This case was last updated from Los Angeles County Superior Courts on 08/10/2021 at 19:48:34 (UTC).

SARA KHOOBAN VS PATRICE BRADFORD ET AL

Case Summary

On 03/02/2018 SARA KHOOBAN filed a Personal Injury - Motor Vehicle lawsuit against PATRICE BRADFORD. This case was filed in Los Angeles County Superior Courts, Stanley Mosk Courthouse located in Los Angeles, California. The Judges overseeing this case are JON R. TAKASUGI, THOMAS D. LONG and HOLLY E. KENDIG. The case status is Pending - Other Pending.

Case Details Parties Documents Dockets

 

Case Details

  • Case Number:

    ****6607

  • Filing Date:

    03/02/2018

  • Case Status:

    Pending - Other Pending

  • Case Type:

    Personal Injury - Motor Vehicle

  • Courthouse:

    Stanley Mosk Courthouse

  • County, State:

    Los Angeles, California

Judge Details

Presiding Judges

JON R. TAKASUGI

THOMAS D. LONG

HOLLY E. KENDIG

 

Party Details

Petitioner and Plaintiff

KHOOBAN SARA

Respondents and Defendants

BRADFORD MICHAEL

BRADFORD PATRICE

DOES 1 TO 50 INCLUSIVE

BRADFORD ALEXANDRA

Attorney/Law Firm Details

Petitioner and Plaintiff Attorneys

KHORSHIDI OMID ESQ.

KHORSHIDI OMID

Defendant Attorneys

MUENCH RICHARD A.

MUENCH RICHARD ARTHUR

 

Court Documents

Ex Parte Application - EX PARTE APPLICATION TO CONTINUE TRIAL AND EXPERT DEPOSITIONS

2/3/2020: Ex Parte Application - EX PARTE APPLICATION TO CONTINUE TRIAL AND EXPERT DEPOSITIONS

Minute Order - MINUTE ORDER (EX-PARTE PROCEEDINGS PLAINTIFF SARA KHOOBAN'S EX PARTE APPLIC...)

3/16/2020: Minute Order - MINUTE ORDER (EX-PARTE PROCEEDINGS PLAINTIFF SARA KHOOBAN'S EX PARTE APPLIC...)

Notice of Posting of Jury Fees

3/26/2020: Notice of Posting of Jury Fees

Motion for Sanctions

4/8/2020: Motion for Sanctions

Notice of Joinder - NOTICE OF JOINDER (NAME EXTENSION) NOTICE OF JOINDER BY NON PARTY CHARLES ROSEN, M.D. TO OPPOSITION TO PLAINTIFF'S MOTION FOR SANCTIONS; MEMORANDUM OF POINTS AND AUTHORITIES; DECLA

4/23/2020: Notice of Joinder - NOTICE OF JOINDER (NAME EXTENSION) NOTICE OF JOINDER BY NON PARTY CHARLES ROSEN, M.D. TO OPPOSITION TO PLAINTIFF'S MOTION FOR SANCTIONS; MEMORANDUM OF POINTS AND AUTHORITIES; DECLA

Opposition - OPPOSITION OF PLAINTIFFS MOTION DEFENDANTS RETAINED EXPERT DR. DEFENDANTS COUNSEL OF RECORD, AND DEFENDANT ALEXANDRA BRADFORD, AMOUNT OF $7,107.50 AGAINSTFOR MONETARY SANCTIONS IN THE

4/30/2020: Opposition - OPPOSITION OF PLAINTIFFS MOTION DEFENDANTS RETAINED EXPERT DR. DEFENDANTS COUNSEL OF RECORD, AND DEFENDANT ALEXANDRA BRADFORD, AMOUNT OF $7,107.50 AGAINSTFOR MONETARY SANCTIONS IN THE

Minute Order - MINUTE ORDER (TRIAL SETTING CONFERENCE; HEARING ON MOTION FOR ORDER MOTION ...)

6/26/2020: Minute Order - MINUTE ORDER (TRIAL SETTING CONFERENCE; HEARING ON MOTION FOR ORDER MOTION ...)

