Excerpt: ...pany, Inc. ("Defendant") for negligence On April 12 2023, Plaintiff filed motions to compel further responses to Demand for Production of Documents, Set Two and Special Interrogatories, Set Three. On April 19, 2023, the parties participated in an Informal Discovery Conference ("IDC") concerning these discovery requests, which included requests for contact information of employees of Defendant who witnessed Plaintiffs alleged injuries and for cert...

Excerpt: ...rmis filed this action agamst Defendants Sajjad Takallou, Maryam Ghasemi, and DOES 1-10 for motor vehicle and general negligence. The action arises from an accident on February 2, 2020 where Plaintiffs were struck by Defendants' vehicle while they were walking across a crosswalk at Independence Avenue and Vanowen Street in Los Angeles. Trial in this matter is currently set for May 31, 2023. On April 18, 2023, the parties submitted a stipulation t...

Excerpt: ...liability and negligence On January 3, 2022, Plaintiff Juana Martinez Figueroa filed a complaint against Defendants Immaculate Conception Catholic Church, Archdiocese of Los Angeles, and DOES 1-25. Trial in this matter is currently set for July 3, 2023. Relevant to this motion, Defendants' motion for summary iudqment is set to be heard on July 18, 2023, two weeks after trial is currently set to begin. Defendants now move to continue the current t...

Excerpt: ...y Tashkoff ("Tashkoff) Michael Chiranian ("Chiranian"), and Precision Rent A Car, LLC ("Precision") for damages arising from a motor vehicle accident vs. pedestrians accident Plaintiffs allege that Tashkoffran a redlight and hit Plaintiffs while they were crossing the street Plaintiffs allege that Precision negligently permitted Tashkoffto drive the vehicle, which was owned by Chiranian. The operative First Amended Complaint asserts causes of act...

Excerpt: ...s, LAX for injuries Plaintiff sustained when "Plaintiff was loading luggage when his foot fell into and tvvisted beb,veen an open gap in the street" (Compl. at pp. 4, 5.) Plaintiff alleges the incident occurred on June 10, 2021. The complaint alleges causes of action for general negligence and premises liability agamst defendants. The premises liability claim includes a count for dangerous condition of public property. Defendant the City now move...

Excerpt: ...r injuries Plaintiff sustained due to an alleged unsafe condition on Defendant's property. Plaintiff alleges she was mjured on or about January 10, 2018. The complaint alleges causes of action for general negligence and premises liability agamst Defendant. At this time, Defendant moves for judgmenton the pleadings as to Plaintiffs complaint Plaintiff opposes the motion, and Defendant filed a reply. Defendant contends that Plamtiffs negligence and...

Excerpt: ...ly 21, 2022. Plaintiff provides that after multiple extensions were granted, responses were due on or before October 17, 2022. Plamtiffavers that to date Defendant has failed to sewe verified responses to the discovery requests. Plaintiff therefore seeks an order compelling Plaintiffto respond, without objections, to the outstanding interrogatories and RPDs and deeming the RPAs admitted. Defendant opposes each motion. Defendant argues that it sew...

Excerpt: ...is Brass, and Glenda A. Brass for damages relating to Plaintiffs alleged trip and fall over a raised portion of sidewalk that presented a dangerous condition at or near the premises located at 330 Queen Street Inglewood, California 90301 (the "Queen Street Property"). The complaint alleges causes of action for premises liability/violation of Government Code and negligence/violation of Government Code. The premises liability claim includes a count...

Excerpt: ...cident Trial in this action is currently set for August 4, 2023. At this time, Plaintiff moves to augment his expert witness list and to reopen fact and expert discovery. Defendant opposes the motion. Any reply to the motion was due on or May 1, 2023 As of May 3, 2023, no reply has been received. Plaintiff provides that his current counsel substituted into the action on December 16, 2022, and upon review of Plaintiffs file determined that Plainti...

Excerpt: ...lleged slip and fall in Defendant's property. Plaintiff alleges that as she walked near a hostess booth within the subject premises, she stepped on an unknown substance on the floor that caused her to slip and fall. (Compl_ at pp. 4, 5) The complaint alleges causes of action for negligence and premises liability against Defendant Defendant now moves for summary judgment, or altematively, summary adjudication, as to Plaintiffs claims. Plaintiff op...

