(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this sexual harassment case and its proceedings.) E. DEFENDANTS’ DEMURRER MUST FAIL BECAUSE PLAINTIFFS’ HAVE SUFFICIENTLY STATED A CAUSE OF ACTION FOR VIOLATION OF BUSINESS AND PROFESSIONS CODE § 17200…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this medical malpractice case and its proceedings.) COMPLAINT FOR DAMAGES (1) Negligence/ Medical Malpractice; (2) Willful Misconduct and Battery [Brought by Plaintiff Sura Bhandi as against all Defendants] COUNT ONE:…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this workplace harassment/sex discrimination case and its proceedings.) ARGUMENT SUMMARY JUDGMENT STANDARDS IN WRONGFUL TERMINATION A plaintiff in a wrongful termination case can overcome summary judgment by one of two…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this automobile accident/insurance coverage case and its proceedings.) Blue Shield’s argument that this court should conformist ruling on this motion to a statement of decision recently signed by a Los…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this workplace/sex discrimination case and its proceedings.) ACTS OCCURRING PRIOR TO JUNE 10, 2004 ARE ACTIONABLE UNDER THE CONTINUING VIOLATION DOCTRINE The defendant concedes that evidence of retaliation or discrimination…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this workplace harassment/sex discrimination case and its proceedings.) THE REASONS FOR HER TERMINATION ARE TOTALLY FABRICATED Defendant’s reasons for termination are totally fabricated. Plaintiff never yelled at Mr. Chan in…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this automobile accident/insurance coverage case and its proceedings.) BLUE SHIELD DID NOT COMPLETE ITS MEDICAL UNDERWRITING OR TAKE STEPS TO ANSWER ALL REASONABLE QUESTIONS ARISING FROM THE INFORMATION CONTAINED IN…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this workplace harassment/sex discrimination case and its proceedings.) THERE IS DIRECT EVIDENCE THAT THE TERMINATION WAS MOTIVATED BY PLAINTIFF’S PREGNANCY AND COMPLAINTS There is ample direct evidence that Plaintiff was…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this workplace/sex discrimination case and its proceedings.) If the defendant believed Mr.Carter was permanently disabled as a firefighter, then it had an ongoing duty under the law to alert him…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this automobile accident/insurance coverage case and its proceedings.) PLAINTIFFS’ OPPOSING SEPARATE STATEMENT OF UNDISPUTED MATERIAL FACTS DEMONSTRATES THAT DEFENDANTS FACTS ARE DISPUTED AND THAT DEFENDANT’S MOTION MUST THEREFORE BE DENIED.…