How to Prepare Separate Statement – Discovery Motions

Useful Resources for 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

EARL BULL ET AL VS SUPERIOR MOBILITY INC ET AL

Hearing on Motion to Compel Further Discovery Responses - Compelling Cross-Complainant Pride Mobility Products Corporation's Further Responses to Cross-Complainant/Cross-Defendant Superior Mobility, Inc.'s Special Interrogatories, (Set 3) scheduled for 02/11/2021 are continued to 02/16/2021 at 10:00 AM in Department 29 at Spring Street Courthouse. The Moving Party is ordered to give notice.

  • Hearing

    Feb 11, 2021

  • Type

    Personal Injury/ Tort

  • Sub Type

    Products Liability

ELINTON GRAMAJO VS JOE'S PIZZA ON SUNSET INC ET AL

Plaintiff provides no reason as to why the meaning of what “full and complete in and of itself” means should be interpreted differently depending on the discovery form. Moreover, while Plaintiff emphasizes that Defendant’s response does not fall within one of the response categories outline in section 2033.220, this ignores the fact that Plaintiff’s discovery requests are not code-complaint.

  • Hearing

    Jan 22, 2021

  • Type

    Employment

  • Sub Type

    Other Employment

SUSHI CALIFORNIA WAGE AND HOUR CASES

According to Petitioner, coordination will streamline discovery. Id., 5:23-25. Again, under the particular circumstances here – where one of the two Included Actions has settled and is on the verge of completion – there is no need for unified discovery. Further, the proposed coordination site of Ventura County Superior Court is not more convenient. Plaintiff herself recognizes that all counsel in Chilel and Bernal are located in Los Angeles County.

  • Hearing

    Jan 22, 2021

RASHYN REYNOLDS, ET AL. VS AHM RESICOM LLC

TENTATIVE RULING DISCOVERY MOTIONS 1/21/2021 REYNOLDS V. AHM 19STCV13678 AS TO ARMY RIDDLESPRIGER: Motion to compel response to form interrogatories: DENIED. The minor has no guardian ad litem. Proceedings may not proceed against a minor plaintiff who does not have a guardian ad litem. AS TO ALAIN COOK: Motion to compel response to form interrogatories set one and two, Motion to compel response to request for production of documents set one: BOTH MOTIONS ARE GRANTED.

  • Hearing

    Jan 21, 2021

JAIME MANIPIS VS ALLSTATE NORTHBROOK INDEMNITY COMPANY

However, Respondent requests that, due to the seriousness of the allegations, the parties be given sufficient time to complete expert discovery and designate expert witnesses for the arbitration hearing. (The superior court has exclusive jurisdiction to hear and rule on discovery matters arising in an UM arbitration. The arbitrator has no such power. See, Miranda v. 21st Century Ins. Co., supra, 117 Cal.App.4th at 924-926.)

  • Hearing

    Jan 21, 2021

RASHYN REYNOLDS, ET AL. VS AHM RESICOM LLC

TENTATIVE RULING DISCOVERY MOTIONS 1/21/2021 REYNOLDS V. AHM 19STCV13678 AS TO ARMY RIDDLESPRIGER: Motion to compel response to form interrogatories: DENIED. The minor has no guardian ad litem. Proceedings may not proceed against a minor plaintiff who does not have a guardian ad litem. AS TO ALAIN COOK: Motion to compel response to form interrogatories set one and two, Motion to compel response to request for production of documents set one: BOTH MOTIONS ARE GRANTED.

  • Hearing

    Jan 21, 2021

DORIS ANN WARNER VS LONG BEACH YELLOW CAB CORPORATION, INC., ET AL.

Long Beach Yellow Cab On the Court's own motion, the Hearing on Motion to Compel Discovery (not "Further Discovery") - Compelling Plaintiff's Responses to Defendants' Demand for Inspection and Production of Documents; Request for Monetary Sanctions Against Plaintiff scheduled for 01/20/2021, and Hearing on Motion to Compel Discovery (not "Further Discovery") - Compelling Plaintiff to Answer Defendants' Interrogatories (Set One) , Without Objection; Request for Monetary Sanctions Against Plaintiff scheduled

  • Hearing

    Jan 20, 2021

BLASI CIUDAD VS MARC CANADELL TORRAS, ET AL.

Plaintiff argues there is no risk of prejudice given that no trial date has been set, and discovery is in its infancy. Moreover, Plaintiff argues that these allegations could not have been included in her original Complaint because they had not yet taken place. The Court agrees that no meaningful prejudice will result by granting Plaintiff the requested leave. Based on the foregoing, Plaintiff’s motion is granted. It is so ordered. Dated: January , 2021 Hon. Jon R.