Motion in Limine - MOTION IN LIMINE #2

1/21/2021: Motion in Limine - MOTION IN LIMINE #2

Certificate of Mailing for - CERTIFICATE OF MAILING FOR (FINAL STATUS CONFERENCE) OF 05/20/2021

5/20/2021: Certificate of Mailing for - CERTIFICATE OF MAILING FOR (FINAL STATUS CONFERENCE) OF 05/20/2021

[Proposed Order] and Stipulation to Continue Trial, FSC (and Related Motion/Discovery Dates) Person - [PROPOSED ORDER] AND STIPULATION TO CONTINUE TRIAL, FSC (AND RELATED MOTION/DISCOVERY DATES) PERSO

8/6/2019: [Proposed Order] and Stipulation to Continue Trial, FSC (and Related Motion/Discovery Dates) Person - [PROPOSED ORDER] AND STIPULATION TO CONTINUE TRIAL, FSC (AND RELATED MOTION/DISCOVERY DATES) PERSO

Opposition - OPPOSITION OPPOSITION TO DEF'S MOTION TO COMPEL DME

7/22/2019: Opposition - OPPOSITION OPPOSITION TO DEF'S MOTION TO COMPEL DME

Motion to Compel - MOTION TO COMPEL PLAINTIFF SARA KHOOBAN'S ATTENDANCE AT AN LNDEPENDANT MEDICAL EXAMINATION ON AUGUST 15, 2019

7/2/2019: Motion to Compel - MOTION TO COMPEL PLAINTIFF SARA KHOOBAN'S ATTENDANCE AT AN LNDEPENDANT MEDICAL EXAMINATION ON AUGUST 15, 2019

Request for Dismissal

12/26/2018: Request for Dismissal

Order - ORDER BY THE COURT DENYING MOTION TO COMPEL DEPOSITION

3/4/2019: Order - ORDER BY THE COURT DENYING MOTION TO COMPEL DEPOSITION

Minute Order - Minute Order (Hearing on Motion to Compel Deposition of Alexandra Bradford)

3/4/2019: Minute Order - Minute Order (Hearing on Motion to Compel Deposition of Alexandra Bradford)

Notice - Notice NOTICE OF RULING RE PLAINTIFFS MOTION TO COMPEL DEPOSITION OF DEFENDANT ALEXANDRA BRADFORD

3/5/2019: Notice - Notice NOTICE OF RULING RE PLAINTIFFS MOTION TO COMPEL DEPOSITION OF DEFENDANT ALEXANDRA BRADFORD

Affidavit - Affidavit of Non-Service

8/21/2018: Affidavit - Affidavit of Non-Service

Summons -

3/2/2018: Summons -

56 More Documents Available

 

Docket Entries

  • 12/21/2021
  • Hearing12/21/2021 at 08:30 AM in Department 31 at 312 North Spring Street, Los Angeles, CA 90012; Non-Jury Trial

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  • 12/07/2021
  • Hearing12/07/2021 at 10:00 AM in Department 31 at 312 North Spring Street, Los Angeles, CA 90012; Final Status Conference

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  • 06/04/2021
  • Docketat 08:30 AM in Department 31, Thomas D. Long, Presiding; Final Status Conference - Held - Continued

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  • 06/04/2021
  • Docketat 08:30 AM in Department 31, Thomas D. Long, Presiding; Non-Jury Trial - Held - Continued

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  • 06/04/2021
  • DocketOrder and Stipulation to Continue Trial, FSC (and Related Motion/Discovery Dates) Personal Injury Courts Only (Central District); Filed by Alexandra Bradford (Defendant)

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  • 06/04/2021
  • DocketMinute Order ( (COURT TRIAL FINAL STATUS CONFERENCE)); Filed by Clerk

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  • 05/20/2021
  • Docketat 10:00 AM in Department 31, Thomas D. Long, Presiding; Final Status Conference - Not Held - Continued - Court's Motion

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  • 05/20/2021
  • Docketat 08:30 AM in Department 31, Thomas D. Long, Presiding; Final Status Conference - Not Held - Clerical Error

