Donald Jones v. Nicolae Butoi

I. Background

This is a personal injury case. On November 8, 2018, Plaintiff, a California citizen, got into a motor vehicle accident with Defendant Butoi, who was a truck driver for Defendant Bunic. See Complaint, Dkt. # 1-3 (““Compl.), 10. Both Defendants are Minnesota citizens. See Declaration of Krsto Mijanovic, Dkt. # 14-1 (“Mijanovic Decl.”), 9. 6. Plaintiff alleges that he suffered several injuries as a result of the accident. See Compl. J] 15. On January 7, 2020, Plaintiff filed this case in Los Angeles Superior Court, bringing two separate causes of action for motor vehicle negligence. See generally id. He served Defendants with the complaint on January 9, 2020. See Mijanovic Decl. 4 3. In his prayer for relief, Plaintiff seeks the following: general damages, damages for hospital and medical care, damages for loss of earnings, costs of suit, and prejudgment interest. See Compl. § 22. Defendants propounded form and special interrogatories in January 2019. See Mijanovic Decl. § 8. On March 12, 2020, Defendants received Plaintiff's interrogatory responses and saw, for the first time, that Plaintiff sought approximately $91,111.12 in past…