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FILED: BRONX COUNTY CLERK 03/07/2023 03:50 PM INDEX NO. 801219/2021ENYSCEF DOC. NO. 15 RECEIVED NYSCEF: 03/07/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX -------------------------------------------------------------------------------------------x QUINCY JONES, VERIFIED BILL OF PARTICULARS Index No.: 801219/2021E Plaintiff(s), -against- DARDANIA PROPERTIES LLC, Defendant(s). -------------------------------------------------------------------------------------------x Plaintiff(s), QUINCY JONES by his attorneys, LESCH & LESCH, P.C., responding to Defendants’, Demand for Bill of Particulars as follows: 1. Plaintiff(s)’ name is Quincy Jones. 2. Plaintiff(s) is a U.S. citizen, born in 1990. Pursuant to 22 NYCRR §202.5(e), Plaintiff(s) will not supply his Social Security Number in this responsive document, for security reasons. Instead, Plaintiff(s) will provide his Social Security Number at his deposition, specifically putting the last four number on-the-record. 3. Plaintiff(s)’ residence during the time of accident, as well as current residence, is New York 10461. 4. Upon information and belief, the bed bug infestation occurred on December 29, 2019 and continues to the present. Plaintiff(s) reserves his right to amend and/or supplement this portion of his Verified Bill of Particulars upon completion of discovery. 5. The location of the occurrence was in located at New York 10461. Bed bug infestation was throughout the entire apartment and, specifically, in the Plaintiff(s)’ bedroom. Notwithstanding said assertion, the entire apartment was infested with bed bugs and the biting occurred throughout the entire apartment. 6. Not applicable. 1 of 24FILED: BRONX COUNTY CLERK 03/07/2023 03:50 PM INDEX NO. 801219/2021ENYSCEF DOC. NO. 15 RECEIVED NYSCEF: 03/07/2023 7. Not applicable. 8. Not applicable. 9. Not applicable. 10. Defendant(s), DARDANIA PROPERTIES LLC, by their agents, servants, and/or employees, were negligent in the ownership, maintenance, and repair of their premises when they permitted bed bugs to exist in New York 10461, in all apartments, as well as in failed to remove bed bugs; failed to warn Plaintiff(s) of dangerous bed bug condition after Plaintiff(s) rented the apartment; failed to exterminate bed bugs; allowed a nuisance to exist; failed to use due care and caution; failed to keep a proper lookout; failed to observe condition and remedy same; failed to inform tenants, particularly Plaintiff(s), QUINCY JONES, of the bed bug hazard throughout the building; failed to have an action plan in place when infestation of bed bugs could occur; failed to warn tenants of procedures to prevent bed bugs; failed to have prophylactic measures in place of a bed bug infestation of the entire apartment building as well as Plaintiff(s)’ particular apartment; failed to take necessary steps to eradicate infestations; failed to hire adequate exterminator to rid building of bed bug infestations; failed to change exterminators once infestation procedures were not being properly met; failed to change exterminator when exterminator failed to remedy bed bug condition; failed to remedy bed bug infestation themselves; failed to abate infestation; failed to exercise due care and caution. 11. Actual notice is alleged in that Plaintiff(s), QUINCY JONES, notified Defendant(s)’, DARDANIA PROPERTIES LLC, building supervisor about the bed bug infestation in Plaintiff(s)’ apartment. Said notice occurred prior to December 29, 2019. Time and place the notice was given are within the purview of Defendant(s)’ knowledge. Furthermore, this information is within the exclusive knowledge of Defendant(s) and will be purged and/or supplemented after depositions of the Defendant(s), their agents, servants, and/or employees, and after receipt of maintenance and inspection records pursuant to 2 of 24FILED: BRONX COUNTY CLERK 03/07/2023 03:50 PM INDEX NO. 801219/2021ENYSCEF DOC. NO. 15 RECEIVED NYSCEF: 03/07/2023 Plaintiff(s)’ Demand for Discovery and Inspection. Plaintiff(s) reserves his right to amend and/or supplement this portion of his Verified Bill of Particulars after a deposition of the Defendant(s)’ witness has been taken. 12. Negligent repairs are claimed in that there were holes on Plaintiff(s)’ apartment walls, which the bed bugs used as a means of entry to his apartment. Person or persons who made the repairs, as well as the time of such repairs are within the purview of Defendant(s)’ knowledge. Moreover, Plaintiff(s) was forced to repair the holes himself. Plaintiff(s)’ repair estimates will be provided upon receipt of same. Plaintiff(s) reserves his right to amend and/or supplement this portion of his Verified Bill of Particulars upon completion of discovery. 13. Constructive notice is alleged in that the condition existed for an unreasonable amount of time throughout Plaintiff(s)’ apartment, as well as the entire building, to impute constructive notice upon Defendant(s). The date, place, and persons whom the notice were given are within the exclusive knowledge of Defendant(s). Plaintiff(s) reserves his right amend or supplement this portion of his Verified Bill of Particulars upon completion of discovery. 14. Statutes, regulations, ordinances, or rules are within the exclusive province of the Court, and Plaintiff(s) begs leave to refer to same at the time of trial, or after Defendant(s)’ depositions. Notwithstanding the aforementioned, Defendant(s) violated the following laws or statutes: Real Property Law Section 235(b); 24 RCNY Section 151-05; 24 RCNY Section 151.02: Prevention and pest management measures; The City Housing Maintenance Code Section 27-2018; Multiple Dwelling Law Section 80. 