Joana Gallegos v. Costco Wholesale Corporation

I.

BACKGROUND

Plaintiff asserts that she suffered injuries when she slipped and fell at a store owned and operated by Defendant Costco Wholesale Corporation (“Costco”) in August 2018. On October 23, 2019, Plaintiff filed a Complaint in Los Angeles County Superior Court against Defendants Costco and Russell Lee stating claims for general negligence and premises liability. Notice of Removal, Ex. A (“Compl.”) [Doc. # 1–1]. According to Plaintiff, each Defendant negligently owned, maintained, managed, and operated the store premises where she slipped and had notice of grapes on the floor of the store, leading to dangerous conditions. Id. at 7. Plaintiff claims that, as a result of her injuries, she incurred hospital and medical expenses, wage loss, general damages, and emotional distress. Id. at 6.

In late January 2020, Plaintiff’s initial counsel told Costco via telephone that he was unsure of Plaintiff’s damages amount, Plaintiff would need back surgery, and medical expenses would be part of her damages. MTR, Saleh Decl. at ¶ 3 [Doc. # 12]. On March 23, 2020, Plaintiff responded to Defendants’ discovery requests and provided a statement of damages exceeding $20…