Tali Sigalus vs Martin K. P. Chiang, et al.

Case No. 19STCV24076. Defendant explains at the last hearing on the demurrer to the First Amended Complaint, prior counsel for Plaintiff notified the court that she could not continue to represent plaintiff Jackson, because she had been party to a lawsuit involving him and the exact same Triplex. Based on the prior action, Defendant contends Plaintiff admits that Plaintiff "discovered" the alleged wrong more than four years before he filed in the instant action. Specifically, the 2019 Action alleges Mr.

Jackson sued Mr. Jefferson and two of the entities for multiple counts of elder abuse, undue influence, fraud in the inducement, rescission of contracts, quiet title, declaratory relief, and professional negligence. Because the statute of limitations lock beings to run once the plaintiff had suspicion of wrongdoing, Defendant contends the financial elder abuse claim is time barred. (See Jolly v. Eli Lilly & Co. (1988) 44 Cal. 3d 1103, 1110 holding "[u]nder the discovery rule, the statute of limitations begins to run when the plaintiff suspects or should suspect that her injury was caused by wrongdoing, that someone has done something wrong to her.") The court notes the opposition is untimely.

Counsel states the court should consider the untimely opposition as counsel was busy concluding a trial in another case. The court declines to consider the untimely opposition. The opposition was filed two days before the hearing. Plaintiff is admonished to comply with the statutes, rules and procedures governing this litigation despite calendaring management issues. The court finds the May 2021 discovery date alleged in the Second Amended Complaint does not satisfy the specificity required by the demurrer standard. (See Doe v.

Roman Catholic Bishop of Sacramento (2010) 189 Cal.App.4th 1423, 1430 holding "[i]n assessing the sufficiency of the allegations of delayed discovery, the court places the burden on the plaintiff to 'show diligence'; 'conclusory allegations will not withstand demurrer.'") Currently, the 2019 complaint's allegations demonstrate that Jackson knew--or at minimum suspected with specificity--the following facts as of July 2019: that Jefferson had presented Jackson with a title document transferring 100% of the triplex to Jefferson's entity, when Jackson believed he was adding Jefferson only as a managerial partner (Sinclair Decl., Exh.

A, P.P.77-78); that Jefferson had taken out a $250,000 mortgage without Jackson's knowledge or consent (Sinclair Decl., Exh. A, P.80); and that the transaction involved deceptive title transfers and encumbrances affecting the triplex's ownership and equity (Sinclair Decl., Exh. A, P.P.100-101.) However, the current SAC alleges Jackson did not reasonably understand that defendants had structured transactions materially different from the refinance represented to him. (SAC P.36.) While the SAC sufficiently alleges the time and manner of discovery, it does not allege with specificity the inability to discover the conduct earlier despite diligence.

The SAC does not explain why a reasonable investigation in July 2019 would not have uncovered the factual basis for a claim against Robbins specifically. Plaintiff is given one more opportunity to allege facts to bring a claim against Defendant Robbins within the statute of limitations. Based on the foregoing, the demurrer is SUSTAINED WITH LEAVE TO AMEND. Case Number: 24STCV26351 Hearing Date: August 26, 2026 Dept: 529 TALI SIGALUS VS MARTIN K. P. CHIANG, ET AL.

DEFENDANT/CROSS-COMPLAINANT'S MOTION FOR ISSUE, EVIDENTIARY, AND MONETARY SANCTIONS Date of Hearing: August 26, 2026 Trial Date: March 29, 2027 Department: 529 Case No.: 24STCV26351 Moving Party: Defendant Martin Chiang Responding Party: No opposition BACKGROUND This is a wage and labor claim. On October 10, 2024, Plaintiff Tali Sigalus filed a complaint against Defendants Martin K. P. Chang and Mason Chang for various Labor Code violations as well as violation of Business and Professions Code and wrongful termination in violation of public policy.

