Excerpt: ...Defendants”), and Does 1 through 50 asserting causes of action for Negligence, Negligence Per Se, Vicarious Liability, Negligent Entrustment of a Motor Vehicle, and Negligent Hiring, Retention, Supervision and Training. Defendants filed their answer on September 2, 2021. On January 5, 2023, Defendants served Plaintiff with Special Interrogatories (Set Two) and Requests for Production of Documents (Set Two). Plaintiff did not respond. On March 9...

Excerpt: ...berto Ramirez and Fernando Santana Velazco (“Plaintiffs”) filed this motion for leave to file a First Amended Complaint. Defendants Juan Carlos Tejeda and Braxton R, LLC (“Defendants”) filed their opposition on December 18, 2023. Plaintiffs have not filed a reply. On December 18, 2023, Plaintiffs amended their complaint to name Tejeda Transportation, LLC as Doe 1. Trial is currently set for February 6, 2024. Legal Standard CCP § 473(a)(1...

Excerpt: ...ay 28, 2020, Plaintiff filed proof of personal service on Defendant. On March 23, 2021, default was entered as to Defendant. On June 2, 2023, the Court vacated the default. On November 29, 2023, Defendant filed this motion to set aside default and quash service of the summons. No proof of service is attached to the motion. On December 12, 2023, Defendant filed a proof of service showing mail service on Plaintiff's counsel on November 29, 2023. On...

Excerpt: ... (erroneously sued as Bell Canyon Association), Mohammad Moghaddam Hallaj (erroneously sued as Mohammad M. Serand), Maryam T. Nezhad, and Does 1 through 100, inclusive, for (1) negligence, (2) premises liability, and (3) loss of consortium. The FAC alleges the following. Defendants failed to own, lease, operate, maintain, design, build, manage and/or otherwise control the property located at 46 Saddlebow Road, Bell Canyon, California, 91307, incl...

Excerpt: ..., and Does 1 through 50. On June 7, 2021, Defendants Christopher Harbonville (erroneously sued as Christophe Harbonville), Rasier LLC, and Rasier-CA, LLC each filed an answer. On May 18, 2022, James River Insurance Company (“JRIC”), the insurer for Defendant Christopher Harbonville, filed a complaint in intervention. JRIC filed this motion to continue trial on November 28, 2023. According to JRIC, it only “recently” learned that Defendant...

Excerpt: ...led this motion for leave to intervene. No opposition has been filed. Legal Standard Code of Civil Procedure, section 387, subdivision (d)(1) provides that the court shall, upon timely application, permit a nonparty to intervene in the action or proceeding if “a provision of law confers an unconditional right to intervene,” or “[t]he¿person seeking intervention claims an interest relating to the property or transaction that is the subject ...

Excerpt: ...on his race. Plaintiff filed his First Amended Complaint (“FAC”) on January 19, 2023. On May 22, 2023, the Court granted Defendant's motion to quash service of the summons and complaint based upon improper service. On October 18, 2023, Plaintiff apparently attempted to serve Defendant by sending a copy of the FAC and Complaint to Defendant's agent for service of process by FedEx. (Villamor Decl., ¶ 5.) On October 26, 2023, Defendant filed th...

Excerpt: ...California. On January 3, 2020, Plaintiff Debbie Thomas ("Plaintiff") filed the complaint in this action asserting one cause of action for motor vehicle negligence against Defendants American Medical Response, Inc., Global Medical Response, Inc, Envision Healthcare, Inc, Zane Steven Petterson, and Does 1 through 50. On June 27, 2023, Plaintiff served Defendant American Medical Response, Inc. (“Defendant”) with Requests for Admission (Set One)...

Excerpt: ...Interrogatories, Special Interrogatories, and Demand for Production. Defendants filed the Motions to Compel S Form Interrogatories, Special Interrogatories, and Demand for Production of Plaintiff on March 6, 2023, as well as for sanctions of $860.00 for each motion, $2,580.00 total. The Court has not received any opposition. Legal Standard A party must respond to interrogatories within 30 days after service. (Code Civ. Proc., § 2030.260, subd.(a...

Excerpt: ...d as Sara Contreras) (“Defendant”) filed this motion to strike the portions of the prayer for relief in Plaintiff's Complaint seeking attorney's fees and punitive damages. Plaintiff has not filed an opposition. Legal Standard A motion to strike challenges “any irrelevant, false, or improper matter inserted in any pleading” or “all or any part of any pleading not drawn or filed in conformity with the laws of this state, a court rule, or ...

Excerpt: ...judgment. To date, no opposition has been filed. Legal Standard “The purpose of the law of summary judgment is to provide courts with a mechanism to cut through the parties' pleadings in order to determine whether, despite their allegations, trial is in fact necessary to resolve their dispute.” (Aguilar v. Atlantic Richfield Co. (2001) 25 Cal.4th 826, 843.) Code of Civil Procedure section 437c, subdivision (c), “requires the trial judge to ...

Excerpt: ...lity for Dangerous Condition of Public Property, Pursuant to Government Code section 835 et seq., (2) Negligence, and (3) Premises Liability. City and Botach filed their Answers on January 18, 2023. On January 24, 2023, Hot and Cool filed an Answer and a Cross-Complaint against City, County, Botach, and Roes 1 through 10. On February 7, 2023, Botach filed a Cross-Complaint against Hot and Cool and Moes 1 through 10. City filed a motion for leave ...

