This case was last updated from Los Angeles County Superior Courts on 09/18/2020 at 00:48:21 (UTC).

ALEXANDRA BRUNELL VS UBER TEHNOLOGIES INC

Case Summary

On 03/23/2018 ALEXANDRA BRUNELL filed a Personal Injury - Other Personal Injury lawsuit against UBER TEHNOLOGIES INC. This case was filed in Los Angeles County Superior Courts, Stanley Mosk Courthouse located in Los Angeles, California. The Judges overseeing this case are MARC D. GROSS, JON R. TAKASUGI, HOLLY E. KENDIG and THOMAS D. LONG. The case status is Pending - Other Pending.

Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    ****9297

  • Filing Date:

    03/23/2018

  • Case Status:

    Pending - Other Pending

  • Case Type:

    Personal Injury - Other Personal Injury

  • Court:

    Los Angeles County Superior Courts

  • Courthouse:

    Stanley Mosk Courthouse

  • County, State:

    Los Angeles, California

Judge Details

Presiding Judges

MARC D. GROSS

JON R. TAKASUGI

HOLLY E. KENDIG

THOMAS D. LONG

 

Party Details

Plaintiff, Petitioner and Cross Defendant

BRUNELL ALEXANDRA

Defendants and Respondents

UBER TECHNOLOGIES INC

DOES 1 TO 50

SNOOTY FOX MOTOR INN AND

RASIER LLC

WONG MATTHEW

Riverside, CA 92506

Defendant and Cross Plaintiff

WONG MATTHEW

Riverside, CA 92506

Not Classified By Court

PINE TREE INDUSTRIAL CORPORATION

Attorney/Law Firm Details

Plaintiff, Petitioner and Cross Defendant Attorneys

STEINER JON M. ESQ.

STEINER JON MATTHEW ESQ.

Defendant and Respondent Attorneys

GIBSON STANLEY M. ESQ.

TYSON & MENDES LLP

CALEO PAUL

BRINSON KATHERINE JEANINE

LIU JEFFREY ZENKANG

Defendant and Cross Plaintiff Attorney

LIU JEFFREY ZENKANG

 

Court Documents

Certificate of Mailing for - CERTIFICATE OF MAILING FOR [STIPULATION AND ORDER TO CONTINUE TRIAL, NOTICE OF REJECTION OF ELECTRONIC FILING]

8/24/2020: Certificate of Mailing for - CERTIFICATE OF MAILING FOR [STIPULATION AND ORDER TO CONTINUE TRIAL, NOTICE OF REJECTION OF ELECTRONIC FILING]

Brief - BRIEF SUPPLEMENTAL BRIEF

2/6/2020: Brief - BRIEF SUPPLEMENTAL BRIEF

Minute Order - MINUTE ORDER (HEARING ON EX PARTE APPLICATION TO CONTINUE TRIAL AND ALL REL...)

2/18/2020: Minute Order - MINUTE ORDER (HEARING ON EX PARTE APPLICATION TO CONTINUE TRIAL AND ALL REL...)

Ex Parte Application - EX PARTE APPLICATION DEFENDANTS' EX PARTE APPLICATION TO CONTINUE TRIAL AND ALL RELATED DATES; DECLARATION OF SAMUEL R. NORA

2/18/2020: Ex Parte Application - EX PARTE APPLICATION DEFENDANTS' EX PARTE APPLICATION TO CONTINUE TRIAL AND ALL RELATED DATES; DECLARATION OF SAMUEL R. NORA

Reply - REPLY PLAINTIFFS REPLY TO DEFENDANTS OPPOSITION TO PLAINTIFFS MOTION TO COMPEL PERSON MOST KNOWLEDGEABLE DEPOSITION(S); DEPOSITION OF TRACEY BREEDEN AND RESPONSES TO REQUEST FOR PRODUCTION

12/24/2019: Reply - REPLY PLAINTIFFS REPLY TO DEFENDANTS OPPOSITION TO PLAINTIFFS MOTION TO COMPEL PERSON MOST KNOWLEDGEABLE DEPOSITION(S); DEPOSITION OF TRACEY BREEDEN AND RESPONSES TO REQUEST FOR PRODUCTION