Excerpt: ...igence. Plaintiff alleges she was on Defendant's premises waiting in line to enter its store when an employee negligently allowed a metal dumpster door to violently swing open and into Plaintiff At this time, Defendant moves for a protective order prohibiting the deposition of Fonda Burke ("Burke"). Plaintiff opposes the motion, and Defendant filed a reply. Defendant provides that on February 6, 2023, Plaintiff unilaterally noticed the deposition...

Excerpt: ...mco") for damages arising from a trip and fall on the lawn of a property located ator near 1050 Frederick St., Venice, CA 90291. Plaintiff alleges the property was in a dangerous condition due to a "grass concealed hole on the lawm" (Compl_ at p. 4.) The complaint alleges causes of action for general negligence and premises liability. On October 15, 2019, Lincoln Place and Aimco filed a cross-complaint equitable indemnity, declaratory relief, and...

Excerpt: ...efendants employee allegedly drove "an industrial caddy* inside Defendant's store and crashed into Plaintiff On October 12, 2022, Plaintiff filed the instant motion to compel further responses to request for production of documents ("RPDs"), set one, against Defendant On December 20, 2022 Defendant filed its opposition to the motiom On April 10, 2023, the pallies participated in an Informal Discovery Conference conceming the RPDs, but the issues ...

Excerpt: ...f sustained while on board of Defendant's aircraft. At this time, Defendant moves for terminating sanctions against Plaintiff for disobeying the Court's December 8, 2022 order regarding written discovery responses, and for failing to submit to authorized methods of discovery. The motion is unopposed On April 28, 2023, Defendant filed a reply noting that no opposition was served or filed by Plaintiff 2. Motion for Terminating Sanctions Code of Civ...

Excerpt: ...y sued as West Valley Occupational Center ("Defendant" or "LAUSD") for injuries relating to Plaintiffs slip and fall on Defendants property. On June 16, 2021, Plaintiff filed the operative Second Amended Complaint ("SAC") alleging causes of action for (1) negligence, (2) premises liability, and (3) dangerous condition of public property. On August 30, 2021, Defendants demurrer to the SAC was sustained without leave to amend. On October 20, 2022, ...

Excerpt: ...ries Plaintiff suffered while on Defendants' premises to repair the air conditioners located on the roof. Plaintiff alleges that as he walked down the ladder from the roof to the floor below, the door hatch immediatelv,' slammed shut onto Plaintiffs body causing him to suffer injuries. (Compl_ at MI 10-11.) The complaint alleges causes of action for general negligence and premises liability. Defendants now move for summary judgment or altemativel...

Excerpt: ...e, and Does 1-25 for damages relating to Plaintiffs alleged trip and fall on a sidewalk The complaint alleges causes of action for general negligence and premises liability. The premises liability claim includes counts for negligence, willful failure to warn, and dangerous condition of public property. On February 27, 2023, Plaintiff filed a Notice of Errata Re: Complaint providing that the premises liability claim erroneously states the incident...

Excerpt: ...dia Flores Trinidad (collectively, "Defendants") for damages related to Plaintiffs trip and fall on steps on Defendants' property. At this time, Plaintiff moves to augment her list of expens by replacing one of Plaintiffs originally retained experts, Dr. Cebula, with Plaintiffs recently retained expert, Dr. Grossmam Defendants oppose the motion. Any reply to the motion was due on or before April 26, 2023. On April 27, 2023, a reply was filed at 4...

Excerpt: ...t Nancy Foster ("Defendant") for damages arising from a motor vehicle accident Defendant now moves for leave to conduct a neurological examination of Plaintiff Sheila, more than 75 miles from Ms. Keller's residence, before Dr. Edwin C. Amos ("Dr. Amos") on May 15, 2023, at 2:00 p.m., at 2021 Santa Monica Blvd. Suite 525E Santa Monica, California 90404. Sheila opposes the motion, and Defendant filed a reply. Defendant provides that after meeting a...

Excerpt: ...r injuries relating to Plaintiffs trip and fall on an alleged defective concrete walkway that occurred on December 2, 2019. On February 25, 2022, the City filed a cross- complaint for indemnification, apportionment of fault, and declaratory relief against Roes 1-20. As relevant to this proceeding, on October 3, 2022, the City filed an Amendment to Cross-Complaint naming Jade Enterprises, LLC ("Jade") as Roe 3. Jade now demurs to the cross-complai...