Excerpt: ...and general negligence. On April 11, 2022, Defendant Alta Los Angeles Hospitals, Inc. (“Defendant”) filed its answer. On April 13, 2022, Plaintiff amended the complaint to name Marlon R. Mejia Paz as John Doe 1. On October 12, 2022, the Court granted the motion of Plaintiff's attorney to be relieved as counsel. On September 18, 2023, the Court granted Defendant's motion for an order compelling Plaintiff to provide verified, code-complaint res...

Excerpt: ...eposition of Plaintiff on July 21, 2023. Plaintiff did not file any opposition. Legal Standard Code of Civil Procedure § 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 examinat...

Excerpt: ...y of 2019, with a Stipulation for Entry of Judgment entered into between the parties on September 30, 20219. A Stipulation for Settlement and Order was filed with the Court on December 23, 2019. On March 7, 2023, Plaintiff filed this motion to set aside or vacate the dismissal and for entry of judgment. Legal Standard Under Code of Civil Procedure, section 664.6: (a) If parties to pending litigation stipulate, in a writing signed by the parties o...

Excerpt: ...ion for: (1) general negligence; and (2) motor vehicle negligence. On January 19, 2021, Defendant filed and answer. On March 30, 2021, Plaintiff substituted in Randall M. Awad as counsel. On January 10, 2023, after several prior Final Status Conferences at which one or both parties had not submitted the trial readiness documents required by the Standing Order, the Court held a Final Status Conference and ordered Plaintiff's counsel Mr. Awad to pa...

Excerpt: ...18. On August 28, 2020, Plaintiff filed the Complaint in this action against Defendants Quality Naturally! Foods, Inc; Yum Yum Donut Shops, Inc; Winchell's Francising LLC; Managing Personnel Services, Inc; California Analytics, LLC, and Does 1 through 1000, asserting claims for negligence, premises liability, unfair business practices, negligent misrepresentation, and intentional misrepresentation. On August 31, 2020, Plaintiff filed the First Am...

Excerpt: ...wth Spike Holdings, LLC (“Defendant”) filed its answer. On June 8, 2021, Defendant Raul Mariscal filed his answer. On December 21, 2021, Plaintiff amended his complaint to name BKJK, LLC as Doe 11. On February 1, 2023, Plaintiff amended his complaint to name TC Machine Builds LLC as Doe 21. On June 7, 2023, Plaintiff amended his complaint to name Good Tree Holdings, LLC as Doe 41. As is relevant here, on June 13, 2022, Plaintiff served Defend...

Excerpt: ...ber 25, 2020, Plaintiff filed the Complaint in this action asserting claims for premises liability and negligence against Defendants Uninational Corporation, Healthcare Partners, and Does 1 through 20. On May 24 and November 17, 2022, Defendant Uninational Corporation (“Defendant”) and Defendant Optumcare Management LLC (erroneously named as Healthcare Partners) filed their Answers. On October 20, 2023, Plaintiff amended the Complaint to name...

Excerpt: ..., Defendants filed the instant motion to continue trial currently scheduled for January 16, 2024, by approximately five months. On November 15, 2023, Plaintiff filed an opposition. On November 17, 2023, Defendants filed a reply. Legal Standard¿ Trial dates are firm to ensure prompt disposition of civil cases. (Cal. Rules of Court, rule 3.1332, subd. (a).)¿ Continuances are thus generally disfavored.¿ (See Id., rule 3.1332, subd. (b).)¿ Nevert...

Excerpt: ...s liability, and general negligence against Defendants City of Glendale, City of Glendale Public Works, L.A. Federal Credit Union, Glendale Maintenance Service, and Does 1 through 50. After the Court granted a motion to strike (with leave to amend), Plaintiff filed a First Amended Complaint (“FAC”) on May 12, 2021. In the FAC, Plaintiff asserts the same causes of action against the same defendants. On June 10 and July 6, 2021, Defendants City...

Excerpt: ... leave to intervene in the action. No opposition has been filed. Trial is set for April 19, 2024. Legal Standard Code of Civil Procedure, section 387, subdivision (d)(1) provides that the court shall, upon timely application, permit a nonparty to intervene in the action or proceeding if “a provision of law confers an unconditional right to intervene,” or “[t]he¿person seeking intervention claims an interest relating to the property or tran...

Excerpt: ...��Defendant”) and Does 1 to 10, asserting causes of action for motor vehicle negligence and general negligence. On April 28, 2023, Defendant filed its answer. On May 26, 2023, Defendant served Plaintiff with discovery requests, including Special Interrogatories (Set One). (Paulick Decl., ¶ 6 & Exh. A.) Plaintiff did not respond. (Id., ¶ 7.) On October 27, 2023, Defendant filed this motion for an order compelling Plaintiff to respond to the De...

Excerpt: ...Elmer Lopez (“Plaintiff”) filed this action on December 17, 2020, alleging one cause of action for negligence against Defendants Michael Pourshalimi (erroneously sued as Mykel Toursalami), Ester Pourshalimi (erroneously sued as Chester Toursalami) (collectively, “Defendants”) and Does 1 through 50. On January 26, 2021, Defendant Michael Pourshalimi filed a cross-complaint against Plaintiff. On May 24, 2023, the Court granted Defendants' m...

Excerpt: ... On July 18, 2023, Defendants served Plaintiff with discovery requests, including Form Interrogatories (Set One) from Defendant Cordero; Special Interrogatories (Set One) from Defendant Cordero; Form Interrogatories (Set One) from Defendant Donlen Mobility; and Requests for Production (Set One) from Cordero. (Zicarelli Decls., ¶ 2.) Plaintiff served unverified responses on August 28, 2023, and served the verifications on September 7. (Id., ¶ 3....

