How to Prepare Separate Statement – Discovery Motions

Useful Rulings on Separate Statement – Discovery Motions

Recent Rulings on Separate Statement – Discovery Motions

1-25 of 10000 results

T-12 THREE, LLC VS. TURNER CONSTRUCTION COMPANY

Turner did not specify the ultimate material facts as to the economic loss rule as to each plaintiff’s negligence claim in its Separate Statement, instead reciting verbatim deposition testimony and other discovery responses, which left it to the Court the cumbersome task of trying to determine whether Turner established that Plaintiffs only have economic damages. (SSUF 44-61.)

  • Hearing

    Apr 25, 2026

FALISHA PORTER VS PHARMAVITE, LLC

Finally, the issue of whether every single page of her employment file should be open to discovery is also an issue. For instance, what if she had private conversations about health issues unrelated to the damages in this case. What if she was asked to be a witness in a claim against another co-employee? The court can envision many situations which are unrelated to issues of her damages in this case and her representations to this employer upon which it relied in hiring her.

  • Hearing

    Dec 07, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    other

NINA MONTOYA VS OLUFEMI OGUNTOLU, ET AL.

“Though the discovery gives us some discomfort in terms of legal symmetry, it appears to us that once the court in a partition action has determined that true joint tenancy exists, it may not order reimbursement or contribution on account of differences in the amounts the parties have paid toward the initial acquisition of the property.

  • Hearing

    Dec 04, 2020

  • Type

    Real Property

  • Sub Type

    other

CHARISSE STRODE, ET AL. VS FLOWER 77TH, LLC, ET AL.

The discovery and motions cut-off shall be based on the new trial date. The Court orders Counsel to serve a copy of this order, as well as a copy of the Court’s order on Form MC-053, upon all parties including Plaintiff within ten (10) days. The Court orders Plaintiff’s counsel to file proof of service within twenty (20) days. Counsel shall remain counsel-of-record until BOTH of the Court’s orders are served and he files proof of service with the Court. Counsel shall provide notice.

  • Hearing

    Dec 04, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    other

JOHANNES ZUURVEEN ET AL VS LA COUNTY DEPT OF HEALTH SERVICE

Defendant / Cross-Complainant County has established that the discovery was properly served on cross-defendant Zuurveen, and cross-defendant failed to respond to this discovery. Cross-defendant Zuurveen does not oppose this motion. Conclusion The County’s motion is granted.

  • Hearing

    Dec 04, 2020

JUAN PALMA ET AL VS KAISER FOUNDATION HEALTH PLAN INC ET AL

Rosa has agreed to produce the various PMKs’ subject to discovery motions filed before the COVID-19 pandemic.” Rosa represents that it was his recollection that they were discussing the PMK’s that were requested by Vigil rather than by Plaintiffs’ counsel, and notes that only Vigil had filed a discovery motion before the COVID-19 pandemic. (Rosa Decl., ¶21.) The motion is denied. Plaintiffs’ request for sanctions is declined.

  • Hearing

    Dec 04, 2020

CAEZAR SEALS, AN INDIVIDUAL VS WAL-MART STORES, INC.. A CORPORATION, ET AL.

However, this order is without prejudice to Plaintiff seeking leave to amend if he develops facts in discovery that support such an amendment. Defendant shall provide notice and file proof of such with the Court. DATED: December 4, 2020 ___________________________ Stephen I. Goorvitch Judge of the Superior Court

  • Hearing

    Dec 04, 2020

NICHOLAS DAN VS LYNN HOFFER

The discovery and motions cut-off shall be based on the new trial date. The Court orders Counsel to serve a copy of this order, as well as a copy of the Court’s order on Form MC-053, upon all parties including Plaintiff within ten (10) days. The Court orders Plaintiff’s counsel to file proof of service within twenty (20) days. Counsel shall remain counsel-of-record until BOTH of the Court’s orders are served and he files proof of service with the Court. Counsel shall provide notice.

  • Hearing

    Dec 04, 2020

AHMED HIJAZI ET AL VS ALVARO ECHEVERRY ET AL

Indeed, this is not referenced in Plaintiff’s separate statement of material facts. The “golden rule” of summary judgment states: “[A]ll material facts must be set forth in the separate statement. . . . [I]f it is not set forth in the separate statement, it does not exist.” (United Community Church v. Garcin (1991) 231 Cal.App.3d 327, 337, superseded by statute on other grounds.) Therefore, the motion is granted with respect to Defendant Penske. B.

