Excerpt: ... to depose Plainti
¯. Plainti
¯'s second amended veriÞed complaint alleges, essentially, that she is entitled by agreement with her brothers BART and MALCOLM to one- third ownership of family business CTF and she seeks dissolution of CTF because BART and MALCOLM have mismanaged the business to her detriment. Meet and Confer E
¯orts. The court Þrst considers the adequacy of the parties' e
¯orts to meet and confer to work these issues out bef...

Excerpt: ... “anti-SLAPP”) motion that struck Plainti
¯'s previously existing breach of contract claim. Defendants contend that while the work done on those motions was separate from their work on the anti-SLAPP motion the antiSLAPP law permits them to recover fees for that work regardless because it was necessary for the e
¯ective defense of their victorious anti-SLAPP motion. Wanland v. Law O
¯ices of Mastagni, Holstedt & Chiurazzi (2006) 141 Cal.Ap...

Excerpt: ...unsel engaged in a “serious e
¯ort at negotiation and informal resolution” that amounted to a su
¯icient “attempt to talk the matter over, compare their views, consult, and deliberate.” (Clement v. Alegre (2009) 177 Cal.App.4th 1277, 1294; Townsend v. Superior Court (1998) 61 Cal.App.4th 1431, 1439.) Rather than engaging in a meaningful attempt to informally resolve the dispute regarding each discovery request for which Plainti
¯ seeks...

Excerpt: ...ked by a horse. Request for Judicial Notice. The court takes judicial notice of the complaint Plaintiff filed against JACKSON in this county in case CU23-03078, alleging wage and hour violations, as a record of a court of this state. (Evid. Code, S 452, subd. (db.) Legal Standard. A defendant may move for judgment on the pleadings on the basis that the complaint against him does not state facts sufficient to constitute a cause of action. (Code Ci...

Excerpt: ...ly with the list of discovery identified in the motion. The parties are therefore to appear for hearing on this motion, with Defendant's counsel to clarify whether verified further responses will be voluntarily provided not only to the discovery listed in the opposition, but also to Special Interrogatory 17; and Requests for Production 7; 10-14; and 16. Because the promise of further responses was not made before Plaintiff filed this motion, and ...

Excerpt: ...lemental interrogatory can be propounded by a party who earlier propounded interrogatories, "to elicit any later acquired information bearing on all answers previously made by any party in response to interrogatories." C.C.P. 52030.070(a). The same is true for requests for production, "to inspect, copy, test, or sample any later acquired or discovered documents, tangible things, land or other property, or electronically stored information in the ...

Excerpt: ...EICHERT") moves for leave to file a cross-complaint for indemnity against only JOHN and Defendant DEANN PETERSON ("DEANN"). Plaintiff's operative first amended complaint alleges that Defendants PULTE HOMES OF CALIFORNIA, INC. ("PULTE"), TEICHERT, JOHN, DEANN, and former Doe Defendant GARRETT PETERSON ("GARRETT") are responsible for injuries she sustained when a motor vehicle she was riding, and which GARRETT drove, went into a pit on PULTE and TE...