Excerpt: ...ry 16, 2023, the Court entered an order pursuant to the parties' stipulation which continued trial from May 16, 2023, to January 23, 2024. On October 5, 2023, Defendant filed and served a motion for summary judgment. The hearing on the motion for summary judgment is set for August 1, 2024. On October 25, 2023, Defendant filed and served a motion to continue the current trial date and all trial- related dates to a date after the hearing on Defenda...

Excerpt: ...efendant”) and Does 1 to 10, asserting causes of action for motor vehicle negligence and general negligence. On April 28, 2023, Defendant filed its answer. On May 26, 2023, Defendant served Plaintiff with discovery requests, including Form Interrogatories (Set One). (Paulick Decl., ¶ 6 & Exh. A.) Plaintiff did not respond. (Id., ¶ 7.) On October 25, 2023, Defendant filed this motion for an order compelling Plaintiff to respond to the Defendan...

Excerpt: ...he intersection of Arrow Highway and Mills Avenue in Claremont, California. On August 3, 2022, Defendant filed an Answer. On November 12, 2022, Plaintiff served Defendant with discovery requests, including Requests for Production (Set One). (Hobbs Decl., ¶ 4 & Exh. A.) As of the filing of this motion, Defendant had not responded to the discovery requests. (Id., ¶ 9.) On February 22, 2023, Plaintiff filed a motion to compel Defendant to provide ...

Excerpt: ...ctober 21, 2021, alleging a cause of action for negligence. On October 10, 2023, Defendant filed the motion to compel deposition of Plaintiff. Defendant also seeks sanctions. On October 27, 2023, Plaintiff filed an opposition and her own request for sanctions. On November 2, 2023, Defendant filed a reply and additional evidence in support of the motion. On November 3, Plaintiff filed objections to Defendant's evidence. On November 8, 2023, in con...

Excerpt: ...e negligence, general negligence, and loss of consortium against Defendant Ampac Logistics LLC and Does 1 to 100. On November 1, 2021, Plaintiff amended the complaint to name Rush Truck Leasing, Inc. (“Rush”) as Doe 1 and Ampak Logistics Inc. as Doe 2. On December 17, 2021, Plaintiff amended the complaint to name 3Power Logistics Management (“3Power”) as Doe 3. On January 5, 2022, Rush filed its answer and a cross-complaint against Ampak ...

Excerpt: ...d The court may grant leave to¿amend¿the pleadings at any stage of the action. (Code Civ. Proc., § 473, subd. (a).) A party may discover the need to¿amend¿after all pleadings are completed (the case is “at issue”) and new information requires a¿change in the nature of the claims or defenses previously pleaded. (See Dye v. Caterpillar, Inc. (2011) 195 Cal.App.4th 1366, 1380.) “The policy favoring amendment is so strong that it is a rar...

Excerpt: ...“Defendant”) and Does 1 through 50. Defendant filed an Answer on August 30, 2021. Last month, the Court granted the motion of State Farm Mutual Automobile Insurance Company (“State Farm”) to intervene, and on October 18, 2023, State Farm filed an Answer in Intervention. Back on December 2, 2022, Plaintiff served Defendant with discovery requests, including Requests for Admission (Set One) (“RFAs”). (Movsesian Decl., ¶ 5 & Exh. A.) De...

Excerpt: ...nce company is QBE. The complaint alleges that on November 4, 2019, Plaintiff was lawfully on Defendant's premise and sustained injury while participating in a reality television competition series produced by Defendants. On September 14, 2023, Defendants ITV America, Inc., Upper Ground Enterprises, Inc., (“UGE”), USA Network Media Productions LLC, NBCUniversal Medica, LLC, Comcast Corporation, and Kevin Wehrenberg (collectively “Defendants...

Excerpt: ...walk adjacent to Defendant's premises, encountered a broken stretch of sidewalk, struck it, fell off the scooter, and sustained injury. On September 5, 2023, the Court sustained Defendant's demurrer to the Complaint, with leave to amend. Plaintiff filed her First Amended Complaint (“FAC”) on September 18, 2023. Defendant demurred to the FAC on October 4. Plaintiff filed her opposition on October 18, and Defendant filed its reply on October 20...

Excerpt: ... products that fell on him in Defendant's store. Defendant filed an answer on August 16, 2022. According to Plaintiff's counsel, Plaintiff has been attempting for some time, without success, to schedule the depositions of two of Defendant's employees (Joseph Angulo and Laura Cancinos) as well as a person-most-qualified (“PMQ”) deposition of Defendant on certain topics. (Van Gelder Decl., ¶¶ 4- 17.) On July 3, 2023, Plaintiff served notices ...

Excerpt: ...a Complaint against Defendants City of Los Angeles, Travel Town Transportation Museum, City of Los Angeles Department of Parks and Recreation, and Does 1 through 50, asserting claims for premises liability and general negligence. On September 26, 2022, Plaintiffs filed a First Amended Complaint against the same defendants, asserting a single cause of action for premises liability. On October 31, 2022, Defendant City of Los Angeles (“Defendant�...

Excerpt: ... May 22, 2023. Also on May 22, Defendants served Form Interrogatories (Set One), Special Interrogatories (Set One), and Requests for Production of Documents (Set One) on Plaintiff. (Webb Decls., ¶ 2 & Exh. A.) Plaintiff has not responded to these discovery requests. (Id., ¶¶ 2-4.) Defendants filed the three motions to compel that are currently before the Court on August 28, 2023. Plaintiff has not filed any opposition. On October 10, 2023, the...