15. Upon information and belief, Plaintiff(s), QUINCY JONES, suffered bedbug bites on his upper body, arms, chest, back, forearms, legs, and abdomen. Moreover, Plaintiff(s) sustained three to four scattered marks on his back consistent with bug bites. Upon information and belief, said bed bug bites left marks and lesions are permanent in nature. Accompanying injuries include skin irritation, itching, scarring, and dermatographia. 3 of 24FILED: BRONX COUNTY CLERK 03/07/2023 03:50 PM INDEX NO. 801219/2021ENYSCEF DOC. NO. 15 RECEIVED NYSCEF: 03/07/2023 16. Not applicable. 17. Upon information and belief, Plaintiff(s) received treatment from Jacobi Medical Center, located in 1400 Pelham Parkway South, Bronx, New York 10461, shortly after the accident. Plaintiff(s) does not allege confinement to bed and/or a hospital. Plaintiff(s) reserves his right to amend and/or supplement this portion of his Verified Bill of Particulars upon completion of discovery. 18. Upon information and belief, Plaintiff(s) was and is a superintendent for Safety Facility Services, located 5 West 37th Street, New York, New York 10018. Plaintiff(s) reserves his right to amend and/or supplement this portion of his Verified Bill of Particulars upon completion of discovery. 19. Not applicable. 20. Unknown at this time and will be provided upon completion of discovery. 21. Questions regarding disability will be answered at Plaintiff(s) deposition. 22. Special damages are unknown at this time and will be provided upon receipt of estimates and/or completion of discovery. Notwithstanding, Plaintiff(s), QUINCY JONES, incurred the following expenses: a. Out-of-pocket medical expenses incurred from Jacobi Medical Center, located in 1400 Pelham Parkway South, Bronx, New York 10461. b. Out-of-pocket expenses in relation to repair, in which client had to fill and paint over the holes on his apartment’s walls. c. Out-of-pocket expenses in relation to the prevention of bed bug biting, such as buying bed bug covers for his apartment. Plaintiff(s) reserves his right to amend and/or supplement this portion of his Verified Bill of Particulars upon receipt of estimates and/or completion of discovery. 23. Unknown at this time and will be provided upon completion of discovery. 4 of 24FILED: BRONX COUNTY CLERK 03/07/2023 03:50 PM INDEX NO. 801219/2021ENYSCEF DOC. NO. 15 RECEIVED NYSCEF: 03/07/2023 Dated: Bronx, New York March 7, 2023 Yours, etc. LESCH & LESCH, P.C. By: ____________________________ GARY E. LESCH, ESQ. Attorneys for Plaintiff(s) 860 Grand Concourse, Suite 2M Bronx, New York 10451 (718) 292-1131 TO: SMITH MAZURE, P.C. Attorneys for Defendant DARDANIA PROPERTIES LLC 111 John Street New York, NY 10038 Phone: (212) 964-7400 Your File No.: HUD-01032 5 of 24FILED: BRONX COUNTY CLERK 03/07/2023 03:50 PM INDEX NO. 801219/2021ENYSCEF DOC. NO. 15 RECEIVED NYSCEF: 03/07/2023 STATE 0F IEW YORE) COUNTY OF BRONX) NCY JONE S be g duly sworn, deposes and says dat she Is the phinfiffin the m within that he has =*inn, read the foressing VauEED BILL OF PAR3ICULARS and knows the thereoC that 1he sameis ene so him knowlestgat careept as to aie rosters diesein stated to dNi aBegory an inform"*ian and and a beNaf; that as to those mamera, he beHesar thens to be of nam p.usocu Netagh8We of NewYbrk NAGlugMD8883 QndBedimNewWtCoungr comminenn ames cenasons 6 of 24FILED: BRONX COUNTY CLERK 03/07/2023 03:50 PM INDEX NO. 801219/2021ENYSCEF DOC. NO. 15 RECEIVED NYSCEF: 03/07/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX ----------------------------------------------------------------------------------x QUINCY JONES, REPLY TO DEFENDANTS ‘ DEMAND FOR DISCOVERY AND INSPECTION Index No.: 801219/2021E Plaintiff(s), -against- DARDANIA PROPERTIES LLC, Defendant(s). ----------------------------------------------------------------------------------x Plaintiff(s), QUINCY JONES, by his attorneys, LESCH & LESCH, P.C., responding to Defendant(s), DARDANIA PROPERTIES LLC’s, Demand for Discovery and Inspection as follows: 1. Affidavit of Service: Served simultaneously with this reply is a copy of the Affidavit of Service of Plaintiff(s)’ Summons and Complaint. 2. Demand for Plaintiff(s)’ Income Tax Returns: Not applicable. 3. Authorizations for No-Fault Medical and Wage Records: Not applicable. 4. Claims Pursuant to No-Fault Law: Not applicable. 5. Claims Pursuant to Workers’ Compensation Law: Unknown at this time and will be provided upon completion of discovery. 6. Disability: Questions regarding disability will be answered at Plaintiff(s) deposition. 7. Demand Pursuant to CPLR 4545(c): Unknown at this time and will be provided upon completion of discovery. 8. Authorizations for Employment Records: Unknown at this time and will be provided upon completion of discovery. 9. Authorizations for Medical Records: Served simultaneously with this reply are authorizations allowing the release of Plaintiff(s)’ medical records from Jacobi Medical 7 of 24FILED: BRONX COUNTY CLERK 03/07/2023 03:50 PM INDEX NO. 801219/2021ENYSCEF DOC. NO. 15 RECEIVED NYSCEF: 03/07/2023 Center, associated with NYC Health + Hospitals, located at 1400 Pelham Parkway South, Bronx, New York 10461. 10. Demand for Medical Records: See response to number 9 above and number 13 below. 