintiffs"), individually and as successors in interest to Lucas Obdulio Perez Vicente ("Decedent"), filed this action against defendants 1037 North Sycamore (Los Angeles) Owner, LP. ("1037 North"), CIM Group, L.P. ("CIM Group") and CIM Holdings, LLC ("CIM Holdings") (collectively, "Defendants") for wrongful death arising from work Decedent performed on Defendants' property, in which unsecured ...

Excerpt: ...defendants Los Angeles County Metropolitan Transportation Authority (“LACMTA”) and Anuja Rane (“Rane”) for injuries arising from a March 15, 2022 collision between LACMTA's bus and Rane's motor vehicle (the “Taylor Action”). Taylor alleges he was a passenger on the b us, and that both LACMTA and Rane operated their respective vehicles in an unsafe manner. Rane filed his own action against LACMTA and Jon Paul Jimenez (Doe 1), Case No. ...

Excerpt: ...sign Inc. (“DSD”), Wilmer Rolando Cruz Lopez, and Babken Ovsepian for damages arising out of a motor vehicle accident, specifically when she collided with a Ford F250 carrying concrete. DSD now moves for an order compelling Plaintiff to attend a mental examination with psychologist/neuropsychologist Kyle B. Boone, Ph.D., ABPP-ABCN, (“Dr. Boone”) at 24564 Hawthorne Boulevard, Suite 208, Torrance, CA 90505. Plaintiff opposes the motion, and...

Excerpt: ...automobile incident At this time, State Farm Mutual Automobile Insurance Company ("State Farm") moves for leave to intervene in the case, contendmg it is the automobile insurer for defendant Christian Jonathan Mejia ("Mejia"). State Farm contends it has a direct interest in the litigation due to the insurance policy issued to its insured, Mejia, and that it wnll be required to satis$ any judgment obtained against Mejia. State Farm avers Mejia has...

Excerpt: ...ick Arbuckle ("Arbuckle") for damages arising from an automobile accident.LMafra-Neto and Spencer filed a cross-complaint agamst Arbuckle and Roes 1 to 50 for contribution, indemnity, and declaratory relief. Defendants/cross-complainants Mafra-Neto and Spencer (collectively, "Defendants") now move for an order requirmg Plaintiff to postan undertakmg in the sum of $48,794.70 pursuant to Code Civ. Proc. 5 1030. Plamtiff opposes the motion, and Defe...

Excerpt: ...ant”) for damages arising from an automobile incident. The complaint sets forth two causes of action for (1) motor vehicle negligence and (2) negligence per se. The complaint includes a prayer for punitive damages as to the second cause of action. Defendant now moves to strike the prayer for punitive damages at page 6, line 4, of the complaint. As of March 24, 2024, no opposition was filed. II. MOTION TO STRIKE 1. Procedural Standard Before fil...

Excerpt: ...ng from a motor vehicle accident On January 25, 2024, Plaintiff filed the instant motion moving the Court for an order compelling Moller to provide further responses to Request for Identification and Production of Documents ("RPDs"), set three. More particularly, Plaintiff seeks an order compelling Moller to produce further responses to request no. 60, which seeks Mollers medical records related to injuries suffered from the incident Plaintiff co...

Excerpt: ...Mechanical Contractors, erroneously sued as Pacific Mechanical Contractor, (“PMC”) served (1) form interrogatories, set one, and (2) special interrogatories, set one, on plaintiff Eduardo Galeno (“Plaintiff”) on November 15, 2022. Additionally, PMC served form interrogatories, set two, on Plaintiff on January 27, 2023. After providing Plaintiff with an extension for set one of discovery up to January 13, 2023, Plaintiff did not properly e...

Excerpt: ...defendants Superior Plastering of California, Does 1 to 5 individually and d/b/a Superior Plastering of California, and Does 6 to 100 for damages arising an unsafe work environment in which Plaintiff fell from a scaffolding. Stanley Caron dba Superior Plastering of California, erroneously sued as Superior Plastering of California, filed a First Amended Cross -complaint against S&D Drywall, S&H construction Builder Corporation, and Roes 1 to 50. S...

