Judge: Armen Tamzarian, Case: 20STCV13190, Date: 2022-12-16 Tentative Ruling

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Case Number: 20STCV13190    Hearing Date: December 16, 2022    Dept: 52

Defendant R&H Automotive Group, Inc.’s Motion for Leave to File Cross-Complaint

Defendant R&H Automotive Group, Inc. (R&H) moves for leave to file a cross-complaint against plaintiff American Honda Finance Corporation.

Evidentiary Objections

            Defendant R&H makes one objection to the declaration of Bryan King Sheldon in support of plaintiff’s opposition.  The objection is overruled.

Leave to File Cross-Complaint

R&H’s proposed cross-complaint would allege compulsory-crossclaims against plaintiff American Honda Financing Corporation.  When a party fails to timely bring compulsory crossclaims, “whether through oversight, inadvertence, mistake, neglect, or other cause,” the court may grant leave to file a cross-complaint “at any time during the course of the action” so long as the moving party “acted in good faith.”  (CCP § 426.50.)  This provision is “liberally construed to avoid forfeiture of causes of action.”  (Ibid.) 

Denying leave to file a compulsory cross-complaint requires “bad faith of the moving party.”  (Silver Organizations Ltd. v. Frank (1990) 217 Cal.App.3d 94, 99; accord CCP § 426.50.)  “Bad faith” implies “ ‘actual or constructive fraud, or a design to mislead or deceive another, or a neglect or refusal to fulfill some duty or some contractual obligation, not prompted by an honest mistake ..., but by some interested or sinister motive[,] ... not simply bad judgment or negligence, but rather ... the conscious doing of a wrong because of dishonest purpose or moral obliquity; ... it contemplates a state of mind affirmatively operating with furtive design or ill will.’ ”  (Id. at p. 100.)  Finding bad faith requires “substantial evidence.”  (Ibid.)

Though R&H delayed over two years before filing this motion, the court finds insufficient evidence of bad faith.  The evidence falls short of showing R&H has engaged in “unusually reprehensible” efforts to delay the litigation.  (Foot’s Transfer & Storage Co. v. Superior Court (1980) 114 Cal.App.3d 897, 903.)  Much of the delay can be attributed to R&H’s suspension by the Franchise Tax Board.  While suspended, R&H could not move for leave to file a cross-complaint. 

Conditions

            Plaintiff argues that if the court grants this motion, defendant R&H should be required to post an undertaking of $250,000.  Courts may grant leave to file a cross-complaint “upon such terms as may be just to the parties.”  (CCP § 426.50.)  Plaintiff seeks to apply the standard for requiring a plaintiff (or cross-complainant) who resides out of state to post an undertaking under Code of Civil Procedure section 1030.  Plaintiff provides no authority that a court can impose such a condition for granting a motion to file an untimely cross-complaint with compulsory crossclaims.  That condition would be excessive in this case.  The court exercises its discretion not to impose any conditions on defendant R&H.

Disposition

            Defendant R&H Automotive Group, Inc.’s motion for leave to file a cross-complaint is granted.

            Defendant R&H Automotive Group, Inc. is ordered to file its cross-complaint forthwith. 

 

Defendant R&H Automotive Group, Inc.’s Motion to Reopen Discovery

Defendant R&H Automotive Group, Inc. moves to reopen discovery under Code of Civil Procedure section 2024.050.  Section 2024.050, subdivision (b) provides:

In exercising its discretion to grant or deny this motion, the court shall take into consideration any matter relevant to the leave requested, including, but not limited to, the following:

(1) The necessity and the reasons for the discovery.

(2) The diligence or lack of diligence of the party seeking the discovery or the hearing of a discovery motion, and the reasons that the discovery was not completed or that the discovery motion was not heard earlier.

(3) Any likelihood that permitting the discovery or hearing the discovery motion will prevent the case from going to trial on the date set, or otherwise interfere with the trial calendar, or result in prejudice to any other party.

(4) The length of time that has elapsed between any date previously set, and the date presently set, for the trial of the action.

Upon weighing all the relevant matters, the court finds good cause to partially reopen discovery. 

First, defendant makes only a minimal showing of the necessity and reasons for reopening discovery.  R&H states it “seeks the deposition and documents of plaintiff and several of its employees because defendant it needs to prepare for trial and understand the facts supporting the allegations contained in the operative complaint as well as obtain evidence related to its cross-complaint.”  This vague explanation applies to any discovery.       

Moreover, as plaintiff argues, co-defendants Hooman Nissani and Babbak Sarraf have the same interest in this action as R&H.  They could and should have done nearly all the discovery R&H needs, except discovery on the cross-complaint.  R&H argues the individual co-defendants are not similarly situated because R&H operated the Acura dealership and was the obligor on plaintiff’s loans.  R&H gives no reason why that matters.  R&H, Nissani, and Sarraf are defending against the same claims.  Most of the evidence on both sides will be the same for these defendants.

Second, defendant shows little diligence and gives no good excuse for not completing discovery.  Defendant relies on the fact that it was suspended by the Franchise Tax Board from September 2021 to October 2022.  But defendants answered on June 26, 2020.  R&H could and should have filed its cross-complaint at that time, as required under Code of Civil Procedure section 428.50(a).  R&H had over a year to conduct discovery between its answer and its suspension.  It did little discovery.  R&H does not have a satisfactory explanation for not doing more discovery before its suspension.

Third, R&H states it can complete its discovery before the trial on February 8, 2023. 

Fourth, the case was initially set for trial on May 5, 2021.  The trial has been continued several times, totaling nearly two years. 

After considering all relevant factors, the court finds it appropriate to partially reopen discovery—with significant limits. 

Disposition

Defendant R&H Automotive Group, Inc.’s motion to reopen discovery is hereby granted in part. 

The court hereby reopens discovery for defendant R&H Automotive Group, Inc. only—not any other defendants—with the following limits: R&H Automotive Group may take up to four depositions.  Each notice of deposition may include a maximum of 15 document requests.  Any deposition of plaintiff’s person(s) most knowledgeable shall be limited to a maximum of 12 matters of examination.  R&H Automotive Group may propound no more than 35 requests for production, 35 requests for admission, and 35 special interrogatories. 

As for plaintiff American Honda Finance Corporation, the court hereby reopens discovery without any additional limits beyond those under the Civil Discovery Act.

Fact discovery must be completed by January 20, 2023.  Any discovery motions shall be heard no later than January 30, 2023.