Excerpt: ...tively, “Plaintiffs”) propounded special interrogatories, set one, and request for production of documents (“RPDs”), set one, on Defendant San Gabriel Transit Inc. (“Defendant”) on February 6, 2023. Plaintiff Jose also propounded form interrogatories, set one, on Defendant on February 6, 2023. Plaintiffs granted Defendant's three separate requests for an extension, with responses ultimately due by May 15, 2023. Defendant did not serve...

Excerpt: ... litem Felipe Rodriguez (collectively, “Plaintiffs”) filed this action against Defendants Uber Technologies, Inc. (“Uber”), Aimin Lin, Andrian Krugliy, and Roman Pidkova for damages arising from an automobile collision. Defendant Uber now moves to compel Plaintiff Felipe to submit to an additional deposition and leave for additional time beyond the statutory limit to conduct the second deposition. Any opposition to the motion was due on o...

Excerpt: ... move to compel the deposition of in pro per Plaintiff Elis Ismael Castro (“Plaintiff”). Defendants noticed Plaintiff's deposition for February 17, 2023, and after receiving no objections, Plaintiff failed to appear for his deposition. Defendants further seek monetary sanctions, or evidentiary sanctions in the alternative. The motion is unopposed. II. Motion to Compel Deposition CCP § 2025.450(a) provides, “If, after service of a depositio...

Excerpt: ...ntiffs”) filed this action against defendants Sitanshu Shyam Singh (“Singh”), Uber Technologies Inc., Rasier LLC, and PV Holding Corp. for damages arising from a motor vehicle accident. The complaint alleges causes of action for (1) negligence against all defendants and (2) unfair/unlawful/fraudulent business practices (Cal. Civ. Code §17200) against Uber Technologies Inc., Rasier LLC, and PV Holding Corp. The complaint includes a prayer f...

Excerpt: ...rry Street Garage, Los Angeles Convention Center, Staples Center for a slip and fall incident. A multitude of cross-complaints were filed. Trial is currently set for January 24, 2024. As relevant to the instant motion, Cross-Complainant/Cross-Defendant Gabriel's Cleaning Maintenance and Pressure Washing, LLC ("Gabriel's Cleaning") filed its Answer to Plaintiff's Complaint on March 30, 2022. On the same day, Gabriel's Cleaning filed its Cross-Comp...

Excerpt: ...nki”) and Wendy Kadi (collectively, “Plaintiffs”) filed this action against Defendants Kathy Mitsuye Kozai and Gerald Kozai for damages arising from an automobile collision. Defendant Kathy Mitsuye Kozai (“Kathy”) moves the Court for an order compelling Plaintiff Solanki to provide further responses to supplemental interrogatories and supplemental requests for production of documents. Defendant Kathy also moves for judgment on the plead...

Excerpt: ...action against defendants Sitanshu Shyam Singh (“Singh”), Uber Technologies Inc., Rasier LLC, and PV Holding Corp. for damages arising from a motor vehicle accident. The complaint alleges causes of action for (1) negligence against all defendants and (2) unfair/unlawful/fraudulent business practices (Cal. Civ. Code §17200) against Uber Technologies Inc., Rasier LLC, and PV Holding Corp. The complaint includes a prayer for punitive damages an...

Excerpt: ...) for damages arising from a motor vehicle incident. At this time, Defendant moves for an order compelling Plaintiff to appear for an examination with board-certified neurologist Edwin C. Amos, M.D. (“Dr. Amos”) at 2021 Santa Monica Blvd., Suite 525E, Santa Monica, CA 90404 on November 14, 2023 at 2:00 p.m. Defendant contends a neurological examination is necessary because Plaintiff claims neurological injuries from the incident, and Plaintif...

Excerpt: ...Plaintiffs”) filed this action against Defendants Lyft, Inc. (“Lyft”), Ayalnesh Tessema, Raquel Rosasarmijo for damages arising from an automobile incident. At this time, Lyft moves for a Protective Order to quash Plaintiffs' notice of deposition of Lyft's employee, Katye Coombs (“Coombs”). Plaintiffs oppose the motion, and Lyft filed a reply. II. Motion for Protective Order 1. Meet and Confer CCP § 2025.420(a) states that “Before, d...

Excerpt: ... Budget Car Rental, LLC (“ABCR”) for damages relating to a hit and run collision. Plaintiff alleges that his vehicle was struck by a vehicle rented through ABCR. Plaintiff amended the Complaint to add Defendant Pedro Ivan Jiminez Aguilera (“Aguilera”) on October 14, 2021. At this time, Defendant Avis Rent A Car System, LLC (“ARACS”) moves for leave to intervene in the case, contending it is the liability assurer for Defendant Aguilera...