Excerpt: ...) filed a Complaint against Defendants City of Los Angeles, Travel Town Transportation Museum, City of Los Angeles Department of Parks and Recreation, and Does 1 through 50, asserting claims for premises liability and general negligence. On September 26, 2022, Plaintiffs filed a First Amended Complaint against the same defendants, asserting a single cause of action for premises liability. On October 31, 2022, Defendant City of Los Angeles (“Def...

Excerpt: ...nt filed his Answer to the Complaint. On July 17, 2023, counsel from the Ford, Walker firm associated in as co-counsel for Defendant. On August 21, 2023, counsel from the Ford, Walker firm substituted as counsel for Defendant. On September 21, 2023, Defendant filed the instant motion to continue trial and all trial-related dates. Plaintiff did not file any opposition to the motion. On October 16, 2023, Defendant filed a notice of non-opposition. ...

Excerpt: ...ction, Plaintiff also alleges a willful failure to warn. On December 15, 2021, Plaintiff filed an amendment to the complaint to name James W. Stewart, II (“Defendant”) as Doe 1. On June 2, 2023, Plaintiff filed the operative First Amended Complaint against City of Long Beach, Defendant, and Does 1 to 50, alleging causes of action for (1) negligence; (2) and premises liability. The FAC alleges that on or about November 10, 2020, Plaintiff was ...

Excerpt: ...) filed a Complaint against Defendants City of Los Angeles, Travel Town Transportation Museum, City of Los Angeles Department of Parks and Recreation, and Does 1 through 50, asserting claims for premises liability and general negligence. On September 26, 2022, Plaintiffs filed a First Amended Complaint against the same defendants, asserting a single cause of action for premises liability. On October 31, 2022, Defendant City of Los Angeles (“Def...

Excerpt: ...g causes of action for motor vehicle negligence and general negligence against Defendants Lyft, Inc., Crystal Villalobos, Juan C. Davalos, Guilda Asuncion Davalos, and Does 1 through 100. The named defendants all filed answers during the period of May through July 2023. On May 3, 2023, Defendant Villalobos filed a cross-complaint against Juan C. Davalos, Guilda Asuncion Davalos, and Roes 1 through 25. The named cross-defendants filed an answer to...

Excerpt: ...nt filed his Answer to the Complaint. On July 17, 2023, counsel from the Ford, Walker firm associated in as co-counsel for Defendant. On August 21, 2023, counsel from the Ford, Walker firm substituted as counsel for Defendant. On September 21, 2023, Defendant filed the instant motion to continue trial and all trial-related dates. Plaintiff did not file any opposition to the motion. On October 16, 2023, Defendant filed a notice of non-opposition. ...

Excerpt: ...cident that allegedly occurred on October 17, 2021. On January 19, 2023, Defendants Jim K. Garcia and Ian McNeal Guevara filed their answer. On May 5, 2023, Plaintiff Luca Bruno (“Plaintiff”) propounded written discovery to Defendant Jim Garcia (“Defendant”), including Requests for Production (Set One). (Miletic Decl., ¶ 3 & Exh. B.) As of the date of filing, Defendant had not responded to the discovery requests. (Id., ¶ 7.) On July 6, ...

Excerpt: ...a Complaint against Defendants City of Los Angeles, Travel Town Transportation Museum, City of Los Angeles Department of Parks and Recreation, and Does 1 through 50, asserting claims for premises liability and general negligence. On September 26, 2022, Plaintiffs filed a First Amended Complaint against the same defendants, asserting a single cause of action for premises liability. On October 31, 2022, Defendant City of Los Angeles (“Defendant�...

Excerpt: ...Defendant Courtney was allegedly driving a rental vehicle leased from Alamo Rental Car. On February 17, 2023, Plaintiff voluntarily dismissed Defendant Courtney. On May 15, 2023, Enterprise Rent-a-Car filed an answer to the complaint, stating that it had been erroneously sued as Alamo Rental Car Company. On September 25, 2023, Plaintiff filed a motion to set aside the dismissal of Defendant Courtney pursuant to Code of Civil Procedure section 473...

Excerpt: ...trepo (“Plaintiffs”) filed the Complaint against Defendants Geoffrey Thomas Craighead (“Defendant”) and Does 1-50, asserting causes of action for auto negligence and loss of consortium; in the Complaint, Plaintiffs allege that Defendant drove his automobile negligently and collided with the motorcycle on which Plaintiff Rolando Enrique Restrepo was riding. On May 11, 2022, Defendant filed his Answer. Liability is disputed. On September 28...

Excerpt: ...a Complaint against Defendants City of Los Angeles, Travel Town Transportation Museum, City of Los Angeles Department of Parks and Recreation, and Does 1 through 50, asserting claims for premises liability and general negligence. On September 26, 2022, Plaintiffs filed a First Amended Complaint against the same defendants, asserting a single cause of action for premises liability. On October 31, 2022, Defendant City of Los Angeles (“Defendant�...

Excerpt: ... 17, 2023, Plaintiff Karina Elizabeth Hernandez (“Plaintiff”) filed a complaint asserting causes of action for motor vehicle negligence and general negligence against Defendants Lyft, Inc., Crystal Villalobos, Juan C. Davalos, Guilda Asuncion Davalos, and Does 1 through 100. The named defendants all filed answers during the period of May through July 2023. On May 3, 2023, Defendant Villalobos filed a cross-complaint against Juan C. Davalos, G...