11. Demand for List of Attorneys: The attorney for the Plaintiff(s), QUINCY JONES, is GARY E. LESCH, ESQ., associated with the law firm of LESCH & LESCH, P.C., located at 860 Grand Concourse, Suite 2M, Bronx, New York 10451, with telephone number (718) 292-1131. Defendant(s), DARDANIA PROPERTIES LLC, is represented by the law firm of SMITH MAZURE, P.C., located at 111 John Street, New York, New York 10038, with telephone number (212) 964-7400. 12. Demand for Photographs: Served simultaneously with this reply are photographs of Plaintiff(s)’ injuries and of the hole on the wall of his apartment with a bed bug crawling out of it. 13. Demand Pursuant to CPLR 3101(d): Plaintiff(s) intends to call the following as expert witness at time of trial: Dr. John Ettwein Arbo, M.D., an Emergency Medicine Specialist, Internal Medicine Specialist, and Critical Care Medicine Specialist, associated with Jacobi Medical Center. The aforesaid expert is duly licensed to practice Medicine within the State of New York and will testify that the injuries sustained by Plaintiff(s) as a result of the bed bug infestation that occurred on or about December 29, 2019 are permanent in nature and duration. The physician will rely on their physical examination of the Plaintiff(s) and on the medical records of Jacobi Medical Center. His testimony can be found in his reports/records attached hereto, including history, diagnosis, prognosis, and treatment. Plaintiff(s) refers the Defendant(s) to the Medical Directory of the State of New York Volumes 2019-2023 for a detailed list of the physicians’ educational background, licenses, publications, and hospital affiliations. Curriculum vitae will be exchanged upon receipt of same. 8 of 24FILED: BRONX COUNTY CLERK 03/07/2023 03:50 PM INDEX NO. 801219/2021ENYSCEF DOC. NO. 15 RECEIVED NYSCEF: 03/07/2023 14. Demand for the Names and Addresses of All Witnesses: Upon information and belief, Ms. Raven Frazier, Plaintiff(s)’ girlfriend, was a witness to the accident. The address and contact number of Ms. Frazier is currently unknown and will be provided upon completion of discovery. Plaintiff(s) reserves his right to amend and/or supplement this upon completion of discovery. 15. Demand for Statements Pursuant to CPLR 3101(e) and 3120: Plaintiff(s) does not have in possession any statements of the Defendant(s), its servants, agents, and/or employees. 16. Demand for Medicare, Medicaid, and SCHIP Extension Act of 2007: Unknown at this time whether or not Plaintiff(s) availed Medicaid and/or Social Security benefits for treatments arising from injuries sustained. Notwithstanding, served simultaneously with this reply is an authorization allowing release of Plaintiff(s)’ Medicaid records. 17. Demand for Notice of Non-Emergency Surgery: Not applicable. 18. Demand for W-9: Not applicable. 19. Demand for Insurance Information: Unknown at this time and will be provided upon completion of discovery. Dated: Bronx, New York March 7, 2023 Yours, etc. LESCH & LESCH, P.C. By: ____________________________ GARY E. LESCH, ESQ. Attorneys for Plaintiff(s) 860 Grand Concourse, Suite 2M Bronx, New York 10451 (718) 292-1131 9 of 24FILED: BRONX COUNTY CLERK 03/07/2023 03:50 PM INDEX NO. 801219/2021ENYSCEF DOC. NO. 15 RECEIVED NYSCEF: 03/07/2023 TO: SMITH MAZURE, P.C. Attorneys for Defendant DARDANIA PROPERTIES LLC 111 John Street New York, NY 10038 Phone: (212) 964-7400 Your File No.: HUD-01032 10 of 24FILED: BRONX COUNTY CLERK 03/07/2023 03:50 PM INDEX NO. 801219/2021ENYSCEF DOC. NO. 15 RECEIVED NYSCEF: 03/07/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX QUINCY JONES, Index No.: 801219/2021E Plaintiff(s), -against- DARDANIA PROPERTIES LLC, Defendant(s). VERIFIED BILL OF PARTICULARS LESCH & LESCH, P.C. Attorneys for Plaintiff(s) Office & P.O. Address 860 Grand Concourse, Suite 2M Bronx, New York 10451 (718) 292-1131 TO: SMITH MAZURE, P.C. 11 of 24FILED: BRONX COUNTY CLERK 03/07/2023 03:50 PM INDEX NO. 801219/2021ENYSCEF DOC. NO. 15 RECEIVED NYSCEF: 03/07/2023 / OCA Official Form No.: 960 AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA [This form has been approved by the New York State Department of Health] Patient Name Date of Birth Social Number Q UINCY JONES 1990 Patient Address New York 10461 I, or my authorized representative, request that health information regarding my care and treatment be released as set forth on this form: In accordance with New York State Law and the Privacy Rule of the Health Insurance Portability and Accountability Act of 1996 (HIPAA), I understand that: 1. This authorization may include disclosure of information relating to ALCOHOL and DRUG ABUSE, MENTAL HEALTH except and CONFIDENTIAL HIV* RELATED TREATMENT, psychotherapy notes, INFORMATION only if I place my initials on the appropriate line in Item 9(a). In the event the health information described below includes any of these types of and I information, initial the line on the box in Item 9(a), I specifically authorize release of such information to the person(s) indicated in Item 8. 2. If I am authorizing the release of HIV-related, or drug treatment, or mental health treatment alcohol information, the recipient is prohibited fmm redisclosing such information my authorization unless permitted without to do so under federal or state law. I understand that I have the right to request a list of people who may receive or use my HIV-related information without authorization. If I experience discrimination because of the release or disclosure of HIV-related information, I may contact the New York State Division of Human Rights at (212) 480-2493 or the New York City Commission of Human Rights at (212) 306-7450. These agencies are responsible for protecting my rights. 