Judge: Armen Tamzarian, Case: 23STCV17130, Date: 2024-02-22 Tentative Ruling
Case Number: 23STCV17130 Hearing Date: February 22, 2024 Dept: 52
Plaintiff Chill Space LLC’s Request
for Court Judgment
Plaintiff Chill Space LLC requests court judgment by default against
defendants Refurbished Lifts Inc. and Adam Thomas Martinelli. The request for court judgment has three
defects.
First, plaintiff has not shown
sufficient grounds for judgment against defendant Adam Thomas Martinelli. In general, the law recognizes “separation
between an individual and a business entity.”
(Curci Investments, LLC v. Baldwin (2017) 14 Cal.App.5th 214, 221.) Where “the liability of the individual
defendants” relies “upon disregard of the corporate entity by application of
the alter ego doctrine,” a complaint’s “bare conclusory allegation[s]” are
insufficient for a default judgment against the individuals. (Vasey v. California Dance Co. (1977)
70 Cal.App.3d 742, 748-749.) “In order
to prevail in a cause of action against individual defendants based upon
disregard of the corporate form, the plaintiff must plead and prove such a
unity of interest and ownership that the separate personalities of the
corporation and the individuals do not exist, and that an inequity will result
if the corporate entity is treated as the sole actor.” (Id. at p. 749.)
The complaint’s allegations include
defendant Adam Thomas (later changed to Adam Thomas Martinelli via an amendment
to the complaint) as a party to the subject contract. (¶¶ BC-1-3.)
Plaintiff’s application for default judgment, however, demonstrates that
is not true. Plaintiff brings a sole
cause of action for breach of contract. The
parties’ contract states, “This Agreement is entered into by and between
Refurbished Lifts, Inc. (‘RL’) and the entity … specified in the ‘FOR’ section
above (‘Buyer’).” (Grover Decl., Ex. 1,
p. 4.) It does not state Adam Thomas
Martinelli is a party to the agreement.
Dale Grover, the founder and manager
of plaintiff Chill Space LLC (Grover Decl., ¶ 1), explains the basis for naming
Adam Thomas Martinelli as a defendant: “At all relevant times discussed herein,
Adam Thomas Martinelli held himself out as the Chief Executive Officer of
Refurbished Lifts, Inc. and was the sole representative at Refurbished Lifts,
Inc. whom I, on behalf of the Company, negotiated and communicated with in
contracting for the forklifts and executing the Contract.” (Id., ¶ 6.) That does not suffice to make Adam Thomas
Martinelli liable for Refurbished Lifts Inc.’s obligations any more than it
would make Dale Grover liable for plaintiff Chill Space LLC’s obligations. To obtain judgment against Adam Thomas
Martinelli, plaintiff must either amend the complaint to allege sufficient
facts for alter ego liability or provide sufficient evidence showing Martinelli
is liable as an individual. (See Vasey
v. California Dance Co., supra, 70 Cal.App.3d at pp. 748-749.)
Second,
an application for default judgment must include “[a] proposed form of judgment.” (Cal. Rules of Court, rule 3.1800(a)(6).) Plaintiff did not submit a proposed form of
judgment. The court will require plaintiff
to submit a proposed judgment on Judicial Council form JUD-100.
Third,
an application for default judgment must include “[a] dismissal of all parties
against whom judgment is not sought or an application for separate judgment
against specified parties under Code of Civil Procedure section 579, supported
by a showing of grounds for each judgment.”
(Rule 3.1800(a)(7).) Plaintiff’s
complaint names Does 1-20 as defendants.
Plaintiff has not dismissed them or shown grounds for a separate
judgment against the other defendants.
Disposition
Plaintiff
Chill Space LLC’s request for court judgment by default is denied without
prejudice.
The
court hereby sets an order to show cause re: default judgment for April 11,
2024, at 8:30 a.m.