  • Hearing

    Dec 04, 2020

MICHAEL LAWRENCE KLINE VS MICHAEL DIBACCO

As such, the motion to compel discovery responses is taken off-calendar in light of the stay. The Court sets an OSC re Status of Defendant’s Bankruptcy for March 4, 2021 at 8:30 a.m. Plaintiff shall provide notice of this order.

  • Hearing

    Dec 04, 2020

  • County

    Los Angeles County, CA

MOHAWK WESTERN PLASTICS, INC.A CALIFORNIA CORPORATION VS REVEL ENERGY, LLC., A DELAWARE LIMITED LIABILITY COMPANY, ET AL.

BY INITIALING IN THE SPACE BELOW EACH PARTY IS GIVING UP ITS JUDICIAL RIGHTS TO DISCOVERY AND APPEAL, UNLESS THOSE RIGHTS ARE SPECIFICALLY INCLUDED IN THE CONSTRUCTION INDUSTRY ARBITRATION RULES. IF A PARTY REFUSES TO SUBMIT TO ARBITRATION AFTER AGREEING TO THIS PROVISION, SAID PARTY MAY BE COMPELLED TO ARBITRATE UNDER THE AUTHORITY OF THE BUSINESS AND PROFESSIONS CODE OR OTHER APPLICABLE LAWS. A PARTY’S AGREEMENT TO THIS ARBITRATION PROVISION IS VOLUNTARY.

  • Hearing

    Dec 04, 2020

FELIX DELAROSA VS VOLKSWAGEN GROUP OF AMERICA, INC., ET AL.

.: 20STCV14775 Hearing Date: December 4, 2020 [TENTATIVE] order RE: motion to compel further responses to plaintiff’s request for production of documents The Court finds Plaintiff’s discovery to be overly broad and unduly burdensome. The Court issues the following discovery order: Defendant Volkswagen Group of america, Inc.

  • Hearing

    Dec 04, 2020

RAY HEITMANN VS LINDHOLM PROPERTIES, INC.

The Court provides notice to Plaintiff that he must address the outstanding discovery, as Defendant has filed the following motions: (1) Motion to compel responses to Form Interrogatories, (2) Motion to compel responses to demand for inspection and production of documents, (3) Motion to compel responses to special interrogatories, and (4) Motion to compel responses to requests for admission. These motions shall be heard on March 30, 2021, at 8:30 a.m.

  • Hearing

    Dec 04, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    other

PATRICIA A. MAY VS DENNIS L JONES

App. 4th 216, 224) (rejecting facts supporting the production of documents that were in a separate statement because the document was not verified and did not constitute evidence). In Calcor, the Court of Appeal issued a writ of mandate issue directing the trial court to vacate its order compelling the defendant to produce records because the plaintiff had failed to provide specific facts showing good cause for their production. Subsequently, in Digital Music News LLC v Superior Court (2014) 226 Cal.

  • Hearing

    Dec 04, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    Fraud

DANA MCCOY VS CITY OF LOS ANGELES

Defendant served the written discovery on Plaintiff on March 9, 2020 by mail. Defendant granted Plaintiff an extension of time to respond to May 15, 2020. As of the filing date of this motion, Defendant has not received responses from Plaintiff. Plaintiff has not opposed the motion, and there is nothing in the record suggesting that Plaintiff has complied with her discovery obligations. Therefore, the motion is granted. Defendant seeks sanctions in connection with the motion.

  • Hearing

    Dec 04, 2020

DO WOO KIM, ET AL. VS HYUN JONG HAN, ET AL.

Form interrogatories are drafted by the California Judicial Council, and are meant to aid parties in the discovery process by providing a set of standardized, carefully worded interrogatories to guide discovery. (See Clement v. Alegre (2009) 177 Cal.App.4th 1277, 1288, fn 9.) Plaintiffs have not make a good faith attempt to identify percipient witnesses to this action. (CCP Code Civ. Proc., § 2030.300(a)(1).) Han’s motion to compel further responses to FROG No. 12.1-12.7 is GRANTED.