Opposition - OPPOSITION TO PLAINTIFF'S MOTIONS TO COMPEL

12/18/2019: Opposition - OPPOSITION TO PLAINTIFF'S MOTIONS TO COMPEL

Motion to Compel - MOTION TO COMPEL PLAINTIFF'S NOTICE OF MOTION AND MOTION TO COMPEL PMK DEPOSITION(S);MEMO OF POINTS AND AUTHORITIES; DECLARATION OF JON M. STEINER

12/9/2019: Motion to Compel - MOTION TO COMPEL PLAINTIFF'S NOTICE OF MOTION AND MOTION TO COMPEL PMK DEPOSITION(S);MEMO OF POINTS AND AUTHORITIES; DECLARATION OF JON M. STEINER

Declaration - DECLARATION DECLARATION OF LYNN V. RIVERA IN SUPPORT OF DEFENDANTS SNOOTY FOX MOTOR INN AND PINE TREE INDUSTRIAL CORPORATION'S REPLY TO PLAINTIFF'S OPPOSITION TO DEFENDANT SNOOTY FOX MOT

9/13/2019: Declaration - DECLARATION DECLARATION OF LYNN V. RIVERA IN SUPPORT OF DEFENDANTS SNOOTY FOX MOTOR INN AND PINE TREE INDUSTRIAL CORPORATION'S REPLY TO PLAINTIFF'S OPPOSITION TO DEFENDANT SNOOTY FOX MOT

Declaration - DECLARATION DECLARATION OF MARIA DE JESUS SOLIS IN SUPPORT OF DEFENDANTS SNOOTY FOX MOTOR INN AND PINE TREE INDUSTRIAL CORPORATIONS MOTION FOR SUMMARY JUDGMENT

6/6/2019: Declaration - DECLARATION DECLARATION OF MARIA DE JESUS SOLIS IN SUPPORT OF DEFENDANTS SNOOTY FOX MOTOR INN AND PINE TREE INDUSTRIAL CORPORATIONS MOTION FOR SUMMARY JUDGMENT

Declaration - DECLARATION DECLARATION OF LYNN RIVERA IN SUPPORT OF DEFENDANTS SNOOTY FOX MOTOR INN AND PINE TREE INDUSTRIAL CORPORATIONS MOTION FOR SUMMARY JUDGMENT

6/6/2019: Declaration - DECLARATION DECLARATION OF LYNN RIVERA IN SUPPORT OF DEFENDANTS SNOOTY FOX MOTOR INN AND PINE TREE INDUSTRIAL CORPORATIONS MOTION FOR SUMMARY JUDGMENT

Minute Order - MINUTE ORDER (INFORMAL DISCOVERY CONFERENCE (IDC))

7/18/2019: Minute Order - MINUTE ORDER (INFORMAL DISCOVERY CONFERENCE (IDC))

Answer

3/21/2019: Answer

Proof of Service by Substituted Service

3/29/2019: Proof of Service by Substituted Service

Summons - Summons on Cross Complaint

1/28/2019: Summons - Summons on Cross Complaint

Stipulation - No Order - Stipulation - No Order and Protective Order

1/4/2019: Stipulation - No Order - Stipulation - No Order and Protective Order

Minute Order - Minute Order (Hearing on Motion for Protective Order as to Confidential Inf...)

12/6/2018: Minute Order - Minute Order (Hearing on Motion for Protective Order as to Confidential Inf...)

Declaration - Declaration In support of Defendant Uber Technologies, Inc's and Raiser, LLC's Motion for protective order as to confidential information

11/9/2018: Declaration - Declaration In support of Defendant Uber Technologies, Inc's and Raiser, LLC's Motion for protective order as to confidential information

Proof of Personal Service

10/29/2018: Proof of Personal Service

64 More Documents Available

 

Docket Entries

  • 03/21/2022
  • Hearing03/21/2022 at 08:30 AM in Department 31 at 312 North Spring Street, Los Angeles, CA 90012; Jury Trial

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  • 03/07/2022
  • Hearing03/07/2022 at 10:00 AM in Department 31 at 312 North Spring Street, Los Angeles, CA 90012; Final Status Conference

