Judge: Armen Tamzarian, Case: 23STCV15682, Date: 2024-05-03 Tentative Ruling

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Case Number: 23STCV15682    Hearing Date: May 3, 2024    Dept: 52

Tentative Ruling:

Defendant Min Liu’s Motion to Quash Service of Summons

Defendant Min Liu moves to quash service of summons on him by plaintiff Jonathon A. Valdez.

Service of Process

            Liu contends plaintiff did not effect valid service of summons on him.  “[O]nce a defendant files a motion to quash the burden is on the plaintiff to prove by a preponderance of the evidence the validity of the service and the court’s jurisdiction over the defendant.”  (Bolkiah v. Superior Court (1999) 74 Cal.App.4th 984, 991.) 

Plaintiff meets this burden.  “[I]n deciding whether service was valid, the statutory provisions regarding service of process should be liberally construed to effectuate service and uphold the jurisdiction of the court if actual notice has been received by the defendant.”  (Gibble v. Car-Lene Research, Inc. (1998) 67 Cal.App.4th 295, 313.)  “ ‘Personal service usually contemplates actual delivery.  But the person on whom service is sought may not, by merely declining to take the document offered, deny the personal service on the ground of lack of delivery, where under the circumstances it would be obvious to a reasonable person that a personal service was being attempted.  In such a case the service may be made by merely depositing the process in some appropriate place where it would be most likely to come to the attention of the person being served.’ ”  (Crescendo Corp. v. Shelted, Inc. (1968) 267 Cal.App.2d 209, 212; accord In re Ball (1934) 2 Cal.App.2d 578, 579 [“when men are within easy speaking distance of each other and facts occur that would convince a reasonable man that personal service of a legal document is being attempted, service cannot be avoided by denying service and moving away without consenting to take the document in hand”].)

The declaration of process server David Wall shows adequate personal service where Liu tried to evade service.  Wall states, “When I stopped the Defendant and indicated that I was a process server with legal documents, he became irritable and insisted that he did not speak English.  Despite my efforts to explain my purpose, the Defendant refused to physically accept the documents and attempted to walk away.  I followed the Defendant and repeatedly advised that I would have to leave the documents at his feet if he did not accept service.”  (Wall Decl., ¶ 8.)  “At 1:12 p.m., the Defendant indicated that he wanted to return to the offices of West Coast Employment Lawyers and began walking north on South Hope Street.  I placed the documents at his feet and Defendant hastily returned to the office without collecting the documents.”  (Id., ¶ 9.)  “Shortly thereafter, I observed the Defendant exit the law office and make a ten-minute phone call outside.”  (Id., ¶ 10.)

Under the authority cited above, Liu could not avoid service by refusing to accept the documents and walking away.  Process server David Wall effected valid service of summons on Liu.  Liu’s reply does not respond to this argument.

Doe Amendment

            Liu also argues service of summons should be quashed because plaintiff improperly substituted Liu as a Doe defendant.  Code of Civil Procedure section 474 “allows a plaintiff in good faith to delay suing particular persons as named defendants until he has knowledge of sufficient facts to cause a reasonable person to believe liability is probable.”  (General Motors Corp. v. Superior Court (1996) 48 Cal.App.4th 580, 595.) 

A defendant may challenge the use of a Doe amendment via a motion to quash.  (A.N. v. County of Los Angeles (2009) 171 Cal.App.4th 1058, 1066 (A.N.).)  “[S]ection 474 includes an implicit requirement that a plaintiff may not ‘unreasonably delay’ his or her filing of a Doe amendment after learning a defendant’s identity.”  (Id. at pp. 1066-1067.)  “[A] defendant named in an action by a Doe amendment under section 474 may challenge the amendment by way of an evidence-based motion, which argues that the plaintiff ‘unreasonabl[y] delayed’ his or her filing of the challenged amendment.”  (Id. at p. 1067.)  “ ‘[U]nreasonable delay’ … includes a prejudice element, which requires a showing by the defendant that he or she would suffer prejudice from plaintiff’s delay in filing the Doe amendment.”  (Ibid.)

Liu fails to establish plaintiff unreasonably delayed filing the Doe amendment.  Defendant presents evidence plaintiff knew sufficient facts to determine “Tom Liu” may be liable for the causes of action alleged in plaintiff’s complaint.  (E.g., Yang Decl., Ex. C, response to form interrogatory No. 202.1.)  That is not the moving defendant’s name.  All the papers, including Liu’s sworn declaration, state his name is “Min Liu.”  The Doe amendment identifies defendant as “Min ‘Tom’ Liu.”  Liu presents no evidence plaintiff unreasonably delayed filing the Doe amendment after learning Liu’s true first name is Min, not Tom.

            Assuming Liu met his burden of showing plaintiff unreasonably delayed filing the Doe amendment, Liu shows no prejudice.  Generally, prejudice arises from the doctrine of relating back to the date of the initial complaint—which is the purpose of Code of Civil Procedure section 474.  (A.N., supra, 171 Cal.App.4th at pp. 1065-1066.)  When the new defendant is “added to the lawsuit as a defendant prior to the expiration of the statute of limitations,” “[t]he question of whether or not the amendment ‘related back’ to the date the complaint was filed was irrelevant.”  (Davis v. Marin (2000) 80 Cal.App.4th 380, 387.)  Where the plaintiff “could have filed an amended complaint naming [the new party] as a defendant, rather than an amendment to the complaint,” so “the analysis used under Code of Civil Procedure section 474, would have been irrelevant.”  (Ibid.; accord McClatchy v. Coblentz, Patch, Duffy & Bass, LLP (2016) 247 Cal.App.4th 368, 375.)

            Liu does not argue any prejudice arises from the doctrine of relating back.  The reasoning from Davis v. Marin applies equally here.  Plaintiff’s claims arise from alleged sexual harassment by Liu.  The complaint alleges plaintiff began working for defendant Ekko Material Handling Equipment Manufacturing Inc. in November 2022.  (Comp., ¶ 9.)  It further alleges, “In or around December 2022, Ekko’s owner, Harrison Liu … began bringing his brother Tom (Last Name Unknown) … to work with him at Ekko.”  (Id., ¶ 10.)  It alleges Liu engaged in inappropriate conduct beginning “[i]n or about February or March 2023.”  (Id., ¶ 12.)  Plaintiff filed an amendment to the complaint substituting Liu for Doe 2 on December 15, 2023.  Whether that amendment relates back to the date of the initial complaint, July 6, 2023, makes no difference for any statute of limitations.

            Prejudice may also arise from bringing a new defendant “into the case … on the eve of trial.”  (A.N., supra, 171 Cal.App.4th at p. 1068.)  Plaintiff filed the Doe amendment naming Liu as a defendant only five months after plaintiff filed the complaint.  The trial is set for December 4, 2024.  Liu shows no prejudice of this kind.       

Liu makes only a conclusory argument that deposing him before adding him as a defendant “has a substantially prejudicial effect on Liu because Liu had no counsel to represent him during the Deposition.”  (Motion, p. 5.)  “ ‘[A] defendant must show specific prejudice.”  (A.N., supra, 171 Cal.App.4th at p. 1066.)  Liu makes no such specific showing of prejudice.  He relies on the premise that not having an attorney is inherently prejudicial.  Liu cites no authority supporting that premise.  And he does not identify any prejudicial event at the deposition that could have been avoided if he had an attorney then.

Disposition

Defendant Min Liu’s motion to quash service of summons is denied.  Liu shall file a responsive pleading within 20 days.