Excerpt: ...agid aka Roberta A. Magid and Gregory Philip Segal (“Defendants”) propounded requests for admissions (“RFAs”), set one, on pro per Plaintiff Elis Ismael Castro (“Plaintiff”) on February 1, 2023 by mail. (Mot. Decl. Aloyan ¶ 4; Exh. A.) Responses were due on or before March 8, 2023. (Ibid.) To date, Plaintiff has not responded to Defendants' meet and confer letter or served responses. (Id. at ¶ 5.) The RFAs were mailed to Plaintiff's...

Excerpt: ... Defendants, M-4 Apartments, L.P. (“M-4”), 13119 Moorpark, L.P. (“13119 Moorpark”), Valley Meadow Investments, LLC (“Valley Meadow”), Larr Investments, L.P. (“Larr”), Roger D. Friedman, and Linda A. Friedman, for failure to remedy uninhabitable conditions due to water intrusions in Plaintiffs' rental unit. On November 15, 2023, Plaintiffs filed the operative First Amended Complaint (“FAC”) against Defendants for the following ...

Excerpt: ...��) and Does 1-20 for injuries arising from an alleged pothole/gap in the road. Plaintiff alleges he was riding his bicycle down Coldwater Canyon Drive when his bicycle ran into a pothole/gap in the road, causing him to crash his bicycle and sustain injuries on August 21, 2020. (FAC at ¶ 9.) Plaintiff sets forth a single cause of action for dangerous condition of public property (Gov. Code § 835). The City now moves for summary judgment. Plaint...

Excerpt: ...otion to Compel Defendant Cynthia Davoodian ("Defendant”) propounded form interrogatories, set two, on Plaintiff Maikel Zehavi (“Plaintiff”) on January 23, 2023. After receiving no response, on March 10, 2023, defense counsel sent a letter to Plaintiff's counsel requesting verified responses to discovery. On March 10, 2023, Plaintiff's counsel requested a copy of the discovery be resent, which defense counsel provided. Plaintiff has not ser...

Excerpt: ...action against Defendant Los Angeles County Metropolitan Transportation Authority (“Defendant”) for injuries arising from a bus v. motor vehicle incident. Plaintiff alleges Defendant's bus attempted to merge into traffic without use of a turn signal, and collided with Plaintiff's vehicle. Plaintiff now moves to compel Defendant to produce documents to Plaintiff's demand for production of documents with the deposition notice of Defendant's bus...

Excerpt: ...”), Dylan Sellers (“Dylan”), and the City of Santa Monica (the “City”) for damages arising from a motor vehicle vs. pedestrian accident. Plaintiff alleges that on July 23, 2021, Lily was operating a motor vehicle owned by Dylan, when she struck Plaintiff while Plaintiff was crossing the street in a marked crosswalk. Plaintiff alleges the City failed to maintain the crosswalk and created a dangerous condition of public property. On Decem...

Excerpt: ...dants Teresa Montes De Oca and Robert Martinez for damages arising from a fall over an alleged dangerous condition. Trial is currently set for November 18, 2024. At this time, Plaintiff seeks leave to file a First Amended Complaint (“FAC”) to assert causes of action for Breach of Statutory Obligation, Negligent Exercise of Retained Control, Negligence, and Premises Liability. The motion is unopposed. The motion was previously heard on Decembe...

Excerpt: ... (“City”) for injuries relating to Plaintiff's trip and fall on a broken upraised sidewalk located on the north sidewalk of Moorpark St. approaching Beeman Ave. The complaint alleges causes of action for general negligence and premises liability. Preliminary, the City filed its Answer to Plaintiff's complaint on July 23, 2020. However, after the Court set a trial date and without obtaining leave of the Court, on June 8, 2021, the City filed a...

Excerpt: ...s action against Defendants Eduar's Construction and 314 Rowland, LLC (“Defendants”) for damages arising from a slip and fall. On April 13, 2022, Plaintiff obtained Defendants' default. On April 18, 2022, Defendants' filed their Answer to Plaintiff's complaint. On June 30, 2023, Defendants filed the instant motion to set aside the default on the grounds of equitable relief, averring that they did not realize they were in default at the time t...

Excerpt: ...geles, and Jilk Heavy Construction, Inc. for damages arising from a trip and fall on a sidewalk. Plaintiff dismissed the County of Los Angeles. Defendants City of Los Angeles (“City”) and Jilk Heavy Construction, Inc. (“Jilk”) (collectively, “Defendants”) now move for terminating sanctions against Plaintiff to dismiss Plaintiff's complaint, or in the alternative, evidentiary sanctions to preclude certain witnesses from testifying at t...

Excerpt: ...ty of Los Angeles, and State of California for an alleged dangerous condition of public property, wherein Plaintiff fell when she rode her bicycle over a non-cross-hatched 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.) Plaintiff filed amendments to complaint, naming the City of Los Angeles as ...

Excerpt: ...ued as Bermuda Manufactured Home Park, (“Defendant”) moves to compel Plaintiff Aida Brackens (“Plaintiff”) to appear for her deposition and to pay monetary sanctions. Defendant noticed Plaintiff's deposition for February 3, 2023. Plaintiff did not object to the deposition notice, and the day before the deposition date, defense counsel attempted to contact Plaintiff's counsel regarding whether Plaintiff would appear. Plaintiff's counsel re...

Excerpt: ...ir Agaliyev (“Defendant”). Defendant opposes the motion. As of December 14, 2023, no reply was filed. CCP § 2025.450(a) provides, “If, after service of a deposition notice, a party to the action or an officer, director, managing agent, or employee of a party, or a person designated by an organization that is a party under Section 2025.230, without having served a valid objection under Section 2025.410, fails to appear for examination, or t...