Excerpt: ...en Dong, erroneously sued as Dong Chen (“Dong”), and Estate of Dylan Tszking Chan (“Chan” or “Decedent”) (collectively, “Defendants”) for damages arising from a motor vehicle accident on February 21, 2021. Plaintiff issued a subpoena to Dong's insurer, National General Premier Insurance Company (“National”), seeking documents related to Dong's insurance coverage, claims, collisions, and citations related to two vehicles driven...

Excerpt: ...this action against Lisa Kahn Mazzarella and Jeffrey Paul Mazzarella for damages arising from a motor vehicle collision. At this time, Plaintiffs seek leave to file a First Amended Complaint (“FAC”) to add the Estate of Lisa Kahn Mazzarella, deceased, and Jeffrey Paul Mazzarella, deceased, as defendants to the action. II. Motion for Leave to File FAC CCP § 473(a)(1) provides, in relevant part: “The court may, in furtherance of justice, and...

Excerpt: ...nguez is currently in pro per, after the withdrawal of defense counsel due to a mistake and lack of authority to file an Answer on behalf of Dominguez. (Min. Order, Feb. 16, 2023.) Plaintiff then hired an investigator, who personally served Dominguez on May 11, 2023 with the initial summons, complaint, discovery and deposition subpoena for May 25, 2023. On May 25, 2023, Dominguez failed to appear for his deposition. Plaintiff's counsel has attemp...

Excerpt: ...ian Ad Litem Jesse Ronald Carrasco, and Jazelle Dimas (“Dimas”) (collectively, “Plaintiffs”) filed this action against Defendants Positive Investments Inc., PI Properties LLC, and Becky Radgowski (“Becky”) for injuries Plaintiffs sustained in a dog bite attack. On May 17, 2022, Plaintiff filed Amendments to Complaint naming Defendants Ariana Arambula (“Arambula”) as Doe 1, Joseph M. Radgowski (“Joseph”) as Doe 2, and Mark A. R...

Excerpt: ...y Lu (“Defendants”) for damages arising out of a motor vehicle accident. Trial is currently set for May 6, 2024. Plaintiff has designated Andrew S. Morris, D.C. (“Morris”), Jan Roughan, B.S.N. (“Roughan”), Jonathan Eskenazi, M.D. (“Eskenazi”), John J. Smith, P.E. (“Smith”), and Fardad Mobin, M.D (“Mobin”) pursuant to Code of Civil Procedure section 2034.260. Defendants move to compel the depositions of these expert witness...

Excerpt: ...ngeles, and Los Angeles County Metropolitan Transportation Authority for damages arising from a trip and fall while attempting to exit a bus. Plaintiff dismissed the City of Los Angeles and County of Los Angeles. Trial is currently set for November 30, 2023. At this time, Defendant Los Angeles County Metropolitan Transportation Authority (“Defendant”) moves to compel Plaintiff's physical examination and requests monetary sanctions. Any opposi...

Excerpt: ...geles County Metropolitan Transportation Authority (“Defendant”) for damages arising from allegations that Defendant's employee closed the bus doors on Plaintiff without warning as Plaintiff was boarding the bus. At this time, Defendant moves to compel Plaintiff's physical examination and requests monetary sanctions. Any opposition to the motion was due by October 11, 2023; none was filed. II. Motion to Compel Physical Examination CCP § 2032...

Excerpt: ...s Foot Locker Retail, Inc., John Doe, and Does 1 to 100 for injuries related to an assault and battery on Plaintiff while inside a store. At this time, Defendant Foot Locker Retail, Inc. (“Foot Locker”) seeks leave to file a cross- complaint against A.J. Molino & Associates, Inc. (“A.J”) for equitable indemnification, equitable contribution, and declaratory relief. The motion is unopposed. II. Motion for Leave to File Cross‐Complaint A ...

Excerpt: ...ogies, Inc., Rasier LLC, Rasier-CA-LLC, Charter Communications, Inc., and John E. Roche for injuries arising from a motor vehicle incident. Trial is currently set for January 17, 2024. At this time, Defendants Uber Technologies, Inc., Rasier LLC, Rasier-CA-LLC (“Uber”) move to disqualify Los Angeles City Law, APLC (“LACL”) from their representation of Plaintiff due to a conflict of interest concerning LACL attorney Nanette Reed, Esq. (“...

