(Please note: the names and locations of all parties have been changed to protect the confidentiality of this wrongful death case and its proceedings.) D. Universal Exercised Complete or Substantial Control Over its Franchises Universal first started franchising its stores in 1972 to further merchandise its products and increase profits.…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of this car accident case and its proceedings.) SECOND CAUSE OF ACTION Breach of Implied Covenant of Good Faith and Fair Dealing (Plaintiffs against Defendants XYZ and DOES 1-20) 29. Plaintiffs incorporate by reference…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of this medical malpractice case and its proceedings.) IN ESPINOSA v. LITTLE COMPANY OF MARY HOSPITAL, THE SECOND DISTRICT REJECTED ARGUMENTS IDENTICAL TO DEFENDANTS’ ARGUMENTS HERE Included in the Sources and Authorities supporting CACI…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of this wrongful death case and its proceedings.) C. There Is No Requirement That Plaintiffs Show That Dr. XY Was The Custodian of Claire Fine. In his moving papers, Dr. XY maintains that he…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) B. Universal Exposed Tina Gomez to Asbestos Decedent Tina Gomez met David Plaza during the summer of 1981. They soon began an 18-month relationship with Mr. Plaza living in Ms. Gomez’s…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of this car accident case and its proceedings.) FIRST CAUSE OF ACTION Breach of Contract (Plaintiffs against Defendants XYZ and DOES 1-20) 23. Plaintiffs incorporate by reference each and every allegation of this Complaint…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of this wrongful death case and its proceedings.) A. Decedent Was a Dependent Adult Within the Meaning of Welfare & Institutions Code § 15610.23 Welfare & Institutions Code § 15610.23 defines a dependent adult…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) Plaintiffs’ enterprise/market-share liability causes of action allege that the nature of the asbestos-products industry and market were such that decedent Tina Gomez likely used or was exposed to each defendant’s fungible…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of this car accident case and its proceedings.) BRIEF FACT SUMMARY cont. 16. On or about April 13, 2009, Plaintiffs again requested an explanation for Defendant’s denial and unreasonable delay in settling Plaintiffs’ claims.…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of this wrongful death case and its proceedings.) PLAINTIFFS AGREE TO DISMISS THEIR FOURTH CAUSE OF ACTION AS TO DR. XY Plaintiffs agree to dismiss their Fourth Cause of Action for Fraud-Concealment as to…