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  • 03/23/2021
  • Hearing03/23/2021 at 08:30 AM in Department 31 at 312 North Spring Street, Los Angeles, CA 90012; Order to Show Cause Re: Dismissal

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  • 09/16/2020
  • Docketat 10:30 AM in Department 31, Thomas D. Long, Presiding; Trial Setting Conference - Held

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  • 09/16/2020
  • Docketat 10:00 AM in Department 31, Thomas D. Long, Presiding; Final Status Conference - Not Held - Advanced and Vacated

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  • 09/16/2020
  • DocketMinute Order ( (TRIAL SETTING CONFERENCE)); Filed by Clerk

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  • 08/26/2020
  • Docketat 10:20 AM in Department 31, Thomas D. Long, Presiding; Court Order

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  • 08/26/2020
  • DocketMinute Order ( (Court Order Re: Rescheduling of Hearings due to Covid-19;)); Filed by Clerk

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  • 08/26/2020
  • DocketCertificate of Mailing for ((Court Order Re: Rescheduling of Hearings due to Covid-19;) of 08/26/2020); Filed by Clerk

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  • 08/24/2020
  • DocketCertificate of Mailing for ([Stipulation and Order to Continue Trial, Notice of Rejection of Electronic Filing]); Filed by Clerk

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91 More Docket Entries
  • 09/12/2018
  • DocketDEFENDANT UBER TECHNOLOGIES, INC.'S ANSWER TO PLAINTIFF'S COMPLAINT

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  • 09/12/2018
  • DocketAnswer; Filed by Rasier LLC (Defendant)

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  • 08/08/2018
  • DocketDeclaration (of Yousaf M. Jafri Re: Inability to Comply with Meet and Confer Requirements); Filed by Rasier LLC (Defendant)

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  • 08/08/2018
  • DocketDECLARATION OF YOUSALF M. JAFRI RE: INABILTY TO COMPLY WITH MEET AND CONFER REQUIREMENT

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  • 07/13/2018
  • DocketDEFENDANTS SNOOTY FOX MOTOR INN AND PINE INDUSTRIAL CORPORATIONS NOTICE OF ASSOCIATION OF COUNSEL

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  • 06/28/2018
  • DocketDEFENDANTS SNOOTY FOX MOTOR INN AND PINE TREE INDUSTRIAL CORPORATION'S ANSWER TO COMPLAINT

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  • 06/28/2018
  • DocketAnswer; Filed by SNOOTY FOX MOTOR INN AND (Defendant)

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  • 03/23/2018
  • DocketCOMPLAINT-PERS. INJURY, PROP DAMAGE, WRONGFUL DEATH (2 PAGES)

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  • 03/23/2018
  • DocketComplaint; Filed by Alexandra Brunell (Plaintiff)

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  • 03/23/2018
  • DocketSUMMONS

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Tentative Rulings

Case Number: BC699297    Hearing Date: February 13, 2020    Dept: 31

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT

ALEXANDRA BRUNELL,

Plaintiff,

vs.

UBER TECHNOLOGIES, INC., et al.

Defendants.

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CASE NO: BC699297

[TENTATIVE] ORDER GRANTING MOTION TO COMPEL DEPOSITION OF PMK; GRANTING MOTION TO COMPEL DEPOSITION OF TRACEY BREEDEN; DENYING MOTION TO COMPEL PRODUCTION OF DOCUMENTS

Dept. 31

1:30 P.M.

February 13, 2020

Plaintiff served a Notice of Deposition on Defendant Uber Technologies, Inc. (“Uber”) on October 3, 2019. The Notice indicated an intent to depose Tracey Breeden – Uber’s Head of Women's Safety & Gender-based Violence Programs. It was noticed for October 21, 2019. Plaintiff received Defendant’s objection on October 17, 2019. Defendant’s objections include: 1) Ms. Breeden is an apex employee, 2) Plaintiff noticed the deposition for a date prior to an already scheduled deposition of Plaintiff without the agreement of opposing counsel, and 3) a variety of boilerplate and procedural grounds.

Plaintiff served a second Notice of Deposition on Uber on October 29, 2019. The Notice indicated an intent to depose Uber’s PMK concerning 17 issues. It was noticed for November 13, 2019. Plaintiff received Defendant’s objection on November 8, 2019. Defendant objected on the ground that Plaintiff unilaterally noticed the deposition without attempting to meet and confer; that it is vague, ambiguous, irrelevant, overbroad, as well as a variety of boilerplate and procedural grounds.