3. I have the right to revoke at any time by writing this authorization to the health care provider listed below. I understand that I may revoke this authorization that action has aheady been taken based on this authorization. except to the extent 4. I understand that signing this authorization is voluntary. My treatment, payment, enrollment in a health plan, or eligibility for benefits will not be conditioned upon my authorization of this disclosure. 5. Information disclosed under this authorization might be redisclosed by the recipient (except as noted above in Item 2), and this redisclosure may no longer be protected by federal or state law. 6. THIS AUTHORIZATION DOES NOT AUTHORIZE YOU TO DISCUSS MY HEALTH INFORMATION OR MEDICAL CARE WITH ANYONE OTHER THAN THE ATTORNEY OR GOVERNMENTAL AGENCY SPECIFIED IN ITFM 9 (h 7. Name and address of health pmvider or entity to release this information: NYC HEALTH + HOSPITALS | JACOBI MEDICAL CENTER; 1400 Pelham Parkway South, Bronx, New York 10461 8. Name and address of person(s) or category of person to whom this information will be sent: SMITH MAZURE, P.C.; 111 John Street, New York, New York 10038 9(a). Specific information to be released: December 29, 2019 until the present GB Medical Record from (insert date) to (insertdate) O Entire Medical Record, including patient histories, office notes (except psychotherapy notes), test results, radiology studies, films, referrals, consults, billing records, insurance records, and records sent to you by other health care providers. GB Other: include billing records and diagnostic Include: (Indicate by Initiating) studies, if any Alcohol/Drug Treatment Mental Health Information Authorization to Discuss Health Information HIV-Related Information (b) O By initialing here I authorize Initials Name of individualhealth care provider to discuss my health information with my attorney, or a govemmental agency, listed here: (Attorney/Firm Name or Governmental Agency Name) 10. Reason for release of information: 11. Date or event on which this authorization will expire: t e uest o UPON COMPLETION OF LITIGATION ndT A ON 12. Ifnot the patient, name of person signing foÀn: 13. Authority to sign on behalf of patient: Allitems on this form have been completed and my questions about this form have been answered. In addition, I have been provided a copy of f sm. March 7, 2023 Date: Signat ofpation e authorized by law. * Human Immunodeficienc Virus that causes AIDS. The New York State Public Health Law protects information which could reasonably identify someone as having HIV symptoms or infection and information regarding a person's contacts. 12 of 24FILED: BRONX COUNTY CLERK 03/07/2023 03:50 PM INDEX NO. 801219/2021ENYSCEF DOC. NO. 15 RECEIVED NYSCEF: 03/07/2023 Authorization to Release Protected NEW YORK STATE DEPARTMENT OF HEALTH Office of Health Insurance Programs Medicaid Member Information to a Third Party Medicaid Member Name (required): Q Uincy Jones Date of Birth (required): / / 1990 At Least one of the following identification numbers is required, preferably both. Client Identification Number (CIN): Social Number (SSN): - - 0693 Security Persons/organizations authorized to receive or use the information: Name: Smith Mazure, P.C. Address: 111 John Street City:New York State:New York zipCode:10038 212 )964 _ 7400 Phone Number: ( Dates Authorized: ¡ All OR From: 12 / 29 /2019 To: / / OR M To Present Purpose of the use/disclosure: LITIGATION 1. I understand that my health care and the payments for my health care will not be affected if I do not sign this form except in some situations when information is needed for the health plan's eligibility or enrollment determinations relating to the individual. 2. I understand, with few exceptions, that I may see and copy the information described on this form if I ask for it, and that I may get a copy of this form after I sign it. 3. I may revoke this authorization at any time by notifying the Department of Health in writing at the address below, but, if I do, it will not have any effect on actions that the Department took before they received the revocation. If not previously revoked, this authorization will expire upon completion of this request or one year from the date this form is signed, whichever comes first. 4. I understand that this authorization is voluntary. I understand that if the organization authorized to receive the information is not a health plan, health care provider or clearinghouse, the released information may no tonger be protected by federal privacy regulations, and therefore the recipient of the confidential data may re disclose the confidential data. By signing this form, Iundentand that Iam attowing the New York State Department of Health to use or disclose att of the payment information for the Medicaid Member as indicated above, including data on certain conditions such as HIV/AIDS, Mentat Health and Alcohot and Substance Abuse.I ecificatty authorize release of such information to the penon(s) indicated above as the recipient. March 7, 2023 Signature of Medi d M er or ent Date If not member, name of person signing for member Authority to sign on behalf of member Witness Signature Witness Name Please return to: Medicaid Data Warehouse - CDRs NYSDOH - MISCNY ESP P1-115 Dock ] Albany NY 12237 DOH-5198 (1/16) 13 of 24FILED: BRONX COUNTY CLERK 03/07/2023 03:50 PM INDEX NO. 801219/2021ENYSCEF DOC. NO. 