Excerpt: ...on against Defendant R-Ranch Market, Inc. dba Bodega “R” Ranch for damages arising from a slip and fall on a foreign substance on the floor. Default was entered on May 5, 2023, and default judgment entered on August 25, 2023. On October 26, 2023, Defendant HAFSA Corporation dba R-Ranch Market, erroneously sued as R-Ranch Market, Inc. dba Bodega “R” Ranch, (“Defendant”) filed the instant motion to set aside the default and default judg...

Excerpt: ...ges arising from a dog bite. On July 31, 2018, Blanca Schlup (“Schlup”) and Martha Bautista (“Bautista”) filed a cross-complaint against Jack Colocho, Denise Colocho, and Catalina Colocho. On March 30, 2021, Plaintiff settled with defendants Schlup and Bautista. Plaintiff dismissed Schlup, Bautista, and all unnamed Doe Defendants. On October 11, 2023, Schlup and Bautista (collectively, “Cross-Complainants”) moved to set aside default ...

Excerpt: ...laint (“SAC”) against Defendants Nicolas Jacobi (“Jacobi”), The Turning Guide (“TTG”), and Howard Tyrone Ferguson (“Ferguson”) (collectively, “Defendants”) for damages arising from a motor vehicle accident. Plaintiff alleges Jacobi suffers from epilepsy and while driving, Jacobi blacked out and lost control of his vehicle. At the time, Plaintiff was a backseat passenger in Jacobi's vehicle. Jacobi's vehicle then struck a tour ...

Excerpt: ...Dyer (“Defendant”) for damages arising from a July 3, 2021 automobile collision. The complaint alleges that Defendant left an unattended vehicle blocking the lane without warning or taillights on, causing the collision. (Compl. at p. 4.) Defendant, at this time, seeks to quash a deposition subpoena and subpoena for production of business records issued by Plaintiff to M. Constance Calvin (“Calvin”)/California Highway Patrol (“CHP”). P...

Excerpt: ...ainst Defendant Golf & Tennis Management, Inc. dba Westlake Golf Course for damages arising from an alleged off-centered wheel stop on a parking lot. The complaint alleges causes of action for general negligence and premises liability. Plaintiff alleges the wheel stop was near the dirt path close to the driving range used by persons to enter and exit that general location, and that the off-centered wheel stop created a dangerous condition. (Compl...

Excerpt: ...t Defendants City of Los Angeles, County of Los Angeles, Kingsley Project, LLC, SAC-MM Properties LLC for damages arising from a trip and fall on a sidewalk. Trial is currently set for September 24, 2024. At this time, Plaintiff seeks leave to file a First Amended Complaint (“FAC”) to correct the alleged location of the incident. The motion is unopposed. Initially, this matter was set to be heard on December 4, 2023. However, the Court briefl...

Excerpt: ... his Guardian ad Litem, Gregory Gray (“Plaintiff”) filed his First Amended Complaint (“FAC”) action against Defendants City of Rancho Palos Verdes, City of Rolling Hills Estates, and Palos Verdes Peninsula Unified School District (“District”) for injuries caused by a sidewalk, which Plaintiff alleges ejected him from his bicycle and caused injury on September 26, 2020. The District, a public entity, now demurs to Plaintiff's FAC, argu...

Excerpt: ...rking Concepts, Inc. for damages arising from a trip and fall on a concrete parking block. Plaintiff filed an amendment to complaint naming CA-Lats South, LLC (“CA-Lats”) as Doe 1. Plaintiff now moves for relief from the waiver of its objections to discovery propounded by CA- Lats. Plaintiff avers that her untimely responses to CA-Lats' set one of form interrogatories, special interrogatories, request for admissions (“RFAs”), and request ...

Excerpt: ...rising from an automobile collision. The complaint alleges a single cause of action for general negligence. On October 13, 2023, Kevorkova filed a cross-complaint against Pool, alleging causes of action for motor vehicle and general negligence. Pool now demurs to Kevorkova's cross-complaint, arguing the cross-complaint lacks sufficient facts to constitute a claim. The motion is unopposed. II. Demurrer A. Meet and Confer Under Code of Civil Proced...

Excerpt: ... action against Defendants Toussain Dumetz Maupin and Breana Dowdy for damages arising from a motor vehicle incident. On August 28, 2023, this matter was called for a non-jury trial, and after no appearances by or for either party, the Court dismissed Plaintiffs' complaint without prejudice. (Min. Order, Aug. 28, 2023.) On August 28, 2023, the same day as the dismissal, Plaintiffs filed the instant motion to set aside the dismissal.¿¿¿ II. Mot...

Excerpt: ...a (“City”) and Eugene Winthrop Warren, Jr. for damages arising from a bus v. motor scooter accident.¿ The City now moves for an order requiring Plaintiff to post an undertaking in the sum of $62,515 pursuant to CCP § 1030. Plaintiff opposes the motion, and the City filed a reply. 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 a...

Excerpt: ...gainst Defendant, Sun Real Estate Investments, LLC (“Defendant”) and for injuries arising from a trip and fall on Defendant's property. Plaintiff asserts that on September 19, 2023, Defendant issued subpoenas to fifteen of Plaintiff's treating providers seeking medical, billing records, and radiological records concerning Plaintiff. Plaintiff, at this time, moves to quash the subpoena on the grounds that the subpoenas are overbroad. Defendant...