Excerpt: ... and negligence arising from Plaintiff's injury at a construction project. On August 9, 2023, Defendants American States Water Company and Golden State Water Company (“Defendants”) filed the instant motion to advance hearing on Motion for Summary Judgment (“MSJ”) or to continue trial. The MSJ is currently scheduled for November 4, 2024. No opposition has been filed by the other parties. Trial is currently scheduled for April 9, 2024. Lega...

Excerpt: ...nt”) filed his Answer. On that same day, Defendant served Plaintiff with discovery, including Requests for Production (Set One). (Andrews Decl., ¶ 2 & Exh. A.) Plaintiff never served responses to this discovery request. (Id., ¶ 5.) On August 31, 2023, Defendant filed the instant motion to compel Plaintiff to respond to the discovery. Defendant also requests sanctions. Plaintiff has not filed an opposition to the motion. The Court is aware tha...

Excerpt: ...vehicle negligence and general negligence against Henry Muyomba, the Estate of Henry Muyomba, Susan Tamale Nantongo, Fook Choon Lee, PV Holding Corp., and Does 1 through 100. Defendants Fook Choon Lee and PV Holding Corp. filed answers in July and August 2022. On August 12, 2022, Defendants Fook Choon Lee and PV Holding Corp. filed a cross-complaint against Henry Muyomba, the Estate of Henry Muyomba, Susan Tamale Nantongo, and Roes 1 through 20. ...

Excerpt: ...ract, (3) specific performance, (4) breach of contractual duty to pay a covered claim, and (5) breach of the implied obligation of good faith and fair dealing. According to the complaint, Thomas was an uninsured or underinsured motorist and State Farm has failed to pay the amounts due to Plaintiff under her uninsured motorist coverage policy. (Complaint, ¶¶ 51-79.) On October 4, 2022, the Court entered an order, based upon the stipulation of Pl...

Excerpt: ... answers on December 14 and 20, 2021. On March 21, 2022, Plaintiff dismissed Defendant Freedom Vision Surgery Center with prejudice. On August 3, 2023, Defendant Dana Tannenbaum (“Defendant”) filed this motion for summary judgment. On October 6, 2023, Plaintiff submitted a Notice of Non-Opposition. Legal Standard “The purpose of the law of summary judgment is to provide courts with a mechanism to cut through the parties' pleadings in order ...

Excerpt: ...on for (1) general negligence, (2) motor vehicle negligence, and (3) negligent entrustment, arising out of a vehicle accident that occurred on January 11, 2018. Defendant filed an answer on March 16, 2022. On September 26, 2023, Defendant two motions: (1) a motion to compel Plaintiff to respond to supplemental interrogatories; and (2) a motion to compel Plaintiff to respond to supplemental demands for production of documents. Plaintiff has not fi...

Excerpt: ...a Complaint against Defendants City of Los Angeles, Travel Town Transportation Museum, City of Los Angeles Department of Parks and Recreation, and Does 1 through 50, asserting claims for premises liability and general negligence. On September 26, 2022, Plaintiffs filed a First Amended Complaint against the same defendants, asserting a single cause of action for premises liability. On October 31, 2022, Defendant City of Los Angeles (“Defendant�...

Excerpt: ... in Downey, California. (Compl., ¶¶ 6, 12-13.) On February 7, 2022, Plaintiff filed her Complaint alleging one cause of action for negligence and a second cause of action for a dangerous condition of Government property under Government Code section 835 against Defendants City of Downey, County of Los Angeles, State of California, and Does 1 through 50. On March 9, 2021, the County of Los Angeles filed its answer. On March 11, 2021, the City of...

Excerpt: ...ach occurring on August 4, 2020. (Compl., p. 4.) Plaintiff filed her Complaint on August 10, 2021. On November 23, 2021, Plaintiff amended her Complaint to name SSA Terminals (Pier A), LLC (“Defendant”) as Doe 1. Defendant filed an answer on December 22, 2021. On March 24, 2023, Defendant served Plaintiff with Requests for Admission (Set No. 1), along with accompanying Form Interrogatories (Set No. 1). (Berry Decl., ¶ 3; Exhibits 1 and 2.) T...

Excerpt: ...and sustain injuries. On August 18, 2021, Defendants Young's Food Services, Inc. and Jose Manuel Santiago-Garcia (erroneously sued as Jose Santiago) (“Defendants”) filed their answer. On September 25, 2023, Defendants filed the instant motion to continue trial. No opposition has been filed. Trial is set for December 11, 2023. Legal Standard California Rules of Court, rule 3.1332, subdivision (c) states that although disfavored, the trial date...

Excerpt: ...cle accident on September 2, 2021, near the intersection of Santa Monica Boulevard and 16th Street in Santa Monica, California. On September 20, 2022, Plaintiff Samira Riahi (“Plaintiff”) filed a complaint asserting causes of action for general negligence and motor vehicle negligence against Defendants Jose Antonio Gomez Gutierrez, Imperfect Foods, Inc., and Does 1 through 25. Plaintiff alleges (among other things) that Defendant Gomez Gutier...

Excerpt: ...r vehicle negligence and general negligence against Clifford Thomas Shelton and Chelsey Miller (“Defendants”) and Does 1 through 100. Defendants filed their answer on October 7, 2021. Currently before the Court are two motions. First, on September 8, 2023, Defendants filed a motion to compel Plaintiff to appear for his deposition. Plaintiff filed an opposition on October 4. No reply was filed. Second, on September 20, 2023, Defendants filed a...

Excerpt: ...endants filed an answer that included a general denial but no affirmative defenses. On April 13, 2023, Defendants filed the instant motion to file a First Amended Answer. The proposed amended answer (attached to the moving papers) would, if allowed, add thirteen affirmative defenses alleging (among other things) that Plaintiff failed to state a cause of action, that the accident was caused by Plaintiff's own negligence or the negligence of others...