  • Hearing

    Jan 20, 2021

  • Type

    Personal Injury/ Tort

  • Sub Type

    other

DAVID ALVAREZ VS FRANCISCO DIAZ

However, no informal discovery conference (“IDC”) has been held as to the discovery at issue. The parties are reminded that this court requires an IDC prior to the filing of discovery motions to resolve any issues the parties are unable to resolve on their own. (See Code Civ. Proc. § 2016.080, subd. (a).) The instant motion presents issues that the parties should be able to resolve on their own through good faith meet and confer efforts or with the court’s guidance in an IDC.

  • Hearing

    Jan 20, 2021

  • Type

    Employment

  • Sub Type

    Other Employment

GARY EISENBERG VS HILLARY COPELAND ET AL

SANCTIONS PER CCP 2023.010, DISCOVERY ABUSE AND NO SUBSTANTIAL JUSTIFICATION FOR ACTIONS, IN THE AMOUNT OF $1,560.00 FOR 5 HOURS X $300 PER HOUR PLUS $60 IN FEES. A CERTIFICATE OF NON-APPEARANCE IS NOT REQUIRED BY LAW AND IS AN UNNECESSARY EXPENSE. SANCTIONS ARE AGAINST DEFENDANT REGAN COPELAND AND HER COUNSEL OF RECORD RAFFALOW, BRETOI, LUTZ & STELE AND ARE PAYABLE TO CLIENT TRUST ACCOUNT OF PLAINTIFF’S COUNSEL WITHIN 30 DAYS. ON DOCUMENT PRODUCTION, GRANT OR DENY AS NOTED BELOW.

  • Hearing

    Jan 20, 2021

LARRY CURLEE V. JOHN E. ODUM

Defendant argues the Subpoena seeks documents that are not within the permissible scope of discovery because they contain privileged, private, and confidential information. As to the first request, Defendant argues it does not contain a specific description as is required under Code of Civil Procedure section 2020.410. Defendant also argues that Plaintiff’s document requests must be limited to the issues brought by Plaintiff in his complaint.

  • Hearing

    Jan 20, 2021

STEPHANIE JIMENEZ, AN INDIVIDUAL VS ANTONIO RAYGOZA, AN INDIVIDUAL, ET AL.

Raygoza et al On the Court's own motion, the Hearing on Defendants Maria Raygoza, Antonio Raygoza, and Juan Ragoza's Motions to Compel Discovery (Responses to Plaintiff's Form Interrogatories, Special Interrogatories, Requests for Production of Documents, and Requests for Admissions) currently set for January 20, 2021 are continued to January 25, 2021 at 1:30 p.m. in Department 29 of the Spring Street Courthouse. The Moving Party is ordered to give notice.

  • Hearing

    Jan 20, 2021

TOBIN LANZETTA VS VOLKSWAGEN GROUP OF AMERICA

The documents that are sought may lead to the discovery of admissible evidence that may be relevant to Plaintiff’s claims that Defendant had prior knowledge of the alleged defect in Plaintiff’s vehicle, and, violated the Song-Beverly Act by refusing to purchase the vehicle. The documents may also lead to the discovery of admissible evidence as to whether Defendant breached the implied warranty of merchantability by selling to Plaintiff a vehicle with a known defect. For example, in Donlen v.

  • Hearing

    Jan 20, 2021

LOMITA NARBONNE, INC., A CALIFORNIA CORPORATION VS GO FRESH, LLC, A CALIFORNIA LIMITED LIABILITY COMPANY, ET AL.

Prior counsel essentially abandoned Plaintiff and failed to serve discovery responses and failed to oppose the motions. In addition, Defendants were not aware of the discovery until after the motion hearing on August 25, 2020. Specifically, prior counsel severely neglected this case by failing to serve discovery responses, failing to oppose the resulting motions to compel, and failing to inform Defendants about the discovery issues until after the motion to deem requests admitted.

  • Hearing

    Jan 20, 2021

  • Type

    Real Property

  • Sub Type

    Landlord Tenant

KATHLEEN F. CARPENTER, ET AL. V. MICHAEL J. GUNSON, MD, DDS, ET AL.

Nature of Proceedings: Motion to Stay Discovery/Continue Trial Confirmation Tentative

  • Hearing

    Jan 19, 2021

POTTER VS. CENTRAL COAST POWER

Plaintiff's claim that the arbitration agreement is unconscionable due to its failure to specify responsibility for arbitration costs and discovery procedures must be rejected. Under governing law and as Defendants concede, Defendants are responsible for arbitration costs. Moreover, the parties can rely on the California Arbitration Act and the arbitrator to provide for the discovery necessary for Plaintiff to vitiate his claims. Accordingly, the motion to compel arbitration is GRANTED.

