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: ...ue No. 1] casue of action as well as the request for punitive damages [Issue No. 2] in the FAC. Defendants also move for summary adjudication of a cause of action asserted in their own cross-complaint, the 8 th (declaratory relief) cause of action against Cross- Defendant Workforce Enterprises WFE, Inc. (“WFE”). (Notice of Motion, pg. 1.) Background On July 6, 2021, Plaintiff filed this action and on July 28, 2021, Plaintiff filed his first a...

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...

Excerpt: ...n of La Cienega Boulevard and Wilshire Boulevard in Beverly Hills, California. On July 2, 2020, Plaintiffs Sion Goel (“Plaintiff”) and Shokouh Adamous 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...

Excerpt: .... Plaintiffs Katty Yasharal, Minoo Yasharal, Ashley Soomekh and Aaron Soomekh were involved in the July 13, 2018 accident. On January 28, 2021, Plaintiffs voluntarily dismissed Defendants Darron Maxtion, Anthony Saleh, Freebrandz Tourgin, LLC and Emagen Entertainment Group. On June 6, 2023, Defendants Avis Rent A Car Systems, LLC and PV Holding Corp. filed the instant motion for summary judgment. No oppositions were filed to the motion. On August...

Excerpt: ...h Plaintiff was injured. The complaint includes a request for punitive damages. On July 5, 2023, Defendant filed a motion to strike the request for punitive damages and other portions of the Complaint. Plaintiff did not file an opposition. On August 4, 2023, this Court continued the hearing on the motion to strike to allow Defendant to file a declaration from counsel demonstrating compliance with the meet-and-confer requirement of Code of Civil P...

Excerpt: ...ness because of death, illness, or other excusable circumstances; (2) The unavailability of a party because of death, illness, or other excusable circumstances; (3) The unavailability of trial counsel because of death, illness, or other excusable circumstances; (4) The substitution of trial counsel, but only where there is an affirmative showing that the substitution is required in the interests of justice; (5) The addition of a new party if: (A)...

Excerpt: ... the motion to continue trial. Background This case arises out of an automobile accident that allegedly occurred on February 18, 2019, in Santa Clarita, California. Plaintiffs Jason and Anne Duplantis (“Plaintiffs”), filed this action on January 28, 2021, alleging causes of action for negligence and loss of consortium against Defendants Jerry and Yolanda Byrne (“Defendants”) and Does 1 through 50. Defendants filed their answer on April 6,...

Excerpt: ...Pena (“Pena”); and Does 1 through 50. Gomez alleged that he, G&G, and Jaguar all reside in Los Angeles County and that Pena resides in Riverside County. The Court will refer to this action as the “Gomez Action.” On September 7, 2022, Gomez filed a First Amended Complaint (the “FAC”) against the same defendants except for Jaguar, which was omitted. In the FAC, Gomez alleges that he is a resident of Los Angeles County, that Pena is a re...

Excerpt: ...dants LACMTA, Romero, Quin Hui Cham and Phuc Cham for negligence. LACMTA filed a cross- complaint against Quin Hui Cham and Phuc Cham for indemnity, contribution and declaratory relief. In April 2020, Defendants Quin Hui Cham and Phuc Cham (“Defendants”) settled with Plaintiff for $1,500. (Wang Decl., Exh. A.) Plaintiff deposited the settlement check in August 2020. (Id., Exh. B.) On December 18, 2020, the Court denied the Application for Det...

Excerpt: ... in that action, if the matter either is itself admissible in evidence or appears reasonably calculated to lead to the discovery of admissible evidence.” (Code Civ. Proc., § 2017.010.) Discovery from a nonparty may be obtained by a deposition subpoena. Code of Civil Procedure section 1987.1, subdivision (a), provides that if a subpoena requires the production of documents, the Court may, upon motion reasonably made by a party, make an order �...

Excerpt: ...olving a common question of law or fact are pending before the court, it may order a joint hearing or trial of any or all the matters in issue in the actions; it may order all the actions consolidated and it may make such orders concerning proceedings therein as may tend to avoid unnecessary costs or delay.” (Code Civ. Proc., § 1048, subd. (a).) The purpose of consolidation is to enhance trial court efficiency by avoiding unnecessary duplicati...