Excerpt: ...n against Defendant Hank Lachman ("Defendant") for injuries Plaintiff sustained after Defendant intentionally discharged a firearm at Plaintiff Plaintiff alleges he was shot twice in the arm. On October 12, 2022, Defendant's counsel Allison 8. Margolin ("Margolin") moves for an order to set aside and vacate the order entered on August 23, 2022, denying Margolin's motion to be relieved as counsel. No opposition has been received to this motiom Add...

Excerpt: ... slip and fall at Defendant's premises. Trial is currently set for July 3, 2023. Defendant now moves for an order specially setting Defendant's motion for summary judgment for hearing, or altematively, to continue the current trial date to a date after the hearing on Defendants summary judgment motion. On April 4, 2023, Defendant filed a Notice of Rescheduled Date for Hearing on Defendants Motion for Summary Judgment providing that while Defendan...

Excerpt: ...for damages arising from a motor vehicle accident that occurred in Sacramento, California on September 11, 202m At this time, Defendant Biomedical Waste Disposal, Inc. ("Defendant") moves for an order transferring venue to Sacramento County Superior Court pursuant to CCP SS 395(a) and 397(c). Plaintiff opposes the motion, and Defendant filed a reply. 2. Motion to Transfer Venue Pursuant to CCP S395(a), an action for personal injuries is properly ...

Excerpt: ...ed when Defendants employee allegedly drove an industrial caddy* inside Defendant's store and crashed into Plaintiff On October 11, 2022, Plaintiff filed the instant motion to compel further responses to special interrogatories, set one, against Defendant. Plaintiff seeks to compel further responses to special interrogatories Nos. 15 and 19, which seek information regarding prior accidents or negligence by Defendant's employees involving industri...

Excerpt: ...odney ("Rodney") (collectively, "Defendants") for damages arising from a motor vehicle accident The Complaint, which was filed on Judicial Council form PLD-PI- 001, states that causes of action for motor vehicle and general negligence are attached. (Compl II 10.) However, only a cause of action for motor vehicle negligence is attached. Further, the Complaint alleges that Plaintiff was required to and did comply with applicable claims statutes. (C...

Excerpt: ... motor vehicle accident On February 17, 2023, Plaintiff filed the operative Second Amended Complaint ("SAC") alleging causes of action for (1) negligence, (2) intentional infliction of emotional distress ("IIED"), (3) assault, and (4) battery. The SAC alleges that after Defendant negligently caused the accident, "Defendant was angry about the occurrence and without exiting his vehicle or exchanging information to identify himself for a bodily inj...

Excerpt: ... the Ikea store located at 600 S Ikea Way, in the City of Burbank, County of Los Angeles, California 91502" (Compl_ at p. 4.) The complaint alleges causes of action for negligence and premises liability. On November 9, 2021 , Plaintiff filed an Amendment to Complaint naming Federal Building Services, Inc. ("FBSÆ) as Doe 1 _ Defendant FBS now moves for summary judgment as to Plaintiffs complaint. the motion, and FBS filed a reply. Plaintiff oppos...

Excerpt: ...nso filed Case No. 19STCV09657 against defendants Access Services, Incorporated, et al. for damages arising from a motor vehicle accident Case Nos. 19STCV09657, 20STCV13206 and 20STCV13191 arise out of the same automobile accident and have been consolidated. (Mim Order Sept 1, 2021.) At this time, Defendant Krishaun Holbert ("Holbert") moves to compel Plaintiff Khaliah Farwell's ("Farwell") deposition. The motion is unopposed. Additionally, Holbe...

Excerpt: ...d Arturo Orozco Torres ("Torres") for damages arising from a motor vehicle accident Plaintiffs allege that Torres was acting in the course and scope of his employment with Vista at the time of the accident Vista propounded its request for admissions ("RFAs"), set one, on Plaintiff Adam Glick ("Plaintiff) on September 18, 2020. After Plaintiffs failed to respond to the RFAs, Vista moved for an order deeming the truth of the matters specified in th...

Excerpt: ... damages relating to Defendant's care and treatment of Plaintiff, including a spinal surgery. The complaint alleges a single cause of action for medical negligence against Defendant Defendant now moves for summary judgment as to the complaint The motion is unopposed. This matter was last heard on October 25, 2022, where it was continued to April 26, 2023, after Plaintiff appeared at the hearing and claimed he did not receive notice of the motion....