  • Hearing

    Dec 04, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    Fraud

LANCE KRIEGER VS VICTORIA HOVSEPIAN

The discovery and motions cut-off shall be based on the new trial date. Plaintiff shall provide notice and file proof of such with the Court. DATED: December 4, 2020 ___________________________ Stephen I. Goorvitch Judge of the Superior Court

  • Hearing

    Dec 04, 2020

DISCOVER BANK VS VIOLET MINAEIAN

Allegations of the Pleadings Plaintiff Discovery Bank (“Plaintiff”) commenced this action against Defendant Violet Minaeian (“Defendant”) on July 22, 2019, alleging a single cause of action for common counts. Plaintiff alleges that it issued a loan to Defendant on account ending 2531 and Defendant was billed periodically. Plaintiff alleges that the amount due and owing on the account is $32,614.87. On December 10, 2019, the default of Defendant was entered.

  • Hearing

    Dec 04, 2020

  • Type

    Collections

  • Sub Type

    Promisory Note

  • County

    Los Angeles County, CA

STATE OF CALIFORNIA VS POLLO MEAL, INC.

They must also be accompanied by a separate statement containing the requests and the responses, verbatim, as well as reasons why a further response is warranted. (Cal. Rules of Court, rule 3.1345(a).) The separate statement must also be complete in itself; no extrinsic materials may be incorporated by reference. (Id., rule 3.1345(c).)

  • Hearing

    Dec 03, 2020

  • Type

    Employment

  • Sub Type

    Other Employment

MARIA DE LOS ANGELES CASILLAS VS ANA MARTIN MEDEROS

Jimenez, so it is unclear whether Plaintiff received notice of her outstanding discovery obligations and this motion. Based upon the foregoing, the Court orders as follows: 1. Daniel F. Jimenez, Esq. shall serve a copy of this order, as well as a copy of the Court’s order relieving him as counsel, upon his client, Maria De Los Angeles Casillas, within ten (10) days of notice of this order. 2. Mr.

  • Hearing

    Dec 03, 2020

JOHN CHOI VS SUSAN P. MARTINEZ, ET AL.

The discovery and motions cut-off shall be based on the new trial date. Defendants shall provide notice and file proof of such with the Court. DATED: December 3, 2020 ___________________________ Stephen I. Goorvitch Judge of the Superior Court

  • Hearing

    Dec 03, 2020

GREGORY BARAM, ET AL. VS CEDARS-SINAI MEDICAL CENTER, ET AL.

The following summary cites the separate statement filed by Cedars-Sinai. Mr. Baram has a history of coronary artery disease. (Undisputed Material Facts “UMF” 1.) On July 18, 2017, Dr. Sokol performed a colonoscopy with removal of one polyp. (UMF 4.) On July 28, 2017, Mr. Baram was post-CABG with peripheral vascular disease, hyperlipidemia, hypertension, and abdominal aneurysm. (UMF 1.)

  • Hearing

    Dec 03, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    Medical Malpractice

JUDI BEDDOW, ET AL. VS ALTEC, INC.,, ET AL.

Third Party Deposition A party seeking discovery from a person who is not a party to the action may obtain discovery by oral deposition, written deposition, or deposition subpoena for production of business records. (Code Civ. Proc., § 2020.010.)

  • Hearing

    Dec 03, 2020

NOHEMY S. PEREZ VS IN-N-OUT BURGERS, A BUSINESS ENTITY

The discovery and motions cut-off are based upon this trial date. The Court orders Plaintiff’s counsel to serve a copy of this order, as well as a copy of the Court’s order on Form MC-053, upon all parties including Plaintiff within ten (10) days. The Court orders Plaintiff’s counsel to file proof of service within twenty (20) days. Counsel shall remain counsel-of-record until BOTH of the Court’s orders are served and he files proof of service with the Court. Counsel shall provide notice.

  • Hearing

    Dec 03, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    other

BRAULIO URBINA GUZMAN, ET AL. VS FIVE F'S TRUCKING, INC., ET AL.

Because Plaintiffs’ evidence shows defense counsel has attempted to contact Defendant and otherwise comply with the discovery requests, sanctions are imposed against Defendant Joaquin Figueroa Andrade only. Defendant only, and not defense counsel, is ordered to pay sanctions to Plaintiffs, by and through counsel of record, in the total amount of $980.00, within twenty days. Plaintiffs are ordered to give notice.

  • Hearing

    Dec 03, 2020

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