Excerpt: ... was struck by a vehicle that was being operated by Defendant William Davenport, during the scope of his employment. Defendants Miracle Method of Corpus Christi, Inc., William Alan Davenport, and Eddie Naro (“Defendants”) filed an answer on October 25, 2021. Defendant Miracle Method, Inc. filed an answer on October 27, 2021. On May 22, 2023, the Court granted Defendants' motion to compel Plaintiff to comply with a demand for a physical examin...

Excerpt: ...ndant”) and Does 1 through 50, alleging the following a single causes of action for premise liability. On January 27, 2021, Defendant filed his answer. On February 2, 2023, Defendant served Plaintiff with a Supplemental Demand for Production of Documents (Set One). (Petrosyan Decl., ¶ 5 & Exh. A.) Plaintiff never served responses. (Id., ¶ 12.) On June 9, 2023, Defendant filed the instant motion compel Plaintiff to respond to Defendant's Suppl...

Excerpt: ...l is currently set for November 16, 2023. Legal Standard California Rules of Court, rule 3.1332, subdivision (c) states that although disfavored, the trial date may be continued for “good cause,” which includes (without limitation): (1) unavailability of trial counsel or witnesses due to “death, illness, or other excusable circumstances”; (2) the addition of a new party depriving the new party (or other parties) from conducting discovery ...

Excerpt: ...interrogatories within 30 days after service. (Code Civ. Proc., § 2030.260, subd.(a).) If a party to whom interrogatories are directed does not provide a timely response, the propounding party may move for an order compelling response to the interrogatories. (Id., § 2030.290, subd. (b).) There is no time limit for a motion to compel initial responses, and no meet and confer efforts are required. (See id., § 2030.290; Sinaiko Healthcare Consult...

Excerpt: ...a. On August 16, 2022, Plaintiff filed her complaint against Defendant and Does 1 through 100. On September 27, 2022, Defendant filed its answer. On December 21, 2022, Defendant served Plaintiff with a Request for Statement of Damages. Under Code of Civil Procedure section 425.11, subdivision (b), a response was due within 15 days. (Rios Decl., Exh. 1.) Plaintiff served a Statement of Damages in response but it did not state any amounts; instead,...

Excerpt: ...paid before the date scheduled for the initial case management conference in the action. (Id., § 631(c).) If no case management conference is scheduled in a civil action, the fee shall be due no later than 365 calendar days after the filing of the initial complaint. (Id., § 631(c)(2).) A party waives jury trial by failing to timely pay the fee unless another party on the same side of the case has paid that fee. (Id., § 631(f)(5).) “The court...

Excerpt: ...ther excusable circumstances; (3) unavailability of trial counsel due to death, illness, or other excusable circumstances; (4) substitution of trial counsel required in the interests of justice; (5) addition of a new party or other parties in regard to a new party's involvement hasn't had a reasonable opportunity to conduct discovery and prepare for trial; (6) party's excused inability to obtain essential testimony, documents, or other material e...

Excerpt: ...int (“FAC”) on June 9, 2022, that (a) adds Maplebear, Inc. dba Instacart (“Maplebear”) as a new defendant; (b) asserts the negligence claim against Huang and Does 1 through 10; and (c) adds a new claim for negligent hiring, supervision, and retention against Maplebear and Does 11 through 50. Maplebear filed an answer to the FAC on July 15, 2022. On August 17, 2022, Maplebear filed a notice that Huang had filed a bankruptcy petition and th...

Excerpt: ...cle accident. The complaint asserts causes of action for (1) negligence, (2) negligence per se, and (3) statutory liability. On January 30, 2023, Plaintiff filed these motions to compel discovery responses. Plaintiff now moves for orders compelling Defendant Espinoza to serve full, complete, verified answers, without objections, to (1) Special Interrogatories, Set One, (2) Form Interrogatories, Set One, and (3) Request for Production of Documents...

Excerpt: ... Plaintiff on June 1, 2023. To date, Plaintiff has not responded to Defendant's discovery requests. On August 16, 2023, Defendant filed the instant motions to compel response to form interrogatories and requests for production of documents. Defendant also requests monetary sanctions in the amount of $1,260 for each motion. The total requested is $2,520. The motion is made pursuant to Code of Civil Procedure sections 2030.290 and 2030.300. No oppo...

Excerpt: ...ction for motor vehicle and general negligence. The complaint arises from an alleged automobile collision which occurred on October 26, 2019. On September 15, 2023, Defendant Aremy L. Villatoro-Lopez (“Defendant”) filed and served these two unopposed discovery motions seeking orders to compel Plaintiff to respond to Form Interrogatories (Set One) and Special Interrogatories (Set One). Defendant also seeks monetary sanctions. A third discovery...

Excerpt: ...orth a general denial and nine affirmative defenses. On March 4, 2022, the parties filed a stipulation, which the Court granted, to continue the trial date from April 1, 2022 to December 5, 2022. On December 1, 2022, the parties entered into another stipulation, which the Court granted, to continue trial from December 5, 2022 to October 26, 2023. Besides the parties' joint motion to continue trial, there has been no motion practice in this action...

Excerpt: ... Defendant's reserved Motion for Summary Judgment Hearing on November 6, 2024. In the alternative, Defendant asks that the Court specially set the hearing on their Motion for Summary Judgment to be consistent with the current trial date as per the California Code of Civil Procedure Section 437c(a)(3). Plaintiff opposes the request to set an earlier hearing for the summary judgment motion but does not oppose the request to continue trial. Addition...