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  • 05/20/2021
  • DocketNotice of Ruling (Re Final Status Conference); Filed by Sara Khooban (Plaintiff)

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  • 05/20/2021
  • DocketMinute Order ( (Final Status Conference)); Filed by Clerk

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83 More Docket Entries
  • 09/11/2018
  • DocketProof of Service by Substituted Service

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  • 09/06/2018
  • DocketReceipt; Filed by Patrice Bradford (Defendant)

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  • 09/06/2018
  • DocketDEFENDANTS PATRICE BRADFORDS ANSWER TO PLAINTIFFS COMPLAINT

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  • 09/06/2018
  • DocketDemand for Jury Trial; Filed by Patrice Bradford (Defendant)

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  • 09/06/2018
  • DocketAnswer; Filed by Patrice Bradford (Defendant)

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  • 08/21/2018
  • DocketDeclaration re: Due Diligence; Filed by Sara Khooban (Plaintiff)

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  • 08/21/2018
  • DocketAffidavit Affidavit of Non-Service

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  • 03/02/2018
  • DocketComplaint; Filed by Sara Khooban (Plaintiff)

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  • 03/02/2018
  • DocketSummons; Filed by Sara Khooban (Plaintiff)

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  • 03/02/2018
  • DocketComplaint

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Tentative Rulings

Case Number: BC696607    Hearing Date: June 26, 2020    Dept: 31

1

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT

SARA KHOOBAN,

Plaintiff(s),

vs.

PATRICE BRADFORD, ET AL.,

Defendant(s).

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CASE NO: BC696607

[TENTATIVE] ORDER DENYING MOTION FOR SANCTIONS

Dept. 31

8:30 a.m.

June 26, 2020

The basic facts relating to this motion are undisputed. Plaintiff noticed the deposition of Defendant’s expert. At the commencement of the deposition, Plaintiff tendered one hour of deposition fees. After one hour, the deposition was not complete; in fact, Plaintiff’s attorney indicated he had not even begun to depose the expert concerning his opinions. Defendant demanded payment for an additional hour of deposition time, and Plaintiff refused, saying payment would be made per Code. The attorneys were unable to resolve the issue, and the deposition was suspended.

The parties continued to meet and confer; while the efforts were ongoing, Plaintiff filed an ex parte application to compel the completion of the deposition. Defendant did not file written opposition to the application, but did appear at the hearing. The Court granted the application, and ordered Plaintiff to provide advance checks for the first two hours prior to the deposition, and to pay any balance within five days of receipt of an invoice. The Court denied any request for ex parte sanctions, but permitted a motion for such relief to go forward by way of noticed motion.

At this time, Plaintiff moves for sanctions based on Defendant’s refusal to permit her expert, Dr. Rosen, to be deposed for more than one hour at his original deposition. Plaintiff moves for sanctions pursuant to CCP §§2025.450(g)(1), 2034.250(d), and 2023.030(a).

§2034.250(d) applies to motions for a protective order. There is no such motion at issue in this case, and therefore this section cannot provide a basis for sanctions.

§§2025.450(g)(1) and 2023.030(a) both provide for sanctions unless the opposing party acted with good cause or substantial justification. The Court finds Defendant and Dr. Rosen did so. Plaintiff appeared and only tendered payment for one hour of deposition testimony. §2034.450(a) requires the deposing party to tender fees based on the anticipated length of deposition. Plaintiff did not reasonably anticipate the deposition would only take one hour. Indeed, the ex parte order granting the request to compel the second session of deposition required Plaintiff to advance two additional hours of fees, for a total of three hours of advance fees. It was patently unreasonable for Plaintiff to only advance one hour of fees, and therefore Defendant and Dr. Rosen acted with good faith and substantial justification in refusing to go forward with additional deposition without the payment of reasonable anticipated fees.

The motion for sanctions is denied. Plaintiff is ordered to give notice.

 

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. 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.

Dated this 26th day of June, 2020

Hon. Thomas D. Long

Judge of the Superior Court

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