Excerpt: ...ntiffs' First and Third Causes of Action for Quiet Title against Hratchia. Plaintiffs base this Motion on the grounds that the following undisputed facts establish that there is no genuine material dispute that Hratchia does not have an interest in either of the properties at issue in this action: (A) in this action, Plaintiffs have only two remaining claims against Hratchia— quiet title claims to each of 703 East Angeleno Avenue, Burbank, Cali...

Excerpt: ... FILE FAC] RELIEF REQUESTED Plaintiffs, Levon H. Bardakjian and Sylvia R. Bardakjian, will and hereby do move this Court for an order granting Plaintiffs leave to file a First Amended Complaint (FAC). This Motion is made pursuant to Code of Civil Procedure §§ 473(a)(1) and 576 and California Rules of Court Rule 3.1324 on the grounds that the requested amendment is in the interests of justice and supported by the facts alleged in the proposed Fi...

Excerpt: ...an order granting leave to file a cross-complaint against Defendant Juan Jose Beltran for indemnity. BACKGROUND On 06/02/2023, Plaintiff, Vardan Baghdasaryan, filed a Complaint against Defendants Juan Jose Beltran and Hovsep Hovsepyan. The allegations in the Complaint arise from a motor vehicle accident that occurred on 10/12/2022 on I-134. On 07/26/2023, Defendant, Juan Jose Beltran, filed a Cross-Complaint against Defendant, Hovsep Hovsepyan, a...

Excerpt: ...ve and confirm an award of attorneys fees in the amount of $134,515.00, and costs in the amount of $10,277.92, which represents the actual fees and costs incurred by ECJ since entry of the First ECJ Payment Order. In addition, ECJ requests that the Court order the approved fees and costs to be paid as an administrative expense of the receivership estate by the Replacement Receiver. ECJ's request for this supplemental order approving and confirmin...

Excerpt: ...r sustaining their demurrer to Plaintiffs' First Amended Complaint (FAC). Defendants Association, Hartounian, and Gevorgyani demur generally or specially to the first cause of action for “Fraud” on the following grounds: 1. The first cause of action for fraud fails to state facts sufficient to constitute a cause of action because (1) plaintiff Gonzalez has failed to allege fraud with the requisite specificity and/or appropriate and sufficient...

Excerpt: ...Associates, LLC; and Brookfield Properties Retail, Inc. (Galleria Defendants) Responding Party: No Opposition submitted by Plaintiff Proof of Service Timely Filed (CRC Rule 3.1300): Ok 16/21 Court Days Lapsed (CCP 1005(b)): Ok Proper Address (CCP §1013, §1013a, §1013b):Ok Moving Papers: Notice/Motion; Proposed Order; Hunt Declaration Opposition Papers: No Opposition submitted Reply: No Reply submitted RELIEF REQUESTED Galleria Defendants move ...

Excerpt: ...ries, Set One, under C.C.P. § 2030.290 and Request for Costs, Sanctions, and Attorney's Fees under C.C.P. §§ 2023.010 et seq. and 2030.290 et seq. against Defendant and/or the Attorney of Record, HESTER LAW GROUP, APC. Plaintiff will also seek sanctions, reimbursement of costs and attorney's fees against Defendant and its counsel of record, Hester Law Group, APC in the amount of $1,811.65 under Cal. Civ. Proc. Code §§ 2023.010 et seq. and 20...

Excerpt: ...M”) objections and compel further responses to Plaintiffs' Request for Production of Documents, Set One, numbers 1- 70 (collectively, the “RFPs”). Plaintiffs bring this Motion pursuant to California Code of Civil Procedure §§ 2031.310, and 2031.320, on the grounds that Defendant failed to provide adequate responses to Plaintiffs' RFPs, which seek documents relevant to their Song-Beverly Consumer Warranty Act (“SBA”) causes of action. ...

Excerpt: ... Plaintiff moves pursuant to CCP §2031.310 on the grounds that Defendant has failed to provide adequate responses to Plaintiff's requests, which seek documents directly relevant to her claims under the Song-Beverly Consumer Warranty Act. Procedural Moving Party: Plaintiff, Milagro J. Reynoso Responding Party: Defendant, FCA US LLC Proof of Service Timely Filed (CRC Rule 3.1300): Ok 16/21 Court Days Lapsed (CCP 1005(b)): Ok Proper Address (CCP §...

Excerpt: ...existing arbitration agreements and to stay the action pending the outcome of arbitration. BACKGROUND: Plaintiffs Ojeda Yuri and Leonel H. Escobar (collectively, “Plaintiffs”) initiated this action against Defendants Hyundai Motor America (“HMA”) and Doe 1, an entity of unknown form dba Keyes Hyundai of Van Nuys (“Keyes Hyundai”), alleging the following causes of action: (1) violation of Song-Beverly Act – Breach of Express Warranty...

Excerpt: ...s of action – (1) Premises Liability and (2) General Negligence. Plaintiff alleges that while they were in Defendant Glendale Adventist Health Center's place of business as a patron, active construction work was conducted by Cornerstone Construction, and Plaintiff tripped over an object on the floor that caused Plaintiff to fall. On 06/02/2023, Defendant, Cornerstone Construction Group, Inc., filed a Cross-Complaint against Chapala Concrete, In...

Excerpt: ...laint (FAC) alleging the following nine causes of action: (1) Damages for Breach of Oral Agreement, (2) Damages for Breach of Written Agreement, (3) Damages for Breach of Fiduciary Duty, (4) Damages for Fraud, (5) Damages for Fraud, (6) Promissory Estoppel, (7) Accounting, (8) Damages for Unjust Enrichment, and (9) Dissolution of Partnership. The first through sixth causes of action were alleged against Defendant Sarksian only. The seventh throug...

Excerpt: ...ounds: 1. The Third Cause of Action for breach of covenant of good faith and fair dealing as it is fatally uncertain and fails to state facts sufficient to state a cause of action and is therefore subject to demurrer under California Code of Civil Procedure sections 430.10(e)&(f). 2. The Fourth Cause of Action for intentional misrepresentation as it is fatally uncertain and fails to state facts sufficient to state a cause of action and is therefo...

Excerpt: ...omplaint (FAC) alleging the following nine causes of action: (1) Damages for Breach of Oral Agreement, (2) Damages for Breach of Written Agreement, (3) Damages for Breach of Fiduciary Duty, (4) Damages for Fraud, (5) Damages for Fraud, (6) Promissory Estoppel, (7) Accounting, (8) Damages for Unjust Enrichment, and (9) Dissolution of Partnership. The first through sixth causes of action were alleged against Defendant Sarksian only. The seventh thr...

Excerpt: ...o state the first cause of action for general negligence as against Defendant and is uncertain. (Civ. Proc. Code, §§ 430.10 (e), (f).) 2. Plaintiff's FAC fails to allege sufficient facts to state the second cause of action for premises liability (count one-negligence) as against Defendant and is uncertain. (Civ. Proc. Code, §§ 430.10 (e), (f).) 3. Plaintiff's FAC fails to allege sufficient facts to state the second cause of action for premise...