Excerpt: ...ia. (Complaint, ¶¶ 1, 6.) Plaintiff Roscelia Pineda (“Plaintiff”) alleges that she was lawfully crossing the street in the crosswalk as a pedestrian when she was struck by the vehicle operated by Defendant Caroline Phillips (“Defendant”). (Ibid.) Plaintiff filed her Complaint on June 1, 2023, asserting a single cause of action for negligence against Defendant and Does 1 through 50. On August 31, 2023, Defendant filed an Answer consistin...

Excerpt: ...ther there a real risk or only a theoretical or potential risk of inconsistent results. The Court may need to continue this hearing and/or request supplemental briefing. Background The underlying action here arises out of the injuries allegedly suffered on March 27, 2019, by Plaintiff Willie Davis (“Plaintiff”). Plaintiff filed a complaint on March 22, 2021, asserting one cause of action for negligence against Defendants Torrance Refining Com...

Excerpt: ...entrustment, arising out of a vehicle accident that occurred on January 11, 2018. Defendant filed an answer on March 16, 2022. On September 11, 2023, Defendant filed a motion to compel plaintiff to appear at deposition. No opposition has been filed. Trial is scheduled for November 3, 2023. Legal Standard “Any party may obtain discovery … by taking in California the oral deposition of any person, including any party to the action.” (Code Civ...

Excerpt: ...wing causes of action: (1) battery; (2) assault; (3) false imprisonment; (4) intrusion of privacy; (5) intentional infliction of emotional distress; (6) negligence; and (7) unlawful eviction. Defendant filed an answer to the FAC on September 29, 2023. The parties were previously married. On April 2, 2019, Defendant filed a petition to have the marriage annulled on the ground of fraud (Los Angeles Superior Court Case No. 19STFL03890). Plaintiff fi...

Excerpt: ...sion (a), for good cause shown, the court may grant leave to take a subsequent deposition, and the parties, with the consent of any deponent who is not a party, may stipulate that a subsequent deposition be taken. (Code Civ. Proc. 2025.610(b).) A party makes a showing of good cause for discovery where such party shows the relevance of the information sought but also that the discovery is material to the issues in the case. (Associated Brewers Dis...

Excerpt: ...Plaintiff Lindsey Esquivel and Sally Ydelbira Tipple (“Plaintiff”) filed a complaint against Defendant Jeanine Rohn (“Defendant”) and Does 1 through 100 alleging causes of action for (1) motor vehicle negligence and (2) general negligence. Defendant filed her answer on September 7, 2022. On May 17, 2023, Defendant filed multiple motions to compel initial responses to discovery. Before the Court at this time are two of those motions: (1) D...

Excerpt: ...uary 16, 2022, Plaintiff filed a first amended complaint against Brown, Black Pyramid, and Does 2-50 for premises liability, negligent infliction of emotional distress, and negligence. On May 23, 2022, Brown and Black Pyramid (“Defendants”) filed an answer. On July 31, 2023, Plaintiff filed a motion to compel third party witness Maria Avila's compliance with Plaintiff's deposition subpoena for production of business records and remaining docu...

Excerpt: ...021, Plaintiff Lindsey Esquivel (“Esquivel”) and Sally Ydelbira Tipple (“Tipple”) filed a complaint against Defendant Jeanine Rohn (“Defendant”) and Does 1 through 100 alleging causes of action for (1) motor vehicle negligence and (2) general negligence. Defendant filed her answer on September 7, 2022. On May 17, 2023, Defendant filed multiple motions to compel initial responses to discovery. Before the Court at this time are three of...

Excerpt: ...on July 28, 2023, Plaintiff filed a First Amended Complaint (the “FAC”). In the FAC, Plaintiff alleges the following causes of action: (1) battery; (2) assault; (3) false imprisonment; (4) intrusion of privacy; (5) intentional infliction of emotional distress; (6) negligence; and (7) unlawful eviction. No answer has been filed, but Defendant has filed at least one motion seeking affirmative relief. The parties were previously married. On Apri...

Excerpt: ...t Defendant Jeanine Rohn (“Defendant”) and Does 1 through 100 alleging causes of action for (1) motor vehicle negligence and (2) general negligence. Defendant filed her answer on September 7, 2022. On May 17, 2023, Defendant filed multiple motions to compel initial responses to discovery. Before the Court at this time are three of those motions: (1) Defendant's motion to compel Plaintiff to provide initial responses to Special Interrogatories...

Excerpt: ...ntly operated their vehicle and collided into Plaintiff's motorcycle at or near the intersection of Pico Boulevard and Veteran Avenue in Los Angeles, California, causing Plaintiff's injuries. On December 14, 2022, based upon the stipulation of the parties, the Court continued the trial date from January 12, 2023, to December 4, 2023. On February 17, 2023, Plaintiff filed the operative First Amended Complaint (“FAC”), adding additional factual...

Excerpt: ...ing train, causing him to sustain severe and permanent injuries. On September 5, 2019, Plaintiff filed a complaint against Defendants City of Los Angeles, County of Los Angeles, Los Angeles County Metropolitan Transportation Authority, State of California, Union Pacific Railroad, and Does 1 through 50, asserting causes of action for negligence, premises liability, and dangerous condition of public property. Between October 24 and November 6, 2019...

Excerpt: ...all be accompanied by a copy of the answer or other pleading proposed to be filed therein, otherwise the application shall not be granted, and shall be made within a reasonable time, in no case exceeding six months, after the judgment, dismissal, order, or other proceeding was taken. (Ibid.) It is well settled that appellate courts have always been and are favorably disposed toward such action upon the part of the trial courts as will permit, rat...