15 RECEIVED NYSCEF: 03/07/2023 ATTORNEY(S) : Lesch & Lesch P.C. INDEx # : 801219/2021E P4533550 PURCHASED/FILED : January 27, 2021 STATE OF : NEw YoRK CouRT : Supreme COUNTY/DISTRICT : Bronx AFFIDAVIT OF SERVICE - SECRETARY OF STATE Quincy Jones Plaintiff(s) against Dardania Properties LLC Defendant(s) STATE OF NEW YORK ) DESCRIPTION OF PERSON SERVED: Approx. Age: 55 Yrs. COUNTYOFALBANY )SS CITY OF ALBANY 5' 0" ) Weight: 120 Lbs. Height: Sex: Female Color of skin: White Hair color: Blonde Other: Robert Guyette , being duly sworn, deposes and says: deponent is over the age of eighteen (18) years; is not a party to this action, and resides in the State of NY, and that on April 20, 2021 , at 12:40pm , at the office of the Secretary of State of the State of NY, located at 99 Washington Ave, 6th FI, Albany, New York 12231 deponent served: Summons with Notice & Verified Complaint on Dardania Properties LLC the Defendant in this action, by delivering to and leaving with Sue Zouky AUTHORIZED AGENT in the Office of the Secretary of State, of the State of New York, personally at the Office of the Secretary of State of the State of New York, two (2) true copies thereof and that at the time of making such service, deponent paid said Secretary of State a fee of $40 dollars; That said service was made pursuant to Section LIMITED LIABILITY COMPANY LAW §303. Deponent further says that deponent knew the person so served as aforesaid to be the agent in the Office of the Secretary of State of the State of New York, duly authorized to accept such service on behalf of said defendant. Sworn to before me on this 20th day of April, 2021 Robert Guyette FAITH CO NOTARY PUBUC, State o or Invoice-Work Order # 2112227 No. 01C06158874, Albany County # 4533550 Attorney File Commission Expires Jan 8, 2023 14 of 24FILED: BRONX COUNTY CLERK 03/07/2023 03:50 PM INDEX NO. 801219/2021ENYSCEF DOC. NO. 15 RECEIVED NYSCEF: 03/07/2023 HHC H L H INFO MGMT 990, Sex: M New York NY 10041 Demographics Patient Name Patient ID Sex Date of Birth Marital Status Jones, Quincy Male 990 Single Address Home Phone Work Phone Mobile Phone Religion Non-Denominational NY 10461 PCP Insurance Information Employer Race Language Provider, Unknown
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Payment shall be made within 45 days of Plaintiffs execution of a long form settlement agreement and release of all claims. 3. Plaintiffs counsel shall file a Notice or Settlement with the trial court. 4. The parties agree to take the trial, scheduled for July 22, 2024, off calendar. 5. The Plaintiff agrees to accept the settlement with the knowledge that she will be barred from proceeding in the future concerning any matter connected or related to this case. 6. The parties shall execute a full and complete releases prepared by the Defendants and approved by Plaintiff which shall include an express waiver of CC 1542, thereby releasing all parties and counsel from any new known and unknown claims arising from the allegations set forth in the pleadings, except for the obligations outlined in this agreement. 7. Each party shall bear their own costs and attorney's fees. 8. This settlement agreement shall be binding and enforceable, pursuant to CCP 664.6& and reflects the final agreement regarding the material terms between the parties to this dispute& The parties dispute the effect of the terms of the settlement, focusing on paragraphs 5 and 6. Specifically, the parties discuss the release, and its effect on the defaulted third party, Specialized Community Healthcare Company. Defendants explain that counsel drafted the contemplated long form settlement agreement and release, but when it came time to sign, Plaintiff refused unless Defendants agreed to exclude Specialized from the release. (Spigner Decl. ¶ 7.) Plaintiff argues Specialized should be excluded from the release and that Plaintiff should proceed to default judgment since Specialized was not part of the settlement, was unrepresented and was previously defaulted. The Court concurs that the proper interpretation of the parties in paragraph 6 would not include Specialized. Thus, Specialized should not be included in any express waiver/release under Civil Code section 1542 required by the Settlement. Defendants proffer an unreasonable interpretation of the parties and all parties and counsel without consideration of the other express terms of the contract. The contract does not refer to Specialized at all. The settlement is expressly between two parties, Plaintiff and Defendants. The title caption only refers to Plaintiff and Defendants. The signature blocks only provide space for Plaintiff and Defendants. Counsel for Defendants purports to only represent Defendants. Paragraph 6 itself specifically requires The parties to execute a full and complete releases. It is unlikely that the parties to the settlement intended for Specialized to execute the full settlement and release. The record suggests the very opposite, since the parties have no apparent control over Specialized. In light of these facts, paragraph 6 does not support Defendants motion. However, the Settlement still requires dismissal of all defendants, including Specialized. The Settlement provides that Plaintiff will be barred from proceeding in the future concerning any matter connected or related to this case. (Settlement ¶ 5.) In light of these broad terms, Plaintiff is barred from proceeding in this action. Plaintiff is precluded from proceeding in any action connected to or related to