  • Hearing

    Jan 19, 2021

  • Type

    Employment

  • Sub Type

    Wrongful Term

DAMIR DE BALKANY VS. MISSION PLAZA TOWNHOMES OWNERS ASSOCIATION

Footnote [1]: In addition to failing to presenting evidence, plaintiff also has not presented a separate statement, identifying which of defendant's proposed material facts he admits or disputes. When a moving party makes the required prima facie showing, failure to file a separate statement may, in the court's discretion, constitute a sufficient ground for granting the motion. (Code Civ. Proc., § 437c, subd. (b)(3); see Buehler v.

  • Hearing

    Jan 19, 2021

PEOPLE OF THE STATE OF CALIFORNIA EX REL. CALIFORNIA AIR RESOURCES BOARD VS NOIL ENERGY GROUP, INC.

Defendant argues that Plaintiff’s claims are barred by the statute of limitations because “Plaintiff's Complaint was filed on August 10, 2017 [sic], over three years since the first date of discovery which according to the facts alleged in the complaint was August 8, 2017.” (Demurrer, pp. 5:24-26.)

  • Hearing

    Jan 19, 2021

PETERS VS CITY OF BEAUMONT CALIFORNIA SPECIAL DEMURRER FOR UNCERTAINTY TO ANSWER

The word contentions are to be taken at its ordinary meaning and plaintiff has discovery options available to him clarify the nature of the contentions. A demurrer on the grounds of uncertainty is improper if the issue can easily be cleared up through discovery. Khoury, supra, 14 Cal. App. 4th at 616. Any issue Plaintiff has regarding what cause of action or contentions the affirmative defenses are directed at can also easily be resolved via discovery.

  • Hearing

    Jan 19, 2021

ANNA BASA VS LUIS ARIAS, ET AL.

Uber essentially makes three arguments: (1) discovery is not complete including Deleon-Ramirez’s deposition and there is insufficient substantial evidence for the Court to grant Deleon-Ramirez’s application; (2) Deleon-Ramirez does not meet her burden to show evidence of the settlement agreement, her financial condition and available insurance, and on the subject of liability that is more than a conclusory attorney declaration; and (3) the only evidence before the Court is Plaintiff’s $1,000,000 demand and there

  • Hearing

    Jan 19, 2021

JOSE DE JESUS DIAZ MATA ET AL VS NEWHALL UNIFIED SCHOOL DIST

Due to Mata’s and his counsel’s failure to comply with their discovery obligations, Newhall is also entitled to an order imposing sanctions against Mata and his attorney in the amount of $1,050.00. See CCP 2030.300(d).

  • Hearing

    Jan 19, 2021

  • Type

    Personal Injury/ Tort

  • Sub Type

    other

ALIONSO ANGEL VS DANA ZIENERT-KIND, ET AL.

The Court orders that the parties participate in an Informal Discovery Conference (“IDC”) and such IDC will take place on January 19, 2021 at 9:00 a.m. to resolve the issues presented by the Motion. Moving party is ordered to give notice of this ruling. In consideration of the current COVID-19 pandemic situation, the Court strongly encourages that appearances on all proceedings, including this one, be made by LACourtConnect if the parties do not submit on the tentative.

  • Hearing

    Jan 19, 2021

RAFI PELTEKIAN, ET AL. VS INTERINSURANCE EXCHANGE OF THE AUTOMOBILE CLUB

The motion lacks any form of separate statement (Cal. Rule of Court, rule 3.1345(a)(3)), and instead submits an 81 paragraph declaration identifying an additional 331 page of exhibits of responses and correspondence. The parties agreed to an extension to serve supplemental responses to July 24, 2020. [Declaration of Zareh Keosian, ¶¶ 73-75.] Responses consisting entirely of objections were served on July 24, 2020. [Keosian Decl., ¶ 77.]

  • Hearing

    Jan 19, 2021

JOSE VALDIVIA VS BEST CONTRACTING SERVICES, INC., ET AL.

In addition, even where a complaint is in some respects uncertain, courts strictly construe a demurrer for uncertainty “because ambiguities can be clarified under modern discovery procedures.” (Khoury v. Maly’s of California, Inc. (1993) 14 Cal.App.4th 612, 616.) Demurrers do not lie as to only parts of causes of action where some valid claim is alleged but “must dispose of an entire cause of action to be sustained.” (Poizner v. Fremont General Corp. (2007) 148 Cal.App.4th 97, 119.)

  • Hearing

    Jan 19, 2021

  • Type

    Employment

  • Sub Type

    Wrongful Term

1 2 3 4 5 6 7 8 9 10 ... 400     last » 

For full print and download access, please subscribe at https://www.trellis.law/.

Please wait a moment while we load this page.