Excerpt: ...��), and that he sustained injuries as a result. Plaintiff filed a Complaint on May 11, 2021, asserting one cause of action for motor vehicle negligence against Defendant and Does 1 through 10. Defendant filed her answer on May 12, 2022. As is relevant to this motion, on the same day that Defendant filed her answer, she propounded Form Interrogatories (Set One) on Plaintiff. (Garibyan Decl., ¶ 3 & Exh. A.) Plaintiff served responses on April 12,...

Excerpt: ...ivision (a), for good cause shown, the court may grant leave to take a subsequent deposition, and the parties, with the consent of any deponent who is not a party, may stipulate that a subsequent deposition be taken. (Code Civ. Proc. 2025.610(b).) A party makes a showing of good cause for discovery where such party shows the relevance of the information sought but also that the discovery is material to the issues in the case. (Associated Brewers ...

Excerpt: ...ons to compel initial responses to Form Interrogatories (Set One), Special Interrogatories (Set One), and Requests for Production (Set One). Defendant also requests monetary sanctions. No opposition has been filed. Legal Standard A party must respond to interrogatories within 30 days after service. (Code Civ. Proc., § 2030.260, subd.(a).) If a party to whom interrogatories are directed does not provide a timely response, the propounding party ma...

Excerpt: ...e of Defendant Paul Nichole Lawry (“Defendant”) and/or Does 1 through 50. Defendant served Form Interrogatories (Set One), Special Interrogatories (Set One), and Request for Production (Set One) on Plaintiff on September 14, 2022. (Weissman Decls., ¶ 2 & Exh. A.). Plaintiff has never served responses. (Id., ¶¶ 5-6.) Current before the Court are three discovery motions filed by Defendant on July 19, 2023: (1) Motion to Compel Responses to F...

Excerpt: ...nt, resulting in injuries to Plaintiff. In the Complaint, filed on June 22, 2022, Plaintiff asserts causes of action for motor vehicle negligence and general negligence against Heredia and Does 1 through 50. On July 15, 2022, Plaintiff amended the Complaint to name Red 1 Express Inc. as Doe 1. On January 26, 2023, Defendants Heredia and Red 1 Express Inc. (collectively, “Defendants”) filed their answer. Currently before the Court is Defendant...

Excerpt: ...ode of Civil Procedure section 877.6, subdivision (c). Background On January 7, 2021, Plaintiff Rosenda Ramirez Clark initiated this wrongful death action against Defendants City of Redondo Beach (“City”), Rudolfo Garcia Muro (“Muro”), Magdalena Garcia (“Garcia”), Maderos Cocina Mexicana Restaurant (“Restaurant”), Adriatica International Inc. (“Adriatica”), Jesus Manuel Gonzalez Cornejo (“Cornejo”), Martha Coronel and Sant...

Excerpt: ...Angeles brought a subrogation claim lawsuit on April 22, 2022, against Defendants City Terrace Service, Inc., Mohammad Amine Rahmani (collectively “Defendants”), and Does 1 through 10, asserting causes of action for general negligence and breach of contract. Defendants answered on June 30, 2022. On October 14, 2022, plaintiff amended the complaint to correct the identification of Defendant Rahmani. On June 7, 2022, Plaintiffs Joel S. and Tere...

Excerpt: ... motion was vacated). The matter has been set for trial several times. The parties filed extensive trial documents for the trial date of October 21, 2022, but at the Final Status Conference on October 7 the trial was continued to February 14, 2023. On motion of Plaintiff, trial was continued again to the current date of October 9, 2023. On August 8, 2023, Defendant Costco Wholesale Corporation (“Defendant” or “Costco”) filed this motion f...

Excerpt: ... Plaintiff to serve verified responses to Defendant's Form Interrogatories (Set One), Special Interrogatories (Set One), and Request for Production of Documents (Set One). No opposition has been filed. Legal Standard A responding party has 30 days after service of interrogatories and an inspection demand to serve their responses on the propounding party and/or party making the demand. (Code of Civ. Proc., §§ 2030.260(a), 2031.260(a).) However, ...

Excerpt: ...onal distress; and negligent infliction of emotional distress. The complaint alleges that Plaintiff sustained personal injuries as a result of an incident in which Mr. Pepi, an employee of American Airlines, grabbed and struck Plaintiff at a Transportation Security Administration (“TSA”) security checkpoint in the Los Angeles International Airport. At the time of the incident, Mr. Pepi was wearing an American Airlines uniform but he had not y...

Excerpt: ...r vehicle and (2) general negligence, stemming from vehicle collision that occurred on January 29, 2019. Defendant filed his answer on May 9, 2022. On the same day, Defendant served Plaintiff with Form Interrogatories (Set One) and Request for Production (Set One). On September 27, 2022, the Court granted the motion of Plaintiff's counsel to be relieved. Plaintiff has been self-represented since then. On October 17, 2022, Defendant served Plainti...

Excerpt: ...n of La Cienega Boulevard and Wilshire Boulevard in Beverly Hills, California. On July 2, 2020, Plaintiffs Sion Goel and Shokouh Adamous (“Plaintiff”) sued Defendants Camille D. Muepo, Zacharie Muepo, and Christina Muepo (“Defendants”), and Does 1 through 100, inclusive asserting causes of action for general negligence and motor vehicle negligence. On January 7, 2022, Defendants filed their answer to the complaint. That same day, Defendan...