Excerpt: ...aint (“FAC”), Plaintiff founded Konda Tech to develop semiconductor devices known as Field Programmable Gate Arrays (“FPGA's”). (FAC, ¶¶ 2, 29.) In 2009, he was introduced to Markovic, a professor at UCLA who offered him funding for his work. (Id. at ¶ 30.) Plaintiff sent Markovic his business plan, but when he visited UCLA to present the plan, Markovic told him that UCLA does not fund technologies built outside of UCLA. (Ibid.) Noneth...

Excerpt: ... Chen (“Chen”), as owner of La Encina. (See XC, ¶ 9.) Group One performed the work and labor for, and furnished all necessary materials, services and equipment to be used in the project, and advanced significant sums of money toward the payment of subcontractors, labor, materials, equipment and other services in connection with the construction project. (See XC, ¶¶ 14‐15.) Immediately after the La Encina project commenced, La Encina fail...

Excerpt: ...ver a 17 day period totaling $46,683,232. Chakravarthy departed Ubiquiti soon after the loss, and Ubiquiti sought coverage for the alleged loss, pursuant to the Computer Fraud and Funds Transfer Fraud coverages of the Commercial Crime Policy issued by defendant National Union Fire Insurance Company of Pittsburgh, PA (“Insurer”). Insurer denied coverage purportedly because the alleged loss did not fall within either insuring agreement. Ubiquit...

Excerpt: .... Nesse failed to act with a sufficient degree of competence and committed malpractice in representing Plaintiff. (Id. at ¶ 6.) Due to his negligence, the resulting custody orders were deficient in various ways and Plaintiff's children were not sufficiently protected. (Ibid.) Plaintiff attributes Mr. Nesse's negligent representation to his chronic and ultimately terminal illness which he did not disclose. (Id. at ¶ 8.) Since his representation ...

Excerpt: ...ifornia's Secretary of State as a nonprofit corporation. Jin and Li would continue to serve on the Board of the now‐incorporated association. As a result, Li was identified as an executive of the association in the application the association submitted to the IRS to obtain its tax exemption. Li became upset by this and accused Jin in public among association members and in a messaging thread of having “raped” him, “sold him out,” and us...

Excerpt: ...f Jeffrey Dickson (collectively, “Plaintiffs”). (See Def.'s separate statement in opposition to motion for summary judgment, undisputed material facts nos. (“UMFs”) 4‐6.) Timothy was 17‐years old on the date of the action, and the vehicle was owned by his parents and defendants, Michelle and Barry Manderson. (UMFs 7‐8.) Defendant Wendy Mann (“Mann”) allowed her granddaughter, Mikaela Kirkman, to have a pre‐prom dinner at her h...

Excerpt: ...erty”). (SAC, ¶ 7, 10.) In 2005, Pham sought to purchase the Property. (Id. at ¶ 11.) Pham hired a mortgage broker who misrepresented the terms of the loan, and forged documents and signatures to complete the transaction. (Id. at ¶¶ 14, 16.) In 2009, Plaintiff sought to repurchase the Property from Pham. (SAC, ¶ 17.) They executed a purchase agreement, followed by a grant deed transferring legal title back to Plaintiff. (Id. at ¶¶ 22, 23...

Excerpt: ...ing that Kuta failed to pay back a loan that was due when Kuta separated from employment with ColorTokens. Defendant ColorTokens served several discovery requests on Kuta and has filed the instant motion to compel further discovery responses. The requested responses are targeted at discovering information regarding Linkaj, a competing company ColorTokens alleges Kuta and several of his coworkers created while they were still employed with ColorTo...

Excerpt: ...inst SJKCC. According to the allegations of the cross‐complaint, in 2017, SJKCC merged with the Way Church (“Way”). (Cross‐Complaint, ¶ ¶ 19, 20.) At the time of the merger, both churches were members of KECA, and were bound by its bylaws. (Id. at ¶ 20.) As a result of the merger, SJKCC became the only true “San Jose Korean Central Church,” and they assumed all rights under that name. (Id. at ¶ 22.) Consistent with KECA's constitu...