this case. This action is a matter connected to or related to this case. Further, Plaintiff filed a notice of settlement of the entire action. As Plaintiff is barred from proceeding in this matter by the Settlement, the Court must dismiss the entire action in accordance with the settlement if the motion is granted. The Court finds the case of Provost, cited by both parties, instructive on this point. (Provost v. Regents of Univ. of California, (2011) 201 Cal. App. 4th 1289, 1299.) There, the Regents were allowed to enforce the stipulated settlement which required dismissal of individual non-signatory defendants. (Id.) The Provost court noted that the individual defendants neither signed the agreement, nor sought to enforce the settlement., but [r]ather, they [were] third party beneficiaries of the stipulated settlement and the judgment in their favor [was] valid as well. (Id., at 1298.) The court found that the language of the stipulated settlement demonstrated it was made for the benefit of the individual defendants by providing statements such as [t]he case is settled as to all claims ... and the entire action [is] dismissed [with] prejudice. (Id. at 1299.) While the instant settlement does not expressly require dismissal of the entire action, the settlement language shows that the parties intended that Plaintiff could not proceed with the action generally, which would necessarily include any further action against Specialized. As such, the Court is will grant the motion on the following terms. Plaintiff and Defendants must execute the full and complete long form settlement agreement and releases prepared by Defendants per paragraph 6 within one week. The releases do not need to expressly reference Specialized and should only pertain to Plaintiff and Defendant. Binko and SCHG must pay Plaintiff a sum of $50,000.00 within 45 days of the execution of the release. The Court will continue the OSC re: Dismissal (Settlement) to December 4, 2024, at 8:30 a.m. If Plaintiff receives payment, the Court will enter a dismissal of the entire action in accordance with the settlement agreement. Considering the above discussion, the Court does not find either partys position to be frivolous or made in bad faith required for sanctions under Code of Civil Procedure section 128.5. Accordingly, the Court will not grant sanctions.
Ruling
Gaige vs. Greyhound Lines, Inc, et al.
Aug 29, 2024 |23CV-0203891
GAIGE VS. GREYHOUND LINES, INC, ET AL.Case Number: 23CV-0203891This matter is on calendar for review regarding status of removal. The matter was removed to Federal Court andon February 23, 2024, the Court found this matter to be exempt from case disposition goals under CRC3.714(c)(1). Due to the removal to Federal Court, the Court removes this matter from the Court’s control. TheCourt continues this Review Hearing to Monday, August 25, 2025 at 9:00 a.m. in Department 63 for reviewregarding status of removal. No appearance is necessary on today’s calendar.
Ruling
EVA HERERRA VS KATHY SCOTT
Aug 26, 2024 |Renee C. Reyna |21STCV23166
Case Number: 21STCV23166 Hearing Date: August 26, 2024 Dept: 29 Hererra v. Scott 21STCV23166 Motion to Continue Trial filed by Defendant Kathy Scott. Tentative The motion is granted. Background On June 22, 2021, Eva Hererra (Plaintiff) filed a complaint against Kathy Scott (Defendant) for negligence arising out of a dog attack incident on June 24, 2019. On July 7, 2023, Defendant filed an answer. On July 29, 2024, Defendant filed this motion to continue trial. No opposition has been filed. Legal Standard Code of Civil Procedure section 128, subdivision (a)(8), provides that the court has the power to amend and control its process and orders so as to make them conform to law and justice. The power to determine when a continuance should be granted is within the discretion of the trial court. (Color-Vue, Inc. v. Abrams (1996) 44 Cal.App.4th 1599, 1603.) A trial court has wide latitude in the matter of calendar control including the granting or denying of continuances. (Park Motors, Inc. v. Cozens (1975) 49 Cal.App.3d 12, 18.) To ensure the prompt disposition of civil cases, the dates assigned for trial are firm. All parties and their counsel must regard the date set for trial as certain. (Cal. Rules of Court, rule 3.1332(a).) Although continuances of trials are disfavored, each request for a continuance must be considered on its own merits. (Cal. Rules of Court, rule 3.1332(c).) The court may grant a continuance only on an affirmative showing of good cause requiring the continuance. (Ibid.) Circ*mstances that may support a finding of good cause include: (1) The unavailability of an essential lay or expert witness because of death, illness, or other excusable circ*mstances; (2) The unavailability of a party because of death, illness, or other excusable circ*mstances; (3) The unavailability of trial counsel because of death, illness, or other excusable circ*mstances; (4) The substitution of trial counsel, but only where there is an affirmative showing that the substitution is required in the interests of justice; (5) The addition of a new party if: (A) The new party has not had a reasonable opportunity to conduct discovery and prepare for trial; or (B) The other parties have not had a reasonable opportunity to conduct discovery and prepare for trial in regard to the new party's involvement in the case; (6) A party's excused inability to obtain essential testimony, documents, or other material evidence despite diligent efforts; or (7) A