This motion therefore follows.

The motion to compel deposition is granted to both Uber’s PMK and Tracey Breeden.  CCP §2025.450(a). The Court finds it is reasonable to depose Tracey Breeden in connection with the Plaintiff’s cause of action. Uber did not provide sufficient evidence to support its contention that deponent Tracey Breeden is an apex employee besides the fact that her title is “Head of Women's Safety & Gender-based Violence Programs.” (See Liberty Mut. Ins. Co. v. Superior Court (1992) 10 Cal. App. 4th 1282.)  Plaintiff’s Counsel and Uber’s Counsel are ordered to work together to schedule a time, date, and location for Uber’s PMK and Tracey Breeden’s deposition(s).  The deposition(s) must go forward within twenty days.  If Counsel are unable to resolve this issue, Plaintiff’s Counsel may set the deposition on Plaintiff’s Counsel’s terms with ten days’ notice to Uber’s Counsel (additional notice per Code if notice is by other than personal service). 

The Court notes that the notice of deposition includes a demand for production of documents. The moving papers fail to show good cause for production of the documents sought, as required by §2025.450(b)(1). The Court therefore declines to enter an order compelling Uber to produce documents, but urges the parties to work together to resolve any issues concerning documents without court intervention.

Parties who intend to submit on this tentative must send an email to the court at SSCDEPT31@lacourt.org indicating intention to submit on the tentative as directed by the instructions provided on the court website at www.lacourt.org.  If the department does not receive an email indicating the parties are submitting on the tentative and there are no appearances at the hearing, the motion may be placed off calendar.

Case Number: BC699297    Hearing Date: January 17, 2020    Dept: 31

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT

ALEXANDER BRUNELL,

Plaintiff(s),

vs.

UBER TECHNOLOGIES, INC., et al.,

Defendant(s).

)

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)

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Case No.: BC699297

[TENTATIVE] ORDER CONTINUING HEARING ON MOTION TO COMPEL DEPOSITIONS

Dept. 31

1:30 p.m.

January 17, 2020

1. Background Facts

Plaintiff, Alexandra Brunell filed this action against Defendants, Uber Technologies, Inc., Rasier, LLC, Rasier-CA, LLC, Rasier-DC, LLC, Rasier-PA, LLC, Matthew Victor Wong, Snooty Fox Motor Inn, and Pine Tree Industrial Corporation for damages arising out of a sexual assault. Plaintiff alleges Defendant, Wong, while working for Uber, took her to the Snooty Fox and raped and sodomized her at the motel.

The Court previously granted summary judgment in favor of Snooty Fox/Pine Tree, leaving Wong and the Uber entities as the remaining defendants in the action.

2. Motions to Compel

a. Relief Sought

Plaintiff seeks to compel the depositions of (a) Tracey Breeden, Uber’s Head of Women’s Safety & Gender-Based Violence Programs, and (b) Uber’s PMK concerning seventeen different areas, all of which concern gender and safety-based programs at Uber.

b. Objections

Uber objected to the Breeden Notice of Depo on the ground that Breeden is an apex officer of Uber, as well as on a variety of procedural grounds. Uber objected to the PMK deposition notice on the ground that it is vague, ambiguous, irrelevant, overbroad, and on a variety of procedural grounds.

c. Continuance of Hearing

The Court finds Uber will definitely need to produce someone to appear and testify concerning issues relating to gender-based violence by Uber drivers. It appears the parties did not adequately meet and confer prior to filing this motion, and the Court is hopeful the parties can resolve issues relating to the deposition without court intervention. The Court notes that Uber has offered to produce a PMK on these issues on January 30 or January 31, but that the parties need to meet and confer concerning the exact scope of that deposition.

The Court also notes that Uber argues Plaintiff was required to schedule an IDC prior to the hearing on this motion. An IDC is only required by the personal injury courts in connection with motions to compel further responses; it is not required in connection with motions to compel deposition over objection. The Court will therefore not require an IDC prior to the continued hearing on this motion.