Excerpt: ...istian Discipleship (“New Beginnings”), GM Service & Management, and Does 1 to 25 for injuries Plaintiff sustained after falling from the second story of a building. At this time, Plaintiff moves again for terminating sanctions against New Beginnings for disobeying the Court's September 2, 2022 order compelling New Beginnings to serve verified responses to Plaintiff's set one of form interrogatories, special interrogatories, and requests for ...

Excerpt: ...ainst defendants O'Reilly Auto Enterprises, LLC, O'Reilly Automotive Stores, Inc., and Oscar Navarro for damages arising from a slip and fall. On July 28, 2022, the parties stipulated to dismiss O'Reilly Automotive Stores, Inc. without prejudice. At this time, Plaintiff moves for issue sanctions and evidentiary sanctions precluding O'Reilly Auto Enterprises, LLC (“O'Reilly”) from offering evidence disputing liability or disputing Plaintiff's ...

Excerpt: ...s Angeles for injuries Plaintiff sustained after tripping and falling on a sidewalk. On April 7, 2022, Plaintiff dismissed the County of Los Angeles. The City of Los Angeles (“Defendant”) is the only remaining named Defendant. Plaintiff previously moved for terminating sanctions against Defendant for disobeying the Court's March 10, 2023 order compelling the depositions of Defendant's person most qualified (“PMQ”) for Bureau of Street Ser...

Excerpt: ...emple City”), County of Los Angeles (“the County”), and In-N-Out Burgers (“In-N-Out”) (collectively, “Defendants”) for damages arising from falling off a scooter after riding her scooter over an unknown substance. The Complaint alleges that Defendants negligently maintained the premises such that an unknown substance was allowed to exist and/or accumulate, thereby causing the area to be slippery. The Complaint alleges claims for pre...

Excerpt: ...nd City of Calabasas for injuries related to a fall. Plaintiff alleges she was riding a bicycle on Valmar Road when her bicycle slid on water and algae in the street, causing Plaintiff to fall and suffer injury. The City of Calabasas filed a cross-complaint against the City of Los Angeles Cleanstreet Inc. The City of Los Angeles filed a cross-complaint against the City of Calabasas, Cleanstreets (Roe 1), County of Los Angeles (Roe 2), Sedaghati, ...

Excerpt: ...ndants TingTing You (“You”), The Cheng Living Trust Dated April 16, 1991, and EAN Holdings, LLC d/b/a Enterprise Rent-A-Car Company (“Enterprise”) for wrongful death involving a motor vehicle v. pedestrian incident. On September 13, 2023, Defendant You filed the instant motion for determination of good faith settlement between Plaintiffs and Defendants You and Enterprise. The motion is unopposed. Preliminarily, the Court notes there is cu...

Excerpt: ..., German Quintan, Xiomara Sandoval, Gatsby Real Estate LLC, R M E G Realty Corporation, and Dan Gatsby for damages arising from a dog bite attack. On March 2, 2023, this matter was called for a non-jury trial, and after no appearances by or for either party, the Court dismissed Plaintiff's complaint without prejudice. (Min. Order, March 2, 2023.) On July 28, 2023, Plaintiff filed the instant motion to set aside the dismissal. II. Motion to Set As...

Excerpt: ...Kouns (“Kathryn”) (collectively, “Defendants”) for damages arising from a motor vehicle incident. On February 15, 2023, Defendants served Plaintiff with an offer to compromise per CCP §998 in the amount of $50,000. On February 27, 2023, the Court dismissed Defendant Heidi with prejudice. Plaintiff did not accept the CCP §998 offer, and the case went to trial. On March 2, 2023, the jury found in favor of Plaintiff and awarded Plaintiff $...

Excerpt: ...ed this action against Defendant Alma Lorena Oseguera and Juan Catalan for a subrogation claim arising from a motor vehicle incident, wherein Plaintiff paid for damages of its insured. On November 12, 2019, Plaintiff dismissed Juan Catalan. On October 1, 2020, the Court dismissed the action pursuant to the stipulation for conditional settlement and entry of judgment between Plaintiff and Defendant Alma Lorena Oseguera (“Defendant”). The Court...

Excerpt: ...s, LLC (“Smart & Final”) for damages arising from an assault by a third party while outside of the Smart & Final store. Plaintiff sets forth two causes of action for premises liability and general negligence. Smart & Final filed a Cross-Complaint against Roes 1-50 for express indemnification, equitable indemnification, equitable contribution, and declaratory relief. Thereafter, Smart & Final filed an amendment to its cross-complaint to name B...