significant, unanticipated change in the status of the case as a result of which the case is not ready for trial. (Cal. Rules of Court, rule 3.1332(c).) In ruling on a motion or application for continuance, the court must consider all the facts and circ*mstances that are relevant to the determination. (Cal. Rules of Court, rule 3.1332(d).) California Rules of Court, rule 3.1332(d) sets forth a non-exhaustive list of factors that the court may consider: (1) The proximity of the trial date; (2) Whether there was any previous continuance, extension of time, or delay of trial due to any party; (3) The length of the continuance requested; (4) The availability of alternative means to address the problem that gave rise to the motion or application for a continuance; (5) The prejudice that parties or witnesses will suffer as a result of the continuance; (6) If the case is entitled to a preferential trial setting, the reasons for that status and whether the need for a continuance outweighs the need to avoid delay; (7) The court's calendar and the impact of granting a continuance on other pending trials; (8) Whether trial counsel is engaged in another trial; (9) Whether all parties have stipulated to a continuance; (10) Whether the interests of justice are best served by a continuance, by the trial of the matter, or by imposing conditions on the continuance; and (11) Any other fact or circ*mstance relevant to the fair determination of the motion or application. (Cal. Rules of Court, rule 3.1332(d).) Discussion Defendant contends that she has been unable to obtain Plaintiffs deposition. (Morand Decl., ¶ 2.) Defendant argues Plaintiffs deposition is necessary to fully evaluate her claims against Defendant. (Id.) Defendant is also interested in pursuing mediation for this matter. (Id., ¶ 5.) In her motion, Defendant contends she has noticed Plaintiffs deposition multiple times, but it has yet to occur. (Motion, 3:10-16.) Plaintiff has not filed an opposition to this motion, and was non-responsive to Defendants request to meet and confer regarding a trial continuance and discovery. (Id., ¶ 4.) The request to continue trial is GRANTED for good cause shown Conclusion The Court GRANTS the motion to continue trial. The Court CONTINUEs trial to approximately mid April 2025. The Final Status Conference and all discovery deadlines are reset based on the new trial date. Moving Party is ORDERED to give notice.
Ruling
RODNEY PIMENTEL VS JOSEPHY BARRETT ET AL
Aug 27, 2024 |BC701615
Case Number: BC701615 Hearing Date: August 27, 2024 Dept: 57 The Court is denying the motion of Defendants Joseph Barrett and the Barrett Law Firm ("the Barrett Defendants") for reconsideration of the Court's decision denying in part their motion for summary judgment or summary adjudication on the claims of Plaintiff Rodney Pimentel ("Pimentel") . The Court disagrees with Pimentel's contention that the Barrett Defendants' motion for reconsideration is a renewed motion for summary judgment or summary adjudication that does not comply with requirements of Code of Civil Procedure Section 437c. In the Court's view, the Barrett Defendants' motion for reconsideration was properly filed under Section 1008. In that regard, the Court accepts the Barrett Defendants' contention that they did not have a meaningful opportunity at the hearing on their motion for summary judgment or summary adjudication to present precedent on the mediation privilege, which, according to the Barrett Defendants, renders the Court's decision denying their motion for summary judgment or summary adjudication wrong as a matter of law. The Court reviewed that precedent following the hearing and before issuing its decision -- particularly Wimsatt v. Superior Court (2007) 152 Cal.App.4th 137. The Court concluded that the precedent did not compel the conclusion that the Barrett Defendants were entitled to summary judgment or summary adjudication on Pimentel's claims that the Court left standing. The Court has reviewed that precedent again in connection with the Barrett Defendants' motion for reconsideration. Following the additional review, the Court is adhering to its summary judgment ruling and denying the motion for reconsideration.The Court also is denying the motion of Defendant Todd Wakefield ("Wakefield") for reconsideration of the Court's decision denying his motion for summary judgment or summary adjudication. The Court based that decision on the ground that the declaration that Wakefield submitted in support of his motion for summary judgment or summary adjudication, which was the only evidence that he submitted, failed to comply with the strict requirements of Code of Civil Procedure Section 2015.5. In the Court's view, Wakefield has offered insufficient grounds to warrant reconsideration of the Court's determination that the defects in Wakefield's declaration compelled denial of his motion for summary judgment or summary adjudication.
Ruling
Stayer vs. A Plus Safety LLC, et al.
Aug 27, 2024 |23CV-0203556
STAYER VS. A PLUS SAFETY LLC, ET AL.Case Number: 23CV-0203556This matter is on calendar for review regarding status of the case. The Court notes that allComplaints and Cross-Complaints are at issue, with the exception of the most recently filed Cross-Complaint, filed by O’Reilly Auto Enterprises, LLC on August 9, 2024. However, all partiesnamed in that Cross-Complaint have previously appeared as Plaintiffs, Defendants, or Cross-Defendants in this action. The parties are ordered to appear to discuss status and trial setting.
