Excerpt: ... on or about 22 October 2018, Quantum breached the Employment Agreement when it terminated Britts before knowing all the facts, incorrectly claimed cause existed, failed to provide notice, and withheld the severance payment owed to Britts. (Complaint, ¶BC‐2.) As a proximate result of Quantum's breach, Britts has suffered monetary damages in excess of $370,000. (Complaint, ¶BC‐4.) On or about 12 January 2015, Britts and Quantum made a writte...

Excerpt: ...f First Amended Complaint1 Defendants Tony Lam and Helen Lam (collectively, “the Lams”) were owners of property located at 1193 Sierra Madres Terrace in San Jose (“Subject Property”). (First Amended Complaint (“FAC”), ¶7.) On 8 June 2008, plaintiff Steven Howard Kuhn (“Kuhn”) and the Lams (through their agent) entered into a lease agreement for the Subject Property. (FAC, ¶11 and Exh. 1.) The lease agreement called for the secur...

Excerpt: ...AC”), ¶12.) In or around 2003, Maintenance Inc. merged with a competitor, Industrial Janitorial Service and the two companies began operating under the name Industrial Janitorial Service (“IJS”). (Id.) When the companies merged, IJS was performing janitorial services throughout the country for various defendant Apple Inc. (“Apple”) retail stores, responsibilities which IJS assumed after the merger. (FAC, ¶13.) To sustain its image of ...

Excerpt: ...urance Company (“CIC”), along with Premier Claims Management, Inc. (“Premier”) for their refusal to indemnify and defend Apec in an underlying action for negligence and fraud arising from construction and repairs to a single‐family home (Brassfield v. Elias, case no. 17CV305267). The underlying action remains pending in Santa Clara County. In the operative First Amended Complaint (“FAC”) filed March 6, 2019, plaintiff Apec alleges c...

Excerpt: ...the underlying complaint (“Complaint”), on November 16, 2011, plaintiff Beth Gray (“Gray” or “Plaintiff”) was seriously injured when she slipped and fell on the stairs leading to her room at the JRC. Plaintiff alleges that the stairs, which were wet when she fell and were made of a smooth stone material that became slick when wet, lacked “friction strips” and only had a handrail on one side. She further alleges that the lighting w...

Excerpt: ...u, Feng Chen, Yuhao Pan, Ruoyi Liang, and ZhuangZhuang Zhang (collectively, “Gao Plaintiffs”), Chinese citizens, are part of a group of 90 investors who each paid $555,000 to defendants Bethany Liou (“Liou”) and Golden California Regional Center (“GCRC”) to become limited partners of defendant GCRC Cupertino Fund (“Cupertino Fund”) in order to obtain lawful permanent resident status in the United States through the EB5 program. (F...

Excerpt: ...chase a piece of property and develop on it a commercial building. (Id. at ¶ 12.) To that end, in 2004 or 2005, Asghar formed an LLC called Rumi Group (“LLC”) with the four siblings as members. (Ibid.) Each member was required to make an initial capital contribution based on his or her percentage of ownership. (Id. at ¶ 13.) Neither Plaintiff, Defendant, nor Mahin had sufficient cash to pay their respective capital contributions, but Plaint...

Excerpt: ...auren Edwards (“Edwards”) of defendant Gomez Edwards Law Group, LLP (erroneously sued as Gomez Edwards Law Group; hereafter, “Gomez‐Edwards”). (Complaint, ¶¶1, 4, 5 and 7.) On January 7, 2020, plaintiff Oster filed a complaint against defendant Gomez‐Edwards asserting causes of action for: (1) Aiding and Abetting False Reports to Police (2) Aiding and Abetting Fraud (3) Perjury and Fraud (4) Concealing Evidence (5) Retaliation, Diss...

Excerpt: ...ndant City of Palo Alto (“City”) to restore section 4 of Article V of the City Charter, which since 1978 provided for binding interest arbitration of unresolved disputes between the City and its police or fire department employee organizations relating to wages, hours or terms and conditions of employment. (Complaint, ¶1.) In July 2010, the City asked staff to develop language to eliminate Article V of the City Charter, the dispute resolutio...

Excerpt: ...of District's schools. Plaintiff filed a complaint against District and Teacher on February 13, 2019. On November 21, 2019, the Court consolidated Plaintiff's action with the following cases for all purposes, except trial: (1) Jane Doe v. Union School District, et al. (Santa Clara County Superior Court, Case No. 19‐CV‐343088); and (2) Jane Doe 1 and 2 v. Union School District, et al. (Santa Clara County Superior Court, Case No. 19‐CV‐3481...

Excerpt: ...nt. Therein, Plaintiff alleges that Vicini and Martinez are California Highway Patrol officers and she suffered general damages, emotional distress, mental distress, and medical negligence. Plaintiff checked boxes in the form complaint indicating that she attached causes of action for general negligence, intentional tort, “medical negligence, officer misconduct, [and] sexually grooped [sic].” (FAC, ¶ 10.) However, those causes of action are ...