Excerpt: ...25, alleging causes of action for motor vehicle negligence, general negligence, and negligent infliction of emotional distress (“NIED”). In addition to physical injuries, and general damages, Plaintiff alleges (among other things) lost earnings and emotional distress from seeing injuries to his minor child, who was riding in the car with him. On September 29, 2022, Defendant filed his Answer. On December 9, 2022, Plaintiff served discovery Sp...

Excerpt: ...n against Defendants Clubbizz.LLC (“Clubbizz”), Douglas C. MacLise, Alyce R. MacLise, and Does 1 through 50. On December 2, 2022, Clubbizz filed an Answer and a Cross-Complaint for indemnity against Roes 1 through 100. On June 5, 2023, Plaintiff amended his Complaint to name Salient Consulting Group Inc. (“Salient”) as Doe 1. On August 1, 2023, Salient filed the instant Demurrer. Salient also filed a Cross-Complaint for indemnity against ...

Excerpt: ...de of Civ. Proc., §§ 2030.260(a), 2031.260(a).) However, if interrogatories and inspection demand are served by electronic service, a responding party has an additional 2 court days to respond. (Code of Civ. Proc., § 1010.6(a)(3)(B).) If the responding party fails to timely respond to the interrogatories, “The party to whom the interrogatories are directed waives any right to exercise the option to produce writings under Section 2030.230, as...

Excerpt: ...9 in Santa Fe Springs, California. Defendants' counsel states that on behalf of Defendant Salvador Gallegos (“Defendant”), he served Special Interrogatories (Set Two) on Plaintiff Antonia Mendez (“Plaintiff”) on April 19, 2023. (Semon Decl., ¶ 6 & Exh. C.) Defendant did not receive responses, and on May 31, 2023, Defendant's counsel inquired regarding the status. (Id., ¶ 7 & Exh. D.) Plaintiff's counsel responded that he had not receive...

Excerpt: ...25, alleging causes of action for motor vehicle negligence, general negligence, and negligent infliction of emotional distress (“NIED”). In addition to physical injuries, and general damages, Plaintiff alleges (among other things) lost earnings and emotional distress from seeing injuries to his minor child, who was riding in the car with him. On September 29, 2022, Defendant filed his Answer. On August 8, 2022, Plaintiff served discovery on D...

Excerpt: ...018 at or around 7001 Garfield Avenue, Bell Gardens, CA 90201 due to Defendants alleged negligent acts. Trial is currently set for March 13, 2024. On May 9, 2023, Defendant Francisco Jose Maisch (“Defendant”) filed two discovery motions. They are scheduled to be heard on April 3, 2024, after the trial date. (Mittskus Decl., ¶ 3.) On July 10, 2023, Defendant filed another discovery motion. That motion is scheduled to be heard on March 27, 202...

Excerpt: ...25, alleging causes of action for motor vehicle negligence, general negligence, and negligent infliction of emotional distress (“NIED”). In addition to physical injuries, and general damages, Plaintiff alleges (among other things) lost earnings and emotional distress from seeing injuries to his minor child, who was riding in the car with him. On September 29, 2022, Defendant filed his Answer. On August 8, 2022, Plaintiff served discovery on D...

Excerpt: ...ccessful efforts to obtain an agreement for the date of Defendant's person most qualified (PMQ) on certain identified subjects, Plaintiff's counsel noticed the deposition for January 10, 2023. (Nalbandyan Decl., Exhs. A, D, E, F, I.) Defendant objected to the deposition notice on the sole ground that Plaintiff had scheduled the deposition unilaterally and that the deponent and counsel were “not available.” (Id., Exh. J.) Defendant did not pro...

Excerpt: ...gligence and general negligence against Defendant Serghei Vasilievich Petrenco (“Defendant”). Defendant filed an answer on March 9, 2023. On May 17, 2023, Plaintiff served Form Interrogatories (Set One) and Special Interrogatories (Set One) on Defendant. (Champion Decl., ¶ 2 & Exh. 1.) Defendant requested, and Plaintiff agreed to, a three-week extension of time for Defendant to respond. (Id., ¶ 4 & Exh. 3.) Notwithstanding the extension, De...

Excerpt: ...tion of Plaintiff for July 17, 2023. (Reddiconto Decl. filed 7/19/23, ¶ 27 & Exh. 22.) Plaintiff counsel served an objection to the deposition notice that stated only that the deposition date had not been agreed to in advance. (Id., Exh. 23.) Plaintiff did not offer alternative dates. (Id.) Defendant refused to take the deposition off calendar and took Plaintiff's non-appearance. (Id., ¶¶ 29-32 & Exh. 26.) Defendant then followed up with Plain...