Trial in this matter is scheduled for 3/27/20. The Court continues the hearing on this motion to Thursday, 2/13/20 at 1:30 p.m. in Department 3 of the Spring Street Courthouse. The Court is hopeful the parties can resolve their issues relating to the PMK deposition and the deposition will go forward in late January. If the parties are unable to resolve their issues, they must file briefs concerning any outstanding issues on or before Thursday, 2/06/20 with courtesy copies delivered directly to the department.

Plaintiff is ordered to give notice.

Parties who intend to submit on this tentative must send an email to the court at sscdept3@lacourt.org indicating intention to submit on the tentative as directed by the instructions provided on the court website at www.lacourt.org.  If the department does not receive an email indicating the parties are submitting on the tentative and there are no appearances at the hearing, the motion may be placed off calendar. If a party submits on the tentative, the party’s email must include the case number and must identify the party submitting on the tentative.

Case Number: BC699297    Hearing Date: January 02, 2020    Dept: 3

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT

ALEXANDER BRUNELL,

Plaintiff(s),

vs.

UBER TECHNOLOGIES, INC., et al.,

Defendant(s).

)

)

)

)

)

)

)

)

)

)

)

Case No.: BC699297

[TENTATIVE] ORDER CONTINUING HEARING ON MOTION TO COMPEL DEPOSITIONS

Dept. 3

1:30 p.m.

January 2, 2020

1. Background Facts

Plaintiff, Alexandra Brunell filed this action against Defendants, Uber Technologies, Inc., Rasier, LLC, Rasier-CA, LLC, Rasier-DC, LLC, Rasier-PA, LLC, Matthew Victor Wong, Snooty Fox Motor Inn, and Pine Tree Industrial Corporation for damages arising out of a sexual assault. Plaintiff alleges Defendant, Wong, while working for Uber, took her to the Snooty Fox and raped and sodomized her at the motel.

The Court previously granted summary judgment in favor of Snooty Fox/Pine Tree, leaving Wong and the Uber entities as the remaining defendants in the action.

2. Motions to Compel

a. Relief Sought

Plaintiff seeks to compel the depositions of (a) Tracey Breeden, Uber’s Head of Women’s Safety & Gender-Based Violence Programs, and (b) Uber’s PMK concerning seventeen different areas, all of which concern gender and safety-based programs at Uber.

b. Objections

Uber objected to the Breeden Notice of Depo on the ground that Breeden is an apex officer of Uber, as well as on a variety of procedural grounds. Uber objected to the PMK deposition notice on the ground that it is vague, ambiguous, irrelevant, overbroad, and on a variety of procedural grounds.

c. Continuance of Hearing

The Court finds Uber will definitely need to produce someone to appear and testify concerning issues relating to gender-based violence by Uber drivers. It appears the parties did not adequately meet and confer prior to filing this motion, and the Court is hopeful the parties can resolve issues relating to the deposition without court intervention. The Court notes that Uber has offered to produce a PMK on these issues on January 30 or January 31, but that the parties need to meet and confer concerning the exact scope of that deposition.

The Court also notes that Uber argues Plaintiff was required to schedule an IDC prior to the hearing on this motion. An IDC is only required by the personal injury courts in connection with motions to compel further responses; it is not required in connection with motions to compel deposition over objection. The Court will therefore not require an IDC prior to the continued hearing on this motion.

Trial in this matter is scheduled for 3/27/20. The Court continues the hearing on this motion to Thursday, 2/13/20 at 1:30 p.m. in Department 3 of the Spring Street Courthouse. The Court is hopeful the parties can resolve their issues relating to the PMK deposition and the deposition will go forward in late January. If the parties are unable to resolve their issues, they must file briefs concerning any outstanding issues on or before Thursday, 2/06/20 with courtesy copies delivered directly to the department.

Plaintiff is ordered to give notice.

Parties who intend to submit on this tentative must send an email to the court at sscdept3@lacourt.org indicating intention to submit on the tentative as directed by the instructions provided on the court website at www.lacourt.org.  If the department does not receive an email indicating the parties are submitting on the tentative and there are no appearances at the hearing, the motion may be placed off calendar. If a party submits on the tentative, the party’s email must include the case number and must identify the party submitting on the tentative.