Maria Ventura v. Dollar Tree Stores, Inc. et. al.

I. BACKGROUND

On April 23, 2023 at approximately 7:30 pm, Plaintiff was shopping at a Dollar Tree store in Los Angeles, California. (Mot. at 4). Plaintiff had paid for her items at cashier number two and, as she exited the store, she tripped over a hand basket on the floor. (Id.) She landed face first on her left arm and sustained several injuries. (Id.).

On August 12, 2024, before commencing the present action, Plaintiff provided a pre-litigation demand package to Dollar Tree Stores, Inc.’s third-party administrator for claims, Sedgewick Claims Management Services, Inc. (Id.). The pre-litigation demand package included a list of damages totaling $71,282.65. (Id., Ex. C at 5). Plaintiff later filed the Compliant in Los Angeles Superior Court on March 24, 2025, naming Dollar Tree Stores, Inc. and Does 1 through 25 as the defendants. (“Compl.,” Dkt. No. 11, Ex. A).

On June 2, 2025, Plaintiff served her initial discovery requests on Defendant Dollar Tree Stores, Inc. (Mot. at 4). In Defendant Dollar Tree Stores, Inc.’s responses, they identified “M. Jenkins” as the employee working at the cashier stand in the hours prior to the incident. (Id.). “M. Jenkins” was also the employee…