Excerpt: ... on December 16, 2022, that Plaintiff must submit evidence demonstrating proper service of the Statement of Damages on Defendant Shaun Michael Huttar (“Defendant”) prior to entry of default. In this fourth default judgment request, Plaintiff's counsel (“Counsel”) declares that he served the Statement of Damages upon the Defendant prior to entry of default on November 18, 2019. (Wolfson Decl. ¶24; Exh, 6.) This Statement of Damages, dated...

Excerpt: ...“Jalal”) on April 28, 2023. Defendant also propounded request for production of documents (“RPDs”), set one, on Plaintiff Alexandra Gomez (“Gomez”) on April 28, 2023. Defendant granted Plaintiffs Jalal and Gomez two extensions to provide responses, and the deadline to provide responses was on July 10, 2023. As of the filing of the motion, Plaintiffs Jalal and Gomez have not served responses. Defendant therefore seeks an order compelli...

Excerpt: ...l Angel Can (“Can”), Uber Technologies, Inc. (“Uber”), Raiser-CA, LLC, and Rasier, LLC for damages arising from a motor vehicle accident on June 5, 2022. The complaint alleges Plaintiff was a passenger in Can's vehicle when Can made a left turn and collided with Juan Ricardo Barrows. At the time of the accident, Can was allegedly acting as an agent for Uber. At this time, Defendants Uber Technologies, Inc., Raiser-CA, LLC, and Rasier, LLC...

Excerpt: ...t Defendant Super Center Concepts Inc. d/b/a Superior Grocers (“Defendant”) for damages relating to Plaintiff's slip and fall on Defendant's property. Defendant now moves for terminating sanctions against Plaintiff to strike Plaintiff's complaint and/or dismiss the action with prejudice on the grounds that Plaintiff failed to abide by the Court's (1) May 30, 2023 Order to provide further responses to Defendant's special interrogatories and fo...

Excerpt: ...es 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 (“Colocho Defendants”). On March 30, 2021, Plaintiff settled with defendants Schlup and Bautista. Plaintiff dismissed Schlup, Bautista, and all unnamed Doe Defendants. Schlup and Bautista (collectively, “Cross-Complainants”) now move to set aside ...

Excerpt: ...iaz (“Plaintiff”). Defendants contend they noticed Plaintiff's in- person deposition on nine different occasions, and that Plaintiff has refused to appear for her in-person deposition. On October 5, 2023, Plaintiff filed her opposition, which was due on or before September 28, 2023. (CCP §1005.) Nonetheless, the Court, in its discretion, will consider Plaintiff's untimely opposition. II. Motion to Compel CCP § 2025.450(a) provides, “If, a...

Excerpt: ...les, 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 tri...

Excerpt: ...LC (“PB Hospitality”) and Liaison Restaurant and Lounge for injuries Plaintiff sustained while attending a party, wherein Plaintiff helped people out of a bounce house that was partially deflated and had his left foot on part of the bounce house when, without warning, another patron jumped in the bounce house and caused air to be pushed to the section of Plaintiff's foot, thereby causing him injury. Plaintiff alleges a single cause of action ...

Excerpt: ...Technologies, Inc, Rasier-CA, LLC, Rasier LLC, Miguel Angel Can (“Can”), and Juan Ricardo Barrows (“Barrows”) for damages arising from an automobile collision that occurred on June 5, 2022. The complaint alleges Plaintiff was a passenger in Can's vehicle when Can made a left turn and collided with Barrows. Plaintiff alleges Can was an employee/agent of Uber. At this time, Defendants Uber Technologies, Inc., Raiser-CA, LLC, and Rasier, LLC...

Excerpt: ...ed this Petition to compel Liberty Mutual Insurance to arbitrate an underinsured/uninsured motorist dispute relating to a July 2, 2020 automobile collision with uninsured driver Wendell A. Swisher. On November 15, 2021, Petitioners served a Demand for Arbitration on Respondent. However, after confirmation of receipt of the Demand for Arbitration, Respondent requested examinations under oath of both Petitioners and advised that Petitioners' arbitr...

Excerpt: ...ummitridge Enterprise, LLC, Vladie Star, aka Vladimir Arnoldov(ich) Staroselskiy, and Airstar Group, Inc. for damages arising out of fall on a ladder. On April 29, 2021, the Court granted United Specialty Insurance Company (“USIC”) leave to intervene on behalf of Summitridge Enterprise, LLC and to file a Complaint-In-Intervention. USIC moves for an order compelling Plaintiff to appear for his physical examination with neurologist Barry Ludwig...