Excerpt: ...d Harold Otero (collectively, "Defendants") for damages arising from a motor vehicle accident At this time, Defendants move to compel Plaintiff to submit to (1) an orthopedic examination bv Kevin J Kulwicki, MO., (2) neuropsychological examination by Terence J Young, Psy_D, and (3) a physical examination by Robert W. Graebner, M.D. Each exam is to take place in Miwaukee, Wisconsin within 75 miles of Plaintiffs residence. The motion is unopposed. ...

Excerpt: ...or damages arising from a motor vehicle accident. The complaint alleges causes of action for motor vehicle, general negligence, and intentional tort The complaint includes a prayer for punitive damages. Plaintiff alleges that Defendant drank alcohol and was intoxicated when he drove his vehicle and collided with five separate cars, including Plaintiffs vehicle. At this time, Plaintiff moves for an order allowing discovery regarding the financial ...

Excerpt: ...les for injuries Plaintiff sustained when a pothole in the street caused her to fall off the motorized scooter she was riding. The complaint alleges causes of action for general negligence and for premises liability. The premises liability claim includes counts for negligence, willful failure to warm and dangerous condition of public property. The City now demurs to the complaint arguing the complaint fails to state a claim against it The City as...

Excerpt: ...intiff) filed this action against Defendant Kenneth Douglas Kochakji ("Defendant") for injuries arising from a motor vehicle vs. pedestrian accident. On October 13, 2022, Defendant filed a motion for leave to compel Plaintiffs neurological and mental/neuropsychological examinations. Plaintiff opposes the motion, and Defendant filed a reply This matter was last heard on April 12, 2023, where it was continued to April 24 2023, at Defendant's reques...

Excerpt: ...iner owned by Defendant. Plaintiff alleges that the subject container's ladder was broken, so Plaintiff climbed on the comer of the container. Plaintiff stabilized himself with one foot on the container and the other on the container's contents. As Plaintiff pushed the container's contents down, the contents shifted causing Plaintiff to fall backward off the container. Trial is currently set for June 5, 2023. Defendant now moves to continue the c...

Excerpt: ... Homeowner's Association, Inc. and the Condo Managers for injuries relating to Plaintiffs trip and fall at the propeny located at 12060 Hoffman-Street, Studio City, CA 91604, that occurred on March 15, 2021 The complaint alleges causes of action for negligence and premises liability. On February 4, 2022, 12060 Hoffman Homeowner's Association, Inc. filed a cross-complaint against the City of Los Angeles (the "City") for indemnification, apportionm...

Excerpt: ...ing out of a motor vehicle accident that occurred on or about August 3, 2018. The complaint alleges a single cause of action for negligence against Defendant. At this time, Defendant moves for judgment on the pleadings as to Plaintiff's complaint. Defendant avers that prior to filing the complaint in this action, Plaintiff settled the claims at issue in this action with this assistance of different counsel. Defendant asserts Plaintiff signed and ...

Excerpt: ... against Defendant Los Angeles County Metropolitan Transit Authority (“Defendant”) for damages arising from a motor vehicle accident involving Defendant's bus. On September 14, 2022, the parties participated in an Informal Discovery Conference (“IDC”) regarding multiple discovery issues, including Plaintiff's Request for Production of Documents (“RPDs”) served on Defendant. The issues were deemed partially resolved, with Defendant to ...

Excerpt: ...ant Frederick William Roberts, Jr. (“Decedent”) for damages arising from a motor vehicle accident. Decedent passed away on or about May 10, 2022. On November 16, 2022, Plaintiff filed Amendments to Complaint naming Joan Roberts (“Joan”) and the Estate of Frederick William Roberts Jr., Deceased (the “Estate”), as Does 1 and 2, respectively. On February 17, 2023, Plaintiff filed the instant Motion to Continue Proceeding Against Defendan...

Excerpt: ...emi (“Defendant”) for damages arising from a motor vehicle accident. On August 9, 2022, Defendant propounded a notice of demand for physical examination on Plaintiff, setting Plaintiff's exam for October 17, 2022. Plaintiff served a Response and Opposition to the demand, which Defendant asserts Plaintiff improperly used to attempt to impose additional conditions on the exam. Plaintiff did not appear for the exam and did not respond to Defenda...