On March 7, 2025, a cross-complaint was filed by Martin K.P. Chang against Tali Sigalus for elder financial abuse, intentional interference with contractual relations, intentional interference with prospective economic advantage, intentional misrepresentation, negligent misrepresentation, intentional infliction of emotional distress, negligent infliction of emotional distress, violation of Business and Professions Code section 17200, conversion, breach of employment contract, trespass to land, conversion and breach of fiduciary duty. [Tentative] Ruling Defendant/Cross-Complainant Martin Chiang's Motion for Issue, Evidentiary and Monetary Sanctions is GRANTED, in part.

DISCUSSION Defendant/Cross-Complainant Martin Chiang moves the court for issue, evidentiary, and monetary sanctions against Plaintiff/Cross-Defendant Tali Sigalus based on her failure to comply with the court's order dated October 15, 2025. Defendant contends Plaintiff had thirty days to provide further responses and documents that were responsive to Defendant Martin Chiang's Requests for Production of Documents Nos. 1-5, 8, and 38-39. However, Plaintiff has not provided verified substantive responses to these requests.

Furthermore, Plaintiff has not provided all documents in her possession. . Where a party fails to obey an order compelling answers to discovery, "the court may make those orders that are just, including the imposition of an issue sanction, an evidence sanction, or a terminating sanction." (CCP Sec.Sec. 2030.290(c), 2023.010(c); R.S. Creative, Inc. v. Creative Cotton, Ltd. (1999) 75 Cal.App.4th 486, 495.) The Court may impose a terminating sanction against anyone engaging in conduct that is a misuse of the discovery process. (CCPSec. 2023.030(d).)

Misuse of the discovery process includes failure to respond to an authorized method of discovery or disobeying a court order to provide discovery. (CCP Sec. 2023.010(d), (g).) A terminating sanction may be imposed by an order dismissing

part or all of the action. (CCP Sec. 2023.030(d)(3).) Defendant/Cross-Complainant Martin Chiang contends this court granted Defendant Martin Chiang's Motion to Compel Further Responses to Requests for Production of Documents (Set One) on October 15, 2025. Plaintiff, however, did not comply with the court order and once it became clear that Plaintiff did not intend to comply with the Court's order by the thirty-day deadline, Defendant engaged in extensive meet and confer efforts. After nine months of discovery disputes, repeated meet-and-confer efforts, and prolonged attempts to obtain the documents, Plaintiff has not still fully produced all the documents.

The court denies the motion for issue and evidence sanctions. As noted by Defendant Chiang, "[t]he trial court has broad discretion in selecting discovery sanctions, subject to reversal only for abuse. The trial court should consider both the conduct being sanctioned and its effect on the party seeking discovery and, in choosing a sanction, should 'attempt [] to tailor the sanction to the harm caused by the withheld discovery.'" (Doppes v. Bentley Motors, Inc., (2009) 174 Cal.App.4th 967, 992.)

At this time, Defendant has not shown that issue sanctions or evidentiary sanctions are warranted or that a lesser sanction would fail to curb the abuse. As for the request for monetary sanctions, Defendant Chiang requests $6,409.00 for bringing this motion. The court grants the request for monetary sanctions in the reduced amount of $4,295.00, payable within 30 days. Based on the foregoing, Defendant/Cross-Complainant Martin Chiang's Motion for Issue, Evidentiary and Monetary Sanctions is GRANTED, in part.

Case Number: 25STCV12409 Hearing Date: August 26, 2026 Dept: 529 ALVARO AGUILERA VAZQUEZ VS GENERAL MOTORS, LLC PLAINTIFF'S MOTION TO STAY PROCEEDINGS Date of Hearing: August 26, 2026 Trial Date: May 11, 2027 Department: 529 Case No.: 25STCV12409 Moving Party: Plaintiff Alvaro Aguilera Vazquez Responding Party: Defendant General Motors LLC BACKGROUND This is a lemon law action. On April 29, 2025, Plaintiff Alvaro Aguilera Vazquez filed a complaint against Defendant General Motors, LLC for various violations of the Song-Beverly Consumer Warranty Act as well as Fraudulent Inducement - Concealment.

On October 10, 2025, Plaintiff filed a First Amended Complaint. Plaintiff filed a Second Amended Complaint on