Excerpt: ... asserting a cause of action for premises liability stemming from an injury allegedly sustained on or about October 2, 2019, on Defendant's premises. On January 3, 2023, Defendant Big Lots Stores – PNS, LLC (erroneously sued as Big Lots Stores, Inc.) (“Defendant” filed an answer to the complaint. The same day, Defendant served Form Interrogatories (Set One), Special Interrogatories (Set One), and Requests for Production (Set One) on Plainti...

Excerpt: ...County of Los Angeles, erroneously sued as Los Angeles County Sheriff's Department (“Defendant”), filed an answer to the complaint. On the same day, Defendant served discovery on Plaintiff Terrell Lee (“Plaintiff”), including Form Interrogatories (Set One), Special Interrogatories (Set One), Requests for Production (Set One). Defendant also served on Plaintiff a Request for Statement of Damages. (Whitelaw Decls., ¶¶ 3-4 & Exhs. A-B.) Pl...

Excerpt: ...nts Aaron Lee Ruskin, Shauna Ruskin, George Favela, and Does 1 through 50. On December 13, 2018, Defendants Aaron Lee Ruskin and Jorge Favela (erroneously sued as George Favela) (“Defendants”) filed an answer. (Defendant Shauna Ruskin subsequently filed an answer, but all claims against her were dismissed.) When the complaint was filed, attorney Vahagn Koshkaryan represented all three plaintiffs. On December 26, 2019, Plaintiff Alvarez (only)...

Excerpt: ...ted, and maintained by Defendant Yard House USA, Inc. (sued as The Yard House, L.P.) (“Defendant”) on Shoreline Village Drive in Long Beach, California. On August 16, 2022, Plaintiff filed her complaint against Defendant and Does 1 through 100. On September 27, 2022, Defendant filed its answer. On or about June 13, 2023, Defendant issued a subpoena to American Express, Plaintiff's current employer, for all of her personnel records, payroll re...

Excerpt: ...nc. and Does 1 through 100, alleging the following causes of action: (1) negligence; (2) vicarious liability; (3) strict products liability; (4) negligence – products liability; and (5) negligence – failure to warn. On July 19, 2023, Defendant Carson Trailer Inc. (hereinafter, “Defendant”) filed three separate motions seeking to compel Plaintiff Antonio Iezza III (“Plaintiff”) to provide initial responses to Defendant's Form Interroga...

Excerpt: ...n Compton, California. On May 9, 2022, Defendant Alpha Beta Company (“Defendant”) filed an answer. On May 25, 2023, Plaintiff served two deposition notices that are the subject of the two motions set for hearing: (1) a notice that Plaintiff would take the deposition of Defendant's employee Alondra Garcia Carcamo (“Garcia”) by Zoom video conference on July 18, 2023; and (2) a notice that Plaintiff would take the deposition of Defendant's p...

Excerpt: ...Plaintiff's vehicle. Plaintiff filed the Complaint on June 28, 2021. Defendant filed the Answer on January 25, 2022. On or about September 28, 2022, Plaintiff served Defendant with Requests for Admissions, Set Two. (Choo Decl., ¶ 5 & Exh. 2.) Defendant never responded. (Id., ¶ 7, 10.) Plaintiff filed the instant Motion for an Order to have Truth of Matters Specified in Plaintiff's Request for Admissions Deemed Admitted and for Sanctions of $754...

Excerpt: ...g other things) that Defendant “raised her glass of water towards Plaintiff, stared at him and sta[r]ted yelling obscene words at Plaintiff right before threw the glass at Plaintiff from a distance of less than four (4) from Plaintiff.” (Complaint, ¶ 9.) Plaintiff asserts (among other things) that the glass hit him “on the left cheekbone area injuring Plaintiffs cheekbone, left eye socket and left ear.” (Id., ¶ 10.) Plaintiff filed the ...

Excerpt: ...y 29, 2022. The same day that she filed her answer, Defendant propounded form interrogatories, special interrogatories, requests for production, and requests for admission. (Clark Decls., ¶ 2.) The responses were initially due on or about August 31, 2022. (Ibid.) After numerous extensions were requested and granted, Plaintiff's responses were due on February 16, 2023. (Id., ¶¶ 3-10.) What happened next, or did not happen next, is subject to di...