Excerpt: ...nc. (“Defendant”) for injuries Plaintiff sustained after allegedly slipping and falling down on wet steps in Defendant's movie theater. On January 23, 2023, Defendant's motions to compel responses to form interrogatories, set one, and special interrogatories, set one, against Plaintiff were granted. [1] Plaintiff was ordered to serve verified responses to the discovery, without objections, within 30 days and monetary sanctions were imposed ag...

Excerpt: ...ts Andrew London (“London”), Brian Geurts (“Brian”), and Carrie Geurts (“Carrie”) for damages arising from a motor vehicle accident. The complaint alleges claims for motor vehicle and general negligence. On January 18, 2023, Plaintiffs each served Defendant with special interrogatories, set one, which each included 71 special interrogatories for a total of 142 special interrogatories served on Brian. At this time, Brian moves for a pr...

Excerpt: ...tems from an injury sustained when Danielle Hemple (“Plaintiff”) slipped, fell, and was injured while exiting a Bristol Farms (“Defendant”) grocery store. On February 3, 2019, Plaintiff alleges that while exiting Defendant's store, she was caused to fall by the wet floor when leaving. (First Amended Complaint, hereinafter, “FAC”, ¶ 8.) Plaintiff filed her initial Complaint on November 11, 2021. The FAC was filed on February 7, 2023. ...

Excerpt: ...oa (“Defendant”) for damages relating to a motor vehicle accident. On February 17, 2023, Plaintiff filed the operative SecondAmended Complaint (“SAC”) alleging causes of action for (1) negligence, (2) intentional infliction of emotional distress (“IIED”), (3) assault, and (4) battery. The SAC alleges that after Defendant negligently caused the accident, “Defendant was angry about the occurrence and without exiting his vehicle or exc...

Excerpt: ...vely, “Plaintiffs”) filed this action against Defendants Dhoor Gurpreet Singh and Tripe Eight Transport, Inc. (collectively, “Defendants”) for damages arising from a motor vehicle accident. At this time, Defendants move for an order compelling Plaintiff to appear for a mental examination. The motion is unopposed. Defendants seek leave to obtain a neuropsychological examination of Elizarraras to be performed by Ari Kalechstein, M.D. at 118...

Excerpt: ...ter, Inc. (“Soma”) for medical malpractice relating to injuries arising from a colonoscopy that led to a perforation of Plaintiff's bowel. On June 23, 2021 Christina Menor (“Menor”) was substituted in for Doe 1. Menor (hereinafter “Defendant”) now moves for summary judgment as to the Complaint. 2. Motion for Summary Judgment a. Legal Standard The purpose of a motion for summary judgment or summary adjudication “is to provide courts ...

Excerpt: ...nt Michelle Proyect (“Defendant”). The complaint filed on Judicial Council form PLD-PI-001 states that causes of action for general negligence and premises liability are attached. However, there are no attachments with any causes of action attached to the complaint. Additionally, the complaint includes a prayer for punitive damages. Defendant now demurs to the complaint arguing the complaint fails to state any claim against Defendant and is u...

Excerpt: ...�) for damages arising from a motor vehicle accident. The complaint alleges causes of action for motor vehicle and general negligence and includes a prayer for punitive damages. Defendant now moves to strike the claim for punitive damages and exemplary damages attachment from the complaint. Plaintiff opposes the motion. 2. Motion to Strike Civil Code § 3294(a) states, “[i]n an action for the breach of an obligation not arising from contract, w...

Excerpt: ...nst Defendant Kenneth Douglas Kochakji (“Defendant”) for injuries arising from a motor vehicle accident. Defendant now moves for leave to compel Plaintiff's neurological and mental/neuropsychological examinations. 2. Motion to Compel Mental Examination and Additional Physical Examination a. Legal Standard A court order is required¿to obtain a party's mental examination or additional physical examination. (Code Civ. Proc. § 2032.310(a).) Suc...

Excerpt: ...orporation, World Oil Marketing Company, Mathew Pakkala, #1 Auto Service, and Hui Li (collectively “Defendants”) for premises liability and negligence/negligence per se. The action arises out of Grace Ho's fall into an automotive repair pit located at Defendant #1 Auto Service on May 15, 2020. Grace Ho suffered injuries and eventually died on December 20, 2020. Trial is set for December 20, 2023. On March 15, 2023, Defendant Li filed a motion...