Excerpt: ... 2d COA.) At the time of the accident, Leonti was driving in the course of his employment with Caltrans. (Ibid.) Plaintiff is Thomas Wydra's husband, and she alleges that she suffered multiple damages as a result of the death of her husband. Therefore, she alleges two causes of action for: (1) motor vehicle negligence; and (2) general negligence. Before the Court are demurrers brought by Leonti and Caltrans. II. Demurrer Caltrans demurs to both c...

Excerpt: ...quirements of the construction contract, and below the standards of quality workmanship, and suspended its work, resulting in damage to the property. (See complaint, ¶¶ 11‐ 15.) As a condition of the issuance, maintenance and renewal of a contractor's license, Di Maggio Construction was required at the time of the project to have on file with the registrar a contractor's bond in the principal sum of $12,500. (See complaint, ¶ 38.) Defendant ...

Excerpt: ... Apps's contract with Boina by soliciting and inducing Boina to breach his contract with Apps. On March 22, 2019, Apps filed a complaint against Ramtek, asserting causes of action for breach of contract, breach of implied covenant of good faith and fair dealing, intentional interference, intentional interference with prospective economic advantage, and common counts. Plaintiff Apps served a subpoena on Wipro Limited (“Wipro”), a company that ...

Excerpt: ...tiffs entered into a written agreement with defendants Ruffo Tile & Stone, LLC and Ruffo Tile & Stone (collectively, “Ruffo”) to install a specific type of high‐end tile, known as Porcelain Euro West in accordance with all specifications and standards established by the Tile Council of North America or Marble Institute of American, utilizing all appropriate tools, equipment and mortar. (See TAC, ¶¶ 12‐ 15.) Ruffo was also contracted to ...

Excerpt: ...middle man—Plaintiff— to sell specialty sensors directly to customers. Plaintiff alleges defendant Lumasense thereby breached their agreement granting it an exclusive license to customize and resell fiber‐optic thermal sensors and nondispersive infrared sensors to the ten companies specified in their value‐added reseller agreement (the “Agreement”). Plaintiff alleges Lumasense misappropriated its trade secrets in the process and faile...

Excerpt: ... written retainer agreement. (See First Amended Complaint [“FAC”] at Ex. A.) Plaintiff Mezzetti Financial Services (“Plaintiff”) is the assignee for attorney Mosher. (Id. at p. 2, ¶ 9.) Plaintiff alleges Defendant has failed to pay sums due and owing under the retainer agreement. On June 26, 2019, Plaintiff filed a complaint against Defendant alleging a single claim for breach of contract. The complaint however failed to attach a copy of...

Excerpt: ...d its successor, Pacific Lodging Group (“Pacific”). (Id. at ¶ 5.) Pacific operates a hotel in Bodega Bay. (Id. at ¶ 3.) In or around 1985, Plaintiff's two corporations, Mosam Enterprises, Inc. and MM&H Investment, Inc. (“MM&H”), invested in Pacific and each received an ownership interest of 21.43%. (Id. at ¶¶ 13, 14.) In 2009, Plaintiff and Partner executed a sale and purchase agreement transferring MM&H's interest in Pacific to Partn...

Excerpt: ...lves a twostep process. First, the court must determine if plaintiff's claims are predicated upon defendant's exercise of a constitutional right of free speech or petitioning. Defendant has the burden to show the claims arise out of protected activity and must make a prima facie showing of same. Governor Gray Davis Committee v. American Taxpayers Alliance (2002) 102 CA 4th 449, 458‐459. If that burden is met, then plaintiff must show a probabil...

Excerpt: ...r into the sewer system owned and maintained by West Valley. (Complaint‐in‐Intervention at ¶ 2.) The complaint alleges causes of action for: (1) negligence; (2) violation of Ordinance § 7.150, violation of Ordinance § 7.360, and public nuisance. (Id. at ¶ 3.) According to the complaint, the plaster discharged into the sewer system by East Bay had blocked the flow of wastewater through the sewer system. (Complaint‐in‐ Intervention at �...