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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Excerpt: ...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: ...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: ...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: ...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: ...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: ...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: ...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: ... 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: ...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...