Irene Gonzalez v. Haier US Appliance Solutions, Inc.

BACKGROUND

I. Factual Background1 On or about January 28, 2021, Plaintiff Irene Gonzalez (“Gonzalez”) was on premises owned, operated, and/or controlled by Defendant Haier US Appliance Solutions, Inc. d/b/a GE Appliances (“GEA”). Compl. ¶¶ 8, 10. Gonzalez was struck by a “dangerous and defective” shipping container, which caused Gonzalez serious and permanent injuries. Id. ¶ 10. Gonzalez’s injuries and damages are a direct result of the actions of GEA’s employees and/or agents, and GEA failed to provide the safety functions they were obligated to in order to “protect all persons” on their property. Id. ¶¶ 7, 9–13. II. Procedural History On January 23, 2023, Plaintiff Irene Gonzalez (“Gonzalez”) filed an Unverified Form Complaint against Defendant Haier US Appliance Solutions, Inc. d/b/a GE Appliances (“GEA”) in the Superior Court of the State of California for the County of Los Angeles. ECF No.1 (“Notice of Removal”).2 Gonzalez raised five causes of action: (1) premises liability; (2) negligent hiring/retention; (3) negligent supervision; (4) gross negligence/reckless misconduct/violations of …