Excerpt: ... only concerning Plaintiff's neck, left shoulder, and back, and further MODIFIED them to be limited to records only from January 1, 2019 to the present and, with those limitations, otherwise DENIES the motion to quash. Background On November 29, 2021, Plaintiff Manuel Lopez Osorio (“Plaintiff”) filed this action against Defendants Ashik B. Mostofa, Administrative Services Cooperative, Inc., Yellow Cab Cooperative, Inc., and Does 1 to 50, asse...

Excerpt: ...on, Department of California Highway Patrol, Teron Liggins, and Trino Naranjo alleging causes of action for dangerous condition of public property, negligence (two counts), negligent infliction of emotional distress, and loss of consortium. This is referred to as the “Gutierrez Action.” On February 14, 2022, in case number 22STLC00914, Plaintiff Aspire General Insurance Company filed a complaint for subrogation against Defendant Teron Liggins...

Excerpt: ... by defendants. On April 7, 2022, Plaintiff filed her Complaint asserting causes of action for negligence and negligent hiring, supervision, and retention against Defendants P.W. Stephens Environmental, Inc. (“PWSE”), Mike Jabbour (“Jabbour”), and Does 1 through 50. After Jabbour's demurrer was sustained with leave to amend, Plaintiff filed her First Amended Complaint (“FAC”) on August 8, 2022. PWSE filed its answer to the FAC on Sept...

Excerpt: ...Complaint asserting causes of action for (1) general negligence and (2) premises liability against defendants Vive Night Club, Ruben Aguinaga, individually and dba Vive Night Club, Matrix Entertainment, and Does 1 through 50. In the Complaint, Plaintiff alleges that on July 11, 2021, she was “walking to a table at Defendants' place of business when she slipped and fell on the wet floor, falling and sustaining bodily injuries including a facial ...

Excerpt: ...alleges (among other things) that Defendant “raised her glass of water towards Plaintiff, stared at him and sta[r]ted yelling obscene words at Plaintiff right before threw the glass at Plaintiff from a distance of less than four (4) from Plaintiff.” (Complaint, ¶ 9.) Plaintiff asserts (among other things) that the glass hit him “on the left cheekbone area injuring Plaintiffs cheekbone, left eye socket and left ear.” (Id., ¶ 10.) Plainti...

Excerpt: ... Plaintiff was on Defendant's premises. On July 20, 2023, Defendant FSC Corporation DBA Il Pastaio, Inc. filed a demurrer. No opposition has been filed. Legal Standard A general demurrer tests whether the complaint states a cause of action. (Hahn v. Mirda (2007) 147 Cal.App.4th 740, 747.) When considering demurrers, courts read the allegations liberally and in context. (Taylor v. City of Los Angeles Dept. of Water and Power (2006) 144 Cal.App.4th...

Excerpt: ...er 13, 2018 on Bundy Drive in the County of Los Angeles. The named defendants filed their answers on March 24, 2002; September 1, 2022; and January 18, 2023. On May 9, 2023, Defendant James Pierre (“Defendant”) served (a) Special Interrogatories, Set Two (Nos. 36-37); (b) Supplemental Requests for Production of Documents; and (c) Supplemental Interrogatories. (Mendoza Decls., ¶ 3 & Exh. A.) As of the date of filing, no responses had been rec...

Excerpt: ...cle collided with Plaintiff Martorell's vehicle; and the force of the collision pushed Plaintiff Martorell's vehicle into Plaintiff Roper's vehicle. (Complaint, ¶¶ 8-9, 21.) Defendant Lyft filed an answer on April 27, 2020. Defendant Zepeda Garcia was served by substitute service on or about June 4, 2020. He filed a motion to quash the service, but he failed to appear at the hearing, and the motion was taken off calendar. His default was taken ...

Excerpt: ...Angeles, California. Plaintiff filed the Complaint on February 4, 2021, asserting causes of action for motor vehicle negligence and general negligence against Defendants Dmitrii Toradze (“Toradze”), Christian James Glover (“Glover”), and Does 1 through 50. The Complaint alleges that Glover was driving behind Plaintiff; that Toradze was driving behind Glover; and that a collision between Toradze and Glover caused Glover's vehicle “to vio...