Excerpt: ...ruma Corporation and Mission Foods for injuries arising from a slip and fall. Trial is currently set for June 11, 2024. Gruma Corporation dba Mission Foods, erroneously sued and served as Gruma Corporation and Mission Foods (“Defendant”) move to continue the trial date and all -related dates by six months to October 11, 2024, or to a date thereafter. Defendant avers that Pla intiff is in agreement with a trial continuance. (Pearlman Decl. at ...

Excerpt: ...efendant”) for injuries arising from a motor vehicle incident. Trial is currently set for September 11, 2024. Defendant now moves to compel Plaintiff's physical examination and requests monetary sanctions. Any opposition to the motion was due by March 15, 2024; no opposition was filed by this date. II. MOTION TO COMPEL PHYSICAL EXAMINATION 1. Legal Standard CCP § 2032.220 states: 1. In any case in which a plaintiff is seeking recovery for pers...

Excerpt: ...ounty 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. Plaintiff opposes the motion, and the City filed a reply. 1. Moving Argument T...

Excerpt: ...ffrey Kai (“Defendants”) for damages arising from an automobile collision.¿ Defendants now move for an order requiring Plaintiff to post an undertaking in the sum of $100,000 pursuant to CCP § 1030. Plaintiff opposes the motion. As of March 20, 2024, no reply has been filed. II. MOTION TO REQUIRE PLAINTIFF TO FILE AN UNDERTAKING 1. Legal Standard In an action or special proceeding brought by a nonresident plaintiff, the defendant may at any...

Excerpt: ...efendants Does 1 to 25 1 for injuries arising from a trip and fall on a pothole in a parking lot. Plaintiff filed amendments to complaint naming Denshaz, Inc. (“Denshaz”) as Doe 1, MJH, LLC as Doe 2, Benjamin Hops as Doe 3, Goodrich And Hops Properties West as Doe 4, Benjamin Hop s50 as Doe 5, Frieda Investments, LLC as Doe 6. On April 26, 2023, Denshaz filed its Answer and a cross -complaint against Goodrich and Hops Properties West, and Roe...

Excerpt: ... Antonio Regla and Antonio's Trucking, Inc. for injuries arising from a motor vehicle incident. The trial date is currently set for September 17, 2024. On March 1, 2024, Plaintiff filed the instant motion to reopen discovery for the limited purpose of expert discovery to track with the current trial date. Defendant Antonio Regla dba Antonio Trucking, erroneously sued and served as Antonio Regla, and Anton io's Trucking, Inc. (“Defendant...

Excerpt: ...pardi ("Defendant") for civil harassment, assault, battery, trespass, and intentional infliction of emotional distress. Defendant now moves for terminating sanctions against Plaintiffto dismiss Plaintiffs action with prejudice for failing to serve verified discovety responses in compliance with the Courts November 16, 2023 Order. In the alternative, Defendant requests issue and/or evidentiary sanctions. Any opposition was due on or before March 1...

Excerpt: ... City”), County of Los Angeles (“the County”), and State of California for an alleged dangerous condition of public property, wherein Plaintiff fell when she rode her bicycle over a non - cross -h atched vertical grate. Plaintiff alleges the non -cross -hatched vertical grate in the bike lane of westbound Florence Ave. near the intersection of Emil Avenue constituted a dangerous condition. (Compl. ¶ 10.) The complaint sets forth a single c...

Excerpt: ...r damages arising from a motor vehicle incident. On November 21, 2021, defendant Linda Rivero served Plaintiff with an offer to compromise per CCP §998 to waive defense costs and defense fees in exchange for dismissal of the action. Plaintiff did not accept the offer. On August 29, 2023, defendant Israel Rivero was dismissed with prejudice. (Order of Dismissal, Aug. 29, 2023.) After multiple trial calls, Plaintiff filed a voluntary request for d...

Excerpt: ...s Cruz, Alvaro Alacon, Uber Technologies, Inc., Rasier LLC, Raiser -CA LLC, and Does 1- 50 for injuries arising from a motor vehicle collision. This matter was consolidated with Tomas Antonio Cruz vs. Alvaro E. Alacon, et al. Case No. 22STCV01166. (Joint Stip. & Ord er, May 21, 2023.) Trial is currently set for May 30, 2024. Defendants Uber Technologies, Inc., Rasier LLC, Raiser -CA LLC (“Uber”) now moves to continue the trial date, and all p...