Ruling
DANIEL CORONA VS WHITE MEMORIAL MEDICAL CENTER ET AL
Aug 27, 2024 |BC585574
Case Number: BC585574 Hearing Date: August 27, 2024 Dept: 78 Superior Court of California County of Los Angeles Department 78 ¿ DANIEL CORONA, by and through his Guardian Ad Litem REBECCA GUTIERREZ, Plaintiff(s), vs. WHITE MEMORIAL MEDICAL CENTER, et al., Defendant(s). Case No.: BC585574 Hearing Date: August 27, 2024 [TENTATIVE] ORDER GRANTING MOTION FOR ATTORNEY FEES I. BACKGROUND & PROCEDURAL HISTORY Plaintiff Daniel Corona, a minor through his mother and guardian ad litem Rebecca Gutierrez, (Plaintiff) filed this action against his mothers prenatal health care provider Dr. Kathryn Shaw (Dr. Shaw). Plaintiff alleged Dr. Shaw negligently failed to diagnose his serious abnormalities that were evident on his ultrasound. On April 19, 2018, the parties filed a Notice of Settlement. On April 16, 2019, Plaintiffs petition to approve minors compromise was granted and the court found that the proposed $1,250,0000 settlement reasonably compensated minor Plaintiff for his claim. After deducting expenses and attorney fees, the balance of $873,504.18 was divided between a deferred annuity and an irrevocable special needs trust. (Order Approving Compromise, April 16, 2019.) Further, with the consent of Department of Health Care Services, (DHCS), $358,117.51 would be disbursed to Plaintiffs counsels Client Trust Account pending determination of DHCS lien claim. (Ibid.) On July 6, 2020, DHCS provided a revised final lien letter stating that it had paid $358,061 for Plaintiffs medical care, from which it sought to recover $229,696. On August 10, 2020, Judge Draper granted DHCS Medi-Cal Lien in the amount of $229,696. Plaintiff timely appealed, and the Court of Appeal found that the court erred by failing to equitably allocate the settlement amount. On November 29, 2023, Judge Feeney ruled that DHCS was to recover on its lien in the amount of $23,204.70. On June 12, 2024, Plaintiffs counsel filed the instant motion seeks approval for disbursem*nt of minor Plaintiffs funds in the amount of $30,973.80 for attorneys fees and $1,499.61 for costs advanced arising from the determination of DHCS lien, and pursuant to the retainer agreement between Plaintiff and his counsel. II. DISCUSSION Plaintiffs counsel avers that Plaintiff previously paid to DHCS $229,696 as determined by Judge Draper. After Judge Feeney determined that DHCS was entitled to collect $23,204.70 for its lien claim, the court ordered DHCS to issue a refund to Plaintiff in the amount of $206,492.03. DHCS paid the refund on February 14, 2024 via a check made payable to Plaintiffs counsels Client Trust Account. Plaintiffs counsel declares he distributed $174,018.62 to Plaintiffs Special Needs Trust, and held the remaining $32,473.41 in the Client Trust Account pending approval of distribution to Plaintiffs counsel for fees and costs advanced. Attorneys fees are allowed as costs when authorized by contract, statute, or law. (Code Civ. Proc, § 1033.5, subd. (a)(10)(B).) Here, Plaintiffs counsel attests that he and Plaintiff have a contingency fee agreement ,which specifies that Plaintiffs counsel is to receive 15% in fees of any reduction of DHCS lien claim, and that Plaintiffs counsel would be reimbursed for any costs advanced on Plaintiffs behalf. (Mot. Exh. 3.) Plaintiffs counsel avers 15% of $206,492.03 equates to $30,973.80, and that the receipts demonstrate costs advanced of $1,499.61 (Mot. Exh. 4) for filing fees and transaction costs incurred for filing the appeal and documents with the superior court. The Court has reviewed the Retainer Agreement Contingency Fee Contract and finds that Plaintiffs counsel has demonstrated that he is entitled to attorneys fees arising from settlement/determination of the DHCS lien by contractual agreement with Plaintiff through his guardian ad litem. Further, Plaintiffs counsel has supported, with evidence, the amount of costs advanced on behalf of Plaintiff. III. CONCLUSION The motion for attorney fees in the amount of $30,973.80 and reimbursem*nt of costs in the amount of $1,499.61 to be distributed from the Client Trust Account to Plaintiffs counsel is GRANTED. Moving Party is ordered to give notice. DATED: August 23, 2024 __________________________ Hon. Michelle C. Kim Judge of the Superior Court PLEASE TAKE NOTICE: " Parties are encouraged to meet and confer after reading this tentative ruling to see if they can reach an agreement. " If a party intends to submit on this tentative ruling, the party must send an email to the court at SMCDEPT78@lacourt.org with the Subject line SUBMIT followed by the case number. The body of the email must include the hearing date and time, counsels contact information, and the identity of the party submitting. " Unless all parties submit by email to this tentative ruling, the parties should arrange to appear remotely (encouraged) or in person for oral argument. You should assume that others may appear at the hearing to argue. " If the parties neither submit nor appear at hearing, the Court may take the motion off calendar or adopt the tentative ruling as the order of the Court. After the Court has issued a tentative ruling, the Court may prohibit the withdrawal of the subject motion without leave.
Ruling
MONCINO HADNOT-BROWN VS GLAM HOUSE LOS ANGELES
Aug 26, 2024 |24STCV00245
Case Number: 24STCV00245 Hearing Date: August 26, 2024 Dept: 28 On August 1, 2024, the Court granted Midvale Indemnity Company (Midvale) leave to intervene on behalf of Defendant Happy Home Goods LLC dba Glam House (erroneously sued and served as Glam House Los Angeles) based on the stipulation between Midvale and Plaintiff Moncino Hadnot-Brown. Therefore, Midvales motion for leave to intervene, set to be heard on August 26, 2024, is moot.
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