Excerpt: ...nts (“Termirzavants”) for damages arising from a motor vehicle incident. Plaintiff moves the Court for an order compelling Termirzavants to provide further responses to special Interrogatories, set one, and request for admissions, set one. Plaintiff requests provide further responses to (1) special interrogatories, set one, request Nos. 2-3, 4-13, 16, 19-20 & 23-25; and (2) request for admissions, set one, requests Nos. 1 and 2. Termirzavants...

Excerpt: ...s (“Termirzavants”) for damages arising from a motor vehicle incident. Plaintiff moves the Court for an order compelling Termirzavants to provide further responses to Request for Production of Documents (“RPDs”), set one, and Form Interrogatories, set one. Plaintiff requests full and complete responses, and production of documents as (1) RPDs, set one, request Nos. 1-2, 7-12, 14-15, 17, 26-28, 32 and 44-46 and (2) Form interrogatories, se...

Excerpt: ...es, Inc. (“Apex”) moves to consolidate Case Nos. 21STCV12326, 21STCV22180, 21STCV23203, 21STCV23173, 21STCV25523, and 21STCV24684 contending that the six cases arise from the same event of a roof collapse on July 15, 2019 at Larry Flynt's Lucky Lady Casino. Defendant Casino LLC (“Casino”) joins the motion to consolidate. Apex avers each Plaintiff in each case alleges he or she suffered personal injuries arising from the same event. Case N...

Excerpt: ...ff contends that Belk objected to Plaintiff's four deposition notices without cause. In opposition, defense counsel contends that they repeatedly indicated Belk would appear for his deposition on a mutually agreeable date, and defense counsel offered dates to Plaintiff's counsel. However, Plaintiff did not notice the deposition after the dates were provided. Further, Defendant contends that Plaintiff's motion is set to be heard past the motion-cu...

Excerpt: ...s to compel the deposition of Plaintiff Eugel Nicoleau (“Plaintiff”). Defendant initially took Plaintiff's deposition on June 20, 2023, but the deposition was suspended after several hours when Plaintiff became ill. The parties agreed to resume the deposition at a later date. Defense counsel avers that Plaintiff's counsel has not responded to repeated inquiries for alternate dates. Defendant noticed Plaintiff's resumed deposition for August 7...

Excerpt: ... damages arising out of a trip and fall on the street on December 15, 2020. Plaintiff brings a cause of action for dangerous condition of public property pursuant to Gov. Code section 835. Plaintiff alleges injuries arising from stepping on an uneven, scarred and deformed portion of asphalt on the street. (Compl. ¶ 13.) Defendant now moves for summary judgment. Plaintiff opposes the motion, and Defendant filed a reply. On September 13, 2023, the...

Excerpt: ...) for damages arising from a motor vehicle incident. At this time, Defendant moves for an order compelling Plaintiff to appear for an examination with board-certified neurologist Barry Ludwig, M.D. (“Dr. Ludwig”) at 2811 Wilshire Boulevard, Suite 508, Santa Monica, CA 90403 on October 10, 2023 at 9:00 a.m. Defendant contends a neurological examination is necessary because Plaintiff claims her headache and neurological condition was caused by ...

Excerpt: ...bber North America, Inc. (“Sumitomo”), EAN Holdings, LLC, and Jacob Koo (“Koo”) for damages arising from a motor vehicle incident. At this time, Defendants Sumitomo and Koo (“Defendants”) move for an order compelling Plaintiff to appear for a second medical examination with a neurologist. Defendants contend a neurological examination is necessary because Plaintiff claims for traumatic brain injury. Plaintiff opposes the motion, and De...

Excerpt: ...Tesoro Refining & Marketing Company LLC, BP West Coast Products, LLC, BP Products LLC, BP Products North America Inc., and BP America Inc. for damages resulting from automatic sliding doors at an entrance, which closed without warning and struck Plaintiff.¿Plaintiff is currently in pro per. Defendants Petrolion, Inc., BP Products North America Inc. and Tesoro Refining & Marketing Company LLC (“Defendants”) now move for terminating sanctions ...

Excerpt: ...nc., Rasier, 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 Defendants”) seek leave to file a cross-complaint against Defendant Francisco J. Giron (“Giron”) for (1) comparative indemnity and apportionment of fault, (2) equitable indemnity, (3) contribution, a...