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: ...Defendant") for damages arising from a motor vehicle incident Trial is currently set for Januaty 27, 2025. Defendant seeks leave to file a First Amended Answer ("FAA") to Plaintiffs complaint to include an amrmative defense based on prelitigation settlement of Plamtiffs claims. The motion was initially denied, without prejudice, due to procedural defects. (Mm. Order, Dec. 13, 2023.) Preliminary, the Court notes that Plaintiff filed a brief opposi...

Excerpt: ...ntiffs”) filed their First Amended Complaint against defendants San Gabriel Transit Inc. (“SGT”), Access Services (“Access”), Los Angeles County Metropolitan Transportation Authority, Steve Ly (“Ly”) and Does 1 through 50 for injuries arising from falling off an alleged moving or malfunctioning vehicle ramp on October 13, 2021. Plaintiff Aline now moves to quash defendant Access's deposition subpoena for production of business recor...

Excerpt: ...fendant”) for injuries arising from a slip and fall on allegedly defective stairs covered in foreign debris and dust. The trial date is currently set for May 17, 20 24. On August 5, 2023, the parties stipulated to continue trial to February 26, 2024 and for all pre - trial discovery and motion deadlines to track with the new trial date. (Stip. & Order, Aug. 5, 2023.) The Court then continued the trial date to May 17, 2024, but denied without pr...

Excerpt: ...ria and Does 1 through 100 for damages arising from a slip and fall on Defendant's property. Plaintiff filed amendments to complaint, naming Brkic Ferdo and Zdenka Trs as Doe 1 and Brkic Ljilj a as Doe 2. Trial is currently set for April 23, 2024. On December 18, 2023, defendants Maria Delgado dba Birrieria Chalio (erroneously named as Chalio Birrieria), Ferdo Brkic, Zdenka Brkic, and Brkic Trust (erroneously sued and served as Brkic Ferdo And Zd...

Excerpt: ...g from a motor vehicle collision. Plamtiff filed an amendment to complaint naming Pedro Ivan Jimenez Aguilera as Doe 1. On October 26, 2023, the Court granted Avis Rent A Car System, LLC leave to intervene in this action. At this time, Plaintiff moves to compel the deposition of Avis Budget Car Rental, LLC's employee Jeanne Motosko ("Motosko") and its employee(s) and/or person(s) most qualified ("PMQ"). Plaintiff requests monetary sanctions. Defe...

Excerpt: ...LLC and Rasier -CA, LLC, Cesar Augusto Campos Orellana and Francisco J. Giron for injuries arising from an automobile incident. At this time, defendants Uber Technologies, Inc., Rasier, LLC and Rasier -CA, LLC (collectively, “Uber”) moves for an order compelling Plaintiff to appear for a mental examination with neuropsychologist Howard J. Friedman, Ph.D., ABPP (“Dr. Friedman”) at 30 3 North Glenoaks Blvd., Suite 200, Burbank, CA 91502. Pl...

Excerpt: ...om a motor vehicle collision. Defendant now moves for terminating sanctions against Plaintiffto dismiss Plamtiffs action with prejudice for failing to serve verified discovety responses in compliance with the Courts November 27, 2023 and November 28, 2023 Orders. Defendant further requests monetary sanctions. Plaintiff is in pro per. Any opposition was due on or before March 7, 2024; none was filed. 11. MOTION FOR TERMINATING SANCTIONS 1. Legal S...

Excerpt: ...s Angeles World Airports ("LAWA") (collectively, "Defendants") for injuries arising from a trip and fall on Defendants' premises. The PAC alleges Plaintiff went to the premises to receive a Covid-19 vaccination shot, when she tripped and fell over an elevated surface mount for a vehicular traffic guidepost while crossing the parking area to the trailer. (FAC at 7. ) Plamtiff alleges the guidepost mount remamed in the direct path from the parking ...

Excerpt: ...ose Baking Inc„ and Mehran Termechi for damages arising out of an automobile v. pedestrian accident At this time, AmGUARD Insurance Company ("AmGUARD") moves for leave to intervene in the case, contending that it is the commercial automobile insurer for Retail Baking LLC. AmGUARD argues it has a direct interest in the litigation due to the insurance policy issued to its insured, Retail Baking LLC, which is currently a suspended corporate entity...