(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) In Huggins v. Longs Drug Stores (1993) 6 Cal.4th 124, the trial court granted defendant pharmacy summary judgment in an action by parents for negligent infliction of emotional distress arising from…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) PURSUANT TO GOVERNMENT CODE SECTION 12940 ET SEQ. PLAINTIFFS, ROSA BROWN, MANUEL WHITE and PATRICIA GREEN, jointly and/or severally allege as follows: GENERAL ALLEGATIONS BY PLAINTIFFS AGAINST DEFENDANTS FOR VIOLATION OF…
C. Third Cause of Action: Loss of Consortium Andy Bates, husband of Susan Bates, makes a claim for loss of consortium following his wife’s total incapacity. II. DAMAGES A. Alex Barchuk, M.D. In order to assess Ms. Bates’ need for ongoing medical and attendant care under both her First and…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) The collision was investigated by Officer A. E. Jones of the California Highway Patrol. In his report Jones states the following: “P-1 [Chris] stated he was driving V-1 westbound on Greenback…
Superior Court of California. Sacramento County Sabrina Williams, Plaintiff, v. HBZT, a California corporation, Dan Black, an individual and Does 1 through 50, inclusive, Defendants. Jury Trial Demanded Complaint for Damages 1. Employment Discrimination-Gender (Violation of Gov’t Code §12940 et seq.) 2. Sexual Harassment (Violation of Gov’t Code §12900 et…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) II. LEGAL STANDARD A party who seeks a court’s action in its favor bears the burden of persuasion thereon. (Evid. Code § 500). Thus, “from commencement to conclusion, the party moving…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) RE: Susan and Andy Bates I. BRIEF SUMMARY OF CLAIMS Ms. Bates’ claims involve two distinct separate injuries occurring at two different times. Her claims are brought under two separate legal…
3. Plaintiff is informed and believes, and based thereon alleges that Defendant DAN BLACK, (hereinafter “BLACK”) is an individual who at all relevant times herein was a resident of the County of Sacramento. Plaintiff is informed and believes that at all relevant times herein BLACK was Defendant HBZT’s Nighthawk’s bar…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) Here, the Plaintiffs contemporaneously understood that viewing the child’s deterioration was watching injury to a close relative. In Byrd, the Supreme Court discussed Ochoa v. Superior Court (1985) 39 Cal.3d 159:…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) IV. PLAINTIFF’’S ACUTE TRAUMATIC BRAIN INJURY Plainitff was unconscious when fire rescue arrived on scene. She had a Glasgow Coma Scale (GCS) of only 3. Her jaw was clenched. Plainitff remembers…